ML20058P161

Package Consisting of Attachment 1 to Employee Concerns Program

ML20058P161
Person / Time
Site:	FitzPatrick
Issue date:	07/29/1993
From:	NRC
To:
References
NUDOCS 9312230105
Download: ML20058P161 (4)

Text

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EMPIDYEE CONCERNS PROGRAMS  ;

PLANT NAME: James Ac FitzPatrick LICENSEE: New York Power Authority- .l DOCKET #: 50-333 j

• NOTE: Please circle yes or no if applicable and add comments in the space l provided. ~

A. PROGRAM:

1. Does the licensee have an employee concerns program? Yes j

2. Has NRC inspected the program?. No l B. SCOPE: (Circle all that apply)

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1. -Is it for:  !

a. Technical? Yes-  !

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b. Administrative? Yes .

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c. Personnelissues? Yes .-

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2. Does it cover safety as well as non-safety issues? Yes l

3. Is it designed for: 'i

a. Nuclear safety? No (However, nothing precludes its use for l nuclear safety issues. A separate program, Deviation / Event l Report, is designed for handling nuclear safety issues.

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b. Personal safety? Yes 1!

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c. Personnel issues - inc'uding union grievances? Yes a 200040 1

4. - Does the program apply to 1.11 licensee employees? Yes 1

5. Contractors? Yes Issue Date: 07/29/93 A-1 '2500/028 Attachment

-n 9312230105 930729 ,

DR ADOCK 050003 3 g

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6. Does the licensee require its contractors and their subs to have a similar i program? No

7. Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns? Yes (However, the question is posed differently. [Do you have any suggestions for improvement or concerns for the way NYPA conducts activities on site?])

C. INDEPENDENCE:

1. What is the title of the person in charge? Resident Manager

2. Who does he report to? Executive VP Nuclear Generation

3. Are they independent ofline management? No

4. Does the ECP use third party consultants? No, however, other non-nuclear NYPA employes are used for certain issues followup (i.e.,

corporate attorneys, corporate auditors, human resource ' staff, etc.)

5. How is a concem about a manager or vice president followed up?

At the discretion of the Resident Manager.

D. RESOURCES:

1. What is the size of the staff devoted to this program?

Resident Manager, his secretary, and various line managers as needed (also see C.4 above).

2. What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?

None specific to the ECP staff.

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2500/028 Attachment A-2 Issue Date: 07/29/93

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• j E. REFERRALS:

1. Who has followup on concerns (ECP staff, line management, other)?

Principally line management, but corporate attorneys and human resour:e staff may be involved from time to time.

F. CONFIDENTIALITY:

1. Are the reports confidential? Yes (But not by any formal process, at the discretion of the Resident Manager.)

2. Who is the identity of the alleger made known to? Resident Manager only, but at his discretion others may be informed.

3. Can employees be:

a. Anonymous? Yes

b. Report by phone? Yes (And by walk-in [ Resident Manager's open door policy])

G. FEEDBACK:

1. Is feedback given to the alleger upon completion of the followup? Yes, written feedback.

2. Does program reward good ideas? No (Separate employee suggestion program provides monetary awards.)

3. Who, or at what level, makes the final decision of resolution?

Resident Manager

4. Are the resolutions of anonymous concerns disseminated? s Case-by-case, at discretion of Resident Manager.

5. Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)? On a case-by-case basis, but there are no auditable records.

Issue Date: 07/29/93 A-3 2500/028 Attachment

H. EFFECTIVENESS: ,

I. How does the licensee measure the effectiveness of the program?

Currently do not measure effectiveness.

2. Are concerns: .!

a. Trended? No i

b. Used? Yes

3. In the last three years how many concerns were raised? 2  !

Of the concerns raised,- how many were closed? ! What percentage were substantiated? o

• Data not available. 1

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4. How are followup techniques used to measure effectiveness

' 1 (random ' survey, interviews, other)? ' Not done.

5. How frequently are internal audits of the ECP conducted and by -

whom? Not done.

I. ADMINISTRATION /TRAININd: I

1. Is ECP prescribed by a procedure? Yes, Plant Standard, STD-li200, .t Employee Feedback. j

2. How are employees, as well as contractors, made aware of this .i program (training,' newsletter, bulletin board, other)? -

Drop box located at plant security entrance / exit. -,

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k 2500/028 Attachment A-4 Issue Date: 07/29/93

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.[  %+f UNfTED STATES

• Q y g NUCLEAR REGULATORY COMMISSION gg E 'j REGloN I

• , 475 ALLENDALE ROAD

%,, f,s. KING OF PRUSSIA, PENNSYLVANIA 19451415 nrT 121993 Docket No. 50-333 Mr. Harry P. Salmon, Jr.

Resident Manager New York Power Authority James A. FitzPatrick Power Plant Post Office Box 41 Lycoming, New York 13093

SUBJECT:

NRC REGION I INSPECTION NO. 50-333/93-17 This refers to the results of the routine resident safety inspection conducted by Messrs.

W. Cook and J. Tappert fium August 1,1993 to September 4,1993 at James A. FitzPatrick Nuclear Power Plant, Scriba, New York. A summary of the inspection findings was presented to you and members of your staff at the conclusion of the inspection.

This inspection was directed toward areas important to public health and safety. Areas examined during the inspection are described in the NRC Region I inspection report, which is enclosed with this letter. Within these areas, the inspection consisted of observation of activities, interviews with personnel, and document reviews.

Performance by the FitzPatrick staff during this inspection period was generally good. One unresolved item was issued to track resolution of a licensee identified weakness with surveillance testing of your CO, fire suppression .;ystems. This itm will remain unresolved until the inspectors have reviewed your assessment of the problem and your corrective actions.

The inspectors reviewed your staff's actions in response to a self-identified minor Technical SpecificatiDn violation. It involved improper radiological monitoring of ventilation system

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exhaust during maintenance on the installed monitors. This event was of minor safety consequence and your corrective actions were found to have been prompt and thorough. In accordance .with the provisions of 10 CFR 2, Appendix C, Section VII.B.2 of.the Enforcement Policy, this Technical Specification violation was not cited.

OCT l 2 1993 Mr. Harry P. Salmon 2 ,

Your cooperation with us is appreciated.

