ML20059N331
| ML20059N331 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/28/1990 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9010110269 | |
| Download: ML20059N331 (20) | |
See also: IR 05000285/1990024
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SEP 28 WD
In Reply Refer To:
Docket: 50-285/90-24 ;
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Omaha Public Power District
ATTN: W. G. Gates, Division Manager
Nuclear Operations l
444 South 16th Street Mall
Mail Stop BE/EP4 i
Omaha, Nebraska 68102-2247 +
Gentlemen:
'
This forwards-the final report of the Systematic Assessment of Licensee ,
Perfonnance (SALP) for the Fort Calhoun Station (FCS) for the period of May 1 j
1989,- through April 30, 1990. This final SALP report includes:
1 The initial'.SALP report (no revisions). j
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2. A summary and. list of attendees at our July 26, 1990, meeting at the FCS' t
Emargency Operations Facility in Omaha, Nebraska. l
3. Your August 27, 1990, response to the initial.SALP report.
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I consider the actions discussed in the July 26, 1990, SALP management meeting- i
and in your August 27, 1990, response to the< initial SALP report to be l
responsive to NRC concerns and recommendations.
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The next SALP period for the FCS is scheduled to last 15 months, from May 1 !
1990, through July 31, 1991. ;
Sincerely, !
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ORIGINAL SIGNED BY
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_M 0. MARial _
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Robert'D. Martin
Regional Administrator :
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Enclosures:
1. Initial SALP report and revision sheet ,
2. Meeting Suninary and Attendance List ,
3. OPPD response the the initial SALP report ,
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cc w/ enclosures: . ,
LeBoeuf. Lamb, Leiby & MacRae :
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ATTN: . Harry H. Voigt, Esq.
1333 New Hampshire Avenue, NW
Washington, D.C. 20036' t
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ATTN: Jack Jensen, Chairman
Blair, Nebraska 680re
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Combustion Engineering,. Inc.
ATTN: Charles B. Brinkman, Manager :
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Washington Nuclear Operations
12300 Twinbrook Parkway. Suite 330
Rockville, Maryland 20852 ;
Nebraska Department of Health
ATTN: Harold Borchert Director
Division of Radiological Health >
301 Centennial Mall, South !
P.O.' Box 95007 -
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Lincoln, Nebraska 68509
Fort Calhoun Station
ATTN: T. L. Patterson, Manager
P.O. Box 399 ;
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fort Calhoun, Nebraska 68023
U.S. Nuclear Regulatory Comission
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ATTN: Resident Inspector
i P.O. Box 309 -
Fort Calhoun, Nebraska 68023
U.S. Nuclear Regulatory Comission
ATTN: Regional Administrator, Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
bectoDMB(IE40)
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R. D. Martin Resident Inspector
DRSS-FRPS SectionChief(DRP/C)
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l DRP (2)- . RSTS Operator ,
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Project Engineer (DRP/C) Lisa Shea, RM/ALF
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A. Bournia, NRR Project Manager (MS: 13-D-18) ChairmanCarr(MS: 17-D-1)
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' Tomissioner Roberts (MS: 18-H-1) RRIs at all sites
Comissioner Rogers (MS: 16-H-3) G. F. Sanborn, E0 ;
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. Comissioner Curtiss (MS: 16-G-15) DRS
Comissioner 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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In Reply To:
Docket: 50-285/90-24 ;
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Omaha Public Power District
. ATTN: W. G. Gates, Division Manager i
Nuclear Operations- '
444 South 16th Street Mall
Mail Stop BE/EP4
Omaha, Nebraska 681C2-2247
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Gentlemen:
This forwards the initial Systematic Assessment of Licensee Performance (SALP) !
Report (50-285/90-24) for the Fort Calhoun Station (FCS).' The SALP Board met on i
June 13, 1990, to evaluate FCS's performance for the period May 1,L1989, through
April 30, 1990. The performance analyses and resulting evaluations are
documented in the enclosed initial SALP Board Report. 3
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In accordance with NRC policy, I have reviewed the SALP Board's assessment and-
concur with their ratings, as discussed below: -
l 1. The performance in the functional area of operations was rated Category 2
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with an improving performance trend evident during this assessment. period.
The improved performance in this functional area was attributed to the
performance of the operations staff toward safe operation of.the plant. ;
2. The functional area of radiological controls was rated Category 1. This !
represents an improvement from the previous Category 2 rating. Strong '
management oversight and the implementation of a comprehensive radiological -
protection program were evident in this functional area. '
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3. The functional area of maintenance / surveillance was rated Category 2 with
an improving performance trend. Performance improvement was the result of
the initiation of programs that, when fully implemented, should enhance ,
I the overall performance in this functional area.
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4. The functional area of emergency preparedness was rated Category 2.
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Weaknesses were identified during evaluation of the annual emergency !
exercise that had been previously identified which is an indication that
more effective corrective actions need to be implemented.
5. The functional area of security was rated Category 2 with an improving
performance trend. Programs had been established to address the ongoing
problems identified in this functional area.: Effective implementation of
the programs should provide the necessary elements for an increased :
performance level.
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6. Performanc0 in the functional area of engineering / technical support was -
rated Categry 2. The systems engineering organization was noted as '
making a posit ve contribution to the overall safe operation of the plant.
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Weaknesses were !dentified with the technical content of system,
maintenance, abnormal, and emergency operating procedures.
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7. The functional area of safety assessment / quality verification was rated '
Category 1, which is an improvement from the previous Category 2 rating.
The improved performance in this functional area was attributed to the ,
development of programs that establish a sound basis'for the overall -
improvement in *he areas that. affect.rafe plant operation and to the
increased leve, of attention and oversight displayed by senior management.- -
Overall, licensee performance reflects the initiation of efforts in all'
functional areas to increase the facility performance level and enhance plant .
safety. Based on the SALP Board's assessment, the length of the SALP period '
has been increased from a 12- to a 15-month cycle; therefore, the next SALP 4
period will be from May 1,1990, to' July 31, 1991. ,
A management meeting has been scheduled with you.and your staff at 1 p.m. on
July 26, 1990, at your emergency operations facility in Omaha, Nebraska, to.- .!
review the results of the SALP Board. Within 30 days of this management meeting, '
you may provide written comments on and amplification of, asLappropriate, the
initial SALP report. Yoer comments, a summary of our meeting, and my .
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disposition of your comments will be issued as an appendix to the enclosed
initial SALP report and will constitute the final 3 ALP report.
A copy of any written comments will be included in the distribution of the
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final SALP report.
l Sincerely,
Y
Robert D. Martin
Regional Administrator
i Enclosure: :
Initial SALP Board Report 50-285/90-24 *
cc w/ enclosure: (see next page)
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INITIAL SALP REPORT
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U.S. NUCLEAR REGULATORY CCMMISSION
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REGION IV
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-285/90-24
Omaha Public Power District -
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Fort Calhoun Station ,
May 1, 1989, through April.30, 1990
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I. INTRODUCTIDN
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The Systematic Assessment of Li.*ensee Performance (SALP) program is an
integrated NRC staff effort to callect available observations and data on ,
a periodic basis and to evaluate iMensee performance based upon this
information. The program is supplem etal to normal regulatory processes ,
used to ensure compliance with NRC rules and regulations. It is intended :
to be sufficiently diagnostic to pr) vide a rational basis for allocating
NRC resources and to provide meaningful feedback to licensee's management
regarding the NRC's assessment cf th sir facility's performance in each i
functional area. ,
An NRC SALP Board, composed ~of the staff members listed below, met on
June 13, 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
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evaluation criteria are summarized in Section III of this report. The
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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 Fort Calhoun Station for the period May 1, 1989, through April 30,
t 1990,
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l The SALP Board for the Fort Calhoun Station was composed of: [
Chairman
S. J. Collins, Director, Division of Reactor Projects (DRP), Region IV
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Members
J. P. Jaudon, Deputy Director, Division of Reactor Safety (DRS), Region IV
A. B. Beach, Director, Division of Radiation Safety and Safeguards (DRSS)',
Region IV . .
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O. L. Wigginten, Acting Directre, Project Directorate IV-1, Office of
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NuclearReactorRegulation(NRR)
G. L. Constable, Chief, Profect Section C, DRP, Region IV -
A. Bournia, Project Manage.r, Fort Calhoun Station,. Project Directorate IV-1,
P. H. Harrell, Senior Resident Inspector, Fort Calhoun Station
The following personnel also participated in the SALP Board '
meeting:
L. J. Callan, Director, DRS, Region IV ,
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L. A. Yandell, Deputy Director, DRSS, Region IV
B. Murray, Chief, Facilities Radiation Protection Section, DRSS, Region IV ,
D. A. Powers, Chief, Security and Emergency Preparedness Section (SEPS), ,
DRSS, Region IV
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I. Barnes, Chief, Materials and Quality Programs Se '1on, DRS, Region IV l
W. C. Seidle, Chief, Test Programs Section, DRS, Rt on IV- ,
4 T. Reis, Resident Inspector, Fort Calhoun Station
R. V. Azua', Project Engineer, DRP/C ,
R. P. Mu111 kin, Project Engineer, DRP/A
R. A. Caldwell, Security Specialist, SEPS, DRSS, Region-IV
P. C. Wagner; Inspector, Plant Systems Section, DRS, Region IV
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P. J. Prescott, Performance and Quality Evaluation Branch, NRR.
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II. SUMMARY OF REtVLTS
Overview
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The licensee's performance during this assessment period indicated
increased management involvement in and attention to the safe operation of. ;
the facility. The evaluation of the safety. assessment / quality verification j
functional area indicated that senior manajement oversight and involvement- '
was readily evident, and emphasized, through the continuation of the
safe +y enhancement program. Actions taken thus far have generally
inertased the level of-personnel performance in all areas related to safe :
plant operation. Effective implementation of the programs should continue t
to' increase the performance in each functional area.. ,
Improved performance was specifically noted in the functional areas of
plant operations, maintenance / surveillance, and security. In the
functional area of radiological controls, strong management oversight was
evident, as indicated by the-implementation of comprehensive programs that
address the elements necessary to ensure a high level of. performance.
Continued management attention is required in these areas to ensure that the
enhancement programs are fully and effectively completed.-
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The licensee's performance ratings are summarized in the table below,
along with the ratings from the previous SALP assessment period.
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Ratino last Period Rating This Period
[u,nctionalArea (05/01/88 to 04/30/89) (05/01/89 to 04/30/90) Trend ,
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! 1. Plant Operations 2 2 !*
l 2. Radiological Controls 2 1 NA
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3. Maintenance /$urve111ance 2 2 I*
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4. Emergency Preparedness 2 2 NA
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5. Security 2 2 !*
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6. Engineering / Technical 2 2. NA
Support >
7. Safety Assessment / 2 1 NA ,
Qualitu Verification !
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- (I) Improving Trend - licensee performance was determined.to be improvint
during the assessment period.
