IR 05000261/1988029
| ML14191B070 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/12/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B069 | List: |
| References | |
| 50-261-88-29, GL-85-09, GL-85-9, GL-88-06, GL-88-6, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8901300378 | |
| Download: ML14191B070 (43) | |
Text
JAN 12 ls ENCLOSURE INTERIM SALP BOARD REPOR U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-261/88-29 CAROLINA POWER AND LIGHT COMPANY H. B. ROBINSON July 1, 1987 -
October 31, 1988 D8901300378 890112 PDR ADOCP o50002B6 PNU
JAN 1 2
SUMMARY OF RESULTS H. B. Robinson has been operated in an overall safe manner during the assessment period. There were no major weaknesses identifie A major strength was identified in the area of securit The plant experienced a significant reduction in the number of reactor trips during low power or shutdown conditions, whereas the number of at power trips remained approximately the same as that experienced in the last assessment perio Although the total number of trips is still
JAN 1989
relatively high, the low number resulting from operations personnel errors is indicative of management attention in this area. Implementation of the fire protection program was adequate. Frequently accessed portions of the plant were maintained in a high state.of cleanliness. Management changes at the plant and site provided a new outlook and ideas for plant performanc The overall quality of the health physics staff was considered as a strengt The amount of contaminated areas in the plant has continued to be reduced such that the contaminated area percentage was among the lowest in Region II. Although cumulative exposure decreased during this period, it still remained hig An effective program for reducing the volume of solid radioactive waste shipped offsite was implemente Performance in the maintenance/surveillance area was mixe Although preventive maintenance has increased with a corresponding. decrease in corrective maintenance, a large number of the forced outages and the reactor trips were attributed, at least partially, to hardware failure Even so, the overall maintenance backlog continued to decrease during the assessment perio The microbiological induced corrosion program was stronger and more thorough at the end of the assessment perio An effective valve repacking program led to improvement in valve packing performanc The number of violations increased in this combined area, from the last assessment perio Although a full scale emergency exercise demonstrated that the licensee could implement the emergency response program, three exercise weaknesses were.identified. A subsequent inspection revealed an additional weakness in the identification of emergency action levels. The licensee maintained a capability for prompt communication with onsite and offsite.support organization A strong security program continued to be maintained at the sit The security plan has required only minimal revisio Site and corporate security management were responsive to security program need One Severity Level III violation was considered as an isolated even Site management reacted positively to the engineering/technical support deficiency identified during the previous assessment perio A Design Basis Documentation program has been initiated to improve the design basis knowledge of the plan An additional management effort was the initiation of a Design Change Reduction Progra The overall technical capability of the engineering staffs was good, although the system engineering staff was overloaded, resulting in reduced attention to routine daily operation The site was the pilot plant for the operator requalification program and the training staff was highly cooperative, and contributed to a good NRC/CP&L working environmen JAN 1 2 1989
With respect to the safety assessment/quality verification area, several aspects of plant performance -were assesse A Quality Verification Functional Inspection identified. several strengths and one weaknes QA surveillances have continued to shift from documentation review to more performance-based review Licensee Event Report content improved significantly from the previous assessment period. A weakness existed i the development of the full scope of emergent issues; however, once an issue was identified as a significant problem area, management attention and commitment was strong and positiv There was good progress in reducing the overall backlog of licensing related issues. The. licensee was increasing its pace in resolving several major licensing issues; but at the same time, was very slow in addressing others. Safety analysis submittals were generally of high quality and thorough; however, the No Significant Hazards Considerations were addressed with less car The licensee demonstrated a conservative approach to safety as evidenced by several shutdowns and a delayed startup resulting from self-initiated engineering review Overview
[November 1, 1985 Through June 30, 1987]
Rating Last Functional Area Period Plant Operation
Radiological Controls
Maintenance
Surveillance
Fire Protection
Security
Outages
Quality Programs and Administrative Controls Affecting Quality
Licensing Activities
Training
Engineering Support
JAN 1 2 g
[July 1, 1987 Through October 31, 1988]
Rating This Functional Area Period Plant Operations2 (operations & fire protection)
Radiological Controls Maintenance/Surveillance
Security Engineering/Technical Support
(engineering, training & outages)
Safety Assessment/
Quality Verification
(quality programs & licensing)
III. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phas Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area:
1. Assurance of quality, including management involvement and control; 2. Approach to the resolution of technical issues from a safety standpoint; 3. Responsiveness to NRC initiatives; 4. Enforcement history;.
5. Operational and construction events (including response to, analyses of, reporting of, and corrective actions for);
6. Staffing (including management); and 7. Effectiveness of training and qualification program However, the NRC is not limited to these criteria and others may have been used where appropriat JAN 1 2 lasg 1 On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
1. Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting-performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat. Category 2. Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirement Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal level. Category 3. Licensee management attention to and involvement in the
.performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively use NRC attention should be increased above normal level The SALP Board may also include an appraisal of the performance trend of a functional area. This performance trend will only be used when both a definite trend of performance within the evaluation period is discernable and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment perio Declining:
Licensee performance was determinedto be declining near the close of the assessment -period and the licensee had not taken meaningful steps to address this patter IV. PERFORMANCE ANALYSIS Plant Operations 1. Analysis During the assessment period, inspections of plant operations and fire protection were performed by the NRC staf Management involvement and commitment to assuring quality was evident in the areas of preplanning, staffing, procedural rewrites and enhancements, which included Operations Management
JAN 12 1989
Manual revisions, improved interface with maintenance and outage planning, and establishment of prioritie Plant management maintained an active involvement in the daily activities of plant operations and routine unit manager meetings were conducted to discuss corrective actions for abnormal plant events. These meetings, in addition to addressing management issues, were often technical in nature and acted to facilitate the inter disciplinary resolution of, complex event recover Tracking of repair efforts for known equipment functional and operability deficiencies were efficient and a listing of priority items was maintained for resolution during forced outage During the latter part of this assessment period a new Robinson Nuclear Department Manager was selecte His extensive experience as the former plant manager at Brunswick provides a new perspectiv Additionally, the previous Manager of Planning and Scheduling, was selected as the new Manager of Operations. The latter selection provided additional management emphasis in the operations are The operations staff is composed of six shifts which were fully manne The work force was very stable with a negligible turnover rat Efforts to diversify the opportunities for operations personnel and expand operational expertise resulted in SRO rotation into both training and regulatory compliance groups on site, as well as active participation in INPO peer evaluations and QA audits of other CP&L facilities. This effort aided in providing new insights and sensitivity to the operations staff relative to training, maintenance activities, planning, and familiarity with changing industry and regulatory issue Additionally, 14 SRO licenses were maintained by licensee management personnel which added operational insights to many management decision Efforts to provide control room upgrade continued with emphasis on modifications to the control operator's station and the shift foreman's work area to address human factors concern Also, during this assessment period both the Safety Parameter Display System (SPDS)
and the Emergency Response Facility Information System (ERFIS)
have been declared operational and have had a cumulative availability factor of 98.8%.
