Information Notice 1993-72, Observations from Recent Shutdown Risk and Outage Management Pilot Team Inspections

Observations from Recent Shutdown Risk and Outage Management Pilot Team Inspections

ML031070092
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	09/14/1993
From:	Grimes B K Office of Nuclear Reactor Regulation
To:
References
IN-93-072, NUDOCS 9309090243
Download: ML031070092 (8)

KuUNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555September 14, 1993NRC INFORMATION NOTICE 93-72: OBSERVATIONS FROM RECENT SHUTDOWN RISK ANDOUTAGE MANAGEMENT PILOT TEAM INSPECTIONS

Addressees

All holders of operating licenses or construction permits for nuclear powerreactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this informationnotice to inform addressees of observations from recent shutdown risk andoutage management pilot team inspections. It is expected that recipients willreview the information for applicability to their facilities and consideractions, as appropriate, to avoid similar problems. However, suggestionscontained in this information notice are not NRC requirements; therefore, nospecific action or written response is required.BackgroundEvents that occurred during the past several years have caused the NRC staffto be increasingly concerned about plant safety during shutdown operations.The Diablo Canyon event of April 10, 1987, in which boiling of the reactorcoolant resulted from a loss of decay heat removal, highlighted the fact thatoperation of a pressurized-water reactor with a reduced reactor coolant system(RCS) inventory is a particularly sensitive condition. Based on its review ofthat event, the staff issued Generic Letter 88-17, "Loss of Decay HeatRemoval," October 17, 1988, which requested that licensees address certaingeneric deficiencies to improve safety during operations with a reduced RCSinventory. More recently, Incident Investigation Team report, NUREG-1410,"Loss of Vital ac Power and the Residual Heat Removal System During Mid-LoopOperations at Plant Vogtle Unit 1 on March 20, 1990," emphasized the need forrisk management of shutdown operations. Discussions with foreign regulatoryorganizations support NRC staff findings that the core-damage-frequency forshutdown operations may be a substantial fraction of the total core-damagefrequency.

