IR 05000400/1992020
| ML18010A993 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/02/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A991 | List: |
| References | |
| 50-400-92-20-01, 50-400-92-20-1, NUDOCS 9302020137 | |
| Download: ML18010A993 (24) | |
Text
ENCLOSURE FINAL SALP REPORT U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report Number
.
50-400/92-20 Carolina Power and Light Company Shearon Harris June 2,
1991 to September 26, 1992 9302020i37 930ii5 PDR ADOCK 05000400
SUMMARY OF RESULTS During the assessment period, Shearon Harris continued to be operated in a. safe and effective manner.
Major strengths were identified in the areas of security, emergency preparedness, engineering/technical support and radiological controls.
Weaknesses were identified in the safety
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assessment/quality verification section.
Good management involvement in plant operations. activities and site
, w'alkdowns contributed to the overall safe operation and good material condition of the plant.
However, inconsistent performance by operators during transient and routine operations resulted in a declining trend.
Implementation of the radiation protection program was good.
Efforts.to control radiation exposure were noteworthy and effective as were those efforts to reduce contaminated areas.
.Strengths were noted in the preventati.ve maintenance program and improvement was noted in the area of post-maintenance testing.
Additionally, management involvement in maintenance activities was also exhibited.
Some weaknesses in the performance of maintenance activities was observed including one which caused a reactor trip.
Strengths were noted in the emergency preparedness area, specifically during two annual graded emergency exercises.
Good management support was 'also noted in the area of simulator configuration control and the maintenance of emergency response facilities and equipment.
Implementation of the security program was good.
Hardware changes, training and good management involvement in this area contributed to this successful implementation.
Engineering and technical support continued to be good.
Strong engineering support was demonstrated through refueling activities, the system engineering program and engineering evaluations associated with plant modifications.
However, a weakness was noted for an inadequate post-trip review.
Licensee performance in the area of safety assessment and quality verification was less effective than during the previous cycle.
Weaknesses were noted in the corporate self-assessment function.
Overall, the licensee's performance was considered to be superio Functional Area Overview Performance ratings for the last rating period are shown below.
Rating Last Period
~l>>
9-6>>
and the current period Rating This Period 06 02 91 - 09 26 92 Plant Operations Radiological Controls Maintenance/Surveillance Emergency Preparedness Security and Safeguards Engineering/Technical Support Safety Assessment/equality Verification 1 (declining)
2 (improving)
1
2 III.
CRITERIA The evaluation criteria which were used to assess each functional area 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 held with the licensee management.
IV.
PERFORMANCE ANALYSIS A.
Plant 0 erations A~nal sis This functional area addresses the control and performance of activities directly related to operating the facility, including fire protection.
The plant was operated in a safe and conservative manner during the assessment period.
Four reactor trips occurred from power'peration and one Reactor Protection System actuation occurred while the plant was shutdown.
There were no reactor trips during the last assessment period.
Two of the reactor trips this period involved component failure, one occurred during the performance of a maintenance calibration procedure, and,a manual reactor trip was inserted when a main feedwater pump tripped following deenergization of an electrical bus for a breaker failure.
Three of the four reactor trips occurred during a one week period.
The plant had an excellent continuous run of 271 days which set a plant record, The plant was managed conservatively as evidenced by the decision to shutdown and repair boric acid leakage on a reactor coolant system temperature detector bypass line even though leakage was well below regulatory limit Operating activities were generally conducted in a professional, dedicated, and conscientious manner.
Shift turnovers and the performance of operator rounds were considered to be good.
Go'od attention to detail was exhibited by an operator during the performance of rounds to identify an improper flange on the turbine-driven auxiliary feedwater pump lube oil cooler.
Also, operator performance to control a plant transient during troubleshooting on the digital electric hydraulic control system was good.
Operator performance during plant transients was inconsistent, however, as evidenced by poor control of steam generator level and steam pressure which both resulted in unnecessary safety system actuations.
In addition, instances were noted during routine operations indicating a
lack of attention to detail.
In one instance operators failed to detect a mispositioned switch which rendered the quadrant power tilt alarm inoperable.
In another,. operators failed to notice a low oil condition in a safety injection pump.
Operator actions which failed to properly identify and document several adverse conditions resulted in three violations.
