IR 05000269/1989001
| ML15239A026 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/29/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15239A024 | List: |
| References | |
| 50-269-89-01-01, 50-269-89-1-1, 50-270-89-01, 50-270-89-1, 50-287-89-01, 50-287-89-1, NUDOCS 8907120139 | |
| Download: ML15239A026 (47) | |
Text
ENCLOSURE 5 ENCLOSURE FINAL SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-269, 270, 287/89-01 DUKE POWER COMPANY OCONEE UNITS 1, 2, AND 3 AUGUST 1, 1987 -
JANUARY 31, 1989 89071 20139 890629 PER AICK 05000269 EPDC
SUMMARY OF RESULTS Overview Oconee was operated in an overall safe manner during this assessment period. Strengths were observed in the areas of Plant Operations, Radiological Controls and Emergency Preparedness.
A decline in performance was identified in the areas of Security and Maintenance and Surveillance.
Additional managerial attention is needed to return these areas to their previous performance status.
Operations performance continued to be a strength.
The number of automatic trips were reduced well below the industry average and below the goals established by the licensee.
Corporate interest and oversight of plant activities was very apparent. Fire protection was adequate. Good progress has been made in plant cleanliness which resulted in a reduction of contaminated areas.
Management was frequently observed in various areas of the plant providing oversight of activities and guidance to personnel in those areas. The operator training and experience were excellent.
The Radiological Controls area is considered a strength.
The reduction of contaminated areas noted above and the continuing effort to further reduce these areas was noteworthy.
The reduction of person-rem by use of mockup training and use of remote devices and other training activities is also noteworthy.
A weakness was identified in the extended period of inoperability of several Radiation Indicating Alarms.
The licensee has strong maintenance and surveillance programs.
However, over this assessment period, numerous performance problems in maintenance were identified.
These performance problems were characterized by inattention to detail, miscommunication, and procedure/personnel errors resulting in violations of NRC requirements.
Over the period Oconee station has had good availability and few operational problems directly attributable to maintenance.
Surveillance activities have also experienced a decrease in effectiveness. Surveillances were completed on time with only minor problems identified. However, notable problems were identified in the in-service testing of valves.
The chemistry program in conjunction with the chemical cleaning of Unit 1 and 2 steam generators and the continued attention being provided to meet the guidelines recommended by the Steam Generators Owners Group has minimized degradation of the steam generator tubes.
Emergency Preparednessactivities have been maintained as a strength.
The licensees many drills conducted in this area have been beneficial as demonstrated by the utilities actions during several actual conditions that occurred during this assessment period.
However, a weakness was noted that involved an incorrect classification of an emergency declaration during the conduct of the annual drill.
The Security area, which historically has been a strong area, experienced a significant number of minor problems during this assessment period.
Although no single problem was overly signi ficant, the number of problems identified showed a distinct decrease in the effectiveness of the security effort. Of special note is the continuing problem with the closed circuit television assessment capability attributed to poor design and installation.
Management reacted positively to weaknesses identified in the Engineering/Technical Support area during the previous assessment period.
This effort was noted in the assignment of design engineering personal to the site and the restructuring of corporate engineering groups to a site specific function rather than a discipline function as was used in the past.
Management activities have resulted in the self-identification of several significant problems notable among these was the HPI system mode requirements previously not addressed correctly by the operations staff. Although progress has been made in this area weaknesses still exist such as those associated with communications and simulator hardware and software. Additional management attention may be needed to achieve the desired results in this area.
With respect to the Safety Assessment/Quality Verification area several aspects of plant performance were assessed.
The licensee continues to perform self initiated technical audits and use other sources to improve safety performance.
QA, QC and management continue to provide good oversite of all activities. The quality of Licensee Event Reports have improved.
Weaknesses were noted in the area of complete follow through of activities. This was exemplified by the lack of thoroughness associated with the HPI "piggyback" mode of operation issue and several issues concerning
CFR 50.59 evaluations.
Rating Last Rating This ctional Area Period Period Plant Operations 1/2
(operations & fire protection)
Ra iological Controls
1 Mai enance/Surveillance 1/1
Emerg ncy Preparedness
1 Securi
2 Engineer'ng/Technical Support
2 (engine ing, training & outages)
Safety Asse sment/
2/2
Quality Ve ification (quality pro rams & licensing)
III. CRITERIA Licensee performance is s<essed in selected functional areas, depending on whether the facility in a construction or operational phase.
Functional areas normally r yesent areas significant to nuclear safety and the environment. Some fu cjional areas may not be assessed because of little or no licensee activit
..or lack of meaningful observations.
Special areas may be added to hi light significant observations.
The following evaluation criteria re used, as applicable, to assess each functional area:
1. Assurance of quality, including ma agement involvement and control; 2. Approach to the resolution of tec ical issues from a safety standpoint; 3. Responsiveness to NRC initiatives; 4. Enforcement history; 5. Operational and construction events (including esponse to, analyses of, reporting of, and corrective actions for);
6. Staffing (including management); and 7. Effectiveness of training and qualification progrim However, the NRC is not limited to this criteria and otners ma have been used where appropriate.
Rating Last Rating This Functional Area Period Period Plant Operations 1/2
(operations & fire protection)
Radiological Controls
1 Maintenance/Surveillance 1/1
1 Security
2 Engineering/Technical Support 2/2/2
(engineering, training & outages)
Safety Assessment/
1/2
Quality Verification (quality programs & licensing)
III. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase.
Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functiona.l area:
1. Assurance of quality, including management involvement and control; 2. Approach to the resolution of technical issues from a safety standpoint; 3. Responsiveness to NRC initiatives; 4.
Enforcement history; 5. Operational and construction.events (including response to, analyses of, reporting of, and corrective actions for);
6. Staffing (including management); and 7. Effectiveness of training and qualification program However, the NRC is not limited to this criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
1.
Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
2. Category 2. Licensee management attention and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels.
3. 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 attention should be increased above normal levels.
The SALP Board may also include an appraisal of the performance trend of a functional area. This performance trend will only be used when both a definite trend of performance within the evaluation period is discernable and the Board believes that continuation of the trend may result in a change of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment period.
Declining:
Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern.
IV. PERFORMANCE ANALYSIS A. Plant Operations 1. Analysis During this assessment period routine inspections and evaluations of plant operations were performed by the resident and regional inspection staffs. A total of five automatic trips occurred during this rating period, two on unit 1, one on unit 2 and two on unit 3. One manual trip was also experienced. Seven automatic trips occurred during the last rating period.
The quality of operations has been maintained at a high level of performance. The number of automatic reactor trips has been reduced below the industry average of 2.1 automatic trips a year and the goal established by the licensee of no more than two trips per unit per year.
Upper level management continues to be extensively involved in all aspects of plant operation.
The licensee has taken action to provide senior reactor operator training to most of the superintendents and many senior supervisory personnel.
In addition some of the superintendents have rotated positions in order to provide a greater understanding of how each discipline functions to support the overall effort of safe and efficient operation.
Management has been observed frequently in the control room and touring the plant areas. Outage management has shown major improvement.
Outage time has been reduced to approximately 45 days without any significant reduction in the quantity and quality of work being accomplished.
The Shift Engineers, who are licensed senior operators, are very involved in coordination of outage work during backshift and weekends.
The low turnover rate (less than 3%) maintained by the licensee has been instrumental in maintaining a continued high experience level and a high level of competence in the operations staff.
Due in part to this low turnover rate, the amount of overtime required of the operators has not been excessive. In addition to the experience in the operations group, senior personnel with operating experience have been placed in various other groups.
Control room demeanor and attentiveness has been good.
There have been several instances where operator attention and quick action have prevented a reactor trip due to malfunctioning components.
To promote professionalism,. the operators, in conjunction with the operators at Catawba and McGuire, have developed a set of operator principles. These are posted in the control rooms and other operations areas and identify their commitment to excellence. Operations staffing level continues to exceed TS requirements for shift crew composition. A high level of attention to details beyond their normal duties on the part of several non-licensed equipment operators (NEO) identified and assisted in resolving several problems. Examples of this were the identification of a problem with the Emergency Power Switching Logic (EPSL) and also identification of a containment isolation valve being mispositioned.
Only two instances have been identified where operators have failed to follow their procedures. These primarily occurred during the early part of this assessment period and were attributed to the incorrect use of identifying steps as "not applicable" by the supervisor or an isolated personnel error. Improvement in this area has occurred during this period due to managements attention to this problem and the continued emphasis by management to follow their procedures.