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III. CRITERIA
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Licensee's performance was assessed in seven selected functional at .
Functional areas normally represent areas significant to nuclear safecy-
l and the environment.
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The following evaluation criteria were used, as applicable, to assess each
functional area:
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A. Assurance of quality, including management involvement and
control; ,
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B. Approach to the resolution of technical issues from a safety
standpoint; ,
C. Enforcement history; i
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D. Operational events (including response to, analyses'of,
reporting ef, and corrective actions for);
E. Staffing (including management); and ,
F. Effectiveness of the training and qualification programs. !
However,.NRC is not limited to these criteria and others may have been
used where appropriate.
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On the basis of the NRC assessment, each functional area evaluated is i
rated according to three performance categories. The definitions of these ;
performance categories are: j
Category 1 - Licensee's management attention and involvement are readily ;
evident and place emphasis on superior performance of nuclear safety or ,
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 i
is being achieved.- Reduced NRC attention may be appropriate. ,
Category 2 - Licensee's management attention to andI1nvolvement in the
performance of nuclear safety or safeguards activities is good. The. ;
licensee has attained a level of performance above that needed to meet l
regulatory requirements. Licensee's resources are adequate.and reasonably l
allocated so that good plant and personnel performance'is being achieved.
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NRC attention may be maintained at normal levels . ,
Category 3 - 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.
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IV. PERFORMANCE ANALYSIS +
A. Plant Operations !
1. Analysis I
This functional area consists of~ activities such as plant
startup, power operation, plant shutdown, and system lineups.
Thus, it includes activities such as monitoring and logging
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plant conditions, normal operations, response to. transient and '
off-normal conditions, manipulating the reactor and' auxiliary '
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controls, plant-wide housekeeping, and control room
professionalism. Activities that support operations (e.g.,
training and requalification, evaluation of emergency and
abarrmal operating procedures, and other similar areas) are
assessed in the other functional areas discussed in this report..
During this assessment - iod, the licensee minimized challenges ,
to safety systems as o, 3 one manual and no automatic reactor I
trips were experienced. The manual trip was appropriately
initiated by an operator because of an indicated high bearing
temperature on a reactor coolant pump. This noteworthy
i performance continued a long trend, in that the licensee has ;
experienced only one automatic and two manual trips since
July 1984. (
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The licensee continued to maintain a very experienced and
knowledgeable group of licensed senior reactor operators ($ft0s)
and reactor operators (R0s), as has been evident during past
performance assessments. The operations staffing level was
stable during this assessment period with a very small turnover
rate of licensed operators (2 SR0s and 1 RO). On-shift staffing
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was maintained at'a. level that permitted the licensee to
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maintain a six-shift rotation, except for vacation schedules-
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during the summer months. The excessive use of overtime in the
operations department has not been identified as a concern.
The: licensee maintained a comparably small licensed staff that
currently includes 27 individuals (14 on-shift and 13 staff
personnel).that hold an SRO license and 8 on-shift' individuals
that hold an R0 license. This staffing. level represents a net
decrease of 2 R0s when compared to the staffing 1 year ago. The
.small size of the licensed staff has been discussed by NRC
during the two previous assessment periods. d ensee's
management has stated that they. intend to increase the number of
licensed personnel, especially in operations, by providing
three ca.ndidates for the RO examination in May 1990 and
five adoitional candidates in October 1990.. The licensee i
maintains a practice of producing very small operator license j
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classes in spite of a high success rate for recent license
examinations (100 percent initini examination pass rate for the
last 6 site visits). License 6 operators have been transferred
to other departments within the licensee's nuclear organization,
such as outage. planning, maintenance planning training,
I simulator services, and quality. assurance. The operations
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expertise of these individuals has shown to have a positive
impact on these organizations with respect to providing support l
te the operations department,
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The shift technical advisor (STA) program has provided a
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positive contribution to plant operations. The STAS function-as
an integral part of the operations crew and are very involved.in
l the day-to-day operation of the plant by providing technical ;
assistance to the shift supervisor. In addition to the STAS,. ,
the systems engineers provided technical recommendations to the
shif t supervisor when component _or_sy.ste.m' anomalies occur that
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potentially affect the operability of safety-related equip' ment. 1
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The interface between the operations staff and the departments i
that provide support to operations (e.g., health, physics, <
maintenance, chemistry, and training) has been effective during j
this assessment period. To minimize the impact on the operating s
crews during the refueling outage, the licensee assigned an ;
outage coordinator to act as an interface between operations'and .
other departments. This approach was effective in minimizing
the impact on operations during this high activity period. ;
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Licensed, on-shift operators exhibited a dedicated commitment _
toward the performance of their duties and safe plant operation. ;
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Control roon professionalism and decorum was evident during this '
assessment period. Plant operators (licensed:and nonlicensed) ;
maintained at awareness of plant conditions and work activities ,
being performed.under their control. On a number of occasions, '
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during this assessment period, operations personnel responded to ;
plant perturkations and prevented more significant problems that
may have cause1 challenges to safety-related. systems. Examples
include a loss ef shutdown cooling.due to the loss ~ of offsite
power and a partial loss of component cooling water flow at full '
power. i
Preplanning of activities affecting plant operations was
apparent as evidenced during the removal of the 161-kV offsite- '
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power supply, one of the two offsite power grids, for preventive !
maintenance. Actions were taken to ensure that the onsite and
offsite electrical distribution systems.were not disturbed by. i
maintenance or other activities. However, the.same conservative ,
approach was not exhibited toward shutdown cooling operations
with the reactor coolant system in a reduced inventory. l
Licensee's management allowed removal of all power supplies, ;
except for one offsite source and one emergency diesel >
l generator, for supplying power to the shutdown cooling pumps. ,'
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In this configuration, the electrical system was potentially
vulnerable to a single failure.-
On two occasions, operations personnel actions resulted in.the :
failure to comply with the lim'. ting conditions for- i
operation (LCO) specified by the Technical Specifications (TS);
l neither occurrence resultec' in a degradation of safe plant ,
! operation. The events involved the fai_ lure to ' reduce plait :
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power when two reactor protection system channels were declared :
inoperable, and the failJre to return the isolation valves I
properly for a component cooling water heat = exchanger to service
following maintenance activities. The first event resulted from
inadequate directions from plant management,'and'the second
event resulted from an oversight by a nonlicensed individual. A l
review indicated that these events were isolated cases.
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A number of issues were identified during ' activities related to ;
the licensee's reconstitution of the ple.nt design basis,
self-initiated reviews, and inspections performed by NRC
personnel. It appeared that management generally took a-
conservative approach when addressing problems of equipment and .
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component operability. Some isolated cases were identified,
early in the assessment period, where management exhibited a i
reluctance toward timely determination of equipment. operability.
In the latter part of the period, operability determinations'
appeared to be conservative. 1
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On.several occasions during the early part of the assessment i
period, the licensee experienced difficulty in making i
reportability decisions. In the latter part of this assessment :
period, management's performance improved with respect to j
reportability issues. !
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Difficulties encountered with operability and reportability l
1ssues' appeared to be the result of inexperience, in that, new
plant and assistant plant managers were appointed early in this
assessment period. '
The last SALP report (NRC Inspection Report 50-285/89-19) .
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identified concerns in the areas of operations personnel using
and following procedures, plant personnel entering the control
beard area in the control room for no, obvious reason, and
infrequent tours of the operating spaces by senior plant :
management. The licensee addressed the first two concerns; (
however, management (except for radiological protection
. personnel) infrequently toured the plant operating spaces other
than the control room. The licensee took actions to increase 1
the frequency of plant tours prior to the end of_this assessment i
period. Shift supervisors, throughout this assessment period,
routinely toured the plant operating spaces to verify that
equipment was operating satisfactorily.
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The licensee has made significant progress with upgrading plaat
l housekeeping, labeling, and appearance. The licensee's program-
t for installing new valve and component labels has improved the
l operator's capability for equipment identification. Color
coding and labeling of system piping and painting of the plant
operating spaces (approximately=75 percent complete) has
significantly contributed to enhanced operations and the overall ;
plant appearance. ,
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Overall, it appeared that the operations' staff conservatively
operated the plant to ensure that the health and safety of the - ':
public were properly protected. The operations' staff
demonstrated their abilities to' handle plant perturbations and ~
events. Weaknesses with plant management's oversight of the
operations area and a number of problems and concerns were ,
identified to which the licensee provided timely resolution and '
took actions to prevent recurrence.
2.. performance Ratino ,
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The licensee is considered to be in performance Category 2 in i
i this functional area. Licensee's performance was determined to
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be improving during this assessment period.
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3. Recommendations
a. NRC Actions j
Inspection effort in this' functional area should be
consistent with the fundamental inspection program. .;
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b. Licensee Actions
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Licensee's management should contin.ue efforts for . I
increasing operator staffing. Management should continue l
to ensure that activities related to equipment operability
and event reportability.are performed in a timely and ,
conservative manner. !
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B. Radiological Controls
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1. Analysis j
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The assessment o' this functional area consists of activities I
related to occur.stional radiation protection, radioactive waste d
management, rar'iological effluent control and monitoring, i
radiological environmental monitoring, water chemistry controls,
radiochemistry and water chemistry confirmatory measurements, ,
and. transportation of radioactive materials. '
The radiation protection program inspections indicated that the
licensee had implemented a high quality radiation protection
program. Some minor weaknesses were identified. One .
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NRC-identified violation occurred in September 1989 and involved
the failure to survey visitors' leaving the site.. A
licensee-identified violation was noted in' December 1989 and
- involved the failure to provide continuous health physics
coverage for a worker in a very hign radiation area, and another l
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in March'1990 that involved the failure of a security guard to - '
follow established radiation protection procedures duringientry
into a high radiation area. The licensee took prompt and
effective corrective actions and the. violations were not an
indication of programmatic breakdowns.
. The licensee made significant improvements in the radiation:
l protection area during the last part of the previous assessmenti ,
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period and continuec8 to make additional improvements during this
assessment period. These improvements included items such as
staffing, procedures, equipment'and instrumentation, i
coordination with other departments, training, and
4 self-identification of problem areas.
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The staffing level in the radiation protection department
increased from 22 to 54 personnel during the previous assessment
period, and this level was maintained during this assessment
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period. The licensee only used contract radiation protection
personnel during outages and relied on the permanent staff.
during routine operations. Within the current staffing level,
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three new supervisor positions were authorized ud filled. Eacb :
individual selected for the supervisor positions holds a Masters. I
degree in health physics or nuclear engineering, along with !
several years of applied health physics experience. The i
licensee experienced a low turnover rate in the radiation '
protection department, as only two individuals have left the i
department since 1988.
