ML20197H642
| ML20197H642 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/22/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20197F278 | List: |
| References | |
| 50-498-97-99, 50-499-97-99, NUDOCS 9712310340 | |
| Download: ML20197H642 (7) | |
See also: IR 05000498/1997099
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SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
Report 50-498/97 99: 50 499/97 99
1. BACKGROUND
The SALP Board convened on November 19,1997, to assess the nuclear safety
performance of the South Texas Project for the period March 24,1996, through
November 15,1997. The Board was conducted in accordance with Management
Directive 8.6, " Systematic Assessment of Licensee Performance." The board members
included: T. P. Gwynn (Board Chairperson), Director, Division of Reactor Projects:
D. D. Chamberlain, Deputy Director, Division of Reactor Safety; and J. N. Hannon, Director,
Project Directorate ill 1, Office of Nuclear Reactor Regulation. This assessment was
reviewed and approved by the Regional Administrator.
Eunctional Areas and Ratinas .
Current Previous
Plant Operations 1 2
Maintenance 1 1
Engineering 2 2
Plant Support 1 1
11. PLANT OPERATIONS
Overall performance in the operations functional area improved and attained a superior
rating. Management oversight and supervisory presence in the plant were effective,
resulting in conservative decision-making and contributing to the organization functioning
well as a team. An excellent safety focus was maintained throughout the organization.
Routine and nonroutine activities were performed well, although equipment clearance-
orders needed management attention. Operator performance improved with superior
operating practices being the norm. Emergency operating procedures were properly
implemented. The training organization continued to thoroughly train, evaluate and critique
operating crews, contributing to the professional response of the operators to plant events.
Some examples were noted where the training staff lacked an understanding of NRC
requirements. Self-assessments were effective in improving operational performance.
Management involvement and oversight were effective and resulted in conservative
decision-making and excellent safety focus. This was particularly evident in the decision to
take Unit 2 off-line to repair an iso-phase bus duct boot following restart from the fifth
refueling outage. Management support of site activities was evident at alllevels.
Additionally, a strong sense of teamwork permeated the organization. Supervisory
presence in the plant continued to increase the staff's awareness of management
expectations.
Procedural and administrative controls governing plant operations, refueling activities, and
reduced inventory operations were excellent. Reduced inventory operations conducted
- during the latter half of the assessment period showed marked improvement. Containment
closeout inspections performed during the latter half of the assessment period were
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thorough and provided assurance of containment recirculation sump operability. Shift
turnovers and pre-evolution shift briefs were thorough and professional, contributing to the
effective and efficient operation of the units. However, instances of inadequate equipment
clearance orders and improper use of equipment clearance orders to implement de facto
procedure changes were identified, indicating the need for increased management attention
to this performance area.
Operators performed well during routine activities. Operator attentiveness to the plant,
formality of operational practices, and professionalism were notable. Excellent
communications continued to be a strength. Self verification was routinely observed, and
operators properly implemented the requirements of operating and surveillance procedures
with few exceptions. Operator response to plent perturbations and transients resulted in
safe and effective control of the units. This was particularly notable in the response to a
f ailed open moisture separator reheater relief valva. Supervision, communications,
coordination of operational activities across the organization, alarm response, and
implementation of emergency procedures were all strengths.
The material condition of plant equipment wcs excellent. The reliable oper3 tion of
equipment in response to plant events and the small number of restraints to plant restart
after trips were clear evidence of the excellent material condition of the plant. Systems
were routinely found properly aligned and safety equipment availability was high. However,
some examples of problems during the manipulation of controls and components were
noted. This was particularly evident in the inadvertent manipulation of the wrong valves
which resulted in the loss of level control for the volume control tank and, in another
instance, for the spent fuel pool. These remote, manually-operated valves were later found
to have inadequate position indication.