Administrative controls regarding plant operations were considered to be effective.
A new program was developed to control. infrequent tests and evolutions.
The additional management involvement, planning, and interdepartmental communication which resulted from this program had a
definite benefit to safe plant operation.
However, areas in need of improvement were also noted.
Boric acid system temperature monitoring alarm response procedures for radwaste personnel did not provide sufficient guidance.
Additionally, the operating procedure for removing a hose from a demineralizer filter was weak which resulted in personnel and area contamination.
Plant housekeeping was considered to be good.
Progress was made in a new paint and labeling program which was initiated during this assessment period.
The practice of weekly management inspections of areas inside the power block and specific outside areas was continued.
This effort was effective in identifying housekeeping deficiencies.
The licensee reinstituted the practice of rotating licensed personnel to other departments/work groups.
Several licensed operators were rotated to the operations procedure writers group, work scheduling group, real-time trainer position, and the load dispatcher's office.
The licensee-maintains extra licensed personnel on shift in excess of TS requirements.
Additionally, licensed operators have been transferred to the training department and the Nucl'ear Assessment Department (NAD) to increase the technical expertise in these. area Formal communication was observed between control room operators and between control room personnel and auxiliary operators in the field.
Use of repeat backs was common.
Day-to-day communications between shift operating personnel and technical support system engineer's/managers and maintenance managers was evident.
Operations management was routinely observed monitoring several of the planned shutdowns and startups.
Control room drawings were found to correctly reflect plant conditions.
However, the NRC identified deficiencies in updating one set of drawings to accurately depict modifications which had been performed on the CCW system.
Operator logs were found to be organized, and usually provided sufficient information on plant status and events.
However, one instance was noted where a deficiency regarding a service water valve, was not'dequately addressed.
The fire brigade duties were assigned to radwaste operating personnel.
A licensed operator was also assigned to the brigade as an advisor.
This action allowed less impact on main control board personnel and allowed more detailed fire fighting training to be provided.
The'ire brigade response to several minor fires was considered to be satisfactory, During this assessment period six violations were cited.
2.
Performance Ratin Category:
Trend:
Declining 3.
Board Recommendations The Board determined that there was a decline in performance during this period as evidenced by less inconsistent operator performance during transient and a lack of attention to detail during routine operations.
Even though performance remained superior, in this area, management attention to this trend is considered appropriate.
Radiolo ical Controls A~nal sis This functional area addresses activities related to radiological controls, radioactive waste management, environmental monitoring, water chemistry, and transportation of radioactive material The. licensee continued to maintain stable and well qualified radiological controls staffing.
Sufficient numbers of qualified technicians were available to support both outage and non-outage activities, and the licensee ensured a
favorable return rate for contractor technician support for the 1992 refueling outage.
The technician continuing training program was considered comprehensive and included plant systems overview and performance related training.
In addition, the licensee actively supported technician certification by the National Registry of Radiation Protection Technicians, and certified twelve radiation control personnel.
Hands-on-training facilities utilized radiation detector simulation to reinforce ALARA concepts.
The-licensee took steps to improve performance in the area of self-assessment during the period.
In particular, increased management attention to the feedback reporting system was evident by the implementation of causal factor trending and close-out of old action items.
Overall, the licensee continued to effectively manage collective dose expenditure during the assessment period.
Collective dose for the period was approximately 82 person-rem.
This dose level was good since it reflected expenditure primarily for operating conditions and spent fuel operations with 28 outage days during the period.
The licensee also began refueling outage activities thirteen days prior to the end of the period.
The licensee effectively managed dose for significant activities including an unplanned outage to repair a resistance temperature detector valve.
The dose for this activity was considered low at approximately 7.4 person-rem.
Licensee personnel exhibited effective ALARA planning which limited personnel exposure.
For example, detailed pre-planning for work (adding oil to reactor coolant pumps, repairing valves, and cleaning waste storage tanks)
included conservative power reductions, mockup training on spare equipment, and the use of video cameras and dose rate instruments for remote monitoring of job performance.
The licensee also actively decreased radiation sources in the plant by cleaning waste tanks.
I Licensee planning and preparation for the 1992 refueling outage was thorough, and the established goal of 165 person-
'rem appeared aggressive relative to the scope of work.
The -licensee's contamination control and housekeeping practices were considered excellent.
