ML20057D204
| ML20057D204 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/27/1993 |
| From: | Roe J Office of Nuclear Reactor Regulation |
| To: | Capella B, Oconnell R, Wene L AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20057D205 | List: |
| References | |
| NUDOCS 9310010255 | |
| Download: ML20057D204 (3) | |
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i UNITED STATES i
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WASWNGTON, O C. MSS @ut September 27, 1993 Hr. Bob Capella Mr. Leo Wene Mr. Ron O'Connell 315 Garfield Street Geneva, Ohio 44041
Dear Messrs. Capella,
Wene, and O'Connell:
This is to respond to your letter dated August 20, 1993, submitted on behalf of the Concerned Citizens of Lake, Geauga, and Ashtabula Counties, Ohio, to Mr. John B. Martin, Regional Administrator, Region III, U. S. Nuclear Regulatory Commission (NRC).
In your letter, you expressed concerns about the Perry Nuclear Power Plant and requested that the NRC immediately shut down the Perry Plant, conduct public hearings on what is wrong with the plant, and keep the Perry plant closed until the plant can operate safely.
Your request is based upon statements made by Mr. Martin about the Perry Plant. Mr. Martin did make statements as quoted in your letter, to emphasize the issues facing the licensee that required continuing attention from both the NRC and licensee management. However, Mr. Martin and the NRC staff do not believe that these problems pose any undue risk to the health and safety of the public at this time.
The NRC staff is continuously evaluating the performance of the Perry plant (and all other operating nuclear plants). The staff formally evaluated the licensee in the most recent Systematic Assessment of Licensee Performance (SALP) for Perry, which covered the period from November 1,1991, through January 31, 1993.
(A copy of the SALP report is enclosed for your information.)
The staff has identified performance weaknesses in a number of areas, particularly in effectiveness of licensee management's oversight of plant activities.
The utility is agressively taking action to resolve such problems including an influx of new management talent to provide the needed oversight.
The NRC staff has initiated a number of steos to more closely monitor specific aspects of the licensee's progress in dealing with its prcblems.
For example:
(1)
Eleven senior resident inspectors and regional management personnel
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recently evaluated onsite licensee activities at Perry, particularly the programs aimed at improving performance.
This was part of a planned activity to have NRC management evaluate the licensee's activities onsite on a quarterly basis.
(2)
Two senior engineering inspectors from NRC Region III have recently performed a special evaluation of engineering activities at the plant.
Two additional engineering inspections are planned between now and the spring of 1994.
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Mr. Bob Capella, Mr. Leo Wene, Perry Nuclear Power Plant and Mr. Ron O'Connell Unit Nos. I and 2 Centerior Service Company cc:
Mr. Robert A. Stratman, Vice President David P. Igyarto, General Manager Nuclear - Perry Cleveland Electric Illuminating Company The Cleveland Electric Illuminating Perry Nuclear Power Plant Company P. O. Box 97, SB306 10 Center Road Perry, Ohio 44081 Perry, Ohio 44081 Mr. James W. Harris, Director Jay E. Silberg, Esq.
Division of Power Generation Shaw, Pittman, Potts & Trowbridge Ohio Department of Industrial Relations 2300 N Street, N.W.
P. O. Box 825 Washington, D.C.
20037 Columbus, Ohio 43216 Mary E. O'Reilly The Honorable Lawrence Logan Centerior Energy Corporation Mayor, Village of Perry 300 Madison Avenue 4203 Harper Street Toledo, Ohio 43652 Perry, Ohio 44081 Resident Inspector's Office The Honorable Robert V. Drosz U.S. Nuclear Regulatory Commission Mayor, Village of North arry Parmly at Center Road North Perry Village Hall Perry, Ohio 44081 4778 Lockwood Road North Perry Village, Ohio 44081 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Attorney General 799 Roosevelt Road Department of Attorney General Glen Ellyn, Illinois 60137 30 East Broad Street Columbus, Ohio 43216 Lake County Prosecutor Lake County Administration Bldg.
Radiological Health Program 105 Main Street Ohio Department of Health Painesville, Ohio 44077 P. O. Box 118 Columbus, Ohio 43266-0118 Ms. Sue Hiatt OCRE Interim Representative Ohio Environmental Protection Agency 8275 Munson DERR--Compliance Unit Memtor, Ohio 44060 ATTN: Zack A. Clayton P. O. Box 1049 Terry J. Lodge, Esq.
Columbus, Ohio 43266-0149 618 N. Michigan Street, Suite 105 Toledo, Ohio 43624 Mr. Thomas Haas, Chairman Perry Township Board of Trustees Ashtabula County Prosecutor 3750 Center Rd., Box 65 25 West Jefferson Street Perry, Ohio 44081 1
Jefferson, Ohio 44047 State of Ohio Mr. Kevin P. Donovan Public Utilities Commission Cleveland Electric Illuminating Company East Broad Street Perry Nuclear Power Plant Columbus, Ohio 43Z66-0573 P. O. Box 97, E-210 Perry, Ohio 44081 James R. Williams, Chief of Staff Cleveland Electric Illuminating Company Ohio Emergency Management Agency 2825 West Granville Road Worthington, Ohio 43085
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(3)
NRC Region III staff also plans to perform additional inspections in the areas of radiation protection and radioactive waste management to assure compliance with appropriate regulations and standards.
