ML20058E139
| ML20058E139 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/26/1990 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| NUDOCS 9011070048 | |
| Download: ML20058E139 (3) | |
See also: IR 05000482/1990014
Text
{{#Wiki_filter:.- -- ' 4- . = - ,3 _ '- OCT 2 6ll990., o ! Docket-No. STN 50-482/90-14 ! ,
- License No. NPF-42
' Wolf Creek Nuclear Operating Corporation - -ATTN: Bart D. Withers , ! President and Chief Executive Officer ! P.O. Box 411' 4 Burlington, Kansas 66839 { . Gentlemen: i This forwards the final report of-the S)stemat#c Assessment of Licensee Performance (SALP) for the Wolf Creek-G!nerating Station (WCGS) for the period ' April 1,.1989, through June 30,1990. It is the staff's understanding that ' > you will not be issuing a written respt,nse to the SALP report. Therefore, the ' initial SALP report issued September 11, 1990, is now considered the final SALP report. This final report incluJes: ! ! 1.- The initial SALP report (no revisions). 2. - 'A' summary of and list of attendees at our_0ctober 11, 1990, meeting at WCGS to discuss-the SALP report. , The next SALP period for WCGS is scheduled to last 15 months from July 1, 1990, through September 30, 1991. , Sincerely, , ORIGINAL SIGNED ST
~ ROBERT D. MARTIN ; e Robert D. Martin R, Regional Administrator ' { ' 4 Enclosures:- H
- 1. ' Initial SALP report
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- 2. . Meeting summary and list of
attendees- - I T .cc w/ enclosures- ' Wotf Creek Nuclear Operating Corp. u l ATTN:, Gary Boyer,' Plant Manager ' P.O. Box 411 < ' ~ Burlington, Kansas 66839- 50 , ,y 'AC:DRP/ NRR'Nwe' NRR % M RR % h D:DRSS ph h;lRIV:SRIk e ESkow;df-
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- ATTN:- Chris R. Rogers, P.E. Manager, Electric Department . ' " ' P.O.-Box 360. Jefferson . City, Missouri 65102 .4 U.S. Nuclear Regulatory Comission
- ATTN:' Regional Administrator, Region III
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Glen Ellyn Illinois; 60137 - -, , - Wolf = Creek Nuclear Operating Corp. ATTN:- Otto Maynard.. Manager _ Regulatory Services r P.O. Box 411 Burlington, Kansas 66839'
- ~ ' - Kansas Corporation Comission ATTN:' Robert Elliot, Chief Engineer -Utilities Division - '4th Floor - State Office Building ~ Topeka.: Kansas ; 66612-1571 ' 't ' Office of the Governo'r- "t -1 - State of' Kansas - l' ' Topeka, Kansas. 66612 L Attorney General , u 1st Floor ' The Statehouse . , Topeka,. Kansas 66612 -
- Chairman, Coffey. County Comission
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- Burlington, Kansas 66839
Kansas' Department;of Health r
' and Environment' - Bureau of-Air Quality & Radiation !, Control l' ATTN: Gerald Allen, Public >
LHealth Physicist Division'of Environment. Forbes Field Building 321' ._ . Topeka, Kansas 66620 L,J t -;
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$11 RYAN PLAZA DRIVE, SulTE 1000 '%,, ,8 ARLINGTON, TEXAS 7e011 SEP l I 500 , In Reply To: Docket: 50-482/90-14 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 6680 Gentlemen: This forwards the initial Systematic Assessment of Licensee Performance (SALP) Report (50-482/90-14) for the Wolf Creek Generating Station (WCGS). The SALP Board met on August 14, 1990, to evaluate WCGS's performance for the period April 1,1989, through June 30, 1990. The performance analyses and resulting evaluations.are documented in the enclosed SALP Board Report. In accordance with NRC policy, I have reviewed the SALP Board's assessment and L concur with their ratings, as discussed below:
Performance'in the area of. operations was' rated as Category 2. WCGS attained a very high operating capacity factor during the assessment period. Although the plant operated well, continued improvement in critical self-assessment is warranted. l l
Radiological controls was rated Category 2 with an irnproving trend. The person-rem exposure for the last several years has been notably low. This was attained, in part, through'a well implemented radiological controls program. Development of comprehensive procedures.to support the 'e '.ablished program was still needed.
The areas of security and emergency. preparedness ren.ained Category 1. Effective management . involvement in these two areas was apparent. 4
The area of maintenance / surveillance was rated Category 2. Little ^ improvement was noted in the trending program since the previous assessment period. Better control of maintenance troubleshooting activities is needed to ensure that operators are constantly cognizant of potentially changing plant conditions.-
Performance in the area of engineering / technical support was rated ! Category 2. Additional programmatic controls have ban implemented identifying and resolving industry technical issues. Nevertheless, additional effort was needed to complete the implementation of the program ! changes. Ay-- - ,-h : i 7po' i y frD , ,
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_ _ , . .,. , .- Wolf Creek Nuclear Operating -2- Corporation , ' The area of safety assessment / quality verification was rated as Category 2. Performance in the area of safety assessment was generally strong; however, the quality verification program was not fully effective in identifying problem areas and ensuring that appropriate corrective actions were taken promptly to prevent recurrence. Overall, performance remained relatively steady during the assessment period. Obvious improvament in the area of radiological controls was noted. Based on
the SALP Board's assessment, the length of the SALP period will remain a 15-month cycle; therefore, the next SALP period will be from July 1,1990, to September 30, 1991. A management reeting will be scheduled with you and your staff to review the - results of this SALP report. The time and date of this meeting will be promulgated separately. Within 30 days of this management meeting, you may provide written comments on, and amplification of, as appropriate, the initial SALP Report. Your comments, a summary'of our meeting, and my disposition of. your comments will be issued as an appendix to the enclosed initial.SALP Report and-will constitute the final SALP Report. A copy of your written comments will be included in the final distribution of the SALP report. . Sincer,p , . Robert D. Martin Regional Administrator Enclosurei SALP Board Report 50-482/90-14 cc w/ enclosure: (see next page) Wolf, Creek Nuclear Operating Corp. ATTN: Gary Boyer, Plant Manager P.O. Box 411 Burlington, Kansas 66839 .Shaw, Pittman, Potts & Trowbridge ATTN: Jay Silberg, Esq. 1800 M Street, NW Washington, D.C. 20036 Public ServiceaCommission ATTN: Chris R. Rogers, P.E, l Manager, Electric Department ! P.O. Box 360 L Jefferson City, Missouri 65102 . - - - . - - - - E
.. . ___-__- _ --- ' y , ,, . Wolf Creek Nuclear Operating -3- Corporation U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137- Wolf Creek Nuclear Operating Corp. ATTN: Otto Maynard, Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities Division 4th Floor - State Office Building Topeka, Kansas 66612-1571 Office-of the Governor State of Kansas Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka, Kansas -66612 Chairman, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839 Kansas Department'of-Health and Environment Bureau of Air Quality & Radiation 4 -Control ATTN: _ Gerald Allen, Public Health Physicist Division of Environment Forbes Field Building 321 Topeka, Kansas 66620 U.S. Nuclear Regulatory Commission ATTN: Senior Resident Inspector P.O. Box 311 Burlington, Kansas: 66839 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
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- DRS
Commissioner' Remick (MS: 16-G-3) A. B. Beach, D:DRSS J. M. Taylor, EDO (MS: 17-G-21) L, A. Yandell, DRSS J. M. Montgomery B. Murray, DRSS J. T. Gilliland, PA0 D. A. Powers, DRSS C. A. Hackney
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.O g e, + 0 INITIAL SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION IV SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE , 50-482/90-14 Wolf Creek Nuclear Operating Corporation Wolf Creek Generating Station l April 1,1989, through June 30, 1990 l l I 1Q
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. ., , .g. I. . INTRODUCTION The Systematic Assessment'of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this 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 to licensee's management regarding the NRC's assessment of their facility's performance in each functional area. An NRC SALP Board, composed of the staff members listed below, met on August 14, 1990, to review the observations and data on performance and to assess licensee performance in accordance with NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section 1., of this report. The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuance. This report is the NRC's assessment of the licensee's safety performance at the Wolf Creek Generating Station for the period April 1, 1989, through June 30, 1990. The SALP Board for the Wolf Creek Generating Station was composed of: Chairman L. J. Callan, Director, Division of Reactor Safety (DRS), Region IV Members B. A. Boger,. Acting Assistant Director for Region IV and V Reactors, Office of Nuclear Reactor Regulation.(NRR) T. P. Gwynn, Acting Director, Division of Reactor Projects (DRP), Region IV A B. Beach, Director, Division of Radiation Safety and Safeguards (DRSS), Region IV C. I. Grimes, Director, Project Directorate IV-2, NRR J. S. Wiebe, Chief, Project Section D, DRP, Region IV D. V.. Pickett, Project Manager, Wolf Creek Generating Station, Project Directorate IV-2, NRR . M. E. Skow, Senior Resident Inspector, Wolf Creek Generating Station 'The following personnel also participated in the SALP Board meeting: B. Murray, Chief, Facilities Radiation Protection Section, DRSS, Region IV D. A. Powers, Chief, Security and Emergency Preparedness Section (SEPS), DRSS, Region IV