The effectiveness of operations personnel training and qualifications relative to facility knowledge and response to plant off-normal conditions was demonstrated by the efficient response to several operational events during the assessment period. Specifically, these events involved the prompt actions of operations personnel in avoiding a turbine/reactor trip on September 27, 1988, and the identification and correction of controller problems on a feedwater regulating valve which caused two turbine/reactor trips in July of 198 JAN 12 1
The licensee's approach to the resolution of technical issues was typically good, with operations management and personnel involved in programs intended to improve plant safety and operation Examples of these efforts included rewriting of the Abnormal Operating Procedures, improvements in the Emergency Action Level Identification procedures, participation in Corporate Quality Assurance (QA)
audits of other CP&L facilities, and the assignment of system responsibility to specific operations personne These efforts resulted in operations participating more decisively in integratedplant issues and consequently strengthened the organization. However, operating personnel were not always aggressive in insisting that malfunctioning equipment was expeditiously repaire Examples of this are nuisance type annunciators and malfunctioning control board indicator Control room demeanor was informal and casual, though effectiv Communications among operations personnel and with other group were acceptabl However, within operations, communications were not always performed in accordance with CP&L's Operator's Code of Conduc The operations staff exhibited a strong understanding of plant configuration and pride in their operational expertise. Unfortunately, in some instances, this led to the attitude that procedures provide guidance, but that their usage is somewhat interpretativ This weakness was observed by two separate NRC operator examination team The teams identified that several of the candidates were.reluctant to consult procedures while performing routine evolution There was also hesitation exhibited in referring to Annunciator Response Procedure Within the area of responsiveness to NRC initiatives, the operations department was generally receptive and cooperative in addressing identified issues. Because of the 'vintage of the plant, there existed a reliance on previously accepted methods and practices which are not necessarily in close agreement with current industry concept This condition was recognized by plant management and steps were initiated to correct this problem. These included emphasis on operator professionalism, adoption of a formal Code of Conduct and a proposed utilization of standard attir The unit experienced seven reactor trips as compared to fifteen in the previous assessment period. Of the seven reactor trips, five were related to component failures, one involved-a procedural deficiency, and one was attributed to a non-licensed personnel erro In the previous assessment period, four reactor trips were attributed to licensed personne None of the seven trips experienced during this assessment period were
JAN 1 2 1989
caused by licensed personne The five reactor trips, involving component failures were attributable to natural aging of components and inadequate preventative/predictive maintenanc Corrective action for the one reactor trip associated with a procedural deficiency resulted in modifying the operations work procedure to ensure that the high flux trip setpoint for replacement intermediate range detectors is bypassed during startup until the proper intermediate range setpoint can be established. The remaining reactor trip, which was attributed to a cognitive personnel error while performing a maintenance surveillance test of the reactor 'protection logic trains, appears to be an isolated cas The licensee took. adequate corrective action to preclude the recurrence of this even The licensee's administrative control procedures for controlling fire hazards within the plant and establishing training requirements for the plant fire brigade were found to meet NRC requirements and guidelines, and were adequate to implement the licensee's fire protection progra The licensee's implementation of the fire prevention administrative controls, and the control.of combustible and flammable materials in safety related areas of the plant were considered excellent. Housekeeping in most of the plant was considered good to excellen Notable exceptions included the Boron Injection Tank room, the RHR pit, and behind and/or under major equipment inside containmen The latter areas were sometimes found to be marginally adequate. The fire protection extinguishing systems, fire detection system, and fire barrier assemblies protection systems required for safe shutdown were functional. In addition, the.surveillance inspection, tests and maintenance instructions for the plant fire protection systems were satisfactory and met the criteria of the Technical Specification The licensee's fire brigade organization, staffing, and training met NRC requirement The training and drills for the fire brigade members met the frequency specified by plant procedure The effectiveness of the fire brigade emergency response was also evaluated during unannounced drills observed by the NRC staff. The drills identified several areas where improvements-could be made; however, overall brigade and brigade leader performance in the drills was very good and indicated that the capability to effectively respond to emergency fire events was maintained. The observed drills were considered realistic and successfully demonstrated the ability to respond to postulated condition JAN 1 2 1989
Staffing for the onsite fire protection group in support of operations was very good. The group was knowledgeable of fire protection issues and has adequate manpower to implement the fire protection progra The staffing included a Fire Protection Shift Technical Aide who provided around-the-clock direct on-shift administrative and technical assistance to the plant operations organizatio This position provided a very effective resource to address ongoing fire protection related activities and thereby enhanced the safe operation of the plan In general, the management involvement and control in assuring quality of the fire protection program was evident based upon their involvement in the site fire protection program to ensure compliance with NRC requirements and prompt resolution of any identified weaknesse Additionally, the licensee s responsiveness to NRC initiatives were technically sound and thorough in most case No violations of NRC fire protection related requirements were identified during this assessment period. However, during the previous assessment period, a Safety System Functional Inspection (SSFI)
conducted at the facility did identify deficiencies in the fire protection area which resulted in the Severity Level III violation listed as a. belo Specifically, escalated enforcement pertaining to full implementation of Appendix R requirements concerning adequate plant procedures, training communications, and emergency lighting was issued and responded to by the licensee during this assessment perio Since the related civil penalty received during this assessment period was for Appendix R deficiencies identified in the previous assessment period, it has not been factored into the rating for this assessment perio The effectiveness of the corrective actions for this violation has not been assesse Overall, the enforcement history in the plant operations area has improved significantl There were only two minor violations that were actually identified during this assessment period. The licensee did receive a civil penalty during this assessment period (violation b. below) for the isolation of Low Pressure Safety Injection. However, like the Appendix R civil penalty discussed above, this problem of mispositioned valves was identified in the previous assessment period and has, therefore, not been factored into the rating for this assessment period. The licensee did take corrective action on this issue, and no other occurrences of mispositioned valves have since been identifie Four violations were cited, with violations a. and b. being identified in the previous assessment perio JAN 12 19S0
a. Severity Level III violation for failure to adequately implement 10 CFR 50 Appendix R requirements.. (261/87-06)
b. Severity Level III violation involving the mispositioning of valves which resulted in the isolation of Low Pressure Safety Injectio (261/87-15)
c. Severity Level IV violation for failure to report the inoperability of emergency diesel generators per 10 CFR 50.72. (261/88-01-01)
d. Severity Level IV violation for failure to maintain records
- relating to diesel generators. (261/88-01-03)
2. Performance Rating Category: 2 3. Recommendations None B. Radiological Controls 1. Analysis During the assessment period, inspections were performed by the NRC staf Included in these inspection efforts were three radiation protection inspections, including one special assessment of the licensee's program for maintaining radiation exposures as low as reasonably achievable (ALARA), one radiological effluent inspection, and a confirmatory measurements inspection using the Region II mobile laborator The licensee's health physics and radioactive waste staffing levels were appropriate and compared favorably with other utilities having a facility of similar size. An adequate number of ANSI qualified licensee and contract health physics technicians were available to support routine and outage operation Key positions in the environmental surveillance organization were also filled with qualified staf The performance of the health physics staff in support of routine and outage operations, as well as the knowledge and experience level, were good. This was the result of, at least in part, a low turnover rate for the staff and little reliance on contract personnel except during outage operation The overall quality of the staff was a program strengt JAN12 19