Operator training remained very effective with thorough evaluations and good crew
critiques. Previous training program weaknesses had been corrected. Critiques were
instrumentalin focusing attention on areas for performance improvement. Training
provided strong support to operations and was routinely involved in preparing the operating
staf f for infrequently performed evolutions. This was particularly evident in the
preparations for a major control room modification that was to be perfort ;n-line. The
quality of operator training was reflected in the professional response of tne operators to
plant perturbations and events. Notwithstanding this high level of training performance,
there were three examples of a lack of understanding of NRC requirements by the training
staff during the assessment period. These involved the f ailure to provide requalification
training to a licensed senior reactor operator with an inactive license, the submittal of poor
quality examination materials to the NRC, resulting in a necessary delay in the
administration of initiallicense examinations, and erroneously exempting the staff involved
in developing examination materials from taking requalification examinations.
A strong self-critical assessment process was evident in the operations functional area.
Both the regu%r feedback & the operating organization and the relatively high level of self-
identification and correction of problems demonstrated this. The condition reporting
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process was effectively used with a low threshold for problem identification. Nevertheless,
several events were caused, in part, by incomplete or inadequate corrective actions to
similar events, indicating additional opportunities to improve in this area. Examples
included the repetitive problems with control of spent fuel pool level and the repeat loss of
reactor coolant system level instrumentation during reduced inventory operations.
Overall performance in the Plant Operations functional area was rated Category 1.
Ill. MAINTENANCE
Overall safety performance in the maintenance functional area continued at a superior level
during this assessment period. Effective management oversight was frequently evident
with conduct of maintenance activities. Outage planning and execution was superior.
Maintenance backlogs were effectively controlled, including the emphasis on control room
annunciator and inttrument deficiencies and any conditions requiring special astention by
plant operators. Very few equipment problems caused plant challenges during the
assessment period and, for those challenges or transients that did occur, plant and
equipment response was excellent. Management and staff continued to take an aggressive
approach to resolving equipment deficiencies. The licensee had achieved and was
maintaining an outstanding material condition at the facility.
Senior management support of maintenance activities was outstanding and conservative
safety conscious decision making was routinely demonstrated in addressing plant and
equipment problems. The licensee's approach to addressing the control rod insertion
problems was indicative of the overall safety conscious approach to issues. Maintenance
programs and implementation were strong, with maintenance planning and scheduling
particularly notable and maintenance schedule adherence high. Problems identified by the
licensee demonstrated a continuing emphasis on assuring quality procedures. Program and
procedure problems were addressed promptly when identified. Maintenan::e personnel
routinely demonstrated a thorough understanding of tasks to be performed. Examples of
isolated problems with maintenance implementation included the identification that
maintenance personnelleft three plastic bags containing equipment in containment and the
f ailure to isolate the component cooling water supply to the residual heat removal pump for
disassembly of the pump.
Outage planning and execution was superior. The "one-stop shopping" concept utilized to
f acilitate and coordinate outage activities was particularly noteworthy and effective.
Licensee control of on-line maintenance activities was effective, including outstanding
utilization of risk insights with well developed risk program tools provided to the plant staff.
Licensee use of equipment mockups was particularly noteworthy for complex maintenance
activities as demonstrated by the activities associated with the control room f acility
upgrades.
The surveillance program and procedures were generally of high quality. Sumellance
program implementation was generally strong, with only a few performance problems that
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were usually identified and corrected by the licensee. Program and procedure problems
were addressed promptly when identified. Licensee actions in response to Generic
Letter 96-01, Testing of Safety Related Logic Circuits, were effective in identifying and
correcting procedure problems.
Trainin0 and qualification of . maintenance and surveillance personnel was a strength.
' Utilization of strong on the job training techniques were noted during observation of
maintenance activities. Formal training programs were strong and the licensee effectively
utilized equipment mockups for training and pre-job planning. Personnel performance errors
were few and not indicative of training or qualification deficiencies. Self assessment and
corrective action processes in the Maintenance area were strengths, with the licensee
utilizing both internal and external assessments to identify areas for improvement.