. 4 , -c -3- , W. C. Seidle, Chief, Test Programs Section, DRS, Region IV T. F. Stetka, Chief, Plant Systems Section, DRS, Region IV J. E. Gagliardo, Chief, Operational Programs Section, DRS, Region IV W. B. Jones, Senior Project Engineer, Project Section D, DRP, Region IV L. Gundrum, Resident Inspector, Wolf Creek Generating Station H. F. Bundy, Inspector, Test Programs Section, DRS, Region IV II. SUMMARY OF RESULTS Overview WCGS attained a high operating capacity factor this assessment period. The licensee performed well in day-to-day plant operations. Effective management involvement in security and emergency preparedness was noted. However, better procedural controls were needed in many areas, including maintenance troubleshooting and radiological controls. The licensee improved their performance in the area of radiological controls. The licensee's ALARA program was well implemented as evidenced by'the low person-REM exposures received during the previous year. However, additional critical self-assessment and improved procedures for identification and correction of deficiencies was needed to support further improvement at WCGS. The licensee's performance ratings are summarized in the table below, along with the ratings from the previous SALP assessment period. Rating Last Period Rating This period Functional Area (04/01/88 to 03/31/89)- (04/01/89 to 06/30/90) Trend 1. Plant Operations 2 2 2. Radiological Controls 2 2
- I
'3. Maintenance / Surveillance 2 2 4. Emergency Preparedness 1 1 5. Security 1 1 6. . Engineering / Technical 2 2 Support 7. Safety Assessment / 2 2 Quality Verification
- ' Improving
. . , , 4 -III. CRITERIA Licensee performance was assessed in seven selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment. The following evaluation criteria were used, as applicable, to assess each functional area: A. Assurance of quality, including management involvement and control; B. Approach'to the resolution of technical issues from a safety standpoint; C. Enforcement history; D. Operational events (including response to, analyses of, reporting of, and corrective actions for); E. Staffing (including management); and , F. Effectiveness of the training and qualification programs. l- However, NRC is not limited to these criteria and others may have been used where appropriate. L
On the basis of the NRC assessment, each functional area evaluated is ' rated according to three performance categories. The definitions of these performance categories are: . -Category 1 - Licensee's management attention and involvement are readily [ evident and place emphasis on superior performance of nuclear safety or L safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee's resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriate. ' ' Category 2 - Licensee's management attention to and involvement in the performance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. The licensee's resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels. Category 3 - The licensee's management attention to, and involvement in, the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.
. o -, . 5- Improving: Licensee performance was determired to be improving during the assessment period. IV. PERFORMANCE ANALYSIS A. Plant Operations 3. Analysis The assessment of this area consisted chiefly of the control and execution of activities directly related to operating the plant, such as plant startup, power operation, plant shutdown, and system lineups. Thus, it included activities such as monitoring and logging plant conditions, normal operations, response to transient and off-normal conditions, manipulating the reactor and auxiliary controls, plant-wide housekeeping, control room professionalism, and interface with activities that support operations. This area was inspected by the resident inspectors and regional inspectors throughout the assessment period. + The last SALP report (NRC Inspection Report 50-482/89-14) recommended that the licensee: (1) Continue efforts towards ' improvements in the operations area; (2) continue to stress . communications between operations and support organizations; and (3) continue to focus attention to detail in day-to-day activities. The licensee facilitated critical self-assessment of operational activities through the rotation of reactor operators and training instructors.- This helped identify areas where licensed L operator training could improve operator performance. The l operations manager also provided additional guidance for i- operators concerning areas he wished to reinforce. Despite the ! above, there were several personnel and procedural errors l- committed by operations personnel, particularly during the fourth refueling outage. The trend noted towards the end of the previous SALP cycle for improving organizational communications continued through this assessment period. In an effort to improve. internal communications, the' licensee initiated a team building training program. Several-individuals from different parts of the organization participated in each course. Promotions within the licensee's organization appeared to have been based on an , individual's ability to communicate ideas and motivate personnel as well as their technical skills. Despite the above, lack of communication between craft and operations personnel continued to be evident prior to the performance of some maintenance troubleshooting activities. l l -
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l . 6- i The previous SALP report identified that the operation of the emergency diesel generators (ECGS) appeared to be a problem area for the licensee as evident by the large number of Licensee Event Reports (LERs) and violations related to their operation. During the present SALP cycle, no LERs regarding the EDGs were issued. One noncited violation was identified con:erning a valve line up on the diesel generator skid, however, the error did not affect diesel generator availability. The plant operating staff consisted of 32 senior reactor operators (SRO) and 15 reactor operators (RO). Six crews were used to operate the plant. Each of the six crews rotated ' through a week as a relief crew and were available to fill in for individuals on shift absences as well as during planned activities requiring adcitional operator involvement. The p relief crew war also available during day shift to assist the l~ onshift crew with unexpected plant transients. Radios and l reading materials which were not directly related to plant operations were prohibited from the operating area of the control room. Clerical support was provided for each shift ' which removed some of the administrative burdens from the control room operators. Administrative controls have been effective in keeping personnel not directly involved in plant operations out of the main control room. Control room professionalism was a strength during the assessment period. During the operating cycle prior to the refueling outage, the
licensee had a ve y high_ capacity factor. The plant was the -leading electrical producer.in the nation for 1989. This censistent operation showed that the licenseo could operate the plant well. 4 The operators shut the plant down in a systematic manner to begin the fourth' refueling outage. The reactor trips that occurred during the assessment period showed that operators responded well to those challenges. There were occasions, such as a repair to the main turbine electrohydraulic control system, where the potential for a plant transient increased, but they i were actively managed by the licensee. Very good communications I between operations and the maintenance crews existed during the > L above work activity. ' There were both routine and nonroutine operations that the plant staff performed well, including the shutdown discussed above. Operating crew turnover during normal plant operations was a strong point. The operators discussed ongoing evolutions as well as items that had occurred during the last shift. The shift supervisors gave their crew briefings on plant status and discussed items that had occurred, were ongoing, or were expected. All crew members were encouraged to contribute to the briefing. There were three occasions where shift turnovers following l .
