ML20056F970
| ML20056F970 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/26/1993 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| EA-93-137, NUDOCS 9309010106 | |
| Download: ML20056F970 (103) | |
Text
UNITED STATES 1
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4 NUCLEAR REGULATORY COMMISSION i
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8 611 RYAN PLAZA DRIVE. SUITE 400 o
k AR LINGTON. T EXAS 76011-8064 AUG 261993 Docket:
50-298 License: DPR-46 EA 93-137 Nebraska Public Power District ATTN:
Guy R. Horn, Vice President, Nuclear P.O. Box 499 Columbus, Nebraska 68602-0499
SUBJECT:
AUGUST 13, 1993, ENFORCEMENT CONFERENCE MEETING
SUMMARY
This refers to the enforcement conference conducted on August 13, 1993, at the Region IV office in Arlington Texas, concerning activities authorized by NRC License DPR-46 for the Cooper Nuclear Station. The meeting was attended by t W e on the attached Attendance List. The subjects discussed at this meeting are described in the enclosed Meeting Summary.
It is our opinion that this meeting was beneficial and has provided a better understanding of the apparent violations identified in NRC Inspection Report 50-298/93-17 and your corrective actions. During the enforcement conference, the NRC staff identified cuestions which required additional review by your staff.
It is our understanding that a written response to resolve eacn of the questions will be provided by August 30, 1993.
Any enforcement action taken will be addressed in separate correspondence.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
Should you nave any questions concerning this natter, we will be pleased to discuss them with you.
Sincereiy,
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bL A. Bill Beach, Director Division of Reactor Projects
Enclosure:
Meeting Sumary w/ attachments 9309010106 930826 PDR ADDCK 05000298 p
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F Nebraska Public Power District l cc w/ enclosure:
j Nebraska Public Power District ATTN:
G. D. Watson, General Counsel P.O. Box 499 Columbus, Nebraska 68602-0499 l
i Cooper Nuclear Station ATTN:
John M. Meacham, Site Manager l
P.O. Box 98 Brownville, Nebraska 68321 Nebraska Department of Environmental l
Control ATTN: Randolph Wood, Director P.O. Box 98922 Lincoln, Nebraska 68509-8922 Nemaha County Board of Commissioners ATTN: Richard Moody, Chairman Nemaha County Courthouse -
1824 N Street Auburn, Nebraska 68305 Nebraska Department of Healtn ATTN: Harold Borchert, Director Division of Radiological Health 301 Centennial Mall, South-P.O. Box 95007 Lincoln, Nebraska 68509-5007 Kansas Radiation Control Program Director i
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I' Nebraska Puclic Power District,
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-bcc to DMB (IE45)s g bec distric. cy RIV:
J. L. Milhoan Resident Inspector Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNB5 4503 MIS System DRSS-FIPS Section Chief (DRP/TSS)
Project Engineer (DRP/C)
RIV File Sr. Resloent Inspector - River Bend Sr. Resicent Inspector - Fort Calnoun W. L. Brown, RC G. F. Sanoorn, EO J. Liecercan, OE, MS: 7-H-5 i
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i MEETING
SUMMARY
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Licensee:
Nebraska Public Power District (NPPD)
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i Facility:
Cooper Nuclear Station j
i License No.: DPR-46 l
i Decket No.:
50-298 l
Subject:
Enforcement Conference (50-298/93-17) i On August 13, 1993, representatives of NPPD met with Region IV, Office of Nuclear Reactor Regulation, and Office of Enforcement personnel in Arlington, l
Texas, to discuss the apparent violations identified in NRC Inspection i
Report 50-298/93-17. The conference was held at the request of Region IV.
The licensee presented a summary of the causes for the apparent violations and its corrective actions.
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The attendance list and licensee presentation are attached to this summary.
i Attachments:
1.
Attendance List l
2.
Licensee Presentation (NRC distribution only)-
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I ATTACHMENT 1 I
ATTENDANCE LIST l
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Attendance at the enforcement conference with NRC and NPPD on August 13, 1993:
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NPPD J
H. Parris, Vice President, Production
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G. Horn, Nuclear Power Group Manager J. Meacham, Site Manager
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R. Gardner, Plant Manager j
G. E. Smith, Quality Assurance (QA) Manager G. R. Smith, Nuclear Licensing and Safety Manager V. Wolstenholm, Division Manager, QA K. Walden, Manager, Nuclear Configuration R. Johnson, Member of Board of Directors J
D. Weed, Member of Board of Directors i
WINSTON & STRAWN i
T. Poindexter, Attorney j
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NRC l
t J. Milhoan, Regional Administrator i
S. Collins, Director, Division of Reactor Safety l
A. Beach, Team Manager, Quad Cities Diagnostic Evaluation Team l
A. Howell, Acting Deputy Director, Division of Reactor Projects (DRP) l E. Collins, Project Engineer, DRP P. Harrell, Chief, Technical Support Staff, DRP K. Connaughton, Project Manager W. Walker, Resident Inspector, DRP l
J. Medoff, Chemical Engineer W. Sifre, Reactor Engineer, Technical Support Staff, DRP R. Kopriva, Senior Resident Inspector, DRP t
l G. Sanborn, Enforcement Officer l
W. Jones, Project Engineer, DRP j
J. Wilcox, Team Leader, Office of Nuclear Reactor Regulation l
L. Coblenz, Enforcement Specialist, Office of Enforcement (via telecon) l W. Brown, Regional Counsel I
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i Nebraska Public Power District l l-t l
bec to DMB (IE45) i bec distrib. by RIV:
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J. L. Milhoan Resident Inspector J
Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503 l
l MIS System DRSS-FIPS-1 l
Section Chief (DRP/TSS)
Project Engineer (DRP/C) j RIV File Sr. Resident Inspector - River Bend i
Sr. Resident Inspector - Fort Calhoun W. L. Brown, RC G. F. Sanborn, EO J. Lieberman, OE, MS: 7-H-5 i
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u NE_BRASKA PU_BLIC POWER DISTRICT NUCLEAR RE_G_ULA TORY COMMISSLON REGION IV i
ENFuRCEMENT CONFERENCE l
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l AUGUST 13,1993 e
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AGENDA introductions H. Parris Overview G. Horn Assessment ofIssues e
Corrective Action Overview J. Meacham o
Corrective Action Self-Assessment G. Smith Enforcement issue Investigation K. Walden Performance Assessment J. Meacham o
Overali Conclusions /
Program Enhancements J. Meacham Enforcement issues e
Discussion of Apparent Violations R. Gardner Broad Actions To Prevent Recurrence G. Horn l
Closing Remarks H. Parris H
I
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OVERVIEW DISCUSSIONS WILL ADDRESS, A T A MINIMUM, THE FOLLOWING CONCERNS:
o ADEQUACY OF THE CORRECTIVE ACTION PROGRAM PROBLEM IDENTIFICA TION /A NAL YSIS/ RESOL UTION PROGRAM CONTENT WORKER UNDERSTANDING AND COMMUNICA TION OF EXPECTA TIONS o
CUL TURE RIGOR APPLIED BY PERSONNEL WHEN CONDUCTING ACTIVITIES EMPLO YEE MINDSET WHEN RESOL VING PROBLEMS MANAGEMENT OVERSIGHT / PERSONNEL ACCOUNTABILITY o
INDIVIDUAL ENFORCEMENTISSUES, INCLUDING:
ADEQUA C Y OF INSERVICE INSPECTION PROGRAM RELEVANCE OF CORRECTIVE ACTION VIOLA TIONS TO O VERALL CORRECTIVE ACTION PROGRAM DEFICIENCIES FAILURE TO FOLLOW /INADEQUA TE PROCEDURES TECHNICAL SPECIFICA TION VIOLA TIONS, MANY OF WHICH RESUL TED FROM THE ABOVE DEFICIENCIES H
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_O VERVIEW i
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NOTWITHSTANDING DISAGREEMENT WITH A
FEW OF THE APPARENT VIOLA TIONS, THE NRC'S MESSAGE HAS BEEN RECEIVED, UNDERSTOOD, APPROPRIATE ACTIONS TAKEN O
PLANS FOR RESOL VING THESE BROAD CONCERNS WILL BE PRO VIDED A T THE END OF THE PRESENTA TION I
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'i Assessment ofissues Corrective Action Overview
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u CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOGL PURPOSE o
CNS ESTABLISHED CAPOG TO ENSURE THAT PROBLEMS RELA TED TO NUCLEAR SAFETY ARE:
PROMPTL Y IDENTIFIED, PROPERL Y EVALUATED REGARDING ACTUAL OR POTENTIAL SIGNIFICANCE, 1
EFFECTIVELY COMMUNICATED TO APPROPRIATE PERSONNEL, AND AGGRESSIVELY RESOLVED WITH RIGOR COMMENSURATE WITH SAFETY SIGNIFICANCE o
AND, TO PRO VIDE AN O VERVIEW FUNCTION FOR CORRESPONDENCE SUBMITTED TO THE NRC TO ENSURE COMPLETENESS AND ACCURACY o
ESTABLISHED APRIL 21,1993, FOR SIX MONTHS 1
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r CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOG)
COMPOSITION o
THREE SENIOR PERSONNEL DEDICA TED FULL-TIME TO CAPOG AND REPORTING TO SITE MANAGER o
HIGHL Y EXPERIENCED, DIVERSE BACKGROUNDS:
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C.M. ESTES, P.E. (NPPD):
18 YRS COMMERCIAL NUCLEAR EXPERIENCE (COOPER, WOLF CREEK, COMANCHE PEAK; ALSO, SRO)
S.M. PETERSON, P.E. (NPPD):
27 YRS DESIGN & POWER ENGINEERING,12 YRS COMMERCIAL NUCLEAR (COOPER, FT. CALHOUN, FT. ST. VRAIN)
R.L.
- SANCHEZ, P.E.
