IR 05000369/1989034
| ML19354E393 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 01/19/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19354E388 | List: |
| References | |
| 50-369-89-34, 50-370-89-34, NUDOCS 9001310129 | |
| Download: ML19354E393 (27) | |
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[ ENCLOSURE INTERIM SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMIS510N !
REGION II
i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-369, 370/89-34 DUKE POWER COMPANY MCGUIRE UNITS 1 AND 2 AUGUST 1, 1988 - OCTOBER 31, 1989 ! I I ( ! i l l
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. c.' ( i .. ' . TABLE OF CONTENTS .P.a gg I. INTRODUCTION..................................................
A.
L i c e n s e e Ac t i v i t i e s....................................... 1 B.
Direct Inspection and Review Activi ties................... 2 I I. S UMMARY O F RE SU LT S............................................ 3 III. CRITERIA....................................................... 4 + IV. PERFORMANCE ANALYSIS ' A.
Plant Operations.......................................... 5 B.
Radiological Controls.................................... 8 C.
Maintenance / Surveillance................................. 11 D.
Emergency Preparedness.................................... 14 E.
Security & Safeguards.................................... 15 F.
Engineering / Technical Support.............................17 G.
Safety Assessment / Quality Verification.................... 19 V. SUPPORTING DATA A.
Escalated Enforcement Action.............................. 21 B.
Management Meetings....................................... 22 C.
Confi rmation of Action Letters............................ 22 D.
Review of Licensee Event Reports.......................... 23 E.
Licensing Activities...................................... 23 F.
Enfo-cement Activity...................................... 24 G, Peactor Trips and Unplanned Shutdowns..................... 24 H.
Unscheduled Manual Shutdowns.............................. 25 -
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, ' - .: . , I. INTRODUCTION The Systematic Assessment of Licensee Performance ($ ALP) program is an late: rated NRC sta#f effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to orovide a rational basis for allocation of NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their f acility's performance in each functional area.
An NRC SALP Board, cc:aposed of the staf f members below, met on December 20, 1989 to review the observations and data on performance, and to assess licensee performance in accordance with Chapter NRC-0516, " Systematic Assessment of Licensee Performance."
The guidance and evaluation criteria are summarized in Section III of this report.
The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance at McGuire Units 1 and 2, for the period August 1, 1988 through October 31, 1989.
The SALP Board for McGuire was composed of: E. Merschoff, Deputy Director, Division of Reactor Safety (DRS), Region II (RII), (Chairman) C. W. Hehl, Deputy Director, Division of Reactor Projects (DRP), RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RII P. K. VanDoorn, Senior Resident Inspector, McGuire, DPR, RII L. A. Wiens, Project Manager, Project Directorate 11-3, Office of Nuclear i Reactor Regulation (NRR) ' K. N. Jabbour, Project Manager, Project Directorate 11-3, NRR , ( Attendees at SALP Board Meeting: l M. B. Shymiock, Chief, Project Section 3A, DRP, RI! l B. R. Bonser, Project Engineer, Project Section 3A, DRP, RII l S. O. Ninh, Reactor Engineer, Technical Support Staff, DRP, RII T. Cooper, Resident Inspector, McGuire, DRP, RII A.
Licensee Activities Unit 1 Operations i Unit I began the period at full power and operated until October 7, 1988 when the unit experienced a runback to approximately 60 percent power. On October 12, 1988, the unit was shutdown for the End-Of-Cycle 5 refueling outage. The unit-i
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returned to operation on December 31.
The unit was manually tripped on March 7, 1989, due to a steam generator tube rupture in the B Steam Generator. The unit returned to operation on May 9, 1989.
The unit operated at full power until June 30, when the unit was brought off line due to a malfunction in the Digital Electro-Hydraulic Control system. The unit was returned to service on July 1.
The unit tripped on August 26, due to a failed logic card which produced a low reactor coolant flow signal.
The unit returned to operation on August 29, and remained at that level through the end of the period.
Unit 2 Operations ' The unit began the period at full power, but was taken off line on August 5,1988, due to a high vibration problem on a main turbine generator bearing.
Following maintenance, the unit returned to operation on August 7.
The unit was taken off line on October 31, to plug leaking condenser tubes and returned to ! operation on November 2.
The unit operated at full power until March 3,1989, when an automatic reactor trip occurred on high negative flux rate caused by dropped rods during the performance ! of a periodic rod movement test.
The cause of the rod drops i could not be determined.
The unit returned to operation on Myth 6.
The unit tripped on March 14, 1989, on Low-Low level , in the B Steam Generator following a Main Feedwater Pump trip
i and a failure of a load rejection bypass valve.
The unit returned to operation on March 16. The unit tripped April 6, 1989, following a failure of the Steam Generator C Main Feedwater Regulating Valve.
The unit returned to operation on April 7.
The unit shut down for the End of Cycle 5 refueling outage on July 5.
The unit returned to operation on September 19.
B.
Direct Inspection and Review Activities During the assessment period. 41 routine and four special inspections were performed at McGuire by the NRC staff.
The following is a listing of the special inspections that were performed: February - March, 1989, Operational Safety Team Inspection; March, 1989 Augmented Inspection Team - Unit 1 Steam Generator Tube Rupture; June, 1989, Maintenance Team Inspection; September, 1989, Augmented Inspection Team - Unit 2 Containment Spray Overpressurization.
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. II. SUMMARY OF RESULTS 1.
Overall Facility Evaluation During the SALP assessment period, the overall quality of operations at the McGuire facility was good.
