ML20125D023

Initial SALP Rept 50-482/92-99 for Period 911006-921010

ML20125D023
Person / Time
Site:	Wolf Creek
Issue date:	12/04/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20125D004	List: ML20125D000 ML20125D023
References
50-482-92-99, NUDOCS 9212140231
Download: ML20125D023 (26)

See also: IR 05000482/1992099

Text

e ^d q '

.

INITIAL SALP REPORT

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT NUMBER

50-482/92-99

Wolf Creek Nuclear Operating Corporation

Wolf Creek Generating Station

October 6,1991, through October 10,1992

{$k"I$$$$ko$o$f{sa

1

_________-_________-__A

. _ ___ _ _ . _.. .- . .__. . . _ .__ __ _ ._, _ _ _ _ _ _ _ .- . _

', *

. ,,

'

!

!

'

.

i

i

j TABLE OF CONTENTS

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . I

11. SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . 2

III. CRITERIA . . . . . . . . . . . . . . . . . . . . . . 3

,

IV. PERFORMANCE A'iALYSIS . . . . . . . . . . . . . . . . 3

A. Plant Jperations . . . . . . . . . . . . . . . 3

,

B. Radiological Controls ............ 6

C. Maintenance / Surveillance . . . . . . . . . . . 9

D. Emergency Preparedness . . . . . . . . . . . . 12

E. Security . . . . . . . . . . . . . . . . . . . 14

,

F. Engineering / Technical Support ........ 16

i G. Safety Assessment / Quality Verification . . . . 19

V. SUPPORTING DATA AND SUMMARIES ........... 23

A. Major Licensee Activities .......... 23

3 B. Direct Inspection and Review Activities ... 24

,

,- , _

________-_

" '

,

o.

.

.

1. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and to evaluate licensee performance based upon this

information. The program is supplemental to normal regulatory processes used

to ensure compliance with NRC rules and regulations. It is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful feedback to licensee management regarding

the NRC's assessment of their facility's performance in each functional area.

An NRC SALP Board, composed of the staff members listed below, met en

November 17, 1992, to review the obser/stions and data on performance and to

asses: licensee performance tii eccordance with NRC Manual Chapter 0516,

" Systematic Asses;=:r.t or Licensee Performance.'

This report 1: the NRC's assessment of the licensee's :afety performance at

Wolf Creek Genei ating Station for the period October 6,1991; through

-

October 10, 197

The SALP Board for Wolf Creek Generating Station was composed of:

Chairman

A. Bill Beach, Director, Division of Reactor Projects (DRP), Region IV

Members

M. J. Virgilio, Assistant Director for Region IV & V Reactors, Division of

Reactor Projects III/IV/V, Office of Nuclear Reactor Regulation (NRR)

L. J. Callan, Director, Division of Radiation Safety and Safeguards (DRSS),

Region IV '

D. D. Chamberlain, Deputy Director, Division of Reactor Safety (DRS),

Region IV

A. T. Howell, Chief, Project Section D, DRP, Region IV

W. D. Reckley, Project Manager, Project Directorate IV-2, NRR

G. A. Pick, Senior Resident Inspector, Wolf Creek Generating Station, DRP,

Region IV

The following personnel also participated in or observed the SALP Board

meeting:

W. M. Hodges, Director, DRS, Region I

T. F. Westerman, Chief, Engineering Section, DRS, Region IV

J. L. Pellet, Chief, Operations Section, DRS, Region IV

M. A. Satorius, Project Engineer, Project Section D, DRP, Region IV

L. E. Myers, Resident Inspector, Wolf Creek Generating Station, DRP, Region IV

P. M. Ray, Operations Engineer, Performance and Quality Evaluation Branch,. NRR

A. B. Earnest, Physical Security Specialist, DRSS, Region IV

L. T. Ricketson, Radiation Specialist, DRSS, Region IV

T. O. McKernon, Reactor Inspector, DRS, Region IV

C. A. Carpenter, Technical Assistant, NRR

.. .. .. .. _

_ _ _ _ _ _ _ _ _ _

. o ,,

.

.

.

.

-2-

11. SUMMARY Of R[SULTS

Overview

Overall, licensee performance was good, with mixed performance results to some

areas. Performance in the Plant Operations functional area was good.

Operators performed generally well during routine plant operations, and their

response to most plant events was good. Management involvement improved in

this functional area as evidenced by improvements in the operator training

program and licensee efforts to reduce the amount of nuisance annunciator

al arms . However, several examples of operations department procedural

weaknesses and operator inattention to detail were identified. Numerous

discrepancies with operator logs were indicative of a need for increased

management attention to this area. Maintenance / Surveillance performance also

was good. The overall material condition of the plant continued to be very

good, ano few equipment problems resulted in plant transients. However,

continuing problems in the area of work control have not been fully resolved.

Performance in the Radiological Controls area improved to a superior level of

performance, and performance in the Security functional area remained

superior. Performance in the Emergency Preparedness functional area was good,

having declined from a superior level of performance. The inability of two

out of three crews to recognize that emergency action level initiating

conditions had been met for a scenario event was considered a significant

weakness.

Performance in the Engineering / Technical Support area was good. Significant

improvements in the licensed operator requalification training program were

noted, and a detailed action plan had been developed to address significant

motor-operated valve program weaknesses that were identified early in the

, assessment period.

Performance in the Safety Assessment / Quality Verification functional area

remained acceptable, with continuing problems noted in the areas of self-

assessment and corrective actions. Actions taken to develop a Performance

Enhancement Program (PEP) to address weaknesses associated with the

organizationai structure, human performance, and plant arograms were viewed as

a positive initiative. However, the effectiveness of tie PEP could not be

evaluated during this assessment period because it had not been fully

developed.

-

I

l

., _ _ _ _ _ _ _ _ _ _ _____

-_. . . . . - -- . , _ - .

1 . u ,,

'

-

i

'

l

l' -3- l

i

i The licensee's performance category rating for each functional area is

<

previded in the table below, along with the ratings from the previous SALP

assessment period:

Rating Last Period Rating This Period

Functional Area (07/01/90 to 10/05/911 (10/06/91 to 10/10/92) ,

Plant Operations 2 2

Radiological Controls *21 1

Maintenance / Surveillance 2 2

Emergency Preparedness **10 2

Security 1 1

Engineering / Technical 2 2

'

Support

Safety Assessment / 3 3

Quality Verification

4

• I improving Trend - Licensee performance was determined to be improving

during this assessment period. Continuation of the trend may result in a

change in the performance rating.

'

• • D Declining Trend - Licensee performance was determined to be declining

during this assessment period and the licensee had not taken meaningful steps

to address this pattern. Continuation of the trend may result in a change in

the performance rating.

