ML14184A423
| ML14184A423 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson, 05000000, 05000408 |
| Issue date: | 05/03/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14184A421 | List: |
| References | |
| 50-261-83-07-BA, 50-261-83-7-BA, 50-324-83-09, 50-324-83-9, 50-325-83-09, 50-325-83-9, 50-400-83-10, 50-401-83-10, NUDOCS 8306290537 | |
| Download: ML14184A423 (65) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION II SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE BOARD ASSESSMENT CAROLINA POWER AND LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 and 2 DOCKET NUMBERS 50-325 AND 50-324 H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2 DOCKET NUMBER 50-261 SHEARON HARRIS NUCLEAR POWER PLANT UNITS 1 and 2 DOCKET NUMBERS 50-400 and 50-401 JANUARY 1, 1982 THROUGH JANUARY 31, 1983 8306290537 830614 PDR ADOCK 05000261D INSPECTION REPORT NUMBERS 50-325/83-09. 50-324/83-09 50-261/83-07 50-400/83-10, 50-401/83-10
CONTENTS PAGE I. INTRODUCTION....................................................
1 II. CRIT ERIA........................................................
1 III.
SUMMARY
OF RESULTS..............................................
2 A.
Overall Utility Evaluation...............
2 B. Overall Facility Evaluation -
Brunswick Units 1 and 2.......
3 C.
Facility Performance - Brunswick Units 1 and 2..............
3 D. Overall Facility Evaluation - H. B. Robinson Unit 2.........
3 E.
Facility Performance - H. B. Robinson Unit 2................
4 F. Overall Facility Evaluation -
Shearon Harris Units 1 and 2..
4 G.
Facility Performance - Shearon Harris Units 1 and 2.........
4 H.
SALP Board Members.........................................
5 I.
SALP Board Attendees.......................................
5 IV. PERFORMANCE ANALYSIS FOR BRUNSWICK UNITS 1 AND 2................
6 A.
Functional Area Evaluation - Operations....................
7 (Units 1 and 2)
B.
Supporting Data............................................ 25 V. PERFORMANCE ANALYSIS FOR H. B. ROBINSON UNIT 2....................29 A.
Functional Area Evaluations - Operations...................
30 B.
Supporting Data............................................
46 VI. PERFORMANCE ANALYSIS FOR SHEARON HARRIS UNITS 1 AND 2...........
48 A.
Functional Area Evaluation - Construction (Units 1 and 2)...
49 B.
Supporting Data............................................
60
I. INTRODUCTION A formal licensee performance assessment program has been implemented in accordance with the procedures discussed in the Federal Register Notice of March 22, 1982. This program, the Systematic Assessment of Licensee Performance (SALP) is applicable to all power reactors with operating licenses or construction permits (hereinafter referred to as licensees).
The SALP program is an integrated NRC staff effort to collect available observations of licensee performance on an annual basis and evaluate performance based on these observations. Positive and negative attributes of licensee performance are considered. Emphasis is placed on understanding the reasons for a licensee's performance in important functional areas, and sharing this understanding with the licensee. The SALP process is oriented toward furthering NRC's understanding of the manner in which:
(1) the licensee directs, guides, and provides resources for assuring plant safety; and (2) such resources are used and applied. The integrated SALP assessment is intended to be sufficiently diagnostic to provide meaningful guidance to the licensee. The SALP program supplements the normal regulatory processes used to ensure compliance with NRC rules and regulations.
II. CRITERIA Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review period. Functional areas encompass the spectrum of regulatory programs and represent significant nuclear safety and environmental activities. Certain functional areas may not be assessed because of little or no licensee activities in these areas, or lack of meaningful NRC observations.
One or more of the following evaluation criteria were used to assess each functional area:
Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Reporting and analysis of reportable events Staffing (including management)
Training effectiveness and qualification The SALP Board has categorized functional area performance at one of three performance levels. These levels are defined as follows:
Category 1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
2 Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and con siders nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or con struction is being achieved.
The functional area being evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or 3. The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of individual items.
III.
SUMMARY
OF RESULTS A.
Overall Utility Evaluation The licensee has three units in operation at two sites and two units in construction at another site that were included in this evaluation of management control effectiveness.
During this appraisal period, the licensee has shown significant improvement in some areas; but several areas, identified during the previous review period as requiring increased management attention, have not shown improvement. The licensee has identified those areas and has initiated extensive long-range improvement programs.
The licensee has exhibited a positive attitude to NRC initiatives; but, in general, licensee responses have demonstrated inadequate management involvement in licensing activities, particularly in the interface with NRR.
Levels of performance were consistent with that noted in the previous review period.
Corporate management's involvement in site activities to assure quality performance, exemplified by the implementation and functioning of the corporate quality assurance (QA) program, has been generally adequate except for a continuing weakness in the functioning of the Performance Evaluation Unit (PEU).
This has seriously hampered the PEU's ability to obtain prompt corrective action to audit findings.
Increased corporate level management's attention is needed to improve the effectiveness of the PEU.
3 Improvements in the area of Radiation Protection were noted at both operating sites during this review period. Increased attention to planning and coordinating functions of the current ALARA program were instrumental in reducing exposures at both sites during the 1982 outages. A significant weakness noted at both operating sites was identified in the area of maintenance. Additional corporate involve ment is needed to correct these weaknesses.
B. Overall Facility Evaluation - Brunswick Units 1 and 2 The performance of the licensee at the plant level is acceptable.
Major strengths were identified in the areas of emergency preparedness and security and safeguards. Positive actions taken during the period were the assignment of a senior manager to the site and development of a long range improvement plan.
Improvements were evident over the previous SALP period in the area of radiological controls.
Major weaknesses were identified in the areas of plant operations, maintenance, surveillance, fire protection, refueling, licensing activities, and quality assurance. Improvements from the previous SALP were not apparent in the areas of plant operations, maintenance, and fire protection.
The long range improvement initiative, which is currently being implemented, is expected to result in improved licensee performance in the weak areas.
The licensee has committed a substantial amount of facility and corporate resources to this improvement program.
C.
Facility Performance - Brunswick Units 1 and 2 Ratings for each functional area are listed below:
Operations (Units 1 and 2)
- 1.
Plant Operations -
Category 3
- 2.
Radiological Controls -
Category 2
- 3.
Maintenance Category 3
- 4.
Surveillance Category 3
- 5.
Fire Protection -
Category 3
- 6.
Emergency Preparedness Category 1
- 7.
Security and Safeguards Category 1
- 8.
Refueling -
Category 3
- 9.
Licensing Activities -
Category 3
- 10.
Quality Assurance Program - Category 3
- 0. Overall Facility Evaluation - H. B. Robinson Unit 2 The performance of the licensee at the plant level was satisfactory.
Major strengths have been identified in the areas of surveillance and refueling. Improvement has been noted in the areas of radiological.
controls and surveillance testing. Major weaknesses were identified in the areas of maintenance, licensing activities, and quality assurance.
4 The weakness i-n the quality assurance area is attributed to the corporate audit function. Licensee performance declined in the areas of maintenance and quality assurance from the previous SALP evaluation.
E.
Facility Performance - H. B. Robinson Unit 2 Tabulation of ratings for each functional area:
Operations Unit 2
- 1.
Plant Operations -
Category 2
- 2.
Radiological Controls - Category 2
- 3.
Maintenance -
Category 3
- 4.
Surveillance -
Category 1
- 5.
Fire Protection -
Not Rated
- 6.
Category 2
- 7.
Security and Safeguards -
Category 2
- 8.
Refueling - Category 1
- 9.
Licensing Activities - Category 3
- 10.
Quality Assurance Program -
Category 3 F. Overall Facility Evaluation - Shearon Harris Units 1 and 2 The licensee performance with respect to construction is satisfactory.
Licensee management involvement and support for quality construction in the various functional areas is evident. Trained and qualified staff were deemed to be adequate for the level of activities involved. In each of the areas evaluated, no programmatic breakdowns were identi fied.
Major strengths were identified in the areas of containment and other safety-related structures and construction fire protection. A major weakness was identified in the area of licensing activities which warrants additional licensee management attention. Improvement is needed to upgrade the timeliness, thoroughness, and technical soundness of information submitted to the NRC.
G.
Facility Performance - Shearon Harris Units 1 and 2 Tabulation of the ratings for each functional area are as follows:
Construction (Units 1 and 2)
- 1.
Soils and Foundation -
Not Rated
- 2.
Containment and Other Safety-Related Structures -
Category 1
- 3.
Piping Systems and Supports - Category 2
- 4.
Safety-Related Components - Category 2
- 5.
Support Systems -
Category 1
- 6.
Electrical Power Supply and Distribution - Category 2
- 7.
Instrumentation and Control Systems - Not Rated
- 8.
Licensing Activities - Category 3
- 9. Quality Assurance Program - Category 2
0 0
5 H.
SALP Board Members R. C. Lewis, Director, Division of Project and Resident Programs (DPRP), Region II (RH), Chairman J. A. Olshinski, Director, Division of Engineering and Operational Programs, RII J. P. Stohr, Director, Division of Emergency Preparedness and Materials Safety Programs, RII D. M. Verrelli, Chief, Project Branch 1, DPRP, RH D. Vassallo, Chief, Operating Reactors Branch 2, Division of Licensing (DL), Office of Nuclear Reactor Regulation (NRR)
I.
SALP Board Attendees P. R. Bemis, Chief, Project Section 1C, Projects Branch 1, DPRP, RII M. V. Sinkule, Chief, Operational Support Section (OSS),
Program Support Staff (PSS), RH D. 0. Myers, Senior Resident Inspector, DPRP, RH S. Weise, Senior Resident Inspector, DPRP, RII G. F. Maxwell, Senior Resident Inspector, DPRP, RII R. Prevatte, Senior Resident Inspector, DPRP, RII A. K. Hardin, Project Engineer, Project Section 1C, Projects Branch 1, DPRP, RII C. W. Hehl, Reactor Engineer, Project Section 1C, Projects Branch 1, DPRP, RII G. Requa, Project Manager, Operating Reactors Branch 1, DL, NRR S. MacKay, Project Manager, Operating Reactors Branch 2, DL, NRR P. Kadambi, Project Manager, Licensing Branch 3, DL, NRR T. MacArthur, Radiation Specialist, OSS, PSS, RTI
IV. PERFORMANCE ANALYSIS FOR BRUNSWICK UNITS 1 AND 2
7 A.
Functional Area Evaluations - Operations (Units 1 and 2)
Licensee Activities Unit 1 began the evaluation period in routine power operation. On February 5, 1982, the unit was brought to cold shutdown for a planned maintenance outage. A snubber inspection and the replacement of leaking reactor recirculation pump seals were among the activities accomplished during this outage. The unit was returned to power on February 14 and remained in routine power operation, with the exception of brief shutdowns, until July 1982.
On July 16, 1982, Unit 1 was shut down to conduct missed surveillance tests, and accomplish action items contained in NRC Confirmation of Action letters issued on July 2 and July 20. Restart attempts on October 10 and 14 were unsuccessful due to safety relief valve mal functions.
Unit 1 was returned to routine power operations on October 17, 1982.
The unit remained at power, except for a shutdown on October 22, until brought to cold shutdown on December 11, 1982, for refueling. Unit 1 remained shut down for refueling for the remainder of this evaluation period.
