IR 05000440/1998001
| ML20216D861 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216B948 | List: |
| References | |
| 50-440-98-01, 50-440-98-1, NUDOCS 9804160021 | |
| Download: ML20216D861 (6) | |
Text
<
Perry Nuclear Power Plant - SALP 15 Report No. 50-440/98001 INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) process is used to develop the
'
_ Nuclear Regulatory Commission's (NRC) conclusions regarding a licensee's safety performanc Four functional areas are assessed: Plant Operations, Maintenance, Engineering, and Plant Support. The SALP report documents the NRC's observations and insights regarding performance and communicates the results to the licensee and the public. It provides a vehicle for clear communication with licensee management that focuses on plant performance relative to safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilitie This report is the NRC's assessment of the safety performance at the Perry Nuclear Power Plant for the period September 15,1996 through February 28,1998. An NRC SALP Board, composed of the individuals listed below, met on March 11,1998 to assess performance in accordance with the guidance in NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance."
Board Chairperson John A. Grobe, Director, Division of Reactor Safety, Region ill Board Members Marc L. Dapas, Deputy Director, Division of Reactor Projects, Region lli Richard P. Savio, Acting Director, Project Directorate ill-3, NRR 1 PERFORMANCE ANALYSIS Plant Operations The plant was operated in a safe and conservative manner throughout the assessment period and management continued to encourage the identification and resolution of problem Improvement initiatives were implemented to address communication, human performance, and equipment tagout problems, but these efforts were not always fully effective. Operators performed well during routine activities and during response to events, in addition, the licensed operator training program was effectiv Management was usually effective in communicating expectations to operating crews which resulted in safe and conservative plant operations. However, some examples occurred where clear management expectations were not established and communicated through procedures !
and instructions. For instance, management expectations were not adequately communicated and implemented regarding operator panel walkdowns and control room panel deficiency tagging. With regard to panel walkdowns, inconsistencies with the quality and frequency of the walkdowns were identified. This was illustrated late in the assessment period when an operator failed to communicate to others that a containment isolation valve had failed at the beginning of his shift and four hours elapsed before another operatoridentified the conditio f PDR ADOCK 05000440 I
G PDR
During the previous SALP assessment period, it was apparent that efforts were needed to improve inter- and intra-departmental communications. Early in this assessment period, problems in this area led to an unintended reactivity addition during a recirculation system fiow control valve fuse replacement. Initiatives taken in response to this event included the implementation of three-way communications and a formalized pre-job briefing policy, which resulted in improved communications and job preparations. For example, crew communications during routine activities, reactor startups, and reactor shutdowns were nearly always fcrmal and clea Operator response to plant transients was generally good; however, human performance errors led to some of the transients which unnecessarily challenged the operators. Operator errors resulted in a reactor water cleanup system isolation, a reactor scram during shutdown, a feedwater pump turbine trip, and the removal of the wrong fuses during emergency diesel generator wor A number of problems were encountered in the equipment tagout program. While management has acknowledged that improvement is needed in this program, corrective actions to address tagout errors have not been fully effective. Errors have occasionally occurred in both tagout generation and implementation. For instance, a tagout generated for scram air header valve work inadvertently created a water flow path from the reactor vessel to the suppression poo Most recently, while performing work under a tagout, an operator inserted a fuse into the wrong panel which energized a system that had been tagged out for maintenance and jeopardized personal safety. Tagout work was suspended late in the assessrnent period to address the problems with this progra The training program for licensed operators was effective. The training department produced a challenging examination for senior reactor operator (SRO) license applicants, and job performance measures were effectively used to determine applicant competency. However, while overall operator performance during the examination was satisfactory and most applicants successfully passed, the SRO candidates were not as well prepared as those for previous examinations. For example, the SRO command and control skills of the applicants were generally lower than those observed during previous examinations and none of the applicants were able to correctly calculate an Average Power Range Monitor thermal trip setpoint when provided with a specified core flow. In addition, all applicants demonstrated some weaknesses in their understanding of the feedwater and reactor pressure vessel level control system Resolution of these problems was not evaluated during this assessment perio Quality assurance activities and line organization self-assessments were effective in identifying problems and concerns, but corrective actions did not always address the full scope of the problems. For example, the NRC determined that while the corrective actions for the feedwater turbine trip effectively addressed the specific procedural deficiencies associated with the event, an evaluation of whether similar deficiencies existed in other procedures was not performe .
I The corrective action process improved as the assessrnent period progressed. Identified problems were reviewed at the daily management meeting and specific individuals were held accountable for resolution of repetitive problem The performance rating in Operations is Category 2.
.
.
'e-I Maintenance Overall, maintenance activities were effective in improving the material condition of the plan ,
Plant equipment was properiy maintained and functioned well when challenged during transient .