. - - . - -. n .; i c v 1 . . . .y. t o , involved evolutions or test briefings did not provide an adequate assessment of the plant's status. The reactor was operated at essentially full power up to the fourth-refueling outage. One reactor trip was experienced prior to the refueling outage because of a relay problem associated with a. reactor coolant pump. Three additional reactor trips were experienced during or closely following the refueling outage. One reactor trip, which occurred because of a failed open main steam line power operated relief valve, was exceptionally well handled by the operating crew. However, one ' reactor. trip and a reactor trip breaker actuation occurred as-a result of operations personnel-not being fully cognizant of. the status of the plant and the effect their actions would have on ' .the plant. .Another example of operations personnel not being
fully cognizant of the plant status involved a failure to 4 restore the turbine driven auxiliary feedwater pump speed controller following recovery from a plant trip. The improperly set controller was not identified by the operators through two ' shift turnovers. Operators generally performed in a professional manner and took i pride in their work, There were-a few occasions where errors by_ the operators contributed to events or TS violations. In severalLeases, the procedures utilized did not provide sufficientLinstructions to ensure that all-the required actions were' performed.' One example involved the failure to remove , ' power to two reactor coolant system (RCS) safety injection _s ' accumulator isolation valves following surveillance tests, as
required by<the TS. Other examples involved securing the fueling cavity cooling fan with RCS temperature above TS limits, i securing the centrifugal charging pumps when-they were required ' as a boron' injection path, and filling the refueling cavity . withoutl venting the containment building, which pressurized the ' containment and-nearly caused a spill along the transfer canal- - in the adjoining fuel building. Operators later moved the fuel handling bridge crane without first releasing a rod cluster
control assembly. j Licensee management appeared to' be committed to quality. , . operation and worked to instill that attitude in the operators. t However, it was noted that the operations department was not l - represented on~the ALARA committee. Management relied on the operators to perform proper plant operations in accordance with j the TS and approved procedures. Procedures were: written to' ! provide' maximum flexibility.where possible and relied on the skill of the1craf t'and training to assure that some safety- related activities were properly performed. Some of the above -noted errors involved failure to follow procedural steps that were clear; others occurred because procedural steps were vague _' or' silent. In reviewing these events, corrective actions often l _ , _. _
. ,. .. . .g. involved additional training to maintain procedural flexibility. The extent to which management relied on operations and other personnel to take appropriate actions and make proper decisions, which were not covered by procedures, placed an additional responsibility on the overall training program to ensure that all personnel were qualified to make those decisions. The licensee enhanced operator performance by completing modifications to the rod control system during the fourth refueling outage. This modification was effective in that the rod contro11 system was subsequently operated in automatic. This o allowed improved operator cognizance of plant transients without 'having to manually operate the control rods to maintain the ' proper reactor parameters. Quicker response to transients was also possible with the system in automatic. The licensee continued a college education program for some of the licensed operators. These operators were taking courses
- on a full-time basis leading to a bachelors degree in nuclear
engineering technology. -The operators returned to duty during -refueling outage periods and they returned to CJty during semester breaks. The operators, therefore, maintained their licenses and remained current on plant conditions and training. .This program wks consistent with the NRC's policy concerning i shift technical advisors. -The licensee continued their efforts toward improvement of operational._ activities, EDG operations, and departmental communication. There were some weaknesses identified in these improved areas. Several problems were noted that appeared to be related to a lack of procedural adherence or procedures which relied on'the-ski.11 of the craft which were not adequately- provided for through training. The. operators demonstrated that they were cognizant of the facility-design'and thatttheir training had been effecti_ve in assuring that they> properly ' responded to plant events. 2. Performance Rating .The licensee-is_ considered to be in Performance Category 2 in- this functional area. i- 3. Recommendations a. NRC Actions Inspection effort in this functional area shoult' be consistent with the core inspection program.
_ ___ ___._ ' .. , ,~ r . g. b. Licensee Actions ,. Departmental communications between operations and - mt.intenance should be emphasized, particularly with regard 'to troubleshooting activities. The licensee should continue to promote self-critical assessment of plant operations. Management should utilize the results of the assessment to ensure they had adequately disseminated their expectations to the operations staff. This needs to include identifying personnel and program weakness promptly ! to management for resolution. B. Radiological Controls ' 1. Analysis The assessment of this functional area consists of activities related to radiation protection, radioactive waste management, radiological effluent controls:and monitoring, radiological environmental monitoring, water chemistry controls, o Tradiochemistry and water chemistry confirmatory measurements, and transportation of radioactive materials. Problems were identified in the radiation protection program < during the previous SALP assessment involving lack of management ' involvement in the radiation protection program, lack of attention.to detail and failure to follow established nprocedures, the need to revise existing procedures, lack of an aggressive audit program for;theiself-identification of problem areas, and:the lack ~ of oversight of ongoing work involving
- radiological controls.
