ML14178A117
| ML14178A117 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/31/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A116 | List: |
| References | |
| 50-261-91-10, NUDOCS 9107080256 | |
| Download: ML14178A117 (25) | |
See also: IR 05000261/1991010
Text
ENCLOSURE
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-261/91-10
CAROLINA POWER AND LIGHT
H. B. ROBINSON
JANUARY 1, 1990 -
MARCH 30, 1991
TABLE OF CONTENTS
Page
I. INTRODUCTION..............................................
1
II. SUMMARY OF RESULTS.........................................
1
III. CRITERIA
.............................................
3
IV.
PERFORMANCE ANALYSIS...........4 ..............................
3
A. Plant Operations .....................................
3
B. Radiological Controls .................................
6
C. Maintenance/Surveillance ....................
.........
8
D.
Emergency Preparedness .................................
11
E. Security ..............................................
13
F.
Engineering/Technical Support .......................... 14
G.
Safety Assessment/Quality Verification .................
17
V. SUPPORTING DATA AND SUMMARIES
.....
20
A.
Licensee Activities .................................... 20
B. Direct Inspection and Review Activities ................
21
C. Escalated Enforcement Actions ..........................
21
D. Management Conferences ........ ........................
21
E. Confirmation of Action Letters .........................
22
F. Reactor Trips .........................................
22
G. Review of Licensee Event Reports .......................
22
H.
Licensing Activities ................................... 23
I. Enforcement Activity ................................... 23
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP)
program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance on the basis of
this information.
The program is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations.
It
is intended to be sufficiently diagnostic to provide a rational basis for
allocation of NRC resources and to provide meaningful feedback to the
licensee's management regarding the NRC's assessment of their facility's
performance in each functional area.
An NRC SALP Board,
composed of the staff members listed below, met on
May 15, 1991, to review the observations and data on performance, and to
assess licensee performance in accordance with the NRC Manual Chapter
"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 NRC's assessment of the licensee's safety performance at
H. B. Robinson, for the period January 1, 1990 through March 30, 1991.
The SALP Board for H. B. Robinson was composed of:
E. W. Merschoff, Deputy Director, Division of Reactor Projects (DRP),
Region II (RII) (Chairperson)
C. A. Julian, Chief, Engineering Branch, Division of Reactor Safety, RII
B. S. Mallett, Deputy Director, Division of Radiation Safety and
Safeguards, RII
D. M. Verrelli, Chief, Reactor Projects Branch 1, DRP, RII
L. W. Garner, Senior Resident Inspector, Robinson, DRP, RII
H. .N.
Berkow, Director, Project Directorate 11-2, Office of Nuclear
Reactor Regulation (NRR)
R. H. Lo, Senior Project Manager, Project Directorate II-1, NRR
Attendees at SALP Board Meeting:
H. 0. Christensen, Chief, Reactor Projects Section 1A, DRP, RII
R. E. Carroll, Project Engineer, DRP, RII
G. R. Wiseman, Technical Support Staff, DRP, RII
K. R. Jury, Resident Inspector, Robinson, DRP, RII
M. T. Markley, Operations Engineer, Division of Licensee Performance and
Quality Evaluation, NRR
II. SUMMARY OF RESULTS
Overall,
Robinson has
been operated in a safe manner during the
assessment period.
The areas of Radiological Controls and Security
remained strengths. Performance in the remaining areas was satisfactory.
2
Performance of Operations continued to be effective.
Actions taken to
reduce shutdown risks were significant and emphasis
on operating
experience/enhanced site performance continued.
Good operator response
to plant transients
and
improved
communications for non-routine
evolutions was demonstrated.
However, operator errors resulted in one of
the two reactor trips experienced, as well as a reactor protection system
actuation while shutdown.
Although an effective fire protection program
was maintained overall, actions taken with respect to a fire at another
Carolina Power and Light facility were not effective in precluding a
similarly induced fire inside H. B. Robinson's containment.
The area of Radiological Controls continued to exhibit strong
performance. Overall quality, technical capability, and experience level
of the health physics staff continued to be strengths.
Related programs
(e.g., contamination control, ALARA, effluent monitoring, and chemistry)
were effectively implemented and produced good results.
Management
involvement/support was evident and deficiency identification processes
such as audits were effectively utilized.
During the outage, personnel
were not always attentive to proper anti-contamination clothing dressout
details.
The
Maintenance/Surveillance
area
produced mixed
performance.
Maintenance personnel capabilities and qualifications were considered
strengths, with no personnel errors resulting in a reactor trip or
turbine runback.
Equipment material condition was generally good and
safety system availability was greater than 98 percent; however,
equipment degradation due to plant aging was a significant maintenance
problem. Although the inservice inspection program was effective, several
concerns were identified in the inservice testing program.
In the area of Emergency
Preparedness,
licensee performance
was
satisfactory.
The emergency response organization was upgraded by
implementing a beeper system.
The emergency response facilities were
well maintained.
However, corrective actions were initially ineffective
in the area of staff augmentation.
The licensee continued to show
weakness in the area of emergency classification.
Security continued to be a strength. Preparatory actions for a spent fuel
shipment and the continued high management support for the security
program were notable.
Performance in the area of Engineering and Technical Support was
satisfactory.
The Nuclear Engineering Department
(NED)
and Technical
Support demonstrated good communications and interface. The NED has shown
a high level of onsite involvement in the development and implementation
of modifications.
