IR 05000269/1984031
| ML20132G457 | |
| Person / Time | |
|---|---|
| Site: | Oconee, 05000000 |
| Issue date: | 12/31/1984 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132G342 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-2.B.1, TASK-2.B.3, TASK-3.D.3.4, TASK-TM 50-269-84-31, 50-270-84-31, 50-287-84-35, GL-84-01, GL-84-1, IEB-80-11, IEIN-82-49, NUDOCS 8507190334 | |
| Download: ML20132G457 (25) | |
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DEC 311984 ,
s ENCLOSURE 1 SALP BOARD REPORT U. 5. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
- Inspection Report Numbers
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! 50-269/84-31; 50-270/84-31; 50-287/84-35 I l-l DUKE POWER COMPANY
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OCONEE NUCLEAR STATION UNITS 1, 2, AND 3 May 1, 1983 through August 31, 1984 f
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- -- - __ . _ - - - - .- -- - .. . - _ - . . - - INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this informa-tio SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be suffi-ciently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio A NRC SALP Board, composed of the staff members listed below, met on November 16, 1984, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report i s the SALP Board's assessment of the licensee's safety performance at the Oconee Nuclear Station for the period May 1, 1983 through August 31, 198 SALP Board for Oconee Nuclear Statien:
J. A. Olshinski, Director, Division of Reactor Projects (DRP),
i Region II (RII) (Chairman)
P. R. Bemis, Acting Director, Division of Reactor Safety, RII
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. J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII l V. L. Brownlee, Chief, Project Branch 2, DRp, RII R. M. Bernero, Director, Division of Systems Integration, Office of Nuclear Reactor Regulation (NRR)
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I Attendees at SALP Board Meeting:
H. C. Dance, Chief, Section 2A, DRP, RII H. Nicolaras, Project Manager, Operating Reactors Branch 4, Division of Licensing, NRR J. C. Bryant, Senior Resident Inspector, Oconee, DRP, RII K. Sasser, Resident Inspector, Oconee, DRP, RII L. King, Resident Inspector, Oconee, DRP, RII l
A. J. Ignatonis, Project Engineer, Section 2A, DRP, RII
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K. D. Landis, Chief, Technical Support Staff (TSS), DRP, RII i D. S. Price, Reactor Inspector, TSS, DRP, RII
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T. C. MacArthur, Radiation Specialist, TSS, DRP, RII i
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II. CRITERIA '
Licensee perforrlance is assessed in selected functional areas, depending upon whether the facility is in a construction, preoperational, or operating phase. Each funct.ional area normally represents areas which are significant-to nuclear safety and the environment, and which are normal programmatic areas. 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 One or more of the following evaluation criteria were used to assess each functional are . Management involvement and control in assuring quality
' Approach to resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Reporting and analysis of reportable events Staffing (including management) Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definition of these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety or construction is being achieve Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieve Category 3: Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieve I
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III. SUMMARY OF RESULTS Overall Facility Evaluation - Oconee 1, 2, and 3 The Oconee facility was effectively managed and achieved a satisfactory level of cperational safety. Major strengths were identified in the areas of- clant operations, maintenance, surveillance, emergency preparedness, security and safeguards, and refuelin The violations identified during this assessment period were of less significant regulatory concern than those identified during the last assessment perio Aggressive and effective licensee management involvement has taken place, particularly in the areas of plant oper-ations and surveillance as evidenced by a reduction in identified violations and licensee event reports. Also, it was noted that of the nine reactor trips that occurred from power operation during this assessment p'eriod, none of them were caused by operator error. The
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operators were knowledgeable of their facilit In assessing the licensee's staff training, it appears that they have instituted an effective licensed operator training progra This was based on a high pass rate of examinations taken for an operator licens During this assessment period, all three units underwent refuelin The licensee's planning and refueling activities were effectively performed and no violations were identiied. This finding is consistent with the last two assessment period Weaknesses were observed in radiological controls. The licensee was weak in assessing non-routine evolutions, specifically in shipment of
, radioactive materials that led to violation Additionally, the licensee was weak in identifying and evaluating problems in the radi-ological measurements, effluent control, and environmental dose assessment program The maintenance program was well organized with adequate planning and management involvemen The maintenance procedures were generally adequat As noted in the past assessment periods, the licensee continued to exhibit strong technical competence in safety review area For example, they have participated in the Babcock and Wilcox (B&W) Owners Groups, contributed to the development of a methodology to analyze for Pressurized Thermal Shock, and joined in a project with the Nuclear Safety Analysis Center to provide the utility industry with a practical application for probabilistic risk assessment (PRA) methods. This latter work culminated with a comprehensive study entitled "A Probabilistic Risk Assessment of Oconee Unit 3," NSAC-60. The licensee also developed generic Abnormal Transients Operating Guidelines (AT0G)