Station managers were actively involved in daily operations and their approach to problem resolutions was generally conservative.
The coordination of plant and corporate engineering organizations was good.
Operators are very knowledgeable of the plant and they maintain a professional environment in the control room. They have exhibited excellent and timely operator actions during plant transients.
The licensee has recognized the procedural compliance problem as one requiring broad based corrective actions.
These actions have been effective in improving procedural compliance and adequacy, however. - all improvements have not been fully implemented.
Radiological control programs were adequate to protect the workers and the general public.
The licensee's training programs in this area were regarded as a strength. The radiation protection staffing levels and training effectiveness was adequately demonstrated in response to events. Management support and involvement in matters related to radiation protection issues have improved during the assessment period.
The maintenance organization is well staffed and trained to support plant operations.
The coordination of management, engineering and maintenance efforts were good. Procedural adequacies and compliance are still a problem in the Maintenance and Surveillance area.
Weaknesses were identified in the Preventative Maintenance program related to functional testing of equipment.
The licensee continues to effectively implement the Emergency Plan as demonstrated during an actual event and during an emergency exercise.
The Technical Support Center meets regulatory criteria, but is small with minimal work space. The licensee has committed to construct a new TSC currently scheduled for completion in June of 1992.
Siren reliability in specific areas was low during periodic tests.
The licensee is in the process of upgrading the entire system to include a computerized control and feedback system for periodic system interrogation. The area indicating low reliability was upgraded with the computerized system during 1989.
. Security force staffing levels and training are adequate.
Many deficiencies were identified with regard to access control and maintenance of required compensatory measures involving failure of plant and security personnel to comply with established procedures and licensee policy. The licensee experienced numerous problems with access control to the protected and vital areas. Licensee security, contingency, and guard training and qualification plan change + submittals have been well coordinated and technically soun i ,... ) '
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i I ' , i Engineering and technical support performance has been adequate.
I Corrective actions for identified design engineering deficiencies l were comprehensive and effective.
Several plant problems were attributable to corporate or onsite engineering performance i deficiencies.
Inadequate post modification functional testing was i ! identified as a weak area.
Programmatic controls for design , development and safety analysis were revised to emphasize post modification testing and acceptance criteria.
Safety assessment and quality verification performance has been good.
[ Overall corporate management leadership, direction and support was
good. Generally the licensee appears to have a broad based program for self assessment which is usually aggressive.
The corporate QA < program is complemented by a diverse onsite surveillance program often weighted toward field observations, i 2.
Facility Performance Summary , l Rating Last Rating This Functional Area Period Period Trend ! Plant Operations
2 I ' (Operations & Fire Protection) Radiological Controls
1 . Maintenance / Surveillance
2 I ' Emergency Preparedness
1 Security
2 Engineering / Technical Support
2 I (Engineering, Training & Outages) Safety Assessment /
2 Quality Verification (Quality Programs & Licensing) - I - Improving III. CRITERIA
Licensee performance is assessed in the functional areas shown above.
Functional areas normally represent areas significant to nuclear safety and the environment. Special areas may be added to highlight significant observations.
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 there, but will be presented in detail at the public meeting to be held with licensee management on January 30, 1990. However, the NRC is not limited to these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are shown here only because of some changes in the ' t . .- - - - - -.
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i NRC Manual Chapter noted above.
These new performance categories are defined as follows:
1.
Category 1.
Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention inay be appropriate.
2.
Category 2.
Licensee management attention and involvement in the performance of nuclear safety or safeguards activities are good.
The licensee has attained a level of performance above that needed to l meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels.
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Category 3.
Licensee management attention to and involvement in the iierformance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Licensee resources appear to be strained or not effectively used.
NRC attention should be increased above normal levels.
l The SALP Board may also include an appraisal of the performance trend of a functional area.
This performance trend will only be used when both a definite trend of performance within the evaluation period is discernible and the Board believes that continuation of the trend may result in a change of performance level.
The trend, if used, is defined as: l Improving: Licensee performance was determined to be improving during the ' assessment period.
l Declining: Licensee performeace was determined to be declining during ! the assessment period and the licensee had not taken meaningful steps to address this pattern.
IV. performance Analysis A.
Plant Operations , 1.
Analysis The overall quality of operations at McGuire remained good.
Reactor trips were fewer in number than previous periods.
Four automatic and one manual trip occurred for the station. Unit I was manually tripped due to a steam generator tube rupture and also experienced one automatic trip from an erroneous low reactor coolant flow signal caused by an electrical failure in the Solid State Protection System.
Unit 2 experienced three !
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- automatic trips.
One occurred when one or more control rods dropped during testing due to an undetermined reason.
The second occurred upon low-low steam generator level resulting from a loss of a Main Feedwater Pump. The third occurred when a Main Feedwater regulating valve failed closed.
Operators responded appropriately in all cases.
Operations staffing levels exceed regulatory ' requirements.
Extra Reactor Operators (RO) and Senior Reactor Operators (SRO) are normally assigned to a shift, typically four R0s and four or five SR0s. Also there are a significant number of SRO trained personnel on the operational support staff and plant management.
In addition, some SR0s and R0s are rotated to assignments in the training center, operation support staff and to other support groups. The Shift Technical Advisor position is filled by the Shift Manager who is a degreed engineer and licensed SRO. The normal duties of the Shif t Manager are to coordinate work activities on shift. This gives him a good awareness of special plant conditions when assuming the role of STA.
Professionalism, Control Room access control, shif t turnovers, operations logging and response to annunciators are generally good.
Shif t turnovers are well controlled, operators display professional attitudes and appear to ensure that there is complete understanding of plant status by the oncoming shift.
