ML20045D522
| ML20045D522 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/23/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20045D518 | List: |
| References | |
| 50-298-93-99, NUDOCS 9306290096 | |
| Download: ML20045D522 (27) | |
See also: IR 05000298/1993099
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INITIAL SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT
50-298/93-99
NEBRASKA PUBLIC POWER DISTRICT
COOPER NUCLEAR STATION
January 19,1992, through April 24,1993
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TABLE OF CONTENTS
'I.
INTRODUCTION . . . . .
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1
4
II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . .
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III.
CRITERIA . . . . . . . . . . ... . . . . . . . . . . . . . .
4
IV.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . .
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A.
Pl ant Operations . . . . . . . . . . . . . . . . . . . .
4'
B.
Radiological Controls
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C,
Maintenance / Surveillance . . . . . . . . . . . . . . .
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D.
Emergency Preparedness:. . . . . . . . . . . . . . . .
13
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' . . . . . . . '25'
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1.
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
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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 May 20
and June 15, 1993, to review the observations and data on performance 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-
Cooper Nuclear Station for the period January 19, 1992, through April 24,
1993.
The SALP Board for Cooper Nuclear Station was composed of:
Chairman
A. B. Beach, Director, Division of Reactor Projects (DRP), Region IV
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Members
J. W. Roe, Director, Division of Reactor Projects III/IV/V, Office of'
Nuclear Reactor Regulation (NRR)
S. J. Collins, Director, Division of Reactor Safety (DRS), Region IV
L. J. Callan, Director, Division of Radiation Safety and
Safeguards (DRSS), Region IV
J. E. Gagliardo, Chief, Project Section C, DRP, Region IV
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H. Rood, Project Manager, Cooper Nuclear Station, NRR
R. A. Kopriva, Senior Resident inspector, Cooper. Nuclear Station, DRP,
Region IV
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The following personnel also participated in or observed the SALP Board
meeting:
J. L. Pellet, Chief, Operations Section, DRS, Region IV
T. F. Westerman, Chief, Engineering Section, DRS, Region IV
P. H. Harrell, Chief, Technical Support Staff, DRP, Region IV
I. Barnes, Chief, Technical Assistant, DRS, Region IV
B. Murray, Chief, Facilities' Inspection Programs Section, DRSS, Region IV
D. B. Spitzberg, Emergency Preparedness Analyst. DRSS, Region IV
C. J. Paulk, Reactor Inspector, DRS, Region IV
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E. E. Collins, Project Engineer, Project Section C, DRP, Region IV
W. C. Walker, Resident Inspector, Cooper Nuclear Station, DRP, Region IV
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11.
SUMMARY OF RESULTS
Overview
Performance in the area of plant operations was mixed.
The plant operations
staff performed its duties in a conservative manner during routine operations.
Command, control, and communications within operating crews and within the
operations department has improved but remains inconsistent. Management
attention and oversight of routine plant operations was evident.
There has
been a lack of a questioning attitude by the plant operations personnel of
operability determinations. The relationship between operations and training
improved; however, the operations department appeared to not totally support
and reinforce the training department's formal training program.
The
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emergency and abnormal operating procedures still exhibited some weaknesses.
In radiological controls, management provided strong support.
External
radiation exposure controls were implemented effectively.
Excellent programs
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were maintained in the radiation protestion area. One enforcement action
involved numerous operators and an operations supervisor that showed a lack of
respect for the special work permit process. The licensee. effectively
implemented planning and preparation for the 1993 refueling outage.
Excellent
coordination existed between the radiation protection department and other
departments and a strong as-low-as-reasonably-achievable (ALARA) program was
maintained. Management has not been aggressive in identifying radiological
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performance weaknesses.
In maintenance and surveillance the licensee's preplanning and work practices
were coordinated and well controlled, and their work item tracking system was
excellent. The performance of maintenance activities was mixed, although
communications and supervisory oversight were good. Maintenance of motor-
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operated valves was generally good, but there were weaknesses noted with the
installation of terminal lugs.
Weaknesses were found in the licensee's
maintenance of the reactor building and safety-related check valves.
Several
licensee event reports were submitted during the~ appraisal period because of
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improper maintenance.
Program procedures for control and scheduling of
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surveillance activities were controlled and explicit.
Weaknesses were found
in the adequacy of technical justifications to verify the operability of
equipment when Technical Specification testing acceptance criteria had not-
been met. Weaknesses were also seen in the licensee's testing of the pressure
isolation valves, secondary containment isolation valves, and manual valves
needed for safe shutdown of the plant.
In emergency preparedness, improvements were observed in certain important
performance areas.
Recurring problems were noted, however, in the' areas of
offsite notifications and emergency assessment and decision making. These
problem areas, combined with certain failures to promptly followup on findings
affecting emergency preparedness, and the violations which were identified,
indicate a need for increased management attention in this program area.
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Performance in the security area continues to be excellent. The program was
effectively managed by personnel within the security department.
Upper
management provided strong support for the security program.
Excellent
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programs were noted in the areas of testing, maintenance, staffing, audits,
and the response to audit findings.
In engineering and technical support, performance was good. The interface
between corporate engineering and site engineering was effective.
The overall
process to control projects and design modification activities appeared to be
very effective.
The temporary modification process was found to be well
implemented. Configuration management was found to be effective.
The
licensee's plant procedures were generally well controlled and technically
adequate to perform the desired actions.
Improvements were seen in training;
however, licensed operator training continued to need management attention and
priority.
Significant weaknesses were observed in problem resolution, and
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several examples of a 1ack of rigorous problem resolution were seen.
Examples
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of over-reliance on verbal information and informality were seen which
directly contributed to escalated enforcement actions.
