IR 05000269/1990024
| ML20058A654 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/02/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058A652 | List: |
| References | |
| 50-269-90-24, 50-270-90-24, 50-287-90-24, 72-0004-90-24, 72-4-90-24, NUDOCS 9010290052 | |
| Download: ML20058A654 (24) | |
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ENCLOSURE
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i INITIAL SALP REPORT
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U.S.NUCLEARREGULATORYCOMMISSION(NRC)
REGION 11 i
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER
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S0-269,270,287/90-24,72-4/90-24 i
DUKE POWER COMPANY l
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f OCONEE UNITS 1, 2. AND 3
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FEBRUARY 1, 1989 THROUGH JULY 31, 1990
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SUMMARY DF RESULTS Oconee has been operated in a safe manner during the assessment period.
Communications between the operating shifts and the support organizations have improved. The quality, content, and preparation of procedures has
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been observed as improving.
There has been a reduction in the number of forced outages.
The effort to institute physical improvements to the plant to upgrade and replace aging equipment has been noteworthy.
Plant operations continues to be maintained at a high level of competence.
Control room performance and the performance of the associated support organizations continued to be effective. However, continued management attention is needed in the area of procedural compliance.
Performance in the area of Radiological Controls continues to be superior.
The reduction of person-rem was very good.
Performance in contamination control was excellent especially in the efforts exhibited during the Spent Fuel Pool overflow event. The new secondary chemistry laboratory has greatly improved the capabilities of monitoring the secondary systems chemistry activities.
Good performance was identified in the area of Maintenance / Surveillance.
Good communications and teamwork in the onsite organization was evident although several problems with procedural compliance were identified.
The support organizations from Transmissions and Construction Maintenance Divisions have recognized a problem in their training process and aggressive actions have been taken to correct this area.
Support of the Emergency Preparedness program was evident from both corporate and site management, as evidenced by the quantity and quality of announced and unannounced drills conducted.
The licensee aggressively pursued emergency response readiness program improvements by conducting unannounced drills as well as timely correction of exercises weaknesses
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and problem areas.
In the Security area, significant improvements have been made.
The long standing issues associated with security cameras have been addressed although there are still some inadequacies that remain to be corrected.
In addition, actions have been implemented which have increased the effectiveness of access control.
Engineering / Technical Support has improved.
The programs in effect to define the design basis and correct any identified problems is considered a strength.
Increased involvement of these organizations has resulted in the units being modified to correct findings that have in some cases existed since initial operation. Management has focused attention on enhancing the communications of these groups with the operating groups and other support groups.
Safety Verification / Quality Verification performance demonstrates a thorough and conservative approach in assessing questionable conditions and activities.
The Nuclear Safety Review Board has been effective in its
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efforts to assure weaknesses in the operation and-control of the units are
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. identified and corrected. Additional attention to'the quality of l
licensing submittals is neede.
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Overview Performance ratings assigned for the last rating period and the current period are shown below.
Rating Last Period Rating This Period Functional Area 8/1/87 - 1/31/89 2/1/89 - 7/31/90
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Plant Operations
1 Radiological Controls
1 Maintenance / Surveillance
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1 Security and Safeguards
2 (Improving)
Engineering / Technical
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Support Safety Assessment /
2 Quality Verification
!!!. CRITERIA The evaluation criteria which were used to assess each functional area are described in detail in NRC Manual Chapter MC-0516, which can b's found in the Public Document Room files. Therefore, these criteria are not repeated here, but will be presented in detail at the public meeting to be held with licensee management.
However, the NRC is not limi'ed to these criteria and others may have been used, where appropriate.
IV. Performance Analysis A.
Plant Operations 1.
Analysis This functional area addresses the control and performance of activities directly related to operating the facility (including fire protection).
The shift operations personnel performance has been maintained at a high level. On several occasions shift operations personnel reacted promptly and prevented a unit from undergoing a transient condition due to the failure of a component. The hign experience levels maintained by the licensee has resulted in a very competent nucleus of operators.
The operating-personnel are aggressive in identifying deficiencies that occur during routine operations. Control room attentiveness and demeanor continue to be a strength.
Comunications, between operations and support groups, which was identified as an area that needed improvement in the previous evaluation period, has improved. There has not been a reac % r trip at power attributable to shift licensed ope;ators since January 198 ;
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l The Independent Spent fuel Storage Installation was placed in operation during the assessment period. Two dry storage canisters were being placed in the facility.
The Operations Support Group, is staffed with experienced i
licensed and non-licensed operators and engineers and continues to be a vital asset. This group also contains some of the
" system experts" (discussed in more detail in Section IV.C
below).
Preparation of initial training as a result of new plant modifications, prior to turnover to the operating shifts 1s normally conducted by this group.
They also provide a staff
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of knowledgeable personnel to assist operations when complex i
evolutions or activities, such as when mid-loop operations are j
performed.
This group's involvement has improved the i
communications and work interfaces with other plant
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organizations. Their knowledge and experience, has improved the overall quality of operating procedures and operators knowledge of systems and new plant modifications.
