IR 05000321/1986042
| ML20207U039 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/24/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207U035 | List: |
| References | |
| 50-321-86-42, 50-366-86-42, NUDOCS 8703240547 | |
| Download: ML20207U039 (44) | |
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b ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-321/86-42 and 50-366/86-42
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Georgia Power Company E. I. Hatch Plant Units 1 and 2 July 1, 1985 through December 31, 1986
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I.
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-tion.
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 operation.
An NRC SALP Board, composed of the staff members listed below, met on February 17, 1987, 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 Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Hatch for the period July 1,1985 through December 31, 1986.
SALP Board for Hatch:
L. A. Reyes, Director, Division of Reactor Projects (DRP), RII (Chairman)
A. F. Gibson, Director, Division of Reactor Safety, RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RI!
V. L. Brownlee, Chief, Reactor Projects Branch 3, DPR, RII D. R. Muller, Project Director, BWR Project Directorate #2, BWR Licensing Division, NRR P. Holmes-Ray, Senior Resident Inspector, Hatch, DRP, RII Attendees at SALP Board Meeting:
F. S. Cantrell, Chief, Reactor Projects Section 28, DPR, RII K. D. Landis, Chief, Technical Support Staff (TSS), DPR, RII R. P. Croteau, Project Engineer, Reactor Projects Secitan 28, DPR, RII C. J. Paulk, Reactor Engineer, TSS, DRP, RII J. Zeiler, Reactor Engineer, TSS, DRP, RII R. E. Hall, Deputy Director, Division of Reactor Safety and Project, RIV II.
CRITERIA t
Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, pret ' rational, or operating phase during the SALP review period.
Each fu: tional area represents an area which is normally significant to nuclear safety and the
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environment and which is a normal programmatic area. Some functional areas may not be assessed because of little or no licensee activity or lack of meaningful NRC observations.
Special areas may be added to highlight significant observations.
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 appropriate.
A.
Management involvement in assuring quality B.
Approach to the resolution of technical issues from a safety standpoint C.
Responsiveness to NRC initiatives D.
Enforcement history E.
Operational and construction events (including response to, analysis of, and corrective actions for)
F.
Staffing (including management)
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Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of these performance categories are:
Category _1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction quality is being achieved.
Category _2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisftetory performance with respect to operational safety or construction quality is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Clcensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not ef fectively used such that minimally satisfactory performance with respect to operational safety or construction quality is being achieved.
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 3.
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 items.
The SALP Board may also include an appraisal of the performance trend of a functional area.
This performance trend will only be used when both a definite trend of performance within the evaluation period is discernible
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and the Board believes that continuation of the trend may result in a change of performance level. The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment period.
Declining:
Licensee performance was determined to be declining near the close of the assessment period.
III. SUMMARY OF RESULTS A.
Overall Facility Performance The stationing of a Vice President on site at Hatch and the reorganization of the site management to enhance the Plant Manager's involvement with operations, maintenance and health physics is evidence of the continued managerial effort to improve performance at Plant Hatch. The management commitment to improving the performance of Plant Hatch was seen in the overall improvement in the areas of emergency preparedness, training, fire protection and maintenance. A high level of performance was noted in emergency preparedness, training, and fire protection. The areas of plant operations, maintenance, surveillance, outages, quality programs and administrative controls affecting quality and licensing were found to have acceptable performance.
Security performance was less than desired. The number and repetitive nature of the violations in the security area indicated a programatic breakdown, however improvement was seen at the end of the period. In the area of outages, increased management attention to control of outage activities is needed.
Programs to improve maintenance are in place however implementation of these programs at the worker level is still being evaluated. Continued management attention in the areas of maintenance, outages and radiological controls is needed and additional management effort should be given to the area of security.
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B.
The performance categories for the current and previous SALP period in each functional area are as follows:
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Functional Ar'a Dates Dates e
November 1, 1983 July 1, 1985 June 28, 1985 December 31, 1986 Plant Operations
2 Radiological Controls
2 Maintenance
2 Surveillance 2'
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Fire Protection
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Security
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Refueling / Outages
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Quality Programs and
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Training
Administrative Co'ntrols i
Affecting Quality
2 Licensing Activities
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IV.
PERFORMANCE ANALYSIS
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A.
Plant Operations 1.
Analysis
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During the assessment period, inspectior of plant oper tions were performed by the resident inspector and regional inspection staffs.
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Management involvement with plant operations continued at a high level during this assessment period. The plant Managar's function was redefinco' such that only the departments directly involved
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with plant operations (operations, r.41ntenance and hsalth physics
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and chemistry) fall in his area of responsibility.
This change allows the plant manager to devote mort of his attention to plant operations. The support functions, which reported to the plant manager, now are the responsibility of a na.w position, plant-support manager. Also a new on-site position of Vice President Hatch has been established to provide ethanced -corporate involvement in plant operations. Along with the reassignment of functions at the plant manager level, changos were also made in the func tion of the manager of operations.
Duilding and grounds and sacurity were moved from under the operations manager. iiii s removes the associated management distractions fro'n the manager of operations.
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With the exception of violation c,
all violations in the operation: area had the same root cause of inadequate attention to detail., Violations were identified during this assessment period in the areas of design change request (a & b), clearance and jumper cont-ol (d & e), operator attention to control panels (f &
h) and reporthq timeliness (g).
Other than attention to detail no underlying programic breakdown was seen.
Responsiveness to NRC initiatives was sound and thorough as demonstrated by the results of the Appendix R, the Equipment
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Oualification ard the Regulatory Effectiveness Review team inspections. There were no major finaings brought out at the ex1t
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interviews fron' these inspections. Another example was that the new emergency operating procedures (EOPs) were in place one month early and include fire protection actions. These are color coded flow chart formated and symptom-based. Also shutdown from outside the control room procedures are symptom-based, flow chart formated procedures. Management approach to safety concerns was good, with t bely and prudent actions taken.
For example, on December 3, 1996, when ready to return Unit 2 to operation after a refueling
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outage, a large spill of con' :ninated water occurred when the air supply to the fuel storage pool transfer canal seals was inadvertently isolated.
The decision was made not to start up Unit 2 due to the distraction and manpower drain of the spill recovery.
The operator response to plant transients was proper and timely.
Operator training and use of the on site simulator for training contributed to the proper response to plant transients.
Plant equipment functioned as designed when called upon by plant transients.
A discription of the plant trips encountered is provided in
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section V.J.
Of the fourteen listed scrams nine were due to equipment failure, two due to licensed personnel error, one due to
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non-licensed personnel error and two due to inadequate procedures.
The three personnel errors do not seem to be indicative of a programic problem.
The equipment f ailures are addressed by the licensee's predictive and preventitive maintenance programs. The Main Steam Isolation Valve (MSIV) steam breakage problem in Unit 2 was corrected by installation of new modified stems.
Determinations of the final correction of MSIV problems continues as an engineering task, f
During the SALP period, events or problems concerning Unit 1 were discussed at three NRR Operating Reactors Event Briefings.
The three events were each of a dif ferent nature (i.e., flooding of safety related areas, crack in the drywell inerting and purge valve, a leak from spent fuel pool).
Also, Unit 2 events or problems were discussed at three NRR Operating Reactors Event
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9, Briefings.
The three' events were each of a different nature
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(i.e., loss of diesels, fuel assembly lifting rig failure, rack in torus ver.t header).
In addition, a study of the reported f
events shows no pattern of repetition,. which suggests that corrective actions are effer.tive.
During the reporting period, the Unit 1 maintained an average service of approximate 83.6% excluding the outage.
Unit I was critical for approximately 8800 hours0.102 days <br />2.444 hours <br />0.0146 weeks <br />0.00335 months <br />, during the reporting period and experienced an average of 0.57 scrams /1000 hrs critical. This scram frequency is significantly lower than the current national average of 1.14 scrams /1000 hrs critical. During the period the forced outage rate for unit I was approximately 6 percent compared to a previous cummulative forced outage rate at the start of the period of 12 percent.
During the reporting period, Unit 2 maintained an average service i
of 87.2% excluding the outage.
Unit 2 was critical for approximately-10700 hours during the reporting period and
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experienced an average of 0.84 scrams /1000 hrs critical.
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scran frequency is lower than the current national average of 1.14 scrams /1000 hrs critical.
During the period the forced outage
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rate for unit 2 was approximately 5 percent compared to a previous
cummulative forced outage rate at the start of the period of 17.8 percent.
Both units have shown significant improvement in the forced outage rates.
Operating events at Hatch, Unit I and 2 have been reported promptly, accurately and conservatively.
The licensee's 50.72 reports indicate that events have been reported in a timely manner and that corrective action was taken promptly.
The use cof the simulator for operator training in control roem discipline and use of procedures continues to be a strong point.
Control room discipline is very good and the operations personnel all in uniform helps improve the professional appearance of the control room.