In safety assessment and quality verification the licensee implemented an
effective operability determination and evaluation process and deficiency
report process. 'While some problems were_ effectively resolved, others were
not, continuing to show significant weaknesses in the licensee's approach'to
the resolution of issues. The causes for ineffective problem resolution
included informality, apparent unquestioning deferment of corrective actions
for generic problems, the absence of corrective action for those instances
where explicit regulatory requirements did not exist, and poor personnel
performance in bringing deficiencies to management's attention. The licensee
has planned or implemented extensive initiatives to impreve performance in
problem resolution, however, the effectiveness of the licensee's initiatives
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to address personnel performance and personnel attitudes remains to be reen.
The licensee's oversight and self-assessment activities were not always
acceptable and will require additional management attention to assure that
these activities provide management with the critical insights into the
performance of the plant and the operating staff.
Rating Last Period
Rating This Period
Functional Area
(07/16/90 to 01/18/92)
(01/19/92 to 04/24/93)
Plant Operations
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Radiological Controls
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Maintenance / Surveillance
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Security
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Engineering / Technical
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Support
Safety Assessment /
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Quality Verification
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- 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.
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Declining Trend - Licensee performance was determined to be declining
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during this assessment period and the licensee had not taken meaningful steps
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to address this pattern.
Continuation of the trend may result in a change in
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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
not repeated here but will be presented in detail at.the public meeting to be-
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held with licensee management.
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
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
by the resident inspectors. The Region-based inspections included two
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operator examinations, two Emergency Plan inspections, one plant procedures
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inspection, and one unannounced followup inspection to. observe licensed
operators' conduct during in-house requalification examinations.
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The previous SALP report (NRC Inspection Report 50-298/92-99) noted that
management's attention and oversight was not always conservative; procedures
were not always used properly; and that significant weaknesses-were identified
in the command, control, and communications activities when the operating
staff was presented with. simulated nonroutine emergency events.
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Command, control, and communications within operating crews and_within the
operations department has improved but remains inconsistent. A training guide
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and an operations directive have been issued in this area. However, formal
training to implement the guide .and ~ directive had not been provided,and none
of the on-shift supervisors questioned shortly after its issuance were-aware
of the operations directive. Management expectations and reinforcement of-
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training in these areas is an ongoing challenge.
For example, operations
management was not expeditiously informed by a shift crew (by written or oral
communications) that a problem with the control room annunciator computer
resulted in 60 annunciators being in an alarmed condition. Control room
logbook entries for the event were also unclear.
The last SALP report cited weaknesses in event diagnosis and implementing
emergency and abnormal procedures effectively. During this SALP period, these
problems appear to have been effectively addressed as. indicated by improved
diagnosis and procedure use during operator license and requalification
examinations and emergency preparedness exercises and inspections. .The last
SALP also described concerns related to emergency and abnormal procedure
validity. During this SALP period, the licensee was cited for the failure to
incorporate changes reflecting plant modifications into the emergency support
procedures in a timely fashion. This could have resulted in the procedures
being unusable during certain accident sequences involving the release or .
potential release of radioactive material. This indicates that procedure
implementation continues to be of concern, although.for reasons different than
described in the previous SALP.
The enforcement history in this functional area involved the failure to
incorporate changes into the emergency support procedures and the failure to
follow procedures, which resulted in a loss of shutdown cooling. The
procedure violations were not repetitive of those addressed in the previous
SALP report but are indicative of the fact that procedure implementation
continues to be of concern.
While the licensee has implemented significant effort to formalize and
document the evaluation of the immediate impact of deficiencies on the
operability of systems, there has been a lack of a questioning attitude by
plant operations of operability determinations prepared by engineering.
Examples included the operability determinations that were prepared to address
a temporary strainer in the suction of the reactor core isolation cooling
system, leaking shutdown coo' ling suction valves pressurizing the low pressure
residual heat removal system, and particulate contamination in emergency
diesel generator fuel oil above the limits specified by the station
procedures.
In each case, the conclusion of operability was accepted without
challenge. The operability determination for the temporary strainer contained
assessments that the strainer could be back-flushed, but the physical
configuration precluded back-flushing and no procedures existed telling
operators how to perform the evolution.
For the leaking valves, a vent path
was established to bleed the pressure, but no limits were specified
identifying how much leakage would be considered unacceptable, and no
evaluation of the containment isolation function was made.
For the high
particulate, the condition was accepted without an evaluation of the impact of
the deficiency on the fuel delivery system and the operability of the
emergency diesel generator. The acceptance of these operability
determinations with apparent weaknesses shows an absence of a questioning
attitude and a lack of ownership by plant operations.
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Management attention and oversight of routine plant operations was evident.
Senior site management routinely toured the control room on a daily basis and,
during major evolutions and/or plant changes, management personnel were
present in the control room, providing on overview of the activities.
Management's actions in response to operational events were usually
appropriate. On two occurrences the licensee elected to shut down the plant
to implement corrective actions (replace batteries in April 1992 and repair
the motive power to the low pressure coolant injection valves in September
1992). The licensee also made a decision to reduce reactor power after the
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design basis reconstitution group identified a problem with the control power
for some emergency core cooling system valves.
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The plant operations staff performed its duties in a conservative manner
during daily, routine, steady-state power operations; reactor startups; and
plant shutdowns.
Few plant operational problems or perturbations were
experienced during the reporting period, and the actions taken by the
operators in response to a feedwater transient and reactor recirculation pump
trip were accurate and timely. There were no automatic plant trips during
this assessment period.
Observed communications between operating staff and other departments during-
the performance of maintenanta and surveillance activities have improved from
those observed in the previous SALP period. Managements' efforts had been
successful in reducing the number of illuminated annunciators on the main
control room boards during steady-state operations.
The relationship between operations and training improved. However, the
operations department appeared to not totally support and reinforce the
training department's formal program.
Instances were noted where more
emphasis was given to on-crew input into training content than to that
prescribed by the formal training program.
This may account for the
differences identified in crew performance.
Some cross-crew normalization
progress has been made by rotating operators into the training department;
however, the full benefit of the program has not been realized.
