IR 05000338/1985004
| ML18142A493 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 05/10/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18142A487 | List: |
| References | |
| 50-338-85-04, 50-338-85-4, 50-339-85-04, 50-339-85-4, NUDOCS 8506270730 | |
| Download: ML18142A493 (29) | |
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MAY 10,985 ENCLOSURE 1 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMAT,IC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION 8506270730 850510 PDR ADOCK 05000280
PDR REPORT NUMB.ERS 50-338/85-04, 50-339/85-04 Virginia Electric and Power Company North Anna Plant Units 1 and 2 September 1, 1983 through February 28, 1985
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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-tio SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulation SALP is intended to be suffi-ciently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on April 11, 1985, to review the collection of performance observations and data. and to assess the 1 icensee 1 s performance in accordance with the guidance in NRC Manual Chapter 0516, 11Systematic Assessment of Licensee Performance. 11 A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assess~~nt of the licensee's safety perform-ance at the North Anna Plant for the period of September 1, 1983 through February 28, 198 SALP Board for North Anna Plant: Bemis, Director, Division of Reactor Safety, Region II (RII)
(Chairman)
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII D. M. Verrelli, Ch~ef, Projects Branch 1, Division of Reactor Projects (DRP),
RII V. L. Brownlee, Chief, Projects Branch 2, DRP, RII G. E. Lear, Chief, Structural and Geotechnical Engineering Branch, Division of ~ngineering, Office of Nuclear Reactor Regulation {NRR)
Attendees at SALP Board Meeting:
S. A. Elrod, Chief, Projects Section 2C, DRP, RII M. W. Branch, Senior Resident Inspector, North Anna, DRP, RII J. G. Luehman, Resident Inspector, North Anna, DRP, RII D. S. Price, Reactor Inspector, Technical Support Staff (TSS), DRP, RII K. M. Jenison, Project Engineer, Projects Section 2C, DRP, RII T. C. MacArthur, Radiation Specialist, TSS, DRP, RII L. B. Engle, Project Manager, Operating Reactors Branch 2, Division of Licensing, NRR I CRITERIA Licensee performance is assessed in certain functional areas depending upon whether the facility has been in the construction, preoperational or operating phas Each functional area represents areas which are signifi-cant to nuclear safety and the environment and which are programmatic area Some functional areas may not be assessed because of little or no licensee
activities or lack of meaningful observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each functional area: Management involvement and control in assuring quality Approach to resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Reporting and analysis of reportable events Staffing (including management) Training effectiveness and qualifi~ation However, the SALP Board is not limited to these criteria, and others may have been used where appropriat Based upon the SALP Board assessment, each functional area.evaluated is classified into one of the three performance categories. The definitions of these performanca categories are:
Category 1:
Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety or construction is being achieve Category 2:
NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieve Category 3:
Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and. considers nuclear safety, but weaknesses are evident; li~ensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieve The SALP Board has also categorized the performance trend over the course of the SALP assessment period. The trend is meant to describe the general or prevailing tendency (the performance gradient) during the SALP period. This catego~ization is not a comparison between the current and previous SALP ratings. It is a determination of the performance trend during the current SALP period irrespective of performance during previous SALP period The
categorizat~on process involves a review of performance during the current SALP period, and categorization of the trend of performance which occurred during the course of that perio The performance trends are defined as follows:
Improving:
Licensee performance has generally improved over the course of the SALP assessment perio Constant:
Licensee performance has remained essentially constant over the course of the SALP assessment perio Declining:
Licensee performance has generally declined over the course of the SALP assessment perio III. SUMMARY OF RESULTS Overall Facility Evaluation North Anna is a well managed site wi1:.h a professional and knowledgeable staff. Acceptable performance at the plant level was observe Strengths were identified in the areas of Refueling, Security and Radiological Control No weaknesses were identifie At the end of the assessment period, the performance trend was considered to be improving in the areas of Plant Operations, Maintenance, Emergency Preparedness, Training, Quality Programs and Administrative Controls Affecting Quality, and Licensing Activities. Tha area of Training has been in a state of transition such that programmatic gains were often hidden by current short term problem Organizational structure changes were also subject to short-term problems but these changes are definitely strengthening site operation Functional Area Plant Operations October 1, 1982 -
August 31, 1983
Radiological Controls
Maintenance
Surveillance
Fire Protection Not Rated Emergency Preparedness
Security
Refue 1 i ng
Training Not Rated Quality Programs and Administrative Controls Affecting Quality
Licensing Activities
September 1, 1983 -
February 28, 1985
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2
2
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2
Trend During -
Latest SALP Period Improving Constant Improving Constant Constant Improving Constant Not Determined Improving Improving Improving
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I PERFORMANCE ANALYSIS Plant Operations Analysis During the assessment period, inspections of plant operations were performed by the Resident and Regional inspection staff The North Anna site has a well staffed operational organization which exhibited a professional attitude and high standards of performanc The Operations organization received adequate corporate support which was evidenced by the 1 i censee I s recent agreements with French and Japanese utility organizations for the exchange of technical information on plant operation As part of the agreement with the French organization, two Operations Depart-ment personnel were sent to France to observe control room opera-tions. These persons brought back several practices that were being evaluated for implemea:tatio Programs,* such as the one discussed above, cl early demonstrate the 1 i censee management I s commitment to quality in the area of plant operation *
The licensee made significant progress in efforts to improve control room discipline and operator alertnes Examples of the steps.taken and planned are listed below:
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0 During the one-half hour period at shift turnover, Control Room entry was restricted to the operating staff only by placement of special signs on the control room card reader Shift clerks were assigned to each shift crew in order to remove some of the admi ni strati ve burden from the senior reactor operators (SRO) and reactor operators (RO).
