IR 05000395/1993007
| ML20036A813 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/30/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20036A802 | List: |
| References | |
| 50-395-93-07, 50-395-93-7, NUDOCS 9305170039 | |
| Download: ML20036A813 (23) | |
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ENCLOSURE INITIAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
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I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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l INSPECTION REPORT NUMBER l
50-395/93-07 SOUTH CAROLINA ELECTRIC & GAS COMPANY
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VIRGIL C. SUMMER NUCLEAR STATION
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SEPTEMBER 1, 1991 THROUGH FEBRUARY 27, 1993 a-t l
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9305170039 930430 PDR ADOCK 05000395-l G
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i SUMMARY OF RESULTS t
During the assessment period, V.C. Summer was operated in an overall safe manner. The performance of V.C. Summer was assessed as being
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superior in the functional areas of Plant Operations, Radiological l
Controls, Maintenance / Surveillance, Security, and Safety
Assessment / Quality Verification.
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Both Emergency Prepare ( ess and Engineering / Technical Support received
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successive good ratings with Emergency Preparedness performance i
demonstrating an improving trend.
Engineering / Technical Support
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attention should be focused on the thoroughness and timeliness of
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corrective actions.
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The number of trips and forced outages related to equipment failures l
increased this assessment period. These equipment failures, procedural
and labeling deficiencies, and the reactor vessel partial draindown incident caused by a surveillance test, contributed to a declining trend i
j in the Maintenance / Surveillance area.
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Performance ratings for the last rating period and the current period l
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are shown below.
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Last Period This Period i
Functional Area 5/1/90 - 8/31/91 9/1/91 - 2/27/93
i Plant Operations
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Radiological Controls
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Maintenance / Surveillance
1 Declining
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2 Improving Security
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Engineering / Technical
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Support
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Safety Assessment / Quality
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Verification t
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f III. CRITERIA
The evaluation criteria which were used to assess each functional area
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are described in detail in NRC Manual Chapter 0516, which can be found
in the Public Document Room. Therefore, these criteria are not repeated here, but will be presented in detail at the public meeting to be held i
with licensee management on May 12, 1993.
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IV.
PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis This functional area addresses the control and performance of activities directly related to operating the unit, as well as fire
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protection.
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Plant operations continued to be performed in a safe and conservative manner. The low number of plant transients were the
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result of effective and careful plant operations. The 1992 yearly
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unit capacity factor of 96 percent was the highest ever achieved i
by the plant. There was one reactor trip due to a maintenance
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activity, and two trips due to equipment failure.
In addition, j
there were two forced outages.
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Management involvement was viewed as a key element in the successful operation of the plant. During outages and shutdowns,
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management support was noteworthy in minimizing challenges to the l
plant and promoting safe operations. The management support for i
the reactor trip and natural circulation flow event was provided
by manning the technical support center (TSC) in a manner similar j
to the structured TSC organization specified by the emergency plan.
Control of this potentially significant event was enhanced j
in part by management's ability to assess the cnndition of the
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plant, and respond appropriately.
Evolutions such as plant
shutdowns and start-ups, reduced reactor coolant system (PCS)
inventory operations and complex testing also received increased
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management involvement. This was provided by management presence i
on backshifts, prejob briefings and dissemination of expectations j
to all involved personnel.
Operators continued to demonstrate a high level of performance
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during both routine plant operations and in response to l
Excellent communication skills, which routinely i
included repeat-backs for message acknowledgement, helped minimize operator errors. During the reactor trip and natural circulation
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flow event, the operate-s took prompt action to verify plant
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parameters and to maintain the plant in a safe and stable i
condition.
Similar excellent performance was observed during the loss of one offsite power supply event, and during another event when prompt i
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operator action to correct decreasing deaerated water tank level prevented a reactor trip.
Shift turnovers were routinely attended by representatives from support organizations and management
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personnel.
Effective communication of the plant status and
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upcoming activities for operators and support groups during the
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shift turnovers contributed to successful plant operation.
i Operation's staffing levels consistently exceeded the regulatory requirement of seven crew members and routinely exceeded the
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minimum level of ten established by the licensee. The average i
crew size was 13 members. Adequate staffing levels were provided for additional operator functions such as fire brigade manning.
During the assessment period, 14 operal s received their reactor
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operator's license.
This permitted the movement of licensed operators into support groups, i.e., procedure writing, scheduling
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4 and training, while still maintaining ample staff on the operating crews.
The addition of two new shift engineers from the training and
operations departments increased the knowledge level of shift engineering and allowed the movement of experienced shift
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engineers to other departments. Shift engineering continued to
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provide an effective interface between operations and maintenance
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while satisfying the requirement for the shift technical advisor e
position.