Communications between operations and other groups is acceptable, but there have been several instances where inadequate communications have caused a problem.
Examples of this communication problem between operations and the performance group involved a loss of all power on Unit 3 for approximately 15 minutes while in decay heat removal during the last refueling outage. Another communication problem between operations and the instrumentation and electrical group resulted in a runback on Unit 3 as a result of a pulled fuse while troubleshooting the rod drive system.
Communications between operations and the General Office Engineering staff resulted in a significant safety concern as discussed in more detail in section G. Improvements have been noted in this area in recent months, but continued management attention should be provided in this area.
An Augmented Inspection Team (AIT)
reviewed two incidents that occurred on January 2 and 3, 1989 on Oconee Unit 1. The AIT was established to review the events associated with a reactor trip from 100% power that occurred on January 2 and an explosion and fire in the 6900 volt switchgear that resulted in a manual reactor trip from a low power level and subsequent operation in a natural circulation condition on January 3. The conclusion reached by the AIT was that during the first incident, the operators took appropriate actions to maintain the plant in a safe condition. The AIT determined that during the second event the firefighting techniques and results were adequate, and that the reactor trip that had occurred the previous day did not contribute to the fire and trip on the following day.
In addition the team concluded that management was highly involved in both the actions taken during the evolutions and the repairs following the stabilization of the unit.
The team identified weaknesses in the training of operators and supervisors in areas associated with use of pressurizer auxiliary spray, the requirements for operation in the Thermal Shock Operating Region, and natural circulation with low decay heat conditions.
As a result of these findings, the licensee has taken action to conduct additional training and provide additional guidance in these areas.
An Emergency Operating Procedure (EOP) inspection found that the Oconee Emergency Procedures (EP)
and Abnormal Procedurer (AP)
adequately cover the broad range of emergencies and cther significant events required by Regulatory Guide 1.33, Section 6.
The team found technical discrepancies in the licensee's, procedures for cooldown using the HPI system, boron dilution, loss of condenser circulating water intake canal/dam failure and reactor coolant pulap operation.
Also inconsistencies in operator interpretation of important terms indicated a need for further operator training in EOP terminology use.
The licensee is correcting these inconsistencies.
The plants housekeeping and material condition continued to be acceptable and continued to improve. Although progress has been made in housekeeping, specific areas are frequently identified where debris has accumulated especially following outages.
Management is making an effort to correct this problem.
With respect to fire protection, the licensee's fire protection prccedural program and implementation of fire prevention administrative controls were found to meet NRC requirements and guidelines.
Fire systems required for protection of safety related plant areas were being maintained operable.
The staffing of the Safety/Fire Protection Department onsite and in the corporate Design Engineering group was adequate. The onsite group was staffed with two fire protection specialists who have primary responsibility for the implementation of the Fire Protection Program.
The entire Safety/Fire Protection staff actively monitored plant activities to assess proper implementation of the program.
In addition, a Fire Protection Engineer was also assigned to the site from the corporate Design Engineering office.
The overall quality of the staff was a program strength.
Two violations were identified in this area:
a. A Severity Level IV violation for failure to follow procedures which resulted in a loss of low temperature overpressure protection for a total of 8 minutes.
(88-28, Unit 3 only)
b. A Severity Level IV violation for an inadequate procedure for testing the Emergency Power Switching Logic causing a complete loss of all AC power to Unit 3. (88-28, Unit 3 only )
2. Performance Rating Category:
Previous Rating: Operations:
Fire Protection: 2 3. Recommendations None B. Radiological Controls 1. Analysis Inspections were conducted in the areas of radiation protection, radiological effluents, and confirmatory measurements during this assessment period.
The licensee's health physics (HP)
radwaste and chemistry staffing levels compared favorably to other facilities of similar size.
Eighty-seven percent of licensee health physics technicians were ANSI/ANS 3.1 qualified, with the remainder to be qualified during the current SALP period.
Contract HP technicians have usually been hired to support refueling outages. However, a refueling outage originally scheduled for January 28, 1989, started three weeks earlier without contract technicians.
The licensee provided radiation protection efficiently in the interim period by reassigning office personnel to the field. The experience of contract technicians was a program strength since a high percentage of contract HP technicians had previous outage experience at Oconee.
The licensee HP staff also had a low turnover rate.
A finding that retraining for contract HP technicians had not been formalized was corrected by changing the HP manual to require retraining for those who had not worked on site in the last twelve months.
The site specific HP training course contained elements required for course accreditation.
Management support for the radiation protection program was demonstrated by the installation and operation of Constant Air Monitors, a state-of-the-art whole body counter, an automated laundry monitor for screening of protective clothing, and a new radioactive waste sorting and compacting facility.
The licensee continued to have an aggressive contamination control program.
Dedicated decontamination crews maintained approximately ninety-three percent of the radiologically controlled area (RCA) as non-contaminated.
The licensee's approach to resolving HP technical issues was adequate. Problems associated with the plant breathing air systems were identified during an inspection and corrective action included calibration of system pressure gauges, operator intervention upon carbon monoxide monitor failure, as-built drawings for the location of air manifolds and pressure gauges, and provision for direct communication between the control room and HP personnel concerning the breathing air system.
Weaknesses were identified in the licensee program to control personnel exposure to radiation. Violations were identified for workers entering containment without reporting to the HP technician as instructed and for workers entering and exiting high radiation areas without knowledge of area dose rates and.
without adequate monitoring of self-reading pocket dosimeters.
In addition, high radiation area hot spots, greater than 100 millirem per hour at 18 inches, were not labeled after shielding had been installed.
Licensee management understood
the issue and committed to take the appropriate and necessary corrective actions.
The licensee established a goal of 1,000 person-rem for 1988 for all three units. During 1988, the licensee's collective dose was 879 person-rem or 293 person-rem per unit as measured by TLD. The low station collective exposure was attributed to efficient ALARA planning during outages and use of robotics in maintenance of steam generators. The dose received in 1988 is the lowest dose since 1975 for the licensee which' is usually at or below the national average for PWRs.
Liquid and gaseous effluents for calendar year 1987, and the first half of 1988, were within regulatory limits.
Offsite doses did not exceed 10 CFR 50, Appendix I ALARA criteria.
Liquid and gaseous effluents for 1985 through the first half of 1988 are summarized in this report (see Section V.I).
The licensee reported a total of three abnormal liquid releases and no gaseous releases during July 1987 to June 1988.
Licensee management attention to and involvement in the calibration and operation of process and effluent monitors was not sufficient in that the Low Pressure Service Water radiation monitors (RIA-35)
have been inoperable since 1985.
Corrective actions to upgrade the entire RIA monitoring system are under development but will not be implemented for approximately three years.
A confirmatory measurements inspection showed agreement between licensee and NRC measurements with the exception of two radionuclides in three counting geometries.
The licensee was responsive to NRC initiatives as demonstrated by an agreement to analyze additional spiked samples.
The results of these analyses are currently pending.
A violation was identified during this inspection for failure to provide an approved procedure for the sampling of the Unit 1 condenser offgas.
Two violations were identified.
a. Severity Level IV violation for failure to identify radiation hot spot locations after shielding has been installed and to instruct personnel in the precautions or procedures to minimize exposure to radiation (89-02).
b. Severity Level IV violation for failure to provide an approved procedure for the sampling of the Unit 1 condenser offgas (88-31).
2. Performance Rating Category: 1 Previous Rating: 2 3. Recommendations None C. Maintenance/Surveillance 1. Analysis Evaluation of this functional area was based on the results of routine inspections performed by the resident inspectors, routine inspections by regional inspectors, and special inspections in the area of Environmental Qualification (EQ)
of Electrical Equipment, a Quality Verification Functional Inspection (QVFI), and a Maintenance Team Inspection (MTI).
Overall the licensee has adopted strong maintenance and surveillance programs.
However, over this assessment period, numerous performance problems were identified. These performance problems were characterized by inattention to detail, miscommunication, and procedure/personnel errors resulting in violations of NRC requirements.
Over the period Oconee station has had good availability and few operational problems directly attributable to maintenance.
The licensee's management was very supportive of a strong maintenance program. This was exemplified by the presence of the station manager and superintendent during daily outage meetings and other meetings that become necessary during periods of routine operations when meetings are not normally conducted.
