IR 05000413/1988024
| ML20205G432 | |
| Person / Time | |
|---|---|
| Site: | Catawba, McGuire, 05000000 |
| Issue date: | 10/13/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205G413 | List: |
| References | |
| 50-413-88-24, 50-414-88-24, NUDOCS 8810280261 | |
| Download: ML20205G432 (38) | |
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ENCLOSURE 2
SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION l
REGION 11 i
l SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBERS 50-413/88-24 j
50-414/88-24 f
DUKE POWER COMPANY
CATAWBA UNITS 1 & 2 j
AUGUST 1, 1987 THROUGH JULY 31, 1988
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l SUMMARY OF RESULTS 1.
Overall Facility Evaluation During the SALP assessment period, the Catawba facility was effectively managed and achieveo a satisfactory level of operational safety.
Management has effectively led the transition from construction to operations and is actively involved in daily
operations and problem resolution.
The new plant manager is very
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active and has clearly established his acenda, which has goals for T
improvement in all areas and is monitorec under a site performance indicator program, t
The alignment of the functional areas for this SALP period reflects the new format, but a comparison with the last rating period shows no
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f change in ratings.
The following overview observations in each area
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are presented for your action as appropriate:
i The period included a 140+ day continuous run on Unit 1.
Total reactor trips for Units 1 and 2, respectively, were 2 and 10 compared with a total of H trips in the previous assessment period.
Personnel errors and procedural adherence problems were still l
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occurring and have led to three tri L
Technical Specification violations.ps, two safety injections and some Unit 1 showed improvement as experience was gained in its operation and has operated close to the national average for the period.
Unit 2 operation is still experiencing startup problems and continued management attentien is
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t appropriate.
l Radiological controls reflected active site management and were good overall. Accumulated radiation dose is slightly below industry average.
Some weaknesses were identified relative to personnel frisking which are being addressed.
Radiation monitor inoperability I
has plagued the plant and strong management attention, which has been started, is expected to have an impact.
Maintenance and surveillance is the weakest area.
One of the two
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site problems which required an enforcement conference occurred in this area:
the asiatic clam fouling problem was dealt with in a superior manner after it was detected.
Some equipment problems have l
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continued, such as main feedwater control and Unit 2 steam generator
level control. These and other uncorrected equipment problems have
contributed to the majority of the reactor trips during the period
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and are now receiving elevated attention.
A large number of L
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emergency diesel genert. tor maintenance which led to moi (sture in the instrument air supply.EDG) fa This was exacerbated by a vendor manufacturing problem.
The corrective actions taken were effective once the problem received the appropriate level of management attention and support.
Management
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attention is :.urrently being directed at the large backlog of modification and work requests and the system expert program is beginning u de useful.
Emergen y preparedness drill results have improved since the beginning of the assessment period. The site has aggressively pursued improvem2nts in this area v'ia monthly drills, aggressive pursuit of corrective actions and procedure changes.
The offsite personnel have also m. proved through receipt of additional guidance and by conducting additional practice sessions.
Security staff is very professional and well trained.
One inattentive
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guard was found by the resident inspector.
Some access control
problems were experienced.
Engineering / Technical Support is im roving, especially with estabitshment of the on-site Design En ineering organization.
One of the two site problems which require an enforcement conference
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occurred in this area: the environmental qualification issues should have attracted increased management attention earlier, but have now been adequately addressed.
The ongoing improvement in management of
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the facility modification process is noted.
The task force setup to
deal with the EDG problems was effective.
This area's performance is
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improving and can contribute to an improvement in overall plant performance.
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Safety Assessment / Quality Verification can be improved.
Better coordination between NRC, Duke corporate licensing and plant
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personnel is warranted.
Weaknesses in QA Department overview functions were noted during the last SALP period and marked
improvement has not yet been observed.
The site performance
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indicator program should improve the overall area by focusing
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management attention.
Facility Performince Summary functional Area 10/1/85 - 7/31/87 l
Plant 0 erations
i Radiological Controls
l Maintenance
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Functional Area 10/1/85 - 7/31/87 (Cont c/
Surveillance
Fire Pretection
Security
Quality Proarams and Administrative
Control Affecting Quality Licensing Activities
Training
Engineering Support
Preoperational and Startup Testing
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Functional Area 8/1/87 - 7/31/88 Plant Operations
Radiological Controls
Maintenance / Surveillance
Security
Engineering / Technical Support
Safety Assessment / Quality Verification
III. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phase.
Functional arets normally represent areas significant to nuclear safety and the environment.
Some functional areas may nat be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
1.
Assurance of quality, including management involvement and control; 2.
Approach to the resolution of technical issues from a safety stand-point; 3.
Responsiveness to NRC initiatives; 4.
Enfcrceaent history; 5.
Operational and construction events (including response to, analyses of, reporting of, and corrective actions for);
6.
Staffing (including management); and 7.
Effectiveness of training and qualification program
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However, the NRC is not limited to these criteria and others may have been used where p ropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categoriec.
The definitions of these performance categories are as follows:
1.
Category 1.
Licensee management attention and involvement are readily evident and place emphasis on superior performance of nucir.ar safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and
)ersonnel performance is being achieved.
Reduced NRC atte, tion may
)e appropriate.
2.
Category 2.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is good.
The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonable allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at hormal levels.
3.
Category 3.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet minimal regulatory re airements.
Licensee resources appear to be strained or not of ectively used.
NRC attention should be increased above normal levels.
The SALP Board may also include an appraisal of the performance trend of a functional area.
This performanco trend will only be used when both a definite trend of performance within the evaluation period is discernable and the Board believes that continuation of the trend may result in a change of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the
close cf the assessment period.
Declining:
Licensee performance was determined to be declining near the
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close of the assessment period and the licensee had not taken meaningful
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steps to address this pattern.
IV.
PERFORMANCE ANALYSIS A.
Plant Operptions
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Ary d Du eg this assessment period routine and special inspections of plant operations were perforced by the resident and regional aased inspectors.
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Plant management is active in the day-to-day operations of the plant.
Daily status meetings are held to discuss each unit's i
alanned activities and possible problem areas being encountered.
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,4anagement is very involved in the pursuit of problem resolu-
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tions and the assurance of quality.
Policy is adequately stated and disseminated for implementation.
The plant's material, preservation and housekeeping status is good.
The licensee's program to maintain equipment and area condition is effective and includes weekly tours of selected areas by plant superintendents.
Emphasis is placed on equipment appearance, installattun, stowage, safety hazards and fluid system leaks.
Weak areas are identified and ef forts are
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redirected.
However, ocassionally during routine plant tours specific areas are found by the resident inspectors where debris has collected.
The licensee has completed about 40% of an improved component lab 0 ling program to clearly identify equipment and valves.
F.ienolic labels have unit specific or
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group specific colors and should enhance operator component identification.
Some cases of handwritten inscriptions identif panels,ying components continue to be observed on control is and doors.
Control room demeanor is professional and operators are dedi-cated and attentive to their duties.
To promote professionalism, operators recently developed a set M commitment to excellence principles which were presented to and approved by senior management.
The operations shif t staffing level during this
assessment period continued to exceed the shift crew composition required by Technical Specifications (TS).
Each o has either 3 or 4 Senior Reactor Operators (SR0s) perating shift
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(TS require at
least 2) and 4 or 5 Reactor Operators (R0s) (TS require at
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least 3).
