ML14181A734
| ML14181A734 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/17/1996 |
| From: | Jaudon J, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A735 | List: |
| References | |
| 50-261-96-06, 50-261-96-6, NUDOCS 9606120047 | |
| Download: ML14181A734 (20) | |
See also: IR 05000261/1996006
Text
eR REGo.
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.:
50-261/96-06
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson Steam Electric Plant, Unit 2
Inspection Conducted: May 6 - May 17, 1996
Inspector:
'
/
Date Signed
Accompanying Personnel: W. Bearden, Reactor Inspector
B. Desai, Resident Inspector
D. Jones, Senior Radiation Specialist
C. Smith, Senior Reactor Inspector
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................ .
1.0
INSPECTION OBJECTIVES AND SCOPE.
.
............
. . .
2
2.0
EVALUATION METHODOLOGY..
............... . . .
2
3.0
PLANT OPERATIONS - PERFORMANCE ASSESSMENT...........
. . .
3
3.1
Safety Focus
. . . *............................
. ...
3
3.2
Quality of Operations.
............. ...
. . . .
4
3.3
Problem Identification.
.
.............
. . . .
5
3.4
Problem Resolution *.....*.*.*................... . ..... 5
3.5
Programs and Procedures.
............. ..
. . . .
6
4.0
ENGINEERING - PERFORMANCE ASSESSMENT.
..........
. . . .
6
4.1
Safety Focus..
..................
. . .
6
4.2
Problem Identification.
.
............
. . . . .
7
4.3
Problem Resolution............. .
- ..............
. ..
8
4.4
Quality of Engineering Work.
............
. . . .
8
4.5
Programs and Procedures.
.
............
. . . .
9
5.0
MAINTENANCE - PERFORMANCE ASSESSMENT.
..........
. . . . .
9
5.1
Safety Focus
. . . *.............................. ...
9
5.2
Problem Identification/Problem Resolution.... .
. . . ..10
5.3
Equipment Performance and Material Condition...
. . . ..
10
5.4
Quality of Maintenance.
.
..............
. .
11
5.5
Programs and Procedures. ...........
. . .
. . . ..12
6.0
PLANT SUPPORT - PERFORMANCE ASSESSMENT. ........
. . . . ..13
6.1
RADIOLOGICAL CONTROLS. ...........
. . . .
. . . ..
13
6.1.1 Safety Focus ............................. ... .
13
6.1.2 Problem Identification/Problem Resolution...
. . ..13
6.1.3 Quality of Radiological Controls. ........
. ..
13
6.1.4 Programs and Procedures........ . .
. . . . . ..
14
6.2
SECURITY..
................ . . . . . ..14
6.2.1 SAFETY FOCUS.
.
............
. . . . . ..14
6.2.2 Problem Identification/Problem Resolution........ .
. . . ..
14
6.2.3 Quality of Security. ...........
. .
. . . ..15
6.2.4 Programs and Procedures......... .
. . . . .
..
15
6.3
............
. . .
. .
..
15
6.3.1 Safety Focus ...........................
. .. .
15
6.3.2 Problem Identification/Problem Resolution....
.
..
15
6.3.3 Quality of Emergency Preparedness.....
. . . . ..15
6.3.4 Programs and procedures.
............ .
. ..
16
7.0
SAFETY ASSESSMENT/CORRECTIVE ACTION...............
16
7.1
Problem Identification....................................16
7.2
Problem Analysis and Evaluation ...............
16
7.3
Problem Resolution.....................
17
APPENDIX A . . . . . . . . . . . . . . . . . . .............
18
APPENDIX B. ..........
. . . . . . . . . . . . . . . . . . .
.
.
19
1
EXECUTIVE SUMMARY
The Region II Office of the U. S. Nuclear Regulatory Commission conducted this
preliminary assessment of Carolina Power and Light Company's H. B. Robinson
Steam Electric Plant, Unit 2 on May 6 through May 17, 1996. The purpose of
the preliminary assessment was to develop an integrated perspective of
performance strengths and weaknesses based on an in-office review of
inspection reports, event reports, and other NRC and licensee generated
performance information. The assessment covered a two year period from April
1994 through April 1996. A two-week on-site assessment is scheduled for
June 3 through June 14, 1996, to validate the conclusions reached during this
in-office review. Ratings for performance areas are identified on the
Preliminary Assessment/Inspections Planning tree (Appendix A) and are
summarized as follows:
The licensee's focus in operations was on plant safety. Operators generally
performed well in response to transients and scrams. However, operator errors
occurred throughout the period. Problem identification by the line
organizations appeared to be not fully effective. Problem resolution was
ineffective in preventing recurring configuration controls. Operations
programs and procedures also contributed to recurring problems including
inadequate equipment clearances.
The licensee's engineering organizations were properly focused on safety,
although some non-conservative determinations were made. Engineering
identification of problems has not been consistent. Problem resolution was
satisfactory. Quality of engineering was indeterminate. Engineering programs
and procedures were satisfactory.
The licensee's maintenance and test activities have not always been planned
and conducted with appropriate focus. Although recent improvements in
management attention and supervisor involvement have been evident,
communication of management expectations has not always been effective. This
has resulted in recurring problems such as procedure adherence and inadequate
restoration of equipment following maintenance. Equipment performance and
material conditions have generally been acceptable and safety related
equipment has functioned properly. The licensee has not experienced numerous
scrams or unplanned transients due to equipment problems or errors while
performing maintenance or surveillance testing during the period. Most
required testing has been performed correctly and on schedule. Identification
and resolution of known problems have not always been effective. Several long
term problems, and work instructions, have continued to occur.
