ML20133A793

Advises That Regional SALP Review Board Meeting Scheduled on 851106 at Region V Ofc.Assessment Will Cover Apr 1984 - Sept 1985.Anticipated Outline of SALP Rept Provided.Performance Analyses Required by 851010

ML20133A793
Person / Time
Site:	Palo Verde
Issue date:	09/24/1985
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Bosted C, Chaffee A, Crews J, Fiorelli G, Hernandez G, Andrew Hon, Miller L, Sorensen C, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8510020337
Download: ML20133A793 (15)

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Q SEP 241985 MEMORANDUM FOR: J. Crews, RV

• A. Chaffee; RV L.' Miller, RV A., Hon', RV C. Sorensen,'RV R. Zimmerman,fRV G. Hernandez,..RV G..Fiore11i, RV C. Bosted, RV J. Ball, RV R. Scarano, RV G. Knighton, AD/L:NRR E. Licitra, Project Manager, NRR M. . Ley,' Project Manager, NRR D. Schaefer, RV C. Sherman, RV R. Fish,.RV P. Qualls, RV FROM: D. Kirsch, Acting Director Division of Reactor Safety and Projects, RV

SUBJECT:

SYSTEMATIC ASSESSMENT.0F LICENSEE PERFORMANCE (SALP)

FOR PALO VERDE (Period April 1, 1984 through September 30, 1985)

References:

(1) NRC Manual Chapter 0516 (2) Pro' posed changes to the SALP process, J. M. Taylor Memorandum dated June 27, 1985 (3);_ Region V Instruction 0701 l (4) SALP Board Schedule, J. B. Martin Memorandum dated l August 22, 1985 l'

[ Pursuant to references (1), (2), (3) and (4) above, the regional SALP Review L Board meeting for Palo Verde is scheduled to convene at the Region V Walnut Creek office on November 6, 1985, at 8:30 a.m. The board members will consist of_the above addressees and myself who will serve as chairperson.

This assessment will cover'the 18 month period from April 1, 1984 through September 1985. The evaluation period will include recent events through.

September 1985.

8510020337 850924 ./ g I\

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ADOCK 05000528 PDR {

s Members of the Palo Verde SALP Board are herewith provided a review guidance package to be used in preparing performance analyses of the various functional areas. This package consists of the following:

Description of functional areas (Attachment 1)

Evaluation criteria (Attachment 2)

Attributes for the evaluation criteria (Attachment 3)

Performance categories (Attachment 4)

SALP evaluation matrix (Attachment 5)

Sample SALP functional area performance analysis (Attachment 6)

Supporting data and summaries is under preparation and will be distributed to the SALP Board Members by October 4, 1985.

The following is the anticipated outline of the Palo Verde SALP report, along with the individuals assigned lead responsibility for preparing input for each section.

I. Introduction Hon II. Criteria Hon III. Summary of Results Hon IV. Performance Analysis

1. Plant Operations Zimmerman

2. Radiological Controls Sherman

3. Maintenance Zimmerman

4. Surveilla'nce Zimmerman i

5. Fire Protection Qualls

6. Emergency Preparedness Fish

7. Security and Safeguards Schaefer )

8. Refueling N/A i

9. Quality Programs and Administrative Controls Affecting Safety Zimmerman

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10. Licensing Activities Licitra

11. Training Zimmerman

12. Containment Safety-Related Structures Hernandez and Major Steel Supports

13. Piping System and Supports Hernandez

14. Safety-Related Components - Mechanical Hernandez

15. Auxiliary System Hernandez

16. Electrical Equipment and Cables Hernandez

17. Instrumentation Hernandez

18. Preoperational Testing Fiorelli l

19. Startup Testing Bosted V. Supporting Data and Summaries Hon (Including tables) l

Each person assigned lead responsibility for a functional area shall prepare a performance analysis and submit it to A. Hon by C.O.B. October 10, 1985. Each performance analysis shall be prepared as follows:

1. Assess the licensee's performance in the functional area based upon inspections performed, available data and observations of the licensee's performance during the SALP period. Obtain inputs from others who had inspection responsibilities in the functional area.