Operations and plant management have consistently exhibited a conservative and safe approach to plant operations.
The resolution of plant problems are rapidly and effectively
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addressed.
Following a series of personnel errors during a recent outage all work activities were stopped for approximately
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30 minutes and the plant manager personally addressed this issue
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to all site personnel. All organizations, including general
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office personnel, assist as necessary to resolve questionable issues. The NRC resident staff is apprised immediately of all
potential problems and are invited to attend all meetings
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conducted by the licensee. Outage management continues to be a
strength ac indicated by the consistently good performance exhibited during the recent outages on each of the units.
The licensee's correctise actions to resolve the findings of the Emergency Operations Procedures inspection, performed during the previous assessment perior were technically viable and generally sound.
Howevr, two areas identified during the followup inspection, '.e., operator guidance for controlling the reactor with Reactor Coolant System voids, and additional information needed in an Abnormal Procedure, required further action. Two deficiencies not previously noted were quickly addressed and adequately resolved.
l Although the operating procedures have and continue to improve, several instances occurred where personnel were careless in following the procedure.
This resulted in several violations, such as, the overflow of the spent fuel pool and spill of
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l contaminated water in the High Pressure Injection Pump room.
l Aanagement assigned several plant personnel to a team to assist in the resolution of this problem. To address this problem, an
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innovative training program was implemented.
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included a video which emphasized the importance of following procedures.
This program was implemented near the end of this evaluation period and as a result, the effectiveness of this effort can not be fully assessed.
Subsequent to the implementation of this program a decreasing trend was noted in the failure to follow procedures.
Two reactor trips occurred during this assessment period. The first occurred due to a large bolt falling through a hole in the floor and contacting a pressure switch which caused a loss of all condensate booster pumps.
The licensee attributed this to a management deficiency.
The second trip was caused by a loss of the electrohydraulic oil system to the turbine due to water intrusion into a control cabinet.
The licensee attributed this to poor work practices. Management took quick and effective actions to clean up loose materials in the turbii.: building, protect cabinets from water intrusion, train cleaning personnel on protection of sensitive equipment and evaluate components that needed protection from potential inadvertent contact.
A special inspection was conducted to determine the licensee's responsiveness to deficiencies identified by NRC in the licensee's Appendix R program.
The inspection concluded that the responses were timely, technically sound and thorough. Also inspected was the program for fire brigade training and staffing and coordination with offsite fire departments. The licensee's approach to resolution of technical issues from a safety standpoint was conservative and demonstrated a clear understandingoftheseissues.
This inspection concluded that the licensee s fire protection program meett "RC requirements.
Six violations were cited.
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Performance Rating
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Recommendations None B.
Radiological Controls 1.
Analysis This functional area addresses those activities directly related to radiological controls and primary / secondary chemistry control, reviewed during routine inspections conducted throughout the assessment perio i
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j Both Radiation Protection and Chemistry were well staffed for
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i normal plant operations.
The licensee continued to employ a high percentage of Health Physics (HP) technicians that are American National Standards Institute (ANSI)/American Nuclear Society (ANS) 3.1, Selection and Training of Nuclear Power Plant Personnel qualified. The number of HP technicians qualified to these standards increased from 81 percent to 95 percent of the total technicitn staff.
The practice of utilizing experienced contract HP technicians that have worked at Oconee during previous outages and the high percentage of ANSI /ANS 3.1 qualified licensee HP technicians is considered a continuing strength.
The licensee corrected several violations identified during the previous assessment period regarding access controls to high radiation areas. The licensee implemented increased controls including additional monitoring devices and HP coverage.
The licensee immediately responded to and corrected two identified items; failure to hold quarterly As Low As Reasonably Achievable (ALARA) meetings, and failure to perform periodic Health Physics audits of the radiation protection program, in addition the licensee produced an excellent video tape for employee training regarding personal exposure-reduction techniques. The licensee's response to problems and subsequent corrective actions are indicative of high standards, and a commitment to controlling and reducing collective dose.
The licensee established a total collective dose goal of 575 person-rem for 1990.
Through June 1990 the licensee's collective dose was 161 person-rem. The declining annual collective dose during this assessment is also indicative of management's support for dose reduction at the station. The collective doses were 290 person-rem, and 228 person-rem per
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unit respectively, in 1988 and 1989.
Continued dose reduction was due to the controlled crud burst program, experienced staff, and individual commitment to the ALARA Program.
The licensee continued to have an aggressive contamination control program. Ninety-four percent of the radiologically controlled area (RCA) is maintained as non-contaminated.
This effort to cleai: previously contaminated areas and maintain these areas clean has resulted in a reduction of skin contamination cases. The number of skin contamination cases in 1989 was 146 compared-to only 14 tim far in 1990.
During the spill of contaminated water from the Spent Fuel Pool Cooling System that occurred on May 17,1990, radiological controls personnel and other site personnel were very effective in controlling the spread of contamination and the followup cleaning process.
