IR 05000338/1990022
| ML20058E930 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/23/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058E928 | List: |
| References | |
| 50-338-90-22, 50-339-90-22, NUDOCS 9011080029 | |
| Download: ML20058E930 (26) | |
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i ENCLOSURE SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION 11 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-338,339/90-22 VIRGIkIA ELECTRIC AND POWER COMPANY NORTH ANNA UNITS 1 AND 2
JUNE 1, 1989 THROUGH AUGUST.31, 1990 t
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90110B0029 901023 PDR ADOCK 05000330
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SUMMARY OF RESUl.TS The overall performance of North Anna improved significantly during the assessment period.
Plant Operations activities continued to be conducted in a superior manner and Emergency Preparedness, Engineering / Technical j
Support, and Safety Assessment / Quality Verification improved significantly
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from-the last assessment period.
The Radiological' Controls and Mainte-nance / Surveillance areas did not exhibit significant improvement, and performance in the Security functional grea decreased somewhat.
Site management awareness and involvement in daily activities and operator knowledge and sensitivity contributed heavily to the continued high performance level in -the Plant Operations functional area. An innovative computer-based system to assist the operators and a record operating run for Unit 2 also strongly influenced performance in this area.
The 1990 exercises demonstrated significant improvement in-the Emergency Prepared-ness (EP) area.
This exercise revealed not only that the emergency plan would. function effectively, if needed, but also that the licensee's EP corrective actior program was functioning in an effective and timely manner. Engineering / Technical Support performance demonstrated an overall improvement during the period.- The Configuration Management / Design Basis Documentation (DBD) Program and improvements in system engineering (SE)
were examples of good perfonnance.
Some engineering performance problems, though,. revealed activities that would -benefit from increased attention.
improvement was also made in the Safety Assessment / Quality Verification area.
The licensee's sensitivity to nuclear safety, identification of deficiencies, and. effective root ceuse evaluations contributed to improvement in this and the other functional areas which improved.
The licensee's involvement in station licensing activities was also a-strength.
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Although significan_t effort was expended to improve performance in the area of Radiological -Controls, the :results were ' inconsistent..
l-Contaminated areas continued to decrease, but clean. area personnel-contaminations continued to be a problem.
Source term reduction continued
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to be pursued aggressively but elimination of a primary dose source, the
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reactor coolant system (RCS) resistance temperature detector (RTD) bypass y
lines, was delayed.
.This problem and extensive outage activities contributed to a high collective dose. The Maintenance / Surveillance area improved, but not substantially, during the assessment' period.
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corrective maintenance backlog was maintained Iow and the preventive maintenance (PM) program was conducted without-deferrals. Several instances -of missed surveillances, continued problems with maintenance procedure adequacy, inadvertent equipment actuation from personnel inattention to detail, maintenance planning problems, and vendor manual usage problems, offset the improvements made in this area.
Performance in the Security area was satisfactory during the assessment period, but declined from the last' period.
Improvements in hardware and equipment from the last period were offset by several licensee-identified
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security violations and a problem with followup of a drug issue at the site.
Overview:
i Performance ratings for the last assessment period and the current period are shown below:
Rating Last Rating This Functional Area Period Period Plant Operations
1 Radiological Controls
2 l
Maintenance / Surveillance
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Security
2 l
Engineering / Technical Support
1 Safety Assessment /
1 Quality Verification Ill. CRITERIA The evaluation criteria which were used, 'as applicable, to assess each l
p functional area are described in detail in NRC Manual Chapter 0516. This L
Chapter is in the Public Document Room files.
Therefore, these criteria
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are not repeated here, but will be discussed in detail at the public meeting held with the licensee management on November 7,1990. However, the NRC-is _not limited to these criteria and others may have been used.
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IV. PERFORMANCE ANALYSIS
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l A.
Plant Operations 1.
Analysis l
This functional area addresses the control and performance of activities directly related to operating the units, as well as fire protection, as reviewed-during routine inspections conducted during the assessment
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Perfonnance in this functional area was superior. Significant progress was made in this area identified during the last assessment period and needed improvement.
Several programs and philosophies such as coaching,
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self-checking and check operator contributed to a reduction in personnel errors and attention to detail problems.
Some of these-programs were implemented in previous assessment periods but continued to contribute to effective operations.
The overall performance of the units was excellent, characterized by long runs and few teactor trips.
Unit 1 started the assessment period in a refueling outage.
During the period, Unit I experienced three reactor trips at power.
All three trips were maintenance-related.
Two of the
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trips were a result of turbine electro-hydraulic control (EHC) maintenance problems and the third trip was caused by the failure of a driver card for the main feedwater regulating valve. This maintenance-related trip problem continued from the previous assessment period in that, of the three reactor trips on Unit 1 during the last assessment period, two were
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- equipment problem related.
At the end of the assessment period, Unit I had operated continuously for 219 days at power.
Unit 2 continued to operate in an outstanding manner, starting the assessment period at 100%
power..The unit set a Westinghouse continuous online run record of 469 days.
Unit 2 also exceeded four years without an at-power reactor trip.
Unit 2 completed the assessment period in a refueling outage, which was begun approximately)two and a half weeks early due to primary-to-secondary steamgenerator(SG tube leakage problems.
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Station housekeeping and control room decorum continued to be strengths.
Station management's high standards were reflected in the highly success-ful. station painting program, which was extended during this period into the safeguards and quench spray buildings and the charging pump cubicles.-
This, along with significant reductions in auxiliary building contaminated areas, contributed to increased pride and professionalism on the part of station. personnel.
The shif t composition continued to exceed the Technical Specifications staffing requirements, in addition, the station manager and the two I
assistant manager positions, the majority of superintendent level positions and some of. the supervisory level positions were filled with persons who either hold or held senior reactor operator licenses.
