ML20056C999
| ML20056C999 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/23/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20056C995 | List: |
| References | |
| 50-445-93-99, 50-446-93-99, NUDOCS 9308020052 | |
| Download: ML20056C999 (32) | |
See also: IR 05000445/1993099
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INITIAL SALP REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT NUMBER
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50-445/93-99
50-446/93-99
TU Electric
Comanche Peak Steam Electric Station, Units 1 & 2
February 3,1992, through May 29,1993
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TABLE OF CONTENTS
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1.
INTRODUCTION
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II.
SUMMARf 0F RESULTS . . . . . . . . . . . . . . . . . . .
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CRITERIA . . . . . . . . . . . . . . . . . . . . . . . .
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IV.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . .
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A.
Plant Operations, Unit 1
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B.
Radiological Controls, Units 1 & 2
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C.
Maintenance / Surveillance, Units 1 & 2 .
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D.
Emergency Preparedress, Units 1 & 2 . . . . . . .
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E.
Security, Units 1 & 2 . . . . . . . . . . . . .
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F.
Engineering / Technical Support, Units 1 & 2
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G.
Preoperational Testing / Operational Readiness
Unit 2
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H.
Power Ascension Testing, Unit 2 . . . . . . . . .
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Safety Assessment / Quality Verification
Units 1 & 2 . . . . . . . . . . . . . . . . . .
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V.
SUPPORTING DATA AND SUMMARIES
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Major Licensee Activities
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B.
Direct inspection and Review Activities
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I.
INTRODUCTION
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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
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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
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resources and to provide meaningful feedback to licensee management regarding
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the NRC's assessment of their facility's performance in each functional area.
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An NRC SALP Board, composed of the staff members listed below, met on June 23,
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1993, to review the observations and data on performance and to assess
licensee performance in accordance with NRC Manual Chapter 0516, " Systematic
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Assessment of Licensee Performance."
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This report is the NRC's assessment of the licensee's safety performance at
the Comanche Peak Steam Electric Station for the period February 3,1992,
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through May 29, 1993.
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The SALP Board for Comanche Peak was composed of:
Chairman
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T. Gwynn, Deputy Director, Division of Reactor Projects (DRP), Region IV
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Members
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S. Black, Director, Project Directorate IV-2, Office of Nuclear Reactor
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Regulation (NRR)
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L. Callan, Director, Division of Radiation Safety and Safeguards (DRSS),
Region IV
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S. Collins, Director, Division of Reactor Safety (DRS), Region IV
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L. Yandell, Chief, Project Section B, DRP, Region IV-
D. Graves, Senior Resident Inspector, DRP, Region IV
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W. Jones, Senior Resident inspector, DRP, Region IV
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T. Bergman, Project Manager, NRR
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B. Holian, Senior Project Manager, NRR
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The following personnel also participated in or observed the SALP Board
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meeting:
T. Reis, Project Engineer, Project Section B, DRP, Region IV
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G. Werner, Resident inspector, DRP, Region IV
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B. Murray, Chief, Facilities Inspection Programs Section, DRSS, Region IV
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J. Pellet, Chief, Operations Section, DRS, Region IV
T. Westerman, Chief, Engineering Section, DRS, Region IV
D. Powers, Chief, Maintenance Section, DRS, Region IV
1. Barnes, Technical Assistant, DRS, Region IV
S. McCrory, Reactor Engineer (Examiner), DRS, Region IV
L. Ricketson, Senior Radiation Specialist, DRSS, Region IV
M. Murphy, Inspector, DRS, Region IV
J. Ganiere, Intern, NRR
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H. Astwood, Intern, NMSS
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II.
SUMMARY OF'RESULTS
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Overview
Overall, licensee performance was good. The licensee's management oversight,
personnel, programs and procedures were sufficient to support dual unit
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operations. Management successfully coordinated safe operations of Unit 1 and
the second Unit I refueling outage, while simultaneously completing the
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intensive efforts necessary to support Unit 2 licensing.
Similarly, the
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licensee demonstrated its ability to safely coordinate Unit 1 operations with
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' Unit 2 startup testing.
Performance in the functional area of plant operations remained good although
operator performance was mixed. Operations personnel have demonstrated strong
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performance in their ability to respond to plant transients and off normal
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events. Nevertheless, significant operational concerns were revealed in May
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1992 from a loss of spent fuel pool cooling. Subsequent corrective actions
implemented by the licensee resulted in measurably improved performance,
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However, performance during routine evolutions and the failure to properly
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implement management expectations at the operator and first line supervisor
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levels were noted as significant weaknesses.
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A declining trend in the functional area of radiological controls was noted.
This decline was primarily due to ineffective communications and instances of
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poor radiological work practices exhibited by contract personnel. A weakness
was noted in the training program for contract personnel. Nevertheless, the
program remained strong with senior management support evident.
Excellent
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performance was noted in the ALARA program, radioactive waste effluents
management, radiological environmental monitoring, transportation of
radioactive materials, . solid waste management, and radiochemistry.
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Performance in the maintenance / surveillance area remained good.
Strengths
were noted in work ; tioritization, maintenance planning, and the reduction in
the backlog of outstanding work.
However, weaknesses were noted in that-
program objectives were not fully met and Technical Specification required
surveillance tests continued to be missed.
Personnel errors resulted in a
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reactor trip and an ESF actuation.
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Performance continued to be excellent in the emergency preparedness area.
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Superior performance was noted during the two actual event declarations which
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occurred this assessment period. The licensee staff has repeatedly
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demonstrated its ability to protect the public health and safety during an
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emergency.
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Performance declined in the functional area of security. Managerial problems
related to the oversight of the contract security organization and to
supervision within certain security shift organizations were revealed during
review of a security event. Management was' ineffective in identifying and
correcting morale and command problems. Strong performance was noted,
however, when the security force was called upon to respond to an actual
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security event. The licensee's security hardware continued to function well
and the maintenance and testing programs for security equipment remain
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superior.
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Performance continued to be superior in the area of engineering / technical
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support.
Programmatic strengths were noted in training, motor operated valve
testing and maintenance, as built verification, environmental qualification,
and design modifications. The efforts taken to qualify "Thermo-Lag" as an
acceptable fire barrier material were commendable and the engineering
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justifications supporting commitments to fire protection regulations were
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comprehensive.
System engineers continued to provide valuable support to
operations and maintenance.
Technical evaluations were generally sound with
minor exceptions.
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Performance was superior in the area of preoperational testing / operational
readiness.
Lessons learned from Unit I were well incorporated and staffing
and interdepartmental coordination were excellent. The quality of test
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procedures improved over the previous assessment period and execution was
excellent, The programs for the turnover of systems to operations were
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rigorous, resulting in the transfer of structures, systems and components to
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operations with relatively few outstanding deficiencies. Weaknesses were
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noted in system status control and the quality of some Unit 2 operational
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procedures.
Performance was excellent in the functional area of power ascension testing.
Implementation of fuel loading and startup testing procedures has been
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exempl ary. The exceptional implementation of the power ascension test program
was slightly diminished by operator errors,which occurred during routine
portions of the integrated startup procedures.
Performance declined in the safety assessment / quality verification functional
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area.
Self-assessment and quality assurance programs are considered superior,
but management has not been totally effective in preventing recurrence of
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significant deficiencies and achieving timely resolution of deficiencies
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identified by the Independent Safety Engineering Group (ISEG) or other
internal mechanisms.
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Rating Last Period
Rating This Period
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Functional Area
(02/03/91 to 02/02/92)
(02/03/92 to 05/29/93)
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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
Support
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Preoperational Testing /
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Operational Readiness
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Power Ascension Testing
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Safety Assessment /
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Quality Verification
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Engineering / Technical
Support - Unit 1
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Safety Assessment /
- Quality Verification - Unit 1
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Construction Activities
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Engineering / Technical
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Support - Unit 2
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Safety Assessment /
Quality Verification - Unit 2
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Preoperational Testing - Unit 2
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D - 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-
to address this pattern. Continuation of the trend may result in a change in-
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the performance rating.
