IR 05000338/1989016
| ML20246L244 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/15/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20246L238 | List: |
| References | |
| 50-338-89-16, 50-339-89-16, NUDOCS 8909060288 | |
| Download: ML20246L244 (35) | |
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ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-338, 339/89-16 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA UNITS I and 2 May 1, 1988 through May 31, 1989 l
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' TABLE OF CONTENTS Page I. INTRODUCTION . . ........................................... 1 Licensee Activities ... . .. . .. ........... . .... . . 1 Direct Inspection and Review Activities ............... 2 II. S UMMARY O F RES U LTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 0verview...................... ............................. 5 III. CRITERIA ........................ .... ..................... 6 IV. PERFORMANCE ANALYSIS ........ ............................. 7 Plant Operations ............. ........ ............... 7 Radiological Controls .......... ..................... 11 Maintenance / Surveillance ............................. 14 Emergency Preparedness ............................... 19 Security ...................... . .................... 20 Engineering / Technical Support ........................ 22 Safety Assessment / Quality Verification ............... 26 V. SUPPORTING DATA AND SUMMARIES ..............................'30 Investigation Review ............. ................... 30 Escalated Enforcement Action ......................... 31 Management Conferences ............................... 31 Confi rmation of Action Letters . . . . . . . . . . . . . . . . . . . . . . . 32 Review of Licensee Event Reports . . . . . . . . . . . . . . . . . . . . . 32 Licensing Activities . . .. . ....................... 32 Enforcement Activity ... .............................. 32 Reactor Trips . . . . . . . . . . . ............................ 33 Effluent Release Summary . ........................... 33
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. INTRODUCTION' 'l The Systematic Assessments 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 on .the basis of this information. The program is supplemental to normal : regulatory processes -
- used to ensure compliance with NRC rules and regulations. It.is intended to be sufficiently ~ diagnostic to provice~ a rational basis for allocation of NRC.. resources and to provide meaiingful feedback to the licensee's management regarding. the NRC's assessment of their f acility's perform'ance in each functional are An NRC SALP Board, composed of the staff members listed below,_ met on-July 21,;1989, to review the observations and data on performance, and t assess licensee ~ performance in. accordance with Chapter NRC-0516,
" Systematic Assessment .of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of. this repor The Board's_ findings and ~ recommendations were forwarded to the. NRC Regional Administrator for approval and issuanc This report .is the NRC's assessment of the licensee's safety performance at North Anna facility for the period May 1, 1988 through May 31, 1989-L The SALP Board for North Anna Units 1 and.2 was. composed of:
L-.:Reyes, Director, Division of Reactor Projects (DRP), Region II (RII)
(Chairman)'
- Merschoff, Acting Director, Division of Reactor Safety (DRS), RII D.LCollins, Acting Director, Division of Radiation Safety and Safeguards (DRSS),. RII M. Sinkule, Chief,' Reactor Projects Branch 2, DRP, RII H. Berkow, Director, Project Directorate II-2, Office of Nuclear Reactor Regulation (NRR)
J. Caldwell, Senior Resident Inspector, North Anna, DRP, RII L. Engle, Project Manager, Project Directorate II-2, NRR
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' Attendees at SALP Board Meeting:
P. Fredrickson, Chief, Project Section 2A, DRP, RII M. Lewis, Project Engineer, Project Section 2A, DRP, RII S. Shaeffer, Project Engineer, Project Section 2A, DRP, RII l G. Wiseman, Reactor Engineer, Technical Support Staff (TSS), DRP, RII J. Munro, Resident Inspector, North Anna, DRP, RII l-
- Licensee Activities The assessment period began with both units operating at approxi-mately 100% power. Unit 1 experienced one automatic reactor trip on ;
August 6,1988, and a second on February 25, 1959. Just following '
.the second-reactor trip, the unit experienced a major steam generator (SG) tube leak in the "C" SG, resulting in declaration of an Alert classification. The cause of the tube leak was determined to be a failed tube plug, a fragment of which was propelled up the tube, causing a penetration of the tube at the tangential point of the SG L
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U-ben As a result, the licensee elected to commence the refueling i outage earlier than originally schedule Just prior to the February 25, 1989 reactor trip, Unit 1 had been operating continu-ously for 198 days. By the end of the assessment period, Unit I was still in the refueling outage, day 9 Unit 2 did not experience any at power automatic reactor trips or unplanned shutdowns during the assessment period. Unit 2 established
. a VEPC0 record of 371 days of continuous operation prior to beginning-a refueling outage on February 19, 1989. At the commencement of the Unit 2 outage on February 19, North Anna set a dual unit three loop Westinghouse record which consisted of 192 days of continuous operation, breaking the previous record of 172 days also set by North Anna. The refueling outage was completed on May 8,1989 with the turbine being placed on line. The unit achieved 100*4 power on May 16 and remained at that power level through the end of the assessment perio Also noteworthy during the assessment period, was the report from an outside nuclear publication that North Anna Unit 2 was number one in the world for Westinghouse plants, number three in the world overall and number two in the United States for its 1988 capacity facto On March 7, 1989, the licensee instituted an interim corporate reorganizatio This change was initiated to ensure that the licensee could deal more effectively with nuclear problem The changes realigned the Senior Vice President of Power Operations and Vice President of Power Engineering Services to that of the nuclear program only, removing their non-nuclear responsibilitie The change also created two new positions, Vice President of Nuclear Services in charge of the nuclear support sections and Assistant Vice President of Nuclear Operations to assist the present Vice President of Nuclear Operation The on'v changes affecting the station as a result of the reorganization involved the creation of a new position called Superintendent of Outage Management and the placement of the station engineering staff under the Vice President of Nuclear Engineering. The latter resulted in a new position of Superintendent of Engineerin B. Direct Inspection and Review Activities During the assessment period, routine inspections were performed at the North Anna facility by the NRC staff. Special inspections were conducted as follows:
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May 24-27, 1988; an inspection was conducted to review the licensee's actions concerning the excessive fouling of the recirculation spray heat exchangers (RSHXs).