The licensee implemented a comprehensive t' raining program for
the radiation protection staff at both the technical level'and
for professionals and supervisors. An effsetive program was'in
place for the evaluation, screening, and training of contract .
radiation protection technicians that were brought on~ site !
during outage activities. The licensee; demonstrated initiative
to increase the technical expertise in the radiation protection
department in that about 50 percent of the' licensee's radiation
protection technicians have been certified by the National
Registry of Radiation Protection Technologists. 4
.A high level of cooperation was achieved between the radiation
protection-department and other departments such as operations.- ,
and maintenance. Hewever, one area, self-identified by the '
licensee, was noted where the plant staff (nonradiation '
protection department personnel), on two occasions,-did not .
,
follow established radiation control procedures. <To. reduce.the
l numbers of radiological occurrences, it appeared that department ,
l supervisors needed to increase the emphasis for the plant
personnel compliance with radiation protection procedures. ,
l The licensee completed construction of new facilities for access
control into the radiation controlled area, office and work
areas for the health physics and chemistry staff, and clothing
change areas for radiation workers. These new facilities were -
completed just before the 1990 refueling outage and some final
arrangements remained to be completed such as personnel flow
paths and work stations at the access' control point.
Improvements were made in the as-low-as-reasonably-
achievable (ALARA) area since the previous assessment. Strong .
support for the ALARA program was demonstrated by the formation ;
of an ALARA executive committee that-is chaired by the senior -
vice president, and includes representatives from various
corporate divisions, the plant manager, and the supervisor,
radiation protection. Improvements were also noted in ALARA
activities such as the technical evaluation of ALARA work,
processing of ALARA packages, purchase of video equipment, and ;
better coordination between the ALARA group and other '
departments.
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The person-rem for 1989 was approximately 93; however, this j
period did not involve a refueling outage. .The annual average '
person-rem for 1986 through 1989 was 208, as compared to a )
national average of.approximately 300 person-rem. This low
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person-rem was an indication of an effective program for the '
control of external exposure., The licensee established a -
conservative, 250 person-rem' goal for the 1990 refueling outsge. ;
As of April 30;'1990, 214 person-rem had been. expended and.it
appeared that the outage would be completed under the 4
established goal. . The licensee set a conservative personnel ,
skin contamination goal of 23 for 1990, but 36 events had. l
occurred as of late March 1990.
Management oversight was evident by the performance of
comprehensive audits and surveillances, and progress in the area -;
of self-assessment. The 1990 audit of the radiation protection ~
program included an euditor in the quality;assurancef(QA)-
organization with several years of experienre as a senior. .l
radiation protection technician, along with a consultant that
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also had several years of radiation protect. ion experience. The '
audit report included verification that work was performed in '
accordance with established procedures anr,also included i
suggestions concerning program itnprovemenc items. The responses
to the audit findings'by the radiation p.otection department ,
were made in a timely manner and indicated a good understanding t
of the technical issues. Except for some ongoing revision of
procedures, the licensee. completed work on approximately
i 375 improvement items identified as part of the radiation
i protection enhancement program. -
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l The radioactive waste management and radioactive effluent
l control and monitoring programs were inspected'and no violations
were identified. An effective liquid and gaseous release permit
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program was established. No problems were identified concerning
staffing, training, or qualifications of the personnel-
responsible for operating the radwaste systems.- The licensee 1
implemented a radwaste management program that demonstrated {
cempliance with the Radiological Effluent Technical
Specifications and the Offsite Dose Calculation Manual.
The radiological environmental' monitoring program was inspected
and no significant problems were identified. Regulatory
requirements were met regarding sample collection, analyses, and '
resulting dose calculations. W11 qualified personnel, with at
least 10 years of exone%nce, were assigned to implement the .
environmental monitoring program. However, a formal training
program had not been established for personnel assigned to this ;
group. '
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The radiochemistry and water chemistry programs were inspected,
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no problem areas were identified, and continued improvener's
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were noted in this area. The. staffing level in the
radiochemistry and water chemistry remained at 19 positions, the -
same number as during the previous. assessment period. Four new
supervisor positions were authorized within'the existing staff
organization. : Management oversight included _ comprehensive QA
audits.
e 1
New chemistry laboratory and radiochemistry counting facilities ,
were constructed and scheduled to be in use by the end of 1990. .
Vendor recommendations and EPRI guidelines for primary and ,
secondary water chemistry parameters were incorporated into the
station chemistry procedures and were being followed. Water *
chemistry and radiochemistry confirmatory comparison measurements
, were performed. The radiochemistry confirmatory results showed !
98 percent agreement, which was consistent with tt.e 97 percent ,
agreement obtained during'the previous' assessment. Water .
chemistry confirmatory measurements indicated 97 percent
agreement, which was an improvement over the 88 ~ percent agreement l
noted during the previous assessment. The confirmatory ,
measurement results indicated that the licensee's performance
was above the industry average in this area. The licensee made
imorovements in the quality control (QC) area, including the use
of QC charts to trend daily analyses of chemical parameters and
reactor coolant and secondary water quality results.
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The transportation of radioactive materials and solid radwaste
i programs were inspected and no violations were identified. The t
licensee completed construction of a new solid radwaste ;
processing and transportation facility, which is scheduled to be
fully operational in 1990. The licensee established
implementing procedures that addressed waste classification and '
characterization, procurement and selection of packages,
preparation of packages for shipment, and delivery of the i
completed packages to the carrier. The staffing level assigned
to handle solid radwaste and transportation activities was
satisfactory. It was noted that the most recent QA audit of the
solid radwaste and trarftportation area, conducted in
November 1988, did not include transportation activities.
Overall, the licensee made progress during the previous
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assessment period to improve performance in the radiological
controls area and this effort carried over into this assessment *
period. Improvements made in the radiation protection and ,
chemistry / radiochemistry areas were particularly noteworthy. l
Strong management oversight of the activities in this functional >
area was evident. '
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2. Performance Rating
The licensee is considered to be in Performance Category 1 in
this functional area. >
3. Recommendations-
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a. NRC Actions
Inspection effort in this functional area should be
consistent with the fundamental inspection program.
7
b. Licensee Actions
!
Licensee's management should continue efforts to. implement ;
a strong self-assessment program, ensure that radwaste
personnel complete specified training, and consider
transportation activities in the QA. audit program. t
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Emphasis on compliance with radiological protection
procedures should be str" sed by management.
'
C. Maintenance / Surveillance g
1. Analysis
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This functional area includes all activities associated with
either diagnostic, predictive, preventive, or-corrective
maintenance of plant structures, systems, and components;
procurement, control, and storage of components, including :
qualification controls; installation of-plant modifications; and
maintenance of the plant physical condition. It also includes- *
conduct of all surveillance testing activities and inservice' s
inspection and testing activities. 4
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( This area was inspected on a routine basis by the tsident
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inspectors and periodically by regional inspectors. A special-
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inspection was performed in the area of systems entry :
retest (SERT) by personnel from Region'IV.
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The licensee has maintained a stable and well qualified
maintenance work force with little turnover. The staffing level ,
in the instrumentation and control (I&C) area was a concern
identified in the previous SALP report. The licensee's current
,
full-time I&C staffing level has been increased to 29 employees
! (24 licensee and 5 contractor personnel) and appears to be .
sati sf actory. *
The quality of maintenance procedures was previously identified
as a concern with respect to the level of detail and the
technical content. To address this concern, the licensee-
established a procedures upgrade project as part of the Safety
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Enhancement Progria. This project is currently. scheduled to be
completed by the end of 1990. Maintenance personnel have :
performed their activitiss satisfactorily and in accordance with-
the existing procedures, as the knowledge level and experience
of the crafts has compensated for marginally acceptable -
procedures.
The licensee has implemented a good maintenance program as ;
evidenced, in part,'by all equipment functioning preparly during:
'
engineered safeguards actuations, and.no plant shutdowns.have
resulted from equipment maintenance problems. The' operations
department identifies equipment needing maintenance attention to. -
the maintenance department each morning at the plan-of-the-day..
meeting. This interface has resulted in prompt attention to the
! repair of safety-related equipment.
The SERT was conducted in the areas of design changes, temporary
- alterations, and maintenance activities. .The SERT inspection
. determined that planned retesting of' structures, systems, and ,
components, that have been modified or subjected.to' maintenance,
properly verified equipment operability and ensured that the-
design basis was met.. The licensee has a strong program for
determining required retests and for the identification of the
appropriate retest method. _The licensee's program for .
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development of procedures and performance of these procedures '
for retest of structures, components, and systems,.following
plant modification and maintenance activities, was found to be
satisfactory. A weakness was identified in the assignment of
l review responsibilities to ensure that correct retestr. were
l included in postmaintenance and temporary modification work .
L packages. The licensee strengthened this area by administrative l
procedure revisions.
Systems engineering developed and performed, during this ;
assessment period, comprehensive raw water (RW) system testing
that demonstrated that pump and heat exchanger performance had
degraded from the original design basis assumptions._ With the
implementation of administrative controls, the RW system
remained operational and met the design basis. . A reactive
inspection was conducted.to review the test results and . .
operability status of the'RW system. The inspection indicated ;
that the four RW pumps had-become degraded as a result of
deficient preventive maintenance, system testing, and erosion of ,
the pump bell housing because of pumping silt laden Missouri i
river water. System engineering's performance in developing
integrated testing procedures to demonstrate proper system
performance was noteworthy.
An inspection of the installation of plani, modifications !
determined that the licensee's modification program contained
very good controls and procedures, and is considered to be a
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, Inspections were performed:in the area of: inservice
l inspection (ISI) and inservice testing (IST) and included the :
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surveillance, visual inspection, repair, and testing of
snubbers. Implementation of the IST program upgrade appeared to
be consistent with the licensee's committed schedule. ' .
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Surveillance testing of pumps and valves was consistent with the
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requirements of Section-XI to the ASME Code and the criteria
outlined.in NRC Generic Letter 89-04. The ISI and snubber
programs contained sufficiently detailed procedures to govern i
the work, provided easily retrievable records, and had i
sufficient qualified personnel. Management involvement in these
areas was evident. An exception to this performance was noted
'
during followup of the turbine-driven auxiliary feedwater pump ;
event, as discussed in the engineering / technical support
functional area. ,
The systems eng'ineering organization provided field oversight l
activities for equipment and component maintenance. The
presence of the engineers provided for the timely resolution of
technical issues that were identified during maintenance
activities to minimize equipent down time.
