IR 05000424/1993001
| ML20034G419 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/29/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20034G412 | List: |
| References | |
| 50-424-93-01, 50-424-93-1, 50-425-93-01, 50-425-93-1, NUDOCS 9303090487 | |
| Download: ML20034G419 (15) | |
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ENCLOSURE INITIAL SALP REPORT
U. 5. NUCLEAR REGULATORY COMMISSION REGION IT i
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE f
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Inspection Report Number 50-424/93-01 AND 50-425/93-01
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Georgia Power Company
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V0GTLE, UNITS 1 AND 2
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SEPTEMBER 29, 1991 - JANUARY 2, 1993
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9303090487 930302 PDR ADOCK 05000
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TABLE OF CONTENTS
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INTRODUCTION..........................
i II.
SUMKARY OF RESULTS.......................
l III. CRITERIA............................ 3
IV.
PERFORKANCE ANALYSIS...................... 3
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A.
Pl ant Operati ons..................... 3 B.
Radiological Controls.................
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C.
Maintenan:e/ Surveillance................. 8
D.
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E.
S e cu ri ty........................
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Engineering / Technical Support (ETS)..........
. 14 G.
Safety Assessment / Quality Verification.........
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V.
SUPPORTING DATA AND SUMMARIES................
. 18 A.
Licensee Activities..................
. 18 B.
Direct Inspection and Review Activities........
. 20 C.
Escalated Enforcement Action.............
. 20
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D.
Management Conferences.................
. 21 E.
Confirmation of Action Letters............
. 21 i
F.
Reactor Trips.....................
. 22 i
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Review of Licensee Event Reports (LERs)........
. 22
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Licensing Activities..................
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Enforcement Activity..................
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I.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an i
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I integrated NRC staff effort to collect available observations and data
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on a periodic basis and to evaluate licensee performance on the basis of this infomation. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a rational basis for allocation of NRC resources and to provide meaningful feedback to licensee management regarding the NRC's assessment of their performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on February 9, 1993, to review the observations and data on performance and to assess licensee performance in accordance with Mr.nual Chapter NRC-0516, " Systematic Assessment of Licensee Performance." The Board's
findings and recommendations were forwarded to the NRC Regional
Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance at Vogtle Units I and 2 for the period September 29, 1991, through January 2, 1993.
The SALP Board for Vogtle was composed of:
E. W. Herschoff, Director, Division of Reactor Projects (DRP), Region II (RII) - (Chairperson)
B. S. Mallett, Deputy Director, Division of Radiation Safety and Safeguards, RII A. F. Gibson, Director, Division of Reactor Safety, RII D. B. Matthews, Director, Project Directorate II-3 (PD 11-3), Office of Nuclear Reactor Regulation (NRR)
A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, P.II B. R. Bonser, Senior Resident Inspector - Vogtle, DRP, RII D. S. Hood, Senior Project Manager, PD II-3, NRR Attendees at SALP Board meeting:
P. H. Skinner, Chief, Reactor Projects Section 3B, DRP, RII D. A. Seymour, Project Engineer, DRP, RII
S. E. Sparks, Project Engineer, DRP, RII R. D. Starkey, Resident Inspector P. W. Baranowsky, Chief, Trends, Patterns and Analysis Branch, Office for Analysis and Evaluation of Operational Data J. L. Starefos, Intern, DRP, RII i
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SUMMARY OF RESULTS Vogtle continued to operate in a safe and conservative manner and exhibited good overall operational performance. This operational performance was characterized by long periods of operation at power with
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few transients or problems requiring shutdowns to resolve.
However, instances of inadequate procedure implementation, personnel error and i
inattention to detail during plant activities occurred. Management continued to perform an active and visible role in plant operations, and the professionalism of the licensed control room staff continued to be good.
Performance in the area of Radiological Controls remained excellent.
The radiation protection and chemistry staffs were well qualified and effectively supported routine activities. The licensee's aggressive control of contamination continued during the assessment period.
Programs for monitoring and controlling liquid and gaseous radioactive effluent, as well as for generation, storage, and shipment of solid radioactive waste (radwaste), were implemented effectively.
Maintenance activities were very effective this assessment period and did not result in any reactor trips or unplanned outages.
Improvements this assessment period were noted in the predictive and preventive maintenance programs, in the reduction of maintenance backlog, and the general material condition of the plant. Overall performance in the surveillance area was good. A recurring concern was noted with the failure to perform special condition surveillances.
j In the area of Emergency Preparedness, the licensee demonstrated an effective response capability for dealing with emergency situations during the annual NRC evaluated exercise, with the exception of notifications to State and local agencies. During the exercise, the licensee failed to make accurate and timely notifications to State and local agencies concerning emergency classification status, release conditions, and follow up information. The NRC staff recommends
continued management attention to the accuracy and timeliness of notification to offsite agencies.
Site management continued to support the Security program resulting in a high level of performance by its staff and proprietary security force.
Management's involvement was evident by efforts in areas of hardware upgrades, improved cameras, timely maintenance of failed systems, and the elimination of long-term compensatory measures. During the first part of this assessment period, the licensee continued to experience a
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high number of vital area doors being left unsecured from personnel r
errors or mechanical problems.
