ML20141E694

Informs That on 970507,D Lochbaum Met W/Nrc in Rockville,Md to Discuss Ucs Nuclear Safety Monitoring Program.List of Attendees & Copy of Handouts Used in Meeting Encl

ML20141E694
Person / Time
Issue date:	05/15/1997
From:	Allsopp D NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9705210089
Download: ML20141E694 (30)

Text

{{#Wiki_filter:4 4 >I 4 May 15, 1997 MEMORANDUM T0: FILE FROM: - David K. Allsopp, DISP, NRR (Original signed by:).

SUBJECT:

UNION OF CONCERNED SCIENTIST'S (UCS) NUCLEAR SAFETY MONITORING PROGRAM- ~ On May 7,1997, David Lochbaum met with the U.S. Nuclear Regulatory Commission (NRC) in Rockviller Maryland, to discuss UCS's Nuclear Safety Monitoring Program. Attachment 1 is a list of the meeting attendees.

is a copy of the handouts that were used in the meeting.

Attachments: 1. List of Attendees 2. Handouts Distribution Central Files PUBLIC PIPB R/F q,p iec [ d -//8 60-3f y o qos -(, n b I DOCUMENT NAME: G:\\SECY2\\ MEETING. MIN T3,eoelve e sepy of this document. Indcate in the box:

• C" = Copy without enclosures *E" = Copy with enclosures *N" = No copy 0FFICE PIPB: DISP l5 PIPB: DISP lE PIPB: DISP jJ #

l l NAME DKAllsadji M / MRJohnsD19F/ m RWBorchardt#4 /40 DATE 05// E"/97 ' ~ 05//r /97 ' 05/ /5 /97 // OFFICIAL RECORD COPY 2000'71 .. - n e w,a Lg p p y a,. 9705210089 970515 PDR ORG ECIUCS PDR Db VAS

l - r i MEETING WITH DAVID LOCHEAUM, UCS i ~ May 7, 1997 l 4 i f H&ME ORGANIZATION l .E.' Jordan. NRC/EDO T. Martin NRC/EDO B. McCabe NRC/EDO S. Collins' NRC/NRR D. Ross NRC/AE00 F. Miraglia NRC/NRRE i T. Martin NRC/ADT V. Dricks NRC/0PA M. Johnson NRC/NRR W. Dizard McGraw-Hill D. Lochbaum UCS B. Bradley NEI 1, D. Chung NUS LIS i r I v 1 i l ? l 4 i i ]

N e N PRESENTATION TO THE NRC STAFF ON 1 UCS's NUCLEAR SAFETY MONITORING PROGRAM MAY 7,1997 'l i DAVID A. LOCHBAUM NUCLEAR SAFETY ENGINEER UNION OF CONCERNED SCIEN11STS r .e

UCS's Nuclear Safety M'onitoring Program OBJECFIVE Evaluate nuclear power plant performance to monitor resolution of generic safety issues and to identify d emerging trends with potential adverse nuclear safety implications. METHODOLOGY Review publicly available information for a focus group of operating plants that represent the nuclear industry. Evaluate events documented in these reports to detennine if the licensees are meeting expectations for the identification, assessment, and resolution of safety issues. Assess potential new safety issues by determining if focus plant (s) may be vulnerable. b - RESULTS For specific focus group plants - Later. In general, experience shows that the method meets the objective, although some mid-course corrections have been identified and may be incorporated. May 7,1997 Slide 1 m.,__,, _ _ _. _ -y

4 UCS's Nuclear Safety Monitoring Program l FOCUS GROUP SELECTION CRITERIA:

• Seek diversity in terms of reactor vendors, plant age, geographical location, and configuration (i.e., single unit site vs multiple unit site).

e Consider special factors such as prior UCS involvement (Indian Point 3), opportunity to complement 4 other UCS efforts, presence oflocal citizens' groups, and selection of at least plant operated by the major utilities (Commonwealth Edison, Entergy, and TVA). Selection of a Comed plant will also provide an opportunity to interface with a major player in nuclear oversight at the state level, the Illinois Department of Nuclear Safety.