The good judgement, good training and quick action of these personnel prevented the release of radioactive material from the
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The liquid and gaseous effluent program was well managed.
During 1989, the licensee had formed a Radwaste group within the Chemistry department which was responsible for liquid tank sampling, release calculations, and the valve line-up for liquid releases. The formation of this group represented an improvement in the process for liquid sample releases since Chemistry Health Physics, and Operations) groups (i.e.,
prior coordination among various facility was minimized.
Liquid and gaseous effluents for calendar year 1989 were within the dose limits specified by TS and within the radioactivity concentrations specified in 10 CFR 20, Appendix B.
The projected offsite whole body dose to the most highly exposed individual from all pathways was 0.65 mrem / year for calendar year 1989. This value reflected good ALARA practices and commitments and was well within 40 CFR 190 limits.
Gaseous effluents decreased substantially during this assessment period as evidenced by a 65 percent reduction in fission and activation products, and a 74 percent reduction in iodines and particulates when compared to the previous assessment period.
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This decrease was due to fewer outages and no abnormal liquid or gaseous releases during this assessment period Liquid fission and activation products during this assessmc'it period increased by 25 percent over previous assessment peried values since the units operated for longer periods of time.
There were no unplanned 9r accidental releases reported during this assessment period.
The licensee has effect vely maintained primary and secondary chemistry parameters within TS requirements and Electric Power Research Institute and the Steam Generator Owners Group guidelines during steady state operations. The facility's
monitoring capabilities of secondary system parameters has been
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improved due to the completion of a new secondary chemistry laboratory and by the installation of an on-line chromatograph.
A Morpholine /all volatile treatment secondary chemistry program has been initiated in an effort to reduce secondary system corrosion rates and subsequent corrosion product transport to the steam generators.
As indicated in the previous SALP report, the Low Pressure l
Service Water' radiation monitors (RIA-35) had been inoperable
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t since 1985.
During the. current assessment period, the_ licensee initiated modifications to upgrade the associated piping, change
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the sample collection point, and install flow switches in order to correct-low flow conditions to the monitors. This l
modification was installed on Units 1 & 3 during this assessment j.
period and will be installed during the current outage on Unit 2.
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The licensee appropriately developed radiation protection procedures and provided subsequent training for spent fuel movement to the Independent Spent Fuel Storage Installation.
No violations were cited.
2.
Performance Rating Category: 1 3.
Recommendations None C.
Maintenance / Surveillance 1.
Analysis
This functional area addresses those activities directly related to the maintenance activities and the associated maintenance program, including implementation of plant modifications and surveillances of equipment.
In the surveillance area, the licensee has not missed a surveillance during this assessment period.
They have conducted
approximately 12S,000 surveillances during this assessment period without exceeding a time limitation specified in the Technical Specifications.
In the maintenance area, the licensee continues to perform well as indicated by the series of continuous operating periods with a minimum of forced outages.
The maintenance effort has primarily shifted to a preventive maintenance system which has resulted in a lower failure rate of equipment.
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contributed to a low backlog of work requests and a gradual upgrade in material conditions.
The results of the 10 CFR 50, Appendix J, Integrated Leak Rate Testing were good. Operational problems attributable to maintenance have been minimal near the end of this evaluation period. However, during the beginning of the evaluation period four reactor trips occurred and some additional problems were caused, in part, by poor maintenance work practices.
A reactor trip was caused by the improper I
installation of wiring during a plant modification in conjunction with an existing ground. A second reactor trip was caused by an instrument technician taking two channels of the i
Reactor Protection System out of service at the same time.
Another reactor trip was caused by inappropriate action during
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troubleshooting of the Control Rod Drive System which resulted in a rod group dropping into the core. An additional trip
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occurred, in part, due to the failure to correct a failed limit i
switch on a feedwater valve. Management took prompt corrective
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actions to correct the root cause of each of these trips, however, a part of this corrective action will require extensive training to fully implement.
This training is discussed in more detail below.
The licensees' Maintenance Engineering personnel work directly with the craft to resolve questions during component maintenance.
A " Systems Engineer" program has been established by licensee management. Although other engineers in the various plant groups are assigned as a " System Engineer", the majority of these engineers are part of the Maintenance Engineering
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group. This engineering group has been effective in the resolution of routine problems and in assisting operations personnel in understanding complex system functions, in addition they have been effective in identifying root causes for e.omponent failures.
Programs that are in place and functional, such as valve motor operator testing, erosion and corrosion testing, and air to water heat exchanger testing, have been effective in identifying problems before significant failures occur. A preventive maintenance program has been implemented for service water systems which includes inspection and cleaning of silt deposits and monitoring for clam infestation.
The licensees' use of Construction Maintenance Division (CMD)
and Transmission Department personnel to supplement maintenance J
efforts has resulted in the capability to assign specific maintenance activities to specialized crews.
