IR 05000280/1986023
| ML18149A479 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 12/11/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18149A464 | List: |
| References | |
| 50-280-86-23, 50-281-86-23, 50-338-86-22, 50-339-86-22, NUDOCS 8612230010 | |
| Download: ML18149A479 (75) | |
Text
ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-338/86-22 and 50-339/86-22 Virginia Electric and Power Company North Anna Plant Units 1 and 2 March 1, 1985 through August 31, 1986
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8612230010 861211 PDR ADOCK 05000280 Q
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~ *. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this informa-tio The SALP program is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulation The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on November 5, 1986, to review the collection of performance observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performanc A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at North Anna for the period March 1, 1985 through August 31, 198 SALP Board for North Anna:
R. D. Walker, Director, Division of Reactor Projects (DRP), RII (Chairman)
V. W. Panciera, Deputy Director, Division of Reactor Safety, RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII V. L. Brownlee, Chief, Reactor Projects Branch 3, DPR, RII L. S. Rubenstein, Project Director, PWR Licensing Division-A, NRR J. L. Caldwell, Senior Resident Inspector, North Anna, DRP, RII L. B. Engle, Project Manager, PWR Licensing Division-A, NRR Attendees at SALP Board Meeting:
A. J. Ignatonis, Chief,.Reactor Projects Section 3B, DPR, RII K. D. Landis, Chief, Technical Support Staff (TSS), DPR, RII R. P. Croteau, Project Engineer, Reactor Projects Seciton 3B, DPR, RI!
C. J. Paulk, Reactor Engineer, TSS, DRP, RII T. C. MacArthur, Radiation Specialist, TSS, DRP, RII I CRITERIA Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review perio Each functional area represents an area which is normally significant to nuclear safety and the environment and which is a normal programmatic are Some functional areas
may not be assessed because of little or no licensee activity or lack of meaningful NRC observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria was used to assess each functional area; however, the SALP Board is not limited to these criteria and others may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement hi story Operational and construction events (including response to, analysis of, and corrective actions for) Staffing (including management) Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are:
Category 1:
Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieve Category 2:
NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction quality is being achieve Category 3:
Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that mini ma lly satisfactory performance with respect to ope rational safety or construction quality is being achieve The functional area being evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of individual item The SALP Board may also include an appraisal of the performance trend of a fun ct i ona l are This performance trend wi 11 only be used when both a definite trend of performance within the evaluation period is discernible and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as:
.,
Improving:
Licensee performance was determined to be improving near the close of the assessment perio Declining:
Licensee performance was determined to be declining near the close of the assessment perio III. SUMMARY OF RESULTS Overall Facility Performance The North Anna nuclear power station is staffed and operated by knowledgeable and qualified personnel, especially first line managemen The corporate senior management involvement to improve quality and plant performance was evident by the licensee's use of such programs as the Nuclear Performance Monitoring where 34 performance indicators are trended on a monthly basis, implementation of Quality Maintenance Teams for improving maintenance activities, responsive-ness to NRC initiatives, and maintaining good communications with the NR Acceptable performance at the plant level was also observe The licensee's evaluation and resolution of technical issues was thorough and technically soun Some examples include licensee's prompt correction of a problems associated with the main steam safety valves, root cause evaluation and implemented corrective actions to the problem associated with the emergency diesel generators, and a high quality submittal of the Appendix R Reanalysis Effort and Exemption Request Strengths were identified in the functional areas of fire protection and licensing activitie During the SALP period the North Anna facility had high availability and unit capacity factors, fewer than the industry average safety system actuations and safety system failures, and a reactor trip rate that was comparable to the 1985 industry wide average (6 trips per unit per year).
However, for the performance i ndi ca tor of inadvertent automatic reactor trips, the licensee exceeded their own set goal of having no more than two automatic reactor trips per unit per ye~ For the 1986 time frame (January through August 1986), Unit 1 had six automatic reactor trips and Unit 2 had fiv The licensee recognizes this and is working with the Westinghouse Owners Group to reduce the number of reactor trip In the maintenance area, the NRC has noted that the corrective maintenance items backlog was not being efficiently reduce The licensee is cognizant of this and is trending the backlo Also, frequent identified reactor coolant system leakages were experience In order to minimize these events, more aggressive and effective corrective actions need to be pursue The licensed operator training program may need to be strengthened because the requalification program was found to be marginally acceptable based on the examination result In conclusion, the licensee is implementing new and innovative techniques to improve quality and performance in various disciplines of plant operations including the information.received from international
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5 agreement program Also, the licensee is working with INPO to complete their training programs accreditatio The performance categories for the current and previous SALP period in each functional area are as follows:
Functional Area Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Refueling/Outages Training Quality Programs and Administrative Controls Affecting Quality Licensing Activities I PERFORMANCE ANALYSIS Plant Operations Analysis Previous SALP Dates September 1, February 28,
1
2
2
1
2
Current SALP Dates 1983 March 1, 1985 1985 August 31, 1986
2
2
2
2
2
During the assessment period, inspection of plant operations were performed by the resident inspector and regional inspection staff The North Anna facility is staffed with a knowledgeable and professional management organization especially first line managemen Their involvement in the day to day activities of the plant is evident by the detailed instructions provided to the operations staff and their presence in the control room during the hours on sit One good ex amp 1 e of management support and involvement is the Check Operator program which was initiated in May of 198 This program involves choosing one of the more experienced operators whose function will be to observe day to day control room operations involving normal, abnormal and emergency operations and event The check operators will assess operator actions and equipment operation and report their findings and recommendations directly to the Assistant Station Manager for Operations and Maintenanc The operator chosen to perform this
function is very enthusiastic and dedicated to the program and appears to be very well received by the operations staff. Also, the Vice President of Nuclear Operations was observed to be aware, when necessary, of current. plant matters and plant management decisions, and is involved when necessar He visits the facility peri odi cal ly to observe and discuss p 1 ant activities and is visible to the plant's staf The VEPCO staff continues to provide the operations department with adequate support as evidenced by continued cooperation with the French and Japanese Nuclear Organizations and they are presently working on an agreement with the Swiss Nuclear Organizatio This cooperation involves trips to the various sites such as a recent trip to Japan by Virginia Electric and Power Company (VEPCO) engineers and technicians to review and assess the good aspects of the Japanese operatio It also involves having these organizations review VEPCO programs and make recommendations regarding improvement The introduction of the corporate Nuclear Operations Department month 1 y report ent it 1 ed 11 Nuc 1 ear Performance Monitoring Management Information Report 11 has provided trending information for management personnel in 34 different area Some of the areas are; Forced Outage Rate, Reactor Trips, Safety System Events, Personnel Radiation Exposure, Control Room Annunciators, Temporary Modifications, Quality Assurance Findings, et This monthly trending report is a valuable tool for management in assessing performance and identifying problem area Along with the report, the corporate staff, with input from the sites, has developed a Nuclear Operations Department Standards Manual providing the policies and standards by which both North Anna and Surry will operat This manual will provide a consistent mode of operation between the two sites and will allow the corporate office to evaluate the comparison of the performance indicators between the two site The plant operations staff response to reactor trips and other operat i ona 1 events has generally been very goo Fo 11 owing a reactor trip and prior to plant restart the licensee conducts a review of the operational event which incTudes human performance evaluation to determine human error cause During the assessment period, North Anna Units 1 and 2 experienced a total of nine and seven reactor trips, respectivel This converts to a reactor trip rate of O. 78 per 1000 cri ti ca 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (or 6 per year) for Unit 1 and 0.61 per 1000 critical hours (or 4.7 per year) for Unit The 1985 industry wide average was trips per year and the average rate of 1.04 per 1000 critical hours (6.8 per year) for Westinghouse plant For the 1986 time frame only (January through August 1986), Unit 1 experienced six automatic reactor trips and Unit 2 had fiv The licensee has
established a goal of having no more than two automatic reactor trips per unit per year. Thus based on the 1986 data, this goal was not me Out of the nine reactor trips for Unit 1, three trips were manual and six trips were automati The review of the reports submitted by the licensee indicates that two of the nine reactor trips were caused by personnel error and seven reactor trips were caused by equipment failure Of the seven Unit 2 reactor trips, one was a manual trip and the remaining were automatic trip One reactor trip was caused by personnel error and the others were caused by equipment failur The reactor trips are described in Section V.J. of this repor Based on the above data, the licensee 1 s performance in the area of reactor trips is comparable to the industry average when examined over the SALP perio For the 1986 ti me frame, the number of North Anna facility reactor trips exceeded the licenseers expectation and their set goal of having no more than two automatic reactor trips per unit per yea In fact, the number of reactor trips was considerably greater than that at the Surry facilit The licensee is cognizant of their performance in this area and is participating with the Westinghouse Owners Group for reduction of reactor trip Additional plant operational statistics observed during this SALP period are presented below:
012erational Parameters Unit 1 Unit 2 Unit Availability Factor(%)
86 Unit Capacity Factor - Design
77 Electrical Rating (DER)(%)
Forced Outage Rate(%).2 The North Anna Units 1 and 2 availability factor, the Unit Capacity Factor-DER, and the Forced Outage Rate compare favorably with the industry averages for 1985 which are 68.5%, 61.7%, and 11.3%, respectivel Thus, all of these indicators reflect an index of merit which is better than the industry averag Also, when evaluating th~ performance indicator of forced outage rate averaged over four quarters with the last one ending the second quarter of i986, both North Anna units performed above the industry averag Plant operations have been interrupted on sixteen occasions due to Technical Specifications required shutdown Most of these shutdowns involved greater than the Technical Specification limit leak rates inside Containment or Emergency Diesel Generator (EOG)
failure The licensee has experienced EOG degradation and EOG failures at the North Anna facility in 1985 and early 198 These
problems were of a significant concern that resulted in management meetings with the licensee to discuss their engineering evaluations for the root cause determination and proposed corrective action The EOG engine failure mechanism was piston wrist pin bushing elongation primarily due to EOG piston overload and inadequate lubricatio The corrective actions included reduction of fast, cold starts and loadings, engine oil (lube oil) changeout, and increased surveillanc The oil was changed in March 1986 followed by a 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> demonstration run of the EOG; no evidence of any significant bushing elongation was observed after the * end of the EOG ru The root cause was adequately identified and no further problems have. been encountered to dat The operational information provided by the licensee in Licensee Event Report (LER)
Submittal was brief and accurat An evaluation of the content and quality of a representative sample of LER 1 s was performed by the NRC using a refinement of the basic methodologies presented in NUREG/CR-4178, March 198 The results show that the North Anna LERs have an overall average score of out of a possible 10 points, comp a red to a current industry average of 7.9. The principle weaknesses identified, in terms of safety significance, involve the requirement to provide an assessment of the safety consequence of the event and the requirement to identify failed componets in the tex One strong point identified by the report are the well written discussions concerning the failure mode, mechanism and effect of failed component Early in the assessment period some 10 CFR 50.72 immediate notifications were not telephoned to the NRC within the required limits. This was discussed with licensee management as documented in inspection report 50-338/85-18 and 50-338/85-1 The problem was one of interpretation and licensee management did agree to use the -NRC interpretatio Immediate Notifications, together with their updates, did not always agree well with the event descriptions in the Monthly Reports and sometimes components w~re not identified in sufficient detail to tell if the same components were failing in similar reported event On two occasions, Immediate Notification of forced rampdown to 0% power did not appear in the Monthly Repor However, both the Immediate Notifications and LERs indicate the licensee took appropriate action with regard to reportable event Control room decorum continues to be very well maintained. Access to the contra l room during the periods of shift turnover is *
restricted to operations personnel onl At all other times personnel other than operations personnel must get permission from the Senior Reactor Operator (SRO)
to enter the designated controlled are Licensed Operators wear distinctive clothing to aid in distinguishing their function in the control roo The
Shift Supervisor's office is presently in the Technical Support Center (TSC) where he screens and processes a 11 paper work associated with the maintenance, surveillance and operation of the plan This minimizes the number of non-operational personnel in the control room and gives the shift supervisor good knowledge and control over activities which could affect plant operation. Shift clerks are assigned to each shift to help the Shift Supervisor, Assistant Shi ft Supervisor and Reactor Operators with administrative task Early in the assessment period plant housekeeping and cleanliness was averag However, the licensee has started an aggressive new program to upgrade the overall plant appearanc This program involves extensive painting and labeling in the plant. Along with the painting, the licensee will be providing uniforms for all the plant staf The main goal of the program is to establish a feeling of pride and professionalism among the staf Staffing in the operations department is adequat The licensee's goal to have six shift coverage has been delayed until sometime in 1987 due to the most recent licensed operator exam result Although the violations listed below did not indicate a programmatic weakness and covered several areas of responsibility, they generally reflect personnel failures to follow procedure Four violations and one deviation were identified during the assessment perio Severity Level IV violation with two examples; one for failure to have an adequate procedure to ensure design criteria for the auxiliary feedwater pump was not exceeded and the other for failure to follow procedures and provide mechanical danger tags as require (85-26-01) Unit 1 onl Severity Level IV violation for failure to fo 11 ow procedure and perform a required safety evaluatio (86-17-03) Unit 1 onl Severity Level V violation with 2 examples for failure to follow a valve lineup procedure and failure to follow a danger tagging procedur (85-03-05) Severity Level V violation with examples for failure to follow procedures (85-16-02). Deviation for failure to properly use to governor valve limiter as a load limite.
Conclusion Category:
Trend During This Period:
Improving Board Recommendation The frequent (approximately 8 occurrences that required shutdown)
high leakage rate problem is an issue which must be aggressively pursued by the licensee managemen Also, the licensee needs to be more attentive to fo 11 owing procedure Emergency Di ese 1 Generator problems were of a significant concern in the earlier part of the assessment period; however, after extensive evaluation by the licensee the root cause was identified and the problem appears to be resolve No change in the level of NRC staff resources applied to the routine inspection program is recommende Radiological Controls Analysis During the assessment period, inspections of radiological controls and chemistry were performed by the resident and regional based inspectors, including a confirmatory measurement inspection using the Region II mobile laborator The licensee's health physics (HP) staffing level was adequate to support routine operation During refueling outages, extensive use was made of contract HP technicians to supplement the permanent staf Efforts were underway to increase the size of the onsite technician staff, and to add additional persons to the technical staff in order to reduce their reliance on contractor personne Personnel exposure during the evaluation period was approximately 380 man-rem per reactor in 1985 which was below the average (425 man-rem per reactor) for U. S. pressurized water reactors (PWRs).