Shift logs are orderly and provide current plant status.
Operator responses to annunciators are immediate and followup actions are taken in a timely manner.
Control Room access control is good, however, on two occasions an excessive number j of personnel were observed in the Control Room.
The licensee was responsive to this concern.
Operators are very knowledgeable of the plant and inspectors have witnessed excellent and timely operator actions during plant transients. Noteworthy, examples were operators responses to secondary plant problems including a loss of the turbine control system, a loss of a main feedwater pump with steam generator feed flow in manual control, and a fire in the main feedwater control circuit for a steam generator.
Initial-operator response was also good during the steam generator tube rupture event. One Operations error allowed stroke time testing of a valve with incorrect plant conditions.
This resulted in overpressurization of the Containment Spray System.
Operator licensing examinations were administered to 6 RO and 5 SRO candidates with all candidates passing.
Re-examinations were administered to two SRO candidates who failed examinations in the previous assessment period.
The McGuire simulator has been incorporated into the operator training program for less than 1 year and has not been certified.
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Station management is actively involved in daily operations.
Their approach to problem resolution is generally conservative.
Daily management meetings' are used effectively and management meetings held to evaluate abnormal plant events are generally thorough. Management has stressed the importance of equipment availability and equipment down time has been minimized through aggressive scheduling of related maintenance / surveillance activities.
A continued weakness has been the lack of strict compliance with procedures and procedure inadequacies as evidenced by six , violations in this area.
Three temporary losses of Residual Heat Removal occurred due to weaknesses in procedures. Problems with procedures were also identified in the previous SALP. The licensee has recognized the procedurai compliance problem as one requiring broad based corrective actions.
Actions include , procedure improvements, development of section specific. guidance , relative to procedure adherence, additional training, increased in plant surveillance of procedure compliance, increased , emphasis on in-depth root cause evaluation for errors involving procedure usage, and implementation of a supervisory effectiveness program.
These actiors have been effective in improving procedural compliance and procedural adequacy, however; all improvements have not been fully implemented.
Actions not fully implemented include all section specific guidance and all aspects of the supervi sory effectiveness program.
, Also, weaknesses were identified in the Emergency Operating Procedures. Prior to the steam generator tube rupture event, it was noted that the justifications for deviations from the Owners , . Group Guidelines were not adequately documented causing concern l over the rigor of the licensee's verification process.
. l McGuire's procedures for recovery from a steam generator tube rupture did not fully incorporate the Emergency Response Guidelines provided by the Owners Group.
The use of several procedures, and time consuming evaluation of procedural
alternatives, appeared to delay and extend the duration of
reactor coolant leakage. The licensee's prompt response to this ! issue indicated effective management attention to a significant
issue.
A weakness was also identified in the management of Control Room l drawings although no significant effect on operations was ! identified.
Problems included several out of date drawings, , some illegible areas, and annotations on drawings that were not in accordance with the licensee's program.
The licensee has corrected the specific problems, made program improvements and provided additional training.
No additional problems have been noted, i.
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The number of Control Room Indication Problems (CRIPS) remained high as was identified in the previous SALP. These items such as invalid annunciators and invalid meter indications are not a significant hinderance to the operator's ability to safely run the plant and properly control plant conditions. The number of control room deficiencies, and the age of some of these deficiencies are indications of a weakness in managing the back. log of CRIPS. Some progress towards improving this area was noted during the latter part of this assessment period.
A Triennial Postfire Safe Shutdown Capability _ Reverification and Assessment inspection was performed. This inspection verified that the licensee has a program to maintain its postNre safe shutdown capability and to maintain compliance with 10 CFR 50, Appendix R, fire protection requirements.
The inspectors examined operating procedures and training pertaining to postfire shutdown requirements, emergency lighting and communication equipment, and cable separation.
The inspectors I concluded that licensee management has a clear understanding of fire protection and Appendix R requirements and is responsive to l NRC initiatives.
2.
Performance Rating Category: 2 Improving 3.
Recommendations None B.
Radiological Controls 1.
Analysis In addition to routine inspections, special inspections - of radiation protection issues were conducted during ALARA and t Maintenance team inspections.
Additional evaluations of radiation protection program adequacy were conducted by Augmented Inspection Teams (AIT) during reviews of the March 7, 1989 Unit 1 B steam generator tube rupture and the September 5, 1989, Unit
containment spray system overpressurization-event.
For the assessment period, the licensee's radiological control programs were effective to protect the workers and the general public.
In general, the licensee's training programs were regarded as a program strength. General employee training was organized and the radiation protection topics presented during retraining were current and applicable to site activities.
Effectiveness of general employee training was demonstrated by worker and management knowledge of ALARA concepts and responsibilitie. _ -- - _-
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' . I The radiation protection staff, consisting of licensee and contract individuals, was adequate for routine and outage j activities.
Training for radiation protection personnel was , thoroughly defined and properly implemented. The adequacy of
the staffing levels and training effectiveness us. demonstrated ! by the radiation protection staff responses to events reviewed , by the NRC AITs in March and September 1989.
Tht radiation i protection staff activities during these events ano during- ' subsequent recovery actions were considered timely and technically adequate.
Management support and involvement in matters related to radiation protection issues have improved during the assessment , period.
For example, the licensee completed changes to - procedures detailing ALARA Committee membership requirements and ' responsibility.
Inplementation of the changes appeared to strengthen the ALARA program. Additior, ally, the level of plant and corporate management awareness and support for the dose reduction program was identified as a program strength.