In assessing the licensee's performance, use the guidance in Attachment 1 through 4.

2. Prepare a performance analysis for the functional area following the format of Attachment 6. If possible, discuss'the trend of the licensee's performance since the previous SALP period. The analysis should reference pertinent data, enforcement items or events, when appropriate, but should be principally a quantitative analysis of the licensee's performance in the area (depending upon the level of activity, approximately one to one and one-half page in length when single space typed).

3. Include recommendations for licensee actions related to the functional area.

4. Provide a copy of the SALP evaluation matrix (Attachment 5),

assigning a performance category for each evaluation criterion.

By copy of this memoranoum, the Director, Office of Investigations, San Francisco Field Office, is requested to provide a summary of major investigative activities and results involving Palo Verde, by October 10, 1985.

In addition, by copy of this memorandum, the offices of NMSS and AE0D are requested to provide performance analyses by October 10,1985 (or updated earlier submittals to address the extended SALP period).

Originoi sigr.ed Sr ~

D. F. Kirsch D. F. Kirsch SALP Board Chairman Acting Director, Division of Reactor Safety and Projects

Enclosures:

As Stated cc: J. Davis, NMSS R. Seyfrit, AEOD

0. Shackleton, OI/SFF0 R. Scarano, RV bec: RSB/ Document Control Desk (RIDS)

Mr. J. Martin, Mr. B. Faulkenberry, G. Cook, Resident Inspector

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AHhn:- 1 ler AChaffee DKirdch 9/g/85 9/p /85 9/Af/85 9/ /85

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Functional Areas

1. Plant Operations

< Consists chiefly of the activities of the licensee's operational staff l (e.g., licensed operators, shift technical advisors, and auxiliary operators). It is intended to be limited to operating activities such as plant startup, power operation, plant shutdown, and system lineups.

Thus, it includes activities'such as reading and logging plant conditions; responding to off-normal conditions; manipulating the reactor L and auxiliary controls; training / retraining of licensed operators, shift technical advisors, and auxiliary operators.

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2. Radiological Controls Includes controls for occupational radiation protection; radioactive materials and contamination controls; radiological surveys and monitoring; processing of gaseous, liquid, and solid wastes; transportation of radioactive materials; radiological effluent and environmental monitoring; and the results of the NRC's independent measurement program.

3. Maintenance Includes all activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.

4. Surveillance Includes all surveillance testing activities as well as all inservice inspection and testing activities. Examples of activities included are:

instrument calibrations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.

5. Fire Protection Includes routine housekeeping and fire protection / prevention program activities. Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation; and those fire protection features provided for structures, systems, and components important to safe shutdown.

6. Emergency Preparedness

! Includes activities relating to the implementation of the emergency plan j and implementing procedures. Thus, it includes such activities as l licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implementation;

( notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; medical treatment; t

radiological exposure control; recovery; protective actions; and l interfaces with onsite and offsite emergency response organizations.

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7. Security Includes all activities whose purpose is to ensure the security and continued operability of the plant. Specifically it includes all aspects-of the licensee's security program (e.g., access control, security checks, badging).

8. Refueling Includes all activities associated with refueling. Thus, it includes outage management, and the manipulation of new and spent fuel. *

9. Quality Programs and Administrative Controls Affecting Quality Includes all verification and oversight activities which affect or assure the quality of plant activities, structures, systems and components.

This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctly. The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities and materials are provided and used during the operation of the nuclear power plant. Principal emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring che effective implementation of the quality assurance program along with evaluating the history of licensee performance in the key areas of: committee activities, design and. procurement control, control of design change processes, inspections, audits, corrective action systems, and records.

10. Licensing Activities Includes all activities supporting the NRC review of the application for and the issuance of the Construction Permit and Operating License, and amendments. In~ addition, includes the adequacy and timeliness of all licensing submittals, responsiveness to NRC licensing initiatives, and the licensee's' approach to resolution of technical issues from a safety standpoint.