which the B&W Owners Group has endorsed for utility use. Other areas in which the licensee had a good understanding of technical issues were
the implementation of NUREG-0737 items and structural design when responding to the IE Bulletin on masonry wall The licensee's responsiveness to licensing activities was adequat However, a trend was noted of providing tardy submittals in certain areas such as reload application Facility Performance - Oconee 1, 2, and 3 June 1, 1982 - May 1, 1983 - Trend During Latest Functional Area April 30, 1983 Auoust 31, 1984 SALP Period Plant Operations 2 1 Improved Radiological Controls 2 2 Same Maintenance 1 1 Same Surveillance 3 1 Improved Fire Protection Not Rated Not Rated Not Determined Emergency Preparedness 2 1 Same Security and Safeguards 1 1 Same Refueling 1 1 Same Quality Assurance Program 2 2 Same Licensing Activities 2 2 Same IV. PERFORMANCE ANALYSIS Plant Operations Analysis During the evaluation period, inspections of plant operations were performed by the regional and resident inspection staff Facility operations reflected adequate preplanning and assignment of prioritie Facility operating procedures were generally adequate although one deficient procedure was identified in which a caution statement was placed after the operative statement, which resulted in improper operator action. Specifically, the emergency procedure for loss of steam generator flow should have provided the caution note for placing the emergency feedwater system discharge valves in manual control mode prior to the step for restart of the main feedwater pump. Use of this deficient procedure led to temporary loss of feedwater flow during Unit 3 recovery from a r& ctor tri Operational decisions were consistently made at management levels adequate to assure appropriate supervisory involvement, as reflected by operational histor An example of management involvement and conservative actions occurred during the night of March 2, 1984, when sample analysis determined that the boron concentration in a Unit I core flood tank (CFT) was below o
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Technical Specification limit A controlled shutdown was initiated and the station manager arrived on site. The manager directed that the shutdown continue and that neither power escalation nor startup (if appropriate) be initiated until after three consecutive two hour samples indicated acceptable boron concentration. Cause of baron dilution in the CFT was a leaking demineralized water system isolation valve; the problem was corrected and the unit returned to power the same day.
Significant operational events that occurred during the assessment period included nine reactor trips from power operation. None of these were caused by operator or maintenance error. Early in the assessment period, Unit 2 sustained a four day shutdown due to leakage past the pressurizer relief valves. At the end of the appraisal period, Unit 2 was continuing the longest sustained on-line operation of any Babcock and Wilcox plant in this country, having completed 266 days of continuous - on-line operation. A pinhole leak was detected in an extraction steam line of Unit 1; the affected unit was reduced to 25 percent power and the leak was repaired. The licensee took measures to repair the leak immediately so as to preclude a potential extraction steam line break which did occur on Unit 2 on June 28, 1982.
Operating staff responses to events have been satisfactory.
Following operational events, the operators effectively recovered the plan All reactor trips were due to equipment failure.
Examples of equipment failure consisted of such items as reactor coolant flow transmitter failure and feedwater control valve '
sticking.
The frequency of instances of failure to follow procedures has decreased considerably compared to the last assessment period.
One such event was cited during this assessment period.
Licensee in-station investigations were routinely performed to address, assess, and correct actions for both reportable and non-reportable event Report submittals have been timely.
Events were properly identified and analyzed, although one violation was cited for incomplete safety evaluation following loss of an overhead electrical power suppl For corrective action, the licensee provided an additional evaluatio The licensee event reports (LERs) contained adequate descriptions of the occurrences enabling knowledgeable readers to understand the event Comprehensive updates to LERs were provided where applicabl y However, the LERs lacked the reporting of similar previous failures data. Corrective action on technical matters was usually complete and accurate, showing a clear and thorough understanding-of the issue Corrective action was effective as indicated by the lack of repetitio Strong performance was indicated by the licensee's handling of the issue of inadequate sealing at cable / equipment interfaces as presented in LER 50-269/83-01 The licensee's activities demonstrated an example of successful feedback of operating data; i.e., triggered by a moisture seepage problem at the McGuire station, the licensee examined the Oconee units and found similar problem The licensee evaluated the problem at Oconee and proposed a schedule for taking corrective action Licensee responses to NRC initiatives have been satisfactory.