The Shif t Technical Advisors (re-titled Shift
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Engineers) have also been licensed as SR0s, although they do
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maintain an inactive license.
The licensee has contiliued to add
SRO qualified individuals to various staff positions.
The total
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number of licensed operators is as follows:
SRO-22 Active,
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23 Inactive; R0-25 Active, 5 Inactive.
Operations personnel i
also assist in staffing the fire brigade.
A violation was i
identified early in the SALP period in the ares of fire brigade
staffing.
The violation involved the assignment of unqualified
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personnel to the fire brigade and identified a weakness in the i
licensee program for controlling fire brigade assignments.
The i
licensee has now implemented a computerized program to track brigade member qualifications.
i An essessment of reactor trips during this SALP period shows a
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significant decrease in the unplanned trip rate for Unit 1 (two subcritical trips due to equipment malfunctions).
Unit 2
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however, perforced poorly.
There were 10 automatic or manu,al
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trips which occurred from various power levals.
Four of the trips were related to malfunctions with feedwater control valves (See Maintenance / Surveillance section).
Three trips were associated with other unrelated ec.aipment failures.
Two trips were caused directly by operator errors and one trip by a management deficiency which led to an operator error.
Three
trips that occurred during the previous SALP assessment were due to water level control problems ;f the Westinghouse 0-5 steam generator (S/G) (Unit 2 only).
(he licensee has successfully trained operators to deal with the level control sensitivity and narrow operating range.
No trips occurred directly related to operator ability to maintain levels this assessment period.
It is believed, however, that some of the Unit 2 trips (3 or 4) are indirectly related to the S/G level sens!tivity and had the same
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feedwater related problems occurred on Unit 1 they may not have resulted in reactor trips.
This is because Unit I has 0-3 steam
generators with a much larger operating level range.
The licensee plans on modifying the 0-5 steam generatces during the
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next refueling outage to expand the operating range by moving the narrow range level instrument tap locations.
This should make the steam generators more forgiving during unexpected feedwater transients.
l The licensee continued to have a relatively )high rate of
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i Engineered Safety Feature (ESF) actuations (35.
Approximately 50% of these resulted from Operations, and Instrument and Electrical (IAE) personnel errors.
Operations accounted for
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i about 64% of the personnel errors.
The errors included failure j
to follow procedures, problems with tagouts, and difficulty
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interpreting plant response during tiansients.
Also included were two inadvertent safety injections,ing from a failure to one resulting from j
impropen use of a tagout and one result i
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follow procedure.
As a result, licensee management has focused
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attention on attempting to increase the level of sensitivity
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towards understanding procedural steps.
Additiona.ly, personnel
errors, management deficiencies, and procedural inadequacies are
tracked and trended in order to evaluate results.
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Management's approach to tech..# cal issues is generally charac-i terized by conservatism when safety significance exists.
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i Notable examples of conservative decisions made during the
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rating period involved:
the operability of post accident i
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monitoring resistance tecerature detectors (RTO) in January, 1988; the operability of Limitorque valve operator T-drains in l
February,1988; and the operability of the auxiliary feedwater i
system in March, 1988.
On January 15, 1988, wide range hot and cold leg RIDS were
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l determined to be non-environmentally qualified on Unit 2 which was shutdown at the time.
Due to a suspected similar j
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condition on Unit 1, the unit was shutdown for inspection
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and it was determined that its RIDS were also improperly installed.
On February 5,1988, Unit I was shutdoJn when the licensee
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had reason to believe Limitorque valve operator T-drains were either painted over or not installed based unon NRC
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j and licensee inspection of Unit 2.
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On March 9, 1988 Unit 2 tripped from 21% power with
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resulting auxiliary feedwater flow degradation due to
Asiatic clam infestatfor..
Unit I was shutdown to inspect
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for and correct similar problems.
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Significant improvements were achieved in the area of reactor
coolant system leaks.
No shutdowns were required because of i
excessive unidentified leakage.
One shutdown was initiated when
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reactor coolant pump seal leakoff rates were low and erratic.
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seal problem was suspected, however, the seal reseated after the i
j plant transient.
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Hanagement has established a noteworthy goal to reduce safety i
system unavailability with the intent to minimize the time that L
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systems are in Technical Specification (TS) action statements.
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The licensee tracks diesel generator and auxiliary feedwater
i system unavailability and total number of outstanding TS items.
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j The effort will require planning coordination to ensure that
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required maintenance does get performed and is not sacrificed i
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Technical Specification compliance has historically been a problem at Catawba and has continued during this assesscent
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This issue is described in detail in NRC Report
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413,414/88-25.
This problem involves not only Operations personnel but also personnel who support operations such as
Compliance, Design Engineering and corporate licensing.
I Contributing to this problem have been some TSs which are unclear and the licensee's inter)retations have not always been
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j consistent with plant design anc TS bases.
The licensee has
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recognized the need for improved guidance to operators and is
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in the nrocess of correcting this situation.
Further corrective
actions'>lanned include a more pro active approach to TS manage-
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i ment, adding another SR0 to the compliance group, more
compliance involvement in operability decisions,itization of TS more thorough
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review of TS interpretations and improving prior i
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l this evaluation period in Six violations were identified durinfire protection area.
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the operations area and one in the We
have evaluated these incidents and believe them to require
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1 management attention as they represent a programmatic weakness i
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i (a) 59 verity level IV violation for failure to demonstrate operability of ac offsite sources within the required time frame with one diesel generator inoperable on three separateoccasions(87-25).
(b) Severity Level IV violation for failure to follow
procedures for locking of valves (87-30).
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(c) Severity Level IV violation for failure to follow TS and maintain automatic valves in the auxiliary feedwater flowpathfullyopen(87-44).
(d) Severity level IV violation for failure to follow procedures resulting in two inadvertent safety injections t
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(88-08).
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(e) Severity level IV violation for failure to follow procedure
resulting in both trains of control room area ventilation
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without an emergency power supply (87-44, Unit 2 only).
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(f) Severity Level IV violation for failure to follow the
j Technical Specification when a pressurizer code safety
valve position indicator was inoperable (88-15, Unit 2 f
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only).
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Severity Level IV violation for assi
personnel to fire brigade duty (87-37).gning unqualified
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Performance Rating
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Category 2
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3.
Recommendations
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I The high reactor trip rate of Unit 2, continuing personnel
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attentlonintheseareasisrequired.
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Radiological Controls
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Analysis I
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i During the assessment period, inspections were performed by the
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The inspections
included four radiation protection inspections and one radiological effluent inspection.
Resolution of radiation protection technical issues was adequate r
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as evidenced by both site and corporate involvement in the study
and analysis of hot particle contamination and the dose
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assignments required as a result.
The licensee conducted i
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studies (and plans to purchase point sources for further
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I studies) in order to determine the proper methodology for
estimating hot particle activity and calculating the ap3ropriate
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t skin dose.
Site arocedures have been modified to reflect the changes determinec necessary by the studies.
i The licensee was enerally responsise to NRC initiatives in the area of radio ogical controls.
This was exemplified by
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contamination survey (frisking) problem noted with monitoringpractice the licensee's resolution of a
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the plant radiation controlled area from numerous locations.
In order to provide more positive control of personnel and
equipment leaving the controlled area, the licensee established t
a single point access (SPA) to the Radiation Control Area (RCA)
inside the plant.