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material allowed for access to plant areas necessary for maintenance. There was a continuing effort to reduce the extent of surface contamination throughout the plant. The reduction of contamination in the plant resulted in better housekeeping.
Eight violations were identified:
a.
Severity Level IV violation for failure to get prior Commission approval of system modifications which required a Technical Specifications change. (85-24) (Unit 2)
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Severity Level IV violation for failure to incorporate design change in an operations procedure. (85-32) (Unit 1)
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Severity Level IV violation for a backseated valve closure time exceeding limits.
(85-34) (Unit 1)
d.
Severity Level IV violation for failure to follow written procedures resulting in flooding of the south east diagonal, Unit 1. (85-39)
e.
Severity Level IV violation for failure to adequately prepare lifted wire and jumper sheets resulting in an unplanned ESF actuation. (86-03) (Unit 1)
f.
Severity Level IV violation for loss of shutdown cooling.
(86-12) (Unit 1)
g.
Severity Level V violation for failure to make timely reports. (85-24) (Unit 1)
h.
Severity level V violation for Core Spray jockey pump not running when required. (86-09) (Unit 2)
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Conclusion Category: 2 3.
Board Recommentations No change to the level of NRC staff resources applied to the routine inspection program is recommended.
B.
Radiological Controls 1.
Analysis
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During the assessment period, inspections were performed by the l
resident and regional inspection staffs.
This included confirmatory measurements using the Region II mobile laboratory.
In comparison with the previous assessment period, the licensee showed some weakening of the radiation protection program.
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licensee identified problems in the positive access control l
program for high radiation areas where plant personnel were intentionally bypassing the controls.
Licensee procedures required that areas with general area dose rates greater than 100 millirem per hour be maintained as locked high radiation areas.
Technical Specifications require that doors providing
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access to areas where the general area dose rates are greater than 1000 millirem per hour, be locked to restrict access.
The licensee took effective corrective action to prevent recurrences.
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Problems were also identified in the area of proper surveys of materials being removed from the Radiation Control Area (RCA).
This area was cited a second time when the licensee's corrective action was found inadequate. Other deficiencies were noted during the assessment period and included radiation survey instrument calibration, improper packaging of low specific activity (LSA)
material for shipment and inadequate posting of radiation areas in the facility.
Licensee management support and involvement in matters related to radiation protection and radwaste control was adequate.
Health physics management was involved sufficiently early in outage preparation to permit adequate planning. The manager of health physics generally received the support of other managers in implementing the radiation protection program.
The performance of the health physics staff during routine and outage operations was satisfactory. During the assessment period,
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the licensee began a program to reduce the number of contract health physics technicians employed by the utility and increase the size of the in-house health physics staff.
Fatigue of the in-house health physics staff was noted as a potential problem area as well as a low health physics staffing level due to vacations and completion of training requirements. Another factor contributing to the fatigue of the staff was the change in non-outage work scope, which exceeded the initial planning scope and required additional health physics involvement.
In response, the licensee hired additional contract health physics technicians to supplement the permanent plant staff and limited the amount of overtime the permanent plant health physics staff could work.
During a subsequent inspection, it was noted that the staffing level was still less than the licensee's objective but the fatigue of the staff was no longer evident.
Resolution of technical issues by the health physics staff was adequate as demonstrated by the licensee's response to an NRC finding in the area of instrument calibration tracking.
A computer tracking system was developed to replace the manual bookkeeping system used by the licensee.
There were instances where there were delays in resolving technical issues in a timely manner.
For example, the licensee was in the process of installing a modification package to the post accident gaseous effluent monitoring system designed to minimize the detector's over-response to high energy gases.
However, this modification package had been available from the vendor for several years.
The site internal audit organization conducted audits of the health physics program using personnel that were experienced in the health physics area. The audit program was comprehensive and was of sufficient scope and depth to identify problems and adverse trends; however, the licensee was slow in resolving audit
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findings.
In general, it was noted that many records within the area inspected were either _ incomplete, unavailable, or not maintained.
Evidence of management involvement in assuring quality was lacking as noted in the inadequate management review of data resulting in the reporting of numerical errors in the first-half 1985 Semi-annual Radiological Effluent Release Report.
During the evaluation period, the licensee's radiation work permit and respiratory protection programs were found to be satisfactory.
Control of contamination and radioactive materials within the facility was adequate.
In July 1985, the licensee maintained approximately 40% of the total area regarded as the Radiation Control Area (RCA) under contamination controls. The total area did not include the drywells, condenser bays or spent fuel pools.
By the end of the assessment period, the area under contamination controls had decreased to approximately 25% of the total RCA.
During 1985, the licensee's cumulative exposure was 409 man-rem per unit as measured by thermoluminescent dosimeter (TLD). This value was well below the national average of 800 man-rem per unit observed at similar BWR facilities. The total exposure through December 31, 1986, as measured by TLD was 835 man-rem per unit.
Licensee management stated that the increase in occupational exposure observed at the facility was due to Appendix R and Inductive Heat Stress Improvement work performed during the year.
During the assessment period, the licensee encountered problems
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with noble gas contamination on personnel clothing.
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contamination decayed in approximately thirty minutes, but
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presented problems for plant personnel exiting the reactor l
building.
In an effort to control the noble gas problem, the licensee reduced power in Unit 2 to 85 percent. The licensee also instituted a daily inspection program to identify potential leaks in piping which might contribute to the noble gas problem and also began a program for the replacement of leaking small bore piping which was identified as a source of noble gas in the plant.
The liquid and gaseous effluent management program was reviewed l
and the quantities of radioactive materials in both liquid and l
gaseous effluents are summarized in Table 1 Section V.K.
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licensee was below average in releases of gaseous effluents except for tritium. For liquid effluents, the licensee was higher. Dose
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to members of the general public were well within the regulatory l
l limits of 40 CFR 190.
In the area of radiological confirmatory measurements, during participation in the NRC's spiked sample program, the licensee
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l The licensee demonstrated average performance during measurement comparison with the Region II mobile laboratory.
Thirteen of nineteen comparisons were in agreement with trends that indicated l
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measurement bias. This indicates a programmatic weakness in the radiochemistry quality assurance program.
Inspectors noted that though the programs contain _ the major elements of Regulatory Guide 4.15,
" Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," there was no mechanism or system to provide an integrated analysis of all the elements in the program. There was a lack of coordination between interlaboratory comparison studies, gamma spectroscopy detection trending, instrument calibration, etc.
These circumstances were partially responsible for inaccurate measurements which resulted in a violation.
During 1985, the licensee made 158 solid radioactive waste shipments totalling 73,884 ft3 (36,942 ft per reactor) and
containing 38,311 curies of activity. These values are well above 3 per reactor shipped by other the national average of 28,800 ft utilities with similar facilities. Through December 31, 1986, the licensee had made 117 solid radioactive waste shipments totalling 3 per reactor) and containing 882 curies of 48,184 ft3 (24,092 ft activity. The licensee purchased a 400,000 pounds per square inch compactor in 1986 which has been effective in reducing the volume of solid radioactive waste shipped.
The increase in solid radioactive waste shipped was due to the extensive outage activities, clean-up following the recircolation pipe replacement outage and the licensee efforts to cleanup the plant.
Six violations were identified:
Severity Level IV violation for two examples of failure to a.
calibrate radiation survey instruments (86-01),
b.
Severity Level IV violation for failure to properly package LSA material transported for burial (86-01).
c.
Severity Level IV violation for failure to monitor and authorize the release of materials from the RCA and for failure to perform adequate surveys of materials being removed from operating buildings (86-18).
d.
Severity Level IV violation for three examples of failure to post radiation areas (86-34).
e.
Severity Level IV violation for failure to monitor and authorize the release of materials from the RCA and for failure to perform adequate surveys of materials being removed from operating buildings (86-34).
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f.
Severity Level V violation for failure to verify the volume of the geometries cited to conduct surveys of gaseous radioactive material released to the environment which resulted in inaccurate gamma spectroscopy measurements (86-21).
Deviation:
Deviation for failure to take appropriate action following the required review to ensure continuing performance during a required surveillance (86-04).
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Conclusion Category:
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Board Recommendations No change in the level of NRC staff resource applied to the routine inspection program is recommended.
C.
Maintenance 1.
Analysis During this assessment period, inspections were performed by resident and regional inspectors.
Two team inspections were conducted; one for allegation investigation in the area of valve maintenance, and one of two weeks duration for maintenance assessment. Due to back to back category 3 ratings in this areas, management meetings between NRC and Georgia Power Company (GPC) to discuss maintenance program progress were held in the first and second quarters of 1986.
These meetings provided a solid understanding of NRC concerns and the GPC initiatives for improvement of maintenance at Hatch.