Management also was observed frequently in the various plant areas watching activities and reviewing the conditions in the areas.
Management has established goals to increase their preventive maintenance/corrective maintenance ratio to 70% and reduce their outstanding work requests that are over three months old to less than 450. During the latter portior of this assessment period the plant had nearly achieved their goal, in that the preventive/corrective ratio was about.65% and the work requests greater than three months old numbered about 200 for the site.
The QVFI which included the areas of maintenance and surveil lance testing identified a number of minor violations, and found work practices and procedural controls to be acceptable. Also the inspection concluded that based on the low component failure rate and few repetitive failures the licensee's corrective and preventive maintenance programs appeared to be effective.
However, ore instance was identified by the resident inspectors where safety-related components had been omitted from the preventive maintenance program. This was a failure to provide proper maintenance for the Reactor Building Cooling Unit (RBCU)
drop out plates. When the drop out plates were tested in their as-found condition, the plates would not function as designed.
At the end of this SALP period, this issue was still under NRC review for escalated enforcement.
Enforcement in this functional area has increased since the previous assessment period.
Thirteen violations in the maintenance and surveillance area were identified this period compared with one violation in the maintenance area and one violation in the surveillance areas during the previous SALP period. Most of the violations during this period have had only minor safety significance.
One of the violations was a failure to follow procedures associated with a freeze seal which thawed allowing a spill of approximately 30,000 gallons of slightly radioactively contaminated water, a small amount of which resulted in an uncontrolled release to the chemical treatment pond and subsequently off-site (Violation a).
A second violation involved a failure to perform an adequate verification to ass.ure work was being performed on the correct component prior to performing maintenance. This resulted in the removal of packing from an instrument valve on an operating unit rather than the shutdown unit. This error resulted in a leak of approximately
gpm in the auxiliary building.
Although operations personnel did a good job in isolating the leak and maintaining the unit in a safe condition, several persons were contaminated and a spill of approximately 1,000 gallons of contaminated water occurred (Violation b).
Inattention to detail was a major contributing factor in the violations identified during the EQ inspection.
This resulted in the failure to fully document essential information in the licensee's EQ files and subsequently in a failure to include-the information concerning these specific EQ requirements in the development of some su'veillance and maintenance procedures (Violation c, k and 1).
A Maintenance Team Inspection (MTI) was conducted in July 1988.
A weakness was identified in communication/coordination between the plant maintenance department and the Duke Transmission Division.
This was exemplified in a violation involving verification and calibrations in the Instrumentation and Electrical (I&E) maintenance area (Violation h).
During the MTI other weaknesses were identified that related to 10CFR50.59 reviews. One example involved the licensee's failure to perform an adequate 50.59 review for the inoperability of the ground detector prior to startup of Unit 2.
This issue is discussed further in the Safety Assessment/Quality Verification section of this SALP report.
The quality of maintenance and surveillance planning at Oconee has been good. This area has been enhanced due to the efforts of the integrated scheduling group and the use of dedicated engineers permanently assigned to this group.
Through the efforts of management and this group, the outage periods have been reduced without a reduction in the quantity or quality of work being accomplished. One major activity that was undertaken was an effort to assure all work is completed on a component or system when it is taken out of service (through closer coordination of the various onsite groups) to preclude redundant testing.
Materials control, which includes procurement, receiving activity, and material storage, was good during this assessment period. Violation (m) related to access control of material storage areas and does not impact the quality of material handling and storage.
Because it is a three-unit station and must plan for a minimum of two major refueling outages per year, the station has established a fairly large, stable work force in the area. of maintenance. The Oconee site is also the home base for the Southern division of Duke Power Company's Construction and Maintenance Division (CMD), which is an additional resource for trained and qualified maintenance personnel.
The chemistry program is being implemented in a satisfactory manner to meet Technical Specification limits and the gu-delines recommended by the Steam Generators Owners Group. The licensee is continuing, through the effectiveness
of plant components and chemistry control, to minimize degradation of the steam generator tubes.
Surveillance and preventive maintenance programs have been expanded for the Once-Through-Steam-Generators and the Decay Heat Removal Heat Exchangers in order to identify potential problem areas.
The licensee has made improvements in analytical methods with the installation of online ion chromatography analyses systems.
Surveillances continue to be performed with only occasional problems. Surveillances have been performed as required by Technical Specifications. There have been very few instances of missed surveillances during this period.
The QVFI identified that licensee technicians performing a valve stroke timing surveillance test did not recognize that the stroke-time performance did not meet its acceptance criteria. A review of previous testing also identified that the preceding test had not met the acceptance criteria (Violation d).
Another inadequacy with the licensee's surveillance program was stroke time testing was not being performed as specified by ASME Section XI requirements.
Section XI of the ASME Boiler and Pressure Vessel Code requires timing to begin at the signal initiation and conclude at the actual closure as opposed to the
"light to light" criteria-being utilized by the licensee (Violation e). The method in use by the licensee was based on the timing method that had been approved by the NRC for the IST program established at the Catawba Nuclear Station.
Examples of licensee response to surveillance failures in MOVATS testing were identified to be poor in that there was an apparent attitude by some personnel that acceptance criteria for Inservice Test-Program (IST) program valves was guidance and not a requirement.
Additional examples were identified where corrective.actions for failed surveillances were delayed, minimal, or not performed. Other items observed were a failure to verify that all specified acceptance criteria in MOVATS testing was performed (i.e. to verify ease of movement of an actuated valve) and several valves which meet the requirements for IST program valves were not entered into the IST program (violation f).
The thirteen violations listed below represent a significant increase over the previous SALP period. There was one violation in the maintenance area and one violation in the surveillance area during the previous SALP period.
Most of the violations during this period have had only minor safety significance.
a.
Severity Level IV violation for failure to follow procedure on freeze seal of a line to the BWST resulting in a 30,000
gallon spill of slightly contaminated boratec water (87-51).
b. Severity Level IV violation for inadequate procedures to assure the correct component was identified prior to performing work which resulted in a spill of contaminated water due to the work being performed on the incorrect valve and also with a main steam valve that was incorrectly removed from a supply line to the auxiliary feedwater pump turbine (88-08).
c. Severity Level IV violation for inadequately documenting the performance characteristics for the Victoreen High Range Radiation Monitor System (88-03)(EQ).
d. Severity Level IV violation for failure to keep accurate records for PT/2/A/0150/22A, operational valve functional test on May 11, 1988, and nuclear equipment operator fire watch logs on May 19, 1988 (88-13).
e. Severity Level IV violation for failure to routinely measure valve stroke times from actuation signal initiation to the end of the actuation cycle (88-13).
f. Severity Level IV violation for failing to include valves LPSW-773 and HP-98 in the valve inservice testing program (88-13).
g. Severity Level IV violation for failure to follow procedures relative to correctly filling out work requests and for inadequate cleanliness levels in the reactor protection and engineered safeguards cabinets (88-13).
h. Severity Level IV violation for procedural problems related to verification and calibration of control room instrumentation and battery undervoltage alarm relays, circuit breaker maintenance, 4160 volt switchgear, and ground detection circuit alarm set points (88-17).
i. Severity Level IV violation for failure to follow.
procedures resulting in overpressurization of a safety related pipe section. (88-32, Unit 3 only)
j.
Severity Level V violation for failure to follow, in its entirety, the procedure f component verification while performing RPS Channel "B" calibration and functional tests (87-44).
k.
Severity Level V violation for the reactor building level transmitter junction box not being maintained completely
filled with oil and, therefore, not in the as tested configuration (88-03)(EQ).
1. Severity Level V for deficient EQ maintenance procedures in that requirements in the Equipment Qualification Reference Index were not properly addressed in the maintenance procedures (88-03)(EQ).
m.
Severity Level V violation for failure to maintain access control to storage areas. (87-32, Unit 3 only)
2.
Performance Rating Category: 2 Previous Rating:
Surveillance 1 Maintenance 1 3. Recommendations Increased management attention is warranted in this area due to the reduced attention to detail and increase in personnel and procedural errors.
D. Emergency Preparedness 1. Analysis The regional inspection conducted during this assessment period by both resident and regional inspectors included a routine emergency preparedness inspection and two annual emergency response exercises.
Four Emergency Plan revisions were also submitted by the licensee for NRC review.