Station management maint'ined a high degree-of awareness and involvement a
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Contributing factors included a
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detailed daily plant status, report summarizing limiting conditions for l
operations, significant events,; equipment problems and indicators, a recorded phone sumary of plant status, and the use of modems to access
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- plant-operating parameters from offsite. An additional example of manage-ment's comitment to operations involved'the development of a computer for L
use by the control. room operators.
The program allows the operator to L
imediately obtain' annunciator response procedures, equipment status,
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emergency action levels, Technical Specifications or trend plant equipment l
operating parameters.
In addition, this system can provide on-demand '
equipment out-of-specification data for the operators. Effective mrnage-mentL controls were also noted with the licensee's startup assessment to:
support unit restart following-an outage.
Policies were clearly i
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communicated and personnel were held accountable for actions.
L Corporate. management typically exercised good ' judgement and conservatism
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when. dealing with nuclear safety.
One example included a decision by-management to reduce power and eventually shut down a unit when evidence indicated that a primary-to-secondary SG tube leak was increasing, even s
though the leak rate was significantly below that allowed by Technical Specifications. The decision was particularly noteworthy considering that the unit was only eight days from the world's record for a light water
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reactor continuous online performance. A second example of good judgement and connunication involved a response following a partial loss of offsite power and reliance on the emergency diesel generator to supply power for an extended time.
Actions included dedicated operators and mechanics to monitor diesel perfonnance and elimination of activities which could perturb the system.
One decision, though, to continue operation with a degraded turbine EHC system, contributed to a subsequent automatic trip.
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Operator performance during the assessment period continued to improve an'd generally demonstretad professionalism and. sensitivity to events.
Both-unit: continued to achieve " black boards" (no annunciators lit) on a rou te basis.
Any annunciator which could not innediately be corrected, received prompt attention.
The " black board" concept was considered i
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effective because operators gave full attention to abnormal conditions and were not unnecessarily distracted by nuisance alarms.
Daily duties were observed to be carried out in a professional manner.
Operators demonstrated excellent knowledge of unit operations as indicated by very few problems during startups and shutdowns.
Several examples of excellent response to events were noted.
In one case, actions following a loss of-power to the process control cabinet averted a potential reactor trip. A second example involved the quick detection and correction of a reactor coolant-shift from the reactor vessel to the pressurizer, while shut down.
due to air intrusion from Type C penetration testing.
The operators were sensitive to RCS draindown and reduced inventory evolutions.
Another
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L example of. operator sensitivity occurred when an - operating shift identified during the prejob briefing that the planning phase.of draindown
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was def.icient in that previously Wntified procedural problems had not
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been corrected. Although attention-co-detail errors were reduced, failure to foHow -procedures resulted in two containment recirculation spray subsistems being inoperable' simultaneously and resulted in a violation. A combination of operator error and a procedural inadequacy resulted in a failure to align the fuel building' ventilation system through the charcoal t
L filters during fuel movement.
1he emergency operating procedures (EOPs) were adequate to cover the broad range of accidents and equipment failures necessary for safe shutdown of the plant, but contained numerous. deficiencies.
A significant number of these deficiencies, identified by an NRC E0P inspection, were. similar to findings < identified. by the licensee shortly before the NRC inspection.
Also, many of the licensee's abnormal operating procedures were weak.
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some cases the procedures were incomplete, lacked guidance and conflicted
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L with the E0Ps. Although the procedures.had problems, operators were aware L
of the proper action to take.. Specifically, during two actual events
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involving loss' of electrical power, operators correctly relied ~ on electrical load lists to restore power to equipment in spite of inadequate
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procedural. guidance.
At the end of the assessment period, the licensee was addressing the problem and committed to periodic audits of the E0Ps-by Corporate Nuclear Safety (CNS).
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Numerous problems with the instrument air system were identified during the last assessment period.
While problems continued to occur early in this period, the installation and operation of a new instrument and service air system, late in the period, essentially resolved this issue.
One violation was identified for failure to maintain containment irtegrity when the equipment hatch escape door had been breached.
This issue was an isolated event and not symptomatic of any programmatic weakness,
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t The licensee's fire protection program continued to be effective.
Strengths identified included staffing in the fire protection group and the licensee's program for controlling movement of transient combustibles, which ensuies fire safety in the plant.
- Two violations were identified during the assessment period.
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Performance Rating Category:
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Board Recommendations None B.
Radiological Controls 1.
Analysis
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This' functional area addresses those activities directly related to radiological controls and-primary / secondary ' chemistry control, as reviewed during routine inspections conducted-throughout the assessment period.
Staffing levels in these areas were appropriate and the groups experienced-a low-turnover rate.
The licensee's -three-year average for collective radiation dose per unit for 1987 through 1989 was 518 person-rem with a collective radiation dose of 736 person-rem per unit experienced in 1989.
In 1989, the licensee experienced two planned refueling / maintenance outages and one unplanned forced outage for a total of 175 days.
The first. planned outage resulted in 678 person-rem. - The second planned outage,. entered earlier than scheduled due to a-failed SG tube mechanical plug, resulted in the expenditure of 799 person-rem. The unplanned outage expended 34 person-rem.
The high collective doses were attributable to the two planned outages, overruns in these outages and high radiation-levels in the ' areas where a significant amount of the work was performed.
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The licensee continued to reduce contaminated square footage of the radiologically controlled area (RCA) of ~ the auxiliary building.
The
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contaminated area of the -96,000 square feet RCA was reduced from 13,200
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f tr in 1987 to 9,800 f te in 1988.
In 1989 the contaminated area.was reduced to 6,700 ft2 and further reduced to 5,300 ftr at the end of the assessment period.
As the contaminated area of the plant.has been reduced, personnel contamination events (PCE) have also declined.