Unit 2 began the evaluation period in routine power operations and, except for an occasional brief outage, remained at power until the unit was shut down for refueling on April 24, 1982.
The Unit 2 refueling and integrated leak rate testing outage lasted from April 24, 1982, through October 2, 1982. Restart was delayed due to unanticipated snubber support modifications and the completion of action items contained in the NRC Confirmation of Action letters of July 2 and July 20, 1982. The unit was returned to routine power operation on October 3, 1982.
On October 10, 1982, the unit was shut down to repair a crack in the heater drain piping.
Repairs were completed and the unit returned to power on October 18, 1982.
On October 29, 1982, the unit was again shut down to repair a trav ersing incore probe tube.
During this maintenance outage, a crack in a section of shutdown cooling pipe necessitated extension of the main tenance outage.
Unit 2 was successfully returned to routine power operation on December 5, 1982, and continued in this mode, except for an occasional brief shutdown, for the remainder of the evaluation period.
Inspection Activities The routine inspection program was performed during the review period.
8 The following special inspections were performed during the period:
January 6-7, 1982 in response to the reported failure of the Unit 1 plant staff to recognize the failure of a safety-related water level instrument.
January 19-21, 1982 to review the scram event of January 16, 1982 in which Unit 2 RHR service water pumps failed to start.
July 12-14 and 20-22, 1982 in response to reported failures to conduct required surveillance testing.
June 2-4 and July 20-21, 1982 in response to reports of damaged under-vessel instrumentation at Unit 2.
September 28, 1982 to January 17, 1983 in response to allegations that contractor personnel tampered with dosimetry.
October 27-29, 1982 to determine the facts relating to a shipment of radioactive material, reported by the State of South Carolina to have been in violation of regulatory requirements.
Special prestartup team inspections were conducted on August 24-27 and September 7-10, 1982 to determine the status of action items contained in the July 2 and July 20, 1982, NRC Confirmation of Action letters.
A special team training assessment was conducted on January 10-14, 1983 to evaluate CP&L licensed and non-licensed operator training programs.
A special inspection was conducted on January 10-13 and 17-21, 1983 to follow work activities required by IE Bulletin 82-03.
- 1.
Plant Operations
- a.
Analysis During the evaluation period, the resident inspectors regularly performed inspections of operations activities.
Additionally, routine and special inspections by regionally based inspectors were performed.
Poorly stated or ill understood procedures, identified during the previous review period, continued to degrade the effec tiveness of the operating staff and contributed to the substantial numbers of reported personnel errors. Inadequate management involvement, indicated by a demonstrated laxness in discipline of operations and adherence to procedures, also had an adverse affect on operation's performance. These weaknesses were key elements in each of the violations
9 identified below, in the civil penalties issued in June 1982 and February 1983, and in the 65 Licensee Event Reports (LER) attributable to personnel error that were i-ssued during this review period. NRC concerns in the area of management and supervisory controls were discussed at each of five enforce ment conferences held during this review period. A procedure upgrade program, renewed emphasis on discipline of operations and adherence to procedures are commitments contained in the licensee's long-range improvement program, confirmed by NRC Order on December 22, 1982.
Weakness in the operating staff's approach to resolution of technical issues, also identified in the previous review period, were again noted. Resolutions often provided viable approaches but were lacking thoroughness or depth. An apparent reluctance on the part of the operating staff to adequately involve available technical and engineering expertise contributed to this weakness. This weakness was exemplified by two recent events: (1) a failure to promptly identify and correct degraded isolation circuitry in the reactor water cleanup (RWCU) system, identified as violation (8) below; and (2) the hasty isolation of high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems reported in LER 324/82-140.
Ineffective communications combined with poorly defined lines of authority and responsibility also contributed to degraded operational performance during the review period. This weakness was exemplified in violations (7) and (11), below.
Other events involved the inadvertent resetting of a Group 1 trip system isolation, reported in LER 1-82-149; and the inadvertent scramming of three control rods and the insertion of fuel assemblies in rodless reactor vessel locations, discussed in RH Report 83-03*.
Weaknesses in the licensee's training and qualification programs were determined to be a contributing factor to several reportable events and the rather marginal performance observed on recent operator licensing examinations. The following instances were partially attributable to poor understanding of technical specifications and job functions:
- NRC RII Report 83-03 issuance is pending evaluation of enforcement items by the NRC.
0l 10 LER 324/82-140, discussed above; the exceeding of emergency diesel generator limiting conditions for operation, reported in LER's 324/82-124 and 325/82-127; and the failure to satisfy technical specification prerequisites prior to moving the reactor mode switch to the Refuel position, identified as violation (9) below. The results of operator licensing examinations, conducted during this and the previous review period, further exemplified this weakness. During the previous review period, a passing grade was recorded for 18 of the 27 reactor operator candidates. The examinations conducted during this evaluation period resulted in only three of nine senior reactor operator and 11 of 25 reactor operator candidates receiving passing grades. This record is not indicative of an effective training program. Upgrades in the area of training and qualification programs are underway at Brunswick, both as a licensee initiated training improve
- ment program and as part of the long-range operational improvement program. The supplementary training in technical specifications, that was recently conducted, was a positive step toward improvement in this area.
Sixteen violations were identified during the evaluation period in the area of plant operations. These violations are indicative of a programmatic breakdown in the operations area. The program lacked effective supervision and engi neering overview, and failed to address root causes and to affect more than temporary solutions to problems. Staff vacancies and management changes contributed to this break down.
Further examples of these inadequate management controls were also demonstrated by the tardy development and implementation of a procedure rewrite program and the resolu tion of the independent verification issue.
Violations and deviations identified during the review period are identified below:
(1) Three Severity Level III violations for events sur rounding a reactor vessel water level instrument mal function, identified during the previous review period, which resulted in a civil penalty issued in June 1982.
(2) Severity Level IV violation for failure to implement corrective action in two independent lineup verifica tions prior to radwaste effluent discharges, as commit ted to in response to a previous violation.
(3) Severity Level IV violation for failure to implement double verification as required by NUREG 0737 Item I.C.6.
11 (4)
Severity Level IV violation for failure to implement procedure OP-43 which resulted in one subsystem of the residual heat removal service water system being inoper able.
(5) Severity Level IV violation for failure to provide procedure content in accordance with ANSI 18.7.
(6) Severity Level IV violation for failure to evaluate and document the inoperability of the standby liquid control system heat tracing circuit as required by procedure 01-4.
- (7)
Violation for failure of the Plant Nuclear Safety Committee to adequately review a procedure; this resulted in the inadvertent scramming of three control rods.
- (8)
Violation for failure to isolate the reactor water cleanup system within the required time interval of an identified instrument malfunction.
(9) Severity Level V violation for not locking the reactor mode switch in the shutdown position as required by the technical specifications.
(10)
Severity Level V violation for not including in proce dures the proper alignment of valves necessary for operability of a containment isolation instrument.
(11)
Severity Level V violation for operating above the technical specification value with the condensor vacuum-low isolation switches bypassed.
(12)
Severity Level V violation for failure to implement clearance procedure 1-459, which resulted in a scram; and for failure to implement operating procedure OP-43, in that service water valve V118 was not positioned properly.
(13)
Severity Level V violation for failure to adequately establish an annunciator procedure, and several normal operation and expected transient procedures.
(14)
Deviation from a commitment to the NRC, as stated in a response to NUREG 0737 Item I.A.1.3, to modify procedures to specifically require a senior reactor operator in the control room.
- These violations will be discussed in NRC RII Report 83-03.
12
- b.
Conclusion Category 3
- c.
Board Comments Licensee performance in this area conti.nues to be Category 3 as rated during the previous SALP review period. It is recognized that certain improvements have been made; however, significant overall improvement is not evident. The licensee has recognized the weaknesses in this area and an aggressive long-range improvement program has been initiated. The licensee should continue increased management attention and the NRC inspection effort should be increased by assignment of an additional resident inspector.
- 2.
Radiation Protection, Radioactive Waste Management and Transporta tion
- a. Analysis During this period, eight inspections were performed by regional based inspectors. Additionally, routine inspections in this area were performed by the resident inspectors.
It was noted that the Radiation Protection Program showed some improvement when compared to the findings of the previous evaluation period. The Radiation Protection area accounted for one Severity Level V violation and one devia tion from licensee commitments which are described in items (4) and (5) below. It was also found that the plant ALARA program was successful.
The current ALARA program, which is supported by management, was established early in 1982.
The planning and coordination that the ALARA group did for the 1982 Unit 2 outage was instrumental in reducing outage exposures.
The radwaste program consisting of liquid, gaseous and solid radwaste, accounted for one Severity Level V violation described in item (3) below. This violation was due to a poor chemical separation procedure in the analysis for Sr-89 and Sr-90. The root cause of the violation was inadequate quality assurance interface between the plant and the General Office laboratory that made the analysis. The licensee responded by developing a better chemical separation tech nique as well as increasing attention to comparisons between General Office laboratory results and technical specification requirements. This violation, and the findings of a QC and Confirmatory Measurements inspection discussed later, indi cate a need for additional licensee effort in the radwaste chemistry area.
13 During 1982, the generated volume of solid radwaste decreased as compared to previous years. However, the volume generated was still significantly higher than that generated by other similar facilities in this region. The facility did not have an effective program for reducing the quantity of waste gen erated in the radiologically controlled area nor for reducing the volume of waste so generated. Additional management attention is needed in this area'to minimize solid radwaste volume.
The radioactive waste transportation program received one Severity Level IV violation described in item (1) below.
This violation resulted from performing a shipping activity without an adequate activity review. The licensee was responsive in investigating and correcting the radwaste shipping program in order to preclude a similar occurrence in the future. The overall radwaste transportation program was found to be generally well managed.
One radiological environmental protection inspection was conducted during the appraisal period. No violations or deviations were disclosed. In general, the environmental surveillance program appeared to be adequately managed and directed toward development of effective off-site environ mental protection. The management and staff responsibility for implementation of off-site monitoring showed significant improvement regarding adherence to environmental sampling and radioanalytical procedures, and procedures defining required maintenance of monitoring equipment and surveillance systems.
The radiological environmental protection program was con sistent with technical specification requirements.
One QC and Confirmatory Measurements inspection was performed during the evaluation period using the RII Mobile Laboratory.
One Severity Level V violation, item (4) below, was identi fied for failure to collect stack gas samples in accordance with the approved procedure. The inspection revealed the need for upgrading quality control activities associated with the collection of stack gas and charcoal samples.
This continuing weakness in the radiological measurements area resulted from the lack of adequate management review at the plant level.
The results of effluent samples collected and analyzed by both the NRC and licensee during the inspection showed agreement.
Four violations and one deviation were identified during the evaluation period. The violations do not indicate major weaknesses in the radiation protection, radioactive waste management or transportation programs; however, additional attention is needed in quality control for the radwaste management program. The violations abd deviation identified were:
14 (1) Severity Level IV violation for failure to control a radwaste shipment.
(2)
Severity Level IV violation for failure to collect stack gas samples as required by chemistry procedures.
(3) Severity Level V violation for failure to meet minimum detectable concentrations in a sample of liquid efflu ents as required by the Technical Specifications.
(4) Severity Level V violation for failure to implement radiation control procedures.