(S& W):
27 YRS NUCLEAR EXPERIENCE, 18 YRS COMMERCIAL (COOPER, FT. ST.
VRAIN, FT. CALHOUN, RANCHO SECO, PRAIRIE IS., COMANCHE PEAK, SOUTH TEXAS) 1 M
O O
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O CORRECTIVE ACTION PROGRAM O VERVIEW GROUP (_CAPOG)
_ COMPOSITION (_ CONT'D) o EACH MEMBER FOCUSES ON A DIFFERENT ASPECT OF OPERA TION SANCHEZ:
ENGINEERING AND RADIA TION CONTROL PETERSON: MAINTENANCE ESTES:
OPERA TIONS AND INSTRUMENTA TION & CONTROLS I
H
m CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOGL
_ GENERAL ACTIVITIES TO DA TE o
REVIEW TWO-YEAR HISTORY OF CORRECTIVE ACTIONS PROGRAM DOCUMENTA TION TO ENSURE THA T SAFETY CONCERNS HA VE BEEN ADEQUA TEL Y ADDRESSED OR ARE BEING AGGRESSIVEL Y PURSUED NCRS DRS (SINCE 10/92)
OPERABILITY DETERMINA TIONS OPERABILITY EVALUA TIONS RADIOL OGICAL SAFETY INCIDENT REPORTS MAINTENANCE WORK REQUESTS ENGINEERING WORK REQUESTS SURVEILLANCE TESTS o
REVIEW CURRENTL Y-GENERA TED VERSIONS OF ABOVE DOCUMENTS H
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CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOG)
GENERAL ACTIVITIES TO DA TE_(CONT'DJ o
REVIEW CORRESPONDENCE TO NRC FOR COMPLETENESS AND ACCURACY INSPECTION REPORT RESPONSES LERS NOTICES OF VIOLA TION GENCRIC COMMUNICA TIONS o
IDENTIFY POTENTIAL SAFETY AND CULTURE PROBLEMS THROUGH INTERVIEWS OF PLANT PERSONNEL o
CHANGE CORRECTIVE ACTION PROGRAM " CULTURE" THROUGH INTERACTION AND ASSISTANCE H
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CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOG)
S2_ECIFIC ACTIVITIES TO DATE E
o REVIEW PAST DOCUMENTA TION (SOME NOS. APPROXIMA TED) 10,350 MWRS 5,840 PM ITEMS WORKED 700 COMPLETED, CURRENT, SURVEILLANCES 450 COMPLETED SURVEILLANCES FROM THIS OUTAGE 830 SURVEILLANCE, NUCLEAR PERFORMANCE AND I&C PROCEDURES 170 ODS AND OES~
350 NCRS, OPEN AND CLOSED 300 DRS, OPEN AND CLOSED 350 EWRS, OPEN AND CLOSED 10 RSIRS 70 INSPECTION REPORTS AND RESPONSES 28 GENERIC LETTER RESPONSES 6 NRC BULLETIN RESPONSES o
ONGOING REVIEWS OF CURRENT DOCUMENTATION N
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v CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPO_G)
_ SPECIFIC ACTIVITIES TO DA TE_[_C_ONT'D) o INTERVIEW STA TION OPERA TION, MAINTENANCE, ENGINEERING, AND RADIOLOGICAL PERSONNEL TO ENSURE THA TKNOWN WEAKNESSES WHICHMA Y PRESENT SAFETY CONCERNS HA VE BEEN ADDRESSED, l.E., NO SKELETONS IN CLOSET o
DISCUSSION SESSIONS WITH STATION MANAGEMENT AND OTHER STATION PERSONNEL TO ENSURE THAT THEY ARE COGNIZANT OF THE CURRENT EXPECTATIONS FOR EFFECTIVENESS, CULTURE, ACCOUNTABILITY, AND MIND SET o
TEACH THE PROPER CULTURE BY HELPING PLANT LINE PERSONNEL RESOLVE PROBLEMS, SHO WING ??EM HOW TO USE THE PROGRAM, AND INVOL VING THEM IN THE PROCESS.
INVOLVEMENT AT PRE-APPROVAL STAGE ENSURES JOB IS DONE RIGHT THE FIRST TIME N
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U CORRECTIVE ACTION PROGRAM QVERVIEW GROUP (CAPO_GL SPECIFIC ACTIVITIES TO DA TE (CONT'DJ o
REVIEW HP LOGS FOR ABNORMALITIES, FOLLOW-UP RESOLUTION o
SITIN ON ROUTINE MEETINGS, E.G., SORC, TO MONITOR EVALUA TIONS o
MAINTAIN AN OPEN DOOR POLICY H
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4-CORRECTIVE ACTION PROGRAM O VEBVIEW GROUP (CAP _0_G)
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CAPOG CONFIRMED THA T CURRENT CORRECTIVE ACTION PROGRAM CAPTURES AND RESOL VES MAJOR CONCERNS o
O VER 300 ISSUES IDENTIFIED: NONE RESUL TED IN LERS MOSTISSUES CAMEFROM CONCERNS VOICED DURINGINTERVIEWS. COULD NOT HA VE BEEN IDENTIFIED BY TRADITIONAL AUDIT PROCESS RELA TIVEL Y FEW ISSUES FROM DOCUMENT REVIEWS INDICA TES SOME RELUCTANCE TO COME FORWARD WITH PROBLEMS AND A LA CK OF COMMUNICA TION B Y MANA GEMENTRA THER THAN INADEQUA TE RESOLUTION OFIDENTIFIED PROBLEMS o
95 ISSUES IDENTIFIED FOR PRE-STARTUP RESOLUTION BG
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l CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOG)
BESUL TS OF ACTIVITIES (CONT'D) o MOST "INTERVIEWISSUES"INVOL VED FAILURE TO COMMUNICA TE A BASIS FOR THE CORRECTIVE ACTIONS TAKEN INTERVIEWEE DID NOT THINK' RESOLUTION WAS CORRECT OR WAS NOT INFORMED OF RESOLUTION MOST ITEMS WERE FOUND TO HA VE ADEQUA TE, BUT NOT VISIBLE, RESOLUTION ISSUE WAS RESOL VED WHEN BASIS WAS REVIEWED WITH INTERVIEWEE N
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CORRECTIVE ACTION PROGRAM OVERVIEW GRO_UP (_CAPO_GL lLESUL TS_OF ACTIVITIES (CONT'D]
o REVIEW OF HP LOGS FOR DURATION OF OUTAGE IDENTIFIED 51 POTENTIAL ISSUES ALL WERE VERIFIED TO FALL BELOW RSIR THRESHOLD ABOUT 10 %
WERE DISPOSITIONED BY LOWER-LEVEL METHOD (E. G.,
CONTAMINA TION REPORT, LETTER TO SUPERVISOR)
DISPOSITION OF REMAINDER BEING DOCUMENTED DUE TO CAPOG REVIEW RE-EMPHASIZES NEED FOR A LOWER THRESHOLD SYSTEM M
CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPO_GL BESML TS OF ACTIVITIES (CONT'D) o INCREASING TREND FOR CORRECTIVE ACTION ITEMS INDICATES THAT PAST CUL TURE OF "WHY THIS ISN'T AN NCR?"IS BEING REPLA CED WITH "COULD THIS BE AN NCR?"
CYCLE NCRS DRS 12 ( 6/88-6/89) 206 (18/MO) 13 ( 6/89 - 5/90) 164 (16/MO) 14 ( 5/90- 12/91) 212 (12/MO) 15 (12/91-4/93) 208 (14/MO) 147 (10/MO)
(4/93 TO DATE) 133 (33/MO) 259 (65/MO) 1993 OUTAGE (4 MOS) 148 (37/MO) 274 (68/MO) o NUMBER OF OUTAGE-RELA TED NCRS HAS INCREASED FROM 59 (LAST OUTAGE)
TO 148 (THIS OUTAGE) o INCREASED USE OFNCRS AND DRS IN THIS OUTA GE REFLECTS, INPART EFFORTS OF CAPOG AND ACCEPTANCE OF DR PROGRAM.
PLANT PERSONNEL ARE BECOMING INCREASINGLY AWARE THAT MANAGEMENT SUPPORTS A SAFETY FIRST A TTITUDE BG
g CORRECTIVE ACTION PROGRAM OVERVIEW GROUP (CAPOGL BE_S_UL.TS OF ACTIVITIES (CONT'D_)
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O THER INDICA TIONS THA T CUL TURE IS CHANGING:
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MANAGEMENT IS EMPHASIZING ANALYSIS WHEN DECIDING WHAT NEEDS i
CORRECTIVE ACTION PAST:
MWR WAS OK PRESENT:
USE NCR OR DR TO FIND ROOT CAUSE, EXTENT OF CONDITION, EFFECTIVE CORRECTIVE ACTION MANAGEMENT IS REEMPHASIZING A "FIX IT RIGHT THE FIRST TIME" A TTITUDE EXAMPLE:
RECENT CORRECTIVE ACTION FOR 4160 V CIRCUIT BREAKER CONTACTS o
TO MINIMlZE "KNOWN BUT UNREPORTED" PROBLEMS, CAPOG'S ADVERTISED OPEN DOOR POLICY EMPHASIZES MANAGEMENT'S RECEPTIVENESS TO SAFETY CONCERNS H
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_ A IND_EPEND_ENT AS_SES_SMENT O_E_ CAP _O_G Q
CONCLUSIONS (JUNE 8,1993 REPORT) o DIRECT AND FREQUENTINTERFACE BY QA WITH CAPOG o
CAPOG IS:
EFFECTIVEL Y FULFILLING ITS INTENT ROUTINEL Y VERIFYING THA TPROBLEMS RELA TED TO NUCLEAR SAFETY ARE PROMPTL Y IDENTIFIED, PROPERL Y EVALUA TED REGARDING SIGNIFICANCE, CORRECTL Y COMMUNICA TED TO THE APPROPRIA TE PERSONNEL, AGGRESSIVELY RESOLVING ISSUES WITH RIGOR COMMENSURATE WITH SAFETY SIGNIFICANCE N
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_O_UTS!D_E AS_SESTSMENT OF CAPOG OBJECTIVES ANSWER THE FOLLOWING QUESTIONS:
o HAS CAPOG PROVIDED AN ADEQUATE SAFETY NET FOR THE CURRENT CORRECTIVE ACTION PROGRAM?