Ill. CRITERIA

The evaluation criteria, category definitions, and SALP process ir.ethodology

that were used, as applicable, to assess each functional area are described in

detail in NRC Manual Chapter 0516, dated September 28, 1990. This chapter is

available in the Public Document Room files. Therefore, these criteria are

not repeated here, but will be presented in detail at the public meeting to be

held with licensee management.

IV. PERFORMANCE ANALYSIS

A. Plant Operations

-

1. Analysis

This functional area consists primarily of the control and execution of

- activities directly related to operating' the plant.

NRC inspection efforts consisted of-the core inspection program by the

resi&nt inspectors and a regional initiative'to review plant procedures.

The previes SALP report (NRC Inspection Report 50-482/91-99) noted that

operators respnnded well to plant events and maintained a superior continuous

operating history. Enforcement history was good, and staffing levels remained

l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ ._

.

<- ,,

'

.

.

-4-

good with the exception of operations support staffing. The effectiveness of

licensed operator requalification training was marginal, with continuing

weaknesses noted in emergency operating procedure implementation. Examples of

operators failing to properly document known problems were also identified.

This was attributed to a lack of sufficient management guidance and direction

in this area. The previous SALP recommended that the licensee continue to:

evaluate and enhance communications between operations and the other

departments; provide additional support to operations and various support

activities; conduct self-critical assessments of plant operations; and ensure

that appropriate issues are being identified for resolution.

The enforcement history and reportable events in this functional area were

indicative of a good level of performance. However, problems with procedural

adequacy and compliance and several instances of inattention to detail were

noted. For example, because of inadequate procedural guidance, licensed

operators overpressurized the positive displacement pump discharge piping, and

an auxiliary operator failed to perform certain steps in a procedure, which

diluted the containment spray additive tank.

Operator performance during routine plant operations was very good, but

operator responses to plant events were mixed. During power operations,

operators responded quickly and in accordance with approved procedures to an

inadvertent main feedwater regulating valve closure. During a loss of

nonvital power, operators recognized the event quickly but were slow to

evaluate the failed steam generator water level instrument and select an

alternate channel prior to the reactor trip. An operator over-reacted to a

high average temperature by increasing main turbine load too quickly and,

subsequently, reduced reactor coolant system (RCS) pressure below the

administrative limit for departure from nucleate boiling, requiring automatic

system response to restore pressure.

The level of housekeeping throughout the plant was very good. Few equipment

problems challenged the operators.

Throughout the assessment period, there were several problems caused by

operator inattention to detail. A lack of awareness of clearance order status

by operators and test engineers resulted in contaminating a room because of an

open vent valve. Operators inadvertently removed the control room ventilation

system from its safeguards lineup, and an operator failed to log axial flux

readings as required by procedure.

During this assessment period, procedural weaknesses were identified with

plant operating procedures (general, system, emergency, and alarm response).

For example, weaknesses in a general plant operating procedure resulted in the

inoperability of both centrifugal charging pumps while the plant was operating

in Mode 4. During plant and emergency operating procedure inspections,

progrannatic weaknesses were noted in several procedural control areas,

including documentation, the temporary procedure change process, revision

.I

. .. . ___-_- __-__

. .- _ _ . _ . _ __ .-. . - _ . . _ . . -- - __. -_ .

,

. N ,

,

,

i

i .

.

2 -5-

1

j implementation, and the procedure writers guide. In response to the plant

operating procedural weaknesses, the licensee has begun to implement a long-

! term procedure upgrade program.

! The licensee has taken steps to improve training effectiveness. The

l Operations and Training Departments established formal communications at

' several levels. At the end of each requalification training week, the shift

j supervisor for that crew and the operations training supervisor discussed the

d

topics covered during the week to identify any needed improvements. The

,

Operations and Training Departments agreed upon the operator training needs

instead of the Training Department identifying the course topics.

The overall level of operator professionalism and decorum was good. Shift

turnover briefings were thorough. Operators routinely referenced alarm

'

response procedures when responding to control room annunciators. The

i licensee implemented steps to reduce control room traffic by placing a rope

,

barrier across the entrance to the control room and required licensed operator

permission to enter. However, on a number of occasions operator communication

lacked formality.

> The effectiveness of the assurance of quality and the resolution of technical

issues was mixed. For example, the licensee identified that an inadequate

, off-normal procedure resulted in 3 Technical Specification violation, and

"

effective corrective actions were promptly taken. Licensee actions to resolve

a number of problem areas following a February 1992 reactor trip were thorough

and effective. On the other hand, operations management was slow to realize

! the scope and causes of numerous examples of operator log discrepancies.

'

Operations department management did not take effective actions to identify

1 and correct the causes of these log discrepancies until NRC and licensee

quality assurance personnel identified similar discrepancies.

Operations staffing was good. Operations support staffing had not changed

,

significantly from the last assessment period. The licensee plans to augment

the support staff with additional personnel after they complete licensed

operator training and become licensed.

'

The overall level of management involvement in this functional area was good

and improved throughout the assessment period. Senior licensee management was

more involved in the day-to-day operation of the plant, and there was

increased management visibility in the plant. The licensee enhanced

communications among work groups and the control room operators by

implementing a work group turnover with the shift supervisor. The licensee

i significantly reduced the number of main control board deficiencies and

nuisance alarms during the assessment period. The licensee began to implement

the Management Action Plan (MAP) and began to develop the PEP to address

4

identified problem areas. Several of the MAP and PEP actions are intended to

,

correct weaknesses associated with this functional area.

,

In summary, licensee performance in the area of Plant Operations was good.

Operators responded well to most plant events and usually operated the plant

__

- - - .

_ _ _ _ - _ _ _

' '

..

.

.

.

-6-

well during normal operating conditions. Overall, staffing levels remained

good and actions were being taken to increase the operations support staffing.

The licensee began addressing weaknesses in this area as a result of

implementing the MAP and developing the PEP. However, weaknesses continued to

be identified in the areas of procedural adequacy and operator attention to

detail. Management oversight and involvement improved throughout the

assessment period as evidenced by a number of positive initiatives.

2. Performance Ratina

The licensee is considered to be in Performance Category 2 in this functional

area.

3. Recommendations

None

B. Radiological Controls

1. Anal _ysi s

This functional area consists primarily of activities related to radiation

protection, radioactive waste management, radiological effluent control and

monitoring, radiological environmental monitoring, and transportation of

radioactive materials.

This area was inspected five times by Region-based radiation specialist

inspectors and on a continuing basis by the resident inspectors.

The previous SALP report recommended that management assess the as low as

reasonably achievable (ALARA) suggestion program to assure _ that the program is

fully utilized. The report also recommended that management evaluate the

adequacy of the radiation protection technician training staff.

Management provided strong support to the radiation protection program during

this assessment period as evidenced by increased staffing and budget

allocations. The increased use of computer technology for task tracking and

information sharing demonstrated a high level of management commitment.