Overall, during this SALP period, the licensee, with one exception noted below, continued to demonstrate the capability to fully implement the critical aspects of emergency preparedness during simulated or actual emergency events.
The licensee's response to simulated emergencies during the annual emergency preparedness exercises demonstrated their capability to effectively implement the Emergency Plan.
A partial participation exercise was performed on November 11, 1987.
A full scale exercise was performed April 14, 1988.
An exercise weakness involving an incorrect emergency classification was identified during the latter exercise.
Specifically, a Site Area Emergency should have been promptly declared based on the simulated loss of reactor shutdown capability concurrent with a LOCA greater than 50 gpm.
In response to this finding, the licensee promptly revised the Emergency Plan and respective implementing procedure to more clearly define Site Area Emergency, Emergency Action Levels (EAL)
regarding loss of shutdown function.
Additionally, the
respective revised Emergency Plan implementing procedure was rendered more user friendly.
Corrective action also included training of all operations personnel regarding EALs and emergency classification.
The license also effectively demonstrated their capability to correctly use EALs and promptly identify and classify an actual Alert resulting from the loss of functions needed to maintain Unit 3 in cold shutdown.
Additionally, four Notification of Unusual Event (NOUE)
were promptly classified including a fire and a steam generator tube leak.
The annual exercises demonstrated the licensee's proficiency in promptly implementing protective action recommendations consistent with the licensee's Emergency Plan and respective emergency procedures, and EPA Protective Action Guidelines. The exercises also disclosed the licensee's prompt and effective implementation of dose assessment and projections attending simulated offsite releases of radioactive materials.
Comprehensive critiques were conducted following each exercise.
Licensee-identified findings were recorded and corrective actions required were implemented.
The routine emergency preparedness inspection found that the licensee maintained the capability for prompt notification and effective communications with offsite support agencies and emergency response facilities.
Instrumentation and supplies were appropriate and emergency preparedness training was complete and effective.
The site emergency organization continued to demonstrate a
strong commitment to training by development of drill scenarios and consistent use of Oconee plant specific Probabilistic Risk Assessment (PRA)
data to render such drills realistic and challenging. The experience developed as a result of frequent unannounced drills and practice exercises has significantly enhanced the capability of emergency response personnel during evaluated exercises and actual emergencies.
No emergency preparedness violations were identified during this assessment period.
2.
Performance Rating Category:
Previous Rating:
3. Board Comments Failure to promptly and correctly classify a simulated event during an emergency exercise is normally considered by the NRC to show a significant weakness in a licensee's emergency preparedness program.
Such a weakness would not be expected in a SALP Category 1 program.
It was noted however, that the licensee implemented a prompt and very effective response to the exercise weakness.
Subsequently, the licensee effectively demonstrated this capability during this assessment period, during an actual Alert and four NOUEs. The Board therefore concluded that the performance in this area was SALP 1.
E. Security and Safeguards 1. Analysis The Physical Security functional area evaluates and assesses the adequacy of the security force to provide protection for the stations vital systems and equipment. To determine the adequacy of the protection provided, specific attention was given to the identification and resolution of technical issues, responsiveness to NRC initiatives, enforcement history, staffing, effectiveness of training,- and qualification.
The scope of this assessment includes all licensee activities associated with access control, physical barriers, detection and assessment, armed response, alarm stations, power supply, communications, and compensatory measures for degraded security systems and equipment. This evaluation is based on routine and special inspections conducted by the NRC in this area and related functional areas.
Authority and responsibilities associated with the security organization were clearly delineated and appeared to be effective. The site contract force is adequately staffed and appropriately trained and equipped. The facility guard Training and Qualification Plan is implemented on a continuing basis at all levels of the security organization using the onsite training staff.
The licensee has provided the security force with adequate procedures. Security plan changes are submitted on a timely basis and licensee records are complete, adequately maintained and available. Licensee events reports are prompt and complete.
The licensee's independent security program audit covered various aspects of the site security program and the program auditors were thorough and well acquainted with licensee commitments.
The regional staff identified a problem with the closed circuit television (CCTV) assessment capability at the beginning of this rating period. This poor CCTV assessment was partially due to low priority maintenance but more significantly due to poor design and installation.
This problem was not resolved at the end of the rating period, demonstrating a slow response to regulatory concerns and a lack of urgency in addressing this
issue.
The licensee has been relying on long term compensatory measures to provide this assessment capability.
One Material Control and Accountability inspection was conducted during the SALP period.
This inspection was performed to determine whether the licensee had limited his possession and use of special nuclear material (SNM)
to authorized locations and uses, and had implemented :n adequate and effective program to account for and control all SNM in possession under license.
The inspection determined that the licensee had developed and was maintaining an adequate safeguards program for the control and use of both fuel and non-fuel SNM.
External reporting was found to be accurate and timely.
While the licensee has experienced an increase in the number of security related violations, they are not indicative of a major security program breakdown. Six of the violations cited during this reporting period were licensee identified.
Analysis indicates that the majority of the violations are attributable to errors by individual members of the security force relative to adherence to procedural requirements and documentation rather than hardware and equipment associated problems.
The one violation identified by regional inspection concerned a degraded vital barrier that had not been previously identified by the licensee.
These violations indicate a need for additional attention to detail, and increased regulatory sensitivity on the part of the security force.
The violations identified were as follows:
a. Severity Level IV for allowing an employee into the protected area without a picture badge. (87-45)
b. Severity Level IV for allowing a visitor into the protected areas without a hands-on search.
(87-46)
c. Severity Level IV for failure to control Safeguards Information.
(87-50)
d. Severity Level IV for transmitting Safeguards Information over unprotected telecommunication circuits..(87-50)
e. Severity Level IV for degradation of the Central Alarm Station barrier bullet resistivity. (88-10)
f.
Severity Level V for allowing the training certification of a member of the security force to expire. (87-46)
g. Severity Level V for allowing an escorted visitor into the protected area with incorrect access authorization documentation.
(88-10)
2. Performance Rating Category:
Previous Rating:
3. Recommendations The Board recognized the continued high level of management and oversight and support prov'ded the contract security force in the areas of training, staffing and procedural guidance.
HOWEver, the lack of responsiveness in resolving a long standing issue relating to the assessment capability of the closed circuit television system and the increase in the number of violations, attributable to personnel error, detract from an otherwise favorable evaluation of the security program.
The Board recommends management emphasis in these areas.
F. Engineering/Technical Support 1. Analysis The Engineering Technical Support functional area addresses the adequacy of technical and engineering support for all plant activities.
To determine the adequacy of support provided, specific attention was given to the identification and resolution of technical issues, responsiveness to NRC initiatives, enforcement history, staffing, effectiveness of training and qualification.
The scope of this assessment includes all licensee activities associated with plant modifications, technical support provided for operation, maintenance, testing and surveillance, operator training, procurement, and configuration control.
This evaluation is based on routine and special inspections conducted by the NRC in this area and related functional areas.
Engineering and technical support in this assessment period has been generally good.
Design engineering (DE)
activity has resulted in a number of self-identified plant problems as well as improvement initiatives.
The effective utilization of engineering resources has been demonstrated by a number of issues addressed by the licensee. An exception to the generally good performance was a recurrence of a communications weakness which was identified in the previous SALP assessment period.
The communication effort has improved during the latter part of this SALP period.
The plant engineering staff, outside the DE organization, is assigned to various plant functional activities, (i.e.,
operations, maintenance, and radiologic.l controls), providing more timely evaluation and resolution of plant problems.
In particular, maintenance engineering support was strong with
regard to involvement in field work and accessibility by craft personnel.
Maintenance engineering activity involving failure analysis, preventive maintenance, and material qualification was effective.
The quality of engineering and technical support has been compromised by the quality of the communication between the plant and DE. The DE/p'ant communication was identified as a weakness in the previous assessment period and has been demonstrated as a weakness during this assessment period.
The DE organization failed to provide the plant with adequate information regarding HPI system mode requirements and Safe Shutdown Facility HVAC configuration requirements.
The former issue resulted in a violation (see violation (a)-Safety Assessment/Quality Verification).
Although the initial HPI design deficiency was licensee identified the resolution was initially inadequate'due to a DE/plant communications failure.
Management has taken action to resolve the communication problem. This action was to reorganize DE on a site dedicated basis, establish a small on-site DE contingent to facilitate the DE/plant interface, and assign system engineers to selected safety significant systems.