ARE ACTIVITIES EFFECTIVE FROM A SHORT AND LONG-TERM PERSPECTIVE?
O WHAT IS THE CAUSE OF THE RECENT APPARENT INCREASE IN NON-CONFORMANCE REPORTS?
o ADEQUACY OF SCOPE AND CONTENT OF CURRENT CAPOG EFFORTS?
o HOW CAN CORRECTIVE ACTION PROGRAM IMPROVEMENTS BE VERIFIED IN THE FUTURE (E. G., PERFORMANCE INDICA TORS)?
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-_UTSIDE AS_S_E_SSMENT OF CAPOG O
CONCLUSIONS o
CAPOG HAS BEEN EFFECTIVE AS A SAFETY NET, ANAL YZING PAST AND PRESENT PRACTICES, RAISING ISSUES TO MANAGEMENT ATTENTION, AND ENSURING EFFECTIVE AND TIMEL Y RESOLUTION DEMONSTRA TING TO PLANTPERSONNEL MANA GEMENT'S EXPECTA TION OFA SAFETY FIRST AND FIX IT RIGHT THE FIRST TIME CUL TURE TEACHING PLANT PERSONNEL HOW TO PRACTICE THA T CUL TURE MONITORING PRESENT CORRECTIVE ACTIONS PRACTICES FOR EFFECTIVENESS FEEDING BACK LESSONS LEARNED INTO THE PROGRAM AS A BASIS FOR PERMANENT IMPROVEMENTS o
THE RECENT INCREASE IN NON-CONFORMANCE REPORTS APPEARS TO BE DUE TO INCREASED USE OF THE CORRECTIVE ACTION PROGRAM o
CAPOG SCOPE APPEARS TO BE ADEQUA TE FOR ITS INTENDED PURPOSE o
CORRECTIVE ACTION PROGRAM IMPROVEMENTS SHOULD BE MONITORED THROUGH PERFORMANCE INDICA TORS, PERSONNEL FEEDBACK, AND ADJUSTMENTS TO THE PROGRAM AS NECESSARY H
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Assessment ofissues Corrective Action Self-Assessment
CORRECTIVE ACTION PROGRAM SELF-AS_SE_S_SMENT GROUP SCOPE EVALUA TE:
o MANAGEMENT'S EFFECTIVENESS IN DIRECTING, SUPPORTING, AND MONITORING THE CORRECTIVE ACTION PROGRAM O
CORRECTIVE ACTION PROGRAM CONTENT AND METHOD o
CORRECTIVE ACTION PROGRAM IMPLEMENTA TION o
CORRECTIVE ACTION PROGRAM OVERALL EFFECTIVENESS H
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_CAPSAG CONCLUSIONS _
P_ORITIVE o
CAP PROCESS SATISFIES 10 C.F.R. PART 50, APPENDIX B EFFECTIVENESS OF IMPLEMENTA TION MUST BE IMPRO VED o
WORKERS BELIEVE THA T ONGOING EFFORTS ARE IMPROVING THE PROGRAM o
OPERA TIONS AND ENGINEERING PERSONNEL ARE FAMILIAR WITH THE PROCESS AND NOT HESITANT TO WRITE NCRs AND DRs IMPRO VED UNDERSTANDING MAY BE APPROPRIA TE IN SOME CIRCUMSTANCES o
GOOD TEAMWORK BETWEEN OPS, I&C AND SYSTEMS ENGINEERING H
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CAPSAG CONCLUSIONS _
NEGA TIVES MANA GEMENT'S EXPECTA TIONS FOR THE CORRECTIVE A CTION PROGRAM WERE NOT WELL COMMUNICATED OR UNDERSTOOD BY WORKING LEVEL PERSONNEL TRAINING ON THE CAP FOR NUCLEAR POWER GROUP PERSONNEL NEEDS IMPROVEMENT THE CAP IS NOT USER FRIENDLY DUE TO THE MULTIPLICITY AND COMPLEXITY OF PROGRAMS AND PROCESSES INVOLVED INCONSISTENT PROGRAM ENTRY AND APPLICA TION SIGNIFICANT OVERVIEW NECESSARY t
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CAPSAG CONCLUSIONS NEGA TIVES (CONT'D) o TREND REPORTS PROVIDED BY TECHNICAL STAFF AND QUALITY ASSURANCE ARE NOT USED OR ARE OF LIMITED USEFULNESS TO MANAGEMENT FOR MONITORING CAP STATUS TREND REPORTS DO NOT CAPTURE ALL THRESHOLDS OF CORRECTIVE ACTION ISSUES o
THE CAP HAS NOT BEEN EFFECTIVE IN CAPTURING PERSONNEL PERFORMANCE ERRORS o
THE THRESHOLD FOR REWORK WHICH SHOULD BEIDENTIFIED WITHIN THE CAP NEEDS TO BE DEFINED o
EXISTING OVERVIEW MECHANISMS MA Y REDUCEINDIVIDUAL AND SUPERVISORY ACCOUNTABILITY AS WELL AS COMPENSATE FOR INTERDEPARTMENTAL COMMUNICATIONS DEFICIENCIES H
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u ENFORCEMENT IS_S_U_E INVESTIGA TION TEAM P_URPOSE TO PERFORM AN INDEPENDENT ASSESSMENT OF ENFORCEMENT ISSUES RAISED IN NRC INSPECTION REPORT 93-17 OBJECTIVES DETERMINE:
o VALIDITY OF THE APPARENT VIOLATION o
ROOT CAUSE OF THE VIOLA TION IF VAllD o
EXTENT OF CONDITION o
ADEQUACY OF PROPOSED CORRECTIVE ACTIONS (INTERIM, LONG-TERM) o RECOMMEND ADDITIONAL ACTIONS TO PREVENT RECURRENCE M
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ENFORCEMENT IS_S_U_E INVESTIGA TION TEAM TEAM MEMBERS o
MANAGER, NUCLEAR CONFIGURATION o
LEAD MECHANICAL ENGINEER o
QUALITY ASSURANCE MANAGER - CNS o
ENGINEERING PROGRAMS SUPERVISOR o
NUCLEAR TRAINING SUPERVISOR o
NUCLEAR REGULA TION EXPERT H
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v ENFORCEMENT IS_Si_lE INVESTIGA TION TEAM METHODOLOGY o
REVIEW OF RELEVANT DOCUMENTS o
CANDID INTERVIEWS OF COGNIZANT PERSONNEL, INCLUDING SENIOR SITE MANAGEMENT o
GENERAL FEEDBACK TO MANAGEMENT N
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o ENFORCEMENT ISSU_E INVESTIGA TION TEAM
_ GENERAL CONCLU_SIONE.-
THESE CONCLUSIONS AND RECOMMENDATIONS ARE ADDRESSING THE APPARENT VIOLA TIONS IDENTIFIED IN IR 93-17.
THESE CONCLUSIONS ARE NOT PORTRAYED AS BEING REPRESENTATIVE OF OR WIDESPREAD THROUGHOUT THE CORRECTIVE ACTION PROGRAM BUT WERE BELIEVED TO CONTRIBUTE TO SOME OF THE VIOLATIONS.
CRITERION V VIOLATIONS REGARDING FAILURES TO IMPLEMENT OR FOLLOW PROCEDURES LACK OF PERSONAL ACCOUNTABILITY INFREQUENT DISCIPLINARY ACTION WITH RESPECT TO IR 93-17 CRITERION XVI VIOLATIONS REGARDING FAILURES TO IDENTIFY AND CORRECT PROBLEMS.
