ML16341G858
| ML16341G858 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/18/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341G857 | List: |
| References | |
| 50-275-92-34, 50-323-92-34, NUDOCS 9302230185 | |
| Download: ML16341G858 (46) | |
See also: IR 05000275/1992034
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
.
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
BOARD REPORT
Nos. 50-275/92-34
and 50-323/92-34
PACIFIC GAS 5 ELECTRIC COMPANY
DIABLO CANYON POWER
PLANT
JULY 1,
1991
THROUGH DECEMBER 31,
1992
9302230i85
930228'DR
ADOCK 05000275
8
e
r
STABLE OF CONTENTS
I. Introduction..............
II.
Summary of Results
A.
Overview.
.
.
.
B.
Results of Board Assessment
.
III. Performance
Analysis
Pacae
~
0
~
1
~
~
~
2
~
~
~
2
A.
B.
C.
D.
E.
F.
G.
Plant Operations.
Radiological Controls
.
.
.
.
Maintenance/Surveillance.
.
.
Emergency
Preparedness.
.
.
.
Security.
.
.
.
.
.
.
.
.
.
.
Engineering/Technical
Support
Safety Assessment/guality
Veri
~
~
~
ficatione
~
~
~
~
3
~
~
o
5
~
~
0
7
~
~
~
9
11
13
16
IV.
Supporting
Data
and Summaries
A.
B.
C.
D.
E.
Licensee Activities
.
Inspection Activities
.
Enforcement Activity
Confirmatory Action Letters
.
Licensee
Event Reports.
.
.
.
19
20
21
21
21
t
I.
INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) is an integrated
NRC staff effort to collect available observations
and data
on
a periodic
basis
and to evaluate
licensee
performance
based
on this information.
The
program is supplemental
to normal regulatory processes
used to ensure
com-
pliance with NRC rules
and regulations.
It is intended to be sufficiently
diagnostic to provide
a rational basis for allocating
NRC resources
and to
provide meaningful
feedback to licensee
management
regarding the NRC's
assessment
of their facility's performance
in each functional area.
An NRC SALP Board,
composed of the
membei s listed below,
met in the
Region
V office on January
21,
1993, to review observations
and data
on
the licensee's
performance
in accordance
with NRC Manual Chapter 0516,
"Systematic
Assessment
of Licensee
Performance."
This report is the NRC's assessment
of the licensee's
safety performance
at Diablo Canyon
Power Plant for the period July 1,
1991 through
December 31,
1992.
The
SALP Board meeting for Diablo Canyon
was attended
by:
V~iN
b
K. Perkins,
Director, Division of Reactor Safety
and Projects,
RV (SALP
Board Chairman)
H. Virgilio, Assistant Director for Region
IV & V Reactors,
Division of
Reactor Projects III, IV, V,
R. Scarano,
Director, Division of Radiation Safety
and Safeguards,
RV
L. Miller, Chief, Reactor Safety Branch,
RV
P. Johnson,
Chief, Reactor Projects
Section
1,
RV
S. Peterson,
Project Manager,
M. Hiller, Senior Resident
Inspector,
Diablo Canyon
Other Attendees
J.
Reese,
Chief, Facilities Radiological Protection
Branch,
RV
R. Pate,
Chief, Safeguards,
Emergency
Preparedness
and Non-Power Reactor
Branch,
RV
D. Kirsch, Technical Assistant,
RV
P. Horrill, Chief, Operations
Section,
RV
M. Ang, Chief, Engineering Section,
RV
P. Narbut,
Team Leader,
RV
D. Schuster,
Safeguards
Inspector,
RV
A. Hcgueen,
Emergency
Preparedness
Analyst,
RV
L. Norderhaug,
Safeguards
Inspector,
RV
L. Coblentz,
Radiation Specialist,
RV
D. Corporandy,
Project Inspector,
RV
C. Hyers,
Reactor Inspector,
RV
l I
'\\
II.
SUMMARY OF RESULTS
A.
Overview
The licensee's
overall performance level during this assessment
period was
good or superior in all areas.
Examples of superior
performance
were
demonstrated
by relatively event-free operation,
low occupational
radiation exposure,
awareness
and training of personnel
to minimize safety
risks during outages,
prompt and aggressive
response
to indications of
cracking in feedwater piping nozzles,
and aggressive
and well focused
insight into performance
weaknesses
by the Onsite Safety Review Group.
The strengths
observed
in the Operations,
Radiological Controls,
Engineering/Technical
Support,
Emergency
Preparedness,
and Safety Assess-
ment/guality Verification functional areas
resulted in these
areas
being
rated
as Category
1.
The board noted in the functional area of
Maintenance/Surveillance
that early in the
SALP period there were
a few
problems involving prompt problem identification and resolution,
and
engineering
involvement in maintenance
issues.
The board concluded,
however, that the overall performance
was superior
based
on strong
corrective actions
and very high quality performance
throughout the
remainder of the pe} iod.
While strengths
were noted in the security area,
security management
did
not appear to have conducted
an adequately
broad examination of their
activities to assure
a high standard of performance
throughout the
organization.
The board discussed
NRC-identified problems at length,
particularly in comparison with the high level of performance
seen in most
of the security organization.
While corrective actions
were taken for
specific problems identified by the
NRC, it appeared
that the requirements
of the security organization
had not been
implemented with a consistent
level of assurance
of quality.
Although management
appeared
to have
corrected
weaknesses
noted during the previous
SALP period,
weak manage-
ment involvement in maintaining high quality in all security program areas
detracted
from otherwise superior performance
in this area.
B.
Results of Board Assessment
Overall, the
SALP Board found the performance of NRC licensed activities
to be very effective and directed toward safe operation of Diablo Canyon.
The
SALP Board has
made specific recommendations
in most functional areas
for licensee
management
consideration.
The results of the Board's
assess-
ment of the licensee's
performance
in each functional area,
along with the
results
from the previous period,
are
as follows:
Functional
Area
Rating
Last
Period
Rating
This
Trend
Period
Trend
A. Plant Operations
B. Radiological Controls
C. Maintenance/Surveillance
D. Emergency
Preparedness
E. Security
III
I
Improving
2
Improving
f
j
~
F. Engineering/Technical
Support
G. Safety Assessment/
guality Verification
III. PERFORMANCE ANALYS S
The following is the Board's
assessment
of the licensee's
performance
in
each of the functional areas,
along with the Board's conclusion for each
area
and its recommendations
with respect to licensee
actions
and
management
emphasis.