These actions were not fully implemented prior to the occurrence of the communications deficiencies discussed above.
The operator training and requalification training programs are good although some simulator weakness were identified during this assessment period.
The supplementation of simulator training staff with experienced plant operators on a two year rotation was a notable contributor to training program quality.
Generally the simulator is updated to incorporate Unit 1 modifications, however, simulator hardware and software nonconformances existed this assessment period which impacted the value of simulator training.
An example of a hardware nonconformance was the control instrumentation for the Pressurizer Power Operated Relief Valve which differed between the control room and simulator. A modification completed at the end of the assessment period corrected this hardware nonconformance. The Loss of Instrument Air simulation which did not accurately reflect the actual plant evolution was an example of a software nonconformance.
Although the overall training program was generally good, simulator nonconformances which required performance compensations by the operators-in-training impacted the value of the training.
Two replacement examinations were administered during the assessment period. Eleven of eleven SRO candidates passed and six of seven RO candidates passed.
Material submitted for exam
development contained minor information deficiencies but was generally adequate and legible.
T violation identified below is an outage related violation.
During refueling outages on all three units, containment isol ion was compromised by open one-inch emergency hatch equali ing valves and small gaps (3 to 4 square inches) in hatch seals.
These failures to maintcin containment isolation were the resu t of an inadequate temporary modification and inadequate attention to detail regarding all aspects of maintaining ontainment isolation during refueling outages.
This violatio was identified by Duke Power staff and reported to the NRC.
One violation was identified during this assessment period.
a.
Severity Level ('
for failure to maintain containment conditions during ueling outages (87-49)
2. Performance Rating I
Category: 2 Previous fing:
Engineering Support 2 Training 2 3. Recommendations The board noted an improved perform nce in this area over the assessment period. While many positi attributes were observed in this area relating to self-identifl d plant problems,. there was recurring weakness in the quality of ommunications between design engineering and other plant organ' ations.
To achieve further improvement, management attention required in this area.
G. Safety Assessment/Quality Verification 1. Analysis This section includes an assessment of licensee a tivities associated with the implementation of licensee safety p licies; licensee activities related to amendment, exemption and relief requests; response to Generic Letters, Bulletins, and othe NRC initiatives. This section also includes licensee activit s related to the resolution of safety issues and self assessme t activities.
The evaluation of licensee activities is based upon observations of numerous licensing actions active or completed during the assessment period. This included about 252 licensing activities for the three Oconee units, of which 54 were licensing amendments completed during this period.
development contained minor information deficiencies but was generally adequate and legible.
The violation identified below is an outage related violation.
During refueling outages on all three units, containment isolation was compromised by open one-inch emergency hatch equalizing valves and small gaps (3 to 4 square inches) in hatch seals.
These failures to maintain containment isolation were the result of an inadequate temporary modification and inadequate attention to detail regarding all aspects of maintaining containment isolation during refueling outages.
This violation was identified by Duke Power staff and reported to the NRC.
One violation was identified during this assessment period.
a. Severity Level IV for failure to maintain containment conditions during refueling outages (87-49)
2. Performance Rating Category: 2 Previous Rating:
Engineering Support 2 Training 2 Outages 2 3. Recommendations The board noted an improved performance in this area over the assessment period. While many positive attributes were observed in this area relating to self-identified plant problems, there was recurring weakness in the quality of communications between design engineering and other plant organizations.
To achieve further improvement, management attention is required in this area.
G. Safety Assessment/Quality Verification 1. Analysis This section includes an assessment of licensee activities associated with the implementation of licensee safety policies; licensee activities related to amendment, exemption and relief requests; response to Generic Letters, Bulletins, and other NRC initiatives.
This section also includes licensee activities related to the resolution of safety issues and self assessment activities.
The evaluation of licensee activities is based upon observations of numerous licensing actions active or completed during the assessment period. This included about 252 licensing activities for the three Oconee units, of which 54 were licensing amendments completed during this period.
Management involvement is evident at the corporate and station levels through planning and assignment of priorities for activities associated with licensing.
Duke is an active participant and often assumes leadership roles for the industry regarding generic issues. This industry involvement includes, for example, the Association of Edison Illuminating Companies, NUMARC, various codes and standards committees, owners group committees, trade groups much as the American Nuclear Society and Health Physics Society and numerous others.
The extent of Duke's involvement is commendable and much is accomplished that could not be achieved on an individual plant basis.
However, Duke has not provided timely resolution and implementation of several significant, longstanding generic issues for Oconee such as ATWS mitigation design approvals, Regulatory Guide 1.97 and several TMI issues.
Duke is also an active participant in the B&W Owners Group (BWOG)
safety and performance improvement program (SPIP)
which has recommended numerous modifications to enhance plant performance. Duke has made significant contributions to the SPIP and has incorporated a large number of these recommenda tions at Oconee. However, a significant number which should enhance performance of systems such as the main feedwater system and the integrated control system are still being evaluated for implementation.
Duke's staff generally displays in-depth knowledge of the plant and of technical and regulatory issues.
Duke tends to be well prepared and to provide ample support during meetings, site visits and conference calls.
Licensee Event Reports submitted by the licensee were generally well written and provided a sufficient depth of information.
The reports describe the relevant aspects of the events, including component or system failures that contributed to the events and the significant corrective actions taken or planned to prevent recurrence.
Previous similar occurrences were appropriately acknowledged in the reports.
The licensee has demonstrated the capability to identify plant problems and has dedicated resources to resolve these problems.
Mechanisms to identify plant problems include corporate self-initiated technical audits (SITA),
audits required by Technical Specification 6.1.3 information sharing with other Duke plants, and a design calculation review program.
The SITA program and design calculation review program were developed using the NRC Safety System Functional Inspection (SSFI)
philosophy as guidance. Oconee developed a prioritized list of systems which they will examine.
These mechanisms identified problems related to the High Pressure Injection (HPI)
system, start-up transformer circuit breakers, containment penetration fire barriers, Reactor Building Cooling Unit (RBCU)
capacities,
electrical sliding link problems, and emergency power system overloading.
The resources to evaluate and resolve these problems, particularly the RBCU fouling problems, have been considerable and reflect management commitment to operate and maintain a safe plant.
Engineering activity in response to an NRC identified potential control panel configuration control problem was timely and comprehensive once the operability impact implications were recognized.
Additionally, the Oconee performance group and design engineering have been extensively involved in heat transfer performance testing of the Reactor Building Cooling Units (RBCU)
for most of this assessment period.
Due to fouling problems discovered at McGuire, Duke began looking at all heat exchangers for reduced heat removal rates due to fouling.
It was discovered by performance testing and calculations that the RBCU's were not capable of removing their design heat capacity due to both air and water side fouling.
Although the problem has not yet. been fully resolved, this group (with support from design engineering personnel) has dedicated significant effort toward resolution of this issue.
Duke has displayed a cooperative attitude with the NRC regarding its experiences in this field which has been a benefit to the NRCs efforts to develop generic conclusions and assess the need for future regulatory guidance.
The station manager initiated a program to conduct detailed reviews of specific INPO Significant Operating Event reports (SOERs).
This review consists of extensive discussion and analysis sessions involving most of the senior onsite management. Several changes contributing to safety enhancement have been incorporated into procedures as a result of these discussions.
Breakdowns in communication, however, have hindered the resolution of problems once they have been identified.
One significant example of this, which resulted in escalated enforcement, was the failure of Design Engineering to provide the plant with adequate information regarding HPI system mode requirements. This resulted in a lack of procedural guidance associated with the high pressure injection "piggyback" mode of operation (violation a).
Another example of a communication breakdown as mentioned in the Engineering/Technical Support section was the Safe Shutdown Facility HVAC system circulating water pump requirements.
The licensee provided timely, sound responses to NRC generic letters, and bulletins.
This was evident in the licensees resolution of issues in NRC Bulletins on main steam safety valves, masonary wall designs, nonconforming materials and fastener testing.
Oconee initiated a program during this SALP assessment period to grade 10 CFR 50.59 evaluations.
This resulted in improved e luations for permanent and temporary modifications, however, doc mentation of some evaluations for valve replacements and alar setpoint changes was weak.
This resulted in violaton(b). Another example of this problem is addressed in the Mai tenance/Surveillance section.
