ML20056E517
| ML20056E517 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Monticello, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Indian Point, Wolf Creek, Cooper, Braidwood, Columbia, Brunswick, North Anna, River Bend, Comanche Peak, Quad Cities, Big Rock Point, Rancho Seco, FitzPatrick, 05000212, Trojan, Crane File:Consumers Energy icon.png |
| Issue date: | 08/31/1993 |
| From: | Israel S NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| Shared Package | |
| ML20056E458 | List: |
| References | |
| TASK-*****, TASK-AE, TASK-T93-02, TASK-T93-2 AEOD-*****, AEOD-T93-02, AEOD-T93-2, EA-91-161, EA-91-181, EA-92-034, EA-92-074, EA-92-075, EA-92-134, EA-92-211, EA-92-34, EA-92-74, EA-92-75, GL-91-18, NUDOCS 9308240165 | |
| Download: ML20056E517 (13) | |
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4 TECIINICAL REVIEW REPORT f
TARDY LICENSEE ACTIONS i-August 1993 f
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l Prepared by:
Sanford Israel r
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t Reactor Operations Analysis Branch Office for Analysis and Evaluation i
of Operational Data t
U.S. Nuclear Regulatory Commission t
9308240165 930805 PDR ADOCK 05000155.
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SUMMARY
Twenty-five violations related to tardy licensee actions were reviewed to understand the factors involved in this issue. About 40 percent of the violations resulted in civil penalties and the remainder were Ixvel IV violations. A large fraction of the violations were attributed to the failure of the licensee to take timely action on available information because it was not brought to the attention of those persons in the organization having responsibility and authority for initiating action. The remainder of the situations reflected delay in performing actions that were previously scheduled. The NRC has issued a policy statement on integrated schedules that reflects our relative concern about different types of schedule slippage. In addition, existing regulations provide a means for the NRC inspectors to monitor compliance with the requirement for timely corrective actions.
1.
INTRODUCTION Tardy licensee action refers to delayed action on safety equipment that is degraded or in need of modification to meet a licensing requirement or a licensee commitment or delay in processing industry communications. There may be delays in making operability findings on degraded equipment; there may be delays in reviewing adverse surveillance data; there may be delays in responding to NRC or industry recommendations; there may be delays in scheduling required actions; there may be postponements of scheduled actions.
I This study was prompted by the loss of five uninterruptible power supplies at Nine Mile Point Unit 2 because small batteries used to power the switchover logic during a loss of primary power were not replaced in a timely fashion (Ref.1). In this instance, the power supplies were not considered safety grade and therefore did not command the attention of more closely regulated equipment.
All safety-related equipment are covered by quality assurance (QA) programs based on 10 CFR 50, Appendix B, Section XVI, which requires that adverse conditions be corrected in a timely manner. This regulation is the basis for many enforcement actions because of chronic equipment failures (caused by deficient root-cause analyses) or unjustified delays in completing remedial actions. This study is directed at delayed actions; not deficient root-cause analyses, not deficient significant safety hazard analyses, nor deficient justifications for continued operation.
The NRC addressed " scheduling major modifications and activities initiated by both the NRC and licensees" in a policy statement in the Federal Register at page 43,886 on September 23,1992. The voluntary program is directed primarily at new initiatives contained in rules, orders, license conditions, amendments, and generic communications.
Actions arising from normal plant activities are controlled to a lesser extent by this scheduling policy. Many of the situations relevant to this study are covered by the Commission's scheduling policy.
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licensee identified five MOVs that might not be capable of performing their safety functions.
The initial assessments were reconfirmed in November 1991 and January 1992. In May 1991, a contractor notified the licensee about deficiencies in the MOV test program. These deficiencies had not been corrected by November 1991 (Insp. Rpt. 50-482/91-34, 11-22-91).
The licensee was fined $150,000.
Trojan EA 91-181 - The licensee failed to establish measures to preclude recurrence of significant conditions adverse to quality of diesel generator (DG) air start tank safety valves, other safety-related safety valves, and diaphragm valves (Insp. Rpt. 50-344/91-34, 12-17-91).
Over 3 years elapsed since the licensee committed to implement a surveillance and inspection program on air start safety valves in response to an earlier violation. Over 1S months elapsed after the licensee recognized that nozzle control rings on safety valves needed to be verified. Similar delays were noted in addressing improper modifications of diaphragm valves. The licensee was fined $100,000.
