ML20199C568
| ML20199C568 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/26/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| 50-361-97-99, 50-362-97-99, NUDOCS 9801300040 | |
| Download: ML20199C568 (9) | |
See also: IR 05000361/1997099
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AR LINGT ON. T E X AS 760118064
January 26,1998
Harold B. Ray, Executive Vice President
Southem California Edison Co.
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, Califomia 92674-0128
SUBJECT: RESPONSE TO COMMENTS RELATED TO NRC'S SYSTEMATIC
ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT 50-361/97
99;50 362/97 99
Dear Mr. Ray:
On August 26,1997, the Southern California Edison Company (SCE) provided docketed
comments in response to SALP Report 50 361/97-99; 50-362/97 99, dated July 29,1997, for the
San Onofre Nuclear Generating Station (SONGS), and requested that NRC reconsider the
Category 2 rating assigned to the engineering functional area. In the enclosure to this letter,
SCE indicated that performance in the engineering area during the past SALP period was
consistently and properly focused on safety and compliance to NRC regulations, and has
resulted in a superior level of performance. This conclusion was made on the basis of: 1) the
SALP process definition of Category 1; 2) the engineering strengths noted in the SALP report; 3)
an analysis of three performance issues noted in the engineering functional area discussion of
the SALP report; 4) engineering strengths noted in the NRC inspection reports that were issued
during the SALP period; and 5) other major engineering accomplishments.
The SALP Doard reconvened to consider the information provided in this letter, the Information
provided at the August 27,1997, SALP public meeting, the information provided relative to the
September 30,1997, predecisional enforcement conference involving inconel 600 nozzle
failures, and other relevant assessment data, in itu deliberations, the SALP Board also
considered whether the information provided by SCE affected its assessment of the
maintenance functional area because of the overlap of programs, processes, and activities
between the maintenance and engineering functional areas. .
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In the August 26,1997, letter, SCE provided its perspective on three performance issues
discussed in the engineering functional area of the SALP report. The three issues were the /
implementation of the Maintenance Rule, the implementation of the Improved Technical
Specification Program (ITS), and inconel 600 instrument nozzle failures.
With respect to the SALP report discussion of engineering support to maintenance (relative to
the Maintenance Rule), SCE indicated that: 1) there are two important elements for successful
implementation of the Maintenance Rule, which are an aggressive corrective action system and
consideration of risk insights; and 2) the SALP ,eport noted that SCE has an excellent corrective
actio program, and strong programs for utilizing probabilistic risk assessment and the Safety
Monitor. While these are two important elements, they are not the only critical attributes of
ensuring an acceptable Maintenance Rule program. As you know, the Maintenance Rule
9901300040 990126
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became effective during the SALP period in July 1996. Accordingly, processes and procedures
were developed in order to implement the rule. In the SALP Board's view, establishment of
effective performance monitoring criteria as part of the process is also an essential element of a
satisfactory program. The problems ioentified by the NRC during the SALP period involved the
inadequate establishment of performance monitoring criteria.
Southern California Edison Co. stated that the observations in the SALP report stemmed from
an assessment of the Maintenance Rule program performed by the SONGS Nuclear Oversight
organization, which may have been taken out of context. The SALP Board was aware of the
information in SCE's self assessment, which identified strengths and improvement areas.
However, the SALP Board assessed the information developed during an NRC indepenaent
inspection of various aspects of your Maintenance Rule pre jram. Two violations were issued as
a result of this inspection. While the NRC concluded that the violations were not indicative of a
programmatic breakdown, they were indicative of problems with the establishment of effective
monitoring enteria. A third apparent violation involving the failure to have goals and monitoring
requirements established for 13 SSCs was not cited because: 1) the undocumented goals for
these SSCs were to reattain their performance criteria; and 2) the existing corrective action
program was adequate to identify and correct the causes of failure. While no citation was
issued, the letter that transmitted the enforcement action noted that the reattainment of
performance criteria is not always appropriate, and specific goals for monitoring the
effectiveness of corrective actions were not established for the 13 affected SSCs. In response
to these violations, SCE indicated that a Maintenance Rule implementation Team, consisting of
inter-divisional middle managers, was formed to address project management concerns
associated with the SONGS Maintenance Rule Program.