• Adjust the focus plant population as necessary to ensure that all UCS's nuclear issues (e.g., restructuring, BWR ECCS strainer, UFSAR deficiencies, station blackout, etc.) are covered.
• The focus group population is not intended to be the worst plants or the best plants - without

) independently evaluating all the plants, developing a best or worst list would require reliance on a prior evaluation process. t i May 7,1997 Slide 2 qy-, 3m. ._m-

UCS's Nuclear Safety Monitoring Pmgram l Reactor Type BWR 1 - Containment Type DRYAMB ? Big Rock Point Consumers Power Company 240 03/29/63 Reactor Type BWR 2 - Containment Type Mark 1 Nine Mile Point 1 Niagara Mohawk Power Corp 1850 12/14/69 Oyster Creek GPU Nuclear Corporation 1930 12/01/69 Reactor Type BWR 3 - Containment Type Mark 1 Dresden 2 Commonwealth Edison Company 2527 06/09n0 Dresden 3 Commonwealth Edison Company 2527 11/1601 Millstone 1 Northeast Utilities 2011 12/28n0 Monticello Northern States Power Company 1670 06/3001 Pilgrim Boston Edison Co. 1998 12/09n2 Quad Cities 1 Commonwealth Edison Company 2511 02/1803 Quad Cities 2 Commonwealth Edison Company 2511 03/10n3 Oyster Creek: Representig the older BWR types, which were essentially one-of-a-kind during the early phases ofreactor development Oyster Creek is operated by GPU Nuclear and is located in New krsey. It is the 'second oldest plant operating in this country. ? o May 7,1997 Slide 3 w 3m-,. 3,, m. -'W*

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UCS's Nucicar Safety Monitoring Pmgrain Reactor Type BWR 4 - Contaimnent Type Mark 1 Browns Ferry 1 Tennessee Valley Authority 3293 08/Oln4 Browns Ferry 2 Tennessee Valley Authority 3293 03/01n5 ~ Browns Ferry 3 Tennessee Valley Authority 3293 03/Oln7 Brunswick 1 Carolina Power & Light Company 2436 03/18n7 Brunswick 2 Carolina Power & Light Company 2436 11/03n5 Cooper Nebraska Public Power District 2381 07/01n4 Duane Arnold Iowa Electric Light & Power Co 1658 02/0ln5 Edwin I. Hatch 1 Georgia Power Company 2436 12/31n5 Edwin I. Hatch 2 Georgia Power Company 2436 09/05n9 Fenni 2 Detroit Edison Company 3430 01/23/88 Hope Creek Public Service Electric & Gas 3293 12/20/86 James A. FitzPatrick New York Power Authority 2436 07/28n5 Peach Bottom 2 PECO 3458 07/Oln4 Peach Bottom 3 PECO 3293 12/01n4 Vermont Yankee Vermont Yankee Nuclear Power 1593 12/Oln2 Corporation Cooper: Representhqq the 22 BWRB and BWR/4 Mark 1 containmentplants. Cooper is operated by the Nebruska Public P6wer District and is located in Nebraska. - May 7,1997 Slide 4

4 UCS's Nuclear Safety Monitoring Pmgram Reactor Type BWR 4 - Contaimnent Type Mark 2 Limerick 1 PECO 3293 02/01/85 Limerick 2 PECO -3293 01/08/90 1 Susquehanna 1 Pennsylvania Power & Light 3293 06/08/83 Susquehanne 2 Pennsylvania Power & Light 3293 02/12/85 Reactor Type BWR 5 - Containment Type Mark 2 LaSalle County 1 Commonwealth Edison Company 3323 01/01/84 LaSalle County 2 Commonwealth Edison Company 3323 10/19/84 Nine Mile Point 2 Niagara Mohawk Power Corp 3323 03/11/88 WNP-2 Washington Public Power 3323 12/13/84 Supply System 1 Ldalle County 1: Repusentig the eight BWRM and BWR/S Mark 2 containmentplants. LaSaile is operated by the Commonwealth Edison Congpany and is located in Blinois. Ldalle was selected primarily for the opportunity to monitor one of the Com Edfacilities. ] May 7,1997 Slide 5

UCS's Nuclear Safety Monitoring Pmgram Reactor Type BWR 6 - Containment Type Mark 3 Clinton Illinois Power Company 2894 11/24/87 i Grand Gulf Entergy Operations Inc. 3833 07/01/85 Perry Cleveland Electric Illuminating Co. 3579 11/18/87 4 River Bend Gulf States Utilities Company 2894 06/16/86 River Bend: Representing thefour BWR/6 Mark 3 containment plants. River Bend is opemted by Entergy and is located in Louisiana. River Bend we constructed amt initially opemted by GulfStates Utilities until that utility was acquired by Entergy in a merger afew years ago. The plant has notyetfully assimilated into Entergy. NOTE: Because there are only four BWE/6 plants and they an all relatively new, it is pmposed that tids plant would be the lowest priority among thefocus gmup. t A May 7,1997 Slide 6 r