11. Training Includes the following facility training categories:

Non-licensed operators Control room operators Senior control room operators / shift supervisors Shift Technical advisors Instrument and control technicians Electrical maintenance personnel Mechanical maintenance personnel Radiological protection technicians Chemistry technicians Onsite technical staff and managers u.

12. Containment, Safety-Related Structures, and Major Steel Supports Includes all activities related to the structural concrete and steel used in the containment (including the basemat) and safety-related structures, and major steel equipment supports. It includes all aspects of structural concrete (e.g., reinforcing steel; concrete batching, delivery, placement, in-process testing, and curing; liner plate erection and fabrication; and containment post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam generators, pressurizer, polar crane, tanks, heat exchangers, etc.).

13. Piping Systems and Supports Includes those safety-related piping systems described in 10 CFR 50.2(v) and R.G. 1.26, quality groups A, B and C. It is intended to be limited to the primary pressure boundary and other safety-related water, steam and radioactive waste containment piping systems. It includes those quality checks necessary to ensure compliance with the applicable codes and other requirements specified in the SAR for these systems. The primary inspection emphasis in this area is on piping systems and their supports / restraints.

14. Safety-Related Components - Mechanical Covers mechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described in 3 above.

The primary emphasis here is on components rather than piping.

15. Auxiliary Systems Includes those safety-related auxiliary systems included in the nuclear facility which are essential for the safe shutdown of the plant or the protection of the health and safety of the public. Included here are systems such as HVAC, radwaste, fire protection and fuel storage and handling.

16. Electrical Equipment and Cables Includes safety-related electrical ccmponents, cables and associated items used in the electrical systems of the plant, such as: motors, transformers, batteries, emergency diesel generators, motor control centers, switchgear, electric raceways, cable (power, control, and instrument), circuit breakers, relays, and other interrupting and protective devices.

. 17. Instrumentation

. Covers safety-related instrument components and systems that are designed to measure, transmit, display, record and/or control various plant f

variables and conditions. The Reactor Protection System and the Engineered Safety Features Actuation System are two plant systems utilizing such devices as: sensors, transmitters, signal conditioners, l

controllers and other actuating devices, ' recorders, alarms, logic devices, instrument air supplies, racks, and panels.

18. Preoperational Testing Covers the preparation, conduct, and evaluation of test results for preoperational tests performed by or under the direction of the licensee's staff to demonstrate the proper functioning and conformance to design requirements of components, systems, and structures.

19. Startup Testing Covers the preparation, conduct, and evaluation of test results for testing conducted following the issuance of the operating license. It starts with initial fuel loading and precritical tests, and continues until the plant reaches commercial operating status at or near its licensed power rating.

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Evaluation Criteria

-Elements which must be considered when assessing a licensee's performance in a functional area.

a. The evaluation criteria are as follows:

1. Management involvement in assuring quality.

2. Approach to resolution of technical issues 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.

b. Guidance for using these criteria to arrive at a category assignment is found in the Appendi:: to this Chapter.

Attachment 2 L

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• l'.[ALUATION ClllTERIA WITil ATTRlilUTES Fort ASSESSMI.!6

1. ' MANAGE 14ENT INVOLVEMENT AND CONTROL IN ASSURING Q11ALITY Catecorv i Catet orv 2 Catecorv 3 consistent evidence of prior plan- . evidence of prior planning ning and assignment of prior 2 ties; and assignment of priorities; little evidence of prior planning -

well stated, controlled and explicit stated, defined procedures and assignment of priorities procedures for control of activities poorly stated or ill understood for control of activities procedures for control of activities well stated, disseminated and under- adequately stated and under-

. standable policies stood policies pc,orly stated, poorly understood or non-existent pol.icies decision making consistently at a decision making usuauy at a level that ensures adequate level that ensures adequate delision making seldom at a level management review management review that ensures adequate management review corporate management frequently corporate management usuaUy involved in site activities involved in site activities corporate management seldom involved in site activities audits complete, timely and thorough audits generally complete.