The licensee's performance in the plant support areas of radiation protection
and emergency preparedness was excellent. The licensee's security program
appeared to be inadequately focused, and management's expectations in this
sub-area had not been effectively communicated for problem identification and
resolution. Quality of security was lacking in several areas. Security
programs and procedures were adequate.
2
INITIAL INTEGRATED PERFORMANCE ASSESSMENT OF ROBINSON
1.0
INSPECTION OBJECTIVES AND SCOPE
This Integrated Performance Assessment of the H. B. Robinson Steam
Electric Plant, Unit 2, is being performed in accordance with NRC
Inspection Procedure 93808 "Integrated Performance Assessment Process."
The assessment objectives are to develop an integrated perspective of
licensee strengths and weaknesses through a combination of document
reviews of selected NRC and licensee documents and an on-site
performance based inspection. Once this perspective is gained, the team
will recommend where future NRC resources should be used for maximum
safety benefit. The scope of the assessment includes the areas of
safety assessment and corrective action, operations, engineering,
maintenance, and plant support during approximately the last two years.
The assessment is divided into the following parts: a preliminary
assessment performed at NRC Region II; an on-site assessment to validate
the observations from the in-office review; and a final analysis of the
results of the previous assessments and development of inspection
recommendations. The assessment is being conducted by inspectors from
NRC, Region II.
The preliminary assessment is based on an in-office review of the
inspection record, licensee event reports, enforcement history, licensee
periodic performance reports, and other NRC documents. The preliminary
assessment was performed during the weeks of May 6 and May 13, 1996.
The results from this phase of the assessment are contained in the
following preliminary assessment report and accompanying Preliminary
Performance Assessment/Inspection Planning Tree (Appendix A).
Following the issuance of this preliminary assessment report, the team
will attempt to validate its conclusion via a performance based, on-site
assessment. The on-site visit is scheduled during a two-week period
beginning June 3, 1996. The results of this on-site visit will be
integrated with those of the preliminary assessment and documented in a
Final Assessment Report which will be issued following the on-site
visit.
Included in the Final Assessment Report will be recommendations
on where to focus future NRC inspection effort. These recommendations
will be depicted on a Final Performance Assessment/Inspection Planning
Tree.
2.0
EVALUATION METHODOLOGY
The scope of evaluation includes the five functional areas of safety
assessment and corrective action, operations, engineering, maintenance,
and plant support. Within each functional area, key elements of
performance such as safety focus, problem identification/resolution,
quality of actions, and programs and procedures are analyzed. Based
upon this preliminary analysis, each key element is assigned a color
[code] defined as follows:
Green [Back-Slashed Lines] - Reduced Inspection.
Licensee
attention and involvement are properly focused on safety and
result in a superior level of performance. The NRC will strongly
consider reducing inspection effort.
No Color [Cross-Hatched Lines] - Normal Inspection. Licensee
attention and involvement are normally well focused and result in
a good level of performance. The NRC will consider applying a
normal inspection effort.
Blue [Dotted Background] -
Increased Inspection. Licensee
attention and involvement are often not well focused and
performance suffers.
The NRC will strongly consider increasing
inspection effort and focus in these elements.
Yellow [Forward-Slashed Lines] - Indeterminate. The information
available was insufficient or inconsistent, and an evaluation
could not be completed. Further review and analysis will be
performed to ascertain the performance level.
The results obtained from the preliminary assessment will be used by the
assessment team to develop individual on-site assessment plans for each
of the major assessment areas. The team will have special focus during
the on-site review in those elements rated as Indeterminate and
Increased Inspection during the preliminary assessment. The overall
assessment of a functional area was not determined during the
preliminary assessment but will be assigned during the final analysis
after the on-site visit.
3.0
PLANT OPERATIONS - PERFORMANCE ASSESSMENT
3.1
Safety Focus
Although the licensee maintained focus on safety, numerous challenges
occurred that distracted this safety focus. These distractions were
primarily human performance related events that were manifested in the
form of instances of valve misalignments, clearance and tag-out
problems, ineffective communications, and inadequate procedures.
Licensee focus on reducing these human errors appears to have recently
reduced the error rate. Notwithstanding the errors, the licensee was
responsive to overall plant and equipment conditions improved (Ref. IR
95-19), and the ACR process was satisfactorily utilized to keep focus on
safety (Ref. IR 94-22).
Further, operational performance during
shutdown and reduced inventory as well as following several transients
was indicative of conservative operating philosophy (Ref. IRs 95-14, 95
15).
PNSC and NAD actively participated in event and plant condition
reviews (Ref. IR 95-29).
The long term effectiveness of licensee actions to reduce human errors
warrants further evaluation during the on site inspection phase of the
IPAP.
4
3.2
Quality of Operations
Overall, the quality of operations during the assessment period was
noted to be poor. Weaknesses in licensed and non-licensed operator
performance and lack of attention to detail resulted in numerous
examples of component misalignments, incorrect configuration during
clearance and tag-outs, and inadequate communication of actions and
expectations. Further, weaknesses pertaining to licensed operator
knowledge during initial examination were also noted.