A.
Plant
0 erations
~nal sis
During the assessment
period, the resident
inspectors
conducted
frequent inspections
involving observation of operations activities.
Some engineering
section
and project inspector inspections
also
evaluated
operations activities.
Review of operations activities
accounted for about
34 percent of the total inspection effort.
The last
SALP assessment
rated the licensee's
performance
in this
area
Category I.
Strengths
were noted in relatively event-free
operation,
and in superior operator
response
to plant transients.
Operations
exhibited significant strength
in conservative
operational
decisions.
The previous
SALP Board also noted weaknesses
in occa-
sional lack of timeliness in identifying and resolving problems
and
in issuing operability determinations.
During this
SALP assessment
period, the licensee
continued to show
superior performance
in this area.
Strengths
were observed
in the
general
high quality of the Operations staff's performance,
and in
relatively event-free
and uncomplicated
operations.
Management
involvement
has
been frequent
and probing,
assuring timeliness in
identifying and resolving problems
and in making operability deter-
minations.
Operations
management
has set high performance
standards
which have usually been
met or exceeded.
Recovery from each event,
regardless
of cause,
and the subsequent
root cause
investigation indicated significant strengths.
This was
due in part to a high level of skill and sense of ownership
among the
Operations staff,
and to intensive
management
involvement at all
levels of the organization.
During operations
at power and during outages,
the Operations staff
showed strong
awareness
of overall plant safety system availability
and the significance of evolutions relative to the risk to the plant.
This appeared
to have
been
a direct result of aggressive
management
commitment to plant safety
and risk reductions.
The licensee
developed
and implemented
a comprehensive
and effective outage
plan
that appropriately considered risk associated
with plant shutdown
evolutions.
Operations staffing levels, appeared
to be appropriate,
and operations staff qualifications were strong.
Other examples of significant strengths
were
as follows:
~
Active Operations
involvement with maintenance
crews near
sensitive
equipment
helped to avert events.
Documentation of operability determinations
was strong, timely
and consistent.
Also,
a very low threshold
was established
for
the level of equipment degradation
which required
an operability
evaluation.
Operations
simulator training was challenging
and effective,
and
critiques
appeared
to be appropriately critical and probing.
Toward the end of the
SALP period, Operations
personnel
were
progressively
more alert to anomalous
plant conditions.
For
example,
an operator's
observation
and followup of a failed
fastener resulted in identification and repair of a degraded
neutral
connector to a main tr'ansformer, potentially averting
a
plant trip.
During this
SALP period,
two severity Level
IV violations occurred in
this area.
One was
a repeat violation, for operation in Modes
2 and
3 with one of two reactor cavity sump wide range level channels
The other violation involved inadequate
instructions to
operators for avoiding excessive
piping vibration on loss of speed
control to the positive displacement
charging
pump.
Neither had
an
impact
on safe plant operation,
and each of these
instances
was
promptly corrected.
During the first part of the
SALP period,
a few Licensee
Event
Reports
(LERs) were issued
as
a result of personnel
errors.
Although
this was not an unusually high rate,
the concern
was that it indi-
cated
an increasing trend.
The personnel
error rate
was reduced
later in the assessment
period
as
a result of strong
management
involvement.
Four isolated
instances
of minor weakness
were observed,
either in
following procedures
or in coordination with other groups.
The most
significant involved an inadvertent
chemical spill, which generated
noxious
fumes
and prompted declaration
of an Unusual
Event.
Another
instance
occurred
as
a result of unclear procedures,
which allowed
a
condenser
vacuum
pump to be started
before its seal
water isolation
valve was opened.
This ultimately resulted
in a reactor trip.
In
each of these
cases,
root cause
evaluation
and corrective actions
were immediate
and appeared
appropriate.
In summary,
the performance of Operations
has
been strong,
and
has
continued to improve.
Weaknesses
have
been minor, isolated
and
infrequent,
and have
been corrected
promptly and appropriately.
2.
Performance
Ratin
Performance
Assessment:
Category I
3.
Recommendations
None
B.
Radiolo ical Controls
l.
~na)
s
s
Radiological controls inspections
during this SALP period found that
the licensee
continued to be aggressive
in assuring quality.
Radio-
active effluents continued to decrease,
and occupational
dose
was
reduced in 1992 despite
a demanding
outage
schedule.
A continued
strength
was the licensee's
innovative approaches
to improving
measures
for personnel
radiation protection.
Minor weaknesses
identified, related to radiological posting
and labeling,
were solved
rapidly and thoroughly.
Regional
inspectors
examining this
functional
area contributed approximately
5 percent of the total
inspection effort during this assessment
period.
The licensee's
radiological controls performance
during the previous
SALP period was rated Category
1.
The previous
SALP Board recom-
mended that management
continue to fully support site
and corporate
initiatives for improving performance.
The board also
recommended
added
emphasis
toward correcting minor weaknesses
in controlling
personnel
contaminations,
reducing the backlog of non-Technical
Specification radiation monitoring equipment
needing calibration,
and
training dosimetry clerks
and radwaste
handlers.
During this assessment
period,
management
continued to be proactive
in assuring quality.
The ALARA awareness
program,
established
to
reward outstanding
outage
performance,
continued to be
an effective
incentive toward meeting rigorous
ALARA goals.
The
1991 average
occupational
dose per reactor
was
273 person-rem,
and for 1992 was
214 person-rem.
Liquid effluents continued to decrease.
Gaseous
effluents were also maintained
at
a small fraction of the Technical
Specification limits.
Management
support
was evident in the elaborate
remote monitoring
capabilities
used to support
shot peening
and eddy
current testing during the
1R5 outage.
Use of this equipment
significantly reduced
both the dose received
and the radiological
risk involved in conducting several
complicated,
high-dose tasks at
once.
In addition, corporate
involvement
and support
was evident in
continuing efforts associated
with a major upgrade of radiation
and
effluent monitoring equipment.
The licensee's
approach to resolving technical
issues
was conserva-
tive and timely, and demonstrated
a clear understanding
of the issues
involved.