UCS's Nuclear Safety Monitoring Pregam 4 Reactor Type PWR 2 Loop - Containment Type DRYAMB Kewaunee Wisconsin Public Service Corp 1650 06/16n4 Point Beach 1&2 Wisconsin Electric Power Company 1519 12/21n0 & 10/0ln2 Prairie Island 1&2 Northern States Power Company 1650 12/16n3 & 12/21n4 R. E. Ginna Rochester Gas & Electric Corp 1520 07/0100 Reactor Type PWR 3 Loop - Containment Type DRYAMB H. B. Robinson 2 Carolina Power & Light Company 2300 03/07nl Joseph M. Farley 1&2 Southern Nuclear Operating Co 2652 12/01n7 & 07/30/81 Shearon Harris Carolina Power & Light Company 2775 05/02/87 Turkey Point 3&4 Florida Power & Light Company 2200 12/14n2 & 09/0703 Virgil C. Summer South Carolina Electric & Gas Co 2775 01/01/84 Reactor Type PWR 3 Loop - Containment Type DRYSUB Beaver Valley 1&2 Duquesne Light Company 2652 12/01n6 & 11/17/87 North Anna 1&2 Virginia Power 2893 06/06 0 8 & 12/14/80 __Surry 1 Vireinia Power 2441 12/22n2 Surry 2 Virginia Power 2441 05/01n3 Suny: Representiog the 13 Westirg/wuse 3-loop plants ami six Westinghouse 2-loop plants. Suny is opemted by Virginia Power and is lxatcJ in Virginia Virginia P6wer is an industry femier in dry cask storage ofspent . fuel May 7,1997 Slide 7 v -,e

i UCS's Nuclear Safety Monitoring Pmgram i Reactor Type PWR 4 Loop - Containment Type DRYAMB i Alvin W. Vogtle 1&2 Georgia Power Company 3565 06/01/87 & 05/20/89 Braidwood 1&2 Commonwealth Edison Company 3411 07/29/88 & 10/17/88 Byron 1&2 Commonwealth Edison Company 3411 09/16/85 & 08/21/87 Callaway Union Electric Company 3565 04/01/85 Comanche Peak 1&2 Texas Utilities Electric Company 3411 08/13/90 & 08/01/93 Diablo Canyon 1&2 Pacific Gas & Electric Company 3338 05/07/85 & 03/13/86 Indian Point 2 Consolidated Edison Company 3071 08/Oln4 Indian Point 3 New York Power Authority 3025 08/30n6 Salem 1 Public Service Electric & Gas Co 3411 06/30n7 Salem 2 Public Service Electric & Gas Co 3411 10/13/81 Seabrook North Atlantic Energy Service Corp 3411 08/19/90 South Texas Project 1&2 Houston Lighting & Power Co 3800 08/25/88 & 06/19/89 Wolf Creek Wolf Creek Nuclear Operating Corp 3565 09/03/85 Zion 1&2 Commonwealth Edison Company 3250 10/0203 & 11/Oln4 l Reactor Type PWR 4 Loop - Containment Type DRYSUB Millstone 3 Northeast Utilities 3411 04/23/86 Millstone 3 and Indian P6 int 3: Representig the 22 Westighouse 4-loop dry atmospheric and sub-atmospheric plants. Millstone 3 is operated by Northeast Utilities and is located in Connecticut. IP3 is operated by the New York Puwer Authority and is located in New York about 25 miles ppriver ofNYC IP3 has been operatig over 20 years, but has a lifetime eqpacity factor of around 50%. UCS has a log history of involvement with IP3. Millstone 3 is currently shutdown and requires approval by the NRC Commissioners prior to restartig. May 7,1997 Slide 8 --w y 3 v wr -+.3 e

UCS's Nuclear Safety Monitoring Pmgram Reactor Type PWR 4 Loop - Containment Type ICECND Catawba 1 Duke Power Company 3411 06/29/85 Catawba 2 Duke Power Company 3411 08/19/86 Donald C. Cook 1 Indiana / Michigan Power Company 3250 08/23n5 Donald C. Cook 2 Indiana / Michigan Power Company 3411 07/Oln8 McGuire 1 Duke Power Company 3411 12/01/81 McGuire 2 Duke Power Company 3411 03/01/84 Seouoyah 1 Tennessee Valley Authority 3411 07/01/81 Sequoyah 2 Tennessee Valley Authority 3411 06/01/82 Watts Bar Tennessee Valley Authority 3411 10/01/95 Sequoyah 1: Representire the nine Westirghouse 4-loop ice condenser containment plants. Sequoyah is opemted by the Tennessee Valley Authority and is located in Tennessee. Sequoyah and Watts Barr are sister plants so selectity this TVA plant will monitor both sites. 4 i - May 7,1997 Slide.9 i

