ML15239A004
| ML15239A004 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Oconee |
| Issue date: | 06/19/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15239A003 | List: |
| References | |
| 50-269-86-02, 50-269-86-2, 50-270-86-02, 50-270-86-2, 50-287-86-02, 50-287-86-2, NUDOCS 8607100493 | |
| Download: ML15239A004 (38) | |
See also: IR 05000269/1986002
Text
JUN 19 1986
ENCLOSURE 1
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
Inspection Report Numbers
50-269/86-02; 50-270/86-02; 50-287/86-02
DUKE POWER COMPANY
OCONEE NUCLEAR STATION UNITS 1, 2, AND 3
September 1, 1984, through February 28, 1986
8607100493 860619
PDR ADOCK 05000269
I. Introduction
The Systematic Assessment of Licensee Performance
(SALP)
program is an
integrated NRC staff effort to collect available observations and data on a
periodic basis and to evaluate licensee performance based
upon this
information.
The SALP program is supplemental to normal
regulatory
processes used to determine compliance with NRC rules and regulations. The
SALP program is intended to be sufficiently diagnostic to provide a rational
basis for allocating NRC resources and to provide meaningful guidance to
licensee management to promote quality and safety of plant construction and
operation.
An
NRC
SALP Board,
composed of the staff members listed below,
met on
April 23,
1986,
to review the collection of performance observations and
data to assess licensee performance in accordance with guidance in NRC
Manual Chapter 0516,
"Systematic Assessment of Licensee Performance."
A
summary of the guidance and evaluation criteria is provided in Paragraph II
of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Oconee Nuclear Station for the period September 1, 1984,
through February 28, 1986.
SALP Board for Oconee Nuclear Station
R. D. Walker, Director, Division of Reactor Projects (DRP), RII (Chairman)
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII
V. L. Brownlee, Chief, Reactor Projects Branch 3 (RPB3), DRP, RH
G. E. Edison, Deputy Project Director, PWR Licensing Division B, NRR
H. Pastis, Project Manager (Oconee), PWR Licensing Division B, NRR
J. C. Bryant, Senior Resident Inspector, Oconee, DRP, RII
Attendees at SALP Meeting
R. D. Walker, Director, Division of Reactor Projects (DRP), RH (Chairman)
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RH
L. A. Reyes, Deputy Director, DRP, RII
V. L. Brownlee, Chief, Reactor Projects Branch 3 (RPB3), DRP, RII
G. E. Edison, Deputy Project Director, PWR Licensing Division B, NRR
H. Pastis, Project Manager (Oconee), PWR Licensing Division B, NRR
J. C. Bryant, Senior Resident Inspector, Oconee, DRP, RII
K. D. Landis, Chief, Technical Support Staff (TSS), DRP, RII
C. W. Burger, Project Engineer, RPB3, DRP, RII
J. K. Rausch, Reactor Engineer, TSS, DRP, RII
T. C. MacArthur, Radiation Specialist, TSS, DRP, RII
Enclosure 1
2
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.
Each functional area
normally represents an area which is significant to nuclear safety and the
environment and which is a normal programmatic area. Some functional areas
may not be assessed because of little or no licensee activity or lack of
meaningful NRC observations.
Special areas
may be added to highlight
significant observations.
One or more of the following evaluation criteria was used to assess each
functional area; however,
the SALP Board is not limited to these criteria
and others may have been used where appropriate.
A. Management involvement in assuring quality
B. Approach to the resolution of technical issues from a safety standpoint
C. Responsiveness to NRC initiatives
D. Enforcement history
E. Reporting and analysis of reportable events
F. Staffing (including management)
G. Training and qualification effectiveness
Based upon the SALP Board assessment,
each functional area evaluated is
classified into one of three performance categories.
The definitions of
these performance categories are:
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 quality is
being achieved.
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 quality is being achieved.
Enclosure 1
3
Category 3:
Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers 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 construction quality 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.
The SALP Board may also include an appraisal of the performance trend of a
functional area.
This performance trend will only be used when both a
definite trend of performance within the evaluation period is discernible
and the Board believes that continuation of the trend may result in a change
of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the
close of the assessment period.
Declining:
Licensee performance was determined to be declining near the
close of the assessment period.
III. Summary of Results
Overall Facility Evaluation
During this SALP assessment period, the Oconee facility was effectively
managed and achieved a satisfactory level of operational safety.
Strengths
were noted in the areas of plant operations, surveillance, fire protection,
emergency preparedness and outages.
The plant operations and the fire
protection functional areas have shown improvement due to well qualified
operating staffs.
Weakness was noted in the area of maintenance as
evidenced by the number of reactor trips attributed to maintenance work.
The radiological controls functional area needs improvement in its QC
programs and management review areas. The security functional area shows a
lack of interface between security departments and other departments in the
remainder of the plant. Of special note is the establishment of a new
division for integrated scheduling.
This effort should be effective in
improving overall operations particularly in the maintenance, surveillance,
and outages functional areas.
Enclosure 1
4
May 1, 1983 -
September 1, 1984
Functional Area
August 31, 1984
February 28, 1986
Plant Operations
1
1
Radiological Controls
2
2
Maintenance
1
2
Surveillance
1
1
Fire Protection
Not Rated
1
Emergency Procedures
1
1
Security and Safeguards
1
2
Outages
1
1
Quality Programs and
2
2
Administrative Controls
Affecting Quality
Licensing Activities
2
2
Training
Not Rated
2
IV. Performance Analysis
A.
Plant Operations
1. Analysis
During the evaluation period, routine inspections were performed
by the resident and regional staffs.
On day and night shifts
operations personnel were found to be alert, professional
and attentive to their duties. Plant housekeeping has improved
during the evaluation period,
and a major cleanup,
paintup,
decontamination program is in progress throughout the plant.
A special inspection was made by the Office of Nuclear Reactor
Regulation (NRR)
concerning plant susceptibility to "wrong unit
wrong train" events. In general, the plant was found satisfactory
in its approach to prevention of such events. During the assess
ment period,
one reactor trip occurred when
an
I&E mechanic
tripped the wrong train during a surveillance test.
The licensee
has a program for identifying all equipment with color coded, by
unit, signs listing the unit, system and equipment.
An INPO evaluation was conducted during the period.
The resident
inspectors reviewed the report and found that no serious problems
were identified. By inspection, the residents determined that the
licensee has taken positive action on those criticisms listed in
the INPO report.
Station management demonstrates commendable awareness of plant
operating conditions.
The inspectors have found the station
manager
and the department superintendents to be sufficiently
informed to discuss any event in detail.
The several layers of
management provide guidance and stay in touch without interfering
with SRO's and ROs in performance of their duties.
Enclosure 1
5
An evaluation of the content and quality of a representative
sample of the 38 Licensee Event Reports (LERs)
submitted by
Oconee 1, 2 and 3 during the SALP period was performed using a
refinement of the basic methodology presented in NUREG/CR-4178.