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The licensee's performance in providing engineering and technical
support was very effective during this assessment period.
Improvements from the previous assessment period were demonstrated in plant modifications, system engineering, and design control.
Effective
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performance continued in technical interface support and communications, i
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l system engineer training, qualification and certification and license'd I
operator training. The licensee's response to Generic Letter 89-10
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" Safety-Related Motor-Operated Valve Testing and Surveillance" (GL 89-10), was not sufficiently comprehensive.
Performance was excellent in the area of Safety Assessment / Quality Verification. Management was actively involved in assessing plant performance and safety issues, and fully :;upported organizations and programs that identify and assess problems. Overall, the Safety Audit and Engineering Review (SAER) audits were thorough and effective in
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identifying deficiencies. The Safety Review Board and Pl mt Review Board (PRB) continued to be effective in reviewi~
matters.
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Overview Performance ratings for the last rating period ano tne current rating period are shown below.
Rating Last Period Rating This Period Functional Area 10/01/90 - 09/28/91 09/29/91 - 01/02/93 Plant Operations
2 i
Radiological Controls
1 Maintenance / Surveillance
2 Security and Safeguards 2 (Improving)
Engineering / Technical Support 2 (Improving)
Safety Assessment / Quality
1 Verification 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 on March 18, 1993.
IV.
PERFORMANCE ANALYSJ1 A.
Plant Operations 1.
Analysis This functional area addresses the control and performance of activities directly related to operating the facility, including fire protection.
Vogtle continued to operate in a safe and conservative manner and exhibited good overall operational performance.
This operational performance was characterized by long periods of operation at power with few transients or
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problems requiring shutdowns to resolve. During this assessment period Unit I experienced no automatic reactor
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trips, one unplanned manual reactor trip, one forced
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shutdown due to high unidentified reactor coolant system (RCS) leakage, and one voluntary shutdown due to identified
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t leakage approaching TS limits. Unit 2 experienced two
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automatic reactor trips. The total number of trips was comparable to the number of trips during the previous assessment period.
The reactor trip on Unit I was due to a failed controller on a main feedwater pump (MFWP). The two Unit 2 automatic reactor trips were both caused by personnel
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error. One trip was caused by a plant equipment operator who inadvertently tripped a DC breaker while checking switchgear alarms. The second trip was caused by a technician momentarily grounding the main generator excitation circuitry which caused a main generator trip and resultant reactor trip.
In each of these cases the control room operators responded effectively.
During this assessmer.1 period instances of inadequate
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procedure implementition, personnel error and inattention to
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detail during plant activities occurred.
Examples included a failure to exercise adequate control over a Unit I reactor
cavity draindown evolution and inadequate procedures which i
resulted in the interruption of decay heat removal, an inadvertant entry into a condition prohibited by TSs associated with the hydrogen monitor containment isolation valves, and a failure to follow procedure during a Unit I startup which resulted in a failure to correctly withdraw t
control rods. Plant management recognized the weaknesses in
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these areas and has attempted to foster a greater awareness
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of procedural compliance and management expectations.
Personnel, including managers and supervisors, are held accountable for following procedures.
Performance is monitored through trend reports and by management i
observation and involvement. Although improvement has been
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observed, these ongoing activities have not been fully
successful. These types of problems were also observed in the previous assessment period.
The professionalism of the licensed control room staff was generally good. This was evident in observation of control room demeanor, watchstanding practices, shift turnovers, and attentiveness to duties. A weakness, however, was i
identified in Control Room formality. There was a tolerance of informality in one aspect of Control Room activities. As a result, an incident occurred where no personnel were in the 'at-the-controls * area of the Control Room for a brief period.
As a result of successfully licensing a relatively large number of personnel and a reduction in the attrition rate of
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5 licensed operators, the licensee reorganized the Operations Department to more effectively use their resources. This resulted in several licensed reactor operators being assigned to non-licensed duties and changes in responsibilities for some Senior Reactor Operator (SRO)
licensed personnel. These additional personnel resulted in better definition of responsibilities for shift personnel,
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more involvement in work planning activities by shift j
personnel, and more opportunity for field observation and
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involvement by supervisors. A Control Room staff exceeding TS requirements was maintained.
In addition, most department managers now hold an SRO license. This has resulted in enhanced communication and understanding of
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plant issues.
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Management continued to perform an active and visible role in plant operations.
In routine operational activities plant management actively participated in morning meetings, shift turnover activities, and management of the equipment-out-of-service list that prioritized repairs to equipment.
In an effort to more clearly communicate management i
expectations, management enhanced the process for control of infrequently performed evolutions. These evolutions included integrated engineered safety feature actuation systems tests, reactor vessel head lifts, refueling, reactor
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startup, etc. Briefings of the personnel involved in these evolutions were held by the manager responsible for the activity, prior to the activity being performed. These briefings covered various aspects of the evolution and management's expectations.
Management also initiated several innovations to improve the
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performance of the Operations Department. This included use of the computer to prioritize daily work activities by the shift supervisors, an integrated computer system and local area network that provided better access to data and information, and the implementation of some computerized rounds using a hand-held digital data entry device. The information obtained by the data entry device can be used by system engineers and others to track and trend data.