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In the last SALP report, concerns were identified with
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administrative controls of' maintenance work orders, predictive i
and praventive maintenance programs not being fully implemented,
independent review of core physics testing data, and procedural
compliance by maintenance personnel. The licensee has taken. '
actions to address these concerns, except for predictive and
preventive maintenance programs. Actions have been implemented
by the Safety Enhancement Program to address the predictive and
preventive maintenance programs and are currently scheduled'to -
be completed by the end of 1990. '
In the area of surveillance, tests were being scheduled.and
performed as required by the TS. During an inspection, it wts
noted that the systems engineers had unilateral authority to
waive procedural requirements, and justification for waiving
procedural steps and acceptance criteria may not always be
given. Although no examples were identified where testing
requirements were inappropriately waived, the inspector was ;
i concerned that the existence of this authority could result in
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unauthorized changes to procedures. The licensee addressed this
concern by providing guidance in a revised administrative .
procedure. l
Inspections indicated that the licensee's surveillance test
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control program had significantly improved, only one test was -
not performed within the prescribed interval. This was
previously an area where licensee's performance was a concern.-
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Overall, it appeared that the licensee has initiated programs to
strengthen the maintenance area by upgrading the IST program,
addressing the technical adequacy of procedures, and initiation
of preventive and predictive maintenance activities. The
staffing, especially in the I&C area, has been increased to a
satisfactory level. A. surveillance program has been implemented.
that ensures testing is performed in a timely manner.
2. Performance Ratino
The licensee is considered to be in Perf'ormance Category 2 in.
this functional. area. Licensee's performance was determined'to
be improving during this assessment period.
3. Recommendations
a. NRC Actions
The NRC. inspection effort should be consistent with the
fundamental inspection program. In addition, regional-
inspection initiatives should be performed for core physics
testing, observation of plant startup activities from the
refueling outage, maintenance team inspection followup, and.
evaluation of the procedure upgrade program. !
b. Licensee Actions
The licensee should continue emphasis on improving
maintenance activities through the upgrade programs that
have been established. Management attention should ensure 4
that the activities contained in:the' Safety Enhancement i'
Program are completed on schedule, and the IST program
upgrades are completed in accordance with commitments.
D. Emergency Preparedners
1. Analysis
This functional area includes activities related to the
establishment and implementation of the emergency plan and
implementing procedures, licensee performance during exercises
and actual events that test the emergency plan and interactions !
-with onsite and offsite emergency response orga,nizations during :
exercises and actual events.
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During this assessment period, region-based and NRC contract
inspectors conducted two emergency preparedness inspections.<
The first inspection consisted of the observation and evaluation
of the annual emergency response exercise. The second ,
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inspection involved a review of the operational status of the.
emergency praparedness program.= No actual events occurred-
during this assessment period.
Durino the July 1989 emergency. response exercise, the licensee's
overall:- response was determined to be acceptable. The control.
roca and technical support center staffs properly detected,
classified,. and declared emergencies, and made prompt ,
notifications to offsite_ agencies.. Although'the licensee's
ove"all performance during the course of,the exercise
demonstrated'an acceptable 11censeo proficiency to protect the
health and safety of the public, concerns were raised by.NRC-
regarding. specific issues.- One of 'the concerns minvolved:the-
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licensee's over staffing of emergency facilities with. extraneous-
personnel. Also, NPC expressed concern that the' licensee's..
staff had not been able-to ascertain the hypothetical source of-.
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the containment radiation: leak and that licensee's management. I
failed to, devote an acceptable' level of_ attention te the offsite- a
radiological. consequences associated with the plume. 3
An exercise weakness was identified with poor coordination,
direction, and technical support provided to the control room-
staff by the technical support center staff.. A similar weakness ,
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involved the lack of coordination.with the operational; support
center response. Three of: the other exercise weaknesses
involved, to some extent, repeated aspects from the two' prior
exercises. A significant, repeated weakness involved the'
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11censee's inability to demonstrate personnel. accountability
within 30 minutes. Scenario-problems were found.to be an -
exercise weakness. due to the inadvertent prompting ;of_ a ' player
by a controller, which was a repeat finding.. Also,- simulation i
detracted from the extent of free pp and; hence, diminished'the 1
realism of the scenario.-
d
Following the exercise, the licensee conducted.a self-critique
and was able to appropriate 1y' identify and chsracterize a' number
of exercise weaknesses, improvement items, and examples of good
performance. Severali of these findings coincided with;those of. '
the NRC observers.
An = inspection of the operational . status 'of the emergency.
preparedness program identified weaknesses with the training of
emergency response personnel. responsible for performing;early
dose assessments from the control room. As a result of this
finding, . the licensee made ~ a prompt commitment to simplify the
dose assessment procedure:and to' retrain responsible users to-
ensure that accurate anc-. timely dose as'sessments could be made
from the control room. The licensee. completed these corrective
actions prior to the end of.this assessment per.iod. ;
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It was noted that some aspects lof the. emergency preparedness
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program met all requirements and were considered strengths.
Emergency facilities, equipment, and' instrumentation was'.
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maintained in a good state of readiness.7_Aside from control'
room do>e cssessment, che knowledge and performance of the ;
duties of emergs.cy response = personnel intryiewed were good..
-The licensee implemented en aggressive drill' schedule and
l' conducted the drills in an effective man @ r.. Corporate
. management: involvement was. apparent in various' aspects of the- ,
L implementation of the emergency preparedness' program.
The licensee initiated changes to the emergency _ preparedness'
program to implement significant' improvements in the future.
Organizational changes were made-to upgrade the position of
st;ervisor, emergency planning such that this individual reports :(
directly to the division manager, nuclear services. Additional l
technical' staff _ positions _were added to the emergency planning-
'
and training' staffs. In addition, duties of:certain, emergency--
response positions have been proportioned:to enhance: response. ;
capabilities. ;
!' A major effort to upgrade the' effectiveness of the emerge'ncy l
plan implementing procedures was initiated, primarily through
contract resources, to'impt.sve their useability. .The licansee.
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has also initiated an effort to redirect the training in
emergency prepareaness-toward a performance-oriented approach
that will better prepar: emergency response personnel to perform
assigned functions during an emergency.
An effective QA program was implemented in +'- area of emergency
preparedness. Independent audits met requi, .nts, were well
coordinated and planned, and _ utilized sati ' ctory: resources and
_
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personnel. Audit, findings were properly c. cter ?,ed ad-
corrected. The licensee incrr: ed the number and frequency of . i
em3rgency preparedness survei);ances and made use of. functional
are experts in performing QA audits and_surveillances.
Oven ti, the licensee has initiated efforts to upgrade,the l
emergency preparedness program; including. the emergency plan, i
the emerger.cy plan implementing procedures, and,the staffing and
, organizational reporting of the emergency planning staff. While
NRC' recognizes. this effort as a significant move toward
strengthening the licensee's emergency preparedness program,
there has-not been sufficient time for NRC to fully assess _the _i
impact of these changes.
2. Performance Ratir.a .
The licensee is considered to be in Performance Category 2 in
this area.
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3.; Recommendations
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a. NRC Actions-
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NRC effort-should be consistent with the fundamental:
inspection program with regional initiative inspections in:
,
the areas of-training, protectiva action decisionmaking, ,'
l and dose calculations and assessment'.
L
L b'. Licensee Actions .
-Management should conti.we.to emphasize efforts to
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eliminate the' underlying root causes of licensee- and
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NRC-identified weaknessas.: Management's efforts should
also be directed toward maximizing realism in future .i
. scenario development.'
E. Security .
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1. Analysis
The assessment of this. functional. area includes; activities'that
ensure the security of.thr plant, including all_ aspects of.
access control, security checks, safeguar.is, Land
fitness-for-duty. activities and controls. ;
During this assessment period, this area w as routinely reviewed '
j< by the resident inspectors and periodically by region-based
physical security. specialists.
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Throughout the majority of this assessment' period,'the-licensee;
was involved in implementing a major upgrade oflthe entire
physical security program. The upgrade program, completed on
March 31, 1990, was'a well-designed effort'that,was instituted
_
as'a result of NRC- and. licensee-identified f.indings of f
programmatic deficiencies during previous as'sessment periods.
The-licensee now has a redesigned,' closed-circuit
television (CCTV) perimeter surveillance system.. protected and ~
vital area intrusion detection' systems (IDS), and a computer i
support system for the CCTV and: IDS _ systems.- The' licensee
, currently plans ,some minor additions in the areas' of protected
area ' access control- of packages .and vital ' area- access control of d
personnel.
In September 1989 the licensee decided to establish 4 unified i
proprietary-security officer force instead'of Lutilizing a mived-
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force of contract ans proprietary security officers.- Bee;ase of- -
the transition and the, uncertainties e te ,&.f rh connect'
security officers would be retain;d, the flicensee experienced a'
some marginal personnel perfor:aance. Personnel errors resulting
from excessive use of overt;me for required compensatory
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measurescontributedto'thisproblem.'lInl addition. management' I
has not been accessible to the ' security force members to: >
alleviate the officers!' concerns;about the ' restructuring' of the- :)
sei:urity force. ' Consequently, security officer morale has been.
low,Lsome officers have exhibited a-poor attitude, and, in some _
instances, job performance has been adversely affected. J
l The licensee has made cdjustments to improve security officer. ,
morale and. performance. Positive adjustmeats. include the j
, recognition of the need to complete the..+ ansition from contract.. !
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to proprietary security officer force as soon as possible, '
providing new uniforms for security officers, and increasing,
l security officer training.. The nuclear security officer ..
training' programhas been restructured and an acceptable' number '
W 1ersonnel has been assigned to supervise the program.- ,;
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In issues ccnfronting the, licensee during. this assessment"
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period, because of the upgrade l program, involved proficiency. l
l- training for central / secondary alarm stationi(CSS)~operatort and;- ,
l perfo mance-based contingency training., For' CSS operators to -
achieve proficiency; formal..on-the-job training with crucial
task testing was necessary. Unfortunately,' this' effort was
impeded by delays in the' installation of other equipment.
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Consequently, alarm station operators wereLuncomfortable with ;;
their experience level nn the CSS.- As,a result of-the extensive.
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use of compensatory meatures-associated with the upgrade:
program, the licensee t.as not yet been able to implement'the_
performance-based contingency training: that. is 'a ,sart of theirs '
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upgrade program initiatives.
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During this assessment period, the following . violations occurred, ,
some of which were self-identified by the> licensee (including
, the two significant violations): . failure to log / report certain
'
security events; some access, searches lwere inadequate and- a
consequently allowed a handgun and ammunition,to enter the
warehousa within the protected area'(Severity-Level:IIIi <
l violation), and allowed a food stuffs van to enter the protected ,
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area without a proper search; ontoccasions the protection of
safeguards information was inadequate.(Severity Level III ,
violation); an on post, sleeping, security-officer was found=and: "
a problem was identified 'with the inability to post out;' a
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problem was found with' assessment aids due to CCTV and perimeter-
IDS electronic misadjustments; and inadequate control ofca; vital-~ 't
area keys was identified. 'The licensee self-identified j
violations were cited because the. individual violations were '
considered significant. events, because of the need to improve
individual performance, or because the violations were repetitive.
In general, the. licensee's final corrective actions were prompt
and effective.