Once set up, the SPA became the only point of personnel entrance / exit under other than emergency (HP) techni-conditions.
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It is manned during day shift by a Health Ph clan or Independent Radiation Worker (IRW) ysics j
with advanced HP
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training who monitors for proper personnel contamination
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surveys, proper dosimetry and completion of daily dose cards.
l The licensee's health physics and radwaste staffing levels were j
appropriate and compared well with other utilities having a
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j facility of similar size.
An adequate number of qualified
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licensee and contract health physics (HP) technicians were a
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available to support rout.ine and outage operations.
A low
turnover and attrition rate and less reliance on contract personnel in the HP group has resulted in an increasingly
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experienced staff.
The overall quality and experience level of
the HP staff is viewed as a program strength. The licensee used i
144 contractor technicians and supervisors during the recent refueling outage but currently employs only three contract HP l
technicians to assist in the As low As Reasonably Achievable
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(ALARA) and Radioactive Materials Control (RMC) sections.
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Although the licensee continues to rely on temporary contract HP j
Personnel for outages, there has been a decrease in the number
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of permanent contract HP technicians from eighteen durin previous assessment period to the current level of three. g the
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A continued commitment of management to provide support for and l
become involved in matters related to radiation protection was noted during the assessment period, as evidenced by the purchase of whole body friskers to address a problem with p)ersonnel performing personnel contamination surveys (frisking when they
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exited the RCA.
Appropriate members of both management and the i
technical staffs were involved sufficiently early in outage
j preparations to permit adequate planning of proper radiological
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t controls and to provide for ALARA considerations for outage
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j activities.
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However, weaknesses were noted in the areas of meeting established commitments and the audit program.
On two occasions I
I during the assessment period the licensee failed to fully t
I complete corrective act'ions, in the time period established by
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the licensee, following identification of a violation by the
NRC.
With respect to the audit program, it was noted that the
corporate audits were generally adequate.
The corporate arogram was designed to audit all aspects of the site radiation
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protection program and the aud:ts were performed by individuals with technical backgrounds in radiological controls.
The site i
QA surveillances however were of a more limited scope, concentrating only on spec,ific aortions of the radiation protection program and not on al'
aspects.
Site QA personnel
have attended HP and HP-related courses and the scope and depth of future surveillances should reflect this increased level of
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Radiation protection training was considered adequate.
The HP
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technician training program was accredited by the Institute of
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Nuclear Power Operations (INPO) during a previous assessment
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period.
The licensee's general emalo GET) was well defined and given to all personnel. yee training (ining program
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The GET retra i
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had been established and includes not only standard topics as outlined in 10 CFR 19, but current topics such as hot particle information and recent NRC findings.
Respiratory protection
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training included radiological controls and hazards and
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industrial hygiene problems that could be encountered.
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j Hanagement's support of and commitment to training were evident i
in that sufficient time was allocated for training and employees l
were encouraged to attend.
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The licensee experienced 230 personnel contaminations during
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1987 94 of which were skin contaminations.
The number is
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attrIt;utable f
during 1987., in part, to the fact that there were two outages
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This number of personnel contaminations is less
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than most PWRs in Region II.
Through June 30, 1988 the contaminations. perienced a total of 88 skin and 76 clothing licensee had ex t
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The licensee has had one outage in 1988.
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The licensee's average radiation dose for 1987 was 224
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l person-rem per unit which is significantly below the PWR l
national average of 368 person-rem.
This included exposure
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received during two refueling outages.
The low collective dose i
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is attributable to the fact that two units are relatively new (
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and exposures during normal and outage operations are low in
comparison to older plaats.
Also, it has not been necessa
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j thus far, to perform any extended repair work or replace ma or i
items of equipment in radiation areas except for the Upper ead
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P Injection System and the reactor coolant RTD bypass lines.
ThroughJuly19}tisexpectedthatthe1988collectiveradiation 1988, the total collective does was 168 person-
rem per unit.
dose will again be significantly below the national average.
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Liquid and gaseous radioactive effluents were within the Tech-nical Specification limits for radioactivity concentrations in
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effluents and in compliance with 40 CFR 190 limits for radiation dose limits.
Etfluent releases are summarized fi, the Supporting Data and Summaries, Secticn V.I.
The effluent summary data
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indicated an increase in liquid and gaseous effluents from 1985 to 1987 However, Unit 2 was not operatior l during 1985, and a
the effluents increase is partially attributable to Unit 2 startup during 1986.
There were no unplanned liquid or gaseous releases above limits required to be reported to the NRC during
the SALP period.
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The licensee has experienced a series of oaerational problems
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associated with the process and area radiation monitoring
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systems.
A radiation monitoring system working group has been established for the purpose of identifying,is working very evaluating and proposing corrective measures.
This group diligently and has strong management backing.
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The Post-Accident Liquid Sampling System (PALSS) for Unit I was
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evaluated during this assessment period against the criteria set
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forth in NUREG-0737, Item II.B.3.
The licensee demonstrated
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compliance with the applicable NUREG-0737 criteria since the i
required analyses was performed readily and within the time and
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limits prescribed.
i accuracy (PAGSS) was installed in accordance with the design.The P System An unresolved item concerning line loss or radionuclide aerosol due to long sampling lines remained open awaiting completion of licensee tests.
As part of the NRC's confirmatory measurements program, a i
simulated liquid waste sarple containing selected beta emitting l
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radionuclides was given to the licensee in November 1987.
The
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licensee successfully analyzed the liquid spike for Sr-90, H-3 and Fe-55.
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During(f td) of solid radio, active waste per unit containing a calendar year 1987 the licensee disposed of 4800 cubic feet
total of 280 curies of activity.
This volume of waste shipaed i
j was below the PWR national average of 6590 ft3 per unit.
The
solid radwaste volume shipped as of June 30, 1988 was 6190 ftd
)l 3er unit which contained a total of 390 curies of activity.
i Juring the assessment period, the licensee began shipping noncompacted waste to a vendor for supercompaction and eventual
disposal.
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At the end of December 1987, the licensee maintained approxinstely 18,000 square feet (ft*) or 11% of the RCA as l
contaminated (excluding containment).
The area being controlled
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at the end of the assessment period was appropriately 16600 ft*
or 10.5% of the RCA.
The area contaminated is near the median
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for facilities in Region II.
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Three violations were identified during the assessment period:
(a) Severity Level IV violation for failure to adhere to radiological control procedures for personnel contamination monitoring and completion of daily dose cards (87-31).
(b) Severity level IV violation for failure to establish
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adequate written procedures for controlling contaminated l
tools (87-40).
i (c) Severity Level V violation for failure to post the current l
copies of a Notice of Violation (87-40).
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Performance Rating
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Category 2 3.
Recommendations
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None.
J C.
Maintenance / Surveillance
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1.
Analysis During this assessment period routine and special inspections were performed by the resident and region based inspectors.
Inspections in this area included inspection of inservice inspection, snubber surveillance, post refueling startup tests and water chemistry.
The maintenance and surveillance programs appeared to be well organized with a well trained and qualified staff.
Management involvement in maintenance is improving.
Early in the assessment period there were indications that maintenance priorities on some systems were inaparopriately low.
Compressed air systems which contributed to failures of the diesel engines and problems with feedwater control valves are examples.
Throughout most of the assessment period there remained a significant maintenance backlog.