WILLINGNESS TO CORRECT DEFICIENCIES WITHOUT DOCUMENTING THE PROBLEM IN THE CORRECTIVE ACTION PROGRAM ACCEPTANCE OF SOLVING PROBLEMS WITHOUT ENTRY INTO THE CAP -
THRESHOLDISSUE BG
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U ENFORCEMENT IS_S_UE INVESTIGA TION TEAM GENERAL CONCLUSIONS (CONT'D)
THE CAP IS TO RIGID CAUSING ENTRY INTO THE SYSTEM TO BE DIFFICUL T LACK OF PROBLEM OWNERSHIP PERCEPTION THA T THE CAPIS AN NRC PROGRAM TO CAPTURE REGULA TORY CONCERNS (ONL Y)
CORRECTIVE ACTION DOCUMENTS ARE BAD - LERS, NCRS, RSIRS - ARE COUNTED BY NRC, INPO, EVEN THE DISTRICT PERCEPTION OF NEGA TIVE RESPONSE TO CONCERNS PRODUCTION PRESSURES (ISOLATED CASE)
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_ GENERAL RECOMMENDATIONS:
o CORRECTIVE ACTION PROGRAM REDEFINE AND COMMUNICATE THE GOALS OF THE CAP IMPROVE EASE OF ENTRY INTO THE SYSTEM IMPROVE FLEXIBILITY OF THE SYSTEM o
CULTURAL EMPHASIZE AND IMPLEMENT TEAM BUILDING EMPO WERMENT/O WNERSHIP/A CCOUNTABILITY MANAGEMENT A TTENTION TO AND INVOL VEMENT IN THE CAP M
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COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT o
PROJECTINITIATED IN OCTOBER 1992 o
REPORT PUBLISHED JANUARY 1993 o
RECOMMENDATIONS AREBEING APPLIED TOINTEGRATED CORRECTIVE ACTION PROGRAM IMPROVEMENT EFFORTS o
RECOMMENDATIONS ARE RESPONSIVE TO RESOLVING CULTURE CONCERNS M
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o COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT REASONS FOR REQUESTING THIS ASSESSMENT o
CONSISTENCY IN PERFORMANCE LACKING o
NRC ASSESSMENTS NOTED A DECLINEIN PERFORMANCE o
MANAGEMENT DESIRE TO TURN AROUND DECLINE IN PERFORMANCE EURPO_SE o
IDENTIFY ROOT CAUSES OF THE LACK OF UNIFORM PERFORMANCE o
IDENTIFY CHANGES NEEDED TO RAISE LEVELS OF PERFORMANCE UP TO MANAGEMENT'S EXPECTATIONS o
PROVIDE RECOMMENDATIONS TO EFFECT THESE CHANGES H
r-v m
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COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT METHODOLOGY o
SYSTEMATIC DATA COLLECTION, DATA ANALYSIS, DATA VALIDATION AND BARRIER ANALYSIS ROOT CAUSE DETERMINATION M
~
COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT o
BARRIERS THA TPRECLUDE A LACK OF UNDERSTANDING AND ACCOUNTABILITY INTEGRATED GOALS AND OBJECTIVES EFFECTIVE AND OPEN COMMUNICATIONS COMMON UNDERSTANDING OF ROLES EFFECTIVE AND EFFICIENT WORK PROCESSES CONSISTENT PERFORMANCE FEEDBACK SYSTEM APPROPRIATE PERSONNEL SKILLS AND QUALIFICATIONS H
COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT FINDING _S o
INADEQUATE SYSTEM FOR ESTABLISHING AND MEASURING SITE-WIDE GOALS AND OBJECTIVES o
LACK OF AN EFFECTIVE PARTICIPA TIVE MANAGEMENT ENVIRONMENT o
INEFFECTIVE MANAGEMENT COMMUNICATIONS, ESPECIALLY AT THE MIDDLE MANAGEMENT LEVEL M
O
~
u u
u u
v COOPER NUCLEAR STA TION PERFORMANCE ASSESSMENT PROJECT RECOMMENDA TIONS o
ESTABLISH INTEGRATED GOALS AND OBJECTIVES o
COMMUNICA TEMANA GEMENTFUNCTIONS, RESPONSIBILITIES, AND A UTHORITIES o
IMPROVE MANAGEMENT COMMUNICATIONS o
CONDUCT PARTICIPATIVE MANAGEMENT TRAINING o
IMPROVE MANAGEMENT'S EFFECTIVENESS IN THE FIELD o
ASSURE UNIFORM IMPLEMENTA TION OF THE DISCIPLINARY PROCESS o
CONSOLIDATE SELECTED ORGANIZATIONAL FUNCTIONS H
i v
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mecna sh v
en uE ssm If ar og u
t or nP e /s msn so ei m.
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_OVERALL ASSES _SMENT CONCLU_SIONS-o SIGNIFICANT REVISION OF THE CURRENT CORRECTIVE ACTION PROGRAM IS NECESSARY CUMBERSOME PROCESS INHIBITS USE COMFORT LEVEL FOR RAISING DEFICIENCIES MUST BE IMPROVED DEFICIENCY iDENTIFICA TION PROCESS NEEDS FURTHER IMPROVEMENT THRESHOLD DEFICIENCIES REMAIN, BUT HAVE BEEN IMPROVED (DR AND CAPOG PROCESS)
COMPREHENSIVENESS OF CORRECTIVE ACTION ASSESSMENTS MUST BE IMPROVED PROCESS IS TOO RESOURCE INTENSIVE A CCOUNTABILITY MUSTIMPRO VE TO IMPLEMENT THE PROGRAM PROPERL Y PERFORMANCEINDICA TORS SHOULD BE UTILIZED TO VERIFY EFFECTIVENESS OF CORRECTIVE ACTION PROGRAM M
o o
o o
o o
o 0
0 0
0
_OVERALL A_SSES_SMENT CONCLUSIONS o
MANA GEMENT'S EXPECTA TIONS HAD NO T BEEN EFFECTIVEL Y COMMUNICA TED OR ENFORCED o
INTERIM MEASURES SHOULD ENSURE THAT SAFETY ISSUES ARE PROMPTLY RAISED AND ADEQUATELY RESOLVED o
HESITANCY TO TAKE OWNERSHIP OF PROBLEMS H
O O
O O
O O
O O
O O
O APPARENT WOLA TION 9317-04 (8 OF 8)
DESCRIPTION:
TWO WORKERS ENTERED THE RADIOLOGICALLY CONTROLLED AREA WITHOUT SIGNING THE SPECIAL WORK PERMIT. (CRITERION V)
NPPD POSITION:
ADMIT
_ SAFETY / REGULATORY SIGNIFICANCE _
e MINIMAL WORKERS DID NOT RECEIVE ANY SIGNIFICANT DOSES H
g g
g g
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g g
g APPARENT VIOLA TION 9377-04 (8 OF 8). CONT'D-OTHER CONSIDERATIONS:-
DEFICIENCY WAS SELFIDENTIFIED, DOCUMENTED AND TRACKED THROUGH TO APPROPRIATE RESOLUTION CAUSES_
e LACK OF SUPERVISORY CONTROL OF CONTRACT WORKERS e
PERSONNEL ERROR INADEQUA TE HP GUIDANCE H
g y
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.. y g _.
g g
APPARENT VIOLA TION 9317-04 (8 OF 8). CONT'D CORRECTIVE ACTIONS:
SHORT TERM:
e REMEDIAL TRAINING FOR CONTRACT PERSONNEL e
REARRANGED THE DRYWELL CONTROL POINT AND COUNSELED CONTROL POINT PERSONNEL e
COUNSELED CNS MECHANIC (CUPERVISOR)
LONG TERM:
INCLUDE EVENTIN INDUSTRY EVENTS TRAINING FOR CNS MAINTENANCE AND HP PERSONNEL EVALUA TE THE BALANCE BETWEEN HP CONTROL RESPONSIBILITIES AND TRAINING COMPREHENSION EXPECTATIONS FOR CONTRACT WORKERS H
g g
g APPARENT VIOLA TION 9317-05 (1 OF 1)
DESCRIPTION:
REVERSE DIRECTION TESTING OF CONTAINMENT ISOLATION VALVES WITHOUT DETERMINING THA T RESULTS WERE EQUIVALENT OR CONSERVATIVE IS AN APPARENT VIOLATION. (APPENDIX J TO 10CFR50)
NPPD POSITION:
NPPD ACTIONS SHOULD NOT BE CONSIDERED A VIOLATION OF REGULA TORY REQUIREMENTS BASIS FOR POSITION:
e NRC ACCEPTED JUSTIFICATION FOR REVERSE DIRECTION TESTING FOR THESE VAL VES IN INSPECTION REPORT 80-01 M
w N
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+-
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o b
u u
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'o o
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o APPARENT VIOLA TION 9317-05 (1 OF JL CONT'D OTHER CONSIDERA TIONS:
e SELF-IDENTIFICATION OFISSUE e
NOTWITHSTANDING DENIAL OF VIOLATION, EXTENSIVE ACTIONS TAKEN, INCLUDING CHANGE TO TESTING METHODOLOGY ACTIONS:
SHORT TERM:
e ACCIDENT DIRECTION TESTING FOR VALVES THAT CAN BE SO TESTED e
JUSTIFICATION FOR REVERSE TESTING OF CERTAIN VALVES AN EXEMPTION UNTIL THE 1994 OUTAGE HAS BEEN REQUESTED H
g g_
__y__
APPARENT VIOLA TION 9317-O_5 (1 OF 1), CONT'D ACTIONS (CONT'D):
LONG TERM:
ADDITIONAL JUSTIFICATION / EVALUATION OR MODIFICATIONS FOR VAL VES THA T CANNOT BE SO TESTED ENHANCE 4PPENDIX J PROGRAM AND BASIS DOCUMENT e
H
u v
v v
v v
v v
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u-j APPARENT VIOLA TION 9317-08 DESCRIPTION:
FAILURE TO COMPLY WITH THE REQUIREMENT TO INCLUDE THE REACTOR EQUIPMENT COOLING (REC) AND SERVICE WATER (SW) SYSTEMS IN THEINSERVICE INSPECTION (ISI) PROGRAM SINCE FEBRUARY 12, 1916, WHEN THE REVISION TO 10CFR50.55a(g) WENT INTO EFFECT. (10CFR50.55afg)(1),10CFR50.55a(g)(4),
NPPD POSITION:
ADMIT M
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sEEABENT VIOLA TION 9_317-O_8_(1 O_F JL C_ONT'D_
SAFETY /REGDLA TORY SIGNIFICANCE; o
MINIMAL THE AUGMENTED SERVICE WA TER ISI PROGRAM (PER GENERIC LETTER 89-
- 13) PROVIDES EQUIVALENT INSPECTION EXCEPT FOR THE 10 YEAR HYDRO AND CERTAIN SUPPORT STRUCTURE INSPECTIONS THE REACTOR EQUIPMENT COOLING SYSTEM ALSO IS INCLUDED IN THE AUGMENTED ISI PROGRAM ERROSION CORROSION INSPECTIONS PROVIDE INFORMA TION THA T IS EQUIVALENT OR BETTER THAN THE 10 YEAR HYDRO NRC HAS REVIEWED THE AUGMENTED SERVICE WATER PROGRAM AND CONCLUDED THATIT WAS ACCEPTABLE TO ENSURE SYSTEM INTEGRITY --
THEREFORE, REGULA TORY SIGNIFICANCE ALSO IS MINIMAL M
~
~
O O
O O
O O
O O
O O
O APPARENT 1/lOLA TION 9317-08 (1 OF 1). CONT'D OTHER CONSIDERATIONS:
CNS WAS NOT ORIGINALLY LICENSED AS A SAFETY CLASS 1, 2, AND 3 PLANT e
WHEN CNS CONVERTED ITS CLASSIFICATIONS TO 50.55a(g) TERMINOLOGY, THERE WERE SEVERAL ITERATIONS BETWEEN NPPD AND THE NRC REGARDING WHA T SHOULD BE INCLUDED e
NPPD ERRONEOUSL Y BELIEVED THA T THE NRC WAS A WARE THA T THE REC AND SW SYSTEMS WERE NOTINCLUDED IN THE 50.55afg) PROGRAMS NPPD DID NOT BELIEVE THATIT WAS UNUSUAL THAT A " SAFETY-RELATED" SYSTEM WOULD NOT BE INCLUDED IN THE 50.55a(g) PROGRAM SINCE NRC HAD AGREED THAT OTHER " SAFETY-RELATED" SYSTEMS ALSO DID NOT NEED TO BE INC!.UDED
g g
g g_Y_Y-APPARENT VIOLA TION 9317-08 (1 OF 1). CONT'D ROOT CAUSES:
FAILURE TO FULLY ADDRESS THEIMPACT OF THE CHANGE TO 10CFR50.55a(g)
FROM A LICENSING STANDPOINT CORRECTIVE ACTIONS:
SHORT TERM:
e EVALUATED THE OPERABILITY OF THE SWS AND REC SYSTEM AND CONCLUDED THA T ABSENCE OF HYDRO AND CERTAIN SUPPORT INSPECTIONS DID NOT HA VE AN ADVERSE IMPACT ON THE ABILITY TO DETERMINE IF THE SYSTEMS WERE CAPABLE OF PERFORMING THEIR INTENDED SAFETY FUNCTIONS HYDRO WAS SUCCESSFULL Y PERFORMED ON PORTIONS OF THE SWS (FOR OTHER REASONS) e COMPARISON OF CODE REQUIREMENTS TO EXISTING INSPECTION REQUIREMENTS TO BETTER DETERMINE SIGNIFICANCE OF NOT PERFORMING ALL ASME XI TESTING H
o e
e u
u u
o u
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o APPARENT VIO_LA TION 937 7-08 (1 OF TL CONT'D_
CORRECTIVE ACTIONS; LONG TERM:
NPPD HAS COMMITTED TO INCLUDE THE SWS AND REC IN THE 50.55a(g)
PROGRAM e
NRC HAS CONCURRED THATINTERIM OPERABILITY OF THE SYSTEM IS NOT IN QUESTION BASED ON 50.55a(g) REQUIREMENTS e
EVALUATE OTHER SAFETY RELATED NON-CODE CLASS 1, 2, OR 3 SYSTEMS FOR POTENTIAL RECLASSIFICA TION (FOR TEST AND INSPECTION ONL Y; DOES NOT AFFECT DESIGN CLASSIFICA TION) AS CLASS 2 OR CLASS 3 AND INCLUSION IN THE SECTION XIISI AND IST PROGRAMS FOR THE PURPOSES OFINSPECTION AND TESTING
7.