Examples of weak licensed operator performance in the control room
included: an operator momentarily leaving the "at-the-controls" area,
(Ref. IR 94-13), inadvertent draining of the A SI accumulator when the
intent was to drain the B SI accumulator (Ref. IR 94-15), lack of
appropriate monitoring of control room indications resulting in failure
to detect a failed post-accident containment vessel water level
instrument (Ref. IR 94-16), RCS cool-down rates being exceeded (Ref. IR
94-27), failure to monitor and control steam generator level diligently
during a shutdown which resulted in an unnecessary high level condition
(Ref. IR 95-21), and failure to identify a failed RCS loop flow
instrument (Ref. IR 94-17).
Examples of poor communication included: nine main steam system valves
mis-positioned as a result of poor communication between the SRO and the
SCO (Ref. IR.94-23); informal communication of logistics and inadequate
turnover of a maintenance evolution on behalf of the shift supervisor,
which resulted in the auxiliary building ventilation system being
rendered inoperable (Ref. IR 95-06); inadequate communication between a
licensed operator assigned to refueling activities and contractor
refueling personnel which resulted in poor implementation of a thimble
plug removal evolution (Ref. IR 95-14); and inadequate communication of
actions taken by the reactor operator to adjust RCP seal flow which
eventually resulted in increased RCS leakage and a declaration of an
unusual event (Ref. IR 95-23).
Examples of clearance and tag-out related problems included: an SRO
overriding a computer generated clearance restoration that resulted in
mis-positioning of two instrument root valves in the service water
system (Ref. IR 94-28); several waste disposal components not
appropriately configured as a result of a poorly written clearance (Ref.
IR 94-28); SI accumulator fill valve left shut when it should have been
open following restoration of a clearance (Ref.
IR 95-19); failure to
appropriately affix a CIT to preclude running the containment
recirculation fan while the inlet damper was closed through a clearance
(IR Ref. 95-19); and an inadequate clearance boundary resulting in an
inadvertent start of the SDAFW (Ref. IR 95-19) and EDG (Ref. IR 95-27).
An example where licensed operator knowledge weakness surfaced was when
an AFW pump auto started because an SRO did not fully understand the
MDAFW auto start defeat indication on the RTGB (Ref. IR 95-19).
Further, several knowledge deficiencies included EOP and AP related were
noted during an operator licensing initial examination (Ref. IR 94-300).
5
Other examples indicative of weakness included valve mis-positioning
occurrences on the RCDT, AFW, SW, and Condenser system, poor
coordination resulting in LTOP requirements not being met (Ref. IR
95-19), and an RHR pump operating without flow for approximately 66
minutes (Ref. IR 95-19).
On a positive note, operator performance and response during several
transients was appropriate as manual trips were initiated. Further, on
one occasion manual boration was appropriately initiated upon indication
of a possible stuck rod, and manual closure of a PORV upon indication of
it not being fully closed (Ref. IRs 94-12, 94-19). Operator knowledge
of PSA/PRA was also noted and operator performance during refueling
activities were predominantly uneventful from a shutdown risk
perspective.
Increased inspection is recommended.
3.3
Problem Identification
A significant portion of the problems including valve misalignments,
clearance control, communication, and procedure related issues were
identified by the resident inspector or were identified as a result of
an event related to the problem. The ACR process was utilized to
document and access the significance and corrective action associated
with the problems. Further, appropriate threshold and prioritization of
the generated ACR was noted. However, trending of the ACRs was
considered marginal.
The configuration problems identified by the
resident inspector were located in the control room as well as in the
plant. This was indicative of a configuration control on part of
licensed as well as non-licensed operators. The use of independent or
double verification, self assessment, and line management assessment
will be further evaluated during the on-site phase of the IPAP.
Increased Inspection is recommended.
3.4
Problem Resolution
Operations problem resolution was slow and appeared ineffective in
resolving known problems in configuration control, clearance and tag-out
control, and communication errors that frequently occurred. These
errors primarily occurred because of a lack of attention to detail on
part of licensed and non-licensed operators. The stand-down meetings
and counseling that ensued, did not affect the occurrences of these
errors significantly. Indications are that recent performance in this
area appears to be improving. Personnel changes coupled with
implementation of independent verification has had an effect in reducing
the incidents of operating errors.
Particular examples, which were repetitive and indicative of
ineffectiveness, included operations department failing to implement
corrective action to CCW AOP (Ref. IR 96-300), coordination and
communication failures on part of numerous individuals leading to an RCS
leakage and NOUE during CVCS evolution (Ref. IR 95-23), and recurrence
6
of configuration control issues (Ref. IRs 95-19, 95-27).
The number of
negative incidents in the later part of the assessment period has shown
a declining trend indicating positive impact that has resulted from the
recent corrective actions.
Increased inspection is recommended.
3.5
Programs and Procedures
Operations related programs and procedures were satisfactory with some
weaknesses noted. The operator license requalification program was
adequate (Ref. IR 95-25), and EOP and AOP validation and verification
was effective (Ref. IR 95-17).
Strong multidisciplinary involvement was
noted in the implementation of Procedure OST-010 related to steam flow
based calorimetric used to calculate thermal power (Ref. IR 95-29).
Surveillances performed by operations were generally performed with pre
briefings and specific assignments of personnel responsibilities (Ref.
IR 95-30). Missed surveillances were not identified.
Weaknesses identified included occasional use of night orders, vice a
formal procedure change that is subject to appropriate evaluation. An
example of this was the change on allowed CCW temperature during normal
operation from 55 degrees F to 45 degrees F (Ref. IR 95-06).