Management support was also evident by the high number of supervisory ar.d

professional staff that attended offsite training and professional meetings.

Management implemented a program awareness initiative which included required

tours of the radiological controlled area by radiation protection supervisors.

The supervisor inspection program was effective because it identified

potential problems and increased the awareness of radiation protection

supervisors to conditions within the radiological controlled area.

Radiation protection procedures provided good program guidance and were

enhanced so as to remove inconsistencies identified during the previous

assessment period. The radiological occurrence reporting system functioned

well to identify occurrences, trend causes, and track corrective actions. The

I

_ . _ _ _ . _ _ _ _ . _ _ _ _ _

.- ._ - = _ _ - - . .-- - .- __ - _ _ .-__-__ _ _

• .

'

.

k .

-7- ,

'

4

i radioactive materials controls and contamination programs were strengthened by

l the installation of new personnel contamination monitors. The radiation

protection group performed an excellent investigation of a personnel hot  !

particle exposure event. The investigation identified probable causes and  !

, resulted in special training for radiation workers in order to avoid future

,

problems.

i

The percent of contaminated areas within the radiological controlled area was

low, and radiological housekeeping was generally good. The radiation work

permit program was effective and provided good instructions to radiation

workers. Worter adherence to radiation work permit requirements was good.

Locked high radiation areas were properly controlled.

All elements of the internal radiation exposure control program, including air

i sampling, respiratory protection, and whole body counting, were of good 1

,

quality. Engineered controls such as portable ventilation and ambient air fit l

1 testing equipment were used to enhance the internal exposure program. )

i Management provided strong support for the ALARA program. This was )

demonstrated by the President and Chief Executive Officer attending ALARA

committee meetings. Another example of management support for the ALARA

>

program involved the approval of budget items for implementation of plant

i modifications which were justified by a dose-saving-versus-cost analysis.

l Some of the ALARA initiatives were completed during the 1991 refueling outage,

others were planned to be completed in the 1993 refueling outage,-and the

.

remaining are scheduled for completion over several years. The ALARA

'

initiatives which were approved for future implementation included shielding

improvements for the regenerative heat exchanger, new steam generator nozzle

! dams, a reactor head stand shield, and a permanent steam generator bowl

drainline. An ALARA initiative task which should result in significant long-

' term dose savings was accomplished during the 1991 refueling outage and

4

involved the removal of the resistance temperature detector bypass piping.

'

The licensee's person-rem values for the period 1988-1992 were well below the

national pressurized water reactor average. The ALARA suggestion program

gained increased acceptance from the workers through a recently initiated

incentive program, but it remained only modestly productive.

'

.

Overall implementation of radiological controls procedures and practices was

i good. However, during the first half of the assessment period, several

,

implementation weaknesses were identified. For example, radiological postings

were not always maintained in a proper maaner to ensure that personnel were

aware of radiological conditions. On some occasions, personnel were observed

to have leaned over radiation barriers during the conduct of maintenance

activities.

An excellent liquid and gaseous radioactive waste effluent program was

implemented. Radionuclides released in liquid and gaset.us waste effluent, and

doses calculated from the effluent, were within the Offsite Dose Calculation

'

Manual limits. Semiannual Radioactive Effluent Release Reports were submitted

in a timely manner and contained all the required information in the raquired

4

_, _

_ , _ . - _ _ . - . - _ . , , , . . - . .

_ - _ _ _ _ _ - _ _

.

o -

.,

.

.

-8-

format. Two violations were identified that pertained to inadvertent

radioactive gaseous releases that were caused by an inadequate waste gas

system operating procedure. Several inadvertent radioactive gaseous releases

were identified in the previous assessment period. This represented a

continuation of performance problems in this area.

An excellent radiological environmental monitoring program was maintained.

The program was well managed and included good implementing procedures. The

annual land use census was properly performed and documented. The annual

radiological environmental monitoring reports contained the required

information and were submitted in a timely manner. The environmental sampling

stations and equyment were well maintained. A strong meteorological

monitoring program also was maintained.

Superior solid waste and transportation programs were implemented. A state-

of-the-art computer code was used to classify and characterize radioactive

waste, and shipments were made without incident-or problem.

Overall, staffing in the Radiological Controls area was maintained at an

appropriate level. Staffing for the ALARA program was noted to be minimal

during the early part of the Assessment period with the ALARA coordinator

being the only individual responsible for the arogram during routine

operations. Later In the assessment period, t1ree full-time ALARA technicians

were added to the program. The solid radwaste and transportation program had

a minimum number of personnel but obtained excellent results. The staffing to

process radiation work permits was acceptable during routine operations. The

licensee's staff was supplemented with contract radiation protection

technicians during catages, but reliance was not placed on contractor

personnel for normal operations.

A good radiation protection technician training program was in place. The

training sessions were presented by well-qualified training department

instructors. An excellent training program had been implemented for personnel

responsible for radioactivn waste effluent management. Mockup training or

rehearsals were conducted for several jobs performed during the 1991 refueling

outage. Staffing in the technician training group had increased, but this

came at the expense of the corporate training group, which was responsible for

general employee and radiation worker training and was challenged during the

1991 refueling outage. A good program had been implemented for evaluating and

screening prospective contractor radiation protection technicians.

Comprehensive audits were performed in the radiological controls area by the

licensee's quality assurance group, The audits were performed by qualified

individuals and usually included technical experts from other nuclear power

-

plants. The radiation protection organization responded promptly to the audit

findings with effective and timely corrective actions. In addition to the

routine quality assurance audits, a vendor performed an assessment of the

waste management and transportation programs.

_ - _ _ _ _ ___ _ --_ _ _ _ _ _ - - _ -

l

.- .. .. .. . - ___ - - - -

},. z.

.,

.

1

i .

! _g.

i

$

,

In summary, a superior radiation protection program had been implemented.

Management and worker support for the ALARA program had increased. Several

excellent ALARA initiatives were identified and approved. Excellent programs

3

were maintained in the areas of radwaste management, transportation.

! radiological environmental monitoring, and radioactive effluent controls.

l

Minimum staffing was noted in some areas, but, overall, proper staffing levels

!

of well-trained personnel were maintained. An effective audit program had

been implemented.

2. Performance Ratina

The licensee is considered to be in Performance Category 1 in this functional

area.

4

l 3. Recommendations

None

,

C. Maintenance / Surveillance

,

1. Analysis

i This functional area consists of activities associated with the preventive and

corrective maintenance of plant structures, systems, and components. This

,

area also includes the conduct of surveillance testing, welding activities,

l and inservice testing (IST) and inspection (ISI) activities.