An improving trend was noted towards the latter part of the assessment period due to increased management efforts.
Challenging goals have been
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established.
The current level of management attention is
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i a]propriate and should continue. Management has also recognized t
t1at the station modification backlog is high and has taken
'
ef forts to prioritize and reduce it.
Also a new station work control program is under development.
The licensee has established system and corponent expert programs which designate a qualified individual as an expert on a particular component or system.
The expert serves as the issues. point for operability, maintenance and codification focal Although the system expert program is still in the infancy stage, the component expert program is fairly.well
established.
Additionally, the licensee has staffed a group of l
maintenance enginects to assemble component failure data, I
evaluate component lifetime, and adjust preventive maintenance
,
i oractices to improve the reliability of equinment.
The licensee
las experienced repeated failures of the residual heat removal hot leg suction isolation valves.
Thermal binding aaparently
.
causes the valves to stick shut, particularly on Unit 2, as I'
operators attempt to open them for decay heat removal purposes.
Increased management attention is warranted is this area.
.
!
Maintenance and surveillance activities reflected adequate
,
j planning.
Periodic surveillance requirements are tracked by
'
computer.
The program has the ability to flag overdue activ1-
,
j ties.
The licensee uses an additional computer to record
-
',
outstanding Technical Specification items.
The daily
'
outstanding items list is available to key personnel at morning
l status meetings.
The work planning program is effective in
,
scheduling tests and maintenance and minimizes the opportunity l
for opposite train component inoperability overlap.
'
A clear trend of improvement was demonstrated in the performance
[
of Technical Specification surveillance recuirements during the
assessment period.
Procedures were adequate.
Very few tests i
were missed or improperly performed.
One area of weakness was i
noted in diesel generator surveillances in that missed tests
+
occurred due to errors in tracking engine failures and
!
non pre-lubricated cold-f ast starts.
Corrective action was l
l effective and improvement observed.
Weaknesses were also I
identified in the calibration program for safety related
'
'
instrumentation not referenced in Technical Speciffcations.
The l
licensee did not require all instruments to be subject to an assigned calibration period and in some cases, calibration periods significantly exceeded manufacturers recommended
intervals.
Once identified the licensee took effective steps to
calibrate the instruments, evaluate out of specification
!
a j
findings and ensure all instruments were entered into the j
program.
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1
During the last SALP period, several licensee identified
violations occurred associated with missed or inadequate retests following maintenance or modifications.
Inadequate maintenance
'
retests occurred sporadically and one violation was issued during this SALP period. No cases of nonfunctional equipment
-
left undetected occurred as a result of retests. Problems were,
,
however, identified in the area of configuration control.
One
'
safety related pressure switch on the auxiliary feedwater system i
rersained isolated for up to one year rendering one train i
inoperable under certain accident scenarios.
Several instances
.
I occurred where sliding links were discovered mispositioned rendering various equipment non-functional including one case where an emergency bus would not have automatically isolated
from a degraded voltage source.
Two events occurred which revealed improper use of jumpers as a contributing factor t
resulting in a damaged motor operated valve actuator and a
'
ventilation train unknowingly inoperable during cc; e alterations.
Licensee corrective action included cabinet inspections and retraining on independent verification and i
i jumper /slidinglinkcontrol.
r
>
Probably the most significant event of the period occurred on March 9,1988,lating valve failed open.when Unit 2 tripped from 21%
i feedwater regu Operators noted after r
20 minutes that auxiliary feedwater flow to 2 of the 4 steam
-
generators had significantly degraded.
Additionally, it was i
discovered that the water source for auxiliary feedwater had inadvertently swapped to the assured source, nuclear service
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i water.
The cause of the degraded flow was later determined to l
be cloggint of the flow control valves with asiatic clams which
l had been a lowed to collect and grow in stagnant service water
piping.
The licensee had responded to IE Bulletin 81-03, had
)
recognized the potential for clams to exist in stagnant piping t
and had taken action to verify none were present including spot
t radiography of piping low points.
One violation was identified
)
by the AIT, however, as the surveillances were inadequate and
did not detect the clams.
Managen:ent response to the event was timely and thorough.
The licensee is now performing periodic l
'
j flushes of susceptible lines and has implemented administrative
controls to prevent inadvertent swapover to service water.
I l
The licensee experienced a significantly high rate of diesel
engine failures this assessment period.
At one point all four t
engines were required to be tested at an increased frequency due l
,
)
to excessive failures.
One violation was identified when the
'
licensee failed to classify and re> ort a failure.
Some failures
appeared to be isolated however otlers can be grouped into three
}
majorareas.
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t Humphrey shuttle valve in the control air pneumatic
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shutdown logic.
This component caused two valid failures and several invalid failures from October to December 1987.
,
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The component was replaced with a fast acting pneumatic
"0R" gate.
Diesel Generator Air Start (VG) System problems caused l
-
excessive moisture carryover into the control air system
and subsequent corrosion of components.
Increased blowdown of air compressor aftercoolers and increased surveillance of air dewpoint and sensors was implemented.
Modifications
<
were scheduled for desiccant air dryer control panels and
'
aftercooler drain valves.
Calcon Model B4400 pressure sensors (used in the control
-
air system) manufacturing deficiencies caused at least
.
three failures during A)ril to May 1988.
A 10 CFR 21 l
,
report was issued by IFO Delaval on this component in
<
parallel with the licensee problems and the pressure switch j
was modified.
j Although air system moisture can be attributed to inadecuate maintenance of the system, the control air component pro)lems
1 were intermittent and extremely difficult to isolate.
Correc-l tive actions which are discussed in detail in the Engineering
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Support Section appear to have been effective since the number i
of DG failures significantly declined near the end of the SALP
period.
f l
Equipment fai',ures and malfunctions caused or contributed to 9 i
of the 12 reactor trips this assessment period and were
}
identified as causes for ap3roximately 32% of the ESF
actuations.
One trip involvec a blown control rod drive fuse.
!
l This type fuse had previously been shown to be unreliable and was replaced with a more reliable type.
However, a weakness in
-
the licensee's program allowed the less reliable fuse to
!
subsequently be used for the application.
By far the most
!
significant area of concern were feedwater regulating valve
'
failures which caused four of the trips.
Problems have centered
!
around clogging of electro pneumatic converters with debris from I
its air supply, calibration mismatches between valve demand and
!
actual position and circuit card failures.
These have challenged
the operators during plant transients and during steady state
.
oaeration when the valves must be maintained in manual control.
i
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j T ie licensee has pursued corrective action which includes
installatien of fans in the process cabinets and establishment i
of a task force to evaluate solutions.
Problems, however,
.
continue to occur particularly on Unit 2.
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Instrument
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Of the total personnel errors causing ESF actuations, largest and Electrical (IAE) technicians were the second
'
contributor behind Operations personnel.
Errors typically involved failure to follow procedure or component misidenufi-cation.
The resulting events were relatively minor actuations
of auxiliary feedwater or service water and did not cause any t
plant transients, reactor trips or safety injections.
Although i
the nurber of errors is still viewed as high the trend coupled g
withthereductioninsignificanceoftheESEactuations,shows
,
some improvement from the last assessment period.
Eleven violations were identified during this evaluation period in this area.
(a) Severity Level III violation for an inadequate surveillance program to detect the growth of Asiatic clams in the nuclear service water system which resulted in the clogging
'
of auxiliary feedwater flow control valves and inoperability of the system after a realignment
'.o the nuclear service water system (88-14).