The results of this evaluation indicate that Oconee 1, 2 and 3
have an overall LER score in the top quarter of proficiency as
compared to the 49 units (i.e.,
licensees) that have
been
evaluated to date using this methodology.
The resident inspectors are kept informed of plant events and
reportable events are handled according to regulations.
The
approach to resolution of technical issues usually is very
thorough,
and the licensee has sufficient technical staff to
perform these duties.
The resident inspectors have found the
licensee to be responsive to issues expressed by themselves or
other NRC personnel.
During the reporting period, the licensee
initiated programs for rework of main steam code safety valves and
use of motor operated valve actuator testing (MOVATS) prior to
official NRC publications on the issues. Training of operations
personnel is kept current.
The inspectors witnessed simulator
training of personnel
concerning an event which occurred at
another site. The training took place just a few days after the
event and was quickly accomplished by calling in personnel on days
off where necessary.
The reactor operating staff is considerably larger than that
required by Technical Specifications (TS). Whereas TS require one
shift supervisor (SRO)
and two additional SROs for three unit
operation, the normal shift complement is the shift supervisor
plus six additional SROs. There are six RO's on shift rather than
the required five. Five nuclear equipment operators are required,
but the normal complement is eleven or twelve.
There are two
relief SRO's available; two SRO's on training at the Oconee
Technical Training Center (OTTC);
15 in the RO training class at
the OTTC;
and ten learners at the Technical Training Center
located near the McGuire site.
A degreed STA was added to the staff of each shift during the
reporting period.
These individuals are SRO licensed and STA
trained.
They report
to the Superintendent of Integrated
Scheduling.
One of their
normal
shift duties is priority
scheduling of shift maintenance personnel.
In addition to the shift operating engineer and his staff, to
support each reactor unit there is a unit operating engineer and
four assistant operating engineers.
These individuals are SRO
licensed and provide assistance, scheduling and continuity to the
operating staff. All licensed pesonnel are licensed on all three
units.
Enclosure 1
6
During the assessment period, Oconee Unit 2 completed a continuous
power production run of 439 days. Licensee efforts to improve the
quality of performance, aided by the plant simulator which became
operable at the end of the previous evaluation period, are having
a positive effect. There were no reactor trips caused by operator
error during the evaluation period.
Though there was an increase of one violation cited against
operations as compared to the previous assessment period, this in
not considered to be indicative of declining performance in
operation of the plant. The increase is partially due to a longer
evaluation period with a commensurate
increase in inspection
activity. One violation cited below concerns failure to delegate
administrative duties of the shift supervisor to non on-duty
personnel. This violation was essentially for failure to specify
in writing how these duties would be handled. As described above,
there are four extra SRO's on shift above technical specification
requirements.
These additional people normally handle any
required administrative duties.
Violations which were cited
against operations are as follows.
a.
Severity Level
IV violation for failure to delegate the
administrative duties of the shift supervisor to non-on duty
personnel.
(84-16, 15, 26)
b. Severity Level IV violation for exceeding permissible control
rod position limit at 15% power during power ascension.
(85-10)
c. Severity Level
IV violation for failure to log a valve
failure to open. All other required actions, including a
priority work request, were taken. (85-37)
d. Severity Level
IV violation for delay in shutdown for a
reactor coolant system leak.
Over a period of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />,
hourly samples varied from 0.65 gpm above the Technical
Specifications limit of 1.0 gpm to 0.38 gpm below the limit
while the licensee attempted to identify the leak. (85-41)
e.
Severity Level V violation for incomplete documentation of
the controlling procedure prior to startup.
All required
actions had been taken.
(84-36)
f.
Severity Level V violation for a work request not properly
classified as safety related. (85-21)
Enclosure 1
7
2. Conclusion
Category:
1
3. Board Recommendation
No recommended.changes in NRC inspection resources.
B.
Radiological Controls
1. Analysis
During the evaluation period, inspections were performed by the
resident and regional
staffs.
This
included confirmatory
measurements using the Region II mobile laboratory.
The licensee's health physics staffing level was adequate and
compared favorably to other utilities of similar size in that an
adequate number of ANSI qualified licensee and contract health
physics technicians were available to support routine and outage
operations. The radiological effluents control staffing levels
and staff qualifications were acceptable. Key positions in the
radwaste management program and
environmental
surveillance
programs were filled with qualified staff.
The strengths of the health physics program were the quality of
the health physics technicians and the experience level of the
corporate and site health physics staffs.
The staff has a low
turnover rate and an effective training program.
The understanding of technical issues and approaches to technical
problem solving were deficient in several areas of the licensee's
radiological measurements and measurements quality control
(QC)
program. Failure to resolve previously identified measurement and
calibration items regarding liquid scintillation and gamma
spectroscopy system analyses resulted in violations concerning
inaccurate liquid and gaseous effluent measurements,
failure to
meet required lower limits of detection for gaseous effluent
measurements, and failure to complete radiochemical analyses of a
significant proportion of environmental samples. Review of spiked
sample confirmatory measurement results indicated a need for
improvement in QC programs and in management review areas to
assure the capability to identify and correct inaccurate measure
ments associated with vendor nuclide analyses.
Additional technical areas needing timely managment evaluation and
action included evaluation of
systematic biases
noted for
whole-body
counting
activities,
improved
surveillance
and
maintenance of radiation effluent monitoring instrumentation to
ensure operability, and the evaluation and resolution of
identified inaccurate
measurements
associated with the
Post
Enclosure 1
8
Accident Sampling Systems
(PASS).
Although the licensee was
responsive to the violations as noted by their prompt corrective
actions, more timely evaluation and resolution of the effluent
monitor and PASS issues is needed.
The licensee submitted the required effluent and environmental
reports; however, the second half 1984 report was submitted one
month late. Failure of licensee representatives to review and
resolve delays concerning radiochemical analyses by their approved
vendor laboratory resulted in the late submittal.
Liquid and
gaseous data were within established limits for total quantities
and concentration of material released. No significant trends in
releases or in estimated dose were noted.
During the rating
period, the licensee met the reporting requirements for anomalous
results in selected environmental
samples;
however,
licensee
management
involvement was considered deficient in that they
failed to thoroughly evaluate dose estimates using all environ
mental pathways to meet the intent of 40 CFR
190.
Following
additional review, dose estimates were determined to be within
40 CFR 190 limits.
During the evaluation period, the licensee's radiation work permit
and respiratory protection programs were found to be satisfactory.
Control of contamination and radioactive materials within the
facility was adequate.
From January 1985 to January 1986,
the
amount of contaminated area decreased from approximately 56,000 to
17,000 square feet which represents a 69 percent decrease.
In
1985, there was a 10 percent decrease in the number of clothing
and skin contamination incidents when compared to 1984.
During the evaluation period from January 1, 1985 to December 31,
1985, the licensee's collective occupational dose was 1303 man-rem
or 434 man-rem per unit. This compares favorably to the national
average exposure of 425 man-rem per unit for pressurized water
reactors.
The licensee has established and implemented an
aggressive control program.