Carpet was installed throughout the Control Room in order to reduce background nois Encroachment lines were ~stablished in the Control Room with SRO permission required for entry of personne 1 other than 8perations Department personne Licensed operators wore distinctive clothing in order to provide clear identification of those personnel in charge in the Control Roo The licensee had a goal of having three SROs per shift with one assigned to the coordination of maintenance and admini-strative activities during normal operations, leaving the unit supervisors free to concentrate on plant operation During routine operations, Control Room communication formality and behavior were maintained at a professional level. The SROs provided adequate supervision and leadership under both steady state and transient operation Even though positive steps were taken in this area, several weaknesses still existed. During reactor trips, especially on the day shift, Control Room access controls broke down (i.e., a number of non-essential personnel entered the Control Room).. Addi-tionally, improvement in operator awareness and responses to annunciator alarms was needed; for example, both the lockout of the Unit 1, 18 Charging Pump (violation b), and another event which allowed 82,000 gallons of casing cooling water to drain into the Unit 2 containment would have been detected and corrected sooner had the operators been more responsive to the annunciator alarms.. A~other factor that has affected operator responsiveness to annunciator alarms was the large number of nuisance and main-tenance related alarms that are discussed in other areas of this assessmen The licensee's responsiveness to NRC initiatives improved near the end of the assessment perio However, inconsistent responsive actions were noted; for example, deviation h, failure to ensure that the containment hydrogen analyzers would be operable after a safety injection, was resolved rapidly while deviation i, failure to control high pressure gas bottles, took approximately six months to resolv The addition of the new Assistant Station Manager for Safety,fnd Licensing should contribute to continued improvement in this are The licensee's overall performance in the area of resolution of technical problems and concerns was satisfactory though occa-sionally slo Additional management attention was needed in the area of operator logs and instrument accurac Violation c demon-strated a weakness in the method the licensee utilized to satisfy channel check requirements. Acceptance tolerances established to satisfy these requirements were neither adequately documented nor properly supporte Operators have on occasion been asked to maintain very small bands for safety parameters using equipment with.accuracy errors greater than the es tab 1 i shed ban Vi o 1 a-ti on d, dealing with valve lineups, was an isolated ex~mple of failure to provide adequate instructions or training to operations personne Violation e pointed out specific problems encountered with a failure to follow station administrative procedure A large number of the problems associated with the jumper log were directly related to the resolution of the backlog of technical issues and outstanding maintenance wor After this item was discovered, management attention was devoted to its resolutio '
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The operational information provided by the licensee in Licensee Event Report (LER) submittals was brief and accurat Some coded information was incorrec The violations and deviations below point to specific weaknesses in licensee programs but do not indicate an overa 11 lack of management involvemen Seven violations and three deviations were identified during the assessment period: Severity Level III violation for material false statement relating to operability of Reactor Coolant System head vent Severity Level IV violation for the lockout of the 18 Charging Pum Severity Level IV violation for failure to properly conduct instrument channel check Severity Level IV violation for failure to provide adequate instructions to control valve lineup Severity Level IV violation for improper control of the station jumper lo Severity Level IV violation for inadequate procedures controlling independent verificatio Severity Level V violation for failure to implement procedure Deviation for failure to ensure that containment hydrogen monitors were operable within 30 minutes after a safety injectio Deviation for the improper storage of high pressure gas bottle ' Deviation for failure to ensure vents on Boric Acid tanks are locked open and administratively controlle.
Conclusion Category: 2 Trend During This Period:
Improving
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7 Board Recommendation Licensee management attention to this area was concerned with nuclear safet No change in the level of NRC staff resources applied to the routine inspection program is recommende Radiological Controls Analysis During this assessment period~
inspections of radiological controls were performed by Resident and Regional inspection staff These included inspections of chemistry and of con-firmatory measurements using the Region II mobile laborator Additionally, an evaluation of the NUREG-0737 Post Accident Sampling $~stem (PASS) was performed with the assistance of an NRC contracto During 1983 there were 86 ou~age days and during 1984, there were 221 outage day The increased outage time, as would be expected, resulted in increased waste and personnel exposure. The volume of radioactive waste shipped during these two years was comparable with that shipped from other plants of similar type and siz Approximately 19,069 cubic feet of radioactive waste was shipped from *the plant in 1983, and 31,340 cubic feet of radioactive waste was shipped in 198 The station had a well trained and aggressive health physics staf An indicator of the success of the ALARA (as low as reasonably achievable) program was the plant total man-rem exposur During 1983, the total exposure was 644 man-rem (86 outage days).
During 1984, the total exposure was 1918 man-rem (221 outage days). The 1983 exposure total was approximately half of the national average for pressurized water reactors. The 1984 exposure total increased significantly when compared to the 1983 exposure tota 1 ; however, this was not unexpected due to the significant increase in outage days and increased use of contract personnel to perform maintenance work and to provide coverage in the Quality Control are In 1984, there were one unplanned outage and two refueling outage Administrative control of the licensee's routine liquid and gaseous radioactive waste rel eases was adequat Liquid and gaseous effluent releases were small fractions of Technical Specification (TS) limit Control of secondary system discharges was normally not require However, due to primary to secondary leakage, monitoring of secondary system water prior to release to the storm drain system was required as was monitoring of other liquid waste discharge path Due to personnel error, several releases of water from the
secondary system were made prior to samplin The licensee has undertaken a program to correct these problem Although the PASS system was determined to be capable of func-tioning in accordance with the NUREG-0737 design criteria, the PASS and high range effluent monitor systems were p 1 agued by numerous problem Licensee management has taken actions to assure that these systems continue to function as required, which included assignment of personnel to perform system maintenanc Results of gamma spectroscopy analyses, conducted between the NRC and the licensee during a Region II inspection in which the mobile laboratory was used, were generally in agreemen No anomalous trends in the results were note Licensee responses to previously identified violations were adequate. All other aspects
- of the radiological confirmatory measurements program were adequat No envi ronmenta 1 program i n?pecti ons were performed during the evaluation perio Three violations were identified during the assessment period: Severity Level IV violation for failure to take service water effluent grab sample Severity Level IV violation for failure to properly complete radioactive material shipping paper Severity Level IV violation for failure to analyze liquid effluents before release to the environ.
