ML20045J086
| ML20045J086 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/16/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Link R WISCONSIN ELECTRIC POWER CO. |
| Shared Package | |
| ML20045J087 | List: |
| References | |
| NUDOCS 9307230032 | |
| Download: ML20045J086 (5) | |
Text
d
,JiA i C 1933 Docket No. 50-266 Docket No. 50-301 Wisconsin Electric Power Company ATIN: Mr. Robert Link Vice President Nuclear Power 231 West Michigan Street - P379 Milwaukee, WI 53201
Dear Mr. Link:
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) 10 Report for the Point Beach Nuclear Plant, our meeting of June 17, 1993, which discussed the contents of the report, and your written comments dated July 1, 1993, relative to the report.
Based on our discussions during the meeting and our review and evaluation of your letter of response, we have reached the conclusion presented in the enclosed meeting summary, including a change in the SALP rating in the Security functional area to acknowledge an Improving Trend.
With the incorporation of the revised pages from Enclosure 3, the Initial SALP Report should be considered to be the Final SALP Report.
1_ -
In your response letter, you requested additional information about the challenge concerning self-assessments that was addressed during the NRC's SALP presentation of the Security functional area.
The challenge was based on our review of NRC inspection reports which identified a number of programmatic issues which were not identified in your self-assessments of the Security functional area. A more indepth, detailed self-assessment program could lead to your early identification and correction of these types of issues and their underlying causes. This matter was discussed with members of your Security staff on June 17, 1993, prior to the SALP meeting.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter with the referenced enclosures, will be placed in the NRC's Public Document Room.
9307230032 930716
/-@ I PDR ADOCK 05000266
/
)
/
G PDR v
u-J
N 1619'93 Wisconsin Electric Power 2
Company t
i No reply to this letter is required; however, should you have questions regarding the Final SALP Report, please let us know and~we will be pleased to discuss them with you.
r Sincerely, SistNAL SIGNED BY HUBERT J. MILLER John B. Martin Regional Administrator
Enclosures:
i I.
Final SALP 10 Report No. 50-266/93001; 50-301/93001 (Meeting Summary) 2.
Revision sheet (s) 3.
Revised Pages to SALP Report 4.
Licensee Response Ltr, dtd July I, 1993 cc w/ enclosure:
G. J. Maxfield, Plant Manager OC/LFDCB Resident Inspector, RIII Virgil Kanable, Chief Boiler Section Cheryl L. Parrino, Chairman, Wisconsin Public Service Commission Robert M. Thompson, Administrator WI Div of Emergency Govt.
INP0 DISTRIBUTION CONTINUED SEE ATTACHED CONCURRENCES RIII RIII RIII RIII RIII RIII RIII Gavula Jackiw Brown Hasse Greger LaTorre Gunmn RIII RIII RIII-I TMartin-Norelius i ler ia in Qp@
JUL -10533 Wisconsin Electric Power 3
Company DISTRIBUTION CONTINUED The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque J. H. Sniezek, DEDR T. E. Murley, Director, NRR Chief, RPEB, NRR (2 copies)
J. N. Hannon, NRR Director, Project Directorate III-3 J. Lieberman, Director, Office of Enforcement C. D. Pederson, RIII K. R. Jury, SRI L. L. Cox, RIII (2 copies)
TSS, RIII RIII Files RIII PRR bec:
PUBLIC I
l l
L J
J1 ie 53 Docket No. 50-266 Docket No. 50-301 Wisconsin Electric Power Company ATTN: Mr. Robert Link Vice President Nuclear Power 231 West Michigan Street - P379 Milwaukee, WI 53201 l
Dear Mr. Link:
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) 10 Report for the Point Beach Nuclear Plant, our meeting of June 17, 1993, which i
discussed the contents of the report, and your written comments dated July 1,-
1993, relative to the report.
Based on our discussions during the meeting and our review and evaluation of your i
letter of response, we have reached the conclusion presented in the enclosed meeting summary. With the incorporation of the revised page(s) from Enclosure 3,-
l the Initial SALP Report should be considered to be the Final SALP Report.