Configuration control problems identified during the previous SALP i
period did not recur in this SALP period with the exception of a
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few isolated examples associated with a lack of attention to detail.
Examples included hanging a Danger Tag on the wrong valve
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during an emergency diesel generator tagout, opening a containment
isolation valve when a technical specification (TS) action
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statement required the valve to remain closed, and an incorrect j
line up of an emergency diesel generator airstart system that resulted in overpressurization of an air receiver tank. While the
individual significance of each instance was relatively minor, the
number indicates this is an area where there is still room for improvement. The licensee's corrective actions effectively
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addressed each separate event. Corrective actions appeared to be
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appropriate.
l The fire protection program was considered a strength in terms of programmatic controls and implementation of program requirements.
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The inspection of fire barriers was effective in routinely
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identifying degraded barriers that were promptly resolved.
Fire drills were performed well with the drill critiques effective in
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identifying improvement areas. The position of fire protection officer provided the overall coordination for implementing the i
fire protection program and was a key element of the program's j
success.
j One cited violation was identified during the assessment period.
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2.
Performance Ratina Category:
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3.
Board Recommendations None.
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Radioloaical Controls 1.
Analysis
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This functional area addresses those activities related to radiation safety, radiological effluent control and monitoring,
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and primary / secondary chemistry control.
Overall, the radiation protection program continued to effectively control personnel exposure to radioactive materials and protect j
the health and safety of plant personnel and the public.
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Management involvement in radiation protection was observed to be l
strong. This was evidenced by appropriate staffing levels with
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experienced radiation protection personnel, a strong ALARA
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awareness program, and management support for proactive dose
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reduction initiatives and goals. The combination of Health l
Physics and Radiological Wastes under a single Manager resulted in t
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more effective overall management. The licensee had an_ effective
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audit program and acted with responsive and timely corrective j
actions to audit findings.
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The training program for the health physics staff, including l
radwaste and transportation training, continued to be effective
this SALP period. Also during this SALP period, the licensee
implemented appropriate procedural revisions to ensure that a l
formal training and retraining program for the Chemistry and j
Health Physics non-licensed unit staff was established and documented. The effective implementation of this training program i
corrected a weakness which was identified during the previous period with the licensee's program for training non-licensed
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staff.
l The external and internal dosimetry programs and the respiratory
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protection program were well implemented. One relative weakness l
i was identified regarding several examples a lack of timely follow-
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up in assessing internal exposures. The safety significance of
the internal exposures was minimal, and the licensee implemented l
procedural revisions which improved guidance regarding making i
timely assessments. As part of the effort to prepare for the
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reduced individual exposure limits of the revised 10 CFR Part 20, j
the licensee has procured face shields (to be used in lieu of
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respirators), shielding packages, and remote video cameras. The
licensee plans to use these during certain high dose outage job evolutions in an effort to reduce external exposures, j
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Efforts in ALARA during both routine operations and a refueling i
outage were strong. Successful efforts during this assessment l
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period included: implementation of a Reactor Coolant System (RCS)
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fine mesh filter program, which resulted in an estimated 25
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percent decrease in cobalt activity in the RCS; a permanent
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reactor vessel head shield; an electronic dosimetry system; and surrogate video tour units.
The licensee's collective dose during
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j this assessment period was approximately 316 person-rem with j
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approximately 285 person-rem accumulated during the outage. The j
collective dose appeared to be appropriate for the scope of work j
performed. Collective dose in the previous assessment period,
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which did not include a refueling outage, was 89 person-rem.
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I Licensee performance in contamination control continued to be
excellent.
Less than one percent, approximately 746 ft, of the i
total of over 133,000 ft of radiologically controlled area was
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controlled as contaminated. Additionally, the number of personnel l
contamination events (PCEs) decreased from 122 during the previous i
assessment period to 98 this period.
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The licensee's program to monitor and quantify radioactive
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effluents was good. There were no unplanned or abnormal releases
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during this SALP period. The calibration and maintenance of j
monitors was performed as required by the Technical Specifications
(TSs). The Radiation Monitoring System was adequately maintained.
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One problem in this area involved two instances of failure to set l
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radiation monitor in accordance with the Offsite Dose Calculation
3 Manual (0DCM). Although the alarm and setpoints were higher than i
j allowed by ODCM methodology, neither release limits nor regulatory
exposure limits were exceeded during these two liquid effluent l
releases. The licensee successfully analyzed both the beta
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i emitter radioisotope samples as well as all gamma nuclides
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provided to the facility by Region 11 as part of the NRC's Confirmatory Measurements Program, The licensee's program for monitoring primary and secondary
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chemistry was good.