Description of Circumstances

Between December 1991 and April 1993, the NRC staff conducted five pilot teaminspections to assess the effectiveness of industry initiatives for improvingshutdown safety. The inspections were performed at Oconee Nuclear Station,Unit 2 [NRC Inspection Report (IR) 50-270/91-202], Indian Point Nuclear9309090243-U 1?-.crn-9 .3 IN 93-72September 14, 1993 Generating Station, Unit 3 (IR 50-286/92-901), Diablo Canyon Nuclear Station,Unit 1 (IR 50-275/92-201), Prairie Island Nuclear Generating Plant, Units 1and 2 (IR 50-282/92-201; 50-306/92-201), and Cooper Nuclear Station(IR 50-298/93-201). Approximately one week of each inspection focused onlicensee pre-outage planning and control processes and 8 to 10 days focused onlicensee implementation of the outage.In the pre-outage portion of the inspection, the inspectors evaluated thefollowing: (1) management involvement in and oversight of the outage planningprocess, (2) planning and scheduling of outage activities, especially therelationships between significant work activities and the availability ofelectrical power supplies, decay heat removal systems, reactor coolant systemRCS inventory and containment integrity, (3) the process for developingindividual work packages to ensure coordination with other activities, and (4)operator response procedures, contingency plans and training for mitigation ofloss of decay heat removal capability, loss of RCS inventory and loss ofelectrical power sources during shutdown conditions.The inspectors walked through procedures related to shutdown safety todetermine if the specified activities could be accomplished in the allottedtime frames and to verify that the procedures could be implemented consideringprobable equipment availability. The inspectors reviewed training records onoutage procedures to determine if the training was adequate and that, whenappropriate, additional training was provided as the procedures were revised.The inspectors also evaluated the probable effects of environmental conditionssuch as temperature, steam and flooding on the performance of activities thatwould be required to mitigate adverse shutdown events.In the implementation portion of the inspection, the inspectors evaluated:(1) the control of changes to the outage schedule, control of work activities,and control of system alignments, (2) the working relationships andcommunication channels between operations, maintenance and other plant supportpersonnel, (3) the conduct of operations personnel both inside and outside ofthe control room regarding awareness of plant status, control of plantevolutions, response to alarms and other abnormal indications, (4) thecompleteness and effectiveness of shift turnovers, (5) whether maintenance andmodification work was performed in accordance with current written andapproved procedures and appropriate post-maintenance testing was required andperformed, and (6) the adequacy of management involvement and oversight of theconduct of the outage as it progressed.Other areas observed were, plant housekeeping, normal and emergency plantlighting, configuration control, radiological controls, equipment labeling andstatus tagging, vital area access control, use of overtime and licenseecontrol of contractor work including contractor training and qualifications.DiscussionIn general, the inspectors found that licensees had instituted programmaticchanges developed from guidance contained in a Nuclear Management andResources Council document, NUMARC 91-06, "Guidelines for Industry Actions to TVIN 93-72September 14, 1993 Assess Shutdown Management." The team inspectors found individual examples oflicensee failure to follow procedures but more importantly the inspectorsidentified two areas of more general concern: (1) risk assessment forpre-outage planning, emergent work and schedule changes, and (2)implementation of defense-in-depth methodologies for equipment availability.A general discussion of these areas is provided below. Specific details ofthe findings are contained in the inspection reports referenced above.Risk Assessment for Pre-Outage Planning, Emergent Work and Schedule ChangesThe inspectors found that licensees used various programmatic controls toassess shutdown risk factors during initial outage planning, emergent work andschedule changes. Assessment methodologies used for initial outage planningranged from following minimum guidelines for equipment availability toperforming a probabilistic risk assessment of scheduled outage activities.The inspection team found that the risk assessment aided the licensee inidentifying activities that would be subject to high risk during the sched ledoutage. However, as the outage progressed, the risk assessment became lessvalid because it was not updated as changes to the outage schedule occurredaIn the areas of emergent work and schedule changes, the inspectors found thatthree of the plants had a proceduralized process to assess the effect of \emergent work or schedule changes on plant risk. The other two plants reliedon a functional review by planners, schedulers, and operators to adjust theschedule appropriately to reduce risk.The inspectors found that all of the plants maintained status boards orchecklists in the control room to assist the operators in tracking theconfiguration status of plant systems and to help identify potentialrisk-significant activities.Implementation of Defense-in-Depth for Equipment AvailabilityThe inspection teams found that licensee implementation of defense-in-depthfor equipment availability was inconsistent. Although industry guidelines fordeclaring equipment "available" exist, the inspectors found that the criteriafor declaring equipment needed to ensure an appropriate margin of safety"available" varied from licensee to licensee. For example, declaring thatequipment was "available" did not always include ensuring that support systems(e.g., cooling water and heating, ventilation and air conditioning) were alsoavailable. At times, after maintenance had been performed, equipment waslisted as "available" without the benefit of a post-maintenance functionaltest. The inspectors also found that some equipment was considered to be"available" even though actions, such as removal of clearances or realignmentof valves, would be required before the equipment could perform its function.In addition to the above concerns, at most of the plants the team inspectorsfound examples of failures to comply with technical specification restrictionson overtime work in that management approval to exceed overtime limits wasinadequately documente K-,This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactthe technical contact listed below or the appropriate Office of NuclearReactor Regulation (NRR) project manager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contact:J.D. Wilcox, NRR(301) 504-1262

Attachment:

List of Recently Issued NRC Information NoticesRSIB:DRIL:NRRJDWilcox07/02/93RPB:ADMNBeeson08/10/93RSIB:DRIL:NRRSSanders07/02/93OGCB:DORS:NRRJLBirmingham08 /1/ 93 J9AC/RSIB:DRIL:NRRDNorkin07/02/93C70MO:DORS:NRRiGHMarcusPT ;S/Al/93D/DRIL:NRRCERossi07/10/93D/DORS:NRRBKGrimes09/ /93RSIB:DRIL:NRRPSKoltay07/06/93

-IN 93-xxSeptember xx, 1993 This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactthe technical contact listed below or the appropriate Office of NuclearReactor Regulation (NRR) project manager.Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contact:J.D. Wilcox, NRR(301) 504-1262

