IR 05000338/1993015
| ML20045J128 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/18/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045J125 | List: |
| References | |
| 50-338-93-15, 50-339-93-15, NUDOCS 9307230079 | |
| Download: ML20045J128 (26) | |
Text
.-
-
-. -
.
F
'
,
,
.-
,
j
. 1
i
,
'
ENCLOSURE
,
!
INITIAL SALP REPORT
. !
+
L i
i U. S. NUCLEAR REGULATORY COMMISSION
i
REGION II
!
i
..,
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE s
INSPECTION REPORT NUMBER
.i 50-338,339/93-15
-
,
VIRGINIA ELECTRIC AND POWER COMPANY j
NORTP ANNA UNITS I AND 2
-
-i FROM NOVEMBER 3, 1991, THROUGH APRIL 3, 1993
-
,
,
'
!
I
- l
=!
!
.
- ;
9307230079 930618
!
"
PDR.ADDCK 05000338'
'
G PDR
!
,
-, - + '
-
w-w wyr--
,
err
+
er
.
.. _
._ _
E
+
- .
,
-
.
,
.
.
!
,
I SUMMARY OF RESULTS Performance in the Operations area was excellent.
Unit I completed 306 days of continuous operation before being shut down for refueling. Unit 2 operation was good but equipment failures led to several' forced shutdowns.
Management involvement in previous problem areas such as personnel errors was effective in reversing a negative trend identified during the previous SALP period.
The radiation protection program (RP) was effective. A stable and well qualified organization was maintained. Collective dose was being effectively managed, especially during outages when cumulative dose was consistently less than projected. ALARA initiatives were considered to be strengths.
.
.
l
.,
.
.
k
.2 Maintenance was effectively implemented. Maintenance programs related to preventive maintenance, motor operated valves, and check valves were comprehensive and effective. Management involvement in the surveillance area has resulted in improved surveillance procedures.
The Emergency Preparedness program continues to be well organized and received strong management support.
Performance during the annual emergency exercise demonstrated that the emergency organization was well trained and prepared.to implement the plan and supporting procedures.
Management involvement and staff performance in the security organization remained superior.
Phase II of the security upgrade system was completed with
,
minimum problems.
Security training was well planned and executed. The
'
Fitness for Duty program continued to be effective.
.
Performance in providing engineering and technical support was good during this assessment period.
The Steam Generator Replacement Project was a significant example of pro-active engineering and technical support.
'
Engineering support for plant modifications was generally strong.
Management continued to demonstrate a commitment to safety and an awareness of station problems.
Corrective action 'and root cause analysis programs were
,
effectively implemented. Management effectively used QA as a tool to identify
'
problems and assess corrective action adequacy.
Overview Performance ratings assigned for the last assessment period and the current period are shown below.
Rating Last Rating This Functional Period Period t
Plant Operations 1 Declining
Radiological Controls
1 Maintenance / Surveillance
1 Security
1
.
'
Engineering / Technical Support
2 Improving Safety Assessment / Quality Verification 1
III. CRITERIA The evaluation criteria which were used, as applicable, to assess each
'
functional area are described in detail in NRC Manual Chapter 0516. This Chapter is in the Public Document Room files. Therefore, these criteria are
not repeated here, but will be discussed in detail at the public meeting held
with the licensee management.
,
,
P
,
'
.
k
IV. PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis This functional area addresses the control and performance of activities directly related to operating the units, as well as fire protection.
Performance in this functional area was excellent.
Plant operations were conducted safely and conservatively.
There were no significant operational events. Unit 1 operated for 306 continuous days prior to being shutdown for a steam generator replacement and a refueling outage. Unit 2 had operated for 239 continuous days when the assessment period er.ded.
Significant improvements were noted in the reduction of personnel errors caused by operator inattentiveness and in the improvement of
'
operating procedures. The negative trends noted during the last assessment period were effectively reversed.
Unit I was shut down on December 23, 1991, for a mid-cycle steam generator tube inspection outage. On March 4, 1992, during restart from the outage, a manual reactor trip was initiated when four rods from the shutdown bank "B" dropped. The operator::
performed well during the recovery. The unit was shut down on January 4, 1993, for a scheduled 110-day steam generator replacement and refueling outage. Operator performance during the shutdown, in plant configuration control and in recovery from the outage was outstanding.
At the end of the assessment period the unit was on schedule for an early April 1993 startup.
Early in the assessment period, equipment performance adversely affected the Unit 2 operation as evidenced by an RHR packing failure, a feedwater regulating valve driver failure, a dropped control rod following a startup and a main steam trip' valve failing shut.
The operators performed well during these events.
Control room decorum and overall operator performance during the assessment period were good and have shown improvement over the last assessment period.
Early in the assessment period a number of personnel errors occurred which indicated continued
,
inattentiveness on the part of operators.
Examples included:
normally locked valves which were found unlocked, failure to implement procedures which resulted in deenergizing a 120. volt
,
vital AC bus, a safety-related valve being out of its normal
)
position, and failure to maintain containment integrity during i
refueling operations. The containment breach indicated a problem i
associated with maintaining controls over containment penetrations. Management aggressively pursued correctiu action for these errors. At the request of station management, the quality assurance organization extensively witnessed indepor~ent j
)
.
.
-
.
.
.
.
a s
verifications of tagouts 'and operating activities.
This quality assurance involvement, increased emphasis on the self-check philosophy, independent consultant's review of error trends, comprehensive error trending, and a time-motion study to identify potential problem areas resulted in improved understanding of activities vulnerable to error and contributed to substantial improvement in this area.
During the second half of the assessment period, performance was -
characterized by long runs on both units and outstanding performance during the unit 1 shutdown.
Excellent operator performance was also exemplified during startup activities.
Management continued to maintain an annunciator panel black board concept during most operating conditions and aggressively pursued resolution of conditions which caused lit annunciators.