The licensee's-HP technical training program was effective. The general employee radiation protection training program was well defined and applied to all staff members. Management's support of, and commitment to, training were evident in that sufficient time was allocated for training and employees were encouraged to attend training session Management support and involvement in matters related to radiation protection and radwaste control were good. This was evidenced by the continued commitment to maintain the routinely accessed portions of the facility as. radiologically and physically clean as possibl Management support was also evidenced by the acquisition of new equipment and radioactive sources for calibration of radiation monitoring instrumentation, which improved the calibration program and reduced -the radiation dose to technicians. Appropriate members of both management and the technical staffs were involved sufficiently early in outage preparations. This permitted proper identification of work scope, provided for adequate planning of radiological controls, and-allowed for ALARA review of the various outage projects and activities to be performe The licensee was responsive to NRC initiatives, as evidenced by the development of a program to correlate performance in General Employee Training with on-the-job compliance with radiological control requirement The licensee also has developed a training program for individuals who needed further radiological controls training following minor problems noted in procedure compliance or work practice Although the licensee has not identified discrete radioactive particle contamination at the plant, they have developed a program to control, quantify, and determine the radioactive dose from such particle During the assessment period, the licensee's resolution of technical issues was generally goo However, as discussed in Section C of this report, continuing problems with the Environmental and Radiation Control (E&RC)
building sump pump controllers and high level alarm system resulted-in radioactive liquid being discharged to an on-site settling pon The licensee's program for controlling -radioactive solid waste material was generally good. However, violation b. below was identified during the assessment period involving the release of a contaminated dry storage canister mockup to an offsite vendor who was not authorized to receive -radioactive materia The radioactive material release was the result of an inadequate release survey. Once the problem was discovered, however, the licensee's response was excellen JAN 1 2 ig
The licensee's radiation work permit and respiratory protection programs were found to be satisfactor There were 99 skin contaminations and.132 clothing contaminations reported during 1987. As of October 31, 1988, the licensee had reported 39 skin contaminations and 76 clothing contamination Although the number of personnel contaminations declined in 1988, no refueling outage, which is where mo.st personnel contaminations occur, took place during the assessment perio During 1987, the annual average number of square feet maintained as contaminated by the licensee was approximately 2,700, or approximately three percent of the radiologically controlled area (RCA)
of the plant, excluding the containment vesse As of October 31, 1988, the licensee had reduced the number of contaminated square feet to approximately 1,700, or about two percent of the RCA, which was among the lowest in Region I The licensee's collective radiation dose was 499 person-rem for 1987, as compared to a licensee-established goal of 450 for the year. The 1987 exposure total was well above the 1987 PWR national average of 368 person-rem per uni The goal for 1988 was again established at 450 person-rem, but due to an increase in outage work scope after the goal was established, the licensee anticipated that the goal will again be exceeded. Jobs to.be worked that were not originally included in the outage projection included RTD bypass elimination and service water piping removal/replacement/relocation. The licensee anticipated that theseprojects will result in a reduction in collective dose in the futur The revised projected dose expenditure for 1988 was 575 person-rem. Consequently, the collective radiation dose will be well above the PWR national exposure average for calendar year 198 Near the end of the assessment period, the NRC performed a special evaluation of the licensee's ALARA progra Although most of the elements of an effective ALARA program were in place, the overall effectiveness of the program in reducing the station's collective radiation dose is yet to be demonstrate The assessment team found a high level of plant and corporate awareness of the ALARA program; however, strong corporate management direction for the program was not eviden The five year business plan for the plant does not project that the collective dose will be at or below the industry.norms even by 1992. The licensee has taken a number of initiatives to reduce the collective dose, including source term reduction, active participation in industry study groups, the incorporation of annual dose goals as an element in individual management's performance appraisals, development of an ALARA Design Guide for the utility, and the development of an ALARA Design and Operations Training Progra JAN 12i~
A confirmatory measurements inspection resulted in tota-l agreement between the licensee s radiochemistry gamma spectroscopy equipment and the NRC mobile laborator The quality control program for the licensee's equipment was effective as indicated by across-the-board agreement for all compared radionuclide Comparison for pure beta emitting radionuclides also resulted in total agreemen Liquid and gaseous effluents for calendar year 1987 were within the dose limits specified by Technical Specifications and within the radioactivity concentrations specified in 10 CFR 20, Appendix B. Offsite doses did not exceed 10 CFR 50, Appendix I ALARA limits. The calculated maximum individual offsite dose from radioactive effluents for 1987 was 1.11 E-1 millirem total body from liquid effluents and 8.37 E-2 millirem for gaseous effluents. Maximum dose to the thyroid was 5.37 E-1 millirem from gaseous effluents. These values placed the licensee well below the 40 CFR 190.10 limit of 25 millirem annual dose equivalent to the whole body and 75 millirem to the thyroid. No abnormal offsite liquid or gaseous releases were reported during 1987 or the first 6 months of 198 Liquid and gaseous effluents for 1985 through 1987 are summarized in section of this repor The licensee has implemented an effective program for reducing the volume of solid radioactive waste shipped to low level radioactive waste shallow burial facilitie The total volume shipped for burial in 1987 was approximately 22 percent of the volume shipped in 198 The reduction is largely due to the licensee's use of a vendor who performs supercompaction of the dry waste generated at the plan The licensee anticipated further reductions in 198 Three violations were identifie a. Severity Level IV violation for failure to adhere to radiation protection procedures concerning wearing of protective clothing and frisking. (261/87-24-01)
b. Severity Level IV violation for failure to perform an adequate survey prior to releasing material. (261/88-02-01)
c. Severity Level V violation for failure to properly identify the physical form of radioactive waste on shipping paper (261/88-28-10) Performance Rating Category:
JAN 12 19
3. Recommendations The ALARA program to date has not been completely effective reducing collective dose and is not projected to be effective in the site's established 5 year business plan. As expressed in the previous SALP report, the Board remains concerned that the collective dose at the site continues to be high and it appears that future collective dose goals do not reflect an aggressive ALARA progra Accordingly, increased management attention is warranted in this are C. Maintenance/Surveillance 1. Analysis During the assessment period, routine and special inspections were conducted by the NRC staf Management involvement in assuring quality in the maintenance and surveillance area increased during the assessment perio Maintenance and surveillance activities, as well, as corrective action programs were generally well defined and implemented with an emphasis placed on interdepartmental teamwor Active job oversight and control in the form of maintenance supervision at the job site was observed throughout the reporting period. The maintenance backlog, excluding outage work, had continued to decrease during this reporting period and currently stands at approximately 525 outstanding work request Based on information available subsequent to the 1984 steam generator replacement outage, this backlog of outstanding maintenance work requests was the lowest in recent year The procedural upgrade program of Maintenance Surveillance Tests (MSTs)
initiated during the previous assessment period has continued. MSTs which were identified as contributors to plant trips were modified with input from maintenance emphasizing procedural enhancements and human factors consideration An example of this was when an inadequate reactor protection logic MST, concurrent with a cognitive personnel error, resulted in a reactor trip on September 28, 198 The corrective action for this event included the modification of this surveillance test into four separate test procedures which has prevented recurrence of this even Management commitment to the assurance of quality was demonstrated by increased emphasis and continued implementation of the preventive/predictive maintenance program. This effort, as described in the licensee's Maintenance Management Manual, stressed reliability centered maintenance of plant production equipment by reducing equipment failures and downtime due to
JAN 1 2 1g
corrective maintenanc This program also focused the responsibility for modifications and design activities on the system engineer, thereby providing a single point of contact for all related work. Management emphasis on preventive/predictive maintenance activities resulted in both an increase in preventive maintenance and a decrease i.n unplanned corrective maintenanc The Automated Maintenance Management System (AMMS) was instituted during the previous SALP period to provide an automated method for work order planning, initiation, and completion documentation. It provides for the prioritization of maintenance backlogs with emphasis on items pertaining to safety related equipment and limiting conditions for operation, as well as providing scheduling aids for corrective and preventative maintenance and periodic testing and forced outage work list The Electronic Data Base (EDB)