In September
1992, the licensee voluntarily made
a presen-
tation to members of the
NRC Region
V staff concerning
the status of
radiation monitoring system upgrades.
Detailed alternate
monitoring
methods
had
been analyzed,
for use during interim periods while sys-
tem upgrades
were being performed, to ensure
proper monitor ranges,
efficiencies,
and sensitivity to airborne radioactivity.
Technical
improvements
were observed
in licensee
programs for radwaste classi-
fication, the process
control program,
and radiological environmental
monitoring.
Technically sound judgment
was also in evidence in the
licensee's
radiological controls preparations for potential
high-dose
outage tasks,
such
shot peening,
eddy current inspection,
and core barrel inspection.
Licensee
management
support of training was demonstrated
by the
extensive efforts made in mock-up training prior to the IR5 outage.
The steam generator
mock-up included
a fully operational
shot-peening
apparatus.
One weakness
was observed
involving failure to thoroughly
train eddy current testing personnel
on the impact that shot peening
would have
airborne radioactivity hazards.
A
Severity Level
IV violation was cited for the resulting hazard.
The
licensee
took prompt corrective action to resolve this weakness.
The licensee's
other training practices
continued to exhibit
excellence.
Training and qualification programs
made
a positive
contribution to the understanding
of radiological controls issues
and
adherence
to procedures.
Staff members
were kept abreast
of industry
knowledge
and development
through extensive participation in offsite
owners'roup
meetings,
Electric Power Research
Institute
(EPRI)
conferences,
and other opportunities for offsite involvement.
An
improvement
was noticed in the licensee's
training of radwaste
handlers.
Training on the
new
10 CFR 20 requirements
also continued
for appropriate
personnel.
The licensee's
site
and corporate radiological controls
and chemistry
groups continued to be well staffed.
Key positions
were generally
filled on
a priority basis.
Authorities and responsibilities,
both
in the chemistry
and radiation protection organizations,
were well
defined,
and resulted in clear communications
both within the groups
and with other site organizations.
One voluntary Licensee
Event Report
(LER) was submitted relevant to
radiological controls during this assessment
period.
The
LER dealt
with overexposures
received
by contract radiographers,
due to
personnel
error by the radiographers
while performing radiography
on
the licensee's
site.
Three Severity Level
IV violations were
identified in this functional area.
Two resulted
from inadequate
posting
and labeling,
and
one involved the failure to implement
procedures
to control airborne radioactivity from steam generator
work.
Neither the violations nor the
LER indicated
a programmatic
breakdown of the radiation protection program.
The licensee's
root
cause
analyses
and corrective
actions
were prompt and were
effectively implemented.
2.
Performance
Ratin
Performance
Assessment:
Category I
3.
Board Recommendation
None.
4
C.
Maintenance
Surveillance
l.
~Anal sis
During the assessment
period, the resident inspectors
conducted
frequent inspections
which included observation of maintenance
and
surveillance activities.
Engineering inspections
also evaluated
maintenance
and surveillance
programs.
Review of maintenance
and
surveillance activities accounted
for about
10 percent of the total
Diablo Canyon inspection effort.
The last
SALP assessment
rated the licensee's
performance
in this
area Category 2.
Strengths
were noted in the initiation of a program
for trending safety equipment out-of-service time,
and in the use of
to evaluate
preventive maintenance
programs.
Weaknesses
were noted in a lack of management
aggressive-
ness in dealing with problem areas;
occasional
failure to follow
procedures,
resulting in safety significant events;
and
a tendency
for personnel
errors
due to lack of self-verification.
The licensee
was encouraged
to involve management
in timely problem identification
and root cause investigation,
and to continue to support industry
initiatives.
During this assessment
period, the licensee generally displayed
improved performance
in this area.
Virtually trouble-free plant
operation
evidenced
a high quality of maintenance
work in that no
plant events
and almost
no equipment failures occurred
as
a result
of improper maintenance.
Strengths
were observed
in the general
high quality of maintenance
and surveillance
work.
Additionally,
a
high level of management
involvement in scheduling
and planning
maintenance
and surveillance
work maximized safety system avail-
ability from a probabilistic risk standpoint,
both at power and
during outages.
This resulted
in a considerable
benefit to plant
safety.
Noteworthy strengths
were
as follows:
Outa
e Mana ement:
The management of outages
was marked
by an
overriding understanding
and emphasis of the probabilistic risk
of each job and evolution.
Work crews
and planners
were trained
and
aware of the safety significance of the jobs
and systems
on
which they worked at every stage of the outage.
g lfff I: Tt t
I
I
g
dt ltfl
I
p
g
f
Maintenance
personnel
was strong.
Well maintained training
facilities and
a dedicated training staff were significant
factors in good performance,
as
was the sense of ownership
shown
by Maintenance
personnel.
pl f: Iftt
p
I
t
I
d plf
d
,regarding overall plant safety
system availability and the
significance of their individually assigned
work relative to its
risk to the plant.
C~
~
Prioritization of Work:
Outstanding
work items were well
prioritized, with safety-significant
issues
given high priority.
The backlog of non-outage
safety related work items
was low.
~
Root Cause Investi ations:
The routine involvement
and
leadership
shown
by the Plant Maintenance staff in root cause
investigations
was
a significant strength,
as
was the routine
integration of the Maintenance,
Operations,
and Engineering
staffs in maintenance
and surveillance operations.
~
Reduction of Personnel
Errors:,
A relatively high number of
personnel
errors were observed
at the beginning of the
period.
Several of these errors resulted
in conditions which
prompted
a Licensee
Event Report or Non-conformance
Report.
This number was reduced
by about half during the remainder of
the period due to a high level of management
involvement
throughout the organization.
Res
onse to Problems:
Overall, the maintenance staff improved
their response
to problems
by identifying, analyzing
and cor-
recting maintenance
and surveillance
problems promptly.
This
represented
an improvement
over the last assessment
period.
Examples of this improvement were the identification and correc-
tion of an incorrect reactor coolant
system leakage surveil-
lance;
prompt, in-depth evaluation
and compensatory
action for
problems with auxiliary feedwater
pump steam
admission valve
FCV-95;
and
improvement of the clarity of some instrumentation
and control surveillances.
Four Level
IV violations were cited in this area,
involving improper
maintenance
of containment
fan cooler unit
(CFCU) backdraft dampers,
failure to perform
a containment airlock surveillance, failure to
identify inconsistencies
in a pump vibration measurement
procedure
by
writing an action request,
and improper rigging of a cask.
