IR 05000416/1986035
| ML20210A395 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/14/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210A350 | List: |
| References | |
| 50-416-86-35, 50-417-86-05, 50-417-86-5, NUDOCS 8705050080 | |
| Download: ML20210A395 (10) | |
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April 14, 1987 ENCLOSURE
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APPENDIX TO SYSTEM ENERGY RESOURCES, INC.
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GRAND GULF FACILITY-
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SALP BOARD REPORT NOS. 50-416/86-35; 50-417/86-05
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J (DATED JANUARY 15,1987)-
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4 8705050080 870414 PDR ADOCK'05000416 O
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I. Meeting Summary A.
A meeting was held on January 22, 1987, at the Grand Gulf' site to discuss the SALP Board Report for the Grand Gulf facility.
The free exchange of views during this meeting was beneficial.
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B.
Licensee Attendees:
E. A. Lupberger, Middle South Utilities (MSU), Chairman of the Board of Directors W. Cavanaugh, III, System Energy Resources, Inc. (SERI), President and CE0 T. H. Cloninger, SERI, Vice President, Nuclear Engineering Support 0. D. Kingsley, Jr., SERI, Vice President - Nuclear Operations J. E. Cross, Site Director - Grand Gulf Nuclear Station (GGNS)
C. R. Hutchinson, General Manager - GGNS i
J. M. Hendrie, SERI, Safety Review Committee and Nuclear Oversight J. G. Cesare, SERI, Acting Director Nuclear Licensee and Safety R. F. Rogers, III, SERI, Unit I Project Manager F. W. Titus, SERI, Director Nuclear Plant Engineering G. W. Muench, MSU, Vice President Nuclear Assurance
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R. B. McGehee, SERI, Lawyer, WCC&C J. L. Robertson, SERI,. Plant Licensing Support A._C. Morgan, SERI, Supervisor, Emergency Preparedness L. F. Dale, SERI, Assistant to Vice President - Nuclear Operations L. R. McKay, SERI, Manager, Radiological and Environmental Services J. P. Czaika, SMEPA, Resident Manager L.
Warren, SERI, Manager, Corporation Communications M. Wright, SERI, Manager Plant Support
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D. W. Stonestreet, SERI, Manager Plant Mod. and Construction H. D. Morgan, SERI, Unit 2 Construction Support S. F. Tanner, SERI, Manager, Nuclear Site Quality Assurance S. M. Feith, SERI, Director, Quality Assurance J. P. Dimmette, Jr., SERI, Manager-Plant Maintenance A. S. McCurdy, SERI, Manager-Plant Operation C.
NRC Attendees:
M. L. Ernst, Deputy Regional Administrator, Region II L. A. Reyes, Deputy Director, Division of Reactor Projects (DRP)
H. C. Dance, Chief, Reactor Projects Section 1B, DRP L. L. Kintner, Grand Gulf Project Manager, Office Of Nuclear Reactor
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Regulation (NRR)
R. C. Butcher, Senior Resident Inspector, Grand Gulf W. F. Smith, Resident _ Inspector, Grand Gulf J. Unda, Project Directorate No.^4, NRR l
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II. Errata Sheet - Grand Gulf SALP
_Page Line Now Reads Should Read
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... nuclear safety, but
... nuclear safety; licensee weaknesses are evident; resources are adequate and are licensee resources appear reasonably effective so that
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to be strained.... quality satisfactory performance with is being achieved, respect to operational safety or construction is being achieved.
Basis for Change:
To correct typographical error.
Page Line Now Reads Should Read
14 Another plant staff Another plant staff reorgani-reorganization occurred in zation occurred in June 1986.
June 1985.
Basis for Change:
To correct typographical error.
Page Line Now Reads Should Read
15 Audits performed by corpo-Audits performed by the rate health physics staff corporate health physics staff of the health physics were thorough and well program were marginally documented and were of adequate... trends.
sufficient scope and depth Additionally, the site to identify problems and
... physics area.
A adverse trends.
Methods were violation... Technical in place to track items and Specifications, corrective actions by means of correction action requests and plant quality deficiency reports.
The site internal audit organization conducted audits of the health physics program using personnel minimally experienced in the health physics area.