We acknowledge that the SALP Board's primary concern related to prob' ems involving
acceptable performance monitoring criteria, rather than the failure to set goals and monitoring
requirements as noted in the SALP report. Accordingly, the SALP report has been revised to
better reflect this assessment. However, since SCE did not provide any information that was not
already assessed by the SALP Board, the SALP Board's original assessment in this area of
engineering performance remains unchanged.
With respect to the SALP report discussion involving project management of the ITS conversion
process, SCE indicated that: 1) SCE has been actively involved in ITS for 10 years; 2) site
management decided to limit engineering's involvement during the preparation and
implementation of the ITS on the basis of SCE's understanding of what the ITS was intended to
accomplish; 3) after engineering independently identified discrepancies, engineering led a
comprehnsive review of all Suweillance Pequirements, which the NRC noted to be superior;
4) corrective actions were comprehensive and thorough; 5) the review found several subtle and
longstanding deficiencies in surveillances; 6) nine of the 14 examples identified in Licensee
Event Report (LER) 2 97-001, Revision 3 were due to implementation errors unrelated to the
ITS; 7) there was no instance in which safety related equipment was not properly maintained or
was not capable of performing its intended safety function; and 8) this effort did not identify any
safety significant condition, and NRC Inspection Report 50 361/97-11; 50-362/9711 noted that
the examples identified by SCE had limited actual safety significance.
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The information summarized above is generally consistent with the SALP Board's assossment;
however, SONGS Engineering Assessment (SEA) Report 97-001, "Self Assessment
implementation of SONGS 2/3 Technical Specification Surveillance Requirements," documented
over 300 discrepancies between Technical Specification Surveillance Requirements and their
implementing procedures, rather than the several noted in the preceding discussion. Although,
NRC Inspection Report 50-361/9711; 50-362/9711 acknowledged the limited actual
significance of the individual examples, this conclusion was made on the basis of only a sample
of the more than 300 deficiencies, rather than a comprehensive review of all of the problems that
were documented in SEA 97-001 Further review of SEA 97-001 revealed a number of
potentially significant issues, which were not necessarily reportable to the NRC, and, therefore
not documented in LER 2 97-001. Also, SCE subsequently identified additional surveillance
implementation problems, which were not reported in GR 2 97-001 or not documented in SEA
97 001, such as the issue discussed in LER 2 97-016.
With respect to SALP report comment regarding SCE management missing an opportunity to
replace inconel 600 instrument nozzles, SCE indicated that the inspect and repair program for
reactor coolant system nozzle primary water stress corrosion cracking is consistent with industry
prctice, and SCE's Inconel 600 nozzle self assessment is an example of a self-critical approach
to providing the most comprehensive analysis possible to improve perfnrmance. Southern
California Edison Co. stated that NRC may have relied on this self assessment as confirmation
of its conclusions, and that SONGS Nuclear Oversight reports are self-critical and the context of
individual statements must be considered.
The SALP Board assesst.J the information that was developed as a result of NRC's
independent inspection of this matter, rather than the SCE's self-assesment report. However,
the SALP Board's assessment is fully consistent with SEA 97-002," Assessment of the
Inconel-600 Nozzle inspection & Replacement Program a. d Decision Process Leading to the
March 1997 Nozzle Failure in Unit 2," dated April 9,1997. This report concluded, in part, that
missed opportunities occurred,". . when a technical recommendation was changed from a
proactive nozzle replacement program to an inspect and-replace ap necessary strategy The
seconr1 missed opportunity occurred when a decision was made to continue with the inspect-
and replace as necessary strategy in lieu of a plan to perform anticipated repairs as well as
proactively replace some of the nozzles during the Cycle 9 refueling outage " While SCE
provided information regarding the bases for the decisions that were made, the SALP Board
concluded that no information was provided that would invalidate the SEA 97-002 conclusion
noted above. Accordingly, the SALP Board concluded that no change to this part of the
assessment was appropriate.