In some
cases,
as illustrated
by the inoperable
containment
fan cooler unit
backdraft
Engineering
involvement should
have
been
more
timely.
Improper maintenance
of CFCU dampers
was significant in that
the dampers
were not functional,
and only after additional analysis
did the licensee
determine that the
CFCUs
had
been operable despite
the improper maintenance.
These
concerns
appear to have
been iso-
lated,
although the
CFCU issue
was potentially significant to safety.
Other weaknesses
were also observed.
One example
was the improper
tightening of setscrews
on
some motor operated
valve actuators,
resulting in a common
mode failure vulnerability.
Additional, less
significant weaknesses
were observed.
Host were identified by the
licensee
immediately upon occurrence.
Management
involvement was
effective,
and identified problems
were promptly and appropriately
corrected.
Host of these'xamples
occurred early in the
SALP period.
Since that time, significant improvement
has
been noted.
Performance
Rati
Performance
Assessment:
Category I
l
3.
Board Recommendations
The Board encourages
continued intrusive Engineering
involvement in
maintenance
and surveillance
issues,
and focused
management
involvement to ensure
continued
low levels of personnel
errors
D.
Emer enc
Pre
aredness
1.
~na1 sis
Two routine emergency
preparedness
(EP) inspections
and two annual
emergency
exercise
team inspections
were conducted during this
assessment
period.
Review of the
EP program accounted for approxi-
mately
6 percent of the Diablo Canyon inspection effort.
A strength
identified during the current
assessment
period was in making timely
and appropriate classifications
during most actual
emergency
events,
exercises
and drills.
A weakness
was noted regarding the making of
protective action recommendations
(PARs) to offsite agencies
during
the
1991
annual
emergency
exercise.
Generally,
licensee
performance
in the
EP area
appears
to have
improved over the assessment
period.
The licensee's
EP performance
in the last
SALP cycle was rated
Category 2.
The
SALP board at that time indicated several
recommen-
dations:
that management
ensure
the establishment
and implementation
of an effective corrective action plan for drill and exercise
findings; that licensee
management
evaluate
the adequacy of classroom
training provided to emergency
response
personnel
and ensure that
personnel
are given
an adequate
number of opportunities to practice
their assigned
tasks during periodic drills; that the additional
dose
assessment
training provided to Control
Room personnel
continue; that
the need to adhere to radiation protection procedures
under simulated
emergency
conditions also
be stressed
during classroom training and
drills; that administrative
procedures
be enhanced
to ensure that
drills and exercises
consistently
meet
emergency
plan requirements;
and that simulation of sample collection during drills and exercises
be avoided to enhance
realism
and increase
the training value.
During the current
assessment
period, licensee
management
appeared
actively involved in
EP activities
and demonstrated
support
by
providing the necessary
resources
to the
EP staff.
Hanagement
took
interest in correcting
problems
and responding to
NRC findings which
indicated
a need for corrective action.
During the assessment
period,
the licensee
worked closely with the state,
local county
governments,
and
FEHA in resolving issues
in offsite preparedness
planning.
Each of the recommendations
from the previous
SALP Board
was addressed
by the licensee
during this assessment
period.
Cor-
rective actions
were evaluated
by the
NRC during routine inspections
and observation of the two annual
exercises,
and improvement
was
noted in each
area.
Dose assessment
and projection, in particular,
were noted
as strengths
in response facilities during the l991 and
1992 annual
emergency exercises.
Licensee
management's
approach to the resolution of technical
issues
appeared
generally timely and thorough.
During the assessment
t,p
-10-
period,
the licensee significantly upgraded
the emergency warning
siren system.
The new primary system
was completed,
tested
and
turned over to the county with 100 percent activation in September
1992.
The upgrade
provided several
new capabilities
such
as
an
activation system which allows selective
sounding of individual or
groups of sirens
as
opposed to the entire system,
and
a siren
feedback
system which provides input to the county when
a "runaway
sounds without intended activation.
One
EP exercise
weakness
was identified during the
1991 annual
emergency
exercise.
The licensee's
system for providing Protective
Action Recommendations
(PARs) appeared
excessively
complicated
and
caused
delay in the issuance of PARs.
The system
was not based
solely on plant conditions
as would be appropriate,
but included
coordination of PARs with offsite agencies.
This delayed
and
possibly biased the licensee's
decision making.
The appropriate
emergency
plan implementing proceduy e (EPIP)
was revised to insure
licensee
independence
in PAR decision
making
and was validated
through training, drills and exercises.
The system
appeared
to have
been effectively implemented during the
1992 annual
exercise.
There were no'nforcement
actions in the
EP area during the assess-
ment period.
Notifications to the
NRC and offsite agencies
were
consistent with regulatory requirements.
The licensee
reported nine
unusual
events to the
NRC during the assessment
period, including
three earthquakes
detected
at the site.
The other events
were
a
(RCS) leak,
a grass
and brush fire near the
site,
a turbine stop valve failure,
a sulfuric acid spill, radiation
of two contractor
employees,
and
a temporary loss of
communications with the California Office of Emergency Services.
All events
appear to have
been properly identified and analyzed
in
accordance
with regulatory requirements.
EP staffing was
an apparent
strength,
and staff members
appeared
conscientious
toward accomplishment of their assigned
duties.
No
significant changes
occurred in the composition of the emergency
response
organization
(ERO) during the assessment
period.
The
licensee
had
a system to ensure that
new
ERO personnel
were properly
trained prior to assignment
to emergency organization positions.
EP staff and emergency
response
positions
were clearly identified;
authorities
and responsibilities
appeared
clearly defined;
and key
positions
were filled as appropriate.
Decision-making authority
appeared
properly delegated
to ensure
quick identification of and
response
to problems
and changes.
Emergency facilities continued to
be appropriately maintained
and appeared
ready for rapid activation.
The licensee
provided adequate
levels of dedicated staff to implement
the programs
and to interact appropriately with offsite agencies.
During the assessment
period, the licensee
implemented .what appeared
to be
a substantial
change to the
EP training program.
Previously,
the site
and corporate
headquarters
had separate
EP training programs
and responsibilities.