Separately, a violation was
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issued for failure to control access to very high radiation areas as required by the licensee's Technical Specifications.
Basis for Change:
Additional information provided clarified the scope and depth of documentation.
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meaningful NRC observations.
Special areas may be added to highligh 1-significant observations.
One or more' of the following evaluation criteria was used to asse s.each functional area; however, the SALP Board 1s not limited to these criteria
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and others may have been used where appropriate.
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Management involvement in assuring quality
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Approach to the resolution of technical issues from a afety standpoint C._
Responsiveness to NRC initiatives i
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Enforcement history E.
Operational and construction events (including r ponse to, analysis
of, and corrective actions for)
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Staffing (including management)
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Training and qualification effectiveness
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Based upon the SALP Board assessment, each f ctional area evaluated is.
classified into one of three performance ca gories.
The definitions of.
these performance categories are:
Category 1:
Reduced NRC attentio may be appropriate.
Licensee l
management attention and involvem t are aggressive and oriented toward'
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nuclear safety; licensee resour s are ample and effectively used = such j
that a high level of performan with respect to operational safety or
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construction quality is bein achieved.
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Category 2:
NRC attenti should be maintained at normal levels.
Licensee management att tion and involvement are evident and are
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concerned with nuclear safety, but weaknesses are evident; licensee j
resources appear to strained or not effectively used such that i
minimally ~satisfact y performance with respect to operational safety l
or construction q ity is being achieved.
i Category 3:
B h NRC and licensee attention should be increased.
Licensee man ement attention or involvement -is acceptable and
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considers n lear safety, but weaknesses are evident; licensee resources ppear to be strained or not effectively used so that i
minimall satisfactory performance with respect to operational safety or cons ruction is being achieved.
The func onal area being evaluated may have some attributes that would place t evaluation in Category 1, and others that would place it in either
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Catego y 2 or 3.
The final rating for each functional area is a ' composite i
of t attributes tempered with the judgement of NRC management as to the i
s ificance of individual items.
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meaningful NRC observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria was used to assess each functional area; however, the SALP Board is not limited to these criteria and others may have been used where appropriate.
A.
Management involvement in assuring quality 8.
Approach to the resolution of technical issues from a safety standpoint C.
Responsiveness to NRC initiatives D.
Enforcement history E.
Operational and construction events (including response to, analysis of, and corrective actions for)
F.
Staffing (including management)
G.
Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of these performance categories are:
Category 1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee management attent;on or involvement is acceptable and i
considers nuclear safety, but weaknesses are evident; licensee
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resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieved.
The functional area being evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or 3.
The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of individual items.
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Management involvement in the success of the plant in attaining a are of operational readiness was evident in the licensee's report en tled Grand Gulf Nuclear Station, Unit 1 Post Warranty Run Operati al Readiness Review.
The report was well written and adequately overed the aspects of operational readiness.
Inspectors followup of t report's recommendations indicated satisfactory resolutions.
In late 1985, the newly created position.of Site Direc or, GGNS was filled and reporting to him is the GGNS General Manag and the newly created position of Manager, Unit No. 1 Projects.
T e new position of Manager, Plant Modification & Construction was cre ed reporting to the Manager, Unit No. 1 Projects.
This reorganizati n strengthened the site staff and provided more management control ver outage / equipment modification activities that could affect pla operation and safety.
Another plant staff reorganization occurre in June 1985.
The Operations Superintendent assumed a new p ition of Plant Licensing Superintendent.
An Assistant to the Op ations Superintendent was promoted to the Operations Superintende position.
The Manager, Plant Operations -assumed the position of M ager, Plant Support and his Technical Assistant was promoted to anager, Plant Operations.
This reorganization placed operational perience in other areas of plant management and thus created a str ger overall staff.
The licensee increased the nu er of licensed personnel to implement a six shift rotation schedule n April 13, 1986.
There are 15 Senior Reactor Operators (SR0s)
d 24 Reactor Operators (R0s) in the Operations Section.
The erations Superintendent and two Operations Superintendent assistan are SR0s.
The potential for erational difficulties has existed due to discrepancies betw n the system operating instructions, piping and instrument diagra and the actual plant configuration.
