ML20204C749
| ML20204C749 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Millstone, Peach Bottom, Salem, Indian Point  |
| Issue date: | 12/13/1977 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20204C753 | List: |
| References | |
| NUDOCS 7812050004 | |
| Download: ML20204C749 (12) | |
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' MEMORANDUM FOR: H. D. Thornburg, Director, ROI,-IE:HQ- I s
FROM: B. H. Grier, Director, RI, IE
SUBJECT:
LICENSEE PERFORMANCE EVALUATION (AITS fF10698F1).
References:
- 1. Memorandum, Thornburg to Region Directors, dated November 23.E1977, same_ subject. .
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- 2. Memorandum, Thornburg to E. Volgenau, . dated November :j 8, 1977, same subject. '
This- memorandum provides information for.. Indian point, . Millstone 1, and . 1 peach Bottom as requested by Reference 1. Answers to items 1 through 4 !
of' Enclosure 1 to your memorandum are attached .for each of these facilities.
Region:I does not have any other facilities at this time which we con- q' sider to have an abnormal performance record; however, we are' striving: .
to improve the performance record .of most of our facilities. In particular, we are carefully evaluating the performance of Salem 1 and Beaver Valley i 1 ~, since they are having many operating problems. Each of~these is a relatively new facility and'we dc.not believe:that escalated enforcement action is indicated at this time.-
I With respect to question 6 of Enclosure 1, we obviously have not given i this as much thought as you-'and others have. The factors listed in item j 3 b of Reference 2 appear appropriate. To these, we would add 'a formal qualitative evaluation by certain inspectors and their immediate supervisors.
As you obviously realize the identification and weighting.of the proper factors which nake up performance evaluation are extremely difficult.~.
c In fact, developing a statistical methodology for such evaluations may
- be so difficult that it does not justify the effort. A statistical 3
approach requires that different facilities with different requirements 4 somehow be reduced to a co m n basis. We continue to believe that there is such a difference among facilities in license requirements and commitments, i facility complexity and inspection uniformity that comparing them on a -
, common basis will be a major task. The end result may be no better and
.perhaps not as" good as would be accomplished by involved IE management performing qualitative evaluation 3 and taking escalated actions to-improve poor performers. We believe the discussion given in Enclosure 1 .
to this memorandum shows how Indian Point is-being improved by this )
'latter technique.
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Me'morandum'for H. D. Thornburg 2 13 DEC 1977 We do not imply by this discussion that your efforts tcward performance evaluation should be discort'= ued. In fact we believe resources should be applied to it. We do re tend that progress be periodically assessed and the efforts be terminato f real results are not obvious in about one year.
If you desire to further discuss the information contained in this memor-andum, please contact us.
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I/ Yoyq'u H. Grier i
Dir(ctor cc: J. G. Davis L. I. Cobb -
J. P. O'Reilly J. G. Keppler E. M. Howard R. H. Engelken
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1 TDEC 1977 l I
. ENCLOSURE 1" j.
LICENSEE PERFORMANCE EVALUATION OVESTIONS - INDIAN POINT-
- 1. From the data.evalua'ted Indian Point appears to exhibit performance'
.which deviates from the norm. Provide your analysis'as to why the l
i performance of Indian Point appears to stand apart from' the other !
facilities.
Probleis were identified at. Indian. Point Station in"s'everal . areas.
over the past two years-which resulted in many Items of Noncomp1.1- i ance and-intensified inspection activities. Additionally, a civil' ;
penalty was issued as a result of the April 1976 overexposure of a. 1 worker at Indian l Point 2. These facts account for why a data bankL on inspection activities'would flag' Indian Point performance as - -
less than what would normally be expected for_ a facility.
The great majority of the problems identified ~ either deal with !
station-relateditems(e.g., radiation-protection. program, environ- 1 mental program, physical security program, emergency. planning pro-gram) that cast an equally poor reflection on Units 1, 2.and-3 or ;
deal with items primarily related to poor performance at Unit 2. '
It has been and continues to.be an opinion-of Region I that-the overall quality of operations at Unit 3 (even including' Station related items) would compare favorably with other operating plants '
in Region 1, whereas the quality of Unit 2 operations has been less k than what would be ~normally expected at a well-run plant. .The reason for the contrast between Units 2 and 3 is due, in the: opinion ,
of Region I.. to a difference in attitudes of .the units operating l personnel, and the failure of management to correct the' problem at- .
Unit 2. This has resulted in poorer performance at Unit 2. It- '
should be noted that the same personnel who had the poorer attitude on Unit 2 were in large part responsible,for the deficient implementation of station-related programs. The' great disparity in attitudes does not exist at this time.
