IR 05000261/1991010
| ML14178A133 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/22/1991 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 9108120221 | |
| Download: ML14178A133 (38) | |
Text
%2L 221591 Docket No. 50-261 License No. DPR-23 Carolina Power and Light Company ATTN:
Mr. Lynn W. Eury Executive Vice President Power Supply P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NO. 50-261/91-10)
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)
Report for your Robinson facility which was sent to you on May 31, 1991; our meeting of June 11, 1991, at which we discussed this report; and your written comments dated July 9, 1991, relative to the repor Although your July 9, 1991 letter indicates that you agree with the quantitative ratings of the Initial SALP Report, it contends that the report should have recognized an improving trend in the functional areas of operations and engineering/technical suppor In light of your specific comments, a review of these two functional areas was subsequently conducte Like the initial assessment, this subsequent review could not clearly discern definite improving trends which, if continued, may result in changes in these areas' future performance rating Accordingly, changes to the Initial SALP Report are not considered necessar Enclosed is our summary of the June 11, 1991 meeting; a copy of the SALP slides; your response dated July 9, 1991; and a revision to the Initial SALP Report which constitutes the Final SALP Repor No reply to this letter is required; however, should you have any questions concerning these matters, I will be pleased to discuss them with yo
Sincerely, Original Signed by Stewart D. Ebneter S. D. Ebneter Regional Administrator
Enclosures:
(See page 2)
~91812 9.107 PDrR ADOC~IK 050002%I
Carolina Power and Light Company
Enclosures:
1. June 11, 1991 Meeting Summary 2. June 11, 1991 SALP Slides 3. CP&L Letter Dated July 9, 1991 4. Revision Sheet
REGION II ORGANIZATION FFICE OF THE ADMINISTRATOR ADMINISTRATOR S. EBNETER DEPUTY J. MILHOAN TVA PROJECTS CHIEF B. WILSON DIVISION OF DIVISION OF DIVISION OF REACTOR PROJECTS REACTOR SAFETY RADIATION SAFETY AND SAFEGUARDS DI L. REYES DI A. GIBSON DI J. STOHR DEPUTY E. MERSCHOFF DEPUTY J. JOHNSON DEPUTY B. MALLETT
DIVISION OF REACTOR PROJECTS ORGANIZATION DIVISION OF REACTOR PROJECTS DI L. REYES DEPUTY E. MERSCHOFF REACTOR PROJECTS BRANCH NO. I CHIEF D. VERRELLI PROJECTS SECTION PROJECTS SECTION NO. 1A NO. 1B CHIEF H. CHRISTENSE CHIEF F. CANTRELL BRUNSWICK FARLEY HARRIS GRAND GULF ROBINSON SUMMER
NRR ORGANIZATION OFFICE OF NUCLEAR REACTOR REGULATION DIR. T. MURLEY C.1 DRECTOR FOR ASSOC. DIRECTOR FOR PROJECTS INSPECTION AND J. PARTLOW DSVISION OF REACTOR PROJECTS I/Il11VIINO S. VARGA, DIR. I/I1 G LAINAS, ASST. DIR. 11 T. MENDIOLA, DIR I1-1 (ACTING)
RECO INSON R LO, PROJ. MG ASOC DISOORATIONO IPROECTION AND TECENICAL PASSDESSN I
VIS AS SESSMN ARG, DR.QU1ALITYSEAUTIO T. M AND I.1 DIVISION OF REACTOR INSPECTION L,
P O VIG
.