Primary chemistry parameters covered by TSs
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were maintained within specified limits.
Secondary and other non-i TS primary chemistry parameters were generally maintained within
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the licensee's administrative limits.
In those few cases where i
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the latter parameters were exceeded, prompt corrective actions
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j were taken to return them to acceptable levels.
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The radiological environmental monitoring program was completed in
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i a thorough manner.
For this period, environmental results showed i
that there were negligible radiological exposures attributable to i
the operation of VC Summer due to airborne, waterborne, aquatic, a
ingestion, or direct exposure pathways.
In this area, one problem
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I was noted for a failure to perform proper tritium background
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corrections, for surface waters, as defined in the ODCM. There
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were no exposure limits exceeded due to these background
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inconsistencies.
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No cited violations were identified during the assessment period.
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Performance Ratina
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Category:
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Board Recommendations l
None.
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C.
Maintenance / Surveillance 1.
Analysis
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This functional area addresses those activities related to i
equipment condition, maintenance, surveillance performance, and equipment testing.
In addition to the routine inspections in this
area, an Electrical Distribution System Functional Inspection
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(EDSFI) was conducted during this assessment period.
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r The plant maintained a high capacity factor and safety system l
availability due in part to effective maintenance and testing.
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Diagnostic programs such as lube oil analysis, vibration l
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monitoring, and thermography were considered strengths and l
contributed to the successful operation of the plant. The overall
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material condition of the plant continued to be a strength.
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However, there was one reactor trip due to a maintenance activity, and two trips and two forced outages due to equipment failure during this assessment period. This was a decline in this area of l
performance from the previous assessment period which had no
reactor trips or forced outages due to maintenance activities or i
equipment problems.
Licensee management was actively involved in the maintenance process. Management was frequently in the plant and provided
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oversight during key maintenance and testing activities. The l
maintenance organization was adequately staffed and trained to e
support plant operations.
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The licensee was appropriately sensitive to the risks associated with maintenance and surveillance activities. The prioritization and scheduling of maintenance activities reflected the safety
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significance of the item. The licensee consistently held prejob
briefings prior to infrequently performed surveillances or complex tasks. These briefings were attended by a management representative who ensured the participants understood their i
duties and emphasized the safety implications of the task. These briefings were considered a strength and contributed to the low i
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number of inadvertent safety system actuations associated with
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maintenance and testing. The licensee consistently used the l
correct parts and tools for maintenance.
The lubrication program j
was effective in providing the correct lubricant for equipment.
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The overall findings of the EDSFI were generally positive,
reflecting good maintenance, testing, and equipment material
condition. However, several items of concern were noted.
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Examples included the failure to properly maintain the cathodic
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protection system to provide the intended protection for the i
emergency diesel generator (EDG) underground fuel oil tanks and
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piping, and overcurrent trip testing not being performed on
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important molded case circuit breakers used as feeders for the 125
VDC load center buses.
Prompt corrective action int.luded
inspection of the EDG underground piping and replacement of the
molded case circuit breakers during the subsequent refueling
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outage.
Several deficiencies were noted this period in the area of procedural adequacy and procedural compliance.
Examples included:
l (1) Two procedural deficiencies were identified for the integrated
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safeguards test.
(2) Procedural instructions were not followed i
during the change out of the main lube oil duplex strainer
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elements for an EDG.
(3) A mispositioned switch was identified on
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a local control panel for the containment hydrogen analyzer even though the applicable test procedure provided three opportunities i
to ensure the switch was correctly positioned.
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l An additional area of relative weakness impacting maintenance and surveillance was plant labeling.
Inconsistency between equipment
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designations in procedures and labeling of equipment in the field i
led to personnel errors this period. An example of this involved
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a missed TS surveillance requirement for testing the local manual i
shunt trip for the reactor trip bypass breakers. A problem was
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also identified with inconsistent labeling between switches on the
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local EDG control panels and the field labeling of the equipment
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associated with these switches. This contributed to an air start
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receiver being overpressurized during a maintenance activity due to confusion over the correct position for a switch. Additionally i
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t it was noted that plant personnel have occasionally " penciled in"
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corrections on, or adjacent to, the permanent plant label.
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i During this assessment period there was one reactor trip due to maintenance activities. The maintenance activity involved
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replacement of the high voltage power supply for one of the
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nuclear instruments.