Emphasis should also be placed on the fact that Indian Point has l been a station where inspection activities were difficult to accom- l plish and inspectors have not wanted to inspect there. This was due in large part to plant personnel being argumentative .over .
inspection findings and to station programs being cumbersome and I difficult to understand and inspect. These facts would reasonably be expected. to be reflected.in a subjective-type survey such'as the Hayes survey and a low rating would be' expected.
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' Enclosure'1 2 13 DEC 1977 In summary, the above discussion was intended to explain why Indian Point wculd be described as a poor performer in data banks and subjective surveys. prior to the present time. As indicated in our
_ response to Question 4 below, Region I and OIE Headquarters have ;
taken action to improve the perfomance at Indian Point and that ,
action has been effective. At this time, the performance at Indian Point is more than acceptable and Region I expects Indian Point to be one of the better performers by the end of calendar year 1978. <
Since inspector attitudes will take time to change, a subjective '
survey (such as Hayes) of inspector's assessments of the relative operational safety of Indian Point is not expected to yield results favorable to Indian Point prior to the end of calendar year 1978.
- 2. Do you believe that Indian Point has an abnormal performance record?
Yes. As indicated in our response to Question 1, Indian Point Station has had an abnormal per-Tormance record when compared to the performance which would normally be expected for a well-run facility. However, Region I has taken immediate action as necessary to preclude unaccept-able operational safety. Saying that a plant has an abnormal perform-ance record must not be constructed to mean that the plant has been operated unsafely. Poor performance records in, general serve as indicators that unsafe operations may develop and as such should be used by us as r.egulators to initiate corrective enforcement to preclude unacceptable operational safety.
- 3. Do you believe the indicated performance of Indian Point demonstrates Indian Point is less safe than the other facilities? Please explain your answer.
If it is a:sumed that all facilities are equally safe provided they operate within the confines of the Technical Specifications and other license conditions and if it is assumed that the Technical Specifica-tions and license conditions are uniform, a plant that operates more frequently outside those requirements is less safe than a plant having a low incidence of license violations. This would hold true for intentional violations as well as unintentional violations caused by such things as ignorance or equipment failures. Using the above assumption plus an added assumption that enforcement is uniform from plant-to-plant, one must conclude that Indian Point 2 is less safe than many facilities and Indian Point 3 is probably as safe as most.
This does not mean, as discussed in our response to Question 2, that the plants were ever operated with an unacceptable level of safety.
Enclosure 1 3 f
- 4. If you believe Indian Point is a " poor performer," please' describe the corrective measures you have taken or plan to take.
As indicated in our responses to the preceding three questions, Region I believes that Indian Point has had a poor performance record. In each instance where problems surfaced, timely actions by Region I and OIE Headquarters were taken to correct problem areas. Many times this action consisted of or was accompanied by telephone calls from the Regional Director or Branch Chief to the licensee and several enforcement letters were. issued with strong endings. In all cases the problems were discussed within Region I and a deliberate choice was made as to the most effective enforcement options available 'as set forth in MC 0800. As is evident from the <
recurrent nature of items of noncompliance, initial enforcement actions were not always effective and followup and elevated actions were pursued as deemed appropriate by the required office. At the present time, licensee performance indicates that enforcement actions have been effective in improving the performance of_ the licensee.
Listed below are some of the significant enforcement actions taken by Region I and OIE Headquarters:
Civil penalty and Other Enforcement Letters Issued by OI'E Headouarters
- 1. Civil penalty issued in June 1976 related to.the overexposure :
of a worker and observed inadequacies in the radiation protection program.
- 2. Notice of Violation issued by Acting Director, Division of Field Operations, on January 14, 1977, related to inadequacies in the radiation protection program.
Immediate Action Letters Issued by Recion I
- 1. IAL issued April 1976 related to radiation protection program improvements to prevent overexposures of workers.
- 2. IAL issued November 1976 related to slow rate of improvement in radiation protection program.
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' Enclosure 1 4
13 DEC 1977 Enforcement Coroorate Management Meetings Various top.ics related to facility operations were discussed in the following enforcement meetings: ,
- 1. April 1976 - meeti.ng at R.egion I.
- 2. October 1976 meeting at licensee's corporate office.
- 3. November 1976 - meeting at licensee's corporate office.
- 4. December 1976 - two meetings - one at licensee's corporate office and one at the site. 4
- 6. May 1977 - meeting at the site.
- 6. July 1977 - meeting at R.egir,n I.
- 7. October 1977 - meeting at licensee's corporate' office.
Scecial 'Inscection Activities
- 1. Extended health physics inspection - October - November 1976. ;
- 2. . Extended health physics inspection - May - June 1977. ;
- 3. Special followup inspection of eme.rgency planni.ng program imple- !
mentation - April 1977.
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- 4. Special followup inspection of environmental monitori.ng program implementation - September - October 1977.
- 6. Special inspection radiation protection upgrading program imple- .
mentation - November 1977. !