Through March 1986, 415 man-rem ( 208. man-rem/reactor) had been expended against a projected total for the year of 458 man-re Due to an unplanned outage, the man-rem estimate for the year was revised to 790 man-rem, 760 of which have been expende Management support and involvement in matters related to the radiation protection program were not always sufficient to ensure implementation of a strong progr.am for maintaining the occupational dose as low as reasonably achievable (ALARA).
This was exemplified by poor attendance at ALARA Committee Meetings by members from crafts which routinely account for a large proportion of the station's exposure. This was brought to the licensee's management attention during a January 1986 inspectio The licensee had dedicated only one individual to the station ALARA program, and as a result, minimal time was available for prejob planning and postjob reviews for the 1985 and 1986 refueling outage Examination of postjobs reviews for jobs exceeding original dose estimates by 25 percent showed them to be cursory in that they lacked information which would permit future avoidance of encountered problem The collective dose for the outage was approximately 600 man-re Although the licensee exceeded the coll~ctive dose estimates for
the fall refueling outage which lasted 48 days, by approximately 100%, at the time of the last inspection (No. 86-07) the licensee had not identified the reasons for the overag One strength noted in the health/physics program was the stability of the health physics technician staf The low attrition rate has resulted in a more experienced group of individuals and has provided the time necessary to implement an effective and continuing training program for the technicians. Audits performed by the corporate health physics staff and by the quality assurance group for the radiation protection program were adequate in scope and depth to identify problems in the areas reviewe Timely corrective actions were taken and documente During 1985, the licensee had completed development of a formal training and qualification program for radiation protection technician The program was submitted to the Institute of Nuclear Power Operations for accreditation, which was achieved in June 198 Implementation of the radiation protection program by the licensee was, in general, adequate in the area of radiological evaluation However, one violation was issued for failure to evaluate the beta radiation levels present in the steam generators prior to personne 1 entry during the 1986 refue 1 i ng outag A second violation in the area of radiological evaluation was made with dose rates on the extern a 1 surface of the package in excess of regulatory limit This resulted in a Severity Level III violatio In both instances, judgmental error and lack of attention to deta i 1 by first 1 i ne HP supervision contributed to the violatio The respiratory protection appeared adequate in that no violations were identified during the assessment perio During the assessment period, no overexposures~ either internal or external, were identifie In general, internal exposures were lo The licensee's approach to resolution of radiological technical issues has generally been adequat In the area of radiological confirmatory measurements, during participation in the NRC's spiked sample program in 1985, disagreement in measurements for two nuclides was observed while in 1986, no discrepancies were note The licensee demonstrated agreement with the Region II mobile laboratory measurements except for a discrepancy in calibration for the particulate filter*
geometry which led, in part, to a violation issued during the assessment perio The licensee submitted the required effluent and environmental reports during the evaluation perio The total quantity of radioactivity in the licensee's gaseous releases were less than
the average releases reported by 14 Region II plants of similar size and type for 1985, but the liquid releases were greater than averag Both liquid and gaseous effluents were within regulatory limits for quantities of radioactive material released and for dose to the maximally exposed individua For 1985 releases, the maximum calculated total body dose to a member of the public was 1.26 mrem from liquid releases and 1.37 mrad from gaseous effluents. These calculated doses represented 5.0 percent and percent of the 40 CFR 190 whole body limit of 25 mrem/yea Although there were several small unplanned releases of radioactive material in gaseous and liquid effluents, there were no unplanned gaseous or liquid releases above limits required to be reported to the NRC during the evaluation perio No adverse impact due to the plants 1 operation was detected by the radiological environmental monitoring progra The total quantity of radioactivity in gaseous and liquid releases is tabulated in Section V.K. of this report. *
During the assessment period, it was noted that an improvement in chemistry control was being achieved through reduction of inleakage, improvement of the condensate cleanup system, and implementation of the Steam Generator Owners Group guideline Additional plans called for further upgrading of the design of the secondary water cycle, rep 1 acement of copper-a 11 oy feedwater heater tubes, and improvement of the blowdown recovery system. A comprehensive online analytical monitoring system is being installed as part of a new steam generator protection program in conjunction with Westinghous Management involvement in improvement of chemistry controls was eviden During the assessment period, the 1 icensee tracked the square footage of the p 1 ant that was maintained as contaminate On January 1, 1985, approximately 20,675 square feet of the plant was maintained as contaminated whereas as by January 1, 1986, this area had decreased to 16,687 square feet or six to seven percent of the Auxiliary Buildin As of September 1, 1986, total contamination areas were approximately 15,000 fee During 1985, the licensee made 61 shipments of radioactive waste consisting of 23,423 cubic feet (11,711 cubic feet per reactor) of waste containing 290 curies of activit This amount was approximately the same as the national average for PWRs of 11,650 cubic feet per reacto Three violitions were identifie Severity Level III violation for failure to maintain dose rates on the external surfaces of transport packages below regulatory limit (86-07)
13 Severity Level IV violation for the failure to evaluate the beta radiation levels in steam generators 11A 11 and 11 C 11 prior to initiating maintenance activitie (86-07) Severity Level V violation for failure to maintain adequate procedures to ensure accurate radiological survey (85-25) Conclusion Category: 2 Board Recommendations A return to the routine inspection program is recommende Maintenance Analysis During the assessment period, inspections were performed by resident and regional inspection staff Despite the identification of a concern involving a large backlog of outstanding maintenance items in the last assessment period the present backlog, as of August 31, 1986 is 5,257 open maintenance work orders which is still very large. The maintenance work order backlog breaks down to the following:
1461 items are described by the licensee as programmatic; 1,533 items have been reported to be complete but the paperwork has not been reviewed to verify completion; 1,318 items can be worked during any mode of operation; and 945 items require unit shutdown before they can be worke This backlog is indicative of a problem in the area of completing identified maintenance work i terns; however, it a 1 so indicates a good program in the area of equipment problem identificatio The practice of identifying equipment problems should continue but the licensee's performance in closing out identified maintenance items shows a need for improvemen The licensee has taken action to reduce this backlog by hiring additional contractors to aid in closing out some of the item This action caused a reduction in the total number of outstanding maintenance work orders but at present no significant reduction in safety-related maintenance work orders was observe The continued existence of a large number of outstanding maintenance work orders and the need to hire additional contractors indicates that resources devoted to the performance of maintenance items may not be sufficient. A weakness 1n this area was exhibited by the examples given belo The failure to promptly execute certain outstanding work orders have contributed to operational difficulties such as the failure of an Emergency Diesel Generator due to a lube oil line ruptur l
The area where the rupture occurred had been previously identified as havin~ a leak a month earlier and was tagged with a maintenance work order. Another example occurred on May 29, 1986 when Vi ta l Bus 1-I was transferred to its alternate source of power which is a sola transforme This transformer is not an uninterruptable source of powe The transfer was performed because the normal supply battery charger exhibited ampere fluctuation Even though the alternate supply of power is acceptable, the preferred source of power is the battery charger and inverter because it has the station battery as a backu No work was performed on the battery charger and three days later on May 31, 1986, the sola transformer failed, de-energizing the Vital Bus 1-I, and resulting in a reactor tri Both units have experienced a large number (8) of Technical Specification shutdowns due to the leakage inside of containment exceeding the Technical Specification limit The leaks were in valves of the reactor coolant system, the charging system, and in the Unit 1 reactor vessel head 11011 rin Another specific example was of a leak i dent ifi ed on valve 2-RC-6 which re qui red unit shutdown on April 18, 198 The leak was stopped using Furmanite; however, leakage from valve 2-RC-6 again resulted in a shutdown on July 25, 1986, when again the leak was repaired with the use of Furmanit The repetitiveness of reactor cool ant system leaks, even though they are of relatively low magnitude, is indicative of inadequate or ineffective corrective actio *
Review of the selected performance indicators (Pis) such as safety system failures, forced outage rate, and equipment forced outages per 1000 critical hours shows that the performance of both North Anna units was above average in performance when compared to the industry mea In one case, the Unit 1 PI for equipment forced outages per 1000 critical hours showed it to be at the industry mea The data was analyzed over four calendar quarters with the last one ending the second quarter of 198 However, when comparing the PI of equipment forced outages per 1000 critical hours against the plant's performance over four quarters, a declining trend was note In conclusion, the Pis reflect acceptable maintenance practice at the North Anna facility when it is compared to the industr Management involvement in maintenance programs is evident by the observation of the licensees implementation of such programs as the use of MOVA TS equipment, Chesterton valve packing, Visual*
Information Management System, and incentive maintenance agreements with contractors where incentives are proposed for exceptional work and reduced pay for poor wor Al so, the licensee continued to evaluate new approaches to improving the quality of maintenanc One new approach was the initiation of the 11Quality Maintenance Teams 11 concept in 198 This concept establishes a highly trained team of maintenance personnel who are
given special training in the areas of preplanning, and electrical maintenance, mechanical maintenance, qua l iti assurance, and hea 1th physic They then are assigned jobs which they accomplish as a tea The mission of the team is to perform all work assigned in a high quality manner without the involvement of additional support staff in the areas of health physics coverage and quality control inspection The development of the quality team concept includes a formal training program which provides instruction in the fundamentals of the team approach, problem solving techniques, quality control training and inspector certification and advanced radiation worker trainin Quality Maintenance Team members received high visibility and several team members recently participated in an information exchange visit to nuclear plants in Japa Maintenance activities undertaken were observed to be well organized and planned by the planning departmen Maintenance work schedules demonstrated evidence of prior planning and the assignment of priorities by management, however, these priorities were subject to change as evidenced by a backlog of priority one and two safety related work order Problems were identified in the areas of work reviews, maintenance of work records and performance of acceptance test These problems were especially evident in the performance of design change packages which resulted in Violations a., b., and numerous inspector comments about discrepancies in completed and reviewed design change packages for Station Battery replacemen Violations c. and are examples of poor quality assurance and inadequate reviews of completed maintenance procedure Violation d. was identified by the NRC as a repeat violation from the previous assessment period indicating that the licensee's previous corrective action was not sufficient to prevent reoccurrenc Also, portions of violations a. and c. addressed in the functional area of Plant Operations involved problems in the maintenance area where licensee personnel failed to follow procedure The computer tracking system is beginning to be used more effectivel At the request of the inspector, the licensee developed a means of listing only the outstanding safety related maintenance work order The licensee is also modifying procedures to require the superintendents of the other disciplines to have a better understanding of how the system works and become more involved with the decision making process for determining which items are worke In the near future the licensee plans to institute a procedure requiring the superintendents and the Assistant Station Manager for Maintenance and Operations to meet twice a month to review the outstanding work and maintain a list and schedule of a 11 i terns to be worked in the event of an unplanned outag The licensee is also working towards setting up the system so that when a major component becomes available for
maintenance, the computer can be used to generate a list of all maintenance items related to that componen The operations staff (e.g. licensed operators) are performing system walk downs so that priorities can be properly set on the present list of outstanding maintenance work orders in an attempt to ensure that the important maintenance receives top priorit The operation staff has designated an SRO as the Operations Maintenance Coordinato One of the coordinator duties is to track and ensure that the number of alarmed annunciators in the control room is reduced to the absolute minimu Even though the number is smaller than the last assessment period, it still remains significan Four maintenance violations were identified during the assessment perio Severity Level IV violation for failure to provide an adequate design change procedure resulting in the imp roper installation of a safety related piece of equipment (85-36). Severity Level IV violation for failure to follow a design change procedure for determining corrected specific gravities for the station batteries (86-13). Severity Level V violation for failure to follow procedure and sign for work completed in a Mechanical Maintenance Procedure (85-11). Severity Level V violation for an inadequate review of procedures for Reactor Trip Breaker Maintenance (85-11). Conclusion Category:
Trend During This Period:
Declining Board Recommendations Licensee management attention should be devoted to not only to reducing the total number of work orders but also expediting priority item Also, the licensee management needs to increase emphasis on the correction of valve leakag Greater management attention is needed to determine root cause and adequate *
correction of equipment malfunctio On the positive side, the Board was pleased to note licensee's implementation of new
techniques to improve performanc~ and an innovative approach in using Quality Maintenance Team No change in the level of NRC staff resources applied to the routine inspection program is recommende Surveillance Analysis During the evaluation period, inspections were performed by the resident and regional inspection staff Several strengths and weaknesses were observed in the surveillance are The strengths included the successful power upgrade, core performance and startup test areas, staff additions, the resolution of the main steam safety valve problem, and the snubber surveillance progra Weaknesses observed included survei 11 ance tracking, poor handwritten procedures, inconsistencies in procedures, and discrepancies between the Technical Specifications (TSs) and the Final Safety Analysis Repor Reactor core performance and startup testing areas were inspected by the regional staf Surveillance procedures used prior to, during and following initial, post-refueling, criticality to confirm proper operation of systems disturbed during refueling or to confirm core design parameters were generally of the technical quality and detail for data collection and analysis usually encountered in Region II facilitie The procedure developed to measure the moderator temperature coefficient at power is superior to those in use at other facilitie However, its implementation in one case was poo The test results did not meet expectations, and the test was judged to be a failur The cause of the test failure was not fully determined or evaluate Further, a retest was not rescheduled within a reasonable period of time to justify continued operatio This issue is currently being reviewe Improvement in the areas of staffing and training indicate management involvement in the control and quality of the surveillance progra The addition of an Inservice Inspection (IS!) staff consisting of a supervisor and several engineers and technicians is an example of the increased staffin An item of concern in the previous evaluation period was the experience and knowledge level of personnel in the surveillance and test sectio The number of personnel in this section has increased by three, two of which had previous experienc The experience level has increased by the additional time on the job since the last evaluation perio To enhance the surveillance and test section's knowledge of plant systems, industry codes and standards and TS requirements, the licensee has developed a training program
consisting of 17 different training module As of August 31, 1986, half of the surveillance test group had completed 12 of the 17 module Plant management was responsive when a Main Steam Code Safety Valve (MSRVs)
setpoint drift problem was encountere The setpoint drift problem was identified by the licensee during surveillance testing, corporate management responded by contracting an independent test lab to repair and reset the MSRV In addition, corporate personnel were sent to the lab to witness maintenance and testing on the valve The licensee's decision making is at a level that assures adequate management review and corporate management is usually involved in site activitie A review of the documentation associated with the MSRVs indicated the records were complete, well maintained, and availabl In conclusion, the licensee's resolution to this issue was timely, viable, and soun An inspection by the staff of the licensee's snubber surveillance program i dent i fi ed * no vi o 1 at ion Management involvement and control in assuring quality was evident based on the results of the overall review of the North Anna Power Station Snubber Surveillance progra A previous review was conducted in April-May 1984 when problems (which resulted in a Civil Penalty)
were i dent ifi ed by NRC with the Surry Power Station Snubber progra The inspection during this assessment period identified that previous deficiencies in the North Anna program identified during the previous review were corrected through issuance of a new procedur The corrective action to resolve the deficiencies was timely, sound and thorough, and acceptable to NR Records of snubber surveillance activities were complete, legible, well maintained and easily retrievabl Staffing and training of snubber surveillance personnel was adequat The direct responsibility for ensuring that TS surveillances are performed correctly and within the required time frames has been delegated to the supervisor in charge of the section responsible for performing the surveillance. The surveillance and test group still tracks the performance of surveillances to ensure that they are performed with the required time frame but the direct responsibility now rests on the specific superviso Since the supervisor of the section performing a survei 11 ance has direct control over when a surveillance is completed, this change should help alleviate problems related to exceeding TS surveillance frequency requirement The licensee's approach to the resolution of technical issues from a safety standpoint was demonstrated recently by the successful performance of a power upgrade in Unit Surveillance calibration procedures were changed to reflect the new 100% power l~ve The licensee conducted instrument calibration using these
-
procedure changes to adjust the set points for the control and protection instrument These calibrations were conducted -With the unit operating at power and allowed the increase in core thermal power to the new 100% level without shutting the unit dow This operation was completed without any problems or transients occurrin Also during this evaluation period the licensee developed and issued a TS surveillance cross reference procedure designating which plant surveillance procedure accomplishes the specific TS surveillance requirement. This cross reference procedure not only helps in determining which specific licensee procedure is associated with which TS surveillance requirement but it also serves as a check to ensure that all TS surveillance requirements are being addresse In the previous evaluation period the licensee demonstrated a weakness in the area of implementation of new TS surveillance requirements generated from approved TS amendment To alleviate this problem the licensee utilizes a Computer Tracking System (CTS)
to monitor the progress of changes to surveillance requirements generated by TS amendment The system seems to be working to date and its effectiveness will be determined through additional tim The inspector has noted, however, that the licensee does not always place emphasis on preparing procedural changes in advance which would ensure that surveillance procedures were ready and properly conducted once the TS amendment is approve The licensee also utilizes the computer system to keep track of surveillance performanc The computer system is limited to only having positive control over surveillances which have a month or greater time interval requiremen Surveillances which have to be performed on a schedule of less than a month are tracked manuall There have been problems associated with this manual tracking method, as demonstrated by violation d., where the seven day plus 25% grace period TS requirement was exceeded due to a scheduling erro Also if not properly utilized the computer system will not ensure that surveillance test frequencies are met as demonstrated by violation The inspectors identified a concern associated with hard to read hand written procedure change These changes were issued for use until the final typed written ones were availabl The backlog of procedures awaiting final typing was excessive and the quality and condition of the hand written procedures was very poor. Violation c. was directly attributable to a hard to understand hand written procedure chang This situation has been discussed with the licensee on several occasions and documented in inspection reports 338,339/85-18, 338/85-22 and 338,339/85-3 The backlog of procedure changes awaiting fi na 1 typing has not been reduced substantially; however, the licensee has taken the position that only acceptable hand written changes will be approved for us The inspectors identified concerns relating to inconsistencies in surveillance procedures especially in the area of safety related batteries and hydrogen recombiner These inconsistencies consisted of differences between the same procedure for different units, differences in the procedures and TS requirements, failure to have acceptance criteria or perform an evaluation on recorded data and difference in vendor specifications and surveillance procedure These inspections resulted in violation a. in this functional area and violation b. in the maintenance section, both related to safety related battery testin The inspectors also identified a few cases where discrepancies existed with the TS and Final Safety Analysis Report (FSAR)
requirement The first examp 1 e i nvo 1 ved a TS requirement to inspect the cell plates of the diesel fire pump batter These batteries are in solid black cases and cell plate inspection is impossibl The licensee has submitted a TS change to correct this discrepanc The second example deals with the TS requirement to perform a surveillance on the hydrogen recombiner The performance of this surveillance requires manual containment isolation valves to be open which would cause a violation of the TS requirements for containment integrity if this surveillance is performed with the unit in modes 1, 2, 3 or The last example deals with a FSAR requirement for instrumentation calibration accuracy to be within +/-
0. 5% for verifying and setting the overpower setpoint. The inspectors discovered that the alternate feedwater temperature instrumentation had a calibration accuracy of+/- 3%.
