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i U.S. NUCLEAR REGULATORY COMMISSION NRC MANUAL Volume:-
0000 General Administration Part:
0500 Health and Safety IE CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-01 COVERAGE This Chapter and Appendix describe the basic structure and overall procedures for implementation of the NRC program to assess licensee perforinance. This program applies to all power reactors with operating licenses or construction permits (hereinafter referred to as licensees).
0516-02 OBJECTIVES 021 To improve the NRC Regulatory Program with emphasis on resource allocation.
022 To improve licensee performance.
023 To collect available observations on an annual basis and evaluate l
licensee performance based on those observations, through the Systematic Assessment of Licensee Performance (SALP), an integrated NRC staff effort.
Positive and negative attributes of licensee performance are considered.
Emphasis is placed upon understanding the reasons for licensee's perforinance in important functional areas, and sharing this understanding with the licensee.
The SALP process is oriented toward furthering NRC's understand-ing of the manner in which:
(a) the licensee management directs, guides, and provides resources for assuring plant safety; and (b) such resources are used and applied.
The integrated SALP assessment is intended to be suffi-ciently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to !!censee management.
0516-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (EDO) provides oversight for the activities described herein.
032 The Director, Office of Inspection and Enforcement (IE):
a.
Implements the requirements of this chapter within the Office of Inspection and Enforcement.
J 8408150740 840718 Approved: March 23,1982 E
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3 SYSTEMATIC ASSESSMENT OF NRC-0516-033 ~
LICENSEE PERFORMANCE (SALP)
I b.
provides monitoring of SALP process and evaluation of SALP policy, criteria, and methodology; and assesses the uniformity and correct-ness of the Regions' implementation of the program.
033 The Directors, Offices of Nuclear Reactor Regulation (NRR), Analysis and Evaluation of Operational Data ( AEOD), and Nuclear Materink Safety and l-Safeguards (NMSS), implement the requirements of this chapter within their Offices.
034 Regional Administrators:
l a.
implement the requirements of this chapter within the Regions.
b.
assure that assessments of licensee nuclear safety performance are conducted.
1 l
c.
assure that meetings are conducted with licensees subsequent to each SALP Board assessment to provide NRC assessment findings to utility 1
management.
d.
evaluate the SALP Board's report and the licensee's comments; s
I provide a characterization of overall safety performance; transmit
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the results to the licensee; and initiate appropriate actions.
1 0516-04 EVALUATION CRITERIA AND FUNCTIONAL AREAS i
041 Evaluation. Licensees will be evaluated in the functional areas listed in this section using the criteria provided herein and further amplified in the l
. Appendix to this Chapter.
Each' functional area evaluated will be assigned a Category as defined in Section 042.
Not all functional areas need be covered.
in a given review.
If a functional area appropriate to a licensee is not covered, the reasons should be given in the report.
The Appendix to this l
Ch.>ter lists a number of attributes for each evaluation criterion. The func-l tional area being evaluated may have some attributes that would place the i
evaluation in Category 1 and others that would place it in either Category 2 or 3.
The final rating for each functional area will be a composite of the
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attributes tempered with judgment as to significance of individual items.
Departures from this guidance may sometimes be warranted.
In such cases, l
the rationale for such departures should be explained in the report.
042 Performance Categories, a.
Category 1.
Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to opera-tional safety or construction is being achieved.
b.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and l
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NRC-0516-043 are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
Catedory 3.
Both NRC and licensee attention should be increased.
c.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
043 Functional Areas.
a.
Operating Reactors (1) Plant operations (2) Radiological controls (a) radiation protection (b) radioactive waste management (c) transportation (d) effluent control and monitoring (3) Maintenance (4) Surveillance - includes inservice and preoperational testing (5) Fire prctection (6) Emergency preparedness q;
(7) Security and Safeguards j
(8) Refueling - includes initial fuel loading g
(9) Licensing activities (10) Others (as needed)
Li b.
Construction Phase Reactors (1) Soils and foundation l
(2) Containment and other safety related structures
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(3) Piping systems and supports - includes welding, NDE and j
preservice inspection
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SYSTEMATIC ASSESSMENT OF NRC-0516-044 LICENSEE PERFORMANCE (SALP)
(4) Safety related components - includes vessel, internals, pumps
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(5) Support systems - includes HVAC, radwaste, fire protection (6) Electrical power supply and distribution 1
(7) Instrumentation and control systems 7
(8) ' Licensing activities (9) Others (as needed) c.
Preoperational Reactors.
For reactors in the preoperational phase, functional areas from the listing for either Operating Reactors or Reactors under Construction should be selected as appropriate for evaluation.
i 044 Evaluation Criteria.
a.
The evaluation criteria are as follows:
(1) Management involvement in assuring quality (2) Approach to resolution of technicalissues from safety standpoint (3) Responsiveness to NRC initiatives (4) Enforcement history (5) Reporting and analysis of reportable events (6) Staffing (including management)
(7) Training effectiveness and qualification I
b.
Guidance for using these criteria to arrive at a category assignment is found in the Appendix to this Chapter.
1 0516-05 BASIC REQUIREMENTS 051 Applicability.
This Chapter applies to and shall be followed by NRC Headquarters Offices and Regional Offices.
1 052 Appendix 0516.
Procedures for implementation of these directives l
are presented in the Appendix to this Chapter.
053 Reports. The SALP Board report will be transmitted to the licensee by the SALP Board Chairman, who should normally be at the Branch Chief level or above. Following receipt and resolution of licensee comments, if any, the Regional Administrator issues the SALP report to the licensee, provides the characterization of overall safety performance and identifies further actions, as appropriate.
Approved: March 23,1982 I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 CONTENTS Pag PART I GENERAL 1
PART II EVALUATION CRITERIA 3
SALP BOARD ASSESSMENT 11 PART III PART IV MEETING WITH LICENSEE 13 ISSUANCE OF REPORf 15 PART V FORMAT FOR SALP BOARD REPORT.
17 PART VI TABLES PAS
- TA8LE 1 Evaluation Criteria with Attributes for 5
Assessment of Licensee Performance i
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Approved: March 23, 1982
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516
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PART I GENERAL A.
Overall guidance for the Systematic Assessment of Licensee Performance (SALP) is provided in Chapter NRC-0516.
Procedures for SALP are provided in this Appendix.'
B.
The NRC will conduct an annual review and evaluation of the performance of each power reactor licensee possessing an operating license or construc-tion permit. The individual facility assessments are intended to take place at an approximately unifonn rate throughout the year. The evaluation process is comprised of three parts:
(1) a SALP Board assessment; (2) a meeting with licensee management to discuss the assessment; and (3) issuance of the report.