-AND SAFEGUARDS ROBINSON FDIVISION OF RADIATION PROTECTION AND MERGENCY PREPAREDNESS DIVISION OF DIVISFONROFLICEEANSEE FREACTOR PROJECTS III/IV/V QUALITY EVALUATION CAND S
C LDIVISION OF SPECIAL PROJECTS SYSTEMS TECHNOLOGY
PERFORMANCE ANALYSIS AREAS FOR OPERATING REACTORS A. PLANT OPERATIONS B. RADIOLOGICAL CONTROLS C. MAINTENANCE/SURVEILLANCE D. EMERGENCY PREPAREDNESS E. SECURITY F. ENGINEERING/TECHNICAL SUPPORT G. SAFETY ASSESSMENT/QUALITY VERIFICATION
-AREA PERFORMANCE CATEGORY 1 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A SUPERIOR LEVEL OF PERFORMANC NRC WILL CONSIDER REDUCED LEVELS OF INSPECTION EFFOR AREA PERFORMANCE CATEGORY 2 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A GOOD LEVEL OF PERFORMANC NRC WILL CONSIDER MAINTAINING NORMAL LEVELS OF INSPECTION EFFOR AREA PERFORMANCE CATEGORY 3 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS. ACTIVITIES RESULTED IN AN ACCEPTABLE LEVEL OF PERFORMANCE; HOWEVER, BECAUSE OF THE NRC'S CONCERN THAT A DECREASE IN PERFORMANCE MAY APPROACH OR REACH AN UNACCEPTABLE LEVEL, NRC WILL CONSIDER INCREASED LEVELS OF INSPECTION EFFOR EVALUATION CRITERIA 1. MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY 2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT 3. ENFORCEMENT HISTORY 4. REPORTING, ANALYSIS AND CORRECTIVE ACTION OF REPORTABLE EVENTS 5. STAFFING (INCLUDING MANAGEMENT)
6. TRAINING EFFECTIVENESS AND QUALIFICATION
VIOLATION SUMMARY (CYCLE 9)
JANUARY 1, 1990 THROUGH MARCH 30, 1991 I
II III IV V
ROBINSON
0
12
REGION II AV <1
<1 PER OPERATING UNIT FOR ASSESSMENT PERIOD
ROBINSON JANUARY 1, 1990 - MARCH 30, 1991 (CYCLE 9)
COMP FAILURE 19%
OTHER
--
TS/A I
13%
TEST/CALIB 2 PERSONNEL OPERATING 2 25%
PERSONNEL CONSTR.(4 44%(
TOTAL (16)
LERs
FUNCTIONAL AREA I&TRIBUTION For Eighteen Region! I Sites SALP CYCLES 8 AN41D 9 Number of Sites 14 n
_
10 8H
4
o
-
OPS RAD M/S EP SEC ENG/TS SA/QV Functional Areas CATEGORY 1
CATEGORY 2 CATEGORY 3
MAN-HOURS/FUNCTIONAL AREA ROBINSON-CYCLE 9 EE M PR,'EP 4%~
(THER 1%
M LAIHT /SURIFV 27%
SA/Q~V 261%
ENG/TECH SUIPTT 4%-7
FACILITY PERFORMANCE SUMMARY ROBINSON RATING LAST RATING THIS FUNCTIONAL AREA PER[QD PERIOD PLANT OPERATIONS
2 (OPERATIONS & FIRE PROTECTION)
RADIOLOGICAL CONTROLS
1 MAINTENANCE/SURVEILLANCE
2 SECURITY
1 ENGINEERING/TECHNICAL SUPPORT
2 (ENGINEERING, TRAINING & OUTAGES)
SAFETY ASSESSMENT/
2 QUALITY VERIFICATION (QUALITY PROGRAMS & LICENSING)
0)
OPERATIONS (CATEGORY 2)
OVERALL PERFORMANCE IN THE AREA OF OPERATIONS REMAINED GOOD STRENGTHS
- OPERATOR PERFORMANCE
- STAFFING
- MANAGEMENT INVOLVEMENT IN STARTUPS
- SHUTDOWN RISK MANAGEMENT CHALLENGES
- MAINTAINING MANAGEMENT INVOLVEMENT
- LESSONS LEARNED
- CONTAINMENT HOUSEKEEPING
RADIOLOGICAL CONTROL (CATEGORY 1)
OVERALL PERFORMANCE IN THIS AREA REMAINED EXCELLENT STRENGTHS
- PEOPLE
-
MANAGEMENT
-
STAFF
- PROGRAMS
-
-
TRAINING
-
PROCEDURES
-
AUDITS
RADIOLOGICAL CONTROL (CON'T)
(CATEGORY 1)
- PERFORMANCE
-
CONTAMINATED AREA
-
EFFLUENT CONTROL
-
PERSONNEL EXPOSURE
-
PRI & SEC CHEM CONTROL
-
CONFIRMATORY MEASUREMENT CHALLENGE
- MAINTAINING PERFORMANCE
MAINTENANCE/
SURVEILLANCE (CATEGORY 2)
OVERALL PERFORMANCE REMAINED GOOD STRENGTHS
PEOPLE
-
QUALIFIED AND CAPABLE
-
MAINTENANCE IMPROVEMENT PLAN
- PERFORMANCE
-
SAFETY SYSTEM AVAILABILITY
-
NO MAINTENANCE PERSONNEL INDUCED TRIPS
-
IGSCC IDENTIFICATION AND RESOLUTION
MAINTENANCE/
SURVEILLANCE (CON'T)
(CATEGORY 2)
CHALLENGES
- FACILITIES
- PROGRAMS
-
-
POST MAINTENANCE TESTING