Use of the local area network and hand held computers for log-taking remained a significant tool for keeping track of system status and trending plant parameters.
Operators exhibited a good questioning attitude, were attentive in their daily log-taking, and showed a low tolerance for deficient material conditions.
Station management remained aware of plant status.
Daily meetings were effectively used to inform ranagement of plant status, significant events, and problems. Appropriate management attention was directed to adverse conditions. Shutdown activities continued to be closely monitored.
Programs such as the shutdown safety assessment and station oversight board reviews reflected a high level of sensitivity to safe and reliable operation during shutdown conditions. This was routinely exhibited by the station oversight board reviews for assessing activities such as core loading and unit start-ups. Management expectations for control of complex evolutions was evident by the level of attention and management oversight given to these evolutions.
Staffing levels for plant operators continued to exceed the minimum shift composition required by technical specifications (TSs) and fire brigade manning requirements.
Increased emphasis was placed on shifting work control activities away from the shift supervisor. This was accomplished by renewed emphasis on the dedicated tagging office staffed with a Senior Reactor Operator
,
(SRO), and the addition of a licensed on-shift procedure writer.
The structure of the shift was changed to have a dedicated time period for the operators to review the overall plant status without interruptions from support personnel. Non-shift SR0s were effectively used during refueling outages to provide oversight and outage activity support.
All of these activities lessened the administrative burden on the shift operating crew and allowed increased emphasis on safe plant operations.
Procedures used to operate the plant improved during this
.
assessment period. The addition of an on-shift procedure writer,
'
electronic procedure changes, and an aggressive approach to
_.
-.
.
-
fD -.
y
'
'.
.
h
,
reducing the backlog of procedure action requests all contributed to the improvement. As a result, the high backlog of procedure action requests noted during the last assessment period was
,
virtually eliminated.
Very few operator errors were attributed ~to procedures.
Plant material condition and appearance were outstanding.
This was primarily due to equipment maintenance, and station
housekeering and cleanliness controls.
The station painting program continued to progress.
A good valve maintenance program has been established as evidenced by the low number of leaking
,
valves in the plant. This outstanding material condition' reflects
'
the pride and professionalism of station personnel.
Significant progress was made with the component labeling program.
By the end
,
of the assessment period, approximately 40,000 of the expected 60,000 labels had been installed.
The Station Safety and Loss Prevention organization includes two fire protection specialists and an Appendix R coordinator. The administrative requirements of the fire protection program related to Appendix R protection and safe shutdown features were thorough.
Control of ignition sources and combustible materials during c
maintenance activities has successfully prevented significant fires.
Sufficient personnel were assigned to the fire brigade to meet TS requirements.
Personnel assigned were trained and fully qualified.
Five violations were issued during the assessment period.
2.
Performance Ratina Category:
3.
Board Recommendations
.
None
,
B.
Radioloaical Controls I
1.
Analysis This functional area addresses those activities directly related to radiological controls, radioactive waste management, environmental monitoring, water chemistry and transportation of radioactive material.
Tiie radiation protection (RP) program was effective in controlling personnel exposure to radioactive materials and protecting the health and safety of plant personnel and the public.
External and internal exposures were effectively controlled. The licensee's reports, evaluation, and corrective actions associated with a hot particle contamination event were thorough and timely.
.
-
- --- --.------- ----- ---..
-
-
.
. -
.
,
W l
.
s
6 The licensee continueri to' maintain a stable and well-qualified RP organization. Additionally, a separate and distinct RP organization was established which was dedicated to coordinating and supporting only activities related to the steam generator replacement project ($GRP). The organization was observed to be effective and was staffed with appropriate expertise for conducting project activities.
Sufficient numbers of qualified technicians were available to support both outage and non-outage activities, and the licensee was successful in-achieving a high contractor technician return rate for the Unit 1 Cycle 9 Refueling /SGRP outage.
The advanced radiation worker training, contractor technical training, supplemental SGRP technical training program, use of SG mockups fur training, and ALARA supervisory training were considered strengths of the licensee's overall health physics program.
During the assessment period, management involvement in field activities and support of the RP program were effective in i
fostering improvements as well as assuring appropriate corrective actions.
In particular, management's actions in response to a licensee-identified weakness regarding the failure to limit access to locked high radiation areas was prompt and effectively prevented recurrence.
-
Overall, the licensee effectively managed collective dose during the assessment period.
For the extensive work activities conducted during the 17 month period which included the expanded steam generator maintenance and surveillance, Unit I resistance.
temperature detector (RTD) removal, and Unit I steam generator
.
replacement, a dose of approximately 1170 person-rem was accumulated. Although the dose is relatively high, it represented a decrease in the average mcithly dose with respect to the previous period, and was reasonable considering-the work scope for the various activities and the licensee's historically high source
'
term.
For the SGRP, the licensee's management of dose was exceptional; the 240 person-rem was the lowest dose for similar SGRP projects in the U.S.
Licensee ALARA initiatives during the assessment period were considered program strengths contributing to both immediate and long-term dose reduction. As an example, removal of the RTDs from Unit I has resulted in approximately a 50 percent reduction in looproom general area dose rates.
For the Unit 1 Cycle 9 Refueling /SGRP outage, the licensee implemented the following specific dose reduction activities: controlled shutdown using early boration and peroxide shock; hot spot flushing and the use of temporary shielding; comprehensive and high quality mock-up training; upgraded eqaipment which facilitated remote monitoring including closed circuit television, radio communications, and telemetric dosimetry; and area and RCS pipe end decontamination.
The licensee also aggressively implemented exposure reduction
,
t W
_
_
.
_
.
.
L
.
,
.
t
through decreased respirator usage and increased engineering controls for potential high airborne activities.
Management focus and attention continued to be proactive with regard to housekeeping activities and contamination control.