Conclusion Category: 1 Trend During This Period:
Constant Board Recommendation A high level of performance with respect to radiological controls was achieve The Board recommends that NRC staff resources applied to the routine inspection program be reduce The Board noted, however, that si~nificant weakness existed in the related area of the North Anna Water Chemistry Progra In 1984 the 1 i censee incorporated the Steam Generator Owners Group/Electrical Power Research Institute (SGOG/EPRI) guidelines into the North Anna Water Chemistry Progra However, it was evident that plant management was not devoting *the resources needed to implement these guidelines. Significant weaknesses were
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identified in the following areas:
level of staffing and capability to initiate corrective actions in a timely manner during periods when no chemistry personnel were on site; infrequent monitoring/sampling schedules;* degradation of monitoring instrumentation, especially alarms from lack of maintenance; and deterioration of the condensate poli$hing syste These chemistry deficiencies were considered to be sever The licensee has entered into a contractural agreement with the Westinghouse Corporation for steam generator chemistry control This is a positive indication which should result in improvement in this are However, continued management attention should be given to this are Maintenance Analysis During the assessment period, inspections were performed by the Resident and Regional inspectJon staff The computerized maintenance report system in use allowed prompt identification of maintenance problems. This system also provided licensee management with information for the prioritization and scheduling of outstanding maintenance. Despite the fact that this tool ~as available, there was a large backlog of outstanding main-tenance i tern The back 1 og of maintenance i terns was being addressed, but even after elimination of the non-safety related items and of duplicate entries, the backlog shows that resources devoted to the correction of routine maintenance items may not be sufficien Problems in this area have contributed to plant operational difficulties. The large amount of equipment that was tagged as needing some amount of maintenance or a design change, and the quantity of Contro 1 Room annunciators that were in the alarmed condition due to required maintenance had, in some cases, desensitized plant personnel to the equipment operational statu This, in part, led to the problems identified in deviation h, and in violaticin b of the Operations section and in violation a of the Surveillance sectio These problems could have been identified had.the alarming annunciators been recognize Maintenance activities undertaken were observed to be well organized and planned by the planning departmen Maintenance work schedules demonstrated evidence of prior planning and assigning of priorities by managemen The necessary work reviews were thorough and technically soun Maintenance work records were found to be well maintained and retrievabl With respect to mechanical maintenance, the above comments are based on the licensee's program for mechanically cleaning service water piping, the repair of cracks in the recirculation spray heat exchanger diaphragm plates, replacement of outside recirculation
spray pump isolation valves, service water pipe replacement, and steam generator 11J 11 tube replacemen Maintenance of electrical switchgear and protective relays was determined to be acceptabl Maintenance personnel utilized the 1 a test procedures and ca 1 i brated measuring and test equipmen The administrative procedures and plans which control electrical maintenance activities were strictly adhered to, and materials used were properly specified. Work procedures provided sufficient information for maintenance personnel to accomplish the required maintenance in a controlled manne The procedures contained appropriate acceptance criteria and required post maintenance checks prior to turnover of the equipment to operations. However, there were some problems identified with the reactor trip breaker preventive maintenance procedure, in that the as-found condition of the breakers was not tested prior to the performance of routine maintenance and lubrication. The licensee considered this problem potentially generic to other electrical procedures and was taking steps to revise those proced~'.e The creation of an operational data analysis and trending-group and the proposal for a group to provide expertise on individual plant systems were examples of long range plans for further corporate management involvement to assure quality in the area of plant* maintenanc Lack of communication between the licensee 1 s two nuclear plants on potentially common problems has occurred on issues such as degradation of Recirculation Spray Heat Exchangers and the setting of torque switches on Limitorque valve operator The proposed Plant Systems group, in addition to providing a ready reference for system information, should a 1 so pro vi de the avenue by which such problems are reviewed for applicability at each statio Three violations and one deviation were identified during the assessment period: Severity Level IV violation for faiiure to follow a protective relay maintenance procedur Severity Level IV violation for an unanalyzed modification to the facility Design Basis Acci.dent qualified coating Severity Level IV violation for failure to maintain control over welding and welding material Deviation for an inoperable service-water-discharge-to-reservoir radiation monito.
Conclusion Category: 2
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Trend During This Period:
Improving Board Recommendation The involvement of managers in this area was evident; however, management should increase their efforts at reducing the backlog of outstanding maintenance item No change in the level of NRC staff resources applied to the routine inspection program is recommende Surveillance Analysis During the evaluation period, inspections were performed by the Resident and Regional inspection staff Inspections and review of the Inservice Inspection (ISI) program were also performe Management involvement and control in assuring quality in the areas of ISI and Inservice Tisting (IST) was clearly evident. A large amount of effort went into establishing ASME Section II pump and valve (IWP/IWV) programs that fully complied with industry codes and standards as well as Technical.Specifications. Documen-tation of ISI requirements was usually well prepared and submitted in a *timely manner; however, the results of testing the reactor vessel _ irradiation specimens were excessively delayed in submitta The licensee has increased resources in the ISI and IST program area Program documentation was concise and accurate; however, retrievability of the information was cumber-some as a computerized data base was being establishe Quality control involvement.was considered adequat The snubber surv~illance program did not receive adequate corporate management attention until problems in this area were discovered at the licensee 1s Surry Power Statio Numerous deficiencies in the snubber surveillance program were then identifie An inadequate service life program, incomplete listing of safety related snubbers and fail_ure to document generic review of snubber functional test failures existed during the assessment perio In the area of Technical Specification (TS) surveillance, manage-ment involvement and control in assuring quality was inconsisten Consultants were engaged to audit the program to ensure TS requirements were being me This clearly was indicative of management involvemen However, problems in this area continued to exist. A number of surveillances were missed including testing of various fire protection systems (referenced in Licensee Event Report (LER) 338/84-24).