However, the licensee-perfomed assessments indicated that a significant number of PCEs continued to occur in designated clean areas of the RCA.
Problems responsible for the high number of PCEs were identified and management attention given to assure PCEs were further reduced.
While several ' effective dose reduction measures and practices have been implemented, such as-a reactor head shield, a valve packing extraction
tool, digital alarming dosimeters to increase dose awareness, hot spot flushing, shielded SG manway doors, and an enhanced Cobalt Filtration Program; collective dose at North Anna was high. Use of the reactor head shield was postulated by the licensee to save 50-60 percent of the dose during reactor head operations, and a savings of 262 person-rem was postulated as a-result of hot spot flushes. Use of the packing extractor tool reduced packing removal from valves from two to four hours to 20 minutes, depending on location.
In addition, significant dose savings
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were realized from the use of temporary lead shielding.
The= licensee's ALARA group presented data which showed that from 1985 through 1989, dose
. from work in the vicinity of the RCS RTD. bypass manifold area was-responsible for '21 percent of total annual station dose; and that replacement could result in a savings of dose on the order of 50 percent
'in the vicinity of the loop rooms and pump cubicles. This is significant considering that in 1989, 40 percent of total outage dose was attributed to SG work.
Other chronic' contributors to station dose were: excessive dose to ' manually recove sludge from the reactor cavity because,the
transfer canal drainline is located four inches above the floor, health
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pnysics coverage of SG eddy current operations from the inside of the SG cubicles, high radiation levels on pressurizer spray lines, and entries to the sub-atmospheric containment while at power to perform maintenance and repair activities.' In spite of the fact that removal of the RTD bypass manifold system is necessary to further' reduce. collective dose,,the licensee indicated that removal of this system may be three to four years away.
The licensee's program for control of contaminated equipment was generally effective, but there was an instance when North Anna released radioactive material to an unrestricted area when a slightly contaminated Teledose unit was shipped offsite to another facility.
This resulted in a violation.
The licensee implemented more stringent controls for material to be released to unrestricted areas.
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t The liquid and gaseous effluent program was satisfactorily managed with liquid and gaseous effluents for calendar year 1989 within the dose limits specified by Technic 61 Specifications and within the radioactivity concentrations specified in 10 CFR 20, Appendix B.
The projected whole body dose to the maximum exposed member of the public due to liquid effluents was 3.08 mrem.
.The projected dose to the critical organ (infant's thyroid) due to gaseous effluents was 0.18 mrem. The doses for 1989 were greater than those for 1988, but consistent with 1987 doses. A Unit _1 SG tube leak contributed to an increase in liquid fission and activation products in 1989.
Containment purges during outages (both units) in 1989 contributed to an increase in gaseous iodine. A review of the Semi-Annual Radioactive Effluent Release Report for January.1,1990 through June 30, 1990, indicated a small reduction in the amounts of
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liquid and gaseous effluents released, although there were no outages during this period.
The Radiological Environmental Monitoring Program (REMP) was effectively managed.
A review of. the 1989 annual Radiological.
Environmental Operating Report indicated that there were no.significant radiological consequences attributable to the operation of North Anna in 1989 due to airborne, waterborne, aquatic, ingestion, or direct exposure pathways.
Tritium levels in Lake Anna have shown an increasing trend since-1977, although the reported levels were below the reporting level of 20,000 pCi/ liter.
The 1989 values for river water averaged 3,749 pCi/ liter, as L
compared to 3,925 pC1/ liter in.1988.
The Updated Final Safety Analysis L
Repert (UFSAR) postulated an equilibrium concentration of 3,671 pCi/ liter.
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However, there was insufficent data to conclude-that the tritium l
concentration has stabilized.
No significant offsite dose can be
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projected as a result of these levels of tritium in the lake water.
The-licensee performed an audit of the REMP, the Offsite Dose Calculation Manual,-andithe Process Control Manual.
The findings and observations.
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included: liquid and gaseous dose projections not being performed as required, inoperable monitors not being reported as required, problems with' radiation monitor setpoints, and repair of inoperable radiation monitoring. equipment.. The corrective actions were adequate. Overall this audit was well planned, thorough and adequately documented.
The primary and secondary chemistry program was well managed.
In November 1989 the chemistry organization was moved. under the Radiation Protection
. Superintendent.
Total chemistry staffing was increased from 23 to 26 l
persons, providing for increased attention to plant chemistry.
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and secondary chemistry parameters wera. being effectively' maintained within Technical Specifications and Electric Power Research Institute /
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Steam Generator Owner Group guidelines-during steady state operations.
The licensee had-an aggressive program to measure, control, and reduce corrosion in various plant water systems.
One violation was identified during the assessment period.
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Performance Rating Category 2 3.
Board Recommendations The Board is concerned 'that despite the licensee's dose reduction initiatives during the assessment period, overall collective dose remained high.
Additional management emphasis on the pursuit and effective implementation of good ALARA practices is warranted.
C.
Maintenance / Surveillance 1.
Analysis This functional area addresses those activities related to equipment condition, maintenance, surveillance performance, and equipment testing as
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reviewed during routine inspections conducted during the assessment
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period.
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The licensee's maintenance program improved during the assessment period, primarily as a result of-corporate and station management's consnitment to improve both resource allocation and programs.
The maintenance department staffing-levels were increased by the addition of maintenance engineers, maintenance support personnel, planners, and instrument technicians. The l
instrument support service group was reorganized to provide dedicated i-personnel for specialty areas such as security equipment, meteorology and computers..
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Maintenance support of operations contributed to long operating runs, reducediforced outage rates, and " black boards." With the exception of a diesel engine connecting rod failure early in the assessment period, minimum equipment problems occurred.
Three reactor trips, however, were
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caused. by 11 adequate maintenance practices.