In your response letter, you requested additional information about the challenge concerning self-assessments that was addressed during the NRC's SALP presentation of the Security functional area.
The challenge was based on our review of NRC -
i inspection reports which identified a number of programmatic issues which were not identified in your self-assessments of the Security functional area. A'more O\\
indepth, detailed self-assessment program could lead to your early identification Y.
and correction of these types of issues and their underlying causes. This matter was discussed with members of your Security staff on June 17, 1993, prior to the SALP meeting.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, l
Title 10, Code of Federal Regulations, a copy of this letter with the referenced enclosures, will be placed in the NRC's Public Document Room.
No reply to this letter is required; however, should you have questions regarding i
the Final SALP Report, please let us know and we will be pleased to discuss them
.l with you.
Sincerely, John B. Martin Regional Administrator i
See Attached Distribution RIII RIII R
I
- 0T RIII RI I
.RIII j
'GFk 9
D
'o a
C J'acK BrownV8lf3 Hasse d e 1
vi qrre
~l l2 7f fj RIII RIII RIII
,RIII i
jst Nore i Miller JMartin M
?6&
F J k 1
- 9.D Wisconsin Electric Power 2
Company
Enclosures:
I.
Final SALP 10 Report No. 50-266/93001; 50-301/93001
.i (Meeting Summary) 2.
Revision sheet (s) 3.
Revised Pages to SALP Report 4.
Licensee Response Ltr, dtd July I, 1993 cc w/ enclosure:
G. J. Maxfield, Plant Manager OC/LfDCB Resident Inspector, RIII Virgil Kanable, Chief Boiler Section Cheryl L. Parrino, Chairman, l
Wisconsin Public Service Commission
- l Robert M. Thompson, Administrator WI Div of Emergency Govt.
1 INP0 The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque-J. H. Sniezek, DEDR T. E. Murley, Director, NRR Chief, RPEB, NRR (2 copies)
J. N. Hannon, NRR Director, Project Directorate III-3 J. Lieberman, Director, Office of Enforcement C. D. Pederson, RIII
)
K. R. Jury, SRI i
L. L. Cox, RIII (2 copies)
TSS, RIII RIII Files RIII PRR j
~
i
.. l j
SALP 10 t
FINAL SALP REPORT t
U.S. NUCLEAR REGULATORY COMMISSION REGION III SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report Nos. 266/93001: 301/93001 Wisconsin Electric Power Company Point Beach Nuclear Plant 1
February 1, 1992, through March 31, 1993
&;fQQ~$-iffl0
P Point Beach A.
Summary of Meeting with Wisconsin Electric Power Company on June 17, 1993 The findings and conclusions of the SALP Board are documented in Report Nos. 50-266/93001; 50-301/93001 and were discussed with the licensee on June 17, 1993, at the Point Beach Nuclear Plant.
While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observers.
The following licensee and NRC personnel were in attendance, as well as the noted observers.
Wisconsin Electric Power Company J. W. Boston, President and Chief Operating Officer R. E. Link, Vice President, Nuclear Power G. J. Maxfield, Manager, Point Beach Nuclear Plant G. M. Krieser, Manager, Quality Assurance Nuclear Regulatory Commission H. J. Miller, Deputy Regional Administrator J. N. Hannon, Director, Project Directorate III-3, NRR I
- 1. N. Jackiw, Chief, Reactor Projects Section 3A J. R. Creed, Chief, Safeguards Section A. T. Gody, Jr., Senior Project Manager, NRR K. R. Jury, Senior Resident Inspector J. Gadzala, Resident Inspector Other M. J. Lien, Chief of Police, Two Rivers, WI l
B.
Comments Received from Licensee Wisconsin Electric Power Company's response to the Point Beach Initial SALP 10 Report dated May 28, 1993, included several comments that have resulted in minor revisions to the Initial SALP Report.