Sincerely, (la Cu 'sJ. wgi , Chief Projects Bran No.1 Division of Reactor Projects

Enclosure:

NRC Region I Inspection Report Number 50-333/93-17 cc w/ encl:  ;

R. Schoenberger, President R. Beedle, Executive Vice President - Nuclear -

G. Goldstein, Assistant General Counsel J. Gray, Jr., Director, Nuclear Licensing - BWR Supervisor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Director, Energy & Water Division, Department of Public Service, State of New York K. Abraham, PAO (2) ,

Public Document Room (PDR)

Local Public Document Room (LPDR) -

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York, SLO Designee  ;

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Mr. Ilarry P. Salmon 3 bec w/ encl:

Region I Docket Room (with concunences)  :

C. Cowgill, DRP  ;

P. Eselgroth, DRP R. Urban, DRP ,

B. Welling, DRP B. Cook - FitzPatrick V. McCree, OEDO R. Capra, NRR  :

I J. Menning, NRR

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4 U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.: 93-17 Docket No.: 50-333 License No.: DPR-59 Licensee: New York Power Authority P.O. Box 41 Lycoming, New York 13093 I i

Facility: James A. FitzPatrick Nuclear Power Plant I.ocation: Scriba, New York Dates: August 1,1993 through September 4,1993 Inspectors: W. Cook, Senior Resident Inspector J.Tappert, Resident Inspector Approved by: J-2FYS l Peter W. Eselgroth,, ef Date Reactor Projects on IB, DRP INSPECTION

SUMMARY

Routine NRC resident inspection of plant operations, maintenance, engineering and plant support.

RESULTS: See Executivs Summary i

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TABLE OF CONTENTS Pace No.

1.0

SUMMARY

OF FACILITY ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . 1 .

1.1 NYPA Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l.2 NRC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 PLANT OPERATIONS (71707, 71710, 93702, 40500) ................ 1 ,

2.1 Followup of Events Occurring During Inspection Period ........... I 2.1.1 Fuel Pool Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I  ;

2.1.2 Severe Weather Response . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.1.3 Potential Failure of 10MOV25A and B . . . . . . . . . . . . . . . . . . 2 2.2 Previously Identified Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.2.1 (Closed) DEO. OPS.002 . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.0 MAINTENANCE (62703, 61726) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.1 Maintenance and Surveillance Observation . . . . . . . . . . . . . . . . . . . . 3 3.2 Previously Identified items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.2.1 (Closed) DEO.MT.001 ........................... 4 3.2.2 (Closed) DEO.MT.002 ........................... 4 3.2.3 (Closed) DEO.MT.006 ........................... 4 3.2.4 (Closed) DEO.ENG.008 and DEO.MT.023 . . . . . . . . . . . . . . . 5 i 3.3.5 (Closed) Violation (91-22-01): Failure to Establish Qualified Service Life for Analog Transmitter Trip Unit Systems (ATTS)

R elays . . . . . . . ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.2.6 (Closed) Violation (91-22-04) and DEO.MT.008 . . . . . . . . . . . . 6 4.0 ENGINEERING (37700,93702) .............................. 7 j 4.1 Drop in Reactor Vessel level During RHR Initiation ............. 7  ;

4.2 Previously Identified Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.2.1 (Closed) Unresolved item (92-01-04): Inadequate Design Controls .................................... 8 4.2.2 (Open) Unresolved Item (93-14-03): Control Room Ventilation System Single Failure Vulnerability . . . . . . . . . . . . . . . . . . . . 8 4.2.3 (Closed) DEO.ENG.007 . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.2.4 (Closed) DEO.ENG.013 . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i 4.2.5 (Closed) DEO.ENG.039 . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

• 4.2.6 (Closed) DEO.ENG.067 . . . . . . . . . . . . . . . . . . . . . . . . . . 10 50 PLANT SUPPORT (64704, 81700, 82701, 83750, 93702) ............. 10_ ,

5.1 Radiological Controls . . . . . . ......................... 10

5.1.1 Radiologically Control Area access Review . . . . . . . . . . . . . . 10  ;

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TABLE OF CONTENTS (CONT'D)

Pare No. +

5.2 Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.2.1 E-Plan Drill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.3 Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.3.1 Protected Area Boundary Review . . . . . . . . . . . . . . . . . . . . 11 5.4 Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.4.1 CO 2Fire Suppression Systems . . . . . . . . . . . . . . . . . . . . . . 11 5.5 Employee Concerns Program Review . . . . . . . . . . . . . . . . . . . . . . 13 5.6 Previously Identified Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 5.6.1 (Closed) Violation (93-06-02): Inaccurate Information Provided in Licensee Event Report . . . . . . . . . . . . . . . . . . . . . . . . . 13-5.6.2 (Closed) Unresolved Item (91-20-02): NYPA Identified Technical Specification Violation .................... 13 6.0 REVIEW OF WRITTEN REPORTS . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 6.1 LERs Reviewed (92700,90712) ......................... 14 7.0 MANAGEMENT MEETINGS (30702, 71707) . . . . . . . . . . . . . .. . . . . . . . 14 ,

7.1 SALP Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 7.2 Exit Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 , Employee Concerns Programs . , SM.P Management Meeting NRC Slides , SALP Management Meeting NYPA Slides NOTE: The NRC inspection manual procedure or temporary instruction that was used as inspection guidance is listed for each applicable report section.

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EXECUTIVE

SUMMARY

James A. FitzPatrick Nuclear Power Plant Insoection Report No. 50-333/93-17 Plant Operations: .

The plant continued to operate at 100% power. Good operator performance was noted during an August 31 storm which resulted in a loss of several emergency sirens and a ,

momentary loss of offsite power. Due to FitzPatrick's electrical lineup, power was not lost ,

to any plant equipment. Various aspecs of NYPA's fuel pool cleanup project were observed  ;

and found to be well controlled.

Maintenance:

Generally good performance of surveillanc:s was observed. Minor labelling deficiencies were noted. Numerous observations from FitzPaMck's diagnostic evaluation team (DET) inspection were reviewed and closed.

Eneineerine:

A system engineer's memorandum evaluating rector vessel level response to initiating shutdown cooling was reviewed and found to be comprehensive. Observations from the DET  !

involving modification controls, labelling, de-icing heaters, and emergency service water were reviewed and closed. ,

Dant Suncort:

Radiological and security controls for the reactor building track bays were reviewed and found to be acceptable. NYPA's practice emergency plan drill was observed and no significant deficiencies were noted. On August 12, NYPA declared all of their CO 2systems  ;

inoperable due to a failure to fully perform Technical Specification required surveillances. .

This area remains unresolved pending further NYPA and NRC review (URI 93-17-01).

FitzPatrick's employee concerns program was reviewed. The licensee event reporting (LER) l process was xviewed and an unresolved item regarding a NYPA identified Technical Specificatic : ziolation was not cied i

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DETAILS 1.0

SUMMARY

OF FACILITY ACTIVITIES 1.1 NYPA Activities The plant operated at 100% power throughout the inspection period except for a brief downpower on August 20 to perform control rod testing. NYPA continued their spent fuel pool cleanup project and were crushing and cutting control blades for disposal at the end of the assessment period.

On August 12, NYPA declared all of their carbon dioxide fire suppression systems inoperable due to inadequate surveillance testing. Upon further review, NYPA also determined that the CO, discharge timers were not set for the appropriate discharge duration.

After resolving all surveillance deficiencies, all of the CO systems 2 were tested and restored to an operable condition on August 21 to 24, except for the relay room. The relay room CO2system remains inoperable pending ventilation modifications and a test discharge >

scheduled for the 1995 refueling outage.