Inadequate test procedures have also been a problem as illustrated by violations b, c, and d as well as the licensee identified improper breaker overload testing for
Unit 2 (referenced in LER 339/84-04).
Staffing was adequate to perform surveillance requirements, but the experience level in the Performance Test Group was margi na Some of the engineers in this group and their supervision had little knowledge of the industry codes/standards associated with the testing program they administered, and this, in part, led to some of the problems in the surveillance are As discussed in the previous SALP appraisal, the licensee made a permanent appointment.to the position of Reactor Engineer, which provided additional technical stability and depth to the onsite staf The information and resources that should be placed at his disposal are a continuing topic of discussion with the license A particular weakness, which was identified by the NRC and the licensee through the surveillance program, was the implementation of TS amenqments that revised or expanded the testing programs per 10 CFR 50 requirements. A result of the breakdown in the imple-mentation of the 10 CFR 50 requirements was a Severity Level III violation (violation *a) and associated civil penalty for not having the RCS head vents op*erab 1 e as required by 10 CFR 50.44 The containment integrated leak rate (Type A) test (ILRT) on North Anna Unit 1 was performed from August 4 through August 7, 198 Due to excessive containment leakage, test acceptance limits were inittally not met, and the ILRT was classified as a failed tes Subsequent retesting was acceptable. A Type A ILRT on Unit 2 was also completed satisfactorily during the assessment perio Management was involved as demonstrated by the quality of the prior planning and preparations for the tes Further, test personnel demonstrated a knowledge of the test and the technical'
issues involve The licensee revised the method of performing the verification test to comply with 10 CFR 50 Appendix J and defined an evaluation program which included review of the method of performing Type C testing. These actions were responsive to NRC concern The two Severity Level III violations (one in Plant Operations and the other in this Section) received by the licensee during this assessment period occurred largely because of internal mishandling of only one issu These two violations comprised an isolated instance and were not the result of lack of overall management attentio Four violations were identified during the assessment period: Severity Level III violation for failure to assure the reactor vessel head system was operable as required by 10 CFR *
50. 44( C )( 3) (iii)., Severity Level IV violation for an inadequate performance test leading to draining of the Unit 2 Casing Cooling Tan..
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I 13 Severity Level IV violation for inadequate response time procedure Severity Level V violation for failure to adequately review procedure.
Conclusion Category: 2 Trend During This Period:
Constant Board Recommendation Licensee resources in this area were adequat NRC and licensee management.attention should be directed to reviewi~g the adequacy of existing surveillance procedure No change in the level of NRC staff resources applied to the routine inspection program is recommende Fi re Protection Analysis During the assessment period, inspections were performed by the Resident and Regional inspection staff The fire brigade organization and training were found to be satisfactor Reviews of shift crew composition indicated that adequate personnel were.assigned io the shifts to meet required minimum manriing level~.
Fire drills were performed on a regular basis, and licensee personnel demonstrated their proficiency in this are The extensive reviews and subsequent modifications of the station's fire protection programs and equipment, made in order to meet 10 CFR 50, Appendix R, requirements, received a large amount of management attentio Routine problems encountered in the fire protection area did not receive such attentio The fire protection.staff at the plant was well trained, and they aggressively addressed problems; however, the staff had not been fully integrated into daily plant operation The fire marshal and his staff were not routinely informed of evolutions and events at the plant and could not make an indepen-dent professional assessment of the impact of these evolutions and events on fire protection systems. Corrective maintenance on fire protection system components such as relief valves was routinely delayed in order to address what the licensee felt were more urgent ope rat i ona 1 maintenance prob 1 em The motor driven fire pump failed its performance test in September 198 Some immediate work was performed in an attempt to return. it to service, but due to various problems, some of which were outside
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management's control, it was not brought back to full service until the end of January 198 During 1983, a preliminary NRC review of the licensee evaluation and proposed corrective actions to meet the NRC safe shutdown and fire protection requirements of 10 CFR 50 Appendix R was conducte Potential major violations were identified in that:
adequate fire protection features were not proposed for essential hot shutdown components; and, repair components for cold shutdown equipment were not availabl The licensee was not required to meet the Appendix R Section III.G requirements until late 198 Following this 1983 inspection, the licensee promptly began an extensive re-evaluation of the plan Appendix R deficiencies were identified and numerous modifications were undertaken to bring the plant into compliance with NRC requirement In general, management demonstrated a supportive role in the implementation of an effective fire protection program that met NRC requirement When unique problems were identified, such as the potential Appendix R vio'lations, or the two violations asso-ciated with the failure to adequately inspect the fire barriers between safety-related areas, the licensee took prompt action to resolve the problems with sound and viable resolution Housekeeping at the plant was goo Areas of the plant that were frequently travelled were kept cleaner than those areas that received little traffic, but even these less travelled areas were satisfactor Two violations were identified during the assessment period: Severity Level IV violation for failure to include the fire barrier between the auxiliary feedwater pumps as part of the 18 month fire barrier surveillance schedul Severity Level IV violation for failure to maintain up-to-date fire system surveillance procedure.