(5) Deviation from a commitment to the NRC, as stated in response to TMI Item II.B.3, for failing to calibrate three gas radiation monitors.
b. Conclusion
Category 2
- c. Board Comments Licensee performance has improved from a Category 3 during the previous SALP review period to a Category 2 during this period. The improvements implemented at the end of the previous SALP review period to upgrade management controls appear to have been effective. Significant improvement is apparent in decontamination control programs due to the effort being expended by the licensee's staff. No decrease in licensee or NRC attention in this area is recommended.
- 3. Maintenance
- a. Analysis During the evaluation period, maintenance activities were routinely reviewed by the resident inspectors. Additionally, supplemental inspections were performed by regional based inspectors.
Weaknesses in management controls and involvement in assuring quality maintenance activities, identified as areas of concern during the previous review period, continued to forestall needed program improvements.
Poorly stated and ill understood procedures often frustrated attempts to implement required programs as identified in violations (5) and (6) below.
Required programs, for assuring maintenance activi ties have not degraded system capabilities, and for providing necessary data for decisions regarding adequacy of equipment
15 applications, had either not been established or implemented.
Examples of these program deficiencies are found in viola tions (2), (3), and (4).
Weakness in the amount of super vision applied to maintenance activities was again evident during this review period. An example of this occurred during the diesel generator flexible drive coupling repairs discussed in RII Report 82-30.
The licensee's approach to resolution of technical issues often provided viable approaches but implementation generally lacked thoroughness or depth. An example of this weakness was the resolution of the issues associated with the residual heat removal (RHR) service water pump low suction pressure switche's.
As illustrated by violation (1) below, corrective action was not always effective in preventing recurrence.
This issue was discussed during an enforcement conference held on July 14, 1982.
Improvements in this area have occurred over the review period.
The licensee was re'ceptive to NRC initiatives. Problems of regulatory concern were identified and reported, but responses often lacked thoroughness or depth. This can be attributed, to some extent, to inadequate engineering over view of the maintenance program. Inadequate training of the maintenance staff on new procedures, procedure changes and modifications appears to have contributed to some of the violations identified below. Maintenance staffing and training appeared generally adequate except as noted.
The violations identified below are indicative of a program matic breakdown:
(1) Severity Level IV -violationfor failure to take adequate corrective action on pressure switch repairs.
(2) Severity Level IV violation for failure to have a maintenance trending and review program.
(3) Severity Level IV violation for failure to provide a calibration program for instruments used to verify technical specification parameters.
(4) Severity Level IV violation for failure to establish an adequate post maintenance testing program.
(5) Severity Level V violation for failure to implement a calibration procedure.
(6) Severity Level V violation for failure to implement an approved maintenance procedure.
16 (7) Severity Level VI violation for failure to maintain surveillance activity records.
- b.
Conclusion Category 3
- c.
Board Comments Licensee performance, which was evaluated as a Category 3 during the previous SALP period, has not improved during this period. Weaknesses in this area are attributable to inadequate management controls, inadequate procedures, and inadequate implementation of existing procedures. Additional licensee management attention is needed and the present level of NRC inspection effort should be continued.
- 4.
Surveillance and Inservice Testing
- a. Analysis Resident and regional based inspectors routinely observed surveillance and inservice testing activities as part of their inspection program. The surveillance and inservice testing program was also the subject of special inspections by regional based inspectors.
During this review period, major programmatic breakdowns were identified in the area of surveillance and inservice testing.
Thirty-eight separate instances of reportable technical specification non-compliances were identified in this area.
A key factor which precipitated these program breakdowns was a lack of management involvement and control.
Little evidence of adequate program planning and assignment of priorities existed; poorly stated, ill understood and tech nically inadequate procedures for control of these activities contributed significantly to program deficiencies.
Prior program reviews and audits of these areas by the licensee's quality assurance organization were not timely, thorough or technically sound. These weaknesses were the subject of two NRC confirmatory action letters issued in July 1982. A Commission order, requiring implementation of the licensee's improvement program to achieve basic improvements in manage ment, operations and quality assurance performance, was issued in December 1982.
NRC enforcement action, prompted by this breakdown in management controls, resulted in the issuance of a civil penalty in February 1983.
17 The licensee's-approach to the resolution of technical issues often provided viable approaches, but lacked thoroughness or depth.
Understanding of the issues was frequently lacking in scope, resulting in resolutions being applied to a single unit or system without consideration of similar deficiencies elsewhere. This "tunnel vision" approach to the resolution of technical issues, as discussed in RII Report 82-28, preci pitated the failure to conduct the primary containment leak rate tests as identified in violation (1) below.
The licenseee was receptive to NRC initiatives, but consid erable NRC effort or repeated submittals, were sometimes required to obtain acceptable resolutions.
Problems of regulatory concern were identified and promptly reported.
Since July 1982, significant licensee resources have been applied to strengthen management controls in this area and resolve identified discrepancies. A long-range improvement program has been developed by the licensee and is being implemented. Lasting improvements in this area are expected.
The following violations were indicative of programmatic breakdowns:
(1) Severity Level III violation for failure to establish and maintain procedures for each surveillance test, inspection and calibration listed in technical specifi cations.
(2) Severity Level IV violation for failure to establish reference data for a pump after modification.
(3) Severity Level IV violation for failure to establish a calibration surveillance procedure for the fuel oil tank level instruments for the diesel driven fire pump.
(4) Severity Level V violations for failure to include main steam piping between the containment isolation valves and the turbine stop valves in the Inservice Inspection (ISI) program.
(5) Severity Level V violation for failure to retain ISI calibration block for recirculation system safe-end inspection.
- b.
Conclusion Category 3
- c.
Board.Comments None
18
- 5.
Fire Protection
- a. Analysis During this assessment period, one inspection was conducted in the fire protection area by a regional based inspector.
Additional inspections were also performed by the resident inspectors.
Management involvement and control in the plant fire protec tion program has not been effective. A program review, prompted by the NRC's Confirmation of Action letters of July 2 and 20, 1982, identified significant program break downs precipitated by inadequate management controls. These breakdowns included failures to perform required fire protection surveillances and tests, and inadequacy of most of the fire protection annunciator procedures.
Ineffectiveness in initating corrective actions for regulatory non-compliances, as evidenced by repeat violations (2) and (3) below, is also indicative of inadequate management control in this area.
Poorly stated and ill understood procedures continued to hinder effective implementation of this program. Inadequate fire proection procedures contributed to the violations which resulted in a February 1983 civil penalty, violation (1),
listed in the surveillance and inservice testing area.
Procedural deficiencies are discussed further in RH Report 82-25.
It is noted that additional personnel have been assigned to the fire protection group and routine fire inspection functions have been transferred to the operations division.
Improvement in this area is expected.
(1) Severity Level V violation for failure to implement the station fire prevention procedures, in that an accumula tion of combustible material soaked with leaking oil from the diesel generators was permitted to exist in the diesel generator rooms for an excessive period of time, and was not identified and reported as required.
(2) Severity Level V violation for failure to provide the required number of serviceable spare self contained breathing apparatuses for the fire brigade.
(3) Severity Level V violation for failure to provide all fire brigade members with the required respirator protection training.
19 (4)
Severity Level V violation for failure to replace three electrical penetration seals in the cable spreading rooms fire barriers following their removal during plant modification work.
b. Conclusion
Category 3
- c. Board Comments Licensee performance, which was evaluated as Category 3 during the previous SALP period, has not improved during this review period. In addition to procedure implementation problems which were identified during the previous SALP, the quality of procedures and the corrective action program needs improvement. The increased level of licensee and NRC attention in this area should continue.
- 6.
- a. Analysis During the evaluation period, one small scale exercise was observed and two routine inspections were conducted by the regional staff.
No enforcement items were identified as a result of the exercise or inspections.
The licensee appeared to be responsive to concerns identified by NRC and was willing to take corrective action in a timely manner.
No major problems, which could be considered indi cative of programmatic weaknesses, were identified during the period.
Key positions in the emergency preparedness staff were filled at corporate and plant levels.
Responsibilities and authori ties were established. Staffing levels in the emergency preparedness staff appeared adequate.
A training program was established and implemented for the emergency preparedness organization; this contributed to an adequate understanding of the individual roles and purposes of the emergency organization.
Corporate management appeared to be supportive of emergency preparedness programs and issues and was directly involved in site activities. There was evidence that priorities were correctly assigned in the area of emergency preparedness.
Procedures were developed, and a mechanism for revision was established. Program records were well maintained and were generally complete.
020 20
b. Conclusion
Category 1 C.
Board Comments Licensee performance has improved from a rating of Category 2 during the previous SALP period to a Category 1 rating during this period. The licensee has applied the proper amount of management attention and resources in this area.
No decrease in the level of NRC inspection effort is recommended.
- 7. Security and Safeguards
- a. Analysis Three unannounced routine inspections and one special unannounced inspection were performed by the regional staff.
Additional routine inspections by the resident inspectors were performed throughout the evaluation period. No viola tions were identified.
A special inspection was conducted after the licensee identified potential willful damage to several incore instru ments located under the Unit 2 reactor vessel.
A Confirmation of Action letter, dated June 4, 1982, detailed special security and operational interim measures which the licensee took during fuel loading and in preparation of startup for Unit 2. This damage was subsequently determined to have resulted from poor maintenance practices and was not considered willful.
Throughout this evaluation period, the licensee continued an aggressive program to repair and maintain security equipment and hardware. As a result of this effort numerous long term compensatory measures were alleviated and members of the security organization were more advantageously utilized.
Corporate and site management supported the security program and security awareness was positive, as indicated by their professional approach to provide a safe and secure environ ment onsite. This was demonstrated by their responsiveness to NRC comments and discussions; and the non-adversary relationship that existed with onsite personnel.
The con tract security guard force was adequately staffed to meet all commitments of the security and contingency plans. Review of the training and qualification plan, observations of on-the job training and structured training classes, and interviews with security force personnel indicated that the security training was being efficiently and effectively implemented.
This was also demonstrated by the positive morale of the security force.
21
- b.
Conclusion Category 1
- c.
Board Comments Licensee performance has improved from a rating of Category 2 during the previous SALP period to a rating of Category 1 during this period. The licensee has applied the proper amount of management attention in this area. No decrease in the level of NRC inspection effort is recommended.
- 8.
Refueling
- a. Analysis During this review period, Unit 2 underwent a refueling outage from April to October 1982, and Unit 1 initiated its refueling outage on December 11, 1982.
The resident inspectors reviewed selected evolutions during these refuel ing outages.
Management involvement and control in assuring quality showed little evidence of prior planning and assignment of priori ties; poorly stated and ill understood procedures led to several refueling operation problems as discussed in RH Report 83-03,* and resulted in violation (1) below. This weakness in the area of management controls was most apparent during the performance of non-routine refueling operations.
Staffing weaknesses were apparent during the outages with key positions being poorly identified and authority and responsi bilities being ill defined. These weaknesses contributed significantly to the recent fuel movement event resulting in violation (2), below.
- NRC RH Report 83-03 issuance is pending evaluation of enforcement items by NRC.
22 The following violations were identified during this review period.
(1) Violation for failure to implement fuel handling procedures; this resulted in entering the refueling mode prior to establishing prerequisite plant conditions.
(2) Violation for failing to maintain refueling procedures; this resulted in the mispositioning of fuel assemblies into rodless core locations.
- b.
Conclusion Category 3
- c.