III.
CRITERIA
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The evaluation criteria, category definitions, and SALP process methodology-
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that were used, as applicable, to assess each functional area are described in
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detail in NRC Manual Chapter 0516, dated September 28, 1990.
This chapter is-
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available in the Public Document Room files.
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. For this SALP Cycle, the~ performance of both units _was considered in
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each functional area with the exceptions of Plant Operations, for which the
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emphasis was on Unit I and Preoperational Testing / Operational Readiness and
Power Ascension Testing, which were applicable to Unit 2 only.
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.IV.
PERFORMANCE ANALYSIS
A.
plant Operations
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Analysis
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This functional area consists primarily of the control and execution of
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activities directly related to operating the plant.
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This functional area was inspected on a routine basis by the resident
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inspectors.
Supplemental inspections were performed which focused on -
preparation for refueling as well as' refueling activities, operation and
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maintenance of the balance-of-plant. A special inspection was conducted to
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review a loss of spent fuel pool cooling. The previous SALP report
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recommended that licensee management centinue its efforts to improve the
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reliability of secondary plant equipment, and unit interface controls.
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During this assessment period, management involvement and support for plant
operations continued to be a notable strength. Management had established
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clear expectations for the conduct of operations, in part, through procedures,-
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guidelines, and standing orders.
Senior management remained cognizant of
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plant issues and promptly provided needed resources to ' assess ' plant events and
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support plant operations.-
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The most significant enforr snent action during this assessment period involved.
the loss of spent fuel pool cooling event that occurred in May-1992. The
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enforcement action included seven examples of the failure to follow
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procedures, a failure in relation to locked valve controls affecting the
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Units 1 and 2 interface, a failure to translate design criteria into the
appropriate procedures, inadequate licensed operator requalification training,
a failure to maintain station procedures, and a failure to initiate a ' required
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corrective action document. Other enforcement included further examples of
failure to follow procedures. Operator errors and lack of attention to detail
continued to be a concern throughout the assessment period.
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The operating crews and initial license applicants have demonstrated high
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levels of performance in various NRC administered operational' evaluations
including dynamic simulator examinations and emergency preparedness
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inspections and exercises.
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Six plant trips occurred during this assessment period, and a high level of
performance by the operating crews when responding to abnormal and transient
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plant conditions was noted.
Examples included a partial loss of control room
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annunciators, a six hour plant shutdown required by the Technical
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Specifications, and several complete or partial losses of main feedwater flow
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from high power.
The licensee-effectively addressed the causes of these plant
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trips and abnormal plant conditions.
The operators' performance during routine and planned activities was mixed.
Shift turnover meetings were professional and well conducted. The operators
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demonstrated on numerous occasions the use of outstanding communication and
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self-verification techniques.
Command and control . functions were generally
found to have been effectively implemented during dynamic plant conditions.
Nevertheless, improper operator actions continued to result in challenges to
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the plant including engineered safety feature actuations and a reactor trip.
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There were also several problems noted with system status control including
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the implementation of the clearance program. The most notable operator
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performance issues occurred early in the assessment period when a loss of
spent fuel pool cooling revealed significant weaknesses with command and
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control over perceived routine activities, use of procedures, awareness of
annunciator and control board status, logkeeping, and supervisory oversight of
operator activities.
The licensee implemented corrective actions to enhance
supervisory oversight and to reduce the administrative work activities
required of the unit supcrvisor. An annunciator tracking log was also
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implemented to assist the operators in assessing annunciator status.
Observation managers and contracted shift advisors were assigned to oversee
plant operations and a permanent field support supervisor position was
established to coordinate auxiliary operator activities.
An extra unit
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supervisor was added to each shift to help reduce the administrative work
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load.
These corrective actions were generally. effective in assuring
management's expectations were being met and in reducing the total. number of
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operator induced events from the previous assessment period. The activities
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of the Performance Enhancement Review Committee, discussed in the Safety-
Assessment / Quality Verification functional area, were a factor in this
reduction. However, as the intensity of direct management oversight was
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reduced, there is evidence that suggests some operators and crews lapsed, at
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times, into some of the poor behaviors identified as ontributors to the May
1992 loss of spent fuel pool cooling event. This was most notably
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demonstrated in May 1993 when the licensee identified that the rate of reactor
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power increase exceeded administrative limits and shift supervision was
generally unaware of how power was being controlled.
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Licensee management had implemented specific measures to identify and resolve
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annunciator deficiencies which were discussed daily during the plan of the day
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meeting. Nevertheless, the plant continued to have a significant number of
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control room annunciators with deficient conditions during this assessment
period. An instance was noted where a repetitive diesel generator trouble
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alarm resulted in the operator not promptly identifying that the diesel
generator had started.
The effectiveness of this program has been limited as
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indicated by the total number of annunciators with deficiencies remaining
relatively constant.
Operations staffing was ample as demonstrated by the licensee's ability to
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support two major activities concurrently: preoperational testing on Unit 2
and a refueling outage on Unit 1.
During this assessment period, the licensee
decreased the number of operating crews from six to five. This change
provided additional licensed personnel in the control. room and in the plant
areas and did not result in an appreciable increase in personnel overtime.
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The conduct of operations _ during the second refueling outage was excellent.
Fuel movement was performed in a controlled, deliberate manner with
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communications appropriately maintained between the control room and refueling
bridge. Complex activities performed during the refueling outage and plant
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operation were well coordinated.
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The reliability of the secondary plant has improved. Challenges to primary
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plant components because of secondary plant failures were significantly
reduced. Housekeeping activities were well implemented with only minor
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exceptions.
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The Unit 1 and Unit 2 interface program was effectively implemented.
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operators demonstrated sensitivity to the interface boundaries which were well
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labeled in the plant.
Weaknesses in the interface control and locked valve
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programs were identified as a result of the loss of spent fuel pool cooling
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event. Appropriate corrective actions were implemented and no subsequent
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challenge to safety-related equipment occurred.
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In summary, mixed operator performance contributed to unnecessary challenges
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to the reactor plant. However strong management involvement in the
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operations program resulted in .aproved performance in the latter-part of the-
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assessment period. Operations staffing, crew. performance during complex and
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nonroutine plant evolutions, and response to transients and operational events
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were noted as significant strengths. Continuing problems with system status
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control, including implementation of the clearance program, were also noted as
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weaknesses. Unit interface cont;ols and the locked valve program were areas
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of concern early in the assessment. period, but recent significant improvement
was noted.
Efforts in decreasine the number of deficient annunciators and
increasing operator awareness te valid annunciators have been notable, but
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they have not been totally effe;tive.
Secondary plant reliability has
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improved over the previous assessment period, but continuing improvement is
warranted to minimize challenge 3 to the reactor plant.
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Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
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area.
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3.
Recommendations
a.
NRC Actions
Continue to monitor licensee actions to enhance personnel performance and
reduce personnel errors.
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b.
Licensee Actions
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Implement corrective actions to reduce personnel. errors. Monitor plant
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activities to ensure that performance expectations are being met.
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B.
Radiological Controls
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Analysis
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This functional area consists of activities related to radiation protection,
radioactive waste management, radiological effluent control and monitoring,
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radiological environmental monitoring, and transportation of radioactive
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materials.
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This area was inspected five times by region-based radiation specialist
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inspectors and on a continuing basis by the resident inspectors.
The previous
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SALP report recommended that the licensee evaluate the need for onsite storage
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of low-level radioactive waste. The licensee has since identified a warehouse
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that will be used as a low-level waste storage area.
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During this assessment period, the performance of daily radiation protection
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coverage of work activities was excellent; however, during stressful times,.
such as the refueling outage, the external and internal exposure control
program implementation was hampered by poor communications both within the
radiation protection department and between the radiation protection
department and other departments.