Allegations in the maintenance area that were reviewed resulted in two violations (see violation c & h). In each case, the licensee took prompt and positive corrective actions.
l The maintenance training and procedures upgrade programs were
particularly comprehensive.
Maintenance training programs including mechanical, instrument and control technician, and electrician have been implemented and submitted for INPO accreditation. Approximately one third of the maintenance personnel are in training at all times. The maintenance training laboratories and equipment were excellent and incumbents were utilized in program development.
The licensee is requiring that all maintenance personnel, including qualified incumbents,
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complete the entire upgrade training and qualification program which should improve overall proficiency in the maintenance area.
In the area of procedures upgrade, the licensee has dedicated a large full time staff to ensure adequate revision and review.
l Procedures are reviewed against vendor manuals, receive a
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technical review by a job representative, and also receive an ALARA review.
A validation review by qualified personnel, to include a walkthrough or use of the procedures, has been added.
This validation process should improve the quality and useability of the new procedures. The resident staff reviewed the validation effort in December of 1986 and found that 4 to 6 procedures per week were being validated with about 200 completed.
The maintenance team inspection placed emphasis on a review of recently upgraded maintenance programs. Areas reviewed included maintenance training, procedures upgrade, maintenance including motor operated valves, corrective actions, deficiency reporting, quality trend programs, quality assurance audits, operational events and feedback of experience, and control of contract maintenance personnel.
The inspection indicated that Georgia Power had expended considerable resources in the upgrading of those programs, and that they were comprehensive with the potential for significantly upgrading maintenance performance.
The maintenance team inspection indicated that the upgrade programs had not yet been fully implemented at the working level.
Specific areas of concern included failure to follow procedures, failure to document expansion in work scope or problems identified during maintenance activities, and failure to take timely and adequate corrective actions for previously identified deficiencies. Although these deficiencies were addressed in the last SALP, several violations identified during this period were due to the same deficiencies. The licensee's lack of timely and adequate response to some of the identified deficiencies and the standard response to several violations that "the event, which had no actual safety consequences, occurred," indicate that NRC findings may be taken too lightly. In December 1984, the licensee was cited for failing to document a problem detected during maintenance and the subsequent expansion in scope to correct the problem (violation 50-321, 366/84-46-02).
As a result of the maintenance inspection during this SALP period, the licensee was cited for similar deficiencies.
On the basis of a procedure revision and training program completed in December 1986, several months after the inspection and the events, the licensee stated that the violations had no actual or potential safety consequences and requested that they be downgraded to inspector followup items.
Subsequently, failure to document deficiencies detected during maintenance and corrective actions taken, played a role in the release of several thousand gallons of contaminated water to the environment through a fuel pool transfer canal seal in that the defective air pressure regulator and the use of the manual valve as a throttle valve were not documented.
In the previous SALP period, the licensee was cited for failing to provide operational experience feedback to maintenance personnel (violation 321,366/85-07-03).
During this SALP period a program i
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to ensure the feedback of operating experience to maintenance personnel had still not been established. In addition, the audits required by NUREG 0737 to ensure the program for feedback of operating experience is functioning adequately at all levels, had been assigned to engineering and had never been conducted. This was an additional violation, and, if the audits had been conducted as required, the failure to provide this training at the mechanics level, as well as the failure to take corrective action for the previous violation, should have been detected.
The maintenance inspection also placed emphasis on the implementation of actual maintenance and the effectiveness of -
upgraded maintenance programs.
This inspection was conducted during a unit outage which provided additional maintenance activities for observation. The inspection results indicated that the upgraded maintenance programs involving outage management were not yet implemented to any significant extent.
The licensee experienced problems with establishing priority of maintenance work orders related to the outage. The problem is being evaluated by the licensee and efforts are being made to reach a resolution.
A violation for failure to implement or provide adequate procedures was cited. Two of the procedural violation examples indicated a lack of adequate control over vendor and contractor personnel, which was an area of upgrade.
A post maintenance diesel generator test observed indicated inadequate procedures and preparation.
There were two positive indications during this inspection that the upgraded programs may be starting to take effort. The design change control program, which has been subject to significant upgrade, appeared to be effective in controlling design changes t
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and related documents such as procedures and drawings.
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addition, the pre-outage maintenance ALARA briefing appeared to be j
effective in reducing the exposure to plant and contract l
personnel.
In summary the maintenance team inspection revealed
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several weaknesses but did not result in any enscalated i
enforcement action.
A comparison of LER's from the previous SALP period to this SALP period showed an overall reduction in component failure which indicated an improvement in maintenance.
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the maintenance superintendents were replaced during this l
assessment period.
This reorganization was to strengthen maintenance management.
As previously mentioned, the reorganization at the plant manager level was such that the plant manager only has operations, health physics and chemistry, and maintenance departments under him. This organization allows more management attention in the area of maintenance.
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i The predictive.and preventive maintenance programs have shown results.
Pumps have been repaired prior to failure when the lube oil analysis program has observed water or wear particles in the oil.
Infrared analysis has been used to locate loose ground straps, loose bolts on a disconnect switch pivot arm, and a leaking radwaste valve.
Vibration analysis has discovered safety related pump misalignment, bad motor bearings on several pumps and-other vibrational type problems prior to component failure. The programs of predictive and preventive maintenance have shown that they save challenges to systems by pre-failure identification of
problems.
There was an effort to reduce the number of contract personnel at Plant Hatch.
This reduction in contractors provides for better control of contractors. GPC has been changing their contractor agreements so that GPC has a voice in the selection of contractor workers. A program to train contractor personnel was instituted to reduce personnel errors, improve procedure compliance and work quality.
Eleven violations were identified:
I a.
Severity Level IV violation for inadequate procedure causing loss of shutdown cooling in Unit 1. (85-34)
b.
Severity Level IV violation for failure to maintain secondary containment. (86-03) (Unit 1)
c.
Severity Level IV violation for failure to document conditions adverse to quality when the wrong RHR relief valve
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was worked on the RHR heat exchanger and for failure to properly implement procedures by omitting steps which were required to be performed. (86-08) (Unit 1)
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Severity Level IV violation for failure to perform valve limit switch adjustment when required by procadure. (86-30)
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Severity Level IV violation for failure to reinstall RHR system valve internals. (85-22)
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Severity Level IV violation for failure to properly document maintenance activities. (86-22)
g.
Severity Level IV violation for failure to document the results of preliminary leak rate tests (86-22)
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Severity Level IV violation for grinding down a replacement
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wedge without proper administrative controls and procedural l
requirements (86-08).
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Severity Level IV violation for failure to assure that a torque multiplier was properly calibrated.
(86-22)
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Severity Level V violation for improper reference numbers used in safety-related calibration procedures. (85-22)
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Severity Level V violation for failure to follow inspection program for class 2 tubing welds.
(85-26) (Unit 1)
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Conclusion Category:
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Board Comments The board ackowledges that programs to improve the maintenance area are in place. The board encourages you to continue your efforts to improve these programs and implement them on the working level. The board expressed concern with the frequent use of the following statement in response to violations.
"The events, whicn had no actual or potential safety consequences, occurred."
This statement may foster an attitude that NRC findings are not significant and problems do not exist.
A return to the normal level of NRC staff resources applied to the routine inspection program is recommended.
D.
Surveillance 1.
Analysis During this assessment period, inspections were performed by resident and regional staffs.
In 1985 a line-by-line review of Technical Specifications, for both units was conducted to insure procedural coverage of all surveillance requirements.
This review was by highly qualified personnel from the operations and maintenance departments.
No attempt was made to determine the technical adequacy of the procedures as part of this review. Errors were found for failing to incorporate into procedures TS surveillance requirements for
!
instrument and equipment calibration.
Areas with errors were drywell radiation monitoring, RCIC flow instrumentation, 4160 VAC undervoltage relays; and liquid and gaseous effluent monitoring systems.
Also, other areas identified by the licensee with surveillance inadequacies included fire protection, primary containment, diesel generator battery, and reactor water level instrumentation.
The licensee, in its response to surveillance violations c and d concerning the failures to perform control room filter testing, addressed these licensee identified items (LERs)
in terms of their procedure upgrade program (PUP). In the future,
.
.
the technical adequacy will be assured by the PUP. However, the PUP validation of the surveillance procedures is not planned to be accomplished until December 31, 1987.
Two surveillance inspections were performed involving containment leak rate testing.
No violations were identified for Unit I and one violation was identified for Unit 2 (see violation f). The licensee failed to determine the change in leakrate due to repairs or adjustments made to the containment boundary prior to the type A test. Without quantifying the leakage which was corrected the "as found" containment leak rate cannot be determined. This violation resulted from a breakdown of program controls rather than a failure to have a program.
An inspection of the local leak rate test program was conducted
'and some weaknesses were identified. The licensee had committed to re-evaluate the local leak rate test program for both units to identify and resolve any non-conservative local leak rate tests.