system augments the AMMS and incorporates system inputs from corrective maintenance history, vendor recommendations, special requirements, NPRDS, PMs, document control, performance trending, parts inventory, and planning and scheduling into a central EDB tag fil The EDB system is scheduled to be fully implemented by late 1989, an has currently been loaded with data for over 10,000 component The combination of EDB and the existing AMMS has tended to improve the performance of the maintenance and surveillance program In spite of the above efforts, the success of the maintenance program has been mixe During this assessment period, approximately 2/3 of the 14 forced outages and 6 reactor trips were either attributed to hardware failures or hardware failures in conjunction with other problem Specifically, balance of plant components and leaking primary system valves were the major initiator A modification is scheduled during the November 1988 refueling outage to eliminate the RTD bypass manifold, since leaking valves on this manifold resulted in shutdowns on November 9, 1987, and April 29, 198 The number of balance of plant problems was not indicative of an effective proactive maintenance program for this equipment. In addition, other events during the assessment period also indicated a weakness in the preventive/predictive. maintenance program in identifying component failures associated with natural aging of components. Examples of these problems included a defective overspeed trip device on the A EDG; the failure of an alarm switch associated with a DB-50 supply breaker for HVH-2; and a faulted E-H relay card in the governor valve position limiter circuitr Additionally, the failures of the predictive/
preventative maintenance program to identify and correct a defective relief valve on the turbine E-H system and-faulty solenoid valves associated with the turbine redundant overspeed
JAN1 2 1g
trip system resulted in turbine/reactor trips on January 19, 1988,. and May 12, 1988, respectivel Once identified,. the resolution of these and other technical issues was -generally acceptable and indicated an adequate application of resource However, a more aggressive maintenance; program could have possibly prevented the July 16, 1987 reactor trip after earlier problems were experienced with the A Feedwater regulating valv During a review of the hydrostatic testing section of the Inservice Inspection (ISI) activities, problems were identified in the area. of preparation and submittal of test reports to the NRC. Specifically, a weakness was identified in the licensee's program for the review of results of test programs conducted by contractor Inspections were also conducted on the Service Water Micro biological Induced Corrosion (MIC)
program at the beginning and the end of the assessment period. The licensee's program at the end of the period was much stronger and more thorough than the program observed at the beginning of the perio The licensee addressed the total problem and prepared well thought out plans for correcting all of the problems, not just the obvious one Plant management placed increased emphasis-in the area of solving the total service water problem, including being aware of recent NRC initiatives in the area of testing heat exchangers for thermal efficiency and coolant flow rate The licensee's action with regard to responsiveness to NRC initiatives was good. Favorable examples included the continued implementation of the erosion/corrosion program initiated during the latter part of the previous assessment period. This program was designed to identify secondary system components susceptible to this phenomenon and to monitor and repair piping systems utilizing inspections, mapping of defects, and repair/replacement activities. As a result of this program, repairs were accom plished on portions of the heater drains and vents, condensate system, steam generator blowdown recovery lines, and the moisture separator reheater drain line Success of the program was demonstrated by the almost complete elimination of leak repairs by Ferminite during this assessment perio Additionally, the licensee initiated an active valve repacking program utilizing Chesterton die-formed graphite packing and live loading on selected valves in both primary and secondary system This program has led to significant improvements in valve packing performanc Staffing within the maintenance area was adequate as indicated by the continued reduction of outstanding work request Similarly, the staffing required to support surveillance activities was adequate in that there have been no known
JAN 1 2 fg
occurrences of surveillance test deferrals based solely on manpower constraint The effectiveness of training and qualifications for maintenance and surveillance personnel appears adequat The licensee maintained a Craft and Technical Development Program for its maintenance staff which was INPO accredited in December 198 This training included certification and development for all phases of maintenance personnel through the senior mechanic leve The licensee had.also provided specialized training for selected maintenance personnel at various vendor facilities including Fairbanks Morris (EDG),
Woodward Governors, Limitorque, and Westinghouse (rod drive control system, and DB 50 breaker inspection and refurbishment).
Onsite specialized training has also been provided. to maintenance personnel fo Chesterton die-formed graphite packing, live loading, and use of vibrational analysis and optical laser alignment equipmen The violations listed below primarily involved procedural deficiencies and failure to follow procedure These issues included the failure to have a program to control calibrated stop watches and the failure to implement an adequate surveillance procedure for the turbine redundant overspeed trip system.as required by TS table 4.1-Coupled with the latter violation was a subsequent licensee non-conformance report (NCR 88-087) which identified several surveillance tests that exceeded the test frequency tolerance of +25% and four additional examples of Technical Specification related items without any applicable procedures. The four additional examples all involved event triggered surveillance activities. Available information indicated that these had never been required to be performed. At the conclusion of the assessment period, the subject NCR. remained outstanding and it remained to be determined if these items represent a larger programmatic concer At the end of the assessment period, violation c. below was identified involving the failure of the licensee to promptly correct identified problems associated with the E&RC building sump pump controllers and the high level alarm system which led to the introduction of radioactive liquid into the storm drain system. The controllers, including the alarm and level probe, had not worked properly since their installation in 198 Repairs to the system were completed in January 1988, and the automatic activation of the sump pump and alarm verifie Shortly thereafter, the licensee identified that the system was not functioning properly; however, no further work requests were initiated nor was the problem corrected-until the release to the on-site storm drains was identifie JAN 1 2 199
Overall, the number of violations attributable to the main tenance/surveillance area increased from the previous assessment period. Specifically, there have been two Level V violations
.and three Level IV violations identified during this assessment period compared to one Level IV and one Level V violation identified in the previous assessment perio The Level IV violation identified during the SSFI in the previous assessment period was not cited until this assessment perio Therefore, although listed as violation d. below, it has not been factored into.the rating for this assessment perio Six violations were cited, with violation d. being identified during the previous assessment perio a. Severity Level IV violation for failure to properly control work activities associated with reinstallation of pipe supports. (261/88-04-01)
b. Severity Level IV violation for failure to establish a program to control or calibrate stop. watche (261/88-28-02)
c. Severity Level IV violation for failure to identify and correct environmental and radiation control building sump pump controls. (261/88-28-09)
d. Severity Level IV violation for failure to take prompt corrective action associated with vendor recommendations and water in oil samples involving the emergency diesel generators. (261/87-06-11)
e. Severity Level V violation for failure to follow procedures relating to temporary repairs and trend analysis 'program deficiencies. (261/88-01-04) Severity Level
- V violation involving inadequate surveillance test procedure for the Turbine Redundant Overspeed Trip System. (261/88-10-02)
2. Performance Rating Category: 2 3. Recommendations The Board notes that although preventive maintenance has increased with a corresponding decrease in corrective maintenance, a large number of forced outages and the reactor trips were attributed, at least partially, to hardware failure JAN 1 2 gow
Accordingly, the board strongly recommends that appropriate management attention and resources be applied to correct this situatio D. Emergency Preparedness 1. Analysis During the assessment period, inspections were performed by the NRC staff, including evaluation of a full scale exercise,* a partial participation exercise, and a routine emergency preparedness inspectio Additionally, a routine announced inspection which included an onsite followup of operational events and appropriate event declarations, was conducted during the period of April 11, 1988, through May 10, 198 The full scale emergency exercise, performed on October 6, 1987, demonstrated that the licensee could implement the essential elements of emergency respons However, three exercise weaknesses were identified. Two weaknesses were in the area of public informatio One was the failure to provide a timely news release following the declaration of a General Emergency (unexplained delay of 76 minutes).
The other involved the failure to conduct a timely initial news briefing of State, County, and local support agencies following declaration of the General Emergenc A delay of approximately 67 minutes was observed regarding the initial news briefin It should be noted, however, that the licensee demonstrated the capability to develop and disseminate accurate news releases, and to conduct effective joint news briefings with representatives of state, county, and local government The third exercise weakness identified was. inadequate administrative *controls required to minimize radiological exposure to the environmental monitoring teams (EMTs)
during a simulated casualt A decision was made to simulate authorization for EMT personnel to take the thyroid blocking agent potassium iodide (KI).