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LICENSEE PERFORMANCE NRC Appendix 0516 PART II EVALUATION CRITERIA The assessment of licensee perfonnance is implemented through the use of seven evaluation criteria. The criteria which provide standard guidance, are applied to each functional area for the categorization of licensee performance.
l To provide a consistent evaluation of licensee performance, several attributes associated with each criterion are listed to describe the characteristics appli-cable to the three categories.
The seven criteria discussed in Chapter NRC-0516-04 are listed in Table I with their associated attributes. These form the guidance which aids in understanding and evaluating licensee performance by identifying the causes and factors appropriate for categorization. It is not intended that considera-tion of these attributes influence established programs of the agency. For example, it is not intended that specific inspections be performed to evaluate attributes. It is expected that during the implementation of established programs many of the attributes which describe performance will be observed.
l Cognizance of these attributes should assist the staff in their observation of licensee performance during routine activities.
All of the attributes of the evaluation criteria are not necessarily applicable.
In some instances, the observed performance within a functional area may be f
insufficient to allow consideration in the evaluation. Conversely, additional attributes may be appropriate for the evaluation. Matters such as Quality Assurance, Design Control, Training and the like, are attributes of each j
functional area and should be considered in the evaluation of the functional areas. On the other hand, if there is a problem with one of these attributes j
that is observed in several functional areas, it may be desirable to highlight that attribute in a separate discussion; e.g., Quality Assurance may be a I
problem in Operations, Radiological Control and Surveillance. It would be
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appropriate to discuss Quality Assurance as if it were a functional area, in j
addition to covering the specific QA problem in each functional area.
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The listed attributes are intended only as guidance in the assessment of performance in the functional areas and thus, are indicators of the licensee j
performance.
It is emphasized that all available information should be analyzed by the SALP Board, and its significance, whether it be positive or negative, should be 4
weighed. If information is scarce or nonexistent, a decision as to performance as it relates to an attribute should not be forced.
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MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY gg
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Category 1 Category 2 Category 3 en consistent evidence of prior plan-evidence of prior planning little evidence of prior planning ning and assignment of priorities; and assignment of priorities; and assignment of priorities;
$g" well stated, controlled and explicit stated, defined procedures poorly stated or ill understood aM procedures for control of activities for control of activities procedures for control of activities M%
well stated, disseminated and under-adequately stated and under-poorly stated, poorly understood k
k standable policies stood policies or non-existent policies decision making consistently at a decision making usually at a decision making seldom at a level level that ensures adequate level that ensures adequate that ensures adequate management management review management review review m
corporate management frequently corporate management usually corporate management seldom involved in site activities involved in site activities involved in site activities audits complete, timely and thorough audits generally complete, audits frequently not timely, i
and thorough incomplete or not thorough E
committees properly staffed and committees usually properly committees not properly staffed 3~
functioning in almost all cases staffed and functioning or functioning z
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reviews timely, thorough and reviews generally timely, reviews not timely, thorough or h
technically sound thorough and technically sound technically sound 9
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records complete, well maintained records generally complete, well records not complete, not well 3
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corrective action systems promptly corrective action systems corrective action syster s rarely y
y and consistently recognize and generally recognize and recognize and address non-o address non-reportable concerns address non-reportable concerns reportable concerns o
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.9 procurement well controlled and procurement generally well repetitive breakdown in procure-E y
documented controlled and documented ment control Q
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design well controlled and verified rare breakdowns of minor repetitive breakdown in designs a
significance in design control control or verification
2.
APPROACli TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT r
Category 1 Category 2 Category 3 clear understanding of issues understanding of issues understanding of i:: sues demonstrated generally apparent frequently lacking conservatism routinely exhibited conservatism generally exhibited meets minimum requirements I
when potential for safety significance exists technically sound and thorough viable and generally sound and often viable approaches, but approaches in almost all cases thorough approaches lacking in thoroughness or depth cnH timely resolutions in almost all generally timely resolutions resolutions often delayed g3 f-t~ M cases m>
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RESPONSIVENESS TO NRC INITIATIVES CQ n en Category 1 Category 2 Category 3 Ed meets deadlines generally timely responses frequently requires extensions M g of time yg W
timely resolution of issues few longstanding regulatory longstanding regulatory issues g$
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issues attributable to licensee attributable to licensee pg i
K en technically sound and thorough viable and generally sound and often viable responses, but gg lacking in thoroughness or om responses in almost all cases thorough responses depth M%
acceptable resolutions prcposed acceptable resolutions generally considerable NRC effort or Q
initially in most cases proposed repeated submittals needed to obtain acceptable resolutions 9
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ENFORCEMENT HISTORY j
Category 1 Category 2 Category 3 major violations are rare and are major violations are rare and may multiple major violations or l
not indicative of programmatic indicate minor programmatic programmatic breakdown breakdown breakdown indicated
'Oo minor violations are not repetitive multiple minor violations or minor violaticas are repetitive 3
and not indicative of programmatic minor programunatic breakdown and indicative of programmatic I
breakdown indicated breakdown 2:
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REPORTING AND A ALYSIS OF REPORTABLE EVENTS y
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events are properly identified events are accurately identified, events are poorly identified or, l
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. corrective action is usually corrective action is not timely 1
as indicated by lack of repetition taken but unay not be effective nor effective, events are as indicated by occasional repetitive repetition
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STAFFING (INCLUDING MANAGEMENT) y Category 1 Category 2 Category 3 j
positions are identified, authorities key positions are identified, positions are poorly identified, and responsibilities are well defined and authorities and responsi-or authorities and responsibil-bHities are defined ities are ill-defined to
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staffing is aanple as indicated by staffing is adequate, staffing is weak or minimal as y
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TRAINING AND QUALIFICATION EFFECTIVENESS C$..
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makes a positive contribution, program contributes to an program is found to be the mg
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j and staffing, to understanding work and fair adherence poor understanding of work, of work and adherence to procedures to procedures with a anodest as indicated by numerous proce-p, y
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resources and a means for feed of the staff applied for a significant segment h
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 I
PART III SALP BOARD ASSESSMENT The SALP Board Assessment should include the following activities:
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1.
Obtain assessment data applicable to the appraisal period, a.
Notify NRR, AEOD, and NMSS of the assessment period and the date when inputs from those offices are needed. The notification should be at least 30 days before the inputs are needed.
b.
NRR will provide written input.
c.
Normally, NMSS will respond to the notification by telephoning the regional security experts and, if appropriate based on licensing activities during the appraisal period, providing input to the draft functional area analysis.
d.
AZOD will respond and will provide input, if appropriate based on AEOD activities relative to the appraisal period.
e.
Inputs will be directed into the functional areas as defined in Chapter NRC-0516.