The NRC had not yet reviewed the licensee's findings as of December 31, 1986; however, it should be noted that Unit 2 failed the first attempt to perform the type A test due to a valve packing leak which was not tested in the leak test program.
Both Unit I and Unit 2 failed the "as found" containment integrated leak rate test.
The licensee has an adequate leakrate test procedure which conforms to the regulations, assigns responsibilities, and controls test activities. Test personnel have a working knowledge of leak rate testing and an understanding of the technical aspects of 10 CFR 50, Appendix J.
In this regard, the licensee is assisted by leak rate consultants from Bechtel who are experienced and knowledgeable in leak rate testing.
Management involvement and responsiveness to NRC concerns are indicated by the development of acceptable procedures, obtaining the service of leak rate test consultants and commitment to evaluate and upgrade this test program.
The computer data base control of surveillance performance continues to be a strength of the surveillance program.
Maintaining the procedures current with the changing requirements is still a problem.
TS Amendment 51 to Unit 2 TS changed the snubber inspection criteria but was not incorporated into the surveillance procedure (violation b.).
The following violations were identified:
a.
Severity Level IV violation for personnel error resulting in isolation of Reactor Core Isolation Cooling (RCIC). (85-34)
(Unit 2)
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_
.
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__.
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b.
Severity Level IV violation for failure to recognize 'an inoperable snubber. (86-15) (Unit 2)
c.
Severity Level IV violation for failure to establish the required flow condition across the control room filters using an inadeouate procedure. (86-28)
d.
Severity Level IV violation for failure to meet the required frequency of surveillance for the control room filters.
(86-28)
e.
Severity Level IV violation for improper stroke time testing of power operated valves (86-30)
f.
Severity Level IV violation for a failure to determine the change in leak rates prior to repairs or adjustments.
(86-39)
2.
Conclusion Category: 2 3.
Board Recommendations No change in the level of NRC staff resources applied to the routine inspection program is recommended.
E.
Fire Protection
,
1.
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 a review of the implementation of the safe shutdown and related fire protection requirements of 10 CFR 50 Appendix R.
The Appendix R inspection was conducted near the end of this assessment period by a team inspection group.
This inspection reviewed the following areas:
the Hatch safe shutdown analysis; random sample of the cable routes of shutdown components; fire protection features provided for the shutdown components and associated cables; associated circuits for shutdown components; shutdown circuits fuse and breaker coordination; and emergency shutdown procedures available for use in the event of a fire.
This inspection verified, based on areas reviewed, that the plant design and available plant fire protection and operational features are sufficient to assure that one shutdown train or pathway can be maintained free from fire damage to permit the plant to be shutdown following a fire.
The licensee's analysis and plant shutdown capability are conservative and use both high
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and low pressure reactor coolant makeup systems to maintain the coolant level above the reactor core. These meet the requirements of Appendix R Sections III.G and L.
For the routine program, the licensee has issued procedures for the administrative control 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 guidelines except for several procedure weaknesses which could result in future discrepancies in the areas of bulk gas storage, fire brigade drills, fire brigade instructors qualifications and fire fighting strategies.
The licensee promptly initiated corrective action to resolve the inspector's Concerns.
The staff inspections reviewed the licensee's implementation of the fire protection and administrative controls.
General housekeeping and control of combustible and flammable materials were satisfactory.
The fire protection extinguishing systems, detection systems and fire barriers and fire barrier penetrations were found to be in service or the appropriate limiting condition for operational requirements of the Technical Specifications had been implemented.
Surveillance inspection and tests and maintenance of the fire protection systems and features were satisfactory.
Organization and staffing of the plant fire brigade met the NRC guidelines. The training and drills for the brigade members met the frequency specified by the procedures and the NRC guidelines.
The annual fire protection / prevention audit and 24 month QA fire protection program audit by offsite organizations and triennial audit by an outside fire protection organization required by the Technical Specifications were reviewed.
These audits were conducted within the specified frequency and covered all of the
'
essential elements of the fire protection program. The licensee l
had implemented corrective action on discrepancies identified by the audit.
'
The licensee identified and reported fire prevention events and discrepancies as required. These reports were reviewed and found to be satisfactory.
,
The management involvement and control in assuring quality in the fire protection program is evident due to the frequent involvement in the site fire protection program and due to the issuance and implementation of fire protection procedures that met the NRC requirements and guidelines. The licensee's approach to resolution of technical fire protection issues indicated a
clear l
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understanding of the issues, and was sound and timely.
The responsiveness to NRC initiatives were technically sound and thorough.
Licensee identified fire protection related event or discrepancies were properly analyzed, promptly reported and effective corrective action was taken.
Staffing for the fire protection program was adequate.
Fire protection staff positions were identified and authorities and responsibilities were clearly defined.
Personnel were well qualified for their assigned duties. The fire brigade training program was adequately defined and implemented.
No violations or deviations were identified.
2.
Conclusions Category:
3.
Board Recommendations The board recommends that NRC staff resources applied to the routine inspection program be reduced.
F.
Analysis During the assessment period, inspections were performed by regional and resident inspection staffs.
These included observation of two exercises and three routine inspections. One revision to the radiological emergency plan was reviewed.
The most recent routine inspection and emergency preparedness exercise evaluation disclosed that the licensee demonstrated the
'
capability to promptly identify and correctly classify emergency events consistent with the current emergency plan and implementing procedures.
No problems were identified during the exercise evaluation and routine interviews of emergency response personnel who may be assigned as interim emergency director.
Emergency response personnel have demonstrated significant improvement in identification and classification of emergency events.
Review of emergency action levels (EALs) and classification procedures disclosed, however, that two examples of initiating conditions for the notification of an unusual event (NOVE) listed in Appendix 1 of NUREG-0654 were not included.
This finding was also identified by the licensee's site quality assurance team during an audit of the emergency preparedness program.
The licensee committed to corrective action.
-
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.
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Routine inspections and exercise evaluations disclosed that emergency response personnel demonstrated the capability to make
'
protective action decisions following declaration of a general
'
emergency.
Previous findings disclosed that emergency response personnel were unable to promptly determine recommended protective actions following a general emergency declaration, and were unfamiliar with pertinent procedures addressing such requirements.
,
During this SALP period, protective action recommendations were l
promptly made and were consistent with implementing procedures and regulatory guidance. During this assessment period, the licensee demonstrated significant improvement in protective action decision making and effective use of pertinent procedures.
The licensees notification procedures and communications systems were adequate.
During the exercise, initial telephone notification of state, federal, and local response organizations was completed within 15 minutes following declaration of each emergency classification. All followup notifications to offsite response organizations were reviewed and approved prior to dissemination.
Communications within and between the emergency response facilities and the flow of information and data among the various groups within the emergency response organization was effective.
The latter finding represents an improvement over previous disclosures identified during this assessment period which addressed inadequate exchange of information and flow of data between the licensee's response facilities.
Shift staffing and augmentation satisfied the staffing criteria defined in the emergency plan and Table B-1 of NUREG-0654.
Accordingly, the licensee maintained updated emergency call lists for contacting essential offshift emergency response personnel, if
,
needed. The emergency call lists were adequate to accommodate l
staffing requirements over prolonged periods.
i
!
The licensee implemented a major change to the emergency response l
training procedure involving the training matrix. As a result, an improved training program was initiated.
The first phase of the program was designed to complete initial training of all emergency response personnel by the end of the 1986 calendar year. The effectiveness of the revised training program was demonstrated by
,
!
improvement in the following areas:
emergency detection and classification; protective action decisionmaking; and notification l
and communications. Onshift operations supervisors were cognizant i
of their duties, authorities, and responsibilities during the initial stages of the emergency exercise and walkthrough interviews conducted during the routine inspection. Licensee site l
and corporate management were committed to maintaining an effective emergency response training program to assure that
!
'
emergency response personnel demonstrate required understanding of l
their assigned duties and responsibilities.
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.
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_ _
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A routine inspection disclosed that annual independent audits of the licensee's emergency preparedness program were conducted during the subject assessment period. The audits satisfied the annual frequency requirement, and verified that evaluation of the licensee's interface with state and local governments were included. A previous finding disclosed that required evaluation of licensee /offsite support organizations interface was excluded.
Inspection also disclosed that the licensee's program for followup action on audit, drill and exercise findings was implemented as required. The licensee initiated an " Action Item Tracking System" to assure that corrective actions are implemented for identified deficiencies.
Dose calculations and assessment were reviewed incidental to emergency detection and classification during annual exercises and a walk-through interviews of emergency response personnel during routine inspections.
Personnel evaluated demonstrated required knowledge of dose assessment and projection methods.
No discrepancies were disclosed.
Emergency response personnel continue to demonstrate adequate training in required dose assessment and projection methods and practices.
