IR 05000261/1989030
| ML20033G792 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/23/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20033G791 | List: |
| References | |
| 50-261-89-30, NUDOCS 9004120131 | |
| Download: ML20033G792 (24) | |
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ENCLOSURE.
INITIAL SALP REPORT U.S.NUCLEARREGULATORYCOMNIS$10N(NRC)
REGION !!
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER
$0-261/89 30 CAROLINAPOWER4LIGHTCOMPANY.(CP&L)
H. B. ROBINSON NOVEMBER 1, 1988 - DECEMBER 31, 1989
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_ TABLE OF CONTENTS
.P.,ag 1. INTRODUCTION....................................................
!!. SUMKAkY OF RESULTS..............................................
Overview........................................................- 3
!!!. CRITERIA........................................................
IV. PERFORMANCE ANALYSi$............................................
A.
Plant Operations...........................................
B.
Radi ol ogi cal Control s......................................
C.
Maintenance / Surveillance...................................
D.
Emergency Preparedness....................................
11-E.
Security..................................................
F.
Engineering / Technical Support.............................
G.
Safety Assessment / Quality Verification....................
Y. SUPPORTING DATA................................................
A.
Licensee Activities.......................................
B.
Direct inspection and Review Activities...................
C.
Management Conferences....................................
D.
Review of Licensee Event Reports..........................
E.
Licensing Activities......................................
F.
Enforcement Activity......................................
G.
Reactor Trips.............................................
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INTRODUCTION i
The Systematic Assessment of Licensee Performance ($ ALP) program is an
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integrated NRC staff effort to collect available observations and data on
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a periodic basis and evaluate licensee performance on the basis of this
information.
The program is supplemental to normal regulatory processes
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used to ensure compliance with NRC rules and regulations, it is intended to be sufficiently diagnostic to provide a rational basis for allocation
of NRC resources and to provide meaningful feedback to the licensee's
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management regarding the NRC's assessment of their facility's performance-in each functional area, t
An NRC SALP Board, composed of the staff members listed below, met on r
February 21, 1990, to review the observations and data on performance, and i
to assess licensee performance in accordance with NRC Manual Chapter 0516,
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" Systematic Assessment of Licensee Performance." The Board's findings and
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recommendations were forwarded to the NRC Regional Administrator for
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approval and issuance.
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I This report is the NRC's assessment of the licensee's safety performance at H. B. Robinson for the period November 1,1988 through December 31, l
1989.
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The SALP Board for H. B. Robinson was composed of:
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C. W. Hehl, Deputy (Director, Division of Reactor Projects (DRP),
Region 11 (Rll) Chairperson)
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E. W. Merschoff, Deputy Director, Division of Reactor Safety, Rll l
W. E. Cline, Chief Nuclear Material Safety and Safeguards Branch,
Division of Radiation Safety and Safeguards, RIl t
D. M. Verrelli, Chief, Reactor Projects Branch 1, DRP, Ri!
E. G. Adensam, Director, Project Directorate.!!-1, Office of Nuclear Reactor Regulation (NRR)
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L. W. Garner, Senior Resident inspector. H. B. Robinson, DRP, Ril
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R. H. Lo., Senior Project Manager, Project Directorate 11 1, NRR
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Attendees at SALP Board Meeting:
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J. W. Roe, Director, Division of Licensee Performance and Quality
Evaluation (DLPQ),NRR i
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- G. E. Grant. Senior Operations Engineer, DLPQ, NRR
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R. L. Nease, Operations Engineer, DLPQ, NRR
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H. C. Dance, Chief. Project Section 1A, DRP, Rl!
R. L. Carroll, Project Engineer, Project Section 1A, DRP, R!l i
M, M. Glasman, Project Engineer, Project Section 1A, DRP, R!l
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K. R. Jury, Resident inspector, H. B. Robinson, DRP, RIl
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G. R. Wiseman, Reactor Engineer Technical Support Section, Ri!
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!!. SUMMARY OF RESULTS
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H. B. Robinson has been operated in an overall safe manner during the
areas of security and radiolog'gths in performances were identified in the assessment period. Major stren
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cal controls.
No major functional area
weaknesses were identified.
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Strengths in the plant operations area were characterized by increased management oversight and increased emphasis on identification and resolu.
tion of problems.
The operating staff's anticipation of problems or potential recurrence of problems was excellent.
With the exception of
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specific outage related activities, housekeeping has been good.
With respect to fire protection, the licensee demonstrated a clear understanding
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of and responsiveness to related requirements. Weaknesses were identified
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in communications, independent verification, log keeping practices, identification of equipment deficiencies, operability determinations, and
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management control of emergency operating procedures.
Performance in the radiological controls area improved this assessment
period.
An elevated lithium control program in the RCS and a more effective letdown filter has resulted in significant reductions in plant
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dose source terms.
The amount of contaminated areas in the plant has t
continued to be reduced.
Cumulative exposure and radioactive gaseous
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releases decreased substantially.
Improvements in the ALARA program were
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noteworthy.in that planning for specific job activities was effectively l
implemented.
A weakness was noted in the improper release of radioactive
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materials from the RCA.