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The licensee's operations staff was a very experienced and knowledgeable group
of licensed senior reactor and reactor operators.
During this assessment
period, the licensed operator staffing remained adequate to maintain a six-
shift rotation of operating crews.
Housekeeping in the plant was good. Most of the areas have been painted and
have been provided adequate lighting.
Labeling has been completed for most
components throughout the plant and found to be of a quality to support
component manipulations by plant personnel.
There remain some less-trafficked
areas in the plant, which are not up to the housekeeping equivalence exhibited
by the majority of the plant areas.
In summary, overall performance in the area of plant operations was mixed.
The plant operations staff performed its duties in a conservative manner
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during routine operations.
Command, control, and communications within
operating crews and within the operations department has improved but remains
inconsistent. Management attention and oversight of routine plant operations
was evident.
Although different, the emergency and abnormal operating
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procedures still exhibited some concerns identified in the previous SALP
report.
There has been a lack of a questioning attitude by plant operations
of operability determinations.
The relationship between operations and
training improved, however, the operations department appeared to not totally
support and reinforce the training department's formal training program.
2.
Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
area.
3.
Recommendations
a.
NRC Actions
Review the licensee's actions and training with respect to operator
communications during nonroutine operating activities.
Review the licensee's
actions to enhance their operability determination process.
b.
Licensee Actions
Licensee management needs to take appropriate measures to assure that the
long- term issue of operator communications during nonroutine operating
activities has been included in the training process for all operators. The
licensee should implement an effective process for the evaluation of deficient
conditions that impact the safe operation of the facility.
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B.
Radiological Controls
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1.
Analysis
This functional area consists primarily of activities related to radiation
protection, radioactive waste management, radiological effluent control and
monitoring, water chemistry controls, radiological environmental monitoring,
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and transportation of radioactive materials.
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This area was inspected seven times by Region-based radiation specialist
inspectors and on a continuing basis by the resident inspectors.
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During the previous assessment period, concerns were identified involving the
implementation of the radiological protection program during outages and
routine, day-to-day activities.
During this assessment period, the licensee
improved implementation of the radiological protection program during routine,
day-to-day activities, but still experienced some problems during outages when
activity levels were high.
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Enforcement was taken when several plant operators. did not follow the
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requirements of a special work permit requirement. This example was of
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particular concern because numerous operators and an operations supervisor
were involved. This event reflected a lack of respect for the special work
permit process as an essential part of the radiation protection program.
Senior management's support for the radiation protection program, and the
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radiological protection management's oversight of day-to-day activities, was
excellent.
Strong programs had been developed and were maintained in the
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areas of control of radioactive materials and contamination, surveys,
monitoring, and radiation instrument calibration.
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Management has not been aggressive in identifying radiological performance
weaknesses. During this assessment period, the licensee generated only
five radiological safety incident reports.
Given the number of plant areas
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that are contaminated and the magnitude of work performed, the absence of
incident reports reflects a site attitude of not documenting, and consequently
not aggressively pursuing, radiological problems.
Communications among the radiation protection department and other departments
were instrumental in the progress made to reduce the number of contaminated
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areas within the radiological controlled area.
The licensee planned to
implement a program for controlling radiation exposures, which included a new
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radiological support system that used a state-of-the-art computer-based
electronic dosimetry system and access control system.
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The licensee effectively implemented planning and preparation for the 1993'
refueling outage. The strengths of this program included an inventory of
radiation protection supplies and equipment, coordination between the
radiation protection department and other departments, and an appropriate
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number of contract radiation protection personnel to provide the required
radiation protection coverage of outage activities. The contract technicians
were brought on site several weeks prior to the outage to receive training.
External radiation exposure controls were implemented effectively by
monitoring whole body exposures using thermoluminescent dosimeters, self-
reading dosimeters, radiation surveys, radiation work permits, and
administrative dose limits.
Radiation areas and high radiation areas were
properly posted and controlled.
Special work per::.its were improved to provide
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enhanced guidance to workers and make them easier to understand.
Isolated
examples were noted of workers not following all of the instructions of
special work permits.
The licensee had implemented a good internal exposure
control program.
The licensee had -implemented an excellent ALARA program. The radiological
protection department was proactive in the area of ALARA briefings, which were
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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 well organized, addressed all
important issues, and emphasized good radiological protection practices.
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Prior to the 1993 refueling outage, the plant utilized a " soft" shutdown,
which provided good control of crud bursts and improved reactor water cleanup,
reducing external exposure. The ALARA suggestion program received an increase
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in ALARA suggestions and was given excellar' support from management and
workers from other departments.
ALARA :
iel performed daily reviews of
the doses accrued by jobs during the 199S
aling outage and made frequent-
tours of the drywell to observe work activ.t
Person-rem exposures and
personnel contamination events were maintaint. 31ov outage goals.
The licensee's liquid and gaseous radioactive waste effluent program, water
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chemistry and radiochemistry programs, and radiological environmental
monitoring program were effective and well managed. -The sampling results from
all these programs compared well with NRC independent measurements.
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The solid radwaste and radioactive materials transportation programs included
excellent procedures for the preparation and shipment of radioactive waste and
other radioactive materials. The licensee's performance of characterizing,
classifying, and preparing radioactive waste for shipment and burial during
this assessment period was excellent. Radioactive materials and waste
shipments were made without incident or problems.
Staffing was maintained at appropriate levels in the radiological controls
areas. The various departments in the radiological controls areas had
experienced a very low turnover of technical personnel.
The radiation
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protection staff was supplemented with contract radiation protection
technicians.during outages, but reliance was not placed on contractor
personnel during normal operating periods.
Accredited training and qualification programs were established and being.
implemented for personnel in this functional area. The radiological controls
area personnel were well trained and qualified. Training instructors were
well qualified. Coordination existed between the training department and the
various departments that received training in this functional area. The
licensee's overall training efforts were excellent.
The quality assurance audits and surveillances performed in the radiological
controls area identified pertinent findings, and the corrective actions for
the findings were timely and comprehensive.