In addition, review of the comments pertaining to the Security functional area enforcement history and further consideration of our inspection data has resulted in the SALP Board's recognition lof an improving trend in the Security functional area. These changes are listed in Enclosure 2 and the revised pages are included as Enclosure 3.
The affected pages of the Initial SALP Report should be replaced with the corrected pages included in Enclosure 3.
C.
Regional Administrator's Conclusions Based on Consideration of Licensee Comments l '.
t I have concluded' that the overall ratings in the affected areas have not changed,. however, an Improving Trend is recognized in the Security -
functional area.
t 4
b e
i a
B t
sk
1 REVISION SHEET i
PAGE LJE NOW READS SHOULD READ 2
44 While security performance Security performance remained good with excellent remained good and also staffing levels and training exhibited an improving
- programs, enforcement trend.
Staffing levels and history declined and training programs were remained a
program excellent.
challenge.
Basis:
Although the enforcement history was initially characterized as declining, additional consideration of the time frame when two of'the violations occurred and the programmatic significance of some of the
.i violations changed this characterization.
3 11 Security (Rating This Security (Rating This Period) 2 (No Trend Given)
Period) 2 (Trend) Improving Basis:
Reconsideration of the enforcement history characterization and its implications on our assessment of. management effectiveness ' and i
technical issue resolution resulted in an overall improving trend being noted in the Security functional area.
8 24 Performance in this Performance in this functional area was functional area was characterized by a decline characterized by good in enforcement
- history, management effectiveness...
mixed management effectiveness...
Basis:
Although the enforcement history was initially characterized as declining, additional consideration of the time frame when several.of the violations occurred changed this characterization.
8 28 Enforcement history...
(This paragraph removed in accountability programs, its entirety) j Basis:
Recent SALP guidance is that a separate paragraph on enforcement history should not be included unless it is very significant. Several of the violations discussed in this functional area concerned one event which occurred more than ' ten years ago and therefore did not reflect on the current management effectiveness.
Reconsideration of this aspect indicated that this paragraph should be deleted.
u
s l
4 e
PAGE LINE NOW READS SHOULD READ i
8 32 Management effectiveness _
Management effectiveness l
in ensuring quality was in ensuring quality was mixed.
Pl ant... prog ram.
generally good yet at Management was not times inconsistent.
effective...
... weak P1 ant...
program.
management controls were Management was not identified in the...
always effective...
... management control weaknesses.
were identified in the...
j Basis: Additional consideration of the enforcement history significance and its implications toward management effectiveness resulted in changing the characterization to good.
However, management controls were not i
effective in some instances which led to violations. Also, minor changes in our characterization of day-to-day operations-and specific Security weaknesses resulted from our review of these matters.
i' 9
26 Performance is rated Performance is rated Category 2 in this area.
Category 2
with an improving ' trend in this.
area.
Basis:
Reconsideration of the enforcement history characterization and the programmatic significance of some of the violations resulted in. an overall improving trend being noted in the Security functional area.
11 38
...was evident.
The SEG
...was evident. The SEG and offsite and onsite review offsite and onsite review committees...
committees...
Basis: The initial wording was misleading in that it appeared to refer to only two entities when in fact there are three.
t r
(
the ssessment period. Performance in the areas of Maintenance / Surveillance, Emers,cy Preparedness, Security, and Engineering / Technical Support remained consis.,nt with the previous assessment period.
The impro ing trend previously noted in Radiological Controls continued during this asses. 'ent period and resulted in excellent performance.
The total station dost decreased for the third consecutive year and a program challenge identified la t period was addressed through better participation in exposure reduction comm tee meetings. Solid waste generation was significantly reduced by makir changes to the routine radiological work practices and a marked improvemen was noted in the radiological condition of the auxiliary building.
The improving trend n +ed in the Safety Assessment / Quality Verification area continued throughout t period and resulted in good performance. Management emphasized a high level afety awareness and made several organizational changes to assure the p focus on safety by plant and corporate staff.
Safety reviews, quality a e audits and other self assessment programs were effective in providi hts and identifying safety issues.
- However, corrective actions were not s timely because of inconsistent management oversight and ineffective gu 'anc for prioritizing issues.