Two violat'ons were identified during this assessment period.
a. A Sever Level III violation with a $50,000 civil penalty a. lack of procedural guidance associated with high press injection piggyback operation during a loss of coolant a Wident. (88-25)
b. Severity Level giolation for failure to provide the basis for determinatio Athat changes did not affect an unreviewed safety question f r multiple alarm and set point changes (88-13)
2. Performance Rating Category: 2 Previous ting:
Quality Programs 1 Licensing Activities 2 3. Recommendations Management attention as provided dur'ng the latter portion of this SALP period should continue in th's area.
V. SUPPORTING DATA A. Escalated Enforcement Actions 1. Civil Penalties Severity Level III violation issued on December
, 1988 for a lack of procedural guidance associated with hig pressure injection "piggyback" mode of operation during a los of coolant accident. ($50,000 CP)
The licensee provided timely, sound responses to NRC generic letters, and bulletins.
This was evident in the licensees resolution of issues in NRC Bulletins on main steam safety valves, masonary wall designs, nonconforming materials and fastener testing.
Oconee initiated a program during this SALP assessment period to upgrade 10 CFR 50.5 9 evaluations.
This resulted in improved evaluations for permanent and temporary modifications, however, documentation of some evaluations for valve replacements and alarm/setpoint changes was weak.
This resulted in violation (b). Another example of this problem is addressed in the Maintenance/Surveillance section.
Two violations were identified during this assessment period.
a. A Severity Level III violation with a $25,000 civil penalty for a lack of procedural guidance associated with high pressure injection piggyback operation during a loss of coolant accident. (88-25)
b. Severity Level V violation for failure to provide the basis for determination that changes did not affect an unreviewed safety question for multiple alarm and set point changes (88-13)
2. Performance Rating Category: 2 Previous Rating: Quality Programs 1 Licensing Activities 2 3. Recommendations Management attention as provided during the latter portion of this SALP period should continue in this area.
V. SUPPORTING DATA A.
Escalated Enforcement Actions 1. Civil Penalties Severity Level III violation issued on December 13, 1988 for a lack of procedural guidance associated with high pressure injection "piggyback" mode of operation during a loss of coolant accident. ($25,000 CP)
2. Orders August 6, 1987 -
Elevated lake water temperature, Oconee 1 August 19, 1987 -
Elevated lake water temperature, Oconee 2 B. Management Meetings October 27, 1987
-
SALP meeting with licensee at Oconee site March 1, 1988
-
NRC/DPC meeting at NRC office in Washington to discuss Integrated Safety Assessment Program January 15, 1988
-
Enforcement Conference at Region II related to protection of safeguards information in electronic transmission January 28, 1988
-
Technical meeting with Duke Design Engineering in Charlotte, NC to discuss current issues and concerns June 7, 1988
-
Meeting in Atlanta Region II offices to discuss findings of NRC Quality Assurance Team July 1, 1988
-
Enforcement Conference at Region II related to environmental qualification of electrical equipment September 8, 1988
-
Meeting at Oconee to discuss fouling of Reactor Building Cooling Units September 12, 1988
-
Enforcement Conference at Region II related to high pressure injection
"piggyback" mode of operation
October 6, 1988
-
Enforcement Conference at Region II related to potential degraded capabilities of the. Reactor Building Cooling Units (RBCU)
January 6, 1989
-
Enforcement Conference at Region II related to the inadequate design of the Lee Station transmiss'on system January 12, 1989
-
Meeting at Oconee site by with Duke Licensing group, NRC licensing Project Managers, and NRC Region II personnel C. Confirmation of Action Letters (CAL)
January 5, 1989
-
CAL issued following switchgear fire to maintain equipment related to the fire in the "as found" condition D. Review of Licensee Event Reports (LERs)
During the evaluation period, 29 LERs for Units 1, 2, and 3 were analyzed. The distribution of the events by cause, as determined by the NRC staff, was as follows:
Cause Total Component
Design
Construction, fabrication or installation
Personnel:
-
operating activity
- maintenance activity
-
Test/calibration activity
- Other
Other
29 E. Licensing Activities During the evaluation period, review of 252 licensing actions and 54 licensing amendments was completed for the three Oconee units.
F. Enforcement Activity No. of Deviations and Violations in Functional Each Severity Level Area Dev.
V IV III II I
Plant Operations
Radiological Controls
-
Maintenance/Surveillance
9 Emergency Preparedness Security
5 Engin eving/Technical
Support Safety Assessment/Quality
1 Verification TOTAL
19
G. Reactor Trips A total of five automatic trips occurred during this rating period, two on Unit 1, one on Unit 2 and two on Unit 3.
Seven automatic trips occurred during the previous rating period. One manual trip was also experienced. The trips are described in more detail.below.
1. Unit 1 a.
On July 5 an automatic trip occurred from 100% power due to an error by an Instrument and Electrical (I&E)
technician while troubleshooting a turbine header pressure instrument.
b.
On January 2, 1989, a trip from 100% power occurred during surveillance of the Reactor Protection System due to an I&E technician error. Channel D was tripped when Channel A was also in a tripped condition.
c. On January 3, 1989, a manual trip from less than 15% power due to a fire in a 6900VReactor Coolant Pump switchboard.
2. Unit 2 a.
On August-26, 1988, an automatic trip occurred frum 100%
power due to a anticipatory reactor trip on turbine trip caused by a faulty Moisture Separator Reheater high level instrument.
3.
Unit 3 a.
On November 14, 1988, the reactor tripped from 100% power due to a main turbine trip.
The reason for the main turbine trip could not be identified and the reactor returned to power.
b. On November 14 while recovering from the trip discussed above, the reactor again tripped. Power was at 39% and the reason for the trip was a main turbine trip due to faulty relay in the steam generator high level circuitry.
The reactor tripped due to high reactor coolant system pressure.
H. Effluent Release Summary (First Half)
Activity Released (Curies)
1985 1986 1987 1988 1. Gaseous Effluents Fission and Activation 2.35 E+4 2.43 E+4 1.05 E+4 1.85 E+4 Products lodines and 6.14 E-3 5.41 E-2 1.58 E-2 9.74 E-2 Particulates 2. Liquid Effluents Fission and Activation 4.16 EO 5.85 EO 2.90 EO 1.57 EO Products Tritium 1.24 E+3 1.34 E+3 9.49 E+2 4.28 E+2
II I
Duke Pbuw Company ENCLOSURE 2 He! R T.
P0 Box 33198 11-Pr, 1,1,y Charlotte, N.C 28242 Nue lr Pr'du, 00 ;
DUKE POWER
'
,
May 19, 1989 Mr. Stewart D. Ebneter Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W. Suite 2900 Atlanta, Georgia 30323 Subject:
Oconee Nuclear Station Docket NOS. 50-269, -270, -287 Inspection Report 50-269, -270, -287/89-01 Systematic Assessment of Licensee Performance (SALP)
Dear Sir:
By a letter dated April 11, 1989 you transmitted to me the NRC Systematic Assessment of Licensee Performance (SALP) for the Oconee facility. In a public meeting on April 21, 1989 at the Oconee site a verbal presentation of that report was given. Although I am generally pleased with the report and felt it adequately reflected our performance over the period, I would like to comment on two areas of the report to provide additional information and to request that the NRC reconsider the ratings specified in these areas. The two areas are; 1) maintenance/surveillance and the 2) security categories. Attachment 1 and 2 to my letter provides our comments and additional information to the two areas respectively.
Should you have any questions concerning the information provided, please don't hesitate to contact myself or members of my staff.
Very truly yours, Hal B. Tucker cc:
U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Mr. P.
H.
Skinner NRC Resident Inspector Oconee Nuclear Station Mr. D. B. Matthews Office of Nuclear Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 DRP OFFICIAL CO (P 5uo LL PI
Duke Power Company Oconee Nuclear Station Attachment 1 MAINTENANCE/SURVEILLANCE We are disappointed in the SALP rating and the language in your report indicat ing that our performance has declined in the Maintenance/Surveillance category.
It has been our perception that our performance, although not perfect, has continued to improve from the last SALP period and through the current period.
Our definition of the expectations of a quality program for the Maintenance/
Surveillance category are as follows:
a) Maintain the condition of components critical to the operability of the station to allow them to perform their intended functions.
b) Perform surveillance during the cycle to provide a high degree of assurance that components are functioning correctly and will perform their intended function if called upon.
c) Adopt a 'fix before break' philosophy, which will allow plant operators to be in full control of a predictable plant, thus minimizing the potential for adverse consequences to the plant and the public and to maximize the efficiency and reliability of the station.
d) The performance of this work will be planned and executed to minimize errors by personnel and radiation exposure to them.