I&C technicians incorrectly assumed a
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capacitor in the nuclear instrument drawer was isolated by removing fuses in the front of the drawer. When the capacitor was
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discharged a spike occurred which resulted in a reactor trip. The technical manual for the nuclear instrumentation provided instructions for power supply replacement which would have l
prevented this trip. The technical manual was not referenced in
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l this procedure. Management oversight and prejob briefings i
improved. As a result, I&C maintenance activities showed
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substantial improvement.
Subsequently, several maintenance
activities in the 7300 series process racks were identified as i
strengths.
i The licensee continued in developing a Reliability Centered
Maintenance (RCM) program. The analysis of 55 systems was
completed. The RCH program will encompass approximately 90
systems upon completion.
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The surveillance test scheduling was performed well with the exception of two missed TS surveillances. One case involved a
computer malfunction which resulted in a missed surveillance for axial flux difference. The other case involved a missed explosive i
gas sample due to personnel error.
j Overall implementation of surveillance activities was good.
f Efforts by the test group to provide consistency for testing i
methodology and data review have resulted in a strong surveillance program. Test equipment used for surveillances were within their i
calibration due dates and appropriate for the task. An exception to this involved a strip chart recorder with a non-isolated input
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amplifier which was connected to a pressurizer level channel during an accumulator. check valve test. The_ strip chart recorder
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developed an internal ground, and due to it being non-isolated, a
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ground loop feedback into the pressurizer level circuitry was
introduced. This ground loop feedback resulted in false
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indication of pressurizer level, which resulted in a RCS drain down farther than planned for the surveillance test procedure
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(STP).
Partial voiding in the reactor vessel head resulted from
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the excessive drain down.
Three violations were cited in the Maintenance / Surveillance area l
during the assessment period.
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Performance Ratina
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Category:
1 (Declining)
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Board Recommendations
Management attention should focus on the negative trend indicated by several reactor trips, forced outages, and the partial draining of the reactor vessel all of which were related to maintenance o-surveillance activities, or other equipment performance issues.
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D.
Emeraency Preparedness
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Analysis i
i This functional area addresses activities related to the implementation of the Emergency Plan and procedures, training of l
onsite and offsite emergency response organizations, licensee
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performance during emergency exercises, maintenance of facilities, l
and staffing.
- The Emergency Preparedness (EP) program continued to receive i
adequate management support to ensure a state of readiness for
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responding to emergencies. Specifically, the licensee took
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actions to improve training for the Control Room staff via
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quarterly simulator drills. The licensee's Emergency Preparedness and Operations staff evaluated the drills in the areas of plant operations, event classification, notification, and completeness of notification forms. Also, management's involvement in the
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installation and modification of the Early Warning Siren System l
(EWSS) was successful in resolving previous problems associated l
with spurious activations.
The emergency response facilities (ERFs) and equipment, were generaly maintained in good condition and in a state of readiness.
l However, equipment maintenance problems were identified with air sampling equipment. Two portable air samplers assigned to offsite monitoring team kits exceeded the calibration frequency due dates.
i Also, the adequacy of acceptance criteria for audibility testing of the plant alarm system was a concern. The weekly alarm (fire, evacuation, and radiation) audibility tests were considered acceptable based solely on alarm audibility within the Control Room. Other plant locations, particularly high-noise areas, were not checked for audibility.
Modifications were made to the emergency planning zone (EPZ)
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warning system to resolve previous operability problems. The annual operability for 1991 was 88.9%.
Following the system upgrade, which included a computer controlled activation and
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polling system for monitoring each siren status, the operability increased to 96.3% for 1992.
The licensee's performance during an off-hours annual exercise and a backup Emergency Operations Facility (BEOF) drill, demonstrated that staffing was adequate for responding to simulated emergencies. With one exception, the facilities were activated in a timely manner. The one exception involved approximately 13 minutes in excess of the stated goal for activation of the BE0F.
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In response to problems identified during the previous SALP period, improvements were made in the emergency preparedness training area to prevent personnel with expired training from i
being assigned to the emergency response organization (ERO). A
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computer based tracking system combined with a manual system was
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effectively implemented for tracking ERO training to ensure that personnel training was current. Other training enhancements included a job task analysis of key EOF positions and performance
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of drills or exercises in excess of those required by the Emergency Plan.
Training for Emergency Communicators however was not adequate
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during this period. As part of the NRC's exercise inspection activities, interviews were conducted with individuals designated as Emergency Communicators regarding ERO pager activation during of f-hours.
Interviewees provided incorrect or incomplete information. As a further indication of inadequate training, during the exercise (discussed below) additional Communicator problems were noted.