I

l

This area was inspected on a routine basis by the resident inspectors and on

'

several occasions by Region-based inspectors. The Region-based inspections

included inspection of the maintenance program implementation, surveillance

testing and calibration control programs and implementation, a fuel integrity

and reactor suberiticality inspection, inspection of the implementation of the

!

l

l boric acid prevention program, surveillance test procedures and records

l inspection, inspection of the IST program, and an ISI program inspection. A

l special inspection was conducted at the end of the assessment period to review

l

the circumstances surrounding a degraded essential service water flow

condition.

! The previous SALP report noted that equipment continued to perform well. The

l licensee was very effective in identifying the causes of personnel errors

i committed during the implementation of the surveillance program and in

'

improving controls over the maintenance troubleshooting program. Staffing.

levels were appropriate to assure timely completion of maintenance and

surveillance activities. The previous SALP recommended that licensee

msnagement should increase its efforts in establishing more effective work

process implementation controls because of continuing weaknesses noted in work

control, coordination, and surveillance scheduling activities. The SALP

report also recommended that the licensee should continue to implement its

commitment to enhance the maintenance program, the root cause analysis of

equipment problems, and IST implementation effectiveness.

!

, . ,, . - - _ , - -

- .-- , . . - _ ._ -- - - , , ,

. - - . -_. -+_._-a ,n.. - . - - . -

__ +=.-_.a - -- - - a . .- .,

.

,,

.

-10-

During this assessment period, the enforcement history and reportable events

related to this area were indicative of continuing weaknesses in the area of

work control. Other violations of lesser safety significance also were

identified.

The conduct of preventive and corrective maintenance activities was usually

good. The activities were implemented by qualified personnel. The

maintenance, modification, and instrumentation and controls groups maintained

a strong, qualified staff. Generally, personnel implemented the work in

accordance with procedures. However, continuing problems in the area of work

control were indicative of a need for increased management attention. For

example, maintenance personnel corrected an interference on a boric acid tank

reath rod valve without an approved work request. During conduct of

preventive maintenance on a manually operated essential service water (ESW)

system valve, mechanics adjusted the valve position indicator without work

authorization and failed to document this activity. The valve position

indication adjustment was not properly performed. As a result, the valve was

locked in the incorrect throttle position, which caused a significant i

degradation of ESW flow to a component cooling water heat exchanger.

Overall, the material condition and the level of housekeeping in the plant

were good. Few equipment problems resulted in unnecessary challenges to the

operators. However, some recurring equipment problems were identified.

Examples included the rod control system, plant computer, an emergency diesel

generator thermostatic control valve, and a safety-related battery charger.

Some long-standing system design problems have caused nuisance alarms in the

control room. For example, component cooling water temperature sensitivity

and flow problems which were identified in 1985 and 1988, respectively, have

not been corrected. The corrective maintenance backlog has been increasing

throughout the assessment period, but the significance of this increasing

backlog had not been fully evaluated by the end of the assessment period.

The surveillance test program was considered to be strong. The licensee

appeared to be proactive in upgrading the surveillance testing control process

and had initiated improvements in the surveillance testing database. The

calibration control program was good and had been well documented and

coordinated. The administrative controls in place for scheduling and tracking

surveillance testing activities appeared to be good. Surveillance test

procedures contained the appropriate elements and generally satisfied the

Technical Specification requirements.

The implementation of surveillance and testing activities was generally good,

but declined from the high level noted during the previous assessment period.

Several examples of missed or inadequately performed surveillances were

identified. For example, an emergency diesel generator (EDG) surveillance was

not performed within the specified surveillance interval because of weaknesses

in the administrative controls governing increased EDG surveillance testing.

A similar issue was identified during a previous assessment period. In

another instance, the failure to incorporate changes into a nuclear

instrumentation calibration procedure caused instrumentation and

--- ,_ , -- -

. - - - .

_ _ _ _ . _ _ _ _ . _ _ . _ _ -_ -__- _

. _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

i

.n ,,

-

Y

.

~

- -11-

l

l

l

l controls (I&C) technicians to incorrectly adjust an intermediate range monitor

i following the fifth refueling outage. In addition, several instances were

noted during the assessment period in which I&C personnel were observed to be

working around minor procedure deficiencies, rather than stopping work and ,

i correcting the procedures. ,

h

Implementation of the IST program was found to be generally satisfactory. The

'

licensee had previously recognized that weaknesses existed in the IST program

and, as a result, committed to perform a com)1ete review of IST procedures to

ensure technical adequacy and compliance witi American Society of Mechanical

,

j

4 Engineers (ASME)Section XI Code requirements. The licensee also obtained an

independent review of the IST program by an engineering-consulting firm.

1 Additional program. issues requiring resolution were noted during the licensee

l review, which licensee personnel committed to include in the IST procedure

i

review. A weakness was, however, identified by NRC pertaining to the use of a

i differential pressure gauge which did not conform to ASME Section XI Code

l. range requirements. Licensee personnel became-aware of:this discrepancy in

j early 1991 and had taken steps to replace the. instrument. The condition was

not, however, documented in accordance with corrective action program

! requirements,

.

i

.

j ISI data from the fifth refueling outage was found to be consistent with ASME

Section XI Code and ISI program requirements. The organization of the ISI

i data in clearly identifiable files containing applicable examination results,

i equipment calibration records, and personnel certifications was considered a ,

l document control program strength. Welding activities associated with the

l resistance temperature detector thermowell system modification to the reactor

coolant system were noted to be well planned, executed, and documented.

' The licensee's program for boric acid corrosion prevention was found_to

generally meet the intent o_f Generic Letter 88-05, " Boric Acid Corrosion of

! Carbon Steel Reactor Pressure Boundary Components in PWR Plants." The program

l included an extensive list of components inside containment being checked _ for

i boric acid leakage. However, the licensee omitted from the program components

outside the containment that were part of the reactor coolant pressure

l boundary.- In addition, the program's requirements for engineering evaluations

i

'

of boric acid-leaks were limited in scope in that evaluations did not assess

the in-plant locations where conditions could cause high concentrations of

boric acid or other observed degradation. While the licensee was utilizing

1

the work request process to correct boric acid leaks, it was observed that no

'

boric acid leakage conditions had been submitted to engineering for evaluation

since the inception of the program.

! Management involvement in the assurance of quality in this area was mixed.

For example, the licensee has been successful in resolving the surveillance

problems that were_ identified during the previous assessment period. Licensee

management has taken steps to develop a reliability-centered maintenance

program and to further enhance the predictive maintenance program in order'to

-improve the overall . effectiveness of- plant maintenance. On the other hand,

the licensee has been less than fully successful in. identifying the causes-of

, - .. _ , - --- - - - , , ,,.. , -

. - - . , , , ------~,n..---...

_ . _ -- . . _ . . .. . . - _ _ - - _ _ . _ _ _ ._ . _ -

,

,

.= .,

'

.

'

.