'
(b) Severity Level IV violation for inadequate measures to calibrate all safety related instruments (87-30).
(c) Severity Level IV violation for failure to properly classify a diesel generator failure (87-42 Unit 1 only).
(d) Severity level IV violation for failure to perform adequate channel checks on auxiliary feedwater flow rate instruments
'
(87-25 Unit 2 only).
l (e) Severity Level IV violation for failure to control and calibrate stopwatches used in activities affecting quality
>
(88-18).
.
(f) Severity Level IV violation for failure to test a contain-
"
ment isolation valve (2BB-61) following maintenance (88-18, t
Unit 2 only).
j
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(g) Severity Level IV violation for inadequate measures to i
'
control and accomplish eddy current inspection of steam generator tubes resulting in a TechnOal Specification
,
violation (88-09, Unit 2 only).
!
(h) Severity level IV violation due to an emergency bus being incapable of deenergizing during a degraded voltage situation (88-15 Unit 2 only).
i i
(i) Severity level IV violation for an inoperable auxiliary
!
feedwater flow path due to a pressure switch remaining
'
isolated (87-30 Unit 1 only).
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1 (i) Severity Level V violation for failure to apply corrective actions involving inadequate mounting of a valve motor to other affected valves (88-08).
(j) Severity level V violation for failure of station manager or designee to approve station modifications (88-13).
2.
Performance Rating Category 2 3.
Recomendation Increased management attention is warranted due to the number of violations and personnel errors / procedural adherence problems.
D.
Analysis During the assessment period, inspections were performed by resident and regional staffs.
Inspections included observation of an annual radiological emergency preparedness exercise, two routine inspections,5 actions in response to Emergency Response and an announced followup inspection to review the licensee facility (ERF) appraisal. findings.
One radiological Emergency Plan change was reviewed during this assessment period.
An adequately staffed corporate emergency response and planning organization routinely provided support to the plant.
Key positions in the corporate and plant emergency response organizations were filled.
The licensee effectively responded to NRC initiatives regarding emergency preparedness issues, as demonstrated by effective planning and implementation of corrective actions in response to exercise weaknesses discussed below.
The licensee has provided excellent dedicated Technical Support Center, Operations Support Center, and offsite Crisis Management Center facilities.
Routine inspections performed during the assessment period disclosed that the following key emergency planning elements were adequate:
emergency detection and classification (note, however, the contrasting weakness during the annual exercise discussed below); protective action decision-making,lculationtraining, i.e.,
knowledge and performance of duties, dose ca assessment; review and audits; organization and management control; and effective maintenance of the Emergency Plan and irplementation procedures.
The licensee continues to pror>ptly submit to the NRC all revisions to the cited plan and implementing procedure.
.
The 1988 annual emergency preparedness exercise was observed and evaluated.
Player performance was adequate in most areas of response; however, nspection disclosed five weaknesses during the course of the exercise, including:
'
Failure to provide timely health physics support during the
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medical emergency drill.
Failure to implement the scenario objective regarding
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demonstration of the ability to declare General Emergency classification.
Failure to arovide adequate communications between and
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within the ERFs.
Failure to ensure dissemination of accurate news
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information to the public.
Failure to provide timely dose projections and field
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measurement data to of fsite agencies and the protection action recomendations made old not agree with the licensee's flowchart.
The poor performance observed by the inspection team was identi-fled as an insufficient appreciation of the requirernents of exercise participation i.e., a lax attitude, primarily on the part of the Crisis Management Center (CMC) players.
Following the exercise critiques, as corrective actions, the licensee committed to perform a table top training exercise for the dose assessment team as well as to fully participate with the CMC in the upcoming McGuire exercise which they were previously not planning nor required to do.
Revision 10 of the Catawba Radiological Emergency Plan was submitted to the NRC for Review.
Based upon review of the subjectlicenseesubmittal,thechangeswereconsistentwiththe requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50.
No violations or deviations were identified during this assessment period.
2.
Performance Rating Category 2 3.
Recomendations Board Comment:
Though outside the SALP period, the CMC staff participation in the September 1988 McGuire exercise demonstrated that a good corrective action program had been performe _ ~ _.
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E.
Security l
1.
Analysis
i During this evaluation period, inspections were performed by t
i
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the Resident and Regional inspection staffs.
The total of five t
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inspections of the security program included one special inspec-
,
tion conducted in response to a licensee reported safeguards
event concerning the failure to adequately protect safeguards
,
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information.
Inspections confirmed the occurrence of six physical security events in addition to three violations.
One
inattentive guard was found by the Senior Resident Inspector
'
during the assessment period.
>
In general, the licensee's security program, as established and
'
maintained, conformed with commitments contained in approved t
Physical Security, Contingency, and Training and Qualification
'
Plans.
The licensee demonstrated evidence of planning and
j prioritization of physical security matters.
The authority and i
detailed responsibilities associated with security operational I
activities are identified ar.d adequately defined in security i
plans and procedures.
The licensee's efforts to ensure the i
resolution of operational and functional security issues
continued to be positive, and responsiveness to NRC initiatives l
was timely.
Each of the violations and the physical security l
events identified during the evaluation period were the result f
j of a failuce to comply with procedural requirements, primarily
'
access controls.
I
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The licensee's submittal of 1.icensing Actions relating to
Physical Security, Safeguards Contingency, and Training and i
Qualification Plans were timely and relevant.
The basis for the
!
i revisions was clearly stated.
The licensee responded adequately
!
to changes in regulatory requirements.
,
,
j The licensee maintains an effective audit program that has i
'
contributed to security program improvements through i
identification of deficiencies and areas requiring enhancement, l
Audit findings are reviewed for generic application at each of
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the licensee s nuclear facilities.
i
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The operational capability of the security organization was
'
enhanced by an effective training program.
The effectiveness of
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the training and qualification program was evident in personnel performance of security duties and positive morale.
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During the assessment period inspection in the area of Material
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i Control and Accountability (MC&A) was conducted at the Catavba
Nuclear Station.
The inspection confirmed that the licensee had established, maintained and followed adequate HC&A procedures
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for controlling and accounting for fuel and non-fuel type special nuclear material.
The licensee had maintained an adequate staff that was familiar with the assigned functions.
The licensee had properly documented and reported required inventory change reports and material balance information.
No violations or deviations were identified in the HC&A area.
Ihree security related violations were identified during the evaluation period.
These violations were not indicative of a significant breakdown in the security program, but did reflect a lack of knowledge or attention to security procedural require-ments.
The violations were:
(a) Severity Level IV violation for failure to comply with protectedareaaccesscontrols(87-39)
(b) Severity Level IV violation for failure to control access to Safeguards Information (87-43)
(c) Severity Level IV violation for failure to protect Safeguards Information (87-43)
2.
_ Performance Rating Category 2 3.
Recommendations None.
F.
Engineering /Techn,ical Support 1.
Analysis The Engineering and Technical Sup) ort functional area addresses the adequacy of the technical anc engineering support for all plant activities.
To determine the adequacy of the support provided, specific attention was given to the identification and resolution of technical issues, operational events, responsiveness to NRC initiatives
,nforcement history staf fing, ef fectiveness of training,and qualifications, an'd if the assurance of quality was provided by the support given.