The staff has determined that, at this time, the plant should not be shut down I
as you requested.
However, the NRC staff will continue to closely monitor i
performance at the Perry Plant and will take appropriate actions to ensure that performance does not pose any undue risk to the health and safety of the public.
t If deemed necessary, we will require the plant to shut down and remain shut down until the licensee has corrected any associated problems.
Sincerely, I
ORIGINAL SIGNED BY:
Jack W. Roe, Director Division of Reactor Projects - III/IV/V
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Office of Nuclear Reactor Regulation i
Enclosure:
SALP 12 Report cc w/ enclosure: See next page DISTRIBUTION:
Docket File 50-440(w/ incoming)PDR & Local PDR (w/ incoming) ED0#9290 J. Sniezek H. Thompson J. Blaba T. Murley/F. Miraglia J. Liberman J. Goldberg i
J. Partlow J. Roe J. Zwolinski 4
J. Hannon R. Stransky A. Kugler OCA NRR Mailroom (ED09290)
PDIII-3 r/f PDIII-3 Gray E. Greenman, RIII C. Mohrwinkel S. Wiens J. Martin, RIII M. Rushbrook J. Taylor OPA EDO Reading File
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ENCLOSURE MAR 311993 I
5 Docket No. 50-440 Docket No. 50-441 Centerior Service Company ATTN: Mr. R. A. Stratman Vice President Nuclear - Perry c/o The Cleveland Electric illuminating Company 10 Center Road Perry, OH 44081
Dear Mr. Stratman:
Enclosed for your review, before our scheduled meeting of April 8,1993, is the Initial SALP 12 Report for the Perry Nuclear Power Plant, covering the period November 1, 1991, through January 31, 1993.
In accordante with NRC policy, I have reviewed the SALP Board Assessment and concur with their ratings..
It is my view that your conduct of nuclear activities in connection with the Perry facility was adequate, but declined from the previous assessment period. This decline is of concern to us.
Overall, staffing and qualifications were considered a facility strength in all program areas.
The functional areas of Emergency Preparedness and Security were rated Category '.
You are commended for your continued excellent performance in these areas. The remaining functional areas, with the exception of Safety Assessment and Quality Verification, were rated Category 2.
Safety Assessment and Quality Verification was rated Category 3.
Your performance in Radiological Controls, Maintenance and Surveillance, and j
Engineering and Technical Support declined, though not enough to lower the numerical ratings.
The rating in Safety Assessment ?nd Quality Verification j
was lower than the rating in the previous SALP.
There are a number of issues that exist that demonstrate a need for management attention.
The low Category 2 ratings noted above are, at least in part, attributed to the general management approach in those functional areas.
For l
example, in Maintenance and Surveillance, management was not effective in ensuring that the material condition of the plant and post-maintenance cleanup were maintained at appropriate levels or in ensuring that corrective actions were effective; in Radiological Controls, the acceptance of the poor material condition of the plant and the poor housekeeping contributed to the attitude that these conditions were acceptable and to a large increase in the number of low level contamination events; and in Engineering and Technical Support, management lacked an aggressive questioning attitude needed to ensure that technically adequate evaluations of issues were consistently performed. These
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MAR 311993 Centerior Service Company 2
P factors, combined with the continued number of personnel errors, contributed to the Safety Assessment and Quclity Verification Category 3 rating.
At the SALP meeting, you should be prepared to discuss our assessments and your plans to improve performance. The meeting is intended to be a candid dialogue wherein any comments you may have regarding our report are discussed.
Additionally, you may provide written comments within 30 days after the meeting.
Your comments, a summary of our meeting, and my disposition of your comments will be issued as the Final SALP Report.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the Initial SALP Report will be placed in the NRC's Public Document Room.
Should you have any questions concerning the Initial SALP Report, we would be pleased to discuss them with you.
Sincerely, ONG!'7d. S!G"ED EY A. DERT davis A. Bert Davis Regional Administrator
Enclosure:
Initial SALP 12 Report No. 50-440/93001 cc w/ enclosure:
F. R. Stead, Director, Nuclear Support Department Kevin P. Donovan, Manager, Licensing and Compliance Section S. F. Kensicki, Director, Perry Nuclear Engineering Dept.
H. Ray Caldwell, General Superintendent Nuclear Operations David P. Igyarto, Plant Manager Licensing fee & Debt Collection Branch
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MAR 311993 Centerior Service Company 2
l factors, combined with the continued number of personnel errors and management's failure to ensure that balanced engineering evaluations were conducted, contributed to the Safety Assessment and Quality Verification Category 3 rating.
At the SALP meeting, you should be prepared to discuss our assessments and your plans to improve performance. The meeting is intended to be a candid i
dialogue wherein any comments you may have regarding our report are discussed.
Additionally, you may provide written comments within 30 days after the meeting.
Your comments, a summary of our meeting, and my disposition of your comments will be issued as the Final SALP Report.
i In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the Initial SALP Report will be placed in the NRC's Public Document Room.
Should you have any questions concerning the Initial SALP Report, we would be pleased to discuss ther with you.