Board comments Licensee performance in this area was not evaluated during the previous SALP period. During this period routine refueling operations were found to be satisfactory, however late in the period problems were identified involving non-routine evolutions. Additional licensee management attention is needed to correct this problem. The level of NRC inspection effort in this area should be continued.
- 9.
Licensing Activities
- a.
Analysis The assessment of licensee performance was based on an evaluation of the following licensing activities:
Project management administration Response to NUREG 0737 items 10 CFR 50, Appendix R Environmental qualification RPS power supplies Operator licensing Spent fuel storage increase Radiological effluent TS
- These violations will be discussed in RH Report 83-03.
23 In general, management involvement was inconsistent, resulting in varying levels of licensee performance.
Evidence of quality management capability was apparent in selected areas, but consistent management attention over the full range of licensing activities was not evident. No improvement was noted in this area since the last SALP evaluation.
Technical understanding of the issues was generally demon strated, but a lack of thoroughness or depth in the approach to resolution was noted in several instances. This level of performance was consistent with that noted in the last SALP evaluation.
Initial licensee responses were generally timely but often required extensions of time to complete (e.g., Appendix R, fuel storage increase).
The licensee had recognized this deficiency and had been attempted to improve responsiveness by establishing integrated scheduling of licensing actions.
The licensee previously identified a lack of adequate licensing staff as a significant factor in their failure to provide timely responses and took actions to augment the licensing staff. This factor was considered in the evalua tion of responsiveness, discussed above.
In summary, inconsistent quality in the management of licensing activities and a general lack of timeliness in responding to staff requests were identified as significant negative factors.
- b.
Conclusion Category 3
- c.
Board Comments Licensee management attention should be increased in this area.
- 10.
Quality Assurance Program
- a. Analysis During this evaluation period five inspections were performed by regional based inspectors. Two of these inspections were special inspections related to licensee actions resulting from Region II Confirmation of Action letters dated July 2 and July 20, 1982.
24 Audits were generally complete and thorough; however, the licensee's corrective action system for timely resolution of problems identified by the audit staff was ineffective. This was a key contributory element to the programmatic breakdowns in the plant operations and surveillance sections of this report and resulted in violation (1) below.
In general, the licensee's QA policies were adequately stated and understood as revealed by the NRC's reviews of QA procedures and discussions with licensee personnel.
One weakness in this area involved poorly defined corrective action procedures which failed to promptly obtain QA manage ment assistance in seeking resolution to problems identified by the QA staff. The licensee's Performance Evaluation Unit (PEU) was seriously hampered in obtaining prompt corrective action to audit findings due to this procedural inadequacy. This weakness directly resulted in violation (2) below. The licensee was requested to submit a supplemental response to this violation; this resulted from QA manage ment's apparent reluctance to provide definitive guidance for operation of the PEU.
Certain levels of corporate management were involved in site activities as evidenced by frequent visits and communications between the Manager, Operations QA/QC, and site QA personnel.
However, there appeared to be very little direct involvement in site activities by PEU management.
The onsite review committee appeared to be staffed to meet technical specification requirements.
Licensee records were generally complete, well maintained, and available as evidenced by the NRC's ability to retrieve the information needed to complete the inspection program. The licensee was generally responsive to NRC identified items relating to QA activities as evidenced by closure of 21 items during one inspection.
The licensee's training program appeared to need more involvement by management to achieve the desired level of adequacy. A surveillance of training activities conducted by the site QA surveillance staff identified numerous problems in this area.
Similar problems were identified by regional based inspectors during inspections discussed in RII Report Nos. 82-26 and 83-04. The training area should receive increased licensee management attention to assure that corrective actions identified by the licensee are properly implemented and result in an improved training program.
25 Three violations directly attributable to QA functional area were identified during this assessment period and are identified below. The breakdown in management controls to assure quality contributed to many of the violations discussed in the operations, surveillance, and maintenance sections of this report.
(1) Severity Level III violation for failure to correct, determine the cause of, and take action to preclude recurrence for, a licensee identified condition adverse to quality.
(2) Severity Level IV violation for failure to establish measures to assure that conditions adverse to quality were promptly corrected.
(3) Severity Level V violation for failure to issue an audit report within the time required by technical specifica tions.
- b.
Conclusion Category 3
- c.
Board Comments Licensee performance, which was evaluated as Category 3 during the previous SALP, has not improved during this review period. It is apparent that the QA program was not effective because of the failure to identify deficiencies in opera tional programs and failure to take effective corrective action. The increased level of licensee and NRC attention should be continued.
B.
Supporting Data
- 1. Reports Data
- a.
Licensee Event Reports (LERs)
Three hundred and nineteen LERs were reported for Units 1 and
- 2. The listing of these reports into licensee identified causes is as follows:
Unit 1 Unit 2 Personnel Errors 32 33 Design Manufacturing, Construction/Installation 27 22 External Cause 1
0 Deficient Procedures 9
5 Component Failure 83 69 Other 17 21
26 These reports were categorized in terms of SALP functional areas as follows:
Unit 1 Unit 2 Operations 84 75 Maintenance 5
3 Surveillance 56 51 Quality Assurance 24 21 In general, the LER submittals were usually acceptable. The LERs typically provided clear and concise descriptions of the events. Only one of the more than 300 LERs reviewed was not submitted on or before the due date. However, LERs often did not provide a'clear indication of the effects on system function. Related or repetitive events were rarely speci fically cited even though reports often contain a general statement that an event was repetitive. Also, root causes and symptoms were only infrequently provided.
Over 300 LERs were submitted by the licensee for both units.
Almost 50% of the LERs were related to four repetitive events. These events were:
(1) trickle flow errors in reference legs: (2) procedural deficiencies; (3) failures in the containment oxygen analyzers; and (4) defective control rod reed switches. The first two events are being resolved generically while the latter two pose little challenge to plant safety. Twenty-three LERs reported procedural problems.
This problem area has previously been identified as being related to management control over plant systems.
Four LERs reported incorrect actions by plant personnel.
Two of these were operator's failures to recognize plant technical specification Limiting Conditions for Operations (LCO) or action requirements.
- b.
Part 21 Reports None
- 2.
Investigation and Allegation Review An investigation of circumstances surrounding the damaging of under vessel incore instrumentation at Brunswick Unit 2 was conducted in June 1982. The investigation findings indicated that the damage was not willful but resulted from poor maintenance practices.
An investigation was conducted from September 1982 to January 17, 1983, in response to allegations that contractor personnel had been tampering with personal dosimetry.
Investigation findings did not support this allegation.
0I 27
- 3.
Enforcement Actions
- a.
Violations Severity level I and II: 0 Severity level III:
5 Severity level IV:
14 Severity level V:
16 Severity level VI:
1 Deviations:
2 The severity level for four violations in RII Report 83-03 has not been assigned at the time of issuance of this report.
- b.
Civil Penalties June 1982 - for three Severity Level III violations involving failure to meet an LCO concerning operability of reactor vessel water level instrumentation, failure to correct the problem once identified; and, failure to meet all action statement requirements once it was recognized.
February 1983 -
for two Severity Level III violations; one for failure to have procedures for and conduct surveillance testing; and the other, for failure to take adequate correc tive actions in response to audit findings which should have alerted the facility to the surveillance area problems.
- c.
Orders December 22, 1982 - to confirm the commitments contained in the licensee's improvement program and implementation plan.
- d.
Administrative Actions Confirmation of Action Letters April 8, 1982 - confirming licensee commitments to perform certain actions deemed appropriate as a result of events involving the misalignment of three components in safety related systems.
June 4, 1982 - confirming licensee commitments concerning special interim operational and security measures adopted as a result of damage to under-vessel instrumentation at Brunswick Unit 2.
28 July 2, 1982 -
confirming licensee commitments concerning special measures to be accomplished as a result of failure to identify and perform surveillance test requirements.
July 20, 1982 - confirming licensee commitments concerning further special measures to be accomplished as a result of determining the existance of additional failures to identify and perform surveillance test requirements.
- 4. Management Conferences An enforcement conference was held on February 24, 1982, to discuss proposed corrective actions concerning exceeding a limiting condition for operation and the failure of the residual heat removal (RHR) service water system to operate.
A conference was held on May 28, 1982 to discuss the previous SALP findings.
An enforcement conference was held on July 14, 1982, to discuss proposed corrective actions concerning events involving misalign ment of electrical breakers and valves which occurred in March 1982.
NRC concerns in the areas of operational performance and management control were also discussed.
A meeting was held on July 20, 1982 to discuss CP&L comments with regard to the previous SALP and the status of the missed surveil lance test issue.
An enforcement conference was held on August 24, 1982 to discuss the status of action items contained in the Confirmation of Action letters dated July 2 and July 20, 1982. A preview of the post startup Brunswick Improvement Program was presented by CP&L.
A conference was held on November 10, 1982, to discuss recent actions taken by CP&L to improve the overall performance at the Brunswick facility. The status of the long range improvement program was also discussed.
A meeting was held on November 17, 1982, to discuss integrated and local leak rate test programs performed at the site.
An enforcement conference was held on November 24, 1982, con cerning violations involving radioactive materials shipments to the Barnwell Low Level Waste Management Facility.
An enforcement conference was held on December 22, 1982, regarding a number of personnel errors which resulted in non-compliance with regulatory requirements.
A meeting was held on January 11, 1983, to discuss implementation of the NRC Confirmatory Order issued December 22, 1982.
V. PERFORMANCE ANALYSIS FOR H. B. ROBINSON UNIT 2
30 A.
Functional Area Evaluations - Operations Licensee Activities A refueling outage and a ten year inservice inspection occurred during the period February 26 through August 12, 1982.
Major inspections were conducted on the reactor vessel, reactor coolant pumps, and steam genera tors.
Hydrostatic tests were conducted on the majority of plant fluid systems. Modifications during the outage included TMI and secondary system work.
The licensee limited power to below 1955 Megawatts, thermal, during the SALP review period. The power reduction and low average temperature program constituted an attempt by the licensee to reduce the rate of steam generator tube degradation.
The Institute of Nuclear Power Operations (INPO) conducted an evaluation of management controls and operating practices during the weeks of July 26 and August 2, 1982.
Inspection Activities A radiological emergency preparedness appraisal was held January 25 through February 4, 1982.
An NRC Task Force on Pressurized Thermal Shock visited the site on April 5-7, 1982. A plant procedures and drawing control team inspection was conducted May 10-14, 1982.
- 1. Plant Operations
- a. Analysis During this evaluation period two inspections were performed by regional based inspectors, and routine inspections of the area were performed by the resident inspector.
A weakness was noted in the area of plant procedures. Speci fically, most procedural violations resulted from either poorly stated or out-of-date procedures, or from operations personnel failing to implement procedural requirements. One reportable event involved valve misalignment on safety related equipment by operations personnel.
While the licensee was responsive and initiated programs for upgrading procedures and for training plant personnel on procedural compliance, this effort has, thus far, not been effective in reducing procedural violations. These short comings were the subject of an enforcement conference conducted December 22, 1982.
31 Operations staffing and training appeared to be generally adequate, with the exceptions noted above on procedural compliance and maintaining procedures current. The large number of newly qualified personnel in the operations staff appeared to contribute to the procedural problems. The plant staff, generally, was very observant of Limiting Conditions of Operations (LCO) conditions, and was conservative in applying action statement requirements.
Decision making was generally at a sufficiently high level to ensure adequate review.
Operator licensing examinations were conducted during the evaluation period. This process included both written and oral examinations.