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June 20-24, 1988; a special inspection was conducted concerning previously identified findings in the area of environmental qualification of electrical equipment important to safet _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
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1 June 27-30, 1988; a special Emergency Response Facility (ERF)
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appraisal was conducted to evaluate the effectiveness of the ERF and equipment support of _the Emergency Response Organization,
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during the 1988 annual emergency preparedness exercis f
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July 18-22,1988; a triennal post-fire safe shutdown capability reverification and assessment was conducted to evaluate whether the licensee _ had a functioning configuration management program as it relates to fire protection and post-safe-shutdown capabilitie August 15-19, 1988; an inspection was conducted in the areas of confirmatory measurements and counting room quality assurance for in plant radiochemical analysi December 5-9, 1988; a special inspection was conducted in the area-of radiation protection preparation for the Unit I and Unit 2 refueling outage February 13-17, February 27 - March 3, May 8-12, and May 22-26, 1989; a joint Safety Systems Outage Modification Inspection (SSOMI) and a Maintance Team Inspection (MTI) was conducted to review planned plant changes and determine if the as-modified plant remained in accordance with its licensing basis. The team also reviewed installation and testing to ensure that the repaired, modified or newly inrtalled components conformed to the design, installation, and operating requirement The implementation of the maintenance program was also assesse February 21-23, 1989; a special inspection was conducted to follow up on the previous ERF appraisal open items and emergency preparedness program enhancement item February 26 -
March 20, 1989; the NRC dispatched increased inspection resources to North Anna to support the review of the SG tube leak and plug failure even March 6-10, 1989; additional inspection effort concerning the SG tube failure and a review of historical eddy current data associated with the failed tube were conducte March 13-17, 1989; an additional inspection of the SG tube leak event including a review of the licensee's recovery efforts was conducte April 3-7,1989; an inspection was conducted of the licensee's compliance with Regulatory Guide 1.97, verifying the licensee has an instrumentation system for assessing variables and systems during and following an acciden April 6-7, 1989; a special inspection was conducted as a followup to the SSOMI team's significant finding _ _ _ _ _ _
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April .17-21, .1989; an inspection ' was conducted to review the
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licensee's perf_ormance during the 10 CFR 50, Appendix J, Type A E and Type C leak rate testin .IL SUMMARY OF RESULTS Operations performance during the assessment period was very good. Both urits sustained exceptionally long runs with a substantial decrease in the number of reactor trips f rom the two previous periods. The physical condition of the plant continued to be a strength. Although operations personnel-'were involved with several events involving inattentiveness and procedural adherence performance, corrective actions for these problem areas' were in place toward the end of the assessment period. Also, the
- startup/ shutdown problems encountered during the previous assessment l, appeared to have been corrected. The fire protection program was also being managed in an effective manne Health physics (HP) performance was mixed during the assessment perio While the staffing levels, knowledge and experience of the HP organization was good, numerous instances of radiation area access control problems occurred during the. assessment perio Although site management
. aggressively pursued a resolution of this problem, access problems continued to the end of the assessment period. The collective dose for the station was also slightly above the national average. Also, with the exception of tritium, the station's gaseous and liquid effluents were below the industry averag Evaluation' of the Maintenance / Surveillance functional area benefited significantly from the successful operating performance of the unit utside the direct support to operations, though, maintenance activities were in various stages of development and implementation. Several issues identified in previous assessments, such as the check valve preventive maintenance (PM) program, the post-maintenance testing program and test scheduling during outages, have .been addressed, but . only partially. The SS0MI also identified additional problems in post-maintenance testin Maintenance procedure deficiencies contributed to several safety signifi-cant problem a~reas, such as the recirculation spray system, the control room' habitability system and the instrument air (IA) system. Staffing was adequate, but successful maintenance appeared to be due primarily to good technical knowledge compensating for the limited number of personnel and minimally adequate procedure Implementation in the Emergency Preparedness functional area was adequat Although the licensee effectively handled an Ale L condition during a SG tube -leak, this event did not fully challenge the emergency preparedness program. With respect to correcting identified deficiencies, the licensee was slow in resolving the problems identified in the emergency response facilities appraisal, revealing a need for improved timeliness of response to NRC initiative Security activities were conducted in a better than adequate, although not exceptional, manner. In several areas, extensive coordination was observed between the corporate security staff and the NRC staff. Also, a stable qualified staff received aggressive training and requalificatio _ _ _ _ _ - _ _ _ _ - . - - - - - _ _ - _ -- __ __ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ -
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Security plan revisions: revealed . evidence of prior. planning by licensee management.. However, the licensee was less than aggressive in repairing orJ upgrading the security detection systems and the computerized access control system Performance -in several areas of the Engineering / Technical Support functional area.needed. improvemen Reactive.. issues such as the SG tube
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leak were handled quite well; but proactive issues such as the check valve PM program and the weak root'cause analysis program revealed a lack of the required aggressiveness to effectively fix the probl3ms. Although design development by.the engineering staff was good overall, several performance deficiencies were identified during the' assessment period. Develo? ment of post-modification testing and design verification as well as severel areas of technical support were also found. to need improvement. Licensed operator training improved significantly, contributing to. the improved operations performance. Training accreditation renewal had been received for all the licensee ' training programs during the assessment perio Results of operator exams were higher than the industry averag Several significant problems were identified in the ' Safety Assessment /
Quality Verification functional are The need for an effective - root cause program, identified during the previous assessment, still existe A program was developed, but was not effective as evidenced by several events during . the period. Although the station's review activity - was functioning satisfactorily, the offsite independent group was not meeting its required oversight responsibilitie Problem identification at the site level was a strength; but problem resolution at this level, though adequate,.needed improvement. ,Another positive attribute in this area was
- the licensee's self-assessment and startup assessment ef fort. Also, the quality assurance organization improved its effectiveness by -conducting performance < based inspection Overall, the quality of submittals was good and there was an adequate level of management involvement- in licensing actions. However,-in-some instances, the licensee's submittals were not timely or were not evaluated sufficiently prior to submitta Overview
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Rating Last Rating This Functional Area period Period Plant Operations 2/1 1 (operations and fire protection)
Radiological Controls 2 2 Maintenance / Surveillance 2/2 2 Emergency Preparedness 2 2
. Security . 2 2 Engineering / Technical Support NR/1/3 2 (engineering, training & outages)
Safety Assessment / 2/1 2 Quality Verification (quality programs & licensing)
NR - Not Rated
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- II CRITERIA Licensee performance is assessed in selected functional areas, depending on L whether the facility is .in a construction 'or operational. phas . Functional areas normally represent areas significant to- nuclear safety
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and the. environment. Some functional areas may not be assessed because o little or. no licensee activities or. lack of. meaningful . observation Special areas may be added to highlight significant observation . The following evaluation criteria were used, as applicable, t'o assess each functional area: Assurance of quality, including management involvement and control;
' Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; I Operational and construction events (including response to,- analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness'of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where' appropriat On the basis of the NRC assessment, each functional' area evaluated is rated'according to three performance categories. The definitions of these performance categories are as follows: Category Licensee management attention .and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a .high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to
' meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieve NRC attention may be maintained at normal level Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee
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b resources appear' L to .be? strained or not eff ectively use NRC
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attention should be increased.above normal levels- .
The SALP Board may also include an appraisal of=the performance. trend.of a-
' functional area. This performance trend will only be- used when both a definite trend of performance within the evaluation period is discernable'
and the; Board believes . that continuation of the strend 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 perio Declining: Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this patter I PERFORMANCE ANALYSIS Plant Operations Analysis During the assessment period, inspections of plant operations-and fire protection were performed by the resident inspector'and
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regional inspection staffs. The overall operational performance of the units during the assessment period was-~ exceptionally good. Unit I had several' continuous on-line runs exceeding 100 days before- completing a 198 day continuous run prior to the commencement of the refueling outage on February 25, 1989. Unit 2 completed a continuous on-line- run of 371 days prior to the commencement of the refueling outage 'on February '19,1989, and was recognized as number three in the world for its 1988 capacity factor. The two units also set a dual unit continuous on-line' record of 192 days for.three loop Westinghouse plant The licensee achieved a station goal of no more than four reactor trips per year during the 13-month assessment period by experiencing a combined unit total of only three reactor trip This is compared to 11 and 16 trips, respectively, during the previous two assessment periods. Two of the reactor trips were
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from power operations and occurred on Unit I due to equipment problems. The third reactor trip occurred while Unit 2 was in cold shutdown, and was due to an inadequate procedur This decreasing trend ,in reactor trips and overall increase in the operating performance was due in part to a number of programs initiated and supported by station management, including the Coaching, Self Checking, Check Operator, and Human performance i Evaluation System (HPES) programs. Management has also directed
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the Quality Assurance (QA) Department to conduct performance based inspections of routine and nonroutine station operation These initiatives demonstrate station management's support of station ' operations and desire for improved performance, and provided management with the necessary self assessment capabilities to properly allocate management resource _ _ _ _ _ _ _ _ _ - . - - _ _ _ _
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l Station housekeeping and control room decorum continued to be
- strengths. .The. painting and overall upgrade of the station had n been virtually completed in the turbine building and was.well on the way to being- completed in the auxiliary building. This
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e effort, which resulted in a more professional looking facility,
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= and seemed to be reflected.in increased station personnel pride and' professionalism. The operations staff continued to maintain a very ~ professional and knowledgeable approach to unit operatio The shift composition generally exceeded the technical specifications (TS) requirements. In addition, all of the management level positions, the majority of the superinten-dent level positions and some of the supervisory level positions were filled by persons who either hold or have held a senior reactor operator. (SRO) license. The control room' atmosphere was quiet, controlled and well organized, which contributed to the safe operation of the unit ' Licensee management continued to provide a presence at the station by ' conducting both normal and off-shift tours of the unit Management also clearly documented its policy on supervisory and employee performance and disciplinary measure These actions increased personnel accountability in relation to their action The licensee also established a policy to involve its staff in enforcement conferences and NRC exit meetings to provide a better understanding of the consequences of personnel actions The licensee's approach to resolving technical issues from a safety standpoint was generally good. An example of a strength in this area involved management's initiatien of specific-operator training for' unit shutdowns, startups and . loss of RHR events. This training was conducted in response to weaknesses identified in the previous assessment period concerning operator errors during unit transient conditions and to address the industry concern involving loss of residual heat removal (RHR).