Other
weaknesses included inadequate Procedure OP-201, to facilitate a flow
path for the A RHR pump (Ref. IR 95-19), a containment closeout process
weakness (Ref. IR 95-19), an inadequate procedure to conduct RHR system
leak test (Ref. IR 95-12), and a failure to revise Procedure OP-923
appropriately to reflect identification of certain containment isolation
valves (Ref. IR 94-23).
Increased inspection is recommended.
4.0
ENGINEERING - PERFORMANCE ASSESSMENT
4.1
Safety Focus
The licensee reorganized the engineering functions from a central design
oriented organization, located at the corporate office, to an on-site
centered organization. The intent of this reorganization was to
establish a consistent engineering organization at each of the three
CP&L nuclear sites and to increase the efficiency of the delivery of
engineering services (Ref. IR 94-25). A RPRG was also established for
reviewing and approving proposed plant modifications for inclusion in
the Master Project Index and the Robinson Five Year Plan.
Prioritization of proposed plant modifications under the RPRG review and
approval process included assignment of an index based on nuclear safety
concerns which determined the scheduled implementation date of plant
modifications (Ref. IR 94-25). A second reorganization change was also
implemented to establish the Rapid Response Team which provides
immediate response to engineering service requests transmitted to the
Robinson Engineering Site Services organization (Ref. IR 95-07).
The staffing level of the on-site engineering group was considered
adequate to maintain engineering support to plant operations and
7
maintenance (Ref. IR 94-25).
Additionally, engineering evaluations
performed to support operability determinations were sometimes
technically correct (Ref. IRs 95-27, and 96-01).
On occasions,
inadequately performed engineering evaluations resulted in reportable
event such as occurred from LERs 50-261/94-014-00 and 01 (Ref. IR 96
02).
A non-conservative operability determination was also made in
connection with the engineering evaluation performed for the erroneous
FI-605 flow indication on the RHR System (Ref. IR 94-17).
Equivalency
Evaluation, EE-94-133, performed for main control room dampers solenoid
valves SV-6521 and SV-6522, along with EE 94-094 performed for the
penetration pressurization system further demonstrated weaknesses in the
implementation of this process (Ref. IRs 94-23 and 95-07). A
discernable improvement in the safety focus of engineering personnel has
not been demonstrated since de-centralization of the engineering
organization.
Increased inspection is recommended.
4.2
Problem Identification
Self assessments and independent quality audits of engineering
activities by the Nuclear Assurance Department were effective in
identifying several major areas for improvement. Engineering Technical
Support Near-Term Improvement Action Item Plan-Engineering Excellence 94
was initiated, and details of this plan were shared with the NRC on
August 29, 1994 (Ref. IR 94-25).
The Engineering Excellence 94 program
has been extended with the objective of making it a corporate wide
program in 1996 (Ref. IR 95-07).
Engineers performance in identifying problems have not been consistent.
At times, the engineering staff has been effective and timely in
responding to plant problems and in interfacing with the operations
staff (Ref. IRs 95-07, 95-26, 95-27, and 95-30).
Identification and
correction of the pressure locking phenomenon involving containment sump
suction valves also demonstrated effective problem identification and
resolution (Ref. IR 95-07).
On other occasions, weaknesses in
engineering support to operations were identified because of a lack of
initiative by engineering to conduct detailed evaluations of emergent
issues (Ref. IRs 96-01, and 95-06).
Increased inspection is recommended.
4.3
Problem Resolution
Engineering support for resolution of long standing, repetitive , or
similar concerns were mixed. Engineering support for restarting the
reactor following a reactor trip on June 30, 1995, was inadequate (Ref.
IR 95-21).
Additional examples of inadequate support for resolution of
long standing problems were demonstrated by the setpoint program
deficiencies and TS violations involving inaccurate setpoint
calculations (Ref. IRs 96-02 and 94-16).
Continuing problems with the
slope of sensing lines for electronic differential pressure transmitter
were indicative of an inability to develop and implement effective
corrective action (Ref. IR 95-30). The engineering'function's
effectiveness for resolution of problems was also demonstrated by timely
8
support for resolution of erratic charging pump operation caused by low
T-Average temperature. Pursuant to decentralization of the engineering
organization, administrative and design engineering controls have been
established to ensure proper prioritization of engineering work (Ref.
IRs 95-27 and 94-25).
Also, corrective action plans for deficiencies
identified in independent audits and self assessments have been
implemented for the engineering organization (Ref. IRs 95-07 and 94-25).
Normal inspection is recommended in this area.
4.4
Quality of Engineering Work
Plant modification and temporary modification packages were generally
determined to be technically adequate. The control of temporary
modifications was also effective as was demonstrated by their low number
and the level of management review they received (Ref. IRs 95-07 and 94
25).
Numerous instances of deficiencies involving inadequate design
control were also identified. Additionally, one example of the use of an
unverified assumption in a 10CFR50.59 Safety Evaluation occurred (Ref.
IRs 96-03, 95-19, 95-06, 94-27, 94-24, and 94-16).
These deficiencies
demonstrated a lack of attention to detail during implementation of the
design engineering control program. Corrective actions for identified
deficiencies were resolved and fixed in an acceptable manner (Ref. IRs
95-29, 95-21, and 95-12).
However, a lack of engineering justification
was identified in some of the completed corrective actions (Ref. IR 95
20).
Good communications was demonstrated between the engineering technical
support staff and the operations staff since decentralization of the
engineering organization. An engineering Technical Support duty
representative was made available on a twenty four hour basis to
expedite engineering assistance to the operations staff. A Technical
Support representative also attends the operations morning meeting in
order to identify issues which require engineering technical support
assistance. A training course has been established to provide training
modeled on INPO guidelines to engineering support personnel.
management has demonstrated a strong desire to have a qualified and
technically competent engineering staff by establishing this course and
implementing plans for engineers to be certified to various systems
(Ref. IR 94-25).