During the evaluation period from January 1 to December 31, 1985,
the licensee disposed of 33,507 cubic feet of solid radioactive
waste containing 2,069 curies.
This is quite close to the
national average of 11,650 cubic feet per unit shipped by other
PWR facilities. However,
the radwaste shipping area resulted in
one violation for failure to transport radioactive material in a
strong, tight container.
Enclosure 1
9
Nine violations were identified:
a. Severity Level III for failure to transport radioactive
material in a strong, tight package as required by 10 CFR
71.5(A).
(85-03)
b. Severity Level IV for failure to have adequate procedures for
radiological effluent measurements. (84-30, 29, 32)
c. Severity Level IV for failure to meet detection limits for
radiological environmental samples.
(84-19, 18, 20)
d. Severity Level IV for failure to document E-bar calculations
correctly on
some occasions and,
in one case,
to base
calculations on 45 minutes elapsed time rather than the
actual elapsed time of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, 15 minutes. (85-26)
e. Severity Level
IV for failure to adequately control the
access to high radiation areas
as
required
by
10 CFR
20.203(c)(2).
(85-42)
f. Severity Level V for failure to meet required lower limits of
detection (LLD) for effluent measurements.
(84-30, 29, 32)
g. Severity Level V for failure to label containers of radio
active material as required by 10 CFR 20.203(f).
(85-30)
h.
Severity Level V for failure to post an airborne radio
activity area as required by 10 CFR 20.203(d).
(85-33)
i. Severity Level V violation for failure to address inoperable
effluent monitors in a semi annual report. (85-20)
2.
Conclusion
Category:
2
3. Board Recommendations
Licensee attention in this area was evident; particularly in the
staffing of health physics key positions.
It appears, however,
that there is room for improvement in the licensee's timeliness in
evaluating and resolving issues,
i.e., effluent monitor
and
post-accident sampling system.
Enclosure 1
10
C. Maintenance
1..
Analysis
During the evaluation period, maintenance performance was
inspected by regional and resident inspection staffs. Units 2 and
3 were each refueled during the assessment period; Unit 1 began
the period during a refueling outage and ended the period in
another refueling outage. Much of the maintenance work inspected
occurred during these outages and is discussed in the outage
section of this report.
The
maintenance
program
is well
organized and demonstrated
evidence of adequate planning and priority assignment; maintenance
procedures were generally adequate, complete and well maintained.
Licensee reponse to resident inspector and other NRC initiatives
has been satisfactory. The maintenance department is well staffed
and has made several major changes in staffing in the past three
years. In addition, there are initiatives in work to improve
capabilities of the personnel.
These changes are discussed below.
In
1983,
prior to the current assessment period, maintenance
personnel joined the operations rotating shifts.
Mechanical
maintenance has a supervisor and six mechanics on each shift,
while there is an Instrument and Electrical (I&E)
supervisor and
four technicians on each shift. This closer working relationship,
in addition to improved availability of maintenance personnel,
appears to be having a positive effect.
The maintenance department has a planning and scheduling section
for mechanical, I&E, and outage maintenance. While priorities and
timing are established by the Integrated Scheduling Department, as
described in the Surveillance Section of this report, the details
are handled by this 41 person section.
In addition to the scheduling section, plant maintenance has a
mechanical maintenance staff of about 160 persons and an I&E staff
of approximately 130. Also stationed at the Oconee site is the
Duke Power
Company
Construction
and Maintenance
Department
(CMD)-Southern Division, with a staff of approximately 350 persons
in the maintenance portion of CMD. These people are scheduled by
the Planning and Scheduling Section,
as needed,
to augment the
Plant Maintenance Department. CMD also supplies vendor assistance
as needed. Other off-site divisions of Duke Power Company provide
assistance where needed. The construction portion of CMD performs
modifications to the plant and also supplies, as needed, builders
for scaffold erection and other such work, bringing the available
work force for outages to about 1000 people.
This large pool of
personnel available for maintenance is a major asset.
Enclosure 1
11
Training of maintenance
personnel
is conducted at the DPC
facilities near Charlotte, at the Oconee site, and at vendor
training facilities where appropriate. A part of the DPC Employer
Training Qualification System
(ETQS),
which is a formalized
program including verification and documentation of skills, is
evaluation of each employee by his own supervisor and another for
the specific training needed to prepare him for any work to which
he may be assigned.
CMD maintenance employees are being brought into the ETQS program
with the goal of bringing them to the same level of proficiency as
the plant maintenance staff. The ETQS will verify the qualifica
tions of Oconee maintenance and interfacing maintenance support
personnel prior to their performing work.
Other initiatives in work include bringing the engineering groups
into closer relationship with mechanics and technicians to form
logical working groups and allow engineers to better understand
maintenance; concentration of persons on major problems; review of
equipment for the quality of maintenance and study by management,
engineers,
and other qualified personnel to improve the quality;
upgraded procedures, tooling, training and dedicated personnel to
specific work to enhance quality; electrical circuit analysis; and
bringing ALARA into planning and the work group to establish
responsibility there.
Planned to begin in 1986 and to be
completed in 1987 is a maintenance training center at Oconee.
The resident inspectors latest review of the maintenance backlog
revealed no problem with maintenance being kept current, but there
was a considerable backlog of station modifications.
During the
assessment period,
DPC assigned 14 additional engineers to the
site for a period of two years to study the backlog items for
relevance and to get the work brought up to date.
Four of the 15 reactor trips which occurred during the assessment
period may be attributed to maintenance work in progress at the
time.
a.
On April 26,
1985,
Unit 2 tripped from 72% power due to a
problem in the electro hydraulic control (EHC)
system.
At
the time,
maintenance personnel
were working inside the
cabinet. Examination revealed no questionable components.
b.
On July 10,
1985,
Unit 2 tripped while a mechanic was
investigating a problem with the ICS turbine header pressure
control. As he plugged in a test meter, a noise signal was
introduced causing turbine control and intercept valves to
close.
Enclosure 1
12
c.
On January 31, 1986, Unit 2 tripped while switchyard breaker
testing and maintenance were in progress.
A misalignment of
circuits, when a test signal was introduced, caused a load
rejection
resulting
in a generator/turbine/reactor
anticipatory trip.
d.
On January 31, 1986, Unit 1 tripped while switchyard breaker
testing and maintenance were in progress.
A combination of
one bus being out of service related to the Unit 2 trip four
hours earlier, and a miscommunication between a switchyard
mechanic and the control room caused Unit 1 generator output
to transfer to a single breaker.
The single breaker is
designed to accept the full load, but it failed to do so.
The maintenance personnel at work during trips c and d are
not a part of Oconee maintenance. Eight of the remaining 11
trips were the result of equipment failure.
Three violations were identified in the maintenance area as listed
below.
a. Severity Level IV violation for failure to file a noncon
forming item report in a timely manner. A Cuno filter in the
low pressure service water system had been installed in the
reverse direction.