t UCS's Nuclear Safety Monitoring Pmgram Reactor Type PWR CE - Containment Type DRYAMB Arkansas Nuclear 2 Entergy Operations Inc. 2815 03/25/80 5 i Calvert Cliffs 1 Baltimore Gas & Electric Company 2700 05/08DS Calvert Cliffs 2 Baltimore Gas & Electric Company 2700 04/01n7 Fort Calhoun Omaha Public Power District 1500 09/26n3 Maine Yankee Maine Yankee Atomic Power Co 2700 12/28n2 Millstone 2 Northeast Utilities 2700 12/26n5 Palisades Consumers Power Company 2530 12/31nl San Onofre 2 Southern California Edison Co 3390 08/18/83 San Onofre 3 Southem California Edison Co 3390 04/01/84 i St. Lucie 1 Florida Power & Light Company 2700 12/21n6 - St. Lucie 2 Florida Power & Light Company 2700 08/08/83 Waterford 3 Entergy Operations Inc. 3390 09/24/85 i Reactor Type PWR CE80 - Containment Type DRYAMB a Palo Verde 1 Arizona Public Service Company 3800 01/27/86 Palo Verde 2 Arizona Public Service Company 3800 09/18/86 Palo Verde 3 Arizona Public Service Company 3800 01/01/88 Calvert Chfs 1: Representing the 15 Combustion Engineerhng plants. Calvert Ch'(fs is operated by Baltimon. Gas & Electric and is located in Maryland. Calvert Chffs has become the point plantfor license nnewat efforts after Yankee Rowe pulled out of the picture. ~ May 7,1997 Slide 10 L-

UCS's Nuclear Safety Monitoring Program Reactor Type PWR LLP - Containment Type DRYAMB Arkansas Nuclear One 1 Entergy Operations Inc. 2568 12/04n4 Crystal River Florida Power Corporation 2544 03/13n7 Davis-Besse Toledo Edison Company 2772 07/31n8 Oconee1 Duke Power Company 2568 07/1603 Oconee 2 Duke Power Company 2568 09/09n4 Oconee 3 Duke Power Company 2568 12/16n4 Three Mile Island 1 GPU Nuclear Corporation 2568 09/02n4 Oconce 1: Repsesentirg the seven Babcock and Wilcoxplants. Oconee is opemted by Duke P6wer Company and is located in South Camlina. Duke is an importard player in the nuclear irufustry and is seeking to expand its business area by pmviding engineering and operations support to other utilities. Slide 11 - May 7,1997

i l j + UCS's Nuclear Safety Monitoring Pmgram l EVENT CHECKLIST The nuclear power plant event checklist features questions that probe the effectiveness of the licensee's problem identification and corrective action programs. The event cliecklist will be used when reviewing publicly available documentation: e licensee event reports (LERs) submitted by licensees to the NRC on problems reportable under 10 CFR 20,10 CFR 50.9,50.36, or 50.73 e inspection reports issued by the NRC documenting the scope and results from periodic and special inspections oflicensee activities e daily event reports issued by the NRC on actual and potential problems reported by licensees 4 a. weekly information reports issued by the NRC on staff activities during the week including meeting summaries and significant plant event reviews

• Systematic Assessment of Licensee Performance reports issued every 18-24 months for each nuclear plant site by the NRC 4

Events may be addressed in more than one of these sources. A single event checklist will be prepared using the document which most fully describes the event, it-causes, and corrective actions. i - May 7,1997 Slide 12 ~ - - - -, - - - -. -,, -,,,, -n-e ~, n =

UCS's Nuclear Safety Monitoring Pingram i i i EVENT CHECKLIST (CONTINUED) i Answers are provided for each question. The answer that most completely addresses the question for the specific event is selected. The only question permitting more than a single answer is the question involving root cause(s). i Each answer is assigned a numeric value. When the answer indicates that the minimum safety standard has been met, the assigned value is zero. When the answer indicates that the minimum safety standard has been exceeded, indicative of aggressive licensee action, the value is positive. The positive value gets larger the more that the licensee's actions exceed the minimum standards. When the minimum safety standards have not been met, the value is negative. The negative value gets larger as the licensee's actions fall further below minimum expected performance levels. The scoring system recognizes that events periodically occur in nuclear power plants given their complex nature. When equipment and personnel respond in conformance with minimum standards, the event is I considered to have negligible safety significance. As long as the minimum standards are met, the frequency of I such events also has minimal safety significance. The underlying assumption is that the federal regulations goveming the design and operation of nuclear power plants provide reasonable assurance that public health and safety are protected. The objective of the event checklist is to ensure that the safety margins established by the regulations have not been eroded by persuasive problems. The scoring system acknowledges the positive role of pro-active licensee actions. The theory is that a licensee turning over every rock and dealing with every problem operates a safer plant than a licensee letting sleeping dogs lie. The scoring system attempts to quantify the safety significance of the events rather than simply tracking event frequency. May 7,:1997 Slide 13 t rev-- = = - - v, -v -v--,- '-~v-e v- '= v - +-