Management's commitment to improve Technical Support's
performance was demonstrated
by the issuance of a Technical Support
Improvement Plan.
However,
weaknesses were noted with the strained
Technical Support staffing, as evidenced by the high amount of overtime
during the refueling outage and the inconsistent support provided for
routine plant activities.
The number of backlog items in the engineering
area continues to be large.
we
3
The licensee's commitment and involvement in the Safety Assessment/Quality
Verification area was evident. The Plant Nuclear Safety Committee, Onsite
Nuclear Safety, and the licensee's 10 CFR 50.59 process were effective.
However, management's visibility in the plant was not consistent throughout
the assessment period.
The Quality Assurance/Quality Control
and
corrective actions programs have demonstrated inconsistent results.
Rating Last
Rating This
Functional Area
Period
Period
Plant Operations
2
2
Radiological Controls
1
1
Maintenance/Surveillance
2
2
2
2
Security
1
1
Engineering/Technical Support
2
2
Safety Assessment/.
Quality Verification
2
2
III. CRITERIA
The evaluation criteria which were used,
as applicable, to assess each
functional area are described in detail in NRC Manual Chapter 0516.
This
W
chapter is
in the Public Document Room files.
Therefore, these criteria
are not repeated here,
but will be presented in detail at the public
meeting to be held with licensee management on June 11, 1991.
IV. PERFORMANCE ANALYSIS
A.
Plant Operations
1. Analysis
This functional area addresses the performance of activities
directly related to operating the unit, as well as fire
protection. A total of 1485 inspection-hours were expended in
this
functional
area,
comprising
31%
of the
total
inspection-hours.
The performance of Operations continued to be effective.
Control room personnel maintained awareness of plant conditions,
equipment status, and maintenance/testing activities in
progress.
Response to alarms and logkeeping improved since the
last assessment period. A small number of lighted annunciators
were present during normal operations, half of which required
engineering action to eliminate. The responses to both automatic reactor trips were proper and in accordance with procedures, as
was the operator response to a turbine runback initiated by a
loss of power to the control rod position indication system.
4
However, operator errors caused one of the two automatic reactor trips, as well as a reactor protection system actuation while
draining a steam generator during refueling outage 13.
Operations'
staffing
exceeded
Technical Specification
requirements and was sufficient to effectively support routine,
non-routine,
and outage operations.
Shift staffing, which
consisted of four operating shifts and a training/relief shift,
was appropriately supplemented by licensed administrative/relief
personnel when necessary.
Management's continued emphasis on
operating experience for senior level positions was reflected in
the promotion of the Operations Manager to the position of Plant
General Manager and the subsequent filling of the vacated
Operations
Manager position with a licensed engineering
supervisor.
The licensee's commitment to enhance site
performance continued through the rotation of licensed personnel
within Operations and into other departments. These rotational
assignments occurred in Training, Outages and Modifications, and
the Operations' procedure writing group.
In addition, licensed
personnel were transferred to Maintenance and Training.
Control
room demeanor and communications involving routine
operations were informal,
yet effective.
Shift turnover
meetings included preplanned activity discussions, as well as
plant status.
Communications associated with non-routine
evolutions improved from the previous assessment period.
This
was demonstrated by special shift briefings held immediately
prior to the performance of major surveillance, modification,
or special tests.
During plant startups, non-essential entries
to the control room were limited, and shift communications and
control were formal
and well executed.
Like the previous
assessment period, standard attire continued to be used by
Operations personnel.
Effective management oversight and involvement was evident
during plant restarts.
This was accomplished through direct
observations by the Operations Manager and the utilization of
startup managers.
In comparison,
management involvement in
routine plant operations was deficient as demonstrated by the
lack of routine management tours and work observations in the
auxiliary building and control
room.
Improvements were
observed in this area during the second half of the assessment
period.
Housekeeping in most areas of the plant was good.
Materiel
condition and housekeeping concerns were occasionally
identified in areas not frequented by management.
Containment
was an area which warranted increased management attention.
During the latter part of the assessment period, increased
routine management tours resulted in improved housekeeping.
5
Significant actions were taken by the licensee to reduce safety
risks while the unit was shutdown.
These actions included
scheduling to avoid mid-loop operations,
maintaining both
emergency
busses operable during critical evolutions,
and
utilization of a redundant temporary cooling system for
emergency diesel generators and the spent fuel pool.
In
addition, the licensee has continued to address long-term
issues.
A program was
implemented to address emergency
operating procedure program weaknesses which were identified in
the previous assessment period.
A generic applicability
document and revised plant-specific technical guidelines were
issued.
Incorporation of human factors concepts and use of a
revised validation process were being implemented at the end of
the assessment period.
Overall, the licensee continued to maintain an effective fire
protection program.
Reorganization of the site fire protection
staff has had a positive effect on the long-term management of the
fire protection program. This was evidenced by self-identification
and correction of potential programmatic problems with fire
barrier penetration seals.
However, actions taken with respect
to a temporary services induced fire at another Carolina Power
and Light (CP&L)
facility were not effective in precluding a
similarly induced fire inside H. B. Robinson's containment. The
fire brigade demonstrated good performance through their timely
and proper responses to this fire and to a diesel generator
exhaust smoke initiated fire alarm. Additionally, fire protec
tion personnel were knowledgeable of their responsibilities
and requirements.