Improvements in the area of configuration control were noted during this assessment period. During the refueling outage in the early part of this assessment period, several problems occurred in the area of configuration control, such as the reactor cavity drain down incident. Corrective actions for these problems resulted in significant improvements in configuration control which were reflected in the most recent refueling outage.
During this assessment period, plant housekeeping and material condition continued to improve and were considered
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excellent. This was achieved through the continuation of a broad painting and preservation program, management walkdowns, a leak walkdown program, and greater accountability by plant personnel for plant appearance and material condition.
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Routine observation of activities associated with the fir _
protection program indicated the program requirements were well implemented. The Operations Department now has responsibility for the fire protection program and the fire brigade is composed of trained Operations personnel.
Fire protection surveillances that require operation of fire
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protection equipment are performed by Operations personnel.
A fire protection technician is on shift at all times in the Control Room to assist in implementing program requirements.
Fire brigade responses to drills were satisfactory.
During the assessment period, nine violations were cited.
2.
Performance Ratino i
Category: 2
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Recommendations
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Although the board has noted improvement in the area of procedural compliance, management attention in this area i
should continue to assure procedures are correctly implemented.
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B.
Radiolocical Controls 1.
Analysis i
This functional area addresses those activities directly
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related to radiation safety, radiological effluent control and monitoring, and primary / secondary chemistry control.
i The radiation protection and chemistry staffs, consisting of
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licensee and contractor personnel, were well qualified and i
effectively supported routine activities.
Personnel
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training was comprehensive, in-depth, and was a program strength, i
The licensee's aggressive control of contamination continued during the assessment period.
Contaminated square footage
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continued to be well-maintained, averaging less than 2 % of
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the total radiologically controlled area. The number of
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personnel external contamination events decreased from 53
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during the previous assessment period to 42 during the current assessment period. This represents a significant i
improvement given that this assessment period included two
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refueling outages as opposed to one during the previous
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period.
Radiation protection staff and licensee management were
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committed to meeting established dose goals. As a result, the licensee's actual collective dose for the assessment period remained close to the licensee's estimates despite forced outages during the assessment period that caused the licensee to expend more dose than planned in certain areas.
Overall, the collective dose for both units over the assessment period was approximately 649 person-rem. This is
well below the goal of 721 person-rem for this period.
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Overall, external and internal exposure controls were effective during the assessment period. No personnel exposures in excess of 10 CFR Part 20 limits occurred.
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Early in the assessment period, the radiation protection
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group was challenged by high levels of radiciodine in work areas in the lower levels of containment. The extent of the iodine levels was unanticipated and several workers received iodine internal contaminations exceeding the licensee's administrative limits. As a result of this experience, the licensee initiated effective corrective actions for the
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subsequent refueling outage, including engineering controls, the use of respirators, an extensive whole body counting program, and training awareness sessions on the extent of the iodine concentrations.
Isolated problens occurred during the assessment period that led to violations for improper entries into the Refueling Makeup Water Storage Tank (RMWST) valve gallery, inadequate high radiation area barriers, and improper use of digital alarming dosimetry.
No significant trends or weaknesses were identified from
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these violations and the licensee took appropriate corrective actions in response.
J The licensee developed and/or implemented a number of ALARA l
initiatives during the assessment period.
For example, the use of teledosimetry and remote video cameras was effective in reducing exposure during outages. Also, the resistance temperature detector (RTD) bypass manifolds were eliminated for both units, which should result in significant dose i
reductions during future outages. A large number of ALARA suggestions were received and many were approved.
The licensec's program for monitoring and controlling liquid
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and gaseous radioactive effluents was implemented
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effectively. The total annual doses from the liquid and gaseous effluents released during 1991 and 1992 were a small fraction of the allowable limits. Significant reductions in radionuclide concentrations in releases of liquid effluents were achieved using the liquid radwaste microfiltration system installed during the previous assessment period. The
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total activity from fission and activation products in liquid effluents released during the assessment period continued to decline from 0.9 Curies (C1) for 1990, to 0.3 Ci for 1991, and remained low (0.1 Ci) during the first half of 1992. One unplanned liquid release occurred involving approximately 15 microcuries of radioactive material.
No dose limits were exceeded as a result of this release.
The Environmental Monitoring Program continued to effectively monitor releases to the environment. As a result, 1991 data indicated that there was no adverse radiological impact to the environment resulting from plant releases. Also, there was excellent agreement between the Georgia Department of Natural Resources * environmental monitoring program data and the licensee's program data.
In addition, the results of the licensee's Environmental Protection Agency's interlaboratory crosscheck program
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verified that the licensee was able to perform accurate analyses of environmental samples.
The licensee's programs for generation, storage, and shipment of solid radwaste were implemented effectively.
For 1992, the total quantity of radwaste generated and
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processed due to routine and outage activities remained low.
Contaminated sludge, which had been previously stored onsite, was also disposed of during this assessment period.
No incidents involving the transportation of licensed material were reported or identified.
During the assessment period, four violations were identified.
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Performance Ratino t
Category:
3.
Recommendations
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None.
C.
Maintenance / Surveillance 1.
Analysis This functional area addresses those activities related to equipment condition, maintenance, surveillance performance, and equipment testing.
Overall maintenance and surveillance activities were very
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effective. Maintenance activities did not result in any
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reactor trips or unplanned outages.