-

.

-12-

,

and correcting problems in the work control area. A number of maintenance and

I surveillance procedural weaknesses were identified throughout the assessmerit

'

period; however, no meaningful corrective actions associated with addressing

4 the generic implications of these procedural weaknesses had been initiated

during this assessment period.

I In summary, licensee performance in this area continued to be good. Equipment

continued to perform well, with some exceptions noted. Some weaknesses were

identified in the implementation of surveillances. Work control problems

continued to be identified during this assessment period. Previously

, identified concerns with the IST program had not been fully corrected prior to

the end of the assessment period.

2. Performance Ratina

The licensee is considered to be in Performance Category 2 in this functional

area.

4

3. Recommendations

a. NRC Actions

Inspection effort in this area should be consistent with the core inspection

program, with regional initiatives in the areas of work control, planning and

scheduling, and the backlog of corrective maintenance work requests.

b. Licensee Actions

The licensee should assess work control effectiveness and take those actions,

as appropriate, to correct identified weaknesses.

D. Emergency Preparedness

1. Anal _Ysi s

This functional area includes activities related to the establishment and

implementation of the emergency plan and implementing procedures, onsite and

offsite plan development and coordination, support and training of emergency

response organizations, licensee performance during exercise and actual events

that test the emergency plans, and interactions with onsite and offsite

emergency response organizations during planned exercises and actual events.

Evaluation of this functional area was based on the results of two inspections

conducted by regional emergency preparedness analysts and observations by the

resident inspectors. The two inspections included evaluation of the 1992

emergency exercise and an operational status inspection which also included

the regional initiative to inspect dose calculation and assessment.

., . - - . _. _ ._ _ . _ _ . _._ _ __

, __. . . . _ . _ . _ _ . _ . _ . __ _

- -

j .

.,

-

,

i

4

.

J

- -13-

4

The previous SALP report noted a Performance Category I rating, with a

declining trend. Problems were identified with the failure of shift crews to

a make accurate offsite dose assessments, several emergency exercise weaknesses,

and poor internal reviews of changes made to the emergency plan.

Recommendations for licensee action included training shift crews and

evaluating dose assessments capabilities.

During the assessment period, there were no emergency declarations associated

with actual events.

.

Licensee management demonstrated a commitment to maintain an effective

emergency preparedness program. Improvements were made in emergency response

facilities, including installation of new plant data computer terminals to

upgrade the capabilities for data transfer. The emergency response facilities

'

and equipment were maintained in an excellent state of operational readiness.

improvements were made in the emergency planning organization by moving more

,

of the supervision and planning activities onsite from the Wichita, Kansas,

!

office. The licensee continued to maintain good working relationships with

state and local agencies.

During the 1992 exercise, the licensee's response demonstrated that it was

prepared to protect the health and safety of the public. Control room

personnel properly detected and classified emergency events. .Their

. performance in identifying &nd following the correct procedures to mitigate

the simulated accident was considered a strength. Excellent command and

control was observed in the Emergency Operations Facility. The scenario

permitted the demonstration of all exercise objectives and the verification of

the effectiveness of corrective actions for weaknesses identified during the

previous exercise. One weakness was identified during the 1992 exercise

relating to delays experienced in making initial notifications of an emergency

to the state and county and in activating the group pagers so that emergency

response personnel could be recalled to activate emergency response

facilities.

Walkthroughs conducted with shift crews during the operational status

inspection revealed three weaknesses. The most significant weakness involved

two out of three crews that failed to recognize that emergency action level

initiating conditions had been met for a scenario event. Improvements were

noted in the response activities of the health physics and chemistry

technicians in the control room environment under emergency conditions.

The operational status inspection determined that the licensee's emergency

response training program provided comprehensive training to members of the

emergency response organization. A good level of staffing had been maintained

for the emergency response organization. Audits performed in the emergency

preparedness area were comprehensive and performance oriented. The emergency

response organization effectively responded to the audit findings. A regional l

initiative inspection performed in the area of dose calculation and assessment '

found that a new computer based method for calculating offsite dose

projections improved the licensee's capabilities in this area.

l

l

l

I

- .. -

_ _ _ __ _ ____ - -

.

• • -

.,

.

.

-14-

In summary, the licensee's perfonnance in this functional area was good. An

effective emergency preparedness program was maintained throughout the

assessment period. Management demonstrated superior support for the emergency

preparedness program. Maintenance of emergency response facilities was

excellent and several improvements were noted. Implementation of the

emergency plan during the annual exercise was effective; however, some

problems with emergency plan implementation were identified during operational

walkthroughs. The failure of two shift crews to recognize that emergency

action level initiating conditions had been met for a scenario event was

considered a significant weakness. Overall, the licensee demonstrated an

effective capability to protect the health and safety of the public during

emergencies.

2. performance Ratina

The licensee is considered to be in Performance Category 2 in this functional

area.

3. Recommendations

None

E. Security

1. Analysis

This functional area includes activities that ensure security of the plant,

including all aspects of access control, security background checks, and

protection of safeguards information.

Evaluation of this functional area was based on the results of one routine

security inspection performed by regional physical security specialist

inspectors and observations by the resident inspectors.

The previous SALP report noted that licensee management demonstrated a strong

commitment to the implementation of the security program. The security force

staffing, training, and enforcement history were considered superior. No

specific recommendations were included in the previous SALP report.

No enforcement issues were identified during this assessment period, which was

indicative of continuing superior performance.

Management continued to provide strong support to ensure that a high quality,

effective security program was maintained during this assessment period.

Management support was evidenced by several security program upgrades. The

upgrades included replacement of some intrusion detection eglipment,

installation of several additional assessment aids, and the modification of

alarm system multiplexers to reduce the need for compensatory measures during

system outages. The installation of system upgrades was well-planned and

coordinated so as not to disrupt the routine security program or the conduct

-

-

._ - __ - -.

- *

-

.,

,

1

.

'

-15-

r

of plant operations. Excellent communications and cooperation between the

'

security staff and the operations staff ensured that the appropriate

'

operational safety and safeguard interfaces were maintained.

High quality reporting procedures were maintained and understood by security

supervisors. In-depth analyses of the event reports were conducted to

determine root causes. A proactive approach was taken to correct any degraded

security systems.

The security organization received excellent support from the I&C department.

Five !&C technicians were assigned to the security organization to repair,

replace, and test security equipment. A formal and highly effective

preventive maintenance program was in place for the security systems. Repairs

of security equipment were generally accomplished within hours after the

identification of equipment problems. The rapid maintenance response to

problems resulted in very few compensatory postings of security officers.

"

During the assessment period, the licensee submitted two changes to the

Physical Security Plan, one change to the Safeguards Contingency Plan, and one

change to the Security Training and Qualification Plan under the provisions of

10 CFR 50.54(p). The revisions were technically sound and reflected well

developed policies and procedures. It was evident that security personnel

involved with submitting plan changes performed thorough reviews of the

proposed changes and were knowledgeable of NRC requirements.