The average contaminated surface area continued to trend downward with respect to previous assessment periods.
The licensee also actively tracked valves which exhibited leakage of contaminated liquid so that appropriate management attention
could be applied.
Personnel contamination events for the year 1991 and through September 26, 1992, were 131 and 44, respectively.
This is about the same level as that observed during previous single outage and non-outage periods.
One isolated poor practice was identified late in the assessment period associated with trash frisking operations.
Immediate corrective actions were implemented, and the licensee initiated actions to evaluate the need for long-term training and procedural improvements.
Improvements in both radiological and chemical controls
.associated with fuel stored in the spent fuel pools were noted during this assessment.
As mentioned in the previous assessment report, the licensee removed a significant amount, of crud from the bottom of the spent fuel pools.
Licensee management decided to halt any further clean-up of crud as a
method-of reducing dose to plant personnel.
Thus, crud management for spent fuel continues to provide a challenge for contamination control.
Issues regarding technician training for the operation of the Post Accident Sampling System and the development of a procedure to remove an undiluted sample from a shielded container were resolved.
Although significant progress has been made, some operability problems identified during the last assessment continued.
The licensee was implementing corrective actions to resolve those problems.
The plant water chemistry program was effectively'mplemented, maintaining chloride, fluoride, dissolved oxygen and dose equivalent iodine well within their respective TS limits.
A sampling system was installed for in-line monitoring of chemistry conditions. in the secondary side of the plant.
The system was undergoing testing at the end of the assessment period.
Secondary chemistry was very good as evidenced by steam generator sludge lancing results with less than'0 pounds of sludge per generator for each of the last two operating cycles.
The liquid and gaseous effluents program was managed effectively.
During this period, the licensee continued to have some effluent radiation monitors declared inoperable for periods greater than 30 days.
The licensee made a
concerted effort to return effluent radiation monitors to operable status.
This effort was successful as the number of inoperable monitors was reduced by the end of the period.
Two non-routine gaseous releases were recorded during this period.
'Liquid and gaseous effluents for the 12-month period from mid-1991 to mid-1992 were well within regulatory limits.
The maximum whole body dose was less than five percent of the allowable limi.
The Radiological Environmental Monitoring Program was implemented effectively.
Collection stations were '
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calibrated and well maintained.
Licensee sample results compared favorably with those of the State of North Carolina.
Overall, the radiological -environmental data'ndicated that plant operations had no significant impact on the environment or public health and safety.
Shipp'ing and handling of radwaste were efficient, reflecting
,'the competence, training, and experience of the staff.
In general, shipping documentation was in compliance with requirements.
During this assessment period, no violations were cited.
Performance Ratin Category:
I 3.'oard Recommendations None Maintenance Surveillance l.
A~nal sis This functional area addresses those activiti'es related to equipment condition, maintenance,
'surveillance performance, and equipment testing.
Performance of maintenance and surveillance activities continued to be effectively'performed.
For the majority of activities observed, performance of work was good with proper documentation of removed or replaced components and independent verification of their reinstallation.
Maintenance efforts to decrease air lock leakage were effective.
However, instances of inattention to detail were also noted.
One reactor trip occurred during the performance of a maintenance surveillance test when a,
pressure pulse occurred on the common leg of the three reactor coolant flow detectors while a flow transmitter was being returned to service.
One AFW system actuation was reported while troubleshooting a steam generator, level instrument.
The cause was attributed to personnel error.
An additional weakness was noted where licensee personnel fai.led to properly, reference the equipment technical manual during an oil addition to the turbine driven auxiliary feedwater pump.
,The. resultant improper oil level could have caused pump damage if not correcte Good pre-planning to reduce personnel exposure, equipment down time, and avoid plant transients was evident for several maintenance activities.
This planning included utilization of spare equipment for mock-up training, pre-evolution briefings with operations personnel, and contingency planning.
This demonstrated supervisory involvement in these activities.
Specialized vendor training programs, the continuing training program, hands-on training facilities, and a low turnover rate have enhanced the craft skills and knowledge.-
A full-time dedicated crew of instrumentation and control technicians was maintained to perform testing and troubleshooting associated with RPS and ESF instrumentation.
This has provided consistency in job performance and resulted in fewer problems'ssociated with the testing and maintenance performed on these systems.