1.2 NRC Activities The inspection activities during this report period included inspection during normal, "

backshift and weekend hours by the resident staff. There were 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of backshift (evening shift) and 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> of deep backshift (weekend, holiday and midnight shift)

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inspections during this period.

2.0 PLANT OPERATIONS (71707,71710,93702,40500) 2.1 Followun of Events Occurring During Inspection Period  ?

2.1.1 Fuel Pool Cleanup In order to make room for additional reactor core offloads, NYPA is undertaking a fuel pool cleanup project. Specifically, the licensee is preparing 51 control rod blades,16 local power range monitoring (LPRM) strings, and a variety of other materials for shipment and offsite >

disposal. Various aspects of this project have been observed by the inspectors including pre-evaluation briefings, preparatory spent fuel movements, stellite ball removals from control ,

rod blades, velocity limiter shearings, and control blade crushings. All operations are overseen by the refuel floor supervisor and the inspectors found the various activities to have been conducted in a controlled, methodical, p.nd safe manner.

2.1.2 Severe Weather Response On August 31,1993, the Central New York area experienced severe weather and a tornado i watch was in effect. In response to these environmental conditions, NYPA entered Abnormal Operating Procedure (AOP)-13, Hurricanes, Tornados, and High Winds, at

2 2:15 p.m. The power grid was receiving numerous lightening strikes and at 2:35 p.m., the plant lost both offsite 115 kV power sources for a period of approximately eleven seconds.

FitzPatrick normally supplies all site loads from the station generator so the loss of offsite power had no effect on any plant equipment. Also due to the storm, NYPA lost six ,

emergency sirens at 3:59 p.m. which required an NRC notification via the Emergency Notification System. Four of the sirens were restored at 5:52 p.m. At 8:30 p.m., the storm had subsided and the licensee exited AOP-13. Six sirens were again reported as out of service on the morning of September 1 for approximately three hours. FitzPatrick operators performed well throughout the storm and responded appropriately to the loss of offsite power transient.

2.1.3 Potential Failure of 10MOV25A and B Subsequent to the motor failure of 10MOV25A during surveillance testing on July 22,1993, the NYPA staff determined that the combination of an undersized motor brake and automatic closure logic may result in the failure of both 10MOV25A and B motors while aligned in a shutdown cooling configuration. These potential motor-operated valve failures in the >

shutdown cooling mode would potentially result in the unavailability of the valves to function in the low pressure coolant injection (LPCI) mode. A detailed evaluation of this potential '

scenario by the NYPA staff was ongoing at the conclusion of the inspection period. In the interim, special condition tags were hung on 10MOV25 A and B to ensure operators declare both trains of LPCI inoperable while in the shutdown cooling mode. The inspectors reviewed these interim actions and found them to be consistent with plant Technical Specifications. Followup of the results of NYPA's detailed evaluation will be conducted in a subsequent inspection period. j 2.2 Previousiv Identified Items 2.2.1 (Closed) DEO. OPS.002 This Diagnostic Evaluation Observation (DEO) identified an apparent lack of adequate Plant Operations Review Committee (PORC) review and follow-up with respect to a hydrogen ignition e,ent summary documented in PORC meeting minutes91-021, dated March 13,1991. The specific technical issue identified in this DEO was reviewed and closed in inspection report 50-333/92-15, section 2.3.5. With respect to the adequacy of the  ;

PORC review and follow-up, this broad concern was reviewed during the Restart Assessment Team Inspection, as documented in inspection report 50-333/92-82, section 2.4. The team concluded that the PORC was appropriately fulfilling its Technical Specification obligation.

Subsequent to the RATI and unit restart, NYPA has implemented the integrated Deficiency i Event Reporting (DER) program which consolidates all previous departmental problem identification / resolution tracking programs. The DER program has enhanced the PORC  ;

l events review process and accelerated station management's awareness of all identified i

3 problems and concerns. DERs generated in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are reviewed daily by the '

Resident Manager, three General Managers, and Operations Review Group and has significantly improved the timely development of corrective action plans and assignment of action item responsibilities. This DEO. OPS.002 is closed, i

3.0 MAINTENANCE (62703,61726) 3.1 Maintenance and Surveillance Observations The inspector observed and reviewed selected portions of preventive and corrective maintenance and surveillance tests to verify compliance with codes, standards and Technical Specifications, proper use of administrative, maintenance and test procedures, proper QA/QC involvement, and appropriate equipment abgnment and retest. The following activities were observed:

The inspector observed the performance of surveillance test ST-5B, APRM Instrument Functional Test (Run Mode), Revision 17, on August 6. The inspector noted good three-point communications, and procedural adherence. Operators performing the surveillance test were familiar with the procedure, knowledgeable of the instrumentation under test and alert to potential adverse plant impact.

On August 28, portions of smveillance test ST-76Ji9, Smoke and Heat Detector Functional Test - South Emergency Switchgear Room, were observed. The test was well coordinated and executed and fulfilled the surveillance testing requirements of technical specifications.

However, one deficiency in the labelling of 76EMPC9 was noted by the inspector. The component number was correct, but the noun name was identified as the South EDG WGR room master pilot when it is actually the 3 Ton CO, system master pilot which is common to .

the North and South EDG switchgear rooms. This was similar to a labelling deficiency identified the previous week by NRC inspection of 76EMPC10 which again had the proper component identification number, but the incorrect noun name. NYPA was made aware of this deficiency through their validation program, but left the label while manufacturing a new one because the component ID was correct. Discussions with the configuration manager and the labelling coordinator revealed that approximately 30,000 labels have been hung within the '

last year and that only approximately 10 deficiencies had been noted. The inspector also reviewed Plant Standing Order 60, Plant Label Program, which discusses independent verification of labels and found it to be adequate. NYPA is currently replacing these labels and due to the procedural controls and low deficiency rate, no additional action appears to be warranted.

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3.2 Previousiv Identified Items 3.2.1 (Closed) DEO.MT.001 This DEO identified a variety of motor-operated valve (MOV) issues indicating potential weaknesses in the FitzPatrick MOV Program developed in response to Generic Letter 89-10, Safety-Related Motor-Operatrx! Valve Testing nnd Surveillance, dated June 28,1989. A detailed inspection of the FitzPatrick MOV Program was conducted in February 1993 by a team of inspectors using the guidance of NRC Tempomry Instruction 2515/109. The results of this inspection are documented in Inspection Report 50-333/93-80, dated April 9,1993.

The team concluded that NYPA had developed an adequate MOV program to address the recommended action of Generic Letter 89-10, with a few exceptions. These exceptions are being tracked by NYPA as noted in the inspection report. Based upon_this detailed team inspection of the MOV program and the generally good overall assessment of the program, DEO.MT.001 is closed.