When the error was discovered after the
system had been in operation for some time, corrective action
was taken immediately but the NCI report was not filed.
(84-28)
b. Severity Level IV violation for returning a modified sample
line to service prior to Design Engineering review of the.
change. Material of below required wall thickness had been
used. (85-41)
c. Severity Level V violation for inadequate development and
implementation
quidance for
breaker inspection and
maintenance activities.
Specific recommendations in the
vendor manual had not been included. (85-21)
2.
Conclusion
Category: 2
3.
Board Recommendation
The Board notes indications of strong management participation in
this area. No change in NRC inspection activity is recommended.
Enclosure 1
13
D. Surveillance
1. Analysis
During the assessment period, inspections of surveillance
activities were performed by the regional and resident inspection
staffs. The inspectors witnessed selected operational surveil
lances of reactor protective systems,
pump and valve operations,
calibration of instruments and others, and reviewed completed test
procedures. Startup tests and low power physics testing were
witnessed.
During outages, the inspectors witnessed and/or
reviewed inservice inspection activities, reactor vessel examina
tion,
performance testing of pump and valves,
and tendon and
snubber surveillance.
The quality of procedures in use was found to be good, and there
was evidence of prior planning and assignment of priorities.
Procedures were controlled and contained sufficient detail for the
control of activities.
Completed procedures were reviewed by
managers and by senior reactor operators. Surveillance activities
were conducted by qualified personnel,
and as witnessed by the
inspectors, suitable levels of management
became involved when
problems arose. Surveillances were supported by a competent QA
organization.
The Performance Section, which conducts surveillances, has a staff
of 33. These are knowledgeable engineers and technicians.
The
inspectors have found this group to be very professional. Actual
manipulation of equipment is performed by operators and mainte
nance personnel.
During the assessment period,
the licensee established a new
division for integrated scheduling.
This division handles the
overall schedule for operations, surveillance, maintenance and
outages. While the affected divisions do the detailed job
planning and manpower allocation, the new division considers the
overall plant needs and establishes priorities and time frames for
work performance. The permanently assigned integrated scheduling
engineer for each unit conducts the daily outage meetings when a
unit is shut down.
The division produces the integrated schedule
for the entire refueling outage to avoid conflicts between the
various departments, and resolves conflicts on a daily basis when
they occur.
The division also schedules the priorities for
surveillance and maintenance during operation.
The integrated scheduling division is headed by a superintendent,
indicating the priority assigned to the group.
This superinten
dent is completing SRO training.
While this training is not an
NRC requirement for the position, all of the plant superintendents
are SRO trained or are being trained.
Enclosure 1
14
Some
problems identified in the surveillance area included a
determination that the temperature and humidity of the instrument
calibration shop was not routinely verified although specified
requirements for temperature and humidity were in effect for some
instrument calibrations.
The licensee relied on
the
air
conditioning system to maintain the shop within the necessary
parameters during calibration. Another inspection determined that
trains A and B of the containment hydrogen monitoring system were
technically inoperable for a twenty day period due to inability to
calibrate the instruments to the specified tolerance.
The
licensee was aware of the problem and was attempting to resove it.
A technician,
while performing
a reactor protection
system
calibration and test, mistakenly tripped breakers in the wrong
channel. This resulted in a reactor trip.
This was a personnel
error and the only instance of wrong unit-wrong train error
identified during the assessment period.
The three violations cited against surveillance are listed below.
a.
Severity Level IV violation for failure to verify on a
regular basis that instrument shop temperature and humidity
met procedure requirements. (85-04)
b. Severity Level
IV. violation for allowing the containment
hydrogen monitor to be technically out of service for a
period of twenty days. (85-25)
c.
Severity Level IV violation for failure to follow procedure,
despite independent verification, in surveillance of a
resulting in a reactor trip.
(86-01)
2. Conclusion
Category:
1
3. Board Recommendation
The Board notes that the licensee's new division for integrated
scheduling has a potential for providing new initiatives in this
area. No change in NRC inspection activity is recommended.
E.
Fire Protection
1. Analysis
During this assessment period, inspections were conducted by the
regional and resident inspection staffs of the licensee's fire
protection and fire prevention program.
The licensee's imple
mentation of the 10 CFR 50,
Appendix R, safe shutdown capability
and associated fire protection features was not reviewed during
Enclosure 1
15
this assessment period. Resident inspectors witnessed a number of
fire drills including those where offsite support organizations
reported to the site and participated in the drill.
The licensee has issued procedures for the administrative control
of fire hazards within the plant, surveillance and maintenance of
the fire protection systems and equipment,
and organization and
training of a plant fire brigade.
These procedures were reviewed
and found to meet NRC requirements and guidelines.
The inspectors reviewed the licensee's implementation of the fire
protection and administrative controls. General housekeeping and
control of combustible and flammable materials were in need of
improvement
in several plant areas but corrective action was
promptly initiated. The fire protection extinguishing systems,
detection systems and fire barriers and fire barrier penetrations
were found to be in service.
Surveillance inspection and tests
and maintenance of the fire protection systems and features were
satisfactory except for the failure to conduct the semi-annual
surveillance on the licensee's C02 system. However, this item was
properly identified and reported to the NRC.
Organization and staffing of the plant fire brigade meet the NRC
guidelines. The training and drills for the brigade members meet
the frequency specified by the procedures and the NRC guidelines.
The annual fire protection/prevention audit and 24 month QA fire
protection
program audit by offsite organizations and the
triennial audit
by
an
outside fire protection organization
required by the Technical Specifications were reviewed.
These
audits were conducted within the specified frequency and covered
all essential elements of the fire protection program.
The
licensee had
implemented
corrective action
on
discrepancies
identified by the audit.
The licensee apparently identified, analyzed, and reported fire
prevention
events and discrepancies
as required
by
license
condition or Technical Specifications.
These reports were
reviewed and found to be satisfactory.
In general,
the management involvement and control in assuring
quality in the fire protection program is evident due to frequent
involvement in the site fire protection program and well
developed, issued and implemented protection administrative
procedures. The licensee's approach to resolution of technical
fire protection issues indicates an understanding of issues, and
is geared toward meeting the
requirements.
However, the
licensee's implementation of the 10 CFR 50, Appendix R fire
protection and
safe shutdown requirements have not yet been
verified by the NRC.
The responsiveness to NRC initiatives are
generally timely and thorough. Fire protection related violations
Enclosure 1
16
are rare. However, when violations do occur, effective corrective
action is promptly taken.
Licensee identified fire protection
related events or discrepancies are properly analyzed, promptly
reported and effective corrective action taken.
Staffing for the fire protection program is adequate to accomplish
the goals of the position within normal work hours with only
occasional overtime or backlog of work.
Fire protection staff
positions are identified and authorities and responsibilities are
clearly defined.
Personnel
are qualified for their assigned
duties. The fire brigade training program is well defined and
implemented.
No violations or deviations were identified during this assessment
period.
2. Conclusion
Category:
1
3. Board Recommendations
The Board notes that the licensee's implementation of the
Appendix R was not reviewed during this period.