Palisades EA 92 The licensee failed to act on a contractor's report on equipment qualification nonconformances for more than 11 months (Insp. Rpt. 50-255/92-11, 6-2-92).
The licensee was fined $75,000.
Oconee EA 92-211 - The licensee failed to take timely corrective action when low service water flow was identified (Insp. Rpt. 50-269/92-24, Il-16-92). The problem existed for 3 months. The proposed fine was $100,000.
Indian Point EA 92 The licensee failed to take prompt action to identify and correct a potential overloading of safety bus (Insp. Rpt. 50-286/92-02, 2-21-92). The condition existed for 2 months. The licensee was fined $75,000.
Indian Point EA 92-134 - The licensee did not repair Class 3 service water piping according to code requirements in a timely manner (Insp. Rpt. 50-286/92-20,7-31-92). This condition persisted for 3 months. The licensee was fined $33,000.
Brunswick EA 92 The licensee failed to repair masonry walls in the DG building in a timely fashion (Insp. Rpt. 50-324/92-10,5-27-92). In 1987, the licensee discovered inappropriately modified anchor bolts. In 1990, the licensee committed to modifications to the wall anchor bolts to restore the long-term structural integrity requirements. About 15 months later, this action had still not been prioritized. The licensee was fined $225,000.
3.
DISCUSSION Based on the data searches used in this study, tardy licensee actions re not generally identifiable in LERs. All the events cited in this report resulted in regulatory violations discussed in inspection reports. Consequently, it appears that diligent investigation by NRC inspectors is the dominant process for identifying these situations and reporting them. The i
principal regulation cited in these violations is 10 CFR 50, Appendix B, Section XVI, which reads in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, 3
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SUMMARY
)
Twenty-five violations related to tardy licensee actions were reviewed to understand the factors involved in this issue. About 40 percent of the violations resulted in civil penalties and the remainder were 12 vel IV violations. A large fraction of the violations were attributed to the failure of the licensee to take timely action on available information because l
it was not brought to the attention of those persons in the organization having responsibility and authority for initiating action. The remainder of the situations reflected delay in performing actions that were previously scheduled. The NRC has issued a policy statement on integrated schedules that reflects our relative concern about different types of schedule slippage. In addition, existing regulations provide a means for the NRC inspectors to monitor compliance with the requirement for timely corrective actions 1.
INTRODUCTION i
Tardy licensee action refers to delayed action on safety equipment that is degraded or in need of modification to meet a licensing requirement or a licensee commitment or delay in processing industry communications. There may be delays in making operability findings on degraded equipment; there may be delays in reviewing adverse surveillance data; there may be delays in responding to NRC or industry recommendations; there may be delays in scheduling required actions; there may be postponements of scheduled actions.
j This study was prompted by the loss of five uninterruptible power supplies at Nine Mile Point Unit 2 because small batteries used to power the switchover logic during a loss of primary power were not replaced in a timely fashion (Ref.1). In this instance, the power supplies were not considered safety grade and therefore did not command the attention of l
more closely regulated equipment.
All safety-related equipment are covered by quality assurance (QA) programs based on 10 CFR 50, Appendix B, Section XVI, which requires that adverse conditions be corrected in a timely manner. This regulation is the basis for many enforcement actions because of chronic equipment failures (caused by deficient root-cause analyses) or unjustified delays in completing remedial actions. This study is directed at delayed actions; not deficient root-cause analyses, not deficient significant safety hazard analyses, nor deficient justifications for continued operation.
The NRC addressed " scheduling major modifications and activities initiated by both the NRC and licensees" in a policy statement in the Federal Register at page 43,886 on l
September 23,1992. The voluntary program is directed primarily at new initiatives l
contained in rules, orders, license conditions, amendments, and generic communications.
Actions arising from normal plant activities are controlled to a lesser extent by this scheduling policy. Many of the situations relevant to this study are covered by the Commission's scheduling policy.
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l Identification of degraded or inoperable equipment is another aspect of the issue of tardy licensee action. The NRC issued Generic Letter (GL) 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and Operability," November 7,1991, (Ref. 2) on guidance to NRC inspectors for monitoring licensees' interpretations of equipment operability. For the purpose of this study, the concern is the delay in making interpretations or acting on them, not flawed interpretations.
2.