Accordingly, the EMTs were instructed to return to the plant dosimetry office and obtain the blocking agent with authorization forms. The return route taken by the EMTs to the plant involved an additional traversing of !the plume, resulting in the unnecessary additional radiological.exposure. An inventory of EMT kits disclosed that each kit contained two bottles of KI, revealing that the return of EMTs through the plume was not warrante The second emergency exercise, conducted with partial participation, was performed on August 2, 198 No exercise weaknesses were identified. In view of the limited scope of the scenario for this exercise, corrective actions implemented in response to. the exercise weaknesses identified during the 1987
JAN 1 as
full scale emergency exercise could not be verifie The subject weaknesses will be reviewed for resolution during future exercise The licensee's response to the simulated emergencies presented during the exercises demonstrated the capability to promptly identify and classify.the postulated emergency events. However, the licensee's operations staff did demonstrate a weakness in identification and reporting of events requiring declaration of a Notification of Unusual Event (NOUE). This item is discussed in the paragraph belo The licensee's protective action recommendations made during the exercises were consistent with the Emergency Plan and implementing procedures, as well as EPA criteria. The exercises and routine emergency preparedness (EP)
inspection disclosed that the licensee developed and implemented an effective dose assessment progra The licensee conducted detailed and effective exercise critiques that included substantive findings and recommended improvements. The licensee committed to take required corrective actions on all such finding On April 29, 1988, the plant operating staff demonstrated a weakness in the identification of emergency action levels (EALs)
requiring declaration of a NOUE. The related violation, listed below, was issued for the failure to promptly identify the EAL and implement Plant. Emergency Procedure PEP-101, which requires that a NOUE be declared when the identified reactor coolant system leak rate exceeds.10 GP Separate from this event, a second situation occurred which also involved a failure to properly follow the referenced Plant Emergency Procedur This second event, which occurred on June 7, 1988, involved the explosion of a 55 gallon drum resulting from the reaction between residual amounts of hydrazine within the drum and the caustic solution transferred to it. The licensee's corrective actions for the first event also addressed this second even Notwithstanding the above identified EP program implementation weakness, a routine EP inspection performed on August 29 through September 2, 1988, disclosed that the licensee maintained a capability for prompt notification and effective communications with onsite and offsite support response organizations in the event of an emergenc Organization and management of the Emergency Preparedness program were reviewed and determined to be adequat Review of an independent audit of the program, conducted by the licensee's Quality Assurance Department, disclosed that all findings identified were tracked for required response and closeout actio The routine inspection also disclosed that the licensee maintained a Tracking System Open Items List which documented all EP exercise, inspection, and
JAN 1 2 1989
drill finding Additionally, inspection of the emergency organization training program concluded that emergency preparedness training was adequat Review of the licensee's system for making changes to the Emergency Plan and Plant Emergency Procedures (PEPs)
verified that licensee management approved all revisions to the Station Emergency Plan and PEPs during this assessment perio Controlled copies of the Station Emergency Plan and PEPs examined in the control room, TSC, and EOF were found to be updated and correc One violation was identified:
Severity Level V violation for failure to implement Emergency Plan Procedure PEP-101 which requires declaration of a NOUE following identification of a RCS leak rate in excess of 10 GPM. (261/88-07-01)
2. Performance Rating Category: 2 3. Recommendations None E. Security 1. Analysis During this assessment period, several physical security inspections and one inspection of material control and accountability activities were performed by the NRC staf In addition, a Regulatory Effectiveness Review of the security program was conducted in December 198 The licensee has continued to demonstrate the ability to implement and manage an effective security program as evidenced by inspection results. The security organization was adequately staffed with knowledgeable and dedicated managers and supervisors who are capable of maximizing performance and productivity with available resource The soundness of the licensee's established security program was reflected in the adequacy and current status of Physical Security and Training and Qualification Plan Security management continued to demonstrate awareness of, and participation in, security force activitie Both site and corporate security managers were responsive to security program needs and aggressively sought effective and lasting solutions to
JAN 1 2 1gg
security-related problem Effective communications and managerial interface between.the proprietary security management function and the contract -security force further enhanced security program effectiveness. A well established and viable security training program, along with aggressive audit of performance and compliance requirements, contributed to the continuing effectiveness of the security progra The Regulatory Effectiveness Review of the Robinson Security Program was conducted to determine if the security program, as implemented, provided the level of protection expressed in 10 CFR Part 7 No potential sabotage vulnerabilities were identified. However, several minor security issues were noted; some of which were, beyond the scope of Security Plan and regulatory commitment The licensee initiated actions as appropriate. In addition, four security program strengths were identifie One Severity Level III violation, as described below, was identified during the assessment period, but was not indicative of a programmatic weaknes The Material Control and Accountability inspection was conducted to determine whether the licensee had limited his possession and use of special nuclear material (SNM)
to authorized locations and uses, and had implemented an adequate and effective program to account.for and control all SNM in possession under licens The inspection determined that the licensee had developed and was maintaining an effective safeguards program for the control and use of both fuel and non-fuel SN External reporting was found to be accurate and timel One violation was identifie Severity Level III violation (without civil penalty) involving an unauthorized, unsearched, unbadged person's entrance into the protected area (50-26.1/87-26-01).
2. Performance Rating Category:
3. Recommendations None
JAN 1 2
F. Engineering/Technical Support 1. Analysis The Engineering Technical Support functional area addresses the adequacy of the technical and engineering support for all plant activities. To determine the adequacy of the support provided, specific attention was given to the identification and resolution of technical, issues, responsiveness to NRC initiatives, enforcement history, staffing, effectiveness. of training, and qualificatio It includes all licensee activities associated.with plant modifications, technical support provided for operations, maintenance, testing and surveillance, training, procurement, and configuration management. This evaluation was based on inspections conducted by the NRC staff in this area, as well as related functional area In the previous assessment period, overall engineering support was identified. to be wea Inadequacies were in the areas of design analysis, modification control, engineering documenta tion, design basis utilization, and design verificatio Plant management increased their involvement and control during this assessment period to improve the quality of engineering suppor This management involvement was demonstrated by the scope of licensee initiatives involving the Design Basis Documentation, (DBD)
program, Microbiologically Induced Corrosion (MIC)
service water investigation, and a Design Change Reduction progra The quality of engineering support has shown improvement as evidenced by engineering evaluation activity related to service water problems, SI pump small break loss of coolant accident (SBLOCA),
EDG problems, and response to NRC Bulletin Licensee management identified the root cause of engineering weakness as a lack of understanding of system design basis, system functional requirements, system interfaces, and as-built system configuration To resolve these basic weaknesses the licensee initiated the development of a comprehensive DBD program. This is a large scope program to acquire and integrate available safety system design basis documents in a common forma This program is scheduled for completion-in 199 Three pilot systems were scheduled for completion in 1988 and these were on-schedule at the close of this assessment perio Management policy for staffing this project was to minimize the use of contractor personnel, thereby maintaining knowledge and expertise at program completion and enhancing the licensee engineer's understanding of system design basis, interfaces, and functional requirement The project team is directed by a project manager who reports to the corporate Nuclear Engineering
JAA I 12
30 Department (NED)