This feedwater temperature instrumentation was to be utilized for the calorimetric calibration only if the computer feedwater temperature instrument input is lost. The licensee has not had to use the alternate feedwater temperature instruments and has taken action to ensure that they will not be use Another area the regional staff specifically reviewed was the measuring and test equipment (M&TE) progra The M&TE program met regulatory requirements except that envi ronmenta 1 conditions had
' not been established in the electrical and physical work sho Violation f. was issued for this discrepanc Finally violations a., b., and f. are examples of failure to follow procedures and vendor recommendation Six violations were identified during the assessment perio Severity level IV violation for failure to properly conduct surveillance requirements of TS on the station batterie (85-12-04) (Unit 2 only) Severity level IV violation for failure to follow procedure for testing the emergency diesel generato (86-04-01)
(Un it 2 on 1 y)
21 Severity Level IV violation for failure to comply with Technical Specification Limiting Condition for Operation Action Statement of RVLIS operabilit (85-22-01) (Unit 1 only) Severity level V violation for failure to surveillance requirement in the allotted time (85-18-02)
perform interva Severity level V violation for failure to comply with TS surveillance frequenc (85-19-01) (Unit 1 only) Severity level V violation for failure to establish proper environmental controls for the calibration of Maintenance and Test Equipment (M&TE).
(85-19-02) Conclusion Category:
2 Board Recommendations Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effectiv NRC attention should be maintained at normal level No change in the level of NRC staff resources applied to the routine inspection program is recommende Fire Protection Analysis During this assessment period, inspections were conducted by the regional and resident inspection staffs of the licensee's fire protection and fire prevention program including the implementation of the 10 CFR 50 Appendix R requirement The Region's Appendix R inspection of North Anna, conducted in September 1985, reviewed VEPCO's revised Appendix R safe shutdown and related fire protection reana lyses, commitments which were sent to the NRC May 1, 1984 and March 8, 1985, and the Appendix R related plant modification The Region's inspection identified several unresolved items which are being reviewed by the NR These items, along with VEPCO's revised Appendix R analysis, are currently under review by the NCR Staff (NRR).
Upon completion of this review and issuance of a Safety Evaluation Report, Region II will conduct another inspection to verify compliance with the NRC requirement The licensee has issued procedures to implement the normal plant fire protection program for the admi ni strati ve contra 1 of fire hazards within the plant, surveillance and maintenance of the fire protection systems and equipment, and organization and training of a plant fire brigade. These procedures were reviewed and found to meet the NRC requirements and guideline The staff inspections reviewed the licensee's implementation of the fire protection program and administrative control General housekeeping and control of combustible and flammable materials were satisfactor The fire protection extinguishing systems, detection systems and fire barriers and fire barrier penetrations were found to be in service with one exception. A number of cable penetrations through fire barriers were found which did not conform to the FSAR and tested design in that the 11cerafiber 11 or 11 cerablanket
damming materials had been removed from the penetrations. This was identified as a deviation. Otherwise, the survei 11 ance inspection and tests and maintenance of the fire protection systems and features were satisfactor Organization and staffing of the plant fire brigade appear to meet the N'RC guideline The training and drills for the brigade members meet the frequency specified by the procedures and the NRC guideline The management involvement and control in assuring quality in the fire protection program is evident due to the involvement in the site fire protection program and the issuance and implementation of fire protection procedures that meet the NRC requirements and guideline The licensee's approach to resolution of technical fire protection issues indicates an understanding of issues, and is sound and timel The responsiveness to NRC initiatives are technically sound and thorough in most case Fire protection related violations are rar However, when violations do occur, effective corrective action is promptly take Licensee identified fire protection related events or discrepancies are properly analyzed, promptly reported and effective corrective action is take Staffing for the fire protection program is adequate to accomplish the goals of the position within normal work hours and only occas*ional overtime or backlog of wor Fire protection staff positions are identified and authorities and responsibilities are clearly define Personnel are qualified for their assigned duties. The fire brigade training program is adequately defined and implemente The number of. trained fire brigade members is adequate to meet the minimum of five brigade members per shift as required by the Technical Specification The following deviation was identified:
Deviation i nvo 1 ved with severa 1 conduit fire stop pen et ration seals through fire barriers not installed in conformance with the approved tested configuratio (85-24) Conclusion Category:
1 Board Recommendations Licensee management attention and involvement are aggressive and orientated toward nuclear safet The board recommends that NRC staff resources applied to the routine inspection program be reduce Emergency Preparedness Analysis During the assessment period, inspections were performed by the r~sident and regional inspection staffs. The inspections included two routine emergency planning inspections, one reactive inspection assessing the licensee's classification of a
Notification of Unusual Event, and observation of one full participation and one partial participation emerg~ncy exercis The routine inspections and exercises showed that the licensee had the capability to detect and classify emergencies, notify appropriate offsite agencies, assess plant conditions and project offs ite consequences, and make appropriate protective action recommendation Although no violations were identified during this assessment period, the licensee's demonstration of its ability to adequately implement the emergency plan and procedures during the 1986 annual emergency exercise showed the need for improvement The 1986 emergency exercise did not meet all objective The exercise did not demon st rate the ability to evacuate non-essential personnel from the site and the ability to make a full transition to the recovery mod However, exercise players demonstrated knowledge of applicable procedures in these two area In addition, the licensee noted that, because of a misunderstanding, the offsite rescue squad did not participate in the exercis The licensee committed to run a medical drill promptly to demonstrate this capabilit During the 1986 exercise, NRC inspectors observed that the licensee did not demonstrate a clear assignment of responsibility for communicating protective action recommendations to offsite agencie Although the Emergency Plan specifies that this is a nondelegatable re spon s i bi 1 ity of the Emergency Manager, the Recovery Manager assumed this responsibility during the exercis In addition, NRC inspectors observed that field monitoring data was not fully
considered in the development of protective action recommendation This did not result in inappropriate recommendations during the exercise, but indicated a need to assure such consideration was included in the futur The licensee has conducted a thorough critique as indicated by identification of additional 23 findings for followup as part of their exercise observation and critique progra The licensee committed to take action on these finding No violations or deviations were identified during the assessment perio.
Conclusions Category:
2 Board Recommendations No change in the level of NRC staff resources applied to the routine inspection program is recommende Security and Safeguards Analysis During this evaluation period, routine inspections were performed by the resident and regional inspection staff Corporate and site management have continued to support the security program; however, since the last SALP rating period, the North Anna Power Station has been cited for two Severity Level III and one Severity level IV violations for physical security related event One Severity Level III violation resulted from allowing an authorized individual to enter the protected area without being challenged, identified, searched, or badge A second Severity Level III violation was caused by the licensee 1 s failure to control a path from the owner controlled area to the protected are The Severity Level IV violation resulted from the licensee 1 s failure to notify the Nuclear Regulatory Commission of changes to the protected area perimeter, within the required 60 day time perio While the identified violations reflected deficiencies in the area of access control and administrative oversight, the licensee has continued efforts to eliminate security personnel errors, provide improved procedures, and renovate access portal hardwar During the most recent security inspection the licensee 1 s enforcement of access controls received extensive review and resulted in no violations being identifie The licensee's security program as established and maintained has conformed with commitments contained in approved physical security, contingency and training and qualification plans with the exception of the areas note Inspector observations and findings indicated that the licensee 1 s approach to technical issues related to physical security program commitments were sound, conservative and thorough in most case However, errors in performance and lack of adherence to requirements by responsible employees detracted from levels of performance previously note The licensee has a well established and aggressive hands on performance training program rather than a written examination type progra The violations noted below were not indicative of the total effectiveness and proficiency of the security program at North Ann The violations identified were as follows: Severity Level III for failures to control access to the protected are (86-08) Civil Penalty of $25,000 issue Severity Leve 1 I II for fa i 1 ure to contra 1 a path from an owner controlled area to the protected are (85-20) No civil penalty was issue * Severity Level IV for failure to report changes of. the Physical Security Plan to the NR (85-13) Conclusion Category: 2 Board Recommendations No change in the level of NRC staff resources applied to the routine inspection program is recommende Outages Analysis During the eva 1 ua ti on period inspections were performed by the resident and regional inspection staffs. Refueling operations were observed for Unit 1 during November and December 1985 and for Unit 2 during February and March 198 The inspectors observed reload from the control room, refueling floor, and the spent fuel pool are Refueling activities reflected thorough preplannin The refueling staff and staff training were adequat Technical problems encountered during refueling were promptly resolved in a competent and safety conscious manne Unit 1 Unit 1 experienced several problems in starting up following the refueling outag A shutdown was required on December 24, 1985 due to 18 1 loop Delta T greater than 6% from 1A1 loop with the 1C1 loop Delta T already in the trip positio The problem existed as a result of a disconnect of the valve disc from the stem in the Rockwell Edwards valves located in the bypass loo The licensee examination showed that fourteen of fifteen valves experienced stem separatio This problem was identified in the NRC issued Information Notice (!EN)
84-4 This indicates that the licensee had not appropriately followed up on this !E The reactor was shutdown on December 29, 1985, when the unidentified leakage exceeded 1 gp The problem was identified as Conoseal leakage which was then repaired and the pl ant heated u During heatup the leakage st i 11 exceeded 1 gpm and the plant was cooled down, the reactor vessel (RV) head was removed and the RV head 110 11 ring was replace Also, during the period of December 23-29, 1985, repairs were made to correct several other leaking compo-nent The repairs included the application of Furmanite to some of the reactor coolant system valve Unit 2 A complete overhaul of the 2H and 2J emergency diesel generators (EDGs) was accomplished with a licensee commitment to take wrist pin bushing gap measurements every 6 months or
hours of operatio This surveillance commitment, together with the replacement of engine oil, were a part of the corrective actions taken to preclude excessive bushing elongation resulting in EOG failur These actions were implemented in late March 1986, and to date no problems have recurre The licensee and Westinghouse personnel were interviewed while performing the fuel handling evolution to en sure that personnel were properly trained and following approved procedure Westinghouse was contracted to do the fuel replacement The people interviewed were experienced and had performed these evolutions in the pas The inspectors verified that adequate housekeeping, radiological and accountability controls were established and implemente The inspectors vis i tad. the West i nghousr2 tra i 1 ers and observed
the !SI testing of a reactor vesse 1 nozzle and the eddy current testing of the 11 C 11 steam generato Procedures were in place for all activitie Unit 2 experienced several valve leaks on the reactor coolant system and the charging system in April 198 Furmanite was required to repair both the 18 1 and 1C 1 main feedwater regulating valve Leaks were also encountered on the 18 1 reactor coolant loop cold leg loop bypass valve RC-45, the drain header from the 181 loop RC-69, and the sample line off of 18 1 loop RC-6 Most of these valves were repaired by the use of Furmanit The Unit 2 post refueling startup test performance records were adequat The reload analysis results predicted a positive moderator temperature coefficient (MTC)
for beginning of cycle and unrodded core condition A review of open safety related work requests for both units indicated that severa 1 priority 1 and 2 work requests i dent ifi ed as mode 5 which predated the outage had not been completed after the outage. It appears that in order to expedite the outage some of the identified maintenance deficiencies were omitte This later showed up in component leaks and facility down time. A high reliance is placed on Furmanite applicatio \\
Facility maintenance work during unit outages was routinely inspected by the NRC staf This work effort included modification of spent fuel racks, hydrolasing of service water pipe, assembly of large diameter service water piping, and letdown filter isolation valve replacemen Within these areas the inspector determined that the activities were adequately planned, performed and reviewed in a safe and controlled manne Documentation was concise and retrievabl Quality control involvement in these activities was adequat The licensee's resolution of technical issues was acceptabl The licenseers inservice inspections of safety related components and associated piping were inspected by the NR This work effort was primarily an audit of the inservice inspection (ISI) program, review of records, and evaluations of inspection result The program was consistent with regulatory requirements and documentation was concise, accurate and retrievabl Quality control involvement was adequat No violations were observed in this perio.