OBSERVED EVENTS Inspection reports, Sequence Coding and Search System (SCSS), and Nuclear Documents System (NUDOCS) were used to identify situations involving tardy licensee action. The best source of events was inspection reports containing violations. Only violations in 1991 and 1992 were examined. Several events were identified from the Augmented Inspection Team l
(AIT) : nd Incident Investigation Team (IIT) reports starting in 1986. A search of LERs in the SCSS database was not fruitful. Violations related to tardy licensee action continued to l
be issued during the study; however, no attempt was made to incorporate these new events into this report because the underlying factors are adequately illustrated by the 25 events used l
in the study.
Below are descriptions of nine events involving tardy licensee action that resulted in civil penalties. Another 16 events having Severity Level IV Violations are presented in the Appendix.
Rancho Seco IIT - A loss of power to the integrated control system (ICS) caused a severe transient in the feedwater system that ultimately resulted in a reactor trip and an overcooling of the primary system. The vulnerability of Babcock & Wilcox Co. (B&W) plants to loss of power to the ICS was known since 1978. A generic B&W system called EFIC (emergency feedwater initiation and control) was proposed in 1980 that would correct the vulnerability to loss of ICS. Because of an NRC order, this system should have been installed at Rancho Seco in 1984 according to the inspection report following the 1985 event (NUREG-1195, "Imss of Integrated Control System Power and Overcooling Transient at Rancho Seco on December 26,1985," dated February 1986). The installation had been originally scheduled for 1983, but was delayed by the licensee. As part of the proposed "living schedule" program, Sacramento Municipal Utility District scheduled the EFIC installation for 1988.
The licensee was fined $175,000.
Fitzpatrick AIT - Radioactive material was sucked from the radwaste concentrator through the auxiliary boiler system and released to the atmosphere. The problem was attributed to inadequate procedures. Eight years earlier, the radwaste process had been changed and a commitment made to modify the operating procedures within 2 years. The radwaste supervisor prepared the original commitment, but never got around to acting on it (Insp. Rpt.
l 50-333/91-80, 5-20-91). The licensee was fined $137,500.
I Wolf Creek EA 91-161 -The licensee failed to take timely corrective action when made aware of deficiencies associated with motor-operated valves (MOVs). In February 1991, the 2
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licensee identified five MOVs that might not be capable of performing their safety functions.
The initial assessments were reconfirmed in November 1991 and January 1992. In May 1991, a contractor notified the licensee about deficiencies in the MOV test program. These deficiencies had not been corrected by November 1991 (Insp. Rpt. 50-482/91-34, 11-22-91).
The licensee was fined $150,000.
Trojan EA 91-181 - The licensee failed to establish measures to preclude recurrence of significant conditions adverse to quality of diesel generator (DG) air start tank safety valves, other safety-related safety valves, and diaphragm valves (Insp. Rpt. 50-344/91-34, 12-17-91).
Over 3 years elapsed since the licensee committed to implement a surveillance and inspection program on air start safety valves in response to an earlier violation. Over 18 months elapsed after the licensee recognized that nozzle control rings on safety valves needed to be verified. Similar delays were noted in addressing improper modifications of diaphragm valves. The licensee was fimed $100,000.
Palisades EA 92 The licensee failed to act on a contractor's report on equipment qualification nonconformances for more than 11 months (Insp. Rpt. 50-255/92-11, 6-2-92).
The licensee was fined $75,000.
i Oconee EA 92-211 - The licensee failed to take timely corrective action when low service water flow was identified (Insp. Rpt. 50-269/92-24, Il-16-92). The problem existed for 3 months. The proposed fine was $100,000.
Indian Point EA 92 The licensee failed to take prompt action to identify and correct a potential overloading of safety bus (Insp. Rpt. 50-286/92-02, 2-21-92). The condition existed for 2 months. The licensee was fined $75,000.
i Indian Point EA 92-134 - The licensee did not repair Class 3 service water piping according to code requirements in a timely manner (Insp. Rpt. 50-286/92-20,7-31-92). This condition persisted for 3 months. The licensee was fined $33,000.
Brunswick EA 92 The licensee failed to repair masonry walls in the DG building in a timely fashion (Insp. Rpt. 50-324/92-10,5-27-92). In 1987, the licensee discovered inappropriately modified anchor bolts. In 1990, the licensee committed to modifications to the wall anchor bolts to restore the long-term structural integrity requirements. About 15 months later, this action had still not been prioritized. The licensee was fined $225,000.