Actions taken to reverse the pre y noted declining trend in Plant Operations were not fully success While performance was considered good, significant personnel errors cont to cause operational problems.
An automatic reactor trip and several c
'nated water and chemical spills occurrea because of personnel errors g scommunication.
Operator error also caused an excessive cooldown of t hctor vessel which led to the issuance of a civil penalty. Managemen ight of the activities which lead to these personnel errors was not e However,. operators responded well to abnormal events and pre at least one unnecessary automatic reactor trip. Daily shutdown ris essments and utilization of extra senior reactor operators were excellent in' atives.
Maintenance / Surveillance continued to show good rmance and demonstrated an improving trend.
The maintenance staff remai ble, well trained, and qualified which helped sustain high equipment reli and good materiel conditions. Strong management oversight was'presen
' g the conduct of complex and sensitive evolutions. A long-standing we continued to be the lack of detailed maintenance procedures, consisten in uality and content. However, recently written procedures were of g uality and the ongoing procedure improvement initiative remained on schedu -
Inconsistent procedure implementation contributed to the continuing proble of personnel errors.
Performance in the other three functional areas remained consiste with the previous assessment period.
Emergency Preparedness continued to h re excellent exercise performance and strong management support for the rogram.
While security perfor ance recained good with excellent staffing leve s and training programs. enforcement history declined and remained a program challenge.
Performance in Engineering / Technical Support also remained good.
Pesoluti of several challenges that were identified in the previous assessment perio included increased staffing levels, more proactive engineering staff, and 2
Encisoure 3 imp ved safety evaluations for modification packages.
However, some problems invol 'ng the improper assignment of priorities and poor work process controls contin :d to persist.
The perfo ance ratings during the previous assessment period and this assessment eriod according to functional areas are given below:
Rating Last Rating This Functional Arei Period Period Trend Plant Operations 1 Declining 2
Radiological Contr
'e 2 Improving 1
Maintenance /Surveill ce 2
2 Improving Emergency Preparednes.
I 1
Security 2
2 Engineering / Technical 2
2 Support Safety Assessment / Quality 3 Im; roving 2
Verification
- 11.
PERFORMANCE ANALYSIS A.
Plant Operations
/
Analysis Plant operations' performance decline the two previous assessment periods. While routine activities and or response to events remained strong, inconsistent manage:Ent effecti and significant personnel errors were primary causes of the performance d P
Management effectiveness in ensuring qualit 9 operations was mixed.
On the positive side, management initiatives to ize shutdown risk were excellent.
For example, management assigned a de '
ted extra senior reactor operator (SRO) to oversee reactor coolant system ndown to reduced inventory condition. However, management was n ective in identifying procedural inadequacies during reviews of a new st erator crevice flushing procedure, which contributed to a reactor cooldown event and resulted in a civil penalty. Additionally, manageme ot recognize these procedural inadequacies until the NRC identified them.
ement did, however, effectively institute corrective actions, incl horough pre-evolution briefings for infrequently performed tests, cri surveillances, inventory reductions, and reactor startups.
Operator response to automatic reactor trips, engineered safegu ds feature actuations, and several minor events, demonstrated an ability to 'spond' effectively to plant transients and stabilize plant conditions.
F
- example, rapid operator action during the loss of a vital direct current (DC) instrument inverter and during a turbine generator hydrogen pressure
> crease averted two potentially unnecessary reactor trips.
Personnel errors, v'ich were a concern during the previous assessment period, continued to occur Operator error was a primary cause of the reactor vessel cooldown event a 4 the cause of the only automatic trip of Unit 2.
In addition, operator err s resulted in several minor chemical spills and the simultaneous inoperability 3
exercise included the first use of the control room simulator, evacuation of he technical support center and the operational support center, and responses t
separate releases of radioactivity.
The 1992 routine inspection indicated ex >llent program maintenance with no significant problem areas. One acti ation of the emergency plan occurred during the assessment period and was appro,-iately classified.