Two trips involved the
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turbine EHC system and the third trip was due to a failed driver card for the main feedwater regulating valve.
This maintenance-related trip problem continued from the previous assessment period.
Also, superior-material condition and equipment preservation was evident based on routine plant tours.
- Both units experienced isolated cases of high RCS
- unidentified leakage during the assessment. period, although the Tecnnical Specification limits were not exceeded.
The leaks were located primarily on the RTD bypass manifold.
Corrective. action was effective and unidentified leakage remained low towards the end of the period.
The licensee effectively applied its resources to significantly reduce and maintain a small corrective maintenance backlog and to conduct PM without deferrals.
The previous assessment identified the licensee's lack of a l
formal check valve PM program as a weakness.
Corporate and station management assigned the necessary resources and developed a check valve program and, in addition, a relief valve program, a circuit breaker program, an motor-operated valve program and a component analysis program; each of which was assigned to a maintenance engineer.
The licensee was also developing increased use of pred :tive maintenance techniques and
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reliability-centered maintenance programs.
However, the licensee's failure to implement a vendor-recomended Grinnell valve PM program in a timely manner contributed to a chronic problem of radiological gas in the auxiliary building which had been tolerated by the licensee and had continued from previous assessment periods.
During this period, the licensee identified leaks from the gas stripper, VCT level instrumentation and low level waste tank to be significant sources of rubidium.
By the end of the assessment period, the gas problems were under control.
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violation for failure to establish an effective program to identify and reduce radioactive leakage in fluid systems outside containment involved both this issue and the Grinnell valve PM program.
The licensee experienced reliability problems with various recirculation L
heat exchangers and service water radiation monitors during the previous l-assessment period ~ and early into this assessment period.
Increased station management attention resulted in improved performance in the operability of radiation monitors,- although some problems continued.
The. licensee maintained an adequate program for ensuring that surveillances were properly scheduled and conducted, in some cases, however, the failure to properly revise test procedures and schedules
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L resulted in missed surveillances.
Examples of this included missed surveillances on the auxiliary feedwater system pumps, valves and flowrate instrumentation, pressurizer level time response testing and the failure
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to. include 79 containment isolation valves in the monthly containment
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p integrity certification.
Surveillance procedures associated with the ten-year inservice inspection activities on the Unit I reactor vessel were technically ' adequate.
The examination results were promptly and
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conservatively evaluated by the licensee ~.
Overall, the in-service testing' (IST) program was implemented in a satisfactcry manner.
Several performance problems did-occur, though, involving failure to increase testing frequency based on high vibration of a casing cooling pump, a procedure which did not ensure adequate running time prior to data collection and the. implementation of a relief request -
. prior to NRC approval.
In previous assessment
)eriods, various problems with maintenance procedures were identif< ed in that many were generic, lacked component-specific guidance.and required " write-in" steps.
The licensee.
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embarked on a long-term program to upgrade and. develop component-specific -
t maintenance procedures. Although several procedures had been written, the -
overall program had not been implemented long enough during the assessment period to be evaluated. Current procedure' inadequacies continued to cause problems.
In one case the absence of detailed steps resulted in a low head safety injection pump discharge relief valve failing to reseat due to an. incorrectly adjusted blowdown ring.
Also a hydrogen analyzer calibration procedure required the acceptance criteria to be written in by
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the instrument technicians.
Subsequent review determined that the-written-in criteria was incorrect resulting in a violation.
Surveillance procedural inadequacies accounted-for a spurious diesel generate start
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and a non-conservative calibration of all the refueling water storage tank (RWST) low level automatic setpoints, l-
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A.lthough personnel error corrective action effort from the previous assessment period continued to be effective, personnel problems contributed to several significant equipment issues.
The failure to follow procedures during a RCS letdown filter replacement contaminated seven workers and resulted in a viclation.
Personnel errors also contributed to the previously mentioned diesel generator start and the RWST calibration error.
l Although planning was generally satisfactory, problems continued to occur, In one case, when the low head safety injection pump was removed from service for corrective maintenance, the failure to identify procedural interference and needed repair parts by conducting walkdowns precluded timely completion of the job and resulted in the pump remaining out of service for an unnecessarily extended period.
The lack of a planning
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walkdown and an effective procedure contributed to several problems observed - during repair activities on a containment vacuum pump.
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Ineffective maintenance controls resulted in the removal of the service water pumphouse concrete blocks on one occasion and the charging pump cubicle blocks on another without adequate compensatory measures.
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' blocks serve structural support functions for the safety-related pumps.
u Several examples of successfully planned and executed work activities were observed.
These included a reactor coolant pump motor replacement, a reserve station. service transformer replacement-and an outage to repair-
' butterfly. valves in the component cooling water system.
These were the result-of improvements _in coordinating maintenance planning with -
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operations, health physics and other groups.
In part, because
)roblems occurred with control of vendor manual'
information, the licensee was comprehensively addressing vendor manual control by including upgrading programs as 'part of. the overall
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contiguration management program. Examples of vendor manual problems were
'the failure to incorporate casing leak repair procedures on a low head safety injection pump, torque values for Grinnell ~ valve bonnet nuts not being. incorporated into a maintenance procedure which contributed to an unplanned spill, and technicians observed using an uncontrolled vendor manual to perform calibrations.
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Microbiological induced' corrosion was being managed in the service water L
system with molybdate / phosphate corrosion inhibitors and biocides.
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treatment scheme reduced uniform corrosion in this system to approximately
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I mil per year.
The licensee installed a corrosion monitoring system for the. service water system.
The licensee was involved in several ongoing L
studies dealing with corrosion inhibition.
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Five violations were identified during the assessment period.
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2.
Perfonnance Rating
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Category: ?
3.
Board ReconsnenaaUcos
% 5tenance and calibration procedures have continued to cause problems
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during this evaluation Piiod.