In the SALP report it is stated that some of the key evaluation criteria used for assessment were as follows:
1. Assurance of quality, including management involvement and control; 2.
Approach to the resolution of technical issues from a safety standpoint; 3. Responsiveness to NRC initiatives; 4.
Enforcement history; 5. Operational and construction events; 6. Staffing (including management);
7. Effectiveness of training and qualifications program We do understand that you are not limited to this criteria and others may be used where appropriate. In the case of Maintenance, it would seem appropriate to look at capacity factors, length of continuous runs, trips, and forced outage rate as a gross indicator of your performance in the Maintenance area.
In the following paragraphs, we offer additional information which has led us to a perception of improved performance.
During the SALP period of August 1, 1987 to January 31, 1989 the Oconee Nuclear Facility operated with a high degree of reliability. We conducted 4 refueling outages with high quality. Indicators of the quality of work performed is summarized in the following statistics:
-
The three units achieved a capacity factor of 83.06% during the period, one of the highest for a multi unit facility in the U.S.
-
The three units achieved a low forced outage rate of only 2.41%
during the period. Almost none of the forced outage rate is re flective of conditions which a prudent maintenance program would have avoided.
-
Units 1 and 3 achieved their longest continuous runs in their 15 year history of 235 and 351 days respectively.
-
Reactor trips and Safety Injections were below industry average during the evaluation period. This obviously minimizes challenges to safety systems.
-
Outage execution has been excellent. During the first two outages in the period the steam generators were chemically cleaned and averaged approximately 68 days each. The second two outages were conducted in 43 and 42 days respectively - among the best in our history.
The above performance could not be achieved without an effective maintenance/
surveillance program.
The material condition and housekeeping have consistently improved since the last SALP period. We do recognize that we have a long way to go to meet our standards, however the following achievements are noteworthy:
-
The Maintenance Engineering support for facility and equipment upgrade has been strengthened and is providing improved attention to component reliability.
-
The physical plant appearance and cleanliness has improved drastically during the period.
-
The plant contaminated areas have been significantly reduced.
The planning of work has improved significantly during the period as indicated by the following:
-
The amount of backlogged work has decreased significantly to only 250 non-outage work requests outstanding longer than 90 days for a 3 unit facility.
-
The preventative to corrective maintenance ratio has been improved and is approaching our goal of 70%.
-
Extensive improvement in ALARA planning has resulted in 1988 having the lowest station exposure since 1975. The Unit 1 refueling in 1989 had the lowest exposure of any outage in our history.
-
Attention to detail on work request quality has improved during the period.
We have been very responsive to industry and NRC initiatives in the Main tenance/Surveillance area as indicated by the following:
-
Oconee is one of the few plants in the U.S. that has a large dedi cated engineering resource in the maintenance department able to work directly with craft personnel to improve reliability of components.
-
779 Limitorque valve motor operators (safety and non-safety) at the Station have been rebuilt and Movat tested where appropriate. This action has taken place since the 1986 SSFI inspection.
-
Oconee has been the industry leader in identification and resolution of problems with air to water heat exchangers (Reactor Building Cooling Units).
-
Our erosion and corrosion testing program for pipe wall thinning was established before the NRC initiatives.
-
Our containment leak rates in Type A and C testing has continued to improve and was the best in our history in recent outages.
-
Many of the B&W Owners Group SPIP recommendations have been imple mented and these have been directly responsible for trip reduction.
-
NRC identified issues have been aggressively pursued and we have received praise from inspectors on our thoroughness and responsive ness.
In analyzing the SALP report, it appeared that a great deal of emphasis was given to the increased number of violations from last period to this period.
Although we are not disputing the validity of these violations, it should be recognized that there were more team inspections - Environmental Qualification, Quality Verification, Maintenance Team - that contributed to inspector hours in the maintenance area. The following is our analysis of the data you presented in the SALP report:
Three violations were significant during the period:
-
Violation 87-51 resulted in loss of a freeze seal.
We disagree that the procedure was at fault; however, we have taken actions to reduce the probability of this event. This was very early in the period.
-
Violation 88-08 Inadequate equipment identification of a component prior to beginning work. We feel that we have a very low number of wrong unit, wrong train events. As a practice we had not labeled instrument root valves at Oconee. As a result of this event, we are labeling all instrument root valves at the plant.
-
A violation not cited during this period, but covered in the report dealt with RBCU drop out plates. We feel this was a strength of our surveillance program in identifying that no pre-op test had been
performed on this component and developing plans to do testing identified the inadequacy of the design.
The Environmental Qualification inspection identified the following violations:
-
Violation 88-03 Design documentation not adequate for Victoreen high range radiation monitors. This was not related to maintenance.
-
Violation 88-03 Level V Reactor Building level transmitter not being maintained completely filled with oil and therefore not in a tested configuration. This was an error in capturing the requirements of the EQRI several years earlier.
-
Violation 88-03 Level V deficient EQ maintenance procedures in that requirements not properly captured from EQRI. This involved 3 components, one of which was the above violation, and none of any significance.
The Quality Verification Team inspection identified the following violations:
-
Violation 88-13 Failure to keep accurate records.
This was not a record keeping problem but rather a falsification of documents problem. Individuals involved have been disciplined and other actions taken. This was not a Maintenance/Surveillance problem.
-
Violation 88-13 Failure to measure valve stroke time from actuation to end of actuation. Oconee used the same guidance that was approved for the Catawba SER which allowed light to light measurement.
-
Violation 88-13 Failure to include valves LPSW-773 and HP-98 in IST program. Valve LPSW-773 was not included and is not necessary.
HP-98 was the only valve in 3 unit's programs that had not been included that should have been. A very low error rate.
-
Violation 88-13 Failure to correctly fill out work requests and inadequate cleanliness of cabinets. The errors on work requests were very minor and did not contribute to problems in the field. Emphasis since identification has resulted in significant improvement (inspectors comments at last inspection). Cleanliness issue was an isolated case and has been corrected.
The Maintenance team inspection identified the following violation:
-
Violation 88-17 Procedure problems related to calibration of control room ground detection circuit, battery undervoltage alarm, certain circuit breaker and 4160 volt switchgear maintenance. The procedural problems were minor and are being corrected. Problems with omitting ground detectors and control room instrumentation resulted from miscommunication on the department responsible many years ago and was missed. This has now been rectified.
The other 3 violations are considered isolated situations.
As noted above, there have been three team inspections that focused heavily in the area of maintenance/surveillance during this review period. The Environmental Qualification (EQ) team inspection (Inspection Report 88-03)
concluded that overall the EQ maintenance program is acceptable. The report noted that the program was ".... changing and improving as the overall maintenance program is being upgraded as a result of prior inspections.
Procedure changes and transfer of responsibility have taken place that should improve the program".
The quality verification team inspection report (88-13) noted a number of Violations, but found that the various work practices and procedural controls generally acceptable and that personnel were knowledgeable of their work activities. The following observations were noted within the report:
The number of valve stroke time failures was very small.
- Maintenance history records did not indicate repetitive failures.
- Based on the low component failure rate and few repetitive failures the licensee's corrective and preventive maintenance programs appeared to be better than average.
- The licensee's maintenance engineering program, with emphasis towards component engineers, appeared to be an effective method of resolving component failures.
- The requirements of ASME 45.2.11 Design Control appeared to be adequately implemented for most engineering activities.
- The preventive maintenance program and MOVATS testing program appears to have created a high operational reliability for plant poer operated valves.
- The ASME Section XI Valve testing program is above average.
The maintenance team inspection report (Inspection Report 88-17) found that Oconee had a very good performance record in the areas of plant availability and very few operational problems attributable to maintenance. The report indicated that management was very supportive of a strong maintenance program and appreciated the fact that good maintenance translates into improved performance and availability. The results of the inspection were summarized as follows: ".... the licensee has an overall strong maintenance program with a few minor implementation flaws". ".... The Oconee maintenance program is, for the most part, a very good program with the sound backing of plant and corporate management."
As a final note, Duke has not observed any increase in the inspection in the area of maintenance/surveillance, excluding the team inspection, that one would expect for a functional area that has experienced a decline in performance.