Fire protection features were satisfactorily
maintained.
No violations were cited.
2. Performance Rating
Category: 2
3.
Recommendations
The
occurrence of the fire in containment brings forth
considerable concern, in that it could have been avoided through
lessons learned from a similarly induced fire at another CP&L
nuclear facility. Accordingly, increased management attention
in this area is warranted.
The normal level of inspection is
recommended.
6
B. RADIOLOGICAL CONTROLS
1. Analysis
This functional area addresses those activities related to
radiological controls, radioactive waste management,
effluent
and environmental monitoring, water chemistry, and transporta
tion of radioactive materials. A total of 269 inspection-hours
were expended in this functional area, comprising 6% of the
total inspection-hours.
The radiation protection program continued to be effective in
controlling personnel exposures to radioactive materials and
protecting the health and safety of the workers. The licensee
had no internal or external radiation exposures greater than
regulatory limits and no significant safety or technical issues
concerning the radiation protection activities were identified.
Strong management involvement in the radiation protection program
was evidenced by management's authorization and support for
numerous radiation protection program improvements.
Included
among these were assurance of appropriate vendor Health Physics
(HP) technician support; upgrade of plant radiation monitoring
systems; purchase of new personnel radiation monitoring equipment;
and various "As
Low As Reasonably Achievable"
(ALARA)
dose
reduction projects.
Additional initiatives to increase the
radiation protection program effectiveness included the review
and enhancement of Environmental & Radiological Control (E&RC)
procedures. This effort utilized input from workers concerning
dose reduction, improved worker efficiency, safety and procedure
compliance.
The E&RC audits were effectively performed. These audits were
well planned, adequately documented, and identified substantive
items.
When deficiencies were noted, the licensee responded to
audit findings with commitments to effect corrective actions. A
radiation safety violation identification process was also
effectively utilized by the licensee to identify and correct
radiation protection program weaknesses.
Control of radioactive material released from radiation control
areas was identified as a program weakness during the previous
assessment period.
The licensee took appropriate corrective
action,
including a more comprehensive survey program,
to
prevent recurrence.
The licensee's ALARA program was administered by a qualified
and experienced ALARA staff that reported directly to the plant
E&RC Manager.
Other plant management personnel served on the
7
ALARA Committee and participated in the Committee's activities.
The ALARA program has successfully implemented numerous dose
reduction programs including: adoption of an ALARA suggestion
award program; modified shutdown chemistry control to reduce
source term levels; use of high efficiency filters in spent
fuel and reactor coolant systems which reduced source terms;
video taping of high dose jobs for future reference; and
purchasing alarming dosimeters.
ALARA awareness was also
promoted on the plant video system and plant newspaper.
Most
of the tasks performed during the assessment period received
pre-job ALARA
reviews and briefings.
ALARA specialists
maintained awareness of current dose reduction methods by
attending Radiation Exposure Management Seminars and Region II
Licensee ALARA Supervisors Meetings.
The licensee's radiation protection staffing level for HP,
radwaste,
and transportation functions were sufficient to
support both routine and outage operations.
The staff's
experience level was good and staff turnover rate during the
assessment period was low.
The overall quality, technical
capabilities, and experience level of the HP staff and the
program for reviewing and qualifying vendor HP personnel
continued to be program strengths.
The training programs for
general employee radiation protection, and both site and vendor
HP technicians were well defined and continued to be effective.
Other
staff personnel
attended training sessions on
implementation of the new 10 CFR 20.
Emergent work extended refueling outage 13 and significantly
increased the collective personnel dose.
The licensee met the
1990 person-rem goal of 450 with 437.
Source term reduction
and ALARA implementation were the major factors in meeting this
goal.
However,
due to the extension of the refueling outage,
the 1991 collective person-rem goal of 100 was exceeded in
March with 145.
Overall,
the outage dose was not excessive
considering duration,
type,
and quantity of work in the
radiological controlled areas.
The licensee's contamination control
programs were good.
Contaminated floor space was maintained at a very low level.
Excluding containment,
approximately 87,000 square feet was
included in the contamination control
program.
During
non-outage periods,
the contaminated area was normally less
than two percent. Activities in contaminated areas resulted in
316 personnel contaminations.
This total was lower than for
previous years having a similar amount of work in contaminated
areas.
However, during refueling outage 13, personnel were not
always attentive to proper anti-contamination clothing dressout
details.
8
Corporate support for the radiation protection program was
evidenced by the development of a 10.CFR 20 Implementation
Committee to define, coordinate, and schedule a plan for meeting
the new regulatory requirements.
The corporate radiation
protection staff also supplied personnel to support ALARA
program activities during refueling outages.
Programs to control, quantify, and monitor radioactive effluents
and releases were effective. There were no unplanned releases
and the amount of liquid effluent released was low.
Doses to
the public in 1990 were less than 1 percent of the 10 CFR 50,
Appendix I annual limits.
During 1990, the licensee completed
upgrading their radiation monitoring
system
(RMS)
to a
state-of-the-art microprocessor-based digital system.
This
upgrade improved the operability and reliability of the RMS.
The team that was formed to plan and implement the upgrade was
considered a strength.
The program for controlling, tracking, and trending primary and
secondary chemistry parameters was good. Primary and secondary
chemistry parameters were generally maintained within Robinson
internal action limit guidelines. Important secondary chemistry
parameters were tracked and corrective actions were taken when
needed to bring these parameters back into limits.