While the Board recognizes the long term j
efforts underway to corect this problem, continued management attention j
and support to this ar% is encouraged, j
D.
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Analysis
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This functional area addrenes activities related to the implementation of l
the Emergency Plan and procedwes, support and training of onsite and
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offsite emergency response organizations, as reviewed during licensee i
. performance during emergency exercises and routine inspections conducted
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during the assessment period.
This assessment period included both the 1989 and 1990 annual emergency exercise.
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'During this period the licensee provided good management support to the EP program and maintained a qualified on-call staff for responding to an emergency.
Support to the EP program was evident and. highly effective from both corporate and site management, as reflected by the 1990 annual exercise.
The 1989 annual exercise resulted in licensee consnitment to demonstrate objectives that were not adequately demonstrated in the exercise, primarily because of ' scenario / controller problems.
The 1990 exercise scenario was challenging and technically accurate; the exercise i.
controller organization was well-trained and well-coordinated; and the 1989 exercise consnitments were fully demonstrated.
Emergency planning staff at the site was. increased during this assessment period with the addition of the Emergency Planning Station Coordinator position, l
Implementation of the Virginia Power Emergency Preparedness Enhancement Program resulted in additional ~ upgrades in the EP program and initiatives l'
to increase effectiveness.
The more significant of these were the j'
improved staff augmentation available from a significantly enhanced notification and callout methodology and the installation and demonstrated use of an upgraded dose assessment system.
EP coordination and support was very good, as indicated by the detailed-exercise scenario and effective control observed during the 1990 annual exercise.
EP training was effective, as demonstrated during exercise observations and a simulator exercise, with one exception. 'The exception i
was. the training of the 1989 exercise controller staff which, because of excessive prompting of players, prevented the full evaluation of' the i
L licensee's capability to classify, assess, and respond to an accident.
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The 1989 emergency exercise also identified weaknesses in the area of personnel accountability and radiological monitoring activities; however, both of these were demonstrated as fully satisfactory during the 1990
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exercise.
The licensee also demonstrated an effective critique process l
and corrective action program-in that all EP open items were closed by the
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end of the assessment period.
The licensee continued to maintain appropriate facilities and equipment to respond to an emergency, including the Technical Support Center, Local Emergency Operations Facility, and
- omunications equipment, with one exception noted.
The exception was a failure to maintain respirators in accordance with procedures such that respirator cartridges with an expired shelf-life were found in an emergency kit.
The licensee imediately corrected the situation.
In addition, the licensee's EP augmentation capability was improved from the last assessment period by putting all 30-minute responders on shif t and extending the assignment of pagers to all personnel required for minimum staffing of the emergency response facilities.
The licensee had effective working relationships with the Virginia Commonwealth and local emergency response organizations.
When emergency _
planning issues from the Virginia Commonwealth and local agencies were
identified during drills and exercises, the licensee worked with these
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agencies to improve the programs and, when necessary, provided significant l
support.
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The' licensee submitted one revision to the North Anna Power Station
The submittal was a complete plan change, which did not degrade the Emergency Plan's effectiveness."
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No violations were identified during the assessment period.
2.
Performance Rating Category: 1 b-3.
Board Recommendations None E.
Security
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1.
Analysis
.This functional area addresses those-activities related to security protection of plant vital systems, equipment, and special nuclear material, as reviewed during inspections and observations conducted during the assessment period.
Security personnel performance was satisfactory during the assessment period, and the security program was, in general, effectively implemented.
Perimeter detection zones were improved by installation of concrete foundations on which' a new 4-wire Stellar E-field intrusion detection system was installed to replace the old 3-wire system. Testing of the new system demonstrated acceptable detection capability.
The motivation and professionalism demonstrated by security. personnel was noteworthy.
The recent change in security shift scheduling to 12-hour shifts of 4-days on duty and 4-days off contributed to improved morale.
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Access control was satisfactory during the period with the exception of two problems involving security requirements related to unsecured alarmed security doors and an inadequate materials search. An additional problem, related to inadequate management oversight resulted in an individual's station access continuing with positive drug test results.
A review of the event revealed the occurrence of a communications breakdown between the security organization and the Louisa County Sheriff's Department.
This lapse in comunications resulted in a 14-month delay in the initiation of appropriate follow-up action oy the licensee due to the licensee's failure to contact the sheriff's office for the results.
Review of the licensee's audits of the security program during this assessment period revealed a lack of documented conclusions relative to the adequacy of effectiveness of the security program early in the
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assessment period.
However,' more recent audits were thorough and also l
detailed the' auditor's actions to determine the effectiveness of the security program.
The licensee made a concerted effort to ensure that plan changes were coordinated and properly documented prior to submittal.
The lines of comunication regarding plan changes improved during the assessment period.
Three changes were made to the North Anna security plans under the provisions of 10 CFR 50.54(p).
The changes were consistent with the applicable requirements.
The licensee improved their comunication with the NRC regarding the context and content of plan changes.
The licensee followed all appliable NRC guidelines and maintained an-adequate program for controlling and accounting for special nuclear material.-
No violations were identified during the assessment period.
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2.
Performance Rating
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Category: 2 3.
Board Recomendations I
None F.
Engineering / Technical Support 1.
Analysis This functional' area addresses those activities associated with the design of plant modifications, engineering and technical support for operations, outages, maintenance, testing and surveillance, and licensed operator l
L training as reviewed during routine. inspections conducted during the
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assessment period.
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Although examples of deficient performance were identified, the licensee generally demonstrated an improving trend in engineering and technical support performance.
The licensee's connitment to improve performance was demonstrated by actions initiated to address previously identified weaknesses in this functional area.
Corporate engineering management developed and implemented an Engineering Quality Plan which established goals and directions for improvement.