In this SALP assessment period', the two inspections of this program area indicated that-the licensee-has taken significant steps--to make improvements in this program, ' The licensee is aware of these past problems and has worked- m aggressively to resolve most of them.- However, continued > improvement is still-needed in some areas. For example, u . , ' inconsistencies.were+noted in existing procedures regarding the ' issuance.of' respiratory protection equipment, tritium bioassay requirements,=and the release of items from the radiation - controlled area. The licensee recognized the need.to improve i - - department ~ procedures and plans to conduct a ~ thorough review of .all procedures during mid-1990. ' Increased management . involvement was evident in-the performance , , of. quality assurance (QA) audits of the radiation protection- program and increased oversight of ongoing work activities by ," department' supervisors. Staffing for the radiation protection department has been maintained at an adequate level to support - routine plant operation. Several new positions were approved and filled during the assessment period. All permanent positions were filled with licensee personnel. Contractor >
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. .' -10- < s health physics technicians we"e used to support the permanent J plant staff during outages,'ut the licensee does not place a heavy reliance on contractSrs during normal plant operations. The. licensee had maintained a stable staff.with a low personnel turnover rate.. The licensee had implemented a comprehensive training and qualification program for personnel at the technician level. A program had been implemented to encourage technicians to become certified through the Natienal Registry of
Radiation Protection Technologists (NRRPT). Several technicians had received NRRPT certification during this assessment period. However, a well defined program had not been established for ' department _ supervisors and professionals. The training department was understaffed concerning the number of qualified - instructors assigned to provide training for the radiation protection organization.. In some cases, these instructors were
' not provided adequate time to prepare for.their training
sessions. Some of the contractor personnel filling senior . radiation protection positions had limited experience. This was L* L, in part due to the lack of a procedure to provide guidance for
. persons _ responsible for evaluating the past work histories of prospective contract technicians. Improvements were made in the area of keeping radiation exposures "as. low as is reasonably achievable" (ALARA), _ p Management had provided increased support for the ALARA program. Improvements were noted concerning-staffing, procedures, and , - ' ALARA-summary reports. An ALARA handbook was developed and g issued to plant personnel. The ALARA Committee provided good support for-ALARA' activities. Only:14 person-rem were expended a during:1989. This period did not include any major outages, but ~ theflicensee had also maintained low-person-rem in that the ! i average annual. person-rem for 1986-through 1989-was only 147. c , 'The licensee established a 312 person-rem. goal lfor 1990. Based - on scheduled work activities, it appears that the-licensee should be able to meet the projected person-rem goal. ! The radioactive waste management ~and radioactive effluent " control.and monitoring programs were inspected once during the - . assessment period. No violations were identified. Radioactive " effluent sampling,; analyses, and controls were adequately- - 1 defined-in plant procedures. An effective liquid and gaseous ' ~ y release-permit program was in place to assure that planned ' continuous and. batch radioactive effluent releases to the , environment receive proper review and approval-prior to being ireleased. .No-problems were identified concerning staffing, training, or qualification of personnel responsible for 4 operating-the radwaste systems. The licensee had-implemented a radwaste management program that demonstrated compliance with ' .the Radiological Effluent Technical Specifications and the Offsite Dose Calculation Manual. The semiannual effluent reports were submitted in a timely manner and contained the s --e _.--._,___-___m_______m._ . . . . .
- . -- . ,o . , , (j' -11- 1 l l required information. Testing and surveillances of the plant air cleaning system were performed as required. , .The radiological environmental monitoring program was inspected once during the assessment period. No significant problems were identified. Regulatory requirements were met regarding sample collection, analyses, and offsite dose calculations. The group assigned to implement the environmental program included an
adequate number of well-qualified personnel. A formal training program had not been established for personnel responsible for implementing the environmental' program. Most of the training provided to the group was through on-the-job training. Program
. -review was accomplished by the performance of routine QA audits.- The audits were designed to verify compliance with environmental u procedures, but did not contain comments or recommendations regarding program improvement items. The. audit team did not include a member with technical expertise in radiological ) environmental matters. The radiochemistry and water chemistry confirmatory measurements , were-inspected'once during the assessment period. The inspection also included radiochemistry and water chemistry confirmatory-measurements using the Region IV mobile laboratory. ' An adequate staff had been maintained to implement the radiochemistry and water chemistry. programs. A staffing > turnover rate.of about 20 percent.was noted, but the staffing = . changes did not seem to affect the performance in this area. No problems were: identified in the areas of personnel ' qualifications, enforcement, resolution of technical issues, or s responsiveness to NRC initiatives. . Management oversight < included comprehensive-QA audits of the radiochemistry and water chemistry programs.' Westinghouse and the Electric Power D Research Institute (EPRI) guidelines and recommendations had. been incorporated.into.the plant chemistry procedures to ensure- , ' M that water chemistry parameters were properly maintained. The h . results'.of the radiochemistry confirmatory measurements' l +- indicated 96' percent agreements between NRC.and licensee- ' results. Water chemistry confirmatory measurement results " indicated 100 percent agreement. These results reflect high quality programs-in both areas. ' The transportation of radioactive materials and solid waste processing programs were inspected once during the assessment period. The. licensee had established implementing procedures- for'these programs.that addressed such items as waste classification and characterization, procurement, and selection ' of packages, preparation of packages for shipment, and delivery L of the completed packages to the carrier. The level of staffing L assigned to handle the transportation and solid radwaste D activities was adequate. The individual responsible for supervising these programs spent most of his time involved with , L 1- , .. - ._ -. .
. . . . -12- administrative matters, which reduced the amount of time available to devote to the oversight of field activities. No problems were identified concerning enforcement, personnel training and qualifications, or resolution of technical issues. A declining trend was observed in the radiation protection area during the two previous SALP assessments. In response to the 1989 SALP report, the licensee made several specific commitments to improve the radiation protection program. The licensee had expended considerable resources and management effort to address various identified problems. The licensee had stopped the declining trend and there was a good indication that the radiation protection program would continue to show improvements in the future. 2. Performance Rating The licensee is considered to be in Performance Category 2 with an improving trend in this functional area. 3. Recommendations a. NRC Actions Inspection effort in this functional area should be consistent with the core inspection program. Regional initiatives should be performed in the areas of: (1) training and qualifications, (2) the effectiveness of the licensee's program for the self-identification of problem areas, and (3) review of radiation protection implementing procedures. b. Licensee Actions The licensee's management should continue to provide their present level of support for the radiological controls program. Continued development of radiological procedures will help to ensure the consistent implementation of the radiological control program. C. Maintenance / Surveillance 1. Analysis The assessment of this functional area included all activities associated with predictive, preventive, and corrective maintenance: procurement, control, and storage of componencs, including qualification controls: installation of plant modifications; and maintenance of the plant physical condition. It included conduct of all surveillance, inservice inspection, and testing activities. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
, , 1 x ,, f= . - -13- 1 This aren'was inspected on a routine basis by the resident inspectors- .! and periodically by regional inspectors. The regional inspections I . included: two regional initiative team inspections; verification of ' isolation component exemptions (VOICE) and system entry retest (SERT). An inservice inspection utilizing the nondestructive examination (NDE) van was also conducted. The previous SALP Board recommended that the licensee: (I) complete
g. their review of surveillance requirements and related procedures, ! (2) increase their effort in assessing quality of maintenance ' activities, and (3) improve root cause analysis. ! During this SALP period, the licensee was more effective in ensuring proper corrective action was taken to correct surveillance identified deficiencies. There were no examples of surveillance identified deficiencies not being corrected which la d resulted in equipment 3 being inoperable per the TS. ! A weakness which had been carried over from the previous SALP assessment period,'concerning the adequacy of surveillance -j , procedures, improved during this assessa nt period. The licensee L identified one example at the beginning of the assessment period . ' 'where: a TS-required surveillance had not been implemented in the F surveillance program. The surveillance involved a diesel generator ! fuel oil cloud point analysis. The example was promptly corrected. .2 One inspection was performed to followup on maintenance program
concerns. It was found that the licensee had.taken actions to strengthen n >eral areas--which were previously identified as weak'. There,was evidence of management involvement in most phases of'the maintenance process, including prior planning with the appropriate consideration for operational priorities in both the maintenance and- surveillance-areas..'The plant manager was involved in the- decisionmaking process for significant maintenance activities, and took an active'part in a daily meeting held to' discuss,'among other things, both emergent and planned maintenance and surveillance ' activities. Personnel in the maintenance organizations'were ir 'iuded in the licensee's team building training: program, . Management-involvement in the inservice test (IST) and inservice g* . inspection (ISI) programs was evident. The licensee had a good inservice test-administrative program for assuring compliance with ASME. codes and the Safety Evaluation, Report. The IST program check 6 valve' disassembly'and inspections were performed during the previous . outage: as required by IST program relief. request. The ISI program . ! I .was reviewed, in part, by the NRC NDE inspection. The IST program E was properly performed with the use'of detailed procedures. Records of the above programs were properly retained. ' In December 1989, NRC staff assessment of the licensee's trending program, as part of followup to maintenance program concerns, l l ' ' .