The audit teams included
qualified auditors and technical specialists who were knowledgeable of the
applicable requirements to be reviewed in specific program areas. A self-
assessment of the radiation protection program, including source term
reduction, work control, communications, radiation protection during outages,
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ALARA, and training, was performed, and the assessment identified several
recommendations for program improvement.
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In summary, management provided strong support for the radiological controls
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area.
External radiation exposure controls were implemented effectively.
Excellent programs were maintained in the radiation protection area. One
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enforcement action involved several operators and an operations supervisor
that showed a lack of respect for the special work permit process.
The
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licensee effectively implemented planning and preparation for the 1993
refueling outage.
Excellent ~ coordination existed between.the radiation.
protection department and other departments, and a strong ALARA program was
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maintained. Management has not been aggressive in identifying radiological
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performance weaknesses.
2.
Performance Ratina
The licensee is considered to be in Performance Category 2 in this functional
area with an improving trend.
3.
Recommendations
a.
NRC Actions
None
b.
Licensee Actions
The licensee needs to implement measures to assure that the facility staff is
more aggressive in the pursuit of issues which are to be documented in-the
radiological safety _ incident report process established by site procedures.
C.
Maintenance / Surveillance.
1.
Anal _vsi s
This functional area consists of activities associated with the' predictive,
preventive, and corrective maintenance of planc structures, systems, and
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components. This area also. includes the conduct' of surveillance testing,
inservice testing, and inspection activities.
NRC inspection efforts consisted of routine inspections by the resident
inspectors and five inspections performed by region-based inspectors.
In the
last SALP report, no recommendations were made for the overall program
improvement.
During this assessment period, maintenance work practices-were performed in a
coordinated controlled manner. One exception to procedure compliance was
observed during emergency diesel generator maintenance where workers did not
obtain a system engineer inspection as required by the work package. The.
licensee continued to have an excellent work item tracking system, which is
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effective in assuring that work in progress is properly documented and work
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needing to be performed is prioritized appropriately.
The licensee's performance in-implementation of maintenance activities was
mixed.
Preplanning of maintenance activities and attention to detail by
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maintenance personnel were good with good communication between maintenance
personnel in the field and other organizations. Supervisory personnel
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presence was noted during complex activities and periodically during the
performance of more routine efforts.
Maintenance of motor-operated valves was generally' good.
Some weaknesses were
seen, however, in the maintenance of motor-operated valves. Discrepancies'
involving improper terminal lug installations and evidence of corrosion and
dirt in the limit switch compartment for environmentally qualified
motor-operated valves were not identified or corrected by maintenance
personnel.
In mid-1992, the licensee initiated the development of a formal check valve
program based on NRC and industry recoinmendations. A significant weakness
existed, however, in the licensee's check valve maintenance and testing
activities. While many check valves were tested in the inservice testing
program and others were inspected by the preventive maintenance program,
reactor coolant pressure isolation check valves were neither disassembled for
inspection nor leak rate tested. The licensee's maintenance and testing
activities did not ensure that these valves were capable of performing the
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safety-related pressure isolation function.
At the end of the assessment
period, the licensee was implementing plans to perform leak rate -testing of
these check valves.
During the refueling outage, testing of the secondary containment showed that
the licensee had not effectively tested or maintained secondary containment.
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The secondary containment integrity test did not effectively address adjacent
building status, and this masked identification of a significant deficiency.
Also, features such as secondary containment isolation valve timing were not
effectively tested. The licensee had not effectively maintained door seals,
which were worn from use during the operating cycle, degrading the secondary
containment. At the end of the assessment period the licensee was
implementing corrective actions to address these deficiencies.
During this assessment period, safety-related systems were declared inopercble
and licensee event reports were issued as a result of ineffective, or ' lack of,
maintenance on plant equipment.
The instances involved:
(1) the clogging of
a steam trap, due to a lack of preventive maintenance, that raised questions
about the operability of the reactor core isolation cooling system,
(2) inoperability of a damper in the control room heating and ventilation
system because the linkage was not routinely lubricated, (3) failure of a
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motor-operated valve to operate due to a stripped stem nut on the valve which
was not detected because of the lack of appropriate acceptance criteria in the
maintenance work procedure, and (4) failure of a battery charger to operate
properly due to a lack of preventive maintenance.
The systems engineering organization was involved in maintenance and
sur -:11ance activities. The oversight provided by the engineers helped to
that the maintenance and surveillance activities were acceptably
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implemented. However, the issues discussed in the four preceding paragraphs
indicate shortcomings in program technical definition and technical resolution
of identified problems.
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Early in the assessment period, a significant weakness was found in the
licensee's surveillance test program involving the station batteries. The
program allowed that safety-related equipment could be considered operable
without an adequate technical justification when _ Technical Specification test
acceptance criteria were not met.
Following identification-of-this issue, the
licensee effectively implemented corrective actions to ensure that Technical
Specification test acceptance criteria reflected actual operability criteria
,
and that test discrepancies were formally evaluated and approved.
Program procedures for control and scheduling of surveillance activities were
controlled and explicit. There were very few missed or overdue surveillance
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tests.
The surveillance schedule consistently reflected planning and assigned
priorities.
Procedures for conducting surveillances were well written and
easy to follow.
Personnel conducting surveillances were qualified. Senior technicians and
senior operations personnel provided oversight and guidance to trainees while
conducting on-the-job training. During surveillance performance, the
licensee's staff continued to demonstrate nood communication and ccordination.
The performance of nondestructive examinations in the inservice inspection
program was observed to be good. The nondestructive examinations were
performed by contract personnel that were well qualified for the specific
processes. The repair and replacement program was effectively implemented by
well-documented work packages, and the performance of work activities was
observed to be good.