, ' The extent of contaminated floor space at the facility remained low, ranging between 5.2 to 11.7 percent. The consistently low percentage of contaminated space, was attributable, in part, to the licensee's program to contain leaks, preventative i maintenance program for valves, and aggressive contamination controis as noted during both the maintenance and ALARA team inspections.
The cumulative skin and clothing personnel contamination events for the current assessment period, relative to the previous assessment period, remained high, with more than 500 events reported for each.
During the previous assessment period, licensee actions to reduce the frequency of personnel contamination events included protective clothing improvements , and upgraded training.
Although, the number of total contamination events remained high, the use of improved protective clothing contributed to the reduced number of skin contaminations, from approximately 300 to 200 reported events.
Collective dose for facility operations remained high during the , l assessment period but showed. improvement in the latter half of l the period. For this 15 month period, the licensee reported an i expenditure of approximately 599.4 person-rem per unit.
This value is similar to the dose expenditure of 556.2 person-rem per unit reported for the previous 12 month SALP assessment period.
The average annual collective dose per unit at McGuire for 1986 ' through 1988 was approximately 527 person-rem. For the. initial 10 months of 1989, which included the completion of two outages at the facility, the licensee reported a collective dose of approximately 305 person-rem per unit and estimated that the i - - - -
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The licensee's overall commitment to, and implementation of the ALARA concept were reviewed during _ the assessment period.
Program ~ strengths were_ noted for_ several dose. reduction initiatives to control source terms, to reduce dose rates, and to minimize worker time in radiation -areas'. However,-it was noted that thare was a lack of detailed mock-up training for high dose maintenance activities.
11guid and gaseous radioactive effluents were within the lechnical Specification. limits and in compliance with 40 CFR-190 limits for radiation dose. -One unplanned release related to plant operation was reported during the SALP period.
The unplanned gaseous release occurred-March-7, 1989, when a significant primary to secondary leak developed in the Unit:1, B-steam generator.
The offsite'whole body and thyroid doses from thf s event i are a small fraction of the Technical Specification limits.
The licensee-effectively maintained primary chemistry within Technical Specification requirements and secondary chemistry within the criteria recommended by the Steam Generators Owners Group. Good chemistry control was evidenced by low levels of - ionic contaminants in the primary and secondary systems; continuous surveillance of air inleakage into the main condenser and low levels of dissolved oxygen in the condenser. hotwellt moderate amounts of sludge removed from the -steam generators; and increased eddy current testing of the steam generator in response to the Electric Power Research Institute s guidelines and the March 1989 tube rupture.
A confirmatory measurements inspection resulted in agreement _- between the licensee and the RII mobile lab for all measured isotopes.
Eighty-nine percent of the licensee's measurements were within 10 percent of NRC values. '.This ' demonstrates good performance in this area.
The -licensee discovered that sanitary sewage sludge containing low levels of radioactive materials has been accidentally removed from Duke property by a contractor in October 1989 and subsequently buried in a landfill.
The licensee was very responsive to-this finding, dispatching survey teams to the landfill and working with the State - to assure, appropriate corrective actions.
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Recommendations None C.
Maintenance / Surveillance 1.
Analysis A maintenance team inspection was performed and directed toward evaluation of equipment conditions, observation of in process maintenance activities, review of equipment histories and records, and evaluation of maintenance control procedures and.
the overall maintenance program.
In general, the NRC staff concluded that the licensee has developed and implemented a good maintenance program.
A number of management initiatives in the maintenance area have shown positive results.
These include the licensee's
application of industry initiatives, performance of maintenance self-assessment, and a well organized.and qualified QA/QC staff who are heavily-involved in the maintenance process.
The maintenance organization is= well staffed. Staffing levels, experience levels-of management and craft, qualified personnel, good supervisor to craf t ratios, and an enthusiastic attitude combined to provide an overall strong organization. Maintenance work is accomplished without excessive overtime. There is good' interface and communications between the maintenance staff and j other organizations. The training and qualification program is ~ strong and provides very detailed requirements.
The licensee's maintenance facilities are good.
Maintenance I shops are well organized and contain adequate equipment. ' Tool rooms (contaminated and non contaminated) are clean and orderly.
The material control program ~ is good. A particularly strong point is the Bar Code system used for the control of material issue.
i Engineering support for maintenance is strong. The engineering-
support is provided by the licensee's large off-site Design Engineering Department and on-site System Experts (SE).
Although the system expert program has been in effect a j relatively short time ' and some personnel. were still learning i their systems, tnis program should contribute -to better
maintenance support.
' The maintenance data base and equipment records systems are I excellent.
Records are readily retrievable and provide useful information in evaluating equipment past history for maintenance purposes.
However, some weaknesses were identified in the . i quality of completed work requests (WR).
Most of the ,
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i _ discrepancies related to identification of the cause of the problem (including failing to use cause codes).
The NRC staff identified numerous-minor housekeeping and material condition deficiencies during plant walkdowns.
Although no major housekeeping or material condition deficiencies were identified, the number of minor deficiencies l indicated the need for improvement. Overall housekeeping and material condition was average. However, a weakness in cleanup following maintenance activities was noted. Minor _ problems with labeling of plant equipment ~and a weakness in the deficiency tagging program were identified. Tags were found that had not been removed from equipment when repairs were-complete. some were illegible, and others had been on equipment for long periods of time. Also, a significant number of minor. equip;nent deficiencies existed that had not been identified and tagged.