The company-wide responsibility for EP
training management
and accomplishment
was shifted entirely to the
site.
A system
was established
to ensure that required training is
-11-
2.
conducted
and that training due dates
are not exceeded,
by linking
accomplishment of EP training requirements
to unescorted
access
privileges.
To supplement
and reinforce routine annual training,
a
program of monthly integrated drills was conducted.
Performance
Ratin
3.
Performance
Assessment:
Category I
Board Recommendations
The licensee
should strive to maintain
a consistent
level of
management
oversight to continue
and improve on the program quality
achieved during this assessment
period.
E.
~Secnrit
~Anal sis
During this
SALP period,
approximately
4 percent of direct inspection
effort was applied to the licensee's
physical security
and fitness
for duty programs.
In addition to region
based
inspections,
the
resident
inspectors
also monitored implementation of this program
as
part of their routine inspection activities.
The previous
SALP report rated the licensee's
performance
Category 2,
Improving, for Security.
Primary weaknesses
identified in that
report focused
on personnel
access
control to vital areas
and
failures of compensatory
security measures.
These
weaknesses
were
significantly reduced during the current
assessment
period.
In the
previous
SALP report, the Board encouraged
the licensee to resolve
a
longstanding
weakness
in the
CCTV alarm assessment
capability,
initially identified during
a 1986 Regulatory Effectiveness
Review.
A significant equipment
upgrade to incorporate
a video capture
system
was installed during the current
assessment
period
and
has largely
eliminated this weakness.
Some minor limitations remain with the
video capture
system
and the licensee is actively exploring further
equipment
and/or procedural
improvements.
The licensee's
performance in the areas of physical security
and
fitness for duty appeared,
on the basis of inspections
conducted,
event reports,
and other observations
and analysis,
to be good in all
assessment
areas.
Both program strengths (vital area barriers
and
armed response)
and weaknesses
(effectiveness
of the audit program
and the
number of pending requests
for security equipment modifica-
tion or maintenance)
have
been noted during the assessment
period.
Principal strengths
in the licensee's
security
and fitness for duty
programs
included control of access
to vital areas,
the use of roving
patrols dedicated
to armed response
(carrying carbines
or shotguns,
as appropriate,
as well as side arms),
and the availability of
Employee Assistance
Programs for contractor employees.
A major
program upgrade to establish
a search train at the intake structure
protected
area
was completed during the assessment
period.
C
'I
A principal program weakness
was noted concerning the number of cited
and non-cited violations that could have
been identified and
corrected
by a stronger audit program.
This indicated
a need for
increased
management
attention to upgrade the audit program
and
make
it more effective.
Although the licensee
has
been
aware of a large backlog of action
requests
for maintenance
or modification to security equipment,
little progress
was
seen in addressing this concern.
This was also
seen
as
a program weakness.
Discounting action requests
of an
administrative nature or otherwise having no direct effect on
security activities, approximately
90 requests
were identified as
being more than
90 days old, nearly half of which were more than
a
year old.
A more effective audit program could have identified this
weakness.
This further demonstrated
the need for increased
management
attention.
One Licensee
Event Report dealing with safeguards
matters
(requiring
prompt reporting pursuant to 10 CFR 73.71)
was issued
and adequately
resolved during the
SALP period.
This report dealt with failure of
circuit boards in the alarm annunciation
system,
and prompted
a full
replacement
of the obsolescent
components
which is scheduled
to be
completed in the near future.
However, technical
issues
discussed
in
two reports
issued in January
and December
1990,
and dealing with
backup
power to communications
equipment
and vital equipment pro-
tected
by compensatory
measures,
respectively,
remain to be resolved.
Enforcement
actions during the assessment
period included four viola-
tions,
which were resolved
by appropriate corrective actions:
one
each related to access
control at the main and intake structure
protected
areas,
one violation related to protection of Safeguards
Information,
and
one violation related to urinalysis testing of
fitness for duty program personnel.
Two weaknesses
related to
fitness for duty and four non-cited violations dealing with vital
area
access
control, communications,
lighting, and protection of
Safeguards
Information were promptly corrected
by the licensee.
The licensee's
loggable safeguards
events
were promptly and
completely reviewed
and reported
as required.
The root cause
and
trend analyses
of these
events
determined that most of the events
were related to aging equipment
scheduled for replacement
by major
hardware
upgrades
then underway.
The frequency of occurrence
has
exhibited
a decreasing
trend
as those projects
have
been completed.
Licensee staffing appeared
effective in most areas,
although the
identified long delays in resolving security related action requests
may indicate
a need for additional senior
management
support.
Key
positions
have
been identified and responsibilities
are well defined.
Decision making authority appears
properly assigned
to ensure
prompt
identification and response
to program challenges.
During the
current
assessment
period,
management
implemented
team development
workshops for all staff.
This training showed significant promise in
improving staff communications
and cohesiveness.
J
-13-
The licensee's
guard training and qualification program was well
defined
and implemented with dedicated
resources.
During this SALP
period,
the licensee initiated sophisticated
contingency drills
incorporating diversionary tactics
and covert penetrations.
2.
Performance
Ratin
Performance
assessment:
Category 2, Improving
3.
Board Recommendatio
Licensee
management
is encouraged
to more effectively identify and
address
weak areas.
Nore attention should
be given to improving the
effectiveness
of the audit program
and to reducing the number
and
age
of outstanding
maintenance
requests.
F.
En ineerin
Technical
Su
ort
l.
~Anal sis
During the assessment
period,
NRC regional
and Headquarters
inspectors
conducted
a total of twelve inspections.
Two of these
inspections
were team inspections
which addressed
motor operated
valves
and shutdown risk management.
The other inspections
involved
facility modifications,
design
changes,
inservice inspection
and
testing,
erosion/corrosion
monitoring,
eddy current testing of steam
generator
tubes,
and procurement of a new emergency
diesel
generator.
The resident
and project inspectors
also conducted
inspections
in
this area.
Review of Engineering
and Technical
Support activities
accounted for approximately
15 percent of the total Diablo Canyon
inspection effort.
The last
SALP assessment
rated the licensee's
performance
in this
functional
area Category l.
Improvements
were recognized
in Engi-
neering
involvement in plant operations
and modification work, design
basis
reviews, setpoint reverification,
vendor interface,
personnel
qualification and training.