The scope of the inservice inspection program did not include all
safety-related heat removal systems, such as the service water and reactor
equipment cooling system. These systems consequently have not received all
the inspection activities specified by the Technical Specifications, including
pressure testing. The licensee's third party review of the inservice
inspection program did not identify these systems as needing to be included in
the inservice inspection program.
The licensee's testing did not include periodic verification of many manual
valves that were specified to be operated, using emergency operating
procedures, or would need to be operated in other emergency conditions. One
example was the emergency diesel generator fuel oil storage tank cross-connect
valve.
A weakness was seen in the licensee's primary containment leak rate testing
'
program. The licensee had tested 26 containment isolation valves with test
pressure applied in a direction: opposite to containment pressure without an
adequate basis that the test results would be equivalent or conservative.
Licensee testing with the test pressure applied in the direction of accident
pressure demonstrated, for some valves, that the testing was nonconservative.
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At the end of the assessment period, the licensee was implementing corrective
actions to either test the valves in the direction of accident pressure or
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provide an adequate justification that testing in the reverse direction was
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equivalent.
The licensee also did not verify that instrumentation cabinets
that would be exposed to primary containment pressure after the accident were
tested. The hydrogen / oxygen analyzers were not tested at accident pressure.
In summary, the licensee's preplanning and work practices were coordinated and
well controlled, and their work item tracking system was excellent.
The
performance of maintenance activities was mixed, although communications and
supervisory oversight were good. Maintenance of motor-operated valves was
i
ger.? rally good, but weaknesses were noted with the installation of terminal
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lugs. Weaknesses were found in the licensee's maintenance of the reactor
building and safety-related check valves.
Several licensee event reports were
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submitted during the appraisal period because of improper maintenance.
Program procedures for control and scheduling of surveillance activities were
controlled and explicit.
Weaknesses were found in the adequacy of technical
justifications to verify the operability of equipment when testing acceptance
criteria had not been met. Weaknesses were also seen in the licensee's
1
testing of the pressure isolation valves, secondary containment isolation
valves, and manual valves needed for safe shutdown of the plant.
.
2.
Performance Ratina
The licensee is considered to be in Performance Category 3 in this functional
area.
,
3.
Recommendations
a.
NRC Actions
!
lhe NRC should conduct inspection activities with the focus of assessing the
technical adequacy of activities and the appropriate scope of activities and
to review maintenance and surveillance program identification and resolution
of conditions adverse to quality.
b.
Licensee Actions
,
The licensee should review the scope and depth of maintenanca/ surveillance
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activities to make sure that the maintenance and surveillance programs for
safety-related equipment are adequate to assure that the equipment can and
,
will continue to perform its safety functions. The licensee should also
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increase the emphasis on oversight by plant management and systems engineering
to provide an increased level of technical support to the maintenance and
surveillance activities at the plant.
Management should provide additional
emphasis on generation of thorough and detailed maintenance and surveillance
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procedures, and on the need for maintenance / surveillance personnel to
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carefully follow the procedures.
D.
f
1.
Analysis
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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
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events that test the emergency plans, and interactions with onsite and offsite
emergency response organizations during planned exercises and actual events.
The previous SALP report noted a Performance Category 2 in the emergency
preparedness area.
The report recommended licensee action to implement
proactive corrective actions for identified weaknesses and to enhance its
self-assessment capabilities.
Evaluation of this functional area was based on the results of two inspections
conducted by the regional emergency preparedness analyst and observations by
the resident inspectors.
The two inspections included evaluation of the 1992
emergency exercise and an operational status inspection which included a-
regional inspection initiative to evaluate the knowledge and performance of
duties of emergency response personnel.
During the assessment period, there were six emergency declarations associated
'
with actual events, 'all at the Unusual Event classification level.
Five of
the declarations were made following initiation of a shutdown required by
Technical Specifications. The sixth declaration was made following a minor
earthquake detected onsite.
During two of these events, the licensee experienced some difficulties in
implementing portions of the emergency plan and implementing procedures.
Specifically, following one event there was a delay in event classification,
which indicated a weakness in the decisionmaking process.
In addition, a
violation was cited for the licensee's failure to complete notifications to
offsite authorities in a timely manner following the declaration of this
event.
Following a subsequent Unusual Event declaration, notification of one
offsite organization was untimely. The licensee identified the problems noted
above and initiated corrective action.
In one instance, however, the
licensee's process of investigating, formulating, and documenting the needed
corrective action was slow.
The 1992 exercise resulted in five NRC identified weaknesses.
The weaknesses
involved:
(1) weak analysis and technical assessment of plant conditions,
(2) failure to take steps to ensure habitability of the Technical Support
.
Center / Operational Support Center,-(3) failure to detect and classify General
Emergency conditions promptly, (4) failure to make the offsite notification'of
the General Emergency in a timely manner, and (5) use of multiple dose
assessment programs for decisionmaking purposes without clear guidance on
i
reconciling conflicting results.
The weakness concerning analysis and
technical assessment of plant conditions was found to be a repeat of a similar
weakness identified during the previous exercise.
During the exercise, the
NRC noted licensee improvements in several areas from the performance in
previous exercises. Most notable were improvements in the performance of
control room operators, tracking of response teams, and the licensee's self-
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critique process. The 1992 exercise was not evaluated by FEMA, however, the
' licensee demonstrated an excellent working relationship during the exercise
with the state response organizations that participated.
As a result of the 1992 exercise weaknesses and the previously mentioned
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findings related to actual event declarations, a management meeting was held
with the licensee to discuss NRC concerns in emergency preparedness.
The operational status inspecc an found that emergency response facilities _had
been well maintained. A good grogram of emergency response training had been-
administered and a good number of trained personnel had been assigned to_ the
emergency response organization. Quality assurance _ audits of emergency
preparedness were of good scope and depth.
During emergency preparedness.
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walkthroughs, operating crews performed well and demonstrated an improved
knowledge and performance of duties in all areas found to be weak in recent
inspections,
lwo violations were identified during the operational status inspection. One
viobtion was for failure to conduct required tests of the pagers used to
notify members of the emergency response organization.