' Operating staff training, knowledge of the facility, and attitude appeared to be good. Of eight persons who took the Senior Reactor Operator (SRO) examination for license, seven passed. The eighth failed one part and subsequently passed it on re-examination. NRC requalification examinations were administered to sixteen SR0s and all passe The R0 license examinations were administered to fourteen persons and nine passe Seven individuals were administered the R0 requalification examinations and six passe Based on the examination results for licensed operators, the licensee appears to have instituted an effective licensed operator training progra The licensee has adequately stated and understood training policies for non-licensed personnel and licensed operator requalificatio The licensee has received Institute of Nuclear Power Operations (INP0) accreditation for their licensed operator requalification progra Oconee licensed personnel were also trained on a site specific simulator. This simulator became fully operational in September 1983. Training personnel estimated that operator simulator time could as much as . double over the time spent using previous training method General employee training (GET) was satisfactory and was supplemented by formal classroom training when availabl Training records were generally complete, well maintained, and easily retrievable for review. The licensee's licensed training staff was adequate to maintain existing training schedule Two violations were identified as follows: Severity Level V violation for failure to follow procedure resulting in an unplanned release into the Keowee River. The release did not exceed Technical Specification Limit Severity Level V violation for failure to make a complete safety evaluation following loss of an overhead power suppl _ - - -
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7 Conclusion Category: 1 Trend: Improved Board Recommendations Licensee resources appeared to be ample in this area. No decrease in licensee or NRC attention in this area is recommende B. Radiological Controls Analysis During the evaluation period, inspections were conducted by the regional and resident inspection staff The licensee's health physics staffing level was adequate and
. compared favorably to 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 The licensee had an effective general employee and specialized health physics and chemistry technician training program. During the evaluation period, a skills training and evaluation program was implemented for these technician Management support and involvement in matters related to radiation protection were adequate. Health physics-management was involved sufficiently early in outage preparations to permit adequate planning. The station health physicist received the support of other plant managers in implementing the radiation protection progra The performance of the health physics staff in support of routine plant operations was generally adequate. Job coverage by health physics technicians and housekeeping were noted to be program strengths. Also, the licensee effectively established a program to evaluate beta radiation exposure hazards and to provide multiple dosimetry for workers in non-uniform radiation field Some weaknesses were noted in the licensee's ability to adequately assess nonroutine evolutions, specifically nonroutine radioactive material shipments and potential sources of neutron radiatio _
Weaknesses were also identified in the licensee's identification of deficiencies and trends. The inspections revealed buildup of radioactivity on the turbine building roof and in Chemical Treatment Pond 3 that the licensee's onsite surveillance program had failed to identify or contro Communications between corporate and station health physics staffs needed improvement. During the evaluation period, difficulties were experienced in determining the status of the post accident sampling system implementation, the technical basis for deter-mining effluent radiation monitor setpoints, the basis for positive bioassay evaluations, and the differential pressure corrections for gaseous effluent monitor The station health physics staff should have a better understanding of the basis of procedures and instructions developed by the corporate staff and the status of issues forwarded to the corporate office for resolutio During this 16 month evaluation period, the licensee disposed of 45,812 cubic feet of solid radioactive waste. This compares to 67,576 cubic feet disposed of in the previous 11 month evaluation period. This significant reduction can be attributed in part to a reduction in outage time and the licensee's use of a more efficient waste compactor. The licensee's man-rem exposure during this evaluation period was 1725 man-rem, which was comparable to other facilities of similar size and operational activitie Results for split samples analyzed with licensee GeLi detector systems and the Region II mobile laboratory GeLi detector systems were in agreement for all nuclides in the sampled medi Inspections identified the licensee's failure to evaluate the applicability of IE Notice 82-49 " Correction for Sample Conditions for Air and Gas Monitoring," initially identified to the licensee in an NRC inspection report dated July 9,1982. The inspections identified the need for improvements in identifying, responding to, ano evaluating problems in the radiological measurements, effluent control, and the environmental dose assessment program Eight violations were identified during the evaluation period; one of which (item f) has been appealed by the licensee and is under review by the Office of General Counsel. These violations were not indicative of a programmatic breakdown in radiological control Severity Level IV violation for failure to adequately evaluate whole body and extremity dosimetry dat Severity Level IV violation for failure to properly determine l a radioactive material shipment classification.