Since these crews
are assigned to perform only one function such as, valve repairs, head removal / installation, turbine refurbishment, switchyard activities, large breaker and motor control cubicle work, etc., the repetition has resulted in more qualified personnel, fewer errors and less rework requirements. CMD has implemented an in-depth training program to establish training levels of all their personnel to meet a skills level based upon the needs of the station.
This complex program assures an individual has received general employee training, basic math training, basic modification or mechanical maintenance training, and specific task training.
The CMD training department is working with local county educational institutions to provide
some of the required basic training.
Since this program is a.
long term program and there are approximately 545 personnel to'
be trained all craft are not expected to complete the training until the end of 1993. To date approximately 100 personnel have completed all requirements through basic training. A continuing training /requalification program is being developed as part of this effort.
Several areas still exist where a lack of program and personnel
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training have contributed significantly to problems.
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management controls over the CMD and Transmissions Department i
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personnel, while performing activities at the site has been identified as one area that needs to be improved. This deficiency has resulted in the Transmission Department not setting safety-related relays to their proper setpoints and procedures being used by these personnel containing a lack of information to assure adequate interface with station operating personnel, in addition, training of CMD personnel has been
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identified as a second area that requires improvement.
A program, as discussed above, is in place to correct this condition.
However, several problems continue to occur such as,
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component removal from an incorrect unit and use of the polar crane over the transfer canal while fuel movement was in progress.
In the areas of containment leak rate testing, containment integrity, inservice testing (IST) of pumps and valves, and inservice inspection (ISI), the licensee's surveillance procedures were technically adequate and in conformance with requirements.
Staffing and training of IST and ISI personnel was adequate.
A strength was identified in the performance of IST on non-code required test of pumps and valves.
A violation was identified for the use of an incorrect ultrasonic testing calibration block while performing ISI activities.
Five violations were cited.
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Performance Rating Category: 2 3.
Recommendations None
D.
Analysis This fmetional area includes evaluation of activities related to the i.aplementation of the Emergency Plan and procedures, support and training of onsite and offsite emergency response organizations, and licensee performance during emergency exercises and actual events.
The licensee provided good management support to the Emergency Preparedness (EP) program and maintained adequately trained staffing levels for responding to an emergency.
Support to the EP program was evident from both corporate and site management, as evidenced by the quantity and quality of announced and unannounced drills conducted at the initiative of the licensee.
The licensee aggressively pursued emergency response readiness
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I through several unannounced drills as well as timely correction of identified problem areas.
The licensee had numerous exercise
drills which also indicated their eggressiveness in this area.
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Effective EP coordination and control was demonstrated during the preparation of the exercise scenario, the conduct of the annual NRC evaluated exercise, and the conduct of the exercise critique.
EP training was adequate as observed during exercise observation and inspection walkthroughs.
Three weaknesses were identified during the annual emergency exercise. These weaknesses were: inadequate demonstration of comand and control
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of fire fighting resources; untimely offsite notification due primarily to emergency communicator being unfamiliar with procedures, and failure to make timely emergency classification of a Site Area Emergency due to retrieval of seismic scratch
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plates not being accomplished which delayed upgrading the event, in February 1990 the licensee conducted a routinely scheduled
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emergency drill and adequate performance was demonstrated which indicated that the weaknesses previously identified were properly corrected.
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The independent audit conducted of the EP program had no audit findings or recommendations for the Oconee station. Management support for the program was evident by promptly implemented corrective action and closure of items from drills and exercises tracked on the Oconee Nuclear Station Commitment Index.
There was one emergency declaration (Notification of Unusual Event (NOVE)) during this rating period. On April 26, 1990 the licensee declared and terminated a NOUE based on a chemical spill in the pipe yard.
Sixteen gallons of a liquid chemical solvent (tetrachloroethylene and methylene chloride) spilled from a rusted 55 gallon drum.
The spill was contained and the affected soil cleaned up. -This event was properly classified
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and timely notifications were made.
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The licensee continues to maintain adequate emergency response facilities and equipment to respond to an emergency, including the Technical Support Center and the Operational Support Center.
Also completed during this assessment period was a new spacious and well designed Crisis Management Center which represented a significant upgrade in a key emergency response facility.
The licensee submitted six revisions to the Oconee Nuclear Plant Emergency Plan during this assessment period. One plan change was found to be consistent with NRC criteria. However, two contained Emergency Action Levels (EAls) that were inconsistent with NRC criteria and, subsequent to a management meeting on these issues, the-licensea revised the EALs. Two submittals are still under review.
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Three exercise weaknesses were identified during this period.
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Performance Rating Category: 1 3.
Recomendations None 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, enforcement history, staffing, effectiveness of training, and qualification.
The scope of this assessment also 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.
Authority and responsibilities associated with the security organization were clearly delineated and are effective. The site contract force is adequately staffed and appropriately trained and equipped. The Training and Qualification Plan is implemented on a continuing basis at all levels of the security organization using the onsite training staff.
During a recent inspection, innovative training practices were observed regarding tactical responses to contingencies.