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Maintenance and surveillance activities were properly coordinated and performed.
However, procedural adherence problems were identified as a weakness.
A procedure upgrade program is underway.
Implementation of
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sreventive/ predictive maintenance was effective only in isolated areas.
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)roblems were encountered with material condition of auxiliary feedwater l
components and fastener torquing control.
Balance of plant equipment
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failures resulted in challenges to the operationg staff.
A weakness was
also observed in fully implementing and evaluating inservice testing
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requirements and repetative repairs.
l The emergency preparedness (EP) program was maintained in a state of l
operational readiness.
Programmatic aspects appeared to be strong, and
the licensee responded to four actual events in a proper manner. However, j
weaknesses in the EP exercise involved scenario ciscrepancies, response
organization timeliness, and a similar example of a previous problem
regarding event classificatior..
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t Security continued to be a strength.
Two isolated problems were identified with access control; however, routine, as well as, abnormal
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security activities remained well controlled, j
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Performance in the engineering / technical support area was mixed.
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Effectiveness of technical support was exemplified by their response to
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operational events and. their support of modifications to correct e
identified design deficiencies.
Deficiencies were identified in engineering performance associated with the identification and resolution of some emergent issues.
Regarding the safety assessment / quality verification area, the licensee's comitment to the assurance of quality was demonstrated by efforts to
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improve site processes and. practices.
Site assessment programs and i
quality assurance programs were not always effective.
Licensee sutaittals and safety reviews were inconsistent, occassionally lacking quality and completeness.
Overview L
The specific assigned ratings for the last rating period and the current period are shown 'n the following table.
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Rating last Period Rating This Period i
7/1/87 - 10/31/88_
11/1/68 - 12/31/89" functional Area l
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Plant Operations
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Radiological Controls
1 Maintenance / Surveillance
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Security
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Engineering / Technical Support
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Safety Assessment / Quality l
Verification
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111. CRITERIA i
Licensee performance is assessed in the selected functional areas shown I
above.
Functional areas normally reprtsent areas significant to nuclear
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safety and the environment.
i The evaluation criteria which were used to assess each functional area are i
l described in detail in NRC Manual Chapter 0516.
This chapter is in the Public Document files.
Therefore, these criteria are not repeated here but will be presented in detail at the public meeting to be held with l
licensee management on March 30, 1990.
However, the NRC is not limited to l
these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluateri is rated according to three performance categories.
The definitions of these performance categories are as follows:
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Category 1:
Licensee management attention and involvement are
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readily evident and place emphasis on superior performance of nuclear
safety or safeguards activities, with the resulting performance
substantially exceeding regulatory requirements.
Licensee resources
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are ample and effectively used so that a high level of plant and i
personnel performance is being achieved.
Reduced NRC attention may j
be appropriate.
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Category 2:
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good.
The
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licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and
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reasonably allocated so that good plant and personnel performance is
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being achieved.
NRC attention may be maintained at normal levels.
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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 requirements.
Licensee resources appear to be strained or not effectively used. NRC atten-tion should be increased above normal levels.
IV.
PERFORMANCE ANALYS!$
A.
PLANT OPERATIONS 1.
Analys,Q This functional area addresses the control and performance of activities directly related to operating the unit, as well as fire protection.
In addition to routine inspections conducted by the NRC staff, an operational safety team inspection (OSTI),
emergency operating procedures team inspection (EOP), and a triennial postfire safe shutdown inspection were performed.
Management involvement and commitment to assuring quality was enhanced by establishment of routine management backshift tours and increased utilization of first line supervision and workers in the identification and resolution of problems.
Site manage.
ment meetings were held weekly to address goals and respond to emergent issues.
Unit management meetings were held twice a week and more frequently as needed to provide an interdisci-plinary coordinated response to both management and technical issues.
Toward the end of the assessment period, each organi-zational unit developed a top ten outstanding issue list for their respective organizations.
Integration of these issues into an overall site priority scheme had not been completed.
Organizational changes resulted in a streamlined chain of command with the elimination of one level in operation's hierarchy.
The shift foreman's direct control of personnel
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involved in shift activities was expanded by the assignment of fire protection personnel and shif t technical advisors to each shift.
These changes resulted in increased personnel accountability and improved intradepartmental communications.
In addition, establishment of a dedicated operations procedure group composed of licensed operators resulted in higher quality procedure revisions.
Operations was composed of five shif ts with an additional relief / training crew.
Shif t staffing levels met or exceeded Technical Specification (TS) requirements.
The incorporation of recently licensed individuals into the operations staff should provide additional flexibility in the performance of routine and necessary support functions.
Control room shift performance continued to be effective.
Comunications between operations and other groups were typi-cally good; however, communications among operations personnel tended to be informal and assumed a greater understanding on the part of the listener.
Lack of adequate communication between operations ersonnel contributed to an inadvertent safety injection ( !) system actuation during the reactor coolant system (RCS resistance temperature detector (R1D) manifold removal modification.
Weaknesses were observed in certain operating activities and programs.
Areas affected included independent verification, annunciator pane 1~ procedures, the operations corrective action program, logkeeping practices, and procedure revisions.