-
PROCEDURES-IST
- WORK CONTROL
-
FREON ISSUE
-
CAVITY SEAL
- PLANT AGING
EMERGENCY PREPAREDNESS (CATEGORY 2)
PERFORMANCE IN THIS AREA REMAINED GOOD STRENGTHS o*
PERFORMANCE
-
CHALLENGING EXERCISE
-
EFFECTIVE MITIGATION
-
EFFECTIVE CRITIQUE
- AUGMENTATION/ACTIVATION
-
BEEPERS
-
DRILLS
- FACILITIES
- TRAINING
SECURITY (CATEGORY 1)
PERFORMANCE IN THIS AREA REMAINED EXCELLENT STRENGTHS
- PEOPLE
-
QUALIFIED AND CAPABLE
-
WELL MANAGED
-
EFFECTIVE OVERSIGHT OF CONTRACTORS
- PROGRAMS
-
EFFECTIVE AUDITS
-
SECURITY PLAN
-
COORDINATION AND COMMUNICATION
EMERGENCY PREPAREDNESS (CON'T)
(CATEGORY 2)
CHALLENGES
- CORRECTIVE ACTION EFFECTIVENESS
- EMERGENCY CLASSIFICATION
SECURITY (CON'T)
(CATEGORY 1)
- PERFORMANCE
-
ACCESS CONTROL
-
BARRIER VERIFICATION
-
CONTROL OF SAFEGUARDS INFORMATION
-
SPENT FUEL SHIPMENT
- FACILITIES
-
SECURITY BADGE DETECTION
-
UPGRADE X-RAY EQUIPMENT
-
FIRING RANGE RENOVATION CHALLENGE
- MAINTAINING PERFORMANCE
ENGINEERING/
TECHNICAL SUPPORT (CATEGORY 2)
PERFORMANCE IN THIS AREA REMAINED GOOD
- STRENGTHS
- SUPPORT TO OPERATIONS
-
MODIFICATIONS
-
EMERGENT ISSUES
- DESIGN BASIS DOCUMENTATION
- MANAGEMENT INVOLVEMENT
-
TECHNICAL SUPPORT IMPROVEMENT PLAN
ENGINEERING/
TECHNICAL SUPPORT (CON'T)
(CATEGORY 2)
PERFORMANCE
- MODIFICATIONS/UPGRADES
- CONTROL ROD GUIDE TUBE PINS-SERVICE WATER SYSTEM
- TRAINING CHALLENGES
- TECHNICAL SUPPORT
-
STAFFING
-
TRAINING
-
QUALIFICATION
-
BACKLOG MANAGEMENT
SAFETY ASSESSMENT/
QUALITY VERIFICATION (CATEGORY 2)
PERFORMANCE IN THIS AREA REMAINED GOOD STRENGTHS
- MANAGEMENT INVOLVEMENT
-
MONITORING/ASSESSING
-
STARTUP MANAGERS
-
SHUTDOWN RISK MANAGEMENT
- OVERSIGHT
-
PLANT NUCLEAR SAFETY COMMITTEE
-
ONSITE NUCLEAR SAFETY
-
OPERATING EXPERIENCE FEEDBACK
- SAFETY EVALUATIONS
SAFETY ASSESSMENT/
QUALITY VERIFICATION (CON'T)
(CATEGORY 2)
CHt-ALtLENGES
- CORRECTIVE ACTION
-
SURVEILLANCE TEST PERFORMANCE
-
EMERGENCY RESPONSE AUGMENTATION
- RESPONSE TO INDUSTRY EVENTS
-
CHECK VALVE PROGRAM
-
TEMPORARY SERVICES IN CONTAINMENT
- EFFECTIVE NAD IMPLEMENTATION
ENCLOSURE 3 CP&L Carolina Power & Light Company ROBINSON NUCLEAR PROJECT DEPARTME POST OFFICE BOX 7 JUL HARTSVILLE, SOUTH CAROLINA 29550 JUL 0 9 1991 Robinson File No.:
13510E Serial: RNPD/91-159 6 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO NRC INSPECTION REPORT 91-10:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Gentlemen:
Carolina Power and Light Company (CP&L) has reviewed the Systematic Assessment of Licensee Performance (SALP) Board Report forwarded by your letter of May 31, 199 This report provided results from the evaluation period January 1, 1991, through March 30, 199 The Company agrees with and appreciates recognition of the quantitative ratings of the SALP Board which reflect the overall performance of the Robinson Projec In particular, CP&L was pleased to note the recognition of continued strong performance and management attention in the areas of security and radiological control CP&L contends that the Commission should recognize a positive improving trend in Operations and Engineering Support. Operations has had an aggressive program in leak identification and fuel integrity as indicated by H. Robinson's best quartile appearance for volume of radwaste and fuel reliability. Through the Corrective Action Program, Operations has ardently pursued resolution of near misses. The results of these efforts is seen in the 1990 Unplanned Safety System Actuations (0) and Forced Outage Rate (1.7).