UCS's Nuclear Safety Monitoring Pmgram Question 1: ~ Whofust identujied the problem that we nported? l Appendix B to 10 CFR 50 requires that the licensee administer a quality assurance (QA) program. The QA requirements cover independent verification on work tasks, periodic testing and inspection efforts, and corrective action programs. The objective of the QA requirements is to ensure that safety standards are met and to detect and correct any deficiencies as soon as possible. Therefore, a finding by an external auditor, either NRC or INPO, reflects a breakdown in the licensee's QA program that merits a negative score. An allegation (e.g., a safety concern expressed by a nuclear worker to a company organization outside the normal chain of command cr to an external agency) indicates that the culture maintained by the licensee does not permit the free and open expression of safety concerns by its employees, thus also warranting a negative score. There can be no positive score for this question since the licensee is required under the law to identify ~ problems. Aggressiveness by the licensee in seeking out problems is addressed by the next question. 4 L May 7,1997 Slide 14 l

i t UCS's Nuclear Safety Monitoning Pmgnm i i i Question.2: How was the reportedpublem identrfied? When the event was discovered by a special licensee self-assessment effort, by an assessment of conditions at i another power plant, or by a rigorous extent of condition evaluation, positive scoring is recorded. These efforts represent pro-active licensee performance that exceeds the minimum required standards. It is commendable when a licensee takes actions to prevent or eliminate a problem experienced by another licensee. It is equally i_ commendable when a licensee's corrective actions extend beyond the simple fix of the initiating event to address its broader implications and similar faults. l Discovery through testing, work control practices (e.g., technical review of proposed modification), and i assessment of a plant incident represent expected performance. Discovery by an internal audit gamers minor negative points because one performance barrier (the administrative controls over the original work activities) was breached. 4 Discovery by an external audit gets maximum negative points because two performance barriers were breached (the licensee's QA program in addition to the administrative controls over the original work activities).. - 1 l l Slide 15 H i May 7,1997 m .I

UCS's Nuclear Safety Monitonng Pmgram Question 3: Was the reportedpmblem evaluatedpmperly? A "yes" answer results in a zero score because that is the necessary performance expectation. A "no" answer obviously warrants a negative score because it indicates unacceptable performance. A " partially adequate" answer is permitted because there are times when the initial assessment for the event is incorrect, but is reversed upon further review by the licensee. The " partially adequate" answer also applied to the situation in which the licensee took appropriate actions to resolve the problem, but failed to properly report the issue to the NRC. The distinction between " partially adequate" and "no" should be based on the safety implications of the offending element. " Partially adequate" would be appropriate when the licensee's technical resolution of the problem was both timely and sufficient, but the licensee failed to properly inform the NRC. The plant's safety margin would have been restored in such an event. A "no" would be recorded in the case where the licensee met all of the reporting and notification requirements, but failed to adequately address the technical problems. i May 7,1997 Slide 16

P

l UCS's Nuclear Safety Monitoring Pmgram Question 4: What was the cause of the reportedpmblem?

There can be no positive scoring for this question since such events are tolerated, not encouraged. Random equipment failures, although scoring zero points in the root cause category, will generate an overall negative score during evaluation of questions six through eight if there is a history of failures implying insufficient corrective actions. Maintenance deficiencies and design / fabrication / installation errors produce maximum negative scores because they reflect poor management oversight with the associated implications of contributing to an overall erosion of safety margins. The concern is that these root causes may represent broader problems because the deficient management controls render all work potentially suspect. This is the only question where multiple answers are permissible because there can be more than one root cause contributing to the event. " Double jeopardy" will be avoided whenever possible. For example, if the - root cause is procedural inadequacy, personnel error will not also be automatically indicated on the premise that someone failed to do a good job developing and/or reviewing the procedure. i. May 7,1997 Slide 17 1 .,.L 'r-..- e v- ,. ~, w . ~ ,n,, r