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The licensee's performance during the annual exercise, an NRC observed simulator drill, and interviews with response personnel,
demonstrated the overall capability of implementing the Emergency
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Plan and other procedures that provide for the health and safety of the public during a radiological emergency. The emergency classification procedures were effectively used to promptly and correctly classify the scenario accident.
The licensee's protective action recommendations (PARS) were in accordance with procedural requirements and were provided to offsite authorities
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in a timely manner.
j During the exercise two aspects of communication problems resulted in exercise weaknesses. One weakness resulted when the Control
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Room Communicator failed to provide correct information to offsite
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authorities, during the initial follow-up message, regarding the incident status and plant conditions nd inadequate information was provided regarding the location and status of a simulated accident victim requiring offsite medical support. A second weakness resulted from intra-plant communications performance.
Key accident assessment personnel in the Technical Support Center
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(TSC) delayed the flow of information between the TSC and the Emergengy Operations Center (EOF) regarding conditions for incident upgrade. Consequently, the delay resulted in the event upgrade from an Alert to a Site Area Emergency approximately 16
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minutes after the emergency action level was met.
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The engineering accident assessment team functioned effectively in
analyzing the plant status. Good recommendations regarding
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mitigating actions to reduce damage to plant equipment, to prevent release of radioactive material, and to terminate the emergency
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condition, were provided.
During the assessment period, the licensee initiated a self assessment program that was analytical and objective, and served
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as an enhancement to the independent audit performed by the
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Quality Assurance Group. The licensee's interface with the i
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offsite authorities in the areas of training, and Emergency Plan
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changes were considered a program strength. The licensee
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submitted one proposed change requesting review and approval by j
NRC prior to implementation, and two Emergency Plan Revisions.
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l The revisions were deemed acceptable and were submitted in a l
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timely manner.
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Two exercise weaknesses and no cited violations were identified
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during the assessment period, f
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Performance Ratina
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Category: 2 (Improving)
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Board Recommendations i
None.
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Security
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Analysis j
This functional area addresses those security activities related
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to protection provided for the station's vital systems and
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equipment, special nuclear material, and the Fitness for Duty
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Program.
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During the assessment period, the licensee implemented and managed l
an effective security program.
Strong security support by j
management was evident, in part, by many program improvements l
implemented since the last assessment.
Examples of these l
improvements included enhanced assessment capabilities and
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improved access control and perimeter detection equipment.
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I The licensee upgraded their protected area perimeter microwave
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detection equipment. This improved the effectiveness and
efficir:.1cy of the security personnel by eliminating most of the
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nuisance and false alarms initiated by the older equipment. The installation of this equipment and the continued excellent testing
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l and maintenance support provided by the Security Maintenance
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Section has resulted in improving the equipment availability time.
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l The security equipment events have also been greatly reduced for j
the same reason.
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The licensee effectively staffed, equipped, and trained the security force for their assigned duties. The licensee's security
training staff was dedicated and knowledgeable. The security
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i tactical response team recently placed 5th out of 29 participates
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in a national competition evaluating marksmanship. The security
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force had a low turn-over rate during this period helping to t
maintain a well qualified staff.
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l Other areas of the licensee's security program were enhanced
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during this period.
For example, the licensee replaced the vacuum i
tube closed circuit television (CCTV) cameras with solid state
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color cameras and installed 21" color monitors in the alarm stations. The primary and alternate access portals were i
reconfigured to enhance control of packages, personnel and l
vehicles entering the protected area. Upgrading the x-ray l
equipment with larger off-the-shelf monitors greatly enhanced the detection capabilities of this equipment. Additionally, improved l
metal detectors were installed. These enhancements of the
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protected area detection system, access control detection
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equipment and the alarm stations' assessment capabilities typified
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management's efforts to provide a strong security program.
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Capable and knowledgeable personnel operated the security
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equipment associated with the alarm stations.
The licensee's
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audits of the security program were thorough and productive.
j Non-reportable safeguards logged events were reduced by i
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approximately 50% over the last assessment period, indicating l
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improved performance.
The licensee's three Physical Security, and two Training and
Qualification Plan revisions submitted during this period were consistent with 10 CFR 50.54(p), and were timely and adequately
coordinated with the NRC.
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l No cited violations were identified during the assessment period.
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Performance Ratina
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Category:
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Board Recommendations i
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Enaineerina/ Technical Support f
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Analysis This functional area addresses activities associated with the f
design of plant modifications, and technical support for i
operations, outages, maintenance, and licensed operator training.
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l The licensee's performance in providing engineering and technical
support was satisfactory during this assessment period.
Engincaring management was actively involved in the day-to-day resolution of technical problems. Aggressive engineering involvement in major issues continued.