Sincerely, ORl:!;1A' Sl;;!ED BY A. SERT davis 1
A. Bert Davis Regional Administrator
Enclosure:
Initial SALP 12 Report No. 50-440/93002 cc w/ enclosure:
F. R. Stead, Director, Nuclear Support Department Kevin P. Donovan, Manager, Licensing and Cortpliance Section S. F. Kensicki, Director. Perry Nuclear Engineering Dept.
H. Ray Caldwell, General Superintendent Nuclear Operations David P. Igyarto. Plant Manager s
Licensing fee & Debt Collection Branch RIII Rlll RIII Rill RIII RIII Hopkins/ml Lanksbury Brown Hasse Greger Greenman Rlll Rill RIII R Il Martin Norelius Miller Davis h}
MAR 311993 Centerior Service Company 3
i Distribution Cont.
Resident inspector, Rill Terry J. Lodge, Esq.
James R. Williams, State of Ohio Robert E. Owen, Ohio Department of Health A. Grandjean, State of Ohio, Public Utilities Commission i
INP0 t
The Chairman K. C. Rogers, Commissioner J. R. Curtiss, Commissioner F. J. Remick, Commissioner E. G. de Planque, Commissioner J. H. Sniezek, DEDR T. E. Murley, Director, NRR Chief, RPEB, NRR (2 copies)
J. N. Hannon, Director, Project Directorate 111-3, NRR J. Lieberman, Director, Office of Enforcement C. D. Pederson, Rlll D. C. Koslof f, SRI L. L. Cox, Rlll (2 copies)
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PUBLIC
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SALP 12 i
INITIAL SALP REPORT l
1 l
U.S. NUCLEAR REGULATORY COMMISSION l
4 REGION III l
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report No. 440/93001 Cleveland Electric Illuminating Company Perry Nuclear Power Plant i
n November 1, 1991, through January 31, 1993 l
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k CONTENTS i
Page j
I.
INTRODUCTION 1
II.
SUMMARY
OF RESULTS 2
f Ill.
PERFORMANCE ANALYSIS 3
1 1
3 l
A.
Plant Operations B.
Radiological Controls 5
l C.
Maintenance / Surveillance 6
i D.
j 8
E.
Security 3
F.
Engineering / Technical Support 9
G.
Safety Assessment / Quality Verification
...........10 i
IV.
SUPPORTING DATA AND SUMMARIES 13 A.
Major Licensee Activities
.................13 B.
Major Inspection Activities 13 i
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i 1.
INTRODUCTION i
The Systematic Assessment of Licensee Performance (SALP) program is an-integrated U.S. Nuclear Regulatory Commission (NRC) staff effort to collect l
available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback l
to the licensee's management regarding the NRC's assessment of the facility's performance in each functional area.
This report is the NRC's assessment of the licensee's safety performance at Perry Nuclear Power Plant for the period November 1,1991, through January 31, 1993.
An NRC SALP Board, comprised of the staff members listed below, met on i
March 10, 1993, to review the observations and data on performance and to assess 1icensee performance in accordance with the guidance in NRC Manual Chapter 0516. " Systematic Assessment of Licensee Performance."
j Board Chairman C. E. Norelius, Director, Division of Radiation Safety and Safeguards (DRSS)
Board Members E. G. Greenman, Director, Division of Reactor Projects (DRP)
J. A. Zwolinski, Assistant Director for Region III Reactors, Office of Nuclear Reactor Regulation (NRR)
L. R. Greger, Chief, Reactor Projects Branch 3, DRP G. C. Wright, Chief, Engineering Branch, Division of Reactor Safety (DRS)
J. R. Hall, Acting Technical Assistant, DRP III/IV/V, NRR D. C. Kosloff, Senior Resident Inspector Other Attendees at the SALP Board Meetinq H. J. Miller, Deputy Regional Administrator, RIII R. D. Lanksbury, Chief, Reactor Projects Section 3B, DRP J. W. McCormick-Barger, Chief, Emergency Preparedness, DRSS M. C. Schumacher, Chief, Radiological Controls, Section 1, DRSS W. G. Snell, Chief, Radiological Controls, Section 2, DRSS W. E. Scott, Senior Operations Engineer, NRR A. Vegel, Resident Inspector M. A. Kunowski, Senior Radiation Specialist, DRSS G. M. Christoffer, Physical Security Inspector, DRSS F. A. Maura, Reactor Inspector, DRS B. A. Wetzel, Project Engineer, NRR C. E. Brown, Reactor Engineer, DRP J. L. Cameron, Reactor Engineer, DRP E. R. Duncan, Reactor Engineer, DRP S. K. Orth, Radiation Specialist, DRSS 1
11.
SUMMARY
OF RESULTS The licensee's overall performance was adequate; however, a decline in performance was noted from the previous assessment period. The functional areas of Emergency Preparedness and Security, for the seventh and eighth consecutive SALP periods, respectively, received Category 1 ratings.
The remaining functional areas, with the exception of Safety Assessment and Quality Verification (SA/QV), received Category 2 ratings.
SA/QV was rated Category 3.
The SALP Board noted that performance in Radiological Controls, Maintenance and Surveillance (M/S), and Engineering and Technical Support (E/TS) declined, though not enough to change the numerical ratings.