Conclusion Category:
2 Board Recommendations
Licensee resources were adequate in this are No change in the level of NRC staff resources applied to the routine inspection program is recommende Quality Programs and Administrative Controls Affecting Quality Analysis During this evaluation period, routine inspections were performed by the resident and regional inspection staff The regional staff specifically reviewed the off site support staff, off site review committee, QA Program, and licensee actions on previously identified inspection finding For the purpose of this assessment, this area is defined as the ability of the licensee to identify and correct their own problem As such it encompasses all plant activities, all plant personnel, as well as those corporate functions and personnel that provide resources to the plan The plant and a corporate QA staff is a part of the entity, and as such, is mainly responsible for verifying quality. Thus, the rating in this area specifically denotes the results for various groups in achieving quality as well as the QA staff in verifying that quality is achieve A review was performed on all sections of this SALP report in an attempt to capture apparent strengths and weaknesses related to management controls affecting qualit The following are some perceived strengths in management controls affecting quality:
An innovative approach in using Quality Maintenance Teams to improve maintenance activitie Management i nvo 1 vement in the maintenance area where new programs such as Chesterton valve packing, Visual Information Management System, and maintenance agreement with contractors have been introduced to improve performanc Nuclear performance monitoring where 34 * performance indicators are trended on a monthly basi Use of the operator check program where one of the best operators is selected to observe day to day control room operation Additional staffing and training of personnel dealing with the surveillance progra This illustrates a priority within management to correct a potential prob 1 em with surveillance activitie Prompt correction of a problem associated with the Main Steam Code Safety valve This problem was identified during an
..
surveillance tes The licensee hired personnel to address this item and seek corrective actio Licensee's handling of a number of licensing issues in a professional and competent manne The following are some perceived weaknesses in management controls affecting quality:
Frequent, identified reactor coolant system leakages indicating inadequate or ineffective corrective action in the maintenance are Continued problems with personnel failing to follow procedure Continued problems with a large backlog of outstanding maintenance issue Problems with the performance of design change package Repeat violations relative to inadequate procedure reviews for reactor trip breaker maintenanc Concerns related to the surveillance are Not taking adequate corrective action relating to an IE Information Notice 84-48 relating to Rockwell Edwards valve Offsite support staff activities appeared to be well controlled in that various staff members understood their responsibilities and authorities. Corporate staff members frequently visit the site to augment their support functio Corporate staff groups exhibited close working relationships which resulted in coordinated support to the sit The Independent and Operating Event Review Group (IDER) is undergoing changes since a new manager was appointed in early 198 Some changes include new evaluation depths on certain areas, streamlining reviews and information disseminatio VEPCO has also formed a Nuclear Overview Committee (NOC) which is made up of upper level management which reviews IDER activitie Licensee QA program controls were adequate and the licensee was in the process of revising their program from Revision 4 to Revision During a routine regional inspection in the area of modification to the service water intake structure, four examples of a violation of licensee requirements were identified -
Failure to control temperature of concrete test cylinders, failure to control
moisture content of se 1 ect fi 11, fa i 1 ure to meet specified test requirements for slump, air, concrete temperature and aggregates, and document correct quantities of concrete mix ingredients on batch tickets, and failure to have a procedure which implements current specification This led to severity level III violation identified as violation a. belo Four violations occurred during this reporting perio Severity Level III violation for multiple failures to met requirements during modification to the service water intake structur Severity Level III violation involving numerous quality assurance records falsified without apparent management knowledg (This violation is entered for record purposes only in that it occurred in a previous SALP period but was issued during this SALP period). Severity Level IV violation for failure to maintain th necessary quality records to verify qualification of personne Severity Level IV violation for failure to require a review of Design Change Acceptance Tests for Technical Specification requirement.
Conclusion Category:
2 Board Recommendations No change in the level of NRC resources applied to the routine inspection program is recommende Training and Qualification Effectiveness Analysis In this evaluation period the regional staff assessed the licensee's training program in different disciplines of the licensee's organization during the routine inspections performed in the functional areas addressed in this SALP repor Training of personnel was looked into in such areas as plant operations, maintenance, quality assurance, heal th physics, emergency preparedness, fire brigade, and securit No particular deficiencies were identified in the areas reviewe In the maintenance area, Quality Maintenance Team members received specialized training in the areas of preplanning, electrical and mechanical maintenance, quality assurance, and health physic In
the physical security area, the 1 icensee has a well established and aggressive training program for their personne The fire brigade program was adequat The licensee has been participating with INPO (Institute of Nuclear Power Operations) to establish new programs for plant performance improvemen In particular these include the INPO Accreditation Program and the Human Performance Evaluation System (HPES) wherein all plant events caused by human error are investigated using guidelines and methodologies established by INPO and the results transmitted to INPO for use in an HPES data bas INPO has accredited the licensee 1 s licensed operator and non-licensed operator training programs, the radiation protection training program, and the electrical and mechanical technician training program INPO is scheduled to review the instrumenta-tion and control, shift technical advisor, and engineer training programs in 198 The check operator training program was instituted during this SALP period. This program is designed to use experienced and well qua 1 i fi ed 1 i censed operators to eva 1 uate performance of new operators that are being trained on the simulator and assigned on shift in the control roo Three sets of replacement operator licensing examinations were administered and one requalification examination was administrated during the SALP rating perio Two of two senior reactor operator (SRO) candidates passed the written examination administered in April 198 The operating and written exami nat i ans administered in October 1985 and June 1986 resulted in five of ten SRO candidates and eleven of twelve reactor operator (RO) candidates passin The requalification examination administered in December 1985 resulted in two of five SRO candidates and four of four RO candidates passin The requalification program was deemed marginally acceptable based on the examination result The replacement examination passing rate of 75% and was consistent with the industry averag.
Conclusion Category:
2 Board Recommendations No change in the 1 eve 1 of NRC resources app 1 i ed to the routine inspection program is recommende Licensing Activities Analysis
The licensee has demonstrated a high level of management involvement in assuring quality in licensing activitie The licensee 1 s management has demonstrated active participation in licensing activities and has kept abreast of current and anticipated licensing action Particularly noteworthy has been the management involvement and initiative in the following areas:
(1) the completed licensing activities associated with the North Anna Units 1 and 2 amended 1 icense for the receipt and storage of 500 Surry spent fuel assemblies; (2) the completed license activities for the uprate in the core power level from 2775 MWt to 2893 MWt; (3) forceful effort in pursuing the North Anna Units 1 and 2 Service Water Piping and Valve Corrosion and Preservation Program; (4) attention and response to recent emergency diesel generator problems; (5) the Appendix R Reanalysis Effort and associated plant modifications and exemption requests, and (6) the licensee 1 s proposed Integrated Implementation Schedul The 1 icensee 1 s management actively pursues an aggressive and continuous upgrade in the North Anna Units 1 and 2 Technical Specification (TS) for continuity and similarity. This effort is substantiated by the number of TS changes submitted on a continuing basis by the licensee. It is noted that the licensee 1 s management has actively supported licensing issues and resolution which represented ~nalyses or m~thodology which have been first of a kin A case in point was the licensee's amendment request for extending the Limiting Condition of Operation (LCO) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> for which one redundant service w~ter header can be inoperabl Probabilistic and failure mode analyses were presented by the licensee which represented a new approach to the NRR staff for solving this type of issue. Another example was the licensee 1 s presentation to NRR management on April 17, 1986 regarding excessive reactor trip breaker testing and presentation of a revised maintenance schedul The licensee 1 s management has actively initiated and pursued an aggressive policy of Quality Control on proposed amendment changes to assure that the final submittal to NRR represents a quality produc During the last half of this SALP reporting period a significant improvement has been noted in the licensee 1 s submittal During the previous SALP reporting period, it was indicated that the licensee I s management had reacted to a proposed 11mater, al false statement 11 by a two fold increase in the time required for sign-off of any NRC submittal In addition, licensee management changes had resulted in some confusion and loss of continuity regarding the integral status of NRC actions for the facilit These problems have been corrected and it can be stated that the licensee 1 s management appears to have now significantly 11 fine tuned 11 the control and quality of NRR submittal The licensee 1 s Nuclear Programs and Licensing Organization has been increased by at least a factor of two since the last SALP reporting period. This increase in staffing has taken place both at the licensee 1 s corporate office as well as the facilit Both at the supervisory level and at the working level this increase in staff has resulting in an enhanced ability to assess, evaluate and prepare licensing responses to NR In addition, operations qualified personnel are integrated into the corporate levels of management to provide guidance in licensing matters which involve operation Finally, the level of expertise of the licensee 1 s augmented staff (nuclear, engineering, opera ti ans, etc.) has increased the licensee 1s ability to provide in a timely manner, high quality submittals for NRR evaluation With regard to the licensee's approach to resolution of technical issues from a safety standpoint the licensee understands the issues involve Whenever technical issues are addressed in depth, k"nowledgeable people are involved who can address an issue not only from the licensee 1 s standpoint but also from a knowledge of NRC regul at i ans, criteria and generic issue Interface with the NRR staff at meetings and site visits is open, professional, candid and responsive to staff need The licensee accepts its responsibility for plant safety and operability and assesses, evaluates and implements technical modifications when required and does not necessarily wait for ~RC requirement A recent example of this responsibility is the licensee 1 s submittal to the NRC (extending the LCD from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) regarding the corrosion and mechanical cleaning of the service water system piping and valve repair As presented, the licensee 1 s program represents a unique approach to upgrading the service water syste On occasions, when the licensee deviated from staff guidance, the licensee has consistently provided good technical justification for such deviation The fire protection program is a good example illustrating the soundness of the technical justification for deviations and exemptions from the guidanc When unusual events have occurred at the facility, the licensee had used conservative approaches in dealing with the situations and performed in-depth analyses of significant safety issues raised by such event During the recent and ongoing resolution of emergency diesel generator failures, the licensee has contracted an engineering consultant as an independent third party to monitor and critique the licensee and vendor effort for improving maintenance, operating procedures and root cause(s) for previous component failure This is not the first time that the licensee has made use of an independent third party to monitor licensee and vendor endeavor The licensee has made frequent visits to NRC to discuss forthcoming requests for staff actions prior to formal submittal Examples of such visits are licensee-staff meetings regarding the North Anna Units 1 and 2 Power Upgrade, the issue of the facility site visits, the licensee is most cooperative and provides the technical staff necessary to discuss appropriate matter The licensee's quality of responses has been excellen The licensee's submittals for Power Uprate, the Appendix R Reanalysis Effort and Exemption Requests, and the Service Water System Piping Cleanup Program are a few examples of excellent quality conten The licensee, after NRC identification, has significantly improved the quality of the no significant hazards evaluations for TS amendment request The quality of these submittals has alleviated, in part, a large work load for NRR in noticing the licensee's many TS changes for North Anna 1 and The licensee's management and staff maintains excellent liaison with the NRR project manage It is common practice for the licensee to expeditiously report to the project manager any event reported to the NRC emergency response center. Also, the licensee notifies the project manager we 11 in advance of forthcoming requests for amendments or review of safety issue As noted in the previous SALP report, the licenseers response for meeting commitment dates had significantly deteriorated because of problems noted abov These problems have been correcte Moreover, the licensee has initiated a tracking system for licensing issues which uses in part input from the NRC Regulatory Information Tracking Syste This effort has resulted in an enhanced capability to assign priorities to licensing actions and maintain schedules and provide applications to NRR on a more selective and orderly month by month basi This effort on the part of the licensee has alleviated sbme of the past NRR workload in processing the licensee's many application However, in the area of Inservice Inspection and Testing, the licensee's submittals for requesting relief have in the past been provided to NRR on a "last minute" basis indicating poor control and scheduling. This matter has been discussed with the licensee and marked improvement has been noted in the last third of the subject SALP reporting perio.