Examinations were given to eight candidates, all of whom passed. Reactor Operator (RO) licenses were issued to six persons and Senior Reactor Operator (SRO) licenses were issued to two persons.
The licensee was highly successful in licensing operator candi dates. The licensee's licensed operator qualification and requalification programs have shown significant improvement in the areas of lesson plan quality, emphasis placed on mitigating core damage, plant modifications, and feedback of operating experience.
Deficiencies identified by the NRC in the area of pressurized thermal shock have received appropriate management and training attention.
As identified in items (6) and (12) below, licensee attention to commitments and modifications concerning the low temperature overpressure protection system was not directed at a sufficiently high level to ensure compliance.
Due to reactor vessel embrittle ment concerns, the licensee should increase its diligence in this area of NRC commitments.
Fourteen violations and one deviation were identified during the evaluation period. These violations are indicative of a minor programmatic breakdown in the area of procedure adequacy and operator compliance. The violations and deviation identified were:
(1) Severity Level IV violation for failure to implement drawing control procedures.
(2) Severity Level IV violation for failure to maintain valve checkoff procedures.
(3) Severity Level IV violation for'failure to review and correct potential safety hazards.
(4) Severity Level IV violation for failure to maintain operating and abnormal procedures.
0 0
32 (5) Severity Level IV violation for failure to control superceded valve lineup procedures.
(6) Severity Level IV violation for failure to implement valve locking procedures.
(7) Severity Level IV violation for failure to implement valve position controls.
(8) Severity Level IV violation for overpressure protection system inoperability.
(9) Severity Level V violation for failure to follow procedures for shift turnover and logkeeping.
(10)
Severity Level V violation for failure to maintain annuncia tor procedures.
(11)
Severity Level V violation for failure to report flow instrument inoperability.
(12)
Severity Level V violation for failure to establish proce dures.
(13)
Severity Level V violation for failure to follow fuel movement procedures.
(14)
Severity Level V violation for failure to issue adequate instructions for identification of masonry walls.
(15)
Deviation for failure to install equipment as committed.
Subsequent to the evaluation period the licensee -prepared and submitted the Robinson Improvement Program (RIP).
The program is designed to enhance sensitivity to regulatory requirements and strengthen the management control systems related to the opera tional and safety aspects of the facility.
- b.
Conclusion Category 2
- c.
Board Comments No decrease in licensee or NRC attention in this area is recom mended.
33
- 2.
Radiation Protection, Radioactive Waste Management and Transportation
- a. Analysis During the evaluation period eight inspections were performed by regional based inspectors. Additionally, routine inspections in this area were performed by the resident inspector.
It was found that the Radiation Protection Program has shown some improvement when compared to the findings of the previous evalu ation period. The licensee's programmatic efforts to improve in the radiation protection area were evident in health physics controls. The licensee has an effective decontamination program which has decreased the number of contaminated areas and personnel contamination events. Preplanning, training, and use of mockups have become more prominent in the licensee's conduct of main tenance and inspection.
A ten year inservice inspection and refueling outage was conducted without any overexposures or significant personnel contamination.
However, it was noted that the program was deficient in air sampling, and in high radiation area control.
The scope of work permitted under a routine radiation work permit (RWP) was excessive.
The plant did not have a routine air sampling program consistent with industry standards. During 1982, all constant air monitors (CAMs) except the stack monitor, were taken out of service due to maintenance problems, and no additional routine air sampling program was established. The air sampling program in effect during 1982 consisted of air sampling only for specific work which required air sampling.
It was found that the job specific air sampling program needed to be more aggressive in order to ensure regulatory compliance. It was found that the frequency of respiratory protection device use by plant personnel was not sufficient to ensure that worker exposures were maintained as low as reasonably acheivable.
A wide scope of work was performed under routine RWPs.
For example, one RWP was utilized for decontamination work in all areas of the auxilliary building. Records for decontamination work were found to be non-retrievable because workers conducted their own surveys and did not document them.
Plant management was responsive to this inspector concern and now limits the use of the routine RWP. Radiation and contamination survey documentation for work controlled by specific RWP's appeared to be adequate.
<K,*
34 During the evaluation period, failure to provide adequate control of high radiation areas accounted for three violations. In one case, licensee personnel did not lock a high radiation area after being notified of this condition. Additional violations resulted from individuals being in high radiation areas without the instru ments required by technical specifications, and another for fail ure to properly post high radiation areas.
Licensee management was responsive in this area and corrective action appeared adequate.
The radwaste program, consisting of liquid, gaseous and solid radwaste, accounted for one Severity Level IV violation for disposal of contaminated oil.
The cause of the release indicated a weak program for sampling and release of oil.
The licensee did not have procedures describing sampling technique, sample volume, or minimum detectable concentrations for release.
Final correc tive action for the release of waste oil from the plant is still under licensee evaluation.
Other areas of the liquid and gaseous effluent accountability program appeared to be adequate.
Transportation of radioactive materials accounted for one Severity Level III violation, item (1) below, which resulted in an enforce ment conference. The violation stemmed from an initial inadequate evaluation to determine if the contents of drums being shipped had been satisfactorily solidified. Although the process control program had been developed to ensure solidification of liquids, the licensee had no previous experience in processing the type of substance contained in the drums being shipped; nor did the licensee evaluate available evidence that the process was ineffective in solidifying the drum contents. In addition, personnel responsible for radwaste shipping permitted the shipment of drums to proceed even though significant external rusting of the drums was evident. The-licensee-was responsive in this area and has established requirements in the radwaste solidification area that should preclude the recurrence of this type problem.
The overall transportation program was adequate as evidenced by having only one violation in this area.
In the general area of radiation protection, ten violations were identified during the evaluation period. These violations collectively indicated a failure to follow health physics procedures at the worker/technician level.
This is indicative of a need for detailed procedures, increased personnel training on procedures, and procedural compliance to ensure that routine health physics practices are understood and correctly performed.
35 One radiological environmental protection inspection was performed during the appraisal period.
Inspections were also performed by the resident inspector.
No violations or deviations were disclosed. The environmental monitoring program was well managed and directed toward continued maintenance of effective off-site environmental protection. Management controls and organizational responsibility for program implementation (including environmental sampling and sample analyses, retention and storage of required environmental data, development and implementation of an effective quality assurance program) were consistent with technical specifi cation requirements and accepted industry practices. Plant staff and staff training appeared above average, and staff morale was high. The licensee had commenced increased effort in this area to prepare for the implementation of forthcoming radiological effluent and environmental technical specifications.
One quality control and confirmatory measurements inspection using the RH mobile laboratory was performed during the evaluation period and no violations were identified. Correction of weak nesses identified in an earlier inspection demonstrated licensee responsiveness to resolving problems identified by the NRC.
The results of effluent samples collected and analyzed by both the NRC and licensee during the inspection showed agreement. All aspects of the laboratory program were satisfactory.
The following violations were identified:
(1) Severity Level III violation for failure to control radio active waste shipment packaging.
(2) Severity Level IV violation for failure to control a high radiation area and failure to implement control procedures for other high radiation areas.
(3) Severity Level IV violation for failure to implement control procedures for high radiation areas.
(4) Severity Level IV violation for failure to establish a procedure that provided for personnel exit from a locked high radiation area.
(5) Severity Level IV violation for improper disposal of licensed material.
(6) Severity Level V violation for failure to post high radiation areas.
(7) Severity Level V violation for failure to implement proce dures for the control of radioactivity.
(8) Severity Level V violation for failure to follow health physics procedures.
36 (9) Severity Level-V violation for failure to establish or implement health physics procedures.
(10)
Severity Level V violation for failure to follow health physics procedures.
- b.
Conclusion Category 2
- c.
Board Comments Licensee performance improved from a Category 3 during the pre vious SALP period to a Category 2 during this period. Continued improvement will be needed to ensure that the radiation control program is sufficient to handle the projected steam generator replacement work.
No decrease in licensee or NRC attention is recommended.
- 3. Maintenance
- a.
Analysis During this evaluation period one inspection was performed by regional based inspectors. Additionally, routine inspection in this area was performed by the resident inspector.
The majority of safety-related maintenance has been performed consistent with regulatory requirements; however, some weakness was noted in maintenance procedure adequacy. Specifically, several of the violations and reportable events discussed below were caused or contributed to by procedures containing insuffi cient guidance and signoffs.
Inattention to details during the procedure review and approval process was also contributory.
While licensee procedures have generally been adequate to conduct maintenance when used by experienced personnel, problems have occurred in activities involving less experienced personnel and/or infrequent maintenance activities.
The licensee has recognized a need for improved procedures for several years, and recently both permanent and contractor staffing were increased to address the problem. The licensee's efforts have resulted in some program matic improvements, but considerable numbers of maintenance procedures need further development and revision. These short comings were the subject of an enforcement conference conducted December 22, 1982.
Maintenance staffing appeared to be adequate, and licensee manage ment has conducted additional training on the importance of quality procedures and procedural compliance. This effort was directed at improving the quality of maintenance prior to comple tion of the longterm procedural upgrade. Maintenance personnel
37 generally communicated well with the operations staff to assign a proper priority to the maintenance of safety related equipment.
Additional emphasis needs to be given to the importance of main taining the equipment that directly supports safety-related systems.
Ten of the nineteen reportable events for this plant were due to component failures, however review of these reports indicated almost no correlation with maintenance activities.
Four report able events resulted from personnel errors and/or procedural inadequacies related to maintenance activities. Two events affected safety system operability and one caused reactor coolant system leakage. A special report issued by the licensee described the failure, during surveillance testing, of a reactor trip breaker caused by inadequate cleaning and lubrication of the undervoltage trip device.
Five violations were identified during the evaluation period.
These violations are generally indicative of the need for improved maintenance procedures. The violations identified were:
(1) Severity Level IV violation for failure to implement modifi cation controls during maintenance.
(2) Severity Level IV violation for failure to adequately review a maintenance procedure prior to approval and use.
(3) Severity Level IV violation for failure to control mainten ance activities.
(4) Severity Level IV violation for failure to establish adequate calibration procedures.
(5) Severity Level V violation for failure to implement equipment control policies on completion of maintenance.
b. Conclusion
Category 3
- c. Board Comments Licensee performance, which was evaluated Category 2 during the previous SALP period, has declined during this period. Licensee management attention should be increased.
38
- 4.
Surveillance
- a.
Analysis During this inspection period seven inspections were performed by regional based inspectors.
Routine inspections were performed by the resident inspector.
The licensee's surveillance program was generally well established and implemented. Scheduling and completion of surveillances have been timely and have received adequate management attention.
Additional programs for surveillance tracking and auditing have been established to ensure complete compliance with requirements.
An in-depth review of surveillances required during the refueling period was conducted and no violations were identified. Several procedures for performance of surveillance activities were poorly written. However, reviewed as a program, surveillances and inservice testing activities were well controlled. There were no reportable events in this area. There were four inspections in the area of inservice inspection (ISI) and non-destructive examination (NDE) activities by regional based inspectors during this inspection period. Major ISI activities involved the ultra sonic inspection of the reactor vessel belt-line region and the radiographic examination of welds in a main coolant pump. When some bolts inside the main coolant pump were found to be degraded, the licensee aggressively pursued the cause and extent of the problem. This involved dismantling the other two main coolant pumps and extensive evaluation of all failed bolts. There were no violations or deviations found during the inspection of the ISI/NDE activities.