The enclosure of SCE's letter of August 26,1997, summarized a number of positive comments,
which were documented in NRC inspection reports that were issued during the SALP period. As
discussed in the Handbook to NRC Management Directive 8.6," Systematic Assessment of
Licensee Performance (SALP)," the SALP report is intended to document the Board's
assessment of the functional area in one or two pages, including a characterization of overall
safety performance for that functional area, it is not intended to detail all the inspection findings
that were documented in individualinspection reports during the SALP period. Rather the SALP
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Southem California Euson Co. 4-
report functional area discussions provide an overall assessment of performance in each of the
four functional areas, with examples discussed as appropriate. Inspection report findings
constitute a significant portion of the assessment data provided to the Board members in
preparation for the SALP Board meeting. Cc .antly, the SALP Board members had
available to them all the information docur,'er .n inspection reports, which included the
information summarized in the enclosure t SL.'s letter in balance with other information
j regarding performance of engineering activities at SONGS. Since this information was
assessed as part of the SALP process, the SALP Board concluded that SCE did not provide anv
new information in this renard.
With respect to other major engineering accomplishments that were summarized in the
August 26,1997, letter, several of these accomplishments were specifically noted as examples
of good performance in the SALP report in the appropriate functional area discussion. Many of
these accomplishments pertained to the resolution of hardware and other material condition
problems, which signific antly contributed to the Category 1 rating in the Maintenance functional
area.
On the basis of the preceding discussion, the SALP Board concluded that no change to
either the maintenance category rating or the engineering category rating was appropriate.
Specifically, overall safety performance was again assessed as superior in the maintenanca
functional area (Category 1) and Good in the engineering functional area (Category 2) ' i
reviewed this recommendation of the SALP Board and concur. Accordingly, the categ
ratings for the maintenance and engineering functional areas will remain as stated in SALP
Report 50 361/97 99; 50-362/97 99, dated July 29,1997,
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its
enclosure will be placed in the NRC Public Document Room.
Should you have any qu?stions or comments, I would be pleased to discuss them with you.
Sincerely,
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Ellis W. Mersghpff
Regional Adn9histrator
Docket Nos.: 50-361;50-362
License Nos.: NPF 10; NPF-15
Enclosure: Revised NRC SALP Report
50 361/97-99;50 362/97-99
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cc w/ enclosure:
. Chairman, Board of Supervisors
4 County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
,
i Alan R. Watts, Esq.
Woodruff, Spredlin & Smart
701 S. Parker St. Suite 7000
Orange, California 92868-4720 ,
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Sherwin Harris, Resource Project Manager
Public Utilities Department
City of Riverside
3900 Main Street
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Riverside, California 92522
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R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, Califomia 92674-0128
Stephen A. Woods, Senior Health Physicist
Division of Drinking Water and
Environmental Management-
Nuclear Emergency Response Program
California Department of Health Services
P.O. Box 942732, M/S 996
Sacramento, California 94334 7320
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Mr. Gary D. Cotton, Sr. Vice President
Energy Supply
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San Diego Gas & Electric Company ,
P,0. Box 1831
San Diego, California 92112-4150
'- Mr. Steve Hsu
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Radiological Health Branch
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State Department of Health Services
P.0, Box 942732
Sacramento, California 94234
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Mayor
City of San Clemente
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100 Avenida Presidio
San Clemente, Califomia 92672
Mr. Truman BumsWr, Robert Kinosian
Califomia Public Utilities Commission
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505 Van Ness, Rm. 4102 -
Sen Francisco, Califomia 94102
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Deputy Regional Administrator
Commissioner Dicus B. Henderson, PAO
Commiss:oner Diaz DRP
Commissioner McGaffigan SRis at all RIV sites
L. J. Callan, EDO (MS: 17 G-21) B. fLrray, DRS/PSB ,
Associate Dir. for Projects, NRR C. A. Hackney
Associate Dir. for insp., and Tech. Assmt, NRR
SALP Program Manager, NRR/lLPB (2 copies)
J. W. Roe, NRR, Director, Division of Reactor Projects Ill/IV