The
Board recommends that NRC inspection activities determine this at
an early date.
1. Analysis
During this assessment period,
inspections were performed by
regional
and
resident
inspection
staffs.
These included
observation of a small-scale exercise and two routine inspections
addressing emergency response and related implementing procedures.
The resident inspectors participated in the technical
support
center during a number of drills.
Routine inspections and exercise observations indicated that the
emergency organization and staffing were adequate. The corporate
emergency planning organization provided adequate support to the
plant. Key positions in corporate and plant emergency response
organizations were filled.
Corporate management appeared to be
committed to maintaining an effective emergency response program,
and was directly involved in the annual exercise and the followup
critique. Critiques were held following periodic drills as well
as the annual exercise and appropriate corrective actions were
taken to resolve identified problems.
Enclosure 1
17
Personnel assigned to the emergency organization understood their
emergency response roles and were adequately trained in required
areas
of emergency
response.
During
routine
inspection
interviews, walkthroughs and exercise observations, the emergency
response
personnel
adequately
identified
and
classified
hypothetical emergency events. The emergency response organiza
tion
promptly made
required
notifications,
and
provided
appropriate protective action recommendations. During the annual
exercise, however, the following findings were identified by the
NRC for corrective action: (1) radiological field teams failed to
define plume dimensions and identify the plume center line;
(2) frequent prompting of players by controllers and excessive
dialogue between controllers and players.
Corrective actions
initiated by the licensee for these findings included additional
training of radiological field teams and training regarding the
limit of interactions between controllers and players.
No
violations were issued for actions during the exercise, because
one purpose of such exercise is to identify weaknesses in program
implementation so that corrective actions can be taken by the
licensee.
The following essential elements for emergency response were found
acceptable: Emergency classification; notification and communica
tions; public information; shift staffing and augmentation;
emergency preparedness training, except as noted above;
dose
projection and assessment;
emergency worker protection;
post
accident measurements and instrumentation;
changes to the
emergency preparedness program;
and annual
quality assurance
audits of the plant and corporate emergency preparedness programs.
The exercise demonstrated that the plan and procedures could be
effectively implemented in the areas of communications, accident
assessment, and exposure control.
The emergency response
facilities, namely the TSC and OSC,
and the equipment therein,
were adequate to support radiological emergency events.
The
interim EOF,
however, requires additional available space and an
improved configuration. A permanent facility is planned. Current
use, however,
does not compromise
response capability.
The
licensee demonstrated
an adequate working relationship with
offsite emergency support organization.
No violations were identified regarding the licensee's implementa
tion of the emergency preparedness program.
2. Conclusion
Category:
1
3.
Board Recommendation
The Board recognizes an improving trend and has no recommended
changes in NRC inspection resources.
Enclosure 1
18
G.
Security and Safeguards
1. Analysis
During this evaluation period, various routine inspections were
performed by the resident and regional
staffs.
The
NRC's
Regulatory Effectiveness Review was also performed during this
period.
The licensee utilizes a contract security force which is monitored
by proprietary Security Technical Associates who continually audit
the
contractor
and
resolve
licensee
identified issues.
Additionally,
the contractor has its own Contract Compliance
Review Program which ensures each security shift adheres to the
licensee's approved security procedures.
During
this
evaluation
period,
inspectors witnessed
the
performance of the security force during various back-shifts.
During these irregular hours the security force appeared well
staffed, adequately equipped and professional in the conduct of
its routine duties.
A small turnover rate has allowed the
licensee to establish a reliable corps of experienced and
knowledgeable security officers. As noted in the previous SALP
report,
one strength in the licensee's security program is an
aggressive implementation of its Training and Qualification Plan.
The security shifts are not encumbered with extensive compensatory
measures necessary for failed security equipment.
This reflects
plant management's
attention
to
maintenance
and
setting
appropriate priority to the repair of security related hardware.
The licensee is in the final transition of upgrading its security
alarm system to include a new alarm station facility.
While the licensee has experienced an unusual increase in the
number and severity level of security related violations, they are
not indicative of a major security breakdown.
Upon analysis of
the trend, it appears that the majority of the violations are
symptomatic of problems associated with people,
procedures and
documentation, versus hardware and equipment. Specifically, two
of the five violations listed below concern degraded security
barriers and are attributable to a lack of a comprehensive
interface between the security organization and other departments
of the plant.
A third violation deals with
an
inadequate
procedure and a fourth violation concerns inadequate documenta
tion.
Although the licensee has corporate and site management support of
its security program,
it
appears that intraplant communication
needs to be emphasized so that non-security individuals are aware
of their security responsibilities.
Enclosure 1
19
The violations identified were as follows:
a. Severity Level III due to inadequate security barriers.
(85-39) Civil Penalty of $25,000 issued.
b. Severity Level IV for having an unattended security barrier
breach. (85-28)
c. Severity Level IV due to an electronic alarm annunciation
failure. (85-28)
d. Severity Level V for failing to have adequate records.
(85-28)
e.
Severity Level V due to
an
inadequate alarm testing
procedure. (85-05)
2. Conclusion
Category: 2
3.
Board Recommendation
No change in NRC inspection activity is recommended.
H. Outages
1. Analysis
During this evaluation period, routine inspections were performed
by the resident and regional inspection staffs.
All three units
were refueled during the period.
The inspectors reviewed the
comprehensive shutdown schedule which integrates work schedules
for all groups; operations,
maintenance, testing and surveil
lances. The newly established integrated scheduling division is
discussed under Surveillance.
The inspectors reviewed prepara
tions for refueling, including controls on receipt, inspection and
storage of new fuel,
inspection of facilities for fuel handling,
reviewed records on selected new fuel assemblies, verified that
adequate procedures were on hand for all phases of the operation,
and verified that procedures met Technical Specification
requirements.
The inspectors witnessed refueling from the refueling floor, the
control room and the spent fuel area to verify that preparations
and conditions prior to and during core alteration were
in
accordance with licensee and NRC requirements.
Enclosure 1
20
Major work performed during
the outage
included inservice
inspection activities, reactor vessel examination,
performance
testing of pumps
and valves,
replacement of main feedwater
nozzles, letdown cooler replacement, reactor coolant pump and main
turbine refurbishment,
sludge lance and water slap cleaning of
steam generators, rework of several hundred valves on each unit,
installation of reactor vessel level instrumentations (RVLIS)
on
Unit 1, installation or adjustment of safe shutdown makeup pumps,
rework of main steam code safety valves, installation of control
room display system,
and Motor Operated Valve Actuator Testing
System (MOVATS) analysis of several motor operated valves.
Areas
inspected included replacement of main feedwater flow
nozzles,
letdown cooler replacement, reactor coolant pump
refurbishment, activities associated with IE Bulletins 79-02 and
79-14, disassembly and repair of an emergency feedwater
pump
turbine, rework of code safety valves, repair of a control rod
drive, replacement of an inner hatch seal, RVLIS installation, and
MOVATS testing.