3.
DISCUSSION Based on the data searches used in this study, tardy licensee actions are not generally identifiable in LERs. All the events cited in this report resulted in regulatory violations discussed in inspection reports. Consequently, it appears that diligent investigation by NRC inspectors is the dominant process for identifying these situations and reporting them. The principal regulation cited in these violations is 10 CFR 50, Appendix B, Section XVI, which reads in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, 3
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1 and nonconformances are promptly identified and corrected." The opemtive word in this regulation is "promptly" which is not well defined. The inspection guidance on making operability interpretations for degraded equipment (Ref. 2) expects these findings to be made immediately and for the most marginal situations within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Commission policy on scheduling delegates responsibility to the licensee to establish a process for scheduling maintenance and other retrofit activities.
A rough examinadon of the time delays in the 25 violations indicates that 10 had delays of 0 to 6 months; 8 had delays 6 months to 1 year; and 7 had delays greater than 1 year. The distribution in delays is about the same for items identified in enforcement actions and Level IV violations with some bias towards longer delays in the items cited in the enforcement actions.
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The reasons attributed to the delays in situations identified in the enforcement actions varied.
However, it appears that no one felt he was accountable for taking action when adverse conditions were observed. The personnel performing tests were concerned about completing the tests and were not concerned about operability determinations. Onsite review committees raised issues in their deliberations that were not followed up. The maintenance manager recommended that an engineer not write a corrective action report, so the concern was lost.
There was a perception of resource limitations at the plant so a concern was not brought forward.
l 3.1 Failure to Initiate Timely Action About 60 percent of the violations were caused by the licensee failing to initiate timely action on unambiguous information available at some level within his organization because the information was not brought to the attention of a person who had responsibility and authority for initiating action. At Palisades, the licensee failed to act on a contractor's report about deficiencies in environmental qualification for at least 1I months. At Oconee, the licensee did not take action for at least 3 months after low service water flow was identified. At Indian Point, the licensee didn't take action for at least 2 months after identifying a potential overloading of a safety bus. The licensees have formal procedures for processing observed equipment deficiencies, so these violations shouldn't have occurred. In a similar fashion, the NRC has produced formal guidance for monitoring a licensee's processing of observed equipment deficiencies (Ref. 2). Thus, an accountability program for identifying these types of delays exists.
Some of the more global commitments made by the licensees to remedy failure to initiate actions on known deficiencies noted in the violations are:
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- 1) A formal process for dealing with potential design deficiencies was established to evaluate concerns...
- 2) Appropriate administrative controls will be reviewed and revised as necessary to clearly indicate that documents which originally report a problem are to be identified as design inputs in a modification package...
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- 3) Appropriate modification controls will be reviewed and revised as necessary to clearly indicate that as-found discrepant conditions are to be independently verified...
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- 4) The importance of following established administrative requirements, in particular, the requirements for submitting station deviation reports, has been discussed, and re-emphasized, with the appropriate station personnel...
- 5) During plan of the day meetings, management reemphasized the need to initiate deviation forms when failures which are abnormal / unusual occur...
- 6) The surveillance test administrative procedure has been updated to require immediate declaration ofinoperability in the event that technical specification limits are not met during testing...
- 7) A corrective action document will be generated following receipt of a contractor report or other contractor notification identifying plant deficiencies...
- 8) The president and CEO held meetings with department heads, managers, and supervisors to stress the staff responsibility for prompt identification and thorough corrective actions upon identification of potentially significant conditions...
How do the licensee personnel feel about reporting adverse conditions? In a recent audit of the corrective action program at Point Beach (Ref. 3), the NRC inspectors noted " employee attitudes toward the condition reporting system, while somewhat improved, continue to generally view the condition reporting system as a burden..." If problems are not brought to the attention of the appropriate plant personnel, they are not going to be adequately addressed. This is exemplified by the following excerpt from an inspection report on Comanche Peak (Ref. 4):
"The licensee conducted ASME Section XI testing on Train A RHR pump... Train A RHR pump was started and immediately secured due to indications of cavitation (varying motor amperage and fluctuating discharge pressure). The initial test was conducted at high flow rates and the licensee changed the procedure to reduce the system flow rate to approximately 1000 gpm and move the pump farther away from pump run-out conditions.