. - , . . , .: > . -14- 4 concluded that little work had been performed to improve performance in this area. The lack of an effective trending program was identified to the licensee as a weakness in 1988 during the maintenance team inspection. Sinco that time to December 1989, the licensee had not determined what parameters should be trended or how- trending information should be evaluated. Subsequently, the licensee made some progress in trending. In the past, data was available for trending such as vibration, flow rates, oil analysis, and leak rates, but the information was not compiled in a useable form. Some trending was performed informally by various personnel. The licensee was planning a trending system of component failures from corrective work request data. This showed'that some progress had been made on the ' trending issue, but that significant work remained. The licensee's quality verification program was not effective in this case for following through with the identified trending weakness. The onsite policies and procedures for controlling maintenance and surveillance activities were generally adequate. The licensee'was found to have good corrective maintenance procedures and detailed. procedures for complex surveillance activities. The licensee has shown an ability to effectively manage complex surveillance and .: maintenance activities. The containment building tendon surveillance was controlled and performed well. An electronic component in the main turbine electrohydraulic control unit was replaced while the turbine was-on the'.line. ~ The licensee's program for scheduling surveillances was not - completely effective. There were several surveillance scheduling errors identified by the licensee duringJthe assessment period. These instances involved both personnel. errors in scheduling and ' implementation and a weakness with the licensee's program for , scheduling surveillance activities. The licensee procedurally - crequired the surveillance coordinator to weekly review the past due a surveillance procedure inquiry report (PDSIR).- However, it was found - that the .PDSIR entries did not accurately reflect actual cases of missed surve11' lances. The-VOICE inspection revealed that the' licensee had'a-strong program l 'in-the area.of containment integrated leak rate testing (CILRT) and ! local leak rate. testing. During-a 100 percent visual inspection, the L _ inspectors did not observe any significant discrepancies. The-SERT- inspection covered modifications, temporary modifications, and H _ maintenance activities. It was determined that the licensee had a L strong program for determining the need for retest after maintenance p and modification activities and for identifying the appropriate type I of. retest. The licensee also had a good program for-developme t and ~ performance of adequate procedures for retasts of structures,. components, and systems following plant modifications and maintenaime -activities. . l Although the licensee's corrective maintenance program demonstrated good control of maintenance, this same control was not evident with L p L b . --
, _ . .? .i f -15- the maintenance troubleshooting program. The established maintenance troubleshooting program did not ensure that control room personnel were cognizant of all troubleshooting activities and the scope involved and did not ensure the activity was properly s documented. On one occasion, a worker was found inspecting a transformer without the knowledge that a work request existed for the job. In another case, workers tightened body-to-bonnet bolts for a number of diaphragm valves without documenting the specific valves on which the bolts were tightened. Troubleshooting activities contributed to an LER when maintenance workers lef t a panel to an auxiliary feedwater pump room cooler off. That left the cooler and the pump inoperable. Troubleshooting a digital rod position indication problem gave the control room operators several unexpected alarms and indications. The licensee's procedures provided much latitude for- skill-of-the-craft knowledge instead of detailed ' troubleshooting and maintenance instructions. This latitude appears ~ to' be carried over to documenting work accomplished and informing the- control room of potential indications, alarms, or other systems r affected by those activities. Performance of root cause analysis has shown improvement. Management has' generally been prompt at_ requesting root cause analyses and in. many cases the analysis has been' good. The licensee expanded efforts to identify the root cause(s) for the main feedwater isolation-valve -four-way~ slide. valve problems. 'The identified problems were corrected and the surveillance frequency increased to' assure that the valves were_ operating properly. On the other hand, the sensitivity to the _ potential need'for root cause analysis had not reached all areas of the organization.- For example, a circuit breaker was discarded before' root cause analysis could- be performed. -Improvement was noted in EDG operation. The licensee performed -several additional"24-hour reliability runs of the EDGs above those . required by;the TS. These additional runs were:also performed prior to-and after the preventive maintenance tasks performed on the EDGs during the last refueling outage. However, maintenance problems continued to exist'regarding the EDGs. A fire occurred as the result of using an unacceptable sealant for repairing leaks on the exhaust manifold.: Fretting and leak- problems were also noted on' fluid lines. These. items had been noted by the licensee and were included in their work request program. In an effort to resolve the EDG problems,sa maintenance. engineer and system engineer have been assigned to the. EDGs, -This effort appeared to be effective in resolving EDG maintenanct problems before they became operational problems. The licensee improved their performance in the areas _of root cause analysis, ensuring that appropriate corrective action was taken for surveillance identified deficiencies, and ensuring surveillance requirements were properly implemented through the surveillance program. The maintenance and surveillance programs were generally well controlled. However, improvement of the trending program was . .
- - - - _ _ _ _ _ _ . _ _ . _ _ . . _ . . . . . - . . . . . . . . . .. . . . - . . . _ - - '.: , c .w '~ 16- slow and lacked direction. The surveillance scheduling program did not provide the proper assessment tools to the surveillance program coordinator to reliably schedule the required surveillances. Troubleshooting activities were not well documented to demonstrate ' proper notification of control room personnel or specify the work performed. 2. Performance Rating The licensee is considered to be in Performance Category 2 in this functional area.- 3. Recomrendations a, ,NRC Actions Inspection effort in this functional area should be consistent with the. core inspection program. In addition, regional inspection initiatives should be performed to follow up on maintenance team inspection issues. The control and documenting of maintenance-troubleshooting activities and the surveillance- scheduling program should be specifically reviewed, b. Licensee Actions The licensee-should continue to provide daily management involvement-with the maintenance and surveillance programs. ' . Additional licensee attention should be directed toward < establishing an effective trending-program, surveillance tracking s , program, identifying the root cause for personnel errors committed during implementation of the surveillance program, and improving controls over maintenance troubleshooting activities. D. Emergency Preparedness 1. Analysis- The assessment of this functional area-included activities related to the establishment at' implementation of emergency; plan and implementing procedures, licensee performance during exercises and actual events that test emergency plans, and -interactions with onsite-and offsite emergency response organizations during exercises and actual events. During this assessment period, region-based ~and NRC contractor inspectors conducted two emergency preparedness inspections.- The first inspection consisted of observation and evaluation of the annual emergency response exercise. The second inspection involved a review of the operations status of the emergency preparedness program.