l Broad Actions To Prevent Recurrence
~
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I o
o o
o o
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O O
O o
BROAD ACTIONS TO PREVENT RECURRENCE CORRECTIVE ACTION PROGRAM o
COMMUNICATION AT ALL LEVELS WILL BEIMPROVED BY:
ENSURING THA TALL PERSONNEL RECEIVE THE SAME MESSA GE B Y UTILIZING SMALL GROUP / SENIOR MANAGEMENT MEETINGS, FEEDBACK MECHANISMS o
OWNERSHIP AND ACCOUNTABILITY WILL BE CLARIFIED AND ENFORCED AREAS OF RESPONSIBILITY WILL BE CLEARLY DESIGNATED UNSATISFACTORY PERFORMANCE IN THE AREAS OF RESPONSIBILITY WILL BE ADDRESSED o
CUMBERSOME PROCESS WILL BE STREAMLINED COMFORT LEVEL FOR RAISING DEFICIENCIES MUST BE IMPROVED STEPS WILL BE TAKEN TO CLEARLY' DEMONSTRATE THAT MANAGEMENT WANTS WORKERS TO RAISE CONCERNS, NOTWITHSTANDING THEPOTENTIAL IMPACT ON SCHEDULE H
O O
O O
O O
O O
O O
O 1
_ ROAD ACTIONS TO PREVENT RECURRENCE B
CORRECTIVE ACTION PROGRAM (CON'T) o CORRECTIVE ACTION ASSESSMENTS WILL BE ENHANCED TO REQUIRE A BROADER PERSPECTIVE WHEN RESOL VING ISSUES o
QA WILL VISIT OTHER NUCLEAR FACILITIES WITH PROVEN CORRECTIVE ACTION PROGRAMS TO UPGRADE ITS EFFECTIVENESS WHEN AUDITING THE CNS CAP o
PERFORMANCE INDICATORS WILL BE UTILIZED INDICA TORS WILL BE DEVELOPED AND MONITORED PERIODICALLY TO DETERMINE EFFECTIVENESS OF IMPROVEMENT EFFORTS AND NEED FOR MODIFICA TION OF APPROACH H
o e
o o
a o
o o
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o BROAD ACTIO_N.S TO_ PREVENT RECURRENCE CULTURE o
CNS PERSONNEL ARE GOOD PEOPLE, AND WILL DO THE RIGHT THING WHEN PROPERL Y MANAGED o
ONGOING CLARIFICA TION OF PERFORMANCE OBJECTIVES AND IMPLEMENTA TION OFREMEDIA TION AND/OR DISCIPLINE POLICIES WHEN OBJECTIVES ARE NO TMET o
PERIODIC CHECKS WITH PLANT WORKERS TO ENSURE THAT MANAGEMENT EXPECTATIONS ARE UNDERSTOOD BY ALL LEVELS o
SMALL GROUP MEETINGS WILL BE HELD BETWEEN SENIOR NPG MANAGERS EMPLOYEES TO PERSONALLY ENSURE THAT EXPECTATIONS AND ASSOCIATED MOTIVES ARE CLEARL Y UNDERSTOOD OVERVIEW o
AN ORGANIZA TION ASSESSMENT IS IN PROGRESS RESUL TANT CHANGES WILL ENSURE PROPER OVERVIEW OF THE CORRECTIVE ACTION PROGRAM AND FEEDBACK TO MANAGEMENT BG
____._ g._._... _
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Proceduralized Deficiency Other l
Reporting / Resolution Methods Non-Proceduralized Threshold Assessment Methods Safety Related Structure, System, i
Component Significant Technical Specification I------------
-i I
Safety Concern l
l SORC-Approved Procedure 4
General 4
Worker Observation NCR DR RSlR MWR EWR OD OE QA NPPD E included in threshold 8 Available, but underutilized
'o o
o o
o o
o o
o o
.o-1 i
1 i
5 9
i 1
Enforcement issues Discussion of Apparent Violations I
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DISCUSSION OF APPARENT VIOLATIONS o
NPPD HAS CLEARL Y RECOGNIZED THE SIGNIFICANCE OF THESE FINDINGS TAKEN AS A WHOLE o
MOST OF THE VIOLATIONS, TAKEN INDEPENDENTLY, HAVE MINIMAL SAFETY SIGNIFICANCE o
DUE TO NATURE OF AND NUMBER OF VIOLATION EXAMPLES, REGULATORY SIGNIFICANCE EXISTS o
SOME OF THE SAME ISSUES HA VE BEEN CITED IN DIFFERENT WA YS o
DUE TO EXTENT OF NPPD EFFORTS, ENFORCEMENT DISCRETION SHOULD BE CONSIDERED FOR SEVERAL CIRCUMSTANCES Be
r r-u-o wm u-v-
o-APPARENT VIOLA TION 9317-01 (1 OF 51 DESCRIPTION:
FAILURE TO IDENTIFY AND CORRECT THE MISSING LOOP SEAL AFTER A SECONDARY CONTAINMENT TEST FAILURE ON MARCH 8, AND PRIOR TO DECLARING THE SECONDARY CONTAINMENT OPERABLE, AND FAILURE TO RESOLVE TEST CONFIGURATION DEFICIENCIES PRIOR TO DECLARING THE SECONDARY CONTAINMENT OPERABLE. (CRITERION XVI)
NPPD POSITION:
ADMIT H
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APPARENT '/lOLA TION 9317-01 (1 OF 5) CONT'D SAFETY /REGULA TORY SIGNIFICANCE:
MINIMAL -- AL THOUGH SECONDARY CONTAINMENT INTEGRITY MA Y HAVE BEEN DEGRADED, SUBSEQUENT TESTING VERIFIED SECONDARY CONTAINMENT OPERABILITY WITH THE MISSING LOOP SEAL (MARCH 11,1993 TEST)
CAUSES:
INADEQUA TE PROCEDURE UNTIMELY RESPONSE TO AN ANOMALY (NO IMMEDIATE ACTION TAKEN ON RADWASTE EFFECT ON REACTOR BUILDING PRESSURE)
INADEQUA TE SECONDARY CONTAINMENT DESIGN BASIS DEFINITION HISTORICAL ACCEPTANCE OF TEST FAILURES, TROUBLESHOOTING e
METHODOLOGY, AND DOCUMENTATION OF THESEITEMS B5
u o
e u
o u
o u
o o
o APPARENT VIOLA Tl_ON 9317-01 (1 OF SL CONT'D CORRECTIVE ACTIONS:
SHORT TERM:
e INSTALLED LOOP SEAL e
PROCEDURES MODIFIED TO MINIMlZE EFFECTS OF ADJOINING / ADJACENT H&V ON SECONDARY CONTAINMENT LEAK RATE TESTING e
CORRECTIVE ACTION OVERVIEW GROUP ESTABLISHED LONG TERM IMPROVE CORRECTIVE ACTION PROGRAM TO CLARIFY USE e
REGARDING TROUBLESHOOTING TESTS CLEARLY DEFINE DESIGN BASIS FOR SYSTEM AND EVALUATE e
RESULTS FOR ADEQUACY / EFFECTIVENESS OF SURVEILLANCE PROCEDURES M
. _ T_...