The inspectors were informed of the train A pump cavitation the next morning... The required net positive suction head pressure stated in the design basis documents and Final Safety Analysis Report is approximately half of what was being supplied to the pump at the time of the surveillance. Subsequent questions about the cause of the pump cavitation were not addressed and the inspectors questioned the operability of the RHR pump during accident conditions under the same flow and pressure conditions.
[ Subsequently,] System engineering, working in conjunction with operations, determined that the pump had not cavitated; however, they did conclude that the pump fluctuation had been caused by air in the RHR heat exchanger U-tubes that had been recirculated to the suction side of the pump...
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Due to early interactions between the inspectors and the licensee with respect to the i
RHR pump and system performance, it could not be determined whether the licensee's corrective action process would have adequately identified and resolved this issue without NRC involvement. The licensee's initial corrective actions to revise the surveillance procedure to decrease the pump flow rate were taken without first determining the cause for the indications of apparent pump cavitation. As a minimum, the licensee's delay in initiating a ONE form for potential cavitation is a weakness in the licensee's safety assessment and corrective action programs."
The above inspection report hints at quick " work-arounds" when problems are encountered.
Many of the licensee proposed corrective actions for the violations imply a more thorough approach to addressing problems at a plant. How best to instill a proper questioning attitude in the plant personnel is not clear. A review of the Salem ATWS event in 1983 attributed the failure to recognize the significance of the event to a lack of an " intuitively questioning attitude" on the part of the organization (Ref. 7).
3.2 Failure to Complete Scheduled Work in a Timely Manner The remaining 40 percent of the violations in this review concerned the licensee not completing a maintenance work request (20 percent) or completing a commitment (20 percent) in a timely fashion. At Fitzpatrick, the licensee committed to modify certain procedures within 2 years and still had not performed the task 8 years later. At Brunswick, the licensee committed to modifying wall anchor bolts to restore structural integrity and still had not started the job 15 months later. At Braidwood, the licensee committed to develop a i
procedure for restoration of components when completion of the maintenance action is deferred, however, no action was taken on this item for over 2 years.
As discussed in SECY 92-023, a trial of "living schedules" by selected licensees showed a wide spread in implementation. One licensee abused the process by continuously delaying certain activities (Ref. 5). In light of the trial, the Commission published a voluntary scheduling policy. The policy identifies three levels of initiated work activity. The lowest level priority coasists of license: initiatives including commitments made for LER followup.
The policy proposes no NRC oversight responsibility for items in this lowest category.
However, these types of activities would still be regulated by 10 CFR 50, Appendix B, Section XVI.
A review of reports from special maintenance inspections performed during the 1989 to 1991 indicates that most licensees have a system for prioritizing maintenance work requests.
l Generally the highest priority is given to technical specification requirements (LCOs),
j personnel safety, and support for power generation. About 25 percent of these inspection reports indicated less than satisfactory tracking of the maintenance backlog.
Discussions 4 bout deferred maintenance with several utilities indicate that each has a system for keeping track of maintenance work requests and some form of formal management review (having responsibility and authority for committing resources) for those actions greater than about 3 months old. The tracking system (maintained by a dedicated scheduling group) mixes together repair of degraded safety-related equipment, enhancement of safety-6 l
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h related equipment, and actions on nonsafety-related equipment. This mixture of work requests occurs because the licensee is concerned about his total resource management, not l
just actions on safety-related items. A review of overdue work requests at several plants l
indicated that some of the items were of a non-urgent nature and had been carried on the j
i books for several years.
l If parts are available and no engineering evaluation is required, the work requests are l
generally completed expeditiously. A problem appears to arise if parts have to be ordered or engineering gets involved. In these situations, additional depanments come into play and I
schedules get strung out accordingly. One licensee indicated that the priority of an overdue work request would sometimes be increased automatically after a certain elapsed time,.but generally there are no formal procedures for disposing of such overdue actions.
Regulatory commitments (LERs, responses to violations, NRC generic communications, etc.), which also compete for plant resources, are tracked by a separate licensing group.
This group includes processing industry experience as indicated by the River Bend violation in the Appendix. These commitments were genemlly characterized by the licensees as procedure modifications. Presumably, any commitments involving hardware modifications end up as maintenance work requests and are tracked separately. Based on discussions with several utilities, it appears that commitments do not receive the same degree of management attention that maintenance work requests do. The licensing group distributes status reports to i
the affected departments and is responsible for tracking the various items; however, no regular management meetings are scheduled to address stale commitments. The licensing group does inform the NRC if a previously promised schedule is slipped for those items having firm commitments to the NRC.