M. B. Fields, NRR, Project Manager
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DOCUMENT NAME: G:HOWELL/SONGSSAL. REB *Previously concurred
To receive copy of document, indicate in box:"C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy
ATHowell ll1 * JRoe* KEPerkins* EWMerschoff *
1/23/98 1/21/98 1/20/98 1/25/98
OFFICIAL RECORD COPY
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Branch Chief (DRP/TSS) M. Hammond (PAO, WCFO)
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The Chairman (MS: 16-G 15) Records Center, INPO
Commissioner Rogers (MS: 16-G-15) Deputy Regional Administrator
Commissioner Dieus B. Henderson, PAO
Commissioner Diaz DRP
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Associate Dir, for Projects, NRR C. A. Hackney
Associate Dir for insp., and Tech. Assmt, NRR >
SALP Program Manager, NRR/lLPB (2 copies)
J. W. Roe, NRR, Director, Division of Reactor Projects Ill/IV [
M. B. Fields, NRR, Project Manager
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DOCUMENT NAME. G:HOWELL/SONGSSAL. REB *Previously concurred
To receive copy of document indicats in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
ATHowell 111 * JRoe' KEPerkins' EWMerschoff *
1/23/98 1/21/98 1/20/98 1/25/98
OFFICIAL RECORD COPY
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EMCLOSURE
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NRC SALP REPORT
50-36'l97-99; 50-362/97-99
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[ AR LINoToN, T E X AS 760118064
July 29,1997
Harold B. Ray, Executive Vice President -
Snuthern California Edison Co.
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128-
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
REPORT 50-361/97 99;50-362/97 99
Dear Mr. Ray:
Enclosed for your review is the SALP report for the San Onofre Nuclear Ganerating Station,
Units 2 and 3 for the period of December 31,1995, through July 5,1997. A public ,
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' meeting to discuss this report with you and your staff has been scheduled for "
10 a.m. (PDT) on August 27,1997, at the Training and Education Center at the San
Onofre facility. During this meeting you are encouraged and expected to candidly
comment on our report. Although this meeting is a forum between Southern California
Edison and the NRC,it will be open to observation by members of the public and other
interested parties.
In accordance with NRC policy, I have reviewed the recommendations of the SALP Bocrd -
and concur with the ratings and views. The Maintenance and Plant Support functional
areas were assigned Category 1 ratings, reflecting superior safety performance, and the
Plant Operations and Engineering areas were assigned Category 2 ratings, reflecting overall
good safety performance.
Overall performance in ihe area of Plant Operations was good, with strong performance
noted during plant evolutions and improved performance noted during outages. Instances
of inconsistent performance related to operator attentiveness, procedure implementation,
communications, and control of field activities were noted.
In the Maintenance area, safety performan::e improved to a superior level due to
improvement in the overall material condition of the station, reduction in the problem
identification threshold, and the conduct of maintenance activities in the field. We
encourage your continued efforts to improve the plant material condition and to improve
performance in the areas of surveillance testing and welding.
Performance in the area of Engineering was good. Strong performance was noted in the
areas of corrective actions, self-assessments, and outage support, although inconsistencies
were noted with management oversight and quality of engineering support to certain
activities. Particularly strong performance was noted in the resolution of the degraced
steam generator tube supports (i.e., eggcrates) in Unit 3.
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Overall performance in the Plant Support area remained superior. Radiological protection ,
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. during.the steam generator chemical cleanirig activities was strong.
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Safety assessment and quality verification activities continue to be a strength at San
- Onofre. You have demonstrated strong self assessment performance by your line
organizations and the Nuclear Oversight organization,
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this let+er-
and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions or comments, I would be pleased to discuss them with
you. While no written response is required, you may provide written comments within
30 days of the public SALP meeting.
Sincerely, l
Original signed by
//s// i
Ellis W. Merschoff
Regional Administrator
- Docket Nos.: 50-361
50 362
License Nos.: NPF-10 - '
NPF 15
Enclosure:
NRC SALP Report
50-361/97 99:50 362/97-99
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cc w/ enclosure:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
Alan R. Watts, Esq.