During non-outage periods in 1992, the licensee took steps to maintain contaminated floor space below three percent of the
-
radiation controlled area (RCA). The licensee also conducted an extensive decontamination effort to further reduce contaminated areas during routine operations.
In addition, personnel contamination events (PCEs) for 1992 and first quarter of 1993 were 142 and 140, respectively. These were less than the licensee's goal for each period. This performance was similar to that of the previous assessment period. An increase in the frequency of minor facial contaminations attributable to the respirator reduction program was identified.
The licensee's analytical performance in the area of radiological and non-radiological water chemistry was good and was independently verified by splitting samples with the NRC mobile
'
laboratory and by the analysis of the NRC-supplied standards. The plant water chemistry program was effectively implemented, maintaining chloride, fluoride, dissolved oxygen and dose equivalent iodine well within their respective TS limits.
Liquid and gaseous effluents for the period of mid-1991 to the end of 1992 were well within the limits specified by'the Technical Specifications (TS) and 10 CFR Part 20, illustrating effective
,
'
implementation of the effluents release program. As a result, the maximum whole body and critical orgar. doses were a small percentage of the allowable limits as specified in 10 CFR 50, Appendix I.
There were no unplanned releases during this period nor were there any significant changes in activity from previous periods.
-
The Radiological Environmental Monitoring Program (REMP) was implemented effectively.
Collection stations were observed to be calibrated and well-maintained.
Licensee sample results compared f avorably with those of the State of Virginia for 1991 (the latest year available for comparison). The radiological environmental
'
data indicated that plant opcrations in 1991 caused minimum impact to the environment and virtually no dose to the general public.
Shipping and handling of radioactive waste was efficient, j
reflecting the competence, training, and experience of the staff.
j No violations were issued during the assessment period.
.
-
- - - - - - - - -
(T
-
h..
.
' :
.
.,
2.
Performance Ratina
.
Category:
3.
Board Recommendations None C.
Maintenance / Surveillance 1.
Analysis
.
This functional area addresses those activities related to -
equipment condition, maintenance, surveillance performance, and-equipment testing.
During the assessment period, maintenance was effectively implemented. Good maintenance programs and continued management attention in the maintenance area were exemplified by the excellent overall plant material condition, the low backlog and low average age of corrective maintenance (CM) work orders, and the low leak rate of the reactor coolant pressure boundary.
Pl ant ~
tours identified very few material defects or equipment leaks.
This further indicated a strong commitment to the effective maintenance of plant equipment.
Programs such as the preventive maintenance, motor operated valve, check valve, valve repack and reliability centered maintenance were also effective. The valve maintenance program has been effectively implemented as evidenced by very few leakage problems across all fluid systams.
Implementation of the surveillance program improved throughout the period.
.
Effective maintenance and raised standards for maintenance were further exemplified by very few personnel errors and by performing preventive maintenances (PMs) and maintenance on the polar crane prior to the steam generator replacement.
Examples of good maintenance practices included using a valve packing extraction tool to quickly repack valves in high radiation areas, the effective use of freeze seals to perform maintenance, good coordination of work and corrective action during overhaul of
,
service water valves, replacement of Klockner Moeller breakers, and the in-place service water piping repair.
The Maintenance Department was adequately staffed with highly
'
knowledgeable and skilled personnel. The use of mock-up training for complex maintenance along with procedural improvements enhanced performance in the field.
Late in the assessment period an adverse trend was identified with the number of maintenance personnel errors, an example being-
,
signal cables to nuclear instrumentation power range amplifiers i
which were reversed due to inattention to detail _and an inadequate
,
p
.
- .
independent verificatii1.
Licensee management noted the trend and promptly initiated actu,ns similar to those which proved
'
successful in the operations area.
Planning and scheduling of maintenance during non-outage conditions showed further improvement this period.
Coordination between various groups performing maintenance activities also improved.
Daily, weekly and quarterly planning meetings were effective. Management oversight of the planning effort was evident.
Management routinely reviewed older work orders and
.
directed resources to maintain the average age and number of corrective maintenance work orders very low.
Planning was especially effective for complex equipment repairs.
Planning for t
outages was excellent during this assessment period. Maintenance outage personnel effectively planned a Unit I steam generator inspection outage which began on December 23, 1991.
This was especially noteworthy because the shutdown was unexpected.
Management effectively mobilized contractors and craft personnel to complete the outage in 72 days which exceeded the original schedule due to the expanded (100 percent) steam generator eddy
,
current inspection.
A unit 2 refueling outage which began in
'
February 1992, and a unit I steam generator replacement / refueling outage which began January 1993, were also effectively planned and completed on schedule. The latter was a significant achievement in that it was completed safely in less than 100 days.
'
Improvement was noted during this assessment period in the quality of procedures in support of maintenance.
Specifically, the high backlog of procedure action requests for instrument calibration procedures noted in the last assessment period was eliminated.
Contributors to this were the addition of an instrument shop procedure writer which resulted in on-the-spot procedure changes of high quality, the elimination of pen-and-ink changes and establishing electronic procedure change capability. Toward the end of the assessment period a dedicated mechanical maintenance procedure writer was added to support the mechanical shops. The Technical Procedure Upgrade Program continued to proceed with upgraded procedures which provided excellent graphics showing significant improvement over the old generic procedures.
In general, daily testing activities were conducted safely using
'
highly knowledgeable individuals which resulted in very few errors.
Complex system tests were coordinated and usually directed by system engineers. Coordination and communications between the various engineers, technicians and operators was good.
This was exemplified during outages where integrated technical
,
specification surveillance tests were completed without i
significant errors.
Some weakness was noted in the conduct and control of testing by support organizations, particularly early in the assessment period.
-
.
._
..
..
,
-
.
-
-
.
.
L
.
.
.
.
The licensee instituted an innovative and extensive program to
.
reduce previously identif.ied surveillance problems.