The Office of Nuclear Reactor Regulation has initiated a study to assess licensee procedures for processing NRC generic communications (Ref. 6). The results of this effort will be j
reported to the Commission as background on plant current licensing basis. This study will not examine timeliness, but rather appropriateness of responses to selected generic communications and the licensees' tracking systems to assure that the implementations are maintained over the lifetime of the plants.
Based on conversations with several licensees, each utility may have several problem tracking systems that overlap and generate a plethora of reports that are widely distributed within the organization. These reports may be informative, but generally do not require formal response by the recipient. Different scheduling groups are responsible for the different tracking systems. While these groups may have responsibility for meeting schedules (management by objective), they have no authority for redirecting resources, except through jawboning the line depanments. As noted above, upper management generally meets regularly to address stale maintenance work requests, however, no similar management action ensures timely completion of commitments made to the NRC.
Similar observations about deferred maintenance were made in several recent SALP reports at different plants. The following excerpts are from these repons:
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l The licensee documented and evaluated discrepant conditions via one of several corrective action documents. However, the disposition of corrective action was not timely in at least four areas. As a result of these findings, the licensee consolidated their various corrective action processes into a single problem report. While the problem report has ensured consistent identification and operability and reportability reviews of plant concerns, the process has not established sufficient responsibility and accountability to ensure consistent timely closure ofissues.
I Line management did not consistently implement corrective actions for known problems I
or consistently respond to QA audit findings. Additionally, senior management, by i
l themselves or with the assistance of independent oversight groups, did not exercise sufficient oversight to ensure that previously identified problems were being effectively j
resolved. QA management did not notify senior management of significant audit findings or the lack of timely resolution of problems.
j Licensee corporate management maintained direct involvement with plant status by l
monthly meetings. The meetings were beneficial in ensuring that issues were i
forwarded to the appropriate level of management and insuring that assignees of recommended actions were held accountable for their responses. At the end of the previous SALP period, there were no open findings older than 180 days, while at the end of the current assessment period, there were no open audit findings older than 60 l_
days. One of the 1992 tasks involved developing and implementing a new consolidated reporting system to provide a single reporting process by which conditions of concern to the plant staff may be identified, evaluated, analyzed, and corrected.
One example included management's decision not to remove debris from the condenser during the 192 refueling outage, which contributed to clogging of the hotwell pump strainers and condensate system transients during the subsequent startup.
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t These comments come from NRC personnel who observe the licensees on a daily basis.
Their focus on reducing reporting systems and involving upper management m overseemg f
I plant operations is noteworthy.
At one plant, the backlog of stale work requests was reduced from about 500 to 200 in anticipation of an INPO inspection. The management dedicated resources to accomplishing this task presumably to get below INPO's threshold on stale work requests. According to a j
survey by the NRC inspector, these work items were completed in an appropriate manner in spite of the crash program. Timely action can be achieved if desired. At another plant, a negative diagnostic evaluation prompted the licensee to revamp his surveillance scheduling and require adherence to scheduled milestones. After an initial break-in period of about 1 year, the disciplined approach was so successful that other related maintenance activities were being treated in a similar fashion. The general expectation of what could be done on a i
timely basis increased along with the morale of the staff who became more proactive instead of reactive.
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t 4.
CONCLUSIONS Unacceptable delays in maintenance or other remedial actions continue to occur at the nuclear plants as shown by the violations cited by the NRC inspectors. The significance of these situations is demonstrated by the large fraction of these violations resulting in enforcement actions against the licensees. The licensees know they are responsible for timely corrective actions and generally appear to have administrative procedures for addressing this effort although accountability may be deficient in some circumstances.
Similarly, the NRC has regulations requiring timely corrective actions by the licensees and these are being enforced (at least one plant in each region in the past 2 years).
Consequently, no new generic initiatives are warranted at this time.
5.
REFERENCES 1.
U.S. Nuclear Regulatory Commission, " Transformer Failure and Common-Mode Imss of Instrument Power at Nine Mile Point Unit 2 on August 13,1991," NUREG-1455, October 1991.
2.