The backlog of maintenance work was relatively constant.
Plant management assigned an additional ILC crew which started to reduce the backlog at the end of this assessment period
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The overall material condition of the plant was good.
However, specific deficiencies, such as oil leaks on the safety injection pumps and several safety injection valve motor operators, needed improvement.
Sodium hydroxide leakage was noted on several transmitters associated with the containment spray additive system.
Also, a few emergency service water vent and drain valves had signs of general corrosion.
The licensee took action to correct these deficiencies and significant improvements were noted, especially in the area of boric acid and sodium hydroxide leakage control.
The licensee continued the preventive maintenance program for large pumps and.motors by completing inspections on the normal service water pumps.
This program has been effective in ensuring the reliability of this type of equipment.
Strengthening of the licensee's predictive maintenance activities was demonstrated during this assessment period due to improvements in the vibration and lube oil analyses programs.
These included the completion of monthly vibration tests for normally operating safety-related equipment, with more frequent testing as needed, and the adoption of an expanded list of equipment requiring lube oil testing.
Vibration analyses detected problems with the jockey fire pump'and a main feedwater pump enabling repairs before pump fai.lure.
Thermography was utilized to detect hot spots in large motors, process instrumentation cabinets, rod drive cabinets, and the switchyar As discussed in the previous SALP report, efforts to improve post-maintenance testing were in progress.
The licensee, has expanded the planner,'s test matrix, completed training-on the new matrix, and enhanced the Automated Haintenance Hanagement System database to improve the post-maintenance testing process.
Improvement was noted during this assessment period.
The licensee developed a formal program for the conduct of infrequent tests and evolut'ions to strengthen the communication and pre-planning between maintenance and operations personnel.
Industry guidance on the conduct and substance of pre-job briefings, training, and procedures to be utilized, was included.
Likewise, the licensee developed a troubleshooting procedure-incorporating risk-oriented reviews by management.
Strong supervisory and management involvement was noted for several work activities.
Work involving the entry into TS action statements received management attention.
Haintenance managers were observed daily in the control room communicating with operations personnel on equipment problems.
Hanagement was also involved in on-the-job-training and qualification of personnel.
This action contributed to improved procedural compliance.
The surveillance test scheduling program continued to perform well.
The reports generated from this system allowed management to focus attention on potentially overdue tests, No scheduled tests were overdue or missed.
However, on one occasion, boric acid pump testing periodicity was not increased as required.
The licensee's approved inservice inspection ( ISI) program continued to be satisfactory.
ISI program procedural requirements and responsibilities were clearly defined.
Technical and supervisory personnel were generally knowledgeable in their areas of responsibility.
During the assessment period, four violations were cited.
Performance Ratin Category:
Trend:
Improving Board Recommendations None
Emer enc Pre aredness l.
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~Anal sis This functional area addresses activities related to the implementation of the Emergency Plan (EP)
and procedures, support and training of onsite and offsite emergency response organizations, and licensee performance during emergency exercises and evaluated actual events.
Good management support for the EP program was demonstrated.
The licensee carried out several drills to test alternates for: response positions, initiated an auto-dial. call-out system and relocated the Operational Support Center (OSC) in an effort to protect workers from potential radiation plumes.
The licensee continued to provide effective Emergency Response Organization training throughout the assessment period.
With one exception, all personnel had completed the required training.
The licensee maintained emergency response facilities and equipment in a state of readiness through equipment surveillance and functional testing.
Two equipment operability problems did occur."'ne problem involved inadequate maintenance of the gross failed fuel detector and the other was the inoperability of some Emergency Response Facility Information System (ERFIS) terminals.
Both issues were corrected, with the latter resulting in improved ERFIS reliability.
The licensee's audit.and critique program was effective in identifying routine and exercise conditions requiring corrective actions.
Management
'reviewed these findings and verified that corrective actions were taken.
The licensee implemented its Emergency Plan in response to one event this period.
The event was correctly classified as a Notification of Unusual Event, with offsite notifications performed in a timely manner, Harris demonstrated good response capability for dealing with site emergency situations during graded exercises in September 1991 and August 1992.
During the exercises, the licensee demonstrated it could implement the Emergency Plan and its implementing procedures, as well as take suitable actions to mitigate the consequences of the accident scenarios.