Examples of weaknesses in this area involved both management's and the operations staff's tolerance of substandard conditions concerning the IA system and the cold shutdown temporary vessel level indication system. The IA system was operated in such a manner that the air quality to safety related components was allowed to degrade below standard guidelines. System dryers and filters were routinely bypassed and construction air was allowed to supply the IA system. This allowed oil and moisture laden air to contaminate the components supplied by I Similarly, the temporary vessel level indicating system was considered to be reliable during unit conditions which were known to affect the indication accuracy. This resulted in two reductions in the Unit I reactor vessel level without the full awareness of the operator. An incomplete evaluation of the first event resulted in continued misunderstanding by both management and the operators on the cause of the event. Consequently, the second event was not prevente The root cause involved inadequate procedures, and inadequate operator guidance and training
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concerning the effect of other evolutions, such as head purging, I, on the level indication. This problem resulted in a violation, however, the level reductions did not challenge the operation of the RHR system or cause vessel level to drop to the reduced inventory conditio Responsiveness to NRC initiatives was generally very good. For the most part, the responses were timely, technically sound and
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effective. An example of this was the licensee's response to a problem of operator inattention to detail. Thi s problem, whic was identified in the last assessment period as a weakness requiring management attention, involved events resulting from failure to follow procedures, inadequate . procedures, and personnel errors during outage related situations. With the exception of a number of errors that occurred during the middle of the current assessment period, station management appeared to be effective in instituting corrective actions to reduce events caused by operator inattentiveness. The errors that occurred during this assessment period- involved _ tagging problems and several cases of failure to follow procedures. These errors, which resulted in a violation, occurred within a short time frame and the licensee's problem identification system had already documented the occurrences, grouped them for generic review and was identifying the root cause when the violation was identified. The response to the violation wss comprehensive and involved programs discussed earlier to address the generic issue of personnel error The effectiveness of management corrective action was demon-strated by the completion of the Unit 2 shutdown, refueling outage and startup at the end of the assessment period with very few problems. In addition, Unit I unexpectedly entered a refueling outage which paralleled the Unit 2 outage. The Unit I refueling outage, which was still in progress at the end of the assessment period, had also been conducted with few identified problem Operator response to operational events was very goo The operators properly identified, analyzed and reported the events as demonstrated by the SG tube leak event following the second i Unit I reactor trip. During this event, operator response was
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timely and effectiv The leak was isolated from the environment and the unit was placed in a stable condition in a short period of time. Operator actions were very good, even though both the licensee and the NRC identified that an interface problem existed between the abnormal procedures which addressed the tube leak and the applicable emergency procedure Other events which occurred mostly during the refueling outages were also handled effectively by the operator On several occasions, RHR cooling capability was disrupted by unrelated events. However, in each case, timely operator actions resulted in restoration of RHR cooling without any significant increase in reactor coolant system (RCS) temperatur _ _ _
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-Additional examples exhibiting strengths in this functional: area'
involved management's continued ' support of the control room
- 0 " black j board" concept.which consists' of n_ot. having lit y , annunciators-'on the control . room vertical panel., . and resolution of the steam flow. instrumentation problems. .' Shortly after the -
Unit ~2 restart 1and just. following the T end of ' the assessment period,r the licensee 'successfully achieved a '" black board" i 'the control room of Unit 2. Both units had been~ operating with very few annunciators lit prior to the refueling . outages,. but
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neither had obtained: a' " black board". With' few exceptions,
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Unit 2 is maintaining a " black board" status. With regards to the steam flow instrumentation problems,- the licensee' had-received: a Severity' Level III . violation with. a S100,000. civil penalty during the last assessment period for. starting:up Unit 2 with inoperable! or inaccurate steam flow . instrument Even though the engineering staff initially stated that the'
instrumentation was incapable. of indicating ' accurately at low
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. steam flow rates, the licensee's . site management pursued
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corrective action which resulted in accurate' steam flow indic'ation' over the full range of the steam - flow instrumen-tation. This was demonstrated during the startup of Unit 2 in May of this yea The :overall status of the control room drawings was good,
'however several' problems were identified early in the assessment period concerning the control room and Technical Support . Center (TSC) drawings. These ' problems included inadequate clarity, minor inaccuracies and inadequate controls for updating drawings to reflect station' modifications. Two violations were issued as:
a result of these drawing problems and are discussed further in the Engineering / Technical Support functional area. The licensee addressed the drawing clarity problem by assigning an operations coordinator to review all control room drawings prior to their issuance to the ' control room. As a result, the clarity of control. room drawings'was acceptable. The TSC drawings were not updated on :the same priority as the . control room drawings, resulting in discrepancies between' the two sets of drawing The licensee corrected this situation by issuing a procedure change requiring both TSC and control room drawings to be updated at the same tim Also, the licensee revised their procedural controls' for updating drawings to reflect station modification and identified deficiencies. These new procedural controls required more timely updates of drawings following station- design' changes, but were still weak concerning
, requirements for timeliness of drawing changes resulting from L Engineering Work Requests (EWRs) and identified deficiencies.
, With respect to the fire protection program, a triennal NRC team L inspection of the licensee's configuration management program, as it relates to maintaining Appendix R compliance, was conducted during this assessment period. The results of this NRC . inspection are discussed in the Engineering / Technical Support functional are Other routine inspections revealed that implementation of the site's fire protection program (: ._ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
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continued to function- at a high leve The licensee issued revisions to procedures for _ the administrative control of fire hazards within the plant and for the organization and training of the fire brigade. These procedures were reviewed during the staff inspections and found to meet NRC requirements and
. guideline The staff's inspections also reviewed the licensee's implementation of the fire prevention administrative controls. Administrative controls on work that could result in ignition, and the use and control of combustibles within -
safety-related areas were adequately implemente The required training and drill s for brigade members were conducted within the frequency outlined in plant procedure The training program demonstrated effectiveness based on the satisfact( y performance of the fire brigade in an unannounced drill witnessed by the NRC staff during the assessment perio Four violations were identified during the assessment perio Most of the violations occurred during the middle of the assessment period and very few occurred near the end of the assessment period, indicating an apparently effective management corrective action effor . Performance Rating Category: 1 Recommendations Despite numerous indicators of excellent performance ( reactor trip reduction, good response to operational events, reduction in outage related errors, and well trained and knowledgeable . operators), the Board is concerned about the number of operational errors again relating .to inattention to detai Since these errors occurred, for the most part, during the middle of the assessment period, and management corrective action appeared to be effective in reducing these occurrences, the Board recommends a rating of Category However, the Board also recommends that management's attention continue to be directed toward improvement in the area of operator attention to detail and that the level of NRC staff resources applied to the routine inspection program in this area remain unchange B. Radiological Controls Analysis During this assessment period, there were four radiation protection inspections, two radiological effluent inspections, one confirmatory measurements inspection, and numerous routine resident inspection The licensee's HP, radwaste, and chemistry staffing levels were adequate and compared well to other utilities having a facility
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of'similar size. ' At' the end of this assessment period, alliHP supervisory positions were filled when- the HP. supervisor; y position 'was made permanen The licensee was also attempting
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.to fill:other vacancies in the organization. An adequate number of.. American National Standards Institute ( ANSI) qualified licensee and contract HP technicians were available- to support both routine and outage operation The contract technicians who worked during ' routine operations of the units were used as coordinators of the supplemental contractor . technicians during outages. This effort resulted in an. improved interface between the. technicians and the permanent plant staf The knowledge and experience level of the site HP staff was good. Staff members appeared enthusiastic about'their programs and demonstrated a ' dedication to performing the job well. The-staff had a low turnover rate and an effective training progra HP technicians were provided with approximately 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year of refresher. training, which is above normal for other Region II plant Management' support' and involvement in matters related to radia-tion protection and radioactive waste control were good' as evidenced by their participation on station and corporate As Low As Reasonably ' Achievable- ( ALARA) committee The plant's radiation protection manager received the support . of other management . in implementing the radiation protection progra However, one' area in which there was a lack of effective manage-ment support was: the control of entries into high radiation area During this assessment period, there were numerous incidents involving the failure to comply with TS requirements-for entry into high radiation areas, resulting in the . issuance of a violation. During a management meeting at the end of the assessment period,.the licensee discussed the root cause.of this recurring problem as well as the actions taken to increase the plant staff's awareness of radiological control requirements and to prevent recurrenc A . subsequent inspection showed some improvement in this area, but continued effort is neede The licensee's radiation work permit and respiratory protection programs were satisfactor The licensee improved personnel monitoring capability by installing an adequate number of
" state-of-the-art" whole body frisker Wr. ole body friskers were located at the exits of most of the radiologically controlled areas (RCAs).