Earlier I&C surveillances did not test all circuitry for testing completeness.
Licensee management initiated a detailed review of surveillance procedures to verify accuracy. At the end of the assessment period this comprehensive TS review program was approximately 85
,
percent complete.
The program is extensive and has provided l
excellent results. The reviews have identified numerous incomplete tests.
Eleven Licensee Event Reports (LERs) were attributed to incomplete surveillance procedures this assessment period. Nine of these were found as a result of the surveillance program review.
Management was sensitive to changes made to the inservice testing (IST) program during this assessment period. As a result the licensee has overcome the problems associated with implementation of the program which were noted in the last assessment period. To strengthen the program an IST basis document was developed which documents requirements for pump and valve testing.
During the assessment period the inservice inspection (ISI) program implementation was satisfactory.
ISI activities were conducted in a professional manner by qualified personnel.
.
Seven violations were issued during the assessment period.
,
2.
Performance Ratina Category:
3.
Board Recommendations None
-
D.
Analysis This functional area addresses activities related to the implementation of the Emergency Plan and procedures, support and training of unsite and offsite emergency respot.se organizations, licensee performance during emergency exercises and actual events, and interactions between onsite and offsite emergency response organ 1zelions during exercises and actual events.
Overall, the licensee's Emergency Preparedness program continued to be well organized and received strong management support. The licensee continued to have a good EP training program and assurance of a quality program was also reflected in the licensee's internal audit program, which was considered a program strengt..:.
.
.a.
'
.
.,
The licensee continued to maintain effective emergency response facilities (ERFs) and equipment, with appropriate equipment
.
,
surveillance and functional testing. The licensee took prompt corrective action to revise a surveillance procedure when a
problem was identified with the Technical Support Center (TSC)
emergency ventilation system test acceptance criteria.
.
The licensee's performance during the annual emergency exercise demonstrated an emergency response organization that was well
'
'
trained and prepared to implement the Emergency Plan and implementing procedures.
Emergency classification procedures were effectively used to promptly and correctly classify the scenario events. The response organization demonstrated timely and effective communications with State and local authorities.
Accident mitigation was effective and appropriate Protective Action Recommendations were made for onsite personnel and the
,
public. Corrective action for concerns noted in the previous SALP'
report were evident as the licensee demonstrated effective information flow between the Control Room and the TSC.
Good radiological exposure control means were demonstrated with the
'
issuance of self-reading dosimeters to members of the emergency response organization.
During this assessment period, the licensee's Emergency Plan was
'
implemented four times, all at the Notification of Unusual Event (NOVE) level. Each event was properly classified and initial notifications to State and local authorities and the NRC were made in accordance with applicable requirements.
The licensee continued to maintain effective offsite support as reflected in current letters of agreement and the conduct of the required annual reviews of the Emergency Action levels with governmental authorities. The licensee was also proactive in providing contractor support'to the State to assist in the resolution of offsite issues that required corrective action from FEMA-identified findings.- The licensee made one revision to its
Emergency Plan during this period and submitted it to NRC in a i
timely manner.
j One violation was issued during the assessment period.
i 2.
Performance Ratina Category:
3.
Board Recommendations None.
l
.
-
f I-
..
1'.
,
- .
l
'
E.
Security
.
1.
Analysis This functional area addresses those safeguards activities associated with the plant's safety-related vital equipment, the accountability of special nuclear material, and the effectiveness of the licensee's Fitness-For-Duty Program.
Management and staffing of the security organization continued to maintain effective levels during this assessment period. The security force continued to perform security functions in an efficient and professional manner and was provided dedicated support by site and corporate management. The continued low turnover rate of the site security force was attributed to management support and effective supervision.
During this assessment period the licensee completed installation of Phase II of the security system upgrade with a minimum of problems or disruption of site activities. The enhancements of security facilities and equipment and the effective utilization of
.
security resources contributed significantly to the security force capability to protect the site's vital resources and respond to unscheduled contingencies.
In addition, a new Secondary Access Control facility was constructed and operationally implemented to expedite access control in support of the Steam Generator Replacement Project. To further support the steam generator replacement effort, the security force was augmented by approximately 25 contract security personnel. These personnel were adequately trained and demonstrated effective performance and cohesiveness with the proprietary security force.
Detailed and current procedures for implementation of the security program were also made available to the security force.
The security training program was well planned and executed.
Site and corporate management's continued support was demonstrated by funding the construction of a new Security Training Facility.
Included in the upgraded security training facility was
,
installation of a security computer system training simulator for
'
use in training alarm station operators. The transition of alarm-station operators from the old security computer system to the new system was accomplished with a minimum of problems, due in large part to advanced training utilizing the training simulator. A major strength of the security training program was the tactical response training conducted by the security force utilizing Multiple Integrated Laser Engagement (MILES) equipment. The effectiveness of the training utiliziag the MILES equipment was demonstrated during the NRC-conducten Operational Safeguards Response Evaluation (OSRE) in November 1991. The Security Force demonstrated the ability to successfully defend and protect safety-related equipment located within the protected area from an overt adversarial threat.
,
-
-
.-
.
,
_
.
.
'
,
.
'1
During this assessment period the licensee experienced problems in the protection of Safeguards Information, both at the North Anna Station and in the corporate office due to personnel errors.
These problems were corrected. The security force continued to track and trend safeguards events, maintenance and priority projects utilizing a computerized data base as noted during the previous assessment period.
Compensatory measures were implemented, as required, with no degradation in the level of protection noted. The licensee did not experience any significant or 1-hour reportable Safeguards Events during the assessment period.
The licensee's Fitness-Fo'r-Duty Program continued to be effective in meeting the objective of a drug-free workplace and licensee commitments relative to access authorization and the prevention of the introduction of contraband items into the protected area.
Random testing for drugs and alcohol was conducted in accordance with procedural requirements and the confidentiality of test
>
results was assured.