This area is discussed in th section on Quality Programs and Administrative Controls Affec ng Quality.
An event oc rred on July 30, 1986, which revealed another problem in the licen e's controls for review of significant events / reports and vendor i formation letters.
In this event, a control rod, while being withdr n from notch 8 to notch 10, continued to slowly withdraw past notc 0 and eventually stopped at full out (notch 48).
GE had issued Ser ce Information Letter (SIL) No. 292 with recommended actions.
The l' ensee had not adequately reviewed the subject SIL for applicability o GGNS.
Subsequently, the licensee agreed to review approximately 350 older GE SILs for impact.'
Implementation of procedural changes resulting from these reviews are scheduled to be accomplished by
@$g December 31, 1986.
This is further discussed in the Quality Programs section.
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Management involvement-in the success of the plant in attaining a state of operational readiness was evident in the licensee's report entitled
Grand Gulf Nuclear Station, Unit 1 Post Warranty Run Operational Readiness Review.
The report was well written and adequately covered the aspects of operational readiness.
Inspectors followup of the report's recommendations indicated satisfactory resolutions.
In late 1985, the newly created position of Site Director, GGNS was filled and reporting to him is the GGNS General Manager and the newly
- created position of Manager, Unit No. 1 Projects. The new position of Manager, Plant Modification & Construction was created reporting to the Manager, Unit No. 1 Projects.
This reorganization strengthened the site staff and provided more management control over outage / equipment modification activities that could affect plant operation and safety.
Another plant staff reorganization occurred in June ~1986.
The Operations Superintendent-assumed a new position of Plant _ Licensing
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Superintendent.
An Assistant to the Operations Superintendent was promoted to the Operations Superintendent position. The Manager, Plant-Operations assumed the position of Manager, Plant Support and his-Technical Assistant was proinoted to Manager, Plant Operations.
This reorganization placed operational experience-in other areas of plant management and thus created a stronger overall staff.
The licensee increased the number of licensed personnel to implement a six shift rotation schedule on April 13, 1986.
There are 15 Senior Reactor Operators (SR0s) and 24 Reactor Operators (R0s) in the Operations Section. The Operations Superintendent and two Operations Superintendent assistants are SR0s.
The potential for operational difficulties has existed due to discrepancies between the system operating instructions, piping and instrument diagrams and the actual plant configuration.
This area is discussed in the section on Quality Programs and Administrative Controls Affecting Quality.
An event occurred on July 30, 1986, which revealed another problem in the licensee's controls for review of significant events / reports and vendor information letters.
In-this event, a control rod, while being withdrawn from notch 8 to notch 10, continued-to slowly withdraw past notch 10 and eventually stopped at full out (notch 48).' GE Scd issued Service Information Letter (SIL) No. 292 with recommended aci kns. The licensee had not adequately reviewed the subject SIL for applicability to GGNS.
Subsequently, the licensee agreed to review approximately 350 older GE SILs for impact.
Implementation of procedural changes resulting from these reviews are scheduled to be accomplished by December 31, 1986.
This is further discussed in the Quality Programs
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section.
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Management support and involvement in matters related to radiation
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protection was a program strength.
During the evaluation perio
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licensee management authorized the~ purchase of an onsite thermol mi-i'
nescent dosimeter (TLD) system in lieu of using vendor suppli and
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processed TLDs.
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The licensee participated in the - National Voluntary La ratory i
Accreditation Program (NVLAP) for personnel dosimetry a d received
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NVLAP accrediation for'the program during the evaluati period..
Resolution of technical issues by the health physi s staff. was a
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program strength as demonstrated: by the licensee' - assessment of radiation doses assigned to workers when the w kers' TLDs were accidentally irradiated during shipment to th TLD processor.
The licensee's investigation was aggressive and t rough. The NRC.was kept informed during the-investigation.
Audits rerformed by the corporate health physics staff of the health and were no' of sufficient physics program were marginally 'adequa c
scope and depth to identify problems d adverse trends. Additionally, the site internal audit organizatio conducted audits of the health physics program using personnel m imally experienced in the health physics-area. A violation was-i ued for failure to control access to r
very high radiation areas as r quired by the licensee's Technical
Specifications.