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m-i APPARENT VIOLA TION 9317-01 (2 OF 5)
DESCRIPTION:
FAILURE TO TAKE ACTIONS TO PREVENT RECURRENCE OF SETPOINT DRIFT PROBLEMS WITH REACTOR SAFETY RELIEF VALVES. (CRITERION XVI) l l
H
o o
o o
o o
o o
o o
o APPARENT VIO_LA TION 9317-01 (2 OF SL CONT'D_
NPPD POSITION:.
NPPD ACTIONS SHOULD NOT BE CONSIDERED A VIOLATION OF REGULA TORY REQUIREMENTS e
THIS IS A RECOGNIZED GENERIC ISSUE (B-55) THA T IS CURRENTL Y BEING RESOL VED ON AN INDUSTRY-WIDE BASIS THE DISTRICT HAS TAKEN APPROPRIATE ACTIONS PENDING A GENERIC RESOLUTION VAL VES INSPECTED A T EACH OUTAGE BWROG RECENTL Y RECOMMENDED INSTALLA TION OF Pl.A TINUM SEATS -- THE DISTRICT PURCHASED THE COMPONENTS AS SOON AS THEY WERE MADE AVAILABIE AND BEFORE MOST OF THE REST OFINDUSTRY (CURRENT PLANS TO INSTALL MODIFIED VALVES NEXT OUTAGE)
H
u e
u u
u e
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APPARENT VIO_LA TION 9_317-01 (2 OF 5). CONT'D_
_ SAFETY /REGULA TORY SIGNIFICANCE PENDING FINAL RESOLUTION OF THIS ISSUE, ITIS NOT A SIGNIFICANT SAFETY CONCERN GE HAS EVALUA TED THE LIMITING OVERPRESSURE EVENT ASSUMING ONE SRV LIFTS A T 1250 PSIG AND THE REMA!NDER LIFT A T 1210 PSIG, THE EVALUA TED VESSEL PRESSURE IS WELL BELOW ASME LIMIT
.OTHER CONSIDERATIONS:
e THE PERFORMANCE OF THE CNS SRV'S IS COMPARABLE TO INDUSTRY AVERAGE l
e DISTRICT IDENTIFIED THIS PENDING MA TTER TO THE NRC BG
O O
O O
O o
o O
O O
O APPARENT VIOLA TION 9317-01 (2 OF SL CONT'L2 ACTIONS TAKEN:
SHORT TERM:
e GENERATED / APPROVED AN OPERABILITY EVALUATION FOR CYCLE 16, WITH THE CURRENT VALVES INSTALLED e
CNS WILL INSTALL DURING THE NEXT REFUELING OUTAGE (OR SOONER), GE/BWROG DEVELOPED PLATINUM / STELLITE PILOT DISC (S) IN FOUR VALVES; EVALUATE PERFORMANCE DURING CYCLE 17 REVISED TECH SPECS TO CHANGE THE SETPOINT TOLERANCE FROM 1% TO 3% (CONSISTEli~ WITH VENDOR RECOMMENDA TION)
H
o e
u
~-~ o o
o o
o o
o o
APPARENT VLOJA TION 9317-01 (2 OF SL CONT'D-ACTIONS TAKEN:
LONG TERM:
EVALUA TE OTHER BWROG RECOMMENDA TIONS e
PERFORM A TREND ANALYSIS e
CONTINUE TO EVALUATE THE ADEQUACY OF AND IMPLEMENT BWROG CORRECTIVE ACTIONS e
SAFETY IMPACY OF THE SETPOINT DRIFT WILL BE ADDRESSED BY THE DISTRICT EACH OUTAGE N
APPARENT VIOLA TION 9317-01 (3 OF 5)
DESCRIPTION:
THE FAILURE TO IMPLE*AENT CORRECTIVE ACTIONS TO RESOLVE THE DEGRADATION OF THL )lESEL GENERATOR FUEL Oll. (CRITERION XVI)
NPPD POSITION:
ADMIT SAFETY / REG _ULATORY SIGNIFICANCE:_
MINIMAL OPERABILITY DETERMINATION 92-074 CONCLUDED (AND WAS CONFIRMED BY AN INDUSTRY EXPERT) THA T NEITHER THE FUEL SUPPLY SYSTEM (FILTERS AND STRAINERS) NOR THE DIESEL ENGINES WERE ADVERSELY AFFECTED BY THE PARTICULATE H
g g
APPARENT VIOLA TION 9377-01 (3 OF 5). CONT'D
_OTHER CONSIDERATIONS 1 THE SOURCE OF THE PARTICULATE (EXCESSIVE ADDITIVE) HAD BEEN ELIMINATED PRIOR TO THE 11-16-92 TEST.
THIS ACTION ALONE WAS ADEQUATE TO REDUCE PARTICULATE TO AN ACCEPTABLE LEVEL WITHOUT FURTHER CORRECTIVE ACTION CONTRARY TO THEINSPECTION REPORT, THE OPERABILITY DETERMINATION DID ADDRESS THE EFFECT OF PARTICULATE ON THE DG FUEL OIL FILTERS H
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o uT APPARENT WOLA TION 9377-01 (3 OF SL CONT'D CAUSES1 e
PERSONNEL ERROR A DEFICIENCY REPORT WAS NOT GENERATED WHEN REQUIRED PROCEDURE DID NOT ADEQUA TEL Y DESCRIBE THE BASIS FOR THE PARTICULA TE LIMIT; PARTICULATE LIMITS SHOULD NOT HAVE BEEN ADDED AS A TESTED PARAMETER IN THE PROCEDURE WITHOUT PROVIDING ACCEPTABLE BASES FOR EXCEEDING A NON-ESSENTIAL PARAMETER H
e 1
e e
e e
e o
o o
o APPARENT VIOLA TION 9317-01 (3 OF SL CONT'D CORRECTIVE ACTIONS:
SHORT TERM:
ADDITIONAL FILTERING 6.3.12.3 HAS BEEN REVISED TO CLARIFY POTENTIAL IMPACT OF e
PARTICULA TES OBTAINED THE SERVICES OF A FUEL OIL EXPERT TO SUPPORT MAINTENANCE OFFUEL OIL QUAllTY LONG TERM:
RECENTLY RECEIVED AN APPROVED LICENSE AMENDMENT TO e
INCLUDE FUEL OIL PARTICULATE AND WATER CONTENTIN QUALITY REQUIREMENTS H
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APPARENT '/lOLA TION 9317-01 (4 OF 5)
DESCRIPTION:
FAILURE TO PROMPTL Y CORRECT LEAKING SHUTDOWN COOLING SUCTION ISOLATION VALVES. (CRITERION XVI)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE:
e NO ACTUAL SAFETY SIGNIFICANCE SYSTEM RELIEF VALVES WERE OPERABLE AND WOULD HAVE PREVENTED SYSTEM OVERPRESSURE SUBSEQUENT LEAK RATE TESTING DEMONSTRATED THE ADEQUACY OF THE PENETRATION N
u v
u u
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APPARENT VIOLA TION 9317-01 (4 OF 5). CONT'D CAU_ SED:
e FAILURE TO INITIA7E A CORRECTIVE ACTION DOCUMENT FOR THE PROBLEM, RESULTING IN NO CLEAR, DOCUMENTED JUSTIFICA TION FOR DECISIONS TO NOT FIX VAL VES EARLIER e
THE OPERABILITY DETERMINA TION DID NOT ADDRESS CONTAINMENT ISOLA TION FUNCTION l
M
u o
u o
o o
o o
u u
u APPARENT VIOLA TION 9_317-01 (4 OF SL C_ONT'D CORRECTIVE ACTIONS:
SHORT TERM:
e REPAIR OF RHR 17 AND 18; SUBSEQUENT TESTING SA TISFACTORY e
PERFORM LLRTIN ACCIDENT DIRECTION e
PERFORM PlV TESTING IN ACCIDENT DIRECTION LONG TERM:
DEVELOP FORMAL PROGRAM FOR PlV TESTING (INCLUDING TRENDING AND MAINTENANCE)
IMPROVE CORRECTIVE ACTION PROGRAM TO BETTER ENSURE e
THA T DEFICIENCIES OF THIS TYPE ARE EASIL Y ENTERED INTO THE CORRECTIVE ACTION SYSTEM N
r v
v v
v v
v v
v v
u r
APPARENT VIOLA TION 9317-01 (4 OF 5). CONT'D CORRE_CTIVE ACTIONS CONT'D:
e DEVELOP PROCESSES FOR ENSURING DOCUMENTING OF PROBLEMS AND THEIR RESOLUTIONS / DECISIONS FOR ACTIONS EVALUATE THE ADEQUACY OF THE ALARM PROCEDURE FOR PS-118 H
o
~~
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o o
o o
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APPARENT VIOLA TION 9377-01 (5 OF 5J
_D_ESCRIPTION:
LICENSEE INSPECTION IDENTIFIED BLISTERING OF THE TANK INTERIOR COA TING OF BOTH EMERGENCY CONDENSA TE STORAGE TANKS.
THIS CONDIlION ADVERSE TO QUALITY WAS NOT DOCUMENTED IN A DEFICIENCY OR NONCONFORMANCE REPORT.
THE FAILURE TO IDENTIFY AND PROMPTLY CORRECT A CONDITION ADVERSE TO QUALITY IS ANOTHER EXAMPLE OF AN APPARENT VIOLA TION OF CRITERION XVI.