vice-presiden This. comprehensive licensee self-initiated program demonstrated the licensee's commitment to strengthen engineering suppor Other management initiatives included the development of a strong program to evaluate service water system problems related to MI The licensee's engineering activity has provided substantial input to the study of an industry wide concern with MI Management has contributed engineering resources to research this phenomenon and initiated a comprehensive surveillance program to.monitor MIC impact on the service water syste An additional management effort was the-initiation of a Design Change Reduction program. This activity identified that inade quate premodification engineering walkdowns and inadequate design reviews were the major causes of excessive numbers of design change notices on modification implementation The overall technical capabilities of the site and corporate staffs were good, providing an improved quality of engineering activity over the previous assessment period. When necessary, the licensee engineering effort was effectively supplemented with contractor expertise, usually the Nuclear Steam System Supplie The staff technical competency was demonstrated by various analyses performed during the review perio For example the engineering staff coordinated an extensive investigation and test program involving plant personnel, corporate personnel, vendors, and industry specialists to determine the root cause of EDG overspeed trip events which occurred in February 198 Success of the effort has been demonstrated by no recurrence of overspeed trips during bi-weekly testing of the EDG Engineering evaluation of EDG cooler tube bundle failures identified a failure mechanism which led to action which improved EDG reliabilit Further examples of technical competency included engineering analysis to resume full power operation following the 60 per cent limitation imposed due to SBLOCA considerations related to SI pump single failure deficiencie Additionally, engineering provided resolution to seismic support deficiencies for reactor protection racks and containment valve packing leakage problem In response to IEB 79-02, Pipe Support Base Plates, and IEB 79-14, Seismic Analysis for As-built Safety Analysis Piping Systems, the licensee's resolution demonstrated a high level of safety consciousnes During this assessment period, a technical inadequacy was identified in the analysis associated with implementation of Appendix K of 10 CFR Part 5 In 1974 the submitted model did
JAN 12 19
not adequately consider single. failures when determining operability of Emergency Core Cooling System (ECCS)
equipment for certain events. This resulted in the Severity Level III violation listed as a. belo It is noted that, although the licensee demonstrated improved engineering support during this assessment period, the engineering effort regarding the initial investigation into the above single failure deficiency was inadequat The licensee also received a civil penalty during this assessment period for.EQ deficiencies identified in the previous assessment-period; thus, this problem has not been factored into the rating for this assessment. perio Subsequently, the licensee's EQ verification and DBD programs have identified deficiencies and weaknesses such as the questionable ability of service water to support containment cooling during design basis accidents, insufficient cable ampacity to carry emergency LOCA loads, and lack of environmental qualification of cable splices at containment fan cooler units. Benefits of the DBD program are also demonstrated by the program's contribution to resolution of concerns, related to emergency electrical systems identified during the previous assessment perio Engineering support for routine plant activities was limited due to the amount of reactive activities required of system engineers. The engineering staff consists of a small on-site group of licensee employees supplemented with contract employees and a corporate Nuclear Engineering Department (NED) located at the corporate office. The NED staff provided support on major design issues and plant modification The on-site staff utilized the system engineer concept which provides the advantage of engineers with up-to-date knowledge of system conditions and better trend identification potential for system problems. Although the quality of the system engineering staff was good, each system engineer had responsibility for a relatively large number of systems (6 to 8) which diluted the effectiveness of this concep Additionally these engineers were the focal point for reactive issues and provided interface with NE The amount of engineering support required by numerous issues (i.e.,
7 reactor trips and 14 other forced outages) severely taxed the site engineering resource This resulted in reduced system engineering oversight of routine operations, quality verifications, and proactive inspection Accordingly, the licensee is considering expansion of the system engineering progra The coordination between onsite and offsite engineering was good. These groups have worked effectively together to rapidly prepare plant modification packages on several emergent issues which required plant shutdown and correction prior to restar JAN 1 2 198g
These included the B SI pump autostart feature, temporary instrumentation to monitor containment fan cooler performance, and temporary replacement of E2 to MCC-6 feeder cable The coordination between the groups was also demonstrated by the preparation of Justifications for Continued Operation (JCO).
The JCOs were expeditiously prepared, technically sound and generally well documente Generally this engineering staff coordination of activities and modifications was good with some exceptions.. For example, the onsite staff in its implementation of design change packages (DCP)
M-912, Pressurizer Operated Relief Valve Block Valve Replacement, and M-920, Auxiliary Feedwater Control Wiring, failed to assure acceptance criteria in the. DCPs were incorporated in the post-modification test This failure resulted in violation c. below. Other inadequacies (violations d. and e. below) were also cited during this assessment period but were identified. during the previous assessment perio Accordingly, they have not been factored into the rating for this assessment perio An adequate commercial grade dedication program for procurement items has not been developed at the sit The existing policy for commercial procurement permits the potential use of commercial "off-the-shelf" items in safety related applications without special quality verifications or a direct reasonable correlation between. the item purchased and that originally teste Engineering evaluations for original procured commercial grade items were adequate and were commonly referenced for further purchases of like items without critical characteristic verification for each usag The lack of a commercial grade dedication or-qualification program was an identified weakness in the procurement progra Engineering response to 10 CFR Part 21 evaluations during the assessment period were found to be fully adequat Review of general Q-List procurement and control of spare parts were also considered adequate with the previously discussed exceptio Training maintained an active involvement in the operations area as evidenced by the voluntary participation in the pilot operator requalifications program administered under the provisions of 10 CFR 55.5 This program represented the combined efforts of the licensee's training and operations departments and NRC, and was the first of these examinations administered in the countr The training staff was adequate and effective in discharging their assigned responsibilities as evidenced by the pass/fail rate of 83%
for operators initial' and requalification examinations administered during this assessment perio Operator licensing replacement examinations were administered
JAN 12 18
during.the weeks of August 11,. 1987, and December 14, 1987, with the.following results:
6 reactor operator replacement examinations were administered with 5 candidates passing; 4 senior reactor operator examinations were administered with three candidates passing. These results are comparable to the industry average for replacement examination The accept ability of the. operating training program was demonstrated by the recertification by INPO in October 1988 of the non licensed operator, RO, SRO, requalification, and STA training program The licensee also initiated an operator degree program utilizing the University,of Maryland's correspondence system which offers a Bachelors Degree in Nuclear Sciences. The program currently has a participation of approximately 75% of those eligible at H. B. Robinso Inspection of the requirements in Generic Letter No. 81-21, Natural Circulation Cooldown, concluded that appropriate training had been provided in the. classroom and on the simulator for both SRO and RO program Overall conformity to the Westinghouse Emergency Procedure guidelines was observed, but some minor inconsistencies were noted, as well as the unavailability of a complete step deviation document for revie The incorporation of a site specific simulator at H. B. Robinson was a strength to the operator training program, and proved to be a valuable asse Although several minor weaknesses in the simulator capabilities were observed during NRC administered examinations, the training staff has continued to improve on these weaknesse The highly cooperative attitude of the training staff helped create a positive working environment for examination development and administration. Reference materials provided to the region continued to be presented in a well organized fashion and maintained current with plant conditions. This has been an asset to examiners in examination preparatio Five violations were cited, with violations b., d., and e. being identified during the previous assessment perio a. Severity Level III violation involving the failure to comply with Appendix K relating to single failure of the SI system. (261/88-03-04)
b. Severity Level III violation involving equipment qualifi cations. (261/87-10-01)
c. Severity Level IV violation for failure to identify and perform adequate post-modification testing. (261/88-01-02)
JAN 12 18
d. Severity Level IV violation involving, inadequate battery load testing. (261/87-06-08),
e. Severity Level IV violation involving inadequate emergency lighting. (261/87-06-06)
2. Performance Rating Category: 2 3. Recommendations The Board is encouraged by the initiative and efforts expended on the DBD program. Based on the large work load placed on the site engineering staff, the Board supports the licensee's efforts to increase the effectiveness of this grou G. Safety Assessment/Quality Verification 1. Analysis The NRC staff routinely reviewed engineering evaluations, Justifications for Continued Operation (JCOs),
resolution of significant issues affecting system operability, and resolution of equipment problem Several conference calls and meetings were held throughout the reporting period between the licensee, Region II and NRR to resolve NRC questions on various issue In addition a Quality Verification Functional Inspection (QVFI)
was performe Management was slow to recognize the full extent of problems and initiate corrective actions. However, once an issue was determined to be significant enough to require extensive corrective actions, the licensee demonstrated a strong commit-.