Conclusion Category:
1 Board Recommendations Non SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 1 began the assessment period at approximately 100% powe On August 3, 1985 the Unit was shutdown for inspection and repair of tube leakage in Steam Generator l Thirteen tubes were plugged and the unit restarted on August 18, 198 On September 11, 1985 the unit was again taken off line until September 17, 1985 to correct reactor coolant system leakage. A refueling outage was entered on November 3, 1985 and Unit 1 returned to power on December 23, 198 Unit 1 experienced high turbine vibration due to a damaged turbine blade on August 27, 1986 and ended the assessment period in a shutdown mode while repairs were being mad Unit 2 also began the assessment period at approximately 100% powe On July 25, 1985 the unit was shutdown to correct packing leakage and returned to power on July 28, 198 Unit 2 was again shutdown on October 11, 1985 due to an emergency diesel generator failure and returned to power on October 15, 198 A Unit 2 refueling outage took place from February 20, 1986 to April 1, 198 Reactor coolant leakage caused a shutdown from August 12, 1986 to August 19, 1986 and the unit ended the assessment period at powe The NRC approved the licensee's request for a core power upgrade toward the end of the perio Inspection Activities
--
During the assessment period, routine inspections were performed at the North Anna facility by the resident and regional inspection staff A sma 11 seal e emergency preparedness exercise was conducted in May of 1985 and a full scale exercise was conducted in June 198 See Section IV.F for details on performance in this area. There were three special inspections involving an Appendix R fire protection inspection in September 1985, a review of circumstances of a security event in July 1985, and an Office of Investigations investigation concerning fa l sifi cation of quality assurance records that occurred in the previous rating perio Investigation and Allegation Review There were no significant investigations or allegation activities completed during the assessment perio Escalated Enforcement Actions Civil Penalties A severity level III violation concerning falsification of QA records which resulted in a civil penalty in the amount of
twenty thousand dollars was assessed on December 13, 198 (This violation occurred in a previous assessment period but was issued during this period). A severity level III violation concerning security which did not result in a civil penalty was assessed on August 28, 198 A severity level III violation concerning the service water intake structure modification was assessed on February 21, 198 A severity level III violation concerning external radiation levels on a transported package which did not result in a civil penalty was issued on August 8, 198 A severity level III violation concerning access control and unauthorized entry which resulted in a civil penalty of twenty five thousand dollars was issued on June 27, 1986. * Orders - None Licensee Conferences Held During Appraisal Period An enforcement conference was held on December 18, 1985, to discuss problems concerning the service water intake structure modificatio An enforcement conference was held on July 18, 1985, to discuss a security event regarding protective area barrier An enforcement conference was held on April 9, 1986, to discuss the transportation of radioactive materials and a security event regarding uncontrolled access of a contractor employe A management meeting was held on March 3, 1986, to discuss operator requalification examination result An enforcement conference was held on September 26, 1986, to discuss NRC office of Investigations report on the falsification of QA record (This subject matter was addressed in the previous SALP). Confirmation of Action Letters None were issue Review of Licensee Event Reports and 10 CFR 21 Reports submitted by the license During the assessment period, there were 52 LERs reporte The distribution of these events by cause, as determined by the NRC staff, was as follows:
CAUSE Component Failure Design Construction/Fabrication/
Installation Personnel:
Operating Activity Maintenance Activity Test/Calibration Activity Other Activity Out of Calibration Other TOTAL Licensing Activities UNIT 1
1
3
4
3
UNIT 3
1
2
1
16 TOTAL
2
4
5
5
The assessment on licensing activities was based on the fol lowing licensing actions:
0
0 0 Core Uprate (2775 MWt to 2893 MWt)
Emergency Diesel Generator Problems Receipt and Storage of Surry Spent Fuel Assemblies at North Anna Units 1 & 2 Service Water Mechanical Cleaning and Refurbishment Program Appendix R Reanalysis Effort Plant Modifications and Exemption Requests Integraded Implementation Schedule Maintenance for Reactor Trip Breaker 08/25/86 07/04/86 (Monitoring)
04/21/86 10/25/85 (Monitoring)
(Ongoing)
(Ongoing)
Significant amendments included:
0
Reduce testing requirements for EDG 1 s (GL 86-15)
Revise TS in response to Generic Letter 83-37 Add post-accident sampling program to Administrative Controls
0
0
0
0
0
0
0
0
0
0 L
--
Revise reactor coolant system chemistry for chlorides and fluorides Minimum decay time (150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />) prior to movement of fuel (refueling operations)
Correct errors existing in Radiological Effluent TS Reduce boron concentration in boron injection tank and boric acid system Eliminate Rod Bow Penalty on nuclear enthalpy hot channel factor Revise TS for allowable time that one redundant service water header can be inoperable (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />)
Generic Letter 84-13, 11Techni cal Speci fi cations for Snubbers,
dated May 3, 1985 Modify snubber visual acceptance criteria and establish functional test methods for large bore snubbers Allow operation with positive moderator temperature coefficient at less than 70% rated power Update pressure-temperature limit curves for heatup and cooldown Suspend MTC measurements for end-of-cycle moderator temperature coefficient Permi-t entry into airlock for repair of inoperable inner air lock door Revise TS to reflect installation of new containment isolation valve Allow widening of axial flux difference bands Allow receipt and storage of 500 spent fuel assemblies from Surry 1&2 Update security, contingency and guard training and qualification Organizational Changes Delete redundancy in reporting requirements for TS 6.5. Correct errors for seismic instrument range and testing requirements LCD and Surveillance Requirements for reactor trip bypass breakers
0 Correct error in Action Statement for Overtemperature Delta T and Overpower Delta trip instrumentation
Revise TS to address EDGs (Generic Letter 84-15) for NA-1 and correct errors NA-2 EOG TS
Increase rated core power level from 2775 MWt to 2893 MWt Enforcement Activity UNIT SUMMARY FUNCTIONAL AREA NO. OF DEVIATIONS AND VIOLATIONS UNIT N Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Refueling Training Quality Programs and Administrative Controls Affecting Quality TOTAL D
1/2 1/1 1/1 2/2 FACILITY SUMMARY SEVERITY LEVEL V
IV III 1/2 1/2 1/2 2/2 2/0 1/1 1/1 1/1 2/1 2/1 3/2 1/2 1/1 2/2 2/2 2/2 8/6 9/7 5/5 FUNCTIONAL NO. OF DEVIATIONS AND VIOLATIONS AREA SEVERITY LEVEL D
V IV III Plant Operations
2
Radiological Controls
1
Maintenance
2 Surv-ei 11 ance
3 Fire Protection
Emergency Preparedness Security
2 Refueling Training Quality Programs and Administrative Controls
2 Affecting Quality TOTAL
8
5 IN EACH II 1/2 IN EACH II I
1/2 I Reactor Trips Unit 1
Nine unplanned reactor trips and eight unplanned manual shutdowns occurred during this evaluation perio The reactor trips are listed belo September 17, 1985 - The reactor was manually tripped due to a group of rods dropping into the cor October 24, 1985 - The reactor was manually tripped due to a failed 480 volt AC circuit breaker resulting in the loss of cooling water to the reactor coolant pump January 19, 1986 - The reactor automatically tripped from approximately 4% power due to the turbine overspeed test switch being inadvertently turned in the wrong directio February 23, 1986 - The reactor automatically tripped from 100% power due to a electro hydraulic control system failure resulting in all the governor valves closin March 26, 1986 - The reactor automatically tripped from 100% power due to the inadvertent closure of the 1B1 steam generator trip valv May 20, 1986 - The reactor automatically tripped from 100% power due to the inadvertent closure of all three main feedwater regulating valve May 31, 1986 - The reactor automatically tripped from 100% power due to the failure of the alternate power supply to vital bus 1-August 14, 1986 - The reactor automatically tripped during startup due to a failure of a temporary jumper installed on an Intermediate Range (lR) instrument drawe The jumper was installed to allow IR drawer replacemen August 27, 1986 - The reactor was manually tripped from 100% power due to a failure of a low pressure turbine blad Unit 2 Seven unplanned reactor trips and eight unplanned manual shutdowns occurred during this evaluation perio The reactor trips are listed belo March 23, 1985 - The reactor was manually tripped from 100% power due to a fault in the offsite power distribution syste April 26, 1985 - The reactor automatically tripped from 100% power due to an inadvertent deenergization of a 125 VAC vital bu February 20, 1986 -
The reactor automatically tripped during a shutdown, whi 1 e in Mode 3, due to a spike in the source range instrumentatio Apri 1 11, 1986 - The reactor automatically tripped from 70% power due to a failure of the permanent magnet generator on the main generato April 16, 1986 - The reactor automatically tripped during startup in Mode 2 due to a spike in the first stage impulse pressur May 29, 1986 - The reactor automatically tripped from 100% power due to the inadvertent opening of the stationary coil power supply disconnect to the rod control power distribution cabinet causing 12 rods to drop into the cor June 29, 1986 - The reactor automatically tripped due to a fault in the offsite power distribution system similar to the trip March 23, 198 North Anna Gaseous and Liquid Effluent Release Gaseous (curies for two units)
RII 1985 AV 1985 1/1-6/30/86 Fi s s i o n *a n d Activation Gases 13140 8053 4556 Iodine 0.30
.065
.003 Particulate
.0144
. 021
.001 Tritium 760 Liquid (curies for two units)
RII 1985 1985 1/1-6/30/86 Fission Activation Products 1. 9.445 Tritium 770 1480 685
ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION I I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-280/86-23 and 50-281/86-23 Virginia Electric and Power Company Surry Plant Units 1 and 2 March 1, 1985 through August 31, 1986 INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this informa-tio The SALP program is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulations. The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management to promote quality and safety of plant construction and operatio * An NRC SALP Board, composed of the staff members listed below, met on November 5, 1986, to review the collection of performance observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, 11Systemat i c Assessment of Licensee Performanc A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of *the licensee's safety performance at Surry for the period March 1, 1985 through August 31, 198 SALP Board for Surry:
R. D. Walker, Director, Division of Reactor Projects (DRP),
RII (Chairman)
V. W. Panciera, Deputy Director, Division of Reactor Safety, RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII V. L. Brownlee, Chief, Reactor Projects Branch 3, DRP, RII L. S. Rubenstein, Project Director, PWR Licensing Division-A, NRR W. E. Holland, Senior Resident Inspector, Surry, DRP, RII C. P. Patel, Project Manager, PWR Licensing Division-A, NRR Attendees at SALP Board Meeting:
A. J. Ignatonis, Chief, Reactor Projects Section 38, DRP, RII K. D. Landis, Chief, Technical Support Staff (TSS), DPR, RII R. P. Croteau, Project Engineer, Reactor Projects Section 38, DRP, RII C. J. Paulk, Reactor Engineer, TSS, DRP, RII T. C~ MacArthur, Radiation Specialist, TSS, DRP, RII
I CRITERIA Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review perio Each functional area represents an area which is normally significant to nuclear safety and the environment and which is a normal programmatic are Some functional areas may not be assessed because of little or no licensee activity or lack of meaningful NRC observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria was used to assess each functional area; however, the SALP Board is not limited to these criteria and others may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement hi story Operational and construction events (including response to, analysis of, and corrective actions for) Staffing (including management) Training and qualification effectiveness Based upon the SALP Board* assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are:
Category 1:
Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieve Category 2:
NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction quality is being achieve Category 3:
Both NRC and licensee attention should be increase Licensee management attention or. involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that mini ma lly satisfactory performance with respect to ope rat i ona 1 safety or construction quality is being achieve The functional area being evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or The final rating for each functional area is a composite
of the attributes tempered with the judgement of NRC management as to the significance of individual item The SALP Board may also include an appraisal of the performance trend of a functional are This performance trend will only be used when both a definite trend of performance within the evaluation period is discernible and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment perio Declining:
Licensee performance was determined to be declining near the close of the assessment perio III. SUMMARY OF RESULTS Overall Facility Performance The Surry nuclear power station is well managed by qualified and experienced personne The corporate senior management involvement to improve quality and plant performance was evident by the licensee 1 s use of such programs as the Nuclear Performance Monitoring where 34 performance indicators are trended on a monthly basis, implementation of Quality Maintenance Teams for the improving maintenance activities, responsiveness to NRC initiatives, and maintaining good communications with the NR Acceptable performance at the plant level was also observe Strengths were identified in the functional areas of plant operations, fire protection, and licensing activitie During the SALP period the Surry facility had high availability, low forced outages rate, and fewer than the industry average of reactor trips, safety system actuations, and safety system failure For the performance. i ndi ca tor of inadvertent automatic reactor trips, the licensee has set an ambitious goal of not having more than two automatic reactor trips per unit per yea The actual trip rate (automatic and manual) was 4.7 per year and 2.7 per year for Units 1 and 2, respectivel This rate is low when compared to the actual 1985 industry average which was six reactor trips per yea The licensee has performed satisfactorily in all other functional area In the radiological controls area, however, the cumulative man-rem exposure was higher than the national averag The licensee is cognizant of this and is working to reduce the total future exposure by implementing various programs which include the removal of selected snubbers and cleanup of contaminated area In the maintenance area, the NRC has noted that the corrective maintenance items backlog was not being*
efficiently reduce As the new work orders were being added to the list and appropriately so, the older items were not being cleared at the same rat Again, the licensee is cognizant of this and is trending the backlo The licensed operator training program may need
to be strengthened because the requalification program was found to be marginally acceptable based on the examination result In conclusion, the licensee is implementing new and innovative techniques to improve quality and performance in various disciplines of plant operations including the information received from international agreement program Also, the licensee is working with INPO to complete their training programs accreditatio.
