ML20148B845
| ML20148B845 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/08/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148B808 | List: |
| References | |
| 50-482-97-99, NUDOCS 9705130388 | |
| Download: ML20148B845 (6) | |
See also: IR 05000482/1997099
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, SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT
j WOLF CREEK GENERATING STATION ,
50-482/97-99
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- i. BACKGROUND
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The SALP Board convened on April 9,1997, to assess the nuclear safety performance of
the Wolf Creek Generating Station for the period October 8,1995, through April 5,1997.
i The Board was conducted in accordance with Management Directive 8.6, " Systematic
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Assessment of Licensee Performance " The Board members included: K. E. Brockman, i
. Deputy Director, Division of Reactor Projects (Chairperson); A. T. Howell, Director, Division
, of Reactor Safety; and W. H. Bateman, Director, Project Directorate IV-2, Office of Nuclear
i Reactor Regulation. This assessment was reviewed and approved by the Regional
I Administrator.
! Functional Areas and Ratinas
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Current Previous
Operations 2 1
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Maintenance 2 2 ;
Engineering 3 2 .
Plant Support 2 1
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II. OPERATIONS
Overall safety performance in the Operations area declined during this assessment period.
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Plant operations during routine activities and noncomplex events were generally good. No
reactor trips were directly attributable to operator errors during this assessment period;
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- however, operator errors did complicate the plant response during the January 1996 frazil
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ico event. In addition, instances of minor procedural violations and attention to detail were
experienced throughout the assessment period. While operators continued to focus on
, maintaining an overall high level of control room material condition,- they accepted a
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number of inappropriate Technical Specification clarifications. They also accepted and
developed numerous poorly supported or poorly documented operability determinations.
j Overall, operator training performance remained satisfactory. Corrective action
effectiveness continued to be a problem area during this period.
Professionalism in the control room remained strong, and operator performance during
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routine and noncomplex events was generally good. This was demonstrated during the
F plant trip caused by a partial loss of feedwater. However, throughout the SALP period,
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operators continually committed minor errors involving procedure implementation, log
taking, and equipment configuration control. Individually, these instances were of little
i safety significance, but together they indicated continuing lapses in attentiveness and
, concern for detail.
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, Although the operators placed and maintained the plant in a safe, stable shutdown
i condition following the frazilice event, there were several operator performance problems
- and procedure deficiencies which complicated the overall response. As in the case of the
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drain-down event of the previous assessment period, some of these problems indicated i
- weaknesses in operator system knowledge and deficiencies in procedure compliance and ;
command and control practices during complex events. :
Operators continued to demonstrate a high degree of ownership ~ of control room material !
condition deficiencies. The number of inoperable main control board annunciators was
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maintained at a low level throughout the assessment period.
Training of the operations staff was satisfactory; however, some operator performance :
problems during the frazilice event were attributed to apparent training weaknesses. The l
licensee's operator requalification program was effectively implemented. Complex ;
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simulator scenarios and the performance of the instructors during simulated emergency
preparedness exercises were especially effective training initiatives. j
The licensee typically derconstrated an appropriate level of management oversight and a
good safety focus. Shift supervisors usually demonstrated a questioning attitude and .
conservative decision making. Operations management, however, failed to take effective 5
corrective actions for, and allowed to remain in place, a number of inappropriate Technical l
Specification clarifications which conflicted with the operating license. in addition, j
operators initiated and accepted a number of poorly supported and poorly documented ;
The operations department completed a number of self-assessments, and the corrective I
actions for past problems (e.g., clearance orders) were effective; however, ineffective
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corrective actions were identified in other areas throughout the assessment period. :
Additionally, there were several examples of weak root cause evaluations. Recently, the ]
licensee's review of corrective actions related to significant Problem Identification Requests
has improved; however, sustained improvement.was not demonstrated by the end of the I
assessment period.
The performance rating in the operations functional area was determined to be Category 2.