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. Severity Level IV Violation for failure to verify presence and condition of a fuel shipment cask moderator prior to the shipmen Severity Level IV violation for failure to properly label two containers of radioactive material in two instance Severity Level V violation for failure to adhere to radiation control procedures resulting in an unplanned radioactive liquid releas Severity Level V violation for failure to post Chemical Treatment Pond 3 as a radioactive material are Severity Level V violation for two instances of failure to perform surveys for neutron radiatio Severity Level V violation for failure to post a current copy of NRC Form . Conclusion Category: 2 Trend: Same Board Recommendations Licensee management attention and involvement were evident and were concerned with nuclear safet However, the licensee's health physics management needs to become more directly involved when nonroutine problems are encountered. No decrease in licensee or NRC attention in this area is recommende C. Maintenance Analysis During the evaluation period, inspections of maintenance performance were performed by the regional and resident inspection staff Units 1, 2, and 3 were each refueled during the assessment perio Maintenance shutdown work included ultrasonic testing of core barrel and thermal shield bolts, replacement of several feedwater heaters and letdown coolers, removal, and inspection of one reactor coolant pump, and mechanical and electrical tie-in of safe shutdown facility equipment.
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The maintenance program appeared to be well organized and demon-strated evidence of adequate planning and priority assignmen Maintenance procedures were generally adequate and no examples of failure to_ provide independent verification have been identifie Maintenance related decisions were made at a management level adequate to assure appropriate supervisory involvement. Manage- '
ment reviews of activities were punctual and thoroug Maintenance records were readily available, complete, and adequately maintaine Resolution of maintenance related technical issues has shown that the licensee had a clear and thorough understanding of the issue The licensee's work was usually thorough and reliabl Licensee meetings to discuss problems were thorough and productiv Licensee responses to maintenance related NRC initiatives were usually timely and acceptabl The maintenance training and qualifications program contributed to an adequate perception of work and adherence to procedures. The licensee has a well organized and strong maintenance program; this was also reflected in the quality of work performed. The program was supported by a competent QA organizatio There were no recurring violations or other evidence of programmatic iradequac The violations identified were as follows: Severity Level IV violation for failure to follow procedure resulting in the use of weld material that was not specified for'the particular weld. The weld was now degraded by this action, Severity Level V violation for' failure to follow procedure in installation of seal staging coils in a reactor coolant pump.
2. Conclusion Category: 1 Trend: Same 3. Board Recommendations A high level of operational safety was achieved in this area. No decrease in licensee or NRC attention is recommende D. Surveillance Analysis During the evaluation period, inspections of surveillance activities were performed by the regional and resident inspection staff In general, the quality of procedures in use has improved considerably during the evaluation period with greater emphasis placed on detail and independent verificatio There was consistent evidence of prior planning and assignment of prioritie Procedures were controlled and contained sufficient detail for the control of activitie Completed procedures were consistently reviewed by management. Surveillance activities were conducted by qualified _ personnel and as witnessed by NRC on several occasions, suitable levels of management became involved when problems arose. Surveillance activities were supported by a very competent quality assurance (QA) organizatio Licensee responses to NRC initiatives were prompt and satis-f acto r Licensee resolution of surveillance related technical issues showed a thorough understanding of the issues and was conservativ During the evaluation period, the NRC staff witnessed containment integrated leak rate testing on Oconee Units 1, 2, and The NRC noted a weakness in the licensee's test control program as related to performing the integrated leak rate test (ILRT). For example, Oconee Unit 2, in November 1983, experienced in-leakage from an incorrect valve line-up of the nitrogen supply syste In May 1984, the licensee failed to adequately review and control repairs to Unit 3 valves during Type A testing. Also, it appeared that the licensee performed a local leak and repair program on valves not required in the Type C test program prior to Type A testing; this was not an acceptable practice and was brought to the licensee's attention. Consequently, the "as is" condition at the containment was not availabl The licensee committed to evaluate the penetration leakage and determine the as-found condition of the containmen This will be included in the licensee's 90-day report for Type A leak rate testing. Based on the type of problems which have occurred during leak rate testing, the NRC concluded that prior planning and control of activities was marginal.
! The NRC performed a series of independent measurements of reactor coolant system (RCS) leakage on all three units. The plant staff gave excellent cooperation in obtaining the data necessary for the evaluations. NRC and licensee calculations were in close agreement. Deficiencies in the licensee's methods, which had been identified in an earlier review period, had all been corrected.