The performance categories for the current and previous SALP period in each functional area are as follows:
Functional Area Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Refueling/Outages Training Quality Programs and Administrative Controls Affecting Quality Licensing Activities I PERFORMANCE ANALYSIS Plant Operations Analysis Previous SALP Dates September 1, 1983 February 28, 1985
1
3 Not Rated
1
2
1 Current SALP Dates March 1, 1985 August 31, 1986
2
2
2
2
2
During the assessment period, inspections of plant operations were performed by the resident and regional inspection staff The Surry facility was properly managed and operated by the corporate office and plant staff during this assessment perio The plant staff was knowledgable and proficient in normal plant operations and performed well during transient operations such as power excursions or shutdown Management involvement in*
operations was apparent throughout the assessment perio The licensee was responsive when violations were identified by the NRC and also implemented appropriate corrective actions for items identified by internal audit group The licensee 1 s knowledge of regulations, guides, standards and generic issues was good, and
interpretations of these documents and associated issues were acceptabl The plant staff generally responded to plant trips and other ope rat i ona 1 events during this review period in a professional and competent manne During this SALP period Surry Units 1 and 2 experienced a total of seven and four reactor trips, respectivel This converts to a trip rate of 0.67 per 1000 critical hours (4.7 per year) for Unit 1 and 0.41 per 1000 critical hours (2.7 per year) for Unit These rates compare favorably with the 1985 industry wide average of 6.0 trips per year and the average rate of 1.04 trips per 1000 critical hours (6.8 per year) for Westinghouse plants. Also, the licensee has established a goal of having no more than two automatic reactor trips per unit per calendar yea As of August 31, 1986, this goal was met for both unit Out of the seven reactor trips for Unit 1, two trips were manual and five trips were automati The review of the reports submitted by 1 icensee indicates that four of the seven reactor trips were caused by personnel error One trip was manually initiated due to arcing on the 1A1 phase bus duc Two reactor
- trips were caused by equipment failure Of the four Unit 2 reactor trips one was a manua 1 trip and three were automatic reactor trip One trip was caused by personnel error and three trips were caused by equipment failure The reactor trips are described in Section V.J. of this repor The above data reflects positive results of licensee actions initiated during the previous evaluation period to reduce the number of reactor trip The number of unplanned reactor trips was substantially reduced during this reporting perio Also, human performance eva 1 uat ion staff reviews of operating events continued to improve operational performanc Additional plant operational statistics observed during this SALP period are presented belo Operational Parameters Unit 1 Unit 2 Unit Availability Factor(%)
73 Unit Capacity Factor - Design
66 E1ectrical Rating (%)
Forced Outage Race(%)
1. 0 The Surry Units 1 and 2 availability factors, the unit capacity factors, and the forced outages rate compare favorably with the industry averages for 1985 which are 68.5%, 61.7%, and 11.3%,
respectivel Thus, all of these indicators for both units indicate an index of merit of plant performance which is better than the industry averag During this SALP period, the 1 i cen see reported 37 reportab 1 e events within the time limits of 10 CFR 50.7 However, some of these Immediate Notifications were not reported within the time limit specified by 10 CFR 50.72. This concern was conveyed to the licensee and corrective action was take The licensee submitted 58 Licensee Event Reports (LERs), during this SALP perio The LER analyses were carefully done and thoroug For the most part, both the Immediate Notifications and the LERs suggest that the licensee took appropriate action with regard to the reported events. Also, an evaluation of the content and quality of a representative sample of LERs was performed by the NRC using a r~finement of the basic methodology presented in NUREG/CR-4178, March 198 The results show that the Surry LERs have an overall average score of 8.5 out of a possible 10 points, compared to a current industry average of 7. The weaknesses identified in the LERs in terms of safety significance, involved the requirement to identify failed components in the text and adequately identify component failures that may prompt a generic concer The strengths identified were in the discussion involving root cause identification; assessment of safety consequences; failure mode, mechanism, and effect of failed components; personnel errors; and safety system response The introduction of the corporate Nuclear Operations Department monthly report entitled "Nuclear Performance Monitoring Management Information Report 11 has provided trending information for management personnel in 34 different area Some of the areas are:
Forced Outage Rate, Reactor Trips, Safety System Events, Personnel Radiation Exposure, Control Room Annunciators, Temporary Modifications, Quality Assurance Findings, et This monthly trending report is a valuable tool for management in assessing performance and identifying problem area Corporate management was often involved in site activities and reviews, utility policies were appropriately stated, disseminated and implemente The corrective action program for deficiencies appeared to address all concerns (both reportable and nonreportable) in a timely and effective manne The licensee was also responsive to NRC concerns and request Control room formality and behavior were maintained at high professional level The licensed operators performed their duties in a highly professional manner which promulgated unit operation in a safe and efficient manne With the exception of one violation on failure to follow procedure, plant procedures were fol lowed and postings prohibited control room entry to all but those on official business. Management involvement with plant operations was evident where the licensee has not only instituted the human performance evaluation system which supplements the post reactor trip review but also added the check operator program used to enhance the qualifications of operations personnel. This is a
self-evaluation of operators in which a more experienced operator reviews the performance of new personnel at the simulators and in the control roo Also, the licensee is putting into place a uniform attire program accomplished through their own employee involvement team Approximately 1200 people will wear uniform The licensee's response to NRC initiatives was timely and adequat The resolution of safety and technical issues was sound and thoroug The licensee's operations program continued to provide the necessary leadership and professional attitude which has maintained a high level of plant performanc One violation was identified during this assessment perio Severity Level IV violation for having charging pump intermediate seal coolers inoperable on Unit 2 due to the failure of personnel to use* approved procedures when performing safety-related evolution (85-07) Conclusion Category:
1 Board Recommendations The licensee's management involvement in assessing plant operations performance and establishing goals for improvement has contributed to the licensee's receipt of a Category 1 rating in this are The Board was also pleased to note an apparent effectiveness of the licensee's reactor trip reduction progra No changes to the NRC 1 s inspection resources are recommende Radiological Controls Analysis During this evaluation period, inspections of radiological controls were conducted by the resident and regional based inspectors, including a confirmatory measurements inspection using the Region II mobile laborator The licensee's health physics (HP) staffing level was adequate to support routine operation For refueling outages, additional contract HP technicians were used to supplement the permanent plant HP staf During the assessment period, the licensee was increasing the size of the onsite HP staff, and was adding*
additional personnel to the technical staff which would provide support functions for HP and chemistr During 1985, the 1 i censee comp 1 eted deve 1 opment of a forma 1 training and qualification program for radiation protection technician The program was submitted to the Institute of Nuclear Power Operations for review, and was accredited in May 198 One strength noted in the health physics program was the stability of the health physics technician staf The low attrition rate has resulted in a more experienced group of individuals and has provided the time necessary to implement an effective and continuing training program for the technician The performance of the health physics staff in support of routine outage operation was goo No substantive issues were identified in this are Management support and involvement in matters related to radiation protection and radwaste contra 1 was adequat Hea 1th physics management was involved sufficiently early in outage preparations to permit adequate plannin The station health physicist received the support of other plant managers in implementing the radiation protection prog~a Audits performed of the health physics program by the corporate staff were of sufficient scope and depth to identify problems and adverse trends. Additionally the site internal audit organization conducted audits of the hea 1th physics program using personne 1 that were experienced in the health physics are Appropriate corrective actions were taken and documente During the evaluation period, the licensee's radiation work permit and respiratory protection programs were found to be satisfactor Control of contamination and radioactive materials within the facility was generally adequate..
At the beginning of January 1985, the licensee maintained 51% of the total area regarded as Radiological Control Area (RCA) under contamination control The RCA did not include the containments or the fuel poo By the end of 1985, the area under contamination controls had been reduced to approximately 40% of the total RC The licensee's instrument calibration program was reviewed during this period and several areas which required improvement were identifie The instrument calibration program did not include verification of calculated decay curves for all calibration sources and the procedures did not include several significant aspects of an instrument calibration progra During 1985, the licensee's cumulative exposure was 820 man-rem per unit as measured by thermoluminiscent dosimeter (TLD).
For 1986, the total exposure through July 1986, as measured by TLD was 725 man-rem per uni These values are well above the 1985 national average of 425 man-rem per unit observed at similar PWR facilities. While the licenseers approach to resolving the higher than norma 1 man-rem exposure results appears not to have been effective during this SALP period, the data based on a longer term (1980 through present) shows a declining tren Nevertheless, the total exposure is hig The licensee has instituted personnel radiation exposure reduction efforts such as source term reduction involving chemical decontamination, reactor vessel head shielding, removal of selected snubbers, and the reduction of contaminated area The effectiveness of the above measures is yet to be determine During the assessment period, no overexposures either internal or external, were identifie D~ring 1985, the licensee made 84 solid radioactive waste shipments tota 11 i ng 71,500 ft 3 (35,750 ft 3 per reactor) and containing 1,206 curies of activity. These values are well above the national average of 11,650 ft 3 per reactor shipped by other utilities with similar facilitie The licensee's approach to reducing the large volume of solid radioactive material shipped appears to have been effective since only 11,200 ft 3 containing 506. curies of activity have been shipped as of July 198 One violation in this area was identified for failure to meet the stability requirements for solid radwaste as described in 10 CFR 61. 5 During this evaluation period, the licensee's approach for resolving technical issues in the area of meeting the requirements of 10 CFR 20.311 for classifying all radioactive waste for burial in accordance with 10 CFR 61.55 was reviewe Two violations were identified. These violations are listed below as violation a. and C,
The liquid and gaseous effluent program was adequately manage The total quantity of radioactivity in liquid effluents has been steadily decreasing since 198 In 1983, gaseous releases were generally below the Region II average for two PWR unit The release rate through June 30, 1986, shows some increase over 1985, but are still below 1985 Region II average rat The total quantity of radioactivity in liquid releases at Surry in 1985 were significantly above the Region II averag Rel ease in the first 6 months of 1986 continued at about the same rate as in 198 There was no unplanned liquid release in excess of Technical Specification reporting limit There was one gaseous re 1 ease of 28. 6 Ci of xenon-133 which exceeded the Techn i ca 1 Specification reporting limi The environmental monitoring program did not indicate any significant increase of radioactivity
1 eve 1 s in the environment during 198 The tota 1 quantity of radioactivity in gaseous and liquid releases is tabulated in Section V.K. of this repor Calculated radiation doses due to liquid and gaseous effluents for 1985 were well below the 25 millirem per year limi Maximum doses due to liquid effluents were 0.0305 mrem (whole body) and 0.203 mrem (organ).
Maximum doses due to gaseous effluents were 1.1 mrad gamma, 3.02 mrad beta, and 0.23 mrem (thyroid).
There were no major changes to the licensee's radioactive liquid, gaseous, or solid waste treatment systems during 198 Maj or improvements in the chemistry contro 1 program had been initiated in the following areas:
the design of selected components of the secondary water cycle; the physical facilities used by the chemistry staff; the instrumentation used for control and diagnosis of p 1 ant chemistry; and the chemistry staf Chemistry control had been well within the Steam Generator Owners Group (SGOG) guideline When the ongoing upgrade program has been completed (in conjunction with Westinghouse) the licensee will have the most advanced chemistry capabilities in the Regio There were numerous indications that this improvement program is the result of increased attention from p 1 ant and corporate managemen The quality control program for radiological measurements met the general guidance of Regulatory Guide 4.15, 11Quality Assurance for Radiological Monitoring Programs (Normal Operations) -
Effluent Streams and the Environmen A 1 though the overa 11 structure and procedures for quality control were adequate, the need for closer management review of procedures and their app 1 i cabi 1 i ty to the Radiological Effluent Technical Specifications was note This lack of management review resulted in the violation noted belo Licensee results for gamma measurements in samples split with the NRC showed good agreement for all sample type Licensee results for radi ochemi ca 1 analyses of H-3, Sr-89 and Sr-90 were in good agreement for 1985, however, during 1986 the results for the analyses of Fe-55 was 26% higher than the known value The results demonstrated the need for improved review of the vendor laboratory's quality control program to ensure the validity of measurement Three violations were identified: Severity Level IV violation for failure to adequately-determine the concentration of certain radionuclides by use of scaling factors as required by 10 CFR 61.55 (85-21).
11 Severity Level V violation for failure to have procedures for determination of gamma spectroscopy lower limits of detection (85-29). Severity Level V violation for failure to meet the stability requirements of radioactive materi a 1 shipped for buri a 1 as described in 10 CFR 61.56 (86-21). Conclusion Category:
2 Board Recommendations Although the licensee has taken steps in reducing the cumulative man-rem exposure and radioactive waste shipments which are above the national average, management attention should continue to be focused in this area for further reductio No changes to the NRC 1 s inspection resources are recommende Maintenance Analysis During the assessment period, inspections were performed by the resident and regional inspection staff The maintenance program appeared to be technically sound, procedures and plans were adhered to, and records were adequately maintaine The licensee has a positive nuclear safety attitude with regard to maintenance and has implemented a viable preventive and corrective maintenance progra However, it was observed that the licensee's corrective maintenance backlog (i.e. outstanding work orders) has not decreased to their set goal for 198 In the last six months of this SALP period the outstanding work orders were consistently above the goal tren For August 1986, the number of outstanding work orders that are under three months and over three months was approximately 3,000; this compares to a set goal of approximately 2,250. Based on the outstanding work orders trend, it appears that the older items were not being cleared expeditiously when new items were being added as require Management involvement in maintenance programs is evident by the implementation of such programs as use of MOVATS equipment, Chesterton valve packing, Visual Information Management System, and incentive maintenance agreemerrts with contractors where incentives are proposed for exceptional work and reduced pay for poor wor Scheduled maintenance activities exhibited evidence of adequate preplanning with established priorities; however, one weakness was
uncovered with procedure preparation for unscheduled maintenance on the Unit 2 recirculation spray heat exchanger (violation d.).
The maintenance procedures and policies were comprehensive and were adhered to, but occasional weaknesses were uncovered (violations through e.).
The licensee has identified weaknesses in the overall preventive maintenance program and as a result is concentrating effort to make improvements in the preventive maintenance progra The licensee continued to evaluate new approaches to improving the quality of maintenanc One new approach was the initiation of the 11Quality Maintenance Teams 11 concept in mid 198 This concept establishes a highly trained team of maintenance personnel who are given special training in the areas of preplanning, electrical maintenance, mechanical maintenance, quality assuranceL_and health physic They then are assigned jobs which they accomplish as a tea The mission of the team is to perform all work assigned in a high quality manner without the involvement of additional support staff in the areas of health physic coverage and quality control inspection The development of the quality team concept includes a formal training program which provides instruction in the fundamentals of the team approach, problem solving techniques, quality control training and inspector certification and advanced radiation worker trainin Quality Maintenance Team members received high visibility and several team members recently participated in an information exchange visit to nuclear plants in Japa Licensee management is significantly involved with Institute of Nuclear Power Operations (INPO) and NUMARC and the company has agreements with French and Japanese utilities to exchange informatio A dedicated effort is underway to upgrade and modernize plant facilitie Management resolution of safety and technical issues was sound and thoroug Management response to NRC initiatives was demonstrated by the licensee through the above mentioned maintenance program improvement Five violations were identified during this assessment perio The violations do not appear to indicate a programmatic breakdow Severity Level IV violation for failure to follow procedure in that electrical cable tray covers and supports were not properly reinstalled following electrical maintenance or design change wor (85-09) Severity Level IV violation in the area of EQ equipment installation for improper installation of Conax electrical conductor assemblies. (85-19)
13 Severity Level IV violation for an inadequate procedure DC 85-32-1, "Vital Bus Expansion 11 concerning the replacement of the lB station battery. (86-11) Severity Level IV violation for inadequate procedures with regard to repair (tube plugging) of the Unit 2 recirculation spray heat exchanger (86-20) Unit 2 onl Severity Leve 1 V vi o 1 at ion for failure to properly document monthly periodic checks on measuring and test equipmen (85-31) Conclusion Category:
2 Board Recommendations Management should continue their effort in reducing the corrective maintenance action backlo The licensee's innovative techniques in improving maintenance work are commendabl These programs are new and have not been fully implemented during this SALP perio No changes to the NRC's inspection resources are recommende Surveillance Analysis During the assessment period, inspections were performed by the re~ident and regional inspection staffs in the areas of periodic surveillance testing, containment local anc\\ integrated leak rate testing, and Inservice Inspection (ISI) programs and examination of test result During this report period, the inspectors increased their monitoring of the licensee's accomplishment of periodic tests (i.e. survei 11 ance testing) to more accurately eva 1 uate the licensee's effort to improve performance in this are Testing was observed during daily tours of the contra 1 room and other plant area The inspectors specifically evaluated compliance with Technical Specification requirements, control of equipment removal from service, the accuracy and completeness of test data, the acceptability of test results and the licensee's resolution of test discrepancie Additionally, the inspectors conducted more in-depth reviews of selected major surveillance testing on safety-related systems on a monthly basi Based on the inspector observations, improvement was noted in the area of surveillance testing during this reporting perio Improvements made in the process and control of handling and implementing Technical Specification changes have been beneficia Increased management
attention and appropriate resources have been provided in the areas of !SI and commitment contro Three region based inspectors visited the Surry plant in the period April 8-12, 1985, for an independent analysis of the licensee's containment leak rate test program including a review of local and integrated leak rate test reports, procedures, data and data analysi The inspection was conducted to resolve certain issues raised during review of the test for the Unit 2 CILRT (Containment Integrated Leak Rate Test) conducted on September 11-14, 198 As a result of this inspection, a violation (violation a.) was issued for failure to follow the requirements of 10 CFR 50, Appendix J, for the 1983 Unit 2 CILR The issues identified in the review of the 1983 CILRT, prompted a followup inspection of the licensee's leak rate testing program which was performed by region based inspectors during the 1985 Unit 2 refueling outage. This inspection included witnessing the licensee's performance of an integrated leak rate test on Unit 2 in the period June 7-10, 1985 and a comprehensive inspection of both the local and integrated leak rate test methodology, test procedures, test controls, data analysis and test result The inspectors observations indicated that the licensee had taken effective action to improve the leak rate testing progra The improvements included a revision of test procedures to.ensure a quality test;* incre_ased attention to the details of test preparation, control, and performance; appropriate level of decision making to ensure a quality test; thorough analysis of test data; and, adequate review of test result Management involvement was evident in various aspects of the test performance and contributed significantly to programatic improvements and to the conduct of a successful tes The inspectors concluded that the licensee has made significant improvement in the containment leak rate testing program since the 1983 Unit 2 local and integrated leak rate test Inspections were also performed by the regional inspection staff in the areas of valve surveillance testing and Type B leak rate test The licensee management displayed a strong determination to correct known weak areas within the surveillance testing progra Reorganization and reassignment of responsibilities have been implemented to ensure compliance with Technical Specifications (TS).