Ill. MAINTENANCE
Overall safety performance in the Maintenance area was good. However, the recurrence of I
previously identified problems detracted from overall effectiveness. The material condition
of the plant was very good; however, problems with the auxiliary feedwater system were i
evident throughout the assessment period. Craft personnel demonstrated good individual
skills, but there were severalinstances of nonadherence to procedures. This was
compounded by the identification of numerous minor deficiencies in surveillance
procedures and a lack of clarity in work instructions. Planning and scheduling
effectiveness improved significantly, but the risk associated with emergent work was not
always properly considered. Audits and self assessments of maintenance activities were
appropriate, but the implementation of effective corrective actions was inconsistent.
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The overall material condition of plant systems, structures, and components was very !
good. One plant transient, a reactor scram which resulted from a f ailure of a feedwater
valve stem, was initiated by a material condition failure. Altogether, this was evidence of
an effective preventive maintenance program and the proper implementation of high risk
surveillances. In contrast, continuing problems were experienced with the auxiliary
feedwater system. This was most evident when, during the frazilice event, the turbine
driven auxiliary feedwater pump packing failed and the pump had to be declared ,
inoperable. j
The skills of the various craft personnel remained an area of strength. However, as was i
noted in the previous SALP report, there were numerous instances in which individuals
failed to adhere to procedural guidance. This resulted in examples of work being
performed beyond the scope allowed and in maintenance activities being improperly
conducted. Additionally, there were several examples of inadequacies in surveillance
procedures, which resulted in some tests being missed and others being improperly
conducted.
During this assessment period, the planning and scheduling of work activities improved
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significantly. This was evidenced by the increased effectiveness of the weekly work
schedule and the reduction in the overall work backlog. Risk was integrated into both the
planning and implementation of maintenance tasks. Human-factors enhancements were
instituted to increase the awareness of the staff to know which was the " protected train."
However, while the process for considering the effects of risk on emergent work activities
was in place, its effectiveness was limited and the " protected train" concept was not ;
always maintained.
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Quality surveillances and audits and organizational self-assessments were inconsistent in
effecting change within the maintenance functional area. While the licensee continued to
be effective in identifying problems, there were several occasions where effective
corrective actions were neither developed nor implemented. This was exemplified by the
repetitive instances of procedural nonadherence and the long-standing difficulties t
associated with the auxiliary feedwater system.
The performance rating in the maintenance functional area was determined to be
Category 2. .
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IV. ENGINEERING
Performance in the engineering area declined during this assessment period. The support to
both the operations and maintenance functions was inconsistent. Problems were identified
l .with the accessibility of design basis information. Consistently comprehensive !
l 10 CFR 50.59 evaluations were not conducted. Additionally, there were numerous
l examples where corrective actions developed in response to identified problems were not ;
thorough and, therefore, did not completely resolve the associated issues. Management
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implemented initiatives to address the performance decline, out results ha.d not been
i observed prior to the end of the SALP period. ,
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Support to operations of ten lacked rigor and comprehensiveness. Operability evaluations
during the frazilice event did not provide rigorous technical bases to support operability
determmations, in addition, engineering had numerous opportunities prior to the event to
identify and correct the inherent design errors with the essential service water system '
warming lines. Weak operability determinations continued throughout the assessment
period; however, improvement was noted during the last 6 months. I
Support to maintenance was also inconsistent and contributed to instances of equipment 1
! inoperability and unavailability. The engineering support provided to resolving the auxiliary '
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feedwater pump problems was especially poor and resulted in questions concerning the
acceptability of the pumps' packing, bearings, and lubricating oil system. Incompleteness
in the engineering support associated with the feedwater regulating valves resulted in
improper material procurement and a subsequent valve failure. This failure resulted in an
unplanned reactor trip.
During the assessment period, it was discovered that design basis notebooks were no
longer being controlled or maintained up-to-date, in addition, design information was not
being maintained in any centrallocation. While design and vendor information was
available, there was difficulty in retrieving this information in a timely manner, and this j
difficulty was a contributing factor to the problems identified in supporting the operations
and maintenance functions.
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Weaknesses were also noted in the implementation of the 10 CFR 50.59 process. For
example, when the inspection frequency of the reactor coolant pump flywheel was
changed, the 50.59 review did not identify the requirements for the inspection. This led to
a violation of the Technical Specifications. In addition, Technical Specification
clarifications were found in use which had been reviewed using a 50.59 type of process. ,
, The guidance in several of these clarifications was in direct conflict with the Technical l
Specifications, and some had actually been implemented. Engineering participated in their
development and approved them as a member of the Plant Safety Review Committee.
