ML20059B328

Discusses Author Observation of INPO Evaluation Process at Clinton Nuclear Power Plant on 900514-25.Recommends That NRC Observe Addl INPO Evaluations.Description of INPO Process & List of Qualifications & Experience of INPO Members Encl

ML20059B328
Person / Time
Site:	Point Beach, Clinton
Issue date:	07/19/1990
From:	Foley T Office of Nuclear Reactor Regulation
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20059B325	List: ML20059B322 ML20059B328
References
NUDOCS 9008290011
Download: ML20059B328 (7)

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c' Mfd 191930 MEMORANDUM FOR: Thomas E. Murley, Director q

0ffice of Nuclear Reactor Regulation

-THRU: William T. Russell, Associate Director for inspection and Technical Assessment Office of Nuclear Reactor Regulation FROM: -Thomas Foley, Senior Operations Engineer Performance Evaluation Section B, POEB Division of Licensee Performance and Quality Evaluation Office of Nuclear Reector Regulation

SUBJECT:

OBSERVATION OF INPO EVALUATION PROCESS AT CLINTON NUCLEAR POWER PLANT from May 14 to 25, 1990, I attended an INP0 eyeluation of the Clinton Nuclear-Power Plant, Clinton, Illinois. I attended this evaluation to compare the-

' Institute of Nuclear Power Operations (INPO) evaluation process to the performance objectives 6nd criteria set forth in the INPO document " Maintenance As requested by Programs in the Nuclear Nuclear Management Power Plant and Resources Industry'("

Council of March I1990.

NUMARC), will refer to this document as the " Maintenance Standard."

During the evaluatiun, I observed INPO team s. embers interfacing with licensee personnel during various work activities, including touring - with operators, discussions with supervisors, and meetings with licensee menagement. I also observed discussions by INP0 team members with their 4partment manegers by way

of: telephone calls, and routine discussions after normal work hours. INP0 was -

very receptive to having an NRC observer on their team.

On the evening of May- 22, 1990, I was joined by. W. T. Russell of your steff with whom I discussed my observations.

The incustry maintenance standard is primarily composed of objectives and criteria taken from " Performance Objectives and Criteria for Operating and NTOL Plants," and " Performance Objectives and Criteria for Corporate Evaluations."

These two documents contain additional objectives and criteria that relate to other areas as well as the maintenence area that are not included the industry

' maintenance standard.

As documented in - the enclosed sheet " Experience and Qualifications," 1NPO personnel are very experienced in their fields and are required to submit to a qualification process for certification as ares evaluators within their individual departments. The INP0 organization has departments for each area of

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.. - Nemorandum for Thomas E.'Murley -

the evaluation process and has other supporting departments. To ccaiplete this qualification trecess an evaluator must be f amiliar with all the performance objectives wit 1in a particular area. Further, evaluators are required to be familiar with internal documents which provide specific guidance for the evaluation of particular topics. These documents are very detailed and compare favorably to Regulatory Guides or inspection modules.

The evaluat' ors do not inspect according to objectives or criteria - as an NFC-inspector might refer to a recent Temporary Instruction during inspection.

Instead, INPO performs an evaluation by identifying deficiencies in the work hetivity, by 'looking for the presence or absence of attributes characteristic of good performance, and relating these attributes and deficiencies to specific performance objectives. The INP0 team does not verify that the utility has met all objectives of an area that are listed in the industry documents. As an example, within a particular area, the team might evaluate eight or nine objectives, although ten to twelve performance objectives are listed in the industry documents. Many of these objectives may have an associated

" observation,"- but only one or two may become a finding. Findings result from significant concerns generated from observations, interviews, and reviews of plant documents or a significant number examples of a single deficiency.

However, for a concern to become en thP0 finding, it must first be reviewed and approved by INP0 management later in the process.

Leoo evaluators inspect in a manner that is very similar tu Resident inspectors, using similar techniques, nut carrying a check list or other documentatiun, and interfacing with licensee personnel much like we would. I did observe. several 'of the peer evaluators and loaned INP0 members refer to objectives of their area pasted in personal notebooks.

. The INP0 evaluation process has many similarities to NRC programs such as SALP, the Mainteriance Team Inspection process, and the Resident inspection program.

During te6m discussions I overheard numerous discussions' regarding the evaluator's observations. I compared these discussions to the NRC's Maintenance Team Inspection Guidance. About 80 to 90 percent of the Maintenance Team inspection Guidance was discussed during afternoon team meetings. During this observation of INPO, Mr. Russell and I were 6110wed to view criteria that INP0 uses to assess licensee performance, and were briefed on the assessment process. I believe that the INP0 assessment process is analogous to the NRC SALP assessment having a similar rating process, presentation of evaluation results, management involvement, voting process, and wording of the-rating criteria.

Near the conclusion of the evaluation, Mr. Russell noted that the observations recorded by the maintenance area evaluators concluded that the same weaknesses existed, suppnrted by different examples, that were identified by the NRC for presentation at Senior Management Meeting discussions.