Three violations were identified during the evaluation period:
(1) Severity Level IV violation for failure to establish an adequate surveillance procedure.
(2) Severity Level V violation for failure to perform surveil lance at the proper frequency.
(3) Severity Level V violation for failure to establish and implement adequate procedures for containment leak rate testing.
- b.
Conclusion Category 1
39
- c.
Board Comments Licensee performance has improved from Category 2 during the previous SALP to Cagetory 1 during this period. Although improve ment was observed in this area, the potential exists for the same problems to develop as with the Brunswick surveillance program.
No decrease in NRC inspection effort is recommended.
- 5.
Fire Protection
- a. Analysis During this evaluation period, routine inspections were performed by the resident inspector.
No violations were identified. A review of fire protection special reports revealed some weaknesses in the licensee's post modification testing program for the major fire protection equip ment upgrade. The licensee has been responsive to these problems and has taken or initiated appropriate corrective action. Over all, the level of plant fire safety was greatly improved.
The plant fire protection staff appeared to be highly motivated and knowledgeable.
Staffing levels and training appeared to be above average.
Fire protection administrative procedures were generally adequate.
- b.
Conclusion Category -
Not Rated
- c. Board Comments There was not sufficient inspection activity in this area during the evaluation period to justify a rating.
- 6.
- a. Analysis During the evaluation period, the regional staff conducted a routine inspection, an emergency preparedness appraisal, and observed an exercise.
During the emergency preparedness appraisal two deficiencies were identified in the areas of training and notification procedures.
A Confirmation of Action Letter dated February 22, 1982, was issued concerning the deficiences. The licensee was responsive to the letter and fulfilled his commitment to correct the deficien cies.
0 0
40 During the licensee annual exercise (October 1982), an emergency preparedness deficiency was identified in the area of accident classification procedures. As a result, a Confirmation of Action letter (dated November 1, 1982) was issued. The licensee responded to the deficiency by revising procedures and conducting training.
Corporate management appeared to be supportive of emergency planning/response programs. There was evidence that priorities had been established and responsibilities assigned in the area of emergency preparedness.
Licensee records and documentation of program activities appeared to be complete.
From an enforcement standpoint, the licensee's corrective action has generally been timely and effective. Although some program matic weaknesses were identified by NRC and corrected by the licensee, recurrence was rare.
Licensee critiques of emergency response activities during drills were not always as aggressive, complete, and objective as needed.
Improvements are necessary in this area.
Emergency preparedness staffing levels at the plant and corporate office appeared to be adequate.
Key positions have been filled at the plant and corporate offices. Authorities and responsibilities have been defined for key positions.
A training program has been defined and implemented for members of the emergency response organization. A program for professional development of the emergency preparedness staff had been defined.
Two violations were identified during the evaluation period:
(1) Severity Level IV violation for failure to meet frequency requirements for audits of the emergency plan and implement procedures.
(2) Severity Level V violation for failure to conduct required tests and drills.
- b.
Conclusion Category 2
- c.
Board Comments No decrease in licensee or NRC attention is recommended.
41
- 7.
Security and Safeguards
- a. Analysis During this evaluation period four inspections were performed by regional based inspectors.
Routine inspections were performed by the resident inspector.
The licensee was responsive to NRC initiatives. The licensee's site security management was enhanced by corporate management with an apparent emphasis on security. Security staffing and training appeared to be adequate.
Personnel morale was high.
The licensee expended an excessive amount of time and effort maintaining security equipment that should have been upgraded; this was identified as a minor programmatic weakness. According to the physical security event reports received, equipment failure was generally a root or contributing cause. While the licensee's compensatory measures have been adequate, increased emphasis on equipment upgrade is needed.
Licehsee management has initiated actions to improve the system.
Four violations were identified during the evaluation period.
These violations were considered isolated and not indicative of programmatic breakdown. The violations identified were:
(1) Severity Level IV violation for failure to report a change to the security plan.
(2) Severity Level IV violation for failure to perform security program audits at the required frequency.
(3) Severity Level IV violation for failure to provide adequate vital area access control.
(4) Severity Level V violation for failure to search a package.
- b.
Conclusion Category 2
- c.
Board Comments No decrease in licensee or NRC attention is recommended.
- 8.
Refueling
- a. Analysis During this evaluation period one inspection was performed by a regional based inspector. Routine inspections were performed by the resident inspector.
42 Extensive inspections were conducted in the areas of refueling preparation, operations, maintenance, surveillance, and startup testing. No violations were observed, and only minor followup items identified. Startup testing procedures were adequate, but would benefit from minor changes in format and clarification.
The reactor engineering staff and their training were adequate, and the licensee has taken steps to provide the reactor engineer with additional training and improve liaison with the corporate fuels section.
- b.
Conclusion Category 1
- c.
Board Comments Licensee performance, which was not rated during the previous SALP period was Category 1 during this period. The proper amount of licensee attention has been expended.
No decrease in licensee or NRC attention is recommended.
- 9.
Licensing Activities
- a. Analysis The assessment of licensee performance was based on the evaluation of the following licensing activities:
Project management administration Response to NUREG-0737 items 10 CFR 50, Appendix R Environmental qualification Operating licensing Control of heavy loads Pressurized thermal shock (PTS)
Cycle 9 reload Radiological effluent technical specification (RETS)
In general, management involvement and control in assuring quality was inconsistent, resulting in varying levels of licensee performance. Evidence of quality management capability was apparent in selected areas, but consistent management attention over the full range of licensing activities was not evident.
The licensee's approach to resolution of technical issues was acceptable. Technical understanding of the issues was generally demonstrated, but a lack of thoroughness or depth in the approach to resolutions occasionally resulted in lengthly requests for additional information.
43 Responses to NRC initiatives generally were not timely and frequently required extensions of time to complete. Several issues have been outstanding for extended periods (e.g., RETS, Control of Heavy Loads, Appendix R, Cycle 9 Reload, and PTS).
The licensee has recognized problems in this area and recently made changes in his organization and staffing to improve this situation. Additional licensing personnel have been added, as well as an onsite licensing representative, to improve communi cations between the corporate headquarters and the plant site.
The licensee has requested a meeting with the NRC staff to discuss initiatives that have been taken and that will be taken to schedule and expeditiously respond to plant specific, multiplant and TMI open items.
Overall, the performance of the licensee has been satisfactory.
However, there were a substantial number of marginal areas.
Inconsistent quality in management of licensing activities, a general lack of timeliness in responding to staff requests, and lack of completeness and depth of submittals were identified as significant negative factors.
- b.
Conclusions Category 3
- c. Board Comments Licensee management attention should be increased in this area.
- 10.
Quality Assurance Program
- a. Analysis During this assessment period, two inspections were performed by regional inspectors in the quality assurance area. One other QA-related problem, violation (5), was identified while inspecting in another area.
In general the licensee has adequately stated and understood QA policies as evidenced by review of QA procedures and discussions with licensee personnel.
However, one weakness in this area related to the failure of certain procedures to involve QA manage ment in the prompt resolution of problems identified by the QA staff.
This issue is discussed in more detail in the Brunswick section of this SALP report; the problems are common to both plants.
44 Licensee records were generally well controlled. Violation (6) was identified in this area, but appeared to be an isolated example.
Procurement activities were generally well controlled and documented; however, increased management attention appears necessary as evidenced by violation (5) below.
The licensee was generally responsive to NRC identified items relating to QA activities as evidenced by closure of 13 previously identified unresolved and inspector followup items as described in RII inspection report No. 82-24. One item involving development of a trend evaluation program had been open since 1979 indicating a need to improve the timeliness of actions taken to resolve certain issues.
Corrective actions for items identified by the site QA surveil lance staff were usually adequate. Action on QA audit findings were hampered by Performance Evaluation Unit (PEU) failure to issue all audits in a timely manner, violation (6) below, and by failure of the audited group to respond to certain audit findings in a timely manner, violation (4) below.
Audit staff training generally appeared adequate; however, exper tise was weak in the area of plant operation. The licensee has indicated a desire to improve the abilities of its inspectors and, where appropriate, supplement audit teams with special expertise.
The NRC encourages this effort in light of the number of viola tions listed in the plant operations section of this report.
The corporate level PEU conducts audits at both operating sites.
Certain levels of management were involved in site activities as evidenced by frequent visits and communications between the Manager, Operations QA/QC, and site QA personnel and by the Manager, Corporate QA Department. However, the Principal QA Specialist who supervises the PEU did not appear to be directly involved in site activities.
PEU audits were not conducted at the required frequency as evidenced by violations (2) and (3) and by one additional example discussed in the safeguards section of this report. Audit reports and responses were not always issued in a timely manner as evidenced by violations (4) and (6) below. Site QA personnel perform a surveillance function and corporate management appears to be involved in this activity as previously discussed. The audit function is performed by the PEU and there appeared to be little, if any, corporate management attention in this functional area. Increased corporate level management attention is needed to improve the overall effectiveness of PEU audits.
45 The staffing level for the PEU appeared to be inadequate as evidenced by the failure of this group to perform and issue audits in a timely manner. However, additional personnel were in training. The increased audit staff should help alleviate this problem.
Eight violations were identified during the assessment period.
Four of these violations (2, 3, 4, and 6) indicate a need for improved management control of the QA audit program. The viola tions identified were:
(1) Infraction concerning failure to report conditions related to the radiation embrittlement of the reactor vessel.
(2) Severity Level IV violation for failure to conduct an audit of the Emergency Plan and implementing procedures at least once per 24 months and for failure to conduct an audit of the fire protection program and implementing procedures at least once per 24 months.
(3) Severity Level IV violation for failure to conduct an audit of the fire protection and loss prevention program by an outside qualified fire consultant at intervals no greater than three years.
(4) Severity Level IV violation for failure to submit audit responses within the allowable time.
(5) Severity Level IV violation for failure to provide written procedures for the control, storage, and preservation of quality controlled material and equipment.
(6) Severity Level V violation for failure to transmit audit reports to management within the allowable time.
(7) Severity Level V violation.for failure to properly store radiographs.
(8) Severity Level V violation for failure to follow QA proce dures.
b. Conclusion
Category 3
46
- c.
Board Comments Licensee performance, which was evaluated as Category 2 during the previous SALP, has declined during this period. This is attrib uted to lack of management support of the corporate Performance Evaluation Unit. The licensee should increase management atten tion in this area.
The NRC should continue the increased level of attention in this area.
B.
SUPPORTING DATA
- 1. Reports Data
- a.
Licensee Event Reports (LERs)
Nineteen LERs were reviewed for Robinson Unit 2 for this assess ment period. The dispersion of these reports into licensee identified proximate cause codes is as follows:
Personnel Error 4
Design, Manufacturing, Construction/Installation 4
External Cause 0
Deficient Procedures 1
Component Failure 10 Other 0
These reports were categorized in terms of SALP functional areas as follows:
Operations 7
Maintenance 4
Surveillance 7
Quality Assurance 1
The LERs for this plant were evaluated for completeness and accuracy for the period January 1, 1982 to January 31, 1983.
Component failure prompted the majority of LERs.
The event descriptions were clear and detailed and supplemental information was provided for every LER. In each case, the licensee made an attempt to determine the root cause of the event and possible implications of the event to other plant equipment. If numerous failures occurred, an investigation was conducted to determine,if the problem might be generic.
