ML14182A264
| ML14182A264 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/08/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14182A263 | List: |
| References | |
| 50-261-93-30, NUDOCS 9402230305 | |
| Download: ML14182A264 (6) | |
See also: IR 05000261/1993030
Text
SALP REPORT -
H. B. ROBINSON UNIT 2
50-261/93-30
JUNE 28, 1992 -
DECEMBER 25, 1993
I.
BACKGROUND
The SALP Board convened on January 13, 1994, to assess the nuclear safety
performance of Robinson Unit 2 for the period of June 28, 1992, through
December 25, 1993. The Board was conducted pursuant to NRC Management
Directive 8.6, "Systematic Assessment of Licensee Performance."
Board members
were Albert F. Gibson (Chairperson), Director, Division of Reactor Safety,
Region II (RII); Jon R. Johnson, Deputy Director, Division of Reactor
Projects, RII; J. Philip Stohr, Director, Division of Radiation Safety and
Safeguards, RII; and S. Singh Bajwa, Acting Director, Project Directorate III,
Office of Nuclear Reactor Regulation.
The performance category ratings and the assessment functional areas used
below are defined and described in NRC Management Directive 8.6, "Systematic
Assessment of Licensee Performance (SALP)."
II. PERFORMANCE ANALYSIS -
PLANT OPERATIONS
Overall plant operational performance during this SALP period, up to the 1993
refueling outage, was good. During the 1992-1993 operating cycle there was
one unplanned shutdown to remove debris blocking the recirculation line of a
safety injection pump and one plant trip due to a relay failure that resulted
in loss of off-site power. The outage that followed this trip was extended to
perform additional corrective maintenance and testing to verify removal of
foreign material from the safety injection recirculation piping. Following
restart, the plant operated for about a year without a trip or forced outage
until it was shut down on September 10, 1993, for refueling.
Control room operator response to plant events was mixed. Good performance
was demonstrated early in the period during the August 1992 plant trip
following a loss of off-site electrical power. Operators successfully
controlled plant systems following the trip when both emergency diesel
generators were loaded for an extended period. This good performance was not
exhibited later in the period during a routine plant startup in November
following the 1993 refueling outage. This attempted return to power
,operations was conducted without appropriate procedures, without appropriate
reactor engineering support, and without effective plant management oversight.
The licensee senior management recognized weaknesses that occurred during the
startup and initiated steps to improve the standards of plant operations as
well as the effectiveness of self-assessments performed by the operations
staff.
Licensed operators had excellent knowledge of plant systems and administrative
requirements as evidenced by excellent performance on both initial and
requalification examinations. However, several examples of procedural
violations and lack of adherence to plant technical specifications indicated a
lack of understanding of management's expectations in this area.
940223305 9402086
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A weakness in control room performance and professionalism during routine
plant operations continued from the previous SALP period. Examples of laxness
in formality included a Shift Technical Advisor leaving the operating shift
without requesting permission or conducting watch turnover; operators not
noticing a control room alarm for an extended period (about nine hours);
operators being unaware that their keys would not provide access to certain
plant areas because the health physics staff had changed all high radiation
area locks; and operators in the control room taking direction for power
ascension via electronic mail without the approval of the operations manager.
During the last half of this assessment period the plant operations management
was in a state of transition. Several key positions in the operations
department remained vacant for significant periods of time. The Plant
Manager's position was permanently filled after a six-month vacancy, and at
the end of the SALP period two key operations department positions (Operations
Manager and Operations Shift Manager) were not permanently filled.
The deficiencies in operator performance discussed above represent a decline
from the level of performance in the previous SALP period and indicate a
weakness in management oversight.
The Plant Operations area is rated Category 2.
III.
PERFORMANCE ANALYSIS - MAINTENANCE
Performance in the area of maintenance and surveillance of plant structures,
systems and components remained good. Maintenance support contributed to
generally good plant performance as evidenced by the extended period without
an automatic reactor trip and few forced shutdowns caused by maintenance
related activities. However, weaknesses in procedural controls, oversight of
work, and corrective actions caused deficiencies in maintenance, surveillance
and refueling activities.