Reportable events were thoroughly addressed and reported in a timely manner.
The licensee's established Material Control and Accountability Program (MC&A) continues to be effectively ma;C iined and managed.
Approved written MC&A procedures for controlling and accounting for special nuclear material (SNM) were followed and no deficiencies in the administration of the MC&A program were identified.
System reviews demonstrated an acceptable accountability and control program and denoted'a sense of accountability awareness which exceeded regulatory requirements.
One violation was issued during the assessment period.
2.
Performance Ratina Category:
-
3.
Board Recommendations
.
!
None F.
Enaineerino/ Technical Support
.
1.
Analysis This functional area addresses activities associated-with the design of plant modifications, and technical support for
,
operations, outages, maintenance, and licensed operator training.
]
>
Performance in providing engineering and technical support was good during this assessment period. The Steam Generator
.
Replacement Project was a significant example of proactive engineering and technical support.
Engineering support of plant i
'
.
.
.. -
~
e
.
L
.
.
-
..
..
modifications was generally strong. The Design Basis Documen-tation (DBD) program continued to be satisfactory, and good engineering and management support to outage activities was demonstrated.
Engineering and Technical Support personnel r
aggressively identified and resolved emergent issues for both operations and maintenance and took a proactive approach to resolving difficult engineering problems. The licensee maintained effective programs for the inservice inspection of valves, engineering training, and operator training.
The overall performance of engineering and technical support in corrective action remained effective during this assessment period, especially for major items. However, some deficiencies were identified which indicate a need for continued attention to this area.
Failure to identify and/or correct rcot causes has contributed to some problems.
The engineering and technical support during this assessment period devoted to the Steam Generator Replacement Project (SGRP)
was significant and was instrumental in the successful completion of the project ahead of schedule and with minimum problems.
Inspections of SGRP activities found significant pre-planning and excellent mock-up training, engineering, technical support, and
'
contractor oversight, demonstrating a pro-active management commitment.
'
Engineering support of p1 ant modifications was generally strong.
The Modification Management Review Team (MMRT) completed
,
prioritization and scheduling of plant modifications so as to emphasize nuclear safety. The quality and technical content of the design change packages were generally good.
Examples include: the Service Water Restoration Project, and the RTD Bypass Removal Project.
Examples of weak plant modifications were also identified. An example was associated with the attempted resolution of a chronic problem (recurring pressure spikes in the LHSI system during pump start) from the previous assessment'
period.
The modification installed a vent valve at a high point in the system piping to alleviate potential voids during pump start.
The modification was completed, but the pressure spiking problem continued. The pressure spiking contributed to the failure of an SI discharge relief valve to properly reseat during pump testing and a cracked SI vent weld. After further
modifications on Unit 1, which added more vent valves, the spiking i
appeared to lessen. Another example of a weak modification was a steam generator blowdown tank piping modification which resulted
)
in the inability to achieve the previous blowdown flow rate.
A-final example of weak engineering was an engineering evaluation for EDG batteries which allowed 2 of 60 battery cells to be jumpered but did not cons'ider the effect of degraded battery capacity. When two cells were jumpered the battery quickly
,
failed.
'
-.
- -
--
T p
-
f i
.,
- .
The licensee's DBD program continued to be satisfactory during the assessment period. The DBD reviews for approximately 20 systems were at or near completion by the end of the period. Mechanisms were included to provide appropriate feedback to the DBD program
,
when a plant design change had been implemented.
Effective controls were in place during the period to ensure that applicable design documents were updated to reflect the as-built plant in a timely manner.
The Engineering and Technical Support personnel aggressively identified ar.d resolved emergent issues for both operations and maintenance.
Engineering and Technical Support computer use for trending, tracking, and analyzing system and component performance was effective.
Communications between the engineering and
<'
technical support groups and the operations and maintenance groups were good. A significant improvement from the previous assessment
.
period was noted in the area of procedures, including the evaluation of each modification's impact on them.
This resulted in a Procedure Action Request (PAR) backlog reduction.
The Engineering and Technical Support groups took a proactive
'
approach to resolving difficult engineering problems.
Examples include the engineering and management commitment to resolve time response problems with the turbine-driven auxiliary feedwater.
pumps and the resolution of a pin-hole leak on a steam ~ system pipe. Good engineering and technical support were evidenced in the request for relief in order to perform a temporary non-Code repair and the response to damac::d EDG cooling fans. The engineering analysis provided adequate justification for short-term repairs to maintain EDG operability until the fan blades could be replaced.
The overall performance of engineering and technical support relative to corrective actions remained effective during this assessment period, especially for major items.
However, some deficiencies were identified which indicate a need for continued emphasis in this area.
Examples of proactive corrective actions included those taken in r'esponse to Electrical Distribution System Functional Inspection (EDSFI) findings, the correction of i
'
previously identified deficiencies in Emergency Operating-Procedures (EOPs) and the implementation of immediate and thorough
compensatory measures in response to Thermo-Lag issues. Other examples of good engineering support in resolution of long-term
chronic problems included the pressurizer heater cable replacement modification on Unit 1,.the upgrade of rod drive room air conditioning, the service water restoration, and reactor coolant temperature bypass loop removal projects.
>
An example of untimely corrective. action was associated with
,
potentially inadequate RHR overpressure relief capacity. The
-
problem was brought to the attention of the licensee by a 1990 Westinghouse Bulletin,. but approximately two years elapsed before I
'
,,
e.
.
'
j
.
t.
,
!
.,
the operability concern of the RHR system was adequately addressed. Adverse contributors included incorrect initial station engineering evaluations and lack of management oversight on deferrals. Another adverse example was slow response to high failure rates of Appendix R emergency lighting. Additionally, an RHR valve packing failure, which required an immediate plant shutdown, was the result of an improperly engineered packing installation.