Woodruff, Spradlin & Smart
701 S. Parker St. Suite 7000
Orange, California 92868-4720
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Sherwin Harris, Resource Project Manager
Public Utilities Department
City of Riverside
3900 Main Street
Riverside, California 92522
R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
Dr. Harvey Collins, Chief
Division of Drinking Water and
Environmental Management
California Department of Health Services
P.O. Box 942732
Sacramento, California 94234-7320
Terry Winter, Manager
Power Operations .
.
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, California 92112
Mr. Steve Hsu
Radiological Health Branch
State Department of Health Services
'- P.O. Box 942732'
Sacramento, California 94234
'
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, California 92672
Mr. Truman Burns \Mr. Robert Kinosian
California Public Utilities Commission
505 Van Ness, Rm. 4102
San Francisco, California 94102
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SAN ONOFRE NUCLEAR GENERATING STATION
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
Report 50-361/97 99; 50-362/97 99
l. BACKGROUND
The SALP Board convened on July 9,1997, to assess the nuclear safety performance of
San Onofre Nuclear Generating Station for the period of December 31,1995, through
July 5,1997. The Board was conducted in accordance with Management Directive 8.6,
" Systematic Assessment of Licensee Performance." The Board members included:
K. E. Perkins (Board Chairperson), Director, Walnut Creek Field Office, Region IV:
A. T. Howell, Director, Division of Reactor Safety, Region IV; and J. W. Roe, Director,
Division of Reactor Projects ill/IV, Office of Nuclear Reactor Regulation. This assessment
was reviewed and approved by the Regional Administrator.
Functional Areas and Ratings:
Current Previous
Plant Operations 2 2
Maintenance 1 2
Engineering 2 1
Plant Support 1 1
II. PLANT OPERATIONS
Overall performance in the Plant Operations area during this assessment period was good.
Operations performance during outages improved during this assessment period; however,
performance throughout the period was inconsistent. Management involvement in control
room oversight and programs for operations were generally excellent. Operators generally
performed well during transient and routine operations; although, they occasionally
demonstrated weakness in attentiveness, procedure implementation, communications, and
control of evolutions involving important field activities.
Management involvement in control room oversight was generally excellent, including
effective oversight of important activities. The strong management coverage of control
room activities during the refueling outages and reduced reactor coolant level conditions
contributed significantly to improved performance during the outages. Although
management oversight of operations activities was improved, control room supervisory
oversight of plant activities and performance by control room operators did not always
meet management's written expectations for conduct of operations. The performance
problems included exceeding the pressurizer cooldown limit and the inadvertent transfer of
refueling storage tank water to the reactor coolant system in Unit 2. Management
consistently took effective corrective actions for identified problems.
Programs for operations were generally excellent, including the programs for conduct of
operations and minimizing operator work-arounds. However, procedure quality and usage
problems were observed. Some procedures were very complex, contained transition and
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component identification errors, or were inconsistent with other guidance. - Procedere
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changes continue to be numerousi_ indicating a need for improved procedures; although,
the backlog of changes was being effectively managed. Weaknesses in procedure detail
contributed to the failure to properly position a reactor vent valve. in addition, weaknesses
in operation's verification"and validation of the Improved Technical Specifications (TS)
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contributed to problems discussed in the Engineering functional area. The corrective
actions taken to resolve these deficiencies were thorough and effective.-
The conduct of operations was generally good. Planning and preparation for most
operational activities was good. Operators generally followed plant procedures during
normal operations; however, operators occasionally exhibited weakness in attention to
detail. Examples of this include setting the automatic boric acid fiow rate low, the ;
mispositioning of several valves, and not verifying offsite power sources when an
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emergency diesel generator was inoperable. There were no reactor trips or other -
significant events and operators generally performed well during routine power operations.
Operation's performance of activities during outages was generally improved from the
previous period. Communications were generally good; although, they occasionally did not
conform to management expectations. Communications improved after management
attention to this area increased. Operations management consistently ensured that
appropriate corrective actions were taken in response to material deficiencies.and
procedural problems _ Plant and control board monitoring by operators was generally good;..
mithough, isolated lapses did occur.
- The operators performed'well during simulator training exercises. Some examples of weak
operator knowledge and skills were observed; including the failure to recognize a change in ' !