R.egion I is confident that the corrective actions taken will result in Indian Point becoming one of the better performing li.censees and l that this improved performance will be reflected in licensee perform-ance data generated in calendar year 1978.
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13 DEC 1977 ENCLOSURE 2 LICENS".E PERFORMANCE EVALUATION OUESTIONS
/EACH BOTTOM UNITS 1, 2, AND 3 .
- 1. From the data evaluated, the peach Bottom facilities. appear to.
exhibit performance which deviates from the nom. Provide your analysis as to why the performance of peach Bottom appears to stand apart frum the other facilities. .
The two 1100 MWe BWR facilities are a major step up in size from ,
the small High Temperature Gas Cooled reactor which was the company's !
only previous nuclear power plant. ;
Frequent personnel errors had occurred at peach Bottom with little.
indication of disciplinary action being taken by the licensee against offenders. The licensee seeis very sensitive about taking action against employees, possibly secause.of concern that union-ization (other than a company unf a)_ will be the result.
Lack of an approved, up to date, QA program before November 1977.
Lack of comprehensive management review of facility events, with RI .
review pointing out inadequacies in cause identification and corrective ,
action adequacy.
Design problems, with inter-plant effects such' as a pump start on one unit causing ECCS actuation on the other.
A corporate management attitude, on the part of lower and middle level management, consistent'with responsiveness to NRC input only when there is no option. This seeming unresponsiveness, diplo-matica11y stated by middle management, has sometimes been vehemently expressed by lower management. Top management does, however, appear responsive. 10 CFR 73.55 compliance appears to be a typical example of slow licensee response to NRC input.
Facility Staffing. The dual units have consecutive refueling -
outages. This means up to a year in an outage status, with employees shifting between operating and shutdown units, and working long hours for extended time periods.
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Enclosure 2 .2 I 13 DEC 1977'.
Health Physics Program inadequacies. The program.has relied heavily ,
on utilization of contractor employees for implementation. The plant Health Physicist had little real authority with major influence over' day-to-day plant activities. Numerous examples of failure to follow HP procedures were identified. A chronic inalility to properly control high radiation areas was identified.
- 2. Do ycu believe that the Peach Bottom facilities have an abnormal -
performance. record?. '
Yes. . Also refer to Enclosure 1 answer to this question. )
- 3. Do you believe the indicated performance of the Peach Bottom facili-ties demonstrates the Peach Bottom facilities are less safe than the other facilities? Please explain your answer,
, It is our belief that the factors we evaluate. as defects in manage-ment review of events, control'over employee actions, quality assurance, radiation protection, staffing, and attitude have resulted in safety assurance which is less than that which could, and should, have been achieved at Peach Bottcm. We do not have definitive data
, showing that Peach Bottom is less safe than other facilities, but "
we do believe that it has been less safe than it should have been.
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- 4. -If you believe the Peach Bottom facilities are " poor performers,"
please describe the corrective measures you have taken or plan to ta ke.
The items identified in the preceeding paragraphs have been discussed i with licensee management, including a frank discussion with the Corporate President in two 1977 management meetings covering our ;
major concerns. We are paying particular attention to these areas -
in our inspection efforts. The licensee has taken the following -
actions.
- a. Personr.el Errors Training staff and programs have been expanded and improved.
An internal mechanism has been developed to identify peor !
performance and develop a disciplinary action concept at this ;
utility. The licensee is also enforcing the two person " hands '
on" apprcach through training and procedures to minimize valving errors. Aoditionally, color coding of components is underway using human engineering concepts.
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Enclosure 2 3 16 DEC 1577
- b. 0A Program NRC acceptance of the 0QAP was completed on November- 18, 1977.- ,
RI inspection remains outstanding.
- c. Review of Facility Events -
Recent experiences with'this licensee indicated that a better 4 and more thorough . approach is being taken with respect to such events. (References LER 2-77-37A and 37D). .The licensee '
continues to have organizational and administrative breakdowns i with respect to the filing of LER reports with. the NRC. These l problems-include LER sequential numbering, completeness of- '
information and correct addressees. All of these areas have been discussed with plant management.
- d. Design Problems RI believes that a large dual unit BWR plant represents a !
unique set 'of circumstances related to operating personnnel, ,
system interactions, and shared system requirements during- ~
outages.- These cannot be altered significantly within the '
existing physical. plant. ;
- e. Management Attitude Responses to recent inspections indicate that management meetings have' resulted in a more cooperative attitude at the plant level. RI cannot at this point complete ~a judgement with respect to middle level corporate management respons-iveness until QA Program implementation is evaluated.
- f. Facility Staffinc Changes 1 The following managerial changes were made at the site on September 8,1977.
The Technical Engineer became Outage Manager.
The Operations Engineer became Technical Engineer.