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Inservice inspection of safety-related components, piping and hangers, letdown cooler replacement, auxiliary feedwater header modification, and reactor coolant pump motor stand repair were performe No violations were cited against surveillance activities during the assessment period. One problem concerning an inadequate procedure for many heavy objects over the spent fuel pool was identified by the license Had this issue not been licensee identified, it would have resulted in issuance of a violation by NR The lack of substantive violations and/or programmatic breakdown (s), coupled with strong administrative controls, and prompt and timely responses to NRC concerns and violations indi-cated management presence and awareness in this are No violations were identified in this functional are . Conclusion
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' Trend: Improved Board Recommendations Licensee resources were effectively utilized in this area. There was significant improvement over the performance level attained during the previous SALP assessment which had resulted in a Category 3 ratin Licensee attention to this area should be maintained to assure continued strong performanc E. Fire Protection Analysis Limited inspections were performed in this area during this assessment period. The NRC discussed with the licensee the application of 10 CFR 50.48 and 10 CFR 50, Appendix R, for the Oconee facility. Licensee proposed exemptions to Appendix R such as separation of instrumentation circuits in the reactor building and emergency lighting units were discussed with the licensee resulting in the licensee's further review of this area prior to issuance of the Oconee Appendix R submitta . Conclusion Category: Not Rated Trend: Not Determined
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13 Board Recommendations There was insufficient inspection activity in this area to justify a rating or-to determine a performance tren F. Emergency Preparedness Analysis During the assessment period, inspections were performed by the regional and resident inspection staffs. These included observa-tion of a full-scale exercise, plant drills, and one special and two routine inspections addressing emergency responses and related implementing procedure Routine inspections and exercise observations indicated that the emergency organization and staffing were adequate. The corporate emergency planning organization provided adequate support to the plant. Key positions in corporate and plant emergency planning organizations were fille Corporate management appeared to be committed to maintaining an effective emergency response program, and was directly involved in the annual exercise and the follow-up critiqu The licensee was responsive to the NRC initiatives related to protective action decision making during emergencies.
, Personnel assigned to the emergency organizations were adequately trained in required areas of emergency response. Training records of -shif t supervisors documented that required familiarization training was conducted in accordance with the emergency plans and implementing procedures. Individuals were cognizant of their responsibilities and authorities, and understood their assigned functions during routine operations and simulated emergency situation The following essential elements for emergency response were found acceptable: emergency classification; notification and communica-tions; public information; shift staffing and augmentation; emergency preparedness training; dose projection and assessment; protective action decision-making, emergency worker protection; post accident measurements and instrumentation; changes to the Emergency Preparedness Program; and annual quality assurance audits of the plant and corporate emergency planning program The exercise demonstrated that the plan and procedures could be effectively implemented in the areas of communications, accident assessment, and exposure contro An adequate working relationship existed between the licensee and county and state offsite emergency support organization _
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The licensee's request for approval of corporate headquarters as the location of the Crisis Management Center for the Oconee Nuclear Station was denied by the Commission. Further review of this matter is pendin No violations were identified regarding the licensee's implementa-tion of - the Emergency Planning program or related Technical Specification . Conclusion Category: 1 Trend: Same Board Recommendations Licensee management attention was aggressive in this are No decrease in licensee or NRC attention is recommende G. Security and Safeguards Analysis
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During this evaluation period inspections were performed by the resident and regional inspection staffs. No special inspections or safeguards events occurred during this perio The licensee's security organization staffing level, both at the corporate office and plant site, was adequate and reflected management's commitment to assuring the quality of the security program. The licensee appears to have benefited from previous efforts taken to increase the quality of the internal compliance and review staff. This has resulted in a decrease in the number of significant violations as evidenced belo The licensee displayed evidence of prior planning and the ability to define priorities with respect to responses to NRC initiative This has been demonstrated in the licensee's program of constructing new security facilities which will upgrade electronic detection capabilities and enhance the overall security progra Resolution of technical issues continues to be approached in a conservative, technically sound, and timely manne Notwithstanding the violation below, the training and qualifica-tion (T&Q) program was considered one of the major strength Particuarly noteworthy -was the effectiveness of maintaining a competent and dedicated security force through use of well managed
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performance oriented incentive program This has been reflected throughout the assessment period in security personnel performance anc' execution of assigned duties. Also noteworthy were the resources provided to establish and maintain an above average physical fitness training progra One violation was identified as follows:
Severity Level IV violation for failure to administer physical fitness tests within the time limits prescribed by the T&Q Pla ' Conclusion Category: 1 Trend: Same Board Recommendations Licensee resources were effectively used in this are No decrease in licensee or NRC attention is recommended.