Emergency classifications were timely as the scenarios progressed, and operation of the emergency response fa'cil,ities and equipment was good.
Performance strengths observed during the exercises included good
2.
teamwork and aggressive play of participants.
Improvement was noted in the involvement of the accident assessment team and casualty control team from the OSC.
The command and control exhibited by the Technical Support Center.{TSC) and Emergency Operations Facili,ty (EOF)
Emergency Directors and the licensee's critique process were also exercise strengths.
All substantive-findings were documented for review and corrective actions.
Although no exercise weaknesses were identified, some minor problems, were noted in the areas of notification messages to offsite authorities
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and issuance of dosimetry to TSC and EOF personnel.
During the assessment period, one violation was cited.
Performance Ratin Category:
I 3.
Board Recommendations None
~Secerit
~Ansi sis This functional area addresses those security activiti,es related to protection of vital plant systems and equipment, and special nuclear material.=
The licensee implemented and managed an effective security program.
Security management at both the site and corporate level was skilled and highly visible in program activities.
The licensee revamped the training program for supervisors to enhance communications.
Many program improvements implemented since the last assessment show site and corporate management's strong support.
Examples of these
'ncluded enhanced alarm stations and assessment capabilities, and patrol and response personnel effectiveness.
The security force was professionally and effectively staffed, equipped, and trained to do their assigned duties.
The security training staff was dedicated and knowledgeable.
The licensee has initiated several programs that have enhanced the security force's professionalism.
The most effective items were the creation of an improved combat stress course using new rifles and the purchasing of a new security radio system that has encryption capabilities.
The licensee continued to identify and implement methods to better perform the security program.
The licensee enhanced
2.
their protected area patrol capabilities by obtaining several security patrol vehicles.
This improved the effectiveness, efficiency, and morale of the security personnel by providing weather protection and increasing the patrol and response speed of the security officers.
The acquisition and issuance of new smaller and lighter semiautomatic rifles have also improved the response capabilities of the response force.
The licensee has replaced the older tube driven closed-circuit television (CCTV) cameras with new solid state cameras, which has improved picture quality and coverage.
Alarm stations'ssessment capabilities were enhanced by the addition of a Video Capture system with a new video switcher and larger CCTV monitors.
To further enhance the alarm stations'ssessment proficiency, a Computer Aided Lighting Analysis program was used to upgrade and identify illumination deficiencies within the protected area.
Licensee management continued to provide trend data to system engineers and maintenance personnel in order to maintain security equipment at an acceptable level.
The licensee's Physical Security, Contingency and Training and gualification Plan revisions submitted during this period were. consistent with 10 CFR 50.54(p),
and were timely and adequately coordinated with the NRC.
The licensee's staff, who coordinated security plan revisions and technical specification changes, were knowledgeable of regulatory requirements.
During this assessment period, no violations were cited.,
Performance Ratin 3.
Category:
Board Recommendations None En ineerin Technical Su ort A~nal sis This functional area addresses those activities associated with the design of plant qodifications, engineering and technical support for operations, outages, maintenance, and operator training.
Overall, engineering continued to provide effective technical support to the operation of the facility.
Strong engineering support was demonstrated through refueling
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activities; the predictive maintenance and repetitive failure analysis programs; the system engineering program and engineering evaluations associated with plant modifications.
High levels of corporate engineering onsite involvement during modification development and implementation were evident.
The licensee's administrative controls for ensuring reliable decay heat removal during outages was noteworthy.
These controls included provisions for identification of higher risk evolutions and key safety functions, defense-in-depth contingency planning, training, and outage risk assessment reviews.
In addition, this information was emphasized during outage meetings to help reduce the potential for 'loss of shutdown cooling events during outage activities.
Furthermore, the refueling outage plan did not include.mid-loop operating conditions.
Excellent technical support was evidenced by reactivity management for planned power reductions and outages.
This action was effective in controlling axial flux peaking.
The power ascension test program, which was created following a nuclear instrumentation miscalibration event, was utilized to control plant startups without any further mishaps.
Additionally, technical support personnel were actively involved in maintenance activities such as troubleshooting the ATWS Hitigation System Actuation Circuitry and the emergency service water screen wash pumps.