The security manager and supervisors were well-trained, highly qualified,

security professionals with an excellent understanding of nuclear plant

'

security objectives. A stable staff of security officers was maintained with

a low personnel turnover rate. The number of security officers per shift was

! adequate to ensure that the licensee complied with all security requirements.

The security training program was administered and implemented by a well

qualified, full-time training staff. The training program included training

',

activities that exceeded minimum NRC trainina requirements. Security

personnel were provided with a well maintained physical fitness room, a

. simulator for training alarm station opeiators, and state-of-the-art training

l aids for hands-on training. In addition, security management and supervisors

instituted a tactical training program for armed security force members.

Security force members observed performing their duties exhibited a

professional demeanor and were very knowledgeable of security program

j procedures and their job responsibilities.

An excellent audit of security program activities was performed by the

licensee's quality assurance group. The audit was comprehensive and

j performance oriented and included a technical expert from another nuclear

-

plant on the audit team. The security organization provided timely,

effective, and technically correct responses to the audit findings and

recommendations.

. . -- - - . - .

- . _ _ _ - - - - - _ . . - _ . . - . -. - _- . . .

. ',, *

.

'

-16-

In summary, the licensee continued to maintain a superior security program.

Management support for the security program was evident by several upgrades

made to security systems and equipment, as well as all areas of the day-to-day

security operations. The security training program and facilities were

excellent. The security program was implemented by a well-trained, stable

staff. A high quality security program audit was performed.

2. Performance Ratina

The licensee is considered to be in Performance Category 1 in this functional

area.

3. Recommendations

None

F. Engineering / Technical Support

1. Analysis

This functional area consists of technical and engineering support for a):

plant activities. It includes all licensee activities associated with the

design of plant modifications; engineering and technical support for

operations, outages, maintenance, testing, surveillance, and procurement

activities; training; vendor interface activities; and configuration

management.

This functional area was inspected on an ongoing basis by the resident

l inspectors and periodically by the region-based inspectors. The inspection

,

effort also included team inspections to assess the motor-operated valve

program and electrical distribution system.

The previous SALP report recommended that the licensee take aggressive actions

to correct weaknesses in the engineering / technical support area and provide

system-specific training for system engineers and general training on the

[ design engineering process.

Enforcement history indicated generally good performance; however, one

significant issue pertaining to a failure to meet a commitment to formulate a

motor-operated valve program was identified by NRC.

The program developed by the licensee to implement commitments to Generic

Letter 89-10, " Safety-Related Motor-0perated Valve Testing and Surveillance,"

l was assessed as ineffective early in the assessment period. The program did

l

not address many of the. important provisions of the generic letter and lacked-

formality as typified by governing procedures that were superficial and

incomplete. The-program failed to acceptably demonstrate the operability of

,

many of the plant's motor-operated valves. Management oversight and support

was weak in this area. In response to NRC findings, the licensee extended a

refueling outage to implement an aggressive corrective action program that

_ - - - _ . .. .. - - - - -. - - - . _ - - .- -._ . - _. .. -

. . .

,

,, 1

) '

-

_17_

!

!

'

j involved many motor-operated valve modifications and utilized the expertise of

j a large number of contractors. The reconstructed motor-operated valve program

{ was detailed, well proceduralized, and comprehensive. By the end of the

assessment period, the licensee had a well-conceived plan to address all

, remaining identified weaknesses in the motor-operated valve program, which

, when implemented should insure that the program will meet the intent of

l Generic letter 89-10.

1

! An electrical distribution system functional inspection (EDSFI) was conducted

! during this assessment period. The EDSFI evaluated the capability of

! providing necessary electrical power to required equipment during normal,

upset, and accident conditions. The EDSFI- found the overall design of the

! electrical systems to be superior. The availability of detailed design

i documentation was a strength. However, NRC identified weaknesses with the

j lack of documentation to support operability and with the control and update

of information contained in the Updated Safety Analysis report.

The licensee has continued to maintain a strong fire protection / prevention

i program. The program was under a single person (Fire Protection Coordinator)

who was knowledgeable and experienced. Procedures were well maintained, up to

-date, and followed applicable administrative requirements. Fire brigade

training was maintained up to date and met all program requirements. Fire

brigade equipment was well maintained and readily accessible. -Plant fire

4

protection systems and equipment were subjected to surveillance tests in

! accordance with the program requirements. Quality assurance was involved in

the program, and engineering support was strong. The licensee had a

,

designated fire protecticn engineer on site and one in the Wichita office.

The licensee realigned their engineering organization, developing in the

j process a system engineering department. The licensee has been slow to

'

implement a formal system engineer program; however, the licensee expects to

have 41 fully qualified system engineers by August 1994. NRC was unable to

-

assess the effectiveness of the system engineer program because it had not

. been fully implemented- by the end of the assessment period. However, in

L consideration of a reconnendation made in the previous SALP report, the

licensee had formulated plans to provide system-specific training to the

! system engineers. The licensee also announced that they will; transfer the

i support service and engineering staffs from the headquarters offices to the

i

site by early 1995.

4

During this assessment period, the engineering organizations demonstrated-

mixed performance in-support of plant operations. For example, the

engineering organization provided strong support ~for the refueling outage,

. which-included effective technical-control of unexpected work items-including *

i -a failed fuel rod, component cooling water heat exchanger manway leakage, and

leakby of the boron injection tank inlet bypass valves. On the other hand,

'

engineering did not determine in a timely manner that two safety-related

motor-operated valves in _the emergency core cooling system were inoperable.

i Several incorrect fuses were installed in plant equipment'because I&C

technicians had relied on incorrect vendor drawings:instead of accurately

l

-l

l

.. .- . - , - - - - . .- . - - , - - _ - . - -.- - -,-

. _-. - - -- -. - . - . _ . . _ - - - _ _ - . - . - -. -

-

.

.

..

-

j

-

l

-

,

<

, .

i -18-

!

i

maintained engineering drawings. The architect-engineer had failed to update

applicable drawings for vendor equipment when a change to the equipment design

occurred. In response to this problem, the licensee developed a fuse control

program.

i The modification and temporary modification processes were observed to be

'

properly functioning. These programs contained all the essential

configuration control elements. The licensee initiated actions to reduce the

backlog of plant modifications. These actions included improved coordination,

scheduling, and prioritization.

J

On two occasions, engineering performed effective evaluation.s to determine the

10 CFR 21 reportability of manufacturing defects. In each case, the

'

i engineering organization properly evaluated the safety significance and

4

reportability of the identified discrepancy and made timely notifications to

the material supplier when necessary.