In addition, weaknesses were observed with equipment identifi-cation, identification of equipment deficiencies, and knowledge of proper component operation.
Contributors to the weaknesses were oftentimes individual or shif t dependent.
Operations management has been responsive in addressing these weaknesses as demonstrated by personnel reassignments, increased training, and increased emphasis on procedure complianco and clarity.
Understanding of compliance with Technical Specifications was typically good.
Early in the assessment period, effective corrective action was taken to address an inadequate detemin-ation of applicable Technical S when motor control center (MCC)pecification action statements 6 was declared inoperable.
A problem in operability determinations involving degraded
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equipment was identified when reduced auxiliary feedwater (AFW)
flow was noted. An interim guideline was subsequently developed to assist operations personnel in performing operability determinations until additional operability training can be developed and implemented.
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The operating staff's anticipation of problems or potential recurrence of problems, was excellent for a number of events.
These included preplanning activities and actions taken associated with recovery of a spent-fuel assembly. Hurricane Hugo, AFW flow te'. ting in August 1989, and surveillance testing involving the turbine generator limiter.
The emergency operating procedures (EOP) inspection team determined that the E0Ps adequately covered the mitigation of a broad range of accidents and equipment failures necessary for safe shutdown of the plant.
Weaknesses were identified in management control of the E0Ps, adequacy of plant specific technical guidelines, incorporation of human factor concepts, verification and validation processes, and prestaging of equipment necessary for the accomplishment of E0P steps. At the end of the assessment period a program was being developed to address these concerns.
A triennial postfire safe shutdown inspection verified that the licensee maintained postfire safe shutdown capability, has a clear understanding of fire protection and Appendix R require-ments, and was responsive to NRC safety requirements.
Housekeeping in most areas of the plant was above average to excellent.
The licensee had taken steps to improve conditions in areas identified in the previous SALP report.
Housekeeping efforts associated with the boron injection tank room and inside containment during the refueling outage were noteworthyt however, housekeeping inside containment during forced outages was inconsistent.
Two sets of operator license initial examinations were administered during this assessment period.
In December 1988 examinations were administered to eight reat. tor operator (RO),
candidates with a 100 percent pass rate.
In December 1989, examinations were administered to five R0 and 5 senior reactor operator (SRO) candidates.
The examination resulted in three R0s and two SR0s passing.
Four of the five failures occurred on the simulator portion of the examination.
No requalification examinations were administered this assessment period.
One violation was identified.
2.
Performance Rating Category:
3.
Recommendations None
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B.
Radiological Controls 1.
Analysis This functional area addresses those activities directly related to radiological controls and primary / secondary chemistry control, as viewed during routine inspections conducted throughout the assessment period.
The licensee's radiological controls program was effective, for the most part, the licensee's radiation protection staff is experienced, and staffing levels were adequate and remained steady.
During the assessment period, the licensee appointed a new Environmental and Radiological Controls (E&RC) Manager.
Training of the E&RC staff was reviewed and found adequate.
In July 1989, the licensee released contaminated welding equipment from the protected area (PA) without proper surveys.
As a result, this equipment was released offsite to a vendor unauthorized to receive radioactive material.
As similar problems occurred during the previous assessment period, the licensee's previous corrective actions had not been effective.
There were also occasions where the licensee impro>erly released radioactive material outside the radiation control area (RCA),
but not outside the PA.
The licensee formed a task force to determine the root cause of these events and has implemented acceptable interim corrective actions.
During the assessment period, the licensee reduced the total contaminated area within the RCA (excluding containment) to 1,044 square feet (ftt) or approximately 1.5 percent of the RCA.
The licensee's goal for 1989 was 2,000 f te or 2 percent of the RCA. The licensee effectively reduced plant contamination areas and Net their desired goal.
The licensee has effectively controlled and held personnel contaminations to a minimum as evidenced by being well within their established goal.
As of December 31, 1989, the licensee recorded 93 personnel contamination (skin and clothing) events, 74 percent of their 1989 goal of 125.
The station's 1989 collective dose goal was established at 150 person-rem.
By the end of the assessment period, the licensee had accumulated 206 person-rem which is 137 percent of their projected goal.
The reason for exceeding the projected goal was unanticipated extended maintenance outages.
Even though the licensee exceeded the 1989 person-rem goals, the total collective dose is well below the previous year when the
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collective dose was $64 person-rem.
This reduction is indicative of numerous source term reduction efforts taken by the licensee and better planning and scheduling of work performed during this assessment period.
During fuel cycle No.
12, the licensee had implemented an elevated lithium control program in the RCS intended to minimize primary side corrosion and the deposition and activation of corrosion products on the fuel cladding.
A more effective RCS letdown filter was placed in service early in the assessment period, increasing suspended solids removal from the RCS.
Although exact numbers were not available, the plant health physics staff had noted significant reductions in general plant dose rate source terms during the last outage.
In response to as low as reasonably achievable (ALARA) program weaknesses identified in the previous assessment period, the licensee established a Plant Management ALARA Review Committee (PMARC) in which each department manager participates. Manage-ment involvement to control dose was good, as exemplified by PMARC planning for specific job activities.