UCS's Nuclear Safety Monitoring Pmgmm Question 5: When was the reported pmblem identajied? A " missed opportunity" approach is used in lieu of a time frame approach. The time frame approach has too many vulnerabilities. As an extreme example, the event where a control room operator ignored a blaring alarm for 45 minutes is worse than the case where a deficiency on the ufueling bridge was missed for a year, especially if the refueling bridge was not used during that year. The negative scoring is proportional to how often the event was overlooked. As an example, Northeast 4 Utilities reported during the summer of 1996 that it had discovered a 32" x 9" hole in the wall of the fuel handling building at Millstone. The hole, hidden from view behind a girder, apparently existed since plant construction. This deficiency was missed by the original workers, by the QA inspection of the original work, and during numerous pressure tests of the fuel handling building. The hole had been missed despite numerous opportunities to be aware ofits presence. The number of" misses" can be somewhat subjective. For example, it could be argued. hat every modification to a system that contained an original design error represented an opportunity to detect that error since the system design was reviewed while preparing the modification. Judgement will be exercised to limit the " misses" to those opportunities where it can be reasonably expected that the error should have been caught. I i May 7,1997 Slide 18 ,m.

UCS's Nuclear Safety Monitoring Pmgram Question 6: Had the uportedproblem.pwriously occurnd orpaviously been identified? This question looks for repeat offenders. If the event or a similar event had previously occurred or had already been identified at the facility, a negative score ensues. The concept is that proper and complete corrective actions for the prior event should have precluded its repetition. 4 Reasonable judgement will be. exercised in the definition of previous occurrence. The definition will not be so broad (i.e., a plant component broke) so as to make every event a repeater; nor will the definition be so narrow (i.e., failure of a 2 inch valve manufactured by Acme in 1994 and installed during 1995 on a low energy water system) so as to exclude repetitions. The event, or similar event, generally must have occurred previously at this facility in order for a "Yes" response to this question. The exceptions would be if an industry event was disseminated to the facility by the NRC or a vendor. 1 May 7,1997 slide 19 (.

UCS's Nuclear Safety Monitoning Pmgram Question 7: Had conective actions been implemented? and Question 8: Did conective actions adequately address the initialproblem? These questions apply only when there has been a previous event and target the effectiveness of corrective actions. These questions are closely related to, but not " double jeopardy" for, the sixth question for the following reason. Consider an event in which power is lost due to a blown fuse. For that event, the corrective action could be to replace the fhse. If this event is repeated five times in two months and the corrective action each time is to replace the fuse, the corrective actions, although implemented, have not resolved the problem. The fuse may be undersized or there may be an intennittent short in the circuit -- in any case, feeding it fuses 4 is an inadequate response. 2 4 May 7,1997 Slide 20 v-e + 4 w -m ,m-

N f UCS's Nuclear Safety Monitoring Program l Questica 9: Has the nportedproblem been nsolved? 4 Properly identifying and evaluating problems is good, but resolving problems is best. A positive score is assigned when the licensee, in addition to correcting the specific problem, aggressively examines its broader implications. A positive score is assigned even when these extra efforts do not identify any related problems. A small negative score is assigned when the corrective action has not yet been implemented, but is reasonably expected to be completed in the near term (defined as within one operating cycle). This concession recognizes that resolution is best, but that there are times and circumstances when a minor delay is tolerable. A larger negative score is assigned when corrective actions will not be completed in a timely manner. a 1 .i i May 7,1997 Slide 21 _~

e UCS's Nuclear Safety Monitoring.Pmgmm The Safety Sigmjicance Multiplier The scores for the questions are added to obtain a sub-total for the event. A safety significance multiplier is i then applied to obtain the overall event score. t When the event does not involve any emergency equipment, the multiplier is 1. If components with important functions are involved, a multiplier of 1.10 is applied. The rationale is that while i the components are not expressly needed to prevent or mitigate accidents, they have an important role in assuring the overall safety margins at the plant. The multiplier rises to 1.25 when emergency equipment is affected. Clearly, whatever the problem, its implications are more severe ifit affects emergency equipment than ifit did not. The multiplierjumps to 2.0 when two or more emergency systems are affected. Essentially, the reported problem represented a potential common mode failure mechanism that must be taken extremely seriously. The rationale for the multiplier is based on the nuc! ear industry being mature and well beyond the " break in" period. All emergency systems have been inspected and tested numerous times with plenty of opportunities for flushing out problems. The multiplier is more tolerant for non-emergency systems because (a) by their nature, non-emergency systems have lower safety significance, and (b) these systems are not designed and tested to the same high standards that are applied to emergency equipment. i The safety significance multiplier is applied for positive and negative scores. Thus, when the licensee's pro-active efforts correct problems affecting multiple emergency systems, a large positive score is reported. Conversely, when standards are not satisfied for multiple emergency systems, a large negative score results. 8. May 7,1997 Slide 22 ~