One minor violation (violation b.) was identified in the area of test contro The overall approach to technical issues by the staff showed evidence of a clear understanding of the issues and problems, corrective actions were implemented in a timely manner with technically sound resolution The 1 i cen see generally demonstrated a cl ear understanding of technical issues, and was responsive to NRC concern The reporting and analysis of surveillance events was prompt and thoroug The licensee 1 s snubber surveillance program was inspected and was found to be satisfactor This program showed evidence of prior planning through well defined procedure Records were generally complete, well maintained, retrievable and legibl The corrective action to resolve several violations including a Severity Level III violation with civil penalty identified in early 1984 was effectiv The resolutions were generally conservativ Approach to resolution of these problems was technically sound and thorough. Staffing and training of snubber surveillance personnel was adequat Two violations were identified during the assessment period: Severity Level IV violation for Type A containment leak rate testing deficiencie (85-11) Severity Level IV violation for failure to follow procedures for control of testing and review of test result (86-05) Conclusion Category:
2 Board Recommendation Management involvement was evident in making programmatic improvements in the containment leak rate testing program and implementation of better controls in performing periodic test No changes to the NRC 1 s inspection resources are recommende Fire Protection Analysis During This assessment period, inspections were conducted by the regional and resident inspection staffs of the licensee 1 s fire protection and fire prevention progra The licensee has issued procedures for the administrative control of the fire hazards within the plant, surveillance and maintenance of the fire protection systems and equipment, and organization and training of a plant fire brigade. These procedures were reviewed and found to meet the NRC requirements and guidelines except, that the fire brigade fire fighting preplans for safety related and safe shutdown plant areas were weak in providing fire brigade
guidance in smoke control, fire damage control and fire suppression water runoff contro The staff's inspections reviewed the licensee's implementation of the fire protection and administrative control General housekeeping and control of combustible and flammable materials in safety related plant areas were satisfactor The plant fire protection features which include automatic fire exting-tt-ishing systems, fire/smoke detection systems, and fire barriers and fire barrier penetration seals in safety related areas were found to be fully functiona Surveillance inspection, tests and maintenance of the plant fire protection features were satisfactor Organization and staffing of the plant fire brigade meets the NRC guideline The training and drills for the fire brigade members meets the frequency specified by the licensee's procedures and the NRC guideline The annual fire protection/prevention audit and 24 month QA fire protection program audit by offsite organizations and the triennial audit by an outside fire protection organization required by the Technical Specifications were reviewe These audits were conducted within the specified frequency and covered all of the essential elements of the fire protection progra The licensee had implemented corrective action on discrepancies identified by these audit The licensee identified, analyzed and reported fire prevention events and discrepancies as required by their plant Technical Specifi cat i an These reports were reviewed and found to be satisfactor Management involvement and control in assuring quality in the fire protection program is eviden This is demonstrated by the adequate implementation of a plant fire protection program that meets the NRC requirements and guideline The licensee's approach to resolution of technical fire protection issues indicates an apparent understanding of the issues and was generally sound and timel Responsiveness to NRC initiatives was found to be timely and thoroug Fire protection violations are rar However, when violations do occur, effective corrective action is promptly take Licensee identified fire protection related events or discrepancies were properly analyzed, promptly reported and effective corrective action was take Staffing for the fire protection program is adequate to accomplish the goals of the position within normal work hours with occasional overt,; me due to a bacl<J og of wor Fi re protection staff positions are identified and authorities and responsibilities are clearly define The licensee's personnel are qualified for their assigned dutie The fire brigade training program is well
defined and implemente The number of trained fire brigade members is sufficient to meet the minimum of the five brigade members per shift as required by the Technical Specification No violations or deviations were identified in the fire protection area during this assessment perio.
Conclusion Category:
1 Board Recommendations The assigned rating for this functional area was based on routine inspections of the licensee's fire protection program; no Appendix R inspections were performed during this assessment perio No changes to the NRC's inspection resources are recommende Emergency Prep a redness Analysis During the assessment period, inspections were performed by the resident and regional staff The inspections included two routine emergency planning 1nspections and observation of one full participation emergency preparedness exercis Inspections disclosed that the licensee had an adequate emergency preparedness organization and staffing at the plant and corporate level, but, as outlined below, showed the need to increase emphasis on training of this staf Corporate management demonstrated their involvement in the emergency preparedness program by their active participation in the emergency exercise and exercise critiqu The routine inspections and exercise showed that the licensee demon st rated the capability to detect and cl ass ify emergencies, assess plant conditions and project offsite consequences, notify offsite agencies, and make appropriate protective action recommendations, except as noted belo During a routine inspection in 1985, one violation was identified for failure to procedurally require issuance of a prompt protective action recommendation to offsite authorities upon declaration of a General Emergenc The procedure was corrected to require such a recommendatio During the emergency exercise in October 1985, it was noted that the protective action recommendation made was not consistent with this procedur In an inspection in March 1986, walk-throughs with Shift Supervisors showed that protective action recommendations made by the Shift
Supervisors were not consistent with one anothe This was indicative of the need for improved training in the area of protective action recommendation During the evaluation period, there were other findings relative to the need for improvements in emergency preparedness training, including the need to develop a formalized system to document training and the need to develop clear emergency training lesson plan Exercise observations further* showed the need for improved training including findings that offsite monitoring teams were not properly briefed or equipped and*that the Recovery Manager was not kept informed of dose assessment calculation One violation was identified during the assessment period:
Severity Level IV violation for the failure to procedurally require issuance of a prompt protective action recommendation to offsite authorities upon declaration of a General Emergenc (85-16) Conclusions Category:
2 Board Recommendations Management attention should be directed towards the deve 1 opment and improvement in the training program for emergency preparednes No change to the NRC's inspection resources are recommende Security and Safeguards Analysis During this evaluation period, routine inspections were performed by the resident and regional inspection staff Corporate and site management's support and security awareness continued to be positive; however, since the last SALP rating period the Surry enforcement history indicates some areas of the program have degrade During the current SALP reporting period Surry Power Station has been cited for two Severity Level III violations and three Severity Level IV violation The most recent Severity Level III violation involved the failure to conduct a proper search at the access control point, which resulted in the introduction of an unloaded rifle into the protected are A previously cited Severity Level III violation resulted from a
licensee employee, previously authorized unescorted access in the protected area, departing and re-entering the protected area through an open vehicle gate without being
identified, searched or being issued a
security photo identification badg The individual remainedin the protected area more than three hours without being detecte The three Severity Level IV violations were similar in that they all related to failure to maintain the integrity of protected or vital area barrier While the identified violations reflected continued deficiencies in the control of access to the facility, and failure to maintain barrier integrity, the licensee continues to take strong measures to prevent personnel error, provide imp roved procedures and ensure adequate training of security personne The licensees efforts to ensure the resolution of operational and functional security issues continued to be positive and reflected managerial attention and corporate support as evidenced by the renovation of the secondary access porta Responsiveness to NRC initiatives was timely, and the licensee had provided evidence of prior planning and generally assigned proper priorities to safeguards matter The licensee demonstrated security initiative in the installation of vehicle barriers at the avenues of approach to the sit The licensee has continued to provide prompt and thorough corrective actions to violations of regulatory requirements and identified technical issues raised during security inspection The violations noted below were not indicative of the total effectiveness and proficiency of the security program at the Surry Nuclear Statio However, it is apparent that continued management attention is necessary to ensure that the performance 1 eve 1 of i ndi vi dua 1 members of the security force is enhanced through training and supervisory attentio The violations identified were as follows: Severity Leve 1 protected are I II for fa i 1 ure to contro 1 access to the (85-30) No civil penalty was issue Severity Level III for failure to conduct a proper search at the access control poin (86-03) No civil penalty was issue Severity Level IV for failure to maintain surveillance over part of the protected area barrie (86-03) Severity level IV for failure to provide intrusion detection capability for penetration of the protected area perimete (86-16) Severity Level IV due to removal of security barriers between the protected and vital are (85-14) Conclusion
Category:
2 Board Recommendations Based on the review of the licensee's enforcement history during this assessment period, the Board has noted deficiencies in access and barrier control The licensee should continue to place emphasis on maintaining controls of access to the facility and barrier integrit No changes to the NRC 1 s inspection resources are recommende Outages Analysis During the assessment period, inspections of plant outage operations were performed by the resident and regional inspection staff The regional staff reviewed the licensee's work in the design change and modification progra The review of the design change and modification program revealed that the licensee had i dent ifi ed, by audit and survei 11 ances problems in this are The corrective actions for these findings were acceptabl Surry Unit 2 conducted a refueling outage from March 20, 1985 to June 27, 198 Surry Unit 1 conducted a refue 1 i ng outage from May 10, 1986 to July 12, 198 The refueling activities on both units were adequately preplanned with realistic assignment of priorities and control of activitie Refueling procedures were adequate to. accomplish the associated tasks efficiently and safel Adequate levels of management attention were observed during refuelin Refueling crew staffing and staff training were observed to be adequat The licensee conducted fuel assembly movements, containment purging, and system venting operations; all were adequat Corporate fuel management representatives as Well as site management were directly involved in the refueling and fuel inspection activitie Refueling was accomplished in accordance with adequately preplanned, properly reviewed, and approved procedure Technical problems encountered during refueling were promptly resolved in a competent and safety conscious manne Post refueling startup test records were adequate and showed that the tests had been performed acceptabl During the Unit 1 refueling outage the operations personnel discovered that one of the twenty control rodlets of the Rod Cluster Control Assembly (RCCA) was broken off and left in a fuel assembl This condition appears to have existed during a portion of the fuel cycle 7 operation where the rodlet may have been fully inserted into the core when it should have been fully withdrawn and then during fuel cycle 8 operation where the same rodlet was
missing from the shutdown bank which was fully withdraw The licensee has performed an extensive evaluation of core parameters during the two fuel cycles that the above described condition existed and determined that the existing accident analyses remained valid, with no new accident types being created. There was no reduction in safety margin required by Technical Specification The licensee's approach to resolution of this issue was complete and typical of their normal resolution of complex issue Severa 1 fue 1 failures were experienced during this period on Unit Fuel element failures did not reflect unfavorably on the way the plant was refueled or operate The failures appeared to result from poor cleanliness control during steam generator rep 1 acement, as we 11 as potent i a 1 vendor manufacturing inadequacie The licensee has completed construction of the first phase of an on-site dry cask spent fuel storage facilit The facility was licensed on July 2, 198 The first fuel elements are scheduled to be placed in casks and moved to the dry cask storage facility in the the fall of 198 A strength was noted in the licensee's technical investigation and understanding of metallurgical conditions that required evaluat1on to determine the need for repairs and other corrective action No significant weaknesses were* observed in the licensee's performance of inservice inspection Management involvement and control in assuring quality was eviden Evidence of prior planning and assignment of priorities was observed and decision making was usually at a level that en sured adequate management revie Records were comp 1 ete and availabl The licensee generally provided viable and sound responses to NRC initiative The licensee's approach to resolution of technical issues was conservative and a clear understanding of the issues was demonstrate No violations were identified during the evaluation perio.
Conclusion Category:
2 Board Recommendations No changes into the NRC's inspection resources are recommende Quality Program and Administrative Controls Affecting Quality Analysis
During this evaluation period, routine inspections were performed by the resident and regional inspection staff The regional staff specifically reviewed the offsite support staff, the offsite review committee, licensee actions on previous enforcement matters, QA pro'gram review management over site of performance indicators, licensee actions on previously identified inspection findings, and test and experiment For the purpose of clarification, Region II defines this area as the ability of the 1 icensee to identify and correct their own problem As such it encompasses the entire plant operation, all plant personnel, as well as those corporate functions and personne 1 that provide sources to the p 1 an The p 1 ant and a corporate QA staff is a part of the entity, and as such, is mainly responsible for verifying qualit The rating in this area specifically denotes the results for various groups in achieving quality as well as the QA staff in verifying that quality is achieve A review was performed on all sections of this SALP report in an attempt to capture apparent strengths and weaknesses related to management controls affecting qualit The following are some perceived strengths in management controls affecting quality:
An innovative approach in using Quality Maintenance Teams to improve maintenance activitie Management i nvo 1 vement in the maintenance area where new programs such as Chesterton valve packing, Visual Information Management System, and maintenance agreement with contractors have been introduced to improve performanc Nuclear performance monitoring where
performance indicators are trended on a monthly basi The assistance of corporate fuel management during the refueling outage and the rapid solution of technical issue High degree of management involvement in licensing activitie The following are some perceived weaknesses in management controls affecting quality:
Inefficient reduction of the corrective maintenance item backlo The total number of outstanding work orders remained above the licensee's set goal for the past several month This observation was based on the review of the licensee's performance indicator trend Degradation of security awareness relative to the enforcement history from the last SALP perio Lack of management involvement in the preparation, conduct, and review of containment integrated 1 eak rate testing ( CI LRT).