The PMARC holds meetings as necessary to discuss radiation exposure goals, successes, and problems, assigning action items for resolution and followup where appropriate.
This Committee provides a forum for plant management to receive up to-date information and have an in-depth involvement in the ALARA program.
The ALARA Subcomittee reports directly to the PMARC and provides informa-tion for review and action.
ALARA planning for specific job activities has been effectively implemented. This was evidenced through pre-planning, coordination, and communication involved with the recovery of a spent fuel assembly which was dropped during loading of a dry storage canister.
Personnel dose was minimized, effective radiological monitoring controls were established, and potential radiological hazards were evaluated, with appropriate p(recautions taken. involving Patel seal grommet replac There was, however, an isolated example where miscommunication between E&RC and Maintenance resulted in maintenance personnel initiating work prior to the placement of shielding, as originally called for during ALARA planning.
The radiological environmental monitoring program has been effective in assessing the impact of radiological releases to the environment.
There was a significant decreasing trend (4-orders of magnitude) in gaseous iodine releases between 1987 and the first half of 1989.
This was attributable to improvements in fuel cladding integrity, reduced RCS leakage, and the use of radwaste domineralizers that eliminated the need for the use of radwaste evaporators.
Fission and activation gaseous release rates for the first half of 1989 were also significantly lower than 1987 and 1988 levels.
Other gaseous and liquid effluents showed no significant trends over the period.
Technical support by EARC to effluent controls was good.
Liquid and gaseous effluents were well within Technical Specification,10 CFR 20,
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l and 10 CFR 50 effluent limitations for 1988 and the first half of 1989.
Secondary plant chemistry was maintained well within owner's group guidelines for the period and circulating water in-leakage into the condenser was minimal.
As a result, only one steam generator tube has been plugged since the 1984 steam generator replacement.
One violation was identified.
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Performance Rating Category:
3.
Recommendations None C.
Maintenance /Sur_veillance 1.
Analysis This functional area addresses those activities throughout the assessment period related to maintenance and surveillance, as viewed during routine inspections, a motor operated valve inspection, and an operational safety team inspection (OSTI).
Overall, maintenance and surveillance activities were coordinated and performed well; however, procedural adherence problems were identified as a weakness.
Licensee involvement in assuring quality in the maintenance and surveillance area increased towards the latter portion of this assessment period.
The intradepartmental reporting chain in the Maintenance section was streamlined, with the foremen now reporting directly to the Maintenance Manager, versus through a supervisor as previously structured.
This organizational change was made to promote more effective consnunications, as well as to increase performance accountability.
Active job oversight and control in the form of direct, first-line maintenance super-vision at the job ' site (including backshifts) improved toward the end of the assessment period. Additionally, the continuing training program for maintenance personnel has been enhanced resulting in program refinements and user-determined training subjects.
There has also been an increase in scheduled speciali:ed training (e.g., batteries) in an effort to improve work efficiency and task knowledge, Maintenance staffing levels appeared adequate.
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f Resolution of issues from a safety standpoint was generally good, f
Major maintenance evolutions such as AFW system pump repairs,
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safety injection ($1) pump repairs, and emergency diesel t
generator (EDG) high cylinder temperature troubleshooting,
were routinely overseen by vendor representatives,. A weakness
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was identified that was associated with excessive rework being I
performed before a condition was permanently fixed.
Examples of i
repetitive repairs resulting from the same failure mode included f
various valves and reactor turbine generator board (RTGB)
recorders.
The unavailability of this equipment presented i
unnecessary distractions and/or challenges to the operating staff, t
.aring the assessment period, a maintenance 3rocedure upgrade
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program was implemented.
This program was in'tiated as a result
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of deficiencies identified in existing maintenance procedures, as well as a lack of detailed preventive and corrective main-l tenance procedures for some systems (e.g., EDGs).
A violation
was issued for an inadequate corrective maintenance procedure
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which resulted in incorrect service water (SW) pump shaft
clearances.
'The maintenance procedure upgrade program is
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scheduled for completion at the end of 1990 and encompasses
approximately 500 maintenance procedures.
The Maintenance
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Surveillance Test (MST) procedure upgrade program is essentially
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complete.
This program appears to have been effective, as there
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were no reactor trips, transients, or violations attributed to
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MST procedural inadequacies.
Control of the maintenance item l
backlog was good.
i The licensee's performance in implementing preventive / predictive
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maintenance efforts was inconsistent.
The valve packing program
has proven beneficial by reducing leak rates.
However, upon disasembly of the motor driven auxiliary feedwater (MDAFW)
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and steam driven auxiliary feedwater (SDAFW) pumps, there were l
various conditions (i.e., cavitation damage, clogged oil lines, i
worn parts, etc.) which could have been identified and corrected i
through an effective preventive / predictive maintenance program.
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lt was determined that the MDAFW pumps were never opened and
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ins)ected; however, the licensee has taken steps to correct this l
wea(ness through further initiatives in this area.
Equipment aging and balance of plant (BOP) equipment cont;nued i
to be a problem.