The stat n's emergency planning unit continued to be staffed with excellent personnel.
Initiatives have been implemented to keep the emergency preparednes program active and visible.
The onsite emergency response organization ERO) staffing also remained good, with at least three individuals as igned to each key emergency response position.
The emergency pre 3 redness training program continued to be excellent.
A-conscious effort w being made to keep staff training current, varied, and interesting.
The t ining program was effective in maintaining qualified ERO personnel in supervis and support positions. Training was effective as demonstrated through
_ise performar.ce anc interviews.
2.
Performance Ratir Performance is rated Cat 1 in this area.
Performance was rated Category 1 during the previous assess erioc.
3.
Recommendations Hone.
E.
Security l.
Analysis Performance in this functional area was ct erized by a decline in enforcement history, mixed management effective s, good support relating to resolving technical issues and operational ev and excellent performance in staffing and training.
Enforcement history declined from the previous as t period and was weak.
Five violations were identified this period compar ree violations during the previous period.
The violations involvec he security and the special nuclear material control and accountability p g Management effectiveness in ensuring quality was mixed.
Pl it and corporate support for improvements was excellent as evidenced by new s urity equipment upgrades and the continuing implementation of a goals and obje ives program.
Management was not effective in ensuring consistency in day-to- -
operations.
Management corrected weaknesses involving strained security mana9 1ent resources and specific overview deficiencies noted during the prev us assessment period.
However, during this assessment, weak management controls were identified in the followup of a fitness-for-duty issue, personne access control, and the control of special nuclear material.
Specific correct ve actions were taken once these issues were identified.
8 i
l
. Enclosure 3 ie approach to the identification and resolution of teci.nical issues was g,d. Excellent action by engineering and security resulted in significant imp ovement of vital area door control and the effectiveness and reliability of p -imeter cameras. Tracking and trending programs were good and continued to im;. ove.
These programs increased site awareness and resulted in a reducti
) of personnel errors.
The volume of security maintenance requests and the
'meliness of completing these activities improved and was good.
Engineerin. and security support was weak in the modification process of an alarm upgra Evaluation and eporting of events was good, except for the failure to identify and rep t the potential loss of a small quantity of special nuclear material.
Requirt' security reports and logs were accurate and timely.
Staffing levels wer ellent.
Licensee and contractor resources were effectively utilize pport operational security program requirements.
Contractor support wa eased at the end of the assessment period to monitcr the effective security maintenance activities.
An effective workirg relationship cor d between local law enforcement agencies and security management.
The effectiveness of the tral and qualification program improved and was excellent.
Upgraded tactical se contingency training improved response capabilities.
The fitness-for-duty program met t
'ectives of 10 CFR Part 26. Program strengths included management suppor ad a canine program to aid in the identification of controlled substan 2.
Performance Ratinq Performance is rated Category 2 in this area
'erformance was rated Category 2 during the previous assessment period.
3.
Recommendations
+
flone.
F.
Enaineerino/ Technical Support 1.
Analysis Engineering and technical support performance remained mixed.
In most instances engineering support of the plant was good, showed a nservative approach, and was timely.
However, there were several instances of poor work process controls' that resulted in personnel errors and a spill of ontaminated water. A major reorganization of engineering took place too close o the end of the assessment period to be evaluated.
flanagement effectiveness in ensuring quality remained mixed. On the pc itive side, there was ample evidence of prior planning and assignment of prior ies during the extensive preventive maintenance of the electrical safeguards buses, the replacement of a DC distribution bus, and motor operated valve (MOV) work in response to Generic Letter 89-10.
Aspects of the MOV program, such as the innovative techniques developed for test performance, were good.
9 I
[
im ovement over the last assessment perioc.
The effectiveness of the major eng eering reorganization could not be evaluated because it took place late in th assessment period. A good staffing level was maintained within the traini organization.
The opera,r training and requalification program was mixed.
While the requalifice ion program experienced a high degree of success, the passing rate for initial oerators continued to be low. The training and qualification of engineers was 'ood.