and thorough audits frequently not timely, incomplete or not thorough -

committees properly staffed and functioning,in almost au cases committees usuaUy properly committees not properly staffed staffed and functioning or functionmg -

reviews timely, thorough and reviews generally timely, technically sound reviews not timely, thorough or thorough and technically sound technicaur sound records complete, weU maintained and available records generauy complete, wen records not complete, not weU matntained and av:dable mamtained or unavadable procedures and policies strictly procedures and policies rarely adhered to violated procedures and poUcies occa-sionaUy violated corrective action systems promptly corrective action systems and ennsistently recognize and generally recognize and corrective action syste i rarely address non-reportable concerns reccgnize and address non-address nor.-reportable concerns reportab!e concerns procurement weu controUed and documented procurement generally weu repetitive breakdown in procure-

? controUed and documented ment centrol design weu controUed and vertfied rare breakdowns of minor repetitive breakdswn in designs signtricance m design control control or verW:stion or verification 2.

APPROAC11 TO RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPO!NT Category 1 Caterory 2 Caterorv 3 ,

clear understanding of issues understanding of issues <

demonstrated generally apparent understanding cf issues frequently lacking conservatism routinely exhibited when potential for safety conservatism generaUy exhibited meets minimum requirersnts significance exists i

technicaUy sound and thorough viable and generally sound and approaches in almost all cases thorough approaches of ten viable approaches, but lackmg in thoroughness or depth -

timely resolutions in almost all ,

cases generally timely resolutions

• resolutions of ten delayed 3.

RFSPONSIVENESS TO NRC INITI ATIVES Cater d C_ategorv 2 _

Catee ry 3 meets deadhnes generally timely responses fraquantly requires e%:er s.:ns of t.;ne timely resolution of ssues few longstanding regulatory issues at t rit'ut at,se to I.censee Innqst ar.cmg r,gulatory issues a,tranutable to betnsee ATTAC10 C T 3

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tecimically sound and thorough viable -and gt nerally sound and of ten viable responst s, but 1:acking m threroughness et respenses in almost all cases thorough responses dcpth acceptable resolutions proposed

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acceptable resolutions generally considerable NRC effort or initially in most cases proposed repeated submittals needed to obtam acceptable rest,lutions

4. ENFORCEMENT lilSTORY Category 1 Catecory 2 Catererv 3 s

major violations are rare and are major violations are rare and may multiple major violations or

, not indicative of programmatic indicate minor programmatic programmatic breakdown breakdown breakdown in dica t ed minor viol.itions are not repetitive multiple minor violations or minor violations are repetitive i

and not indicative of programmatic minor programmatic breakdawn and mdicative of prograrr.matic breakdown indicated breakdown corrective action is prompt and corrective action is timely corrective action is delayed -

effective -and effective in most cases or not effective

5. REPORT!NC AND ANALYSIS OF REPORTABLE EVENTS Caterorv 1

• Cateeory 2 ~ Catererv 3 events promptly and c mpletely events are reported in a timely reported" event reporting is frequently late manner, some mformation may or incomplete be lacking events are properly identafied events are accurately identified, and analyzed events are poorly identified or some analyses are margmal analyses are m: ginal. events are associated with progr:ramatic weaknesses

. corrective action is effective corrective action is usuauy as indicated by lack of repetition corrective acts:n is not timely taken but may not be effective nor effective, events are as mdicated by occasional repetitive repetition

6. STAFFING IINCLUDING M AN AGEMENT)

Caterorv 1 Category 2 Caterery 3 positions are identified, authorities key positions are identtfied, and responsibilities are weu defined positions are poorly identified, and authorities and responsi- or authorities and responsiteil-bahties are defined ities are til-defined vacant key positions are fiUed key positions usuauy filled on priority basis key positions are left vacant in a reasonable time for extended periods of time staffing is ample as in'dicated by staffing is adequate, staffing is weak or minimal as control over backlog and overtime occasional difficulties with backlog or overtime indicated by excessive backlog and overttme 7.