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Maintenance management increased focus on the reduction of corrective maintenance through a strong preventive and predictive maintenance program, efforts to effectively diag-nosc the root cause of recurring maintenance problems, and by effectively using opportunities to perform maintenance.
Examples of this were the licensee's persistent and i
successful efforts to resolve' longstanding problems with the I
emergency diesel generators (EDG) and digital radiation monitoring system, and modifications and replacement of non-IE 4160/480 volt transformers, resulting in greater l
reliability of these components. Management oversight
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resulted in an effective inservice inspection (ISI) program and an improvement in the ratio of preventive maintenance to
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corrective maintenance from the last assessment period. The l
number of non-outage corrective maintenance work orders also decreased during the period.
Improvements this assessment period were noted in the predictive and preventive maintenance programs, in the reduction of maintenance backlog, and the general material
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condition of the plant. The snubber reduction program was l
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completed which will reduce manpower and exposure for subsequent examinations. Recently procured infrared equipment was useful in performing functional tests and troubleshooting problems. Predictive maintenance enhancements were implemented which included a major revision to vibration analysis computer software,
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utilization of the main frame computer to coordinate
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repetitive predictive maintenance tasks with the Operations surveillance testing schedule, and implementation of lubricating oil analysis optical examination for Engineered Safety Feature Actuation System equipment.
Staffing and training were sufficient to accomplish the maintenance program. The onsite Maintenance Engineering group worked with the Work Planning group to reduce the preventive maintenance backlog. Corporate engineering and maintenance personnel were used to resolve complex problems i
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and to assist in various maintenance evolutions.
ISI personnel were knowledgeable and well qualified. Mainte-nance management made a significant commitment to training over this assessment period. Maintenance foremen and supervisors received a three week supervisory course.
Instrumentation and Control technicians received a substantial increase in training over the previous year in specialty areas of the Nuclear Steam Supply System, the
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l Balance of Plant, and microprocessor based systems. This resulted in a greater number of technicians qualified to work on specialty systems such as the Digital Rod Positioning Indication System, the turbine Electrohydraulic Controls, and the Reactor Vessel Level Indication System.
Additional training was provided to some maintenance
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engineers in vibration analysis, nondestructive examination of welds, and motor-operated valve (MOV) test data evalua-tions.
Various maintenance areas throughout the plant were improved. Cleanliness and access control to the hot shop and hot tool room were improved. These areas were previously identified as poorly controlled. The weld test shop was renovated to improve the ability to qualify welding procedures, test / qualify welders and conduct specialized training. Auxiliary building leak inspection walkdowns were effective in reducing the number of leaking contaminated systems. A weakness noted in the previous assessment period was a high threshold for the identification of poor material condition and housekeeping problems, and the material condition of sampling system valves in the penetration rooms. This weakness was improved during this assessment period.
Overall performance in the surveillance area was good. The surveillance tracking program continued to be well managed for routine surveillances. However, a concern was noted
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with the failure to perform special condition surveillances.
Management recognized this area of weakness and took actions, including assigning specific responsibilities to operations shift supervision for ensuring completion of these types of surveillances.
Although improvements were observed with the adequacy of surveillance procedures, problems continued such as, inadequate procedures which resulted in an unplanned safety injection and an improperly calibrated residual heat removal suction valve interlock.
Although safety systems were challenged, there were no significant examples identified which had a negative effect on the operability of safety-related equipment. Management recognized these problems and continued their commitment to improvements in this area by emphasizing strict compliance and correcting procedural deficiencies.
i During this assessment period, three violations were
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identified.
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Performance Ratina Category:
3.
Recommendations None, f
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D.
Emeroency Preparedness l.
Analysis This functional area addresses activities related to the implementation of the Emergency Plan and procedures, support and training of onsite and offsite emergency response organizations, licensee performance during emergency exercises and actual events, the maintenance of facilities and staffing for emergency response, and interaction with offsite support organizations.
The licensee demonstrated an effective response capability for dealing with emergency situations during the annual NRC evaluated exercise, with the exception of notifications to State and local agencies. During the exercise, the licensee failed to make accurate and timely notifications to State and local agencies concerning emergency classification status, release conditions, and follow up information. The problems were identified as an exercise weakness.
Following the exercise, the licensee initiated additional corrective actions to prevent recurrence. The exercise scenario was sufficiently challenging to exercise the licensee's onsite and offsite emergency response organizations. The emergency response facilities were activated fully within the required activation times. The licensee demonstrated the ability to identify emergency conditions and to make correct classifications in accordance with licensee procedures.
Appropriate measures to mitigate the adverse consequences of degrading plant conditions and recommended appropriate protective actions for the public were taken. The exercise critiques were thorough and substantive findings were documented for review and follow up action. Command and control in the control room and Emergency Operations Facility (EOF) and the formation and dispatch of emergency response teams were identified as program strengths.
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previous inspection period, an exercise weakness concerning
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the licensee's response to a contaminated injured worker was identified during the NRC evaluated exercise. The licensee's performance, in response to the contaminated injured person, in the most recent NRC evaluated exercise was significantly improved from the previous observed medical drill and was identified as an exercise strength.