The large Duke Power Company work force available on site and from
off site is discussed in the maintenance section of this report
along with qualification and training of the force.
Also, the
integrated scheduling group,
which plays a large part in outage
performance, is discussed in the surveillance section. Refueling
outages are scheduled to last about 59 days,
and the outages
usually are very close to this schedule unless unanticipated
problems are encountered.
The licensee had been responsive to inspector concerns as
evidenced by an extensive program to rework main steam code safety
valves due to a delay in reseating of some valves after a reactor
trip. The normal relief settings for some of the valves is 1050
psig, with blow down set at 3%. The turbine stop valves maintain
pressure after trip at 1025 psia to control pressurizer level,
bringing the maintained pressure
and
blow
down
very close
together. The problem is under study by the licensee.
In addition to refueling outages and reactor trips, there were 12
shut downs for maintenance during the assessment period.
a. Units 1 and 3 were each shut down once for steam generator
tube leaks.
b. Unit 2 was shut down for steam generator pulse cleaning and
water slap cleaning.
c. Unit 1 was shut down to repair a leak on the nitrogen decay
tank drain valve and was returned to criticality on the same
day.
Enclosure 1
21
d. Unit 2 was shut down to repair a leak on an instrument root
valve and again three months later to repair a leak on
another instrument root valve.
e. Unit 3 was shut down to repair leaks in a moisture separator
reheater tube bundle.
f..
Unit 3 was shut down twice to add oil to a reactor coolant
pump reservoir.
g. Unit 3.was shut down due to leakage past "O" rings on the
reactor vessel
head soon after start up from refueling.
Several other leaks were repaired.
h. Unit 3 was shut down due to an overheated bearing on the high
pressure turbine. This bearing had been replaced during the
recently completed refueling outage during routine turbine
overhaul.
The same bearing failed the second time after
about a weeks operation.
At this time,
extensive efforts
were made to bring the entire turbine into as near perfect
alignment as possible. The shaft and bearing surfaces were
also reworked. No other problems were experienced.
It
appears that the leaks after startup and turbine problems
indicate possible weakness in the maintenance
program.
The
licensee has stated that, although turbine alignment was within
specifications, apparently it would be necessary to bring them
into original, or as new, alignment.
Considering the large number of workers and the scope of shutdown
work, few violations were cited during the refueling outages. A
violation was cited concerning welding of the main feedwater
nozzles in that weld filler metal in use had no coupons tested in
the heat treated condition, while some of the welds in which this
material
was used had
been heat treated.
Another violation
involving the feedwater flow nozzles concerned failure to apply
post weld heat treatment to the weld procedure qualification test.
A third violation concerned release of reactor coolant pump studs
for use, installation of the studs, and declaration of the pumps
to be operable even through a documentation problem existed on the
material
used for stud fabrication.
The violations cited are
listed below.
a. Severity Level IV violation for use of weld filler material
which had not been tested to code requirements stipulated by
the purchase order. (85-27)
b. Severity Level IV violation for use of a weld procedure which
had not been properly qualified for the work being performed.
(85-27)
Enclosure 1
22
c. Severity Level IV violation for use of reactor coolant pump
studs for which Duke Quality Assurance Manual cerification
requirements had not been met. (85-27)
2. Conclusion
Category: 1
3. Board Recommendation
The Board notes that a new division for integrated scheduling has
been established which should result in new initiatives and
positive attributes.
I. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
During this assessment period, routine inspections were performed
by resident and regional
staffs.
The following areas
were
reviewed by the regional staff during this period:
QA program,
QA/QC administration, procurement, receipt, storage and handling,
design control,
test and
experiments, measuring and test
equipment,
and surveillance testing and calibration control.
In
addition, a special,
announced team inspection was performed by
regional, resident and contract personnel to assess the licensee's
compliance with Generic Letter 83-28, "Required Actions Based on
Generic Implications of the Salem ATWS Events".
Areas inspected
included:
Post-trip review; equipment classification; vendor
interface and manual control; surveillance and post maintenance
testing; and reactor trip system reliability.
The licensee
management appeared to be adequately involved in assuring quality
and has been responsive to NRC initiatives. This was observed by
the scheduling, developing, reviewing and submittal of adequate
responses to GL 83-28 which entailed management participation.
The licensee's responses reviewed for GL 83-28 were determined to
be timely, concise, and adequate.
Review of licensee responses
revealed that they understood the requirements of GL 83-28 and had
adequately resolved technical issues.
Review of the test and experiments program identified that it was
well developed and procedurally delineated.
Technical issue
resolution from a safety standpoint was clearly demonstrated by
use of a nuclear evaluation checklist for performance of nuclear
safety evaluations.
Additional management involvement in this
area was further demonstrated by the licensee's present.effort to
enhance and improve the nuclear evaluation checklist for better
evaluation of nuclear safety issues.
Enclosure 1
23
The licensee was responsive to
NRC concerns as evidenced by
successful closure of violations relating to quality, which were
identified in various functional areas.
QA/QC administrative procedures were found to be exemplary in
style and scope,
and the personnel within this group appeared
knowledgeable
of
QA program
changes
and
implementation.
Additionally, QA program procedures appeared well written. The QA
staff had a positive attitude toward the implementation of the QA
program. The commitment tracking system was well developed.
In samples reviewed by the inspectors, the Q-list appeared well
defined, clear, and concise in defining those structures, systems,
components,
documents,
and activities to which the QA program
applies. During this assessment period, a special review by IE
headquarters personnel found the Q-list to be one of the best they
had reviewed. During this assessment period, a team inspection
was conducted which reviewed the licensee's response to Generic
Letter 83-28. This team identified two violations. One concerned
failure to follow procedures for classifying safety-related work
requests. This violation was attributed by the inspectors to be
due to a lack of detail in one area of the Q-list and inadequate
training provided for classifying safety-related work activities.
The resident inspectors have also discussed with the licensee
possible loopholes in use of the Q-list in determining the need of
QA review of job plants.
Another violation concerned failure to incorporate appropriate
vendor recommendations and acceptance criteria into the procedure.
The inspectors noted that this appeared to be an isolated instance
and not a program breakdown.
However,
it
is listed in this
section of the report since the work is performed by non-site
personnel.
The team inspections found that in the area of post-trip review,
the licensee has prepared
and revised procedures to define
responsibilities, authorities, methods of assessment, training,
and equipment
needed to perform a timely technical post-trip
review. Interviews revealed that plant personnel preparing and/or
reviewing the post-trip documentation were familiar with plant
systems, equipment, and operations.
Examination of documentation and interviews with
licensee
personnel confirmed that the licensee's administrative controls
were being implemented during the procurement of safety-related
items and services.
Observations of the receipt, storage,
and
handling process made it
apparent that these activities were
accomplished in accordance with regulatory standards and the
licensee's QA program.
Enclosure 1
24
The current data and information collection systems used at the
plant are considered adequate for the evaluation of unplanned
reactor trips; however, the licensee is planning and installing
enhancements to the plant's data collection. The Safety Parameter
Display system is operational on all units.