Examples included the failure of. radiation
protection technicians to effectively' communicate with one another and to
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transfer responsibility for worker coverage, which subsequently allowed
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workers to become contaminated and experience minor internal. radioactive
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material uptakes.
Failures in communication between radiation protection-
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technicians and other workers and inadequate training resulted in craft
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personnel removing contaminated insulation and wirebrushing contaminated
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components before radiation surveys were performed by radiation protection
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personnel. This incident resulted in the identification of a violation for
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failure to evaluate radiological hazards.
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Controls of radioactive materials and contamination within the radiological
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controlled area were excellent although a violation was identified during the
first half of the assessment period involving the control of radioactive
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- material stored outside of the radiological controlled area awaiting shipment
off-site.
Radiation protection technicians were observed properly performing
radiation surveys before releasing items from the radiological . controlled
area.
Radiation workers were observed on occasion using poor radiological
work practices; however, the number of personnel contaminations was low.
Housekeeping within the radiological controlled area was excellent during
routine operations and well controlled during outage conditions. .The
percentage of, the radiological controlled area identified as contaminated was
maintained low.
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Overall, the ALARA program achieved excellent results that maintained
radiation exposures well below the national person-rem average for PWRs.
Preparation and planning for radiological controls during the reft.eling outage
was excellent.
Preparations included supplementing the permanent radiation
protection staff with contract technicians, ensuring that proper inventories >
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of equipment and supplies were available, and carefully reviewing planned work-
activities to incorporate dose saving measures. Challenging person-rem goals
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were established and achieved for the refueling outage. A variety of advanced
techniques such as the use of telemetric dosimetry equipment and television
cameras for observation were used to reduce radiation exposure.
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activities were well planned to include dose saving measures.and pre-job ALARA
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briefings were consistently of high quality. Workers were responsive to the
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ALARA suggestion program.
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The startup of Unit 2 during this assessment period did not result'in any
decline in
e overall performance of the facility radiation protection
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program. The licensee effectively integrated Unit 2 radiation protection
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activities into the existing Unit 1 program. TV Electric was among the first
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power reactor licensees to implement new 10 CFR Part 20 regulations.
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transition to the new Part 20 requirements was accomplished in a smooth and
effective manner.
Excellent performance was noted during this assessment period in the areas of
liquid and gaseous radioactive waste effluents, water chemistry and
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radiochemistry, radiological environmental monitoring, solid radioactive
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waste, and transportation of radioactive materials.
Staffing was maintained at appropriate levels in the radiation protection,
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chemistry, radwaste, and environmental monitoring departments.
These
departments experienced a very low turnover of technical personnel.
The
chemistry and radiation protection staffs were supplemented as needed with
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qualified contract personnel.
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The training department provided good training to radiation workers, although
some contamination and uptake events were attributed to poor work practices,
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As a result, remedial radiation protection training, focusing on proper
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radiological work practices and proper removal of protective clothing, was
provided to all contractor outage personnel.
Practical factors training was
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particularly noteworthy. A good training program was established for
radiation protection supervisors.
In conjunction with the' licensee's
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initiaMve to implement the new 10 CFR Part 20, a high quality video
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presentation was given to workers to explain the changes.
The licensee promoted the professional development of radiation protection
technicians through incentives and by sponsoring the registration examination
for the National Registry of Radiation Protection Technologists.
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resulted in an increase from 10 to 36 percent in the number of radiation
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protection technicians meeting registration requirements.
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Management provided strong support for all activities in the radiological
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controls area.
Proper management oversight was maintained by thorough,
comprehensive audits. The audit teams usually included technical experts from
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other utilities.
The radiation protection department responded promptly to
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the findings of the audits with appropriate corrective actions.
In summary, a declining trend in performance was noted in this functional area
primarily due to ineffective communications and instances of poor radiological
work practices exhibited by contract personnel.
A weakness was also
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identified in the training program for contract personnel. Nevertheless, the
radiological controls program remained strong with senior management support
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evident. Housekeeping inside the radiologically controlled area was excellent
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and the relatively small area of the plant designated as contaminated was a
positive indicator of a strong program. The licensee's ALARA program,
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planning and preparation for the Unit I refueling outage, controls for
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radioactive materials and contamination were noted strengths within this
functional area.
The radiological support programs _ including waste effluent,
radiochemistry, radiological environmental monitoring, and solid waste
management and transportation were superior.
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2.
Performance Rating
The licensee is considered to be in Performance Category 1 in this functional
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area, with a declining trend,
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3.
Recommendations
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a.
NRC Actions
None
b.
Licensee Actions
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Ensure appropriate communications, training, and control of contract personnel
performing work in radiological controlled areas.
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C.
Maintenance / Surveillance
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Anal ysi s
This functional area consists of activities associated with the preventive and
corrective maintenance of plant structures, systems, and components; and
installation of plant modifications.
It also includes the conduct of
surveillance testing, integrated leak rate testing, and in-service inspection
activities.
This area was inspected on a routine basis by the resident inspectors and on
several occasions by regional inspectors.
Regional inspection activities
included both programmatic and performance based reviews. These inspections
included an assessment of licensee actions in response to the previous SALP
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-11-
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report recommendation that the problems in the surveillance testing program be
identified and effective corrective actions taken to preclude. instances of
The enforcement history in this functional ares was good. Multiple minor
violations were identified but were not indicative of a programmatic
breakdown. These violations included the control of heavy loads around the
reactor vessel head, implementation of certain corrective maintenance program
l
!
requirements, and conduct of surveillance testing including missed
surveillances.
j
During this assessment period, management support for-the maintenance program
.
was excellent.
It was particularly notable that the incorporation of the
i
Unit 2 maintenance activities into the established Unit I maintenance process
>
did not result in an increase in the overall maintenance work backlog or in
i
excessive overtime.
Personnel staffing was appropriately enhanced to support
two unit operation.
,
The maintenance program was.well implemented.
Equipment deficiencies were
,
appropriately identified, although a recurring problem was noted where .
l
deficiency tags were not removed following completion of a work activity.
.
This resulted in instances where subsequent minor deficiencies were not
!
promptly identified.
The maintenance process provided for the scheduling of
1
work activities by system and train.
Safety-related equipment work activities
'
were properly prioritized and scheduled for work during the designated system
outage window. The coordination of these work activities by the work control
i
center was very good. The work scheduling and plan-of-the-day meetings were
-
effective in identifying the planned work activities and providing
,
coordination between the different organizations. However, the
i
'
interorganization communications were not fully effective in assuring that
-
work activities, which required entry into a limiting condition for operation,
,
were promptly initiated after the equipment was removed from service. This-
!
resulted in some safety-related components being out-of-service for a period
- '
substantially greater than required to perform the work activity.
Licensee
performance in this area improved at the end of the assessment period,
i
The effectiveness of the maintenance programs intended to enhance equipment
reliability was mixed. The preventive maintenance program was well
implemented. Preventive maintenance tasks were appropriately scheduled during
designated train outage windows.
However, a weakness with the program was
!
,
identified where the scheduling process did not assure that deferred, outage
>
frequency tasks were identified and evaluated for the effect on plant
!
equipment.
In addition, the repetitive maintenance process was not totally
l
effective in identifying repetitive maintenance tasks, resulting in the
-
failure to properly evaluate the recurrent deficiency. One example included
'
the repetitive work on the diesel generator lifters.
This was caused, in
part, by the complexity of the procedure and the program implementation
responsibility not being well defined.
!
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1
Excellent communications were noted to exist between the maintenance
,
department and training personnel.
For example, maintenance personnel were
l
provided with freeze seal mockup training prior to performing the activity in
~
the field. Routine communications between the operations and maintenance
organization, as previously noted, were good.
Communications during high risk
,
and high priority work activities were outstanding. Management involvement
l
with these activities was often observed. Two examples were the replacement
i
of a feedwater regulating valve control card and repair of the control room
i
air conditioning units to terminate a Technical Specification reluired
shutdown.
,
!