The Results Engineer became Operations Engineer.
A Senior Licensed Operator was promoted to Results !
- Engineer. '
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. i Enclosure 2 4 13 DEC 1977 Additionally, a former Test Engineer was promoted to Assistant Maintenance Engineer, a new position. These changes,.particu-larly in the area of maintenance and operations, should result in a tightening up of management controls. In the past,'the Operations Engineer has not had the authority to effectively '
function in that position as would normally be expected. The licensee is increasing the I&C Department by.8 personnel. . l This should result in reduction of the large number of instru- 1 mentation problems which have been identified in p.I inspec- >
tions. Also, the licensee has expressed the intention to take action to reduce the involvement of operatir.g personnel with ;
administrative matters not related to safety of operations. ;
Assessment of the results will take timc. '
- g. - Health physics-The Health Physics program at Peach Bottom has undergone ;
substantial improvement in the recent past. Major factors in. -
this improvement, precipitated by management meetings, include: .
The plant manager met with all employees and restated with, ,
emphasis that plant procedures, particularly those dealing with radiation protection, must be followed. .
The plant. Health Physicist was permitted to strengthen his authority and with the plant manager's backing was effective in establishing managerial control of the radiation protection -
organization.-
A marked reduction in the influence of the Corporate ' Health Physicist over day-to-day plant Health Physics activities was )
effected.
PECo undertook a program which will lead, in the next few j years, to a complete exchange of PECo employees for presently )
utilized contractor employees in the Health Physics organiza-tion. ,
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13 DEC ISh l ENCLOSURE-3 1 i
LICENSEE PERFORMANCE EVALUATION OUESTIONS - MILLSTONE'1 ,
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- 1. From the data evaluated, Millstone 1 appears to exhibit performance: '
- which deviates from the norm. Provide your analysis as to why the performance of Millstone 1 appears to stand apart from the other facilities.
Millstone Unit 1 has stood apart' from other facilities. Two civil ,
penalties have been issued to the station. The first concerned-
- security. The second involved the circumstances surrounding an ,
accidental criticality. There have also been.significent component. i failures (such as the chloride intrusion incident and isolation- 1 condenser tube failures). The facility .has received considerable !
press coverage. The State of Connecticut has maintained a very 4
active interest in station management and operation. An aggressive- t press has provided less than flattering coverage of plant operation.' ;
- 2. Do you believe that Millstone 1 has an abnormal . performance record? 3 Millstone 1 has an unusual performance record. The circumstances preceding the chloride intrusion incident, accidental criticality, .
and security civil penalties must be. considered in evaluating it. ;
These events illustrate some of the operational < problems an older i
" turn-key" plant may have, and the problems involved in substantially. -!
updating management and administrative controls. This year there have been 32 inspections at Unit 1. A review of the results indicates a less than average noncompliance rate. On this basis, we believe '
that Millstone 1 does not have a bad performance record at this; ,
time.
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- 3. Do you believe the indicated performance of Millstone 1 demonstrates Millstone 1 is less safe than the other facilities? Please explain yo:ur answer.
t At no tir,e did the events referenced in the response to question 1 harm a member of the public. The assurance of safety during continued L cperation is, however, a valid safety question. But, operation is being conducted within the limits provided by Technical Specifications.
Definitive data showing Millstone 1 to be less safe than other facilities is not available. We believe that the events which ,
occurred have shown that the assurance of safety was not what it .
should have been.
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Enclosure 3 2 DEC G77
- 4. If you believe Millstone 1 is a " poor performer," please describe the corrective measures you have taken or plan to take.
We do not consider the Millstone licensee to be a poor performer.
Concerning past events, in each case Millstone management took sound corrective action to prevent reoccurrence.
For example: Followine the chloride intrusion incident there was a turnaround at Millstone which included the installation of superior conductivity monitoring instruments. Technical Specifications for condensate demineralizer capacity were proposed by Millstone. It is the only salt water cooled plant known with that specification..
In their exit interview, the NRR security plan evaluation task force leader noted that Millstone had submitted one of the better Security plans and had been one of the best to deal with during site visits.
Inspection efforts by Region I in the area of Operational Quality Assurance were well received. Following those inspections that.
department was overhauled.by licensee management. Although we have resolved all items concerning the implementation of their program, Millstone maintains an OQA task force to independently study and make recocmendations in that area.
Our inspectors have generally indicated that Millstone management is a cooperative licensee who responds well to NRC input.
This office is presently conducting indepth inspections at Millstone in the area of health physics. These inspections are seeking to
" fine tune" their implemented programs. -
At the present time this office does not consider that inspection activities beyond those specified are required.
It is our opinion that the problems encountered at Millstone 1 are largely due to the genre of the facility, and that the facility management has aggressively pursued, and achieved, a considerable upgrading of facility safety.
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