TR AINING AND OtJ AllFICATION FFFFCTIVENFSS .,

Catecory 1 Caterorv 2 Caterorv 3 trainmg and quahfication program makes a positive contribution, tramme and tualification trainmg and quahfication program contributes to an commensurate with procedures program is found to be the and staffmg, to understandmg adequate understandmg of inator contri uttng f actor to of work and adherence to procedures work and fair adherence poor understandtng of work, to procedures with a nodest with few personnel errors number of personnel errors as indicated by numerous f.roce-dure violations or personnet errers trammg program is weU defined a defined program ts and tmplemented with dedicated tmple-iented (or a larg. , Arceram may be either lackmg.

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n resources and a means for feed of the staff poorly defi .ed. or tr.ef f actively back emperience; program is appbed appbed for a significant se gm en t t2 nearny au stagg c,f the staff ATTACm E T 3 u

Criteria for Use in Evalua' tina Trainnsa functional Area Cateoorv 1 Catenary 2 Catecory 3 management frequently involved in management occasionally involved management seldom involved in review of training activities in review of training activities review of training activities acceptable resolution to NRC train- acceptable resolution generally i considerable NRC effort needed ing initiatives proposed initially proposed to cbtain acceptable resolutions in most cases few significant ever.ts have occurred occasional significant events have frequent significant events have that are indicative of & ?-aining occurred that are indicative of a occurred that are indicative of a deficiency training deficiency. training ceficiency S

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Attachment 3 Page 3 L

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Performance Categories A rating of licensee performance in a given functional area.

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 so that a high level of performance with respect to operational 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 reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.

c. Category 3 Both NRC and licensee attention should be increased. 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 so that minimally satisfactory performance with respect to operational safety or construction is being achieved.

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Sample Performance Analysis Fire Protection

1. Analysis During ,the current SALP assessment period 2 inspections totaling 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br /> of direct inspection effort were applied in the area of fire protection at San Onofre Units 1, 2, and 3.

In addition the resident inspectors provided continuing observations follows: in this area. Three violations were identified as Failure to provide indication of reactor coolant cold leg temperature on the essential plant parameter conitor panel which (Units is 2 used

& 3). if a fire makes the control room unavailable Failure to wrap redundant equipment power cables found to be within 20 feet of each other with a one-hour rated fire resistant material (Unit 3).

Failure to provide required fire protection for safe shutdown equipment (Unit 3).

The above violations were corrected in a timely manner.

The licensee has demonstrated aggressive management involvement in this area by the aggressive pursuit of a co=plete review of the Fire Hazards Analysis (FRA). This review consisted of a verification of plant conformance to this document and a comprehensive review of this document for conformance to NRC

- requirements. This activity has been essentially completed for .

Units approval.

2&3 with the submittal of the revised document to NRR for ,;

In addition, as a result of this work, 5 LERs were identified which covered a number of cases wherein plant configuration was not consistent with the FRA or NRC requirements. The licensee is currently doing a similar effort on Unit 1.

The licensee's staffing in this area appeared adequate and included a large number of fire patrol personnel, a station fire brigade, and an adequate management staff.

The training in this area was adequate.and the fire watch personnel appeared alert, knowledgeable and respansible. The station has its own fire department which has bec;. at the station all year. The licensee's reporting of fire protection system discrepancies appeared aggressive.

The 2, 3 licensee on Unit 3did andhave 0 onseveral Unit 1. LER's in this area - 21 on Unit Of these, three were caused by personnel error, three were caused by defective procedure.

Attachment 6 Page 1

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three were caused by component failure, and seven were caused by design manufacturing or installation error. These LER's appear to result in part due to'a large amount of retrofit work and the FEA review.

2. Conclusion Overall the licensee's performance in this areas has been aggressive and responsive to NRC concerns; however, due to the number of violations in this area, the failure on occasion to perform required surveillances, the failure to ensure compensation measures on occasion and the failure to ensure configuration confor=ance to the FHA and NRC requirement during initial construction on Units 2&3, this area is evaluated Category 2. -

3. Board Reco=mendation The licensee should aggresr,1vely pursue the ce=pletion of the FRA evaluation on Unit I and should continue to emphasize fire protection, particularly in light of the extensive retrofit work.

e Attachment-6 ,

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