This issue d been reviewed by the site internal
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audit organization, which do umented several instances of locked high
radiation area doors being ound open. However,- the audit organization
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did not issue a nonconfo ance report for this finding, and it remained uncorrected.
- The licensee's radi tion work permit and respiratory protection
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programs were fou to be adequate.
The licensee exercised an aggressive contam, nation control program with the decontamination crew
reporting to h lth physics.
The licensee. began tracking plant-
contaminated eas.
In May 1986, 494,500 square feet of the plant were j
designated be tracked for contamination control purposes.
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September 86, 38,000 square feet of the plant were maintained ias contamina ed which represented 7.68 percent of the' total area.
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Durin 1985, the licensee's cumulative exposure was 110 man-rem as meas ed by TLDs which was well below the national average of 800
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ma rem per unit observed at BWR facilities. Through October 31, 1986, t
cumulative exposure as measured by TLDs was 380 man-rem.-
During 1985, the licensee made 49 solid radioactive waste shipments t
i totallin'g 21,249 cubic feet (ft3) and containing 259 curies of'
activity. This value is well below the national average of 28,800 ft3 per reactor of waste shipped by other BWR facilities.
Through
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September 1986, the licensee had made 46 solid radioactive waste -
shipments totalling 10,657 fta and containing 1,170 curies of activity.
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Management support and involvement in matters related to radiation protection was a program strength.
During the evaluation period, licensee management authorized the purchase of an onsite thermolumi-nescent dosimeter (TLD) system in lieu of using vendor supplied and processed TLDs.
The licensee participated in the National Voluntary Laboratory Accreditation Program (NVLAP) for personnel dosimetry and received NVLAP accrediation for the program during the evaluation period.
Resolution of technical issues by the health physics staff was a program strength as demonstrated by the licensee's assessment of radiation doses assigned to workers when the workers' TLDs were accidentally irradiated during shipment to the TLD processor.
The licensee's investigation was aggressive and thorough.
The NRC was kept informed during the investigation.
Audits performed by the corporate health physics staff were thorough and well documented and were of sufficient scope and depth to identify problems and adverse trends.
Methods were in place to track items and corrective actions by means of correction action requests and plant quality deficiency reports.
The site internal audit organiza-tion conducted audits of the health physics program using personnel minimally experienced in the health physics area.
Separately, a violation was issued for failure to control access to very high radiation areas as required by the licensee's Technical Specifica-tions.
This issue had been reviewed by the site internal audit organization, which documented several instances of locked high radiation area doors being found open.
However, the audit organiza-tion did not issue a nonconformance report for this finding, and it remained uncorrected.
The licensee's radiation work permit and respiratory protection programs were found to be adequate.
The licensee exercised an aggressive contamination control program with the decontamination crew reporting to health physics.
The licensee began tracking plant contaminated areas.
In May 1986, 494,500 square feet of the plant were designated to be tracked for contamination control purposes.
In September 1986, 38,000 square feet of the plant were maintained as contaminated which represented 7.68 percent of the total area.
During 1985, the licensee's cumulative exposure was 110 man-rem as measured by TLDs which was well below the national average of 800 man-rem par unit observed at BWR facilities.
Through October 31, 1986, the cumulative exposure as measured by TLDs was 380 man rem.
During 1985, the licensee made 49 solid radioactive waste shipments totalling 21,249 cubic feet (f t3) and containing 259 curies of activity.
This value is well below the national average of 28,800 f t3 per reactor of waste shipped by other BWR facilities.
Through September 1986, the licensee had made 46 solid radioactive waste shipments totalling 10,657 ft3 and containing 1,170 curies of activity.
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III. ' Licensee Coments Licensee coments dated February 23, 1987, in response to the Grand Gulf-
,SALP Board Report are attached.
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sYsTEMENERGY MI I o. w a nnw s
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I C[ M,m February 23, 1987 U. S. Nuclear Regulatory Comission Region II 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Attention: Dr. J. Nelson Grace, Regional Administrator
Dear Dr. Grace:
SUBJECT: Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to SALP Report (Nos. 50-416/86-35 and 50-417/86-05)
AECM-87/0042 Your letter dated January 15, 1987, transmitted the Systematic Assessment of Licensee Perfonnance (SALP) report for the Grand Gulf Nuclear Station (GGNS)
facility for the period May 1, 1985 through October 31, 1986. On January 22, 1987, members of our staff and the GGNS Safety Review Comittee met with you and members of your staff to review the results of the report. System Energy Resources, Inc. (SERI) is responding to that report via this letter.