A particular strength
was found in the
commercial
grade dedication
program.
Some weaknesses
were noted in
incomplete technical
work and untimely identification and resolution
of problems
due to
a weak sense of ownership of plant problems.
The
Board recommended
that the licensee
provide emphasis
on early
identification, effective engineering
involvement,
and timely and
thorough correction of plant problems.
The licensee
was encouraged
to continue building a strong interface
between corporate
and plant
engineering
groups, with corporate
engineering taking
a leadership
role in the resolution of plant problems.
Continuation of innovative
corporate
engineering training programs
was specifically encouraged.
During this
SALP assessment
period, the licensee
showed continued
high quality performance
in this functional area.
Strengths
were
observed
in a generally aggressive
and .thorough engineering attitude
in resolving technical
problems,
an extensive erosion/corrosion
monitoring program,
eddy current testing of steam generator
tubes,
assessment
of probabilistic risks to the shutdown plant,
and overall
-14-
engineering
involvement in plant operational activities.
The
staff observed excellent quality in the technical
content
and
presentation
of licensee
submittals,
which included documents
in
support of license
amendment
requests,
corrective actions regarding
operations
and Licensee
Event Reports,
and responses
to
NRC bulletins
and generic letters.
Improvements
were observed in timely problem
identification, engineering
involvement,
and problem ownership.
Minor weaknesses
were noted related to procurement of the
new
emergency diesel
generator
(EDG) and certain inservice inspection
and
testing activities.
Engineering
involvement in resolving safety issues
was generally
timely.
The most significant exception
was Engineering
s assessment
of problems with containment
fan cooler unit (CFCU) backdraft dampers
in early 1992.
Additionally, resolution of Regulatory
Guide 1.97
issues
was delayed
by inadequate
tracking of engineering
actions,
but
the licensee later identified this weakness
and pursued resolution in
an aggressive
manner.
Substantial
improvement
was displayed later in
the
SALP period in Engineering's
timely resolution of CFCU damper
blade cracking.
Strong Engineering
performance
and initiative were evidenced
in
Engineering's
evaluation of setscrew
loosening
on motor operated
valve
(HOV) actuators
and the licensee's
decision to examine the
feedwater nozzles in response
to problems
observed
at
another facility.
The feedwater nozzle examinations
were extensive
and
used state-of-the-art
techniques.
The Engineering staff's
assessment
of crack indications in both feedwater piping and in a
safety injection tank penetration
resulted
in a conservative
decision
to replace affected piping segments.
Proactive
Engineering
involvement was observed
in the development of
an extensive erosion/corrosion
monitoring program.
Despite extensive
involvement with the industry in the development of predictive analy-
tical computer
programs,
poor correlation
between the quantitative
predictions
and measured
wear rates
had
been experienced
by the
licensee.
The licensee's
program exhibited
a defense-in-depth
approach to compensate
for recognized limitations in the state of the
art.
Although a program weakness
in the measurement
of pipe wall
thickness
was noted,
strong engineering
ownership of the program
compensated
for this minor weakness.
Throughout the
SALP review period, the licensee
demonstrated
an
aggressive
engineering attitude in technical
problem resolution.
For
example,
the licensee instituted
a supplemental
program that is the
first surveillance
program in a U. S. commercially operated
reactor
vessel
to investigate
the effect of annealing
and reirradiation
on
its reactor vessel beltline materials.
Another example of aggressive
engineering
was resolution of the long-
term seismic
program.
The licensee
performed
a detailed analysis to
demonstrate
that adequate
seismic margins exist for the structures
and equipment
which could be affected
by increased
ground motion in
certain frequency ranges
at the Diablo Canyon site.
-15-
The licensee
also developed
and implemented
an effective outage risk
assessment
plan which was found superior to other plants which were
inspected.
The technical
support provided for the outage risk
assessment
plan was excellent.
The engineering
program developed for eddy current testing
(ECT) of
tubes
was observed to be
a high quality program
incorporating current technology
and industry guidance.
However,
a
weakness
was noted in that engineering guidelines for ECT data
analysis
and defect acceptance criteria, although adequate,
were not
controlled through the use of formal plant procedures.
Specific strengths
noted in engineering activities were
as follows:
The motor operated
valve
(MOV) program was found to be
aggressive
and conducted
in a well integrated
manner.
A minor
weakness
was identified in the lack of timely determination of
operability following testing,
due to the complexity of the
engineering
evaluation required to evaluate the test data.
A strong safety perspective
was evident in the development of
engineering
programs to resolve
emerging technical
issues.
The
programs
were implemented with priority on safety significance.
guality assurance
involvement
was evident in the implementation
of engineering
programs.
Design
change
packages for the installation of a new emergency
diesel
generator
were generally thorough
and complete,
although
minor housekeeping
and cleanliness
deficiencies
were observed.
Four Severity Level
IV violations,
one Level
V violation and one non-
cited violation were identified.
The violations were minor in nature
and did not evidence
programmatic
breakdowns.
The low number of engineers
and lack of clear goals for the plant's
System Engineering staff was
a concern earlier in the
SALP period.
The licensee
has since
increased
the staff and clarified the goals
for this group,
and
some
improvement
has
been observed.
The commercial
grade dedication of the sixth emergency diesel
generator
(EDG) presented
unique challenges
to the licensee's
engineering
and procurement activities.
The Region
and
NRR Vendor
Branch identified weaknesses
in the quality of the procurement
and
commercial
grade dedication of the
new emergency diesel
generator.
However, the licensee's
root cause investigation
was candid
and
thorough.
Also, although
most problems
encountered
during testing of
the sixth
EDG were found to have
been
documented
and resolved,
the
test
program did not require formal documentation of problems.
This
weakness
was promptly corrected after identification by the
NRC.
Inservice inspection
and testing activities were found to comply with
approved
programs.
Observed deficiencies
in personnel
qualifications
4
J
0
-16-
and procedural
adherence
indicated minor weaknesses
in the inservice
inspection
program.
In conclusion,
Engineering
and Technical
Support demonstrated
high
quality, with continued strong performance.
Some weaknesses
were
observed,
but these
were minor in that they appeared
isolated, of
low significance,
and were promptly and appropriately corrected.
2.
Performance
Rati
Performance
Assessment:
Category I
3.