The second violation
was identified for failure to conduct a drill critique and for failure to
follow up as required on drill weaknesses. A noncited violation was
identified and corrected by the licensee for failure to submit to NRC one
emergency plan implementing procedure revision within the required time frame.
In response to NRC recommendations from the previous SALP report, the licensee
formed an emergency preparedness task force to review and recommend actions in
areas such as emergency preparedness program effectiveness, the emergency
plan, command and control of the emergency response organization, emergency
preparedness training, exercises and drills, and other programmatic areas.
,
The task force report was issued midway through the SALP period. Substantive
recommendations and initiatives were made by th' task force. Additional
corrective actions and improvement initiatives were presented during the
3
October 1992 emergency preparedness management meeting with the licensee.
Many of the corrective actions and improvement initiatives arising from these
efforts were scheduled for completion beyond this SALP period. Therefore, the
overall effectiveness of these actions had nrt been evaluated by'the NRC.
Despite these self-assessments an
by' security officers on compensatory posts. The support and cooperation
among security, plant maintenance, and the instrumentation and controls group
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was excellent and'there was strong evidence of management's commitment to
maintain a high quality and effective security program.
4
An excellent security reporting program had been implemented.
The security.
event reports and reporting procedures were well understood by security
supervisors and consistent with NRC requirements. The security staff
conducted excellent analyses of security events, identifying trends and
developing sound resolutions to problems.
The security organization was staffed with an appropriate number of personnel
to ensure that the security program was properly implemented.
The security training program was administered by a well qualified full-time
staff. The program was consistent with the requirements of the NRC-approved
Security Force Training and Qualification Plan.
Personnel training records
were current and well maintained.
Personnel were knowledgeable of their
responsibilities and performed their duties competently. However, the
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training section did not have any training aids available for hands-on type
training in the early part of the SALP period.
For example, there were no
'
simulated weapons or explosive devices to use during training on x-ray
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equipment or during bomb search tactics. The video film library, at the time,
was limited to three or four recently acquired films. The licensed developed
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some additional training aids toward the end of the SALP period. However, the
lack of training aids detracted from an excellent training program.
The submitted revisions to the Security Plan, the Security Contingency Plan,
and the Security Training and Qualification Plan under the provisions of
1
10 CFR Section 50.54(p) were technically sound and reflected well-developed
policies and procedures.
Security personnel involved in maintaining program
plans current were knowledgeable of NRC requirements and objectives.
A comprehensive annual audit of the security program was conducted by the
licensee's quality assurance group.
The audit team included an, auditor with
nuclear security experience from another power reactor utility. The audit was
performance-based and very well documented.
The security department
implemented prompt and effective actions in response to the' audit findings.
In summary, the licensee continues to maintain an excellent security program.
The program was effectively managed by personnel within the security
department.
Upper management provided strong support for the security
program.
Excellent programs were noted in the areas of testing, maintenance,
staffing, audits, and the response to audit findings.
2.
Performance Rating
The licensee is rated as Category 1 in this functional area.
3.
Recommendations
None.
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F.
Enaineerina/ Technical Support
1.
Analysis
T
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
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operations; outages, maintenance, testing, surveillance, and procurement
activities; and training and configuration management.
NRC inspection efforts consisted of routine inspections by the resident
inspectors, four region-based inspections, and one structural audit team
inspection. The inspection effort included team inspections to assess the
motor-operated valve Generic letter 89-10 program and engineering and
technical support functions. Additionally, two sets of licensed operator
examinations were administered at Cooper Nuclear Station.
,
The previous SALP report recommended that licensee management should implement
actions to correct the ongoing concerns identified with the licensed operator
training program. During this assessment, improvements were seen in training;
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however, licensed operator training continued to need management attention and
priority, as previously discussed in the Operations functional area.
During this assessment period, a review of design modification activities was
performed. The overall process to control projects and design modification
activities appeared to be very effective, with a small backlog of work.
Procedures to control design changes and modifications were found to be
(
comprehensive and well written as were the plant modification packages. A
great deal of conservative engineering effort was usually incorporated into
the modification process.
The temporary modification process was found to be well implemented, and
.
temporary modifications were not left in place over six months.
Particular
strengths were noted in the weekly audit performed by senior licensed
"
operators and the use and control of temporary modification tags.
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The interface between corporate engineering and site engineering appeared
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effective. There was a very stable engineering staff with a low turnover
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rate. Good morale was observed, and staffing levels appeared consistent with
the workload.
Engineering personnel were_ qualified and trained and their
responsibilities defined. Of particular note was the emphasis'on
certification of system engineers as shift technical advisors.
Engineering
,
appeared to have good credibility and working relationships within the
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licensee's organization.
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Configuration management was found to be effective. Although the licensee's
design basis reconstitution process was found to be somewhat delayed, issues
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have been identified by this program which were promptly addressed.
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'The scope of the licensee's program to test motor-operated valves was
consistent with Generic Letter 89-10 and was managed by knowledgeable
personnel. During NRC reviews, a number of weaknesses were identified
including calculations, use of design basis parameters, and testing.
i
Additionally, the licensee had addressed the recommendation of Generic Letter 89-10 to evaluate and trend motor-operated valve failures but had not
,
yet implemented the procedures.
Inspectors observed the conditions of the
valves to be very good.
Overall, the licensee's motor-operated valve testing
was good.
In the area of engineering, the licensee's plant procedures were generally
well controlled and technically adequate to perform the desired actions.
Examples of weaknesses in procedure support were noted, including a lack of
independent verification of a calculation, providing timely procedure change
information to plant operators and a lack of information in relay maintenance
procedures.
In one case, support procedures were known to be-in error and
timely corrective action had not been performed to correct the errors.
The licensee's program for the training of candidates for an operating license
was determined to be adequate. One weakness was observed in the origin of
learning objectives.