The I
Category 3 rating in SA/QV represents a decline from the previous Category 2
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rating.
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Good performance in Operations was evidenced by the operat' ors response to events, oversight of daily plant operations, shutdown risk management, and 100 j
percent pass rate for initial license examinations. However, management was i
not fully effective in reducing personnel errors and in sustaining good plant' cleanliness.
In the Radiological Controls functional area, excellent support of the as-low-as-reasonably-achievable (ALARA) program was noted. However, weaknesses were noted in management's acceptance of poor housekeeping and material conditir in the radiological restricted area.
The poor material condition in the turble,: tailding resulted in an increased number of low level i
.ontamination events.
In the M/S functional area, personnel errors and maintenance of balance-of-plant equipment were areas warranting attention.
In the Emergency Preparedness and Security functional areas, excellent management support for the programs was noted and no significant weaknesses were observed.
Performance in the E/TS functional area was mixed. The strengths i
in E/TS were engineering experience and the licensed operator training l
l program.
Weaknesses were present in engineering evaluations and in the implementation of the rotor-operated valve (MOV) program.
Performance in SA/0V was adequate.
Good performance in SA/QV was noted in the findings of the nuclear quality assurance (QA) organization's audits and self-assessments, however, followup actions to correct audit findings were weak. The audits and self-assessments were performance-based, thorough, and comprehensive.
Planning for the 1992 refueling outage was effective and shutdown risk was emphasized, with alternate means of decay heat removal and alternate power sources prominently identified for each evolution. However, management failed i
to recognize weaknesses in the MOV program that resulted in an inadequate analysis of MOV capability.
Additionally, management took positions on several issues without providing sound technical justifications for the proposed actions.
Applicable to several functional areas were weaknesses in the adequacy of i
corrective actions.
Actions taken to minimize personnel errors, sustain good plant material condition and housekeeping, and correct repeated leak rate test i
failures of main steam line penetrations were only partially effective.
Although some progress was made in reducing the overall number of events attributable to personnel errors, neither a significant nor sustained improving trend was noted.
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Overall, staffing continued to be a facility strength. The training and I
qualification program remained excallent.
However, there were problems with MOV training and with workers' adherence to dosimetry and radiological tool control requirements.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Rating Last Rating This Functional Area Period Period Trend Plant Operations 2
2 Radiological Controls 2
2 Maintenance / Surveillance 2
1 Security 1
1 Engineering / Technical 2 Improving 2
Support Safety Assessment / Quality 2
3 Verification
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III.
PERr'ORMANCE ANALYSIS A.
Plant Operations 1.
Analysis Operational history included a refueling outage, three short outages to repair l
equipment, and a mid-cycle maintenance outage, in progress at the end of the assessment period, to replace a leaking fuel bundle. One automatic reactor trip occurred due to a partial loss of feedwater.
Two reactor trips were initiated manually; one was due to a circulating water pipe break and the other resulted from a management decision to manually trip the plant after it was identified that a rod control surveillance could not be performed as written during a plant shutdown.
Although the staff generally continued to operate the plant well, equipment problems prevented the plant from operating l
on a continuous basis.
Management effectiveness in ensuring quality continued to be mixed.
Management provided good oversight of daily plant operation and was effective in improving the coordination of activities during outages.
Shutdown risk i
evaluations, performed in support of the outages, were thorough and well-implemented. The fire protection program was well-supported and well-l implemented.
Control room decorum was good and, overall, the control of annunciators was acceptable. A weakness with failure to remove out-of-service stickers from restored annunciators was promptly corrected after identification by the NRC. As reflected in recurrent enforcement actions and events attributable to personnel errors, corrective actions taken to minimize personnel errors were only partially effective.
Four Severity Level IV violations were attributed, in part, to personnel errors.
An overall lack of 3
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I progress in sustaining good plant cleanliness and housekeeping standards remained a concern.
Corrective actions in response to NRC concerns were only partially effective in improving general plant cleanliness. Cleanliness and housekeeping were concerns in the previous assessment period.
The approach to identifying and resolving technical issues from a safety y
standpoint was good.
During routine plant operations, operator awareness of i
( fuipment performance was instrumental in the timely identification of l
probl ems. Overall, event assessment and reporting were timely and conservative. An exception was a missed entry into a technical specification required shutdown action statement following identification of excessive r
containment purge penetration leakage. Operational problems were resolved with a deliberate and conservative approach.
For example, although the late identification of the mispositioned fuel bundle was a concern, the controlled manner in which the plant was shut down and the problem corrected was good.
While operator responses to operational events were excellent, some instances occurred where procedures were not followed. The responses to a circulating l
water pipe breik, a reacter trip, plant transients due to hotwell pump strainer clogging, and an unexpected safety relief valve actuation were conservative ano timely.
Operator control of daily plant activities and evolutions impresed and, for the most part, was good. However, toward the end of the third refueling outage, two events occurred involving a loss of water inventory from the reactor vessel and from the circulating water system l
3 because operators failed to follow procedures, j
Staffing was excellent.