Routine inspections and annual exercise evaluations disclosed that the licensee continues to meet its commitments regarding coordination with offsite support organizations, as defined in applicable agreement letters.
The licensee provides training, manpower, and equipment resources consistent with the agreements.
Similarly, offsite response organization manpower and equipment resources have been available to the licensee during this assessment period.
The initial exercise evaluation conducted during the subject assessment period disclosed several problems regarding coordination of press releases and emergency news information between the licensee and offsite support organizations. A course of corrective action is in progress to improve the public information program and ensure resolution of the subject NRC, FEMA, and licensee identified exercise weakness. The licensee is committed to fully exercise the public information program during the 1987 Hatch Emergency preparedness exercise.
The licensee conoucted detailed critiques to identify and assign for resolution all drill and exercise weaknesses.
Evaluation of exercises conducted during the subject assessment period confirmed that drill and exercise weaknesses, deficiencies, and indicated improvements were documented by the licensee for review and required correction to assure that duties, responsibilities and functions of site and offsite emergency response personnel are implemented as required.
__
...
....
_ _ _ _ _ _ _ _ _ _
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Corporate and plant management were committed to maintenance of an effective emergency response program and was directly involved in the exercises and critiques. The licensee was responsive to NRC comments on emergency preparedness issues.
Four violations were identified during this assessment period. It should be noted that all have been resolved except the final violation. This item remains open pending the licensees final QA review, and NRC verification of corrective action.
a.
Severity Level IV violation for failure to adequately train operations supervisors to determine protective action
-
recommendations requisite to assurance of public health &
safety. (85-23)
b.
Severity Level V violation for failure to place "Use of Emergency Communications" procedure in TSC. (85-23)
,
c.
Severity Level V violation for failure to include evaluation
-
of adequacy of licensee interface with State and offsite support entities.
(85-23)
d.
Severity Level V violation for failure to implement procedure
" Maintenance of the Emergency Organization" as required.
(86-07)
2.
Conclusions Category:
3.
Board Recommendations The board recommends that NRC staff resources applied to the routine inspection program be reduced.
G.
Security 1.
Analysis During the assessment period, inspections were performed by the resident and regional inspection staffs.
Additionally, a regulatory effectiveness review (RER) was conducted towards the end of the period.
The number and repetitive nature of the violations identified during this period indicate a programmatic breakdown.
These violations were caused by a combination of inadequate procedures, inadequate compensatory measures, and lack of management oversight.
Several violations had multiple examples, demonstrating long term weaknesses. Thirteen examples of computer failures and subsequent inadequate compensatory measures were
.
.
identified during a review of operations during the months of January and February.
These computer failures were relatively common during the previous year.
An inspection of the documentation concerning these thirteen failures yielded twenty-two examples of inadequate documentation. These types of examples demonstrate the lack of management oversight and inattention to detail evident during the earlier part of this review period.
The licensee implemented comprehensive corrective actions in response to NRC identified problems, however, the licensee did not aggressively identify problems on its own.
The licensee does however maintain an adequate security training program which has produced well-trained security personnel.
The security organization is adequately staffed and equipped.
During the latter part of the assessment period, the licensee implemented several large scale corrective measures which were proven to be effective as evidenced by the RER.
Although the report had not been issued at the end of the period, the team members found no significant weaknesses and had several favorable comments.
The licensee directed an audit of the Plant Hatch security program; formed a corporate task force to review plant security procedures; and hired a corporate Nuclear Security Manager. This type of management action appears to be producing an improvement in the security program, however, there has not been a sufficient
,
period of time to assure this action will produce a long term improvement.
Eleven violations were identified during this evaluation period:
a.
SL III - Inadequate compensatory measures following loss of alarm annunciation in both alarm stations.
This violation resulted in a civil penalty.
(86-06)
b.
SL IV - Individual was badged prior to completion of background screening.
(85-36)
i c.
SL IV - Failure to report security events.
(86-06)
d.
SL.IV - Failure to perform functional tests following loss of alarm processing capabilities.
(86-06)
e.
SL IV - Failure to maintain adequate documentation.
(86-06)
f.
SL IV - Inadequate compensatory measure at a temporary protected area barrier.
(86-06)
_ _ _ _ _ _ _ _ _ __
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._.
_
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_ - _ _ __ ________ ________
.
.
.
g.
SL IV - Failure to maintain required security computer configuration.
(86-06)
h.
SL IV - Licensee employee gained access to protected area without picture badge.
(86-14)
1.
SL IV - Breach in vital area barrier.
(86-19)
j.
SL V - Failure to submit timely 50.54(p) change.
(86-37)
k.
SL V - Failure to alarm a locked vital area portal.
(86-37)
2.
Conclusion Category:
Trend during the period:
Improving 3.
Board Recommendations The board noted some improvement in this area at the end of the period however overall performance is classified as category 3 due to the number and repetitive nature of the violations.
Increased NRC and management attention should be given to this area.
H.
Outages 1.
Analysis During the assessment period units 1 and 2 under went refueling outages.
The resident inspectors observed refueling operations.
Resider.t ar.d regional based inspectors observed outage activities.
The management commitment to improved scheduling for outages continued during this assessment period.
More personnel were allotted and an outage planning manager position was filled. An experiment in outage management, contracting out the outage planning and control, was attempted for the unit 2 outage. The l
results of both outages was less than desired in that the outages l
lasted longer than scheduled.
In an effort to better define the l
work scope and outage duration the planning for the next unit 1 outage in April 1987, was started in December,1986. A skeleton
'
schedule was issued in December 1986, for comment and work l
~
definition.
During the unit 2 refueling the core was loaded rotated 90 degrees from the desired North / South axis.
Since the core was quadrant symmetrical there was no technical significance.
This event occurred when the reactor engineer developing the loading sheets from the General Electric (GE) core map did not recognize the 90
degree difference between the Hatch axis and the GE axis. The
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r
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,.__.,_,m,_,._,_
_, _ ~ _,.,. _ _.
,.m_
_ _.., _
,,,,,. _. -.
.... _,,
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lead reactor engineer was replaced as a result of this loss of control.
During the unit 1 outage better scheduling revealed that a window existed to perform the loss of off site power test on one emergency diesel generator during the body of the outage rather than at the end of the outage. A check was done to determine if all equipment needed to complete the test was operational and such was the case. No in depth check was done to determine if any equipment needed to support the outage in progress would be lost when the 4160 volt bus to be tested was deenergized. When the test was run, power was lost te the solenoid for a fail open air valve. This valve, which isolated the residual heat removal (RHR)
system from the torus, failed open.
The result was the water level in the torus equalized with the North East diagonal to a depth of about fourteen feet in the diagonal. Two RHR pumps, one core spray (CS) pump, the room coolers, jockey pump and other lesser equipment were submerged. The restoration from this event lengthened the outage. Air valves used for isolation for work are now required to be gagged shut.
Licensee management involvement in inservice inspection (ISI)
activities appeared to be adequate and decision making was at a level that assured adequate management review.
Records were generally complete, well maintained and available. Procedures and policies were occasionally violated as evidenced by the violations listed below.
One violation was identified for not having implementing procedures for scheduling and tracking ASME Section XI pressure tests, and for not scheduling Class 2 and 3 40-month pressure tests required by Section XI.
A violation was identified for incorrectly identifying two recirculation system welds during liquid penetrant examinations.
A violation was identified for performing acid etch examinations to locate reactor pressure vessel longitudinal welds without an approved procedure.
A violation was identified for improper sign off of traveler steps performed during Induction Heat Stress Improvement operations. A violation was identified for failure to properly sign off hold points and the use of improper dimensional acceptance criteria during the inspection of certain analog transmitter trip system ASME Class 2 welds.
The violations were not repetitive and not indicative of a programmatic breakdown.
Key positions were identified and authorities and responsibilities were defined.
A well defined training program for all personnel involved in ISI was delineated and implemented.
The nondestructive examination personnel involved in ISI appeared to be very well trained and experienced in the examination methods employed.
,
- -
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.
_-
- -
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Five violations were identified:
a.
Severity Level IV violation for. failure to have implementing procedures to schedule pressure tests. (86-11)
b.
Severity Level IV violation of failure to follow procedures to assure correct welds were examined during In Service Inspection. (86-32) (Unit 2)
c.
Severity level IV violation for failure to properly implement a safety related procedure resulting in an inadvertent initiation of ESF equipment. (86-03) (Unit 1)
d.
Severity Level V violation for failure to have a procedure for conducting acid etch examinations on safety related components. (86-05) (Unit 1)
e.
Severity Level V violation for failure to folinw procedure for signoff of traveler steps not actually performed by the person making the signoff. (86-02) (Unit 1)
2.
Conclusion Category: 2 3.
Board Recommendation The board had several comments on outage activities and recommends increased management attention to control of outage activities.
No change to the level of NRC staff resources applied to the routine inspection program is recommended.