Failure to identify and/or correct root causes has contributed to some problems. An example was associated with a cracked safety injection system vent weld. The same weld cracked in 1991 and again several months later because the licensee's corrective -
action did not include root cause evaluation. Also numerous test failures of the containment air lock door occurred prior to this issue receiving sufficient management attention to assure adequate corrective action.
Good engineering and management support for outage activities was demonstrated during this assessment period. Outage activities were well planned and generally completed with few associated problems.
The engineering support to the major service water outages was excellent and significant improvements to the system were completed. The Unit 2 refueling outage accomplished significant plant upgradi,ng which included pressurizer heater cable replacement, AFW control circuit modification, gland steam piping replacement, and EDG battery replacement. The interface between corporate design and on-site reactor engineering was found to be satisfactory.
The Motor Operated Valve program was satisfactory during this assessment period.
Licensee actions taken in response to earlier NRC concerns were appropriate and acceptable, and program strengths were demonstrated by well planned and executed diagnostic testing executed by knowledgeable personnel. Control of MOV engineering data was found to be excellent. A review of the programmatic activities associated with safety-related check valves verified that a satisfactory program was in place.
Identified strengths included active involvement with the Nuclear Industry Check Valve Users group since its inception, the use of a strong rating criteria for safety valve assessment, and the use of a check valve database to identify individual valve parameters, summarize valve maintenance history, and recalculate performance rating factors.
An effective engineering training program during this assessment period was reflected by system engineers who demonstrated good knowledge of current systems parameters and system status. The number of managers and supervisors in engineering who have
-
operations experience or hold SR0 certification was an identified
'
strength.
,
.
w.
.
.
-
.-
,
'
.
i
i
17 The facility's operator training program was effective. This was demonstrated by a 100% pass rate on the Generic Fundamentals
Examination Section, initial examinations and requalification examinations. The NRC administered one initial examination during this SALP period to 14 candidates. All of the candidates passed, and no significant training weaknesses were identified by the
examination team. The NRC administered requalification operating
,
'
tests to three Reactor Operators and three SR0s during the week of September 7, 1992. All six operators passed this portion of the examination. The facility training staff effectively used the
,
simulator for training licensed operators and license operator candidates. No simulator fidelity items were identified by the
.
NRC during this period. The facility training staff was timely in their correction of NRC identified weaknesses. The operations-
!
training interface and fe'edback systems were effective. Operator usage of E0Ps and AOPs on the simulator and on in-plant examinations properly mitigated the simulated events. Control
>
Room operator aids served the operator needs. The facility examination banks contained more than the required number of test
'
items and were of generally good quality.
During the first half of the assessment period, deficiencies were identified with the fire protection program / Appendix R equipment maintenance.
Emergency lighting exhibited a high failure rate, a
'
number of fire barrier penetration seals were identified as either l
deficient or missing, and inspection procedures were inadequate.
Subsequently, a detailed inspection indicated that the fire protection program was effective with only minor weaknesses.
These weaknesses were aggressively pursued.
In addition a new dedicated fire protection / Appendix R system engineer position was established.
,
One violation was issued during the assessment period.
2.
Performance Ratino
,
,
Category:
7 Improving
-
3.
Board Recommendations
,
None
'
G.
Safety Assessment /0uality Verification 1.
Analysis
'
This functional area addresses those activities related to the licensee's implementation of safety policies, license amendments,
,
exemptions and relief requests, responses to Generic Letters, l
Bulletins and Information Notices, resolution of safety issues,
!
reviews of plant modifications performed under 10 CFR 50.59, t
M
'
{.
.
.
.
.
.
..
.
safety review committee activities, and use of feedback from self-assessment programs and QA activities.
_
Management continued to demonstrate a high commitment to safety
-
and awareness of station problems. Management was also highly involved in assuring quality in licensing-related activities. The Management Safety Review Committee members possessed extensive experience in diverse disciplines and provided an effective offsite overview of nuclear safety activities.
Committee meetings were held quarterly and provided effective review.
The Station Nuclear Safety and Operation Committee (SNSOC) was effective in reviewing and approving plant programs, procedures, tests and modifications. The members were well qualified, experienced and demonstrated a strong safety focus.
SNSOC meetings were held frequently and were also attended by QA personnel. The Committee reviewed all Deviation Reports and corrective action.
The licensee's corrective action and root cause analysis programs were effectively implemented in most cases. They identified reasons for adverse conditions and solutions to preclude recurrence. The foundation of the program rests on the low threshold at which Deviation Reports are generated. The policy for identifying potential. problems is clearly understood and station personnel rcutinely and consistently document deviations for management's review. When recurring failures of Klockner Moclier circuit breakers were identified, an action plan was developed to implement compensatory measures,. prioritize replacement, procure and test new equipment, and successfully
,
replace 83 breakers. An extensive and detailed review of TS surveillances was initiated in response to continued problems with inadequate surveillance testing. The pressurizer heater cable and
'
conduit and electrical panel cooling modifications were examples of comprehensive corrective actions to improve safety.
Follow-up
-
by S',ation Nuclear Safety (SNS) on an apparent slow turbine-driven
,
auxiliary feedwater pump governor response led to increased testing and the identification of the need for a modified governor.
The Station Oversight Board consisted of the senior station
,
managers and provided oversight for station programs, activities, corrective actions and plant milestones.
Frequent presentations, including reactor startup assessments and the Performance Annunciator Panel results, were made to the Board. Although not specifically required by TSs, the Board was effective in assuring
,
accountability and providing clear direction. Management was very
-
sensitive to safe shutdown operations while in Modes 5 and 6.
The main emphasis was to minimize station activities during critical evolutions. The outage plan was designed around system maintenance windows and was evaluated to ensure adequate system availability for core cooling. The outage scope and schedule were
_-
>
g~
_
..
_
_
.
.
i
.
.