3.2.2 (Closed) DEO.MT.002 This DEO identified a significant backlog of industry experience reviews. NYPA's corrective actions for this identified concern were reviewed in detail, as documented in inspection report 92-82, section 2.4.7. Since the conduct of inspection 92-82, NYPA has continued to reduce the industry operating experience backlog. Per Plant Standing Order i (PSO)-28.01, Administration of the Industry Operating Experience and Vendor Technical Information Assessment Program, all industry event reports and vendor information is processed (initially screened, prioritized, assigned and tracked to completion / resolution) via this program in a timely manner. The inspector reviewed a sampling of events and issues being processed via PSO-28.01 and verified proper implementation of the new program.

This DEO.MT.002 is closed.

3.2.3 (Closed) DEO.MT.006 This DEO identified that NYPA had not included fire protection water system check valves within the scope of review of INPO Significant Operating Experience Report (SOER) No.

86-03. Subsequent to this observation (early 1992) NYPA initiated Preventive Maintenance - ,

Evaluation (PME) No.116 to evaluate all plant systems' check valves. The inspector notes that per SOER 86-03 only selected safety systems were recommended for review. Also, NYPA's 1988 response to this issue included a selected review of 22 systems which captured just under 200 check valves to be included in a Preventive Maintenance (PM) Program. The 1992 PME-116 initiative included a review of the balance of plant systems' check valves (approximately 750 valves), including all fire protection water system check valves.

The inspector reviewed the draft PME-116 summary repon with the Preventive Maintenance ;

Task Force (PMTF) manager and verified inclusion of the fire protection check valves. Per discussion with the PMTF manager, the inspector determined that PME-Il6 results were

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being finalized and would be forwarded to the responsible plant maintenance and engineering staff fu incorporation into the PM program in the near future. This DEO.MT.006 is closed.

3.2.4 (Closed) DEO.ENG.008 and DEO.MT.023 These two DEOs identified weaknesses in NYPA's protective and actuation relay setpoint control program. This program was subsequently reviewed by the Restart Assessment Team Inspection (reference inspection report 50-333/92-82, section 2.3.10) in October 1992, and found to be acceptable. An unresolved item (92-82-W) related to this October 1992 review was subsequently inspected and closed in inspection report 50-333/92-23, section 6.1.5.

Based upon these earlier reviews and satisfactory inspection results, DEO.ENG.008 and DEO.MT.023 are closed. The inspector notes that the FitzPatrick Results Improvement l Program has an open improvement action item (IC 5.2) which will result in corporate Nuclear Engineering and Design (NED) maintaining the fmal setpoint/ tolerance calculation database. The targeted date for completion of this action item is December 31,1993.

3.3.5 (Closed) Violation (91-22-Olh Failure to Establish Oualified Service Life for Analog Transmitter Trio Unit Systems (ATTS) Relays This violation of 10 CFR 50, Appendix B, Criterion III, Design Control, identified that a 1985 design change involving numerous relays in the A'ITS, failed to establish the qualified service life of the newly installed relays. The consequence of this oversight was that the failure of the relays could potentially adversely impact the proper operation of the reactor ,

protection, emergency core cooling, and primary containment isolation systems. Subsequent testing by NYPA identified that, in spite of being in service beyond their qualified service life, all relays tested were able to perform their intended safety function.

The inspector reviewed NYPA's conective actions for this violation, which included prompt replacement of all ATTS relays. These corrective actions included: establishment of a five-year qualified service life for the affected relays; conduct of a broad based service life study by the preventive maintenance engineering (PME) group (documented in PME-120 dated ,

June 30,1992); and programmatic revisions to the site preventive maintenance program as defined by ICSO-16 and WACP 10.1.15. Additionally, revisions were made to DCM-13, Conduct of Engineering, and PSO-28, Industry Operating Experience and Vendor Technical Information Assessment, to ensure proper interfacing of modifications and industry information with the preventive maintenance (PM) program. The inspector reviewed a sampling of PM Program changes initiated from the results of PME-120, and a sampling of operating events reviews performed per the recently revised PSO-28 series procedures. No significant problems were noted with the items reviewed.

The inspector also notes that the site PM Program and Service Life Program were previously reviewed as documented in Inspection Report 50-333/92-82 (sections 2.2.9 and 2.4.10, '

respectively). As stated in report 50-333/92-82, both programs were determined to be adequate. This violation is closed.

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3.2.6 (Closed) Violation (91-22-04) and DEOMr.008 This DEO and subsequently devdoped violation identified a number of significant plant events / problems which collectively indicated inadequate problem identification, root cause analysis, and corrective action progmms. In response to the Notice of Violation which cited against 10 CFR 50, Appendix B, Criterion XVI, Correction Action, NYPA took a number of steps to improve in these areas. ,

First, an Operations Review Group (ORG) was established to screen all plant and industry events for significance and appropriate followup. Prior to unit restart, the ORG conducted an initial sample review of previously reviewed industry operating events which had a potentia! operability impact. The results of this initial review prompted an expanded sample review to gain a higher confidence level in the previous event review process. Additionally, the ORG looked at backlogged unreviewed industry operating events with the potential for operability concerns and screened several (17) for resolution prior to unit startup. All 17 unreviewed events and three previously reviewed events from the closed files were resolved prior to unit stanup.

Secondly, NYPA implemented an industry events review program per Plant Standing Order j (PSO)-28 prior to unit restan to address the backlog of event reviews and to address newly j identified industry events and vendor identified concerns. This program was previously reviewed (reference Inspection Report 92-82, section 2.4.7) and found acceptable prior to j '

unit restart. This program has been monitored by the resident inspector staff and, with few exceptions, found to be adequately implemented and timely with respect to prioritization of event reviews. J Thirdly, NYPA management has demonstrated a heightened awareness of the need to identify and evaluate plant problems. Plant trending of previously used Occurrence Reports and QA .

department Adverse Quality Condition Reports identified a notable increase in the numbers j issued in late 1992 and early 1993. This reflected better problem identification and increased usage of the programs. Subsequent to unit startup, all station problem identification ,

processes were combined under a single program per AP-03.02, Deviation and Event Reporting. This new program has been monitored by the inspectors and found to be  ;

properly implemented. The inspectors found the deviation and event review process to be i detailed and thorough. A sampling of reports (DERs) currently in the review process identified no significant problems. The inspector notes that station management reviews newly opened DERs daily and that overall DER status and trends are reported on weekly at the depanment managers' meeting. The inspector reviewed recent quarterly trend analysis ,

reports generated by the ORG and found the reports to be comprehensive. ]

Lastly, NYPA formalized their root cause analysis processes as part of the new DER Program. Again, resident inspector monitoring of the results of these processes has shown ]

generally good, detailed root cause analysis with effective corrective actions. The inspectors continue to monitor all aspects of the FitzPatrick staff's problem identification, root cause

7 analysis, and correction action programs with respect to day-to-day activities. Violation 91-22-04 and DEO.MT.008 are closed per the above review.