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In general, the licensee's Emergency Plan and its implementing procedures were sufficient in content, controlled adequately and maintained properly. The NRC determined that additional guidance was needed in a procedure utilized by the licensee's staff to make offsite Protective Action Recommendations (PARS). The procedure contained confusing guidance and direction regarding the selection of minimum default PARS following a General
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Emergency declaration. The licensee was revising the
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procedure to clearly state the minimum default PARS i
following declaration of a General Emergency.
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previous assessment period an inconsistency was identified with the Emergency Plan and an implementing procedure. The i
inconsistency involved implementing procedures which
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- classified an event based on " actual plant conditions at the time of classification", and the Emergency Plan which
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classified.the event based on " events in progress or which have occurred". The licensee revised the implementing
procedure, during the assessment period, to make it
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consistent with the Emergency Plan and NUREG-0654 guidance.
The licensee maintained emergency facilities and equipment
in a good state of readiness with thorough equipment surveillance and functional tests. -There were no significant changes in the licensee's emergency facilities i
during the assessment period. The licensee tested and made
operational an automated system for prompt call out of the i
emergency response organization. Problems identified with
the E0F ventilation controls, during the previous assessment
period, were corrected.
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Audits of the Emergency Preparedness program were j
independent, detailed in scope, and provided a good review i
of emergency preparedness activities. The licensee's audit program identified routine and exercise conditions requiring i
corrective action, as well as recommendations for
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improvement. Audits were reviewed by licensee management
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corrective actions taken in a timely manner.
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i The onsite emergency preparedness staff was qualified and i
continued to provide comprehensive emergency preparedness
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training. The licensee maintained emergency response
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proficiency with emergency preparedness drills and exercises
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throughout the assessment period. However, additional training needs for personnel determining minimum offsite
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PARS for a General Emergency declaration were identified by i
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j the NRC. The licensee is providing additional needed training. During the previous assessment period some health i
physics personnel in the emergency respor.se organization
were found to be insufficiently trained to use field team radiological data for making protective action
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recommendations. Additional training for these personnel was provided and these personnel demonstrated the ability to-I effectively incorporate field monitoring data into the dose projection process and make appropriate PARS during the assessment period.
Offsite support agency training for fire, ambulance, rescue,
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hospital, and local law enforcement agencies was conducted
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in accordance with commitments in the Emergency Plan and j
Agreement Letters with assisting agencies. Discussions with
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local County Emergency Directors and State Emergency j!
Response Personnel indicated excellent support and responsiveness to their request by the licensee.
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i The licensee declared an Unusual Event in response to a reactor shutdown caused by excessive unidentified coolant leakage. The event was classified correctly and timely offsite notification was made.
t During the assessment period, no violations were cited. One-
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exercise weakness was identified.
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2.
Performance Ratina
Category: 2 l
3.
Recommendations
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t Licensee management should continue emphasizing attention to the accuracy and timeliness of notification to offsite agencies.
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E.
Security
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Analysis
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This functional area addresses those safeguard measures associated with the protection of the plant's safety related vital equipment and with the assurance that personnel with access to the equipment are fit for duty.
Site management continued to support the security program resulting in a high level of performance by its staff and proprietary security force. Management's involvement was evidenced by efforts in areas of hardware upgrades, improved cameras, timely maintenance of failed systems, and the elimination of long-term compensatory measures. During the last assessment period the licensee had taken aggressive actions to correct problems in the control of safeguards information. Continued management attention during this assessment period resulted in a significant reduction of events relative to unsecured safeguards documents.
Experienced security shift supervisors provided " hands on" leadership to their assigned shifts. Turnover rates and absenteeism were reduced and vacancies were expeditiously filled. Security officers on duty were well trained, aware i
of their duties and responsibilities, and well supplied with
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normal and contingency equipment. Revisions to procedures
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and NRC commitments were technically sound and well i
coordinated within the utility and with the NRC.
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During the first part of this assessment period the licensee continued to experience a high number of vital area doors being left unsecured due to personnel errors or mechanical problems. The licensee instituted an aggressive personnel training program on vital area door control and a maintenance program to address the mechanical problems.
These programs have resulted in a drastic reduction in the number of unsecured vital area doors during the last part of this assessment period.
i The licensee demonstrated strengths in the liaison program
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with local law enforcement by onsite visits for site
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familiarization and meetings. The licensee's close-circuit television system used to access protected area alarms was considered a strength. This was attributed to maintenance and testing of the system. The licensee also had a strong control program and alarm station operation due to security alarm station operators and access control officers
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performing duties in a highly professional manner.
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The licensee continued to implement an aggressive Fitness
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For Duty Program; random testing was conducted such that
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confidentiality of results was assured, and events were timely and thoroughly reported.
During this assessment period one violation was cited.
2.
Performance Ratino I
Category:
3.
Recommendations None
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F.
Enoineerino/ Technical Support
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1.
Analysis
This functional area addresses activities associated with
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the design of plant modifications, technical support for i
operations, outages and maintenance, and licensed operator training.
The licensee's performance in providing engineering and
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technical support was very effective during this assessment period.