By using a video i
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recorder as a training aid the licensee factors in realism for students practicing alarm response drills. The instructors, firearms range and training facility are considered a strength in the training program.
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.
Five revisions of the Security Plan were submitted to the Region during this period. With the exception of one revision, all were consistent with 10 CFR 50.54(p) and adequately coordinated.
The licensee's independent security prcgram audit covered various aspects of the site security program and the program auditors were thorough and well acquainted with licensee o
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comitments.
During the 1989 Audit the licensee's system for l
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trackir,g security commitments and action items was found lackirg.
Several issues such as a barrier repair and an upgrade that was to be completed during an outage had not been planned.
At f.he close of this evaluation period corrective action apptered te bi eficctive.
During the previous SA'.P period a concern with the licensee's capability to assess protected area alarms using closed circuit television was identtiied. While the licensee had begun to install structural supports for cameras located at the protected area barrier approximately half the perimeter zones still require physical assessment by security officers. Although no firm completion date has been established the licensees corrective actions are recognized during this assessment period.
The licensee has expanded its fitness foi' Duty program to meet the new 10 CFR Part 26. The licensee program of testing, and providing employer assistance was evaluated and determined to be meeting the objectives of the Rule.
Early in this assessment period the licensee experienced serious and repetitious access control failures.
This culminated in a terminated contractor entering the protected area and remaining
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onsite for several hours. A civil penalty was issued for numerous failures in badging, escorting, and vital area access controls. All violations issued during this assessment period related to failure to control access in some manner.
Of note during this period were improvements in the operation of the alarm stations and individual security officer performance.
Obvious management attention and closer supervision is being exhibited over the access co'. trol function.
The '4censee's attendance and participation at a NRC sponsored rity workshop and at the industry symposium reflect nitment to its safeguards program.
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One inspection in the area of Material Control and Account-ability was conducted to determine if the licensee's safeguards program was adequate.
The NRC found the licensee to be meeting all requirements relative to the possession of special nuclear material.
Four violations were cited.
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Performance Rating Category: 2 Improving 3.
Recommendations None
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F.
Engineering / Technical Support 1.
Analysis This functional area addresses activities associated with the engineering and technical support area including activities associated with the design of plant modifications, engineering and technical support for operations, outages, maintenance, testing and surveillance, procurement, and licensed operator training.
Overall engineering and technical support has been effective this assessment period.
Notable performance aspects include Design Engineering (DE) self-identification of design deficiencies and improved DE communications with the staff.
Communications between the plant and DE have improved.
In the previous assessment period this had been identified as a performance weakness.
This improvement has been a gradual development resulting from actions initiated during the last I
evaluation period, e.g. reorganization of DE and establishment l
of a DE site contingent. These actions increased the direct interface between DE and the plant staff. The on-site DE staff was routinely involved in daily plant meetirigs and activitics.
The off-site DE staff has also demonstrated an increased on site presence and involvement in plant activities.
DE is responsible for the ongoing Design Basis Documentation (DBD) program. The DBD is a comprehensive program to provide
accurate design base documentation on all safety related systems i
which will be readily available for design control activity.
This program involves a significant dedication of engineering resources.
The DBD has been completed for the Emergency
Feedwater System, Auxiliary Service Water System, 4160 Volt Switchgear, Keowee Structures, and the 230 KV Switchyard. The remaining systems are scheduled for completion by 1995.
The resolutions of licensee self-identified design deficiencies this assessment period have contributed to increased plant safety and reliability.
DE participates in the various processes to evaluate identified deficiencies.
DE activities-that have identified design deficiencies have been through
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reviews conducted as part of system operability evaluations DBD L
program, and the Self-Initiated Technical Audit. Among the l
deficiencies identified were the following:
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Single failure susceptibility of the electrical distribution system's Emergency Power Switching Logic Single failure susceptibility of the Post LOCA Boron Dilute System
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l Inadequate seismic rating of Reactor Building Cooler cooling water piping Reactor Building Spray system operability impact due to spray pump motor replacement Offsite grid degraded voltage impact on plant shutdown capability Inadequate incorporation of design information into electrical relay test procedures.
Proposed and completed corrective actions for the identified deficiencies has been timely and adequate to resolve the problems.
Interface with the NRC on these issues has been good.
Design change 10 CFR 50.59 safety evaluations were detailed, thorough, and technically adequate. Overall, the licensee has demonstrated effective control of the design change process.
Although DE plant support has been generally effective, minor performance concerns were identified: their involvement in the-plant corrective action program as indicated by inconsistent performance of operability reviews for Problem hientification Reports (PIRs). Some PIR were not reviewed for safety significance'in a timely manner. An additional concern occurring early in the assessment period related to interim drawing control and training for plant modifications. This area of concern was improving towards the end of the assessment period.
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A design deficiency _in the Penetration Room Ventilation System (PRVS) was identified by'the NRC-toward the end of this assessment period.
The_ deficiency related to several air-operat'ed valves that were incorrectly designed to fail closed on
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inss ef instrument air resulting in system inoperability.