Management's expectations for the conduct of maintenance activities were
j
generally well established.
The implementation of these expectations by
j
maintenance personnel was good.
An appropriate skill of the craft level was
i
utilized in developing work order instructions.
However, there were several
!
instances where the conduct of maintenance work was inadequate.
Two examples
l
i
involved work performed on an incorrect valve and the performance of
unauthorized troubleshooting, which resulted in a partial loss of main control
!
i
board annunciators. The performance enhancement program has been effective in
!
addressing maintenance personnel errors and in encouraging the use of self-
verification practices.
Enhanced first line supervisory oversight was
!
observed; however, the-degree of oversight provided varied within the
l
maintenance department as did the use of self-verification. Overall, the use
j
of self-verification practices improved during the assessment period.
l
!
Maintenance activities on balance-of-plant equipment were controlled and
l
performed in a manner similar to safety-related activities.
The licensee
j
demonstrated a heightened sensitivity to work activities for equipment which
1
contributed to improving plant reliability. The material condition of
j
balance-of-plant equipment was improved; however, operational challenges
continued as noted for several main feedwater pump problems and a feedwater
flow control valve regulator failure. The latter event resulted in a manual
l
The material condition of primary plant equipment was
j
considered excellent. The control of temporary leakage repairs was considered
j
to be a program strength.
j
I
i
Postmodification testing was well performed and contributed to overall quality
of installed modifications.
Several instances occurred during the refueling
,
outage where testing activities identified contractor initiated design
l
modification errors.
'
The requirements for the surveillance test and calibration control program
were well defined and comprehensive. Management initiated a surveillance task
i
team to review the causes for missed surveillance tests, as discussed in the
previous SALP report. Well founded program improvement recommendations were
identified and subsequently implemented. The surveillance task team
,
recommendations appeared to be effective in resolving the programmatic
concerns; however, additional surveillance program implementation problems
subsequently occurred.
The additional concerns identified by the NRC and/or
the licensee included the adequacy of surveillance procedure revision and
.
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oversight of personnel performing surveillance tests. Although the
surveillance program was improved, the licensee was not fully effective in
eliminating the missed surveillance tests,
j
!
The surveillance test activities were performed b/ qualified personnel
!
utilizing the required administrative controls.
Surveillance tests were well
.
coordinated with safety-related equipment maintenance outage windows.
. i
Excellent coordination was noted between the testing and operations
.
cegar.izations. Coordination and communications during complex surveillance
i
activities were excellent. Test briefings conducted prior to performing
I
surveillance tests were generally very good; however, instances were
identified where test personnel were not fully cognizant of the test
i
instructions. This resulted in the need to reperform specific steps and
j
contributed to a reactor trip.
!
Personnel performance during surveillance testing was generally very good,
although personnel errors resulted in inadvertent equipment actuations and a
j
reactor trip. The implementation of management's expectations improved during
!
the SALP period, including the.use of self-verification techniques
!
!
The inservice inspection program required by ASME Section XI and the Technical
.
Specifications was found to be effectively implemented.
Performance of
j
nondestructive examinations was. observed to be good.
j
. !
In summary, management involvement in the maintenance and surveillance
l
programs continued to be very strong. Maintenance backlogs were well
controlled and personnel staffing was ample as indicated by the control of
overtime and the' backlog. The licensee's maintenance and surveillance
programs continued to be strong, although examples were identified where some
i
program objectives were not consistently met.
Personnel implementation of
l
these programs was good; however, significant challenges to the ' plant and
4
- personnel were again noted. Management's expectations were. understood and
i
generally well implemented.
Supervisory oversight and the use of self-
verification were not consistently applied throughout the maintenance
organization. The licensee was not fully effective in eliminating missed
surveillance tests.
,
2.
Performance Rating
,
The licensee is considered to be in Performance Category 2 in this functional
area.
3.
Recommendations
a.
NRC Actions
Review performance of personnel and supervisory oversight during maintenance
and surveillance activities.
,
.
e
y
e
>
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.e>e
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]
b.
Licensee Actions
Ensure that the maintenance and surveillance programs are accomplishing the
!
I
stated objectives.
l
D.
Emeraency Preparedness
]
1.
Analysis
'
This functional area includes activities related to the establishment and
implementation of the emergency plan and implementing procedures, onsite and
offsite plan development and coordination, support and training of emergency
response organizations, licensee performance during exercises and actual
.
events that test the emergency plans, and interactions with onsite and offsite
,
emergency response organizations during planned exercises and actual events.
Evaluation of this functional area was based on the results of three .
)
inspections conducted by regional inspectors and observations by the resident
-]
inspectors. Two routine inspections included evaluation of the 1992 emergency
exercise, and an operational status inspection. A special inspection was
-!
conducted to ascertain whether the licensing of unit 2 was.taken properly into
j
consideration in the licensee's emergency preparedness-program. The previous
- ;
SALP report did _ not include any specific recommendations.
]
During this assessment period, there were two emergency declarations
j
associated with actual events, both at the Notification of Unusual Event
classification level. One declaration resulted from entering a Technical ~
Specification shutdown action statement.
The second followed a security event
involving an armed security officer. During the two events, the operations
shift supervisors' responses were excellent.
In each case, the licensee
properly implemented the emergency plan and implementing procedures.
Excellent site support was provided to recover from each event.
Licensee management provided strong support for the emergency preparedness and
response programs during this assessment period.
issues associated with the licensing of Unit 2 affected the ability of the
licensee to effectively implement the emergency plan.
It was determined that
emergency preparedness and response requirements related to Unit 2-had been
incorporated into the facility approved emergency plan.
Changes to the emergency plan and implementing procedures were handled in an
excellent manner.
Emergency facilities, equipment and supplies were
maintained in a state of operational readiness.
The number of positions in
the licensee's emergency response organization was increased during the
,
assessment period and a good training program had been established for
emergency response personnel. The emergency planning staff continued to
possess sufficient expertise and experience to maintain an excellent program.
Comprehensive and effective audits of the emergency preparedness program were
)
performed.
.,
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The three shift crews evaluated in walkthroughs made timely and accurate event-
!
classifications.
Improvements were noted concerning emergency action level
i
classifications, but some procedures continue to be rather cumbersome to use.
l
Two of the crews made off-site notifications properly while one crew
'
demonstrated some problems with the completeness of their notification
'
messages. Dose assessments were performed effectively and the decisionmaking
process and actions taken by the crews resulted in effective protective action
l
recommendations. The crews demonstrated good teamwork and communications
i
during event mitigation.
1
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,
During the 1992 emergency exercise, the licensee performed well in response to
a challenging scenario. A major objective was demonstrated with the timely
and orderly activation of the emergency response organization during off-
i
hours. Control room staff performance was noted to be strong.
The licensee's
exercise critique was excellent in identifying areas in need of corrective
!
!
action.
Three exercise weaknesses were identified.. involving delays in
classifying two emergency classes, failure to make prompt notifications to
off-site authorities of an emergency classification, and several examples of
weak emergency command and control. These identified weaknesses did not
l
represent any breakdowns in the emergency preparedness program. The Federal
>
Emergency Management Agency (FEMA) did not evaluate the 1992 exercise,
however, a prior off-site deficiency identified during the previous FEMA
evaluated exercise had been corrected.
'
The licensee continued to demonstrate a'high level of sensitivity to off-site
j
emergency preparedness. On one occasion during the assessment period, a
significant loss of off-site emergency siren capability occurred as a result
of a power supply being damaged.
The licensee promptly . notified surrounding
,
counties of the need to use the alternate notification method.
In addition,
a
short-term corrective actions were effective in significantly reducing the
,
number of inadvertent siren actuations.
In the long term, senior management
,
has decided to upgrade the off-site notification system.
In summary, performance in the functional area of emergency preparedness
,
continued to be excellent.
Performance during two actual event declarations
!
was strong. The licensee has repeatedly demonstrated its ability to protect
'
the health and safety of the public during an emergency. The emergency plan
has been well managed and the emergency response organization remained well
,
qualified.