Weaknesses were identified'in the Preventative Maintenance (PM) program relative to not testing the functional operability of molded case circuit breakers, and failure to include some Generic Letter = (GL) 88-14, " Instrument Air Supply System- ! Problems Affecting Safety Related Equipment," accident l mitigation valves in the PM program.
( Early in the assessment period a problem was identified in post ' maintenance / post modification testing and _is discussed in the Engineering / Technical Support section.
Plant maintenance and surveillance activities were _ routinely reviewed by the NRC staff.
The survei_llance testing - and calibration control program was generally adequate,-displaying i satisfactory levels of management overview. Adequate levels of expertise in.the coordination and scheduling of surveillances , were routinely demonstrated.
i During the previous SALP assessment, weaknesses were identified with respect to procedural adequacy and procedural compliance.
Although improvements have been made by reducing the number of violations in this area, procedural adequacy and compliance is still a problem in the Maintenance and'- Surveillance area.
, ! Efforts to correct these problems are described' in the ' Plant Operations section.
Examples of procedural weaknesses in the surveillance program contributed to the following-problems: ,
Two overpressurization_ events, suction _ piping on centrifugal charging pump and the containment spray system
Inadequate main steam isolation valve testing procedure
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Loss of Residual Heat Removal pump due' to inadequate - surveillance procedure
Inadequate valve stroke timing test allowed _ the turbine driven auxiliary feedwater pump to start and inject ' Required boron surveillance during shutdown was not performed due to not following the procedure ' Starting the wrong Emergency Diesel Generator dur.ing 'a test i due to not following the procedure !
Failure to properly -restore instrumentation following repair of steam generator level control gauge, and'an error-in calibration of power range nuclear instruments resulted - in Unit 1 operating above 101% power.
The Inservice. Inspection (ISI). program was examined during' this j assessment period.
These inspections included ' review of ISI implementing procedures, observation of inspection activities, i and review of ISI records.
The NRC staff concluded that the licensee's ISI program was adequate.
Staffing is adequate and ISI personnel are knowledgeable, well trained, and qualified to perform inservice inspections Responsible engineers evaluated I and resolved ISI findings in a timely and conservative manner.
The NRC staff also reviewed the licensee's -activities for detecting and correcting leaks in the Unit 1 steam generators j (SG). The licensee established a Steam Generator Tube Rupture { Recovery Team following rupture of a SG tube on _ Unit 1.
{ Licensee management as well as corporate personnel were actively l involved in evaluation of the tube rupture and ' determining corrective actions required to prevent recurrence of this event.
Resolution of the technical issues showed a clear understanding.
'; of the issites involved, was technically sound and thorough, and was conservative from a safety standpoint.
The licensee was particularly responsive to this issue by performing eddy current
testing on 100 percent of the SG tubes including hot and cold ' legs, , j 2.
Performance Rating i Category: 2 Improving H 3.
Recommendations . The areas of procedural adequacy and compliance continue to result in operational problems and, as noted in the previous SALP report, require additional management attention. Actions taken recently to restructure the station directives and clarify l
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the station philosophy on procedural compliance appear to be positive and should be pursued vigorously.
D.
Emergency Preparedness 1.
Analysis The emergency preparedness.-program at McGuire. received sufficient management support to ensure that the licensee maintained. the basic elements needed to promptly identify, correctly classify, adequately staff, and effectively implement.
the key elements of the Radiological Emergency Plan-and respective procedures in response to emergency events.
The emergency facilities were adeq'uate.
The Crisis Management Center was an excellent facility to perform the' functions required by an emergency operations facility (EOF).
The Technical Support Center (TSC) met regulatory criteria but is small with minimal work space for certain functions.
In 1986, in response to the Emergency Response Facility Appraisal in 1985, the licensee committed to construct a new TSC to provide.
additional work space.
The current schedule calls. for completion of the new TSC in June of 1992. Areas of strength noted were: the internal audits of the emergency preparedness program were detailed and comprehensive, and there was a strong commitment to provide emergency response-training to offsite support groups.
The emergency exercise conducted during August 1988, ! . demonstrated that the licensee could -implement the Emergency ' Plan and procedures.
The licensee demonstrated effective assignment of emergency response organization responsibilities; I took appropri ate actions to mitigate the - plant casualty; I promptly activated and _ staffed the emergency response -
facilities; and made the appropriate protective action recommen-
dations. Overall, the exercise-was considered successful.
An exercise weakness was identified, however, for failure of the Control Room Shift Supervisor to identify an Emergency Action
Level and promptly declare the respective Alert.
l The' licensee effectively implemented the Emergency Plan in
response to the steam generator tube rupture event, although there were several areas where the licensee noted improvements
could be made.
During the event, it was necessary to provide the NRC with a great deal of information.
The - licensee,. recognizing this, has added personne1' trained as Communicators
(SR0 qualified) to improve communications during prolonged j events.
Also, the licensee -has improved their system of R providing public information-by changing procedures to require. coordination with the NRC on press releases prior to the NRC's site team deployment. The licensee's policy regarding a release was changed to require that all releases, no matter how small,-
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J resulting from an event would be identified as releases.
The j licensee also worked effectively when hurricane Hugo struck the-i plant in September 1989..Although the Emergency Plan was never, ') entered, the plant staff responded to the threat to ensure plant i safety during this event, The licensee has' implemented appropriate administrative controls to ' ensure that the NRC will be notified in a timely manner regarding the Alert' and Notification System (ANS) -stren l failures.
Siren reliability for a portion of the_ McGuire ANS ' was low due to spurious activations and inoperable sirens identified during the_ periodic tests.