4.0 kNGINEERING (37700,93702) 4.1 Droo in Reactor Vessel Level Durine RHR Initiation On May 19,1993, during initiation of shutdown cooling the residual heat removal (RHR) system isolated on a spurious high pressure signal. This w1s the third such isolation this year, and unresolved item 93-1042 was opened to track NYPA's resolution of this issue which is still ongoing. Also on May 19, when shutdown cooling was reinitiated, a drop in reactor vessel level of approximately 17 inches was noted. This level drop was preliminarily attributed to filling voids in the RHR suction piping, but a subsequent analysis was done and are the subject of an engineering memorandum.

The inspector reviewed this memo and found it to be very thorough. The engineer clearly demonstrated that the volume of water represented by the decrease in reactor vessel level was much greater than the capacity of the RHR suction piping, and that therefore, the water must have gone elsewhere. It was concluded that the water was displaced into the steam separators which act as porous standpipes and fill with water when forced circulation is -

initiated. NYPA was able to mathematically predict level drops for given initial levels which correlated well with actual plant data. Overall, the inspector concluded that it was a comprehensive analysis.

One item requiring clarification for the inspector was noted. Specifically, the memo stated that to avoid this vessel level transient, reactor water level should be maintained above the top of the steam separators or approximately 235 inches above the top of active fuel (TAF). ,

This appeared to correspond with a caution in OP-15, Residual Heat Removal System, which ,

states that if level is less than 234.5 inches, temperature indications could be invalid due to insufficient natural circulation. However, review of the reactor vessel internals system drawings indicated that the top of the steam separators was 244 inches above TAF. The inspector discussed this apparent inconsistency to the licensee to ensure that the caution in OP-15 was accurate. After some research, NYPA was able to determine that the caution level of 234.5 inches was. appropriate. The caution was added to the procedure in response

! to a 1981 General Electric Services Information Letter No. 357 which indicated that with no forced circulation, level should be maintained above the bottom of the predryers on the steam g' separator (215 inches at FitzPatrick) to ensure adequate natural recirculation mixing. -The higher level in the operating procedure caution provides additional margin. The reference to 235 inches being the top of the steam separators was erroneous. The inspector had no additional questions on this issue. Unresolved item 93-10-02 remains open pending resolution and inspector review of the shutdown cooling isolation.

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8 4.2 Previousiv Identified Items 4.2.1 (Closed) Unresolved item (92-01-04): Inadecuate Desien Controls This unresolved issue was revievced and closed in inspection report 50-333/92-15, section 6.4.2, dated October 6,1992. However, due to a typographical error the item was numbered 92-01-03 vice 92-01-04. Consequently, item 92-01-04 is administratively closed.

4.2.2 (Open) Unresolved item (93-14-03): Control Room Ventilation System Sincie Failure Vulnerability During this inspection period, the inspector reviewed NYPA's broad-based action plan to resolve this issue. The inspector concluded, based upon review of the proposed action plan ,

and discussion with responsible engineers, that NYPA had established a comprehensive plan to resolve the identified issues. As discussed in inspection report 93-14, NYPA plans to perform testing to measure the amount of ventilation system leakage via the bypass dampers (given a single failure of the normal ventilation isolation valves), when the control room emergency ventilation system is in service (post-accident configuration). In preparation for this testing, the station staff identified that the emergency ventilation modulating dampers' (70 MOD-Il3 and 70 MOD-Il4) actuators were not functioning properly. Consequently, modification M1-92-394 was developed to replace the actuators on these dampers. Proper operation of the modulating dampers ensures a positive pressure is maintained in the control room to minimize intrusion of contaminants in a post-accident environment. Proper emergency ventilation system operation is likewise critical to the testing to be performed.  ;

NYPA was reviewing the reportability of the modulating dampers' actuator problems overall impact on system operation at the conclusion of the inspection period. This unresolved item remains open.

4.2.3 (Closed) DEO.ENG.007 This DEO captured a concern for the apparent lack of clarity and specificity in the station modification control procedures. At the time of the diagnostic evaluation, the corporate and i station engineering staffs shared this concern and were working to improve the modification controls. In addition, NYPA was reorganizing to better define the various engineering disciplines and responsibilities involved. Subsequent inspections in the area of plant i modifications (reference inspection reports 92-82, section 2.3.4 and inspection repon 93-08) which reviewed the implementation of the revised modification control program procedures  ;

and redefined / reorganized corporate and site engineering staffs (reference NUAP-3.7) identified overall improved execution of the modification processes. Implementation of the . i modification control program has also been routinely monitored by the resident inspector l staff and documented in their periodic inspection repons. No significant problems have been )

identified with the revised program implementing procedures. Based on the above, DEO.ENG.007 is closed.

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9 4.2.4 (Closed) DEO.ENG.013 This DEO identified generally poor labelling of plant components. Subsequent to the diagnostic team inspection, NYPA implemented an extensive plant labelling program. The bulk of the labelling activities in the plant were completed by a contractor prior to startup from the 1992 refuel outage. Approximately 30,000 labels were installa! and verified prior to unit restart. The remaming =6,000 labels are scheduled to be installed by the NYPA plant staffin conjunction with routine plant maintenance activities and as plant conditions allow.

NRC inspectors have conducted various system walkdowns (reference inspection reports 92-82 & 92-27) since implementation of the labelling program and have not identified any significant labelling deficiencies. Inspector and plant staff walkdowns have been greatly enhanced by the improved component labelling. This DEO.ENG.013 is closed.

4.2.5 (Closed) DEO.ENG.039 This DEO identified two principle concerns involving the intake structure de-icing heaters.

Specifically, Technical Specification (TS) 3.11.E does not provide the design basis for 18 of 88 de-icing heaters being operable when intake water is less than or equal to 37*F and that existing procedures and guidance do not ensure that 18 heaters will remain operable in the event of a loss of one emergency electrical bus. By letter dated January 16,1992, the NRC staff requested NYPA provide a written summary of the status and schedule for resolution of these issues. By letter dated February 18; 1992, NYPA committed to perform a design basis study of the intake structure de-icing heaters to be completed by December 1992. In the interim, administrative controls were established to ensure at least 18 operable de-icing heaters are supplied by each emergency bus.

The inspector reviewed FitzPatrick Technical Specification Interpretation (TSI) No. 28 which clarifies TS 3.11.E to ensure a minimum of 18 of 44 heaters from each heater supply panel (36 TRH-6A and 36 TRH-6B, supplied by MCC-251 and MCC-261, respectively) remain operable at all times. The inspector also reviewed completed modification F1-92-132, Isolation of De-Icing Heaters from Control / Relay / Cable Spreading Rooms for Appendix R-Concerns. This modification was completed prior to startup from the 1992 refueling outage and provided continued operation of intake structure de-icing heaters without being impacted by a fire in the control or relay rooms. This was accomplished by removing the de-icing heater control circuits located in the control room and relay room and providing control only at the local control panel in the screenwell area. The annunciation and indication circuitry was also modified to eliminate the impact of a control room or relay room fire. The inspector found the above stated actions appropriate.