ment to safety by developing and implementing technically sound solutions and by shutting down the unit when the ability of major safety related equipment to perform their intended functions was in doub One contributor to the slow response concerning design issues was the licensee's assumption that the plant was adequately designed and built; however, support of this assumption was not well documente Excluding recent electrical issues, design related questions.were typically successfully resolved and had only resulted from a lack of adequate documentation. Generally, the licensee did not have an aggressive approach to design type issues.. The result was that some submittals to the NRC were more of a legal type document rather than an engineering document addressing the issu This latter philosophy also contributed to a reluctance to adopt industry-wide practice or
JANd 1. 2 1989
present acceptable plans for equipment upgrade as exemplified by issues involving circuit breaker In addition, the battery duty cycle and station electrical distribution voltages are two examples where submittals were incomplete and unacceptable, requiring repeated questions by the NRC before adequate analysis and information were provide Management occasionally failed to ensure a questioning, aggressive attitude toward problem When combined. with a tendency to initially consider items as isolated cases, this resulted in an initial lack of.definition of the ful.1 scope of an issue and protracted resolutions. Examples of this include the diesel generator overspeed trip and reliability issue, the Cruise Hinds penetration to pigtail EQ splice issue and the submittal of supplemental responses to two violations to address the issues on a broader scop As a result of a series of electrical issues, the need for reconstituting the design basis of the plant was establishe The licensee responded to this need by initiating the DBD effort. This emphasis-on design basis also resulted in a shift toward acceptable technical resolution of outstanding issues at the end of the assessment period. This was exemplified during a series of meetings in October 198 The licensee made commitments for improvements, either in equipment modification or in Technical Specification (TS)
requirements, to address outstanding. electrical issue The licensee's timetable for resolving the electrical systems related concerns is acceptable to the NRC staf As indicated above, management showed a strong commitment to safety once an issue was clearly identified as requiring significant corrective action These actions were typically well planned and execute For example, corrective actions associated with the SI single failure issue, EDG overspeed trips, and biological fouling of the containment fan coolers were very thoroughly researched and addressed prior to resumption of operatio Furthermore, management's commitment to safety was demonstrated when the licensee elected to shut down the reactor in three instances and delayed the startup in one other, instance because of inadequacies identified through self-initiated engineering review These instances were the inadequacy of.the Service Water System to support post-accident containment cooling, EQ of the cable splices for the containment fan cooling system, EQ of the reactor vessel head vent valve operators, and the inadequacy of cable ampacities to supply emergency power to the motor control center and various safety equipmen In every one of these instances, the licensee demonstrated initiative in safety concern identification and was thorough in engineering the corrective actions to assure
JAN i12 1
qualit The staff observed that all these cases of self initiated safety concern identification and reactor shutdown occurred during the later part of this assessment period, since May 198 The licensee's management involvement intensified, and the licensee became more responsive to the staff's questions throughout this assessment period. As a result, there was good progress in resolving a. number of backlog issue These activities were related to the emergency electrical system concerns identified in the SSFI, TMI Action Item reviews, requests for ISI and IST reliefs, Technical Specification amend ments, exemptions from regulations, responses to generic letters and bulletins, and 10 CFR.50.59 evaluation The pace of resolving other licensing actions. also accelerated during the latter -part of this assessment perio Many of the multi-plant action items (e.g., 10 CFR 50.62, the ATWS Rule; GL 85-09, Reactor Trip Breaker Technical Specifications (TS); GL 88-06, Removal of Organization Charts from TS; Inadequate Core Cooling Instrumentation and Auxiliary Feedwater evaluation) were either completed or in the process for near-term resolutio However, for some issues, such as TS for reactor trip breakers and the inadequate core cooling instrumentation, the licensee was very slow responding to the staff's initiative This tardiness resulted in the licensee being, one of the few who still has not resolved these multi-plant action item During this assessment period, five TS amendments and three exemptions were issue The most si-gnificant amendments involved the SI system (i.e.,
the emergency TS. change for operation at 60% power and the TS change to permit 100% power operation with two operable SI pumps).
The licensee's safety analysis submittals for these cases were of high quality and thorough and the licensee was very responsive in expediting the staff's revie However, in general, the licensee's No Significant Hazards Considerations for the amendments were perfunctory, especially in the address of reduction in safety margi The staff had discussions with the licensee's management regarding this weakness, and improvements were in evidence for the submittals toward the end of this rating perio During a meeting with the licensee and a tour of the emergency response facilities, the licensee indicated that those TMI action items related to the upgrade of Emergency Response Facilities were completed and ready for inspection. The licensee was very responsive and thorough in providing the staff with information in this regard. Along with the accelerated pace of resolution of the other multi-plant action items, the licensee has made
,significant progress in reducing backlog issue JA 21989
The licensee has provided timely and thorough responses to all applicable generic letters (GL),
NRC bulletins (NRCB),
and 10 CFR Part 21 Notifications. The licensee performed a thorough engineering evaluation to show that the component cooling water system is not vulnerable to overpressurization and provided a satisfactory response to the Westinghouse Part 21 notification concern. During this assessment period, the staff reviewed the licensee's responses to GL 88-03 (steam binding of auxiliary feedwater pumps); GL 88-05 (boric acid corrosion of carbon steel reactor boundary components);
NRCB 87-01 (thinning of pipe walls)
and 88-01 (defects in Westinghouse circuit breakers).
The staff. found those responses to be timely, thorough, and acceptable for resolutio In general, the licensee has demonstrated high quality inputs; and active licensee management participation was evidenced in providing the staff with technically sound response Based on the observation and review activity of the QVFI conducted during this assessment period, the licensee's QA program was adequately accomplishing its function of identifying, correcting, and preventing problems during this assessment perio Although the QA program has demonstrated strengths in several aspects, one deficiency was noted in the ability-of the trending system to identify adverse trend In response to an NRC question concerning frequency of surveillance testing problems within the recent past, the QA group discovered 16 NCRs had been issued between January 1, 1985, and June 14, 1988, which involved 23 surveillances being performed outside their Technical Specification frequency and five NCRs concerning certain Technical Specification requirements without applicable procedure An NCR was promptly issued to address this potential programmatic issu The quality organization staff was of a size and experience level which permitted fulfillment of quality program objective The qualification and experience of the staff was technically adequate to provide for problem identification in the scope of quality program activities. A low turnover rate resulted in a continuity of inspection and audit expertise. Additionally, the relationship. between the quality organization staff.and plant staff was observed to be professiona The scope and depth of quality organization audits and surveillances provided a generally adequate coverage of plant safety-related activity. QA audit depth was good, based on the relatively significant findings identified by QA audits this assessment perio Observation of quality organization surveillance activity indicated competence in the real time inspection function. A policy shift towards more surveillance and performance-based activity versus documentation compliance
JAN 12 ig
reviews noted in the previous SALP report has continued through this assessment perio Notable examples were;. observed activity surveillances, several "vertical slice" modification audits, and auxiliary feedwater safety system functional inspection (SSFI).