SERI endorses the SALP concept and believes that objective evaluations of licensee performance benefit the licensee, the NRC, and the public by identify-ing and focusing attention and resources on matters important to safety of plant operations. SERI is comitted to operating GGNS safely and at a standard well above the minimum regulatory requirements. Accordingly, we intend to be responsive to the conclusions and recomendations discussed in your report.
SERI believes that a candid and cooperative relationship should exist
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between the NRC and its licensees in order to promote the free interchange of
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information necessary to facilitate the regulatory process and enhance nuclear safety. We believe that this sort of relationship exists between SERI and your office and intend to maintain the spirit of cooperation that has characterized our dealings in the past.
Further, we have recognized and addressed the areas where past SALP reports have shown that our operations needed additional management attention and believe that the significant improvements documented in this SALP report provide evidence that we have been responsive and are comitted to nuclear safety in the operation of Grand Gulf Nuclear Station.
SERI was pleased with your assessment that the level of performance of GGNS has continued to improve. Of particular note was your assessment of our. @-
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radiological controls, security, and outages areas as Category 1, and the t
improvements from Category 3 to Category 2 in emergency preparedness, licensing activities, training, and quality. programs and administrative controls
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affecting quality. As discussed in the January 22 meeting, SERI noted that the
Category 2 definition cited on page 2 of the report is incorrect. Category 2 should read, "NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that -
satisfactory performance with respect to operational safety or construction is
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being achieved."
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j SERI recognizes that several functional areas evaluated as Categcry 2 have been assessed at that level of performance for one or more SALP evaluation periods.
In general SERI further recognizes that improvements in effectiveness
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and execution in the Category 2 areas can be made and has established Category 1 as the overall objective for all functional areas.
SERI appreciates your observations that the reorganization of our staff and the attitude.of our staff have shown a marked increased posture toward nuclear safety. We believe we have worked diligently to address concerns that were raised both during and since the previous SALP report, and your observa-tions are indications to us of the success of our efforts.
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In accordance with your letter dated January 15, 1987, the following are
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SERI's comments on your report:
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IV.A. Plant Operations 1. (p.6)
To improve the overall program for conducting and reporting
10CFR 50.59 safety evaluations, several actions are underway.
The PSRC is generating a listing of commonly identified
deficiencies in safety evaluations based on the committee's review experience. This information will be evaluated for lessons learned and incorporated as appropriate into each department's training programs for those personnel performing 10CFR 50.59 safety evaluations. A corporate-wide procedure
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governing the 10CFR 50.59 evaluation process for all depart-
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ments has been developed. Upon implementation the procedure i
will provide consistency in safety evaluation content and I
format for all departments performing these evaluations. This
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procedure will also provide guidance on the application of 10CFR 50.59. Lower tier implementing procedures and training
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programs will be revised as necessary to comply with the upper
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tier procedure. As discussed with the NRC staff in the January 22 meeting, SERI recognizes the increasing emphasis
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being placed on the 10CFR 50.59 process and is following industry and regulatory activities in this area for the purpose
of continuing to improve the program at GGNS.
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2.(p.7)
The " plant staff reorganization" referenced in paragraph 2 as j
occurring in June 1985 actually took place in June 1986.
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3. (p.7)
SERI's response to the discrepancies cited between "the system operating instructions, piping and instrument diagrams and the
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actual plant configuration" is discussed under Section IV.K.,
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Item 4.
4. (p.8)
The violatiens cited in the SALP report as failure to follow procedures cover.a wide range of personnel errors in failure to follow procedures.
SERI agrees with the SALP finding that no specific programmatic weakness exists, but that overall controls with respect to root cause analysis and management control need to be improved. To achieve improved management control, the following actions-have been taken:
A review board consisting of the Manager-Plant Operations,
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Manager-Plant Maintenance and Manager-Plant Support must meet and review each incident involving a personnel error and provide a written report to the General Manager.