The
licensee was in agreement with all four of the Confirmatory
Measurements Program's radioisotopes and with all the isotopes
measured as part of an onsite NRC split sample inspection.
No violations were cited.
2.
Performance Rating
Category:
1
3. Recommendations
A reduced level of inspection effort should continue.
C. MAINTENANCE/SURVEILLANCE
1. Analysis
This functional area addresses those activities related to
equipment condition, maintenance, surveillance performance and
equipment testing.
A total of 1263 inspection-hours were
expended in this functional area, comprising 27% of the total
inspection-hours.
Effectiveness of the maintenance program was mixed.
Safety
system availability was greater than 98 percent and there were
no maintenance personnel errors which resulted in a reactor
9
trip or turbine runback. One reactor trip was attributed to a
component failure and one turbine runback resulted from a
degraded electrical connection.
Equipment materiel condition
was generally good; however, during refueling outage 13 the
condition of service water pipe and component cooling water
heat exchangers was found to be degraded.
At the end of the
assessment period, Technical Support had initiated a systematic
review to define performance monitoring and preventive maintenance
programs for selected safety-related systems.
This review is
scheduled for completion at the end of 1993.
However,
a
comprehensive program to address facility aging has not been
initiated.
Weaknesses were identified in post-maintenance
testing, the repetitive failure program, the equipment database,
the allocation of resources,
maintenance trending, backlog
assessment, management oversight of routine activities, and the
maintenance shop facilities.
Strengths were noted in the areas
of personnel capabilities and qualifications.
Management demonstrated a commitment to address identified
weaknesses and effect improvements in maintenance by the issuance
of a Maintenance Improvement Plan in October 1990.
The plan
incorporated issues from maintenance personnel interviews, as
well as from external audits such as the maintenance team
inspection.
At the end of the assessment period approximately
30 of the 71 identified items had been addressed; all short-term
items were scheduled for completion by the end of 1991.
Resultant improvements included emphasis on customer/supplier
relationship with Operations. and increased supervisory tours and
work activity oversight.
Management oversight demonstrated
significant improvement during the latter half of the assessment
period.
Progress on some programmatic initiatives has been slow however.
The licensee determined that the maintenance procedure upgrade
program initiated in May
1989,
though providing improved
procedures, was not consistently correcting identified
deficiencies, e.g., those related to human factors. A lack of
procedural detail in an upgraded procedure contributed to the
improper installation of a safety injection pump thrust bearing.
In the last quarter of this assessment period, the established
program was phased out and a new upgrade effort was initiated
utilizing contractor expertise.
This new maintenance procedure
upgrade program, which encompasses approximately 500 maintenance
procedures,
including the 247 procedures issued under the
discontinued program, is scheduled for completion at the end of
1992.
In addition, the licensee has been slow in developing and
implementing a check valve inspection program.
10
The licensee addressed weaknesses identified in the last
assessment period with mixed results.-
Procedural adherence
improved; however, occasional problems still occurred in this
area. During the refueling outage, work control was occasionally
not adequate.
Examples of this included: cutting of a Freon
line during a modification installation resulted in an Alert
emergency classification; the primary and backup gas supplies to
the cavity seal were found to be isolated with the reactor
defueled and the cavity flooded; and a non-approved temporary
wiring configuration resulted in a fire inside containment. The
quantity of rework which had been determined to be excessive was
not identified as a concern. The total number of items/components
reworked in 1990 was low (2.8 percent).
The Inservice Inspection program was effective. Personnel were
knowledgeable, well trained, and qualified to perform activities
within their respective areas of certification.
Licensee
management,
engineering,
and inspection personnel responded
effectively to the intergranular stress corrosion cracking
identified in the safety injection system accumulators by
ensuring that this issue was resolved in a manner that would
assure plant safety.
Technical Specifications required surveillances were generally
performed in accordance with procedures.
One reactor trip was
attributed to an operator error during performance of a nuclear
instrumentation surveillance test.
Two violations involving
inadequate procedures to perform tests as specified by Technical
Specifications were identified,
one of which was a repeat
occurrence.
In the Inservice Test programs, concerns with pump
testing (such as failure to obtain pump bearing temperatures as
required), quality and promptness in performing test evaluations,
control of test evaluations, and failure to include valves in
the program continued to demonstrate weaknesses in this area.
Seven violations were cited.
2. Performance Rating
Category: 2
3. Recommendations
Recognizing the special challenges brought about by aging
equipment,
continued aggressive efforts in this area are
encouraged.
A normal level of inspection effort should be
maintained.
D.
1. Analysis
This functional area addresses those activities related to the
implementation of the Emergency Plan and procedures, as well as
support and training of onsite and offsite emergency response
organizations.
A total of 195 inspection-hours were expended
in this functional area, comprising 4% of the total
inspection-hours.
Management
support for the emergency preparedness program
during the assessment period was satisfactory.
However, prior
to the June 18,
1990 exercise, management was ineffective in
determining
and correcting the root cause for the 1989
emergency exercise weakness regarding the inability to augment
and activate the Technical Support Center and Operational
Support Center in a timely manner. This is further exemplified
by the licensee's audit program which also identified staff
augmentation as a weakness,
but did not result in effective
corrective action.
This inability to take adequate corrective
action was identified as ,a violation during the 1990 emergency
exercise.