Weak procedural controls continued to affect the quality of maintenance and
surveillance adversely .
Previous efforts to improve the quality of
maintenance procedures were not effective as evidenced by numerous examples of
deficient maintenance and surveillance procedures identified during this SALP
period. Many examples of failure to follow procedures were also noted during
this period. These weaknesses were particularly evident in the areas of
testing and calibration of plant equipment.
Failure to take effective corrective action resulted in recurring problems.
For example, failure to remove all foreign material from inside the safety
injection system after it caused recirculation flow degradation in July 1992
resulted in recurrence of the problem in August 1992. Similarly, the cause of
an emergency diesel generator air distributor failure in October 1993 was not
fully corrected, and a similar problem occurred in November 1993.
The Nuclear
Assessment Department had identified continuing weaknesses in the corrective
action program early in the SALP period.
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Weaknesses in the oversight of certain maintenance and refueling activities
were observed late in the SALP period. For example, both emergency diesel
generators were degraded when voltage regulators were misadjusted, apparently
by painters who inadvertently turned the control knobs; the licensee was not
aware that its contractors had lost a portion of a tool inside a spent fuel
assembly until a control rod could not be inserted; and several deficiencies
in the oversight of welding activities were found by the Nuclear Assessment
Department.
The licensee developed a program to identify and eliminate equipment problems
that operators were "working around." The program was effective in reducing
the number of such problems, but equipment problems remained a challenge for
operators. This was apparent during the plant restart following refueling.in
November 1993, when several equipment failures in the balance of plant were a
distraction to operators.
Licensee management took several steps to improve the quality of maintenance
activities. Organizational changes were made, including establishment and
filling of positions for Manager-Mechanical Maintenance and Manager
Electrical/I&C Maintenance. The threshold for identifying deficiencies in
material condition was lowered, and a process was established to manage the
resulting backlog. New maintenance facilities, including shops and equipment,
were placed in service. New programs were established including a minor
maintenance program and an enhanced program for predicting piping degradation
due to erosion and corrosion. A Maintenance Procedures Group was established
to improve the quality of maintenance procedures, and a handbook clearly
defining maintenance performance expectations was distributed.
The Maintenance area is rated Category 3.
IV. PERFORMANCE ANALYSIS -
ENGINEERING
Engineering performance continued to be effective in most cases. This
performance is attributed to a well qualified, highly motivated staff.
Performance deficiencies were caused by a weak interface between design
engineering and site technical staffs and by ineffective corrective actions.
Engineering staffing levels were suffient to provide adequate support to the
plant and the engineering staff was knowledgeable, competent, and exhibited a
willingness to provide maximum effort in performing their engineering duties.
The technical support staff was actively involved in day-to-day activities at
the plant and communicated effectively with the maintenance and operations
staffs. System engineers were responsible and accountable for assuring the
readiness of their systems.
Engineering modification packages were complete and detailed. Packages
contained design and work instructions, design bases, and completed control
room drawings before turnover to operations. Replacement of the 230 KV
generator breakers demonstrated the licensee's strength in this area. This
modification was completed ahead of schedule, with the majority of the work
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completed while the plant was at full power. The actions taken to minimize
the site's vulnerability to a switchyard related event included an appropriate
level of attention to risk. In addition, the licensee had an effective
program for temporary modification control.
The licensee identified a weakness in the interface between site and corporate
engineering staffs and took steps to strengthen this interface. A
reorganization was initiated which included relocation of the design
engineering staff from the corporate office to the plant site. Interface
problems during this SALP period contributed to miscalibration of power range
nuclear instrumentation and inconsistencies between design calculations and
service water pump performance.
Engineering support provided to operations and maintenance was generally
adequate. Engineers assisted operations in system inspections. The
erosion/corrosion program, which was weak during the previous SALP period, was
significantly strengthened, and good engineering oversight was provided to
assure effective implementation. However, the program established to monitor
the performance of heat exchangers in the service water system was an
exception to this good support. The lack of performance testing and
definitive acceptance criteria for inspecting and cleaning these heat
exchangers provided poor assurance of system performance. Also, deficiencies
in engineering support for the cycle-16 refueling outage resulted in the
installation of improperly configured fuel assemblies.