Utilization of the condition report process to self identify and correct problems was a ,
notable strength.
Overall performance in the Maintenance functional area was rated Category 1.
IV. ENGINEERING
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Overall safety performance in engineering was very good. Engineering support to other
organizations was generally strong and particularly noteworthy in systems engineering, The
engineering workload was generally well managed. Engineering programs were generally of
high quality and were being executed effectively. Of particular note was the continued strong
use of probabilistic risk assessment in support of the plant. However, deficiencies related to
corrective actions for set point problems, the proper control of calculations, and condition report
classification s,t the appropriate condition adverse to quality threshold within the design
engineering organization detracted from otherwise strong engineering performance.
System engineering support for operations and maintenance was generally thorough, timely and
conservative. Engineering and safety evaluations were generally of excellent quality. Examples
included review and development of corrective actions related to a bound control rod drive
mechanism and a seal leak of containment Spray Pump 1B, as well as the inspection of an
essential cooling water system annubar flow element to evaluate long-term performance.
System engineers were knowledgeable of their systems, had good communications with other
. plant disciplines, and readily identified plant problems. The_ operability implications of degraded
plant conditions were satisfactorily' addressed, with few exceptions.
The excellent use of probabilistic risk assessment (PRA) insights identified during the last SALP
period continued into this period and matured to a high level. Several industry leading initiatives
took place: PRA insights were used to support an application for extending the allowed outage
times for the standby diesel generators, and PRA insights effectively supported the graded
quality assurance program' application. Both appications were approved by NRC during this
SALP period in addition, PRA insights were being used effectively to monitor plant performance
on a day 4o-day basis and for scheduling and planning purposes
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The training program for engineering personnel continued to be strong. In addition to position
specific and general continuing training, approximately 50 engineers have been Senior Reactor
Operator (SRO) certified.
Management effectiveness and focus on safety were mixed. Management provided the proper
safety focus in dealing with the phenomenon of incomplete control rod insertion. Bumup in
rodded fuel assemblies was iimited, periodic rod drop tests were performed, analyses to support
continued safe operation were performed, and a fuel design change was made. In addition,
support for the condition reporting and corrective action program was evident, and the program
effectiveness continued to improve over the SALP period, in general, condition reports were
thorough and the corrective actions adequate to prevent recurrence. Engineers were
knowledgeable of the corrective action program and confident in its use. Industry operating
experience information was appropriately disseminated and reviewed, and appropriate
corrective action was taken. However, notable exceptions were identified where the corrective
action process was not effectively implemented. One significant exception noted early in the
SALP period involved leakage from the safety injection system outside containment that was not
evaluated until questioned by the NRC. The initial engineering evaluation of this adverse
condition failed to address the design basis aspects of the leakage. Another exception occurred
where timely corrective action was not taken for setpoint problems. Further, engineering
management had not provided sufficient resources for design engineering to have the proper
modeling tools to maintain the design calculations for electrical load studies. NRC involvement
was also needed during this SALP period for design engineering to focus on the design of the
advanced liquid waste processing system. When it was installed in 1992, it replaced portions of
the original processing equipment without clearly meeting the associated Updated Final Safety
Analysis Report commitments and without a documented safety evaluation.
The quality of design engineering was mixed. Design change packages, engineering
evaluations, and 10 CFR 50.59 safety evaluations were generally of excellent quality. Examples
include changes to the qualified display processing system, replacement of a thimble tube fitting,
and the addition of storage racks inside Unit 1 containment. However, there were some
weaknesses in design engineering. For example, the control of calculations for electrical,
mechanical, and instrumentation and control design bases needed improvement. In addition, as
a result of a programmatic weakness, there was not a procedural requirement to evaluate
calculation changes for impact on the Updated Final Safety Analysis Report.