Board Recommendatio
The Board recommends
that licensee
management
provide continued
support for the development
and long term integration of proactive
engineering
programs.
G.
Safet
Assessment
ualit
Veri ication
1.
~Ana1 sis
Evaluation of this area
was
based
on both region-based
and resident
inspections.
Review of Safety Assessment/guality
Verification
activities accounted for about
26 percent of the total Diablo Canyon
inspection effort.
The last
SALP assessment
rated the licensee's
performance
in this
area
Category
1.
Strengths
were noted in the implementation of Event
Investigation
Teams
(EITs).
Weaknesses
were noted in resolving
problems in a timely manner
and in occasional
lack of management
aggressiveness
in dealing with problem areas.
The licensee
was
encouraged
to provide more management
involvement in timely problem
identification and root cause investigation, particularly in the area
of repeat
problems.
During this
SALP assessment
period, the licensee generally
showed
improved performance
in this area.
Hanagement
was more aggressive
and timely in dealing with problems
than during the previous period,
and Safety Assessment/guality
Verification performance
by line and
quality organizations
showed continued
improvement.
A weakness
was
noted in the identification and correction of precursors
of
potentially significant problems.
A significant strength
was the aggressive
implementation of programs
to improve control of safety system availability during operating
and
shutdown
modes.
These
programs
were implemented at all levels of the
licensee's
organization.
Plant design
changes
were also
implemented
to reduce risk, resulting in improved safety performance
and safety
system availability.
Audits performed
by the guality Assurance
organization
were generally
good;
Lack of intrusive involvement by guality Assurance
in problems
such
as the improper maintenance
of the containment fan'ooler back-
C
-17-
draft dampers
was
a weakness.
As discussed
in Section III.E, a need
for more effective audits
was also noted in the Security area.
In
'act,
a factor in several of the problems experienced
during this
SALP period was insufficient gA involvement.
Some
improvement
was
observed
in the latter portion of the
SALP period.
Audits required
by Technical Specifications
were adequate
and appropriate.
Additional audits performed
as guality Assurance initiatives showed
significant technical
depth,
and identified weaknesses
in complex
technical
areas
not typically reviewed by quality organizations.
A
noteworthy improvement in gA effectiveness
was evidenced
in the
increased
use of surveillances,
which are brief audits in specific
areas of concern.
These audits
have allowed rapid focus of gA
oversight in problem areas,
which resulted in more timely management
attention,
root cause evaluation,
and corrective action.
Safety groups continued to be very strong in safety focus
and depth
of technical
assessment.
The Onsite Safety Review Group identified
problems consistent
with issues of higher safety significance.
Management
support of this group was adequate.
The Nuclear Safety
Oversight
Committee
improved during this assessment
period
as
a
result of focus
on higher level concerns,
and the addition of non-
licensee
members.
The Plant Safety Review Committee continued to be
very strong,
providing significant safety insight and conservative
decision
making.
Nuclear Operations
Support
(NOS), which is not by charter
a quality
oversight group,
performed several
reviews
and audits during this
assessment
period which were instrumental
in identifying and
correcting
problems in interfaces
between licensee
organizations.
These
NOS reviews
and audits resulted
in several
improvements
in the
overall
implementation of plant safety functions.
During this assessment
period the
NRR staff reviewed
a large
number
of safety analyses
performed
by the licensee.
The licensee's
submittals
demonstrated
a clear understanding
of safety issues
and
a
conservative
approach to technical
problem resolution.
The submit-
tals for license
amendment
requests
were technically adequate
and
generally complete.
Also, several
of the licensee's
submittals
contained probabilistic risk assessment
(PRA) analyses
which were of
high quality (the
PRA technique
requires
considerable effort by the
licensee,
and when properly used,
adds to the basis for approving
proposed
changes).
The licensee's
replies to
NRC generic letters
and
bulletins were also timely, responsive
and of generally high quality.
Throughout the
SALP review period, the licensee consistently
and
systematically
addressed
operability concerns
in an aggressive
manner,
and
made appropriately conservative
decisions until each
concern
was resolved.
Licensee
management
kept the
NRC well informed
of initial concerns
as well as their followup plans for resolution.
An increased
number of personnel
errors were observed
in several
functional areas
at the beginning of the
SALP period.
This number
was reduced
by about half during the remainder of the period
as
a
I
ly
-18-
result of an effective
human performance
enhancement
program
and
aggressive
management
involvement at all levels of the organization.
The licensee's
program for assessing
industry events
was strong.
A
few vulnerabilities were identifi"ed and corrected
promptly.
Several
programs
were enhanced
as
a result of implementation of lessons
learned
from the industry.
While the licensee typically has
been aggressive
in problem resolu-
tion, there
have
been isolated
examples of insufficient aggressive-
ness
in pursuing safety issues.
For example,
based
on the review of
licensing submittals requesting relief regarding
pumps
and valves,
the licensee's
approach to the resolution of inservice testing
program issues
required amplifying information and in some
cases
were
not technically justified.
Five Severity Level
IV violations were cited in this area,
one for
failure to correct reverse rotation of containment
fan cooler units,
and the others for failure to correct repeated
problems of a lower
safety significance in various functional areas.
A few weaknesses
were observed.
For example,
in three cases,
pre-
cursors of plant problems occurred without being identified as such.
An example of one of these three instances
was
an unplanned turbine
speed-up
event,
corrected
by operators,
which had two precursors
which were not identified and corrected.
In each
case,
the more
significant problem occurred
because
the precursor
had not been
adequately
addressed.
Another weakness
was that the guidelines
used
to trend root causes
of problems
were imprecise,
in that root causes
of problems
could be assigned
to more than
one area.
In conclusion,
the performance of the licensee's
line organization is
very strong in the assessment
of safety
and assurance
of quality.
Independent
safety groups,
although already strong,
showed additional
strength during this assessment
period.
The guality assurance
organization's
performance
was not as strong
as the line organiza-
tions,
but was
above
an adequate
level.
2.
Performance
Ratin
Performance
Assessment:
Category
1
3.
Board Recommendations
The Board
recommends
continued
management
involvement in Safety
Assessment/guality
Verification activities,
and strongly encourages
prompt identification of problems, timely corrective action,
effective guality Assurance
audits
and prevention of repeat
problems.
~ '
-19-
IV.
SUPPORTING
DATA AND SUMMARIES
A.