The quality of engineering is indeterminate and warrants further
evaluation during the on-site inspection of the IPAP.
4.5
Programs and Procedures
Engineering technical support programs and procedures were determined to
be adequate for the development and management of both temporary and
permanent plant modifications. Additionally, the mission, standards,
administration, organization, responsibilities, and duties of the
engineers were adequately delineated in Technical Support Management
is
Manual TMM-001 (Ref. IR 94-25).
Implementation of these procedural
controls has resulted in work products and services of varying quality.
Only one example of an inadequate procedure, AOP-014, Component Cooling
Water System Malfunction, which could not be performed the way it was
9
written , was identified (Ref. IR 95-08).
This example cannot be
interpreted to mean that procedural controls are acceptable given the
mixed performance of the engineering organization since decentralization
of the engineering functions.
Normal inspection is recommended in this area.
5.0
MAINTENANCE - PERFORMANCE ASSESSMENT
5.1
Safety Focus
Improvement has occurred in this area. This appears to be largely the
result of increased management attention and supervisor involvement.
Additionally, there have been observations of a questioning attitude by
maintenance personnel involved in work activities (Ref. IR 94-26).
This
resulted in the discovery and repair of improperly configured
connections in the Instrument Air System (Ref. IR 94-23) and
identification of a discrepancy requiring procedural revision prior to
continuation of testing (Ref. IR 94-12). Although recent improvements
have occurred, communication of management expectations has not always
been effective. This has resulted in recurring problems such as
procedure adherence and inadequate restoration of equipment following
maintenance. Examples of this included a Control Room differential
pressure instrument, which was not adequately returned to service (Ref.
IR 94-15), failure to establish compensatory measures for penetrations
breached for maintenance, which resulted in uncontrolled vital area
during maintenance access (Ref. IR 94-26), failure to restore three WD
System components properely following maintenance (Ref. IR 94-28),
examples of inadequate communications, planning, and procedures such as
the Auxiliary Building ventilation fans being secured prior to
establishing radiological compensatory measures (Ref. IR 95-06), and
poor communications during maintenance of a RHR pump breaker which
resulted in the inadvertent start of the pump (Ref. IR 95-19).
Late in the assessment period, the licensee conducted several planned
on-line preventative maintenance activities on the B Diesel Generator.
These activities were well planned and implemented. The licensee gave
proper attention to not scheduling any other significant work activities
on the other train of safety related equipment while the diesel
generator was out of service. The job received highest available
support and was worked around the clock until completed (Ref. IR IR 96
04).
However, the inspectors also concluded that the licensee's on-line
risk maintenance program did not require formal evaluation of increased
risk due to on-line maintenance (Ref. IR 95-03).
Increased inspection is recommended.
5.2
Problem Identification/Problem Resolution
Although performance in this area has improved, several long term
problems continued to exist through most of the assessment period.
These included problems with procedure adherence, inadequate clearances
and procedures, restoration of equipment following maintenance, and
foreign materials exclusion. The licensee has a good performance based
assessment program associated with monitoring of maintenance activities
010
by Quality Assurance personnel (Ref. IR 95-27).
However, self
assessment by the maintenance organization has not always been
effective. Recent assessments by the licensee's Nuclear Assessment
Department have resulted in the identification of several issues. Many
problems identified by the NRC and more recently by NAD could have been
identified and corrected earlier through self assessment. Examples of
these included: the licensee's failure to correct various known TS
surveillance program deficiencies (Ref. IR 94-16), failure to take
corrective action for repetitive failures of RHR total flow indicator
(Ref. IR 94-17), inadequate corrective actions resulting in recurring
problems regarding FME in safety injection pumps, and the EDG air
distribution failure (Ref. IR 94-22).
Maintenance personnel failed to
identify a missing plug in a new EDG turbocharger (Ref. IR 94-26); the
licensee failed to resolve a previously known problem where no procedure
existed for maintenance on the AFW flow control valve actuators (Ref. IR
94-27); and the licensee failed to document and resolve a previously
known test procedure discrepancy (Ref. IR 96-04).
Although the licensee's trending of maintenance Level III ACRs was
determined to be adequate, trending of work control Level III ACRs was
considered marginal.
Additionally, an independent third party audit
performed for the site identified potential adverse trends which had not
been identified by the licensee. These potential adverse trends were in
the areas of procedure quality, procedure adherence, clearances, and
FME.
Increased inspection is recommended.
5.3
Equipment Performance and Material Condition
Equipment performance and material conditions have generally been
acceptable and safety related equipment has functioned properly. There
has not been a significant number of scrams or unplanned power
reductions due to equipment problems or errors while performing
maintenance or surveillance testing during the period. Few repetitive
equipment problems occurred. An exception to this has been the drifting
of three channels of process instrumentation beyond acceptable
tolerances allowed in TS (Ref. LERs95-006, 95-007, and 95-008).
There has been an improvement in external material condition of plant
equipment. This included less boric acid buildup and the improved
condition of coatings (Ref. IR 95-19).
Housekeeping was generally
satisfactory, and equipment condition of selected systems appeared to be
good with no major system leaks and fewer catch containers. Minor leaks
had been previously identified by licensee and WRs submitted (Ref. IR
96-01).