2.
Tabulate and analyze the data obtained for the facility.
a.
Prepare the enforcement and inspection summary data - numbers and types of inspections performed and enforcement findings for each functional area.
b.
Provide the number of LERs submitted under each of the licensee's cause categories. This information will be included in the SALP Board report. If the review indicates that the proximate cause classification of significant LERs persistently varies from that reported by the licensee that issue should be discussed under the appropriate functional area of the performance evaluation. LERs.
should be discussed under the appropriate functional area.
c.
Provide the number of Construction Deficiency Reports (CDR) and 10 CFR Part 21 reports submitted by the licensee, These reports should be discussed in the appropriate functional area.
d.
Any events which have been determined to be "Abnonnal Occurrences" should be identified.
e.
The number and nature of unplanned trips.
3.
Develop the performance analysis for each of the functional areas. It is
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expected that the performance analysis would be drafted (in a pre-
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11minary form) by a knowledgeable member of the NRC staff prior to the 11 Approved: March 23,1982
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NRC Appendix 0516 SYSTEMATIC ASSESSMENT OF
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Part III LICENSEE PERFORMANCE SALP Board meeting. The analys!s shall include a characterization (Cate-T gory-1, 2, or 3) and its basis, as well as SALP Board recommendations for NRC action, if necessary. The criteria for these categorizations are
'J discussed in Part II of this Appendix. For some functional areas there may be insufficient licensee activity or NRC observation to warrant char-acterization.
This would be appropriate for functional areas for which licensee action or involvement was not necessary during the appraisal period.
4.
Conduct the SALP Board meeting to review the performance analysis and supporting data, develop the report including determination of each func-tional area's performance and recommendations for NRC action. This meet-ing should be attended by senior regional management, the NRR Project Manager, resident inspectors, and other individuals as determined by the Regional Administrator. As part of the SALP Board meeting it may be appropriate to make recommendations for reallocation of NRC resources.
Also note that even in the absence of recommended changes to inspection frequencies, the Regional Office may adjust the frequencies based on SALP evaluations as discussed in the inspection procedures. In some areas the inspection program may mandate a change in scope, depth or frequency.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 i
PART IV MEETING WITH LICENSEE 4
The licensee management meeting should be planned and conducted considering the following:
1.
Notification of the meeting should be made at least two weeks in advance.
Notification should be made to the licensee, the resident inspectors at the involved facilities, the NRR Project Managers for the involved facil-ities and cognizant NRC ranagers.
t 2.
The licensee should be encouraged to have the following management representatives participate in the meeting:
a.
Senior corporate management representative, b.
Management officials responsible for the major functions wherein preblem areas have been identified (e.g., health physics, security, engineering).
c.
Site Manager.
3.
The Board Chairman will transmit the Board's report to the licensee one week before the meeting. The transmittal letter will identify weak areas
(
and request. licensee response in these areas, as appropriate, within 20 days after the meeting. The licensee will also be given the oppor-tunity to make comments on the report during the discussions at the meeting or in writing within 20 days after the meeting.
4.
NRC representatives for this meeting should include the following:
I Either the Regional Administrator, Deputy Administrator, or Divi-a.
sion Director b.
Responsible Regional Division Director (s),
Branch
- Chiefs, or E-ction Chiefs, as appropriate i:
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NRR Project Manager or designated NRR manager.
c.
d.
Resident Inspector and/or assigned inspectors For meetings with minimal issues, the Regional Administrator may elect to
.;l' involve fewer staff members in the licensee management meeting.
4 5.
The Regional Administrator, Deputy Administrator, or Division Director 1
will chair the meeting and discussions of the adequacy of the licensee's management controls. These meetings are intended to provide a forum for candid discussion on issues relating to the licensee's performance.
.j Those aspects of the licensee's operation that need improvement will be identified.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 PART V ISSUANCE OF REPORT After the meeting and after considering the licensee's oral and written com-ments, the report wdl be transmitted by letter to the licensee over the Regional Ariministrator's signature.
The letter should acknowledge the licensee's comments and amplify as appropriate on these comments or other findings of the review board. Additionally, the letter will include a characteri-zation of overall safety performance. This letter, enclosing the report and licensee comments, will receive standard distribution including PDRs.
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LICENSEE PERFORMANCE NRC Appendix 0516 PART VI FORMAT FOR SALP BOARD REPORT Report Cover Sheet (Report Number)
U.S. NUCLEAR REGULATORY COMMISSION REGION Systematic Assessment of Licensee Performance (Name of Licensee)
(Name of Facility)
(Date)
Report Body I.
INTRODUCTION Provide an introductory statement.
II.
SUMMAP.Y OF RESULTS Provide a tabulation of functional area assessments.
III. CRITERIA Describe the evaluation criteria used.
IV. PERFORMANCE ANALYSES Functional Area Analysis For each functional area considered, provide a brief narrative of signifi-l cant strengths and weaknesses; summary of major problems; significant events (LERs or CDRs); enforcement issues; and summary of NRC and i:
licensee actions. Include a brief summary of the previous year's evalua-tion if there has been a significant change or if there should have been significant improvement but there was not.
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SYSTEMATIC ASSESSMENT OF NRC Appendix 0516 Part VI LICENSEE PERFORMANCE 6.
Management Conferences Held During Appraisal Period. Discuss conferences that dealt with regulatory performance or enforcement.
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7.
Other. Nar.rative of any significant strengths, weaknesses, or issues at the discretion of the SALP Board.
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NUCLEAR REGULATORY COMMISSION 6
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- !EMORANDUM FOR:
Roger Mattson, Director, Division of systems Integration Richard Vollmer Director, Division of Engineering Edward Jorden, Director, Division of Emergency Preparedness and Engineering Support,
- 'HRU Thomas M. Novak, Assistant Director
.for Licensing Division of Licensing Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing
- R0Hr Melanie A. Miller, Project Manager
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Licensing Branch No. 4 Division of Licensing
- 50BJECT:
EVALUATION FOR SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) - CONSUMERS POWER COMP MIDLAND NUCLEAR PLANT, UNITS 1 AND 2 Enclosed is a draft of the NRR input for the SALP fo onsumers Power Company, Midland '
- fucicer Plant.
This draft report is based,upon i solicited from selected staff nrscnnel who have had contact and involvement h consumers Power Company's licens-Ing material.
Please review the draft eve on and provide any comments you feel
- sppropriate.
All comments received by M 6,1983, will be considered in the final
- r port.