i t UCS's Nuclear Safety Monitoring Pingrani i EVENT CHECKIBT

SUMMARY

The possible scores for a single event range from -240 to +40. A score of-240, hopefully only a hypothetical condition, reflects unacceptable performance by the licensee in every aspect of the problem identification and corrective action programs. A score of +40, hopefully less of a hypothetical condition, reflects exemplary problem identification and corrective action efforts by the licensee. The event checklist can flag unacceptable performance based on a single event (i.e., a large negative score indicative oflong standing design problems affecting multiple safety systems that were discovered by the NRC after repeated failures of the licensee to detect and/or correct the deficiencies). The event checklist will probably be most meaningful when used to trend performance by a licensee. The waming signal from several event checklists indicating problems will be clearer than from any single event. In addition, such trending may screen out the isolated events ofindicated problems which do not accurately reflect overall licensee perfonnance. 4 i i May 7,1997 Slide 23 i . ~ ~,.,; s ,.....x-

UCS's Nuclear Safety Monitoring Pmgram l EVENT CHECKLET LIMATA TICNS l l The event checklist has been used since late January 1997 to monitor perfonnance at UCS's ten focus plants. This experience has indicated that some minor changes to the checklist may be warranted. For example:

• If the NRC finds the problem, the answers to the first two questions must generate maximum negative points. The first question, which is essentially fully enveloped by the second question, may be eliminated in the revised event checklist.

i w The safety signi6cance multiplier may need to be revised or supplemented to fairly address events l invaving safety equipment, but for which the safety implications were negligible. For example, a licensee recently reported an error in its calibration procedure for nuclear instrumentation. As a result, j the control function would not have automatically enforced at the power level required by Technical Specifications (up to 31% instead of 30%). The problem, although involving safety equipment, had zero j safety implications. i i O The objective of the event checklist is provide insight into the effectiveness of the licensee's safety monitoring program. Since it relics on reviewing events reported by the licensee and the NRC, it is vulnerable to be i blinded when a licensee has a high threshold for reporting problems or a low priority on identifying problems and when the NRC does not conduct many inspections at a licensee's facility. A supplement to the event checklist may be a peer plant comparison evaluation that attempts to determine if a licensee's safety monitoring program is consistent with that ofits peers. Such insights might be provided { i through a screening of LERs and inspection reports for plants comparable to the plant operated by a licensee. i The need for comparison evaluation will be assessed in a later phase of UCS's monitoring program. ~ { May 7,1997 Slide 24 - --r, .-m, ,m..- .,i--- g

~ _ _ i a o + n.p u. s ts: ..., h.. -n. .x. , r o . >r,e ..n &kihk$b$5Ni$$$$5kki; Sil?ns]k(M$5k5$3&l#$hNA$$&iAb idSid5Nbb%5 24; JOSf bdECW:$ik:N$as:bsibbHd:O4b>dhii $, 4 Plant: Event: Date: Source: amep wemw:mrmmmmwremmeanmrewwmewi mmyem uenw grynrgrummyn$is2,$ sis 41$rw djkAfdnMMMMhi@2sd232bda;0$MihnO264sL1!ish$1 WWM:d6dMSisiW.fiM$dsM2M jjij EVENT: zmmyere~~ew:idstilskhe$m$$mm;aEl$diidsd%issl6A$5&nih MK%kM1iiissiblaGA101W&lfs%?LCd% s.wb]n skxm~mpwwvam~ramwermmwm +qq das2 %s'ikk2UUA;4 $A5 ^ Value Score Who first identified the problem that was reported? (Select one) Utility 0 Magation -5 INPO / External -10 NRC 10 mmmm wemmeneswweuwwwmmwn~memnmmemwwmmmmmem-mmmmw ININ10$dbb1EhNNNNNs0;$NhDN[b1NJi!*5+nhNdEdI8NMNNikkhN;Nk$sssdhs);$2Ndib.hk SN;iNb'NN$IN[NNIA How was the reported problem identified? (Select one) Special self-ass,essment 10 Operational experience evaluation 10 Extent of condition evaluation 5 Work control practices 0 Testing 0 Plant incident assessment 0 Not specified / unknown 5 intemal audit -5 i Extemal audit -10 w v.ssw.,wwne mmenemwmmemmmwmmmm m mnmpgmw.mme .ih rw.:t:mudh.;ssmECincAudnCMcA hardiniha&umdssssb41db Was the reported problem evaluated properiy? (Select one) Yes O Partially or eventually 5 No -10 rpmgnmew mwa:ymuye-mumrwwww!U:::,wwwmngmeyse-m weew