A low turnover rate, combined with a strong training i
program, produced an experienced and knowledgeable licensed operator cadre as i
evidenced by the strong response to operational events. The use of overtime i'
was maintained within administrative limits with occasional deviations appropriately reviewed and approved by management.
Initial li:ensing examinations were successfully completed by all three senior
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reactor operator candidates and all four reactor operator candidates.
In addition, operator performance during the emergency operating procedure simulator performance exercise was excellent.
2.
Performance Ratino i
1 performance rating is Category 2 in this area.
Performance rating was Category 2 during the previous assessment period.
a r
3.
Recommendations
- None, s
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B.
Radiological Controls 1.
Analysis Management effectiveness in ensuring quality was mixed. On the positive side, excellent support of the as-low-as-reasonably-achievable (ALARA) program was noted in chemical decontamination and replacement of reactor water cleanup piping, repair of the feedwater sparger, extensive use of video monitoring and computer-based job-planning equipment, and station participation in industry groups.
These efforts led to adoption of dose-savings measures and program enhancements.
Reactor water quality was well-managed with monitored parameter results within industry guidelines. The only exception was elevated feedwater conductivity for a short time after the 1992 refueling outage.
l On the other hand, management was less effective in planning for a waste shipment, in removal of the reactor head that resulted in contamination l
control problems, in ensuring that workers adhered to dosimetry and radiological restricted area (RRA) tool control requirements, and in addressing the problem of contaminated silt in the emergency service water intake forebay.
Poor housekeeping and material conditions in the RRA created an increased potential for adverse radiological consequences.
Records for chemicals released from the RRA were not readily available and hindered a retroactive evaluation of potentially mixed hazardous waste.
The approach to identifying and resolving technical issues from a safety standpoint was good.
Radioactivity in liquid effluents was low and there were no transportation or burial site problems identified.
Proactive efforts to l
increase the service life of resin beds and filters and to implement passive addition of zinc were successful.
In addition, performance in the NRC nonradiological confirmatory measurement program and other interlaboratory comparison programs was good.
However, radioactivity in gaseous effluents increased from the previous assessment period due to a leaking fuel bundle combined with steam leaks in the turbine building.
Land use census data i
changes had not been incorporated into offsite dose calculation software since initial plant startup which initially gave inaccurate but conservative results.
4 Annual station dose has been declining, in part due to a trend toward shorter refueling outages.
This trend continued in 1992 with an 84-day refueling outage and an annual dose of 571 person rem. The dose for the assessment i
period, which included the refueling outage, was still somewhat high for
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boiling water reactors.
Although refueling outage scope control improved from i
l previous outages, rework and individual job planning problems caused the
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outage dose to exceed the established goal.
For examp e, a second disassembly and reassembly of the reactor head due to a mispositioned fuel bundle resulted in extra dose.
In 1992, most of the 299 personnel contamination events (PCEs) r were attributable to the refueling outage, but throughout the year, there was i
a relatively high number of PCEs in unposted areas.
Steam leaks in the i
turbine building in the later half of 1992 resulted in an increase in i
contaminated work areas and to a large increase in the number of low level contamination events.
These leaks resulted in a large number of workers being l
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delayed upon exiting the RRA to await decay of short-lived radionuclides.
Staffing was excellent.
General worker training and qualifications were good.
2.
Performance Rating Performance is rated Category 2 in this area.
Performance was rated Category 2 during the previous assessment period.
3.
Recommendations None.
C.
Maintenance / Surveillance 1.
An al _y s i s Additional information regarding management effectiveness with respect to this functional area is contained in paragraph III.G., Safety Assessment / Quality Verification.
The frequency of events attributed to this functional area i
remained essentially unchanged.
Similar to the previous zssessment period, approximately one-half of the events were caused by personnel errors. The improper installation of a reactor feed pump gasket caused a reactor trip.
Management effectiveness in ensuring quality in the surveillance area was good.
Overall, surveillance activities were well-coordinated and were performed and reviewed in a timely manner.
During the 1992 refueling outage the snubber inspection program was well-implemented. The erosion and corrosion program was a quality program but was not well implemented.
Due to outage scheduling constraints, only a small portion of the scheduled erosion and corrosion examinations were performed during the 1992 refueling outage.
During the 1993 mid-cycle maintenance outage, all planned erosion and corrosion examinations were completed.
However, events continued to occur due to improperly performed surveillance activities resulting from personnel errors or procedure deficiencies. The inservice inspection (ISI) activities were well-planned and controlled with well-stated and well-defined procedures.
Records were complete, well-maintained, and retrievable.
Management effectiveness in ensuring quality in the maintenance area was mixed. The reliabity-centered maintenance program was well-implemented, resulting in good planning and prioritization of work activities.
The maintenance backlog was effectively controlled. Maintenance activities for the most part were well-planned and completed satisfactorily. Corrective maintenance in response to plant equipment problems affecting continuous operation was timely and well-coordinated.
Isolated problems due to inadequate planning or retests resulted in engineered safety feature actuations and technical specification violations. Maintenance support of plant operations was acceptable.
However, poor post-maintenance cleanup practices contributed to the poor cleanliness condition of the plant. The j
material condition of safety-related components was good.
The material i
condition of balance-of-plant equipment was poor, as reflected by the large i
number of steam leaks following the 1992 refueling outage and the condition of 6
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the reactor feed pumps.