EVENT DA TE 3-19-93. (CRITERION XVI)
NPPD POSITION:
ADMIT M
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.g g
g APPARENT VIOLA TION 9317-01 (5 OF SL CONT'D SAFETY /REGULA TORY SJ_GNIFICANCh MINIMAL ACTUAL SAFETY SIGNIFICANCE SINCE COATING WAS STILL INTACT CA USES_;.
e INAPPROPRIATE AND UNTIMELY CHARACTERIZATION OF ABNORMAL CONDITION e
FAILURE TO DOCUMENT RESULTS OFINSPECTION ON MWR FAILURE TO DOCUMElif 555BLEM ON DR e
e PERCEPTION OF SCHEDULAR PRESSURE TO REFILL THE TANKS AND CONDUCT MOV TESTING M
e 4
e e
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o' u
u u
u APPARENT VIOLA TION 9317-01 (5 OF SL CONT'D-C_ORRECTIVE ACTIONS:
SHORT TERM:
e DRAINED TANK, CALLED IN COATINGS EXPERT TO EXAMINE AND RECOMMEND ACTION, REMOVED BLISTERED COATING LONG TERM:
e RE-COA T TANKS NEXT REFUELING OUTAGE (RE-16) e IMPROVE CORRECTIVE ACTION PROGRAM TO BETTER ENSURE THATPOTENTIAL LOWER THRESHOLD DEFICIENCIES ARE ADEQUATELY ADDRESSED e
EVALUATE OTHER STATION TANKS FOR SIMILAR CONCERNS t
H
g g
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g APPARENT VIOLA TION 9317-02 (1 OF 2) l DESCRIPTION 1 OPERATION OF THE PLANT, FOR AN UNKNOWN PERIOD, WITH AN INOPERABLE SECONDARY CONTAINMENT UNTIL THE PLANT WAS SHUT DOWN ON MARCH 5,1993, IS AN APPARENT VIOLATION. (TECHNICAL SPECIFICA TION 3. 7. C)
H
O O
O O
O O
O O
O O
O APPARENT VIOLA TION 9317-02 (1 OF 2L CONT'D NPPD POSITION:
NPPD ACTIONS SHOULD NOT BE CONSIDERED A VIOLATION OF REGULA TORY REQUIREMENTS BASIS FOR POSITION:
e AGREE WITH NRC CONCERNS REGARDING SECONDARY CONTAINMENT INTEGRITY DURING OPERA TION HOWEVER, ENFORCEMENT ACTION NOT WARRANTED BECAUSE e
ISSUANCE OF A VIOLATION WOULD INDICATE A CHANGE IN NRC POSITION REGARDING " FORWARD LOOKING TESTS" AS BEING THE BASIS FOR THE TECHNICAL SPECIFICATION l
H
o o
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6~
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APPARENT VIOLA TION 9317-02 (1 OF 2L CONT'D_
OTHER CONSIDERATIONS:
MEASURED LEAKAGE THROUGH MISSING LOOP SEAL WAS NOT SUFFICIENT BY ITSELF TO CAUSE TEST FAILURE (~ 150 CFM) e BASED ON MARCH 8,1993, TEST AND PRIOR HISTORY, TESTING REQUIRES UPGRADING e
NOTED DEFICIENCIES:
FAILURE TO AGGRESSIVELY ADDRESS PRIOR TEST FAILURES TECH SPEC SURVEILLANCE FOCUSES ON FUEL HANDLING INADEQUATE CONSIDERATION OF LOSS OF OFFSITE POWER CONFIGURATIONS DURING TESTING SP 6.3.10.8 INADEQUATE - ALLOWED CHANGES IN ADJACENT BUILDING DP TO MASK LOOP SEAL LEAKAGE PATH H
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APPARENT VIOLA TION 9317-02 (1 OF 2). CONT'D LCTIONS1 SHORT TERM:
TEST ON APRIL 7,1993, CONFIRMED OPERABILITY EVEN WITH MEASURED LEAKAGE FROM MISSING LOOP SEAL e
SP 6.3.10.8 REVISED TO REQUIRE "AS FOUND" TEST, AND
)
PREVENT TURBINE, CONTROL, AND RADWASTE BUILDING PRESSURE FROM AFFECTING TEST e
SP 6.3.10.17 REVISED TO REQUIRE MORE FREQUENT MAINTENANCE e
INCORPORA TED LOSS OF OFFSITE POWER CONFIGURA TION INTO SECONDARY CONTAINMENT TEST PROCEDURE LONG TERM:
o PERFORM SECONDARY CONTAINMENT LEAK TEST A T FIRST COLD SHUTDOWN AFTER SIX MONTHS OF OPERATION H
_J
APPARENT VIOLA TION 9_317-02 (2 OF 2)
DE_SCRIPTION:
THE LICENSEE OPERA TED THE FACILITY IN MODES OTHER THAN COLD SHUTDOWN OR REFUELING, FROM APRIL,1990, TO MARCH 5,1993, WITH PARTICULA TE FIL TERS INSTALLED IN HYDROGEN CONCENTRA TION ANAL YZERS PC-AN-H/0 l AND -H/0 II, WHICH RENDERED THE 2
2 ANALYZER INOPERABLE. (TECHNICAL SPECIFICATION 3.2.4 AND TABLE 3.2.4)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE:
e MINIMAL SAFETY SIGNIFICANCE FOR DESIGN BASIS ACCIDENTS SINCE THE CONTAINMENT WILL TYPICALLY BEINERTED H
o o
o o
o o
o o
o o
o APPARENT VIOLA TION 9_317-02 (2 OF 2)
CAUSES:
POOR TROUBLESHOOTING e
POOR QUALITY VENDOR PUMP DESIGN / FABRICATION FAILURE OF DESIGN REVIEW PROCESS TO RECOGNIZE MOISTURE PROBLEM FAILURE TO FORMALLY CONSIDER / EVALUATE POST-ACCIDENT CONCERNS WHEN DEALING WITH WATER BUILD-UP ON FILTERS i
H
o u
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u m
APPARENT VIO_LA TION 9317-02 (2 OF 21 CA USESlC_ON'Tk e
LACK OF OWNERSHIP OF PROBLEM, FAILURE TO ACT ON INFORMA TION e
FAILURE TO FORMALLY IDENTIFY OPERABILITY CONCERNS e
APPARENT PERCEPTION BY PERSONNEL OF POLICY WHICH REQUIRED JUSTIFICA TION THA T A PROBLEM EXISTED BEFORE PREPARING AN NCR CORRECTIVE ACTION:
SHORT TERWl:
DC 90-320 AND POST-STARTUP TESTING SHOULD RESOLVE HARDWARE CONCERN N
o-o o
o o
o o
o o-o o
APPARENT VIOLA TION 9317-02 (2 OF 2) l CORRECT lVE ACTIONS:
LONG TERM:
e CORRECTIVE ACTION PROGRAM UPGRADE EVALUATE THE NEED FOR A FORMAL POST DESIGN CHANGE e
EFFECTIVENESS EVALUATION N
O O
O O
O O
O O
O O
O APPARENT VIOLA TION 9317-03 (1 OF 1)
DESCRIPTLON:
THE LICENSEE HAD NEVER TESTED THE H 0 CABINET TO THE 58 PSIG 2 2 REQUIREMENT IN TECH SPECS.
THE FAILURE TO TEST A PRIMARY CONTAINMENT PRESSURE BOUNDARY TO THE SPECIFIED VALUE IS AN APPARENT VIOLATION.
(TECHNICAL SPECIFICATION 4.7.A.2)
NPPD POSITION:
ADMIT SAFETY / REG _ULATORY SIGNIFICANCE MINIMAL o
H O IS A CLOSED-LOOP EXTENSION OF PRIMARY CONTAINMENT REQUIRED TO 2 2 BE TESTED BY TECH SPECS THE SYSTEM WAS DESIGNED TO WITHSTAND CONTAINMENT PRESSURES FAILURE OF THE H 0, CABINET WOULD NOT BE EXPECTED TO HA VE o
2 SIGNIFICANT CONTRIBUTION TO OFF-SITE DOSE H
O O
O O
O O
O O
O O
O APPARENT VIOLA TION 9317-03 (1 OF 1L CONT'D OTHER CONSIDERATIONS:
NPPD ENGINEERING THOUGHT THE CABINET WAS INCLUDED IN THE ILRT. IT WAS UNKNOWINGL Y LEFT OUT OF THE ILRT BECAUSE THE SOLENOID VALVES CLOSED WHEN THE UNIT WAS SHUTDOWN EACH OUTAGE.
CAUSES:
o THE DESIGN CHANGE WAS INADEQUATE IN THAT IT FAILED TO IDENTIFY THE REQUIREMENTS FOR PRIMARY CONTAINMENT LEAK TESTS AND FOLLOW THRU WITH NECESSARY PROCEDURE CHANGES o
3.4 SERIES PROCEDURES DO NOT ADDRESS APPENDIX J CRITERIA.
i H
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APPARENT VIOLA TION 9_317-03 (1 OF IL CONT'L2 CORRECTIVE ACTIONS _:
SHORT TERM:
e PROCEDURE 6.3.1.1.1 HAS BEEN REVISED TO EdSURE THE SYSTEM IS LEAK TESTED TO 58 PSIG WHENEVER THE PRESSURE BOUNDARY IS OPEN e
THE SYSTEM HAS SUCESSFULLY BEEN LEAK TESTED TO 58 PSIG BG
g g.
g g
g- - - - -
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-g g
g APPARENT VIOLA TION 9317-03 (1 OF IL CONT'D C_ORRECTIVE ACTIONS:
LONG TERM:
THE ILRT PROCEDURE WILL BE REVISED TO ENSURE THE H 0 SYSTEM /S e
2 2 TESTED AND THE RESULTS ADDED TO THEILRT TRAINING ON APPENDIX J FOR DESIGN AND SYSTEM ENGINEERS EVALUATE THE NEED TO INCLUDE OTHER PROGRAM AREAS FOR ORIENTATION TRAINING e
ADD APPENDIX J TO THE DC CHECKLIST H
O O
O O
O O
O O
O O
O APPARENT VIOLA TION 9317-04 (1 OF 8)
DESCRIPTION:.