The corporate engineering staff had the necessary technical exper ise to evaluate problems ar.d to provide oversight of contractors. Th technical support staff was knowledgeable of their assigned systems or compon ts.
2.
Ferformance Rat 'n Perforr:ance is rated C y 2 in this area.
Performance was rated Category 2 durir.; t..e previous a r.: perisd.
3.
Lacom,erdations None.
p G.
Safe:
ssessment/D.:alits i cat':-
].
Malvsis Manage:Ent's effectiveness in improvin quality of work and an awareness of the ":pcrtance of safety improved a good.
The timeliness and priorit'za: ion of corrective actions to to be a concern.
Managecent took steps to convey the expec hat plant personnel mus:
maintair. a high level of safety awareness.
iizational changes were nade to focus on plant and corporate staff resources te more efficiently support the safe operation of the plant.
Management involvement in ensuring quality and pl fety was evident in outage safety reviews (OSRs).
The safety evaluati p (SEG) performed an OSR before each refueling outage.
Outage containmen re drills to verify the effectiveness of procedures were perfor ed as rec ed by the SEG. The SEG did not, however, consider the negative effects of fT ming routine surveillance during refueling outages, particularly durirAuced inventory operations or when grid stability could be an issue.
For ex ple, a surveillance performed during reduced inventory conditions in he fall 1992 Unit 2 refueling outage resulted in the tea'orary de-energizati of one train of safety-related electrical buses requiring operators to start le other residuai heat removal pump.
Managemsnt's commitment to perform ef fective and independent safety r ' views was evicent. The SEG offsite and onsite review committees typically c acucted thorougn reviess and provided valuable insicht into plant operations.
However, the onsite review committee Managers Supervisory Staff (MSS) hat a
tendency to occasionally allow details to detract from the focus on the
)
overall safety issue.
Some improvement in the MSS focus was noted towarc th i
end of the assessment period.
!1 i
l i
the assessment period.
Performance in the areas of Maintenance / Surveillance, Emergency Preparedness, Security, and Engineering / Technical Support remained consistent with the previous assessment period.
The improving trend previously noted in Radiological Controls continued during this assessment period and resulted in excellent performance. -The total i
station dose decreased for the third consecutive year and a program challenge identified last period was addressed through better participation in exposure reduction committee meetings.
Solid waste generation was significantly reduced by making changes to the routine radiological work practices and a marked improvement was noted in the radiological condition of the auxiliary building.
The improving trend noted in the Safety Assessment / Quality Verification area continued throughout the period and resulted in good performance.
Management emphasized a high level of safety awareness and made several organizational changes to assure the proper focus on safety by plant and corporate staff.
Safety reviews, quality assurance audits and other self assessment programs were effective in providing insights and identifying safety issues.
- However, corrective actions were not always timely because of inconsistent management oversight and ineffective guidance for prioritizing issues.
Actions taken to reverse the previously noted declining trend in Plant Operations were not fully successful. While performance was considered good, significant personnel errors continued to cause operational problems. An automatic reactor trip and several contaminated water and chemical spills occurred because of personnel errors and miscommunication.
Operator error also caused an excessive cooldown of the reactor vessel which led to the issuance of a civil penalty. Management oversight of the activities which lead to these personnel errors was not effective. However, operators responded well to abnormal events and prevented at least one unnecessary automatic reactor trip.
Daily shutdown risk assessments and utilization of extra senior reactor operators were excellent initiatives.
Maintenance / Surveillance continued to show good performance and demonstrated an improving trend.
The maintenance staff remained stable, well trained, and qualified which helped sustain high equipment reliability and good material r
conditions.
Strong management oversight was present during the conduct of complex and sensitive evolutions. A long-standing weakness continued to be the lack of detailed maintenance procedures, consistent in quality and content. However, recently written procedures were of good quality and the i
ongoing procedure improvement initiative remained on schedule.
Inconsistent procedure implementation contributed to the continuing problem of personnel-errors.
t Performance in the other three functional areas remained consistent with the previous assessment period.
Emergency Preparedness continued to have excellent exercise performance and strong management support for the program.