H. Refueling Analysis During this evaluation period routine inspections were performed
~by the regional and resident inspection staff There were refueling outages during the evaluation period on Units 1, 2, and Personnel staffing during fuel loading was adequate with authorities and responsibilities defined in the procedures applicable to fuel loading. The NRC witnessed fuel handling activities in the containment building and control activities from the control cente In addition, the NRC reviewed procedures relating to refueling to verify that activities were being accomplished _in accordance with license requirement All refuelings went smoothly with the exception of a spent fuel pool verification problem', which the licensee identifie Five fuel assemblies were incorrectly stored in the spent fuel pool by fuel handling personnel. Licensee resolutions of this issue and other technical issues generally reflected clear and thorough understanding of the issues, and were usually conservative and viabl . . - , _ . _ _ .
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The licensee has consistently shown prior planning and assignment of priorities relating to refueling activitie Licensee performance has remained essentially constant over the course of the SALP assessment perio During this evaluation period, an inspection was performed in the area of physics testing following refueling on Units 1 and Review of the controlling procedure and witnessing of the test performance, indicated that there was consistent evidence of prior planning and assignment of prioritie The procedure was well stated, controlled, and explicit for the control of activities and strictly adhered to by the licensee. Personnel staffing during zero power physics testing was adequate, with authorities and responsibilities defined in the controlling procedure. Testing personnel demonstrated a clear understanding of technical issues and used sound and thorough approaches to resolution of issues in almost all areas. Completed records were generally accurate, well maintained, and availabl Licensee performance has remained essentially constant in this area, as compared to past
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4 In the area of refueling operations, no violations or deviations were identifie . Conclusion Category: 1
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Licensee management involvement in this area was orientated toward nuclear safet No decrease in licensee or NRC attention is recommended.
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I, Quality Assurance Program Analysis During this evaluation period routine inspections were performed by the regional and resident inspection staff The licensee's QA program was well defined and understood by site QA personnel. Site QA personnel were knowledgeable in QA procedures ~ and reviewed changes to these procedures. With the completion of the Catawba Unit I facility, additional personnel have become available for the Oconee onsite QA staff and the size of this staff has begun to increas The additional personnel
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were anticipated to supplement site surveillance, quality control (QC) inspection, and technical support to some extent. Most of the licensee personnel, designated as QC inspectors, will also be involved in inservice inspections and some construction wor An NRC team inspected the licensee's quality assurance program for structures, systems, and components considered to be important to safety as opposed to _ safety-related. The licensee was found to have a strong and well controlled program for handling items important to safet However, some weaknesses were observed in which their QA program failed to address "important to safety" equipment as specified in NRC Generic Letter 84-01. Appendix A of the Quality Standards manual was somewhat deficient in that there was no index to define color codes used on drawings, drawings were marked with more than one QA condition stamp with no explanation to differentiate the applicable conditions to a specific component, and there was a failure to include a list corresponding to each drawin Successful closure of previously identified NRC QA inspection findings indicated that the licensee was responsive to NRC
' initiative No violations were identified during this assessment perio . Conclusion Category: 2 Trend: Same Board Recommendations The conduct of activities in this area showed a proper concern for nuclear safet No decrease in licensee or NRC attention is recommende J. Licensing Activities Analysis This performance assessment is based on NRC's evaluation of the licensee's performance in support of licensing activities that had a'significant level of activity during the evaluation perio These actions included licensee requests for amendments and exemptions or relief from regulatory requirements, responses to generic letters, and various submittals of information for multi-
, plant and NUREG-0737 TMI items. A total of 101 licensing actions
- were complete Pertinent licensing actions that received NRC
, review are provided in detail in the supporting data and summaries section, paragraph . - . - . . . _ . , _ _ - _ _ _ _ - . . , .
Management's involvement and control, in assuring quality, continued to var For those areas affecting plant operations, there was a high degree of management participation. For other areas, involvement was adequate, but not outstandin For example, in trying to define the operability and surveillance requirements for hydraulic snubbers in Unit 2, management was aggressive in seeking information to resolve the problem and avoid plant shutdown. Management has also shown aggressive participa-tion in resolving the problem of disposing low-level contaminated sludge to a publicly owned treatment works. Consistently, manage-ment has demonstrated innovative and novel methods of solving many problems which arose during the course of plant operations.