In order to meet this deadline, o comments directed to the project mana' er g
o iX24259, would be adequatsw Yo assist you with review and comment, the following
.p3rs3ns were contacted for input:
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Randy Eberly CHES Bill LeFaye A38 Darl Hood LR H Joe Kane SGEB Hulbert Li IC58 Ron Hernan LB M j
Ray Gonzales EHE5
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1 Frank Rinaldt SEB DEPE5~
M:rk Hertzman MES
- Arnold Lee EQB Dave Rohrer EPLB Hal Walker EQB _,
John G11 ray QAB J ff Kimball Gss Kaz Campe SAB Melante A. Miller, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosure:
2 1.
Evaluation Matrix
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Input for SALP Report i
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1 FACILITY NAME:
Midland Nuclear Plant. Units 1 and 2 LICENSEE:
Consumers Power Company NRR PROJECT MANGER:
Darl 5. Hood I.
INTRODUCTION This report presents the results, of an evaluation of the applicant Can' umers s
Power Compag. in the functional area of licensing activities.
It is intended to provide NRR's input to the SALP review process as described in NRC Manual Chapter 0516... The review covers the period July 1,1981 to March 31, 1983.
A ' distinction of activities between Units 1 and 2 was not considered feasible or approprf ate.
The basic approach used for this evaluation was to first select a number of licensing issues which involved a significant amount of staff manpower.
Comments were then so11 cited from this staff.
The staff applied the evalu-
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ation criteria for the performance attributes based on their experience with the applicant or his products.
Finally, this information was assembled in a matrix wh4ch allowed an overall evaluation of the app 11-l cant's perforssance.
II.
Sur: mary of Results NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category based on a composite of a number of attributes.
The single final rating should be tempered with judgement with respect to the significance of the individual elements.
Based on this approach, the performancIe of Consumers Pouer Compay to the functional area - Licensing Activities - is rated category 2.
III.
_ Criteria Evaluation criteria, as given in 75tC Manual Chapter Appendt,x 0516 Table 1, were used for this evaluation.
IV.
Performanc# Analysis The applicant's. performance evaluation is based on a consideration of seven.
attributes as given in the NRC Manual Chapter.
For the licensing actions e
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- Implommandtfon of NUREC-0737 Items volvement in Asmur7 gei Q The-evoca11 r=ti-- Of thie e-*te-fe= 4! Cetanary 2 with 2 acetwittas raeai?i g idivihel --t?:;;: ef fet-ae-y LTFor the licensing activi-ties evaluated, there appeared to be appropriate management attention with decision making taking place at adequate levels.
During numerous audits conducted by NRR, including audits rel.ating to the so11s issue, emergency planning, instrumentation and control systems, fire protection and equipment goalification, the records maintained by the licensee were l
generally complete, well maintained and available.
In almost every area,
(
?.he appropriate level of management participated in meetings with the NRC ou safety, technical, and licensing issues and demonstrated knowledge on the meeting's sub. ject matter.
In the soils and structures area,however, management involvement was less than desirable since some of the. inform motion giveis to the letC at meetings,was later determined to be inaccurate or misleading.
Also, an exception to adequate management control occurred i
when the licensee proceeded with as ' escavation prior to fulfilling 15tC conditions previously established.
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.m, Clear lines of responsibility were established in support of the staff's safety evaluation and subsequent issuance of the Safety Evalyation Report.
Priorities established ty licensee management were generally consistent with and supportive of those priorities established ty the staff.
Com-afbments made to incorporate resolutions into FSAR revisions were kept and were generally timely.
The licensee also made an objective.aed extensive effort to track open issues related to the safety evaluation.
One issue which involved implementation of a TM1 Action plan item (Item 1.B.1.2) reached an apparent impasse between the staff and applicant.
i However, when the proper level of management attention was focused on -
the issue, both sides were able to reach an acceptable resolution.
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>hrn 2. :
stions were knowledgea)1e and clearly understood the issues.
Ouring the appraisal period, the licensee was usually complete and con-servative in technical sGbeittels to the NRC.
Resolution of two tech-nical issues during the safety evaluation required elevation' to the Division Director appeals level.
In one of these issues, relief was given to the licensee.
In the other, the licensee was required to com-mit to installation of a third auxiliary feedwater pump.
In both cases.
however, the licensee prepared reasonable technical justification for their position.
In addition, the 11,consee's response once the appeals decision on the auxiliary feedwater pump had been made was excellent.
Licensing activities for which this crf terion was rated a Category 1
. include the area of seismic equipment qualifications, where a clear understanding of equipment qualificati' n requirements against design o
basis & seismic margin earthquakes was demonstrated.
The licensing 4
area of soils and structures needs improvement insofar as the app ee;h to technical issues.
In the absence of HRC requirements, there was reluctance by the licensee to perform certain soils remedial work s
utilizing accepted quality assurance procedures.
In regards to the buried piping f asue. Consumers appeared to lack a thorough understand-ing of the safety issues involved.
Improvement in the soils area over the appraisal period has been evidenced by more specific and, clearer submittals to the letC.
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Responsiveness to NRC Initiatives The overall rating for this area is Category 2 with the performance rating for individual licensing action failing in all 3 categories.
The In general, responses to the 1stC were timely and thorough.
itcensee was particularly responsive in the areas of equipment qual ifications and instrumentation and control stees.
Additionally.
in questions concerning the natural gas pi ine. the licensee demon-strated a willingness to effectively address NRC concerns and respon-siveness increased accordingly.
Responsivene was rated poorly for licensing issues which remained unresolved fo ong period of tim /e such as resolution of the-buried piping probi D.
Enforcement History There is no important basis for an NitR evalaution of titis attribute.
E. 3 Reportable Events There is no important basis for a NRR evaluation-of this attribute,at this time.
F.
Staffing Overall rating of this, criterion is Category 2.
Positions appear to be well-defined and responsibilities identified.
Staffing is adequate and at levels consistent with the activity for the licensing activities evaluated.
The licensee effected reorfanizations and personnel replace-ments within a reasonable time insofar as key positions.
In some cases.
however, the staff considers that too much reliance was placed upon s '
representation by consultants and by the architect / engineer.
I S.
Training There is no important basis for an letR evaluation of this attribute at this time.
Y.
CONCLUS10N Based on the evaluation of Consumers' Power Compa6y's performance for a numb of activities in the functional area pf licensing, an opra11prformance rating of Category 2 d-Mgg g,
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Sutunittals were usually timely and thorough.
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II.
CRITERIA The licensee performance is assessed in selected functional areas depending upon whether the facility is in a construction, pre-operational Each functional area normally represents areas and are normal or operating phase.
significant to nuclear safety and the environment,Some functional areas may no programmatic areas.of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
Management involvement in assuring quality 1.
Approach to resolution of technical issues from safety standpoint 2.
3.
Responsiveness to NRC initiatives 4.
Enforcement history Reporting and analysis of reportable events 5.
