ML20136E454
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' From:
. Mark Miller,6 K_ LAN O /6, E[ b. N Ch j f[
To:
KDL, SON Date:
10/24/96 9:28am
Subject:
Answers to RA questions on St. Lucie Self Assessment f
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g 9703130213 970306 PDR FOIA BINDER 96-485 PDR-
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' Responses to RA Questions Regarding St. Lucie Self-Assessment
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Specific Answers a.
Is the assessment correct?
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Yes. The assessment addresses areas which we have identified formally as problems (corrective actions, programs / processes / procedures), areas which we i
have discussed informally (complacency, change management, communications),
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and areas we have not identified (training, self-assessment, accountability).
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Did the NRC identify via inspections and/or SALP any indicators that sho.uld j-have prompted us to potential problems?
i Yes. The NRC began to have concems about St. Lucie's performance as early as Spring / Summer 1994, when an increase in the number of reactor trips (6 in 6 i
months) was noted. In April,1994, the Site Integration Matrix was developed to attempt to identify the problems at St. Lucie. In June 1994, St. Lucie was removed from the NRC list of good performers. The following assessments were j
made:
e Plant Status Report, June 1994 l
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Reactor trips not seen as related, but additional attention to the adequacy i-
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of procedures was recommended. Weakness in review cited. Weaknesses l
in corrective actions discussed. Operations was assessed as continuing to,
l be strong. Other functional area discussions indicated strong performance.
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Plant Status Report, August 1994 i
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Fundamentally the same assessment as June,1994, although potential problems in vendor technical manuals noted in the maintenan:e area.
l Plant Status Report /TPPR, October 1994 PSR concluded that performance remained strong in all functional areas, however, SRI notes for the TPPR indicating a difficulty in identifying 4
common causes for deficiencies identified through inspection. SRI's assessment was that some complacency existed, management standards were not firmly set and communicated, and too many people (in EPL) l didn't believe that a real problem existed.
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Plant Status Report /PPR, March 1995 j
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, Sharp decrease in the number of reactor trips cited.. Weaknesses pointed l
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k out in annunciator response procedures, corrective actions, logkeeping, and some aspects of FRG activities (reviews), however, Ops rated as
- strong overall. Some maintenance weaknesses were identified (VTMs,.
- IVs, welding), but, overall, maintenance was seen as superior. Other functional areas were seen as continuing at superior levels.
August,1995 q
l Regional personnel perform a root cause analysis for indications of.
j organizational and programmatic deficiencies, based on SIM data for 12 months. The predominant root cause for events observed at the plant was insufficient detail and scope in site programs and procedures. Deficiencies j
were noted in job skills, work practices, decisionmaking, interface among i
organizations, and unclear organizational responsibility and
. accountability. These weakness areas conform well to the l
licensee-identified limiting weaknesses in training, accountability, programs / processes / procedures, and communications management.
i Plant Status Report /PPR, September 1995 Increase in personnel errors noted in Operations, including failures to follow procedure, inattention to detail, and. failures to maintain awareness of equipment status. Overall, Operations' performance was seen as having declined. Maintenance performance.was similarly seen as having declined, with procedural quality and adherence and attention to detail cited as problem areas. Engineering and Plant. Support were seen as j
continuing to perform strongly.
A review ofinspection report findings from 1992-93 indicates that, primarily in the areas of equipment reliability and procedural adherence, problems existed. A cursory review indicates that opportunities for enforcement may have been missed in some cases. However, the SALP report covering the period indicates that only minor problems (operator attention-to-detail and maintenan' ce procedure adherence) were identified and does not categorize problems into specific areas in a manner sufficient to conclude that declines in performance levels were occurring.
. Did we pursue any of the indicators? If yes, how? If no, why not?
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- Prior to August,1995, when significant plant events (e.g. containment spraydown, RCP seal failure) indicated a clear decline in performance, no specific inspection efforts were targeted at -
I perceived weaknesses outside of the core inspection effort. A review ofInspection Reports from mid-1994 through the end of 1995 indicate that the only departures from the core inspection.
program were for allegation-related issues.
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.o Miller's. Assessment (Opinion)
-'Ihe failure of the NRC to act more proactively in applying inspection effort to St. Lucie i
stemmed from several factors:
A long history of superior performance leading to reduced inspection effort and a subsequent reduction in the number of findmgs A failure to act on the negative findings which were developed, as they tended to be masked by a large number of positive findings A failure to take advantage of the opinions of DRS and other visiting inspectors who, overwhelmingly, felt the plant was overrated j
A lack of a clear discriminator as to when negative findings warrant amplification over a larger number of positive findings.
Additionally, the plant is now undergoing what has been described in several documents in that,
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with added inspection effort come more findings and more enforcement which tends to appear as j
a decline in performance when, in fact, conditions which had persisted for some time are only now being realized. The percived decline then invites additional inspection, which turns up more problems, and the cycle repeats.
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