..
also independently assessed by SNS.
Daily shutdown assessments were conducted and strict controls were effected for entry and work in the switchyard.
Corporate Nuclear Safety provided effective, independent review of safety evaluations and conducted special assessments of programs and events. The licensee applied industry knowledge and lessons learned from operational events. When weaknesses were identified with the post-trip review process regarding the lack of effective transient plots, the licensee reviewed other utilities' programs
'
and implemented changes to enhance the review of safety system
!
response.
Insights obtained from the Surry Individual Plant Examination (IPE) regarding internal flooding risk were promptly applied to North Anna even though the latter's IPE was not yet complete. A containment radiation monitor inoperability condition
,
due to ventilation lineup at Surry was quickly reviewed at North Anna and immediately addressed. Management also encouraged station employees to visit counterparts at other nuclear plants to
compare programs and identify possible improvements.
Management effectively used QA as a tool to identify problems and assess corrective action adequacy.
Several reactor trips had
previously been attributed to feedwater regulating valve circuit board driver card failures Active involvement by QA helped to develop strict standards for driver card maintenance and receipt l
inspection criteria.
Following a continuation of operator errors early in the assessment period, QA implemented 100% coverage of
!
operations activities which resulted in over 38,000 independent verifications. A third party evaluation of the human performance data determined a low failure rate.
Further, several causes of human failure were identified including distractions while
performing tasks and excessive tasking during scheduled high
'
volume work days. QA performed in-depth and comprehensive audits of station programs including fire protection, ISI, corrective action and maintenance. A vendor audit of Klockner Moeller was i
timely and identified quality assurance program weaknesses. This led to further efforts to assure that newly procured equipment was
qualified. The Integrated Event Trending program, a recent initiative, reviewed a variety of findings and observations to identify precursors which could lead to significant events and to assess programs which would prevent them. QA also provided
effective support for the Steam Generator Replacement Project by
-
establishing a dedicated organization. The group contributed to
.
the success of the project by conducting independent surveillances of contractor activities.
!
A high sensitivity for reporting events to the NEC was
demonstrated. This was evidenced by the conservative approach
'
'
applied during the TS surveillance review when incomplete component testing was identified.
f
+
'
t
...,...
- --
.-
.
. - _ -
_ _ _ _ - - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _
._. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _.
.
'
.,
-
.
..
l
Continuous upgrades in the NA-1&2 TS for continuity and similarity were actively pursued. This effort has succeeded in improving the accuracy and clarity of the TS through numerous changes l
which have been submitted-on a continuing basis.
It was noted that the licensee management has, in the past and for the subject SALP period, actively supported licensing issues and resolutions which represent analyses or methodologies which have l
been first-of-a-kind. An example was the submittal on the service j
water restoration plan. Another was the 10 CFR 50.59 evaluation for the NA-1 steam generator replacement program which was found
'
acceptable by the staff in all the areas of audit / review.
Licensee submittals were generally timely and of high quality.
The submittals related to control rod bank positioning to localize rod control cluster assembly wear, to ensure the design bases are i
met for the SW system, and that the design bases are met for component cooling water are excellent examples of quality content.
There was one exception where the submittal requesting an exemption from the requirements of 10 CFR Part 50, Appendix A, GDC-2 did not provide an adequate safety analysis. A prompt and comprehensive response to requests for additional information allowed the staff to make a favorable determination of the requested exemption which allowed the service water restoration project to commence on schedule.
The licensee maintained excellent licensing-related liaison with the NRC staff as evidenced by the frequent visits to NRC to discuss forthcoming requests for staff actions prior to formal submittals.
In addition, when technical issues could have been better addressed or complemented by site visits, the licensee was cooperative and provided the necessary staff to discuss appropriate matters.
No violations were issued during the assessment period.
2.
Performance Ratina Category:
(
3.
Board Recommendations l
None
!
IV.
SUPPORTING DATA A.
Ma.ior Licensee Activities i
Unit 1 began the assessment period (November 3, 1991) at full power. On l
December 23, 1991 the unit shut down for a mid-cycle steam generator inspection outage. The outage was scheduled for 60 days but extended to I
72 days due to an increased rotating pancake coil inspection of the steam generators. After the outage was complete, on March 4,1992 while
.
__
___.___
_ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _. _ _ _. _ _ _ _ _ _ _. _ _ _._ _._U
r-h.
'
.
-.
,
attempting to restart, a manual trip occurred after a group of rods dropped. On May 5, the unit restarted and operated at full power until start of coastdown on September 8, 1992. After a 306-day run, the unit shut down on January 4, 1993, for refueling and steam generator replacement. The scheduled 110-day outage was in day 89 at the end of
!
the assessment period (April 3, 1993).
,
Unit 2 began the assessment period on November 3, 1991, by shutting down
-
to repair a stem packing leak on valve 2RH-MOV--2700. The unit was
.
restarted on November 5, 1991. Coastdown was initiated on January 13, 1992, for a scheduled refueling outage. On January 29, 1992, during coastduwn, the unit was at 89% when it experienced a reactor trip. The trip occurred due to a driver card failure causing 'C' feed water reguiating valve to fail shut. The unit returned to operation on January 30, 1992, and resumed coastdown until shutdown on February 26, 1992, for refueling. The scheduled 60-day refueling outage was completed in 56 days. After the outage, on April 22, 1992, while attempting restart a rod in control bank 'C' dropped due to a failure in the rod control circuitry.. The unit was taken to Mode 5 for repairs until April 25, 1992, when the unit resumed full operation. On May 23,
'992, the unit shut down for a scheduled maintenance outage on the turbine lube oil system.
It was returned to operation on May 25, 1992.
The unit operated at full power until a SI/ automatic reactor trip occurred on August 6, 1992. Operations were resumed on August 7, 1992.
i At the end of this assessment period (April 3,1993), the unit was
operating at full power.