Security performance remained good and also exhibited an improving trend.
Staffing levels and training programs were excellent.
1 Performance in Engineering / Technical Support also remained good.
Resolution j
of several challenges that were identified in the previous assessment period included increased staffing levels, more proactive engineering staff, and 2
)
L:
n 1
improved safety evaluations for modification packages.
However, some problems involving the improper assignment of priorities and poor work process controls continued to persist.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Rating Last Rating This Functional Area Period Period Trend Plant Operations I Declining 2
Radiological Controls 2 Improving 1
Maintenance / Surveillance 2
2 Improving Emergency Preparedness I
1 Security 2
2 Improving Engineering / Technical 2
2 Support Safety Assessment / Quality 3 Improving 2
Verification 1
III.
PERFORMANCE ANALYSIS A.
Plant Operations I.
Analvsis i
Plant operations' performance declined from the two previous assessment periods. While routine activities and operator response to events remained strong, inconsistent management effectiveness and significant personnel errors were primary causes of the performance decline.
Management effectiveness in ensuring quality during operations was mixed. On the positive side, management initiatives to minimize shutdown risk were excellent.
For example, management assigned a dedicated extra senior reactor operator (SRO) to oversee reactor coolant system draindown to reduced inventory condition. However, management was not effective in identifying 1
- procedural inadequacies during reviews of a new steam generator crevice flushing procedure, which contributed to 3 reactor vessel cooldown event and resulted in a civil penalty. Additionally, management did not recognize these-procedural inadequacies until the NRC identified them. Henagement did, however, effectively institute corrective actions, including thorough pre-i evolution briefings for infrequently performed tests,. critical surveillances, inventory reductions, and reactor startups.
Operator response to automatic reactor trips, engineered ~ safeguards feature f
actuations, and several minor events, demonstrated an ability.to respond effectively to plant transients and stabilize plant conditions.
For example, rapid operator action during the loss of a vital direct current (DC) l instrument inverter and during a~ turbine generator hydrogen pressure decrease averted two potentially unnecessary reactor trips.
Personnel errors, which were a concern during the previous assessment period, continued to occur.
Operator error was a primary cause of the reactor vessel cooldown event and the cause of the only automatic trip of Unit 2.
In addition, operator errors resulted in several minor chemical spills and the simultaneous inoperabil.ity 3
g
exercise included the first use of the control room simulator, evacuation of the technical support center and the operational support center, and responses to separate releases of radioactivity. The 1992 routine. inspection indicated excellent program maintenance with no significant problem areas. One activation of the emergency plan occurred during the assessment period and was appropriately classified.
The station's emergency planning unit continued to be staffed with excellent personnel.
Initiatives have been implemented to keep the emergency preparedness program active and visible. The onsite emergency response organization (ERO) staffing also remained good, with at least three individuals assigned to each key emergency response position.
The emergency preparedness training program continued to be excellent. A conscious effort was beina m oe to keep staff training current, varied, and interesting. The training program was effective in maintaining qualified ERO personnel in supervisory and support positions.
Training was effective as demonstrated through exercise performance and interviews.
2.
Performance Ratina Performance is rated Category 1 in this area.
Performance was rated Category 1 during the previous assessment period.
3.
Recommendations None.
E.
Securit_y 1.
Analysis Performance in this functional area was characterized by good management effectiveness, good support relating to resolving technical issues and operational events, and excellent performance in staffing and training.
Management effectiveness in ensuring quality was generally good, yet at times inconsistent.
Plant and corporate support for improvements was excellent as evidenced by new security equipment upgrades and the continuing implementation of a goals and objectives program. Management was not always effective in ensuring consistency in day-to-day operations. Management corrected weaknesses involving strained security management resources and specific overview deficiencies noted during the previous assessment period. However, during this assessment, management control weaknesses were identified in the followup of a fitness-for-duty issue, personnel access control, and the control of special nuclear material.
Specific corrective actions were taken once these issues were identified.