SERI upper management conducted a review and evaluation of
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incidents occuring just prior to or during the first refueling outage (RF01). The review and evaluation has
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resulted in the issuance of Management Standards to improve j
such areas as control room command function, control room activities, use of procedures, direct management involve-ment in daily activities and tours of the plant,'etc.
Additional controls, including an independent review by the
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releasing organization, were added to plant procedures which govern the generation and use of impact statements
for Maintenance Work Orders -(MW0s). See further discussion
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j of this item under IV.C., Item 2.
Procedure changes were made to provide for timely review of
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Incident Reports to allow for prompt, aggressive corrective actions. In addition, the information supplied during the Plant Modification process has been upgraded to allow l
better procedure change response.
Plant Management continues to stress procedural compliance
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and accountability of plant personnel for noncompliance.
i IV.B. Radiological Controls 1.(p.11) The report cited audits performed by the corporate health physics staff of the health physics areas as being " marginally
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adequate and... not of sufficient scope and depth to identify l
problems and adverse trends." SERI personnel discussed this finding with NRC Region II representatives subsequent to the
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January 22, 1987 meeting. As discussed with, and requested by,
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NRC Region II Health Physics Staff, SERI has separately
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provided representative samples of Health Physics Appraisals
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conducted by the corporate support group during the evaluation period which it belie,vs were of adequate technical scope and
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depth.
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2. (p.11) The report indicated "the site internal audit organization conducted audits of the health physics program using personnel minimally experienced in the health physics area."-
QA uses a functional approach to audit activities. This approach forms the basis for establishing criteria for assignment of auditors.
In most cases the criteria requires specialized training in the audit area to supplement an auditor's educational or experience background. The auditor assigned to audit the HP area is a Senior QA Representative whose selection was based on his qualifications. The auditor has a B.S. in Chemistry, is a registered Professional Engineer in Nuclear Engineering, and has attended numerous HP related courses including course work in applied health physics and radioactive material handling and transportation.
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Overall, SERI believes the auditor chosen for the subject health physics program audits is well qualified for this area.
However, SERI intends to discuss with the NRC their basis for establishing auditor qualification within specific functional areas. Based on those discussions additional requirements will be established if appropriate.
IV.C. Maintenance 1. (p.14) The report mentions that retrieval of maintenance history records from the plant Machinery History Log is not readily available. SERI believes the Material History System (MHS)
which is presently utilized at GGNS does provide a readily available source of historical information, but admits it is not " user friendly".
Personnel must have more than a basic knowledge of system operation in order to operate the MHS.
While this level of knowledge is not possessed by the individual craft personnel, personnel in the Maintenance Planning Section typically do have the necessary degree of system familiarity and are normally called upon to provide material history information.
Until potential future MHS system changes are implemented, reliance on Planning personnel for retrieval of historical information will continue.
SERI acknowledges that in the past the entry of completed history documents into the MHS was not timely. A concentrated effort was made to reduce the backlog.
Following an initial reduction, the backlog again increased during RF01 in late
1986. The Maintenance Department is presently working to
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reduce this backlog to a more manageable level.
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Although the MHS is not the only method utilized for material history retrieval, SERI and Middle South Utilities (MSU) are assessing implementation of an integrated work control system which includes a material history subprogram. Such a system would eliminate the need to separately enter material history information.
2. (p.15) Regarding the SALP recommendation concerning the need for more management attention being given to compliance with procedures and assuring quality during implementation of corrective actions, the following have been implemented and are continuing:
Precedures have been strengthened to ensure that more
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r.nphasis is placed on the initial preparation of MW0s.
Impact statements are being strengthened and an additional independent review by the releasing organization has been implemented.
Increased emphasis has been placed on determining the root
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cause of failed components, personnel errors, or procedural errors. This assessment is to be conducted in a timely manner to identify root cause and the actions to prevent recurrence.
Increased emphasis has been placed on working with all
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employees down to the working level to ensure that they understand the criteria and reasons for the necessit, of compliance with procedures, their accountability for their actions and consequences if procedures are not followed.
As stated in IV.A., Item 4, a review board has been
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established to review each incident involving a personnel error and provide a written report to the General Manager.