An exercise weakness was also identified during the 1990
exercise for failing to appropriately classify a General
Emergency from the radiological data.
Licensee management was
responsive to the identified findings, committing to early
corrective action (including an exercise to redemonstrate the
effectiveness of the corrective actions) and a meeting with NRC
management for discussion of needed improvements.
Licensee
commitments for corrective actions were met by the end of the
assessment period,
as indicated by the adequate performance
observed during the
redemonstration exercise along with
favorable observations from a routine inspection.
With the exceptions previously identified, the licensee's
performance in the June 1990 exercise was satisfactory.
Emergency identification and classification through the Site
Area Emergency for this exercise and through General Emergency
for the redemonstration exercise were timely and correct. The
emergency response organization also demonstrated the ability to
mitigate the plant casualties. In the redemonstration exercise,
the licensee exhibited effective dose projection and monitoring,
and the ability to communicate effectively with state and local
authorities.
The June 1990 exercise was objectively observed
and critiqued by the licensee, and the particularly challenging
exercise start time was maintained confidential.
Interdepartmental
coordination and support was also evident based upon the
in-house development and control of a challenging scenario.
12
Upgrades to the emergency preparedness program included the
implementation of a beeper system to correct the inability to
activate the emergency response organization in a timely manner.
Subsequent augmentation drills and the redemonstration exercise
showed that adequate staffing and activation were achievable.
Management emphasized the importance of the emergency response
function by making it part of the employees' job descriptions.
During this period,
the licensee maintained its emergency
response facilities in a state of readiness through the
performance of periodic tests, maintenance, -and inventories.
In addition, the licensee was nearing completion of a new Joint
Information Center near Darlington,
SC at the end of the
assessment period.
The licensee
has
had a history of isolated emergency
classification problems which
have continued during this
assessment period.
As discussed previously, a weakness was
identified in the 1990 exercise for failure to properly
classify a General Emergency.
In addition, during the only
actual event (toxic gas release) occurring within this period,
the licensee initially improperly classified the event as a
Notification of Unusual
Event.
Subsequently, it was
reclassified as an Alert since the release was into a vital
area, not just the protected area. A violation was identified
for this improper classification.
The onsite emergency organization was adequately staffed and
was trained in accordance with Plant Emergency Plan Procedures.
The licensee also continued to provide effective annual
training for offsite authorities including fire, rescue,
and
law enforcement.
Two violations were cited and
one exercise weakness was
identified.
2. Performance Rating
Category: 2
3.
Recommendations
The licensee should continue to provide attention to root cause
analysis and broad corrective actions for problems identified
in the emergency
preparedness area.
One area requiring
increased management attention is emergency classification.
The normal level of inspection effort is recommended.
13
E. SECURITY
1. Analysis
This functional
area addresses those security activities
related to protection of vital plant systems and equipment, and
shipment of irradiated fuel.
A total of 69 inspection-hours
were expended in this functional area, comprising 1% of the
total inspection-hours.
Security management at both the site and corporate levels were
knowledgeable and highly supportive of program activities. The
licensee continued to provide sufficient shift coverage with
well qualified security officers.
Security shift supervisors
were
sensitive to regulatory concerns.
The licensee's
oversight of its security contractor was effective, as
evidenced by frequent backshift inspections of the security
shifts.
The licensee took steps to reduce the turnover rate
during the latter part of the assessment period. The security
force experienced considerable overtime during the extended
refueling outage, with no noticeable decline in operational
effectiveness.
Management support was evidenced by thorough corporate audits,
responsiveness to safety related issues, and efforts to enhance
security program effectiveness.
Notable in this regard was the
establishment of a corporate security policy in which a member
of the corporate security staff visits the site on a monthly
basis to review security force performance in a selected program
area, the results of which are reported to corporate management.
Licensee security initiatives included:
procurement of more
effective security
badge detection equipment to prevent
inadvertent removal of security access badges and keys from the
protected area; procurement of upgraded X-ray equipment to be
installed in the West Access Portal to enhance control of
material entering the protected area and increase inprocessing
capacity; and initiating renovation of firearms range facilities
to provide for eventual installation of tactical training.
The security program continued to be effectively implemented.
Security program functions such as access controls, barrier
verification, patrols, alarm responses, alarm station operation,
control of safeguards information,
and weekly testing of
security equipment received priority attention. The licensee's
corrective actions for inadequate closed circuit television
camera assessment capabilities noted in the previous assessment
period evaluation were adequate and provided for an acceptable
14
level of assessment.
Following the completion of refueling
outage 13,
the licensee took action to repair two vital area
barriers; thus eliminating two long-term compensatory posts.
Coordination of activities and communication between the
licensee's security staff and NRC staff were satisfactory. Two
security plan revisions were made during this assessment period
and both were consistent with regulatory requirements.
The licensee's preparatory actions for a rail shipment of
irradiated spent fuel were noteworthy; a route mock-up was used
for training purposes which included communications
and
shipment checkpoints,
and local law enforcement involvement.
The fuel shipment was completed in an excellent manner.
No violations were cited.
2. Performance Rating
Category:
1
3.
Recommendations
Maintain a reduced level of inspection effort.
F. ENGINEERING/TECHNICAL SUPPORT
1.
Analysis
This functional area addresses those activities associated with
the design of plant modifications; engineering and technical
support for operations,
maintenance,
outages,
testing and
surveillance; and licensed operator training.