Normal inspection effort is recommended in this area
5.4
Quality of Maintenance
The licensee's maintenance and surveillance programs are generally
effectively implemented. Some improvement has occurred during this
assessment period but the licensee has continued to have problems in the
area of conduct of maintenance activities. Maintenance management
demonstrated strong supervisory involvement, coordination and
communications during complex activities (Ref. IR 95-19). Maintenance
and surveillance activities were well planned and implemented (Ref. IRs
95-03, 95-30 and 96-04).
Additionally maintenance personnel involved in
performing testing demonstrate a questioning attitude. This resulted in
identification of a discrepancy requiring procedural revision prior to
continuation of testing (Ref. IR 94-12).
Examples of problems identified during the assessment period included a
maintenance technician who erroneously commenced work on the wrong Boric
Acid Storage Tank, failure to follow work instructions adequately, and
performance of Pressurizer level instrument WR/JO restoration steps out
of sequence (Ref. IR 94-15). Other examples included maintenance
personnel who used thread sealant with expired shelf life and failed to
read an indicator correctly during a calibration (Ref. IR 94-26), the
use of non-approved oil in plant components (Ref. IRs 94-28 and 95-03),
use of non-controlled training material during performance of
troubleshooting activities (Ref. IR 95-27), a problem with capacitor
replacement including incorrect installation of a replacement capacitor
during maintenance and failure to document lifting and relanding a wire
temporarily lifted during maintenance (Ref. IR 95-29), ineffectively
resolution of transmitter sensing line configuration problems that were
conducive to gas entrapment (Ref. IR 95-30), and lack of attention while
taking required data during PMT and performance of procedure steps out
of sequence (Ref. IR 96-04).
Although corrective actions associated with previous FME problems were
reviewed and found acceptable (Ref. IR 94-19), the licensee has
continued to have problems in this area (Ref. IR 95-19).
The licensee has exercised poor control of contractors resulting in the
polar crane hook striking S/G cubicle and a collision between polar
crane and manipulator crane which damaged manipulator crane (Ref. IR 95
14).
Additionally during a separate event the internals lifting rig
impacted the manipulator crane and wall of the refueling cavity while
the lifting rig was being returned to storage stand (Ref. IR 95-19).
Increased inspection is recommended.
5.5
Programs and Procedures
The licensee has made a significant reduction in the backlog of
maintenance procedure changes. However, inadequate procedures continue
to be identified. Additionally there are ongoing problems with several
licensee programs related to maintenance.
Examples of program inadequacies related to maintenance included
inadequacy of the licensee's surveillance program (Ref. IR 94-16),
failure to include Penetration Pressurization System Wide Range
Flowmeters in calibration program (Ref. IR 94-17), various problems with
the licensee's calorimetric program including the use of some
uncalibrated instrumentation (Ref. IR 94-27), inadequate program for
control and storage of materials which resulted in the use of lubricate
12
with an expired shelf life and improper storage level for EP-1 grease
(Ref. IR 95-06), and failure to control feeler gauges in the licensee's
M&TE program (Ref. IR 95-12).
Examples of inadequate work instructions included inadequate WR/JO where
a Control Room Differential Pressure Instrument was not adequately
returned to service (Ref. IR 94-15), failure to include valve travel
stop adjustment in WR/JO due to oversight by maintenance planner (Ref.
IR 95-03), maintenance planner failing to develop electrical breaker PMT
requirements properly (Ref. IR 95-12), and failure to provide adequate
work instructions for RCP degraded stud inspection (Ref. IR 95-13),
Examples of inadequate equipment clearances included multiple examples
of inadequate equipment clearances (Ref. IRs 95-14 & 95-19) and an
inadequate clearance, which allowed a EDG to be removed from service for
scheduled maintenance with sufficient air in air start piping to cause
inadvertent engine starting while the EDG was being removed from service
(Ref. IR 95-27).
Examples of inadequate procedures included an inadequate procedure for
transmitter isolation and restoration such that a flow transmitter would
be incorrectly isolated and restored to service and no procedure existed
for maintenance on the AFW flow control valve actuators (Ref. IR 94-27),
inadequate surveillance procedure for Battery Test (Ref. IR 95-03),
inadequate surveillance test instruction resulting in an incorrect valve
lineup (Ref. IR 95-19), inadequate instrument calibration instruction
which did not include instructions for ensuring that accumulator level
transmitters were properly calibrated (Ref. IR 95-30), and inadequate
instrument calibration instructions which did not include adequate
controls to ensure proper isolation and restoration and problems with
the licensee's freeze seal procedure (Ref. IR 96-02).
Additionally an
audit performed by an independent third party identified potential
adverse trends in the areas of procedure quality and procedure adherence
(Ref. IR 94-22).
Increased inspection is recommended.
6.0
PLANT SUPPORT - PERFORMANCE ASSESSMENT
6.1
RADIOLOGICAL CONTROLS
6.1.1 Safety Focus
The licensee's Radiological Control program was properly focused on
safety. Pre-work briefings were used effectively for interdepartmental
coordination of work activities and minimizing radiation exposure to
workers (Ref. IR 95-02).
Management was actively involved in decisions
regarding reduction of worker exposure by participation on the ALARA
committee (Ref. IR 95-15).
Communication of management expectations was
accomplished by reviewing the issues and events identified through the
Adverse Condition Report (ARC) process with affected staff members.
Good coordination and communication with other departments was also
evidenced by the support provided during maintenance work by the
radiological control group (Ref. IR 95-30).