Unit 3 control element assembly position resulting in the upper electricallimit lights not lit
- and the failure to know the Unit 2 shutdown cooling flow limit applicable to the procedure
being execuud.- !
Licensee selfassessments continued to be a program strength. The use of metrics to
critically self assess performance'and to provide feedback on the extent to which
management expectations were met was a strength'. The assessment of valve lineup
performance problems, performed by the Nuclear Oversight Division, was excellent.
The performance rating in the area of Plant' Operations is Category 2.
Ill. MAINTENANCE
Overall performance in the Maintenance area improved to a superior level. The quality of
existing programs was maintained at a high level. While maintenance procedures were of
very good quality, there were some surveillance problems that stemmed from procedural
weaknesses. The conduct of maintenance activities was excellent, while the conduct of
surveillance activities was good. The overall material condition of the plant improved
throughout the assessment period. Self-critical assessments and root cause evaluations
contributed to improvement in this area.
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The quality of existing programs was maintained at a high level. For example, the steam
generator inservice inspection program was a noteworthy strength. However, as
discussed in the Engineering functional area, weak engineering oversight and support
resulted in the development of inadequate Maintenance Rule performance criteria for
structures, systems, or components and in the improperly scoped review of the improved
TS surveillance requirements.
Maintenance procedures were very good overall and the licensee initiated a comprehensive
plan to further enhance them. However, there were a number of surveillance
implementation problems, stemming in part from procedural weaknesses. Some of these
problems were attributed to procedural validation and verification weaknesses associated
with the implementation of the improved TS Licensee actions to' correct these
deficiencies were comprehensive.
The overall conduct of maintenance was excellent. Maintenance activities were well
planned and conducted in accordance with procedures by knowledgeable personnel.
Supervisors were frequently observed in the field providing oversight and guidance at job
sites. The performance of welding activities improved; however, some implementation
problems continued to be identified.
Surveillance and testing performance was good. Although not individually significant,
there were a number of surveillance implementation problems that occurred throughout the
assessment period. As discussed in the Operations functional area, many of these
problems were attributed to control room operator inattention and operations surveillance
procedure weaknesses.
The licensee continued to demonstrate a conservative approach to outage planning and
management. The work scope of the two 1997 refueling outages was well defined, and
the outage schedules appropriately incorporated risk-informed considerations. However,
reactor coolant system instrument nozzle leaks and other emergent hardware problems
caused significant unplanned delays during both 1997 refueling outages.
The material condition of the plant was improved throughout the assessment period
because of plant preservation and maintenance backlog reduction activities. There were no
reactor trips that were caused by hardware problems.
Efforts to encourage problem identification resulted in a significant reduction in the problem
identification threshold. Comprehensive, performance-based assessments were conducted
throughout the assessment period. The quality of root cause analyses, a strength noted in
the previous SALP, was maintained at a high level.
The performance rating in the area of Maintenance is Category 1.
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IV. ENGINEERING
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Performance in the Engineering area was good during this assessment period. Strong i
performance was noted ira engineering support to outages, self assessments, and corrective
action development and implementation. Management did not always provide the
appropriate level of oversight for engineering activities. Weaknesses were noted in the
support to maintenance and in the translation of design basis requirements into appropriate
operational requirements and surveillances. Superior performance was noted in the
resolution of complex engineering issues and in self assessment and corrective action
efforts,
Support to Maintenance and Operations during outage activities was excellent overall, with
timely evaluation of emerging issues and good technical support for planned activities. The
use of the safety monitor to plan maintenance activities optimized plant safety, as did the
( detailed risk assessments performed for each refueling outage. However, Engineering
support to Maintenance lacked rigor and thoroughness for one significant program, which
resulted in a failure to develop adequate performance monitoring criteria in accordance with
the Maintenance Rule.
The capability of the engineering organization to conduct complex engineering activities
continued to be superior. The efforts to resolve the degraded steam generator tube
supports (i.e., eggerates) in the Unit 3 steam generators were excellent. A comprehensive
strategy was developed to identify and address all relevant issues, and extensive technical
support for meetings with the NRC provided timely and accurate responses to staff
questions. Also, Engineering took a leadership role in identifying and resolving the
problems associated with the coaxial cable for the containment high range radiation
monitors.