Follow-up actions to address-weaknesses identified by the safety system outage modifications inspection
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(SSOMI) were comprehensive end beyond NRC requirements. Actions to reduce the drawing update backlog were successful and provided improved program controls.
The engineering work request backlog was reduced and improved controls were implemented for engineering calculations. Post-modification test controls were upgradet. and resulted in improved performance in this area.
Evaluation of modification field revisions demonstrated a design control self assessment initiative.
Temporary modifications were reduced and maintained at a minimal level.
Considerable licer;ee resources were allocated to the continuing
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Configuration Management DBD Program.
The program was comprehensive and L
has been effective in upgrading plant design basis information, Completion of the system design basis documents was on schedule.
This i
program -was developing censistently with' well-defined design basis informa tion.
The licensee's interface with the NRC on the DBD program status was very pro-active.
Engineering support contributed to achieving and routinely maintaining control room annunciator " black boards" and also evaluating and reducing a backlog of open justifications for continued operation.
Modifications were implemented which resolved long standing control room habitability and instrument air system problems.
Design Engineering (DE) identified and resolved calculation errors in both large break-loss of coolant accident analysis and. pipe support loading for recirculation spray heat exchanger service water lines.- Additional examples included the identifi-
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cation of design' deficiencies related to the incore flux mapping assembly and root cause for spurious actuation of pressurizer heater protective devices.
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Although improved performance was evident, there were examples of less l'
effective engineering performance.
Station engineering was not pro-active L
in tracking and trending information to determine the impact of elevated environmental temperatures on equipment perfonnance.
Specific examples were elevated temperatures on the cable vaults, battery rooms, rod drive rooms and the extensive use of portable fans and blowers to cool safety-related equipment.
Also, station engineering applicability evaluation of potential orifice installation deficiencies was not timely.
DE evaluation and recommendations regarding the start-u) channel check of steam and feed flow instrumentation was inadequate. /.Lthough the plant rejected this evaluation it demonstrated a deficient knowledge level of DE with respect to Technical Specification operability verification require-ments.
Also an inadequate engineering test procedure for solid state protection system slave relays resulted in inoperabilit; of air ejector
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discharge to containment valves.
Problems related to equipment design and relief valve setpoints contributed to several piping system relief valve lifts during various safety-related pump testing.
Test procedures and piping modifications appeared to have addressed the-concerns with the pumps in the AFW and recirculation spray systems, however, relief valve lifting on the low head safety injection pumps had not been addressed at the end of the assessment period.
The onsite technical support organizatin developed into a more effective support resource.
Contributors to this improvement were the realignment of onsite technical resources and the maturing SE organization.
The onsite organization was well staffed with approximately 65 engineers.
This included a small onsite contingent of DE and 26 system engineers.
The technical support manager's strong operational and technical back-ground provided additional strength for the technical support organiza-l tion.
The SE program was well developed including clearly defined performance goals and a comprehensive training and qualification process.
A specific SE strength was the engineers' knowledge of systems and components.
Also, station engineering demonstrated increased involvement l
in plant activities by participation in routine plant daily meetings.
Although deficiencies were identified in the IST program, which
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contributed to implementation problems, engineering's overall effort L-demonstrated an intention to meet all applicable industry and regulatory I
requirements in program development.
The licensee's overall response to Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Program, was satisfactory, prompt and demonstrated a good interface with the NRC.
Additionally, the licensee demonstrated initiative in resolving
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L IST program deficiencies.
For example, prior to submittal of a relief request regarding test requirements for outside recirculation spray pumps, the licensee perfonned two pump tests and provided test. results to
. substantiate the basis-for. relief.
However, several sections of the
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l program were incomplete.
Specifically, station. engineering failed to l
. identify that the recirculation spray pump testing was not in accordance L
with ASME-Section XI requirements.
In addition, the licensee failed to
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incorporate numerous service water valves into the program and to properly L
full stroke charging ' pump lube oil cooler valves, resulting in a i
violation.
During the-latter part of the assessment period, the licensee
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demonstrated a strong interest in understanding Code requirements NRC positions and generic issues in order to properly. address and incorporate these matters in the IST program.
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The licensed operator requalification training program-was rated as satisfactory based on an 89 percent pass. rate.
Four crews were evaluated with-no failures.-
No initial licensed operator examinations were administered.- Effective use of the simulator was observed for proficiency-training during major evolutions such as reactor startups and major tests.
Two violations were identified during the assessment period.
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2.
Performance Rating Category: 1 3.
Board Recomendations None G.
Safety Assessment / Quality Verification 1.
Analysis This functional area addresses those activities related to licensee implementation of safety policies; license amendments, exemptions and relief requests; responses to Generic Letters, Bulletins and Information Notices; resolution of safety issues (10 CFR 50.59 reviews); safety review
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comittee activities, and use of feedback from self-assessment programs and activities, as' reviewed during routine inspections conducted during the assessment period.
Licensee corporate and station management attention and involvement were readily. evident and placed emphasis on superior perfomance of nuclear safety.
The licensee implemented a series of overlapping programs for self-assessment and quality verification which were effective in identifying weak performance and improving programs.. At the department level onsite, each group conducted quarterly self-assessments by compiling and reviewing perfomance. indicators and other sources for strengths and weaknesses.
The conclusions were-presented for management review and the results visibly displayed to highlight personnel, programatic or equipment problems.
Station management consistently demonstrated active involvement and exercised effective controls in station activities. This was evidenced by the continuation-of management reactor startup assessments following refueling or reactor shutdowns.
An evaluation was conducted by each department to ensure that within their area of responsibility, all equipment tests and supporting documentation necessary for unit startup were complated and. evaluated.
Each evaluation was presented to station management for their review, questions and approval, Quality assurance: (QA) organization performance during the assessment period was effective.
QA conducted perfomance evaluations in various areas, often identifying issues which were outside the regulatory-based scope of QA' audits.