2.
Performance Rating
The licensee continued to be in Performance Category 1 in this area.
]
3.
Recommendations
None
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E.
Security
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1.
Analysis
This functional area consists of activities associated with the security of
{
the plant, including all aspects of access authorization, protection of
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safeguards information, and fitness-for-duty activities.
j
Evaluation of this functional area was based on the results of five routine
security inspections and one reactive inspection performed by regional
i
physical security specialist inspectors and continued observations by the
!
resident inspectors. The routine inspections included the Unit I licensed
!
activities and the Unit 2 preoperational activities. The reactive inspection
involved an alleged assault on a security officer within the protected area.
'Se previous SALP report did not include any specific recommendations.
During this assessment period, several violations and performance concerns
l
were identified involving protection of safeguards information, behavioral
j
observation training, access authorization, fitness-for-duty, inattentive
security officers, access control for vital areas, access control - packages,
1
and control of a licensee designated vehicle. . Although the violations and
performance concerns did not indicate any programmatic breakdowns and prompt
!
and effective corrective actions were implemented to address the problem
'
areas, collectively they indicate an overall performance decline in this
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functional area.
j
f'
Management continued to provide strong support of the security program, but
oversight of the contract security organization was considered ineffective.
l
This was particularly evident during the review of the alleged assault
-!
incident when several problems regarding morale and reporting _ of incidents
were identified to NRC, and TV Electric was unaware of the concerns.
The security systems performed exceptionally well during the assessment
'
period. An excellent testing and maintenance program continued, ensuring
maximum operability of the security systems.
The security force was professional, dedicated, and of sufficient numbers to
i
meet all contingency plan requirements.
Nevertheless, during followup to a
i
security event, the inspectors noted that morale among the security force had
decreased due, in part, to a planned reduction-in-force within the security
!
organization.
Also, the supervision within certain security staff
l
organizations was weak and contributed to lower morale in the contract
security force.
!
!
The security organization provided timely, effective, and technically correct
j
responses to the annual security audit findings and recommendations. Audits
i
i
performed by the security organization of the self-screening contractors'
access authorization programs were thorough and identified several problems
with contractor programs. The licensee performed an excellent in-house
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investigation of an alleged assault incident during the middle of the
i'
assessment period.
The licensee submitted two Physical Security Plan revisions pursuant to
10 CFR 50.54(p) that involved significant changes to the program. The
j
licensee's preparation of the proposed changes was of high quality and
indicated a thorough understanding of 10 CFR 50.54(p) requirements.
l
The licensee maintained a good training program.
The security training
{
program improved in the areas of tactical and firing range training.
Tr_aining
!
records were well maintained and complete.
However, a weakness was identified
-)
in the classroom training involving the organization and presentation of
!
materials.
!
3
In summary, performance in the functional area of security has declined. A
!
reactive inspection into the circumstances surrounding the alleged October
l
1992 assault of a security guard revealed previously unidentified weaknesses.
1
Management oversight of the contract security force was ineffective in that it
i
did not uncover the morale and command problems associated with at least one
-!
security shift until after the investigation into the October incident.
1
Enforcement history over a broad range of areas also indicates a declining
j
performance in this functional area. However, strong performance was noted in
the security force ability to cope with an actual emergency and continued
excellent performance was noted with the security hardware and'its. associated
j
maintenance and testing program.
2.
Performance Rating
]
The' licensee is considered to be in Performance Category 2 in this functional
j
area.
3.
Recommendations
a.
NRC Actions
Monitor licensee performance in the areas of management effectiveness of the-
security organization, training and qualifications, access control, and
behavioral observation.
b.
Licensee Actions
Strengthen oversight of the contract security organization, including the
training and qualification program and the behavioral observation program.
F.
Engineering / Technical Support
"
'1.
Analysis
The evaluation of this functional area addresses the adequacy of engineering
and technical support for all plant activities. This assessment includes all
!
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licensee activities associated with the design of plant modifications-
i
engineering and technical support for operations, outages, maintenance,
l
testing, surveillance, and procurement activities; training; vendor interface
activities; and configuration management.
6
This functional area was im.pected on an ongoing basis by the resident
!
inspectors and periodically by the region-based inspectors.
This inspection
,
effort included a review of Generic Letter 88-05, " Boric Acid Corrosion of
!
Carbon Steel Reactor Pressure Boundary Components at PWR Plants;" team
.
inspections to assess the implementation of Generic Letter 89-10, " Safety-
!
Related Motor Operated Valve Testing and Surveillance," and fire protection
-
requirements; and other inspections involving engineering and technical
j
support functions.
,
The previous SALP report recommended additional licensee attention to the
design basis document (DBD) program, in which some erroneous information
!
existed that could adversely affect future designs and analyses. The report
!
also recommended that licensee management increase efforts to improve
,
thoroughness and comprehensiveness of technical evaluations supporting
!
licensing actions.
The licensee's program to implement commitments to Generic Letter 89-10,
!
" Safety-Related Motor-0perated Valve Testing and Surteillance," and its
l
supplements, assessed as being strong during the last SALP period, was
determined to be outstanding. Diagnostic testing capabilities were very
- j
extensive, including the use of motor dynamometer testing, actuator torque
l
stand bench testing, and stem-mounted torque and thrust strain gauges.
l
Additionally, the evaluation of data generated from these testing devices was
commendably rigorous. The licensee's staff possessed a superior level of
knowledge and experience in this area. The allocation of manpower and
t
financial resources for the motor-operated valve program appeared optimal.
i
Two weaknesses were identified as violations. A weakness was also revealed
involving the lack of a positive verification of initial valve position prior
i
to open-stroke diagnostic testing. Overall, the licensee's program is
considered superior.
The licensee effectively implemented design changes and modifications. Safety
evaluations were detailed, extensive'in scope and provided reasonable
,
1
assurance that the proposed change would not cause a safety concern. Design
calculations and assumptions demonstrated the use of conservative engineering
'
practices. Concerns with the adequacy of contractor design modifications were
identified during the refueling outage.
Prompt corrective action we
initiated to ensure that an adverse safety impact on the plant did not occur.
Modifications were comprehensively reviewed to determine impacts on training,
procedures, drawings, the Final Safety Analysis Report, and the Technical
j
Specifications. The effectiveness of the design modification review committee
1
improved during the inspection period. As-built configurations matched the
.l
details of the drawings.
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-19-
The system engineering program continued to provide valuable support to
operations and maintenance. This was evident during daily plant operations
and in reactions to plant transients and equipment failures.
Excellent
support was noted for the solid state sequencer and balance of plant inverter
j
failures. The system engineers were generally found to be cognizant of their
i
assigned system status.
Repetitive problems with the emergency diesel
generator starting air system were well documer,;ed.
In contrast, temporary
.
.!
measures were taken to address instrument air system problems; however, an
incomplete evaluation was performed which did not assimilate the numerous and
varied system failures.
This resulted in incomplete modifications to addres
the problem.
The licensee had established a competent station nuclear engineering staff.
Direct support provided to operations during the refueling outage and approach
to Unit 2 initial criticality was excellent.
A comprehensive testing process
r
was implemented to identify failed fuel rods to prevent their use in Cycle 3.
l
!
Engineering evaluations generally provided a sound technical justification for
j
their disposition.
Licensee management was proactive in establishing a
i
committee to review all Unit 2 TU evaluation forms generated daily to evaluate
each potential deficiency for reportability as well as potential impact on
Unit 1.
Although the evaluations were generally sound, several technical
!
evaluations were reviewed which did not support the disposition.
.
A review of the assessments and documentation performed by the licensee
relative to the translation of the Unit 1 Post Construction Hardware
Validation Program results to Unit 2 programs concluded that the translation
had been effectively implemented and was commensurate with the methodologies
utilized on Unit 1,
Strong management involvement and support were evident as
indicated by the thoroughness of the documentation associated with attribute
evaluation forms and the sound technical justifications provided.