I.
Quality Programs and Administtative Controls Affecting Quality 1.
Analysis During the assessment period inspections were performed by the resident and regional inspection staff.
These inspections involved reviews of: QA program, QA/QC administration tests and experiments, offsite support staff and offsite review committee.
An inspection of the corrective action program was also conducted as part of a special performance assessment inspection of maintenance activities.
For the purposes of this assessment, this area is defined as the ability of the licensee to identify and correct their own problems. As such, it encompasses all plant activities, all plant personnel, as well as those corporate functions and personnel that provide services to the plant. The plant and corporate QA staff are part of the entity, and as such, they have responsibility for verifying quality. The rating in this area specifically denotes
,
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f
28
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results for various groups in achieving quality as well as the QA staff in verifying that quality is achieved.
A review was performed on all sections of the SALP report in an attempt to capture apparent strengths and weaknesses related to management controls affecting quality.
The following are some perceived strengths in management controls affecting quality:
Upgraded management organization including redefinition of plant. manager's function and addition of an on-site vice president which enhances management involvement in plant operations.
Simulator training for control room discipline.
Professional appearance of operators.
Comprehensive maintenance training and procedure upgrade
programs.
Improved design change control program and pre-outage
maintenance ALARA briefings.
- Improved predictive and preventive maintenance programs.
Computer controlled data base for the surveillance program.
- Frequent management involvement in the site fire protection
program.
Improvement in protective action decision making and
effective procedure usage during emergency preparedness exercises.
s Management involvement in maintaining an effective emergency
response training program.
,
A well defined training program for all personnel involved in
ISI was delineated and implemented.
Enhanced QA group activities related to auditing activities.
[
Improved corrective action trending and tracking program.
,
Improved training programs for plant and licensed personnel.
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The following are some perceived weaknesses in management controls affecting quality:
A weakening of the radiation protection program.
- Upgrade programs in maintenance areas had not been fully
implemented.
Repeated violations in maintenance and health physics areas.
- Technical adequacy errors in surveillance procedures after a comprehensive review and upgrade in this area.
Weakness related to leak rate testing requirements.
- Programmatic breakdown in security due to repetitive nature and number of violations identified.
Quality Assurance Manual has not been updated to reflect FSAR con.mi tments.
Lack of management attention relative to Sholly evaluations and emergency or expedited technical specification change requests.
Failure to take corrective action for a previous violation involving operating experience feedback training and perform audits of the training.
Inspections of QA/QC administration revealed discrepancies between the QA program description contained in FSAR Section 17.2, and the quality assurance manual (QAM). The QAM which implements licensee commitments delineated in FSAR Section 17.2 was identified as not having been revised since 1982. Corrective actions implemented to ensure consistency between QA program documents was evident by activities in progress, to revise the FSAR Section 17.2.
Management's involvement in assuring quality was further demonstrated by tentative plans to convert FSAR Section 17.2 to a QA topical report which addresses the QA program requirements for both plant Hatch and Vogtle.
Weaknesses identified in the quality verification process were revealed by a failure to estabilish QC inspection hold points in design change request (DCR) packages and maintenance work orders (MWO). Failure of the QC group to adhere to established schedules for performing surveillances of work practices and QA activity overviews also contributed to this weakness.
Inadequate involvement of the QC staff in maintenance activities was a concern previously addressed in the last SALP. However, licensee management commitment in assuring quality was demonstrated by the corrective action program developed and implemented not only for this concern, but also that of personnel errors. This program is discussed later in the repor }
.
.
Enhancement of the QA group activities was demonstrated during this rating period by an increased scope and depth of audits performed. Additional responsibilities have also been assigned to auditors for overview of site work activities. Two new first line supervisory positions in the capacity of audit supervisor and engineering support supervisor were also created and filled.
Inspection of the test and experiment program revealed weakness in specifying and administrative control of post-maintenance functional tests (FTs). Licensee management has determined that a significant number of MW0s had inadequate or missing FTs.
The licensee had developed _ corrective action plans to specifically address this deficiency which involve sampling MW0s over an extended time period along with the determination of existing trends.
A safety review board (SRB) subcommittee, which has cognizance for implementation of the corrective action, will make
recommendations to management based on assessed trends.
Further NRC concerns in the maintenance area resulted in a special performance assessment inspection during this rating period.
A comprehensive review of licensee corrective action program was performed during this assessment. Licensee management involvement in assuring quality was demonstrated by a corrective action program that met regulatory requirements and licensee commitments.
The effectiveness of developed corrective action plans are
-
monitored by the following trending programs:
QA trending program; deficiency report (DR) trending program; and LER trending program.
The corrective action trending and tracking program appears to work very well.
Adverse trends are easily observable and/or may be calculated from the graphs or x-bar chart.
This capability to identify problems in various performance areas ensures that problems are evaluated for root cause analysis, and i
l prompt corrective actions are implemented.
I The implementation of developed corrective action plans, with I
regard to maintenance, appears to not be fully effective.
The ineffectiveness of the corrective action program, in maintenance, I
to prevent the recurrence of problems lies not within the program per se, but rather within the worksite control process at the craft level.
Licensee management has taken corrective action to specifically address these deficiencies, such as upgraded i
personnel training and a procedure upgrade program (PUP).
l The following violations were identified:
a.
Severity Level IV Violation for the failure to perform and document audits of the functioning of the operating experience feedback program.
(86-22)
i l
b.
Severity Level IV violation for failure to install control l
rod drive hydraulic control units in accordance with the design drawing.
(86-20) (Unit 1)
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_
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2.
Conclusion Category:
3.
Board Recommendation No change in the level of NRC staff resources applied to the routine inspection program is recommended.
J.
Licensing Activities 1.
Analysis With regard to management involvement and control in assuring quality, the licensee has upgraded its management organization as discussed in the operations section. These changes have provided heightened management attention to all Hatch activities including licensing related activities. There has been extensive management participation in licensing activities associated with the major unit I and 2 refueling and maintenance outages that occurred during the report period.
These activities include Appendix R exemption requests, Inter Granular Stress Corrosion Cracking (IGSCC) inspection of Unit 1 piping, and exemption requests associated with the completion of the first 10 year in-service inspection program.
There has also been extensive management involvement in responding to the staff's review of the second 10 year in-service inspection program and its related exemption requests.
!
The licensee has taken a proactive role in the NRC's program to l
improve Technical Specifications.
Hatch has been designated as the lead plant for the BWR Owners Group on Technical Specification improvements.
The licensee has also implemented an extensive procedures upgrade program that includes checking, correcting, and
,
upgrading all the existing Hatch Technical Specifications. All of
'
the above indicate a growing management attention to licensing
,
matters.
'
However, there continues to be some areas that need improved management attention. One of these areas is in the quality of the I
Sholly evaluations that the licensee submits with each requested i
license amendment.
The bases for concluding that no significant hazards consideration is involved with the proposed changes has been only marginally adequate for most of the submittals. Another area that needs improved management attention is information provided in justification of an emergency or expedited technical specification change request. Since expedited action on the part of the staff is being requested in these cases, adequate and complete information should be submitted at the time of the request. The request for the emergency change to allow continued
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operation with an inoperable diesel generator and the request for an expedited change related to main control room environmental control system operability requirements are cases during the report period where the initial information was insufficient and reflect that insufficient management attention has been given to the licensing requirements.
With regard to the licensee's approach to resolution of technical issues from a safety standpoint, the licensee has, in most cases, exhibited an understanding of the issues, conservatism and sound approaches in its licensing proposals.However, in some of its proposals the licensee has indicated a lack of understanding of the issues or has lacked conservatism, thoroughness or depth.
Examples of these issues are: a) modifying the nitrogen gas lines without prior staff approval when a technical specification change related to the modification was required b) qualification requirements for IGSCC inspectors c) proposed removal of upper pressure limit related to interlocks for valves isolating the low pressure from the high pressure system, and d) certain inservice inspection exemption requests.
The licensee has generally responded to NRC requests, including generic letters and plant specific requests, both oral and written, in a timely and technically adequate manner.
In some cases it provided information in an extremely timely manner.
Examples of such submittals include the revised 10 year inservice inspection program, and its May 1986 Appendix R exemption request.
However, it delayed in an untimely manner in responding to the staff concerns and request for discussion concerning legal aspects of the discrepancy between the Hatch Unit 2 FSAR and the actual seismic design of the unit. It also delayed in an untimely manner its response to the staff concerns related to GPCs proposal to l
delete Unit 2 building settlement monitoring technical
,
specification.
It also submitted the results for its IGSCC l
inspection of unit 2 in an untimely manner - leaving little time
'
for staff review prior to the scheduled restart of unit 2.
Finally, it responded to late staff review questions concerning Appendix R exemptions requests in untimely manner, taking almost a month to provide its response.