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The licensee implemented an: initiative to establish a. general 1
plant employee awareness program of; security.- requirements by ;
placing security awareness issuesf ni the company newspaper.- q
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In regard to the licensee!s annual audit of the security
program,Lan outside organization and a person.with ,securi+.y . , .
expertise were employed. The_ audit was, performed within the < i
specified time period, the _ findings were appropriately. '
documented,' and sect:-ity management was responsive to the .
findings.
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The licensee has.an ample number:of; supervisors, qualified
security-officers,_ and support personnel assigned to the
security department. -In~ June 1989 the position of supervisor, !
nuclear. security operations'was filled. -
Overall, the . licensee continued 'to make. improvements in .the
physical security program. In spite of_the difficulties.
described above, the licensee developed a technically sound and:
acceptable upgrade of the-facility and the program. Licensee;
resources are appropriate for effective nuclear.securb.y-
performance in the future. It appeared that the. licensee has
utablished-the basis and necessary ground work for a: security: 4
program that is capable of operating at improved performance
levels.
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2. Performance Rating
The licensee i= considered ~ to.be in Performance CategoryL 2 in
this functiona ea. Licensee = performance was-determined to-be'
improving duri'. .ne assessment. period..
3. Recommendations [!
, a. NRC Actions- 4
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NRC effort should be consistent with the fundamental inspection
program as augmented with regionaldinitiatives in the areas of
records and reports, training, testing and maintencnce, ,
compensatory measures, access control personnel,' access *
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control packages, and audit activities. :
b. Licensee Actions j
Licensee's management should continue to provide support to the
physical security program to ensure that_ improved performance in '
this functional area continues. Attention'to the involvement
with and oversight of security officers' duties should be .
emphasized by management.
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F. Engineering / Technical Support-
Analysis i
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The purpose of this functional area is_to address the adequacy
of technical and engineering support for all plant activities.
It includes all licensee ' activities associated with the design
of plant modifications;. engineering'and technical- support for
operations,' outages, maintenance, testing, surveillance, andi
procurement activities; and train ;. ,
This functional area.was11nspected'on an ongoing basis by the- l
resident inspectors, periodically by region-based personnel, and ,
'by the probability riskt assessment (PRA)-team from Region IV. -
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The engineering organization 1has experienced a significant- *
.!
transition, from one relying extensively on contractors,.to an- ,
organization with a substantial'in-house engineering capability.
.This has resulted in an increase in the' staffing levels in- the
onsite and corporate engineering organizations.
Early in this assessment period, it was: discovered that the -
lice 6see had not included, in the' group!of: safety-related-
procedures to be upgraded, the alarm response, station '
electrical system (including safety-related electrical .
distribution systems).. main steam system, and main.feedwater-
.
system operating proceoures.' The licensee corrected the scope 1
-
of their effort to include those procedures in the above
groupings that-had a potential safety impact:on.the operation of- -
the plant.
'
The abnormal operacing procedures were in the procass of being
upgraded under a Safety Enhancement Program effort. However,
the abnormal operating procedure upgrade was not' included in. the
,
+
writer's guide issued for other safety-related procedures, and
the scope of the abnormal operating procedures had not: included -
the loss or degradation of most-of the safety-related ac- and
de-electrical distribution systems.
.
As discussed above, and in other functional areas, the: licensee .
encountered problems'with the' technical content of safety-related
procedures. To: address this concern, the licensee.is in.the '
process of revising the technical content of. procedures through a
implementation of.the procedures upgrade program contained in
the Safety Enhancement; Program. In the interim, the licensee is ;
self-identifying procedure implementation issues. This program c
is currently on schedule and is expected to be completed by the
end of 1990.
_
l.
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An inspection in the control of special processes noted thr.t the
i. licensee, through its procedures, welding manual, and quality'
<
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control manual, provided,'for the most part, comprehensive ~I
instructions,for the control of special processes. However,.two. d"
examples were identified for the failure to provide adequate .
instructions for controlling heat input within the proper range,
and failure to qualify the full range of. material thickness
specified in the welding procedure specification. -Also,.as a
'
welding program enhancement, the licensee committed to correlate
the settings on .the welding. machines to actual welding. amperage
before making safety-related welds ~. .,
A special, announced team inspection in'the areaLof PRAwas
performed., This. inspection' covered the critical components of,
the plant'and the operational activities relating to dominant
accident; sequences developed by a generic-based assessment, tThe'
generic PRA study identified the'important systems, components,
and v:tivities .that could contribute;significantly to core melt.
1
Jaccident. sequences or mitigate the consequences of~such events.
The PRA inspection-team concluded that the emergency operating-
procedures,-when used by experienced and trained operators; ;
provided an acceptable level of' direction;to mitigate the,
consequences oflan' accident. The team also concluded that the a
risk-important systems and components'were generally. tested and.
maintained commensurate with their importance.to risk,
i
The PRA team' identified violations that involved inadequate -
emergency and abnormal operating procedures, and.a licensee-
identified failure to have an--adequate, design control program
for electrical' circuit fuses. An NRC-identified deviatio'i
'
involved the failure to conduct an emergency operating' procedure ,
validation as committed to in-a. licensee submittal to NRC.
, Other items of concern from this: inspection included the lack of-
a fuse / breaker coordination study, the lack of a fuse control ;
program, and the lack of a stroke test for the power-operated;
_
relief valves. LThese' items of concern were. indicative of-
weaknesses in the licensee's design control program. .
The licensee continued ~ to show improvement in other areas of the
design change control program. -Several inspections were
conducted that involved the review'of the preparation._of design
changes. The reviews confirmed that modification. packages
continue to be complete,.conci'se, and. contained the appropriate
i1 elements.
- -
L Concerns were previously identified by NRC with the licensee!s
'
capability to adequately resolve technical issues that are
L identified during. operation of the facility. To address these
concerns, the licensee established the systems engineering
organization. This' engineering group has. proven to be a
valuable asset in 'the resolution of problems. The systems .l
engineers are involved in the day-to-day activities related to l
the performance of the surveillance and maintenance functions, i
.
!
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and the trending of the result.< of these- functions. This aspect
of tne systems engineering effort has provided_ technical
expertise in the' field for_early identification.of component and
equipment problems T- contribution of the syst3ms engineering
organization toward overall plant safety was viewed as a
strength. 4
At the end of this essessment period, the plant was in a
refueling' outage. Activities performed during the outage were
'
completed satisfactorily. ; 0perations personnel removed and;
replaced all fuel assemblies in the reactor _ vessel without
incident.- The performance of the integrated leak rate test was
completed in accordance with' the apprnpriate requirements.:
Performance of eddy-current testing indicated that no steami
generator tubes required plugging. This was the third
consecutive outage where no tubes were plugged.and the results
were attributed to the strict secondary water chemistry program
maintained by the licensee.
The. licensee has completed the issuance of the design basis.
documents for plant systems. Through this effort, the licensee- *
identified instances where components and systems did not comply.
with the design basis requirements stated.i. the Updated Safety 1
Analysis Report. The. licensee's engineering organizations-
provided timely resolution of'the identified problems. -This
effort was identified as a strength.'
.
During several NRC inspections, design-related problems.were
identified. A review of the leak-rate testing of containment
isolation valves identified.two penetration : labeling errors and.
incorrect valve position labeling on piping and instrumentation
drawings. An inspection of the implementation ofLcommitments
made relative to Regulatory Guide 1.97, " Instrumentation For
Light-Water-Cooled Nuclear Power Plants to Assess Plant and
Environs Conditions During and Following an' Accident,"-
identified problems with design documents. The inspectors
experienced significant difficulty in extracting required
information from design documentation. ' Licensee personnel
acknowledged these problems and indicated that in-house-efforts
had been initiated to improve the drawing' quality and
usefulness, and the computer data base content and accuracy.
Inspections performed of the instrumentation calibration program'
identified violations that involved inadequate-calibration of
instruments utilized for postaccident monitoring and inadequate
environmental qualification of an instrument channel.
During a test of the turbine-driven auxiliary f eedwater pump,
the pump failed to respond to manually injec6ed air signals to
the pnuematic-hydralic speed governor. The licensee determined
that the pump may not have been operable prior to the test
i
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because of the failed speed governor components'.- .The licensee's j
tesponse to this' problem ~was deemed appropriate; however,. '
( subsequent followup by an inspector determined that the pump-had -l
J been inoperable over an extended period because of deficient.
-
j
l
testing, maintenance, and control system calibration.= The ..-
!
. licensee's actions were aggressive in resolving the programmatic !
i
and technical deficiencies in this instance.
!
! Prior to' the. establishment of a formal procurement' program;for
commercial' grade ite.u in -1988, the licensee: experienced . !
l deficiencies in traceability.. establishment of criticalt . .
1
- characteristics, insufficient inspection-and; testing, and verdor - 1
l qualification. Subsequent to the establishment of_a formal ^ L
program, a significant reduction in these problems were noted.-
-The results of an' inspection indicated that.: while improvement-
-
had occurred, more awareness for-the need of'an indepth-review
du,ing the evaluation and dedication process was required.:
l Licensee management oversight of the; training of licensed
operators and applicants for license improved. Management has .t
become more aggressive in identifying and correcting problems. y
However,sa recent:self-identified failure to properly track- i
medical conditions for a licensed' operator was a repeat of.a !
prior ~progthm failure. The licensee has implemented 1
comprehensive training- programs for the technical', professional, 1
and maintenance staffs. _
During this assessment period, the licensee installed a control ~
room simulator to provide enhanced training 1for licensed) j
operators. Training on the simulator commenced just prior to 'j
the end.of this assessment period.. This training. enhancement I
was viewed as a positive contribution-toward safe plant- f
operation. '
Historically, the licensee has experienced difficulty with the
implementation of TS-required firewatch patrols. During this 1
assessment period, problems were identified in this area.1 To
address this continuing problem, the licensee has' established a 11
group that is dedicated to'.the' performance offfire patrols. The- .!
security organization previously performed this function. ;Since-
implementation of the dedicated group, no ' problems have been
identified.
On February 26,11990, a loss of offsite power (LOOP) occurred
which resulted in a 2 minute loss of shutdown ceoling. The LOOP 3
was caused due ~to the under-voltage trip relays not
automatically shedding the operating low pressure safety 1
injection (LPSI) pump. A special inspection was conducted-' '
following the event. It was determined that.during manual
operation of the LPSI pumps,-the automatic load shed and
automatic diesel generator output breaker closure. features would ,
I
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- be inhibited when.an undervoltage even't on_v_ ital eler.trical 2
buses occurred. The licensee analyzed the event ar.d determined
that design of the. electrical system complied with the plant-.
design basis and did not affect safe plant; operation. As a- -
system enhancement,-the. licensee'has decided to. modify.the' ,
- design in order for-the emargency-diesel-generator to. ..
.