The material condition of the plant has improved consistently largely through the efforts of Operations and Technical Support. These noted efforts were consistent throughout the assessment perio Enclosure 3 Letter to U. S. Nuclear Regulatory Commission Serial No.:
RNPD/91-1596 Page 2 Additionally, Robinson personnel participated in the investigative team that reviewed the Brunswick fire and returned with many lessons learned. Key lessons were reviewed with regard to problems encountered at Brunswick and several actions initiated, mostly dealing with Fire Brigade performance and support. These efforts resulted in excellent response by the Fire Brigade to the February 14th fire in the Containment Vesse In the area of Engineering Support, the System Engineer concept has shown measurable benefits. The Split Pin Replacement and Upper Internals Project were proven examples of this concept to assure continued positive performance in plant and fuel reliability for the future. Plant secondary chemistry also improved due to the System Engineer concept by reducing air in leakag A System Team is responsible for the considerable upgrade in the Radiation Monitoring System. In general, plant, fuel, and safety system reliability have improved due to an concerted effort by a qualified staff and management attention. CP&L believes that the strong showing of the Licensed Operators in the Licensed Operator Requalification Examinations not only reflects an excellent training program but is also indicative of a strong and improving Operations program. CP&L management has taken several steps to enhance Engineering Support, especially with Nuclear Engineering Department (NED)
involvement onsite. NED has taken the lead on material procurement and the development of modifications. NED also participates with the site on resolution and root cause analysis of site issues such as service water pipe corrosion and reactor head work. NED plays a critical role in maintaining design basis and in relieving the burden of the System Engineer, thereby assuring a cohesive Engineering Support Group. The efforts by both NED and Technical Support are ongoing enhancements that have been positively consistent during the assessment period. Due to the noted improvements and continuing progress towards the planned goals, CP&L believes the written report should more clearly reflect the improving trends in Operations and Engineering/Technical Suppor CP&L remains committed to further improvements in all functional areas and appreciates the.opportunity to respond to this assessment. Sustained improvement through proactive management involvement and oversight will provide assurance and that this performance trend will be sustained with measurable, auditable result Very truly yours, C. R. Dietz
-
Manager Robinson Nuclear Project Department PCHJ:sgk cc:
S. D. Ebneter L. W. Garner
ENCLOSURE 4 Revision Sheet Page Line Initial Report Reads Final Report Reads Coversheet
Initial SALP Report Final SALP Report
ENCLOSURE INITIAL SALP PORT U. S. NUCLEAR RE LATORY COMMISSION R ION II SYSTEMATIC ASSE SMENT OF LICENSEE PERFORMANCE IN ECTION REPORT NUMBER 50-261/91-10 CAROLINA POWER AND LIGHT H. B. ROBINSON JANUARY 1, 1990 -
MARCH 30, 1991
ENCLOSURE FINAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-261/91-10 CAROLINA POWER AND LIGHT H. B. ROBINSON JANUARY 1, 1990 -
MARCH 30, 1991