E&RC staffing remained
stable and sufficient to perform the functions necessary for an adequate
0
13
radiation protection program (Ref. IRs 95-02, 95-02). NAD audits of the
E&RC program were consistently found to have been sufficiently
comprehensive to identify areas for improvement and problems of various
levels of significance. Audit results were reported to management for
implementation of appropriate corrective actions. The licensee's NAD
audits and self-assessments were considered a program strength (Ref. IRs
95-01, 95-02, 95-15).
6.1.2 Problem Identification/Problem Resolution
The licensee's self assessment program was designed to involve all
levels of the plant staff in achieving higher standards of performance.
The program's implementing procedure required each organizational unit
to perform at least one self-assessment per quarter (Ref. IR 95-02).
The E&RC staff used the self-assessment process much more frequently
than required to identify substantive areas for improvement. Significant
issues were documented in Adverse Condition Reports (ARCs) for tracking
corrective actions to completion. The ARCs were also used to identify
trends and common root causes for identified problems (Ref. IR 95-02).
6.1.3 Quality of Radiological Controls
Radwaste processing and radioactive effluent release control programs
were effectively used to reduce the amounts of activity released from
the plant. Consequently, the doses to the public were a small fraction
of regulatory limits. The performance of those programs was further
confirmed by the results of the environmental monitoring program (Ref.
IR 95-04).
The radiation protection program was very effective in reducing
occupational exposure. The annual collective dose during 1994 and the
collective dose during the 1995 refueling outage were the lowest ever
achieved at the site (Ref. IRs 95-02, 95-15).
RWPs, pre-job surveys for
dose rates and contamination, job planning and coordination, ALARA
planning, and pre-job briefings were all used effectively for
controlling worker exposure and work practices (Ref. IRs 95-02, 95-15).
Good work practices for minimizing internal and external exposures were
observed throughout the assessment period (Ref. IRs 95-12,95-27, 96-02,
96-04).
However, three NCVs were identified during the assessment
period. Early in the assessment period, radiological postings were
temporarily removed from the door normally used to enter the auxiliary
building. The door was being prepared for painting but the radiological
postings were removed without the knowledge or consent of radiological
control personnel (Ref. IR 94-28).
During the mid-1995 RFO, a contract
worker was observed in the containment building without the cloth head
covering specified in RWP for the work being performed (Ref. IR 95-14).
Also during the RFO, a chain used to secure a door to a LHRA was found
to be sufficiently slack to permit unauthorized access to the area (Ref.
IR 95-15).
Adequate training had been provided to contract health
physics technicians for performance of their assignments during the RFO
(Ref. IR 95-15).
However, the training provided to plant personnel for
the use of a new portal contamination monitor was ineffective.
Additional instruction on the proper use of the monitors was provided
during employee safety meetings (Ref. IR 96-01).
14
6.1.4 Programs and Procedures
Procedures for implementing the radiological control program were kept
current to ensure compliance with regulatory requirements (Ref. IR 95
01).
Reduced inspection in all elements of this area is recommended.
6.2
SECURITY
6.2.1 SAFETY FOCUS
The licensee's Security program was not properly focused. Management
oversight and involvement in the security program implementation and
operations was inadequate as evidenced by the number of violations
identified in this area. However, senior level management support for
the security program was evident by the continued upgrade of security
equipment. Adequate support was also provided for staffing, training,
and maintenance of security equipment (Ref. IR 96-03).
6.2.2 Problem Identification/Problem Resolution
NAD audits of the security program were thorough, and substantive issues
identified by those audits were reported to management for review and
corrective action. Those issues were: management had not effectively
communicated or enforced high standards and expectations within the
security organization; the security organization was not effectively
utilizing the self-assessment process; control of access to safeguards
information did not meet management expectations; security training was
not achieving desired results, and security personnel were not complying
with procedure use and adherence requirements (Ref. IR 96-03).
Management response to audit results was not addressed in the inspection
reports issued during the assessment period. Further review of this
area is necessary.
6.2.3 Quality of Security
Implementation and operation of the security program was inadequate.
During the assessment period, six violations of regulatory requirements
were identified, one of which is currently being considered for
escalated enforcement. One NCV was also identified. Those violations
occurred in the areas of access controls to the protected area (NCV) and
alarm monitoring for access controls (Ref. IR 94-18), compensatory
measures for breaches in the vital area boundary (Ref. IR 94-26),
control of safeguards information (Ref. IRs 95-12 and 96-03), and
testing of access control equipment (Ref. IR 96-03).
6.2.4 Programs and Procedures
Procedures for implementing the security program requirements were found
to be adequate to support security operations at the facility (Ref. IR
96-03).
Increased inspection in all elements of this area is recommended.
15
6.3
6.3.1 Safety Focus
The licensee's Emergency Preparedness program was properly focused on
safety. Good management support of the emergency response program was
clearly evident by the adequacy of the facilities provided for
responding to emergency conditions and by active participation in the
emergency response organization (Ref. IR 95-28 and 95-11). The
emergency response organization and facilities were adequately staffed
during exercises (Ref. IR 95-28 and 95-11).
6.3.2 Problem Identification/Problem Resolution
Independent audits of the emergency response program were performed by
the NAD, but use of the self-assessment process by the emergency
response organization was not evident (Ref. IR 94-20).
6.3.3 Quality of Emergency Preparedness
The licensee's emergency response staff performed very well during the
exercises conducted during the assessment period (Ref. IRs 94-27 and 95
28).