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.l i Memorandum for Thomas' E. Murley During this evaluation, INP0 team members . thoroughly investigated several recently experienced operating events including: inoperability of the emergency diesel generator (EDG) due to inadequate seismic supports, inoper-

. ability cf the EOG due to inadequate. cooling water flow, and a manual reactor scram which took place during the evaluotion. The investigation process of these events was similar to how NRC would investigate the same events.

In conclusion, the INP0 process accounts for most of the objectives listed in i the proposed Maintenance Standard. The current INPO process is more extensive than the maintenance standard. To properly essess the maintenance crea, INP0 may need the maintenance standard to include additional objectives.

The INP0 observation process identifies problems as they evolve and become r obvious during work activities such that evaluators can identify and relate l'

these problems to performance objectives. This process does not appear to

_ provide a structured method to ensure that all objectives of the industry maintenance- standard are assessed during any given period. During my observation, INP0 focused on the problems that appeared to be most in need of improvement, and attempted to redirect licensee attention to correct those L inamaiately deficient areas. I believe that the repeated performance of

evaluations will result in the correction of the major deficiencies, which will '

! allow the minor problems to become more evident, and to be correlated to other performance objectives of the maintenance standard, i i recommend that. NRC observe additional INPO evaluations and observe both the l pre-evaluation and post-evaluation- process, to better understand the evaluator qualification process, pre-evaluation reviews, and the post evaluation process.

. Encloseo is a description of the INP0 process as I understand it, and a list of the qualifications and experience of INP0 members who assessed Clinton.

Should you have any questions regarding my observations, I will be pleased to

- discuss them with you.

1 W h"1 Thomas Foley, Senior Operations Engineer Performance Evaluation Section B, PQEB Division of Licensee Perfor: nance and Quality Evaluation l

Office of Nuclear Reactor Regulation l

Enclosures:

As Stated cc: Jack W. Roe Cecil Thomas Anthony T. Gocy l-

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- ENCLOSURE 1 THE ICP0 EVALUATION PROCESS i

SCHEDULES.: _

The normal period between INP0 evaluations ranges from about 9 to 24 months. 1 This frequency depends upon the time since the last evaluation, the last .l assessment rating, the recondnendations made as a result of= the previous evaluation, and any_ significant licensee activity milestones or indications of degreded performance. j l

If a licensve's performance within a specific area needs significant improve- 1 ment, an INP0 assist visit may be scheduled between normally scheduled i evaluations.

l l PR E -E VAL _U_A_T_I_O_N.:

The effectiveness cf the INPD evaluation process depends significantly on I well-qualified and highly experienced evaluators, and a thorough review of plant information before the evaluation.

The evaluators'. caperience and other information is attached. This team consisted of three employees who were loaned to INPO for about 15 months, three peers, who are experienced individuals from other utilities attending I only this evaluation, four' trainees, 'and eleven full-time INP0 employees. The I collective experience of the members of the team equalled approximately 40 years at INP0, 190 evaluations and assist visits, 250 years of Industry experience, and 40 years of navel experience. Of. the team, seven members were licenseo or certified Senior Reactor Operators and nine members had BWR experience.

l. The team members are required to spend one to two weeks preparing for the

! evaluation. During this preparation, each member reviews the Plant Experience Report (PER). The PER is assembled by the members of the INP0 Operating

- Experience Application Department who compile information from. several different related departments within the organization. The PER contains facts, subjective information, and conclusions. It is organized according to the main topics in its executive summary which include the following: Plant Events, Potential Evaluation issues, Equipment Performance Summary, Plant Performance Indicators, and d list of similar domestic plants. The report contains a section that further analyzes data from many sources relating to that area and organizes the facts and results of the analysis according to the areas to be evaluated. This structure enables individual evaluators to more easily use the information. In eddition, the PER also contains information about facility scrams and their root causes, as assessed by INPO, and cetails of _ problems and events that are related to recent industry issues. The PER mdy compare some of these problems and events to the average for the industry

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's ENCLOSURE 1-i for pl6nts made by that particular vendor. These problems and events include motor operated volve (HOV) failures, instrument air failures, inverter f ailures,. and component f ailures on nuclear plant reliability data system (NPRDS) components at the facility. The PER analyzes equipment failures in many different ways and sumarizes the data in a user-friendly format. For example, the PER might st6te that there were numerous problems with leaky relief valves, or that damaged manual operators are common, or it might list the check valve failures dur'ng the past two years. These types of information  ;

are organized by the area evaluated along with data from the NPRDS Significant Event Evaluation information (SEE-IN)= and Operdting Plant Experience Code (OPEC). The PER also lists the Licensee - Event Report abstr6 cts, plant performonce indicator information and, where the plant performance is compared ,

to other plants of the same vendor, the plant's performance goals and the plant's interactions with 1NPO. The previous INP0 evaluation is also attached j to the PER. I 1

" Maintenance Preparation Information for the Clinton Evaluation," prepared by the maintenance area lead evaluator was another document used during this preparation. This document lists potentially weak areas to be inspected in detail, and areas of current emphasis resulting from the lead evaluator's review of the PER and previous INP0 evaluations.- The maintenance area leader generates a memorencum to the team lead evaluators assigning responsibilities for the plant walkdown inspection. The memorandum list examples of deficien- 1 cies in material condition, housekeeping, safety, and other items for each area. I that should be noted during tours of the facility.