It includes all licensee activities associated with plant modifi-cations; technical su provided for organizations maintenance, testing, pport surveillance; training; and and configuration management.
This evaluation is based on routine and special inspections conducted by resident and regional personnel in this area as well as related functional area.
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i Several technical issues were identified during the SALP period that required engineering and technical support.
Primary issues
were diesel generator testing and misalignment of Nuclear
!
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Hanagement recognized the need to improve diesel generator (D/G)
,
reliability due to an unusual number of failures which occurred
'
I while performing D/G testing (5 failures in 20 starts).
The
licensee aggressively pursued identification of the root casuses for the failures and ' implemented extensive corrective actions.
These included establishment of a diesel engine reliability task
'
force and scheduling of modifications for the engine control and l
}
monitoring functions.
Both long term and short term corrective
-
actions resulted from the task force.
l
Short term corrective actions aimed at resolvir.g the problem l
)
were implemented to improve the quality of the air in the D/G i
starting air system.
Included in the corrective actions were i
increased surveillance frequencies, increased maintenance frequencies, the addition of an automatic aftercooler blowdown
.
i to decrease moisture content the installation of a separate
.
nitrogen control air system for one diesel, and replacing the
flawed pressure sensor.
The licensee also planned to replace the oneumatic emergency trip functions with aa electrical system i
by tie end of each unit's next refueling outage.
l, It appears the licensee provided approprfste corrective actions,
!
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both short term and long term for the problem identified with
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I the 0/G.
The effectiveness of the corrective actions will be
,
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determined during future inspections.
Misalignment of Nuclear Service Water was identified by the
NRC during an inspection conducted on January 11-15, 198.8.
A
)l Severity Level IV Violation was issued.
The response provided l
,
to the NRC during an enforcement conference was complete and
!
i thorough.
The licensee showed that the alignment of the Nuclear j
Service Water System did not place the plant in an ur. analyzed J
)
condition, and that all systems required for accident conditions
<
J were in fact operable.
The licensee demonstrated a tForough and i
complete understanding of the system, and the effect of the
'
valve alignment on the system.
j The licensee provided adequate and timely responses to most NRC
initiatives.
However, one exception, wnile performing an EQ
'
inspection, was noted where the licensee's response to a finding
regarding submergence of the reactor coolant system wide range temperature detectors was not timely.
Following the review of
!
!
other EQ issues the inspection team concluded that the licensee j
had adequate controls in place to ensure proper distribution, review, and evaluation of both NRC Notices and Bulletins
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relative to EQ equipment.
Technical recuirements for procure-ment of EQ equipment were clearly defined by the design
engineering group the design process and were properly described
<
on the purchase documents,
,
further review of EQ documents indicated that management was
,
taking vigorous corrective action to improve the training t
i provided to those personnel that provided support in assuring
<
]
proper EQ application (Engineering,ing an on-site Design Maintenance etc.).
The
!
licensee had also completed staff
'
Engineering (D/f.)
The group is providing timely
!
responses to issues group.
i i
Two ins)ections were performed in the area of Welding /NbE in l
which t1e overall performance was good.
It was apparent in
'
l observing in-process work and reviewing control procedures that
.
management was involved in asse-%g quality.
The staffing level
!
for the work involved has show
.o be adequate at all levels
(Craf ts, QA/(fC, Engineering au supervision).
Based'on the
.
i quality of tie wor t performed and inspections and review of l
)
qualifications records,. the effectiveness of training and
.
qualification is adequate.
One pendin escalated enforcement action in the area of environ-
!
mental qua ification of equipment is attributed to this area.
Three violations were issued as described below.
These viola-l
!
tions appear to be isolated incidents and do not represent i
a programmatic weakness.
l
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i
(a) Severity Level IV violation for failure to follow TS for (
Nuclear Service Water System (88-06).
j l
(b) Severity Level IV violation for failure to follow TS 2.2-1
!
in determining equation 2.2-1 was satisfied following
!
!
nonconservative reactor trip setpoint adjustment (87-30
!
!
Unit 2 only).
,
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(c) Severity Level V violation for failure to maintain two i
operable channels of valve position indication for PORV i
i j
block valves (88 25).
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j 2.
Performance Rating
Category 2 j
$
3.
Recommendations None.
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G.
Safety Assessment / Quality Verification 1.
Analysis This section includes an assessment of licensee activities
'.
associated with the implementation of licensee safety policies;
licensee activities related to amendment exemption and relief requests;responsetoGenericLetters,BulletinsandInformation
,
-
.
Notices, and resolution of THI items and other NRC initiatives.
'
This section also includes licensee activities related to the
'
resolution of safety issues, and self assessment activities.
This assessment was based in part on the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the rating period.
These actions consisted of amendment requests, responses to generic letters,ing data are listed in Section V.F of this bulletins, TMI items and other actions.
!
i Specific support i
re> ort.
The number of licensing actions completed during this
SALP period was 57 for Unit 1 and 58 for Unit 2,ived from the or 115 for the Station.
The number of licensing actions rece l
licensee was 59 for Unit I and 60 for Unit 2, or 119 for the
!
i Station.
These can be divided into various categories.
Four l
l categories and the number of actions completed for these are:
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Unit 1 Unit 2
,
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License amendments
25
.
NUREG-0737 actions
2 t
Generic actions
9 L
Requests denied
5 i
,
Overall corporate management leadership,ive manageecat involve direction and support of licensing activities was good.
Effect
.
!
ment in site activities associated with licensing areas was evident through prior planning, assignment of priorities, and
,
d i
decision making processes.
Management was usually aware of generic and plant-specific safety issues and the schedule for
their resolutions.
Site and corporate priorities occasionally i
]
conflicted.
Management was attempting to improve the prioriti-z ration process.
Management needs to improve the quality of its requests for i
licensing amendments and other NRC submittals.
Several requests l
were denied because of inadequate support and mathematical
.
l errors.
l l
The licensee understood the technical issues and considered I
j carefully the impact of various NRC requests and positions
!
j on the plant.
Conservatism was generally exhibited in the s
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licensee's approach to the resolution of technical issues from a
.
safety standpoint, and the approaches were generally sound and I
thorough.
The licensee made effective use of meetings with the NRC to resolve licensing issues.
The licensee was generally well
,
presared and provides ample support for its positions during suc1 meetings.
l
,
,
Duke was an active participant, and frequently assumed a leading c dustry activities regarding matters of
role, in nuclear n
generic concern.
,
!
The licensee usually provided timely responses to NRC requests and positions, and responses were generally sound and thorough.
,
However, examples of untimely responses followed the NRC's
,
requests in Bulletin 88-02 for implementation of an enhanced leak rate monitoring program and in Generic Letter 88-05 for prompt implementation of a program of systematic measures to
,
ensure that boric acid corrosion does not significantly degrade
,
the reactor coolant pressure boundary.
The licensee's written
<
responses to the NRC regarding the Bulletin 85-03 program,
{
Motor Operated Valve Common Mode Failures During Plant Trans-
.
ients Due to Improper Switch Settings were technically sound
!
and thorough.
CatawbarecognizedtheImportanceofthisprogram
!
and expanded the scope to all safety related motor operated
valves.
It!s was a s'ignificant task that involves approximately
!
460 motor operated valves in addition to the 80 bulletin valves.
I i
The technical expertise of the licensing staff assigned to Catawba was good, the nyerall staffing to support licensing
activities was adequate.