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Actions to strengthen this program continued with the reallocation of
resources to training, but at a. slow rate. . Enlarging the training staff
through direct hiring and implementation of the program to bring in licensed
operators from the operations department had a positive affect on the
operations department's acceptance to training.
Some improvement was noted in
the formal communication process between the operations and training
,
department management staffs.
Significant weaknesses were observed in problem resolution. One cause for
ineffective problem resolution was informality and this has manifested itself
as a tendency to rely on verbal information over documentation or plant
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records.
Plant engineers relied on verbal information from maintenance
personnel, without verification, that no temporary strainers existed in the
system, in deference to the information that was on ' approved drawings that
showed that strainers were installed. This verbal information was found later
to be in error.
Plant engineers also relied on verbal information regarding
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the existence of documentation that temporary strainers had been removed
during preoperational or startup testing, even though the documentation that
the engineer reviewed indicated the exact opposite.
This was presented to the-
NRC as justification that temporary strainers had been removed and was later
.
found to be incorrect; temporary strainers were, in fact, in the system.
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Informality was also seen in the licensee's resolution of a secondary
containment integrity test failure as discussed in maintenance and
surveillance. A lack of rigorous resolution of a high particulate
concentrations in the diesel fuel oil and leaking shutdown cooling suction
isolation valves was also seen. The secondary containment was declared
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operable without a good understanding of the causes for the test failure and
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without action to prevent recurrence. The licensee subsequently found that a
loop seal was missing causing a 10-inch flow path between the reactor building
and the radwaste building.
Overall, the performance _ in this functional area was mixed. The interface-
between corporate engineering and site engineering was effective. The overall
process to control projects and design modification activities appeared to be
very effective. The temporary modification process was found to be well
implemented.
Configuration management was found to, be effective.
The
licensee's plant procedures were generally well controlled and technically
-adequate to perform the desired actions.
Improvements were seen in training;
however, licensed operator training continued to need management attention'and
priority.
Significant weaknesses were observed in problem resolution and
several examples of a lack of rigorous problem resolution were seen.
Examples
of over-reliance on verbal information and informality were seen which
directly contributed to escalated enforcement actions.
2.
Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
area.
3.
Recommendations
a.
NRC Actions
None.
.b.
Licensee Actions
The licensee needs to resolve plant _ proble.as by correcting the root cause,
with the objective of closing the issue with finality, rather than by using a
.
quick-fix approach to mitigate the immediate symptoms. The licensee should
put more thoroughness, formality, and attention to careful documentation into
the process. The licensee should also give management oversight ~ and/or system
engineering function more emphasis, with more responsibility.and authority for_
reviewing all aspects of a problem.
G.
Safety Assessment /0uality Verification
1. ' Analysis
This functional area includes all licensee review activities associated with
.
the implementation of _ licensee safety policies, including licensee activities
related to amendment, exemption, and relief-requests and other regulatory
initiatives.
In addition, it includes licensee activities related to the
resolution of safety issues, safety committees, self-assessment activities,
and the effectiveness of the verification function in identifying and~
correcting substandard or anomalous performance, in identifying precursors of
potential problems, and in monitoring the overall performance of the plant.
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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 identified a high threshold for initiating nonconformance reports.and
that the licensee was not proactive in identifying potential' safety issues -in
this area.
During this assessment period, the licensee expanded the
'
corrective action program to capture those deficient conditions that did not
rise to the threshold of a nonconformance report.
The' programmatic features
appeared to be an improvement in that additional items.were captured for
resolution that would not have been documented under the previous program.
Problem resolution, however, continued to show significant weaknesses.
While
some problems were effectively resolved from a safety perspective, others were
not addressed or evaluated with sufficient rigor to assure that potential
safety issues were clearly brought to management's attention and subjected to
the comprehensive corrective action which would correct the root cause and
prevent recurrence of the problem.
,
Examples of effective problem resolution were the items identified from the
licensee's design basis. reconstitution efforts, such as a single failure
vulnerability in the emergency core cooling systems and the vulnerability of
safety-related switchgear to missiles.
In these examples, the licensee's
understanding of the safety implications of the vulnerabilities was good, and
the licensee implemented effective compensatory / corrective actions to resolve
the problems.
Problems which were not adequately resolved included copper contamination in
station batteries, temporary startup strainers in safety-related systems,
repetitive feedwater check valve leak rate test failures, primary coolant
system relief valve drift problems, informal documentation of deficiencies in
emergency condensate storage tank inspections, emergency diesel fuel oil high
particulate, leaking shutdown cooling suction valves, reactor building
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surveillance test failures, and, emergency operating support procedures with
previously identified deficiencies that were not' corrected.
The apparent causes for ineffective or protracted problem resolutions
included:
(1) apparently unquestioning deferment of corrective actions until
the " generic" or " industry" problems have been solved; (2) reluctance to take
corrective action in'those cases where explicit regulatory requirements did
not exist; and (3) reluctance by working-level personnel to bring problems to
the attention of plant management.
The licensee's protracted resolution of feedwater check valves that failed
local leak rate testing repetitively and the absence of action to prevent
recurrence or to mitigate the primary coolant system relief valve setpoint
drift are examples of a willingness to defer corrective action until generic
issues are resolved.
The licensee's operability conclusion for emergency .
diesel fuel oil high particulate and their ineffective initial corrective
actions for leaking shutdown cooling suction isolation valves are examples of
a reluctance to take corrective action without explicit regulatory
requirements, The emergency condensate storage tank coating blistering which
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was found during an inspection, but not documented in the work package, was an
example of the type of problem not brought to management's attention.
Plant management has shown the ability and desire to effectively resolve
issues once they are made aware of the deficiencies.
However, management
continues to be, for the most part, reactive in identifying deficient
conditions.
Historically, the licensee had established a performance
indicator which placed an upper limit on the number of open corrective action
documents.
This was viewed as a reward for a low number of corrective action
system documents and may have discouraged the documentation of deficient
conditions.