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. . .' -17- . The NRC staff found that the licensee's preparation for, and P' response to, the December 1989 emergency response exercise was good. The scenario was challenging to major segments of the emergency response organization. Also, the use of the simulator during the exercise greatly contributed to licensee player performance by providing realism.
- mergency response personnel
in the control room and emergency operations facility (EOF) proved proficient in detecting, classifying, and declaring emergencies. The licensee's players made prompt notifications to offsite authorities. Operators in the control room worked well as a team and effectively utilized off-normal and emergency procedures. The command and control demonstrated by managers in the emergency response facilities was observed to be strong. The licensee's overall performance during the exercise was demonstrative of a licensee fully capable of implementing the necessary measures in the event of an actual emergency. . 'Although the licensee's overall performance during the exercise was_ good, NRC evaluators identified some exercise weaknesses. One weakness involved inadequate information flow in the EOF. that resulted in the failure of key EOF staff,-including the emergency director, to be aware of critical reactor conditions such as the uncovery of the core and the increase in hydrogen levels. Another weakness involved several scenario problems that caused substantial deviations.from the time line, large differences between actual and intended data, and the failure to meet an exercise objective. Following the exercise, the -licensee conducted a self critique and was able-to identify and ~ characterize several exercise weaknesses, improvement items, and examples-of good performance. .The licensee did not, however, identify the above-described weaknesses. The licensee . ultimately scheduled corrective measures to be completed before the end of June 1990. .The inspection of the operational: status of the emergency , preparedness program identified a problem involving the training of emergency response personnel who are responsible for h ', performing dose. assessments.- This deficiency was identified through interviews of teams of ' emergency responders, including - those who would perform dose assessments of offsite releases. 4 Most of the teams interviewed made simple errors in calculating 4 , offsite. doses which-resulted in, or could have resulted in, nonconservative emergency classifications or' protective action recommendations being made. A factor contributing'to this finding was the widely expressed reluctance among the dose ' assessors to perform computer-based dose assessments because they believed the software program was slow and difficult to use. Aside from this deficiency in dose assessments, all teams demonstrated a good understanding of the emergency plan.
._- ., . -18- i . Overall, the annual QA audit was found to be extensive in scope 3 and depth as well as in resources employed during the audit. ' The audit employed five auditors (one from outside the ' licensee's organization) for a duration of about 2 weeks. It was favorably noted that training interviews were incorpurated as an integral part of the audit effort. Although NRC review of the audit program activities resulted in a favorable impression,
some corrective actions were not implemented a year af ter identification. During the assessment period, NRC personnel found that several , aspects of the licensee's program either improved from the , previous period or continued to be exemplary of a strong program. Corporate management involvement was apparent in various aspects of the implementation of the emergency preparedness program. Emergency facilities and equipment were found to have been maintained in a secure and good state of readiness. Organizationally, the emergency planning department was moved to a higher reporting levd, eliminating the manager of health physics in the reporting chain between emergency planning and the manager of plant support. In addition, the emergency planning staff has added two professional staff members. During the assessment period, the licensee replaced three emergency pager systems with a single, more modern pager system.
The new pagcr system provides greater geographical coverage. The licensee has issued the new pagers to plant and corporate , emernency response personnel and the two NRC resident inspectors. The licensee has continued to maintain a highly effective . , program throughout the appraisal period. Management et,mmitment !, and dedicated efforts to seek improved performance have been L evident. I 2. Performance Rating l L The licensee is considered to be in Performance Category 1 in this area. 3. Board Recommendations a. Recommended NRC Action ' , Inspection effort in this functional area should be consistent with the core inspection program. " b. -Recommended Licensee Action Licensee management should maintain the present level of support for the emergency preparedness program. ..
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' . . -19- E. Security 1. Analysis The assessment of this functional area included activities related to
the security of the plant including all aspects of access control, security checks, safeguards, and fitness-for-duty activities and controls. During this assessment period, this area was routinely reviewed by the resident inspectors. Region-based physical security inspectors ' conducted three inspections. One inspection of the licensee's program for handling Safeguards 1 Information ($GI) was conducted at both the Wichita corporate offices and at the plant site. The inspection found that the licensee had experienced numerous occasions over the past 2 year period when SGI had not been handled properly. Following NRC's compilation of the individual events and a QA audit (89-0328) conducted the month before the inspection, the licensee became aware of the extent of the problem. Consequently, the licensee developed two consecutive task forces to investigate the root cause, issued an SGI stop work order, i and issued a corrective action request. These actions were discussed with NRC pers unel during a management conference at corporate facilities a A nuary 11, 1990. Ultimately, the licensee centralized the storage u m control over SGI documentation, provided awareness training for involved personnel, and made procedural revisions for evaluating the significance of and reporting of potentially compromised SGI. The licensee's "esponses to the inspection findings were exceptional and have apparently resolved the problem. In regard to the licensee's f1tness-for-duty program, the NRC inspection effort was limited to the resident inspector observing a , training session given by the licensee. The training appeared to be in accordance with the requirements of 10 CFR 26. The licensee's annual audit of the physical security program was performed using an experienced lead auditor and an individual from another licensee who had expertise in security operations. The audit appected to be comprehensive, and the licensee appeared to have responded promptly in correcting adverse findings. + The licensee maintained a good access control program despite some routine-access control problems that were self-identified.. An example of the licensee's good performance in controlling visitor t access was the Family Open House that was conducted on October 28 and 29, 1989. During this 2-day event, many of the licensee's employees brought their relatives to tour portions of the facility located 1 - . _ . . _ . ,
. o o- . -20- within the protected area. The licensee met with the NRC regional staff before the event and discussed the planned visitor processing. These tours, v.hich were challenging to the security program, were accomplished within the provisions of the security plan. Management has demonstrated good support for the physical security program. The licensee has been generally responsive to the need to promptly correct self-identified problems promptly. As an example, the licensee reported a problem with escort personnel transferring escortees and subsequently implemented a stronger process whereby - transfers were to take place. Management support for the physical security p 7 gram was also evident in the attention given to maintaining security equipment. Specifically, equipment testing was conducted within the specified time frequencies and generally resulted in optimum equipment performance. During the assessment perlod, the licensee completed the installation of a new microwave intrusion detection system and a new stride breaker fence. These hardware upgrades improved the security force's ability to respond to an assault on the protected area perimeter. The licensee had an ample number of supervisors, fully qualified security officers, and support personnel assigned to the security department to continue its effective nuclear security performance. The security staff continued to perform at a high level. The licensee continued to maintain a highly effective nuclear security program throughout the appraisal period. Management commitment and dedicated efforts to seek improved performance have been evident. 2. performance Rating The licensee is considered to be in Performance Category 3 in this functional area. 3. Board Recommendations a. Recommended NRC Action Inspection effort in this functional area should be consistent with the core inspection program, b. Recommended Licensee Action The licensee management should maintain the present level of support for the physical security program. ! .' l F Engineerino/ Technical Support
2.- Analysis ' l. The assessment of this area evaluates the adequacy of technical and engineering support for all plant activities. It includes all . ._ _-
. - l i c . . 0 -21- licensee activities associated with the design of plant modifications; engineering and technical support for operations, outages, maintenance, testing, surveillance, pror.urement, and training. F This functional area was inspected on an ongoing basis by the resident inspectors and, periodically, by region-based personnel.