One example of an effective. evaluation was a review t
of the Maintenance Deprtment activities and program. The' assessment was-extensive and pointed out several strengths as well as weaknesses in the areas of planning, work activity documentation and post-maintenance testing.
Exits were held with station management to ensure they were aware of the QA observations.
A significant problem was identified in the previous assessment period involving the offsite independent review group meeting its Technical Specification-required review responsibilities.
Major improvements were
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implemented during the assessment period with increased corporate involve-ment in the areas of oversight and independent review.
A Management l
Safety Review Comittee (MSRC) was formulated, consisting of senior corporate members and consultants, to independently review station activities such as significant events, violations, findings, and evalua-tions. A technical specification regarding MSRC activities was requested and issued demonstrating management's commitment to the establishment of
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ao effective oversight program.
To correct the specific problem from the
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avious assessment period, the CNS g,'oup was staffed with qualified
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reviewers and a dedicated supervisor to report to MSRC as a subcommittee.
CNS conducted Technical Specification-required independent reviews and was also detailed by MSRC to review areas where management had concerns.
L Examples of reviews of CNS included an E0P inspection, commitment tracking assessment and an assessment of programs in place to minimize the chances '
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of or to cope with a loss of decay heat removal capability.
With respect to onsite review activities, the Station Nuclear Safety and Operation Comittee (SNS00), which met-frequently, was prudent and l-conservative in its duties to evaluate and approve station activities, l.essons learned from previous events were effectively applied, as i,
indicated by programs established to control reactor water level during periods of reduced inventory.
Station Nuclear Safety (SNS) increased staffing levels and continued to trend deviation re performance evaluations and root cause evaluations. ports, conduct human t
Additionally, the l-shift technical advisors, who repo'.t to SNS, continued to be employed as independent reviewers of daily shift operations.
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Management cont'inuedL to stress a low threshold for identifying conditions adverse to quality and writing deviation reports.
Mana openness in making the NRC aware of potential problems. gement emphasizedThe lic typically sensitive to events requiring NRC notification.
However, one
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violation involved the failure to make a timely notification of the
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discovery that the containment equipment door escape air lock was unable j
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The licensee's root cause evaluation program was fully implemented and i
effectively managed by SNS.
One example involved the reactor trip due to a failed printed circuit driver card for a feedwater regulating valve.
The evaluation identified a history of similar failures due to aging and recomended periodic replacement and a need to identify similar driver
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cards which could cause a reactor trip.
An additional example involved-
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followup to determine the failure mechanism of a diesel generator connect-
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ing rod.
Improper preloading of connecting rod nuts was identified by a s
' team of metallurgists and consultants. Corrective actions were determined and applied to the other engines as well.
The licensee's corrective action program was effective but sometimes not timely.
The licensee. addressed weaknesses identified by an NRC maintenance team inspection conducted during the previous assessment period.
Station management involvement in for.aulating the corrective action was evident through assignment of priorities, prior planning and -
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well defined corrective actions.
Responsiveness was timely, sound and thorough.
In addition, the roolution of the long-tem instrument air problem was an example of the licensee's effort to conduct extensive corrective action.
In some cases, corrective actions to QA audit findings and long standing equipment problems were not timely.
QA findings for which corrective action was not timely and received multiple extensions
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involved emergency preparedness training program development, corrections to the UFSAR, environmental qualification maintenance procedural conthois, and the need for units on_ Technical Specification radiation monitor setpoints.
In addition, station engineering identified several causes for a continuing pressurizer heater trip problem, but corporate and station management timeliness in implementing corrective action was slow.
A degradation in the licensee's management of NRC comitments continued during the assessment period.
The licensee was unable to meet original comitments made to NRC concerning instrument and service air upgrades required for previous enforcement actions.
The submittal on turbine
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governor valve tests during coastdown was late, based on the licensee's original commitment to address this matter.
The licensee has a program under development to improve commitment management.
The human performance evaluation program was also used effectively and identified-inadequate controls and policies governing structural concrete -
blocks following the failure to replace the service water pumphouse missile shield blocks after maintenan;e.
Long-term corrective actions t
L were recomended; however, interim' actions were not effective in prevent-L ing recurrence, as a similar event occurred later on the charging pump cubicle blocks.
All licensee event reports were reviewed.
The reports were timely and L
adequately described the major aspects of the event, including contribut-
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ing factors.
l The licensee continued to demonstrate a high level of corporate and station management involvement, control and active participation in i
l assuring quality in licensing activities... Particularly noteworthy during this assessment period was the licensee's response to implement the Comission's Interim Policy Statement on Technical Specifications Improve-ment. North Anna is the lead Westinghot. e plant for the implementation of the new Standard Technical Specifications (STS)
During the assessment period, the NRR staff began review of the proposed.new North Anna Technical Specifications.
The licensee's participation in the,STS
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. improvement program was exemplary. The licensee actively participated in
. the Westinghouse Owners Group efforts to develop the new STS.
Also, as
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the lead Westinghouse plant, the North Anna fomal proposal was submitted in a timely manner.
The licensee brought strong resources and expertise to bear on this project, demonstrating excellent management attention.
Throughout the. review, the licensee demonstrated appropriate concern for plant. safety.
In addition, the licensee actively pursued an aggressive and continuous upgrade for Technical Specification continuity and-similarity between the two North Anna units, as illustrated by the number
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of Technical Specification chcages submitted on a continuing basis.
The licensee actively pursued an 3ggressive policy of quality control on proposed amendment changes to assure that the final submittal to NRR represented a quality product.
The quality of the licensee's submittals continued to mitigate the amount of NRR staff effort required for review and resolution of licensing issues.
Examples of excellent quality content were the new STS, engineered safety features slave relay, and limiting dose to control room operators submittals.