The initiation of nonconformance reports, historically, has been
'
linked to reportability and/or operability. This fostered the practice of
documenting only reportable conditions in the corrective action systems rather
than documenting deficient conditions and then giving them the appropriate
review for reportability. Deficiencies identified when equipment was not
operable, or not required to be operable, were not likely to be captured by
the licensee's corrective action systems. The licensee's initiatives in
implementing a deficiency report process, while very positive, have not yet
corrected the attitudes that remain from the historical approach to corrective
action systems.
At the end of the assessment period, the licensee had taken corrective actions
to improve performance in resolving problems, many of which had not yet been
implemented.
The licensee's programmatic initiatives appear sound; however,
the effectiveness of the licensee's corrective actions to address personnel
performance and personnel attitudes have not yet been evaluated.
,
Licensee efforts have also been expended to develop and implement formal
operability determination and evaluation processes. These efforts were
initiated in response to an operability determination which did not receive
approval from the Station Operations Review Committee as required. The
licensee had generally been effective in evaluating the immediate impact of
deficient conditions on the o)erability of safety-related equipment, but the
'
immediate conclusion of opera 3ility may have encouraged delay of prudent
corrective actions in some cases.
Also, some operability determinations
contained weaknesses as discussed in plant operations.
i
The licensee's performance of oversight and critical self-assessment
activities were marginally satisfactory.
The Station Operations Review
Committee and the Safety Review and Audit Board met frequently to evaluate
emerging safety issues and to review other issues required by their charters
and the Technical Specifications. The' oversight activities of these
committees had not been effective in identifying the numerous problems which
were found by the NRC inspectors in the special strainer inspection and in the
corrective action inspection.
Although the quality assurance department issued quarterly trend reports that
contained a comprehensive compilation of activities, the reports did not
'
highlight problems or provide any assessment or recommendations as a result of
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indicated trends.
The audit and surveillance activities of the quality
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assurance department had not been effective in providing effective oversight
of site activities to provide early identification of many of:the issues that
were identified in the special inspection on strainers and the corrective
action inspection.
Station performance indicators had received limited distribution and did not-
contain an assessment of the indicators or draw conclusions that would have
been of benefit to management in their oversight of site activities.
The licensee's system for identifying and evaluating-internal and external
operational experience and events had been effective as a management tool.
The Document and Event Review Committee actions to identify training work
requests for improving training effectiveness based on operational experiences
was a strength.
During the assessment period, the NRR staff reviewed a large number of license
amendment requests and the safety analyses performed by and for the licensee.
Generally, the licensee's submittals were acceptable.
The number of licensing-
actions and activities appears to be appropriate.for a plant of Cooper Nuclear
Station's vintage. Overall, the licensee's performance for this element of
i
this functional area is average and could be. improved by increased attention
to timeliness, accuracy, and coinpleteness. The licensee's performance has
been good, however, when it focussed its resources on an issue. An example of
this is the well-thought-out comments the licensee submitted regarding the
staff's draft position on the generic dedication issues that resulted from the
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pilot inspections.
In summary, the facility has generally been operated in a safe manner. While
some problems were effectively resolved, others were not, continuing to show
significant weaknesses in the licensee's approach to the resolution of issues.
The causes for ineffective problem resolution included informality, deferment
4
of corrective actions for generic problems, the absence of corrective action
for those instances where explicit regulatory. requirements did not exist, and
poor personnel performance in bringing deficienci.es to management's attention.
The licensee has planned or implemented extensive initiatives to . improve
performance in problem resolution, however, the effectiveness of.the
licensee's initiatives to address personnel performance and personnel
attitudes remains to be seen. The licensee's oversight and~self-assessment
activities were not always acceptable and will require additional management
attention to assure that these activities provide management with the critical
insights into the performance of the plant and the operating staff.
2.
Performance Rating
The licensee is considered to be in Performance Category 3 in this functional
area.
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3.
Recommendations
a.
NRC Actions
Review the licensee's actions to enhance their process for performing' critical
self-assessments of their performance and providing more depth to their
corrective action processes.
b.
Licensee Actions
Licensee management needs to perform a critical assessment of their corrective
action processes in light of the problems identified by the NRC and correct
the process to assure that the process is meeting licensee and NRC
expectations.
V. . SUPPORTING DATA AND SUMMARIES
A.
Major Licensee Activities
1.
Major Outages
On February 10, 1992, the plant was shut down to replace degraded 250-volt
battery cells.
The plant was returned to full power on February 15.
On April 19, 1992, the plant was shut down to replace additional cells in
250-volt batteries.
The plant was returned to full power on April 27.
,
On July 30, 1992, the licensee imposed a restriction of 90 percent power to
assure emergency core cooling capability because of a single failure.
vulnerability. On September 11, 1992, the plant was shut down to implement a
modification to eliminate the single failure vulnerability. The plant was
'
returned to full power on Seotember 15.
On October 1, 1992, the licensee experienced a recirculation pump trip and.
operated in single loop at 50 percent power.
The plant was returned to full
power on October 5.
On January 24, 1993, the licensee reached the all-rods-out condition and began
end-of-cycle coast down.
On March 5, 1993, the plant was shut down from about-
80 percent power to begin the refueling outage. At the end of the assessment
period, the plant was in the refueling outage with the core off-loaded.
2.
License. Amendments
Eleven licensing amendments were issued during this assessment period.
3.
Major Modifications
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During the current refueling outage, the licensee planned to:
(1) install a
hardened wet-well vent at Cooper Nuclear Station in response to Generic-
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Letter 89-16, (2) remove the rod sequence control system from the plant, and
(3) remove the main steam line radiation monitor scram and containment
isolation function from the plant.
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B.
Direct Inspection and Review Activities
'NRC inspection activity during the assessment period' included 40 inspections.
Approximately 5190 direct inspection hours were expended, which.did not
include operator-licensing examinations or contractor hours.
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