Following' identification of this deficiency, the licensee was
timely in implementing interim corrective action and. initiating-
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a permanent resolution.
.DE had several' opportunities to identify and correct this deficiency, These opportunities
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included Instrument Air system revies
.n 1982 and 1984, a PRVS
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design study in 1957, and a review to address Generic Letter 88-14, i.e. impact on safety related equipment due to loss of n
instrument air.
Subsequent to the evaluation period escalated enforcement was issued for this identified deficiency.
Initial operetor licensing examinations were administered to'15 candidates.this assessment period. Six of seven Senior Reactor Operator (SRO)andeight.ofeightreactorOperator(RO)
candidates-passed.
Retake examinations were administered to one R0 candidate for the previous assessment period and the failed
SR0 candidate from this period, with both candidatas passing.
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The requalification program was rated as satisfactory.
Twenty-four operators were examined.
Eleven of sixteen SR0s and
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seven of eight R0s passed the examinations.
Failure of the SR0s
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was primarily due to event classification errors.
Six four-person crews received the dynamic simulator evaluation with four crews par. sing.
Eighteen of-twenty four individuals passed i
resulting in on overall pass rate of 75 percent, which is the i
minimum NUREG 1021 Operator Licensing Examiner Standards
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criteria for a requalification program rating of satisfactory, i
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The previous SALP addressed simulator deficiencies which
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impacted operator training program effectiveness.
The licensee
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has upgraded the simulator to resolve these deficiencies and to comply with ANSI 3.5, Nuclear Power Plant Simulator For Use In Operator Training, and 10 CFR 55.45(b) requirements.
One violation was cited.
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Performance Rating
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Category: 1 i
3.
Recommen'dations None G.
Safety Assessment / Quality Verification-
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Analysis This functional area addresses the licensee implementation of
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safety policies; activities related to license amendments, exemptions, and relief requests; responses to Generic Letters,
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- Bulletins, and Information Notices; resolution of safety issues
.(10 CFR 50.59 reviews); safety review committee activities; and use of feedback from-self-assessment programs-and-activities. -
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It includes the effectiveness of the licensee's quality i
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verification function in identifying and correcting substandard
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-or anomalous performance, in identifying precursors for potential problems, and in monitoring the overall performanca :,i j
the plant.
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s The licensee responses to the Generic letter on molded case
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circuit breakers, Safety Parameter Display Panel and Service j
Wa'er systems was more in scope than required. When addii %nal iniormation is required for any icsue, the appropriate Merical and/or management personnel'usually respond promptly and cooperatively. Corporate and site management are generally involved and knowledgeable of significant issues, j
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Although many of the licensee proposals and responses were well-prepared, accurate and thorough, such quality was not consistent throughout the assessment period.
Examples that demonstrate the continued need to improve quality of licensee submittals were: a proposed license amendment concerning electrical systems had so many non-technical errors it required a resubmittal; a proposed amendment to delete limits allowing operation with less than three Reactor Coolant Pumps failed to provide justification for this change; the licensee also failed to provide justification for a proposed amendment to increase the maximum linear heat rate for specified periods of fuel burnup; a submittal stating the licensee's intent to use a
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certain American Society of Mechanical Engineers (ASME) code i
case unless the NRC informed them otherwise, was contrary to l
regulations stating that use of code cases require specific NRC approval; and, a response to Generic Letter 88-14 on instrument air was inaccurate.
In addition, other submittals required requests for additional action because of incomplete or untimely submittals.
Examples of these included responses to the issue of tornado missile protection of the Emergency Feedwater (EFW)
system, submittals in support of licensing the Independent Spent Fuel Storage Installation (ISFSI), and licensee amendment for electrical system Technical Specification.
Two other examples of unacceptable and untimely responses were associated with the licensee reluctance to accept certain j
changes which the NRC determined were safety significant. These
included the installation of anticipated transients without l
. scrams (ATWS) modifications. and Technical Specifications
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associated with inadequate core cooling instrumentation. The.
reluctance to submit a design for the A.TWS modification resulted i
in the-inability of.the licensee to implement the modification
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on a timely schedule.
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l lhe licensee demonstrates a clear understanding of technical issues and carefully evaluates the impact and benefits of l
various NRC requests and positions on the plant. An example
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includes their response to Generic Letter 89-19 on safety
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' implications of control systems in which they recognized the safety improvements resulting from the recommended modifications and promptly submitted a design package for NRC review.
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second example was the analysis of proposed modifications of the
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f installation of cavitating venturis to prevent EFW pump runout.
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The analysis was thorough and indicated the modification could be susceptible to early failure which could result in the
inability of the EFW system to perform its safety function.
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i The licensee readily supports conference calls or meetings-when necessary to resolve issues. The licensee ensures that appropriate personnel are available and well prepared.
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Effective meetings were held concerning electrical system issues, cavitating venturk, design basis documentation and
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The Nucitar Safety Review Board (NSRB) provided independent
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review and oversight activities.