However, the same aggressive and innovative attitude was not evident in areas where responses were needed from the licensee regarding amendments to the Technical Specifications and written responses to requests for additional information.
Such a case may be seen with the issue, III.D.3.4, " Control Room Habitability," which has been a long and drawn out issue.
Marginal effort has been applied to resolve those modifications needed to improve control room habitabilit Another example involved a visit to Oconee as part of the Commission's audit of all B&W plants on their status to implement modifications of NUREG-0737 item When the team visited the Oconee site, management participation was lacking. The appropriate personnel to conduct the plant tour and answer questions were not available.
This was one area where difficulties in obtaining information could have been avoided if appropriate management attention had been given. However, based on frequent visits by the regional inspectors and other NRC staff members and consultants who have received good cooperation from the licensee, the above described example of management inattention appeared to be an isolated case.
In mid-1984, the licensee reorganized their corporate structure and the area of licensing for the Oconee units. Key positions were filled in a reasonable tim The transition however, did not appear to take place in a smooth manner and seemed to affect the quality and timeliness of their responses and the number of regulatory issues which were outstanding and attributable to the licensee. A trend seemed to be developing whereby there was a decrease in systematic planning, management striving to anticipate problems, and scheduling priorities in an organized manner. For example, with better planning, the problem of the hydraulic snubbers could have been dealt with earlier and in a more organized manne .
In the engineering staff, key personnel possessed a good working knowledge and history of the plant The efforts of the
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- engineering staff were usually effective in resolving technical problem Technical knowledge of the plant seemed to be high, however, this knowledge was not consistently conveyed in requests for license amendment The licensee has continually exhibited an excellent understanding of technical issues and usually endorsed a resolution which was acceptable to the Commission staff. When resolving technical issues, the licensee generally expressed conservatism from the safety standpoint and usually presented a sound approach to resolving issue When proposing an approach to resolve any safety concern or to meet any regulatory requirements, the licensee usually proposed a solution that met the minimum accept-able standpoint The licensee seemed to follow closely the regulatory environment and took an active role in plant safety. The licensee has consistently taken the lead for the nuclear industry to help resolve matters of generic concer For. example, they have participated in B&W Owners Groups and have proposed to participate in programs or studies that have or will be used at other utilities. Some examples included their participation in studies to develop the methodology to analyze for Pressurized Thermal Shock and conducting a Probabilistic Risk Assessment. They also developed generic Abnormal Transients Operating Guidelines (AT0G)
which the B&W Owners Group has endorged for the industry and utilities' use to pattern their plant-specific guidelines afte The licensee was, however, the last B&W utility to adopt ATOGs on a plant-specific basis. In situations dealing with plant-specific issues, the engineering staff was usually well versed in the pertinent concerns and usually proposed acceptable resolutions to technical concerns. When the Commission staff rejected the
" arching-action" theory in qualifying masonry walls to meet NRC acceptance criteria, the licensee proposed a comprehensive and acceptable program to test the theor The NRC has met with the licensee several times during this review period. The licensee was well prepared, responsive and made a concerted effort to resolve the issues. When the Commission staff met with the licensee to discuss the exemption request for the crisis management center (CMC), the presentation was well prepared, detailed and covered all the major issues involved with this topic. When major differing positions occurred between the
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staffs, the licensee was professional and endeavored to resolve ( all question !
The licensee attempted to meet deadlines and notified the NRC when they could not be me However, a trend developed whereby an increasing number of items were outstanding for significant periods of tim Specifically, applications to review reloads have been consistently submitted, on a schedule requiring review and completion of the licensing action in less than the 90 days requested by the NRC staff; thereby, requiring expedited review and overdrawing on the Commission's staff and resources. A noted pattern was that the licensee was most responsive to those issues that the licensee considered having higher priority (those issues affecting plant operation). Issues to which the licensee assigned lesser priorities, periodically required submittal schedule extension No major deficiencies affecting licensing activities were apparent during the evaluation perio The licensee's approach to the resolution of technical issues was generally sound and conservative; and the licensee was usually responsive to NRC initiative . Conclusion Category: 2 Trend: Same Board Comments Management involvement was evident, particularly in plant operations. However, licensee management attention needs to be focused in anticipating potential problems and scheduling the submittal of major reviews, and in reviewing submittals for their thoroughness, completeness and timeliness. The licensee should try to submit license amendments, such as reload reviews, on a more timely basis to allow adequate time for NRC review. No decrease in licensee attention is recommende V. SUPPORTING DATA AND SUMMARIES Licensee Activities During the assessment period, major licensee activities at Oconee included installation of a new station manager, replacing the previous manager who had served in the position for 17 years; continued construction of a radwaste facility including an incinerator and waste compactor; initiation of a new department for integrated scheduling; and reracking of spent fuel for increased storage capacit The Institute of Nuclear Power Operations (INP0) conducted an overall plant evaluation during a two week period in January 1984.