The licensee is in the
process of upgrading the entiro system to include a computerized control and feedback system for periodic system interrogation-and polling. The area showing low reliability was upgraded ~with a computerized co: trol and feedback system during 1989.
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The licensee maintained adequate equipment and a trained staff for responding to an. emergency.
The licensee continues to r maintain an effective emergency preparedness program as.
evidenced by the licensee's response to simulated and actual , ' emergency events.
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Performance-Ratina.
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Recommendations l l In response to the -- 1985 ERF ' Apprai sal, _ the licensee has ' committed to address the difficulties found in the TSC.
Completion of the new TSC is scheduled for-June 1992. Some of r the communication difficulties. observed during the March 7,1989 event may have been a result of the facility design.
The , licensee is encouraged to maintain the current schedule for l construction of the new TSC.
E.
Security and Safeguards 1.
Analysis
i l Security Force staffing levels and -training appeared to be l adequate, although many of the deficiencies identified with regard to access control and maintenance of required
compensatory measures involved failures of plant and security i personnel to comply with established procedures and licensee
policy.
In all cases, the personnel involved had been trained in the correct procedures regarding-access control _ and compensatory measures, but failed to perform in accordance with i those procedures.
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The licensee experienced numerous problems relating to ' the protected and vital area access control-program during this
assessment period. These problems, which were identified by the , licensee, included several instances in which security badges: and keycards were incorrectly issued, vital area access improperly authorized, persons -admitted to the Protected Area ' without being issued a security badge, security badges not removed from the. badge issue area (although the-individual.'s > access authorization had been terminated), and. admittance of persons to the protected area without _an adequate search.. The apparent failure of ~ personnel to. comply with access ' control i procedures raised questions' concerning the effectiveness. of the licensee's program to - control access-to plant safety-related systems and was the subject of an Enforcement Conference' held in August 1989.
At this conference, the licensee acknowledged the occurrence of the access control failures and presented-the corrective actions undertaken or planned to address this area.. The licensee is proceeding with.a program to resolve previously identified inadequacies with the closed circuit television l system used for Protected - Area alarm assessment.
Action to _ address this concern started late in the previous SALP period.
, , i The licensee identified.a' number of cases. in which security officers who were posted to compensate for' degraded security equipment were withdrawn before the degraded. equipment was , returned to service.
, Licensee security, contingency, and guard training; and qualification plan change submittals have been well ' coordinated and technically sound.
Changes to :these plans were made' ' appropriate under the provisions of 10 CFR 50.54(p).- , 2.
performance Rating Category:
3.
Recommendations We are concerned with the continued failure to implement provisions of the Physical Security program which have resulted in repetitive violations. relating to access control and failure-to provide required compensatory measures. The apparent-lack of management oversight is of significant regulatory concern because of the licensee's repeated-identification of ' issues-involving noncompliance without taking corrective actions.
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Engineering / Technical Support 1.
Analysis , Special inspections this assessment period which included: a review of engineering and technical support performance were the Maintenance Team Inspection and the Operational Safety Team-Inspection. Although some design control deficiencies were , identified,-performance in this functional area was adequate, t The licensee was generally timely in initiating corrective-actions for identified weaknesses and demonstrated responsiveness to NRC initiatives.
The licensee has been aggressive.in ' evaluating issues with potential impact on operability or design margin. For example, flow balance testing to the Auxiliary Feedwater System, an extensive raw water systems evaluation, and identification and .' evaluation of containment-structure corrosion.
Several plant problems identified were attributable to corporate or onsite engineering performance deficiencies.
The corporate engineering organization, Design Engineering (DE), is responsible for design activity.at McGuire.
Inadequate post l modification functional test development. by the onsite engineering organization contributed to a violation relating to inoperability.of safety systems due to repositioned. sliding links and miswiring during: valve modifications.
Engineering i evaluation of alternate containment ventilation operational modes for Hydrogen Skimmer system operability concerns did not identi fy that system operation deviated from FSAR system description.
A civil penalty was issued in conjunction with this issue. Towards the end of the assessment _ period, a violation was identified f or inadequate initial design controls ! of the Control Room Area and Annulus Ventilation systems.
Although the initial design deficiency occurred prior to this assessment period, the licensee was slow in identifying Annulus Ventilation system deficiencies despite an applicable ' information notice available early in the assessment period.
Corrective actions for identified design engineering deficiencies were comprehensive and effective.
Programmatic ' controls for design development and safety analysis were revised to emphasize post modification testing and acceptance criteria.
In November 1988, DE was reorganized, providing dedicated engineering resources to each Duke Power Nuclear station.
Approximately 160 engineers were dedicated to provide McGuire plant support.
Design Engineering management was agressive in evaluating staff performance.
For example, the Nuclear Production and Construction departments were required to provide quality feedback regarding DE support; a comprehensive and - -
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_ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ - - - _ _ - _ _ _ - _ _ _ . ! . ., , e' . .t ., 18- - i thorough evaluation was performed of previous modification program improvements (TOPFORM improvement program of previous I assessment period); and teams were'. established to verify consistent performance by all DE project groups. Post-fire safe shutdown and Appendix R considerations have - been effectively
incorporated into the design change program.
The small onsite-DE group was effective.in coordinating activities and improving communications between the. plant and
DE. Additionally, off site DE personnel frequently l visit-the plant, providing increased familiarity with' plant conditions.
The coordination of plant..and corporate engineering. l organizations was good as demonstrated by several issues this
assessment period.. An example.of this coordinated effort
included the investigation and evaluation of. fraudulent parts in ! safety related breakers which was beyond associated-NRC. Bulletin recommendations. Technical support coordination-and performance was good on-follow-up activities for the plant events related'to the Unit 1 Steam Generator-Tube Rupture and. the Unit -2: . Containment Spray System.over pressurization.