Other violations listed in this section were identified during
inspections of other areas, but were considered to be of corporate
origin or of a programmatic
nature.
These include late or
incomplete reports to the NRC.
The craft personnel
performing surveillances appeared to be
knowledgeable of the procedures and equipment.
QA records of
surveillances and maintenance were well maintained and retriev
able.
Four violations were identified:
a.
Severity Level IV violation for failure to determine
inspection requirements and other variables affecting quality
prior to implementation of a modification.
(85-06)
b.
Severity Level IV violation for failure to comply with a
Technical Specification which requires the Shift Technical
Advisor (STA)
to report to the Operating Engineer and to
advise the shift Supervisor. (84-16, 15, 26)
c. Severity Level IV violation for failure to submit an annual
report of nuclear station modifications within the required
time frame. (85-11)
2. Conclusion
Category: 2
3. Board Recommendation
The Board notes that there is a lateness of reports.
Further
attention on the part of licensee management is needed. No change
in NRC inspection activity is recommended.
J.
Licensing Activities
1. Analysis
This performance assessment is based on our evaluation of the
licensee's performance in support of licensing actions that had a
significant level of activity during the evaluation period. These
actions include licensee request for amendments and exemptions or
Enclosure 1
25
relief from regulatory requirements, responses to generic letters,
and various submittals of information for multi-plant and
actions.
Licensing
actions were completed as
delineated in Supporting Data,Section V.C.
Management's
involvement and control in assuring quality has
improved somewhat since the last reporting period.
Submittals
have improved in quality,
including the descriptions
for
pre-noticing under
a no significant or significant hazards
determination. Management has also shown aggressive participation
in resolving the problem of disposing of low-level contaminated
waste to areas other than licensed low-level radioactive waste
burial sites.
Participation has improved to resolve the
issue, III.D.3.4,
"Control
Room Habitability".
Improvement has also been observed
in visits to headquarters and the Oconee site.
Meetings have
become more effective, management participation has increased, and
participants have all the necessary information.
The Duke staff and key personnel
possess an excellent working
knowledge
and
history of the plant.
The efforts of the
engineering staff have been effective in resolving technical
problems.
An area that continues to need improvement is management attention
for anticipating potential problems with,
and scheduling,
the
submittal of major reviews.
An emergency TS change was processed
in April 1985 for Oconee Unit 3 and much of the information to
support the amendment could have been given to the staff earlier
in the event. Also the lack of information delayed resolution of
the delayed response regarding certain General Electric reactor
trip breakers under-voltage trip attachments.
Many submittals
that could have been anticipated have been given to the staff with
minimal time for review. This can be seen in the steam generator
sleeving submittal and request for a license extension.
Usually,
submittals are timely but recently there have been several
untimely submittals.
Usually, management attention is evident on major issues and in
difficult issues needing resolution.
Additionally,
Duke
has
generally improved on submitting reload reviews on a more timely
basis to allow adequate time for NRR review.
One exception to
this however, occurred for Oconee 1 cycle 9 when the amendment had
to be issued before the prenotice comment period expired.
Enclosure 1
26
Duke has continually exhibited an excellent understanding of
technical issues and has usually endorsed resolutions which have
been acceptable to the
Commission's
staff.
When resolving
technical issues, Duke has generally expressed conservatism from
the safety standpoint and has usually presented a sound approach
to resolving issues. When proposing an approach to resolve any
safety concern or to meet any regulatory requirements,
Duke has
usually proposed acceptable solutions.
Duke seems to follow closely the regulatory environment and takes
an active role from the safety standpoint.
Duke consistently
takes the lead for the nuclear industry to help resolve matters of
generic concern.
For example, Duke has participated in Babcock
and Wilcox Owner's Groups and has proposed to participate in
programs or studies that have or will be used at other utilities.
Some examples include Duke participating in the regulatory
effectiveness program to improve the regulations and the TS
improvement program to improve the TS. Other programs include the
reliability engineering study and probabilistic risk assessment
study.
NRR has met with the licensee several times during this review
period. Duke has generally been well prepared,
responsive and
made a concerned effort to resolve the issues.
When
major
differing positions occurred between the staffs, Duke was
professional and endeavored to resolve all questions.
Overall,
the meetings were generally informative and productive.
However,
some licensing actions (e.g., overtime limits and Shift Technical
Advisor) required repeated submittals and several years to resolve
and the delays were attributable to the licensee.
Oconee Nuclear Station has been visited by various staff members
and consultants for gathering information. Although under a heavy
schedule, Duke has been courteous, cooperative, and informative.
Duke has tried to meet deadlines and notified NRR when they cannot
be met.
Our observations from various plant tours is that housekeeping is
excellent. A concerted effort to maintain a clean facility was
evident throughout the plant and especially so in the common
turbine bay.
Regarding control room behavior, our observations indicate that
the operators act in a professional and responsive manner.
The
operators were attentive to plant conditions and responsive to
control room annunciators.
Enclosure 1
27
Based on an
NRR evaluation of licensing activities during the
period from September 1, 1984 to February 28,
1986,
no major
deficiencies affecting licensing activities became apparent. Duke
has improved
on
the quality- of the
submittals.
However,
continuing effort needs to be devoted for the timeliness of some
submittals.
The licensee's approach to the resolution
of
technical issues is generally sound and conservative; and the
licensee is usually responsive to NRC initiatives.
One violation was identified in the licensing activities area.
Severity Level V violation for failure to report revisions to
the FSAR within the required time frame. (85-20)
2. Conclusion
Category: 2
3. Board Recommendation
None noted.
K. Training
1. Analysis
During the assessment period, routine inspections of plant
training programs were performed by Regional and resident
inspection staffs. A special team assessment of Oconee training
programs was conducted early in the SALP period to determine the
effectiveness of the licensee's overall training
program
in
supporting safe operation of the facility. Toward the end of the
SALP period, the Division of Human Factors Technology conducted a
special post-accreditation audit of INPO accredited training
programs.
The Oconee Training Center is located adjacent to the Oconee site
and is used to train plant specific (Oconee)
operators.
The
facility has
11,600 sq.
ft. of space devoted to classrooms,
offices, and the Oconee simulator including a public viewing area.
The Mount Holly Training facility located approximately ten miles
north of the Duke Corporate Office in Charlotte, N.C. is used for
Mechanical Maintenance Training and Health Physics training. This
facility was just recently put into use in January 1986 and
occupies 31,600 sq. ft.
of classrooms, shop facilities, and
offices.
These facilities and those mentioned in the McGuire training
section represent an extensive commitment to training.
Enclosure 1
28
Although inspections revealed several specific and programmatic
weaknesses in the various plant training programs,
management
responsiveness and commitment, in general, resulted in an overall
improvement in the area of training.
A notable example of management's initiative was the development
of the Employee Qualification and Training System
(EQTS)
to
control
and implement formalized on-the-job (OJT) training
requirements.