Conclusion Category:
Trend During This Period:
Constant Board Recommendations Appropriate management attention was applied to this are No change in the level of NRC staff resources applied to the routine inspection program is recommende Emergency Preparedness Analysis During the evaluation period, routine inspections as well as one special and one exercise inspection were performed by the Regional and Resident inspection staffs. The special inspection primarily addressed the ability of the shift supervisors to make prompt protective action recommendation The exercise involved the full-scale participation of state and local government The special inspection revealed specific weaknesses in the licensee 1 s training program as well as emergency plan implementing procedure One weakness involved failure to provide protective action recommendations following the declaration of a General Emergency as well as appropriate responses for general core-melt sequence The other weakness indicated that no protective action recommendations would be made if a general emergency were based solely on plant condition These findings resulted in viola-tions a and b belo **
Some weaknesses were observed in the licensee 1 s exercise progra The exercise scenario was found by NRC to be technically inaccurate in several places, which necessitated last minute revisions to the scenario prior to the exercis Following revisions to the scenario, the licensee 1 s performance during the exercise was in accordance with plans and procedures and resulted in a successful test of the licensee 1 s emergency pla The -
licensee 1s performance during the exercise reflected corporate and plant management 1s commitment to maintaining effective emergency implementing procedures, training and plan Licensee management actively supported the emergency preparedness programs as evidenced by exercise participation and involvement in emergency preparedness issue resolutio Response to NRC initiatives was timel The training program has shown improve-ment in providing appropriate training for emergency response personne The following essential elements for emergency response were determined to be acceptable: emergency classification, communica-tions, shift staffing and augmentation, dose projection and assessment, emergency worker protection, changes to the emergency preparedness programs and provisions for annual quality assurance audits of corporate and plant emergency planning program An.adequate working relationship existed between the licensee and offsite support agencie.. '
Staffing was at an acceptable level at the plant site. Additional staff support was available from personnel resources at the corporate offices when necessar During this assessment period, the licensee responded to a highway accident involving a shipment of new fuel enroute to North Ann In addition to making prompt notifications, the licensee greatly assisted state and local personnel in surveying the area and clearing the accident sit Two violations were identified during the assessment period: Severity Level IV violation for incomplete guidance for protective action decision-makin Seve.r\\ty Level IV violation for failure to properly train emergency personnel in protective action recommendation decision-makin.
Conclusion Category: 2 Trend During This Period:
ImproviQg Board Recommendation The area of emergency preparedness received a proper amount of management attentio No change in the 1 eve 1 of NRC staff resources app 1 i ed to the routine inspection program is recom-mende Security
, Analysis During this assessment period, inspections of the security program were conducted by the Resident and Regional inspection staff Licensee actions have consistently provided evidence of prior planning and proper prioritization of security related matter The effectiveness of supervision for security personnel performing access control fuctions was strengthened in r'esponse to an increase in violations of a repetitious natur The licensee's efforts to ensure resolution of operational and functional security issues continued to be positiv This reflected effective managerial attention and corporate suppor The approach to resolution of technical issues from a security and safety standpoint was technically sound, conservative and thorough
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in most case A weakness in procedures established for the testing of protected area perimeter alarm equipment was attributed to misinterpretation of regulatory requirements. The licensee was responsive to NRC initiatives and was dedicated to meeting or exceeding minimum regulatory requirements regarding securit Efforts in this regard were demonstrated by the establishment of a vehicle transition zone prior to protected area entry, and installation of heavy concrete barriers along the protected area perimeter and approaches to the protected area vi a the vehicle parking area to preclude forced penetration of the protected area by vehicl Security organization positions and responsibilities were well define The security staff was ample to implement the facility physical protection program. The facility guard qualification and training plan was effectively implemented on a continuing basis at all levels of the security organizatio Of the four security violati.~ns identified during the assessment period, three were attributed to personal error by individual members of the security organization in the issuance of security badges and control of access to vital areas. Violation c was the result of management failing to provide an adequate procedure for testing alarm equipmen Four violations were identified during the assessment period: Severity Level IV violation for four instances of issuance of wrong security badge Severity Level IV violation for failure to positively contr-ol all points of access into a vital are Severity level IV violation for an inadequate procedure for testing the microwave intrusion alarm syste Severity Level V violation for two instances of issuance of the wrong security badg.
Conclusion Category:
Trend during this period: Constant Board recommendations Licensee resources in this area were ampl The Board recommends that NRC staff resources applied to the routine inspection program be reduce Refueling Analysis During this evaluation period, inspections were performed by the Resident and Regional inspection staff Refueling operations were observed for Unit 1 during the period June through September 1984 and for Unit 2 during the period August through October 198 The receipt of new fuel and the condition of spent fuel were inspected as part of refueling operation Managerrient involvement was evident in all areas of refueling operation Refueling related activities reflected thorough preplannin Refueling crew staffing and staff training were adequate; corporate support personnel were readily available; and both refue]ings, including fuel sipping, were accomplished in a safe and professional manne The refueling coordinator (Senior Reactor Operator supervising the refueling) closely monitored the activities of personnel in his charge on the refueling deck and/or in the fuel bui 1 din I.n the contra 1 room, however, the SRO on duty on the unit undergoing the refueling did not always' keep himself informed of control room activities-allowing refueling and testing personnel to direct the control room* operator's activities. This direct interface between test pe~sonnel and the operator was required during post refueling physics testing; however, it was not clear in all cases that while allowing the direct interface the SRO kept himself aware of plant status at various stage~ of the testin Fuel assembly movements and fuel sipping operations were observed for both unit Technical problems encountered during refueli~g were promptly resolved in a competent and safety conscious manne In general, Unit 2 post refueling startup test performance and Unit 1 and Unit 2 test records were adequat Coordination and cooperation between the on-site nuclear engineers ( responsible only for data collection) and corporate office nuclear engineers (responsible for data reduction, evaluation and feedback to the plant) improved. A delay in availability of test results from the off site engineering group was a contributing factor in the incompleteness of some on-site record The approach to managing and correcting an abnormally high number of fuel failures which developed during this period was timely and appropriat The high number of failures reflected poor cleanli-ness control during past maintenance on the Reactor Coolant Syste t '
One violation was identified in this area during the assessment period:
Severity Level V violation for failure to follow procedure.