In December 1988, the area of the plant controlled as contami-nated was approximately 9,850 ft 2 or about nine percent of the RCA, excluding the containment buildin In comparison, approximately 13% of the RCA was controlled as contaminated at the end of 1987, and this was slightly above other regional plants. At the end of the assessment period, the licensee was maintaining approximately 16,740 ft2 as a contamination control area. The increase was typical for the outage work in progress
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and included temporary work areas. The licensee established a goal of eight percent of the RCA as contaminated for 198 In 1988, the licensee recorded 258 personnel contamination events, of which 61 were skin contam1 nations and 197 were personnel clothing contaminations. From January I to May 31',
1989, the licensee experienced 386 personnel contamination events. The average number of personnel contaminations in 1988 for all Region II reactors was 357. The substantial increase in personnel contaminations can be attributed to the increased work load in contaminated areas during the dual unit outage The 1988 collective radiation dose was 59 person-rem per reactor. The licensee had established a collective dose goal of 65 person-rem per reactor. The goal was set low since there were no outages scheduled for 1988. The licensee's three year (1986-1988) average collective dose was 393 person-rem per reacto This was slightly above the national average of 368 person-rem per pressurized water reactor for the same tima perio From January 1 to May 31, 1989, the collective radiation dose was 602 person-rem per reactor. The licensee's revised 1989 collective dose goal was set at 662 person-rem per reacto The original goal of 497 person-rem per reactor was revised due to the additional scope and unplanned work associated with the simultaneous dual unit outage. Some of the additional scope involved inservice inspections, removal and replacement of SG tube plugs, and removal and replacement of small bore snubbers. The doses were higher than average for Region II PWRs, probably because there was considerable work done in RCA The licensee began development of a plan to upgrade the radiation protection program in 198 In 1985, the licensee formally issued the Radiation Protection Plan (RPP), which established policies and responsibilities for upgrading the radiation protection progra The licensee also issued an implementation plan that established a schedule for upgrades in specified program areas such as external dosimetry, respiratory protection, and ALARA. The implementation plan called for the preparation of more than 200 procedures. A strength was noted during this assessment period in that the licensee had fully implemented the RPP by January 198 The 1988 radioactive effluent release reports for the licensee's facility showed that, with the exception of releases of tritium in liquid effluents, the licensee's gaseous and liquid effluents were lower that the Region II unit averages for 24 operating PWR Liquid tritium releases of approximately 970 curies / year per unit were the highest in Region II and were approximately 2.3 times the Region II unit average. This significant increase in liquid tritium was due to the two simultaneous outages. The effluent -elease data is summarized in the Effluent Release Summary T. 'le found in Section V.I of this repor l
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, TheJ 1988 and previous years' discharges had seen a general s increasing 1 trend in tritium concentrations in Lake Anna :The'
preoperational ' background- tritium- concentration was
. approximate 1y' 300 picocuries (pCi); per liter. In.1988, the
. concentration-was 2000 pCi per liter which 1s still substan-e tially below;the..NRC concentration limit of 3,000,000 pCi per liter and the Environment 1L Protection. Agency drinking water
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limit of 20,000 pCi per liter; The - buildup . of . tritium concentrations in Lake Anna . corresponded with ; the . increased '
tritium releases, however, low water . turnover may . also have affected'.the concentration A radiological confirmatory measurements inspection showed good agreement between NRC and licensee measurements except for minor j
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Four violations.were identified during.the assessment period, d
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l Performance Rating j
' Category: 2 Re' commendations Although there has been some improvement in controls over high radiation area entries and in the number of personnel l contaminations, the Board recommends continued licensee !
management attention in: these area In addition,- although l there'has been'a trend showing. reductions in the~ collective dose ove e the past- several years, the~ Board recommends continued line manigement and worker attention.to controlling _ collective dos C. Maintenance / Surveillance Analysis During the assessment period, maintenance, surveillance, and-chemistry inspections were performed by the resident inspector ,
and regional inspection staffs. Late in the assessment period, !
a MTI was performed'in conjunction with the scheduled SSOMI for design change installation and testing.
I As discussed in the Plant Operations functional area, both units
, had successful operational performance during the assessmen ,
period. part of the credit for this performance must be given -l
.to the maintenance department for the overall good materia condition of the units. However, both of the at power reactor trips were caused by defective components related to the main feedwater regulating valves and the one TS required power reduction was due to a packing leak on a RCS valv The' recent successful restart of Unit 2 following the refueling outage also demonstrated increased emphasis'in the maintenance area concerning the adequacy of the work performed and the
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completion of equipment repairs necessary ' to support unit operatio Unit 2 was started up and brought to 100% power without any required power reductions or reactor trips due to l equipment-failures The RCS leak rate was determined to be very l low and all equipment appeared to operate correctly as demonstrated by Unit 2 achieving a " black board" on the control room annunciator panels.
j Management involvement in assuring quality was generally good, L however, several areas were identified as needing improvements, I including valve packing and equipment failure review. Previous
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assessments identified valve packing leaks as a cor.tinuing.
l problem. The licensee developed a systematic program to replace valve packing with Chesterton live-load packin This program was successful in reducing RCS leakage. However, the packing replacement was not a formal program and the licensee still had not prioritized valves needing preventive repacking, with the exception of those in the containmen This was evident considering the auxiliary building contamination and radio-logical gas problem which plagued the station earlier in this assessment perio Maintenance backlogs were identified as weaknesses during previous assessment peried Management efforts to address these. issues resulted in a reduction in the number of backlog items, and also provided a means of trending, tracking and understanding the actual content and significance of the back-log. The backlog of completed, but not closed items, was significantly reduced, and the licensee consistently met their goal of maintaining the average age of the items less than 30 days. The closing of items was considered important because the work orders were inputted into the computer for use as mainte-nance history information. However, even though the information was available, the licensee rarely used i Thus, equipment failure data was not fully utilized for trending and root cause evaluation Responsiveness to NRC initiatives was generally good, but not always fully and/or successf ully implemente Several items discussed as weaknesses in past assessment periods were only partially addressed during this period. These included a formal check valve PM program, a formal post-maintenance testing program, and the scheduling of testing throughout the refueling outag Development of a formal check valve PM program, which was a corporate commitment, still had not been completed even though the lack of one was identified as a weakness in the last assessment period. The station Maintenance Superintendent did, however, institute an acceptable check valve inspection program pending the development of the corporate progra This responsiveness at the station level was considered to be a strength,thile delayed action at the corporate level was viewed as a weakn;ss.
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i The 1fcensee had not developed a. formal post-maintenance testing j program, but in;the interim used the " post-maintenance follower" '
. form 1 to . track testing - performance. This method was somewhat
- cumbersomeLand, unlike an adequate formal program,~ did not rely J on a programmatic approach .of. ensuring both the adequacy and ' I actual performance of post-maintenance testing. - The MTI portion l of the- SSOMI also identified -that. project engineering was not adequately involved in . establishing post-modification test requirements, and that the site test group was only concerned - j with periodic testing (PT) required during the outage'witNt )
. proper consideration for the modification installation. schedul ;
As .an' example, the licensee typically uses pts _ fo r_ :l l
post-maintenance testing. Review of an Anticipated Transient J Without Scram modification identified two examples whe're a
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scheduled periodic test, taken credit for as the specific post-modification test, was conducted prior to - the installation ;
l of-a modificatio l Numerous testing errors occurred during the 1987 refueling outages which were partially attributed to lack of proper 1 scheduling of ' post-maintenance testing, a weakness identified l during. the last assessment period. This lack of scheduling j resulted in a considerable amount of testing being conducted at i the erd of . the outage, which -significantly increased th activity in the control roo To address this issue, the licensee attempted to develop windows in the outage schedule for-testing purpose For various reasons, one of which was the premature entry of Unit 1 into a parallel refueling outage, these scheduling windows were not effective. To compensate for the increase activity level in .the control room at ther end of the outage, management and the operations staff emphasized the importance of proper testing performance ' and attention to detail, in lieu of schedule performance. This appeared to be effective since no significant operator errors occurre Adequacy of maintenance and surveillance procedures continued to j be a proble Several inspection efforts identified that 4 station procedures lacked detail, especially in the maintenance l area. Although the maintenance staff was found to be well I trained and technically knowledgeable, the lack of procedure )
detail for complex . operations provided the potential for l variation in procedural implementation and prevented accurate -l documentation of the actual steps performe Several i maintenance procedures allowed the use of procedure " write-in" l
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step While this practice appeared to be controlled, some instances were noted where the intent or scope of the procedure was changed by the written-in steps, and that the appropriate management reviews had not been specified or obtained. The use of procedure " write-in" steps can significantly contribute to inconsistent maintenance activities. The concern over the lack of detail in maintenance procedures and the use of " write-in" steps was discussed in the previous assessment perio I o l l
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, Examples ; of maintenance 'an'd surveillance procedures . which,
, because of' their inadequacy,. contributed to significant safety issues an.d enforcement actions were procedures associated with the recirculation spray system, the control room habitability system, theilA system and the engineered safety feature (ESF)
480 volt breakers. The maintenance procedure for work on the -
service water throttle valves . supplying the RSHXs ' did not provide- enough guidance' to ensure that the' correcti throttle setting would - be maintained. This. inadequacy r'esulted in several of the throttle valves being misadjusted'such that the
. required service. water flow would- not be achieved, degrading the recirculation spray system's ability to perform its l intended
, safety function, and resulting in a Severity - Level III violatio No civil penalty was assessed for this violation because credit was. given for identifying and reporting the problem, and ~ taking the necessary corrective actio The maintenance procedures for IA and the 480 volt breakers did not incorporate vendor recommendations, resulting in significantly degraded equipment as noted in a violation in this functional area, and a Severity Level III violation discussed in the ' Safety Assessment / Quality Verification functional area. Also, the lack of post-maintenance testing and the inclusion of non-conservative -TS acceptance testing criteria in testing' the control room habitability. . system ' resulted in the system being outside its TS' requirements and contributed to the same Severity Level III violatio Inadequate procedures in the area of containment integrated leak
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rate testing (Type A) were also identifie Type A test
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problems involved multiple procedure deviations which had the potential to add confusion to an. already complicated tes Procedures' lacked instructions for draining _certain penetrations, the potential existed for errors. in - the test
- results .due to artificially controlling the containment l
temperature, and some repaired leakage on secondary system testing was not being quantified for adjusting the Type A test results on an "as found" condition. In spite of these problems, the Type A test was successfully completed for Unit 2.