- b.
Part 21 Reports None
- 2.
Investigation and Allegation Review One investigation concerning reactor vessel surveillance capsule data occurred during the review period.
47
- 3.
Enforcement Actions
- a.
Violations Severity Level I, II - 0 Severity Level III -
1 Severity Level IV - 25 Severity Level V -
19 Severity Level VI -
1 Infraction - 1
- b.
Civil Penalties None
- c.
Orders None
- d.
Administrative Actions (1) Confirmation of Action Letters February 22, 1982 -
involving significant deficiencies from the Radiological Emergency Appraisal inspection.
November 1, 1982 -
involving emergency preparedness deficien cies identified during an emergency exercise.
- 4. Management Conferences A conference was held on May 28, 1982, to discuss the previous SALP findings.
A conference was held on November 24, 1982, to discuss radioactive waste shipping and packaging violations.
An enforcement conference was held December 22, 1982, to discuss concerns about violations of regulatory requirements and the effectiveness of management controls.
VI. PERFORMANCE ANALYSIS FOR SHEARON HARRIS UNITS 1 AND 2
49 A.
Functional Area Evaluation - Construction (Units 1 and 2)
Licensee Activities During this evaluation period, construction progressed at a rate consistent with the projected schedule.
The licensee had significantly increased the manning for the CP&L Site Design Group.
Emphasis was placed on increasing manpower to accommodate the increased construction activities as they relate to mechanical, piping and electrical efforts. The site QA/QC staff has also significantly increased its manpower during this reporting period. The QA/QC staff was increased primarily to accomodate additional inspection responsibilities which it acquired, i.e, to inspect start-up and test personnel and their work efforts, and also to accommodate the increased site activities as they relate to welding, mechanical, material control and QA/QC records and their review. The QA/QC group has been divided into two separate groups. The QA group now is totally responsible for all of the surveillance activities, and is not responsible for first-line inspection functions. The QC group has been assigned first-line inspection activities in selected areas. Both of these groups now report to the site QA/QC director.
The manning of the start-up and task group has also been increased signi ficantly to accommodate the turnover schedule. The licensee has increased its turnover activities with a 125-week schedule starting January 1, 1983.
This schedule, if followed, should allow fuel loading on schedule, in June of 1985.
During the evaluation period the licensee conducted four major audits:
Cresap, McCormick and Padget Inc., conducted an audit of the licensee's management functions. The audit started about April 13, 1982, and was finalized on October 1, 1982.
INPO conducted an audit of the licensee's overall management, design and construction functions associated with the Harris site.
The audit team consisted of approximately 30 members and covered the period of June 14 through June 29, 1982.
MAC (Management Analysis Company) conducted an audit of the licensee, which primarily covered the quality assurance aspect of the Harris site, during the period of September 21 through September 30, 1982.
The licensee conducted a Self-Initiated Evaluation of the activities at the Harris site.
The audit covered the period of October 11 through November 12, 1982. The audit report was published on December 10, 1982, and included the Quality Assurance section taken from the MAC audit which had been previously conducted.
50 As a result of the Self-Initiated Evaluation, a report was generated which required various groups to conduct self-corrective actions by certain dates.
The team which conducted the audit will be required to follow-up to assure that adequate corrective actions have been taken.
The audit was objective and provided the licensee with opportunities for improvement, and also indicated that the company, in general, is performing safe and satisfactory construction work at the site.
In October 1982, the licensee assigned a corporate nuclear representative, (retired vice chairman of the licensee's Board of Directors), to interact between the Chief Executive Officer and Senior Manager for all site aspects of construction. The licensee had required all their employees and the senior constructor(s) employees to attend a video tape production wherein four of the licensee's executives confirmed their commitments to quality.
Inspection Activities Forty-two inspections were conducted during this period; twelve of these inspections were routine inspections conducted by the resident inspector, and the remaining were conducted by Region II personnel.
- 1. Soils and Foundations
- a. Analysis During this evaluation period six inspections were performed by regional based inspectors. Additionally, routine inspections were performed in this area by the resident inspector.
The inspections involved examination of QA implementing proce dures, soils testing laboratory, records, and backfilling of the excavations for Units 3 and 4 which have been cancelled. The majority of the soils and foundation work had been completed for Units 1 and 2. The remaining activities in this area were primarily concerned with underground piping systems.
The QA/QC procedures and controls met NRC requirements. The records were generally complete, well maintained, and retrievable.
Equipment in the testing laboratory was properly calibrated and testing and backfill operations were conducted in accordance with ASTM standards, procedures, and specification requirements. No violations or deviations were identified.
The licensee's activities in this area met industry standards and were considered to be adequate.
- b.
Conclusion Category -
Not Rated
0 0
51
- c. Board Comments There has not been sufficient licensee or NRC activity in this area to justify a rating.
- 2.
Containment and Other Safety-Related Structures
- a. Analysis During this evaluation period twelve inspections involving struc tural concrete and steel structures were performed by regional based inspectors.
The inspections involved examination of QA implementing proce dures, records, concrete testing laboratory, and work activities associated with concrete placements and program review, observa tion of work, and review of quality work associated with safety related steel structures.
The QA/QC procedures and controls met NRC requirements.
Records were generally well maintained and complete. With the exception of the violation noted below, work activities were performed in accordance with procedure and specification requirements.
Management involvement, resolution of technical issues, staffing, and training were adequate for the level of activity involved.
The licensee was responsive in correcting the violation listed below.
Severity Level V violation for failure to properly field cure concrete test cylinders.
b. Conclusion
Category 1
- c. Board Comments Licensee performance, which was Category 2 during the previous SALP period has improved to Category 1 during this period. The proper amount of licensee management attention has been applied to this area.
No decrease in NRC inspection effort is recommended.
52
- 3.
Piping Systems and Support Systems
- a.
Analysis During this evaluation period, eight inspections were performed by regional based inspectors. Additionally, routine inspections were performed by the resident inspector. Inspections included review of program and procedures, observations of work and work activi ties, and review of quality records, in the areas of pipe welding, seal welding, welder qualifications, welding filler material control, repair welding, piping supports, piping assembly storage and preservation, and preservice inspection.
Review of the violations does not indicate a breakdown of the program. No repetitive violations were identified, and corrective actions appeared to be prompt and effective.
Improvements had been made in this area as evidenced by the fact that all the violations except violation (1) below, in the preservice inspection area, were identified within the first sixty days of the reporting period. The preservice inspection violation was identified during the first inspection in that area.
The organization in this functional area appeared to be adequately staffed with trained and qualified personnel.
Procedural require ments implemented in this area appeared generally satisfactory.
Seven violations were identified during the period as follows:
(1) Severity Level IV violation for failure to identify in welding records the inspectors that performed the inspec tions.
(2) Severity Level IV violation for failure to perform weld inspections with qualified inspectors.
(3) Severity Level V violation for failure to follow visual inspection procedures.
(4) Severity Level V violation for failure to follow procedures for inspection of welds and reporting of discrepancies.
(5) Severity Level V violation for failure to establish adequate measures to assure purchased services, including preservice inspection, conform to procurement documents.
(6) Severity Level VI violation for failure to follow welding procedure specifications.
- b.
Conclusion Category 2
53
- c.
Board Comments No decrease in licensee or NRC attention is recommended.
- 4.
Safety-Related Components
- a. Analysis During this evaluation period, five inspections performed by regional based inspectors addressed this area.
Additionally, the
.resident inspector performed routine inspections in this area.
The inspections involved review of program and procedures, obser vation of work and work activities, and review of quality records in the areas of reactor vessel, steam generator and pressurizer storage and protection, installation, and storage of other safety related equipment. Management involvement and controls for assuring quality in the area of protection, installation, and storage of safety related equipment were generally adequate. Two violations related to protection and storage, identified below, indicate that a weakness in these areas did exist early in the reporting period. There is evidence of prior planning and assign ment of priorities and procedures for control of activities are generally adequate and appear to be understood. The corporate quality organization was usually involved in site activities, but some confusion regarding the division of responsibilities between CP&L QA and the site Construction Inspection Group hindered program implementation.
Records were generally available and complete.
The licensee was receptive to NRC initiatives. Responses generally reflected an understanding of the issues, but resolu tions were sometimes delayed and lacked thoroughness.
The organization in this functional area appeared to be adequately staffed with trained and qualified personnel.
The violations identified below were not considered indicative of a programmatic breakdown.
(1) Severity Level IV violation for failure to require the vendor to manufacture a reactor makeup water pump in accordance with the seismic shock analysis for the pump.
(2) Severity Level V violation concerning safety-related equip ment not properly protected from the environment and adjacent construction activity.
(3) Severity Level V violation concerning safety-related equip ment not properly protected from the environment and adjacent construction activity.
54 b..
Conclusion Category
- c. Board Comments No decrease in NRC or licensee attention is this area is recommended.
- 5. Support Systems
- a. Analysis During this assessment period one inspection was conducted in the fire protection area by a regional based inspector. Additionally, inspections were also performed in this area by the resident inspector.
Only a small portion of the permanent fire protection features had been installed at the time of the NRC inspection of this area.
However, it appeared that the systems were to be installed and tested under an adequate quality assurance program.
An adequate construction site fire protection program was provided to prevent loss in the event of fire.
Daily safety inspections of construction actvities were conducted to assure that adequate fire protection/prevention features were in effect. Craft personel were trained in the proper use of portable and semi-permanent fire fighting equipment. The site fire brigade was well trained and familiar with necessary techniques to be used to combat various types of fires which can occur on the site. The construction site fire protection equipment and systems appeared to be adequately maintained, inspected and tested for construction operations.
Management appeared involved and very supportive of the plant's fire protection program.
Responsiveness to NRC initiatives had been timely. Major fire protection discrepancies had not been identified. The staffing and training in the fire protection program at the current construction level appeared adequate.
No violations were identified in the area; however, one deviation was found:
Deviation for the failure to store and maintain the permanent plant fire protection pump and appurtenances in accordance with plant storage procedures.
- b.
Conclusion Category 1
55
- c.
Board Comments Licensee performance, which was not rated during the previous SALP, is Category 1 and is limited to the construction fire protection program. Licensee resources and management attention appear to be at the proper level.
No decrease in NRC inspection effort is recommended.
- 6. Electrical Power Supply and Distribution
- a. Analysis During this evaluation period eight inspections were performed by regional based inspectors. Additionally, inspections in this area were performed by the resident inspector.
A weakness was noted in the welding and welding inspections of electrical items and supports as indicated by the first three violations listed below. These items involved welding and welding inspections associated with electrical supports and vendor supplied electrical equipment. Two of the violations related to welding by off-site manufacturers. These off-site welding problems were not identified by the on-site receipt inspections and/or source inspections by the manufacturer or CP&L. The licensee has been prompt in responding to these items. Corrective action included:
increased surveillance of manufacturer's shop activities; increased on-site inspection requirements for material; re-inspection of material/equipment that may have nonconforming welds; and an improved training program for welding inspection personnel.
In addition, welding inspection supervisors were to perform a more extensive evaluation of employees in this area.
One violation related to storage and protection of electrical equipment. The licensee responded to this item promptly and took action to emphasize to site personnel the importance of proper storage and protection of electrical equipment. The licensee's corrective action concerning storage and protection of electrical equipment from adverse environmental conditions and adjacent construction activities was reviewed by NRC and considered to be acceptable.