While work control was generally good and led to a relatively low maintenance item backlog, j some problems were recently noted in this area. In addition, some recent problems were noted i with maintenance procedural adequacy and adherence, and human performance. Surveillance I test procedures were usually of high quality and program implementation was usually effectiv The plant material condition continued to improve over the assessment period. Inverter failures, which led to two half scram logic actuations early in the assessment period, were effectively addressed and the reliability of the reactor feedwater booster pumps was improved.= The fix-it-now team also contributed to material condition improvements and was particularly effective in r64 cing main control room deficiencies. The material condition improvements contributed to proper functioning of plant equipment during transients and a low corrective maintenance item backlo The control and execution of work was generally good. Improvements were noted in the timeliness of retuming safety equipment to service during online maintenance activities. Good planning and preparation led to the completion of a number of maintenance activities during .
unanticipated forced outages. In addition, work during the sixth refueling outage (RFO6) was usually well coordinated and was generally performed in accordance with procedures and instructions. However, some work control and procedural quality problems were identified. For example, a pre-job walkdown of the reactor core isolation cocling (RCIC) system failed to identify the inaccessibility of several steam jet plugs.' After realizing that all of the plugs could not be .
accessed, maintenance personnel failed to appropriately document actions taken. In another instance,'an improperly written work order led to an incorrect electrical relay being removed which resulted in a half-logic actuation of the main steam line isolation function. Finally, during recirculation system flow control valve (FCV) actuator work, the safety tagout did not isolate the FCV from the reactor coolant system and the FCV packing failed during the work. Several protective barriers broke down resulting in a potentially hazardous situation for the worker Human performance was generally good during maintenance activities and procedures were -
usually adhered to. However, some problems also occurred in this area. The failure of maintenance personnel to properly seal the auxiliary transformer after maintenance work resulted in a three phase ground fault and a subsequent reactor scram. In separate events, inadequate communications between engineering and maintenance personnel led to an incorrect thermal overload relay being installed in a combustible-gas compressor and maintenance personnel left j testing equipment installed on an RCIC motor-operated valve prior to a planned plant mode !
. change. In addition, maintenance workers failed to follow a procedure which caused an invalid l low reactor water level signal and a resultant high pressure core spray system actuation.' ;
- Surveillance procedures were usually of high quality and the planning for and execution of i
- system tests were usually conducted without incident. However, late in the assessment period, i an example occurred where quality control (QC) personnel were not involved in a pre-job briefing l for an RCIC system post-maintenance test and surveillance. This led to the failure of the QC l personnel to complete their required inspection during the normal one hour system test time, the unanticipated heatup of the suppression pool above an administrative limit, and an unnecessary challenge to plant operator l
l l
-.
.
.
The maintenance rule was properly implemented. Systems and functions were generally scoped correctly in the program and performance criteria and goals were adequate to evaluate system performance. A weakness in the process for assessing the risk associated with taking equipment out-of-service while the plant was operating was correcte i Quality assurance and line organization problem identification activities were effective in improving overall performance in maintenance. Plant personnel continued to maintain a low threshold for using the problem identification process and equipment deficiency tags to identify {
issues and potential problems. Critiques were effectively used to identify problems and develop l corrective action The performance rating ir. Maintenance is Category Engineerina Overall, engineering performance improved during this assessment period, most notably with respect to the quality of design change packages. While old design calculation errors continued to be identified, new design work was generally good. Engineering support to maintenance and operations activities was improved, especially with respect to material condition and corrective maintenance work, but some improvement was still needed in this area. The safety evaluation program was also in need of improvemen Process improvements initiated in the previous SALP period resulted in better quality design change packages and overall improvements to the plant design. For example, emergency core cooling system suction strainer clogging was resolved and feedwater booster pump reliability was ,
improved. However, some recent problems were identified with the implementation of the design change process. These included an inadequate evaluation of an electro-hydraulic control system design change which resulted in an automatic reactor scrarn; use of a non-conservative flooding rate in the flooding analysis for emergency closed cooling (ECC) system surge tank makeup; and a narrow focus on reactor recirculation pump oil level switch alarm actuations. In addition, original design calculation errors continued to be discovered during the assessment period. These errors included the acceptance of open assumptions in calculations forlong periods of time and the failure to update calculations to reflect system modification Engineering support to operations and maintenance activities contributed to overall plant material condition improvement and resulted in better plant equipment performance. Modifications to both the service water and circulating water systems during RFO6 rectified longstanding treterial condition issues caused by construction damage and in-service degradation. The supput for corrective maintenance activities led to an overall improvement in balance-of plant material condition and a reduction in main control room deficiencies, which resulted in equipment performing as designed during plant transients. However, occasional problems with engineering support to operations were identified. For example, engineering personnel did not initially i respond appropriately to an issue concerning a missing switchyard fuse which had the potential l to cause a loss of offsite power, and, as discussed in the operations section of this report, inadequate communication of the ramifications of a recirculation system flow control valve fuse replacement led to an unintended reactivity additio l Some problems with the performance of 10 CFR 50.59 safety evaluations were also identified. In J one instance, the plant-specific 10 CFR 50.59 safety evaluation program was not properly '