'
automatically load-in the. event of the design basis accident'and -i
a' LOOP when a manually-loaded LPSI pump <ir operating. This- 1
modification will be completed.by the end of the 1991. refueling' :
. outage. ,
In summary, several strengths,. positive actions,: and: weaknesses
were identified during this assessment; period.- The licensee has: -
undertakenian extensive program for upgrading safety-related and
- abnormal operating procedurest including technical content,- -
through the efforts of the Safety Enhancement' Program :The. .
licensee continued to=show improvement in the design change >
control program as evidenced by the.results from several '
inspections _ conducted during this: assessment period. Concerns , ;
regarding the. licensee's capability- to. adequately. resolve' . t
technical issues identified during plant operation wereibeing)
effectively addressed by:the recentlyLestablished systems;
engineering group. During:the recent refueling outage, the
eddy-current testing conducted'on' steam generator tubes
-
indicated that no tubes required plugging. EThis was the third
-
consecutive outage during which no tubes weretplugged. .The' ,
results were attributed to at strict secondary water chemistry
, program. The. licensee's engineering organizations have provided
,
timely resolution to problems identified by.the issuance of the
[ design basis documents for planti systems. ' Difficulties
,
experienced with the implementation =of firewatch patrols appears ,
I
'
to be resolved by the establishment lof;a group' dedicated to the 3
performance of fire patrols. Several items.of concern I
identified during a PRA inspection were indicative of weaknesses! a
in the design control' program.
2. Performance Rating
,
The licensee is considered to be in Performance Category 2 in
this functional area. '"
4
,
3. Recommendations
a. NRC Actions
NRC inspection effort should be consistent with the q
fundamental inspection program. -Regional initiative should
include an inspection to evaluate the licensee's -
engineering capabilities.
!
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b. Licensee Actions 7
. ,
..
Licensee management should focus;their efforts'on the :s
completion of the safety-related procedures upgrade , .
,
project. Management should take the appropriate actions to
~
a
ensura that the weaknesses identified with emergency and 1
-
abnormal operating procedures are resolved in altimely>
manner.
G. Safety /issessment/Ouality Verification'-
1. [nalysis ,
'
The assessment of this functional area" includes.all: licensee. '
review activities associated with the implementation of = licensee? .3
safety policies; licensee activities related to amendment,- ^ '
exemption, and relief requests; response-to NRC Generic ~ Letters,
-
Bulletins, and Information Notices;-and resolution-of TMI items
and other regulatory. initiatives. It also' includes .licen'see's-
~ activities related to resolution of. safety issues,s
10 CFR Part 50.59 review:, 10 CFR Part 21-assessments, safety . . .
committee and self-assessment activities, ruot cause' analyses;of-
plant events, use of feedback from plant QA/QC reviews,-~and -
participation in self-improvement programs. :Itii.ncludesithe -
effectiveness of~the licensee's quality verification, function in- :
'
identifying and correcting substandard;or ancmalous performance,
in identifying.ptreursors of-potential-problems,' and in ,
- i
'
monitoring the over:Il performance of the plant.
Inspection of licensee self-assessment activities iJentifiedlan;
overall effective performance by the Safety Audit and Review- j
Committee (SARC).and the Plant Review Committee (PRC). The- ,
licensee had identified and corrected the, failure.of.a SARC-
subcommittee to review recent plant modifications and.their ,
'
associated safety evaluations. Additionally, the licensee. 4
[ observed that neither group had performed any-self-assessment
,
activity in regard to the safety-related' procedure upgrade. <
L effort. It was noted that PRC activities.were not well. ...
i, documented and it appeared that-handling of action, items could *
m
l be improved. It was also noted that one PRC? standing l.
l
subcommittee was not scomitting the results of its reviews to- l
t
the PRC for approval. The licensee instituted immediate actions
to correct the obsert&d PRC deficiencies.
l To address a broac spectrum of concerns and weaknesses l
previously identif;ed by NRC, and an independent appraisal:by at
l
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licensee contractor af the FCS nuclear organizations, the
licensee developed and implemented the Safety Enhancement ,
Program. This program provices a comprehensive-listing of ,
- licensee actions related to safe plant operation and the
i activities that support operations. Implementation of the-
i
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actions contained in the program has received a high. level- or
. .,
corporate and plant management-attention?and support.. The- :i
licensee has demonstrated positive, steps toward improving their.
'
overall performance by implementation;of the: items-contained in
the Safety Enh'ancement Program. . This overall improvement: .;
indicates that the licensee is; improving-their capability to
provide management leadership.and oversightt of the diversei *
l elements related to the conservative operation'of the:FCS. 1
Although all: items have not been completed, theieffort to' .
complete the remaining open. items is ont schedule.; l
-Satisfactory. programs were found' to be in plac'e with respect to.
-
' implementation of the 10 CFR Part 21 review program-and the-
control of measuring 'andLtest' equipment"(M&TE). Positive
actions were observed.to have been taken-by the licensee:to .
correct a prior weakness in regard to control: of M&TE used by :
the I&C1 maintenance' group.
-
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The licensee implemented a training program for1those- .
'
individuals involved in the preparation, review, and approval of-
~
'10 CFR Part 50.59 evaluations. . Personnel completing the
training are the only individuals authorized to process
Part 50.59 evaluations. This approach has been a positive-
contribution towards the licensee's satisfactory completion of
Part 50.59 evaluations. ,
A comprehensive corrective action program was established thatL
appropriately provides for identification, tracking, correction,
and trending of safety-related problems. The licensee was also-
observed to have implemented surveillance programs,to provide
additional oversight of inservice' inspection contractors and . a
in process welding.
]
The licensee has established;and implemented a Nuclear Safety
Review Group (NSRG), an independent organization.that-reviews
i
' p?:nt events and occurrences to determine the root cause(s) and
rew mend corrective actions. The establishment of the NSRG was
a 11:9nsee self-initiated action that:psrallels the independent
safey review group required by the TS for newly licensed
,
facilities. The NSRG has been fully staffed by experienced .
individuals with diverse backgrounds,.and-is-managed by an I
individual that previously served as supervi:or, operations. '
The NSRG completed, during this assessiiient perioQ ten root
cause analysis. reviews on plant; events such as inadvertent '
overflow of the spent fuel. pool, failure of the turbine-driven ;
auxiliary feedwater pump speed controller, and the loss of ;
offsita power during the refueling outage. The reviews
performed by the NSRG have beenLcomprehensive and have provided.
the appropriate recomendations for corrective actions to
.
1
i
prevent recurrence. The establishment'and performance of the i
NSRG was-viewed as a strength. >
1 .
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The licensee has upgraded the staffing of.the;QA organization by ,
,
the addition of experienced QC inspectors and technical auditors l
with working experience in the areas of operations, health,
'
ph/ sics, security, and chemistry. The staffing level-in.the QA
~
organization was satisfactory. In the previous SALP. report,'a
concern was-identified with the performance of. audits by QA.,
. The audits were noted to be compliance-based rather than- i
performance-based. The licensee has taken' actions to' address '
this issue. A review of-the licensee's audit program' indicates.. 1
that performance-based audits are now being performed. !As'noted-
in the discussions'of the other functional areas, the licensee's
- audit program has been comprehensive,' thoroughly performed,:and-
corrective ~ actions taken'in response to. audit findings were
appropriate'and timely. -
,
The licensee has established and -issues,' on a monthly basis, as ,
comprehensive set'of performance indicators. tTheseeindicators
provide management.with'agtool that can be used for early [
identification of adverse trends:so that corrective' measures can:
be taken to reverse the t' rend. -In addition,-the QA-organization: .
publishes a detailed quarterly trend report-that summarizes the c
results of their audits.
,
During this assessment' period, eight license amendments were
- issued. These amendments included incorporation.of' surveillance .
and operability-requirements for the alternate shutdown panel, .
generic specifications-incorporated into the TS,Lsurveillances
and limiting conditions for operation forc a control room-
modification to alleviate air-in-leakage, and some '
administrative changes. In addition,tsafety evaluations were
issued that addressed TMI. actions,< Salem ATWS; items,'and actions
~
-
requesting reliefs.from the ISI'and IST programs. . i
- The licensee's submittals, in general,' indicated an acceptable
level of understanding of the technical issues from a safety
standpoint and acceptable approaches were'used.. However, in the. ;
latter part of this assessment period, weaknesses were ;
identified in both the schedular aspects' of. the license'e 's :
submittals and fully addressing the requirements of the' proposed .t
'
.
TS changes. Six-submittals were required prior to the approval l
of a license amendment request for the' boric acid heat tracing .l
system. This can be attributed to factors related to the-
refueling outage, many ongoing actions being1 performed: ,
- simultaneously, recent new employees-joining the organization ~- '
'
(almost doubling the work force), and pressure to meet the
' schedule. The licensee has incorporated changes that should
rectify some of these problems.
'
'
s
The licensee's responsiveness to NRC Bulletins and Generic
"
Letters was timely and technically complete. . Responses during
this assessment period included NRC Bulletins 88-03, General - 9
4
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Electric HFA Relays"; 88-10. " Nonconforming Molded Cas'e Circuit ,
Breakers"; and 89-03, " Potential Loss of_ Required $hutdown '
,
l
Margin During Refueling." The licensee's-response to_NRC l
Bulletin 88-10 had to be revised because four breakers. which
were to?be. replaced during the 1990-refueling outage,1could not 'i
be obtained from<the. vendor. The licensee indicated that.these
'
breakers'would be replaced during the 1991 outage and that a;
-
,
justification for continued operation would'be in place which -
the NRC. subsequently found acceptable. _ The responses to Generic
Letters included 89-06, " Safety Paramete.r Display. System";
- 89-07, " Power Reactor Safeguards' for Surface Vehicle Bochs; -
89-08, " Erosion / Corrosion';'; and 90-01,L"NRC Regulatory -Impact '
Su rvey . '.'
A review of the itcensee event reports submitted to NRC- .
I
indicated that?.the reports described the major aspects.of each~
' event, including the causes of system fai_ lures that contributed' -
to the event and the significant correct 1ye actions'taken or
~
i
planned to prevent recurrence..
Overall, the licensee's programs that provide for the assessment
l and. verification of activities related to the various aspects ofi -
I
safe--plant operation have received a high level of senior
management' attention and involvement and have placed emphasis on
.
l superior personnel performance.- -These programsLprovide a' solid
basis for increased overall ~ performance and the attendant - ,
philosophy contained;in the programs should be implemented i
through all levels of the nuclear. organization. These programs
include self-identification of problems' through the'-
implementation of QA audits,7 effective. performance of- the SARC, i
and the root cause analyses performed by the NSRG ;The actions
implemented through the Safety Enhancement Program provided an' L
increased level of management oversight with respect to plant .,
operations. "
l
2.