6.
Staffing (including management)
Training effectiveness and qualification 7.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
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each functional area evaluated Based upon the SALP Board assessment, The definition is classified into one of three performance categories.
of these performance categories is:
Licensee man-l Reduced NRC attention may be appropriate.
agement attention and involvement are aggressive and o Category 1:
i that a high level of performance with respect to operational safety or construction is being achieved.
Li-NRC attention should be maintained at normal levels.
censee management attention and involvement are evident and are concerned Category 2:
with nuclear safety; licensee resources are adequate and are reasonably effecti*ve such that satisfactory performance with respect to operational l
safety or construction is being achieved.
Li-Both NRC and licensee attention should be increased.
Category 3:
censee management attention or involvement is acceptable and considers licensee resources appear to-nuclear safety, but weaknesses are evident; be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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N III.
SUMMARY
OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Soils and Foundations X
2.
Containment and other Safety Related Structures NOT ADDRESSED IN THIS REPORT
- 3.
Piping Systems and Supports X
4.
Safety Related Components X
5.
Support Systems X
6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT
- 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT
- 8.
Licensing Activities X
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9.
Quality Assurance NOT ADDRESSED IN THIS REPORT
- J' 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT
- I
- For Functional Areas "Not Addressed In This Report" see Section I, Introduction.
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N IV.
Performance Analyses 1.
Soils and Foundations a.
Analysis During this SALP period the licensee finalized the Remedial Soils program and initiated steps to implement the Remedial Foils measures necessary to correct previously identified
- soils deficiencies.
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- .;a uscs ~uut ing--t,he SALP-peri e
Ia dedcIlching:
b The excavation of the access shafts to elevation 609 The installation of six temporary underpinning piers Preparatory work for the Service Water Pump Structure underpinning Initiation of temporary dewatering system for the Service Water Pump Structure Initiation of probing for buried utilities adjacent to the Service h ter Pump Structure The installation of the permanent dewatering system wells The installation of the auxiliary building underpinning v
instrumentation system Thirteen inspections (or nortions of insnactinnd " era pfr-Armeg in tnis area. During this SALP period a total of nine i
noncompliances aud Eso deviations with NRC requirements were identified as follows:
(
\\ t (1) Severity Level IV - examples of failure to follow pro-cedures and failure to develop adequate procedures j
(329/82-03; 330/82-03)
(a) Failure to revise design drawings according to site procedural requirements
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(b) Failure to develop an adequay excavation procedure _
(c) Failure to assure design verification according to site procedural requirements i
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i (2) Severity Level IV ' examples of failure to develop adequate procedures (329/82-05; 330/82-05)
(a)
Access shaft work was initiated without having a reviewed and approved procedure j
(b) Failure to develop adequate procedures to control specification design changes (c) Failure to develop adequate specification for permanent dewatering wells (d) Failure to develop an adequate procedure to prepare or implement overinspection plans (3) Deviation - failure to provide a qualified civil QA staff
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(329/82-05; 330/82-05)
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(4) Severity Level IV - failure to establish a QA program l
which provided controls over the underpinning monitoring l 7
system (329/82-06; 330/82-06).
This finding resulted i the issuance of a Confirmatory Action Letter (CAL) on March 31, 1982
/ (5) Severity Level V - failure to install anchor bolts in accordance with site procedures (329/82-11; 330/82-11)
(6) Deviation - failure to use approved installation /coord-ination forms to document the installation of underpinning monitoring instrumentation (329/82-11; 330/82-11)
) (7) Severity Level IV - failure of specifications to identify
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the location of well sampling points (329/82-18; 330/82-18)
(8) Severity Level IV - failure to assure that the slope layback at the Auxiliary Building access shaft was con-structed in accordance with design (329/82-18; 330/82-18) 1(9) Severity Level IV - examples of failure to establish measures i
to control the issuance of documents (329/82-21; 330/82-21)
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(a) failure to use a controlled copy of a Project Quality Control Instruction (PQCI) to prepare a QC recerti-fication examination.
This finding resulted in the issuance of a CAL on September 24, 1982 (b) Failure to control QC manuals
! h i (10) Severity Level III - failure to translate applicable p
regulatory requirements concerning the purchase of armor stone for a "Q" portion of the perimeter dike into approp-U - h{h riate specifications and design documents (329/82-22; 330/82-22)
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,d I (11) Severity Level III - failure to maintain current remedial
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soils drawings (329/83-03; 330/83-03)
The noncompliances identified during this rating period "Tre evidence of the licensee 's continued los-of--at-ten-Tion to detail in assuring that_the re_quirements~ of the -
nldland QA program were properly implemented.
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'es, chese noncompliances indicate the lack of manage ~
ment attention to quality in this area.
E4 p
As a result of noncompliance item (4) an investigation r
was performed by NRC to determine whether material false statements had been made by the licensee's staff in regard to the installation status of the auxiliary building under-pinning monitoring instrumentation.
The investigation failed to provide conclusive evidence that a material false statement had been made.
An investigation by NRC was initiated during this evaluation period to determine whether tha licensee vio17ted the" April 30 'Tiik?, Ata-ic Safety and Licensing Bu.id (A5LB) urder which suspended all remedial soils g
activities on "Q" soils for which the licensee did not
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have prior explicit NRC approval. This investigation, w
q, which is continuing, focuses on the licen_see digging below F
T.ne decy Q ductTaik" allerediv without NRC approval--
A management meeting was held at the site on Augusc 44, 1982, to discuss the potential violation of the Board Order.
A CAL was issued on this matter on August 17 1982.
Noncompliance items (10) and (11) are individual examples related to the soils area taken from much broader items of noncompliance not associated with this functional area.
(Items 10 and 11 were part of two separate citations for failure to adequately implement a quality assurance program.)
l The two individual examples taken by themselves would not ave been rated as severity level III.
In view of continuine deficiencies in the soils area, the
_ASLB issued an Order on April 30, 1982, suspendine =11 remedial soile activities on safety-related (Q) soils Jor which tha litansee did nnt have prior NRC approval.
Subsequent to this order the licensee resumed remedial p ;;tisitie. -4LL iGC appivv l.
Duria ^- hilow-Ing muuuu. uumcsvus proolems occurred cue to mAswennun-cL %au/misauderstz.salus Lci mmu thu liuou.cc and-the NRh.
TE :::alim these issues a Work Autirurization Procedure was developed.
Inis nroceaure requites the Iicensee to request and obtain written NRL autnorization
-prior-to the initiation of each remedi.1.cri-Is work y
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activity. c e Work Excavation Permit System was expanded to include aWremedi.1 wi-1s-woTR including underpinning.