Improvements from the previous assessment period were demonstrated in plant modifications, system engineering, and design control. Effective performance continued in technical interface support and communications, system engineer training, qualification and certificatica
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and licensed operator training. The licensee's response to
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GL 89-10 " Safety-Related Motor-Operated Valve Testing and Surveillance," was not sufficiently comprehensive.
l An Onsite Modifications Department was established in January 1992, to improve performance in the design and implementation of plant modifications. This also resulted in improvements in the Systems Engineering Department.
Review by the Onsite Modifications Department, of design documentation prepared in Birmingham, resulted in a reduction in problems previously experienced during implementation. This also resulted in a reduction of outstanding Field Change Requests. Timeliness and quality of design packages were improved.
The establishment of this Onsite Modifications Department, along with other changes in engineering management, allowed system engineers to take a more active role in day-to-day operational activities and resolution of technical problems.
In addition, the technical staff provided good engineering support to other plant organizations. Support to operations was demonstrated by resolution of several longstanding operational problems. The backlog of engineering work was reduced. The number of open Design Change Packages, temporary modifications and Requests For Engineering Reviews were reduced. A weakness was identified in the control of temporary modifications in that several temporary modifications remained in place for long periods.
Planning for outage activities continued to improve and was effective. The outage scope was well planned prior to the outage. During the outage, changes to tne outage scope were tightly controlled through the licensee's Outage Schedule
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Change Request Program. Daily meetings provided a means for addressing problems and planning corrections as appropriate.
Shorter duration maintenance outages were also well planned and executed. Outage planning resulted in increased reactor safety by controlling the schedule of outage activities and the configuration of safety systems to reduce the risk and consequences of an accident.
The licensee continued to pursue an aggressive program of training and qualification / certification for system
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engineers and other engineering technical support staff.
l System engineers were knowledgeable and displayed dedication toward their assigned areas.
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Communications and technical interface between the onsite i
technical support staff and other organizations were good
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during this assessment period. An exception occurred early in the period when miscommunication between operations and engineering personnel resulted in an inadvertent reactor
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l water level draindown event. Applications of lessons learned from this event aided in improved performance during the balance of the period. The cooperative working attitude and long term tenure of Engineering and Technical Support
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(ETS) personnel aided in maintaining these strengths.
The licensee's initial GL 89-10 testing commitments were not comprehensive or aggressive in scope, due, in part, to a
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lack of differential pressure testing. Toward the end of
this assessment period the licensee agreed to incorporate differential pressure testing and other improvements in its MOV program. An associated schedule extension was needed to complete this testing.
The licensee demonstrated sound technical support for most amendment requests submitted to the NRC. Examples included requests to allow limited use of Zirlo cladding, deletion of the negative flux rate trip, and removal of the autoclosure interlock from the residual heat residual removal suction valves. However, a requested change to defer code inspection of Unit 2 nozzles was not well supported, and after discussions with the staff, the licensee decided to conduct the inspection as previously scheduled.
An effective licensed operator training program was demonstrated by a 100% pass rate on two initial examinations (24 candidates), and a 97% pass rate on one requalification
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examination (30 operators). The licensee also had a 100%
pass rate on the Generic Fundamentals Examination Section (9 candidates). During the initial examinations, a strength was observed in candidate performance in the simulator portion of the examination. During the requalification examination, strengths were noted in the areas of written exam development, exam administration, and facility evaluator performance.
No generic operator weaknesses were
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identified.
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During the assessment period, four violations were identified.
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2.
Performance Ratina Category:
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3.
Recommendations
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None.
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G.
Safety Assessment /Ouality Verification 1.
Analysis This functional area addresses those activities related to j
implementation of safety policies; amendments; exemptions and relief requests; responses to GLs; Bulletins and Information Notices; resolution of safety issues; reviews of
plant modification performed under 10 CFR 50.59; safety.
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review committee activities; and use of feedback from self-assessment programs and activities.
Management was actively involved in assessing plant performance and safety issues, and fully supported l
organizations and programr that identify and assess problems. Examples included management's commitment to complete repairs during outages prior to restart, the. timely completion of tests for the Emergency Response Data System, and plans for implementation of new 10 CFR Part 20 l
regulations.
The licensee requested meetings to inform the NRC of devalopments or upon tendering applications for NRC staff approval of significant actions.
Periodic interface meetings were effectively used to keep NRC informed of progress on licensing actions and of the licensee's various initiatives. The licensee has been effective in keeping the resident inspectors informed of emerging issues.
Licensee management usually provided the NRC timely.
notification of its planned licensing requests so that normal preparations and scheduling of staff resources could be arranged. However, in one instance, a significant amendment was submitted without advance notification of the need for expedited NRC review.
The licensee had sufficient staff at the plant and technical support by the corporate office to support licensing activities. This staff was experienced and knowledgeable of licensing requirements. Requests for license amendments were of high quality and permitted NRC approval without the need for significant additional information. When additional information was requested the replies were timely L
and responsive.
Overall, the SAER audits were thorough and effective in identifying deficiencies. During this assessment period, the responsibility for approving audit finding responses shifted from the SAER group to the Vice President-Vogtle Project, which removed on-site SAER from directly approving findings and gave the findings higher management attention.
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The Independent Safety Engineering Group (ISEG) reviews and assessments remained effective.
In most cases audits were conducted more frequently than required. Staffing and experience levels of the SAER and ISEG have improved.
SAER added an experienced SRO with an HP/ Chemistry background.