Self-assessments were generally effective in identifying problems, but
corrective actions were not always effective. Assessments by the Nuclear
Assessment Department were aggressive and thorough. System engineers
identified and reported deficiencies on their assigned systems. Problems were
identified through comprehensive evaluations of the service water system and
of events associated with the cycle-16 refueling outage and startup. However,
root cause analyses and corrective actions were not always effective, and some
problems remained months after identification.
The Engineering area is rated Category 2.
V.
PERFORMANCE ANALYSIS - PLANT SUPPORT
The radiation control program was effective in controlling external and
internal exposures, with exposure totals consistent with the radiological work
that was performed during this period. Total collective dose for 1992 was 352
person-rem, and for 1993 the total was 337 person-rem. The exposure for the
refueling outage this .period was approximately 254 person-rem, which was
historically the lowest total achieved at the Robinson site for such an
outage. The ALARA program, which received good support, was effective and
contributed to controlling overall exposures close to preset goals.
Initiatives this period included early boration, use of water shields, remote
cameras, and reduction in respirator usage.
In spite of the good overall radiation control program, there were numerous
examples of performance problems this period with adherence to radiation
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control procedures. Two of the more significant of these problems involved
the failure to properly control access to a highly radioactive bolt that had
been irradiated in the reactor core and the failure to properly control keys
for access to high radiation areas.
A good contamination control program, including reclamation of the
contaminated process areas, contributed to maintaining the number of personnel
contamination events and the total contaminated area at reasonably low levels.
This was supported by a good housekeeping program at the plant.
The radiological effluent treatment and monitoring systems were effective in
maintaining effluent to low levels this period with virtually no resulting
environmental doses. Effluent monitors were well maintained. The quality of
effluent sample results was excellent, as indicated by samples split with the
NRC and other measurement cross-check programs. The environmental monitoring
program was well run and environmental sample results were consistent with
results from the State of South Carolina's sampling program.
The solid radioactive waste treatment, volume reduction, and shipment programs
were well run this period with a significant volume reduction. The program
was implemented by dedicated, competent personnel.
The training to qualify
more technicians to operate the Post Accident Sampling System (PASS) was
successful in increasing the number of qualified personnel to take liquid and
gaseous samples. The primary and secondary chemistry programs were
effectively implemented. The licensee's audit and associated corrective
action program in the radiation control area were adequate and represented
improvements over the previous SALP period.
The emergency preparedness program continued to improve this period with
enhanced staffing and good management support.
Improvements were noted in the
area of emergency facilities, equipment, and supporting computer programs.
Several actual events were properly responded to this period, with the
exception of one for which the correct classification and notifications were
not timely. Responses during drills this period and during a 1992 exercise
were adequate. The emergency preparedness training program was upgraded to
correct performance problems regarding dose assessment, protective action
recommendations and offsite notifications. Licensee audits in the emergency
preparedness area were detailed, comprehensive, and were considered a
strength. Critiques were adequate, but the corrective actions for critique
and audit findings needed improvement in timeliness.
The security program was adequately implemented during this period with
improved management support later in the period. As a result additional staff
and equipment and, most significantly, dedicated technicians for equipment
maintenance were provided. The security force effectively performed its
duties in a professional manner with good procedural adherence throughout this
period. Late in the period, problems indicated the need for additional
response training to which the licensee responded promptly. Access controls
were adequate with safety-related equipment protected as required. The
licensee's audits in the security area were thorough, complete, and effective.
Corrective actions, however, were marginal, particularly with regard to the
timeliness of technical resolution of problems.
Improvements occurred in this
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area later in the period. Shipments of spent fuel were adequately planned and
controlled.
Implementation of the fire protection program was adequate. The licensee
appropriately maintained fire protection features and support equipment, and
control of flammable materials was adequate.
Several problems were noted with
procedural adherence in this area, some of which were repetitive. For
example, multiple instances were identified in which the designated firewatch
abandoned the assigned post prior to restoration of the fire protection
system.
The Plant Support area is rated Category 2.