Due~to thrNRCTroncerns
- wi Un die licemreeT aoirfty to properly _ implement _the y
enality pregrar in the-remedial soils area an iEdependent third party VveYVIIew Tia's7stablished.
All the preceatng actions. occurrea at the direcEiin of tfEee NRT:, and7 Tere' ~
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not a resu4t of the licensee's iniH ative.
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b.
Conclusions
(
I"~The licensee is' rated Category 3'in this area.
Although this is the same rating as the previous assessment period, the licensee's overall performance in this functional area has i
i
_ continued to decline. NRC findings during this assessment period indicate a continued lack of attention to detail by the licensee and the continuing inability on the part of the li-censee to implement properly the requirements of the Midland 3
QA program. A rating of less than minimally acceptable (Not Rated)-was considered by the Board; however, a Category 3 rating was assigned because of the stringent controls insti-tuted to govern work in this area, i.e., the Work Authorization Procedure, the Work Excavation Permit System, the independent third party overview, and continued scrutiny by the NRC staff.
c.
Board Recommendations i
The Board recommends that the liceamaa tharanahly review the j
_$erformance of co_ntituction engineering, and Onnlity Assdrance
~~'
' managers in the Remedial Soils area. The implementation of
' measures to provice closer attention to detail in remedial
~
soils work activities anduto provide assurance that future l
remedial soils work will conform to the requirements of the Midland QA program should be a continuing management goal.
2 Based na infarention provided to cha Roard subseouent to the l
INGUI3tIion period. the Board notes that the licensee has con-tinued to have performance proble== in this area.
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3&4. Safety-Related Components and Piping Systems and Supports j
1 a.
Analysis l
N j
Portions of ten inspections were performed in the Nuclear Steam i
Supply System area during the evaluation period.
The inspec-
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tions involved the observation of large and small bore hanger
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installations (including snubbers and restraints), receipt and installation records', modification of the reactor pressure vessel supports, auxiliary feedwater internal header modifica-tion, and containment structural steel welding.
Within the j-scope of this effort one item of noncompliance was identified l
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\\f S verity Level V - Fa_ilura ' en fallaw. promMes_regarding A
A tire tagging of a_vallelo_cated in-the.. welding. f ahrigation~
area (329/83-01; 330/83-01).
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The licensee's resources appear to be adequate. The management controls being utilized, the records, and the records control system met requirements. The overall' effectiveness and attitudes of licensee personnel in complying with requirements were con-sidered acceptable.
b.
Conclusion The licensee is rated Category 2 in this area.
This is the same rating as the previous assessment period.
c.
Board Recommendations The Board notes that subsequent to this evaluation period the NRC has indications that quality problems exist with installed components, piping, and piping supports.
These indicators include the Independent Design and Construction Verification Program (TERA's Monthly Status Report dated May 27, 1983) and the licensee audit conducted February 23, 1983 through March 10, 1983 (including the R. Sember memo to D. Miller dated March 13, 1983).
NRC inspection activities should focus on essuring that in-stalled items meet the design and regulatory requirements.
5.
Support Systems a.
Analysis
--9 i
Portions of four inspections were performed covering Heating, Ventilation, and Air Conditioning (HVAC) welder certifications, welder procedure qualification, and material traceability.
No items of noncompliance or deviations were identified during j
these inspections.
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t As a result of a licensee audit of Photon Testing, Inc., the l
(11censeesuspendedweldingofsafety-relatedHVACworE.
rnoton Testing, Inc. had previously been contracted by the licensee to qualify welding proceduras and certify velders for HVAC fabrication and installation.
The cumulative audit findings made the credibility of some of Yhe certificat1onE'
'of ps=viousXy certified weldern. mm well as the adeaumev'of or tne weiuxng procedures, indeterminate. Due to the auait tinalngs, Sne NRC imposed a hold point for the restart of safety-related HVAC velding.
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I An initial attempt by the licensee to demonstrate to the NRC l
l that affected HVAC welding procedures had been qualified and
.were ready for implementation demonstrated that the welding procedures were still inadequate.
As a result, the NRC did not authorize the licensee to restart safety-related HVAC welding.
I No other problems in the HVAC area were identified.
b.
Conclusion 1
The licensee is rated Category 2 in this area.
This is a lower rating than the previous assessment due to the licensee's failure to initially take adequate corrective action to resolve the deficiencies identified in the Photon Testing, Inc. audit and the licensee managements failure to identify the inadequate i
initial corrective action.
c.
Board Recommendations Licensee management involvement should be increased in the area
.of ensuring proper and timely followup to correcting identified deficiencies.
The board notes that subsequent to this evalua-tion period the licensee successfully demonstrated the adequacy 4
of welding procedures and welders to perform to those procedures.
l I
Based on the demonstration, the NRC authorized the resumption of HVAC welding.
- 8.. Licensing Activities a.
Analysis The assessment was based on our evaluation of the following licensing activities:
Soils and Structures Emergency Planning Equipment Qualification Quality Assurance Program Natural Gas Pipeline Auxiliary Feedwater System Instrumentation and Control Systems Review Seismic Spectra Fire Protection Implementation of NUREG-0737 Items
?
For the licensing activities evaluated, there appeared to be appropriate management attention with decision making taking place at adequate levels. During numerous audits conducted by NRR, including audits relating to the soils issue, emergency planning, instrumentation and control systems, fire protection and equipment qualification, the records maintained by the licensee were generally complete, 10 o
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well maintained and available.
In almost every area, the I
appropriate level of management participated in meetings with the NRC on safety, technical, and licensing issues and j
demonstrated knowledge on the meeting's subject matter.
In the soils remedial areas, a reorganization provided an execu-tive manager fully dedicated to this area; however, some diffi-culties occurred in the early phases of this reorganization.
Clear lines of responsibility were established in support of the staff's safety evaluation and subsequent issuance of the Safety Evaluation Report.
Priorities established by the li-censee management were generally consistent with and supportive of those priorities established by the staff.
Commitments made to incorporate resolutions into FSAR revisions were kept and were generally timely.
The licensee also made an objective and extensive effort to track open issues related to the safety evaluation. One issue which involved implementation of a TMI Action Plan Item (Item I.B.I.2) reached an apparent impasse between the. staff and applicant.
However, when the proper level of NRC and licensee management attention was focused on the issue, both sides were able to reach an acceptable resolution. On the other hand, licensee's management failed to recognize the safety significance of constructing a high pres-sure gas facility in close proximity to safety structures until after construction completion.
Generally, licensee personnel involved in resolution of technical questions were knowledgeable and clearly understood the issues. During the appraisal period, the technical sub-mittals by the licensee to the NRC were usually complete and conservative. Resolution of two technical issues during the safety evaluation required elevation to the Division Director appeals level.