The approach to identifying and resolving technical issues from a safety j
standpoint was good.
During maintenance and surveillance activities, problems were promptly identified and corrective actions were usually technically sound i
and adequate to prevent recurrence. Troubleshooting efforts were well-planned and thorough in the evaluation of equipment problems including repair of residual heat removal system valves and in the investigation of inadvertent actuation of safety relief valves. Overall, other utilities and vendors were used as sources of information in the assessment of problems and the i
development of troubleshooting plans.
Weaknesses were identified in the adequacy of some corrective actions as reflected in repeated failures of main steam line penetrations and continued problems with containment airlocks.
Staffing levels and qualifications were good. The maintenance and surveillance activities observed were conducted by knowledgeable and experienced personnel.
The use of full-scale mockup training for planned maintenance activities, such as emergency diesel generator repairs, was a strength.
Personnel performing nondestructive examinations were well-i qualified and knowledgeable.
2.
Performance Ratinq Performance rating is Category 2 in this area.
Performance rating was Category 2 during the previous assessment period.
3.
Recommendations 1
None.
D.
Anal ysi s Management effectiveness in ensuring quality was excellent. The emergency response facilities continued to be improved and maintained in an excellent i
condition.
A concern identified during the previous assessment involving the calibration and maintenance of area radiation monitors in the emergency j
operations facility (EOF) and technical support center (TSC) was effectively resolved. The physical layout of the operational support center (OSC) had j
been changed to expedite the formation and dispatch of repair teams.
Maintenance of the EOF improved.
For example, controlled diagrams of the design of the EOF were maintained and access to all areas of the facility was improved.
j The approach to identifying and resolving technical issues from a safety standpoint remained excellent.
The events that were reviewed were conservatively and timely declared with detailed and timely notifications made to the NRC, State, and county officials. Appropriate corrective actions were taken, including training, revising procedures, and enhancing the emergency response organization (ERO) notification system, to resolve a self-identified issue concerning excessive activation time for the TSC and OSC.
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The 1992 exercise performance was excellent with no concerns identified. All significant aspects of the emergency plan were adequately exercised.
I Challenging aspects of the exercise included multiple medical emergencies, simulated loss of plant annunciators while undergoing a transient, and the use of several equipment mockups.
The emergency planning staff continued to be excellent and stable'. Onsite ERO staffing remained excellent with at least four individuals assigned to each critical ERO position.
The training program was effective and remained excellent.
Qualified ERO personnel were maintained in all supervisory and support positions.
Corrective actions from actual events and exercises were properly incorporated into the training program.
2.
Performance Ratino Performance rating is Category 1 in this area.
Performance rating was Category 1 in the previous assessment period.
3.
Recommendations l
None.
i E.
Security 1.
Analysis i
Management effectiveness in ensuring quality continued to be excellent.
}'
Strong managers at all levels of the security department were proactive in improving performance.
For example, the picture badge camera system was-upgraded with a computerized system which greatly improved the badging process.
Security was selected as the pilot group for an enhanced quality assurance (QA) audit which focused on performance efficiency.
The approach to identifying and resolving technical issues from a safety standpoint was excellent.
A team of representatives from various plant groups was established to evaluate possible upgrades to the alarm stations and the security computer systeo..
Evaluation of events was excellent.
Events were properly identified, l
analyzed, documented, and conservatively reported.
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Staffing continued to be excellent. The experience level continued to be high as a result of the low turnover rate.
The effectiveness of the training and qualification program was excellent.
4 Personnel were extremely knowledgeable of program requirements and competent in the execution of their duties.
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2.
Performance Rating
^
Performance rating is Category 1 in this area.
Performance rating was Category I during the previous assessment period.
.l 3.
Recommendations None.
1 F.
Engineering / Technical Support j
1.
Analysis Management effectiveness in ensuring quality was mixed. On the positive side, there was evidence of good assessment and planning of priorities for design I
change packages, temporary modifications, the in-service inspection (ISI) program, and the development of the check valve program.
Improvements were noted in post modification test planning and the quality of modifications.
These were areas of weakness during the last assessment period.
Records and plant performance data were complete, well-maintained, and available. When engineering task force groups were formed and given the independence to thoroughly evaluate and correct continuing problems, they usually produced high quality engineering evaluations.
Followup actions in response to the NRC electrical distribution system functional inspection were thorough in addressing findings. The improved simulator control room and software model, an excellent pass rate on NRC administered examinations, and the results of a i
requalification program audit performed by the NRC were indications that roanagement was effective in implementing the licensed operator program.
On the other hand, weaknesses were noted in some engineering support activities.
For example. the initial engineering evaluations concerning the circulating water system supports and the condensate heater pipe cracks were weak. Weaknesses were also present in the motor-operated valve (MOV) program in response to Generic Letter (GL) 89-10 which resulted in two Severity Level IV violations, with multiple examples.
l The approach to identifying and resolving technical issues from a safety l
standpoint was acceptable. System engineers were at times effective in identifying and correcting adverse plant conditions.
Examples included the identification of an undesirable cross connection of battery supplies and the feedwater flow control problems.