Based.on these reviews, the evaluator discussed the evaluation plan with the department head and specified those objectives that would be emphasized during the evoluation, potential weaknesses, those objectives thdt would not be -

addressed and the re6 sons for not addressing them. The department head would approve or modify the evaluation plan.

EVALUATION!

The team is divided into the following eight departments and areas for evaluation; Operations, Maintenance, Health Physics, Technical Support, Chemistry, Training, Operating Experience, Organization and Administration.

Each evaluator spends about eight hours completing a plant walkdown inspection documenting deficiencies within their assigned areas on " blue cards." These cards are reviewed by the team manager and are forwarded to the appropriate

. lead evaluator. Next, the evaluators observe licensee work activities. Each evaluator uses observations interviews and documation reviews together with the deficiencies noted in various areas on the " blue cards" to formulate concerns within his assigned area. These observations and concerns are discussed daily at team meetings. The evaluator relates these concerns to the performance objectives for his area. Often, the concerns are discussed with home office dep6rtment personnel. During team discussions, the team manager may request the assistance of other area leaders to follow-up on a potential concern more appropistely related to their area of responsibility.

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.- -3 ENCLOSURE 1 At the conclusion of the onsite evaluation, the team manager and the plant manager meet with ev6luators from e6ch area . individually in the presence of the. licensee's manager from the appliccble department-to discuss the concerns.

The INP0 lead evalu6 tors de-brief each department m6n6ser regarding their concerns and the supporting facts throughout the evaluation.

POST-gALUATION:

Upon return to INPO, each of the are6 evaluators presents his results to-departmental peers in an Evaluation Review Committee (ERC) and to the depart-ment manager. Evaluators have to provide supporting examples leading to the concerns identified, and justification for those perf ormance objectives of the area that were not reviewed. This process helps to standaroize the findings end to unify the report. The department makes recommendations regarding their findings and recommencs an assessment of the applicable area.

The report information is forwarded tu the team manager who integrates this information from each of the eight into a draft report. The team manager then forwards the draf t report as the results of the team's findings, for consioer-ation by INP0 executive management.

INP0 executives review the draf t report findings and the recommendatiuns. An exit meeting is scheduled between the INPO exit representative, the team manager, and the licensee executives, normbily the CEO. The INPO team manager and exit representative discusses the findings and their _ meaning with the licensee. The draft report is subsequently forwerded to the licensee executives about one week af ter the final f.xit interview.

-o .

_ ENCLOSUREi2 ,

.n INPO EVALUATION TRIP REPORT OF - f ,' -

TEAM MEMBERS EXPERIENCE ANO QUALIFICATION MO. JCINED SR0 EVALS. INPO MISC BWR DEGREE-AREA *POS -EXPERIENCE BWR MS -- 33 '82 --

Team Manager MGR. Comm. Power Plant / Navy CWR MS SR0 Cert (BWR) 26- '83 --

Asst Team Mgr MGR. Power Plant Vendor'

-- BS SRO Cert (8WR) :21 '65 --

OP MGR. Navy BWR SRO Lic. (BWR) 0 '90 LOAMEE OP TR. Comm. Power Plant BWR SRO Lic. (BWR)

OP PEER Comm. Power Plant 14 '88 --

MA MBR. Architect Engineer -- BS --

Comm. Power Plant BS -- 5 '89 --

MA MBR. Comm. Power Plant Comm. Power Plant BWR MA PEER Comm. Power Plant BWR MA PEER

-- MS SR0 Cert (PWR) 10 '89 --

TS MER. Comm. Power Plant MS SR0 Cert (PWR) 4 '89 LOANEE OE MBR. Comm. Power Plant 0 '89 --

DE TR. Architect Engineer -- MS --

BWR BS SR0 Cert (BWR) 17 '86 --

DE MBR. Power Plant Vendor

-- B5 -- 10 '89 --

RP MBR. Comm. Power Plant / Plant Vendor

-- BS -- 31 85 REPEAT CY MBR. Power Plant Vendor BWR -- 0 '90 LOANEE CY TR. Comm. Power Plant B5 -- 20- '84 --

TO MBR. Architect Engineer / Navy --

BWR SR0 (BWR)&(PWR) 1 '90 --

TQ TR. Comm. Power Plant

• MGR. Manager

• MBR. Team Member

• TR. Trainee Peer presence during discussions with licensee personnel centributed significant corroboration of.

OBSERVATION: Peers on the team helped to keep the team celibrated.with the INPD team members observation and conclusions.

latest industry feelings ar.d state of- the art tect.nological advance information.

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