During this rating period, the licensee has modified the corporate
and plant organization as previously discussed. Appendix R fire protection modification activities were organized under a project manager. An additional manager was added to the Hatch licensing staff.
2.
Conclusion Category:
i i
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@
3.
Board Recor.mendations None
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K.
Training and Qualification Effectiveness
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j 1.
Analysis s
e Inspection conducted during this assessmen't period indicate that training has definitely improved over tha last assessment period; Seven of ten training programs have been Instityte of Nuclear Power Operations (INP0) accredited and'the other three are under review for accreditation.
The most significant improvements appear to be in licensed operator.requalification training and.
licensed replacement training.
Duving the previous SALP period, the licensee's requalificati n training program had been dedlared f
unsatisfactory based upon -the resuits of an NRC ddministered requalification examination.
In response to' 'chis finding, the licensee developed and administered an upgrade r? qualification
program to all licensed operators who had not passed an NRC requalification examination. This program was completed in July of 1985 and requalification examinations administered since that time indicate the program was very successful. The ovmil pass rate on requalification examinations administered as monitored by the NRC during the assessment period was 91% compared with the less than 60% in 1984.'
In addition, the licensee submitted a revised long-term requelification program which was approved bv
'
the NRC on April 22, 19E6.
Licensed operator replacement training improved over the last assessment period.
Inspectors attended training lecture 3r observed simulator training, and interviewed students snd
instructors.
They noted an emphasis on performance based training. Reactor operator (RO) license expminations administered during this period also support this cor.clusion with a pass rate of 100 percent for eleven examinations, compared with a0 percent for ten examinations during the pervious period. -No Senior Reactor Operator (SRO) examinations were administered during this evaluation period.
The inspectors also reviewed selected individual licensed operator and non-licensed operator training records, all of which appeared to be complete and current.
The maintenance of these training records was procedurally controlled which had been a previously identified deficiency.
,
,
With respect to maintenance training, the licensee completed preparations for the INPO accreditation of the three maintenance training programs in Septembec of 1986.
These programs include mechanical, electrical, and instrument atd control (I&C)
,
technician training. Preparation for INPO accreditation appeared
,
to be very thorough and included undivided job task analysis, Gject!Ves, lesson plans, tests, and instructional aids.
Individuals from each of toe classifications were involved in
,
development of training which should add credibility to these i
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three programs.
In addition, as noted in the previous SALP, the i
licensee's instructional aids and maintenance laboratory facilities are exemplary, and these facilities are being upgraded i
even further to support performance based training.
In addition to increasing the level of screening for the hiring of new
',
maintenance personnel, and requiring that they complete the full traininc program, the licensee is requiring that all incumbents also complete the entire program.
Although this additional requirement has met with some resistance and caused significant K
1 scheduling problems, it is a very positive decision.
As
-
incentives to incumbents, the licensee is providing remedial
,
-
mathematics training and monetary awards for completion.
The
~,
implementation of tnese new performance based training programs, m
particularly for incumbents, is still in the very early stages of implementation.
Continuing errors by maintenance, I&C, and
-
electrical personnel, including the failure to follow procedures,
,'
indicated the training has not yet had significant impact on the level of maintenance performance.-
Future inspections and the trending of maintenance error rates will provide a measure of the effectiveness of these new training programs.
,
A number of training deficiencies identified in the previous SALP
< report were inspected and closed during this period.
These s' findings resulted in the establishment of the following:
~
'I
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A training program for Instrument and Control (I&C)
,
technicians for mitigation of core damage.
A formal on-the-job training program for maintenance
-
personnel.
.
-
A formal training program for support engineer's.
s
"
A formal Shift Technical Advisor training program.
-
l An NRC approved license requalification program.
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A severity level IV violation was issued during the previous SALP period for failure to provide operating experience feedback training to maintenance personnel or required by NUREG-0737, Item l
1.C.5.
An inspection conducted during this SALP period indicated that no corrective action had been taken on this deficiency over a I
year later. In addition, a further level IV violation was issued for a failure to conduct required audits to ensure this training
,
is effective at all levels (Violation a in section~IV.I.)
l l
In summary, it appears that the licensee has expended significant p
manpower and resources toward upgrading training, and to achieving l
l INPO accreditation.
The upgrade requalification training program
>
!
appears to have been very successful as well as the improved
'
license replacement training program.
In contrast, the revised L
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maintenance, I&C, and electrical training programs do not yet appear to have - significantly impacted maintenance performance t
during this assessment period, and will need -further review.
Given the INP0 secteditation, the excellant training facilities, and the retraining of incumbent personnel, these program definitely-have the potential to improve Hatch maintenance performance levels.
No violations or deviations were-classified as being attributed solely to training.
2.
Conclusion p
"
Category:
3.
Board Recommendation
!
The board recommend, that NRC staff resources applied to the
'
routine inspection program be reduced.
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V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities Unit'I started the period at power.
On July 24, 1985, the unit experienced an automatic scram due to an MSIV not fully open condition d
and the unit remained off line to make repairs until August 5,1985.
The reactor was manually scrammed on September 20, 1985 for RWCU valve I
repair and was on line on September 23, 1985. On October 1,1985, the reactor was again manually scrammed due to generator ground fault and i
was back on line on October 3, 1985.
The unit was shutdown for a refueling outage on November 26, 1985, and the refueling was completed and generator tied to the grid on May 13, 1986. On June 13, 1986, the unit was mantally scrammed to fix leaks on the drywell pneumatic system and the generitor was back on line on June 16, 1986. The reactor was manually scraimed again on-September 13, 1986, to repair leakage inside the drywell and the generator was back on line three days later. From November 14 to November 21, 1986, Unit I was shutdown to repair
,
l condensate bayisteam steam leaks and to inspect snubbers. The unit l
ended the period operating at power.
Unit 2 started the period at power. On August 17, 1985 the unit was manually scrammed to investigate an A recirculation pump motor bearing
l high temperature. The problem was corrected and the generator was back i
on line on August 19, 1985.
The unit was again shutdown from December 25, 1985 to December 30, 1985 for turbine blade inspection.
On' January 8,1986, management decided to operate at 85 percent power because high. off gas activity in the reactor and turbine building caused by fuel leakage was interfering with Unit 1 outage work.
power was limited to 85 percent for most of the following period until the unit entered a refueling outage on September 18, 1986.
The generator i
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was placed on line on Decer.ber 11, 1986, following the refueling outage but was again shut down for two days to repair an inoperable vacuum breaker on December 12, 1986. The unit ended the period operating.
On December 3,1986, a leak was discovered in the fuel transfer canal
.
seismic gap between Units 1 and 2 which resulted in a loss of approximately 140,000 gallons from the Units 1 and 2 spent fuel pools.
I The leak was caused by the loss of air to the inflatible seals when an air valve was mistakenly shut.
Approximately 100,000 gallons of contaminated water was released to the on site environment. An AIT was dispatched to the site.
B.
Inspection Activities During the assessment period, routine inspections were performed at the Hatch facility by the resident and regional inspection staffs. Special inspections were conducted to augment the routine inspection program as follows:
August 6-9, 1985, in the area of an emergency preparedness exercise.
October 28-29, November 18-22, and December 10, 1985, in the areas of investigation of an allegation involving the Post Accident Sampling System (PASS) and plant liquid and gaseous radioactive effluents.
December 12, 1985, involving onsite review of the facts and circumstances surrounding a physical security event reported by the licensee on December 10, 1985.
December 26-27, 1985, in response to the loss of water through the residual heat removal system to a south east room on December 21, 9185, due to improper status.
April 1-4, 1986, in the area of maintenance programs and practices.
April 17-18, 1986, in reviewing the security event which occurred on April 15, 1986 relating to protected area access control.
July 7, 1986, involving a review of the circumstances of a security event involving a
moderate loss of security effectiveness.
July 28 - August 1,1986, in the areas of maintenance programs, implementation, and correctise actions.
October 21-24, 1986, involving evaluation of the annual radiological emergency preparedness exercis.
October 6-10, 1986, involving reviewing the effectiveness of licensed and non-licensed training programs.
November 3-7, 1986, in the areas of environmental qualitication.
December 4-8, 1986 to determine the cause and to monitor the licensee response to the release of radioactive water from the spent fuel pools to the environment discovered on December 3, 1986.
December 15-19, 1986, in the area of 10 CFR 50 Appendix R compliance.
C.
Investigation and Allegation Review Allegations regarding poor valve maintenance controls and practices at Hatch were made during this period. An inspection was performed which did find several problems in this area and resulted in the discovery of violations of NRC rules.
Plant management took corrective actions in response to these findings. The violations are discussed in Section IV.C.
No other significant allegations were received or significant investigations performed.
D.
Escalated Enforcement Actions 1.