As stated in IV.A., Item 4, a review and evaluation of
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incidents occurring just prior to or during RF01 was conducted by SERI upper management. See additional discussion of this topic under IV.A., Item 4.
The position of the Manager-Plant Maintenance was filled
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with an experienced, SRO qualified individual from an operating BWR Plant.
SERI and MSU are presently performing an operational
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assessment of the Maintenance Department to ensure that maintenance activities are performed in accordance with the highest standards.
An assessment will be conducted to reduce the administra-
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tive work load on the maintenance supervisors to allow them to spend more time in the routine execution and monitoring of activities.
J12AECM87021301 - 5
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Page 6 IV.E. Fire Protection 1. (p.18) SERI intends to file a proposed change to the operating license in response to Generic Letter 86-10. The proposed change will
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request deletion of the fire protection features from the technical specifications and request the standard fire protection license condition. The current schedule for that submittal is Second Quarter,1987.
i IV.G. Security
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1.(p.22) The report acknowledged the interim measures completed to upgrade the temporary barrier separating the Unit 1 operational side from the Unit 2 construction side, yet implied a question regarding installation of a more permanent barrier.
Until such time as a final decision is made on Unit 2 SERI does not
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consider it prudent to make a decision on installing a
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permanent separation barrier which may require removal at
a later date. However, the following contingencies have been
taken or are scheduled for implementation during 1987:
Installation o? additional security cameras i
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Installation of a microwave alarm system
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Continuous check of the Unit 1/ Unit 2 separating wall
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IV.I. Licensing Activities 1. (p.26) The need for proper preparation, review, and involvement of the plant staff in proposing emergency actions related to the
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operating license (or its appendices) is recognized.
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Procedural controls have been implemented such that situations requiring emergency relief from the operating license or NRC enforcement discretion will be reviewed by the PSRC prior to providing the request to the NRC. As discussed with the NRC in
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the January 22 meeting, SERI will strive to keep the NRC staff apprised of circumstances or conditions that may lead to the need for emergency relief actions. However, prior to making the final decision to request enforcement discretion or an j
emergency change to the operating license (or appendices), the matter will receive PSRC review.
>
IV.J. Training
1. (p.31) As discussed with the NRC on January 22, the procedure
governing the operator requalification training program is
!
currently undergoing revision to address NRC questions. The proposed revisions are being discussed with NRC NRR staff.
Following resolution of questions raised, the program procedure will be revised and implemented.
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Page 7 IV.K. Quality Programs and Administrative Controls Affecting Quality 1. (p.32) SERI acknowledges that an inconsistency between the technical
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specifications and the ' approved QA program description occurred
i during the evaluation period. To preclude recurrence of such events in the future, all submittals to the NRC will be
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coordinated by the Nuclear Licensing & Safety (NL&S) organiza-
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tion. This includes matters pertaining to the 0QAM and the plant's technical specifications. This responsibility of NL&S has been incorporated into a corporate-wide procedure governing control of submittals to the NRC. The procedure is in the process of receiving final signature approval.
2.(p.34) The report indicated LER 85-33 "has never been updated" regarding final corrective actions. Based on discussions of this subject with the NRC GGNS Senior Resident Inspector, SERI has committed to develop a' chronology of key events and issues involving Unit I dependence on Unit 2 equipment and structures.
This chronology and the need for updating LER 85-33 will be discussed with the Senior Resident Inspector in the near j
future. Based on those discussions any update or reports
{
necessary to support NRC review of this. issue will be
submitted.
j 3. (p.35)
10CFR 50.59 Safety Evaluation Process. See discussion at Section IV.A., Item 1.
4. (p.35) The report noted " numerous discrepancies... between the Piping
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and Instrument Diagrams (P& ids) and the actual plant configura-
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tion " and cited poor quality in legibility of some P& ids.
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SERI has undertaken a major program to upgrade the GGNS As-Built Program during this SALP period. The cornerstone of
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this program was the installation of a Computer Aided Drafting
(CAD) System which was successfully implemented during RF01.
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This system, in conjunction with other As-Built Program l
procedural changes, allows much improved legibility and turn-i
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around times for the 4200 operational critical drawings currently maintained on the system.