Management oversight of engineering activities was inconsistent. Oversight weaknesses
resulted in inadequate control of some projects. The project management of the improved
TS conversion process did not properly scope the effort and engineering support was not
sufficiently rigorous to ensure all surveillance requirements were properly verified by the
implementing surveillance procedures. This resulted in a number of design basis
requirements that were not translated into appropriate operational requirements and
surveillances and in missed opportunities to identify severallong-standing surveillance
procedure deficiencies. Also, management missed an opportunity to replace inconel 600
instrument nozzles with a history of susceptibility to primary water stress corrosion
cracking. Conservative decisions related to plant safety included a commitment to perform
midcycle inspections of the steam generators in both units and the decision to request staff
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approval to add an inter-unit 4.16 kV bus cross-tie.
Self-assessment and corrective action activities continued to be superior, After discovery
of errors in the implementing procedures for the improved TS, a thorough review of eveiy
surveillance requirement and associated implementing procedure was performed. Other
notable activities during this assessment period included a detailed review of the Updated
Final Safety Analysis Report and a number of comprehensive root cause assessments of
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equipment malfunctions. The Independent Safety Engineering Group performed excellent
root cause assessments of industry events.
The performance rating in the area of Engineering is Category 2.
V. PLANT SUPPORT
Performance in the Plant Support functional area was maintained at a superior level
Performance in radiological protection was strong. Emergency preparedness effectiveness
remained a noteworthy strength. In the security area, overall performance was very good
and was improving during the latter part of the assessment period. The fire protection
program was effectively maintained and implemented. Housekeeping improved throughout
the assessment period. Audits and self-assessments were self-critical and performance-
based, and corrective actions were thorough and timely.
Performance in the radiological protection area continued at a high level. A comprehensive
as-low as reasonably-achievable program was implemented and functioned effectively to
maintain radiation exposures at a low level. Shutdown chemistry controls contributed to
exposure reduction results. Collective radiation exposure was less than the national
average during the assessment period. Good training was provided in all radiological
control areas and technical staff qua'ifications were a strength. Consequently, technical
reviews and analysis of information were excellent. Performance by radiation protection
technicians was good; however, a few problems were noted in the implementation of some
program areas. Strong programs were maintained in the solid weste management,
transportation of radioactive materials, radiological environmental monitoring, and
meteorological monitoring areas.
Radiochemistry and secondary chemistry programs were also effectively implemented.
There as a marked improvement in the reduction of radioactivity released in gaseous
efflut..ts between 1994 and 1996. Chemical cleaning of the Units 2 and 3 steam
generators resulted in the removal of large quantities of sludge and tube deposits.
Performance in the emergency preparedness area continued to be a program strength.
Operating crews performed in an excellent manner during simulator walkthroughs.
Emergency classifications, offsite agency notifications, and protective action
recommendation formulation were correct and timely. Internal communications and
procedural usage were effective. Emergency response facilities and equipment were j
operationally maintained; however, the program for control of emergency lighting permitted
some safe shutdown emergency lighting to become ineffective.
Overall performance in the security area remained very good and improvements were noted
during the latter part of the assessment period. Program strengths included records and
reports, security plan changes, management support, security organization, training and
qualifications, and access authorization. Some isolated problems involving security
procedures, the land vehicle barrier system, lock and key control, and protected area
barriers were ioentified.
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The fire protection program continued to be effectively implemented. The dedicated,
on-site fire department provided a strong, well trained, and effective fire response
capability. Systems were appropriately tested and well maintained. A fire protection
innovation team maintenance program was initiated to reduce the fire protection
maintenance backlog.
Overall, plant housekeeping was welt maintained and continued to improve throughout the
assessment period. Radiological housekeeping was good, with some minor exceptions
noted.
Self assessment activities were effective at identifying problems, and corrective actions
were comprehensive and timely. In one instance, the quality assurance audit of the
security program was not of sufficient scope.
The performance rating in the area of Plant Support is Category 1.
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