Civil Penalties A Severity Level III violation concerning inadequate security compensatory measures which resulted in a civil penalty in the amount of fifty thousand dollars was issued on May 28, 1986.
2.
Orders - None E.
Licensee Conferences Held During Appraisal Period A management meeting was held on July 17, 1985, to discuss licensing activities.
A management meeting was held on August 5, 1985, to discuss operator requalification exams and utilization licensed personnel.
,
A management meeting was held on October 24, 1985, to discuss the quarterly review of Hatch.
A management meeting was held on November 4,1985, to discuss performance during the previous SALP period.
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A management meeting was held at the NRC's request on November 8,1985, to discuss the Unit 1 Nitrogen inerting and purge line crack.
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4 A meeting was held on December 13, 1985, to discuss the GPC repair plan for safe-end to nozzle' weld.
An enforcement conference -was held on January 21, 1986, to discuss a physical security event which resulted in a severity level IV violation.
a A management meeting was held on February 11, 1986, to discuss the NRC assessment of plant maintenance activities and improvements made by GPC to upgrade maintenance.
A management meeting was held on February 12, 1986, to discuss the quarterly-overview of Hatch.
A management meeting was held on March 13, 1986, to discuss concerns in maintenance program, specifically valve maintenance control.
An enforcement' conference was held on March 14, 1986, to discuss a security issue which resulted in a severity level III violation with a civil penalty.
A meeting was held on March 27, 1986, to discuss a seismic response design
i discrepancy.
.
A management meeting was held on April 10, 1986, to continue discussions over concerns raised in the valve maintenance area.
!
A meeting was held on April 22, 1986, to discuss a proposed 10 CFR 50,54(p)
change to the Hatch physical security plan.
A management meeting was held on June 2,1986, to discuss the quarterly review of Hatch.
A management meeting was held on June 12, 1986, to again discuss the NRC assessment of plant maintenance activities and improvements made by GPC to upgrade maintenance.
i A meeting was held on June 18, 1986, to discuss problems with seismic design of cable trays.
r l
A meeting was held on June 19, 1986, to discuss the Technical Specification
~
improvement' program.
An enforcement conference was held on July 18, 1986, concerning access J
control and vital area barriers resulting in a Severity Level IV violation.
A meeting was on July 16, 1986, concerning an Appendix R exemption request.
A meeting was held on September 11, 1986, concerning seismic design.
A management meeting was held on October 14, 1986, to discuss GPC program improvements.
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A meeting was held on October 21, 1986, to discuss a request to delete the building settlement monitoring requirement of the Unit 2 Technical Specifications.
A meeting was held on November 4, 1986, to discuss the quarterly overview of Hatch.
A technical meeting was held on November 13, 1986, to discuss an upcoming 10 CFR 50 Appendix R inspection on fire protection.
A meeting was held on November 20, 1986, to discuss the procedure upgrade program.
F.
Confirmation of Action Letters A confirmation of action letter was issued on March 5,1986, concerning a security issue which resulted in a severity level III violation with a civil penalty.
G.
Review of Licensee Event Reports and 10 CFR 21 Reports submitted by the licensee.
During the assessment period, there were 94 LERs analyzed (57 for Unit I and 37 for Unit 2).
The distribution of these events by causes, as determined by the NRC staff, was as follows:
Unit 1 Unit 2 Cause
- LERs
- LERs TOTAL Component Failure
8
Construction / Installation /
3
Fabrication Personnel
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- Operating activity
11
- Maintenance activity
3
- Test / calibration activity
8
- Other
2
Other
2
TOTAL
37
Note 1:
The 'Other' category is comprised of LEPs where there was a spurious signal or a totally unknown cause.
Note 2:
Unit 1 had 8 LERs concerning the RWCU system - 12.2%
Unit 2 had 9 LERs concerning the RWCU system - 24.3%
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Note 3:
With regard to the area of " Personnel", the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.
The board recognizes that the licensee considers these management deficiencies.
H.
Licensing Activities The basis for the licensing appraisal was the licensee's performance in support of licensing actions that had a significant level of activity during the current rating period. These actions, consisting of amendment requests, exemption requests, code relief requests, responses to generic letters, TMI and Salem ATWS items, and other actions, are listed below:
Multiplant Actions A - 04 Appendix J Leak Testing Exemption (Unit 1 only)*
B - 76 Post Trip Review Program and Procedures *
B - 79 Post Maintenance Testing - RTS Components *
B - 88 Post Maintenance Testing - All SR Components *
D - 19 Diesel Generator Reliability Technical Specifications D - 20 Mark 1 Drywell Vacuum Breakers F - 05 Procedures Generation Package Review F - 26 Inadequate Core Cooling Instrumentation *
Plant Specific Actions ISI Relief Requests *
Exemption to Appendix R*
Inservice Inspection - Second 10 year Program *
Core Spray Sparger Inspection (Unit 1 Only)*
l Licensed Operator Requalification Program *
j ATWS Implementation Schedules *
l IGSCC Inspection and Repair (Unit 1 Only)*
Seismic Analysis Descrepancies Extend License Expiration Date Technical Specification Changes:
Analogue Transmitter Trip System Setpoints*
Standby Gas Treatment System Fast Acting Dampers Surveillance *
Drywell Pneumatic System Valves Listing *
Containment Isolation Valves Listing *
RCIC Suction Auto-Transfer Setpoint (Emergency Basis -
Unit 2 Only)*
l Reactor Vessel Pressure - Temperature Operating Limits l
(Unit 1 Only)*
l Gaseous Effluents Sampling Requirements *
l Hydrogen Injection Testing Requirements * (Unit 2 Only)*
(_
Rod Worth Minimizer, Rod Sequence Control and MAPLHGR Limits *
Diesel Generator Operability Requirements (Emergency Basis Unit 2 Only)
Containment Electrical Penetration Overcurrent Protection
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.
Requirements (Unit 2 Only)*
Removal of Fire Protection Specification *
Control Room Environmental Control System Operability *
Settlement of Structures Survelliance (Unit 2 Only)
'
Scram Discharge Volume Isolation Valve Closure Time Limits Primary Coolant System and Component Surveillance Reactor Protection System Instrument Surveillance Single Loop Operation Limits Low River Water Level Operability Limit
- Indicates action completed t
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I.
Enforcement Activity Functional No. of Deviations and Violations
,
Area in Each Severity Level
'
I II III IV V
D Plant Operations
2 Radiological Controls
1
Maintenance
2 Surveillance
Fire Protection Emergency Preparedness
3 Security 1-
2 Refueling / outages
2 Quality Programs and
Administrative Controls i
Affecting Quality Licensing Activities i
Training TOTAL
40
1 J.
Reactor Trips Unit 1 Five automatic reactor scrams occurred during this evaluation period. Five manual scrams occurred for reasons other than refueling outages and are described in Section V.A.
July 24, 1985, the reactor automatically scrammed due to a MSIV not fully open problem.
May 15, 1986, the reactor automatically scrammed due to MSIV closure.
May 21, 1986, the reactor automatically scrammed due to a turbine trip on high reactor vessel water level.
August 2, 1986, the reactor automatically scrammed due to a turbine trip on high reactor vessel water level.
November 22, 1986, The reactor automatically scrammed due to a B recirculation pump runaway.
Unit 2 Nine automatic reactor scrams occurred during this evaluation period. Three manual scrams occurred for reasons other than refueling outages and are described in section V.J.
November 5, 1985, the reactor automatically scrammed when a second condensate booster pump tripped.
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November 7,1985, the reactor automatically scrammed on startup due to an upscale trip of IRM D and E.
January 19, 1986, the reactor automatically scramned on a group 1 isolation April 20, 1986, the reactor automatically scrammed on an erroneous MSR A high level.
April 24, 1986, the reactor automatically scrammed when condensation in the generator exciter caus'ed a generator field ground.
June 28, 1986, the reactor automatically scrammed on low water level due to tripping of the condensate booster pumps when decreasing power to repair
,
steam leaks.
August 29, 1986, the reactor automatically scrammed due to MSIV closure on low-low reactor vessel water level when the instrument was being valve in.
September 3, 1986, the reactor automatically scrammed when the turbine tripped on low EHC oil pressure.
September 3,1986, the reactor automatically scrammed on low reactor vessel water level due to an RFPT trip on low condenser vacuum.
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K.
Hatch Gaseous and Liquid Effluent Release TABLE 1 Hatch Effluent Release Gaseous (Cf per Unit)
RII 1st Half Avg BWR*
1985 1986 Fission and Activation Gases 7690 6300 6650 Iodine
.012
.003
.006 Particulate
.023
.034
.001 Tritium 7.61 13.3 5.75 Liquid (C1 per Unit)
RII ist Half Avg BWR*
1985 1986 Fission and Activation Products
.15
.234
.144 Tritium 11.35 16.7 6.58
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- Excludes releases from Browns Ferry and Grand Gulf
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