'
Management and/or organizational changes instituted by the licensee during the assessment period:
September 1992 - L.M. Girvin became the new Vice President, Nuclear Services.
September 1992 - E.W. Harrell became Vice President, Nuclear Engineering Services.
September 1992 - F.K. Moore-became Vice President, Procurement.
January 1993 - 1. Capps became Chairman of the Board of Dominion Resources.
.
The following major modifications of both units were completed during this assessment period:
New card reader security system (Units 1 & 2)
i Deactivation of the RTD Bypass Loop (Unit 1)
Replacement of the steam generators (Unit 1)
Service water refurbishment (Unit 1)
i
?
.
f
.
-
!
'
~ ~.., -
'
B.
Maior Direct Inspection and Review Activities t
i During this a.sessment period 47 inspections were conducted by resident and regional-based inspectors.
These included major inspections to
,
assess the licensee's emergency preparedness program and the steam generator replacement program.
Fifteen meetings were held with licensee management. No enforcement conferences were held during this assessment period.
C.
Escalated Enforcement Action
!
~
l None
.
D.
Licensee Conferences Held Durina Appraisal period November 18, 1991 - Meeting at Rockville, Maryland to discuss mid-cycle l'
steam generator degradation and the justification for continued operation of North Anna 1 through the end of the current cycle (April
1992).
December 2, 1991 - Meeting at Rockville, Maryland to discuss the ieed
'
for a mid-cycle steam generator inspection for North Anna 1.
January 6, 1992 - Meeting at Rockville, Maryland to discuss the l
cid-cycle steam generator inspection for North Anna 1.
,
,
January 27, 1992 - Meeting at North Anna Nuclear Information Center to
"
discuss SALP cycle 10 period from September 1, 1990, through November 2, 1991.
February 10, 1992 - Meeting at Rockville, Maryland to ditcuss a supplemental amendment request regarding a proposed reducticn in RCS minimum flow rate.
.
March 19, 1992 - Meeting at Rockville, Maryland to discuss various
,
t licensing issues.
March 23, 1992 - Meeting at Rockville, Maryland to discuss the steam generator replacement outage for North Anna 1.
,
i March 30, 1992 - Meeting at Rockville, Maryland to discuss various
'
licensing issues, SBO, Merits, SW upgrade, and IPE.
!
June 24, 1992 - Meeting at Rockville, Maryland to discuss current and i
forthcoming licensing issues.
,
July 31, 1992 - Meeting at Region 11 office, Atlanta, Georgia to discuss
!
- several topics including operations and key indicators, the surveillance
.
'
and updated final safety analysis reviews, the precursors trending program and the North Anna l's urcoming'SG replacement. Meeting was also used to introduce the new VP (Mr. L. M. Girvin) of Nuclear i
Services.
.
-e
-
-
____
- - _ _
__
_
_ - - __ - - _ _ - -
.
..
...
August 25, 1992 - Meeting at Rockville, Maryland to discuss the North Anna 1 and 2 Service Water restoration program.
September 24, 1992 - An NRC VEPC0 Counterparts Meeting at Virginia Electric and Power Co.'s officos, Glen allen, Virginia, to discuss current issues, open enforcement conference, ASME Code Relief Philosophy, licensing activities overview, North Anna's steam generator replacement, UFSAR upgrade program, etc.
December 15, 1992 - Meeting at Region II's office, Atlanta, Georgia, to_
,
discuss the licensee's self-assessment that was performed for the North Anna Power Station.
January 26, 1993 - Meeting at Rockville, Maryland to discuss a proposed TS change regarding the automat,1c closure function of RHR valves.
I February 25, 1993 - Meeting at Region II's office, Atlanta, Georgia to discuss QA Performance Assessment and Technical Specification Review Programs for the North Anna Power Station.
E.
Confirmation of Action Letters NONE F.
Review of Licensee Event Reports (LERs)
During the assessment period, a total of 46 LERs were analyzed.
The distribution of these events by cause, as determined by the NRC staff, is as follows:
Cause Unit 1 or Both Unit 2 Totals Component Failure
4
Design
3
Construction, Fabrication I
or Installation
-
-
-
Personnel Error
-
- Operating Activity
4
,
- Maintenance Activity
-
2
- Test / Calibration Activity
1
- Other
2
Other
1
!
Total
17
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 errors.
p K
v
-
-
_
_
_ _ _
_
_,
,
.
.
.
Note 2: The "Other" category is comprised of LERs where there was a spurious signal or a totally.nknown cause.
Note 3: The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignments.
G.
Licensing Activities A tabulation of licensing actions is as follows:
Active actions at beginning of period (11/03/91)
Actions added during period
Completed actions during the assessment period 59*
Active actions at end of period (04/03/93)
- 45 plant-specific; 14 multi-plant H.
Enforcement Activity FUNCTIONAL NO. OF VIOLATIONS IN SEVERITY LEVEL AREA IV III II I
flant Operations
-
-
.
Radiological Controls
-
-
-
Maintenance / Surveillance
,
-
-
-
-
-
-
Security
-
-
-
Engineering / Technical Support
-
-
-
Safety Assessment /
Quality Verification
-
-
-
-
TOTAL
-
-
-
I.
Reactor Trips MARCH 4,1992, Manual Reactor Trip Unit 1:
While attempting a restart after inspection of SGs a manual reactor trip was initiated when 4 rods from shutdown bank "B" dropped.
JANUARY 29, 1992, Automatic Reactor Trip Unit 2:
At 89% power a reactor trip occurred when 'C' feed water regulating valve failed shut due-to a driver card failure in its control circuit.
^
AUGUST 6, 1992, SI/ Automatic Reactor Trip Unit 2:
The 'C' MSTV closed causing a SI on high steam flow coincident with low steam pressure.
This resulted in a reactor trip from 100% power.
..
.
.
~