The licensee's program for licensed operator requalification had been

'

evaluated as unsatisfactory by the NRC during the fall of 1990. Through

-

gradual improvement, the licensee has been able to return the program to a

satisfactory status, as determined by a second NRC evaluation (with further

improvement noted in a third evaluation conducted October 19-28,1992).

During this assessment period, the licensee developed and implemented new

initiatives to improve the conduct and content of licensed operator training

and evaluation. Specifically,- notable improvements were obsarved in licensed

i operator training and examination materials. In addition, the licensed

operators were observed to have conducted on-the-job training, with strong

! emphasis en effective communications. The licensee's program for technical

j support staff training was providing adequate initial and cor.tinuing training;

l however, some programmatic weaknesses were identifieo. The program had not

been evaluated or audited by management, quality assurance, or any other

! organization.

l

l In summary, performance in the area of engineering / technical support was good.

'

Gradual improvement was evident in the training of licensed operators;

however, a number of programmatic weaknesses were identified in the area of

l

technical support staff training. The licensee was in the process of

j developing a system engineer department to be staffed with 41 system

i

engineers, each of whom will receive system-specific training. The motor-

l operated valve program, which had lacked management attention and was

i fundamentally unacceptable when first inspected, was successfully

'

reconstructed in response to NRC findings. The EDSFI fumd the overall design

of the electrical systems to be superior. _ The licensee continued to maintain

a strong fire protection program. Engineering support of plant operations

i was strong in some areas, weak in others.

l

! 2. Performance Rating

The licensee is considered to be in Performance Category 2 in this functional

l area.

l

!'

l . - - -

- . - - - - . . . . . - . -~ _-. ., - -_____

i

i v'

.

.l*

(" .

-y ,

'

-D-

4

! 3. Recommendations

j a. NRC Actio_ns

!

Inspection effort in this area should be consistent with the core inspection

-

program, with regional initiatives in the areas of engineering organizational

j structure, tie system engineer program, the design basis capture program,-and

the plant #!fication backlog.

s Licenree Actions

4 9ne

g

i

l- G. Safety Assessment /0uality Verification

!_ . Analysis

!

! shis functional ama includes licensee activities associated with the

-implementation ot licensee safety policies; licensee activities relat> 4 'a ,

j' amendment, exemption, and- relief requests; . responses to generic letter nd

j bulletins; the resolution of safety issues and performance of safety

evaluations; safety committee and self-assessment activities; analysis of

! industry operational experience; licensee activities related to the

r

identification and raiolution of equiptent and programmatic problems; and

'.Icensee activities. associated with qut'ity verification functions.

[ This ar- wa< acutinely inspected by u e resident inspectors and periodically

l by Regic' Ased h spectors._ ~ Regional initiative inspections included the

i review of he fuel integrity and subcriticality program, the motor-operated'

l vaive pragram, and the licensee's programs associated with self-assessment,-  !

feedback of operational experience, quality-verification, and corrective '

actions. A reactive inspection wa.e conducted to review the licensee's

l

respow to the " noise events" which occurred in February and' March 1992.

l- The previous SALP report r.oted strengths in the areas of licensing submittals

and quality verification audits -Weaknesses were identified in the areas of

corrective action programs, licensee self-assessmert capabilities, the

l licensed operator -requalification. program, and management involvement and

l oversight.

! .

.During this. assessment period, there were eight license amendments issued.-

( .-The amendment related to the reactor protection system manual trip. switches

l was processed under emergency circumstances' and an amendment request related

to the Kansas Gas and Electric / Kansas' Power and Light merger which was;

n ultimately _ withdrawn was11nitially processed under exigent circumstances. The

L licensee's. handling of these special' request: as well as the quality of the

routine amendment. requests demonstrated a gcod knowledge'of the regulatory:

L process. The licensee also provided good responses la NRC generic letters and-

bulletins issued during the assessment period. In' addition, topical reports

,

related to the development of_-licensee -inhouse capability to perform nuclear

,

p

I

h.

'

i

. .. ,l =

.

s

.

-20-

l

design and safety analysis have been submitted and are currently under review l

by the NRC staff. The technical quality of the submittals continued to be i

'

good and reflected strong engineering support and cooperation with the

licensing activities, l

,

3

Enforcement history indicated continuing significant weaknesses in the areas 1

'

of self-assessment and corrective action. A Notice of Violation and a Civil

Penalty were issued for the licensee's failure to take prompt corrective i

actions for safety-related motor-operated valve operability concerns. Several

other violations of lesser safety significance were identified for inadequate

.

!

corrective actions.

The licensee's program for the assessment and resolution of issues pertaining

4

to industry operational experience was acceptable. However, several

weaknesses were identified in the areas of review adequacy and timeliness of

actions taken to resolve industry concerns. Recent procedural and

organizational changes should enhance the effectiveness of the program.

The o.';ality of the licensee event report submittals was generally good.

Hr+ever, in a few instances, the corrective actions did not address generic

implications. Periodic NRC reviews of control room logs and reportability

evaluation reports determined that the licensee's co servativeness in making

reportability determinations improved throughout the assessment period.

'

The licensee programs associated with the evaluation of changes to the

i facility in accordance with 10 CFR 50.59 were determined to be good. Recent

changes to the process resulted in improved evaluations and better

coordination of the safety evaluations with other parts of the plant

modification and procedure change processes. Issuance of a revision to the

applicable corporate procedure was considered a positive step in attempting to

4

increase the consistency of the evaluations performed by various licensee

organizations.

1he licensee's self-assessment capabilities remained acceptable, with some

impravement noted during the assessment period. However, several weaknesses

in the licensee's ability to conduct appropriate self-assessments were noted.

A significant br~ kdown in the licensee's self-assessme nt capabilities

pertained to sevecal signifb. ant motor-operated valve hardware and

programmatic problems that were discovered by HRC early in the as;essment

period. Many of the motor-operated valve p ogram weaknesses were known by

licensee workers, but were not appropriately assessed by licensee management;

therefore, no meaningful corrective action was initially taken.

Overall, the licensee's implementation of corrective actions was acceptable.

The licensee significantly enhanced the effectiveness of their licensed

operator training requalification program. However, several examples of  !

inadequate corrective actions were identified during the assessment period.

For example, the licensee failed to implement timely corrective action to

resolve long-standing essential service water system water hammer events and

failed to replace a defective flow transmitter following a surveillance that

,g.. ..*w g + -- - g e

..

. ..

- '-

'

.

,

.

-21-

identified the deficient condition. Licensee actions pertaining to correcting

problems related to procedural noncompliance, inadequate procedures, and

inattention to detail were not fully successful during this assessment period.

_

'

The licensee's actions in response to several issues indicated they were

implementing improvements; however, these improvements had not yet fully

resolved all the identified weaknesses.