Another example of good performance was the analysis of self-identified weaknesses in secondary side performance monitoring which resulted in the installation of a computer workstation that would access all Emergency Response Facility Information System database points and provide real-time display of secondary and primary side data.
Some weaknesses were identified in the area of technical support.
These included an inadequate post-trip review which did not identify the potential for reactor trip breaker failure based on previous industry events, inadequate design control of pipe supports in the boric acid system and emergency diesel generator lube oil system, inadequate incorporation of manufacturers'ecommendations into procedures for periodic heat trace panel calibration, and the omission'f several required items in the PH program for the turbine driven auxiliary feedwater pump.
The licensee recognized the problems with the PH program and implemented a technical manual review process to identify similar items.
Engineering and technical support organizational involvement in the outage planning process was an identified strength.
There were several system engineers designated as coordinators for various major outage activities including
steam generator work and electrical bus outages.
These individuals were knowledgeable and organized as reflected by the efficient completion of their assigned work activities.
In addition to these designated coordinators, many other system engineers were involved in other aspects of outage planning activities which contributed to the overall outage efficiency.
The licensee's system engineering program was effective.
. System Engineers took ownership of their systems.
Their level of knowledge of both system history and performance was commendable.
System engineers were actively involved in troubleshooting, performance monitoring, and the coordination of corrective actions.
An example was a
containment temperature monitoring change initiated to provide data for equipment qualification concerns.
The modification involved the installation of resistance temperature detectors at various locations throughout containment to verify that local temperature conditions did not exceed technical specification limitations.
Additionally, the licensee continued to foster strong communications and effective working relationships between engineering and other plant organizations that was evident during previous SALP periods.
Modifications and engineering evaluations generally contained clear safety reviews and were considered to be technically sound and acceptable.
Examples included modifications to the reactor cavity seal ring instrument air piping to allow component testing and calibration prior to use inside containment, and annunciator setpoint changes to prevent spurious alarms and to more accurately reflect main feedwater flow limits.
However, a plant change request to return the component cooling water system to its normal configuration following a relief valve lifting event failed to accomplish its purpose due to lack of interdepartmental communications.
A lack of progress to modify emergency diesel generator starting air quality was an example of inadequate modification prioritization.
The temporary modification process was strengthened by the inclusion of jumpers and lifted leads as temporary modifications.
A motor-operated valve testing and surveillance program had
.been developed which adequately addressed most of the recommendations of Generic Letter 89-10.
Strengths in the program included the use of state-of-the art diagnostic systems, knowledgeable and well trained personnel, extensive licensee involvement in industry groups, and effective programmatic incorporation of industry experience and vendor information.
However, several concerns were noted.
The concerns primarily involved a potential reduction of the scope of differential pressure testing, the use of static
2.
rather than dynamic flow testing to demonstrate design basis acceptability, and the potential for non-conservative sizing and thrust calculations due to failure to incorporate rate-of-loading effects.
The licensed operator training program continued to be effective as evidenced by a 100% pass rate on the Generic Fundamentals Examination Section and initial examinations.
Improvement of weaknesses identified during the last assessment period was evidenced by improved communications among crew members during an initial examination administered to eight candidates this assessment period.
The requalification program was found to be satisfactory when all twenty operators passed the NRC-administered requalification examination.
The licensee adequately evaluated its operators.
However, inconsistencies were noted in the performance of evaluators during walkthroughs.
The simulator was used effectively for training.
The licensee has implemented corrective actions to alleviate simulator deficiencies identified during examination administration.
The licensed operator training staff has been supplemented by three licensed operators which should strengthen the technical expertise of the department.
During the assessment period, no violations were cited.
Performance Ratin 3.
Category:
Board Recommendations None Safet Assessment ualit Verification A~nal sis This functional area addresses those activities related to licensee implementation of safety policies; amendments; exemptions and relief requests; responses to Generic Letters; Bulletins and Information Notices; resolution of safety issues; reviews of plant modifications performed under
CFR 50.59; safety review committee activities; and use of feedback from self-assessment programs and activities.
Licensee performance in the area of safety assessment and quality verification was satisfactory.
However, as mentioned in the previous assessment report, the licensee had not achieved the desired results from its first level assessment process, which included individual self-checks,
management supervision, independent verification, post-maintenance testing and corrective action program trending.