Attachment:

List of Recently Issued NRC Information Notices*SEE PREVIOUS CONCURRENCE*RSIB:DRIL:NRR *RSIB:DRIL:NRRJDWilcox SSanders07/02/93 07/02/93*AC/RSIB:DRIL:NRRDNorkin07/02/93> C/OGCB:DORS:NRRGHMarcus/Wen08/27/93*D/DRIL:NRRCERossi07/10/93D/DORS:NRRBKGrimes09/ /93*RPB:ADMNBeeson08/10/93*OGCB:DORS:NRRJLBirmingham08/27/93*RSIB:DRIL:NRRPSKoltay07/06/93DOCUMENT NAME:OUTAGEIN.JLB

'-vJIN 93-72September 14, 993Based on the five pilot inspections, the NRC inspection teams concluded thatNRC actions and industry initiatives have increased licensee awareness of therisk associated with shutdown and low power conditions. The inspection teamsfound that licensees were aware of the necessity for ensuring that requiredsystems be available and of the need to maintain the capability of backupequipment during an outage. However, the inspection teams found that licenseeinterpretations of industry initiatives for addressing shutdown risk variedgreatly. This was demonstrated by the various licensee interpretations ofindustry guidelines for declaring equipment "available."This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactthe technical contact listed below or the appropriate Office of NuclearReactor Regulation (NRR) project manager.Original signed byBrian K. GrimesBrian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contact:J.D. Wilcox, NRR(301) 504-1262

Attachment:

List of Recently Issued NRC Information Notices*SEE PREVIOUS CONCURRENCE*RSIB:DRIL:NRR *RSIB:DRIL:NRRJDWilcox SSanders07/02/93 07/02/93*AC/RSIB:DRIL:NRRDNorkin07/02/93*C/OGCB:DORS:NRRGHMarcus/Wen08/27/93*D/DRIL:NRRCERossi07/1 dJ3 (qy*RPB:ADMNBeeson08/10/93*OGCB:DORS:NRRJLBirmingham08/27/93*RSIB:DRIL:NRRPSKoltay07/06/93DOCUMENT NAME: 93-72.IN IN 93-72September 14, 1993 Based on the five pilot inspections, the NRC inspection teams concluded thatNRC actions and industry initiatives have increased licensee awareness of therisk associated with shutdown and low power conditions. The inspection teamsfound that licensees were aware of the necessity for ensuring that requiredsystems be available and of the need to maintain the capability of backupequipment during an outage. However, the inspection teams found that licenseeinterpretations of industry initiatives for addressing shutdown risk variedgreatly. This was demonstrated by the various licensee interpretations ofindustry guidelines for declaring equipment "available."This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contactthe technical contact listed below or the appropriate Office of NuclearReactor Regulation (NRR) project manager.C-Brian K. Grimes, DirectorDivision of Operating Reactor SupportOffice of Nuclear Reactor RegulationTechnical contact: J.D. Wilcox, NRR(301) 504-1262

Attachment:

List of Recently Issued NRC Information Notices KJAttachmentIN 93-72September 14, 1993 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to93-7193-7093-6993-6892-16,Supp. 293-6793-6693-65Fire at Chernobyl Unit 2Degradation of BoraflexNeutron Absorber CouponsRadiography Events atOperating Power ReactorsFailure of Pump ShaftCoupling Caused byTemper Embrittlementduring ManufactureLoss of Flow from theResidual Heat RemovalPump during RefuelingCavity DraindownBursting of HighPressure CoolantInjection Steam LineRupture Discs InjuresPlant PersonnelSwitchover to Hot-LegInjection FollowingA Loss-of-CoolantAccident in Pres-surized Water ReactorsReactor Trips Causedby Breaker Testingwith Fault ProtectionBypassed09/13/9309/10/9309/02/9309/01/9308/23/9308/16/9308/16/9308/13/93All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactorsand all radiographylicensees.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor nuclear power reactors.All holders of OLs or CPsfor pressurized waterreactors.All holders of OLs or CPsfor nuclear power reactors.OL = Operating LicenseCP = Construction Permit