The inspector notes that all de-icing heaters are continually energized by their respHve ,

panels throughout the year to minimize electrical cable insulation breakdown and monture intrusion, which could cause short circuiting. As discussed in inspection repon 93-04 and 93-10, three intake structure icing events occurred during the winter of 1992-93. However, E

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l 10 when forced circulating water flow was reduced, or secured entirely, normal screenwell water level rapidly recovered ensuring sufficient net positive suction head to the emergency i service water and residual heat removal service water pumps. This demonstrated that intake structure flow had a greater impact on ice accumulation and blockage than the de-icing heaters. These events also demonstrated that the de-icing heaters are undersized for 100%

flow and power operations under severe weather and cold conditions. l As documented in Licensee Event Report (LER) No. 91-32-01, dated May 1,1993, NYPA has concluded their de-icing heater design basis evaluation and determined that the heaters are not necessary to maintain safe shutdown and that the present Quality Assurance category (II/III)is appropriate. This conclusion was reached based upon laboratory testing and analysis. As supported by the icing events of the winter of 1992-93, the analysis demonstrated that a complete de-icing heater failure would not impact the minimum required emergency and RHR service water flows under design basis accident conditions. Both minimum and maximum initial intake structure flow conditions were evaluated. The inspector reviewed the results and basis for these conclusions and concluded they were well-founded. Based upon this review, DEO.ENG.039 is closed. In addition, inspection followup item 92-80-04, AR-40, which addresses an Appendix R, shutdown from outside the ,

control room issue is also closed.

4.2.6 (Closed) DEO.ENG.067 This DEO was redundant to DEO.ENG.052 which identified a concern for the adequacy of operability determinations made for several service water and emergency service water valves. DEO.ENG.052 was reviewed and the results documented in inspection report 92-81, sections 3.7.1 and 3.8. The technical issues were resolved at the time of the inspection.

However, the original handling of this issue by the NYPA staff became the subject of an escalated enforcement action (reference Enforcement Action No.92-033, dated September 15,1992) involving a violation of 10 CFR 50.9. NYPA's response to the 10 CFR 50.9 violation was reviewed and found acceptable as documented in inspection report 9344, section 8.3.3. This DEO.ENG.067 is closed.

5.0 PLANT SUPPORT (64704, 81700, 82701, 83750, 93702) 5.1 Radiological Controls 5.1.1 Radiologically Control Area Access Review While touring the facility the inspector witnessed station personnel handling equipment t through th; reactor building track bay outer doors. The reactor building track bay outer doors are interlocked with the inner doors (large equipment doors with an integral personnel access door) to provide a secondary containment boundary. The outer doors also serve as a

11 vital area boundary when closed and locked, however, the vital area boundary is moved to the inner door when the outer doors are open. Lastly, the outer doors serve as radiologically controlled area (RCA) boundaries.

The inspector verified by observation, review of station procedures, and discussions with responsible managers that appropriate security compensatory measures and RCA boundary control measures were exercised for the evolutions observed. The inspector also reviewed the radiation protection technician escorting guidelines for irradiated, contaminated or ,

potential contaminated materials being moved to and from the RCA and found them to be appropriate.

5.2 Emergency Preparedness 5.2.1 E-Plan Drill On September 1, NYPA conducted a practice Emergency-Plan drill at the FitzPatrick facility which had limited involvement by offsite emergency response organizations due to other commitments. The inspectors witnessed various aspects of the drill from the simulator control room and Technical Support Center and found the use of the simulator to be a positive initiative. The inspectors also observed the drill critique conducted by the drill controllers following the exercise. The inspectors noted no significant deficiencies during the drill and concluded the critique was sufficiently self-critical and thorough.

5.3 Security 5.3.1 Protected Area Boundary Review During this inspection period, major canstruction activities were completed on the new Administration Building. As a consequence, the interim protected area boundary modifications and compensatory measures were secured and normal protected area perimeters were reestablished. The inspector observed good execution of these actions.

5.4 Fire Protection i 5.4.1 CO, Fire Suppression Systems On August 12, 1993, NYPA declared all of their CO fire 2 suppression systems inoperable due to a failure to perform Technical Specification required surveillances. Specifically, Technical Specification Table 4.12.12 requires a simulated manual and ' automatic initiation of the CO, systems (except for the relay room which does not have an automatic initiation feature) every 1.5 years. NYPA determined that their surveillance test did not fully test the automatic initiation function.

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4 12 This discovery was made as a result of a sun'eillance test adequacy review performed in conjunction with the scheduled biannual review as an initiative by the site fire protection staff. After NYPA concluded that the Technical Specification surveillances were not being fully performed, the CO systems 2 were declared inoperable and procedures were drafted to test the automatic initiation function. Procedures to test the automatic function were approved by the plant operating review committee (PORC) on August 12 and 13 and performed between August 13 and 15. A " puff" test was satisfactorily conducted in all spaces protected by an automatic CO, sptem, but some surveillance testing failures occurred.

One failure was due to an alarm bell problem and several failures were due to CO2 discharge and alarm timers being out of tolerance. The failure of the timers was referred to the fire protection system engineer and, due to questions regarding the proper timer settings, the CO, j systems were not declared operable.

The inspector concluded that the system engineer's review was thorough. The engineer identified that the discharge timer acceptance criteria in the surveillance tests (STs) since the first draft in 1978 reflected the original design calculations performed in September 1971.

These calculations provided a baseline value for pre-operational testing that was conducted in 1974. After installation, the settings were adjusted for field conditions. These times were recorded in a design summary sheet and provided the basis (except for the South cable tunnel timer which was increased to ensure concentration was met) for NYPA's commitment to the ,

NRC, dated October 23,1978, which described concentrations achieved and corresponding timer settings. However, the values NYPA committed to were not used as the acceptance ,

criteria in their surveillance tests. Rather, the original design calculation values continued to be used except for the south cable tunnel timer which was adjusted in 1980 following an operational test and then erroneously changed during a procedure revision in April 1993 to duplicate the timer values for the North cable tunnel. Additionally, the system engineer identified that the recently performed surveillance tests revealed two timers which were outside their acceptance range, but not identified by the individuals who performed and reviewed the tests. This information was documented in an internal memo, dated August 17, 1993.

NYPA responded to this information by adjusting the discharge timers to reflect the commitments made to the NRC and directing a comprehensive review of the STs. This independent verification was initiated to ensure that all requirements were being met. On August 18, it was discovered that the repositioning of the CO, master pilot valves in response '

to a demand signal was not being verified. The ST review continued, but this was the last significant finding. On August 20, PORC approved the STs with the correct discharge timer acceptance criteria and a clearly written and comprehensive testing methodology. On August 21-24, all CO systems 2 were satisfactorily tested and declared operable.

Overall, NYPA's handling of this issue was good. A site initiated review identified the first i surveillance deficiency. The review of the failed timer surveillance was extremely thorough and enabled NYPA to identify further ST problems. NYPA remained in the Limiting Condition for Operation action statement until all issues associated with the CO2 suneillance I

13 testing were identified and resolved. The licensee maintained a conservative safety perspective at all times.