'

The licensee's response to events was acceptable, with some improvement noted.

< An NRC special inspection was conducted M investigate an event involving a

loud noise during plant heatup which occuired on February 28, 1992. The

inspection tean reviewed the licensee's incident investigation team's

findings, attended meetings, reviewed related historical data, and observed

related surveillance testing and data collection during a number of plant

heatups. NRC concluded that the licenset had not investigated a similar event

occurring before the February 28, 1992, event. However, their investigative

methods following the February 28 event were considered good. The licensee's

. conclusion that the noise event was caused by mechanical binding of the RCS

system during thermal expansion appeared to be supported by data and

observations taken during a subsequent plant heatup.

Licensee quality verification activities were determined to be good.

Reviews during various NRC inspections generally found the licensee's quality

verification audits to have provided comprehensive and accurate appraisals of

on-site organizations' activities and programs. On-site review committees

were also found to be functioning as intended. They were found to provide a

, forum for discussing plant issues and to serve as means for assigning

responsibility for followup actions.

A special team inspection of the licensee's corrective action programs was

conducted late in the assessment period. The team determined that recently

-

implemented changes to the corrective action program and procedures should

improve the overall performance prcvided that the changes are fully accepted

and implemented by the licensee's personnel. Improvements were noted in the

'

reduction of the compartmentalized impicmentation of corrective action

programs that had teen observed in prev 1ous inspections, increased use of

performance trending, additional training of employees regarding corrective

action programs and root cause analysis, and an increased involvement of

management in the routine oversight of plant activities. Some concerns were

identified by the inspection team and internal licensee audits involving a

continued reluctance on the part of many licensee personnel to utilize the

formal corrective action programs. Since many of the program improver.ents and

training were performed late in tne asscssment period, the level of success

related to the changes could not be fully assessed.

The team also reviewed the licensee's Management F. tion Plan (MAP) and

Performance Enhancement Program (PEP), which are inJor programs developed to

enhance a variety of licensee programs and organizations. The MAP was

4

developed in response to problems identified in previous internal and external

evaluations of licensee performance, including past NRC SALP reports. The MAP

was developed by the licensee and was being implemented within existing

. - - .-. -, -.

__

-.

.

,,,,e

.

.

-22-

facility organizations. Several specific improvements resulting from the MAP

included an increased use of trending to identify programmatic concerns and

the formation of an Issues Review Group to identify issues or programs

requiring management attention or increased coordination between licensee

organizations. The MAP process was considered to be responsive in providing

an integrated evaluation of problems and increasing the management's

involvement in plant activities. During the early stages of implementation of

the MAP, the licensee determined that a broader improvement program was needed

and the PEP was developed. The MAP issues will either be closed in accordance

with the established procedures or will be incorporated into a PEP action

plan.

The PEP was developed with the assistance of an outside management consultant

and involved the identification of general areas of concern and the

development of action plans to address each concern. As of the end of the

assessment period, the licensee had developed the general concerns, assigned

action team leaders, and was in the process of forming teams and developing

action plans. The inclusion of a resources impact analysis to allow team

members to estimate the time requiretents for participation and either

reschedule or reassign normal work activities was considered a strength of the

PEP process. An employee survey including questions regarding management

performance and communications was performed as part of the preliminary PEP

development. Issues identified from the survey were being incorporated into

the PEP action plans. The PEP is still in the developmental phase and its

effectiveness will depend on the quality of the action plans and their

implementation.

The licensee initiated several management and organizational changes

throughout the assessment period that were intended to improve communications

and cooperation and eventually improve the licensee's effectiveness. The

licensee deleted a level of management and adied a third vice president in

order to strengthen the quality assurance organization. Because these

management and organizational changes occurred late in the assessment period,

their effectiveness could not be assessed.

In summary, the licensee's overall performance in this functional area was

acceptable, with some '.mprovement noted. However, several significant

weaknesses with the self-assessment and corrective action programs were

observed during the assessment period. Increased involvement and oversight by

management in routine plant activities were observed. Many changes were

either implemented or planned late in the assessment period; therefore, the

effectiveness of these changes could not be evaluated.

2. Performance Ratina

The licensee is considered to be in Performance Category 3 in this functional

area.

I

l

I

- .

-

- - .. - - _ .-. . . .-. . -- .

'

.. .

-

,

, .

'

o

.

. .

y -23-

4

j 3. Recommendations

-

a. NRC Actions

Inspection effort in.this functional area should be consistent with the core

inspection program, with regional initiatives in the areas of self-assessment

- and corrective actions, and MAP and PEP implementation effectiveness.

,

b. Licensee Actions

,

i

- .

The licensee should continue efforts to raise the level of acceptance of the

corrective action program by the plant staff and-begin implementation of

effective PEP action plans.

i

j V. SUPPORTING DATA AND SUMMARIES

,

i- A. Major Licensee Activities-

4

'

1. Major Outaaes

The fifth refueling outage was completed on January 14, 1992. Although the-

i = outage was generally well controlled, extensive problems were encountered that

j. extended the original planned 62-day _ outage to 117 days. Delays were

principally the result of

• Extensive NRC and licensee identified motor-operated valve ' deficiencies;

,

-

• Several failed fuel rods that required additional efforts to permit core

.off load;

- .

a- Unexpected problems --in the cle.aning andL reassembly of_ component cooling

, water heat exchangers; and.

• ~ Difficulties i.n attempting' to stop system leakage associated with the

-

new boron injection tank inlet bypass valves.

'

Significant work completed included:

0

l

• Reactor Coolant Pump B motor replacement;

-

_

i

ll

• -EDG planned maintenance;

[ RCS_ bypass manifold removal and installation of new resistance

temperature detectors (RTD);

1

,

o Installation of new containment! cooler coils;

,

a Installation _of a-new permanent reactor cavity seal;

1

,

. - - . -- - _ _ _ _ . _

7

.

. 4' *

e

e

-24-

.

!

' * Sludge lancing, eddy current testing, and .Inconel 600 plug replacement

j on two steam generators; and

i

l Motor-operated valve static testing.

I

2. License Amendments

l Eight operating license amendments were issued.

l 3. Significant Modifications

!-

l The licensee installed 107 modifications during the assessment period. The

j following major modifications were installed:

i * Reactor Cavity Seal Ring Replacement;

l RTD Bypass Manifold Removal;

f-

t ESW Vault Installation;

!

• ESW Chemical Addition Modification;

i

[ * Radwaste Storage Modifications;

i

i

• Main Turbine Third Stage Extraction Steam Piping Modifications; and

i

• Snubber Removal / Replacement.

"

8. Direct inspection and Review Activities

NRC inspection activity during the assessment period included 33 inspections.

Approximately 4480 direct inspection hours were expended, which did.not

include Operator 1.icensing-Examinations or contractor hours.

..