The licensing department is located in
!
the licensee's corporate headquarters in Charlotte, North t
Carolina which is approximatley 20 miles from the plant.
This l
proximity facilitates better communications and understanding of i
plant objectivies and regulatory requirement.
t In addition, there are several individuals in the onsite i
Regulatory Compliance Group who handle the dayional staff. Theto-day
!
!
interface with the NRC inspectors and NRC reg l
l staff has good knowledge of the plant, of technical issues, and
a good historical knowledge of plant systras and program inte-
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gration.
The licensee has taken effective measures to minimize
!
dependency upon outside contractors, and this has increased the ability to provide more timely responses.
With regard to reporting of operational events, the Licensee
!
Event Report (LER) program was adequate.
The LERs adequately l
described the major aspects of the event, including component
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or system failures that contributed to the event, and the significant corrective actions taken or planned to prevent i
,
recurrence.
The reports were thorough, detailed, well written
and easy to understand.
The licensee, however, should heighten their sensitivity to the reporting of significant events in a timely manner to the NRC.
,
One example of a slow report was loose parts and tube degrada-l tion in the Unit 2 stear generators.
A delay in reporting this significant issue was caused by waiting until all the facts were
,
known.
l Followup of eveits and generic issues was generally thorough.
Corrective actions were generally thorough.
However, some l
repetitive problems have occurred such as:
loss of Main feed-l water aump (lves, p(roblems associated with con MfW) causing Auxiliary feedwater starts, problems
with MFW va links and jurtpers see NRC Report 413,414/88-13), configurat on control problems, and the continuing high rate of personnel
errors.
i i
I To enhance Catawba's overall quality of performance, the
!
licensee recently established a site Performance Indicator (
Program.
Indicators have been established for material
!
condition, modification backlog, commitment index, personnel i
exposure, people performance (errors), cost per kilowatt-hour, i
safety system unavailability,ive maintenance ratio, and work
[
gross equivalent availability factor, preventive to correct (
request aacklog.
Challenging goals have been established and r
positive results are already being seen in several areas.
One i
area showing improvement is the commitment index, i.e., open (
items list.
Open items have historically taken too long to be l
addressed and closed resulting in a large list and many overdue
!
items.
This indicator has provided for management attention in
!
this area resulting in changes as to how items are tracked,
'
reduction in numbers and restrictions on due date extensions.
The site Performance Indicator Program is considered to be a t
management strength, j
One violation wa's identified during this evaluation period in this area.
'
(
Severity Level IV violation for f ailure to adequately
!
-
'
control overtime of personnel performing safety related L
activities (88-22).
I 2.
Performance Rating i
Category 2 l
!
i I
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3.
Recommendations f
None.
V.
SUPPORTING DATA AND SUtHARIES l
J
]
A.
Investigations j
j No major investigative activities occurred during this assessment f
j period.
'
]
8.
Escalated Enforcement Actions F
j 1.
Violations Issued or Pending f
Severity Level III violation, issued June 13,1988; no
-
J Civil Penalty.
Inadequate test program which permitted the
!
,
Auxiliary Feedwater System to be placed in service, ion
to be i
i degraded and unable to meet Technical Specificat
!
j requirements for operability.
I
'
l
.l Escalated Enforcement action is pending on Environmental
!
-
!
Qualificationissues.
l 2.
Enforcement Conferences
!
November 6, 1987 - Auxiliary Feedwater System transmitter I
l Severity Level IV violation, issued
!
December 1, 1987.
l
"
January 15, 1988 - Safeguards Enforcement Conference.
,
l!
February 23, 1988 - Nuclear Service Water System; Severity
,
level IV violation, issued March 14, 1988.
l jl
-
l April 29, 1988 -
Auxiliary Feedwater System Degraded Flow; Severity Level III violation no civil a
.
j penalty, issued June 13, 1988.
i July 1, 1988 -
Environmental Qualification; Enforcement Pending
.
C.
Licensee Conferences I
i October 29, 1987 -
SALP meeting with licensee at Catawba site.
i January 28, 1988 -
Technical meeting with licensee Design
!
Engineering, Charlotte, North Carolina to
discuss current issues and concerns.
!
l
!
.
L
.
.
-
i
.
-
, -
_ - - _ _ _.
-
.
.-. - - _ _ _ -
.
.
f
!
June 9, 1988 Hanagement meeting with licensee to discuss
-
Diesel Generator operability concerns at
,
Region II office.
i D.
Confirmation of Action Letters (CAL)
,
A confirmation of action letter was issued regarding the Auxiliary r
feedwater System swapover event which occurred on March 9,1988.
!
E.
Review of Licensee Event Reports During the assessment period, there were a total of 63 LERs analyzed
[
'
(32 for Units 1 and 31 for Unit 2).
The distribution of these events
'
by causes, as determined by the NRC staff was as follows:
Causes Unit 1 Unit 2 Total
i
,
Component failure
5
[
d Design
0
!
Construction / Installation /
4
,
,
Fabrication Other
6
!
Personnel
Operating Activity
6
I
-
Maintenance Activity
4
-
i Test / Calibration Activity
5
-
Other
1
'
-
wIAL
31
!
)
!
]
NOTE 1:
The "Other" category is coeprised of LERs where there was a spurious signal or a totally untnown cause, i
NOTE 2:
With regard to the area of "Personnel", the NRC considers i
lack of procedures, inadecuate procedures, and erroneous i
j procedures to be classifiec as personnel errors.
The Board
!
recognizes that the licensee considers these management
t
}
deficiencies.
[
f.
Licensing Activities
!
a
I j
The assessment of licensin activities was based in part, uaon i
licensing actions sucessful y completed during this period.
These I
included the following:
'
'
l NUREG 0737 1.0.2 Safety Parar.eter Display System
!
Item 2.2.1 Equipment Class Programs for Safety-Related i
Components
!
i I
I i
-
l
il
_ _ _ _ _ _ _ _ - - _ _ _
_ _ - _ _ - - _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -
_ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
l
,
o
!
!
,
'
'
Item 4.1 Reactor Trip System Reliability-Vendor Modifications
.
'
'
Items 4.2.1 and 4.2.2 Preventive Maintenance for RTBs-Maintenance and Trending
.,
,
ATWS Rule 10 CFR 50.62
'
PTS Rule 10 CFR 50.61
Licensee follow-up on RTB Binding with Westinghouse l
,
'
Resubmitted Startup Physics Test Programs
!
Response to Several Bulletins i
Unit 1 Amendments 29through51(identifiedbysubjectsbelow)
l
'
Unit 2 Amendments 20 through 44 (identified by sub;ects below)
l
,
L Amendment issued during the assessment period addressed:
- Extension of several surveillance intervals
!
l
Containment Penetrations
- Increase time allowance for accumulator chemistry t
!
Removalofupperheadinjection
[
Inoperable but trippable control rods i
Tradeoff of RCS flow against reactor power i
Modification to Turbine trip circuitry
i
Containment air release and additional systems
!
'
j Typographical errors and additional clarlfications l
'
j Increase fuel enrichment to 4.0 weight percent U-235 i
"
Boron dilution mitigation system
'
!
Removal of RID bypass manifold
!
'
Increased allowed containment leakage rate
!