J. Partlow, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and Operability" Generic Ixtter 91-18, November 7,1991.
- 3.,
U.S. Nuclear Regulatory Commission, Inspection Report 266/93-06, Point Beach, May 5,1993.
4.
U.S. Nuclear Regulatory Commission, Inspection Report 445/92-59, Comanche Peak, February 3,1993.
5.
Memorandum from J. Taylor (NRC) to the Commissioners, " Final Policy Statement on Integrated Schedules," SECY 92-023, January 21, 1992.
6.
R. Assa (NRC) to D. Farrar (CEC), "Special Audit of Control Process for Commitments that Affect the Current Licensing Basis at Braidwood," April 23,1993.
7.
U.S. Nuclear Regulatory Commission, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant," NUREG-1000, Vol.1, April 1983.
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APPENDIX EVENTS HAVING LEVEL IV VIOLATIONS Nine Mile AIT - Loss of one line of offsite power during refueling led to loss of annunciators in the control room. One of the two sources of power to the control room annunciators lost power and was unable to transfer to another source due to an internal fault.
The fault had been identified 14 days before the event, had been assigned a "C" priority (action within seven days), and had been scheduled for work 2 days after the event (Insp.
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Rpt. 50-410/92-81, 4-10-92).
Salem AIT - A turbine overspeed event occurred that resulted in destruction of the low pressure turbine and main generator (Nov. 9,1991). The accident was attributable, in part, i
to failure of solenoid valves to open. Potentially, this event was preventable. In an LER, the licensee committed to replace the solenoid valves in Unit 2 after discovering on Sept.10, 1990 that similar components in Unit I were defective. An opponunity was available in May 1991 to effect replacement. However, the work was deferred to the January 1992 outage (Insp. Rpt. 50-311/91-81, 1-7-92).
River Bend - Approximately 47 NRC Information Notices and 18 potentially reportable conditions were identified in which information responses from responsible department heads were neither provided to Nuclear Licensing nor were alternative response due dates established. Due dates were exceeded by 30 days to 2 years (Insp. Rpt. 50-458/92-09, 4-23-92).
1 Cooper - The licensee measured low battery cell voltage and failed to complete an operability review in a timely fashion and failed to take immediate corrective action. The delay was about I month. Additionally, no action was taken to prevent recurrence (Insp.
Rpt. 50-298/92-04, 5-21-92).
IIaddam Neck - Between April 1989 and January 1992, licensee actions to effect long term l
corrective actions for repetitive failures of isolation valves were untimely and incomplete.
Specifically, the maintenance procedure for valve disassembly and reassembly was not written for 17 months after determination that the subject valves required special instructions and a thorough evaluation of the valve's design and material acceptability was not performed until late 1991 (Insp. Rpt. 50-213/92-05, 5-19-92).
Brunswick Deviation - The licensee reply to a notice of violation dated April 11, 1991 f
stated that " Improved guidance with respect to determination and conduct of post maintenance testing requirements will be developed by August 19, 1991." These actions had j
not been completed by March 12,1992 (Insp. Rpt. 50-324/92-04, 4-27-92).
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Three Mile-The licensee failed to promptly restore tubing to Seismic I requirements. The i
gauges were changed in January 1990, with the existing mounting hardware unable to attach to the new gauges. On January 8,1992, licensee management became aware of the missing j
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e i,
supports and failed to act on it until notified by NRC on January 23,1992 (Insp. Rpt. 50-289/92-30, 3-3-92).
WNP A maintenance work request initiated on November 18,1990 was not processed in a timely fashion. The MWR documented that the air pressure to one train of DG air start motors was 50 psi above the design rating of the motors (Insp. Rpt. 50-397/91-24, 9-12-91).
IIatch - The licensee determined that failures of the control room environmental control to meet single failure criteria had not been promptly identified. The most recent failure existed since initial operation (Insp. Rpt. 50-321/91-20, 8-26-91).
1 North Anna - A valve failure in February 1991 was not properly evaluated in accordance with the licensee's administrative procedures and another valve failure occurred in July 1991 (Insp. Rpt. 50-338/91-14, 8-16-91).
Big Rock - The licensee did not adequately correct two valve failures in 1989 and they recurred in 1990 (Insp. Rpt. 50-155/92-10, 6-5-92). The corrective action was to remove the Garlock packing by November 1989, but it was not implemented. In August 1990, one of the affected valves failed its stroke test sd the incorrect packing was found in the other valve in November 1990.