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During Type A and containment valve (Type C) testing, some Unit 2 gate and globe valves were inappropriately tested by applying test pressure in a different direction than the valves would be exposed to during an acciden Additionally, an engineering study did not adequately evaluate testing some globe l
valves in the accident direction resulting in a violatio As discussed in the Plant Operations functional area and identified as a weakness in the last assessment period, attention to detail continued to be a concern in the maintenance and surveillance area. Several of the examples associated with a violation discussed in the Plant Operation functional area dealt with' failure to follow procedures, inadequate procedures and personnel errors in the maintenance and surveillance area and also a violation involving fire watch duty. The licensee l
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. initiated extensive corrective actions which appeared effective, as evidenced by the decrease in personnel errors at the end of j the assessment perio j The MTI identified that staffing in the maintenance department, although adequate, appeared thin and may impede implementation
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.j of site program enhancements. This was especially true in the
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mechanical planning, engineering and the post-maintenance ,
testing groups. Limited staffing levels were identified to the licensee as a potential weakness in the past; however, to date, the quality and knowledge level'of the staff compensated for the low numbers,
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This is 'especially true in the post maintenance testing group, where the supervisor was very knowledgeable and capabl The . implementation of the secondary chemistry control progra was successful in maintaining water purity generally within the accepted guidelines, however, this program had minimal success
in slowing the rate of corrosion in the secondary syste Corrosion products, originating from carbon steel pipe and copper alloy feedwater heater tubes, continued to be transported to the SGs of both units. As a result, large amounts of solid corrosion products were removed from the SGs of both units during the 1987 and 1989 outages, with Unit I removal rates being significantly higher than Unit 2 rates. This provided evidence of pipewall thinning and the formation of conditions within the SGs known to be conducive to the corrosion and cracking of SG tube The TS required surveillance program was routinely reviewed by the inspectors. The program was generally conducted in a timely manne There were three exceptions involving missed surveillance which the licensee identified and documented in Licensee Event Reports (LERs) . These missed surveillance did not indicate any programmatic breakdown of the surveillance tracking syste Over the period, the licensee demonstrated an effective inservice inspection (ISI) program. Management involvement in assuring quality was evident in that the ISI program was well-documented, and procedures examined were technically sound and well-written. Another feature of the licensee's program was the requirement that contractor nondestructive examination (NDE)
personnel must demonstrate competence by passing method examination Licensee i r.dividual s contacted and observed during inspections were well-trained and experience Six violations were identified during the assessment perio . Performance Rating Category: 2
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~3 . Recommendations .
Inadequate maintenance and. surveillance procedures and an informal . post-maintenance testing program have combined . to produce several hardware problems during this assessment perio The Board is additionally concerned over the sufficiency of the maintenance staff level to undertake the many site improvement programs in progress or planned. The issues should be addressed by management in an expedited manne D. Emeroency Preparedness Analysis Inspections conducted during this assessment period by resident and regional inspectors included an evaluation of the licensee's response to the generator SG tube leak of February 25, 1989, an ERF appraisal, a routine emergency preparedness inspection, and '
an ERF appraisal follow-up inspectio The annual emergency preparedness exercise performed during this assessment period was not evaluated since an ERF appraisal was conducte During the February 25, 1989 SG tube leak event, the licensee effectively implemented the Emergency Plan. The licensee demonstrated the ability to properly identify and classify the event, to mitigate the carualty, and to make proper notifica-tions to offsite organizations. However, because the event was terminated at the Alert classification, several key elements of the Emergency Plan were not demonstrate . Routine emergency preparedness inspections conducted during this assessment period disclosed that the licensee could adequately identify an emergency, preperly classify it, make appropriate notifications and protective action recommendations, and deal with the casualty, but that there might be a delay in fully staffing the response function to perform these actions. An emergency preparedness inspection conducted during the previous assessment period also identified a potential problem in this area, and the licensee indicated, at that time, that an augmentation drill would be performed at a later date. The augmentation drill had not yet occurred as of August 1988, when the licensee conducted a drill at NRC's reques The August 1988 drill identified two violations; one for failure to use the most recent call list to notify off-duty staff, and the other for failure to demonstrate the capability to meet staffing augmentation requirements for emergency response team personne With regards to the latter violation, the licensee showed, during the drill, that full staffing of the emergency response function would take in excess of the required 30 minutes. As corrective action for the violation, the licensee proposed to review the Emergency Plan to extend the time frame for full staffing of the emergency response functio This proposed revision was under review at the end of the assessment period, The training of the staff in emergency preparedness appeared to be adequate. In walkthroughs, a supervisor correctly classified
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.es, j, all emergency events, provided the appropriate protective action recomm'endations, and' exhibited a good working knowledge' of the h Emergencyi Plan and its procedures. Additionally, a review ' of
selected training records identified ro problems.
L Emergency equipment, instrumentation, and supplies were adequate
..to support a response to events. There were . generally clear-
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L indications of f attention' to the maintenance of an adequate L
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emergency preparedness. program, and the continued provision of
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the emergency. facilities and equipment required to implement an overall effective emergency: program. The ERF appraisal did find areas that n_eeded. improvement. These included the resolution of a differences in > dose calculations between the computerized and manual' methods; -completion of ' evaluating. the validity of using field monitoring data. for calculating source term; modification of the dose calculational model to provide. dose projections at predicted plume positions; and revision of dose' assessment procedures to include separate stability classes for vertical and horizontal diffusion- The licensee's followup to their
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action plans addressing ERF. findings was not prompt; the completion dates were delayed. from February .1989 to July 31, 198 Two violations were identified duriN this assessment perio . performance Rating Category: 2 Recommendations None Security Analysis During - the assessment period, foui routine inspections were performed by the regional inspection staf The physical security functional area evaluates and assesses the adequacy of the security program to provide protection for station vital systems and equipmen To determine the adequacy of the protection provided, specific attention was given to the identification and resolution of technical. issues, responsive-ness to NRC initiatives, enforcement hi sto ry, staffing, effectiveness of training, ar.d qualification. The scope of this assessment included all "sicensee activities associated with access control, physical barriers, detection and assessment, armed response, .ilarm stations, power supply, communications,
. and compensatory neasures for degraded security systems and equipmen During the assessment period, there were no 3 significant breeches of security and no NRC violations or l reportable event _ __ _ --
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. requirements of its NRC approved Physical Security Plan. This
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licensee was somewhat unique in that the site security organi-
{ zation, a proprietary security. force,- reported directly to the
.offsite; corporate Director, of Nuclear Security, and indirectly
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& < 1 interfaced with the' onsite Plant Manager.. While - these two P' management chains provided adequate. daily operational support, bn ,
thei , appeared to be a problem with respect to the long-term
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commitm a t of financial and engineering support to repair or up-
_ grade security detection systems and computerized access control
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system This . observation had been noted in the previous assessment period. The protected area alarm system, previously identified by a licensee consultant as needing improvement, _
remained virtually-unimproved except for one zone. It should be w 'noted that a violation regarding the perimeter alarm' system was L
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issued by the NRC prior to this ' assessment perio Additionally, the NRC was aware that the computerized access-control system had failed 15 times since January 1, 1988,.