Training and qualification programs were determined to be satisfactory to
support the licensing and power operation of Unit 2.
These training programs
were function,; g as intended though an isolated instance was identified where
the training impact system did not function to initiate a necessary
modification to the accredited training program.
The professional staff
training program was evaluated as superior.
The accredited technical and
operational training programs were effective and proactive in improving the
level of training.
The process included the identification of and training on
unit differences. During one set of initial license examinations and two sets
of unit difference examinations, all licensee applicants passed and
demonstrated generally strong performance. This was attributed to the
sustained higher level of training performance and applicant screening
effectiveness that was first observed and reported in the previous SALP
evaluation period.
There is no apparent link between training effectiveness
and the operator performance errors that have been evident at Comanche Peak
for the past two SALP periods.
In general, the training department performed
well and improved the quality of training during this assessment period.
.
,
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The Unit 2 procurement and receiving inspection program criteria were well
defined and effectively implemented. Organizationally and individually, there
.j
'
was a strong commitment to adhere to the written program. Material and parts
- !
verification efforts have been enhanced by the addition of on-site. test lab
equipment.
A personnel qualification program had been established to ensure
l
the competency of receipt and procurement compliance personnel in the use of
i
the test lab equipment.
l
Senior management oversight and involvement, and the engineering evaluations
j
to address the Thermo-Lag deficiencies were outstanding. The licensee
l
recognized in May 1992, following an internal assessment of fire barrier test
'
results and documentation, that the fire barrier qualification program
-;
(required by their Fire Protection Plan) would need comprehensive testing to
'
confirm the operability of the barrier. An extensive fire barrier test
progy am was planned and conducted to support the qualification of the
.t
prote-ted conduit and cable tray configurations used in the plant.
This
t
progra,a included laboratory testing for barrier performance and ampacity
derating data, extensive plant walkdowns, detailed drawings and procedures,
.j
and the evaluation and analysis c a significant amount of data and industry
~
experience.
The licensee propost
onservative barrier qualification
,
acceptance criteria, and ensured that in-plant installations were carefully
controlled.
In general, the engineering work supporting both the laboratory
!
test program and ir.-plant fire barrier application was sufficiently detailed
and thorough.
Testing was conducted in accordance with procedures, and
results were evaluated according to established criteria.
Detailed barrier
'
installation procedures included provisions for documenting variations to
tested configurations. These variations were adequately documented and
evaluated for acceptability or rework. Only in a few, relatively minor cases
j
were the supporting engineering evaluations deemed deficient.
.
Additionally, the licensee provided sufficient technical justification for
revisions to their fire protection program.
Sufficient information and
-a
detailed evaluations were provided to demonstrate that Appendix R criteria and
commitments were satisfied.
In depth engineering evaluations supported
installed fire protection, detection, and suppression hardware configurations.
Emergency lighting was found to support fire safe shutdown procedures although
i
the licensee's selection and application of emergency lighting power supplies
'
resulted in emergency lighting in some areas being marginal.
Final Safety Analysis Report revisions were, in general, provided with
adequate information and technical discussion, showing evidence of prior
planning and a good understanding of the technical issues and their safety
impact.
Engineering evaluations supporting Final Safety Analysis Report and
Technical Specification changes demonstrated sound judgment and were
indicative of a technically qualified staff.
The licensee identified errors
in vendor supplied analyses for both the boron dilution mitigation system and
the cold overpressure mitigation system that have generic implications.
The
licensee has aggressively pursued-correction of these deficiencies.
_.-
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In summary, overall performance in this functional area was considered
!
excellent .
Strong management involvement was evident.
Licensed operator,
!
technical staff and craft training were considered strengths.
The licensee
!
i
leads the industry in the implementation of the requirements of Generic Letter 89-10, " Safety Related Motor Operated Valve Testing and Surveillance," and the
as-built verificat :en, environmental qualification, and design modification
.;
programs were also superior.
The effort to qualify "Thermo-Lag" as an
t
acceptable fire barrier material was performed in an exemplary manner. The
,
engineering analyses to support the licensee's commitments to Appendix R
i
criteria were detailed and comprehensive and the fire protection program was
!
well implemented. Technical evaluations were generally sound, with minor
.
'
exceptions.
i
2.
Performance Rating
The licensee is considered to be in Performance Category 1 in this functional
area.
3.
Recommendations
Ncne
,
i
G.
Preoperational Testing / Operational Readiness, Unit 2
'
1.
Analysis
This area included activities which were related to the implementation 0 the
i
3
preoperational and startup test programs, operational readiness and the
l
l
performance of existing :lte programs in support of testing and startup cf the
i
second unit.
i
These areas were inspected routinely by the resident inspectors.
Additional
I
regional based inspection focused on specific programs and processes to
{
.
supnert testing and startup. This included an operational readiness team
inspection conducted prior to unit licensing.
Evaluai. ions within the
!
'
preoperational area were based on the observations of over 30 preoperational
!
,
tests by region-based and resident inspectors.
The previous SALP report
j
recommended that the licensee ensure that preoperational test procedures be
~
written to encompass all technical and administrative requirements and that
..
appropriate management oversight be provided.
During this assessment period, the coordination between the construction,
l
startup, maintenance, and operations organizations was generally noteworthy,
although during the performance of maintenance on a battery exhaust fan, a -
s
lack of coordination between the startup engineer and construction personnel
i
resulted in the initiation of work on an energized fan motor.
Additionally,
l
during removal of a component cooling water valve, several work control
!
6
deficiencies were identified regarding scope of work, quality control
involvement, and attention to detail in the work document.
'
l
!
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e
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-22-
One violation involving inadequately controlled construction maintenance
activities was identified early in this assessment period.
This issue
i
concerned the unauthorized repair of a Unit 1 valve by construction personnel
,
who were to have performed corrective maintenance on a similarly designated
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Unit 2 valve.
Subsequent to this event, extensive corrective actions were
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implemented by the licensee to enhance the self-verification process and to
provide additional controls for work activities in the Unit 1 operations
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controlled area. However, these corrective. actions were not completely
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effective in that additional examples of improper self-verification were
experienced.
Operational startup performance during the preoperational testing / operational
readiness period was generally good.
Repetitive instances were identified
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where system status control was less than adequate and resulted in system
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misalignments and, in one case, damage to a diesel generator engine.
In
!
general, operator performance on Unit 2 throughout this assessment period was
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good, although operator inattention resulted in the attempt to parallel a
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diesel generator significantly out of phase.
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The quality of the preoperational test procedures, identified during the
previous assessment period as a weakness, was upgraded. Acceptance criteria
were clearly stated and reflected the requirements of the Final Safety
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Analysis Report commitments, design basis documents, industry standards, and
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regulatory requirements. Good management uversight of this procedure upgrade
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effort was evident.
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preoperational testing activities were conducted in a consistently cautious
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and controlled manner that demonstrated a conservative safety attitude.
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Noteworthy was the performance of operations personnel during the remote
{
shutdown capability demonstratier
The licensee identified numerous
administrative errors made during the conduct of the tests that in some cases
7
required retesting.
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Positive performance was acted
.rino > :oection of the activities associated
f
with the Unit 2 reactor coolant s, ..... i f *ostatic test,~ containment
,
structural integrity tesi, containment integrated leak rate test, and
integrated engineered safety features system testing, especially in the.
!
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incorporation of lessons learned from prior Unit I and 2 testing and Unit 1
operational experience.
!
Administrative procedures regarding testing activities were well written. The
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procedures containec explicit and detailed instructions on the conduct of
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preoperational, initial startup, and power ascension testing.
Procedures also
provided for positive and comprehensive control of the testing process.
Once
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weaknesses identified by a QA audit were resolved, the administrative control
process for personnel qualifications assured the satisfactory qualifications
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of personnel involved in testing.
Test persornel demonstrated extensive
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knowledge of the systems and preoperational test procedures.