The NSRB membership and supportina sub-committees are composed of highly qualified
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individuais.
The NSRB also contains members from industry groups outside the utility.
Each of these individuals has been actively in.nolved in the overview of operations at the site and
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the supporting groups from other areas of the company. The
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Oconee Safety Review Group (0SRG) is an onsite support group for the NSRB that has the responsibility to independently assess abnormal incidents at the site. The OSRG is also responsible for the preparation of all LERs for the Plant Manager.
Both the NSRB and the OSRG have been instrumental in identifying root causes of problems which has allowed plant management to correct the problem to preclude recurrence.
The onsite Quality Assurance (QA) group has established a program to become performance oriented. To assist in this effort an experienced licensed SR0 has been assigned to this
. organization on a rotational basis. This has been a benefit to the identification and correction of operating and maintenance deficiencies.
Licensee Event Reports (LERs)'have been well developed, timely and contain required information to' identify root causes and describe corrective actions to preclude recurrence..
Supplemental reports are promptly submitted for changes in
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information or to report information unavailable in the original report. There were 37-LERs total for the three units, (including two voluntary LERs) which is considered to be a very low number for a~3 unit site during a period of 18 months.
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Seven LERs have been as~a result of the Design Basis Documentation program that is in progress._ If an incident is considered significant by the licensee, although not required to -
be reported a voluntary LER is submitted. The staff considers this a good practice which fosters good communication.
The licensee has implemented a program identified as Self-Initieted Technical Audits (SITA) under the direction of the QA.
department.- These audits are in-depth audits similar in scope and -process to the Safety System Functional. Inspections conducted by the NRC. These audits have been selected for various safety-related systems at all Duke Power Company -(DPC)
units. The licensee utilizes experienced personnel from-the various-groups to assist 1in these audits.
SITA' inspections have
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been completed for High Pressure Injection, Low Pressure Service Water, and the Emergency Power Switching Logics systems. The audits completed to date have been instrumental.in identifying and correcting a variety of system discrepancies.
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An inspection was performed to review procedures and quality records relating to construction of the Independent Spent Fuel i
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Storage Installation.
Requirements for construction of the facility.are specified in NRC Special Nuclear Materials License SNM-2503.
The construction procedures were technically adequate and in conformance with NRC requirements.
From review of the quality records, the inspector verified that the facility was constructed in accordance with requirements specified in the construction documents, and that Quality Control inspections were performed-as specified in License Conditions.
Three violations were cited.
2.
Performance Rating Category: 2 3.
Recommendations None-V.
Supporting Data and Summaries A.
Licensee Activities During this assessment period, Unit I completed a scheduled refueling outage of approximately 41-days duration..This unit experienced a i
reactor runback due to a main feedwater pump control circuit
. malfunction.
Several short duration (less than 4 days) forced
. outages or reductions in power occurred primarily due to oil. level problems in the reactor coolant pumps.
In addition, problems with a
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main steam line atmospheric dump valve, turbine control valve and
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main feedwater pump each resulted in short duration outages.
Unit 2 completed a refueling outage that was 45 days in duration.
-Two reactor runbacks occurred on this unit, one caused by a fault in the control rod drive system and the second caused by a dropped' rod.
Foreca outages and reduced power levels were caused by a turbine exciter ground and main turbine vibration, an oil. leak on a main feedwater pump, and an oil leak on a reactor coolant-pump.
Unit 3 completed a 44 day scheduled refueling outage during this
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assessment period. Although the outage concluded on December 18, 1989, problems with the generator exciter, field breaker and a main
feedwater pump delayed the return to 100 percent power for an
.I additional 10 day,
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A total of eight reactor trips occurred during this assessment period. One trip on Unit 1, three trips on Unit 2, and four trips on Unit 3.
Although this is higher than expected or desired, the causes appear to have been unrelated.
No significant pattern of root cause was determined and no extensive problems resulted due to any of the trips.
B.
Direct Inspection and Review Activities In addition to the routine inspections performed at the Oconee facility by the NRC staff, special inspections were conducted as follows:
- August 21-22, 1989; Special inspection to followup open items in fire protection.
- February 12-16, 1990; Special inspection to review licensee's corrective actions for the problems identified during the September 1989 annual emergency exercise.
- May 17-22, 1990; Special inspection conducted as a result of the overflow of the Units 1 and 2 spent fuel pool.
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C.
Management Conferences
' February 10,1989; Management Conference in Region 11 to discuss the operability of the,,eactor Building Cooling System dropout plates.
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February 22,1989; Management Conference in Region II to discuss Plant Performance and Improvement program.
April 21,1989; -Management meeting at the'0conee Nuclear Station to discuss the SALP Board assessment.
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May 25,1989; Management meeting in Region II to discuss the Duke
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Power Company Nuclear Plant Design Basis Documentation Program.
August 29,1989; Management meeting in Region'11 to discuss licensed
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operator medical. examinations.
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August 2941989; Enforcement Conference in Region II to discuss security issues at all Duke Power facilities.