During those exercises, emergency response facilities were
promptly activated. Good communication between those facilities and
good command.and control within them were established. Event
classifications were correct, notifications were timely, and procedures
were followed (Ref. IR 94-27).
Emergency response facilities,
equipment, instrumentation, and supplies were maintained in a good state
of readiness (Ref. IR 94-20).
Early in the assessment period, training
for emergency response personnel was found satisfactory and improvements
were noted in administration of the training program (Ref. IR 94-20).
6.3.4 Programs and procedures
The emergency response plan did not include methodology for developing
protective action recommendations for a General Emergency. Revision of
the plan to include that methodology was scheduled for May 1996.
Inconsistencies were also noted between emergency response procedures
and lesson plans used for emergency response training. Those lesson
plans were promptly updated (Ref. IR 95-11).
Reduced inspection in all elements of this area is recommended.
7.0
SAFETY ASSESSMENT/CORRECTIVE ACTION
7.1
Problem Identification
The licensee was normally effective at identifying problems. The site
wide process for identifying problems, the ACR system was routinely
used. This process provided an effective communication mechanism for
identifying performance problems to management. Self assessments were
normally useful in identifying problems, although there was mixed
16
effectiveness is completing corrective actions for those assessments.
The licensee effectively used the NAD to identify problems in several
departments.
NAD assessments in radiological controls, emergency response program,
maintenance, and engineering identified implementations problems in each
of these areas. Examples of these issues included surveillance program
deficiencies (Ref. IR 94-16), and a lack of procedures for maintenance
on AFW flow control valve actuators (Ref. IR 94-27).
Normal inspection is recommended in this area.
7.2
Problem Analysis and Evaluation
Problem analysis and evaluation was indeterminate. NAD audits continued
to identify programmatic problems that had existed for some time. The
NAD audits and self-assessments were considered a strength (Ref. IRs 95
01, 95-15).
The on-site safety committee was effective in reviewing plant event and
conditions reports (Ref. IR 95-29).
Trending of maintenance Level III ACRs was determined to be adequate.
Trending of work control Level III ACRs was considered marginal.
Additionally, a third party audit identified adverse trends that had not
been identified by the licensee.
The problem analysis and evaluation element warrants further evaluation
during the on-site phase of the IPAP.
7.3
Problem Resolution
Problem resolution was assessed as indeterminate.
Inspection reports
contained numerous examples of configuration control issues (94-28),
communication weaknesses (Ref. IRs 94-23, 95-06), and engineering
inadequacies (Ref. IRs 96-03,95-06, 94-27, and 95-19).
Recurring clearance problems indicated a lack of questioning attitude
for operators and maintenance personnel (Ref. IRs 94-28, 95-19).
The problem resolution element warrants further evaluation during the
on-site inspection phase of the IPAP.
APPENDIX A
INITIAL ROBINSON
PERFORMANCE ASSESSMENT/INSPECTION PLANNING TREE
SAFETY
ASSESSMENT/
PLANT
CORRECTIVE
OPERATIONS
ENGINEERING
MAINTENANCE
SUPPORT
ACTION
SAFETY FOCUS
SAFETY FOCUS
-SAFEY
FOCUS
FROSLEM:
ROBLEM
PROBLEM
PROBLEM
IDENTIFICATION
IDEN TIFICATION
IDENTIFICATION
IDENTIFICATION
- PROBLEM
- PROBLEM :
PROBLEM
ESOLUTION:
RESOLUTION
RESOLUTION
.SEC
QUALITY OF
OPERATIONS :
QUALITY OF
- PROGRAMS:::
QUALIY
.F
-
ND
-mAINTE5NANCt
PH OCDUREVVOR
W
- i
REDUCEDN
INCREASED
OGRAMS
PROG & PROC
INSPECTION
IIINSPECTION
PC
- PRIOC:EDUR-E:S
SEQ
MAINTAIN
INDETERMINATE-MORE
INSPECTION
INSPECTION REQUIRED
APPENDIX B
Acronyms and Initialisms
ACR
-
Adverse Condition Report
-
ALARA -
As Low As Reasonably Achievable
-
Abnormal Operating Procedure
CIT
-
Clearance Information Tag
-
Component Cooling Water
CVCS -
Chemical and Volume Control System
E&RC -
Environmental & Radiation Control
-
-
Emergency Operating Procedure
-
LER
-
Licensee Event Report
INPO -
Institute of Nuclear Power Operations
IPAP -
Integrated Plant Assessment Program
IR
-
Inspection Report
LTOP -
Low Temperature Over Pressure
LHRA -
M&TE -
Meters & Test Equipment
MDAFW -
Motor Driven Auxiliary Feedwater
NAD
-
Nuclear Assurance Department
-
Non Cited Violation
NRC
-
Nuclear Regulatory Commission
NOUE -
Notification of Unusual Event
-
PNSC -
Plant Nuclear Safety Committee
-
Power Operated Relief Valve
-
Probabilistic Safety Assessment
-
-
RCDT -
Reactor Coolant Drain Tank
-
Reactor Coolant Pump
-
-
RPRG -
Robinson Plant Review Group
-
Radiation Work Permit
-
Refueling outage
RTGB -
Reactor Turbine Generator Gauge Board
SCO
-
Senior Control Operator
SDAFW -
Steam Driven Auxiliary Feedwater
-
Safety Injection
-
Senior Reactor Operator
TS
-
Technical Specifications
WD
-
Waste Disposal
WR/JO -
Work Request/Job Order