8
l The approach to the identification and resolution of technical issues was good. Excellent action by engineering and security resulted in significant improvement of vital area door control and the effectiveness and reliability of perimeter cameras.
Tracking and trending programs were good and continued to improve. These programs increased site awareness and resulted in a i
reduction of personnel errors. The volume of security maintenance requests and the timeliness of completing these activities improved and was good.
Engineering and security support was weak in the modification process of an alarm upgrade.
l Evaluation and reporting of events was good, except for the failure to i
identify and report the potential loss of a small quantity of special nuclear material.
Pequired security reports and logs were accurate and timely.
Staffing levels were excellent.
Licensee and contractor resources were i
effectively utilized to support operational security program requirements.
Contractor support was increased at the end of the assessment period to monitor the effectiveness of security maintenance activities. An effective working relationship continued between local law enforcement agencies and i
security management.
The effectiveness of the training and qualification program improved and was i
excellent.
Upgraded tactical response contingency training improved response capabilities.
The fitness-for-duty program met the objectives of 10 CFR Part 26. Program strengths included management support, and a canine program to aid in the l
identification of controlled substances.
2.
Performance Rating Performance is rated Category 2 with an improving trend in this area.
Performance was rated Category 2 during the previous assessment period.
-)
3.
Recommendations i
None.
1 F.
Engineering / Technical Support 1.
Anal ysi s l
Engineering and technical support performance remained mixed.
In most instances engineering support of the plant was good, showed a conservative approach, and was timely.
However, there were several instances of poor work process controls that resulted in personnel errors and a spill of contaminated water. A major reorganization of engineering took place too close to the end I
of the assessment period to be evaluated.
Management effectiveness in ensuring quality remained mixed. On the positive side, there was ample evidence of prior planning and assignment of priorities during the extensive preventive maintenance of the electrical safeguards buses, the replacement of a DC distribution bus, and motor operated valve-(MOV) work in response to Generic Letter 89-10. Aspects of the MOV program, such as the innovative techniques developed for test performance, were good.
9
improvement over the last assessment period. The effectiveness of the major engineering reorganization could not be evaluated because it took place late-in the assessment period. A good staffing level was maintained within the training organization.
The operator training and requalification program was mixed.
While the requalification program experienced a high degree of success, the passing rate for initial operators continued to be low. The training and qualification of engineers was good. The cor,, orate engineering staff had the necessary technical expertise to evaluate pro' lems and to provide oversight of o
contractors.
The technical support staff was knowledgeable of their assigned systems or components.
2.
Performance Rating Performance is rated Category 2 in this area.
Performance was rated Category 2 during the previous assessment period.
t 3.
Recommendations None.
'I G.
Safety Assessment /0uality Verification 1.
Analysis i
Management's effectiveness in improving the quality of work and an awareness of the importance of safety improved and was good. The timeliness and prioritization of corrective actions continued to be a concern.
Management took steps to convey the expectation that plant personnel must maintain a high level of safety awareness. Organizational changes were made to focus on plant and corporate staff resources to more efficiently support the safe operation of the plant.
Management involvement in ensuring quality and plant safety was evident in outage safety reviews (0SRs). The safety evaluation group (SEG) performed an OSR before each refueling outage. Outage containment closure drills to verify
~
the effectiveness of procedures were performed as recommended by the SEG. The SEG did not, however, consider the negative effects.of performing routine surveillance during refueling outages, particularly during reduced inventory operations or when grid stability could be an issue.
For example, a surveillance performed during reduced inventory conditions in the Fall 1992 i
Unit 2 refueling outage resulted in the temporary de-energization of one train l
of safety-related electrical buses requiring operators-to start the other residual heat removal pump.
Management's commitment to perform effective and independent safety reviews i
was evident. The SEG and offsite and onsite review committees typically' conducted thorough reviews and provided valuable insight into plant i
operations. However, the onsite review committee Managers Supervisory Staff (MSS) had a tendency to occasionally allow details to detract from the focus on the overall safety issue.
Some improvement in the MSS focus was noted toward the end of the assessment period.
i 11 b