The loss of both the main and backup 15-nit i
turbine electro-hydraulic (E-H) control power supplies resulted
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in a reactor trip on March 30, 1989.
This was attributed to equipment aging.
Also, there were several turbine runbacks
which resulted from failures of aging B0P equipment.
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During the assessment period, the licensee implemented a repetitive failure analysis mechanism through utilization of the F
Automated Maintenance Management System (AMMS).
This system provides an automated method for work request planning, initiation, completion documentation, and identification of repetitive failures.
This repetitive failure identification-method was implemented in the last quarter of 1989 and has begun producing positive results.
Examples of procedural adherence and work control problems included incorrect multimeter usage resulting in a reactor trip on February 27, 1989; hydrogen gas introduction into the plant air systems; lack of control of the fastener torquing programt and use of inadequate materials in replacement of a Rosemount transmitter.
These specific examples coupled with several instances of failure to follow procedures, resulted in five violations relating to work performance and work control.
The conduct of surveillances was generally good.
Inadequate procedural adherence during a surveillance resulted in a reactor trip (operator mistakenly closed a main steam isolation valve instead of the SDAFW pump steam admission valve) on March 22, 1989.
A contributor to this inadvertent reactor trip was the concurrent performance of two surveillance tests. Additionally, improper control of a valve line-up configuration and failure to fully implement inservice testing requirements resulted in two violations.
A weakness in evaluating inservice valve stroke data was also identified.
The licensee's inservice inspection program for eddy current examination of steam generator tubes was found to be effective.
Ten violations were identified.
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Performance Ratings Category:
3.
Recommendations In view of the problems encountered with equipment aging, AFW components, and BOP equipment, the Board recommends additional efforts towards implementation of an effective preventive /
predicitive maintenance program.
D.
Analysis This functional area addresses those licensee emergency preparedness activities observed during a routine emergency preparedness inspection, an emergency exercise, and responses to
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12 actual events.
Overal), the emergency preparedness program received good management support.
The licensee maintained the basic emergency preparedness elements needed to effectively implement the key elements of the Emergency Plan and respective procedures in response to emergency events.
The routine inspection conducted in August 1989 noted that the licensee's emergency preparedness program was being maintained in a state of operational readiness.
The licensee was main-taining adequate facilities, equipment, and a trained staff for response to an emergency. Licensee representatives demonstrated an understanding of the concepts and the specifics of the emergency response program, reflecting an effective training program in thi s area.
Several program strengths were identified:
(1) independent audits were detailed, comprehensive, and resulted in effective corrective actions; (2) management commitment was evident in support cf the emergency response program; (3) an
" Emergency Preparedness Tracking System" was effectively maintained for ensuring that prompt and adequate corrective actions were taken for deficiencies identified during independent audits, dril15, and exercises; and (4) the onsite emergency organization was adequately staffed and was trained in accordance with the Plant Emergency Plan Procedures (PEPS) through the use of detailed and well-structured lesson plans.
There were four emergency declarations made during the assessment period.
In each case, the event was properly classified and prompt offsite notifications were made.
The emergency exercise conducted in November 1989 demonstrated that the licensee could implement the Emergency Plan and PEPS.
Exercise weaknesses identified during the previous assessment period (i.e., timely news releases following declaration of a general emergency, timely news briefings, and appropriate exposure control for offsite workers) were corrected during this exercise evaluation.
The licensee demonstrated effective assignment of emergency response organization responsibilities, took suitable actions to mitigate the plant casualty, and made appropriate protective action recommendations to protect the public.
_0verall, the exercise, was considered successful although three exercise weaknesses were identified.
At the outset of the exercise the licensee failed to recognize the occurrence of an initiating condition for a Notification of Unusual Event.
The weaknesses were particularly noteworthy in that during the previous assessment the licensee failed to event (y the appropriate emergency action-level for a real identif NOVE).
The second weakness involved personnel failure to follow procedures for an off hour activation of the emergency
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response organization, which contributed to an untimely activation of the Technical Support Center and Operations Support Center.
Failure to make a timely event classification and failure to fully activate emergency response facilities in a timely manner are significant exercise weaknesses and will require redemonstration during a future exercise.
A third weakness not directly related to the licensee's response performance was the failure to prepare an exercise scenario with l
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technically consistent exercise data.
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The licensee continues to maintain an effective emergency notification and comunications system, consisting of proce-dures, equipment, and trained staff to notify offsite agencies.
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These systems include the Emergency Notification System,.a
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dedicated Selective Signaling System, and backup equipment that included radio, e arivate telephone exchange, and commercial
telephones. The Pu)11c Notification System sirens were properly
maintained and tested.
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No violations were identified.
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Performance Ratino Category:
3.
Recommendations None E.
Security 1.
Analysis This functional area addresses those security activities related to protection of plant vital systems and equipment, as viewed during inspections and observations throughout the assessment period.
There is significant corporate and site involvement in support of the security organization.
Strong interface exists among the licensee's security program at each of its three nuclear facilities and at the Corporate level.
Site self assessments have been effective and led to upgrades and improvements.
During this assessment period the licensee identified the need to better document its annual audit of the security program to capture those efforts spent witnessing performance tests and contingency exercises.