In addition, SERI has
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recognized the need to assess the accuracy of the As-Built
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Drawing program and undertook walkdowns of two systems during l
RF01. As a result of the positive benefit'of these walkdowns, SERI has decided to complete walkdowns on three additional
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systems by the end of the second refueling outage (RF02).
A specific area of weakness identified in the P& ids relates to inconsistencies in the root valve (FX) numbering which could
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cause operational problems.
SERI is reverifying FX valve
identification on safety related systems and will reissue
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affected P& ids by June 30, 1987. Since the changes in the As-Built Program were so far-reaching, a comprehensive QA Audit
,
and other self-evaluations were conducted near the end of RF01.
i These reviews identified a number of specific problem areas requiring corrective action and Corrective Action Request
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Numbers (CARS) 2244 and 2245 were issued.
J12AECM87021301 - 7
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j A task force with QA, Plant Staff, Nuclear Plant Engineering i
and Plant Modifications & Construction representation has been formed to develop appropriate corrective action'recomenda-tions. The task force has identified numerous action items
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that are intended to improve the overall drawing program. The action items cover such areas as drawing accuracy and
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legibility as well as procedural changes to improve the,
l efficiency and timeliness of the revision progress. Efforts
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are currently underway toward implementing the task force identified actions.
In summary, SERI believes significant improvements have been made in the GGNS As-Built Program, but
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SERI will continue to test and assess the program to identify
areas for further improvement.
5. (p.36) The report discussed concerns related to " prompt corrective
actions" as they relate to the " adequacy of the operational QA program, and its implementation by the line organization,
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including their. involvement in assuming direct responsibility
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for quality." The importance of prompt corrective action for identified problems has been emphasized to key management
personnel in the line organization.
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The QA department's role in this area is to continue to
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inform management of all identified concerns regarding safe
plant operation. The QA Quarterly Trend Report, increased emphasis on timely corrective action, and direct senior
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management interface and involvement are effective, established i
methods to accomplish this objective.
(Additional discussion
on this matter is provided in Item 6 below under " CARS".)
j i~
6. (p.37) The report indicates a need to improve the effectiveness of i
quality programs in the areas of Design Change Status, Material
Nonconfomance Report Status (MNCRs), QA Nonconformance Performance Indicator (CARS), and Design Document As-Built
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Status. The NRC recognized corrective actions undertaken by
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NPE in the area of Design Change Notices and related activities
(p.37). Further, the NRC also cited certain program changes
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related to MNCRs and CARS (p.37). Additional information on i
these performance indicators is provided below.
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MNCRs: SERI is assessing methods to properly categorize
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i nonconforming i,tems into at least two new disposi-tions:
(1) Document Discrepancy Forms that pertain.
to vendore paperwork deficiencies, and,
(2) Discrepant Material Reports for material
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nonconformances that are neither safety significant nor impact safe plant operation. These methods
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should help put many of the existing MNCRs into proper perspective.
SERI recognizes that the backlog of open MNCRs is
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i excessive and that steps should be taken to reduce the backlog and effectively control the number of
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i open MNCR's.
For this reason SERI is evaluating the disposition process and has implemented an MNCR
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Reduction Program to effectively address this area.
J12AECM87021301 - 8
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Page 9 CARS:
Timaly corrective action to CARS has been the
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emphasis of several senior management meetings over the past two months. The number of overdue CARS and CARS open greater than 120 days has been significantly reduced. Continued management attention is expected in this area. Also, the fact that CAR closure is often dependent upon a particular milestone (outage, external agencies, etc.) is not considered in the SALP report.
Forty-seven percent of the CARS open prior to RF01 were closed based on corrective actions completed during the outage.
Design Document As-Built Status: See discussion at Section
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IV.K., Item 4.
SERI appreciates the efforts of you and your staff in helping to identify areas where improvement of our operations is needed. We believe the corrective actions we have taken have been effective and expect continued improvement in the future. We look forward to positive indications of this in the next SALP report.
I would be happy to discuss this response or answer any questions you may have at your earliest convenience.
Yours ly,
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ODK:rg
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cc: Mr. T. H. Cloninger Mr. R. B. McGehee Mr. N. S. Reynolds Mr. H. L. Thomas Mr. R. C. Butcher
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