Three violations concerned procedural requirements in which actions were performed out of sequence, requirements were not fully implemented by craft personnel or requirements were not implemented in the specified time period.
The final violation concerned a field change request that allowed the installation of equipment to a mounting criteria that differed from the mounting configuration for the seismic qualification of the equipment.
56 The licensee's approach to the resolution of technical issues has been normally sound and characterized by viable and thorough approaches and has been responsive to NRC issues.
The organiza tion in this functional area was considered to be adequately staffed with qualified personnel.
In total, eight violations were identified during the evaluation period. These violations were not indicative of a programmatic breakdown but were the result of a failure to prepare adequate procedures to implement NRC requirements and licensee commitments or to train personnel and make them aware of these requirements and commitments. As indicated above, the licensee has taken action to rectify these issues. These violations are identified below.
(1) Severity Level IV violation for nonconforming vendor welds on seismic electrical raceway supports.
(2) Severity Level IV violation for inadequate field welds on cable tray supports.
(3) Severity Level IV violation for nonconforming vendor welds in electrical-panels.
(4) Severity Level IV violation for failure to implement proce dural requirements, in that welding of equipment to embeds was performed prior to satisfactory acceptance of equipment set inspection.
(5) Severity Level V violation for failure to properly store and protect electrical equipment from adverse environmental conditions and adjacent construction activities.
(6) Severity Level V violation for failure to implement proce dural requirements, in that craft personnel failed to meet torquing requirements on cable tray fasteners.
(7) Severity Level V violation for failure to implement proce dural requirements with respect to inspection and maintenance of electrical penetration assemblies.
(8) Severity Level V violation for failure to verify that electrical cabinets were seismically qualified to present mounting configuration.
- b.
Conclusion Category 2
57
- c.
Board Comments No decrease in the amount of licensee or NRC attention is recommended.
- 7.
Instrumentation and Control
- a. Analysis No routine inspections were performed in this area due to the early stage of construction activity.
- b.
Conclusion Category -
Not Rated
- c.
Board Comments There was not sufficient licensee or NRC activity in this area to justify a rating.
- 8.
Licensing Activities
- a. Analysis The evaluation was based on the following licensing activities:
Reservoir reanalysis subsequent to cancellation of Units 3 and 4 Environmental engineering review Reactor Systems review of the FSAR Instrumentation and control reviews Radwaste systems review Mechanical engineering review The main area of concern was that the information submittals were frequently not timely, thorough, nor technically sound. Evidence for such inadequacy was noted particularly in the reservoir reanalysis, accuracy of information in the Environmental Report, and technical information on the radwaste systems. This indicated a lack of management involvement in assuring quality of licensing documentation in submittals to the NRC.
With regard to resolution of technical issues from a safety stand point, the licensee seems to be committed to meet all the nuclear safety standards but the program lacks thoroughness and depth in its responses to NRC initiatives.
In the area of the licensee's staffing of personnel there was an apparent lack of sufficiently qualified people to provide technical depth for timely submissions in some areas.
58 Based on review of the licensing activities described in the first paragraph of this section, licensee attention needs to be increased:
(1) to maintain the accuracy of the information provided for NRC review.
(2) to ensure sufficient substance in an information submittal such that repeated questions are not required.
(3) to maintain the qualified staff necessary to accomplish the above objectives.
- b.
Conclusion Category 3
- c.
Board Comments Licensee performance had improved toward the end of the period; however, licensee management attention should be increased to correct the identified weaknesses.
- 9. Quality Assurance Program
- a. Analysis One corporate QA inspection and two site QA inspections were performed by regional based inspectors during the assessment period. In addition, routine inspections were performed by the resident inspector. The QA program, design control, procurement activities, and audits were the areas inspected at the corporate office. Site procurement, receiving, storage, and maintenance; implementation of 10 CFR Part 21; QA inspection of structural concrete and soils backfill activities; and, onsite design activities were the areas inspected at the site.
Four violations and one deviation listed in other parts of this report were identified in the overall implementation of the QA program. These problems involved equipment that was not stored to prevent its damage by the environment, was not protected from adjacent work activities, or was not properly maintained. The violations applied to ASME Section III valves, fuel handling building cranes, permanent plant fire protection equipment, and electrical penetrations. These storage and maintenance violations demonstrate the need for improved licensee management and craft attention in this area.
These problems are not considered a breakdown in the licensee's QA program.
59 CP&L audits its architect/engineer (A/E) (Ebasco) and nuclear steam system supplier (Westinghouse) with particular attention paid to design functions (i.e., oriented more towards technical engineering review and assessment versus the usual program compliance verification). Additionally, CP&L audits vendor-to vendor interface actions. Although the audit frequency for A/Es and major suppliers is required only once every three years, CP&L audited this functions three times per year to ensure meeting all applicable requirements of Appendix B. This resulted in greater depth and overall coverage in their design audits. The audits were generally complete and thorough. Records were generally complete, well maintained, and retrievable. The corrective action systems generally recognize and address nonreportable concerns.
Procurement activities are generally well controlled and docu mented. As identified by violation (1) below, the corporate Performance Evaluation Unit (PEU) missed certain annually required construction site activity audits during calendar year 1981.
Although not audited by corporate PEU, these activities were covered through surveillance and monitoring by the site QA/QC unit.
CP&L management has gradually increased the number of site design personnel, upgrading their engineering expertise and design responsibility with the intent that the onsite design group will eventually handle all plant design, thereby providing a knowledge able site engineering base that will be present during the opera tional phase.
Increased licensee involvement in design activities should prove beneficial to the utility. The licensee and A/E resolution of technical safety issues was viable, generally conservative and thorough in approach, and generally provided timely resolution.
The licensee's responsiveness to NRC bulletins, circulars, and notices was considered acceptable and generally sound.
The CP&L program, procedures, and applicable correspondence for IE Bulletins, Information Notices and IE Circulars was reviewed.
CP&L continually assessed their internal audit and the independent authorized nuclear inspector program findings. Monthly project review meetings were conducted with senior management to review not only planning schedules but engineering and QA matters of concern pertinent to the Harris plant. Senior Management Reviews were conducted on a six-month frequency along with special meetings for specific items of concern at no established frequency to discuss status and implementation of the QA program.
CP&L reorganized the QA program by creating a new Corporate QA Department which reports directly to the Executive Vice President for Power Supply and Engineering and Construction.
This reorgani zation consolidated into one department the QA functions from Technical Services, Nuclear Safety and Research, and the Nuclear
60 Operations departments. Currently included in the Corporate QA Department are Engineering and Construction QA/QC, Operations QA/QC, the Performance Evaluation Unit, and the Training and Procedures Unit. The above consolidation should improve QA effectiveness in that all QA units are now in the same organ ization and receive uniform QA training, direction, guidance, and procedures.
Staffing of QA positions appeared to be adequate.
Key positions were identified and authorities and responsibilities were defined.
Management independence has been retained and strengthened by the decision to divide the site QA/QC group into two separate entities. Both of these groups now report to the site QA/QC director. Both corporate and site QA staffing have increased with expanded work load.
The corporate QA auditors were qualified to the licensee's procedures and ANSI N45.2.23 requirements.
Two violations were identified during this evaluation period.
The licensee has been prompt in responding to NRC violations and their corrective actions have been acceptable to Region II. The violations identified were:
(1) Severity Level IV violation for failure of the corporate QA staff to audit certain structural activities during calendar year 1981.
(2) Severity Level IV violation for failure to analyze cut rebar for acceptability.
- b.
Conclusions Category 2
- c.
Board Comments No decrease in licensee or NRC attention in this area is recommended.
B.
Supporting Data
- 1.
Reports Data
- a.
Construction Deficiency Reports (CDRs)
Twenty-four CDRs were reviewed for this assessment period.
The distribution of these reports into cause related categories is as follows:
61 CATEGORY NUMBER Welding 12 Mechanical 4
Diesel Generator 3
Electrical 2
QA 1
Design 1
Misc.
1
- b.
Part 21 Reports Three reports have been issued.
- 2.
Investigation and Allegation Review No major investigation or allegation activities were performed during the review period.
- 3.
Enforcement Actions
- a.
Violations Severity Level I, II and III: 0 Severity Level IV: 9 Severity Level V: 10 Severity.Level VI: 1 Deviations: 1
- b.
Civil Penalties None.
- c. Orders No orders relating to enforcement actions were issued.
- d. Administrative Actions Confirmation of Action Letters (CALs)
No CALs were issued during the review period.
- 4. Management Conferences A conference was held on May 28, 1982, to discuss the previous SALP findings and is documented in Region II report 400/401/82-14.
0 0
ENCLOSURE 2 NRC/CPL SALP Meeting Attendees Licensee:
Carolina Power and Light Company Facilities:
Brunswick Steam Electric Plant, Robinson Steam Electric Plant, and Harris Nuclear Power Plant Meeting At:
Carolina Power and Light Company's Corporate Office, Raleigh, North Carolina Date Conducted:
May 10, 1983
- 1.
Licensee Attendees S. H. Smith, Jr., Chairman/President J. A. Jones, Vice-Chairman, Retired E. E. Utley, Executive Vice President, Power Supply and Engineering and Construction L. W. Eury, Senior Vice President, Power Supply M. A. McDuffie, Senior Vice President, Engineering and Construction J. M. Davis, Jr., Senior Vice President, Fuels and Materials Management T. S. Ellemen, Vice President, Corporate Nuclear Safety and Research A. B. Cutter, Vice President, Nuclear Plant Engineering B. J. Furr, Vice President, Nuclear Operations S. D. Smith, Vice President, Nuclear Plant Construction P. W. Howe, Vice President, Brunswick Nuclear Project H. R. Banks, Manager, Corporate QA B. H. Webster, Manager, Environmental and Radiological Control W. J. Hurford, Manager, Technical Services S. R. Zimmerman, Manager, Licensing and Permits C. R. Dietz, General Manager, Brunswick Nuclear Project R. B. Starkey, Jr., General Manager, H. B. Robinson Nuclear Plant J. L. Willis, General Manager, Harris Plant R. M. Parsons, Site Manager, Harris Plant L. I. Loflin, Manager of Engineering, Harris Plant 2
- 2.
NRC Attendees James P. O'Reilly, Regional Administrator, RII R. C. Lewis, Director, Division of Project and Resident Programs (DPRP),
(SALP Board Chairman), RII J. A. Olshinski, Director, Division of Engineering and Operational Programs, RII D. B. Vassallo, Chief, Operating Reactors Branch 2, Division of Licensing (DL),
NRR G. W. Knighton, Chief, Licensing Branch 3, DL, NRR D. M. Verrelli, Chief, Project Branch 1 (PB 1), DPRP, RII M. V. Sinkule, Chief, Operational Support Section, Program Support Staff (PSS), RII P. R. Bemis, Chief, Project Section 1C, PB 1, DPRP, RII D. 0. Myers, Senior Resident Inspector, DPRP, RII S. Weise, Senior Resident Inspector, DPRP, RII G. F. Maxwell, Senior Resident Inspector, DPRP, RII R. L. Prevatte, Resident Inspector, DPRP, RII G. Requa, Project Manager, Operating Reactors Branch 1, DL, NRR S. D. Mackay, Project Manager, Operating Reactors Branch 2, DL, NRR N. P. Kadambi, Project Manager, Licensing Branch 3, DL, NRR