, i Plant support by the onsite engineering organization has'been l effective although a need for improvement was identified in post i modification test development activity as previously discussed.
l The maintenance. engineering group has provided strong technical support to maintenance.
For example,,the Service Water System- ' performance evaluations, response to' generic nuclear plant check-valve problems, and the establishment of an on-line system to ' monitor Component - Cooling. Water System -heat exchanger fouling ~ c demonstrated effective plant-support.
The Project : Services group also provided effective' onsite engineering 'and technical- . support in their coordination of modification implementation activity with DE and administration of the Station. Problem Report (SPR) program. The SPR program has provided an effective: mechanism for identification and documentation 'of plant
problems. A formalized system expert program was implemented i this assessment period to enhance site engineering support.
activities.
Licensee response to NRC initiatives was evident in site activity enhancements related to temporary modifications and.
environmental qualification programs.
Additional program controls were implemented to resolve-NRC identified-weaknesses-in the temporary modification program, j Technical support activities of Nondestructive Examination (NDE) - and Environmental Qualification (EQ) have been adequate this assessment period.
Review of NDE program controls, implementation, and personnel qualification and performance identified these activities were adequately. controlled and implemented by qualified personnel.
Efforts -initiated 'to enhance EQ program performance include a design study to update . -. .. . - - - -. -.
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the EQ equipment reference documents-and a' review of station l procedures to verify incorporation of EQ maintenance , requirements.
These enhancements have improved performance and r documentation of EQ related design and maintenance activity.
2.
performance Rating
Category: 2 Improving [ 3.
Recommendations . Continued management attention relative to aggressive and timely' pursuit of problems requiring engineering evaluation is ' ' recommended.
G.
Safety Assessment / Quality Verification i 1.
Analysis ! i Overall corporate management leadership,- direction and support were good.
Effective management involvement in site activities . associated with -licensing areas was evident' through prior ' planning, assignment of priorities, and - decision making-processes.
Management was well aware of generic and plant-specific safety. issues and-the schedule. for their resolutions.
The - licensee understands the technical -issues and considers carefully the impact of various NRC requests and positions on-the plant.
. Conservatism was generally exhibited in the licensee's approach to the resolution of~ technical' issues from a i safety standpoint, and the approaches are generally sound and thorough. This was indicated,in the evaluation of the impact of the waste handling building on the auxiliary building filtered-i ventilation exhaust system for the proposed.TS change to that ventilation system, and in the evaluation of the proposed LCO l extension to facilitate modification of 'the control room ventilation system.
The licensee makes' effective use of meetings-with the NRC when ' l, appropriate to resolve - licensing issues.
The licensee is generally well prepared and-provides ample support for its l- - positions during such meetings.
This ~ was exhibited during t meetings on quality assurance, inspection of Unit 2: steam ? generator tubes, restart of Units 1 and 2-following the. Unit 1.
steam generator tube rupture event and fouling of raw water heat exchangers.
The - licensee reduced staffing levels; however, this reduction did not significantly affect the performance of the station or s the licensing personnel who were reorganized under a regulatory compliance group.
Although some indication of manpower . - .
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limitations -is exhibited during periods of peak licensing activities, the overall staffing to support licensing activities is adequate.
The McGuire Safety: Review Group (MSRG) functions to observe plant activities through' independent surveillances, investi-gation of events and development of Licensee Event Reports including corrective actions. Occasionally, root cause analysis of events is weak; and, therefore, preventive ' actions :are ' .i incomplete.
Examples were failure to identify. program weaknesses for training / relative to modifications, control of containment penetrations and control of ' non-safety related-components for air-operated: valves. Violations were-issued'for each of these.three occurrences, i The Licensee Event Report (LER)' program was: adequate. Generally ' the quality.of the LERs' was good, describing the major aspects of the events. root causes and the licensee's corrective actions.
The reports were thorough, detailed, well written and: , easy to. understand.
Problems have. been identified with root cause analysis as mentioned above, l Generally the licensee appears to have a broad based program for , , ! self-assessment which is usually. aggressive.
.The Quality- ! i-Assurance Department conducts corporate audits of. plant { i activities as well as numerous surveillances with the onsite j surveillance group.
The corporate QA. audits remain heavily weighted toward documentation review.- A consultant was used for.
< a fire protection' audit, and a Senior Reactor Operator from -{ L another Duke. plant participated. in an audit.
The corporate
auditors are completing extensive operations training (46 j weeks).
On-site surveillance personnel have completed this - training, ' The corporate QA program is complemented by a diverse on-site ! I surveillance program often weighted toward field observations.
! Findings were well supported and were more significant than minor paperwork problems, and indicated a good technical' i knowledge of activites associated with an ' operating plant.
It-is noted that the Quality Assurance Department isiin a lead role ,
for-the-Self Initiated Technical-Audits (SITA) and previous NRC ' review has shown these audits to be thorough and valuable.
A SITA identified design deficiencies in the diesel generator i starting air system which was subsequently corrected.
The former site QA Manager is presently in.SRO school which will j
further bolster QA Technical-expertise.
Also an experienced former Maintenance Superintendent has been added to the' SITA staff.
The licensee has been very aggressive in the development and' implementation of a program to perform 10CFR50.59 safety i ? -- .,
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I ' . evaluations.
During the SALP period NSAC-125, " Guidelines For ) 10 CFR 50.59 Safety Evaluations," was issued. The-licensee had ' been monitoring the development of - the guidelines and has-developed their own program in parallel.