The licensee continues to demonstrate the ability to implement and manage an effective security program.
The staffing level for the contract security force was appropriate.
Overall,
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performance and effectiveness of security personnel on posts
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were satisf actory.
However, early in the assessment period two occurrences of f ailure to provide adequate vital area access
controls were caused by watchpersons not being attentive to duty
or sensitive to their regulatory responsibilities, in both
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cases the watchpersons involved had been trained and requalified in the correct access control procedure.
These are considered
isolated events and did not involve programmatic failures or i
weaknesses.
During more recent inspections, improvements were noted in the performance of the security force, specifically in weapons proficiency.
Additionally, performance during adverse
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conditions associated with Hurricane Hugo was professional and i
timely, in that patrols, elarm response, posts, and access control duties were not suspended.
j Inadequate closed circuit television camera assessment i
capabilities along portions of the protected area perimeter resulted in the licensee dispatching officers to perimeter j
alarms without first assessing the alarm by camera to identify i
the existence of a potential threat. A violation was issued for j
this deficiencf and the licensee has taken corrective action.
The licensee was responsive to NRC identified vulnerabilities l
relative to vital area alams and barriers provided to safety
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related equipment, as well as searching personnel and packages t
at the protected area access structure.
During tests observed,
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officers involved in Protected Area search activities were very
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thorough, alert, and effective.
Additionally, related NRC j
Information Notices and Generic Letters received adequate distribution and evaluation.
Licensee security, contingency, guard training, and l
qualification plan change submittals have been well coordinated
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and technically sound.
Changes to these plans were made
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appropriately under the provisions of 10 CFR 50.54(p).
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Two violations were identified.
2.
Conclusion:
Category:
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t 3.
Recommendations:
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None
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F.
Engineerina/ Technical Support l
1.
Anal,ysis
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The Engineering / Technical support functional area addresses the i
adequacy of engineering and technical support for all plant
activities.
In addition to routine itispections, a motor operated
valve (MOV) team inspection, an operational safety team i
inspection, a triennial postfire safe shutdown inspection, and
an augmented inspection team inspection (AIT) were conducted.
i Overall performance in this area has been inconsistent, r
The licensee dedicated significant onsite technical support
resources to the corporate Nuclear Engineering) Department's (NED) l administered Design Basis Documentation (DBD program.
The f
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onsite technical support organization was involved in various phases of DBD evaluations and corrective actions for identified problems.
The program identified numerous documentation and
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plant hardware deficiencies requiring resolution.
Significant l
operability and safety issues which were identified by this
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effort included an AFW system design deficiency, residual heat
- i removal (RHR) system single f ailure vulnerability, and $1 sequencer timing issues. Overall, connunication with the NRC on identified DBD issues was good and plant safety and reliability i
has been enhanced by related plant modifications.
However, engineering performance associated with identification and resolution of emergent issues was inconsistent, as illustrated i
in the following paragraphs, i
Effective technical support was evident in moo.fications to resolve identified design deficiencies, control of contractors.
l and response to operational events.
Good control of contractor r
engineering activity was demonstrated during modifications
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completed for the service water system piping replacement.
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Engineering investigation and evaluation of the A loop RTD
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hotleg thennowell-crack demonstrated good technical support of
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plant operating events.
The resolution of the AFW net positive
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suction head (NPSH) desi
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problem was identified. gn deficiency was thorough once theOther issuei control center (MCC) gineered safeguard features (ESF) motor resolved included en i
overloading and SI sequencer timing issues.
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The triennial postfire safe shutdown inspection (discussed in i
Section IV. A.) identified that engineering's incorporation of i
Appendix R issues in procedures and activities was comprehensive-l and demonstrated a sound knowledge of these issues in design (
control activity.
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Deficient performance observed in various engineering and technical support activities were attributable primarily to communications weaknesses, lack of thoroughness, and inattention to detail.
Engineering did not perform the required safety analysis of component cooling water heat exchangers to verify they continued to meet design requirements following tube plugging.
An electrical modifications to correct various safety related electrical deficiencies resulted in' incorrect MOV breaker sizing and thermal overload setpoints.
Additionally, engineering inadequately evaluated an environmental qualification deficiency related to containment Patel conduit seal testing and installation.
The licensee was untimely in identifying the ArW NPSH issue, in light of the indicators which were evident following the 1985 CP&L safety system functional inspection and system performance deficiencies which were observed prior to and during the current assessment period.
The untimely identifica-tion of this system deficiency demonstrated the er.istence of a consnunications weakness between licensee technical organizations, inaccurate engineering conclusions based on incorrect information, contributed to the delay.
Inadequate communications also resulted in reactor protection system overpower delta T and overtemperature delta T setpoints not being revised when required.
1.imited technical support of routine plant activities was identified as a weakness in the previous assessment period.
Staff increases have occurred during this assessment period, however, they did not fully compensate for the large reactive workload in that engineering resources were principally focused on reactive work and provided little technical support of routine plant activities. A notable exception was the assignment of an onsite engineer to function as the primary interface with operations for issues related to control room instrumentation and controls.