The licensee is addressing this area under a Deficiency Event Report. This area will remain unresolved pending further NYPA and NRC review of inadequate surveillance testing, the erroneous ST procedure change and the inadequate ST procedure review of the CO 2 fire suppression systems. URI 93-17-01 5.5 Employee Concerns Program Review During this inspection periM the inspector reviewed the program (s) available to FitzPatrick employees and contractors to raise safety concerns other 'han via their supenisors and line management. The inspector gathered information pertaining to the FitzPatrick Emp!oyee Feedback Program using the guidance of NRC Inspection Manual, Temporary Instruction (TI) 2500/028. That information is summarized in Attachment I to this report. Tl 2500/028 was developed to assist the NRC staffin assessing whether the NRC should encourage or require licensees to have formal confidential programs which employees may use without fear of retribution. The inspector notes that no assessment of the adequacy or effectiveness of the Employee Feedback Program was made. The inspector did review a large volume (approximately 200-300 pages) of employee feedback forms dating back to late 1991 and as recent as mid-1993, indicating the program has been and continues to be used by station employees and contractors.

5.6 Previously Identified Items 5.6.1 (Closed) Violation (93-06-02k Inaccurate Information Provided in Licensee Event Report This violation of 10 CFR 50.9 was issued in response to an erroneous event chronology submitted in Licensee Event Report (LER) 93-06. NYPA issued a revised corrected LER on May 5,1993. Additionally, NYPA implemented a new administrative procedure (AP) 03.04, Information Reporting Requirements, which requires an independeat technical review be conducted after the LER is drafted. Appropriate times and dates of occrarences during the event are some of the many attributes on the technical review checklist. In general, the quality of recent LER submittals has been good and the new AP will provide additional assurance that LERs are accurate. LERs will continue to be reviewed in future inspection reports. This violation is closed. '

5.6.2 (Closed) Unresolved Item (91-20-02k NYPA Identified Technical Specificati0D Violation On September 11,1991, NYPA discovered that the tmbine building ventilation exhaust iodine and particulate sample pump 17P-26 had not been running for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, and that no auxiliary pump was in service to monitor turbine building exhausts, This was a ,

14 violation of Radiological Effluent Technical Specification 3.1.c which requires continuous monitoring of ventilation system exhaust. LER 91-16 was issued on October 11, 1991, describing this event. NYPA took prompt action to restore sampling capability, however, NRC inspection review of the LER found that it did not reflect a clear description of the event, a' thorough review of the event, or a comprehensive corrective action plan. NYPA acknowledged the inspector's concerns and stated that LER 91-16 would be revised. Pending NRC review, the issue was left unresolved.

On October 27,1992, NYPA issued their revised LER. The inspector review found it significantly improved. The event was clearly described and analyzed and appropriate correction actions to improve the protective tagging process and the radiation monitor operating procedure were implemented. As noted in section 5.6.1 above, NYPA has taken actions to improve the quality of their licensing submittals and has generally been successful.

Therefore, this unresolved item is closed. Because this event was identified by the NYPA staff, of low safety significance, appropriately reported, and the corrective actions were thorough, the Radiological Technical Specification 3.1.c violation was not cited in accordance with the provisions of 10 CFR 2, Appendix C, Section VII.B.2 of the Enforcement Policy.

6.0 REVIEW OF WRITTEN REIORTS 6.1 LERs Reviewed (92700,90712)

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The inspectors reviewed the following Licensee Event Reports (LERs) and found them to be well-written, concise, accurate, and properly submitted for NRC staff review within the guidelines of 10 CFR 50.73:

1

-- LER 93-16, Liquid radioactive waste discharge without testing the radwaste discharge l monitor, dated August 23,1993. -l

-- LER 93-17, APRM downscale companion IRM upscale / inoperable scram surveillance test, dated August 30,1993  !

7.0 MANAGENiENT MEETINGS (30702,71707)

SALP Manacen,ent Meetinc

)

7.1 - -

i On July 28,1993, the Region 1 Regional Administrator and other NRC representatives met with NYPA senior corporate and station managers to review the recent SALP report (50- i 333/92-99) and NYPA's initial response to that assessment. A copy of the NRC presentation  !

slides (Attachment 2) and NYPA's presentation slides (Attachment 3) are attached to this l report.

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15 7.2 Exit Meetings At periodic intervals during the course of this inspection, meetings were held with senior .

facility management to discuss inspection scope and findings. In addition, at the end of the period, the inspectors met with licensee representatives and summarized the scope and.

findings of the inspection as they are described in this report. The licensee did not take issue -

with any of the findings reviewed in this meeting.

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ADDITIONAL COMMENTS: (Including characteristics which make the program especially effective, if any.)

In addition to this loosely structured Employee Feedback Program, NYPA has another Plant Standard, STD-4.120, Prevention of Sexual Ilarassment, which more narrowly focuses on specific personnel matten. Ilowever, STD-4.120 is run by the Iluman Rt.ources staff and has a confidential toll-free hot line phone number. NYPA management's expectation is that safety concerns will be addressed through the chain of command and/or via the Deviation / Event Report Program.

NAME: TITLE: PIIONE #:

William A. Cook / Senior Resident InspectorN315)34204907 DATE COMPLETED: 8/26/93 Issue Date: 07/29/93 A-5 2500/028 Attachment

ATTACHMENT 2 L

U.S. NUCLEAR REGULATORY COMMISSION REGION I 1

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FITZPATRICK NUCLEAR POWER PLANT ASSESSMENT PERIOD: ' APRIL 19 1992 ,

APRIL 17,1993 MANAGEMENT MEETING: JULY 28,1993 e b

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AGENDA INTRODUCTION T. MARTIN REPORT PRESENTATION P.ESELGROTH LICENSEE PRESENTATION NYPA DISCUSSION- T. MARTIN CLOSING REMARKS T. MARTIN m__ .__.m__._-_m.__m--...t. ___-ma.m_ < - + . - - .*_a -,-,--e*m'- = - - - . ----,_.a = --.m ,, ..- -, _ c-- -wa - + , . _.-,.s+.,m. - , -- - , ,-+..-=--+-w-wm ,- --. v w-- - . ' . -- - -m- -u--- . c v 2- * .ww. -ww.r- =w

PERFORMANCE ANALYSIS AREAS .

FOR OPERATING REACTORS A. PLANT OPERATIONS B. RADIOLOGICAL CONTROLS C. MAINTENANCE / SURVEILLANCE D. EMERGENCY PREPAREDNESS E. SECURITY F. ENGINEERING / TECHNICAL SUPPORT G. SAFETY ASSESSMENT / QUALITY VERIFICATION

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EVALUATION CRITERIA

1. ASSURANCE OF QUALITY, INCLUDING MANAGEMENT INVOLVEMENT AND CONTROL

2. APPROACH TO THE RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT '

3. ENFORCEMENT HISTORY ,

OPERATIONAL EVENTS (INCLUDING RESPONSE TO, ANALYSES OF,

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4. .