The current licensee program is in the process of being revised to both bring it into conformance with the final version of the guidelines and to assure conformity between _ the various groups which perform the j evaluations.
The licensee also has a problem investigation process. Problem Investigation Reports (PIR) are issued to document problems and assure ' adequate specific-and preventive corrective actions: are implemented. Sensitivity to issuance of PIRs varied among site: , groups, and one violation was issued for three examples of failure to issue PIRs.
0verall the'PIR program has been an-effective tool in documenting and correcting problems.
A weakness was identified relative to the program:for followup of NRC Information Notices. Untimely followup occurred relative , to two notices involving inadequate surveillance' testing of Main Steam Isolation Valves and inadequate design and testing of the.
' Annulus Ventilation System.
l 2.
Performance Rating i Category:
l l 3.
Recommendations i None V.
SUPPORTING DATA
' A.
Escalated Enforcement Actions i 1.
Civil Penalties /No Civil Penalties Severity Level III violations (2), 50-369,370/88-24,88-29;
$37500 Civil Penalty issued for' inoperability of the Hydrogen ! Skimmer System and failure to' perform.a 10CFR50.59 ~ safety evaluation.
_ Severity Level III violation, 50-369,370/88-24,88-29; no : CP, issued for inadequate post modification / post maintenance -) testing.
, 2.
Orders None - .
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Management Meetings August 10, 1988 - Management Meeting held at Region II to discuss past performance.
October 20,.1988 - Management Meeting held at McGuire to present SALP report October 27, 1988'- Enforcement Conference held in Region II to i discuss operability of the Hydrogen ~ Skimmer l System and adequacy of Post Modification / Post ! Maintenanc.e testing.
! December 9, 1988 - Management Meeting held at Region II to discuss j Duke Power Company's (DPC) reorganization.
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April 28, 1989 - Enforcement Conference held in' Region II to- ! discuss concerns regarding the interface between ' the Diesel Generator Starting Air, System an'd the Instrument Air System.
j May 25, 1989 - Management Meeting held at Region II to discuss-I i DPC Nuclear Plant Design Basis Documentation L Program.
! June 21, 1989 - DPC/NRC Interface Meeting held at McGuire site.
August 29, 1989 - Management Meeting at Region II to discuss licensed operator medical exam two year requirements.
, . August 29,'1989 - Enforcement Conference held in Region II to
discuss potential safeguards violations.
, October 20, 1989 - Enforcement Conference held in Region II to
discuss problems with the Control Room Ventilation System and Annulus Ventilation
System.
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Confirmation of Action Letters (CAL) ) April 19, 1989 - CAL issued on McGuire Unit I regarding the recovery i actions to be taked prior to restart following the steam. generator tube rupture event on March 7 1989.
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. D.
Review of Licensee Event Reports (LER) During the assessment period, a total of 69 LERs were analyzed (57-for Unit 1 and 12 for Unit 2). The distribution of these events by- ! cause, as determined by the NRC staff, is as follows:
Cause Unit 1 Unit 2 Total.
Component Failure
2
Design ~
1
Construction, Fabrication,
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or Installation i Personnel Error - Operating Activity
1 8- - Maintenance Activity
1
- Test / Calibration Activity
3 14- - Other
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- Other
2
i Total 57-
69 i ! Note 1: With regard to the area of " Personnel," the NRC considers-lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.
Note 2: The "Other" category is comprised of LERs where there was a - spurious signal or a totally unknown cause.
E.
Licensing Activities -
. During the assessment period the staff completed approximately 60 licensing actions.
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Enforcement Activity No. of Deviations and Violations in Functional Each Severity Level (Unit 1/ Unit 2)
Area Dev.
V IV III II I Plant Operations 6/6 Radiological Controis 1/1-Maintenance / Surveillance: 8/7 1/1.
Emergency Preparedness 1/1-Security 2/2 Engineering / Technical 1/1 3/3 2/2 Support . Safety Assessment / Quality 1/1 Verification TOTAL 1/1 1/1 21/20 3/3 G.
Reactor Trips 1.
Unit 1 Automatic Reactor Trips August 26, 1989, the unit tripped.from 100% power from a Reactor Coolant low flow signal caused by a failed Universal board in the Solid State Protection System cabinet.
Manual Reactor Trips March 7, 1989, the unit was manually tripped due to a tube rupture in the Steam Generator.
' 2.
Unit 2 , Automatic Reactor Trips March.3,1989, while performing a control. rod movement test, a high negative neutron flux rate trip occurred because of control rods dropping into the core. The cause of the control rod drop was not determined.
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March 14, 1989, the "B" train Feedwater - Pump Turbine tripped.
During the ensuing ' runback, the Generator Load Rejection Bypass valve failed to open and the reactor tripped on Low-Low level.in the "B" Steam Generator. Equipment failure caused the Feedwater Pump Turbine trip and the failure of the bypass valves.
. April 6,1989, the reacter tripped on Low-Low Steam Generator-level on - the "C" Steam Generator, when the bellows in the positioner for the Feedwater Regulating Valve for the "C" Steam Generator failed.
H.
Unscheduled Manual Shutdowns 1.
Unit 1 June 30, 1989, the Digital Electro Hydraulic (DEH) - turbine control system malfunctioned.
Leading to erratic behavior of the turbine governor valves. Despite sudden megawatt decreases the licensee successfully shutdown the plant without a trip.
2.
Unit 2 October 31, 1988, the unit was taken off line to plug a condenser tube leak.
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