The licensee identified a potential system engineer (SE) program weakness due to personnel reassignments and initiated the development of a training program to improve SE technical support performance.
Actions to improve SE performance included a reduction of SE workload by increased staffing levels and the transfer of procurement and design verification functions to NED, An innovative system team concept initiated in the early portion of the assessment period has not been fully implemented.
Toward the end of the assessment period the licensee initiated actions to improve NED's responsiveness and accountability for station technical requirements, as well as plant /NED communica-tions.
Five violations were identifie l
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2.
Performance Rating Category: 2 3.
Recommendations:
The Board notes that p rformance in this area has been mixed.
While performance has been strong in the areas of design reviews and resolution of identified technical issues, additional management attention is needed to assure timely identification of emergent issues and involvement of technical support in routine plant activities.
G.
Safety Assessment /Ouality verification 1.
Analysis The assessment of this functional area is based on a review of licensee implementation of safety policiest activities related to license amendments, exemptions, and relief requests; responses to Generic Letters. Bulletins, and Information Noticest resolution of safety issues (10 CFR 50.59 reviews);
safety review committeet and use of feedback from self-assessment programs and activities.
The licensee has initiated efforts to improve site processes and practices.
Foremost of these was de.velopment of site goals by a Board of Directors (BOD), a committee of unit and department managers. The BOD placed emphasis on recognizing different unit needs, teamwork to address these needs, promotion of the existin Total Quality (TQ) program, and means to improve work controls. g Site management's commitment to TQ was demonstrated by the assignment of a full time TQ coordinator to the site manager and support of TQ programs / methodologies in applicable applications.
Support for quality resolution of problems was demonstrated by a review to examine weaknesses of the work control systems and pro)osed viable solutions.
The process was conceptualized and wor < was in progress to support implementation of pilot work control programs by mid-1990.
The licensee's self-assessment and quality assurance programs were not always effective in problem identification.
The NRC identified programmatic weaknesses in the areas of fastener torquing, quality control inspection and independent verifi-cation. A weakness in the timely recognition of the full extent of problems was identified in the previous assessment period.
Licensee actions to correct this weakness have not been totally).
successful as demonstrated by the AFW NPSH issue (Section IV.F.
However, once the full extent of this and other sipificant problems were identified (e.g. diesel generator exhaust line s
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seismic qualification and SI sequencer timing issues), the licensee demonstrated a strong commitment to safety by taking prompt corrective actions.
The licensee's performance of oversight functions was generally adequate.
The Plant Nuclear Safety Comittee (PNSC) routinely made technically sound and conservative decisions involving emergent safety-related issues such as the RCS RTD themowell cracking problem and AfW system operability concerns. However.
PNSC actions resulting from a proactive overview function were infrequent.
TheCorporateNuclearSafety(CNS)Sectionoversight functions were not always effectively performed (i.e., Licensee Event Report (LER) reviews were not timely and site specific trends were not identified by the CNS independent review).
However, the AFW system performance anomalies were identified by the onsite CNS group during review of site activities.
Licensee submittals to the NRC frequently were incomplete.
The analyses for 10 CFR 50.92(c) on determination of whether or not the proposed action involved no significant hazards consi-deration were often perfunctory and lacked in depth analysis as exemplified by the TS amendment request to increase fuel enrichment.
Furthermore, safety evaluations were not included in initial submittals for several TS amendments involving electrical systems.
The quality and completeness of 10 CFR 50.69 reviews associated with plant modification packages were inconsistent, reflecting the plant procedure inadequacies.
The licensee was aware of these inadequacies and had established a company-wide task force to revise the procedure.
The licensee':, responses to Bulletins, Generic Letters (GL) and data on multiplant actions have been timely and met staff requirements. The licensee has an excellent tracking system for meeting deadlines, updating status, as well as recalling historical data on the Bulletins, GLs, and multiplant actions.
The quality of LERs, though generally good, showed occasional weakness at the end of the assessment period.
For example, LER 89-15 identified a loose Patel seal union nut as an isolated condition even though a s}milar situation had previously been identified during this assessment period.
Events reported per 10 CFR 50.72 were subsequently issued as LERs as required.
One violation was issued for failure to report an event within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery, four violations were identifie,-
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Performance Rating Category:
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Recomendations None V.
SUPPDRTING DATA A.
Licensee Activities Unit operations performance, unlike the previous assessment period, was dominated by a 124 day design deficiency related forced shutdown and a 105 day refueling outage.
The unit began and ended the assessment period at 100% power.
Three reactor trips from greater than 15% power (described in Section V.G.) and two additional forced outages (described below) occurred during the assessment period as compared with six trips and 14 forced outages during the previous period.
On A)ril 3,1989, the unit was removed from service to recover a portd on of a control rod guide tube support pin and nut from the C steam generator.
The outage was extended to April 15,1989, to address potential coninon mode failure of the RHR system due to flooding.
On August 22, 1989, a unit record run of 128 days was terminated when the unit was removed from service due to inadequate net positive suction head for the AfW pumps.