Examples included the i
resolution of emergency core cooling system (ECCS) flow balancing i
problems, steam generator replacement planning, and a strong 50.59 j
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program. Diagnostic programs such as lube oil analysis, vibration
analysis, and thermography were identified as strengths and contributed to the successful operation of the plant.
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engineers' knowledge level and ownership of their systems improved i
during the assessment period. However, during the period some i
problems occurred due to lack of timely and thorough engineering
evaluations.
Engineering efforts to maintain control of the design of the plant r
were generally good. The licensee has taken an initiative to
implement a Design Basis Documents (DBD) program.
Inspections in i
the area of electrical design revealed that the electrical
distribution system had the capacity to perform its intended i
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safety functions and that associated engineering and technical support were adequate for this system.
Examples of strengths in l
this area included the availability of a computer program to j
analyze the DC system, a generally good fuse control program, good j
monitoring of fuel oil quality, and knowledgeable engineering
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personnel.
Examples of NRC identified concerns in this area
included (1) deficiencies in the control of drawings, design i
calculations, and databases; and (2) undersized thermal overload protection for safety-related motors. The licensee has initiated corrective actions in these areas.
t Engineering resolution of emergency core cooling system flow
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problems identified by Westinghouse was thorough in addressing the l
issues, and the system was tested to verify that the desired
!'
results were achieved.
Engineering support for'this issue was thorough and effective.
The licensee's 10 CFR 50.59 programmatic activities were reviewed during this assessment period and found to be a strength.
Formal procedures were established and were found to be adequate to
!
ensure compliance with 10 CFR 50.59. No programmatic weaknesses
were identified and the associated qualification / training programs
'
were identified as strengths.
,
Strong engineering and management support of refueling outage l
activities was demonstrated during this assessment period. Outage
'
activities were well planned and completed with few associated problems.
Problems encountered during the outage were dealt with
!
effectively by engineering. An example of good engineering
!
support during the outage was the modification of a circuit card l
in one of the load sequencers, to eliminate spurious transients j
'
due to circuit noise.
j
'.
A particular area of concern during this assessment period was the thoroughness and timeliness of corrective actions by engineering and technical support groups.
Examples here included: (1) The
'i resolution of repeated emergency diesel generator warning lights failures was not performed in a timely manner and resulted in an
,
(2) The full scope of a required hydrostatic test I
t f
h
'
.
i
following a modification to the service water system was not identified.
(3) Cathodic protection against corrosion of underground diesel fuel oil tanks and piping was not provided.
There were several other problems identified which were due to untimely or deficient engineering actions. The most significant of these was associated with the licensee's failure to correct the i
acceptance criteria for Motor Driven Emergency Feedwater (MDEFW)
pump discharge pressure, despite long-standing information that the criteria was non-conservative.
The licensee's efforts to develop a program to diagnostically test motor operated valves pursuant to Generic Letter (GL) 89-10 continued this assessment period. NRC review of the program
.
during this assessment period verified a satisfactcry initial program with knowledgeable engineers and a good training facility.
However, an NRC inspection late in the assessment period revealed
,
examples of inadequate acceptance criteria in Motor Operated Valve (MOV) test procedures, lack of Motor Operated Valve Testing and Surveillance (M0 VATS) training for signature analysis of MOV test
-
'
data, and little progress since an NRC inspection one year before.
An effective initial licensing training program for licensed operators was demonstrated this SALP period by the number of licensee personnel who successfully passed the Generic Fundamentals examination (GFES) and initial licensing examination.
The GFES was administered to twelve candidates and 92 percent of the candidates passed. The average score on the GFES examination was 91 percent.
Initial licensing examinations were administrated
,
to eighteen applicants and 100 percent of the candidates passed.
The average score on the initial examination was 88 percent.
The simulator was used effectively for training. The licensee's simulator instructors were knowledgeable of the simulator and plant operations. The simulator adequately simulated each sceaario event, and no simulator problems were noted.
Seven violations and one deviation were cited during the assessment period.
!
2.
Performance Ratino Category:
3.
Board Recommendations Management attention should be directed towards improving the thoroughness and timeliness of engineering response to issues requiring technical support.
i
..
..
-
._ _--
-
,
.
,
i G.
Safety Assessment /Ouality Verification 1.
Analysis This functional area addresses those activities related to i
licensee implementation of safety policies related to license amendments, exemptions and relief requests; responses to Generic
.
Letters, Bulletins and Information Notices; resolution of safety
,
issues; reviews of plant modifications performed under 10 CFR
'
50.59; safety committee activities; and the use of feedback from i
self-assessment programs and activities.