ISEG also added an SR0 to the staff. Both groups supplemented their staffs _ with personnel from other disciplines as appropriate. The Safety Review Board and PRB continued to be effective in reviewing plant safety matters.
A set of PRB standards was implemented during the assessment period to enhance communications and effectiveness of the PRB. Review board meetings were conducted openly and professionally.
Application of the deficiency card program was comprehensive and effective in identifying, tracking, trending and responding to identified deficiencies. The licensee's event
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investigation program, which was noted as a strength in the previous assessment period, continued to be a strength.
LERs were timely and generally described relevant aspects of the event, including corrective actions and actions to
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prevent similar occurrences.
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The Quality Verification function performed by the Quality Control (QC) group was generally effective.
In addition to routine inspections, QC implemented a work monitoring
program where areas, such as open link control, lifted wire
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and jumper control, and electrical fuse control, were monitored monthly. This contributed to maintaining
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configuration control in these areas.
During the assessment period, one violation was cited.
2.
Performance Ratino Category:
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Recommendations None.
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V.
SUPPORTING DATA AND SUMMARIES
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A.
Licensee Activities Unit 1 Unit I began this assessment period in its third refueling outage,
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which commenced on September 15, 1991. The unit remained in the
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outage until November 24, 1991, when the generator was tied to the grid. Turbine bearing vibrations, MFWP vibrations, and problems attributed to the RTD bypass manifold elimination modification
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limited power operation until December 7, 1991.
After completion of the Over Temperature Differential Temperature, Over Power Differential Temperature, and Reactor Coolant System Average Temperature reduction design change packages, the unit attained rated full power on December 20, 1991. The unit operated at approximately full rated power until April 2, 1992, when the unit began a power reduction to 60 percent to remove a MFWP from service for maintenance on a failed discharge check valve.
Rated power was attained on April 11. The unit operated at approximately rated full power until May 14, when it was shutdown i
i due to high RCS leakage. The licensee declared a Notification of Unusual Event because the unidentified leakage was in excess of TS limits. The leakage was attributed to a cracked weld on a one inch drain pipe.
The crack was repaired and the unit was returned to rated power on May 23. The unit operated at full power until September 14, when the unit was manually tripped from 89 percent power due to a failed controller on a MFWP. A power reduction had previously been initiated when steam flow / feed flow annunciators alarmed.
The unit returned to rated power on September 19, 1992, and operated at approximately rated full power for the remainder of this assessment period.
Unit 2 l
Unit 2 began this assessment period operating at approximately 100 percent rated thermal power. On March 9, 1992, while coasting down in preparation for the second refueling outage, a plant equipment operator pushed a breaker test button on a molded case circuit breaker, which caused a 125 volt DC control power breaker
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to open.
This removed control power from the "A" train main steam isolation valves (MSIV), and one MSIV per steam line (four total)
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shut.
The reactor subsequently tripped from approximately 78 percent rated thermal power on high pressurizer pressure. After the trip, the licensee decided to begin their second refueling outage, which was scheduled for approximately 58 days.
Prior to the trip, Unit 2 had operated continuously for over 286 days.
During restart of the unit on April 30, 1992, a reactor coolant pump tripped when a stator winding shorted.
The licensee placed the unit in Mode 5 to replace the stator, and continued startup on May 5.
The reactor was taken to Mode 2 on May 7.
On May 14, the unit automatically tripped from approximately 98 percent power due j
to an error by a technician during testing of a circuit board pin in a portion of the main generator excitation system circuitry.
The unit attained rated power on May 17, 1992, and maintained rated power until December 13, when the unit was manually scrammed for a scheduled maintenance outage due to increasing identified i
RCS leakage and a generator hydrogen leak.
During this outage the packing was replaced in two RHR suction values, and the generator bus was replaced. The unit was returned to 100% power on December 19, 1992; and remained at full rated power for the rest of this assessment period.
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B.
Direct Inscection and Review Activities During the assessment period, 37 routine and 6 special inspections were performed at the Vogtle facility by the NRC staff. The special inspections were:
October 29-November 1, 1991; Augmented Inspection Team on Loss of Decay Heat Removal
January 27-31, 1992; Response to GL 89-10, " Safety Related MOV Testing and Surveillance."
- May 18-21, 1992; Emergency Preparedness Exercise June 29-July 2,1992; Review licensee actions for IN 89-87,
" Disabling of EDGs by their Neutral Ground-Tault Protection Circuitry."
- August 7-18,1992; "At the Controls" area left unattended by reactor operator.
- November 30-December 5, 1992; Review the Vogtle EDG 1A failure to start event.
C.
Escalated Enforcement Action 1.
Orders On December 31, 1991, the NRC issued a Notice of Violation (Severity Level III) and proposed $100,000 civil penalty.
The civil penalty was issued as a result of violations associated with the opening of the RMWST valves, which occurred in October 1988.
In the licensee's response, dated January 30, 1992, all violations were denied, and the licensee requested reconsideration of the civil penalty.
On June 12, 1992, an Order Imposing a Civil Monetary Penalty of
$100,000 was issued to GPC to emphasize the importance of ensuring that plant staff is complying with TS and that management is maintaining control of plant activities. The licensee paid the civil penalty on July 9,1992.