Reduce RCS total flow
- Physical security plan l
Ice condenser lower inlet doors r
'
Monitor tank building l
PORVblockvalvechannels(Emergency Steamgeneratortubepluggingcriter)a
[
'
i e
Sections 3.0 and 4.0 to conform to GL 87-09 i
Deletion of RTO bypass loop test i
Fuel assemblies
!
i'
Diesel generator hot restart test l
{
Accumulator tank (Unit 2 only)
i
'
'
J Safety parameter display system (Unit 2 only)
f f
The assessment also included licensee requests during the period
j which were denied by the NRC.
These requests included:
j
- Increase Allowed Unidentified Leak Rate - Inadequate Technical Basis (flaw stability)
Containment Air Release and Addition System - Inadequate f
,
'
Technical Basis
>
$
c
Reload Methodology using CASH 0-2E - Gross Mathematicci Errors
.
i i
I
!
l i
1
- -
-
-
-
>
. - - - - -
.
-
.
. -
_ - - - -
.
. _ _ _ - _ _
- _ -
_ _ _ -
!
.
.
,
,
>
'
i
'
Deletion of non-Type A RG 1.97 Variables - Premature and i
Inconsistent with Staff Positions
'
use of Susuarized Measurements in Environmental Annual f
Reports -Actual Measurements Needed, Inadequa+,e 50.92 Analysis l
r One emergency amendment was issued during the period dealing with i
PORV Block Valve Position Indicator Channels.
No exemptions and no
,
'
exigency amendments were issued.
!
Three discretionary enforcement actions were granted to the licensee during the assessment period.
<
)
Meetings with t.he iltensee and/or site visits occurred during the l
assessment oeriod to discuss and work toward the resolution of
various tecinical issues and planned changes.
These included the
l following:
'
i i
'
i Metallurgical examination of Catawba RTB pole shaft welds
,
'
J Integratedsafetyassessmentprogram(GL88-02)
'
Substitutions within fuel assemblies I
i
Direct generation response spectra and snubber reduction program I
Station safety review functions
)
TDI diesel generator
'
G.
Enforcement Activity i
i I
(
No. of Violations i
in Each Severity 1.evel j
......................_..............
t
}
Functional Area
!
II III IV V
!
i j
Plant Operations
7
l I
Radiological Controls
2
,
4, i
!
Maintenance / Surveillance
8
l i
!
0
!
!
j Security
3
l Engineering / Technical
2
'
,
j Support l
i Safety Assessment /
1
j Quality Verification l
Total
23
!
,
i i
.
l
l f
.
'
-
-
- -
- - - -
-
-
--
- - _.
.
.
H.
,
1.
Unit 1 Two urplanned reactor trips occurred during this evaluation period and are listed below:
automatic subcritical trip from 1 X 10.tu
(a) August arperes intermed23,1987,iate range due to an equipment malfunc
,
i e detector failed due to water in the detector A source rang /or assembly and indicated high source range canister and neutron flux, (b) January 16, 1988 automatic subcritical trip from 1 X 10 10
'
amperesintermedIaterangeduetoanequipmentmalfunction.
-
An intermediate range nuclear instrument was deenergized when a control power fuse blew causing an indicated high i
)
intermediate range neutron flux.
,
l
,
2.
Unit 2
!
!
Ten unplanned reactor trips occurred during this evaluation i
period and are listed below I
'
j (a) September 3,1987, automatic trip frote 22% power due to
.
an equipeent malfunction and a personnel error, Operator
!
failed to evaluate the symptoms of a malfunctioning feed-
'
water bypass control valve, and compounded a feedwater transient which resulted in a steam generator low-low
l-level, i
(b) September 15, 1987, manual trip from 48% power due to an l
equipment malfunction.
The 28 feedwater control valve
!
failed closed due to an overheated electronic component i
<
!
in the controller / driver circuit card resulting in an
.
impending steam generator low-low level.
l (c) November 3,1987, manual trip from 59% power due to an l
equipment malfunction.
A seat leak on a steam generator
-
i level instrument reference leg caused erratic indication
j which resulted in a turbine trip, main feedwater pump trip,
-
and eventual impending steam generator low-low level.
l
t j
(d) March 9,1988, automatic trip from 15% power due to an (
i equipment malfunction.
The 2B feedwater control valve l
failed open due to a defective printed circuit card and i
controller / driver card causing a steam generatar high-high (
levelfeedwaterisolationandeventuallyalow-lowlevel.
i
--- - - -,-,-- -- -. -.., - - -.. -. -. -, - - _.,
- - _ - -.,,,..
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- -.. -. -. -. - -. _. -
. -. =
,
-
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- ,
.
-
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-
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'
r P
(e) May 27,1988, automatic trip from 100% power due' to.a management and design deficiency.
Inadequate human factors consideration for the operator and computer graphical
,
dis) lay of a control power distribution. system coupled wit 1 a lack of training on the display led operators to
'
deenerynginasteamgeneratorlow-lowlevel.ize power to a main fee result
'
(f May 28, ions., manual trip from 15% power due~ to equipment 1988 malfunct Erratic. operation of the 2C feedwater bypass
'
control valve due to suspected debris in the electro /
pneumatic converter and a circuit card failure coupled with i
a mismatch between indicated' and actual valve-position
'
contributed to an impending steam generator low-low level..
.
(g) June 3, 1988,. manual trip from 38% power due to a personnel
error.. Steam supply to the operating main feedwater pump'
was inadvertently isolated causing an impending steam
'
- generator low-low level.
,
,
(h) June'6,1988, automatic trip from 60% power due to a
me.intenance control deftaiency.
An incorrect type fuse was used in the rod control circuitry which subsequently blew, causing a dropped rod and a power range high negative flux a
rate.
'
(i) June 20, 1988, manual trip from 98% poser due to an equipment malfunction.
A control board switch failed causing a low bearing oil pressure trip of one main feedwater pump turbine and an impending steam generator low-low level.
,
(j) ' June 26,1988, automatic trip from 100% power due to a
,
personnel error.
An operator misinterpreted a test proce-i dure step and shut a main stem isolation valve which caused i
a steam generator low-low level.
'
!
I.
Effluent Summary Activity Released (curies)
- 1985 1986 1987
,
1.
Gaseous Effluents
.
!
Fission and Activation Products 2.77 E+2 2.72 E+3 4.82 E+3
'
i Iodine and Particulate 6.40 E-4 1,47 E-2 1.57 E-2 I
.
i
I i
.
.
Activity Released (curies)
- 1985 1986 1987 (cont'd)
2.
Liquid Effluents Fission and Activation Products 1.26 E+0 7.64 E-1 1.31 E+0 Tritium 1.75 E+2 2.36 E+2 7.28 E+2
"Unit 2 was not operational d'n ing 1985.
Therefore, these 1985 values reflect only the effluents for Unit 1.
'i
.i
,
.,
!
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C** Print Diagnostics for: 92SL 3618 Total Formatting Exceptions = 6 Total Listed Below = 6 The Following Two Formats Will Be Used:
Page/Line Format Exception Message Found By The IBM 5520 Sheet Number Format Exception Message Found By The Printer 5.0.0/25 0020-Line Is Too Long To Be Justified 7.0.0/16 0020-Line Is Too long To Be Justified 10.0.0/24 0020-Line Is Too Long To Be Justified 20.0.0/39 0020-Line Is Too long To Be Justified 21.0.0/17 0020-Line Is Too Long To Be Justified 23.0.0/38 0020-Line Is Too Long To Be Justified