This' shift is a positive reflection on response to NRC initiatives towards performance-based and vertical slice" inspection technique The plant broad based corrective action program (nonconformance reporting system) was reviewed for effectiveness in identifying and resolving problem Identified deficiencies were satisfactorily resolve Management emphasis on usage of the deficiency reporting system resulted in a large increase in identified deficiencies by plant personnel without an increase in the backlog.of processed deficiency report These aspects of the corrective action program indicated an effective deficiency reporting proces The management initiative.to promote reporting of deficiencies by all plant personnel was commendabl In the previous assessment period, the NRC determined that the documentation quality of Licensee Event Reports (LERs)
required improvement. Specific areas to be improved were discussions of Safety System responses and identification of failed component In response to this issue,. the licensee developed and implemented a LER quality improvement progra In June 1988, a LER writer's guide entitled "LER Handbook" was completed and implemente At the end of the assessment period, the documentation of discussion of safety system responses and identification of failed components were generally goo Supplementary reports were issued as necessary when additional information became available after the initial report was issued. The reports were issued in a timely manne However, the final processing of the reports, including Plant Nuclear Safety Committee (PNSC)
review, was typically completed within the last three days of the 30 day period, and, in some cases on the last da Although this has not affected the technical accuracy of the LERs, it has resulted in one NRC approved extension beyond the 30 day period (LER 88-006). There were 36 LERs submitted during the assessment perio Five LERs were classified as significant. They involved EDG inoperability due to overspeed trips, reactor protection and control instrument rack not being properly anchored, potential for failure of RHR due to design inadequacy i-n miniflow, inability of SI and RHR to be timely shifted to recirculation mode, and single failure scenarios for SI autostar JCOs in all cases were technically sound and generally well documented. In one instance, the NRC identified that a formal engineering evaluation had not been documented to support continued operation. This issue involved a possible compromise
JAN12 tgI
of containment integrity due to MIC attack on service water piping inside containmen The issue had been previously reviewed by plant management for safety significance, but the need to formally document the technical basis for their decisions had not been identifie PNSC meetings adequately addressed safety issues at the plan Meetings typically consisted of technically sound discussions with active involvement by participants from all discipline This active participation was considered a major strengt On occasion, presentations by some individuals indicated a lack of thorough preparation. Although this impacted the efficiency of-the process, it did not adversely affect the adequacy of the decision making.proces No violations or deviations were identifie. Performance Rating Category:
3. Recommendations The Board acknowledges that the licensee has conservatively shut down the unit when there were indications that safety systems might be inoperable. However., there is a concern over the observed slowness to develop the full scope of emergent issue V. SUPPORTING DATA Investigation Review None B. Escalated Enforcement Action 1. Civil Penalties Severity Level III violation issued on September 18, 1987, involving the mispositiong of valves which resulted in the isolation of Low Pressure Safety Injectio ($50,000 CP)
Severity Level III violation issued on November 13, 1987, for failure to adequately implement 10 CFR 50, Appendix R requirements. ($50,000 CP)
Severity Level III violation issued on June 15, 1988, involving the failure to comply with Appendix K relating to single failure of the SI system. ($50,000 CP)
JAN12 18
Severity Level III violation issued on June 16, 1988, involving equipment qualification. ($450,000 CP) Orders None Management Conferences August 21, 1987 Enforcement Conference at Region II to discuss a failure to maintain access control to the protected are September 17, 1987 Enforcement Conference at Region II to discuss environmental qualification o electrical equipmen October 13, 1987 Management Meeting at the Robinson Visitor's Center to discuss the 1987 SALP Board Assessmen March 1, 1988 Management Meeting at Region II to discuss communications between CP&L and NRC relating to the safety system functional inspection and its followup inspectio March 30, 1988 Enforcement Conference at Region II to discuss a design basis problem involving safety injection pump availabilit April 5, 1988 Management Meeting at Region II to discuss the scope and status of the reconstitution of the Robinson design base June 7, 1988 Management Meeting at Region II to discuss identified problems at the three CP&L sites and to reveal plans and established goals to achieve overall excellenc September 20, 1988 Management Meeting at Region II to discuss the status of the Robinson Design Basis Reconstitution progra D. Confirmation of Action Letters One Confirmation of Action Letter, dated February 11, 1988, concerning the failure of Robinson's electrical distribution system to meet single failure criteria with respect to the Safety Injection Syste JAN 1 2 fg'
E. Review of Licensee Event Reports (LERs)
During the assessment.period, 36 LERs for the unit were analyze The distribution of these events by cause, as determined by the NRC staff, was as follows:
Cause Number Component Failure
Design
Construction, Fabrication, or Installation
Personnel:
-
Operating Activity
- Maintenance Activity
-
Test/Calibration Activity
- Other
- Out of Calibration
Total
F. Licensing Activities In support of licensing activities, meetings were frequently held with the licensee to discuss licensing status and resolution of technical issues. Significant licensing issues that were assessed during this assessment period included:
Regulatory Guide 1.97, Revision II; ATWS Rule 10 CFR 50.62; NUREG-0737 III.A.1.2, Emergency Response Facility, and III.A.2.2, Meteorological Data Upgrade; NUREG-0737 II.E.1.2, Automatic Bus Transfer of Auxiliary Feedwater System; NUREG-0737 II.K.3.5, Auto Trip of Reactor Coolant Pumps; GL 88-03, Steam Binding of Auxiliary Feedwater Pumps; GL 88-05, Boric Acid Corrosion of Reactor Pressure Boundary Components;Bulletin 88-01, Defects in Westinghouse Circuit Breakers; and 87-01, Thinning of Pipe Wall Six (6) amendments were issued during this assessment period including an emergency TS change which limited the plant operation to 60% of the rated power level when two Safety Injection (SI)
pumps were operable.. Other significant amendments were:
Organization of the Plant Nuclear Safety Committee, 100% Power Operation with Two Operable SI Pumps, Number of Incore Flux Thimbles, and Radiation Monitor at Steam Generator Blowdown Heade There were three (3) exemptions during this assessment perio They involved:
Appendix R,Section III.J, Emergency Lighting; 10 CFR 20.103(c)(2),
Physical Examination for Users of Respiratory Equipment; and 10 CFR 50.54(w)(5)(i),
Schedular Requirements of Property Insurance Rule. The licensee was also granted an interim relief from certain inservice testing requirements related to the
JAN 12 1IN
Containment Spray and Component Cooling Water Systems pending the submittal of a revised testing pla In addition to the, regularly scheduled licensing status meetings between the project manager and the licensee's licensing staff, beginning February 1988, there were a number of other meetings on specific licensing issue They involved:
Safety Injection and Single Failures (2/10, 2/12); Emergency TS Change, Safety Injection (2/16);
100% power TS (5/05); Emergency Response Facilities (7/14);
RTD Bypass (7/27); and Emergency Electrical Systems (10/20, 10/21).
G. Enforcement Activity NO. OF DEVIATIONS AND VIOLATIONS IN EACH FUNCTIONAL
.
SEVERITY LEVEL AREA De V IV III II I
Plant Operations
0
2
0 Radiological Controls
1
0 0 Maintenance/Surveillance
2
0
1
0
0 Security
0
1
0 Engineering/Technical Support
0
2
0 Safety Assessment/Quality Verification
0
0
0 TOTAL
4
5
0 Footnotes:
(1) SL III violation involving isolation of LPSI ($50,000 CP)
SL III violation involving Appendix R issues ($50,000 CP)
(2) SL III violation involving access control to the protected area (No CP)
(3) SL III violation involving ECCS evaluation model ($50,000 CP)
SL III violation involving EQ issues ($450,000 CP)
H. Reactor Trip A total of seven automatic reactor trips occurred during the assessment period, six above 15% power and one below 15% powe No manual trips were initiated. Also no trips occurred with the unit subcritica During the previous assessment period, eight trips
JAN 1218
occurred above 15% power, two occurred below 15% power and five occurred with the unit subcritica The trips are described in more detail below:
July 10, 1987 - The A main feedwater regulating valve failed closed, due to an electrical short in the DC wiring on the valve operato This resulted in a steam/feed flow mismatch coincident with low steam generator A level which caused a reactor trip from 100% powe July 16, 1987
-
The A main feedwater regulating valve failed to control properly due to a faulty valve positioner. This resulted in a steam/feed flow mismatch coincident with low steam generator A level which caused a reactor trip from 72% powe August 10, 1987 - A replaced intermediate range detector (N-35) which had an improper setpoint due to a procedural deficiency caused a reactor trip from approximatedly 8% powe September 28, 1987 - During the performance of a surveillance test of the reactor protection logic trains A and B a personnel error resulted in both trains being placed in the test mode causing a reactor trip from 100% powe January 19, 1988 -
The unit tripped from 66% power due to a turbine trip. An excessive leaking autostop oil relief valve when combined with surveillance testing resulted in a low autostop oil pressure turbine tri May 2, 1988
- A component failure in the turbine E-H control system resulted in all four turbine governor valves closing causing a turbine trip/reactor trip from 60% powe May 12, 1988 - During the performance of a surveillance test on the TROTS system a component failure resulted in satisfying the 2/3 logic and a turbine trip/reactor trip from 60% powe I. Effluent Release Summary Activity Released (curies)
1985 1986 1987 1. Gaseous Effluents a. Fission and Activation Gases 2.14E+3
.6.59E+2 7.70E+2 b. Iodine and Particulates 1.37E-2 9.92E-3 2.08E-2 Liquid Effluents a. Mixed Fission and Activation Products 9.41E-2 1.81E-1 7.36E-1 b. Tritium 3.09+2 3.42E+2 2.74E+2