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The most significant shortcoming in the engineering area was the organization's failure to
resolve identified problems. Throughout the assessment period, problems occurred or
recurred that should have been precluded as part of the corrective action process for
previously identified problems. Engineering's f ailure to properly identify the vulnerabilities
of the essential service water system warming lines was one example. The failure to
ensure the procurement of proper roll pins for the feedwater regulating valves was another.
A third example was the failure of engineering to properly identify the noncompliance of
the Technical Specification clarifications, even after they had been questioned by a quality
audit.
During the latter stages of the assessment period, performance deficiencies were
recognized and initiatives were put in place to improve performance. A program to assure
accountability for quality of engineering work products was implemented. A Corrective
Action Review Board was chartered to assure that root causes were correctly identified
and that corrective actions were broadly applied. Specific training was scheduled to
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upgrade the quality of root cause analyses. The long-term results of these initiatives has
not yet been demonstrated and, therefore, it is too early to draw any conch , ion as to their
effectiveness.
The performance rating in the engineering functional area was determined to be
Category 3.
V. PLANT SUPPORT
Overall safety performance in the plant support area was good, having declined from its
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previous superior level. Radiological controls' performance declined slightly as a result of
, repetitive performance problems. In the emergency preparedness area, although biennial
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exercise weaknesses identified during the previous assessment were corrected, multiple
l problems, some of them repetitive, continued to be identified. Performance in the security
j area was maintained at a high level. Housekeeping remained excellent overall.
in the area of radiological controls, overall performance was good. Excellent performance
was noted in the areas of radiological environmental monitoring, solid radioactive waste
management, and transportation of radioactive materials. A generally good radioactive
effluent program was implemented by the chemistry organization. The control of
radioactive materials, surveys, and personal monitoring was good. The reduction of the
3-year person-rem average indicated an effective as-low-as-is-reasonably-achievable
program, which was strongly supported by management. There was a significant
reduction in personnel exposure during the 1996 refueling outage. However, multiple
implementation problems involving postings and barriers of high radiation areas,
radiological work practices, contamination controls, and control of radiography indicated a
decline in radiological protection technician and radiation worker performance. The
repetitiveness of these errors also indicated less than fully effective corrective actions.
Performance in the emergency preparedness area was generally good, but there were a
number of implementation problems. Emergency response facilities were properly
maintained, and the functionality of the backup emergency response facilities was
improved. Emergency preparedness training was satisfactorily implemented, and
emergency plan implementation during the simulator walk-throughs was generally good.
However, corrective action weaknesses were identified in a number of areas. Failures to
effectively communicate and assess available information resulted in delays in emergency
action level determinations during the 1996 frazilice event and during the 1997 biennial
exercise. Ineffective corrective action implementation stemming from the frazilice event
resulted in an inadvertent reduction in emergency planning effectiveness and contributed to
an exercise weakness during the simulator walk-throughs.
The security program continued to perform at a high level, with strong senior management
support being evident. The security training program, assessment aids, records and
reports program, access authorization program, and land vehicle barrier system were
assessed as excellent. An effective compensatory measures program was implemented
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and, as a result of effective maintenance support, compensatory postings for identified
j problems were minimized. A good program for searching personnel, packages, and
vehicles was implemented,
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General plant housekeeping was excellent overall. Radiological housekeeping was
j assessed as good.
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The effectiveness of self-assessments and corrective actions was mixed. The self-
1 assessments of the radiological controls programs were good; however, corrective actions
- were neither timely nor effective in preventing the recurrence of all performance
deficiencies. Late in the assessment period, a comprehensive plan to review and improve
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the radiological protection program was initiated. The scope of the security audit did not
i include three program areas, and corrective actions in the emergency preparedness area
were not fully effective in correcting communication weaknesses that were evident during
this and the previous assessment period.
The performance rating in the plant support functional area was determined to be
Category 2.
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