In some instances, system engineers effectively used plant design bases documentation to ensure that design changes were properly performed and tested, and appropriate procedures were updated. However, system engineers' lack of knowledge of the material condition of their assigned systems was considered a weakness due to the limited amount of time they spent in the plant and the number of deficiencies identified by the NRC staff.
Other weaknesses were the numerous engineering errors and inappropriate assumptions used in the MOV program.
Examples included incorrect " stall thrust" application equation, inappropriate assumptions in the degraded voltage calculations, lack of guidance for limit switch settings, and failure to follow procedures while troubleshooting MOV 9
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main line fuse failures. Occasionally, problem evaluations were not thorough as in the initial approaches to resolving the circulating water system elbow
{
break and the condensate heater pipe cracks.
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Approximately one-third of the operational events were attributed to this l
functional area.
Four events were attributed to plant construction design deficiencies. Most of the remaining events were the result of equipment failures, the most significant being recurring problems with containment j
isolation valves, which was a corrective action concern in the previous assessment period.
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The engineering and technical support staff remained stable.
Staff positions i
i and responsibilities were well-defined. Contractors were used effectively.
'i The use of overtime was low, an indication that the work load was not excessive. Overall, the plant had an experienced engineering staff.
This was particularly evident in the nondestructive examination and check valve programs.
However, in the MOV program, failure to allocate sufficient resources resulted in differential pressure testing, design basis testing data evaluation, and work control procedures not being performed in a timely i
manner.
This led to some of the reportable events and violations issued.
The licensed operator training program remained excellent.
The training program for engineers was good; however, MOV training was poor.
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2.
Performance Rating Performance rating is Category 2 in this area.
Performance rating was Category 2 with an improving trend during the previous assessment period.
j 3.
Recommendations l
1 None.
G.
Safety Assessment !0ualit_v Verifict tion L.
Anal ysi s Management effectiveness in ensuring quality was acceptable, but declined from
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l the previous assessment period.
Several issues indicated that management was not fully successful in ensuring quality in programs and in the performance of plant activities.
The lack of sufficient management oversight and support of the GL 89-10 MOV program contributed to the significant weaknesses in the analysis of valve capability identified by the NRC. Main steam isolation valve (MSIV) modifications were implemented on six of eight MSIVs in refueling outage three (RF03) after gross leakage was identified during leak rate testing.
This is significant since licensee management chose not to install the modifications in RF02 following significant leakage in that outage. The lack of timeliness in addressing the MSIV leakage problem resulted in a repeat Severity Level IV violation.
The MSIV modifications were successful in reducing leakage over the 7-month period between RF03 and the midcycle test; however, the effectiveness of the modifications over an entire operating cycle is unknown as yet.
Also, additional MSIV leakage problems were introduced by 4
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improper valve body-to-bonnet sealing in RF03.
The decline in plant material condition indicated a less than full commitment to quality.
Numerous oil and steam leaks and poor post-maintenance cleanup practices were observed, which occasionally affected plant operation. One example included management's decision not to remove debris from the condenser during the 1992 refueling outage, which contributed to clogging of the hotwell pump strainers and condensate system transients during the subsequent startup.
During the previous assessment period, it was noted that the large number of personnel errors were indicative of ineffective management efforts to ensure a proper attitude toward quality at the working level. Although some progress I
was made in reducing the overall number of events attributable to personnel errors, neither a significant nor a sustained improving trend was noted. Of I
particular concern were three events occurring at the end of the 1992 refueling outage involving an unplanned decrease in reactor vessel water level, drainage from the circulating water system, and the failure to identify a mispositioned fuel bundle prior to reactor startup.
Other personnel errors resulted in actual or potential challenges to plant systems, including the loss of instrument air to the outboard MSIVs and a dc bus voltage transient.
In addition, the improper installation of an oil filter gasket on a reactor '
feed pump turbine control oil system resulted in an automatic plant trip.
j While the performance of the nuclear quality assurance (QA) organization was generally good, actions in response to audit findings were not always prompt and thorough.
A self-assessment performed early in the implementation of the GL 89-10 program for motor-operated valves (MOVs) identified a lack of progress in the areas of design basis testing and analysis; however, due to its timing and scope, the self-assessment was not effective in identifying the j
significant weaknesses subsequently observed by the NRC inspection team. An assessment of the erosion and corrosion program identified weaknesses in program implementation; however, management still deferred a large percentage of the inspections planned for the third refueling outage.
The approach to identifying and resolving technical issues from a safety standpoint continued to be mixed.
On the positive side, planning for the 1992 refueling outage was effective and shutdown risk was emphasized, with i
alternate means of decay heat removal and alternate power sources prominently identified for each evolution.
Good planning and technical expertise were j
also exhibited in responding to potential intergranular stress corrosion cracking indications in two feedwater piping welds.
However. on the negative side, management took positions on several issues without balanced i
j evaluations.
In those cases management failed to ensure that appropriate i
factors were evaluated concerning their potential affects on the outcome of the engineering evaluations and operation of plant equipment.
NRC involvement was necessary to ensure appropriate resolution of these issues.