Conclusion Category: 1 Trend During This Period:
Not determined Board Recommendation Management attention to this area was aggressive and oriented toward nuclear safet The Board recommends that NRC staff resources applied to the routine inspection program be reduce Training Analysis During the assessment period, routine inspections of plant training programs were performed by the Regional and Resident inspection staff A special team assessment of North Anna training programs was conducted to determine the effectiveness of the licensee's overall training program in supporting the safe operation of the plant. Although several weaknesses were identi-fied, the training of plant personnel was determined to be accept-able for the support of safe operatio Management continued to be responsive to NRC initiatives and-concerns, and aggressively sought improvements to plant training programs throughout the assessment. perio Notable examples of management's commitment to improving training were the utilization of a training facility very suitable to the learning process and the completion and startup of a plant specific sim.ulato The development of performance ba~ed training programs and efforts to achieve Institute of Nuclear Power Operations (INPO) accreditation resulted in most training programs being in transition throughout the.assessment perio Management commitment in the area of maintenance training was eviden The construction of a maintenance training laboratory provided the opportun:i ty. for a 1 arge amount of "hands on 11 trainin However, while the level of training of station maintenance personnel has increased, very little time had been devoted to famil i ari zing other personne 1 who performed safety related work whh station procedural requirements or with the specifics of the jobs they were to perfor Violation a of the Maintenance Section and the subsequent multiple losses of station electrical buses, illustrate a case where licensee personnel not
- f
assigned to the station were unfamiliar with station procedures and layou The trend toward assigning more work to a contract workforce without the proper training resulted in problems such as those identified in violation a of the Maintenance Section. The licensee assigned personnel to a job strictly based on past job qualification and did not assure familiarity with station procedures or with specific job requirement A reorganization of plant training and corporate training staffs was initiated to facilitate accreditation efforts and to improve program administration. Instructor certification* was strengthened with the implementation of a two year master certification program. A competent corporate training organization was expanded to control the management of training program development, imple-mentation, administration and evaluation; Improvements in plant training.q,uality were a direct result of increased corporate involvement in the training proces In the area of licensed operator training, eleven SRO and nineteen RO candidates were examined during the assessment period. Nine of the SRO candidates and eleven of the RO candidates passed the examination and were license The passing ratio for RO candi-dates was below the Region II averag Contributors to the poor performance were the lack of an approved procedure controlling the conduct of license training, the lack of current systems texts to supplement classroom lectures and the lack of up-to-date lesson plans to aid instructors. As discussed in the Emergency Prepared-ness section, SROs did have difficulties with protective action guidelines, but retraining was conducte Non-licensed operator training also suffered some of the same basic weaknesses as the licensed training progra The implementation of performance based training and the provision of suitable training materials were alleviating these problems towards the end of the assessment perio Various non-licensed training programs were in a state of transi-tion due to the conversion from kn owl edge-based methodo 1 ogy to performance based methodolog Continued development and utiliza-tion of training laboratories in the maintenance and general empluyee training (GET) programs yielded further improvements to these program Efforts to formalize all phases of training continued throughout the assessment period. The licensee has not implemented a training/continuing training program for staff engineer Development of this program was underway at the close of the assessment perio The licensee's GET program was very goo The depth of the.
material presented exceeded the minimum required. The instructors were always well prepared, interested and very responsive to both questions and suggestion The licensee has developed a comprehensive training program for Quality Assurance/Quality Control (QA/QC) personnel. A training coordinator has been appointed to maintain personnel qualifica-tion QA/QC training records were well maintained and easily retrievabl One deviation was identified during the assessment period:
Deviation for failure to provide management training to Shift Technical Advisor candidate.
Conclusion Category:
Trend During This Period:
Improving Board Recommendation Satisfactory regulatory performance was achieved in this are However, increased management attention should be directed *to the training of the offsite maintenance staf No change in the level of NRC staff resources applied to the routine inspection program is recommende Quality Assurance and Administrative Controls Affecting Quality L
Analysis During this assessment period, routine inspections were performed by the Resident and.Regional inspection staff The surveillance and calibration control program was reviewed and found to be adequat Nuclear Plant Reliability Data System (NPRDS) personnel training, data acquisition, data inputs and data useability was adequat Procurement proc*edures did not always contain necessary tative and qualitative acceptance criteria relative to procurement document review Similar problems were identified with measuring and test equipment procedure problems resulted in violation quanti-various also These The lack of proper control of Category 1 QA materials, as discussed in the previous SALP, improved during this appraisal perio However, additional effort was needed in the area of procurement to ensure that adequate quality controls were specified on procurement document Several examples of improper categorization of procured material have been identified including improper procurement of service water reservoir spray piping and hydrogen recombi ner part Improperly procured service water
p1p1ng resulted in the degradation of original design specifica-tions and circumvented established administrative controls that would normally require a material substitution evaluation prior to us This resulted in violation The site QA department was reorganized to add new functional units and additional personne The training staff, management staff, QA Supervisor and staff, and QC Supervisor and staff report to the QA Manage The QA staff added a Senior Reactor Operator who functioned as a technical advisor and provided the QA Department increased knowledge in the areas of Technical_ Specifications and system operability requirement Records and delineate document control activities were Records were easily retrievabl procedurally An integrated design control and document control program has been establishe This program adequately delineated interface activities between Power Station Engineering and other organiza-tions. Additional programmat'ic controls were provided for design engineering activities performed by Power Station Engineerin Appropriate licensee actions were in progress to more clearly describe how Engineering Work Requests were converted into Outside Technical Support Requests by Power Station Engineerin Two violations were identified during the assessment period: Severity Level IV violation for failure to provide appro-priate qualitative or quantitative acceptance criteria in the controlling procedures for the procurement program and the measuring and test equipment calibration progra Severity Level IV violation for failure to inspect service water spray piping at required interval.