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There was early concern regarding poor coordination of testing activities with
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the control room operating staff. When the licensee became aware of the
concern, actions.were-initiated that resulted in continuous improvement
throughout the preoperational test program including the formation of the
overview assessment team. The team functioned as planned and made a positive
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contribution to the quality of hot functional test activities. The around-
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the-clock support to operations by contracted shift advisers was also a
positive program attribute.
!
Effective management oversight was readily apparent in the scheduling of the
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preonerational test program activities. Approval of preoperational test
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procedures rarely met the timeliness commitments made by the licensee, but the
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process improved during the assessment period. Management controls over the
preoperational test program conduct were strong and reflected thorough
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management planning with extensive coordination.
The scheduling and coordination during major activities, including primary
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system hydrostatic testing, hot functional testing, containment integrated
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leak rate testing, and integrated safeguards system testing, were excellent.
}
Generally the licensee's results evaluations for preoperational test
!
procedures were complete and of excellent quality.
The evaluations identified
test deficiencies that were suitably dispositioned and the appropriate retests
were performed.
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The licensee's program for turnover of systems, rooms, and areas from startup
to operations was excellent, as demonstrated by'the low number of punchlist
items turned over to the operations department and the small maintenance
!
backlog for the unit. One exception related to the turnover of the Emergency
Lighting System was identified.
System deficiencies were individually
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evaluated for impact on system function and operability and were tracked and
!
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worked accordingly. An inspection of system deficiencies following system
turnovers concluded that the licensee was evaluating and prioritizing the
deficiencies appropriately. The. Unit 2 startup organization effectively
.
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implemented the maintenance program quality assurance requirements.
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The combined Technical Specifications to support dual unit operations were
found to be specific, enforceable and to accurately reflect the Unit. 2 as-
built configuration. The combined Master Surveillance Test list accurately _
i
identified the Combined Technical Specifications surveillance requirements and
the respective implementing procedures. However, some minor-discrepancies
were noted among the design basis documents, the Combined Technical
Specifications and the Final Safety Analysis Report.
!
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The licensee's procedcres program was determined to fully support the
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licensing and power operation of Unit 2.
The Unit 2 plant procedure program
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scope and content were good, although additional management attention was
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needed to ensure that policies concerning procedure use were consistently
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implemented.
The biennial procedure review process was not fully implemented
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but the licensee was in the process of addressing this deficiency. An
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inspection of the-Unit 2 emergency operating procedures established that the
program scope and content were good.
However, the Fire protection Inspection
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Team and the Operational Readiness Assessment Team identified several
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deficiencies in ti.e abnormal operating procedures for Unit' 2.
The findings by
the Operational Readiness Assessment Team came after the licensee had-the
cpportunity to validate the procedures based on the previous Fire Protection
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Team findings. Additional inspection of other abnormal operating procedures
identified more deficiencies that had not been identified and corrected
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following identification of the initial deficiencies.
Staffing was sufficient to support dual unit operation. Key manager positions
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were filled with qualified, experienced personnel.
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In summary, performance in the functional area of preoperational testing /-
operational readiness was excellent. Senior management involvement was
.,
evident, lessons learned from the Unit 1 program were well incorporated and
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staffing and interdepartmental coordination were excellent. The quality of
,
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test procedures showed significant improvement over the previous asse sment
period and both the startup and operations organization execution of the test
procedures was excellent. The programs for room, area, and system turnover
were strong and resulted in hardware with minimal deficiencies being accepted
r
by operations.
Performance was only diminished slightly by repetitive
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problems in system status control and-the quality of some Unit 2 operational
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procedures.
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2.
Performance Rating
The licensee is considered to be in Performance Category 1 in this functional
area
3.
Recommendations
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None
H.
Power Ascension Testina. Unit 2
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1.
Analysis
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The evaluation of this functional area adaresses the activities related to
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Unit 2 initial startup and the power ascension testing program.
It included
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the evaluation of precritical tests, initial fuel loading, initial
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criticality, low power physics testing, and operational perforinance during -
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power ascension testing.
These areas were inspected on a routine basis by the resident inspectors and
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Region-based inspectors.
In addition, around-the-clock inspection coverage
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was-provided for significant evolutions involving initial fuel loading,
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initial criticality, and additional periods of high testing activity.
Selected startup test' procedures and activities were examined in detail to
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assess the adequacy of procedural controls, test program implementation, and
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test results evaluations.
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Effective management involvement and oversight were routinely demonstrated
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during the conduct of the startup testing program. As a result of-the
incorporation of lessons learned from preoperational testing, the_ licensee-
established a comprehensive review process to assure the validity and accuracy
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of data obtained during power ascension testing.
This process incorporated
provisions for detailed administrative and technical reviews and approvals of
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test results prior to exceeding the mode or test alateau which existed when.
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the test was performed. Corrective actions were effectively implemented as
demonstrated by the prompt identification and resolution of- test deficiencies.
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The documentation and oversight problems identified during the review of
preoperational test procedures and results were corrected.
t
Detailed self-assessments were performed by the licensee line organizations
prior to fuel load, prior to exceeding 5 percent power, and prior to exceeding
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50 percent power levels in order to provide'an assurance of operational
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readiness. These self-assessments provided meaningful feedback to senior
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management and were considered a notable strength in the licensae's approach
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toward power operations.
During the conduct of power ascension testing, the licensee's_ approach to the
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early identification and resolution of technical issues reflected a well
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developed and thorough methodology.
Identified deficiencies were properly
documented and the technical resolutions reflected conservative engineering
methodologies. Additionally, based on NRC observation of initial fuel
loading, initial criticality, low power physics testing, and power ascension
activities, it was generally concluded that the evolutions were performed in a
controlled and deliberate manner with a clear emphasis on attention to' detail
and safety.
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The enforcement history in this functional area was excellent.
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' As a result of the effective implementation of lessons learned from Unit 1,
few significant operational events occurred during initial startup testing.
The notable performance was attributable, in part, to the incorporation of a
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-comprehensive component testing program prior to the conduct of integrated
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system testing during preoperational testing.
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Operator performance was excellent during plant transients which did occur.
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Neither of the two unplanned trips were attributed to operator error.
Additionally, operator response and performance were observed during several
transients and major startup tests and a high level. of competence and plant
awareness was evident.
Excellent coordination was noted oetween operations,
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engineering, and training in preparation for and execution of th'e remote.
shutdown test. The turbine trip / loss of offsite power test was similarly well
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coordinated between operations and engineering.
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Several instances were identified that would indicate that the level of
attention to detail applied to infrequent or complex evolutions was not
correspondingly applied to routine evolutions.
For example, a valve in the
!
auxiliary feedwater system was found out of its expected position due to a
personnel error during a clearance restoration, although clearance controls
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were generally well implemented.
Another instance involved exceeding the
procedural guidance on the rate of power escalation during a power increase.
The operations shift management demonstrated very good command and control of
control room activities. Access to the control room was positively controlled
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at all times, and particularly during periods of testing or when heightened
awareness by the operators was required. Communication between control room
operators and auxiliary operators was good.
Coordination between control room
!
personnel, the Field Support Supervisor, and the auxiliary operators for
placing equipment in service was excellent. Oversight of auxiliary operator
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activities in the plant by the Field Support Supervisor was very good.
Shift turnovers were well conducted and informative regarding plant
conditions, planned activities, and administrative matters.
Excellent control
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of locked components was demonstrated.
Although ineffective control of keys
required to operate control board equipment was identified, it was promptly
addressed and corrected.
In summary, performance in the functional area of power ascension testing was
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excellent. Those portions of the program evaluated have shown strong
management involvement and oversight.
Execution of the fuel loading and
startup testing procedures has been well rehearsed, cautious and deliberate.
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Licensee self-assessments and the incorporation of lessons learned from Unit 1
experience have proven valuable.
Performance has only been diminished
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slightly by operator errors which occurred during routine evolutions.