The outage to modify and repair the AfW system was extended to address other identified safety-related issues (e.g., diesel generator exhaust line seismic qualification; foreign material in the containment fan coolers; environmental qualification of containment instrumentation and solenoids; and the
$1 sequencer timing issues).
The unit was returned to service December 23, 1989.
Major maintenance and/or surveillance activities which occurred
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during this period included service water flow testing; valve repacking; breaker inspections /setpoint verifications; environmental qualification inspection verificat'ont control room meter calibration and face replacement; Limitorque inspection; EDG high cylinder temperature resolution; AfW system refurbishment / repair and. testing; and Patel conduit seal inspection and gronsnet replacement.
Two major self-assessments utilizing outside management consulting firms were performed during the assessment period.
A review of nuclear operations similar to that conducted at the other CP&L nuclear sites was performed.
An Organizational Analysis which examined job responsibilities and functions was completed.
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personnel reassignments involved the maintenance manager, regulatory
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compliance director, environmental and radiation control manager,
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outage manager, and plant support manager.
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Direct inspection and Review Activities
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Besides the routine inspections performed by the NRC staff, special
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inspections were conducted as follows:
l March 22-26, 1989; MOV team inspection to determine if MOVs were
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designed, installed, and being maintained to ensure capability
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of performing their safety related functions.
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July 10 28, 1989: Operational safety team inspection to assess
the level of performance in the area of plant operations.
August 28 September 1, 1989; Augmented inspection team to review
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events related to the identification of inadequate net positive I
suction head for the auxiliary feedwater system.
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September 18-29,1989; E0P team inspection to verify the E0Ps
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were accurate, and specified actions could be accomplished using
existing plant instruments, equipment, and controls.
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October 12-16, 1989; Triennial ostfire safe shutdown inspection f
to verify shutdown capability f 110 wing a fire.
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C.
Management Conferences f
r 11/16/88 Management Meeting at Region 11 to discuss outage work
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activities, i
12/08/88 Enforcement Conference at Region 11 to discuss a security I
probl em.
l 01/11/89 Management Meeting at Headquarters to discuss the DBD
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Program for H. B. Robinson.
l 01/24/89 Management Meeting at Robinson Visitor's Center to discuss SALP Board Assessment.
i 02/09/89 Enforcement Conference at Region !!
to discuss:
(1) non-qualified power cable splices to containment fan coolers; (2) undersized breakers on MCC-5&6; and
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(3) hydrogen intrusion into the service and instrument air l
systems.
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i 10/02/89 Enforcement Conference at Region 11 to discuss issues
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related to AFW operability.
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10/10/89 Management Meeting at Headquarters to discuss AFW modifications and proposed restart.
12/28/89 Management Meeting at Region !! to discuss activities related to equipnent issues which transpired during the AFW outage.
D.
Review of Licensee Event Reports During the assessnent period, 18 LERs were analyzed.
The distribution of these events by cause, as determined by the licensee, was as follows:
Cause Number Component Failure
Design, Procedures
-Personnel Operating Activity
-Maintenance Activity
-Test / Calibration Activity
-Other
Out of Calibration
Other
Total TE E.
Licensina Activities In support of licensing activities, meetings were held with the licensee to address licensing and other technical issues.
Five license amendements were issued.
Most significant were:
reactor trip breakers; RTD bypass eliminations diesel fuel inventory, and molded case circuit breaker (MCCB) testing.
In addition, several safety ) evaluations were issued (not associated with an Amendment request, the most significant of which were: Appendix J exemptions IST relief t 0B 50 modification plan evaluations MCCB evaluation; battery duty cycle evaluation, and evaluation of the final configur-ation of the safety injection syste E j
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Enforcement Activity NO. Of VIOLATION 5 IN EACH SEVERITY LEVEL FUNCTIONAL AREA V
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PTiiit Operations
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Radiological Controls
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0
Maintenance / Surveillance
10
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0
0
Security
2
0
Engineering / Technical Support
4 1(a)
0 Safety Assessment / Quality Verification
3 1(b)
0 TOTAL
21
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($75K Civil Penalty.11/15/89, )related to Notes:
(a) Severity Level !!! violation issued Severity inadequate AFW system NPSH.
Level !!! violatin ($450K Civil Penalty is pending from the previous assessment period.
Two additional examples of this violation were issued in the current assessment period.
(b) Severity Level 111 violation issued on 4/6/89, involving undersized breakers on MCC-5 & 6. (No Civil Penalty)
G.
Reactor Trips Three automatic scrams with power greater than 15 percent occurred.
On February 27, 1989, the reactor tripped from 30 percent power due to an $1 signal.
A NOVE was dec~1ared at 4:22 p.m. and exited 29 minutes later.
Improper installation of a meter into the E-H control circuit by an instrumentation and control technician initiated the transient. The unit was returned to service February 28, 1989.
On March 22, 1989, the reactor tripped from 100 percent power when an operator inadvertently closed a main steamline isolation valve while performing a surveillance test on the SDAFW pump.
The unit was returned to power operation the same day.
On March 30, 1989, cascading failures of both E H power supplies resulted in a turbine / reactor trip f rom 100 percent power.
Tie unit was returned to power on March 31, 1989.