TECH SPECS REQUIRE A FUNCTIONAL TEST BE' PERFORMED TO VERIFY OPERABILITY OF THE H 0 ANALYZERS.
HOWEVER, THE PROCEDURE 2 2 USED TO PERFORM THIS DID NOT VERIFY OPERABILITY OF THE HEAT TRACING. (CRITERION V)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE:-
MINIMAL SAFETY SIGNIFICANCE DUE TO INERTED CONTAINMENT.
H
m-m m
v m
m m
m m
m APPARENT VIOLA TION 9317-04 (1 OF 8)
-OTHER CONSIDERATIONS:
PROCEDURE 6.3.1.13 VERIFIED SYSTEM TEMPERATURE CAUSE:
INADEQUA TE PROCEDURE H
APPARENT VIOLA TION 9377-04 (1 OF 81 CORRECTIVE ACTLONS:
SHORT TERM:
OSC #12 TO DC 90-320 VERIFIED OPERABILITY LONG TERM:
REVISE THE MONTHLY FUNCTlONAL TEST TO INCLUDE A CHECK TO VERIFY HEAT TRACE OPERABILITY VERIFY THA T HEA T TRA CING IS ADEQUA TEL Y MONITORED BG
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APPARENT VIQLA TION 9_317-04 {2 OF 8J L?ES_CRIPTION:
PROCEDURE 4.15 AND EMERGENCY PROCEDURE 5.2.5 WERE NOT APPROPRIA TE IN THA T NO INSTRUCTIONS WERE PROVIDED TO SPECIFY HOW OR WHEN TO RETURN THE ELEVATED RELEASE POINT RADIATION MONITOR TO SERVICE AFTER A LOSS OF OFF-SITE POWER. (CRITERION V)
BG
O
'e ' ' '
O O
O O
O O
O O
O
^
APPARENT VIOLA TIO_N 9377-04 (2 OF 8L CONT'D NPPD POSITION:
NPPD ACTIONS SHOULD NOT BE CONSIDERED A VIOLATION OF REGULA TORY REQUIREMENTS BASIS FQB PD_SITION:
o POWER SUPPLY COMPLIES WITH REGULATORY GUIDE 1.97, CA T. II MONITOR NOT REQUIRED TO BE IN SERVICE AFTER LOSS OF OFF-SITE POWER; A VAILABILITY IS AN ENHANCEMENT e
OTHER MEANS FOR MONITORING NO REDUNDANCY REQUIRED SINCE NOT ESSENTIAL TO ANY e
TRANSIENTS OR ACCIDENTS ACTIONS TAKEN SP 4.15 AND EP 5.2.5 REVISED TO PROVIDE ENHANCED GUIDANCE TO OPERATORS M
o o
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6
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71
~ ~ 3 6
'd 6
APPARENT VIOLA TION 9317-04 (3 OF 8)
. DESCRIPTION:
FAILURE TO IMPLEMENT A PROCEDURE FOR INTEGRA TED LEAK RA TE TESTING THAT SPECIFIES THE POSITION OF VALVES, WHICH ARE REQUIRED TO BEIN A SPECIFIC POSITION, AND TO REQUIRE VERIFICATION OF THE SPECIFIED POSITION. (CRITERION V)
NPPD POSITION:
NPPD ACTION SHOULD NOT BE CONSIDERED A VIOLATION OF REGULATORY REQUIREMENTS H
APPARENT VIO_LA TION 9377-04 (3 OF 8J, CONT'D l
l BASIS FOR PO_SITION:
ILRT PROCEDURE (SP 6.3.1.3) REQUIRES VERIFICA TION OF VAL VE LINEUPS ACTIONS TO BE TAKEN_:
e IMPROVE SP 6.3.1.3 TO INCLUDE SEQUENCING OF NORMAL OPERATING PROCEDURE LINEUP, CLEARANCE ORDER REVIEW, AND SP 6.3.1.3 SPECIAL LINEUP H
. g..
_g APPARENT VIOLA TION 9317-04 (4 OF 81 DESCRIPTION:
OVERTIME DEVIATION REQUESTS (WITHIN THE PAST 30 DA YS) WERE ON FILE AND NOTIDENTIFIED (ON THE CURRENT OVERTIME DEVIATION REQUEST). (CRITERION V)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE:
NONE OTHER CHECKS AND BALANCES WEREIN PLACE TO ASSURE o
CONFORMANCE WITH REGULATORY GUIDELINES H
g g-g g
g APPARENT WOLA TION 9317-04 (4 OF 81. CONT'D l
OTHER CONSIDERATIONS:
l e
NOTWITHSTANDING THE DEFICIENCY, DEVIATION REQUESTS WERE APPROVED WITH REQUIRED SUPERVISORY OVERSIGHT
-CAUSES:
PERSONNEL, PROCEDURE NOT FOLLOWED IN THA T THE PREVIOUS DEV/A TIONS WERE NOT RECORDED AND THAT THE APPROVED FORMS WERE NOT DISTRIBUTED e
PROCEDURE LESS THAN ADEQUATE BECAUSE IT DID NOT SPECIFY' RESPONSIBILITY FOR DISTRIBUTION OF THE APPROVED FORM M
O O
O o
o o
o o
o 6
'o' APPARENT WOLA TION 9377-04 (4 OF BL CONT'D CORRECTIVE ACTIONS:-
REVISE PROCEDURE TO CLARIFY METHOD FOR REQUESTING OVERTIME DEVIA TIONS e
IMPROVE PERSONNEL ACCOUNTABILITY FOR ADHERENCE TO PROCEDURES BG
g g
g g
g g
g g
3
. g APPARENT VIOLA TION 9377-04 (5 OF 8)
DESCRIPTION:
FAILURE OF CRAFT PERSONNEL TO OBSERVE A HOLD POINT A T STEP 5 ON MWR 93-3021; REQUIREMENT FOR THE SYSTEM ENGINEER TO INSPECT EDG NO.1 AFTER COOLER PRIOR TO CLEANING. (CRITERION V)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE; MINIMAL; HOWEVER MISSING A HOLD POINT HAS POTENTIAL SAFETY SIGNIFICANCE N
e b~
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u o
o u
o o
o APPARENT VIO_LA TION 9317-04 (5 OF 8L C_ONT'D C_AMSES; e
PERSONNEL ERROR: INSTRUCTIONS NOT FOLLOWED e
LACK OF ADEQUATE SUPERVISION MWR SPECIAL INSTRUCTIONS WERE CONFUSING e
CORRECTIVE ACTIONS:
SHORT TERM:
RESPONSIBLE INDIVIDUAL COUNSELED ON INA TTENTION TO e
DETA!L IMPROVE ACCOUNTABILITY ENFORCEMENT LONG TERM:
OWNERSHIP AND ACCOUNTABILITY WILL BE STRESSED BY MANAGEMENT H
g.
g g
g APPARENT VIOLA TION 9317-04 (6 OF 8)
DESCRIPTION:
CONTROL ROOM OPERATORS DID NOT Lt THE CHANGE IN STA TUS OF CRITICAL PLANT COMPONENTS, SUCH AS PRIMARY AND SECONDARY CONTAINMENTS. (CRITERION V)
NPPD POSITION:
NPPD ACTION SHOULD NOTBE CONSIDERED A VIOLATION OF REGULA TORY REQUIREMENTS.
BASIS FOR POSITION:
THE DISTRICT DOES NOTINTERPRET THE CITED PROCEDURE TO LOG THE OPERABILITY /INOPERABILITY OF A SYSTEM IF THE SYSTEM IS NOT REQUIRED TO BE OPERABLE.
N
o o
o o
-o o
o o
o o
o APPARENT VIOLA TION 9377-04 (6 OF 8) CONT'D ACTIONS 1 e
CLARIFY PROCEDURE TO PROVIDE CLEARER, CONSISTENT GUIDANCE BG
APPAREET VIOLA TION 9317-04 (7 OF 81 D.E_SCBIPTION:
STATION OPERATOR DID NOT USE OR FOLLOW PROCEDURES WHEN RACKING-OUT AN ELECTRICAL BREAKER, RESULTING IN A LOSS OF SHUTDOWN COOLING. (CRITERION V)
NPPD PO_SITION:
ADMIT SA_EETY/REGJLL.ATORY SLGNIFICANCE:
THE LOSS OF SHUTDOWN COOLING EVENT WAS SIGNIFICANT LOSS OF LOOP SHUTDOWN COOLING DID NOT HA VE ACTUAL e
SAFETY SIGNIFICANCE; OPERATOR WAS AWARE OF CONDITION OTHER CONTINGENCIES WERE AVAILABLE H
)
U U
~
U U
U U
U U
U U
U APPARENT VIOLA TION 9_317-04 (7 OF 8)
DESCRIPTION:
STATION OPERATOR DID NOT USE OR FOLLOW PROCEDURES WHEN RACKING-OUT AN ELECTRICAL BREAKER, RESULTING IN A LOSS OF SHUTDOWN COOLING. (CRITERION V)
NPPD POSITION:
ADMIT SAFETY / REGULATORY SIGNIFICANCE:
LOSS OF LOOP SHUTDOWN COOLING DID NOT HA VE ACTUAL SAFETY SIGNIFICANCE OPERATOR WAS AWARE OF CONDITION OTHER CONTINGENCIES WERE AVAILABLE N
o o
o o
o o
o o
o o
o APPARENT VIOLA TION 9317-04 (7 OF 8)
CAUSES:
PERSONNEL ERROR e
FAILURE TO FOLLOW PROCEDURE CORRECTIVE ACTION:
SHORT TERM:
e LABELED FLOOR IN FRONT OF BREAKERS e
DISCIPLINARY ACTION AGAINST OPERATOR WAS TAKEN LONG TERM:
e MAINTAIN ACCOUNTABILITY AND STANDARDS FOR UNACCEPTABLE PERSONNEL ERRORS H
-