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B. Inspection Actitivites During the assessment period, routine inspections were performed at the Oconee facilit Areas inspected included refueling activities, startup testing, radiation protection, inservice inspection, high pressure injection thermal sleeve examination, security, fire protection, training and quality assurance. Three special inspections covered AK-2 reactor trip breakers, heating and ventilation systems in the safe ' shutdown facility, and emergency preparedness protective decision makin Two routine team inspections covered operator requalification and an emergency preparedness drill. A special team inspection of systems and components important to safety was also conducted.
C. Licensing Activities A total of 206 licensing actions were received during this assessment period in which 101 were completed by the NRC. These actions consisted of plant specific items, multi plant items, and NUREG-0737 item Specifically, they were as follows:
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85 Plant specific actions (41 completed): Topics common to the three units that were used to provide input to this evaluation and included in this category are:
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Inservice Inspection Relief Request of August 15, 1983;
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Reactor Coolant System Leak Technical Specification (TS)
Change;
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Exemption to Crisis Management Center;
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Startup Transformers and Allowable Degraded Conditions;
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Snubber Operability for Unit 2;
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Unit 3 Axial Power Shaping Rod Position Limits;
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Disposal of Low-Level Contaminated Sludge; and
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TS Change for Degraded Mode of Operation for the Emergency Condenser Cooling Water System (ECCW).
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46 Multi plant actions (22 completed): Topics common to the three units that were used to provide input for this evaluation and included in this category are:
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Masonry Wall Design (IEB 80-11);
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Appendix I - Radiological Environmental Technical Specifi-cations;-
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Response to NRC Generic Letter 82-16: NUREG-0737 TS;
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Reactor Vessel Overpressure Protection;
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Review of Asymmetric Loss of Coolant Accident Loads;
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Pressurized Thermal Shock (Unresolved Safety Issue).
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75 Three Mile Island (NUREG-0737) actions (38 completed): Topics common to the three units that were used to provide input for this evaluation and included in this category are:
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II.E.3, " Post-Accident Sampling";
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II.B.1, "RCS High Point Vents";
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I.C.1.3A, " Abnormal Transients Operating Guidelines";
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III.D.3.4, " Control Room Habitability";
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Participation in the Comparison of Implementation of Selected TMI Action Plan Requirements on B&W Operating Plant D. Investigations and Allegations Review One case was opened to monitor licensee actions regarding several allegations reported to the licensee by a former employe The licensee discussed the results of their investigation with the NRC Region II staff during a meeting on October 5,1984; licensee actions were reviewed by the resident inspectors. The allegations were related to plant activities which occurred up to seven years ag E. Escalated Enforcement Actions Civil Penalties No civil penalties were issued during this assessment period, Orders (only those relating to enforcement)
No orders were issued during this assessment perio F. Management Conferences Held During Appraisal Period Conferences No management conferences were held during this assessment perio Confirmation of Action Letters No confirmation of action- letters were issued during this assessment perio G. Review of Licensee Event Reports and 10 CFR 21 Reports Submitted By the Licensee i
During the assessment period, there'were 13 LERs reported for Unit 1, 3 for Unit 2, and 10 for Unit No 10 CFR Part 21 reports were submitted by the licensee. The distribution of these events by cause, as determined by the NRC staff, was as follows:
- LERs Cause Unit 1 Unit 2 Unit 3 Component Failur Design 4 1 2 Construction, Fabrications,-or 0 0 0 Installation Personnel
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Operating Activity 1 0 0
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Maintenance Activity 1 0 7
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Test / Calibration Activity 0 0 1
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Other' Activity 1 0 0 Out of Calibration 0 0 0 Other 1 0 0 TOTA _
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TABLE 1 INSPECTION ACTIVITY AND ENFORCEMENT FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V IV III II I Operations 2 Radiological 4 4 Maintenance 1 1 Surveillance Fire Protection Emergency Preparedness Security and Safeguards 1 Refueling Quality Assurance TOTAL 7 6 L