A total of 198
inspection-hours were
expended
in this functional
area,
comprising 4% of the total inspection-hours.
Overall,
engineering
and
technical
support has been
satisfactory during this assessment period. Performance of the
Nuclear Engineering Department (NED) and Technical Support Unit
has been satisfactory with good communications and interfacing
between these groups.
However, these strengths were partially
offset by deficiencies in the areas of technical support
staffing, qualification of system engineers,
and a large
backlog of open items.
The NED provides most design engineering support to the plant
through modification development and implementation. The high
level of NED onsite involvement during modification development
and onsite NED oversight during modification implementation were
15
areas of strength.
The Technical
Support and onsite
NED Units demonstrated sound engineering judgement in the resolu
tion of emergent issues such as safety injection accumulator
nozzle cracking, service water pipe thinning, component cooling
water heat exchanger tube cracking, steam generator girth weld
indications, and containment fire effects on equipment. Strong
communications and interfacing were especially evident during
resolution of the service water pipe thinning and steam
generator girth weld indications. The system engineer's support
to Operations during recovery activities associated with an
uncoupled control rod was excellent.
The development and validation of design basis documentation
(DBD) continued to be effective during this assessment period.
The incorporation of DBD information into modification packages
was considered a strength.
However, a weakness was identified
associated with misidentification of containment spray and
motor driven auxiliary feedwater containment isolation valves
in the Safety Injection and Auxiliary Feedwater System DBDs,
respectively. In addition, the licensee's program encompassing
plant instruments to meet the intent of Regulatory Guide 1.97
was evaluated during the period.
Results indicated that the
program was satisfactory; however,
some minor concerns were
identified. Timely improvements were initiated and successfully
completed to yield a strong program in this area.
Management's commitment to Technical Support Unit improvements
was demonstrated by issuance of a Technical Support Improvement
Plan during the assessment period.
Initiatives achieved by the
end of the period include: system and component engineer
training qualification program development,
code of conduct
implementation, procedure writer's guide issuance,
and
technical and procedural guidelines development.
This plan
also included
enhancements
in the areas
of preventive
maintenance and performance monitoring.
Technical support staffing was strained.
Staff increases
occurred during the assessment period and additional staffing
was authorized for 1991.
The additional staff was necessary to
support new program development, system and component engineer
programs,
and reduction in the number of backlogged work items.
However, average Technical Support personnel overtime continued
to remain high during the six month refueling outage; i.e.,
approximately 25 percent overtime was required to support
backshift and weekend coverage and an additional 12 percent of
overtime was required for emergent work items.
16
Limited technical support of routine plant activities was
identified in the previous two assessment periods as a
weakness.
During the assessment period, increased management
attention in this area resulted in additional involvement in
routine plant activities.
However,
consistent improvement
was not achieved.
While examples of good system engineering
performance were noted, system engineers did not consistently
perform system walkdowns nor consistently provide oversight of
significant system maintenance.
Training measures were
developed to address these weaknesses and include a system and
component engineer qualification program and guidelines on how
to perform duties such as technical reviews and system
walkdowns.
Although developed in this assessment period,
qualification implementation was not initiated until after the
refueling outage completion in March 1991.
A previously identified weakness in the method of prioritizing
and tracking items resulted in a large backlog of open items
assigned to Technical Support.
Elimination of this weakness
was an objective of the Technical Support Improvement Plan, the
new prioritization system, and the Technical Support Unit Work
Management System. These programs were not fully effective in
improving management of Technical Support Unit work items.
By
the
end of the assessment period, additional contractor
personnel had been assigned to prioritize items and assist in
reducing the number of outstanding items.
Reduction in the
number of items to a level acceptable to the plant staff was not
anticipated until late 1992.
Technical and engineering challenges were dominated by activities
associated with the extended refueling outage.
The licensee
accomplished a significant number of plant modifications/upgrades
during this outage. These modifications were generally conserva
tive and demonstrated quality engineering and technical support.
Examples included: resolution of electrical system issues by
hardware improvements such as the modification of the 480 volt
DB-50 circuit breakers to upgrade the short circuit fault
current capacities; modifications to incorporate an automatic
nonessential load shedding feature for motor control centers
(MCCs)
and the upgrade of cable ampacities in MCCs; resolution
of concerns due to rejectable indications on a number of control
rod guide tube support pins by a decision to replace all 106
support pins with new pins which have a higher resistance to
intergranular stress corrosion cracking; and dedication of
significant resources in engineering and technical support
to resolve the electrical system single failure vulnerability
issue.
17
Management's attention was focused on the training department
due to the failure of five of ten candidates for an initial
license examination in December 1989,
and the requalification
examination results at another CP&L facility in 1990.
The
licensee's successful efforts to improve performance were
demonstrated
by excellent examination results during this
assessment period.
Operator preparation and training were
intensified and consultants were utilized to assess training
program adequacy and operator exam readiness.
All applicants
passed the initial examinations administered to two reactor
operator (RO) and eight senior reactor operator (SRO) candidates
during this assessment period.
Five of those were retakes of
previous failures.
The Requalification Program was demonstrated to be satisfactory,
as evidenced by a 96 percent pass rate (23 of 24) for requali
fication examinations administered in March 1991 to 12 ROs and
12 SROs.
Strengths were identified during the above examina
tions in the- areas of emergency operating procedure (EOP)
usage
and
communications
between
crew members during simulator
examinations.