There were three areas identified during the previous SALP period where the licensee should improve performance. These areas were drawing configuration control, licensed operator exam performance, and engineering involvement in operational technical issues. Configuration management regarding revision of control room drawings has shown some improvement. However, general drawing revision still take a long time. The licensee was implementing a computer aided , design system to improve the quality and timeliness of revisions to controlled drawings. The previous SALP assessment identified problems with the quality of training that resulted in excessive failure rates among the reactor operator candidates (5 out of 6 failed). During this SALP cyc13, a single site visit was made to administer retake examinations to the individuals for the purpose of licensing. The individuals passed the examinations and have been issued the apprnpriate licenses. Because the examinations only involved individual candidates retaking the specific sections of the exam that they had failed, this exam sample of the training program was insufficient to determine whether the program weaknesses had been corrected. The observed deficiencies were predominantly in the knowledge of basic principles and theory and were not reflected in plant operations. The licensee's training program improved with respect to . communications. Communications were established and functioning well l. between the training and plant operations department, Student evaluations of instructors and the training program were promptly L reviewed by the training staff and the appropriate actions taken. The training department staffing and personnel turnover rate was identified as a concern in that vacancies in the department added stress and additional workload on the present staff. This turnover rate was noted for plant operations and health physics training staffs. Subsequent discussions with the licensee revealed that the licensee was implementing corrective actions to resolve this problem. The licensee showed some improvement in engineering involvement in operational technical issues. The licensee had established the industry technical information program (ITIP) for reviewing and evaluating industry information applicable to the plant. In response to the last SALP, the licensee began to solicit information that they may not have readily available. From that standpoint, the program has become more proactive. The licensee strengthened procedures to , _ .. . . - . . . ~ . ,
. . , $' i . -22- ensure that incoming items are trcnsmitted to the ITIP coordinator for inclusion in the program. Prior to the ITIP procedure revisions, significant items had been either excluded from the program or an operability determination was not properly performed. Two examples , were the containment cooler seismic support and scienoid operated ' valve positioning. Other improvements in ITIP included meving the manager of nuclear plant engineering next to the operations manager to facilitate better communications and program changes that further support those managers promptly discussing design basis and operability issues that may arise. An informal goal of 3 days was established by nuclear plant engineering to present operations with a design basis determination, of potentially significant design concerns, so that operations could make an operability determination. The adequacy of the ITIP program changes was not assured this SALP period. ' Engineering evaluations were generally adequate and records and plant performance data were generally complete, well maintained, and available. The engineering staffing levels and expertise were satisfactory. The licensee provided adequate controls associated with changes and modifications to the facility. One concern was identified by NRC inspectors regarding the lack of attention to details associated with modification program procedures and implementation activities. One i example was identified where a 10 CFR 50.59 review was not performed, although required, for a temporary modification made to 1 l the essential service water system. J l ' ' The management philosophy on procedure flexibility discussed in the plant operations and maintenance / surveillance areas was applicable to i this area as well. Licensee management preferred to allow personnel flexibility within the the bounds of procedures, especially administrative procedures. This was noted within the ITIP procedure ' fur the time allowed in coming to a design basis determination. There was a reliance on the knowledge level, communications, and common sense of personnel to perform properly in specific conditions. The licensee's outage management organization had improved during the previous SALP periods. Continued improvement was noted during the
I fourth refueling outage which was initieted and completed during this I SALP period. The licensee had added SRO licensed individuals to the I outage management organization. This resulted in an improvement in the licensee's ability to plan and schedule work activities during the refueling outage. The work scope 6stablished for the fourth refueling outage was comparable to pre <ious refueling outages. During the fourth refueling outage, the licensee identified a problem with heat exchanger tube integrity on a containment unit cooler, EDG lube oil cooler, and several pump room coolers. These cooler problems were . .
. . . . -23- not anticipated by the licensee and represented considerable growth in work effort. Notwithstanding the improved management of the outage schedule, there were several instances where workers and operators failed to follow procedure leading to minor contaminations or equipment damage. The licensee improved in the area of design configuration control, although general drawing updates still involved a lengthy completion period. Improvements were made in communications between operations and the training department. The loss of experienced training instructors added a significant work load to the remaining staff. . The time to complete engineering program evaluation of some ! operational technical issues was lengthy. The licensee continued to l improve in the area of outage management. Modifications to the facility were, generally, well controlled. 2. Perfortrance Rating The licensee is considered to be in Performance Category 2 in this functional area. 3. Recommendations
a. NRC Actions Inspection effort in this functional area should be consistent with the core inspection program. Regional initiatives should include an inspection to further evaluate the modification program and the training department staffing levels. The effectiveness of the ITIP program should be reviewed. b. Licensee Actions Licensee management should concentrate on the completion of the i program and procedure enhancements regarding the modification I program and stressing attention to detail in all activities, The training department staf fing levels should be evaluated. l g l Management should continue to increase engineering involvement h in plant operations. The licensee should assure that procedural. detail is adequate to ensure that tasks will be ! performed in accordance with approved guidance, j G. Safety Assessment /Ouality Verification 1. Analysis
The assessment of this functional area includes all licensee review activities associated with the implementation of licensee safety policies; licensee activities related to amendment, exemption, and relief requests; response to NRC generic letters, bulletins, and information notices; and resolution of Three Mile Island (TMI) items and other regulatory initiatives. It also includes the licensee's activities related to resolution of l
_ _ _ ._ . .. . . -24- safety issues,10 CFR Part 50.59 reviews,10 CFR Part 21 . assessments, safety committee and self-assessment activities, root cause analyses of plant events, use of feedback from plant quality assurance / quality control reviews, and participation in ' self-improvement programs. It includes the effectiveness of the licensee's quality verification function in identifying and correcting substandard or anomalous performance, identifying precursors of potential problems, and monitoring the overall performance of the plant. The licensee performed well in the area of saftty assessment. This included licensee TS amendment submittals to the NRC, resolution of complex technical issues, and supporting industry groups. However, critical self-assessment in the area of plant operation, although improved, was noted to have needed additional strengthening. This was evident through the number of personnel and procedural errors noted during the latter part of the SALP perioc', During the assessment period, there were 11 license amendments issued. The Technical Specification request submittals were almost always consistently thorough and indicated an assurance of quality including management involvement. In addition, the - submittals indicated an understanding of the technical issues and how the issues relate to plant safety. In these instances when it was necessary to return to the licensee for additional information or clarification, the licensee provided prompt and complete responses to the staff. The quality of the engineering for the Technical Specification amendments indicated that the licensee had technically competent and adequately staffed engineering capabilities. Three of the licensee amencments most notably demonstrate how the licensee was capable of coordinating the engineering and operations staff in managing and resolving complex technical issues. Generic Letter 88-17. " Loss of Decay Heat Removal," directed licensees to identify and modify those Technical Specifications that could limit or restrict operation of shutdown cooling systems. The licensee proposed a number.of significant procedural and hardware modifications that enhanced plant operations during Modes 5 and 6 when decay heat removal relies , on the residual heat removal system. This was a major effort by ' the licensee. The -second license' amendment of note was the reduction of essential service water flow to the containment fan coolers. This Technical Specification submittal was the culmination of a , long-term engineering study and the critical path plant modification during the refueling outage to redistribute the service water system flow rates. This work also represented a L licensee commitment to a long-term staff concern regarding service water system pipe erosion and corrosion.