As can be seen above, we do not believe that there have been a sufficient number of problems to be categorized as you did in the cover letter; "Over this assessment period, numerous performance problems were identified characterized by inattention to detail, miscommunication and procedural/personnel errors."
In considering the nature of a three unit facility, the length of the SALP period, and the opportunities for discovery with the increased number of team inspections, we feel that our performance in the Maintenance/Surveillance category has improved considerably during the SALP review period and, as such, respectfully request reevaluation of the rating in this area.
Duke Power Company SECURITY RELAIED Oconee Nuclear Station Attachment 1 NU CLAS~!E"B SECURITY AND SAFEGUARDS The SALP Report had concluded that due to a lack of responsiveness in resolving a long standing issue relating to the assessment capability of the closed circuit television (CCTV) and the increase in the number of violations attributable to personnel error, had detracted from an otherwise favorable evaluation. We are disappointed in the SALP rating chosen. We do not believe that these two items are significant enough to result in the need to reduce the SALP rating from the previous review period. It is our opinion that our performance during this review period has been consistent with our performance from the previous review period.
In the following paragraphs, we provide a discussion of each of the two items of concern that were identified in the SALP report as detracting from an otherwise favorable evaluation.
The CCTV system inadequacies identified during NRC inspection 87-36 although affecting a major portion of the system, provides minimal security system vulnerability. The CCTV system currently covers the intrusion detection zones and is used for initial alarm assessment, but requires supplemental officer response to assess small portions of the isolation zone.
Once identified during the inspection, compensatory measures were immediately implemented. On 9/12-13/87, a complete review of the CCTV system using the same acceptance criteria as the NRC inspector was performed. Additional areas were identified and compensatory measures were implemented.
The Regulatory Effectiveness Review conducted at Oconee on 9/17-24/85 listed the CCTV system as a "Safeguards Strength" in section 2.5.3 of their report particularly noted the quality of the CCTV pictures at night.
In addition, it is our opinion that management's attention, identified resolu tions, and time frames for resolution implementation are appropriate given the minimal security system vulnerabilities.
As indicated in the SALP report, six of the violations cited were licensee identified. We are concerned with the NRC's practices of issuing a violation that appears to warrant discretion. We believe that each of the six violations that were licensee identified are consistent with the criteria of V.G.1. of the NRC Enforcement Policy Statement provided by 10CFR2, Appendix C, and as such should not have been cited.
In addition, none of these "Licensee identified" violations reflect an exploitable weakness in the Oconee Security program. The following paragraphs provide a discussion of each of these violations.
1) Violation 87-45 - Allowing an employee into the Protected Area without a security badge.
SECURllY RELATED NOT CLASSIFIED The violation as stated is due specifically to individual error based on officer familiarity with the individual who was allowed P. A. access unbadged. Daily, over 2000 individuals are granted access to the P. A.
through the main personnel access portal providing for 2000 opportunities for personnel error. Calculated over this reporting period, this would present 528,000 chances for error with only one actual occurrence. With the inclusion of outages, this number is substantially higher. The access process is totally controlled by personnel with no equipment interface required to prevent these types of incidents.
This reflects an excellent officer performance record for this area.
The individual concerned recognized the problem, and appropriately notified Security as he had been trained to do through the site training program.
This event was reported to the NRC within one hour of the discovery of the occurrence in accordance with Duke Power Company's interpretation of 10CFR 73.71.
2) Violation 87-46 - Allowing a visitor into the Protected area without a hands on search.
The violation, as stated, is due specifically to individual error based on the need for a female officer to pat down a female employee when one was not posted in the search lobby. The individual who entered the Protected Area without the hands on search had been processed through operable metal and explosive detectors providing high assurance that no contraband items could have entered the Protected Area undetected. The individual was also properly escorted the entire time. The pat down requirement for visitors no longer exists due to Security Plan changes required for the 10CFR 73.55, Miscellaneous Rules implementation. Consequently, under the new criteria, this is not considered by the NRC to be a Security concern.
This event was logged in accordance with Duke Power Company's interpretation of 1OCFR 73.71.
3) Violation 87-50 - Failure to control Safeguards Information.
It is our position that this violation does not accurately reflect Oconee's security program effectiveness in the area of Safeguards document control.
The failure to properly destroy Safeguards materials by corporate personnel was the initiating event and was identified by Corporate Security personnel.
Material relating to Oconee, McGuire, and Catawba were all improperly destroyed. Site Procedures, training programs, and audit of the Oconee Safeguard's Document Control program were in place assuring compliance at the time this incident occurred in the Corporate Office.
4) Violation 87-50 - Transmitting Safeguards over unprotected telecommunications circuits.
It is our position that this violation as stated is correct and that Safeguards Information was transmitted in an unprotected manner. The majority of Oconee Security Implementing Procedures are processed by the Station Services Word Processing Group. When the Safeguards rule became effective, a review of the Word Processing computer functions was conducted and at that time it was determined the system was fully contained on site
SECMllY RELATED NOT CLASSIFIED and secured satisfactorily. In March 1984, the Oconee processors were linked to corporate computers for the purposes of archiving documents for long term retention as were computers at the other Duke sites.
The problem was identified by a security staff person at the McGuire Nuclear Station.
5) Violation 87-46 - Allowing the training certification of a member of the security force to expire.
This event occurred because of security supervision error.
Annual re qualification to security tasks are conducted as required by the Oconee Training and Qualification Plan. The specific officer in question had his Protected Area Patrol qualification expire. Prior to requalification to task, he was inadvertently assigned Protected Area patrol duties by his supervision. Procedures were in place to assure only qualified personnel are assigned security duties. The supervisor in question failed to follow the established procedures.
The error was identified on the same shift by security shift management and a qualified officer was dispatched to conduct follow up patrol to verify all the required patrol responsibilities had been correctly carried out. No problems were identified. Although the officers qualification had expired, he had been quali.fied for the previous ten years.
This could not have resulted in adversarliT exploitability.
6) Violation 88-10 - Allowing an escorted visitor into the Protected Area with incorrect access authorization documentation.
While processing an escorted visitor into the station, the security clerk conducting the process retrieved the wrong access document for the subject individual.
The last names were the same but the clerk failed to check the individual's photo I. D. closely enough to assure the correct document was used. The individual was being escorted for a station orientation prior to being permanently badged. He had already been approved for unescorted access. No vital areas were entered during this orientation.
The violation was identified by the security shift lieutenant.
The final violation, which was identified by a Regional Inspector, concerned a degraded vital barrier. It is our opinion that although this incident is a violation of security plan commitments, it does not represent an exploitable weakness in the Oconee security program. The following is a discussion of the violation:
Violation 88-10 - Degradation of the Control Alarm Station Barrier Bullet Resistivity The Vital Area in question is the Central Alarm Station (CAS) which by 10CFR must be treated as a vital area, although there is no equipment located in the CAS, vital to the safe shutdown of the station. The CAS is located inside a building that is a seperate vital area and designed as such. During an NRC inspection, three (3) openings were located above the ceiling tile. The closest to the floor is approximately 12' which would require a climbing device to reach. Once identified, compensatory measures were implemented until a resolution could be reached.
SEClWiNY RTED NOT CIASS1Fll After review, it was decided that since the CAS is afforded vital prot ection by being enclosed in a seperate vital area, a security plan revision would be submitted to clarify the CAS protection as the vital area it is enclosed in. The openings were then filled with firestop foam in accordance with Security Plan commitments for bullet resistancy and the compensatory measures were discontinued. As stated, this situation is not exploitable by an adversary since penetration of the primary vital structure must first occur. Additionally, there is no regulatory basis for an independent CAS barrier, (e.g. vital area compartmentalization) since it is located within a larger vital area that also protects it from external weapons vulnerability.
In summary, six of the seven violations were Licensee identified and satisfied the criteria specified in 10CFR2, Appendix C, Section V.G.1., and thus should not have been cited. We agree with the overall assessment provided in the SALP report, collectively considering all seven violations, they do not indicate a major security program breakdown. In addition, Duke has not observed an increase in inspections on the security area that one would expect for a functional area that has experienced a reduction in performance.
As stated above, we do not believe that the two concerns identified warrant a performance decline from a Category 1 to a Catagory 2 with respect to security.
Accordingly, we respectfully request reevaluation of the rating in this area.