In one of these issues, relief was given to the licensee.
In the other, the licensee was required to commit to installation of a third auxiliary feedwater pump.
In both cases, however, the licensee prepared reasonable technical justification for their position.
In addition, the licensee's response once the appeals decision on the auxiliary feedwater pump had been made was excellent.
The licensing area of soils and structures needs improvement insofar as the approach to technical issues. There was reluctance by the licensee to perform certain soils remedial work utilizing accepted quality assurance procedures until required by the NRC.
In regard to the buried piping issue, the licensee appeared to lack a thorough understanding of the safety issues involved resulting in the submission of additional information several times before acceptable resolution was
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Improvement in the soils area over the appraisal period has been evidenced by more specific and clearer sub-mittals to the NRC.
Responses to the NRC were generally timely and thorough.
The licensee was particularly responsive in the area of instrumenta-tion and control systems.
Additionally, in questions concerning the natural gas pipeline, the licensee demonstrated a willing-ness to address NRC concerns effectively and responsiveness increased accordingly. Responsiveness was rated poorly for those licensing issues which remained unresolved for a long period of time such as resolution of the buried piping problem.
With respect to licensing staff, positions appear 'to be well defined and responsibilities identified.
Staff is adequate and at-levels consistent with the activity for the licensing activities evaluated. The licensee effected reorganizations and personnel replacements within a reasonable time insofar as key positions are concerned.
In some cases, however, the staff considers that too much reliance was placed upon repre-sentation by consultants and by the architect / engineer.
b.
Conclusion The licensee is rated Category 2 in this area.
Generally, in licensing activities, the licensee expressed a willingness to respond to NRC initiatives.
Submittals were usually timely and thorough. Especially notable is the degree of management attention directed toward licensing activities as evidenced by meeting participation and the level at which decisions occur. Areas of above average performance in all criteria include instrumentation and control systems reviews.
Conversely, although improvement in the soils area has been seen during this appraisal period, it is imperative for the licensee to continue to focus a high level of management attention in the soils area in order to maintain an acceptable level of performance insofar as licensing activities are concerned.
c.
Board Recommendations A high level of licensee management attention should be con-tinued in resolving the adequacy of responses to technical issues and improvement of management controls in the area of remedial soils and underpinning activities.
12
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t
1 V.
Supporting Data and Summaries A.
Noncompliance Data i
Facility Name:
Midland, Units 1 and 2 Docket Nos. 50-329 50-330 Inspections:
No. 81-14 through 83-05 Noncompliance and Deviation Severity Levels Functional Aret Assessment I
II III IV V
Dev 1.
Soils and Foundations 2
6 1
2 2.
Containment and Other Safety-Related Structures NOT ADDRESSED IN THIS REPORT 3.
Piping Systems and Supports 4.
Safety-Related Components 1
5.
Support Systems 6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT 8.
Licensing Activities 9.
Quality Assurance NOT ADDRESSED IN THIS REPORT 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT TOTALS 0
0 2
6 2
2
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1 B.
' Report Data 1.
Construction Deficiency Reports (CDR)
During this SALP period, 19 CDR's were submitted by the licensee under the requirements of 10 CFR 50.55(e),
a.
Operating procedures must be modified to require at least one reactor cavity cooling fan in service during normal plant operation.
b.
For certain control circuits, a voltage below the limits for proper operation of the motor control center starter coils was calculated.
This line voltage drop is a direct result of currents passing through long control cables.
The design of electrical components associated with the c.
main steam isolation valves does not conform to the channel separation criteria in Reg. Guide 1.75; also, satisfactory seismic qualification reports have not been submitted.
d.
Rodent damage has occurred in electrical penetration wiring l
and cables.
e.
The auxiliary feedwater level control valves are fed from Class IE instrument control power instead of Class IE p
preferred power supplies as specified in the FSAR.
f.
The existing design of the auxiliary feedwater system pump l-turbine driver steam admission valve interlock system would block steam entry and prevent proper operation.
j
- s g.
It has been. determined that instrument string error in the steam generator level circuits, under accident conditions, exceeds that allowed to establish steam generator ECCS i
control setpoints.
h.
Recent inspections at three operating B&W plants indicated j
damage to the internal auxiliary feedwater header assemb-lies. New external headers will provide all functional requirements.
1,,
i.
During an engineering review it was discovered that some Q-related equipment is located in the auxiliary building that is cooled by a non-safety grade HVAC system. During an accident, this could result in some Q-equipment being l
lost.
i j.
B&W supplied non-seismically qualified transmitter mount-ing brackets for transmitters forming part of the reactor coolant pressure boundary.
h 14
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Approximately 80% of.the radiation monitoring modules, manufactured by Victoreen, Inc.
were found to be noncon-forming. This was due to a significant QA breakdown at the supplier.
1.
During field modifications of 460V Class IE motor control centers supplied by ITE-Gould it was discovered that some of the control power transformers were undersized.
The incorrect size class lE power cables were pulled and m.
installed.
ACI 349, Appendix B, issued August 1979 specifies that n.
shear lugs in embedment designs shall be considered effec-tive only in compression zones.
Some Midland embedment designs, which were completed and installed prior to this date, do not meet this new criterion.
No specific features to mitigate frazil ice formation on o.
the service water intake structure are contained in the design of the service water intake structure.
p.
The design of the suction piping for the auxiliary feed-water system did not include overpressurization protection.
i q.
Unacceptable workmanship conditions have been identified oc electrical control panels and cabinets supplied by t
various suppliers.
Bailey Controls Company NI/RPS and ECCAS cabinets have r.
terminal blocks which are fastened to the termination panels by Tinnerman Nuts. These nuts could become loose.
s.
Class IE electrical control cabinets appear to have in-sufficient clearances from adjacent equipment or walls.
The licensee's threshold for reporting is considered to be appropriate and the total number of items reported is not con-sidered to be excessive.
2.
Part 21 Reports The licensee issued no Part 21 reports during the reporting period.
C.
Licensee Activities The main construction areas during the evaluation period were NSSS work, electrical equipment, conduits, cable trays, cables, HVAC, remedial soils work, small and large bore piping, pipe hangers and snubbers. As a result of the diesel generator building inspection, the licensee halted on December 3, 1982, safety-related work with the exception of the following:
system layup, hanger and cable reinspections, post system i
El 15
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2
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_=.:=..
W turnover work, HVAC work, NSSS work, remedial soils work, and design
. engineering.
Preoperational testing was conducted on the Component Cooling Water System, the Decay Heat Removal System and the Fuel Transfer i
System.
\\
Units 1 and 2 were reported by the licensee to be 79% complete per the licensee's letter.to Hatfield (NRC) dated May 6, 1983.