A conservative approach to the resolution of problems and to the daily operation of the plant was demonstrated. Management was actively involved in promoting this conservative approach for both safety issues and items that were outside the scope of regulatory
.
requirements.
Examples of conservative judgement were the
.
'
rescheduling of a motor operated valve dynamic flow test due to questionable test pressure data, and the precautions taken for troubleshooting a secondary plant protective circuit which had the potential to initiate a turbine trip.
At management's direction two programs were initiated during this assessment period to provide improvements to plant safety and operations. These included a plant walkdown inspection program
headed by duty shift engineers. The walkdown inspections covered the six major plant buildings and were performed on a weekly rotating basis. Additionally, a management observation program
'
was initiated to directly involve management / supervisors with field activities. This program allowed managers the opportunity
,
to observe and evaluate activities of personnel from different
'
disciplines. Approximately 250 observations were performed.
Management also placed additional emphasis on prejob briefings and l
use of the simulator for practicing infrequently performed
'
activities.
i Several organizational changes were made during this assessment period for groups that directly impact this functional area.
Technical Oversight, which was comprised of the Independent Safety Engineering Group (ISEG) and Operating Experience, was disbanded.
)
The Operating Experience group was merged with the licensing organization, and ISEG was placed in the Quality Systems organization along with Quality Assurnnce (QA) and Quality Control (QC). These groups maintained the effectiveness of their i
technical oversight during this organizatkr.11 change.
ISEG activities included an updated system review for the service water system, and outage schedule safety reviews.
In the outage schedule reviews, shutdown safety issues such as available power supplies and flowpaths for injecting water into the RCS were the i
major areas of focus.
'
..
.
The licensee's 10 CFR 50.59 programmatic activities were reviewed during this assessment period and found to be a strength.
Formal procedures were established and were found to be adequate to
ensure compliance with 10 CFR 50.59. No programmatic weaknesses were identified and the associated qualification / training programs t
were identified as strengths.
The Plant Safety Review Committee and the Nuclear Safety Review Committee continued to review and audit prescribed activities.
In observed committee meetings, the active participation of members
during discussions indicated that members had adequately reviewed
!
'
the agenda items prior to the meetings and were prepared to discuss and review issues at hand.
'
QC personnel generally provided valuable oversight for safety-related activities. A strength was identified with QC involvement in rer91ution of a circuit breaker deficiency. However, two examples were noted with QC involvement which involved questionable signoff practices.
During a maintenance activity, it was noted that individual signoffs required for the reinstallation
.
!
and second verification of lifted electrical leads had not been
[
made when the work was complete. This practice had not been
questioned by the QC inspector that observed the work. The second
!
example involved signoffs being made prior to the work actually l
being completed during a safety-related circuit breaker I
maintenance activity.
The QC inspector overseeing this activity
+
also completed the signoffs prior to the work being completed.
!
For both examples licensee management indicated that their t
expectations were not being met regarding cignoffs, and the i
importance of strict procedural compliance regarding signoffs was
,
re-emphasized to station personnel.
f The amendment requests received from the licensee during this
evaluation period were good. Requests were, in general, adequately supported by analyses which required little or no additional information in order to complete the technical review.
The licensee's high degree of involvement in performing safety analyses and their oversight of contractor personnel were noted as strengths.
Significant licensing actions that required SCE&G to i
coordinate their own resources and those of a contractor included a request to use leak-before-break, a request to increase the i
steam generator tube plugging limit to 18%, and a request to use interim plugging criteria.
The quality of amendment requests improved since the last rating period.
Although in general the quality of relief requests improved, some problems were noted. One relief request regarding the inspection of reactor vessel nozzles contained statements that were not adequately supported, and significant additional information was necessar _
,
,
}
l'
The licensee's written responses to Generic Letters and Bulletins were timely and complete. An exception to the licensee's aggressive pursuit of generic issues was noted in their response
to Supplement 4 to Generic Letter 88-20 for which the licensee had
,
not made sufficient efforts to meet the schedule suggested by the l
Generic Letter and its supplements.
The LER's received during this rating period were clear and accurate. The licensee responded well to headquarters inquiries
into the plant trip caused by the loss of the unit auxiliary transformer.
No cited violations were identified during the assessment period.
!
2.
Performance Ratina Category:
- 3.
Board Recommendations None.
V.
SUPPORTING DATA AND SUMMARIES
,
A.
Licensee Activities i
During March 1992, several management changes occurred. Thes-changes included: Mr. G. J. Taylor, previous Operations Manager,
!
assumed the position of General Manager Nuclear Plant Operations.
l
!