causing both. operational and security complication Inspections determined that one cause of the computer failures
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was associated with faulty printer component During the latest' inspection, in May 1989, NRC found that a.new printer ha been onsite since October 1988, awaiting the installation which, most likely, could~ alleviate some of these computer' failure
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occurrence In this regard, the licensee's approach to resolving this technical issue was found lackin The licensee exhibited good judgement in its preparation.for both the flood dam project and the radiation waste building construction with regard to the impact of these efforts on the-security program. Extensive coordination within the plant staff as well as at the corporate level was exhibited for 10 CFR 50.54 submittals for both of these project Additionally, the licensee's responsiveness to several Inspector Followup Items and NRC Notices was indicative of the site security management's commitment to improving the security progra The proprietary security force experienced a minimal turnover rate, overtime was not excessive and the shifts appeared adequately supervised and staffe Procedures were generally clearly written and other documentation was readily available for regulatory tracking purposes. Training and requalification continued to be characterized as being aggressive and contingency tactical drills appeared realistic and thoroug Close liaison with offsite response authorities was also note Regarding audits, the licensee's Corporate Security Department performed. numerous audits of the contractor's screening programs even to include such areas as the administration of psychological test The corporate QA program continued to conduct extensive annual security audits of the site progra Although no major problems or deficiencies were noted, the NRC believed the audit should have identified previously discussed L
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g 4-problems regarding ' plant support 'for upgrading the - secupity system ? A concerted effort.was noted at the corporate and site levels to-
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revise the -applicable. security plans to . improve thei implementation - and at- - the same time reduce extraneous L commitments. The licensee's submittals regarding revisions to l' .
the plant: Physical Security Plan indicated prior planning by utility management. These submittals indicated the existence .of
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well-developed policies .and procedures for - control -of-i: security-related activities.
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$ The ' licensee's ' use of Defensive Positions' (bullet resistant L
towers) assured rapid and accurate ' assessment and resolution of protected area perimeter alarms. . Compensatory measures were almost immediately implemented at the perimeter barrier through the use of cfficers in the Defensive Position No violations or deviations were identifie . ' Performance Rating I Category: 2
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! Recommendations
.The Board considers this functional. area a high ~ Category 2.
- Prompt management initiative. to upgrade / repair the security l- . detection system and access control system is needed to further enhance this functional are ~ Engineering / Technical Support l' ' Analysis The Engineering / Technical Support . functional area addresses the
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adequacy of technical and. engineering support for all plant activities. . To determine the adequacy of the support provided, specific attention was given to the identification and
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resolution of . technical issues,. responsiveness to NRC initiatives, enforcement history, staffing, effectiveness of training and operator qualificatio It includes: licensee activities associated with-. plant' modifications, technical-support provided for operations, maintenance, testing' and ; ,
surveillance, training and configuration managemen This I
evaluation is based .on routine' and special inspections, including the SSOMI and a Triennial Postfire Safe Shutdown inspection, conducted by the NRC in this area and related functional area When significant events occurred that impacted power generation related issues, adequate technical resources were applied. An
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example was the timely and comprehensive response to the Unit 1 SG tube leak. Engineering response to reportable LER issues provided further examples of the staff's technical capabilit It was not strongly evident, however, that these technical resources were focused on issues to increase component and system reliability. The lack of effective implementation of the root cause analysis program, discussed in the Safety Assessment /
Quality Verification section of this report, represented a specific example of engineering's less than aggressive proactive-performanc Engineering response regarding a long standing operational technical issue, the check valve PM program, indicated a lack of responsiveness to non power generation issues as well as poor proactive performanc There were examples of deficient performance by the engineering organization identified during the assessment period. A 4.16 KV vital bus breaker was not coordinated with its two downstream 480 volt load center breakers and could have resulted in a loss of one complete safety division. An improperly dispositioned quality control inspection report involving routing of non-seismic conduit over station batteries indicated weakness with the review process in the engineering organization. An incorrect spent fuel map provided to the site by engineering resulted in an attempt to load a 1ew fuel assembly into a loaded spent fuel rack. Staf f evaluation of the IA and control room habitability issues were untimely and weak. Additionally there were deficient engineering analyses on several operational issue For example, the analysis which determined that the auxiliary feedwater pump recirculation flow was adequate to prevent pump degradation was not entirely correc Overhaul of the pumps indicated that significant degradation had taken place over a long period of time and a primary cause was operation of the pumps with inadequate recirculation flow. An analysis determined that RSHX service water flows were meeting design requirements, however, actual testing performed a year later identified this was incorrect. In fact, several heat exchangers
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demonstrated flow rates below the design flo An analysis accepting wet lay-up conditions for the RSHXs was incorrect. It was later determined that wet lay-up conditions potentially prevented the heat exchangers from providing their design basis heat transfer capabilit Staff evtluation of the reactor coolant system hot leg vent path in response to Generic Letter (GL) 88-17 was another deficient evaluation of operational issues. This evaluation did not compensate for the reduction of l the vent path size attributable to the foreign material
, exclusion screen. An engineering study did not adequately l
evaluate testing of containment globe valves in the accident direction resulting in a violation. TMse examples indicated a pattern of engineering evaluations not addressing the full scope of an issue.
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L .Thef design development activity of ~ the- engineering. staff was L found to be goo The . corporate engineering staff was p technically knowledgeable and procedures governing control of o
design development _were good. Also, modifications were detailed ~
by comprehensive' design requirements. The licensee initiated, Design. Basis ' Documentation Program lwhich will' enhance future
' design development activities. However, the Instrumentation and
' Controls design group demonstrated a lach of. familiarity with calculations, assumptions, and analyses contained in the' design
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change ' packages . (DCP). In addition, . an excessive number of -
field _ change requests and revisions to design change packages
~was L noted on design change packages prepared prior' tog this '
l assessment perio This volume -indicated that' pre-design L engineering . reviews and system walkdowns were not fully-effective during that time fram The limited ' number .of modifications prepared during .this assessment period demonstrated'a reduction in field changes and revision Other. than'a singular instance of a contractor-prepared design package failing to fully address Appendix R issues, whic resulted in a violation, there was an otherwise high level of awareness to Appendix R issues by the design organization. Forf example, a Triennial Postfire Safe Shutdown' inspection revealed that the licensee's management made a strong commitment to
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. ensure long-term compliance with Appendix R by requiring detailed reviews of the impact of design changes on Appendix R, developing an Appendix R checklist for use in reviewing design changes and EWRs, and the good quality of engineering-evaluations in documenting acceptability of deviations from fire protection related code Post-modification testing and design veri fication . weaknesse s have been identified during this assessment period. DCPs did not consistently prescribe post-modification testing to demon-strate that a system continued to meet its design basis function following modificatio An example of failure to perform adequate design verification resulted in inappropriately sized service water system motor operated valves due to operating pressure being utilized to select motor operated valve size H- . rather than system shut-of f head. A DCP to provide positive valve indication for pressurizer spray valves was. incorrectly implemente Post-modification testing did not ensure that limit switch settings accurately reflected associated valve positio Post-modification testing had been identified as a weakness in the previous assessment period. Although licensee f actions resulted in improvement during this period, these L actions have not been fully effectiv Weaknesses were noted in technical support performance related to drawing control, plant procedure quality, and interpretation of radiographs. Administrative deficiencies were identified in the redlining and updating of control room and technical l- drawing A violation issued during this assessment period identified that the design change implementation process did not L== - _: ._ - _ _ _
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. insure timely -incorporation. of modifications into as-built system drawing Although a procedure update group was
- established to resolve a general plant procedures weakness identified in the previous assessment perii", ' procedure quality
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continued to, be inconsisten The backlog of L procedures' for review-land the number of' procedure deviations initiated indicated ' that . this update group's activity was not -fully effective. An error in the evaluation of feedwater- system radiographs was not identi fied . by subsequent reviews of the'
c.- -radiographs by the technical staf Several, examples of strengths related to resolution of technical issues involved operator trainin To address problem associated with unit'startup and shutdown evolutions, which were identified as a weakness -in the previous assessment, the licensee conducted . simulator and classroom training o associated procedures and evolution This training - was conducte'd just prior to the evolutions and was effective because-the Unit 2. shutdown and startup were conducted without any major perturbations. Training conducted for the loss of .RHR event described in GL 88-17 was also a' strengt Operator. training continued to be very. effective as demonstrated by the ~very good operator response to station events, and the overall good operator performance during power and outage situation The licensee had previously received full INPO~