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_.; wi......a.: & u.;aaet, M ::im g:a s&h:Acwsia. Mish .:c:.a: ? What was the cause of the reported problem? (Select all that apply) Random equipment failure O Personnel error -5 Proceduralinadequacy -5 1 Maintenance deficiency -10 i mmmu[ Design / fabrication / installation deficiency -10 ) r~ e - mgemmg w wgruvnnmxmennemswemmmmmmmr 1$$.M$4d44$23/$$Nd.U...,$ddiXdDL.$$dli.SEN4WIGAn4%&.M4=bdrisi[ilhi@'!JinNAL$EEE ~4$$M5N-fhSNEE;5SiU When was reported problem identified? (Select one) First opportunity 0 Second opportunity -5 Within a few chances -10 After numerous chances -20 wmm mpyrmepmmmmppppqymy;pmyyyymyg Page 1

v, fya:?g%?d1,W2.pb;O:Lsd(Z: Libs < Sd.kl,# %.L@ +.K! MdL Vk.'1 < & / i sh%.. lks.%Aw;0 ::(;gii;:&kinen@!.?;,., 4 / Plant: Event: Page 2 Date: Source: vm?m xwemem-mmmmmtwrwomn>ncmmpwnmmmm~n eenmsrw ewmne .:ikds$i+S$aEsjks%41&si$h$GWU3s:skkSlA5lik !$$$dld.Wdh$$1%5eki$$ASW5EliwkCSW.tb Mb$04GGWR$5hknn Had the reported problem previously occurred or previously been identified? No O Similar problem -5 Yes -10

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~m:w emmyrpmppmimwnenw nym %WL,(l'4%4MMb ~ AG%3 BOW}1&.vMb2 If yes, had corrective action been implemented? I n/a 0 Yes 0 Corrective action planned, but not comple?ed -5 4 No -10

A m an assa&mpmen m y rsy wynmg e y y a wa w enw m g m w m me -nw..m u,.c h moawgasazanwusamwssnawau mas c ug w yyeny nw if corrective action was iraplemented, did it adequately address the initial problem?

Na O Yes 0 No -10 m,. w ae w w w m m m m m...a.m.:.,mx;n-ew e.... m wr. e... m m er e'= 'm/'.....wrw. non : m. t .I .,: er v~ t' k. [ h N 4' Y n a* / # 2,. + ~. -. '. >.....d#dM* k n Y.-. l, m +i

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ported'%., pro'.")blem b"a'#4'e e'=. Yon res'olved?s' =d he' E k. '- s /..n'd [. ( Has' ' he re"w. Yes, with aggressive extent of condition investigation 10 Yes O Scheduled for resolution prior to restart from next refueling outape -5 Not yet -10 ewan..;m:pmm~ yn. + mm ~ wem -- wegmn.nym;ww w ~x u; < m:aa : k. J...: M G......%. n 2.....wi.:

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SCORE FOR THIS EVENT: 0 The reported problem involved: Only non safety related systems, structures or components (SSC) 1 Some SSC with function (s) that are important to safety 1.1 Safety related systems, structures, or components 1.25 Multiple safety related systems, structures, or components 2 OVERA. LL,SC.O,,RE FOR THIS EVENT: 0 ney gym egw w.7 c n ,.m m g mm,, 7 _.,,n,,.m, 5 4 Page 2

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g ......s w!. w;sn: Plant: Event: Page 3 Date: i S0urCG 1 M."lMM3"*~hMWilC"?GFv'yti'MWWlirt##R57'?"Yitl?%2B mMM57%5*WDMwnew'9%WM?WMM??wtMMW j ....,,,.,,,s.. . a awwa>s_....,,. u.....,..,,,.,:..,.a....,.. maanwrax u mw ummu, a:wwwaauwuwsu a,..,. ..,waa;.mww,.,>...,....,,...,u.n.,u. .,.,, w,u... a.az n~ wra as j .... Comments from this event evaluation: (A) (B) 9 h Yr. d -[ M' !-. f,k ',i' [,I,h: b.f * $f I: ,f ',f, M/ f f 'kkf "N h ]% (((% %

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id e 21:hidl424, siW$$d$i:Mitg&lj;;h!jb 5%d2;;&,&[N,QMz.y SjyfkNfuy"%:jQQjg55 m y -{% 2. kk :Evaluat,ed by: ,,,,,,,,;,,my, ,,,,, _,,,,,R_ev. _ my f f t Page 3 - -}}