Mr. B. C. Williams, previous Manager of Outage Planning, assumed the position of Operations Manager. Mr. D. A. Lavigne, previous Manager of Materials and Procurement, was assigned as General Manager of Nuclear Safety. On July 18, 1992, Mr. R. M. Fowlkes,
!
previous Associate Manager of Shift Engineering, assumed the position Manager of Licensing.
Early in the assessment period, the plant completed a scheduled i
refueling outage. The duration of the outage was 60 days. Major activities performed during this outage included:
electrical
invertor replacements, steam generator inspections / plugging /
sleeving, MOV actuator refurbishments, and low pressure turbine inspections / repairs. On May 12, 1992, the unit was shutdown to repair a steam generator secondary manway leak. Subsequently, the plant operated at or near full power until January 12, 1993, when a reactor trip occurred due to a main generator load rejection.
Power to the Balance of Plant (BOP) was lost for approximately two hours which resulted in natural circulation flow for the RCS
<
during this time period.
I i
j
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___
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___
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.
B.
Direct Inspection and Review Activities In addition to the 34 routine NRC inspections performed at Summer, 2 special inspections were conducted as follows:
January 27-31, 1992
-
Motor Operated Valve inspection.
March 2-April 3, 1992
-
Electrical Distribution System functional Inspection (EDSFI)
C.
Escalated Enforcement Action 1.
Orders None 2.
Civil Penalties (CP)
None D.
Significant Management Conferences Held During The Appraisal Period 11/14/91 Summer Site - Meeting to present SALP results.
1/9 92 NRC Headquarters Office - Steam Generator replacement
/
project presentation and discussion.
2/7/92 NRC Headquarters Office - Meeting between NRC Chairman and licensee management to discuss plant status and industry issues.
1/11/93 NRC Headquarters Office - Discussion of proposed safety injection pump run-out test to determine acceptability of increasing the run-out limit by 10 percent, i
E.
Confirmation of Action Letters None.
F.
Reactor Trips Three automatic trips and no manual trips occurred:
May 20, 1992: Automatic reactor scram from 3 percent power due to personnel error while repairing the power range instrumentation.
May 21, 1992: Automatic reactor scram from 12 percent power caused by low steam generator level due to clocure of a feedwater isolation valve.
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_--_______ _ -
_ - - _ - _ _ _ _ - _ _ - _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _
- _ _ _
- -.
.. -
.
-
.
. -
- - _.
.._ - -.-
.
.
.-
. - -
,
-
h
-
i
.
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I
.
January 12, 1993: Automatic reactor trip due to a main generator load rejection which resulted in a high flux rate trip signal.
,
G.
Review of Licensee Event Reports (LERs)
!
'
I During the assessment period,12 LERs were analyzed. The
!
distribution of these events by cause, as determined by the NRC f
staff, was as follows:
Cause Total Component failure
Design
i Construction / Fabrication
-
Installation Personnel f-Operating Activity
-Maintenance Activity
1-Testing / Calibration Activity
-
l
!
-Procedure
[
-Other
1
-
l Total
}
!
Notes:
1.
With regard to the area of personnel, the
{
NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel t
i error.
!
t l
2.
The above information'was derived from a
!
review of LERs performed by the NRC staff i
and may not completely coincide with the licensee's cause assignments.
,
i i
f I
t
.
'
!
f
,
!
!
.
I
,
,
_ _ _ _ _..
- _ _
__
__
!
_.. -.
-
-.. - -
.-.
. - -.
..
.
-. _ -...
,
i
!
'
.
!
'
i i
H.
Licensing Activities l
t In addition to quality assurance and security plan submittals,
'
there were approximately 11 licensing actions issued during the
'
assessment period for V.C. Summer.
During this assessment period there were 7 relief requests granted j
and no requests denied.
!
"
!
I.
Enforcement Activity
)
i
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FUNCTIONAL NO. Of VIOLATIONS IN SEVERITY LEVEL AREA DEV.
V IV III II I
!
UNIT I l
- Plant Operations
-
-
-
-
-
f
- Radiological Controls
-
-
-
-
-
-
!
- Main / Surveillance
-
-
-
-
-
I
- Emergency Preparedness-
-
-
-
-
-
-
!
- Security
-
-
-
-
-
-
!
- Engineering / Technical
7
-
-
-
>
-
- Safety Assessment /
l
,
Quality Verification
-
-
-
-
-
-
i TOTAL
-
II
-
-
-
!
.
i f
i
L
)
!
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$
i A
f
=
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t i
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I
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,
Y
- -
. -.. -
-
-
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