accreditation for all of their training programs and just recently received a renewal _ of that accreditatio One replacement examination was administered during the assessment period with 2 SRO and 8 RO candidates participating, resulting in a 100 percent passing rate. The quality of the reference material submitted for exam preparation was exemplar Seven violations were identifie . Performance Rating Category: 2 Recommendations Important products of the engineering and technical support organizations are control room drawings, operational evaluations, procedures, and post-modification testing. During this assessment period, weaknesses were observed in all of these area The procedure upgrade group, established after deficiencies were noted in the previous assessment period, has not yet been sufficiently effective in addressing the backlog of procedures for revie Also, it appears that' the licensee's staff has not been aggressive or proactive in enhancing overall plant performance, indicating that the engineering and technical support organization is either not being effectively utilized and/or is understaffed. Based on these observations, the Board
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considers; this area ' to be . a low Category 2 and recommends
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increased management attention to this functional are G. Safecy Assessment / Quality Verification
' Analysis
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.During'the assessment period, routine inspections were performed'
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involving the.. review 'of various ' ' engineering evaluations,
-justifications- for continued operation (JCOs), and 10 CFR 50.59-safety evaluation In addition,- evaluations of licensing activities were conducted,. and inspections of the licensee's on-site safety committee functions, nuclear - safety engineering, and the corporate offsite independent review group. functions were performe Within this functional area a number of strengths and weaknesses were observed. The strengths dealt mainly with programs
= initiated by the station management, while the weaknesses concerned the1 timeliness of corrective action and the lack of
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safety assessment capability within corporate managemen Near the beginning of the assessment period, a violation'was identified concerning the licensee's inability to review and -
- properly evaluate industry operating experience. The particular-item involved the inadequate evaluation of an NRC Information Notice' and industry information, which led to the inoperability L .of both emergency diesel generators for one of the units. The subsequent response to the violation placed the responsibilit for initial review of industry experience on a corporate review group. This particular group changed management organization affiliation. at least once during the assessment period, at times, with a considerable reduction in the group's resources. Consequently, the group was not yet fully developed and its l
actual effectiveness had not been realized. This delay in the full development of the program indicated a lack of management
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oversight and suppor On the other hand, the station's Nuclear Safety Engineering (NSE) group was performing an adequate job of reviewing industry experience items even though the group was understaffed. This review effort compensated somewhat for the problems concerning the development of the corporate review group. An asset to the corporate operating experience review group was its superviso This individual had an SRO license, and had spent considerable time at the site and INPO, The lack of an effective root cause program was identified as a weakness during the last assessment period. The licensee established a root cause program; however, most of the personnel training on root cause analysis was not conducted until the end of the assessment period, indicating the program was not receiving a high priorit An example of the lack of a root cause analysis involved the Unit I condenser air ejector (CAE)
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radiation monitor. This' monitor failed during the 1987 SG'. tube rupture event, -removing an . important accident diagnostic tool normally available to the operator Because the licensee failed to properly Ldetermine the. root cause, the monitor again failed during the .1989 SG tube leak event. . Similar to root cause analysis, . the failure of the licensee to take prompt and
, adecuate corrective was :also identified as a weaknes Violations for lack of prompt cot rective action were issued for i
the CAE problem discussed above .and~ also for degraded IA and control . room habitabi;ity system The . latter violation was i.ss'ued at ' a. Severity Level III with ' a 525,000 civil penalt Additional examples of a lack of. root'~cause analysis and prompt corrective action on long-term problems ' included the periodic stickirg of the reactor protection system and engineered safety, features K600 relays, the setpoint drift problem associated with-
~
the SG and pressurizer code safeties, the.. continued inoperability of the lake discharge radiation monitor and other process radiation monitors, continued problems with the waste gas hydrogen / oxygen monitor, and Type. C valve leakage failure Several of. these .long-standing problems were discussed in the last assessment repor Al strength was identified concerning station management's newly developed self assessment and startup assessment programs. The licensee assembled all of the information generated in- the
. station that provided some type of assessment of a particular area, and evaluated the information to determine strengths,
< weaknesses, or adverse trends in a particular functional are The first self assessments were performed using functional areas similar to the NRC SALP reports. Along. with the self-assessment, the licensee also conducted a startup assessment prior to the Unit 2 restart following the refueling
' outag The superintendents of each department compiled L
information concerning their accomplishments, 'and listed items
/ or. problems that had not or > ere not going to be completed or resolved prior. to the restart . This information was presented i to station management for.thei review, comments, questions and eventual concurrence that the unit was ready for startup. The l startup assessment program was an outstanding method for station I
management to make an informed and objective decision concerning
.the restart of a unit. Station management also directed that self assessment capability be developed in the maintenance department. Some of this was completed based on the most recent f licensee startup assessment and self assessment repor However,- as identified in the licensee's own report, adequate capability for assessing rework, repeating failures and determining adequate root cause had not been fully develope The station continued to have an excellent problem identifica-tion program, which consisted of generating deviation reports for deficient condition This program has a very low threshold, which ensured that the majority of the significant items were presented for. management review. During the assessment period, the NSE group developed a tracking and
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trending program for the deviation. reports, continued ~to monitor 13 the nuclear plant reliability data system (NPRDS), and continued to support the HPES. With these assessment tools, NSE was 'able to provide station management with valuable.self assessment and l root cause information. However, the overall ' effectiveness' of i> the NSE group was limited by inadequate staffing levels. ~0ne-E compensatory factor was the choice of thel NSE' supervisor. This individual has had an SRO license and considerable station operating experience ..providing him with the- necessary background to establish an effective grou The' QA organization also made changes which should help station management ' identify potential problems or adverse trends. One
~o f the major changes involved ' the commencement of performance based inspections. The . licensee contracted with outside personnel to- train QA inspectors in the conduct of performance based inspections. QA also developed check sheets with weighted questions and observations to assess areas such as operations, maintenance, etc. These sheets assisted- the QA inspector in rating the area inspecte 'The licensee developed a practice of preparing a JC0 for any item or concern which potentially dealt with an operability issue. Numerous JCOs were reviewed by the NRC, and for the most part, were considered to have been properly evaluated.- This practice of performing JCOs was considered to be a strength because it documented how a decision was' made, and generally generated more questions than normal.if a JC0 was not performe Along with the JC0 reviews, the licensee upgraded their 10 CFR 50.59 review process. The procedure governing the process was changed to be more prescriptive and to provide additional training requirements for persons conducting safety evaluations. The NSE group maintained an index of all safety evaluations initiated, and each evaluation was assigned - an identification number. Consequently, the annual' report to the NRC listing the safety evaluations conducted in the last year was more accurat Sevoral of the 10 CFR 50.59 safety evaluations were reviewed during the assessment period and, for the most part, were determined to be adequate. However, the SSOMI team identified examples which ir.dicated that the licensee may not completely understand the requirements for the performance of safety evaluations. First, for a modification associated with the removal of a block wall around the iodine filter unit, the safety evaluation failed to address the effect of radiation on personnel and equipmen Second, for modifications regarding the addition of a dies.el-driven air compressor and air dryer, the safety evaluation inappropriately reasoned that, since no safety-related equipment was involved, no unreviewed safety question could exis Finally, a quality control inspection report (QCIR) was inappropriately dispositioned, accepting the disabling of one vital power channel resulting from the interaction with a non-seismic condui A properly performed
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'gg safety evaluation sho'uld: have identified the' QCIR disposition
, ,' error.
[ A weakness identified during the ' assessment period involved the discovery that the licensee's offsite independent review group wa s . to a large extent', not' meeting, its TS . required review responsibilities. Also identified was an attitude exhibited b ;the licensee'that even though the intent of TS~was.not being .
met, they believed that the letter of.TS was being met. In this case, neither letter nor: intent were met. This ' compliance
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attitude' contributed to an identified TS violation against.the
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independent review group's activitie The main purpose of the independent review group is to. perform reviews' of specific station activities and provide ' feedback on L station, performance to. corporate management. This ' feedback, if
' properly implemented, would provide corporate management .with information necessary to assess the . station manageme'nt's:
capabilities in. conducting proper safety evaluations,. procedural-
, changes, 2 plant modifications, evaluations of abnormal operations, TS changes, determination of- reportableu events, L safety committee. performance and quality assurance . department performance. The compliance attitude discussed above, and
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resultant failure of the independent review group to perform the majority of the required ' reviews severely limited , the ~ safet assessment .information available ;to corporate management, resulting in a reduction in management's ability to properly.