In the area of self assessment and quality verification, performance was good, but selected
areas needed improvement. Effective corrective action was taken for the deficiencies noted in
the previous SALP report. The self-assessment of engineering identified some adverse
conditions; however, there we:e examples where the resulting corrective action was too
narrowly focused. For example, the corrective actions for molded case circuit breaker sizir.g
only assured that the circuit breaker in question was properly s!2ed and did not verify that other
similar circuit breakers were also properly sized. In another instance involving a problem with
essential chiller insulation degradation, the licensee did not assess the adequacy of corrective
r ctions for prev!ous similar condition reports. There were other instances where management
was not effective in assuring that design engineering condition reports were correctly classified
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at the appropriate condition adverse to quality threshold. For example, set point calculation
deficiencies, which were identified by the licensee in 1992 and again in 1995, were not identified
as conditions adverse to quality in tha> condition report system. In ancther instance, a potential
nonconservatism in the auxiliary feedwater storage tank useable volume instrument uncertainty
calculation was not identified as a condition adverse to quality. Consequently, effective
prioritization for corrective action was not always accomplished. Strengths were noted in the
steam generator replacement program and in the quarterly oversight planning and scheduling
process. Corrective actions resulting from the cuality assurance quarterly monitoring reports
were generally appropriate.
Overall performance in the Engineering functional area was rated Category 2.
V. PLANT SUPPORT
Overall performance in the Plant Support area continued at a superior level. Performance in
the radiological controls area was superior, with excellent support provided for plant
activities and only isolated performance problems noted over the assessment period.
Security performance continued to be outstanding, with plant and equipment upgrades
significantly improving capabilities over the assessment period. Emergency Preparedness
performance continued at the superior level attained during the previous assessment period
with a notable commitment to excellence dernonstrated by the entire organization.
Housekeeping was outstanding over the assessment period and the fire protection program
continued to be effectively implemented. Self assessment and corrective action
effectiveness were strong, routinely resulting in early identification of problems and
elimination of recurring problems.
Superior performance in the radiological controls area continued during the assessment
period. Radiation protection personnel provided excellent support for routine plant activities
and outage activities. An excellent ALARA program maintained the 3-year average person-
rem exposure among the top performers in the industry. Control of radioactive materials,
surveys, and personnel monitoring were excellent. Isolated problems were usually
identified by the licensee and timely and etfective corrective actions were implemented.
Superier performance was noted in the chemistry, radiological waste effluents
management, radiological environmental monitoring, solid radioactive waste management,
and transportation of radioactive materials programs. Training and qualification programs
for the staff were excellent and effectively implemented. Qualifications and technical
expertise of the staff remained at a high level.
Superior oerformance was noted in the physical security, access authorization, and fitness-
for duty program areas. Senior management support for the security program continued to
be outstanding. Plant and equipment upgrades in the security area provided notable
improvements in capabilities over the assessment period and significantly enhanced the
ability of the security organization to perform at a superior level. The design and
installation of the vehicle barrier system was excellent. The new video assessment system
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and tiie badge / hand geometry access system significantly enhanced program performance.
, Training and qualification programs were effective, with excellent facilities provided.
- Emergency Preparedness performance continued at the superior level achieved during the ,
previous assessment period, demont,trating a high level of commitment to excellence and
teamwork b/ the entire organization.' Crew performance during simulator walkthroughs
was excellent. The overall performance during the biennial emergency preparedness
exercise was excellent, with only one weakness identified related to recotective measures
for offsite field monitoring teams. Strengths were identiflod related to exercise control and
the critique process. The emergency plan, procedures, and facilities were appropriately
maintained. Training and qualification programs were strong, with personnel demonstrating
a high level of knowledge regarding changes to emergency implementing procedures.
Housekeeping was a notable strength and was considered outstanding over the assessment
period. The fire protection program continued to be effectively implemented. Self.
assessments and corrective action processes in the Plant Support area were strong.
Critical self assessments and audits along with effective problem identification and
correction routinely resulted in early identification of problems and elimination of recurring
problems. ,
Overall performance in the Plant Support functional area was rated Category 1.
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