Examination material quality was good and
simulator scenarios were excellent in detail and depth of EOP
usage.
Facility evaluator performance was generally good and
simulator crew performance for EOPs was very good.
However,
some weaknesses were identified in initiation of Critical Safety
Function monitoring, proper use of Annunciator Alarm Procedures,
and
inconsistent implementation
of Abnormal
Operating
Procedures.
Two violations were cited.
2.
Performance Rating
Category: 2
3. Recommendations
Increased
management attention
should be focused on the
staffing level of the Technical Support Unit. A high priority
should be placed on implementation of the Technical Support
Improvement Plan and on accomplishing training of the system and
component engineers. A normal level of inspection effort should
be maintained.
G. SAFETY ASSESSMENT/QUALITY VERIFICATION
1. Analysis
This functional area addresses those activities related to
licensee implementation of safety policies; license amendments,
exemptions, and relief requests; responses to Generic Letters,
18
Bulletins,
and Information Notices; resolution of safety
issues; reviews of plant modifications- performed under 10 CFR
50.59; safety review committee activities; and the use of
feedback from self-assessment programs and activities. A total
of 1242 inspection-hours were expended in this functional area,
comprising 26% of the total inspection-hours.
Licensee management has continued to be actively involved in
monitoring and assessing plant performance
and operations.
Management's visibility in the plant increased in the latter
portion of the assessment period, with routine weekly materiel
condition inspections and scheduled containment tours during
the outage.
However, these efforts were not initiated until a
concern was raised regarding management presence in the plant as
discussed in section IV.A.
Unit managers were utilized as
start-up managers
during the return to power operation
subsequent to refueling outage 13.
The start-up managers were
effectively utilized to coordinate plant activities and minimize
unnecessary distractions to the plant operators.
Management
involvement
in safety was also demonstrated through the
minimization of shutdown risks during the refueling outage
as discussed in section IV.A.
The licensee's performance of oversight functions continued to
be adequate with appropriate management involvement in safety
decisions.
The Plant Nuclear Safety Committee routinely
disposed of safety issues in a technically sound and conserva
tive manner.
This was demonstrated through the evaluation
and disposition of degraded source range nuclear instrumentation,
service water system piping degradation,
and steam generator
indications.
As
discussed in section IV.F.,
effective
management oversight was evident in the actions to address
operator licensing concerns.
However,
oversight was not
effective in precluding recurrence of concerns with surveillance
test performance and emergency response organization augmentation
and activation (see sections IV.C. and D., respectively).
The
timeliness of independent reviews
performed
by
the
Corporate Nuclear Safety (CNS)
section improved from the last
assessment period, with a significant reduction in the backlog
of items requiring review.
The Onsite Nuclear Safety (ONS)
group continued to be effective in its performance of special
investigations into technical
concerns and events.
The
Operating Experience Feedback (OEF) system was also effectively
utilized through the conduct of Focus on Nuclear Safety
Meetings prior to the transformer outage and prior to plant
start-up from refueling outage 13.
Additionally, dissemination
of OEF reminders which had applicability to scheduled outage
evolutions, demonstrated
a proactive effort to prevent
19
occurrence of industry events at H. B. Robinson. These efforts
are indicative of improvement in proactive oversight since the
last assessment period.
Other oversight functions and programs (i.e., Quality Assurance
(QA)/Quality Control
(QC)
and corrective actions- programs) did
not demonstrate consistent results. Concerns were identified with
the QA/QC function, in that initial required QA/QC reviews of
work requests were not being performed. Additionally, the site
corrective action programs were not consistently applied.
The
degree of management attention that identified issues received and
the threshold for issue identification and categorization were
not uniform among corrective action programs.
The corrective
action programs were revised to provide a centralized site-wide
system which would perform root cause analysis where warranted
and receive consistent management attention.
The root cause
analysis performed on improper safety injection pump thrust
bearing installation was comprehensive and timely, exhibiting
improvement over the previous corrective action programs'
nonformalized root cause analysis process. Management was not
effective in implementing formalized/proceduralized corrective
action trend analysis nor in fully developing the maintenance
repetitive failure program. However, the use of non-formalized
Adverse Trend Meetings successfully identified problems such as
inadequate radiological postings and poor construction work
practices.
Effective January 1, 1991,
the QA Department,
CNS,
and ONS
functions were transferred to the newly established Nuclear
Assessment Department.
The key positions of Section Manager,
Onsite Assessment -and Engineering/Technical
Support
Focus
Manager were not filled at the end of the assessment period.
Licensee Event Report (LER)
quality was considered acceptable
and covered all major aspects of each event; valuable
supplemental information was provided as needed.
Weaknesses
noted in LER quality during the previous assessment period were
corrected.
The licensee's program for reporting defects and
non-compliances,
as required by 10 CFR 21, was adequate.
The
licensee conservatively issued a part 21 notice on potential
concerns with safety injection accumulator weld metals,
even
though the supplier did not believe a notice was warranted.
Improvements were made in the procedure for performing safety
evaluations required by
10 CFR
50.59.
This procedure was
established under the guidelines of Nuclear Safety Analysis
Center
(NSAC)-125,
an industry standard for 10 CFR 50.59
reviews.