applied when ECC system valve leakage was evaluated. In another instance, NRC inspectors I
-
l
\
-
)
l identified that an inadequate safety evaluation was performed for an ECC system modification involving the addition of temperature control valves to the syste The response to the NRC request for information regarding the adequacy and availability of l
,
design basis information stated that the updated safety analysis report (USAR) did not need to be I further reviewed. However, a number of USAR discrepancies were identified during the architect / engineering (A/E) inspection. A thorough assessment of the collective significance of the A/E inspection team's findings was conducted by plant personnel and the subsequent decision to rebaseline the USAR, which is underway, was considered a positive initiativ improvements were made in the quality of the self-assessments conducted by the engineering organization. In particular, the maintenance rule and motor-operated valve assessments were thorough and effective. Following the maintenance rule evaluation, risk assessments for online l maintenance and performance criteria for evaluating the effectiveness of preventive maintenance 4 were improved. Adding periodic collective-significance reviews to the corrective action program, l of which the assessment of the A/E inspection team's findings was an example, was an
{
additionalimprovement to the progra '
The performance rating in Engineering is Category I Plant Support Overall performance in the area of Plant Support was effective. Improvements were noted in radiation protection performance and in the control of radioactive material. However, some weaknesses were observed with ALARA (as low as reasonably achievable) planning, and radiation monitor oversight. With respect to the radioactive waste, chemistry, and environmental monitoring programs, water chemistry was excellent and quality verification programs were ]
effective. Secenty pregram strengths included an experienced and knowledgeable staff and
~ timely mantenance r.upport. However, some problems were encountered in the fitness-for-duty (FFD) progom. Emergency preparedness program performance was good with well-maintained response faclities and equipment, a knowledgeable staff, and successful exercise performanc Performance in the fire protection area remained good with a number of examples of appropriate and timely corrective actions taken for identified deficiencie Radiation protection performance continued to improve due to increased management attention, better planning and scheduling, and better radiation worker performance. In general, the ALARA program was appropriately implemented with ALARA planning and pre-job brie'ings effective in minimizing radiation dose which resulted in low overall dose to workers. However, some communication and ALARA plan implementation problems were observed with the main steam line plug installation during RFO6. The corrective actions implemented for these problems were effective as evidenced by successful completion of the subsequent plug removal evolution. The control of radioactive material improved which demonstrated excellent coordination and good implementation of corrective actions by the radiation protection staff. In general, quality assurance audits, self-assessments, and potential issue forms were effective in identifying a wide range of issues, and once identified, the problems were usually corrected in a timely manner. One exception was evident in the radiation monitor program. Oversight of this program was fragmented, which resulted in unidentified material condition degradation and poor response to out-of-calibration monitors. In addition, some discrepancies within the program were not identified through routine audits.
,
'
.
d
The water chemistry program was effective. Plant water quality remained well within industry guidelines, technician performance was good, and chemistry instrumentation was well maintained. The material condition of the post-accident sampling system was improved from the previous SALP cycle, and representative samples were obtained as required. The radiological environmental monitoring program continued to be effective. Several radioactive waste reduction initiatives were implemented which resulted in a reduction in the amount of liquid and solid radioactive waste that was generate An experienced and knowledgeable security staff responded promptly and aggressively to events
' involving potential threats (by a former employee and a current employee) and to events involving.the falsification of FFD records by two contractors requesting unescorted acces However, operations and security supervisory personnel performed poorly during a FFD situation involving a senior reactor operator called in to work for an unscheduled work tour who had consumed alcohol within the five-hour abstinence period.- The security staff effectively implemented new regulatory programs in the areas of access authorization and vehicle barrier systems. Maintenance _ support for the security systems was thorough and timely, as evidenced by a significant reduction in the use of compensatory measure The emergency preparedness program was maintained in an effective state of operational readiness. In particular, the emergency response facilities and equipment were well-maintained and management support for the program was strong. Key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedure Performance during the 1998 emergency preparedness exercise was good. The licensee effectively addressed and initiated corrective actions for an issue identified in the control room simulator during the 1998 exercise. The exercise scenario was challenging and included significant degradation of plant equipment. In January and February 1998, two Unusual Events were appropriately declared and offsite notifications to State, County, and Federal authorities were made within the required time In the fire protection area, several examples of appropriate and timely corrective actions for ideniified deficiencies were noted. Following a quality assurance audit that identified significant issues, the fire protection program received additional management attention resulting in improved performance. Hot-work controls were effective as indicated by the absence of plant fires due to hot work during the past three years. Most fire protection equipment was well-maintained, but some transient combustible material control problems were identified late in the j assessment period. Also, there were a number of fire protection impairments requiring a fire watch. After the NRC identified this issue, the Thermo-lag replacement program was completed and the number of impairments was substantially reduced. The fire brigade training program was well-managed. Fire brigade performance during a fire brigade drill was excellent. The fire protection surveillance program was effectively implemented with the exception of not validating the friction factor (as a result of aging and using non-potable water) in the fire suppression system piping. Quality assurance audits were detailed and identified fire protection program problem )
The performance rating in Plant Support is Category