Conclusion Category:
Trend.During This Period:
Improving Board Recommendation The licensee's use of resources in this area was reasonably effectiv No change in the level of NRC staff resources applied to the routine inspection program is recommende "r 23 Licensing Activities L
Analysis The lice~see's management has demonstrated active participation in licensiri'g activities and has kept abreast of current and antici-pated 1 i censi ng action Particularly noteworthy has been the management involvement and initiative in ten specific areas:
the North Anna Power Upgrade Program (presently completed for 2 out of 3 phases); the completed licensing activities for increasing the spent fuel storage; the proposed trans-shipment of Surry spent fuel to North Anna (in hearing); the licensing activities asso-ciated with deleting the TS for the temperature limits on steam generator supports; "the revision of the TS for Turbine Overspeed Protection; the Appendix R Reanalysis Effort and associated plant modifi ca,t.i Qns and exemption requests; the forceful effort in pursuing the North Anna Service Water Piping and Valve Corrosion and Preservation Program; the completion and closeout of Environ-mental Qualification of Equipment; the attention and response to recent Emergency Diesel Generator Failures; and the initial response to the NRC regarding Phase I of the Revi.ew of --Risk Importance of Current Regulatory Requirements for Light Water Reactor It *was noted that the 1 i censee I s management i nvo 1 vement and initiative in consummating a partnership responsibility with Westinghouse to improve long-term performance of steam generators was exemp 1 ary. The 1 i cen see I s management actively pursued an aggressive-and continuous upgrade in the North Anna Unit 1 and 2 TS for continuity and similarity. This effort was substantiated by the number of TS changes submitted on a continuing basis. In the case of special problems, management involvement and coopera-tion was excellen Early in 1984, several examples of inadequate licensee responses to the NRC were identified. Later the licensee was faced with a then-proposed violation regarding 11material false statements.
Licensee management reaction to this potential violation was a factor in establishing an enhanced review and concurrence organ-izati.o This new organization added the Assistant Station Manager for Safety and Licensing as well as m~king some changes in the corporate licensing managemen Because of these changes, a significant increase in the time. required for the licensee to process NRC submi tta 1 s was observe The meeting of submit ta 1 commitment dates has deteriorate Additionally, these changes have resulted in some confusion and loss of continuity regarding the integral status of NRC actions for North Ann Discussion with the licensee's management indicated that management was aware of the problems above and was takfng corrective actio In order to alleviate possible staffing level effects, the licensee was actively recruiting to double the licensing staff at the site and
i I
I I
' l
corporate office. It must be noted that some of the licensee 1 s organizational changes were beginning to provide positive result The licensee 1s quality of responses were usually excellent. The licensee 1s submittals for the Power Upgrade (Phases 1 and 2); the Appendix R Reanalysis Effort and Exemption Requests; the amendment requests for Spent Fuel Augmentation and Trans-shipment of Surry Spent Fuel to North Anna; and the Service Water System Piping Cleanup Program were, a few examples of excellent quality conten In addition, the no-significant-hazards evaluations for the many TS amendment changes were either adequate or excellen Whenever technical issues were addressed in depth, knowledgeable people were involved who could address an issue not only from the licensee 1s standpoint but also from knowledge of NRC regulations, criteria, and generic issue Interface with the NRC staff at meetings and site visits was open, professional, candid and responsive to staff need The licensee accepted its responsibility for plant safety and operability, and assessed, evaluated and implemented technical modifications when required without always waiting for NRC requirement An example was the submittal to the NRC regarding the corrosion and mechanical cleaning of the Service Water System Piping and Valve Repair As presented, the licensee's program represented a unique approach to the upgrading of the Service Water Syste On occasion, when the licensee deviated from the staff guidance, the licensee consistently provided good technical justification for such deviations. The fire protection program and the program for environmental qualification of* equipment illustrate the soundness of the technical justifications for deviations from the guidanc When unusua 1 events occurred at North Anna, the licensee invariably used conservative approaches in dealing with the situations, and performed indepth analyses of significant safety issues raised by such event During the recent and ongoing resolution of emergency diesel generator failures, the l i c1:1n see contracted an engineering consultant as an independent third-party to monitor and critique the licensee and vendor effort for improving maintenance, operating procedures and root cause(s)
of previous engine component failure This was not the first time that the licensee made use of an independent third party to monitor licensee and vendor endeavor *
The licensee 1 s management and staff maintained excellent liaison with the NRR project manage It was a common practice for the licensee to expeditiously report to NRR any event reported to the NRC Emergency Response Cente Also, the licensee notified NRC well in advance of forthcoming requests for amendments or review of safety issue The licensee made frequent visits to NRC to discuss forthcoming requests for staff actions prior to formal submittals. Examples of such visits were:
licensee-staff meetings regarding the North Anna Power Upgrade (Phases 1, 2,
and 3), the issue of non-qualified paint on ventilation ducting inside containment, the issue of the North Anna Service Water Corrosion and Mechanical Cleaning of Piping, and the recent issue of diesel engine failure In addition, when technical issues could be better addressed by North Anna site visits, the licensee was most cooperative and provided the technical staff necessary to discuss appropriate matter.