2.
Civil Penalties (CP)
(See paragraph above)
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D.
Manaaement Conferences I
During the assessment period there were several significant.
management conferences with the licensee. These were:
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e November 18, 1991; Management interface meeting to discuss
the status of licensing activities and initiatives.
e December 16, 1991; Enforcement Conference to discuss NRC findings resulting from a Special Team Inspection conducted
to determine if the licensee operated the facility according i
to approved procedures and within the requirements of the i
facility license.
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February 6, 1992; Meeting to discuss the proposed uprating i
of power level.
e May S and 6, 1992; Management interface meeting to discuss the status of licensing activities and initiatives.
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May 13, 1992; Enforcement conference to discuss the i
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circumstances surrounding the willful violation by two instrumentation and control technicians of Vogtle Procedure
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24812-1, DELTA T/TAVG Loop 3 Protection Channel III IT-432 Analog Operational Test and Channel Calibration.
e September 8, 1992; Enforcement conference in discuss the circumstances surrounding the failure of a licensed control room operator, who had immediate responsibility to monitor plant conditions, to remain in the "at the controls area" for Unit 2.
e September 22, 1992; A meeting to discuss the Vogtle MOV
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program, and Vogtle's response to GL 89-10; and on the inspection of reactor vessel outlet nozzles.
e September 28, 1992; A management presentation on the planned transfer of operating responsibility from GPC to Southern Nuclear.
E.
Confirmation of Action letters None.
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Reactor Trios
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Unit 1 One unplanned manual reactor trip occurred:
e On September 14, 1992; from 89 percent power; in response to i
decreasing water level on steam generator 4 due to the failure of the "B" MFWP speed controller tracker / driver card.
Unit 2 Two automatic reactor trips occurred:
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On March 9, 1992; from 80 percent power; while the control building operator was investigating intermittent trouble alarms on train A 125 volt DC switchgear, he erroneously tripped the breaker for control power to train A MSIVs, main feed isolation valves, and bypass feedwater isolation valves. These valves closed as designed, isolating the steam generators.
The resulting increase in pressurizer pressure caused a reactor trip.
On May 14,1992; from 98 percent power; automatic turbine / reactor trip caused by a technician error that grounded the DC power supply for the main generator
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excitation system circuitry. The loss of control power initiated the trip logic s=ouence.
G.
Review of Licensee Event Reports (LERs)
During the assessment period, 35 LERs were analyzed. Special reports were submitted during the period by the licensee, but are not included in the table. The distribution of these events by unit and by cause, as determined by the NRC staff, was as follows:
Cause Total s Unit 1 Unit 2 i
Component Failure
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Design
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Construction / Fabrication
0
Installation Personnel Errors-Operating Activity
6
l-Maintenance Activity
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-Testing / Calibration Activity
2
-Other
1
1 Other
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Totals
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l Note 1: With regard to the area of " Personnel Errors", the NRC considers lack of procedures,. inadequate procedures, and erroneous i
procedures to be classified as personnel error.
Note 2: The "Other" category comprises LERs where there was a spurious signal or a totally unknown cause.
Note 3: One LER was submitted as a voluntary LER, and is not in this total.
Note 4: The above information was derived from a review of LERs performed by the NRC staff and may not coincide with the licensee's cause assignments.
H.
Licensino Activities During the rating period, 16 licensing amendments for the two Vogtle units were issued, beginning with Amendments'47/26 dated l
October 4, 1991 and ending with Amendments 54/33 dated August 20, 1992. On March 10, 1992, the NRC staff also accepted a proposed change to the TS Bases regarding the method of determining end-of-fuel-cycle moderator temperature coefficients.
Significant interaction with the licensee occurred during the rating period on
two license amendment requests involving power uprating and l
transfer of operating responsibility to Southern Nuclear; although not issued during this period, licensee performance during the rating period for these two amendment requests are included in this report. No amendment was required to be issued on an emergency or exigent basis, and no orders due to licensing requests were issued during this period. The NRC staff granted exemptions to four regulations regarding. fuel cladding material.
On November 26, 1991, the NRC staff approved the first ten-year-interval inservice inspection program and plan for Vogtle Unit 1, through revision 4, and granted numerous associated relief requests. The corresponding program and plan for Vogtle Unit 2, through revision 3, was approved and relief request granted on l
December 17, 1991.
I Prehearing activities were supported during the rating period l
regarding a request for intervention on proposed amendments
authorizing Southern Nuclear to become the licensed operator of j
Vogtle.
The licensee provided written responses to the petition j
l for hearing on November 6 and December 22, 1992.
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An audit of the MOV valve program on November 12 and 13, 1992,.
included discussions of the licensee's plans and schedule for completing its program in response to GL 89-10.
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The licensee submitted two changes to both the Physical Security and Training and Qualification Plans requiring only minor clarification. The changes were complete and submitted in a timely fashion.
I.
Enforcement Activity No. of Deviations and Violations in Each Functional Area Dev. V IV III II I
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Plant Operations
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I Radiological Controls
Maintenance / Surveillance
Emergency Preparedness Security
Engineering / Technical Support
Safety Assessment / Quality
Verification TOTALS
1 The SL III violation is related to events that occurred in a
previous assessment period.
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