November 8,1989; ' Enforcement Conference in Region 11.to discuss the
' program to control testing following maintenance and modifications on containment penetrations, e
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February 26,1990; Management meeting in Region 11 to discuss Emergency Action Level actions for Emergency Plans.
March 14,1990; Management meeting in Region 11 to discuss implementation of security program changes at all Duke facilities.
July 12,1990; Enforcement Conference in Region 11 to discuss design deficiencies associated with Penetration Room Ventilation System air operated valves.
D.
Review of Licensee Event Reports (LER)
During the assessment period 37 LERs were analyzed.
The distribution of these events by cause as determined by the NRC staff was as follows:
Cause Totals Unit 1 Unit 2 UNIT 3
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Component Failure
1
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Design
8
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Personnel Operating Activity
11
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Test / Calibration Activity
2
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Other
2
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Other
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2 Totals
23
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Notes: 1. With regard to the area of personnel, the NRC consid'ers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error, a
2. The Other category is comprised of LERs where there-was a spurious signal or a totally unknown cause.
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3. Two LERs were voluntary and not considered in this report.
Based on the NRC screening criteria, 11 of the LERs reviewed were classified as important.
Seven of-the LERs pertained to emergency'
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power and emergency power switching logic which.affected all units.
Many of those LERs address information identified from the licensee's in-depth technical audit and design basis verification programs. The
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remaining LERs of concern were associated with; a design inadequacy in a containment penetration in the Low Pressure Service' Water i
System; calculated failures of several motor operated valves to operate in a specific' accident condition; a. water hammer that-s,
occurred during a reactor-trip;.and, a reactor shutdown as the result j
of a dropped rod. The latter LER was a voluntary LER.
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The LERs generally described all the major 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. The reports were well written and generally provided the reader with information to readily understand the events.
Previous similar occurrences were referenced as appropriate.
The licensee submitted updates to the LERs when needed.
E.
Licensing Activities In support of licensing activities various communications are l
maintained with the licensee.
These consist of meetings, telephone and written correspondence. There have been approximately 198 active
. licensing actions for the Oconee units during this evaluation period of which 117 were completed.
Of these, 36 were license amendments.
F.
Enforcement Activity No. of Deviations and Violations in Each Severity Level Functional (Unit 1/ Unit 2/ Unit 3)
Area Dev.
V IV III II I
P1 ant' Operations 6/5/4 Radinlogical Controls Maintenance / Surveillance 4/5/5 Emergency Preparedness'
Security
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3/3/3 1/1/1 Engineering / Technical 1/1/1 1/1/1
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Safety Assessment / Quality 1/1/2-1/1/1
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Verification-
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1 TOTAL
_1/1/1 15/15/15 2/2/2
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A Severity Level III violation in the Safety Assessment / Quality Verification area was' issued on April 11, 1989, involving the failure to maintain two operable independent reactor building cooling unit trains. ($25K Civil Penalty)
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'1 A Severity-Level. III Security Violation was issued on December 21, 1989, involving repetitive failures to implement provisions of-the physical security program.
Examples were the. repetitive failures-to: assign correct security badges; control tailgating; properly escort visitors, and establish compensatory measures for degraded barriers and alarms.
($50K' Civil Penalty)
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G.
Reactor Trips During this assessment period the units experienced eight automatic reactor trips with power levels greater than 15 per:ent.
February 3,1989 - Unit 2 - A ground on a 125 VDC system caused
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by personnel error during the installation of a modification, in conjunction with an existing ground on a moisture separator reheater circuit.
February 4, 1989 - Unit 2 - A trip occurred while performing a
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routine test on the main generator turbine control system. The cause of this trip could not be determined. Although a specific problem could not be identified, management decided to replace both test switches since an intermittent problem with the switches could have caused this trip.
March 6,1989 - Unit 3 - A turbine trip / reactor trip attributed
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to a fault on the Jocassee Hydro Station buss lines. The exact cause of this trip could not be determined.
April 3, 1989 - Unit 2 - A trip occurred when a large bolt fell
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two floors in the turbine building and contacted a pressure switch which caused a loss of all Condensate Booster pumps.
This resulted in a loss of main feedwater pumps and an anticipatory reactor trip.
I August 10, 1989 - Unit 1 - A personnel error by an
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instrumentation technician while resetting Reactor Protection System setpoints resulted in two channels being taken out of I
service at the same time.
August 18,'1989 - Unit 3 - A' turbine generator / reactor trip
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occurred due to water making contact with the trip' circuits in the~ electro-hydraulic control cabinets.
January 19, 1990 - Unit 3 - A reactor coolant system low-
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l pressure signal generated as a result of a loss of power to control rod drive group six which resulted'in this-group dropping into the core.
March 3, 1990 - Unit 3 - A reactor coolant system high pressure
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H trip occurred due to a failed switch on a main feedwater block
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valve.
The switch caused a false signal to close the block
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valve resulting in a reduction of feedwater-flow to the generator, o
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