Examples i
included an inadequate initial evaluation of the operability of MOVs (RCIC, RWCU) within the scope of Supplement 3 to Generic Letter 89-10 and the intent j
to continue operation with a cracked condensate heater pipe without fully assessing the potential causes of the crack. Alsc,, problems with a high pressure core spray suction valve torque switch were not sufficiently evaluated before the valve was declared operable.
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i Management's approach in addressing operational issues appropriately reflected i
consideration of safety.
For example, the initial startup from the refueling l
outage was promptly terminated upon the discovery of a mispositioned fuel bundle. One exception was the failure to take action in accordance with a l
technical specification (TS) shutdown requirement when containment bypass leakage limits were exceeded.
Although the required action was not taken due l
I to misinterpretation of the TSs, the leakage problem was promptly corrected and the safety significanca of the issue was appropriately considered, i
Management efforts in the areas of root cause analysis and corrective actions j
were acceptable.
However, corrective actions for MSIV leakage were not effective through the third refueling outage.
Planned corrective actions in j
response to the circulating water pipe break did not consider potential dynamic effects.
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The quality of 10 CFR 50.59 evaluations was good; however, the initial evaluation for the proposed interim low-level radioactive-waste storage and processing facility lacked detail.
l The quality of license amendment requests and other licensing correspondence,
was good, The prompt resolution of station blackout issues and the thorough evaluation of seismic design requirements for the control complex chilled water system were notable.
Amendment requests continued to include thorough technical justifications.
Licensee event report (LER) c' dity was good.
However, the response to GL 89-10, Supplement 3 and a suomino; concerning removal of feedwater snubbers were initially inadequate.
The offsite (Nuclear Safety Review Committee (NSRC)) and onsite (Plant Onsite l
Review Committee (PORC)) review committees were effective in evcluating plant activities and pursuing perceived weaknesses.
For both committees, open discussion was promoted and issues were deferred if sufficient information was not available for the members' review.
The Independent Safety Engineering Group (ISEG) effectively ptrformed its review function.
Staffing levels were good and supported the performance of audits and quality control functions.
The qualifications of QA personnel were good. The PORC, NSRC, and ISEG were adequately staffed by knowledgeable and qualified j
personnel.
The composition and qualifications of the members met or exceeded TS requirements.
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2.
Performance Rating i
Performance is rated Category 3 in this area.
Performance was rated Category l
I 2 in the previous assessment period.
3.
Recommendations l
Management attention should be directed towards ensuring completeness of engineering evaluatioas, improvement of plant material condition, and reduction in personnel errors.
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IV.
SUPPORTING DATA AND SUMMARIES A.
Major licensee Activities 1.
On December 22, 1991, the unit entered a forced. outage due to the I
c atastrophic failure of a 36-inch fiberglass circulating water pipe.
lhe plant was returned to operation on January 6.
2.
On March 21, 1992, the unit was shut down to commence its third refueling outage.
3.
On June 13, 1992, the unit completed its third refueling outage and the main generator was synchronized to the grid.
i 4.
On September 10, 1992, the unit tripped from full power due to low vessel level. A gasket leak on a control oil filter of a reactor feed pump turbine resulted in the slow closing of the turbine steam admission valves, reducing feed flow to the vessel. The leak was repaired and the plant was restarted on September 12.
5.
On October 24, 1992, the unit was shut down to repair a weld crack on the main condensate header. Once the repairs were completed, the plant i
was restarted on October 30.
6.
On January 8,1993, the unit entered a forced outage to replace a leaking fuel bundle and conduct other maintenance activities.
The outage was in progress at the end of the assessment period.
B.
Major Inspection Activities i
The inspection reports discussed in this SALP are listed below:
l Unit 1, Docket No. 50-440 Inspection report Nos. 91023 through 91026, 92002 through 92012, and 92014 through 92026.
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Unit 2, Docket No. 50-441 Inspection report No. 92004 1.
From December 2 to December 6, 1991, a special safety inspection was conducted focusing on the effectiveness of operator training (Inspection report No. 440/91024).
2.
From December 22 to December 29, 1991, a special onsite review by an Augmented Inspection Team (AIT) was conducted for a 36-inch circulating water pipe rupture event (Inspection report No. 440/91026).
l 3.
From May 11 to May 15, 1992, a special inspection was conducted to review safety-related check valve performance in accordance with temporary instruction 2515/110 (Inspection report No. 440/92005).
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4.
From May 27 to June 15, 1992, a special safety inspection was conducted to evaluate three loss of water inventory events and a misaligned fuel bundle (Inspection report No. 440/92011).
J 5.
From July 6 to August 7,1992, a special safety inspection was conducted to review engineering and technical support (Inspection report No.
440/92014).
i 6.
From August 17 to August 21, 1992, a special inspection was conducted to followup on previously identified electrical distribution system functional inspection findings (Inspection report Nos. 440/92016 and 441/92004).
7.
From August 25 to October 1, 1992, a special inspection was conducted to review the MOV program (Inspection report No. 440/92018).
8.
From September 13 to September 18, 1992, a special team inspection was conducted to review the ALARA program (Inspection report No. 440/92019).
9.
From December 7 to December 11, 1992, a special team inspection was
+
conducted to observe the annual NRC-graded emergency preparedness 4
exercise (Inspecticr. report No. 440/92023).
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