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2.
Performance Rating
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The licensee is considered to be in Performance Category 1 in this functional
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area.
3.
Recommendations
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None
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1.
Safety Assessment / Quality Verification
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1.
Analysis
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This functional area consists of all licensee review activities associated
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with the implementation of licensee safety policies.
In addition, it includes
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licensee activities related to the resolution of safety issues, safety
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committee and self-assessment activities, and the effectiveness of the
licensee's quality verification function in identifying and correcting
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substandard or anomalous performance, in identifying precursors of potential
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problems, and in monitoring.the overall performance of the plant.
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This functional _ area was inspected on a routine basis by -the resident
inspector and on a periodic basis by Region-based specialists.
A reactive
inspection was conducted to assess repetitive temporary modification
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implementation deficiencies. The previous SALP report recommended increased
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efforts to improve the thoroughness and comprehensiveness of technical
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evaluations supporting licensing actions.
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Management oversight activities were effectively implemented.
Examples
included the internal self-assessments to determine readiness for operations
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and to proceed beyond 50 percent reactor power. Also, management oversight
efforts in the plant analysis area have provided useful information to
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prioritize resource allocation. Task teams were well utilized to provide
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comprehensive reviews of selected events.
The senior management quality __
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assurance oversight meetings provided a. comprehensive means for management to
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assess planc issues and nuclear overview department activities. The
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implementation of the Performance Enhancement Review Committee, which promptly
reviews personnel perforrance concerns, has been effective in identifying
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reasons for personnel performance problems and addressing the causes of
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personnel errors. Management involvement in the daily plan of the day
meetings was notable. Nevertheless, there were instances when management
policies were not carried out as evidenced by the performance of Unit 1
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annunciator system troubleshooting activities without appropriate
'
authorization and several power escalations at rates in excess of those
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established in approved plant procedures.
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The Station Operations Review Committee and the Operations Review Committee
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were effective.
The committee members were found to be cognizant of the plant
,
issues discussed and exhibited a questioning attitude to personnel presenting-
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issues. Concerns and followup actions identified by these committees were
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well documented.
6
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Performance by the nuclear overview department was generally very good. The
quality assurance program was effective. Some weaknesses in specific
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functional areas-were identified in the audit program.
In the radiological
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controls area, little attention was given to the auditing of the operations
and testing of the air cleaning systems and few surveillances were run on the
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liquid and gaseous effluent programs.
In the security area, the annual audit
!
of the security program was not comprehensive in scope, although it was
performance oriented and the auditors were well-_ qualified. A corrective
!
action audit was comprehensive and provided an excellent performance-based -
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assessment. A quality assurance audit of preoperational test personnel
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resulted in the early identification and resolution of training and
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qualification deficiencies.
The Independent Safety Engineering Group (ISEG) provided an excellent risk
assessment for the second refueling outage.
The assessments conducted by ISEG
and each onsite department during the Unit 2 power ascension program provided
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management with valuable and timely information concerning readiness for fuel
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loading and power ascension milestones. A corrective action inspection
'
performed late in the period identified a weakness in the ISEG procedures, in
!
that the procedures did not address requirements and responsibilities for
action, followup, verification, and possible management escalation associated-
with ISEG recommendations; hence the resolution of ISEG recommendations was
1
not always accompiished by _the established due dates.
Although management was
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provided monthly status reports of ISEG recommendations, this was not
'l
considered an effective method for resolving ISEG issues.
For example, ISEG
!
findings had identified temporary modifications implementation problems;
,
however, effective corrective actions were not taken in response to those
t
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findings until prompted by NRC.
The licensee had established a comprehensive industry operating experience
report evaluation process.
This program was generally well-implemented with
}
the appropriate safety awareness demonstrated in most cases. A notable
l
exception involved the evaluation and implementation of corrective action for
a safety injection minimum flow line. The concerns identified included the
!
evaluation due date being established after the second refueling outage, when
.;
the system was required to be operable; the requested due date was
i
subsequently exceeded; and, although the corrective action was identified and
.
the procedure revised, no measure was taken to verify that the condition did
4
not exist in the plant. Another exception concerned insufficient initial
~
actions by the licensee in response to recommended inspections on TERMI-POINT
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connections. Once prompted by NRC, effective corrective actions were
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implemented.
The licensee provided comprehensive documentation for closure of construction
deficiencies, licensee event reports, violations, deviations, inspection
!
followup items, and TMI items.
It was generally noted that generic issues
i
were appropriately addressed for both units.
,
In general, the corrective action process was well implemented. _ Plant
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personnel initiated the appropriate corrective action documents to identify
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plant, programmatic, and personnel performance deficiencies. Several
instances were identified; however, where additional management attention or
!
NRC involvement was required to ensure that applicable deficiencies were
!
evaluated through the Operations Notification and Evaluation (ONE) process.
It was.found that the review of the ONE forms by the work control review
committee was effective in providing an initial cc trebensive evaluation of
each deficiency.
However, the review committee i..;mmendations were not
l
always promptly considered by the responsible organization which allowed some
!
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deficiencies to exist for an L: tended period of time.
Although the licensee's corrective action process and nuclear overview
activities were shown to be effective, some implementation weaknesses were
i
identified.
One example involved numerous programmatic and implek,entation
problems with the temporary modification program.
It was found that plant
incident reports over a year old had not been evaluated and corrective actions
implemented.
Previous challenges to the temporary modification program
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indicated potential implementation concerns; however, trending activities were
not effective in identifying either the programmatic or implementation
problems.
'
The quality of licensee evaluations associated with ongoing Unit I licensing
actions and Unit 2 pre-licensing Final Safety Analysis Report submittals was
good.
Improvement was noted in the quality of the safety analyses and the no
significant hazards determinations prepared by the licensee to support license
amendment requests.
During this assessment period the licensee submitted its
final evaluations regarding both TMI Action Plan Item II.D.1, Performance
Testing of Relief and Safety Valves, and its dual unit station blackout
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submittal. The content of the submittals, coupled with discussions with
licensee staff, indicates that significant attention and thorough evaluation
was given to the many issues relating to these licensing actions, and
demonstrated good coordination and communication between the plant technical
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staff and the licensing staff.
Throughout the assessment period, routine public meetings were held onsite for
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the licensee to present Unit 2 status on critical path items involving
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construction, system turnover, testing, and licensing. These meetings proved
beneficial in assessing the schedule and in enabling the staff to focus
-
resources toward emergent licensing issues.
NRC concerns were factored into
the planning process and incorporated into programs and issue resolution,
where applicable.
,
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in summary, performance in the functional area of Safety Assessment / Quality
Verification has declined. Although the licensee has developed programs which
are considered superior, management has not been totally effective in
preventing recurrence of significant deficiencies and achieving timely
resolution of deficiencies identified by the ISEG or other internal
mechanisms. Strong programs have been developed for corrective actions, root
cause analysis, and performance enhancement and the quality of safety analyses
4
supporting licensing submittals has improved.
2.
Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
,
arec.
3.
Recommendations
a.
NRC Actions
Monitor implementation of the corrective action process and the resolution of
self-identified issues identified by independent assessment organizations.
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b.
Licensee Actions
'
Strengthen the implementation of the corrective action process and the
response to self-identified issues.
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V.
SUPPORTING DATA AND SUMMARIES
A.
Major Licensee Activities
1.
Major Outages
November and December 1992 - Unit 1 second refueling outage
May 1993 - early initiation of Unit 2 surveillance outage
2.
Licensing Actions
February 2, 1993 - The Unit 2 low power operating license was granted.
April 6, 1993 - The Unit 2 full power operating license was granted.
3.
License Amendments
Ten license amendments were issued during this assessment period.
B.
Direct Inspection and Review Activities
NRC inspection activity during the assessment period included 75 inspections,
including three major team inspections. Approximately 12,400 direct
inspection hours were expended, which did not include operator licensing
examinations or contractor inspection hours.
,