Defi ci enci es were i dent i fi ed during this SALP period in reviewing the 1983 Unit 2 CILRT dat However, since this identification the licensee has made significant programmatic improvements in this are Lack of management attention in the determination of the need for improved training in the area of emergency preparednes Offsite support staff activities appeared to be well controlled and various staff members understood their responsibilities and authorities. Corporate staff members frequently visit the site to augment their support functio Corporate staff groups exhibited close working relationships which resulted in coordinated support to the sit The Independent and Operating Event Review Group (IDER) is undergoing changes si nee a new manager was appointed in early 198 Some of the changes include performance of new evaluations in certain areas, streamlining the reviews and information disseminatio The licensee has also formed a Nuclear Overview Committee (NOC) which is made up of upper Tevel management which reviews IDER activitie The licensee QA program, VEPCO Topical Report (Revision 1-5A), was approved by the NRC on February 13, 198 Interviews with licensee personnel identified that personnel were aware of existing QA program requirement Sixteen documents are being revised to incorporate upper tier requirement The licensee utilizes a Nuclear Performance Monitoring Management Information Report, which is prepared monthly, to provide an overview of nuclear pl ant performanc This report has the capability to monitor up to 34 performance indicators. Management acts accordingly if negative trends are identifie Establishment of this report and other tracking and trending mechanisms is indicative of managements support in improving qualit The test and experiments program meets the requirement The licensee is responsive to NRC concerns as evidenced by successful closing of previously i dent i fi ed enforcement matters and inspection finding One violation was identified this assessment perio Severity Level IV violation for failure to assure that vendor identified conditions adverse to quality are promptly identified and corrected (86-02) Conclusion Category:
2 Board Recommendation No changes to the NRC 1 s inspection resources are recommende Training and Qualification Effectiveness Analysis In this evaluation period the regional staff assessed the licenseers training program in different disciplines of the licensee 1 s organization during the routine inspections performed in the functional areas addressed in this SALP repor Training of personnel was looked into in such areas as plant operations, quality assurance, health physics, emergency preparedness, fire brigade, and securit Except for emergency prep a redness, no particular deficiencies were identified in the areas reviewe Routine emergency preparedness inspections and an emergency exercise observation identified weaknesses in the licensee's protective action recommendations and in the communications between different organizational group This indicated a need for improved training in these area The licensee has been participating with INPO (Institute of Nuclear Power Operations) to establish new programs for plant performance improvemen In particular these include the INPO Accreditation Program and the Human Performance Evaluation System (HPES) wherein all plant events caused by human error are inves-tigated using guidelines and methodologies established by INPO and the results transmitted to INPO for use in an HPES data bas INPO has accredited the licensee 1 s licensed operator and non-licensed operator training programs, the radiation protection training program, and the electrical and mechanical technician training program INPO is scheduled to review the instrumen-tation and control, shift technical advisor, and engineer training programs in 198 The check operator training program was instituted during this SALP perio This program is designed to use experienced and well qualified licensed operators to evaluate performance of new operators that are being trained on the simulator and assigned on shift in the control roo.
Two sets of replacement operator licensing examinations and one re qua l i fi cation examination were administered during the SALP rating perio The operating and written examinations administered in April 1985 and July 1986 resulted in el even of fifteen Senior Reactor Operator (SRO) candidates and eight of twelve Reactor Operator* (RO)
candidates passin The requalification examination administered in December 1985 resulted in four of six SRO candidates and four of six RO candidates passin The requalification program was deemed marginally acceptable based on the examination result The replacement examination passing rate of 70% was consistent with the industry averag.
Conclusion Category:
2 Board Recommendations No changes to the NRC's inspection resources are recommende Licensing Activities In general, the licensee 1 s management has demonstrated a high 1 eve l of i nvo 1 vement and contra 1 in assuring qualit Prior planning and assignment of priorities were consistently eviden The licensee's management consistently exercised good control over its activities and has maintained effective communications with the project manage This was specifically evident during the staff review of the amendment request submitted in response to recently revised General Design Criterion-4 (GDC-4).
The management involvement was very obvious in resolving a licensing action on Confirmatory Order for NUREG-0737, Supplement 1 item The corporate management is frequently involved in site activitie The management involvement in licensing of Independent Spent Fuel Storage Installation was quite obviou One area where management involvement could be increased is the area of Inservice Inspection and Testin The quality of ISI/IST program submittals could be improved by making revisions to both units program consistent and timel The licensee almost always demonstrates a clear understanding and approach to resolution of technical issue Conservatism is being exhibited in relation to significant safety issues on a routine basi The resolutions of the technical issues are technically sound, thorough and timely in almost all case This was obvious during recent Equipment Qua l i fi cation audit conducted for the Surry statio The good communications between the licensee and NRC staff have been beneficial to both in the processing of licensing actions and minimizing the need for additional informatio The licensee 1 s involvement in Technical Specification Improvement Program has been noteworth The licensee has been very responsive to NRC initiatives in almost all case The licensee is always cooperative in agreeing to meet with the NRC staff whenever the circumstances call for a meetin The licensee has made every effort to meet established commitments and provided adequate justifications whenever the established deadline cannot be me It is a common practice for the licensee to expeditiously report to the Project Manager any abnormal event regardless of its reportability requirement Also, the licensee notifies the Project Manager well in advance of forthcoming requests for amendments or a review of safety issues. Technic~l issues are resolved in a timely manne In most cases, initially proposed resolutions by the licensee are acceptabl The licensee has adequate staff for licensing activitie The licensing group has exhibited a high degree of cooperation with the NRC staff. Areas of responsibilities are well defined within the organizatio The licensee maintains the staff at the site which is familiar with the plant operation, and which is responsible for supporting licensing activities at headquarter This staff is very helpful in integrating licensing activities with plant operation at the sit.
Conclusion Category:
1 Board Recommendations Non SUPPORTING DATA AND SUMMARIES Licensee Activities Unit 1 began the assessment period operating at powe In August of 1985 a two week maintenance an¢ snubber inspection outage took plac On January 24, 1986, Unit 1 was manually tripped for a maintenance and snubber inspection outag The unit returned to power on February 7, 198 On May 10, 1986, Unit 1 was shutdown for a refueling and maintenance outage which lasted until July 12, 1986, when the unit was restarte Unit 1 ended the assessment period operating at powe At the start of the assessment period, Unit 2 was in a refueling and ten year inservice inspection outag On June 28, 1985, Unit 2 returned to power operatio On October 19, 1985, Unit 2 entered a
maintenance and snubber inspection outage which lasted until November 7, 1986, when the unit was restarted. Another maintenance and snubber inspection outage took place from February 16, 1986 through February 24, 198 Unit 2 was shutdown on June 17, 1986, due to a one gallon per minute service water expansion joint leak inside containment which could not be repaired within the TS Limiting Condition of Operation time fram The leak was repaired and the unit was returned to power on July 3, 198 On July 29, 1986 a recirculation spray heat exchanger tube leak was discovered and the unit was shutdown on July 23, 198 Seven tubes were plugged and the unit was restarted on July 27, 198 Unit 2 ended the assessment period operating at powe An on-site, dry independent spent fuel storage facility was licensed by the NRC in July 198 The licensee was preparing to load spent fuel into the casks at the end of the assessment perio Inspection Activities During the assessment period, routine inspections were performed at the Surry facility by the resident and regional inspection staffs. A full scale emergency preparedness exercise was conducted in October 1985 as described in Section IV.F, abov Two announced inspections were conducted: one in the area of Equipment Qualification; and the other one was an evaluation of the licensee's technical information exchang There were two special inspections on the followup of licensee reported phys i ca 1 security events (Section IV. G).
A 1 so, there were three licensing examination site visit Investigation and Allegation Review There were no significant investigations or allegation activities during this assessment perio Escalated Enforcement Actions Civil Penalties A Severity Level III violation concerning security access control which did not result in a civil penalty was assessed on November 25, 198 A Severity Level III violation concerning access control (weapon in protected area) which did not result in a civil penalty was assessed on April 4, 198.
Orders (those related to enforcement)
Non Licensee Conferences Held During Appraisal Period Enforcement conference held on March 3, 1986, to discuss imp roper search for a firearm at the access control poin Management meeting held on March 3, 1986, to discuss licensed operator requalification examination result Enforcement conference held on September 26, 1985, to discuss a security incident at Surr Confirmation of Action Letters Non Review of Licensee Event Reports and 10 CFR 21 Report Submitted by the license During the assessment period, there were 57 LERs reporte The distribution of these events by cause, as determined by the NRC staff, was as follows:
Cause Unit 1 Component Failure
Design
Construction/Fabrication/
Installation Personnel:
Operating Activity
Maintenance Activity
Test/Calibration
Activity Other Activity
Out of Calibration Other TOTAL 35 Licensing Activities Unit 2
1
1
3
1
Total
6
4
6
1
57 The assessment on licensing activities was based on the following licensing actions:
Multi-Plant Actions (30 complete, 20 in review).
completed actions in this category are:
Some of the
0
0
0
29 Reactor Trip Breakers (B-76, B-78, B-79, B-80, B-81, B-82, B-85, B-87, B-88, B-92)
Environmental Qualification of Safety Related Electrical Equipment (B-60)
Reporting Requirements per GL 83-43 (A-18)
Control of Heavy Loads - Phase II (C-15)
Steam Generator Review per GL 85-02 (C-16)
Diesel Generator Reliability Tech Specs per GL 84-15 (D-19)
TMI (NUREG-0737) ACTIONS (8 complete 14 in review).
Some of the completed actions in this category area:
0
0 Safety Parameter Display System (I.D.2)
Small Break LOCA Outline (II.k.3.30)
Supplemental Confirmatory Order Procedures Generator Package Review (NUREG-0737, Suppl. 1)
Plant Specific Actions (36 complete, 34 in review).
Some of the completed actions in this category are:
0
0
0
0
0
0 Extension for Environmental Qualification Fuel Assembly Reconstitution Adequacy of Station Electric Distribution System Voltages Organization Changes Requested ISI Section Ten Year Interval Unit-2 ASME Section XI Relief Requests Tech. Specs. Amendment for Surveillance of Snubbers Tech. Specs. Amendment for RCS Criticality Temperature Amendment for Revised GDC-4 Dry Cask Independent Spent Fuel Storage Installation Relaxed k-effective (Refueling)
ISI Relief Requests
Significant amendments included:
~
Fuel Assembly Reconstitution (TS Sec. 5.3)
0
0
0 Boron Injection Tank Surveillance Reorganization, and Reporting Requirement for 50.72 and 50.73 Minimum Reactor Coolant Temperature for Criticality Maximum Allowable k-effective During Refueling TS Amendment for Surveillance of Snubbers Amendment for Revised GDC-4
L 31 Enforcement Activity UNIT SUMMARY FUNCTIONAL AREA NO. OF DEVIATIONS AND VIOLATIONS IN EACH SEVERITY LEVEL D
V IV III II I
UNIT N /2 1/2 1/2 1/2 1/2 1/2 Plant Operations Radiological Controls Maintenance Surveillance Fire Protection E~ergency Preparedness Security Outages Training Quality Programs and Administrative Controls Affecting Quality TOTAL 0/1 2/2 1/1 1/1 3/3 2/1 1/1 3/3 2/2 1/1 3/3 11/11 2/2 FACILITY SUMMARY FUNCTIONAL AREA Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Outages Training Quality Programs and Administrative Controls Affecting Quality TOTAL NO. OF DEVIATIONS AND VIOLATIONS IN EACH SEVERITY LEVEL D
V IV III II I
1
1
4
1
2
13 2 Reactor Trips Unit 1
April 29, 1985 - The reactor automatically tripped during shutdown on a turbine trip signal due to a loss of the 11A11 main feedwater pum The unit was being removed from service due to primary system leakage and a scheduled maintenance/snubber outag August 4, 1985 -
The reactor automatically tripped from 100 percent power due to a reactor coolant loop 11A 11 low flow signal to the reactor trip circuitry caused by an operator inadvertently bumping flow sensing lines in loop roo September 11, 1985 -
The reactor automatically tripped on a turbine trip due to inadvertent closure of the condenser inlet valve January 7, 1986 - The reactor tripped automatically due to 11A11 steam generator low level with a feed flow/steam flow mismatch caused by a loss of instrument air due to ice formation in the air drye January 19, 1986 - The reactor was manually tripped due to a dropped jumper cable into the logic cabinet which came in contact with several terminals, initiating a dropping of four control rods and a loss of rod contro January 24, 1986 - The reactor was manually tripped following turbine rampdown due to a fire in 11A 11 phase bus duct caused by ground straps arcin February 7, 1986 - The reactor automatically tripped on turbine trip at 15 percent power due to high water level in 11 C 11 steam generator caused by control difficulty of the main feedwater regulating valv Unit 2 November 7, 1985 - The reactor automatically tripped on turbine trip at 22 percent power due to high water level in 11 B 11 steam generator caused by feedwater contra l di ffi cul ty when the operator shifted the main feedwater control from manual to automati February 16, 1986 -
The reactor was automatically tripped from 16 percent power on a turbine trip due to high water level in the 11 B
steam generator (S/G).
Cause of S/G high water level was excessive leakage through the feedwater regulating and the bypass valve The unit was shutting down.for a snubber outag May 11, 1986 - The reactor tripped automatically from 100 percent power on a overpower delta T signal following turbine runbac The cause of turbine runback and reactor trip was due to undervoltage in the 2J bus resulting from a failure of the 1 oad tap changes on the 'C' reserve station service transforme r June 17, 1986 - The reactor was manually tripped during unit shutdown when the operators observed increasing water level in the 11N1 steam generato Feedwater regulating valve leakage was suspected, contained and repaire Surry Gaseous and Liquid Effluent Release Gaseous (curies for two units)
RII 1985 AV 1/1-6/30/~6 1985 Fission and Activation Gases 13140 1939 2067 Iodine 0.30
.02 0.03 Particulate
.0144
.002
.00123 Tritium 760 11. 7 3 Liquid (curies for two units)
RII 1985 1/1-6/30/86 1985 1984 1983 Fission Activation Products 1. 9.55 9.73 1 Tritium 770 596 1090