With regard to onsite self assessment, plant management continued to perform frequent inspections and tours of various plant areas focusing on the general cleanliness and material condition of equipment.
These activities had a
positive effect on plant housekeeping.
Nanagement involvement was evidenced by the coaching of personnel, the conduct of infrequent -activity pre-evolution briefings, and direct observation of critical work involving TS equipment inoperability.
The Adverse Condition Report system has been fully implemented.
Due to the lower threshold for reporting problems than with the previous system, the data base has grown considerably which has allowed more meaningful problem trending.
Self-identification of problems continued to be a
strength in this assessment area.
However, four violations were cited regarding the failure to adequately identify, document, and correct deficiencies, as mentioned in the Operations and Engineering/Technical Support sections of this report.
6ood participation and advance preparation by plant nuclear safety committee members for those items discussed in committee meetings was noted.
Minutes from the meetings contained accurate documentation of the committee's activities.
, Corporate responsibilities included quality verification surveillances and independent evaluations.
In contrast to the good on-site self assessment effort, corporate activities were initially found to be deficient in several areas.
For most of the rating period, little change was noted in the minimal involvement of the guality Verification (gV) organization.
This organization had recently begun to assist the plant organizations in self-assessment field surveillances during which a gV inspector is temporarily assigned to the other group,'bserves a work activity, and reports discrepancies to the area manager.
Although two self-assessment field surveillances were found to be of high quality, only two were performed.
Near the end of this assessment period, gV involvement was increased and the licensee hired two additional personnel so that field surveillances could be continued throughout the outage.
The initial performance of onsite quality assessments was considered to be poor.
Audits were found to be fragmented and lacked sufficient documentation to draw meaningful conclusions or measure effectiveness.
Audits were not always forwarded to senior licensee management in a timely
manner.
The licensee made extensive efforts to correct the violations and weaknesses.
Improvement was noted near the end of this assessment period as to the adequacy of audit documentation and timeliness of submittal to higher management.
, The amendment requests for changes to TS were adequate in providing "no significant hazards considerations" evaluations.
Licensee management's involvement in interacting with the staff during meetings, site visits, and the review of licensing/technical issues, and in the 'timely submittal of license amendment requests remains effective.
One exception was noted when the licensee failed to submit a
timely request for a TS change regarding surveillance requirements for the emergency core cooling system.
No emergency TS changes were requested during this period.
Some licensee strengths that were observed in the last SALP were sustained during this assessment period.
The licensee was effective and pro-active in identifying potential safety problems during their review of documentation related to license amendment activities and generic industry communications.
When a safety concern was identified, the licensee addressed all aspects of the issue to satisfy all
'regulatory as well as plant safety aspects.
Examples included the identification of a discrepancy involving the safety injection switch-over time from cold leg to hot leg recirculation during the long-term cooling phase of a loss of coolant accident and implementation of the Station Blackout Rule.
The licensee's responses to Bulletins and Generic Letters had been ti'mely and met staff requirements.
The licensee demonstrated a conservative approach to issues and had placed a high priority on the assessment of i'ndustry experience to improve plant safety and performance'.
Plant management conservatively decided to shut the unit down in response to boric acid leakage from valves in the reactor coolant system even though leakage was well within TS limits.
Industry experience was shared with all on-site managers and system engineers and programs were established to address industry concerns which included the main turbine emergency trip system, fuse control and replacement, and solenoid valve reliability.
During this assessment period, longstanding deficiencies in the. design and testing of the high head safety injection system were resolved by design changes.
The 10 CfR 50.59 review process at Harris was consistent with.approved industry guidance and was considered to be a
strength because trained, tested, and experienced reviewers
were maintained by technical discipline; and the necessary procedures were in place.
In addition, two independent reviewers routinely performed the required evaluation to confirm the conclusions.
During this assessment period, five violations were cited.
2.
Performance Ratin Category:
3.
Board Recommendations The Board continued to be concerned over the lack of Corporate activities on self assessment and field surveillance efforts.
Management attention in this area is warranted; SUPPORTING DATA AND SUMMARIES A.
Licensee Activities The plant began the assessment period at 100 percent power.
On June 7,
1991, the plant was shutdown to perform additional post-maintenance testing on a reactor trip switch.
Full power operations resumed on June 9,
1991.