One violation was identified during the assessment period.
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Performance Rating
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Category:
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Board Recomendations None
- V.
Supporting Data and Sumaries l
l A.
Licensee Activities Unit 1 began the assessment period : in a refueling outage and restarted on July 15, 1989.
On July 19 the unit automatically
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tripped from 90 percent power when turbine EHC pressure was lost.
The unit operated at power until December 5 when power was reduced to 7 percent-due to EHC pressure transients. At that time, it automat-ically tripped due to a turbine trip and the resultant steam SG level transient.. After repairs, the unit restarted on December 21' and-
- operated at power. until January 23, 1990, when it again automatically tripped.
The unit returned to 100 percent power on January 25 and continued at this level for the remainder of the assessment period.
Unit 2 started the assessment period operating at 100 percent power.
.The unit did not experience any reactor trips and set a continuous
l on-line operating record of 469 days for a Westinghouse pressurized L
water reactor.
The unit experienced increasing primary-to-secondary L
leakage toward the end of the run and shut down on August 21, 1990,
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two and a half weeks prior to the scheduled refueling outage.
The
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unit ended the assessment period in Mode 5.
The following organization changes and significant events occurred during the assessment period:
October 1989, the licensee instituted their Nuclear
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l Resource Allocation Plan December 1989. E. Harrell was assigned at the new Vice
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May 1990, J. Smith was assigned as the new Site QA Manager
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B.
Direct inspection and Review t.ctivities From June 1, 1989, through August 31, 1990, 38 inspections were conducted by resident and regional based inspectors.
This included two announced team inspections.
One was an IST inspection conducted in January 1990, and the other was an E0P inspection conducted in
June 1990.
Also, a followup to the 1989 SSOMI was made in May 1990.
Fourteen meetings were held with licensee management personnel during
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this assessment period.
One of these meetings was an enforcement conference.
C.
Escalated Enforcement Action
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1.
Violations
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One Severity Level 111 violation with no Civil Penalty involving a loss of containment integrity event on December 28, 1989.
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Orders
None D.
Management Conferences June 12, 1989 - Management meeting at Rockville, Maryland, to discuss the Configuration Management Program for North Anna and Surry Power Stations.
June 19,1989 - Management meeting at Atlanta, Georgia, to discuss the self-assessment for North Anna Power Station.
August 22, 1989 - Meeting at Atlanta, Georgia, to discuss the emergency preparedness plans and programs for North Anna and Surry Power Stations.
August 24, 1989 - Meeting at North Anna Nuclear Information Center, Mineral, Virginia, to present the SALP for North Anna, September 26, 1989 - Management nieeting at Atlanta, Georgia, to r
discuss the Configuration Management Program for North Anna and Surry Power Stations.
October 11, 1989 - Meeting at Atlanta Georgia, to discuss the emergency preparedness plans anc' rogra,rs for hortn Anna and Surry Power Stations.
January 16, 1990 - Meeting at Atlanta, Georgia, to discuss a status report on the emet gency preparedness upgrade program for North Anna
and Surry Power Stations...
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feh ::ary 21, 1990 - Meeting at Atlanta, Georgia, to discuss the Corrmment Management System.
February 27, 1990 - Enforcement conference at Atlanta, Georgia, for the containment escape hatch leakage event of December 1989.
May 23, 1990 - Meeting at Rockville, Maryland, to discuss the procurement and material program for North Anna and Surry Power Stations.
June 25, 1990 - Meeting at Atlanta, Georgia, to discuss the emergency preparedness program.
July 18, 1990 - Meeting at Atlanta, Georgia, to discuss the self-assessment for North Anna Power Station.
August 15, 1990 - Meeting at Atlanta, Georgia, to discuss Configura-tion Management Program.
E.
Confirmation of Action Letters None F.
hview of Licensee Event Reports (LERs)
Durin) the assessment period, a total of 21 LERs were analyzed.
The distribution of these events by cause, as determined by the NRC staff, is as follows:
Case Unit 1 or Both Unit 2 Component Failure
1 Design
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Construction, Fabrication l
or Installation
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Personnel Error-Operating Activity
0-Maintenance Activity
0-Testing / Calibration Activity
2-Other
0 Othe;
0 Total
3 Note 1:
With regard to the area of " personnel error," the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.
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Note 2:
The "Other" category is comprised of LERs where there was a spurious signal or totally unknown cause.
G.
Licensing Activities A tabulation of licensing actions is as follows:
Active actions at beginning of period (06-01-89)
Actions added during period
Completed actions during the assessment period 37 '
Active actions at end of assessinent period (08-31-90)
The 37 actions completed during this assessment period can be
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divided into two major categories.
The number of actions which were completed for each category are:
Plant-specific
Multi plant
H.
Enforcement Activit.y FUNCTIONAL NO. OF VIOLATIONS IN SEVERITY LEVEL AREA Dev.
V IV III
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Unit 1/ Unit 2 Plant Operations 1/0 1/0 Radiological Controls 1/1 Maintenance / Surveillance 1/0 4/3 Emergency Preparedness SetJrity
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Engineering / Technical Support 1/2
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Safety Assessment /
Quality Verification 1/0 TOTAL 1/0 8/6 1/0 1.
Unit 2:
There were no reactor trips on Unit 2 during the assessment period.
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Unit 1:
07-19-89 - Reactor trip from 90 percent power due to turbine trip. A leaking 0-ring in the EHC system caused the trip, t
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12 05 89 - Reactor trip from seven percent from low low level in SG
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The trip occurred approximately 21 minutes following a partial loss of EHC system pressure and resulting load reduction.
01-23-90 - Reactor trip from 100 percent power from a low level in SG
"C" and steam flow / feed flow mismatch.
The feedwater regulating t
valve closed when a driver card in the control circuit for the valve failed.
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