Licensee Activities
Unit
1
Diablo Canyon Unit
1 entered
the assessment
period at full power and
operated
nominally at full power during the
SALP period, with occasional
brief power curtailments for maintenance
and testing activities, except
as
follows:
On July 5,
1991
an unplanned start of engineered
safety features
(ESF)
equipment occurred
when
a licensed operator inadvertently actuated
the
wrong solid state protection
system test switch.
The control
room
operators
promptly returned all actuated
equipment to normal status.
On March 6,
1992
a plant trip occurred
due to the loss of main feedwater
pump l-l.
The cause of the trip was traced to a faulty fusible link in an
inverter.
Unit
1 was restarted
on March 9,
1992 after
a new inverter was
installed for feedwater
pump l-l and fusible links for feedwater
pump 1-2
were inspected.
Unit
1 reached
100X power on March 10,
1992.
On April 25,
1992, while conducting maintenance
on main feedwater
pump
1-1,
vacuum in the condenser
was lost, causing the main turbine
and
reactor to trip.
The primary cause
was attributed to inadequate
instruc-
tions, which allowed
a vacuum
pump to be started
before its seal
water
isolation valve was opened.
Also, condenser
vacuum
pump suction line
check valve CNC-1-747
was observed
to leak excessively
when the condenser
vacuum
pump suction valve was opened.
Unit
1 was restarted
on April 27,
1992 after evaluation of the event
and correction of the cause of the
trip.
Full power was reached
on April,28,
1992.
On July 24,
1992, after observing excessive
flow noise from main turbine
governor valve number 4, the licensee
closed the valve, resulting in
Unit
1 operating at
98X power.
On September
17,
1992, Unit
1 shut
down for a scheduled
63-day refueling
outage.
The shutdown
was complicated
by spurious
reopening of a main
turbine stop valve and two governor valves,
which caused
the turbine to
accelerate
from 1100
RPH to 1870
RPH.
A few hours later, during the
cooldown, reactor coolant system
(RCS) pressure
rose
above the 350 PSI
setpoint.
The system
responded
as expected,
with the power operated
relief valve opening
and relieving pressure.
On November 9,
1992, Unit
1 completed its fifth refueling outage.
The
unit reached
100X power on November 11,
1992.
On December
23,
1992,
an operator .observed
fragments of a fastening device
on the ground.
Followup investigation revealed
a partially melted neutral
line connector
on
The licensee curtailed
power to
10%
and separated
from the grid, fixed the conne'ctor
and inspected all similar
connectors,
and returned to 100X power.
'
P)
-20-
Unit 2
Diablo Canyon Unit 2 entered
the assessment
period at full power and
operated
nominally at full power during the
SALP period, with occasional
brief power curtailments for maintenance
and testing activities, except
as
follows:
On August 31,
1991 Unit 2 shut
down for its fourth refueling outage
about
nine days early because
of an unisolable leak in the charging system.
The
leak had
been increasing
since its discovery
on August 13,
1991.
The leak
had not yet reached its Technical Specification limit at the time of
shutdown.
Unit 2's
shutdown
marked
482 days of continuous operation at
power,
a new world record.
On October 20,
1991, Unit 2 achieved criticality, marking the shortest
refueling outage in Diablo Canyon history.
Full power was reached
on
October 31,
1991.
On February
16,
1992, during
a power curtailment to 50X for condenser
cleaning,
the Unit 2 reactor experienced
an exaggerated
quadrant
power
tilt ratio as
a result of slightly different efficiencies of the secondary
loops.
The licensee
decreased
power below 50X, the level below which the
quadrant
power tilt action statement
does not apply.
The licensee
also
entered
the action statement,
as
a conservative
measure.
During curtail-
ment operations,
the power tilt decreased
due to xenon burnup,
and did not
recur until the following curtailment below 50X power for condenser
clean-
ing on March 14,
1992.
During this occurrence,
the licensee
repeated
the
earlier process,
and entered
the action statement.
Upon power ascension,
the power tilt decreased
to normal,
and the licensee
exited the action
statement.
On March 23,
1992, Unit 2 was shut
down to investigate
a failed turbine
stop valve.
The licensee
disassembled
the failed stop valve and found
that the nut which secures
the valve disk to the swing arm had disengaged,
allowing the disk to separate
and partially block main steam lead
number 2.
Unit 2 was returned to power on March 28,
1992 after the failed
turbine stop valve was repaired
and the other three Unit 2 turbine stop
valves were verified to be properly assembled.
B.
Ins ection Activities
Fifty routine
and special
inspections
were conducted during this
assessment
period (July 1991 through
December
1992),
as listed below.
l.
Ins ection Data
Inspection reports:
91-20,
91-22,
91-24 through 91-27,
91-29, 91-31,
91-32,
91-34 through 91-41,
and 92-01 through 92-33.
Six of these
reports
documented
management
meetings
and
one documented
an
enforcement
conference.
~
v ~
o .>
-21-
2.
S ecial
Ins ection
Summar
Special
inspections
included the following:
91-39
October
21
November 29,
1991:
A review of the licensee's
Generic Letter 89-10 program for safety related motor
operated
valves
92-09
March 10 March 17,
1992:
Review of the licensee's
procurement activities for the 6th emergency diesel
generator
92-17
March
17 April 27,
1992:
Review of the licensee's
maintenance
and inspection activities for the containment
fan cooler units
(CFCUs),
as well as licensee operability
assessments
for the
CFCUs92-201
August
24 - October 30,
1992:
Shutdown Risk Team
Inspection
C.
Enforcement Activit
Inspections
during this period identified 19 cited violations.
Of these,
18 were Severity Level
IV and
1 was Severity Level V.
No deviations
were
identified during this period.
D.
Confirmator
Action Letters
None.
E.
Licensee
Event
Re orts
Unit
1
LERs
Unit
1 issued
40
LERs during this reporting period.
The
LERs were 83-39,91-011 through 91-021,
and 92-001 through 92-028.
LERs91-021,
92-003,92-006,
92-010,92-015,
92-016,
and 92-022 were voluntary.
Unit 2
LERs
Unit 2 issued
18
LERs during this reporting period.
The
LERs were 91-001
through 91-012
and 92-001 through 92-006.
LERs91-002
and 91-008 were
voluntary.
4
W
~ I