'
Performance Ratina
,
The licensee is considered to be in-Performance Category 1 in t
thfs functional area.
l
l 3. Recommendations
a. NRC Actions
-a
l
NRC inspection effort should be consistent with the . ;
l fundamental inspection program. An, assessment of the
i
. licensee's implementation of the items contained in the 1
Safety Enhancement Program should be performed.
a
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b. Licensee Actions
l' ' Licensee's management should take actions to ensure that I
L
"
all submittals made a NRC are timely and address all
technical aspects of the subject. Management should'
provide the' appropriate _ oversight'_to' ensure that the items-
in the Safety Enhancement Program are completed on schedule
~
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and in accordance with the licensee commitments ~. -.,
i
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f V. SUPPORTING DATA: AND SUMARIES .
l~
)
A '.- - Licensee Activities
1 ~. Major Outages
d
~
The licensee commenced the thirteenth refueling outage on ..
-February 17, 1990.. At the end of.this assessment period..the
-
. outage was still in progress.
1
l
2. License Amendments
o-
During this assessment period, .eight license amendments were--
issued. Some ef. the more, significant; amendments were: :
o Extension of the interval for performance of surveillance
tests by.25 percent - Amendment:122=
.
o Operability and'surveillancectesting requirements'for the
alternate shutdown panel - Amendment.125: ;
3. Significant Modifications
l-
o Installation of a third auxiliary feedwater pump'to improve l
reliability of the auxiliary feedwater' system.' -'
o Major upgrade of.the security system.
o
L
o Construction of 'a new radiological waste building, a'-
radiological protection / chemistry office,;and locker room
complex.
'
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B. Direct Inspection and -Review Act'ivities I
NRC inspection. activity during this SALP cycle included 52 ;
inspections performed with approximately 4855 direct Linspection hours '
expended.
C. Enforcement Activity I
.
.1
1
The SALP Board reviewed the enforcement history for the period Mayz 1. y
.
1989, through April 30,'1990. .The enforcement history is tabulated
.1
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in the enclosed' table. One civil penalty was issued in the area of ,
security. No orders were issued ' '
'
TABLE f
ENFORCEMENT ACTIVITY
NUMBER OF VIOLATIONSi -
,
FUNCTIONAL AREA -IN SEVERITY LEVEL :
Weaknesses Dev a NCV.s** :IV 'III ~
A. Plant Operations ~ 2- ~3
7
B.- Radiological Controls 2. 1- !
C.= Maintenance /Survhillance' 2 1 ;
D. Emergency PreparednessL '6 '3
E. Security 1 8 2 ***
F. - Engineering / Technical Support 4- 3 7 1 **** <
G. Safety Assessment / . 4- 2
Quality Verification
TOTAL 6 5 13 25: '3 i
- . I
Deviations
- -
Noncited violations
- -Combined Civil. Penalty of $25K
- No Civil Penalty Issued
(
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)
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WSPECTOR'S REPORT
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UNITED STALES NUCLEAR REGULATORY COMISSION:
- SYSTEMATIC ASSESStENT OF LICENSEE PERFORMANCE
EETIflG- -l
MAHA PUBLIC P0kER DISTRICT
FORT CALHOUN STATION- -. ,
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t%Y 1, 1989, TliROUGH APRIL 30, 1990'.
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FORT CAUOJN STATION'S?
a
EFERGEllCY- OPERATIONS FACILITY ,
JULY 26, 1990- .
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AGENDA. ',
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INTRODUCTION ROBERT D. MARTIN, REGIONAL.
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ADMINISTRATOR,-NRC REGION IV.
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SALP PRESENTATION sat 0EL'J. COLLINS, DIRECTOR, . 1
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DIVISI0tf0F. REACTOR PROJECTS; ,
NRC REGION'IV
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OMAHA PUBLIC POWER DISTRICT LICENSEE fW1AGEENT AND STAFFl -
-RESPONSE AND C0ffENTS
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CLOSING RETMRKS : 8OBERT D. MARTIN
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SALP PROCRAM OBJECTIVES -
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IfPROVE LICENSEE PERFORMANCE ,
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PROVIDE A ECHANISM FOR FOCUSING ATTENTION
ON OVERALL LICENSEE MANAGEENT EFFECTIVENESS
PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES [
IfPROVE TEC REGULATORY PROGRAM-
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PERFORM @CE ANALYSIS' AREAS FOR FORT- CALHOUN STATION
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1, PLANT OPERATIONS: [
2.. RAD 10 LOGICAL C0hTROLS 1l
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3.- MAINTENANCE / SURVEILLANCE
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4.. ETERGENCY PREPAREDNESS 1
5. SECURITY .
6, - . ENGINEERING /ECHNICAL' SUPPORT-
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7, SAFETY ASSESSENT/0UALITY VERIFICATION
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. FUNCTIONAL AREA PERFORfMNCE CATEGORY
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CATEGORY 1 i
LICENSEE t%NAGEENT 'ATTEtlTION' AND lfNCLVEEE ARE READILY .
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EVIDEllT AND PLACE EFPHASIS ON SUPERIOR PERFORf%NCE OF
NUCLEAR SAFETYJOR SAFEGUARDS ACTIVITIES, WITH TE RESULTING
PERFORf%NCE SUBSTANTIALLY EXCEEDING REGULATORY REQUIREfEITS.
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LICENSEE RESOURCES ARE APPLE AND EFFECTIVELY USED S0 THAT A
HIGH LEVEL OF PLANT AND PERSONfEL ?ERFORMANCE IS BEING !
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ACHIEVED. REDUCED NRC ATIEUION MAY BE APPROPRIATE.
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CATEGORY'2. ,
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LICENSEE t%NAGEfBff ATTENTION T0' AND INVOLVEENT IN TE,
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PERFORMANCE OF NUCLEAR SAFETY-OR SAFEGUARDS ACTIVITIES'AREc
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TE LICENSEE HAS ATTAIED A-LEVEL OF'. PERFORMANCE ABOVE
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THAT NEEED TO KE REGULATORY REQUIRE E NTS.: LICENSEE RESOURCES
ARE AMOUATE AND REASONABLY ALLOCATED S0 THAT GOOD PLAfff AND
PERSONEL PERFORI%NCE IS BEING-ACHIEVED,1 NRC ATTENTION MAY BE
t'AINTAlfED AT NORMAL LEVELS.'
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CATEGORY 3- ,
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LICEflSEE MANAGEENT ATTENTION T0 AND IWOLVEENT IN THE ~
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-PERFORf%fCE OF NUCLEAR SAFETY OR SAFEGURADS ACTIVITIES:
~ ARE NOT SUFFICIENT. THE LICENSEE'S PERFORMANCE DOES fCT j
SIGNIFICANTLY- EXCEED THAT fEEDED T0 t'EET MINIMAL REGULATORY : ,
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. RECUIRBENTS, Ll'CENSEE RESOURCES APPEAR T0 BE STRAIfED OR .
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lABOVE NORfML LEVELS,
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EVALUATION CRITERIA
1.- : ASSURAfCE OF. OVALITY, IfCLUDING MANAGEENT IfN0LVETENTL
AND CONTROL'
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2. APPROACH T0 IDENTIFICATION AND RESOLUTION OF TECHNICAL ,
ISSUES FROM A SAFETY STANDP0 lilt >
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3. ENFORCEENT HISTORY
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4, OPERATIONAL EVEffTS (INCLUDING RESPONSE TO',' ANNLYSIS 0F,:
REPORTING OF, AND CORRECTIVE ACTIONS FOR)
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5. STAFFit!G (INCLUDifG MANAGERNT)
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6. EFFECTIVEfESS OF TRAINING AND 00AliFICAT10N PROGRAM l
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PLANT '0PERATIONS - ., .I
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CATEGORY 2 IPPROVING' -
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STRENGTHS :
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OVERALL1 PLANT OPERATIONS AS EVIDENCED BY: LOW SCRAM RATE ,
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DEDICATED AND EXPERIENCED OPERATORS - CONTROL'R00M-
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INTERDEPARTENTAL IPRERFACE-
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WEAKNESSES
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SLOW PROGRESS Ifl INCRESSING THE NUPEER'0F LICENSED STAFF
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RADIOLOGICAL CONTROLS a
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HIGH OUALITY RADIATION. PROTECTION PROGRAM
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EFFECTIVE TRAINING PR03 RAM'
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ALARA PROGRAM a
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MANAGB M OVERSIGHT
STAFFING i
EFFECTIVE LIOUID AND GASE0US RELEASE PERMIT PROGRAM
RAD 10CHailSTRY AND WATER CHEMISTRY PROGRAMS 1
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kEAXNESSES. 1
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SKIN CONTAMINATIONS i
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.KfGA. EDGE AND EXPERIBiCE LEVEL OF-THE CRAFTS
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PROCEDURES
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ASSIGffENT OF REVIEW RESPONSIBILITIES FOR RETESTS
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PREDICTIVE AND PREVENTIVE f%IffTENANCE PROGRAMS
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f%NAGEENT OVERSIGHT OF SECURITY OFFICER DUTIES
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B4GIfFRIfE/ TECHNICAL SUPPORT
CATEGORY 2
STRENGTHS
PROGRAM FOR UPGRADE OF SAFETY-RELATED AND ABNORMAL OPERATING ,-
PROCEDURES
SYSTEf1 ENGINEERING ORGANIZATION
SECONDARY WATER CH911STRY PROGRAM
DESIGli BASIS RECONSTITUTION PROGRNi
NEW Sif0LATOR
WEAKNESSES
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DESIGN C0flTROL PROGRNi
DESIGN DOCUENTATION
ItPLBEITATION OF TECHNICAL SPECIFICATION REQUIRED FIREATCWS
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SAFETY ASSESSPENT/0UALITY WRIFICATION
CATEGORY 1 ,
STRENGTHS
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CORPORATE AND PLANT MANAGB elT OVERSIGHT
10 CFR 50.59 EVALUATION TRAINING PROGRN1
ESTABLISHtEfff AND PERFORf1ANCE OF TIE flVCLEAR SAFETY REVIEW GROUP
OA PROGRAM
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'IECHNICAL SPECIFICAT10ft CHANGE S EilTTALS
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SCHEDULE AND CONDUCT OF DRILLS ,
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CORPORATE MANAGBEfff INVOLVDENT ,
SELF ASSESSIDri
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WEAKtESSEE
P00R COORDINATION, DIRECTION, AflD TECHNICAL SUPPORT TO THE CONTROL
ROOM STAFF -!
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LACK OF C00RDit!AT10N WITH OPERAT10f1AL SUPPORT CalTER STAFF j
ABILITY TO DB DISTRATE PERSONNEL ACCOUNTABILITY - REPEAT
EXERCISE SCENARIO AtlD SIMULAT10tl-
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TRAlfilf1G Ifl EARLY DOSE ASSESSfENT !