Fuel load dates are estimated by the licensee to be February 1985 and October 1984, respectively.
D.
Inspection Activities The routine inspection effort by the NRC consisted of 39 inspections during the evaluation period.
In addition, a special team inspection (329/82-22; 330/82-22) was conducted 4
to assess the' adequacy of implementation of the quality assurance program.
This assessment was done for the most part in the diesel generator build-4 ing where the majority of work was performed subsequent to 1980. This inspection resulted in the licensee suspending some safety-related work on December 3, 1982.
E.
Investinations and Allegations Review 1.
An investigation was conducted to determine whether material false statements had beeu made by the licensee's staff in regards to-the installation status of the auxiliary building monitoring instrumenta-tion. The investigation report (329/82-13; 330/82-13) failed to provide conclusive evidence that a material false statement had been
- made, t
2.
An investigation was being conducted during this SALP period to deter-mine whether the licensee violated the April 30, 1982, ASLB order 1
which suspended all remedial soils activities on "Q" soils for which i
the licensee did not have prior explicit NRC approval.
The report i
was not issued during this SALP period.
3.
A number of allegations were received during this SALP period regard-l ing HVAC work by Zack, welding, electrical work, and deficiencies in the Laplementation of the CPCo QA/QC program.
Investigations or j
special inspections to resolve some of the issues identified within these allegations were initiated during this SALP period.
1 F.
Escalated Enforcement Action r
1.
Civil Penalties A Civil Penalty for $120,000 was issued during this evaluatiou period in regard to the adverse findings identified during the diesel gener-ator building inspection (329/82-22; 330/82-22).
The licensee's request for mitigation of the amount is under review by the NRC staff.
i 16
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2.
Orders
- 1 The ASLB issued an order on April 30, 1982, which suspended all remedial soils activities on "Q" soils for which the licensee did l
not.have prior explicit NRC approval. The ASLB. issued a subsequent clarifying order on May 7, 1982.
G.
Administrative Actions 1.
Corrective Action Letters A letter of understanding was issued by the licensee on f
a.
March 31, 1982, in response to deficiencies observed during i
the inspection of the a_uxiliary_ building monitoring instru-me tation.
(329/82-06; 330/82-06).
This matter is also in Section V.E.1. of this report.
1scu A Confirmatory Action Letter (CAL) was issued on August 12, 7
b.
1982,.:4g response to a_ potential _ASLB order violation (329/82-18; 330/82-18). Inis matter is also discussed in i
Sections IV.I.a and V.E.2 of this report.
Resolution of these concerns was still under investigation at the end of the SALP period.
A CAL was issued on September 24, 1982, in response to c.
deficiencies observed during the inspection of remedial soils 1
QE Inspectors recertifications (329/82-21; 330/sz-zij.
v l
d.
A letter of understanding was issued on December 30, 1982, the diesel ip response to deficiencies observed durine This stnerator building inspection (329/82-22; 330/82-22)2 matter is also discussed in Sections V.C and V.F.1 of this report.
2.
Management Conferences
- 1. M l
During this SALP period eighteen conferences were held between NRC and licensee management:
24, 1981, a management meeting was held to discuss On July a.
inspection findings pertaining to irregularities in control l
and review of small bore piping system design packages.
l 12, 1982, a management meeting was held to review On January b.
and discuss recent changes to the Midland QA organization and the QA program for the remedial soils work.
c.
On March 30, 1982, a management meeting was held to discuss NRC findings in the installation of underpinning monitoring instrumentation.
d.
On April 26, 1982, a meeting was held to present to CPCo f
management the SALP 2 findings.
i 17 O'
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am mmmmer a meeting was held during which the licensee On May 14, 1982, presented a preliminary report of the results of the electrical e.
cable reinspections.
f.
On June 21, 1982, a meeting was held to discuss CPCo's response to SALP 2.
On August 5, 1982, a meeting was held to further discuss CPCo's g.
responses to SALP 2.
11, 1982, a management meeting was held to discuss On August h.
a potential violation of the ASLB order of April 30, 1982.
i.
On August 26, 1982, a management meeting was held to discuss Midland QA problems.
On September 2, 1982, a management meeting was held to discuss j.
the Quality. grovement Plan.
29, 1982, a management meeting was held to discuss On September k.
the integration of QC activities into Midland Project Quality Assurance Department (MPQAD).
On October 5,1982, a meccing was held to discuss the CPCo-TERA 1.
proposal concerning the Independent Design Verification Program (IDVP).
m.
On October 29, 1982, a meeting was held to discuss Bechtel performance / problems.
On November 5,1982, a meeting was held to discuss Stone and n.
Webster (S&W) qualifications for performance of remedial soils third party overview.
(
On January 18, 1983, an enforcement conference was held to discuss the diesel generator building findings.
On February 8, 1983, a management meeting was held to discuss p.
the CCP and the IDCVP as well at CPCo and Bechtel performance and desire to take prcper ce.r uti.<e action.
In addition, the NRC announced the imposicia v a $120,000 fine due to diesel generator building fir it f,
On March 7, 1983, a meu.ing was held to further discuss the CCP.
q.
r.
On March 15, 1983, a meeting was held to discuss the INPO Self Imposed Evaluation results.
3.
Construction Permit Amendment the NRC amended the Construction Permits, CPPR-81 On May 26, 1982, and CPPR-82, to implement the ASLB April 30, 1982, Order suspending all remedial soils activities on "Q" soils without prior explicit NRC approval.
18 1
c III.
SUMMARY
OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Soils and Foundations X
2.
Containment and other Safety Related Structures NOT ADDRESSED IN THIS REPORT
- 3.
Piping Systems and Supports X
4.
Safety Related Components X
5.
Support Systems X
6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT
- 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT
- X 8.
Licensing Activities NDT ADDRESSED IN THIS REPORT
- 9.
Quality Assurance 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT *
- For Functional' Areas "Not Addressed In This Report" see Section I, Introduction.
4
^^
-v, w
r
w' V.
Supporting Data and Summaries A.
Noncompliance Data Facility Name:
Midland, Units I and 2 Docket Nos. 50-329 50-330 Inspections:
No. 81-14 through 83-05 Noncompliance and Deviation Severity Levels Functional Area Assessment I
II III IV V
Dev 1.
Soils and Foundations 2
6 1
2 2.
Containment and Other Safety-Related Structures NOT ADDRESSED IN THIS REPORT 3.
Piping Systems and Supports 4.
Safety-Related Components 1
5.
Support Systems 6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT 8.
Licensing Activities 9.
Quality Assurance NOT ADDRESSED IN THIS REPORT 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT TOTAI.S 0
0 2
6 2
2 i
13
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