Conclusion Category:
Trend During This Period:
Improving Board Recommendation The conduct of activities in the area of licensing showed a~proper concern for nuclear safet Supporting Data and Summaries Licensee Activities During the assessment period, refueling outages were completed on both units, and an emergency response drill was conducte Major items completed were ILRT on both units, the resolution of containment ventilation paint issues, installation of the plant simulator and-Appendix R modification Construction of the site Technical Support Center progressed and partial use of the facility will be available in May 198.
Inspection Activities During the assessment period, routine inspections were performed on the North Anna facility and one special training assessment was conducte Licensing Activities The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating perio These actions, consisting of amendment requests, exemption requests, responses to
generic letters, TMI items, and other actions, are classified as follows:
37 Multi-Plant Actions (14 completed).
Included in this category are:
0
0
0
0
0
0 Natural Circulation Cooldown, (GL 81-21), completed NUREG-0737 Tech Specs (GL 82-16 and 83-02), completed Control of Heavy Loads, Phase I, completed Automatic Actuation of Shunt Trip for Westinghouse Plants, completed Adequacy of Station Electrical Distribution Voltages, completed Environmental Qualification of Equipment, completed Technical Specifications (GL 83-36)
Techn\\cal Specification (GL 84-15)
Revise Technical Specification For LER Reporting (Part 50.72
& 50.73), completed Masonry Wall Design (IE Bulletin 80-11)
Control of Heavy Loads (Phase II)
Technical Specifications (GL 83-36 and 83-37)
100 Plant Specific Actions (86 completed).
Included in this category are:
0
0
0
0
0
0
Amend License to Incorporate Old Dominion Electric Coopera-tive As Partial Owner of North Anna 1 and 2, completed Issue Safety Evaluation Report and EIA for Spent Fuel and Transhipment Hearings, completed Amend Technical Specification for Augmented Spent Fuel Storage, Completed Amend *License for Receipt and Storage of Surry Spent Fuel, In-hearing Extend Burnup to 45,000 MWD/MTV, completed Amend License for Increasing Reactor Coolant System (RCS)
Average Temperature to 587.8 degrees (Phase 2 Power Upgrade), completed Revise TS for Turbine Overspeed Protection Operabi 1 i ty, completed
Delete TS requirements for SG supports, completed Regulatory Review-Vital Area Validation (Phase 1), completed Regulatory Review-Vital Area Validation (Phase 2)
Non-Qualification of Paint on Duct Work Inside Containment, completed Evaluate Five Year Report on Settlement and Groundwater Level at Service Water Reservoir, completed
. Amend Technical Specification for Terminating Turbidity and Suspended Solids from Drain System Under Service Water Pump House, completed
,
0
0
0
0
0
0
0
0
Revise TS for Increased Fire Protection Surveillance, completed Appendix R Reanalysis Exemption Requests Revise TS to Designate PORVs and Safety Valves as part of RCS, completed Request Interpretation of 10 CFR 20.202 and 20.203 for Posting of Radiation Areas, completed Exemption Request to 10 CFR 50.55(c)(3)(III), completed Revise Technical Specification for Quadrant Power Tilt Ratio, complete Revise Technical Specification-Fractional Power Multiplier, completed Revise Technical Specification for Emergency Diesel Generators Service Water Piping Corrosion & Preservation Program, Evaluqte North Anna Main Transformer Failures, complete Revise Technical Specification to Include Cont. Hogger as Part of Gaseous Pathway Review of Risk Importan~e of Current Regulatory Requirements
- Phase I Inservice Testing (Pumps and Valves)
Interim Relief Request - Inservice Testing (Pumps and Valves), completed Extension Request for Interim Relief (Pumps and Valves)
- Detailed Control Room Design Review Program complete~
41 TMI (0737) Actions (25 completed) Investigation and Allegation Review There were no significant investigations or allegation activities completed during the assessment perio Escalated Enforcement Actions Civil Penalties A Severity Level III violation concerning inoperable reactor coolant system vents whi_ch resulted in a civil penalty in the amount of forty thousand dollars was assessed on February 1, 198.
Orders (only those relating to enforcement)
Non Management Conferences Held During Appraisal Period Apri 1 17, 1984 An enforcement conference was held to discuss the operability of the Unit 1 and 2 reactor head vent '
I 28 Review of Licensee Event Reports and 10 CFR 21 Reports submitted by the Licensee During the assessment period, there were 52 LERs reported for Unit 1 and 26 LERs reported for Unit 2. The distribution of these events by cause, as determined by the NRC staff, was as follows:
Cause Unit 1 Unit 2 Component Failure
12 Design
1 Construction, Fabrication, or Installation
0 Personnel Operating Activity
1
-
Maintenance ~ctivity
6
-
Test/Calibration Activity
3
-
Other
0 Out of Calibration
1 Other
2 TOTAL
26 It was noted that for Unit 1, 83% of the LERs were confined to two categories:
component failure ( 56%) and personnel error ( 27%).
For Unit 2, the same two categories accounted for 84% of the LERs, with component failure 46% and personnel error 38%. Inspection Actiivty and Enforcement FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL V
IV III II I
Plant Operations
5
Radiological Controls
Maintenance
Surveillance
2
Fi re Prote_ct ion
Security
3 Refueling
Training Quality Assurance and Administrative Controls Affecting Quality
TOTAL
22 2