REPORTING OF, AND. CORRECTIVE ACTIONS FOR)

5. STAFFING (INCLUDING MANAGEMENT)

'6. EFFECTIVENESS OF TRAINING AND-QUALIFICATIONS PROGRAMS

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EERFORMANCE CATEGORY RATINGS CATEGORY 1 SUPERIOR PERFORMANCE; CONSIDER REDUCED INSPECTION CATEGORY 2 GOOD PERFORMANCE; CONSIDER NORMAL INSPECTION CATEGORY 3 ACCEPTABLE PERFORMANCE; CONSIDER INCREASED INSPECTION P

-IMPROVING: PERFORMANCE IMPROVING DURING ASSESSMENT PERIOD 1

DECLINING: PERFORMANCE DECLINING - DURING - ASSESSMENT l PERIOD AND THE LICENSEE HAD NOT TAKEN l MEANINGFUL STEPS TO ADDRESS THIS PATTERN L

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4 PERFORMANCE ANALYSIS

SUMMARY

Rating, Trend Rating, Trend ,

' FUNCTIONAL AREA Period Ending 4/18/92 Period Ending 4/17/93. ,

1. - Plant 10perations 3 2 2.- Radiological Controls ,

2 2

3. Maintenance / Surveillance 3 Improving 2

~ 4. ~ Emergency Preparedness 1 1

5. Security - 1. 1 .

6. : Engineering and Technical 3 3 Improving Support

-7'. Safety Assessment / Quality 3 2 '

Verification t

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PLANT OPERATIONS .

• GOOD OPERATIONS SHIFT CREW PERFORMANCE

• IMPROVED CONTROL OF ROUTINE AND ABNORMAL PLANT EVOLUTIONS -

• SIGNIFICANTLY ENHANCED MANAGEMENT OVERSIGHT OF ACTIVITIES '

4 e GENERALLY IMPROVED OPERATING PROCEDURES BETTER OVERSIGHT OF LICENSED OPERATOR TRAINING PROGRAMS 4

OVERALL CONCLUSION: CATEGORY 2

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a RADIOLOGICAL CONTROLS

• IMPROVEMENTS IN ALARA PROGRAM AND RADWASTE/ .

• TRANSPORTATION

• GOOD PERFORMANCE IN AREAS OF DOSIMETRY, RESPIRATORY PROTECTION AND INSTRUMENTATION

• WEAKNESSES IN RADIOLOGICAL INCIDENT REPORTING PROCESS AND RADIATION WORK PERMIT PROCEDURE COMPLIANCE OVERALL CONCLUSION: CATEGORY 2

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MAINTENANCE / SURVEILLANCE MAINTENANCE

• INCREASED STAFFING TO SUPPORT PROGRAM IMPROVEMENTS i

• IMPROVED ROOT CAUSE ANALYSES OF EQUIPMENT FAILURES

• . ENHANCED. QUALITY OF PROCEDURES AND DOCUMENTATION

• IMPROVED PLANT MATERIAL CONDITION AND HOUSElGEPING L

___..__.__._._._.._____.____________li______-____m_.____-__.___ . _ . _ _ __ _-__l'____-__,_ .-_- .

SURVEILLANCE .

• PROGRAM GENERALLY GOOD e

• UPGRADING SURVEILLANCE TEST PROCEDURES

• PROMPT INITIATION OF CORRECTIVE ACTIONS OVERALL CONCLUSION: CATEGORY 2

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I E}mRGENCY PREPAREDNESS. .,

• CONTINUED EFFECTIVE PROGRAM IMPLEMENTATION  :

• STRONG MANAGEMENT INVOLVEMENT AND SUPPORT

• UPGRADED TRAINING FOR EM RGENCY RESPONSE ORGANIZATION PERSONNEL

• . EP STAFF FUNCTIONS WERE WELL PERFORMED >

OVERALL. CONCLUSION: CATEGORY 1 I

^l SECURITY

'* EXCELLENT MANAGEMENT SUPPORT

• CONTINUED EQUIPMENT UPGRADES AND GOOD MAINTENANCE SUPPORT

• EFFECTIVE SELF-ASSESSMENT AND CORRECTIVE ACTION PROGRAM 1

• EXCELLENT COMMUNICATIONS BETWEEN SECURITY AhT OTHER PLANT GROUPS OVERALL CONCLUSION: CATEGORY 1 1

9

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ENGINEERING / TECHNICAL SUPPORT

• IMPROVED COMMUNICATION BETWEEN SITE AND ' CORPORATE STAFFS

-e WEAK PERFORMANCE ON MODIFICATIONS AND RESOLUTION OF-TECHNICAL ISSUES .

• SLOW RESOLUTION OF NUMEROUS FIRE PROTECTION / .

APPENDIX R P.ROBLEMS

-* LIMITED. PROGRESS IN THE AREAS OF ENGINEERING BACKLOG AND -

TIMELY COMPLETION OF SCHEDULED ACTION ITEMS

• SIGNIFICANTLY IMPROVED QUALITY OF ENGINEERING SUPPORT TO

- LICENSING ' ACTIONS OVERALL CONCLUSION: CATEGORY 3, IMPROVING L

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i ENGINEERING / TECHNICAL SUPPORT NRC SALP Board Comment: .

• THE BOARD ACKNOWLEDGES THAT SUBSTANTIAL EFFORT HAS BEEN EXPENDED TO IMPROVE PERFORMANCE AND THAT SOME IMPROVEMENT HAS BEEN NOTED.

1 HOWEVER,. WEAK PERFORMANCE HAS'BEEN NOTED PARTICULARLY IN THE EVALUATION OF EMERGENT ISSUES AND ,

LONG TERM CORRECTION OF APPENDIX R AND FIRE

- PROTECTION ISSUES.

THE BOARD CONCLUDES THAT CONTINUED STRONG MANAGEMENT ATTENTION IS WARRANTED TO CORRECT THESE WEAKNESSES AND CONTINUE THE IMPROVING TREND IN THIS AREA. -

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• DEMONSTRATED COMMITMENT TO IMPROVEMENT ,

l ENHANCED USE OF. INDUSTRY EXPERIENCE TO IDENTIFY .'AND RESOLVE POTENTIAL SAFETY CONCERNS <

OVERALL CONCLUSION: CATEGORYJ2.

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-* OVERALL: SAFE PLANT OPERATION

. e. OVERALL PLANT PERFORM 4 .CE IMPROVED IN T11E MAJORITY OF -

SALP FUNCTIONAL AREAS ,

• - IMPROVED MANAGEMENT OVERSIGHT AND SELF-ASSESSMENT PROCESSES WEAKNESSES REMAIN IN ENGINEERING / TECHNICAL SUPPORT

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