Distinctive improvements in safety review quality and
20
thoroughness were observed following the procedure's implementa
tion in June 1990. A critical and noteworthy element of this
new process is the line-item requirement to address the design
basis in safety review packages.
Responses to NRC Bulletins, Generic Letters and other generic
communications were timely and met regulatory requirements.
Reflecting the significant number of modifications and other
activities, the number of Technical Specification (TS) changes,
relief requests,
and exemptions increased during this rating
period.
These licensing activities include a significant
number of actions related to the improvements of the on-site
electrical systems.
During this assessment period, all the
electrical system issues raised during the 1987 safety system
functional inspection were resolved.
In general, the quality
of the submittals was satisfactory, exhibiting improvement in
both quality and completeness since the last assessment period.
The licensee was responsive to staff questions during the
review of these applications.
However,
in the case of the
request to change the TS related to the radiation monitoring
system, the emergency and exigent TS amendment requests could
have been avoided through better planning.
In addition, the
upper range of the plant vent radiation monitor had to be
corrected subsequent to the issue being raised by the staff
during review. Initially, the licensee did not appear to have
full knowledge of the licensing requirements and design basis
of the plant vent monitor.
One violation was cited.
2.
Performance Rating
Category: 2
3. Recommendations
A normal level of inspection effort should be maintained.
V.
SUPPORTING DATA
A.
Licensee Activities
Beginning and ending the assessment period at full power,
the unit
operated with an availability factor of 56.4 percent.
During this
period the unit experienced two reactor trips (discussed in section
V.F.)
and three outage related shutdowns,
one of which commenced
refueling outage 13.
On May 4, 1990, the unit was removed from
service for ten days to upgrade the main and auxiliary transformers.
21
With the exception of a trip initiated three-day recovery period to
make repairs to a failed main feedwater regulating valve, the unit
operated until it
was removed from service on June 16,
1990,
to
replace all three main feedwater regulating valve gaskets.
The unit
resumed operation on June 18,
1990,
and conducted normal power
operations until refueling outage 13, which began on September 8,
1990 and ended on March 9, 1991.
Primarily due to emergent work,
this 99-day scheduled outage lasted
183 days.
Emergent work
encountered included: uncoupled control rod recovery; control rod
guide tube support pin replacements; reactor coolant pump seal work;
and containment fire recovery.
At the start of the refueling outage the former Operations Manager
was promoted to Plant General Manager.
A Technical
Support
engineering supervisor, licensed as a senior reactor operator, was
promoted to the Operations Manager position.
In the last month of
the assessment period the Environmental
and Radiation Control
Manager was replaced by the Nuclear Services Department Principal
Specialist -
Health Physics.
B. Direct Inspection and Review Activities
During the assessment period, 38 routine and two special inspections
were performed at H. B. Robinson by the NRC staff.
The special
inspections were:
o
April 16-20, 1990; Regulatory Guide 1.97 Review
o
May - June 1990; Maintenance Team Inspection
C. Escalated Enforcement Actions
1. Orders
None
2. Civil Penalties
None
D. Management Conferences
During the assessment period there were four management conferences
with the licensee. These were:
o
March 30,
1990; Management Meeting to Discuss
SALP Board
Assessment
O
August 16,
1990;
Management Meeting to Discuss Emergency
Preparedness at all three CP&L sites
22
o
November 27,
1990; Management Meeting to Discuss Robinson
Activities, Improvements, and Future Plans
o
January 3, 1991; Management Meeting to Discuss CP&L's Nuclear
Assessment Program
E. Confirmation of Action Letters
None
The unit experienced two automatic reactor trips which are listed
below:
O
January 17, 1990; The unit tripped from 100 percent power when
an operator inappropriately tripped two bistables during a
nuclear instrumentation surveillance test.
The unit was
restarted the next day.
o
May 17, 1990;
The unit tripped from 100 percent power on low
steam generator level as a result of the B main feedwater
regulating valve disc separating from the stem. The unit was
returned to service after 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br />.
G.
Review of Licensee Event Reports (LERs)
During the assessment period a total of 16 LERs were analyzed. The
distribution of these events by cause,
as determined by the NRC
staff, was as follows:
Cause
Component Failure
3
Design
5
Construction, Fabrication,
2
or Installation
Personnel
-
Operating Activity
2
-
Maintenance Activity
0
-
Test/Calibration Activity 2
-
Other
0
Other
2
Total
16
Note 1:
With regard to the area of "Personnel Errors", the NRC
considers lack of procedures,
inadequate procedures,
and erroneous
procedures to be classified as personnel error.
23
Note 2:
The "Other" category is comprised of LERs where there was a
spurious signal or a totally unknown cause..
Note 3:
Two additional LERs were voluntary and not considered in
this report.
H.
Licensing Activities
During the assessment period the staff completed 31 licensing
activities. This included the issuance of 10 Technical Specification
amendments; the granting of two relief requests; completion of five
(non-amendment)
safety evaluations; and review of six generic
letters, three bulletins, and three Multi-Plant Actions.
I. Enforcement Activity
NO. OF DEVIATIONS AND VIOLATIONS IN EACH
FUNCTIONAL
SEVERITY LEVEL
AREA
Dev.
V
IV
III
II I
Plant Operations
Radiological Controls
Maintenance Surveillance
7
2
Security
Engineering/Technical
Support
2
Safety Assessment/Quality
Verification
1
TOTAL
12