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.. .. . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ + ,, , . -25- Finally, the licensee's Technical Specification submittal proposing operability requirements for the steam generator atmospheric dump valves represented a complex engineering analysis relating to the steam generator tube rupture analysis. Generally, the license submittals were made sufficiently ahead of the required date such that the staff could review them as part of their regularly scheduled work. However, two exceptions to this were license amendment submittals that were needed for the recent refueling outage and were submitted only 4 weveks ahead of the scheduled outage. During this assessment period the licensee's responsiveness to NRC's Bulletins and Generic Letters continued to be technically complete and timely. There were also several staff efforts to survey the implementation status of generic activities during the assessment period. Specifically, the staff requested implementation status on the TMI action plan, unresolved safety issues (USI), and generic safety issues (GSI). Each of the staff's requests required a relatively short response time from the licensee. In addition to providing accurate and timely responses to these requests, the backup records retained by the -licensee for each item were well organized and traceable. The licensee continued to show a willingness to participate in industry groups and to be the lead plant on important issues. The licensee is participating in the Westinghouse Owner's Group in the Technical Specifications improvement program on Westinghouse plants and in a risk-based inspection guide program. In addition, the licensee continued to support voluntary NRC initiatives such as the voluntary response to Generic Letter 90-01 regarding the NRC regulatory impact survey. The licensee's self-assessment program, including quality verification, was not completely effective in identifying problem areas and ensuring that appropriate corrective action was taken to prevent recurrence. The previous SALP report also identified weaknesses in this functional area. These weaknesses included inadequate and untimely corrective action. Examples of these weaknesses identified during this assessment period included the trending, surveillance, and maintenance troubleshooting programs, and E0P verification items. NRC violations continued to cite examples of inadequate or untimely corrective action. The line organizations were generally effective in identifying and resolving specific problems, but did not always ensure that the deficiencies were completely resolved to prevent their recurrence. Examples included multiple surveillance test scheduling errors and repeated problems with the control of maintenance troubleshooting activities. _ _ - - - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - .. . . . .. .. . . . -
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~26- j The licensee's assessment of two of the reactor trips did not . ' provide documented assurance that the plant was ready for restart. However, the appropriate short-term corrective action had been taken in each case. - The licensee had a program to evaluate and track industry operating experience. The ITIP program was effective at assigning an item to the cognizant part of the organization for evaluation and tracking the status of the item. The program had been recently revised to more readily surface those items for prompt action that had higher safety significance. The effectiveness of this program had not been demonstrated at the > end of the assessment period. . The licensee demonstrated good overall performance by the , nuclear safety review committee (NSRC), plant safety review committee (PSRC), and independent safety engineering group - nuclear safety engineering (NSE). However, a specific concern was identified. The licensee had not provided formal oversight and audits (NSRC, QA, NSE, or special) of the corrective actions completed or in progress to address the weaknesses identified by the emergency operating procedure team inspection, completed in early 1988, to ensure that the actions taken were adequate. QA audit activities had been expanded to provide a comprehensive ' review of program areas. Increased management involvement was noted for the OA assessment of the radiological program. The effort could have been improved by including an individual with a strong technical health physics background. The licensee's efforts did include the use of independent offsite organizations. This organization had assisted in the area of ' health physics and'QA. The licensee provided prompt and technically adequate licensee ' amendments which demonstrated coordinated efforts between engineering and the operations staff. The licensee participated in industry groups and was the lead on many important issues. The licensee s self-assessment and quality verification capabilities continued to need improvement. The NSRC, PSRC, and NSE were effective overall. l 2. performance Rating The licensee is considered to be in Performance Category 2 in i L this functional area. ! I i . - - - ,
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, ' . -27- 3. Recommendations 4. NRC Actions Inspection effort in this functional area should be consistent with the core inspection program. Regional initiatives should be performed in the the area of licensee self-assessment capabilities and the effectiveness of their corrective action program. l b. Licensee Actions The licensee should evaluate the effectiveness of their corrective action and self-assessment programs, The notable strong performance in evaluating complex issues and the participation in industry significant issues should continue, Management should ensure that QA teams include members with ! technical expertise in the areas under review, V, SUPPORTING DATA AND SUMMARIES A. Licensee Activities 1. Major Outages The fourth refueling outage was conducted from March 9, 1990, to May 16, 1990, 2. License Amendments During this assessment period, 11 license amendments were issued. One of the more significant amendments was:
Reduction of essential service water flow to the containment fan coolers. Amendment 38, 3. Sionificant Modifications The rod control circuitry was modified to facilitate
reactor operation with the control rods in automatic, Service water flow through the system was redistributed to ' improve system performance and minimize erosion / corrosion problems. B, Direct Inspection and Review Activities NRC inspection activity during this SALP cycle included 43 inspections performed with approximately 4423 direct inspection hours expended.
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l . -28- C. Enforcement Activity The SALP Board reviewed the enforcement history for the period April 1,1989, through June 30, 1990. The enforcement history is tabulated in the enclosed table. No orders were issued. TABLE ENFORCEMENT ACTIVITY NUMBER OF VIOLATIONS FUNCTIONAL AREA IN SEVERITY LEVEL Weaknesses Dev* NCVs** V IV A ,, Plant Operations 1 2 B. Radiological Controls 1 C. Maintenance / Surveillance 3 2 D. Emergency Preparedness 2 1 E. Security 1 2 F. Engineering / Technical Support 2 G. Safety Assessment / 2 5 Quality Verification TOTAL 2 6 1 15 Deviations
Noncited violations
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THE ASSESSfDlT PERIOD, AND THE LICENSEE HAD f0T TAKEN fEtllliGFUL STEPS TO ,, . ADDRESS THIS FATTERN. ' . ? > )-. . ,J , t . ~' 1 i y 3 88 es ? > ' ' Li- . , , ,.-n.- . .-
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