On March 6, 1992, the reactor was shutdown to repair leaking valves on the C
This outage ended a record continuous run of 271 days.
The plant returned to normal power operations on March 12, 1992.
The plant was shutdown for refueling outage No.
4 on September 12, 1992.
B.
Significant management changes occuring this SALP period included the creation and filling of the new President/Chief Operating Officer position who reports directly to the existing Chief Executive Officer.
In addition, a new Site Vice President was assigned.
A new Chemistry Manager was also assigned during the period.
Direct Ins ection and Review Activities During the assessment period, one special audit, 31 routine and five special inspections were performed at the Harris facility by the NRC staff.
The special audit and inspections were:
June 3-7, 1991; Inspection of Activities Associated with Reactor Trip Breaker Failure Following the June 3,
1991 Trip September 23-26, 1991; Emergency Preparedness Program Review October
- November 16, 1991; Program Review for Changes to Plant Environs
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April 6 - 10, 1992; Motor-Operated Valve Inspection August 3 - 7, 1992; Audit of the High Head Safety Injection Alternate Miniflow System and Related Issues August 31 - September 4,
1992; Emergency Operating Procedures Followup Inspection Escalated Enforcement Action Orders None.
2.
Civil Penalties (CP)
Severity Level III problem (EA 91-076) for improper maintenance activities which led to one channel of the reactor protection system being inoperable ($50,000 CP).
CP issued for activities which occurred during SALP cycle 9.
Si nificant Licensee Conferences Held Durin The A
raisal Period During the assessment period, there were seven significant management conferences with the licensee.
These were:
~
June 12, 1991; Management Meeting to discuss Harris'elf-assessment (cycle 9).
~
July 3, 1991; Enforcement Conference to discuss improper maintenance activities which rendered one Reactor Trip System instrumentation channel inoperable (cycle 9).
~
August 1, 1991; Management Meeting to present results of SALP cycle 9 assessment..
~
June 9,
1992; Management Meeting to discuss Harris'elf-assessment (cycle 10).
~
August 20, 1992; Management Meeting to discuss technical and management issues associated with the high head safety injection (HHSI) alternate miniflow system.
~-
September 10, 1992; Management Meeting to discuss the Harris'PEEE submittal schedule.
~
October 14, 1992; Enforcement Conference to discuss apparent inadequate corrective actions associated with the HHSI alternate miniflow syste E.
Confirmation of Action Letters None.
F.
~RT i The unit experienced four reactor trips at power during this assessment period and one reactor protection system actuation occurred on July 13, 1992, while the plant was in the hot standby condition.
The trips were:
~
June 3, 1991; Automatic reactor trip from full power while performing a maintenance calibration procedure 'on a reactor coolant system flow transmitter.
July 12, 1992; Automatic reactor trip from full power due to a failed main condenser boot seal and resultant low condenser vacuum.
July 15, 1992; Manual reactor trip from 30 percent power due to the loss of the main feedwater pump following deenergization of an electrical bus for breaker removal.
~
July 17, 1992; Automatic reactor trip from full power due to.
a failed main condenser boot seal and resultant low condenser vacuum.
G.
Review of Licensee Event Re orts LERs During the assessment period,
LERs were analyzed.
Speci,al reports were submitted during the period by'he licensee but are.
not included in the table.
The distribution of these events by cause, as determined by the NRC staff, was as follows:
Cause Component Failure Design/Procedures
,Construction/Fabrication Installation Personnel-Operating Activity-Maintenance Activity-Testing/Calibration Activity-Other Other
3 2.
0 Totals
22'.
Licensin Activities During this SALP period, 30 licensing activities were resolved.
This included nine license amendments, and 14 other licensing actions.'eview was also completed for seven multiplant activities.
The most significant of these were NRC Bulletin 88-08 and the Station Blackout Analysis to meet
CFR 50.63, which is due to be implemented in 1994.
Enforcement Activit FUNCTIONAL AREA NO.
OF VIOLATIONS IN SEVERITY LEVEL I
II III IV V
DEV Plant Operations Radiological Controls Haintenance/Surveillance Emergency Preparedness Security Engineering/Technical Support Safety Assessment/
equality Verification TOTAL 1*
1 1*
1
- This violation, issued during this period, was discussed in the previous SALP.