E assess station performanc In the area of licensing activities, the licenset demonstrated adequate management involvement and contro Particularly noteworthy during this assessnent period was' the licensee's response to the new technical . issues and resolution of the SG tube leak event of February ~ 25, 1989. The licensee's response to this event was considered very effective by the NRR technical staff. The licensee's management actively pursued an aggressive and continuous upgrade of the TS for continuity and similarit This effort was substantiated by ' the number of TS changes submitted on a continuing basis by the licensee. It is noted that the licensee's management has in the past and for the current assessment period actively supported licensing issues and resolutions which have been first-of .a-kind. A case in point was the licensee's' submittal addressing the SG tube leak even The licensee diligently kept the staff advised of its ongoing investigation of the failure mechanism of the tube lea In addition, the licensee's assessment of the failure mechanism was accurately evaluated and corrective actions implemented well in advance of the staff's issuance of GL 89-01 on May 15, 198 However, several exceptions to the above comments were noted during this assessment period. One example was the licensee's submittal for a change to TS 3.7.12 regarding differential settlement monitoring points and the main steam valve hous Well into the staff's review of this matter, the licensee
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. notified the staff. that the' issue .was primarily a case of correctly . identi fying and. implementing proper surveying
. procedures and ~ techniques. Subsequently, the licensee
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identified other settlement points that could' exceed TS limits and indicated the need for. possible discretionary enforcemen However, theJ staff determined that the : proper procedures identified previously by the licensee had not been implemented
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on these other settlement points, which would 'have eliminated -
erratic settlement point dataL and the possibility .of exceedin .TS limits. Another example was a licensee submittal providing a basis for not requiring on-line testing. of the Unit 2.ESF slave relays. as required by .TS. .The issue was identified by the-l ~ licensee in an LER in . December 1988, which noted that - the' testing was required to be completed by June 11, 198 . Subsequently, an. untimely , licensee ~ submittal on the issue in
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'May 1989 required discretionary enforcement in June 1989. It is believed. that a loss: of licensing ~ personnel at the licensee's corporate office. mid-way into the assessment period affected consistency in.. following through on licensing ~ actions. Since.
, then, the licensee augmented its corporate -licensing ~ personnel by reassignments'or the use of_contrcctor personne ~
I Based upon: review of two requests for TS changes regarding. leak testing of containment isolation valves and increasing heat flux hot channel factor limit for an increase in SG tube plugging, the licensee's submittals were found to be complete and required no follow-up. In the case of leak testing, the licensee was aware 'of potential problem areas, demonstrated sound knowledge of the technical' issues involved, and proposed an acceptable-testing program. In the case of requested increases.to limits, the licensee's submittal was thoroughly prepared using approved analytical techniques. Additionally, the submittal 'asw provide .about six months before the required approval date, allowing ample -time for NRC staff revie This early- submission indicated proper planning and control by the licensee.
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Four violations were identified during the assessment perio . performance Rating Category: 2 Recommendations None
.V; SUPPORTING DATA Investigation Review Non =_ .- . _ _ _ _ _
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18. Escalated Enforcement Action- Violations
~ Severity Level 'III violation issued on April 21, 1989, for
- failure.to take prompt corrective action.with regard to. control room' habitability ~ concerns and IA system' degradatio ($25,000 CP)
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Severity Level III-violation issued on July 5, 1989, for failure-y to, maintain operability.of the RSHX's,'as required by TS, due to
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", incorrect setting of the service water throttle valve (No CP was issued)
n i Orders None C. Management Conferences- ' June 8, 1988- Technical meeting at Region II related to performance problems with RSHX' . July 6,-1988 Enforcement Conference at Region II to discuss emergency diesel generator operability issue . January 18, 1989 Enforcement: Conference at Region II. to discuss corrective action on several control re m habitability deficiencie . February 7, 1989 Enforcement ' Conference at . Region II to discuss IA problems as they relate to design-control and corrective actio . February 22,.1989 Technical meeting / tour at North. Anna Power Station in order 1 to observe appropriate-structures associated with the main steam valve house and settlement issue, March 29, 1989 Technical meeting at' NRC Headquarters, 'to
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p discuss the 02/25/89 : Unit 1 SG tube leak event.. remedial actions and recovery. plans for Units 1 and . April 26, 1969 Management mer cing at Region II- to discuss issues related to the findings of RCA access l- and subsequent corrective actions.
l May 24, 1989 Enforcement Conference at Region II to discuss issues related to the service water system heat transfer capability and reactor inventory perturbation l_________-_____-_____-_-_____--____---___----____--__---_----__----___---
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O. Confirmation of Action Letters None E. Review of Licensee Event Reports (LERs)
During the assessment period, 23 LERs for Unit 1 and 2 were analyze The distribution of these events by'cause, as determined by the NRC staff, was as follows:
Cause Unit 1 Unit 2 Total Component Failure 2 1 3 Design 2 0 2 Construction, Fabrication, 1 0 1 or Installation Personnel
- Operating Activity 0 1 1
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Maintenance Activity 4 2 6
- Test / Calibration Activity 5 2 7
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Other 2 0 2 Other 0 1 1 Total 16 7 23 F. Licensing Activities In support of the licensing activities, frequent meetings were held with the licensee to address licensing and other technical issue During the evaluation period, the staff completed review of 41 licensing actions which resulted in closecut of 21 amendments, 4 reliefs, 4 exemptions,10 Multi-Plant Actions and 2 other action In addition, significant effort was expended on 23 other issues which were not completed but served to provide considerable insight to licensee performance in this are G. Enforcement Activity NO. OF DEVIATIONS AND VIOLATIONS IN EACH FUNCTIONAL SEVERITY LE>EL AREA De V IV III II I Plant Operations 0 1 3 0 0 0 Radiological Controls 0 1 3 0 0 0 Maintenance / Surveillance 0 1 5 1 0 0 Emergency Preparedness 0 1 1 0 0 0 Security 0 0 0 0 0 0 Engineering / Technical Support 1 2 5 0 0 0 Safety Assessment / Quality Verification 0 0 3 1 0 0 TOTAL 1 s 20 2 0 0 i
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y o H.- ' Reactor-Trips
. Unit 1 During the assessment period, Unit 1 experienced two automatic, at abcritical reactor
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, - power, reactor trip There wereino manual .
trips and there were no shutdowns due to TS requirements.
L, l -: August 6, 1988 -1 Unit. I tripped from 100% power. due to a steam 1 ,
flow / feed. flow mismatch coincident with a low SG water level. The
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cause of-the trip. . involved the failure of the' automatic tap changer on .the reserve station service transformer. to function properly in conjunction with a mechanical failure on a main feedwater regulating valve.
l February - 25, 1989 - Unit I tripped from. 76% power due to a steam flow / feed flow. mismatch coincident with a low SG water level. The cause1of the- trip involved the-_ failure of an air line to a' main feedwater regulating valve 'resulting;in the valve failing close Subsequent to.the trip the unit experienced a major SG tube lea Unit 2'
During the assessment period . Unit 2 did not experience any.at power automatic or manual reactor trips. However, the unit did experience, a subcritical automatic reactor trip. There were no shutdowns due to TS requirement May 2, 1989 - Unit 2 experienced an unexpected automatic reactor trip
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signal with the unit in Mode 5 (cold shutdown) and all the control rods fully inserte The cause of the trip was an inadequate feedwater flow instrument (protection channel) calibration procedure.
, Effluent Release Summary Unit Releases C1/Yr*
1986 1987 1988 RII Average / Unit, Ci/Yr (1988)
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Noble Gases 2.85E+03 5.25E+02 2.41E+02 2.36E+03
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Iodines and 1.16E-02 8.65E-03 9.35E-04 1.20E-02 Particulate (Aerosols)
. Tritium (Gasesous) 3.65E+01 8.65E+00 4.72E+01 4.96E+01 Mixed Fission 4.71E-01 6.50E-01 2.16E-01 8.1E-01 and Activation Products (Liquid)
. Tritium (Liquid) 9.81E+02 4.18E+02 9.70E+02 4.21E+02
- Releases shown are for each uni For total site releases, multiply each value.by tw _ . _ _ _ _ _ _ _ _