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PLAffT RADIOLOGICAL 11AINTENAfCE/ EERGENCY TEGINICAL QUALITY
OPERATIONS CGfiRQ S SIRVEILLANCE PREPAPERESS SEORITY SIFPORT VERIFICATION
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TEGINICAL
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STANDPOIrlT
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ATTENDEES
Name' . Affiliation
R, Martin NRC - Region IV
S. Collins NRC - Region IV
J. Jaudon NRC - Region IV
B. Beach NRC - Region IV .i
R. Lanksbury NRC - Region IV
. P. Harrell NRC - Region IV
T. Reis NRC - Region IV
R. Dudley NRC - NRR
T. Bournia NRC - NRR-
F. Petersen OPPD
W. Jones OPPC
G. Gates OPPC .
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R. Andrews OPPD
S. Gambhir OPPD
G. Peterson
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,',. ,. Enclosure 3
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) Omaha Public Power District
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i 1623 Harney Omaha. Nebraska 68102 2247
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402/536 4000 ','i 1
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August 27, 1990 4 311990
LIC-90-0683
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
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Washington, DC 20555 s
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i References: 1. Docket No. 50-285
2. Letter from NRC (R. D. Martin) to OPPD (W. G. Gates) dated ,
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July 12, 1990 (50-285/90-24) ;
Gentlemen:
SUBJECT: Systematic Assessment of Licensee ."eri'ormance (SALP) !
Report (Inspection Report 50-285/90 24) 1
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On July 26, 1990, Omaha Public Power District (OPPD) met with NRC management to ;
discuss the results of the Systematic Assessment of Licensing Performance '
report for Fort Calhoun Station. At that time, OPPD provided verbal comments ;
on the SALP board findings. OPPD has prepared written responses to the SALP
report recommendations, and provides them as the attachment to this letter.
If you should have any questions or comments concerning these responses, please
do not hesitate to contact me. 1
Sincerely, !
AV. E.-
W. G. Gates
Division Manager
Nuclear Operations
WGG/sel
Attachment
c: LeBoeuf, Lamb, Leiby and MacRae
R. D. Martin, NRC Regional Adr 1nistrator, Region IV
A. Bournia, NRC Project Manager
R. P. Mullikin, NRC Senior Resident Inspector
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Attachment
SALP Recommendations and Responses
Plant Operations l
Recommendations for Licensee Actions: i
Licensee't management should continue efforts for increasing operator ,
staffing. Management should continue to ensure that activities relate 1 to !
equipment operability and event reportability are performed in a timely and l
conservative manner. i
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OPPD Response: i
During the past two and a half years, OPPD has transferred a number of licensed. l
personnel out of the operating group and placed them in such areas as
Maintenance Plannir.g, Outage Planning, Training, and Simulator Services. These
transfers were effected to improve the quality of the critical plant activities ;
and provide career opportunities for licensed operators. At all times, OPPD .
-has maintained its shift manning requirements. I
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Since this SALP period ended, OPPD added three licensed operators to the . !
operations group._ In addition, another group of four candidates is scheduled
for the Reactor Operator examination in November, 1990. Another class of six
Reactor Operators and six Senior Reactor Operator candidates has entered ,
training and is scheduled to-take examinations in October, 1991. !
OPPD is currently developing a corporate level procedure to provide guidance on i
operability determinations. This procedure will be developed and approved by
1991. Emphasis will be placed on timely and conservative operability
determinations and event reportability. ;
Radiological Controls
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Recommendations for Lionsee Actions:
Licensee's management should continue efforts to implement a strong ?
self-assessment program, ensure that radwaste personnel complete specified I
training, and consider transportation activities-in the QA audit program. !
Emphasis on compliance with radiological protection procedures should be i
stressed by management. )
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OPPD Response:
OPPD intends to maintain and improve the positive aspects noted in the -;
radiological controls area. The self-assessment program presently in place to. l
evaluate the effectiveness of the Radiation Protection (RP) Program will J
continue to be emphasized and monitored by management. '
Radwaste personnel have completed or are currently in the process of completing I
all identified training commensurate with individual job assignments. This-
L training is being. completed on an established training schedule.
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Compliance with radiological protection procedures will continue to be stressed
'by all levels of management. Enhanced and/or additional training on good
. radiological work practices and the importance of compliance with RP procedures
will be provided to appropriate plant personnel. In addition, increased
efforts are under way to determine the cause of skin and clothing
contaminations and to implement methods to reduce this number.
Maintenance / Surveillance _.
Recommendations for Licensee Actions:
The. licensee should continue emphasis on improving maintenance activities
through the upgrade programs that have been established. Management attention
should ensure that the activities contained in the Safety Enhancement Program
(SEP) are completed on schedule, and the IST program upgrades are completed in ,
accordance with commitments. !
OPPD Response:
Management is continuing emphasis on improvements in the area of :.aintenance
performance. In~ addition to the procedures upgrade program and SEP-
commitments, a major effort is in progress to define weaknesses in maintenance
implementation. This root cause investigation will be used to formulate an
action plan aimed at-upgrading work planning and scheduling, departmental
fid xfaces and work practices.
OPPD considers the upgrading of procedures one of significant challenge and
benefit. Management is providing support and closely monitoring this effort.
Once upgrades are completed and satisfactorily implemented, maintenance
activities should greatly improve. The coordination of the work effort is
being reviewed to identify areas needing improvement.
Control and scheduling of surveillance testing has proved to be effective, as
have the controls for post-maintenance and post-modification testing.
Upgraded programs to enhance teste.g ed : rveillance of equipment and to
improve equipment reliability vill continue to be instituted and utilized.
Primary examples of these upgrades include the new Preventive Maintenance (PM)-
Program instituted in February 1990, surveillance testing of alternate shutdown
panels initiated in May 1990, and upgrades to.the Inservice Testing (IST)
program which are being instituted during procedure upgrades and will be
completed per the schedule established in the SEP.
The new PM program went into effect on February 1, 1990, just before the end of
the SALP period. This program was designed to provide a structured basis for
preventive maintenance performed at the Fort Calhoun Station. Internal reviews
have shown that the program has accomplished this-for the 53 systems or
subsystems selected for evaluation on the basis of their importance to safety
and/or reliability. The program has been turned over to the organizations 1
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responsible for its implementation. Experience with the operation of the new
PM program is providing input for program enhancementi. The predictive
maintenance program (lube oil and vibration analysis) has been included under ;
the same organizational structure as the preventive maintenance program for '
continuity. Preventive and predictive maintenance will continue to be an area
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. Emergency Pr:paredness i
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Recommendations for Licensee Actions:.
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Management should continue to emphasize efforts to eliminate the underlying
root causes of licensee and NRC-identified weaknesses. Management's efforts ,
should also be directed toward maximizing realism in future scenario 1
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development.
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OPPD Response: j
During this SALP period, OPPD completed an organizational change in the . :
, Emergency Preparedness (EP) area. The EP department now reports oto a higher j
level in our organization. OPPD is fully committed to maintaining a high level
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of management attention to this area. Upgrading procedures is another~ area of
improvement for Emergency Preparedness along with staffing increases and
improved training. The exercise scheduled'for later this' year will use these
revised procedures to demonstrate their effectiveness. Scenario development .
j enhancements are anticipated with the early assignment of qualified OPPD and 1
consultant personnel and with the use of OPPD's site specific simulator'for !
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scenario validation. I
Security . i
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Recommendations for Licensee Actions:
Licensee's management should continue to provide support.to the physical
security program to ensure that improved performance continues in this -
functional area. Attention to the involvement with and oversight of security
officers' duties should be emphasized by management.
OPPD Response:
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During the past year, OPPD has implemented a number of initiatives designed to
improve security at Fort Calhoun Station. These initiatives included, among
other things, a major upgrade of the site's physical. security system and a
number of actions to increase and improve management's involvement with and
oversight of the security force.
The security system upgrade project is complete and management is now looking
at methods and procedures to ensure that the system is maintained at peak
operating proficiency.
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Management's actions to improve interaction between supervisors and security
force members include increased emphasis on supervisor tours of work spaces and~ '
improved avenues cf communication, both vertical and horizoatal, within the
organization. The impact of these and other changes has already been reflected '
in improved security force operation.
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Engineering / Technical Sr;; port
Recommendations for Licensee Actions:
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Management should focus their efforts on the completion of the safety-related
procedures upgrade project. Management should take appropriate actions to
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ensure that the weaknesses identified with emergency and abnormal operating
procedures are resolved in a timely manner.
OPPD Response: -
Management will continue to support the monitoring of numerous projects and
programs in the Engineering / Technical Support area. Progress continues toward
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closure of other significant engineering projects. These include:
1. Prioritization, scheduling and planning of modifications to
effectively utilize engineering resources to support OPPD's safety
enhancement objectives.
2. Color coding and labeling of components throughout the Control Room
and the plant to enhance the operator / machine interfaces.
3. The Procedures Upgrade Project continues to receive management
attention through reviews of project progress and proceduro quality.
Over 900 safety-related procedures have been revised and issued to
date to improve procedure content and usability. The schedule for ;
updating the remaining safety-related I&C procedures identified from i
the initial breakdown is currently the end of 1990 (SEP 48). Efforts
to complete the remaining safety-related I&C procedures continue to be -i
a challenging issue for OPPD. Our program to update the annunciator
response procedures is in the implementation phase. Dedicated writers
and Operations personnel are assigned to complete the revisions by
February 1991.
The Emergency Operating Procedures (EOPs) have been revised and issued. These
revisions incorporate guidance contained in Revision 3 of the Combustion
Engineering 0wners Group (CE0G) E0P Guidelines. Abnormal Operating Procedures
(A0Ps) have also been revised and issued. Operator training on the upgraded
AOPs and E0Ps is complete. The remainder of the NRC and INPO comments have
been evaluated and prioritized and will be included in future revisions as part
of ongoing E0P/AOP maintenance.
The Fort Calhoun simulator has been in ;ervice about three months and has been
used for a complete verifiMion/ validation of E0Ps and AOPs. A special task
force has been established to ensure rapid resolution of identified procedural
weaknesses. A mechanism for continuing review and upgrade of E0Ps/A0Ps has
been established.
Safety Assessment / Quality Verification
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Recommendations for Licensee Actions: {
Licensee's management should take actions to ensure that all submittals made to
NRC are timely and address all technical aspects of the subject. Management i
should provide the appropriate oversight to ensare that the items in the Safety
Enhancement Program are completed on schedule and in accordance with the
licensee commitments.
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OPPD Response: $
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OPPD has taken action on improving the Facility License Change submittals to-
the NRC by the addition of a technical reviewer, i.e., a person who has not ',
been directly associated with the Technical Specification (TS) changes. his
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person can independently review the TS or TS change from the standpoint oI
completeness, verbatim compliance, technical adequacy, and clarity. ,
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OPPD considers the Safety Enhancement Program (SEP) to be the singse mos*: ,
important improvement initiative we have undertaken. A SEP project director :
has helped OPPD management by overseeing SEP schedules, commitments, i
verifications and validations, and institutionalization of the many commitments
in the SEP. OPPD will make every effort'to ensure the few remaining SEP items _ -
are comp'.eted with quality and in a timely manner,
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