Browns Ferry - The licensee failed to take timely corrective action related to problems with radiation monitors (Insp. Rpt. 50-259, 8-5-91). Work order to correct known pro'olem was canceled inappropriately about 5 months before error was discovered by NRC inspector.
Monticello - The licensee failed to take prompt action to correct a cable separation problem (Insp. Rpt. 50-263/91-11, 7-24-91). The licensee originally noted problem on April 27, 1991 and committed to correct the situation in May 28,1991 LER. The action did not occur until after June 10, 1991.
Quad Cities - The licensee failed to replace relays with higher capacity coils in a timely fashion (Insp. Rpt. 50-254/91-11, 6-21-91). The licensee recommended replacing relays in 1981 because of high failure rates, but this was not implemented. In 1989, the licensee recommended using higher voltage coils. In 1991, the licensee replaced only five of fifty coils during a refueling outage.
Comanche Peak - The licensee failed to followup on problems observed in the bearing packing of a motor driven auxiliary feedwater pump (Insp. Rpt. 50-445/92-24, 8-12-92).
The licensee failed to follow internal procedures requiring an Operations Notification and Evaluation form be initiated whenever adverse conditions are observed. This situation existed for about 9 months.
Braidwood - The licensee failed to implement the corrective action committed to in an LER (Insp. Rpt. 50-456/92025, 2-4-93). The commitment in September 1990 was "a formal 1
methodology will be developed to facilitate restoration of components to operable status where completion of the work package must be deferred until a later date." This item remained open for over 2 years.
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1 supports and failed to act on it until notified by NRC on January 23,1992 (Insp. Rpt. 50-289/92-30, 3-3-92).
WNP A maintenance work request initiated on November 18,1990 was not processed in a timely fashion. The MWR documented that the air pressure to one train of DG air start motors was 50 psi above the design rating of the motors (Insp. Rpt. 50-397/91-24, 9-12-91).
IIatch - The licensee determined that failures of the control room environmental control to l
meet single failure criteria had not been pron >ptly identified. The most recent failure existed i
since initial operation (Insp. Rpt. 50-321/91-20, 8-26-91).
North Anna - A valve failure in February 1991 was not properly evaluated in accordance j
with the licensee's administrative procedures and another valve failure occurred in July 1991 (Insp. Rpt. 50-338/91-14, 8-16-91).
Big Rock - The licensee did not adequately correct two valve failures in 1989 and they recurred in 1990 (Insp. Rpt. 50-155/92-10, 6-5-92). The corrective action was to remove the Garlock packing by November 1989, but it was not implemented. In August 1990, one of the affected valves failed its stroke test and the incorrect packing was found in the other valve in November 1990.
Browns Ferry - The licensee failed to take timely corrective action related to problems with radiation monitors (Insp. Rpt. 50-259, 8-5-91). Work order to correct known problem was canceled inappropriately about 5 months before error was discovered by NRC inspector.
Monticello - The licensee failed to take prompt action to correct a cable separation problem f
(Insp. Rpt. 50-263/91-11, 7-24-91). The licensee originally noted problem on April 27, 1991 and committed to correct the situation in May 28, 1991 LER. The action did not occur until after June 10, 1991.
Quad Cities - The licensee failed to replace relays with higher capacity coils in a timely fashion (Insp. Rpt. 50-254/91-11, 6-21-91). The licensee recommended replacing relays in 1981 because of high failure rates, but this was not implemented. In 1989, the licensee recommended using higher voltage coils. In 1991, the licensee replaced only five of fifty l
coils during a refueling outage.
l l
Comanche Peak - The licensee failed to followup on problems observed in the bearing packing of a motor driven auxiliary feedwater pump (Insp. Rpt. 50-445/92-24, 8-12-92).
i The licensee failed to follow internal procedures requiring an Operations Notification and i
Evaluation form be initiated whenever adverse conditions are observed. This situation existed for about 9 months.
4 i
Braidwood - The licensec failed to implement the corrective action committed to in an LER (Insp. Rpt. 50-456/92025, 2-4-93). The commitment in September 1990 was "a formal methodology will be developed to facilitate restoration of components to operable status where completion of the work package must be deferred until a later date." This item
~
remained open for over 2 years.
A-2 I
!