The
EQTS,
once fully implemented,
will correct
programmatic deficiencies apparent in the non-licensed operator
(NLO)
and maintenance OJT programs during the assessment period.
Adequate facilities were provided for the support of plant
training and the enhancement of instructional delivery.
The training department appears well staffed and has a low
turnover rate. The facility has, in general, a low turnover rate
of both licensed and non-licensed personnel.
This is attributed
primarily to Duke's hiring and training practices of local
personnel.
Operating staff training, knowledge of the facility, and attitude
appeared to be good.
Sixteen persons took the Senior Reactor
Operator (SRO)
examination with ten passing; five persons took
partial Reactor Operator
(RO)
examinations,
carried over from
previous licensing applications, and all of these persons passed.
This performance was not as good as the last rating period, but
still is comparable to the industry norm.
Simulator instruction was well
structured; however, several
scenarios were not included in the simulator portions of initial
reactor operator and senior reactor operator training programs.
These programs did not provide for proficiency demonstrations in
solid plant pressure control, inert gas bubble pressure control,
and filling the pressurizer to a solid condition and creating a
steam bubble. A direct approach to combat an ATWS malfunction was
not available and the senior operator training program did not
provide sufficient real time practice in
performing routine
heatup, startup, shutdown, and cooldown.
The licensee performed a table top analyses of the NLO and RO
programs to produce a list of the tasks that are performed in
these jobs which were linked to learning objectives in lesson
plans; however, there was no task list for the SRO/STA position.
In many cases, the learning objectives did not include conditions
or standards, or were too broad and vague to link to test
questions. Because of these shortcomings,
the training program
did not meet two to five elements necessary for effective
performance-based training contained in the Commission's Policy
Statement on training and qualifications.
Enclosure 1
29
Administrative deficiencies were noted in the operator training
and retraining programs.
A controlled administrative procedure
was not available to define the licensed operator (LO)
training,
license requalification training and the non-licensed requalifica
tion training programs and to ensure the appropriate administ
ration of revision, review and
approval of these training
programs. Contradictions observed in the participation of backup
licensees and
licensed instructors in the licensed operator
requalification program and the licensee's failure to provide a
formal program description for the Accelerated Requalification
Program were also symptomatic of the lack of controlled documents
detailing the administration of plant training programs.
A significant programmatic weakness in the licensee's operator
training program was the lack of system texts coupled with the
inconsistent format of instructor lesson plans.
These deficiencies in instructional and student training materials
impacted the consistency and sequencing of learning objectives and
diminished their aid to the student in learning the skills and
knowledge necessary to perform the function of plant operator.
The training of maintenance personnel
was determined to be
sufficient to support plant maintenance activities. The lack of a
formalized on-the-job training program was being corrected by the
development of EQTS.
A major weakness in the maintenance area
during the assessment period was the licensee's failure to
establish
and
implement procedures to ensure that pertinent
operating experience is fed back to all levels of maintenance
personnel.
The licensee's general employee training (GET)
was considered
effective; however,
certain weaknesses in the
areas of
physical security and QA were apparent. The generic nature of the
GET video tape and attempts to maintain its applicability to all
Duke Power Plants resulted in certain Oconee security specifics
such as card reader usage and vital area locations not being
presented to the employee during GET.
Related GET omissions in
the area of QA such as the day-to-day role of QA inspectors and
how to report QA deficiencies were also observed.
The following violation was identified.
Severity Level IV violation for failure to establish and
implement adequate procedures to permit timely dissemination
of operating experience to mechanical and I&E maintenance
personnel.
(84/25-24-27)
Enclosure 1
30
2.
Conclusion
Category:
2
3. Board Recommendation
The Board notes that the training has been effective in spite of
weaknesses noted in the Security and Quality Assurance areas.
No
change in NRC inspection activity is recommended.
V. Supporting Data and Summaries
A.
Licensee Activities
During this evaluation period,
major licensee activities included
normal
power operations, four refueling outages, and extensive
modifications and repairs.
Some of these items are listed in the
individual sections of this report.
Two items of particular note are
completion of the safe shutdown facility and of a waste compaction and
incinerator facility.
B. Inspection Activities
In addition to a review concerning importance to safety, a review on
regulatory effectiveness, operator licensing examinations,
ten site
inspections by NRR,
and several other special audits, 62 inspections
involving approximately 7400 inspector-hours on site were performed by
regional and resident inspectors.
C.
Licensing Activities
Summary of significant licensing actions and other activities during
the SALP evaluation period.
1.
NRR/Licensee Meetings - 30
2.
NRR site visits -
10
3.
Commission briefings -
none
4. Schedule extensions granted -
none
5. Reliefs granted - 1 (in-service inspection relief granted)
6. Exemptions granted - 2
a.
Fire protection technical exemptions (lighting)
b.
ISI/IST common start date exemption
7.
Licensee Amendments Issued - 48 (16 for each unit)
Enclosure 1
31
8.
Emergency technical specification changes issued -
one (reactor
building cooling fan '3A')
9.
Orders issued -
none
10.
NRR/Licensee Management Conferences - None
11.
Li-censee Actions
0
118 Plant specific actions were completed. Included in this
category and used to provide input to this evaluation are:
-
ISI/IST Exemption
Cycle 9 Review, Oconee 1
-
Fire Protection Exemption Request (Lighting)
-
Review of Guidelines for Determining Core Damage
-
EOF Location
-
ISI Relief Request
-
Mark BZ Fuel
-
Air Lock Testing Frequency Technical Specification
Change
-
STA Bachelor's Degree or Equivalent
-
Regulatory Effectiveness Program
-
Disposal of Five Feedwater Heaters Onsite
-
Minimum Operator Staffing Technical Specification Change
-
Interpretation of 10 CFR 20.203(e)
-
Startup Physics Report Revisions
-
Emergency Technical Specification Change for "3A"
Fan Cooler
-
Licensing Operators Requalification Program
-
Technical Specification Improvement Meeting
-
Inverter Alert
-
Administrative Technical Specification Change
-
FSAR Reference Amendment
-
Emergency Drill
-
Waste Gas Holdup Tanks Technical Specification Review
-
DCRDR Program Plan
-
Keowee Batteries Inoperability Extension
-
Oconee 1 Spent Fuel to McGuire
-
Confirmatory Items on GK 83-28, Item 4.3
-
RTB UVTA
-
Reload Methodology
-
Cycle 9 Review, Oconee 3
-
RCS Leak Test Technical Specification changes
-
Disposal of Contaminated Sand in Controlled Area
-
Cycle 8 Fuel Assembly, Oconee 2
-
Nuclear Equipment Operators
-
Overtime Limits
-
II.B.3 Technical Specification Change
-
II.F.1.2 Technical Specification Change
-
Definition of "Accessible/Accessibility"
-
H2 Penetrations
Enclosure 1
32
0
38 Multi-Plant actions completed. Included in this category
and used to provide input to this evaluation are:
-
Technical Specification Review of "Reportable
Occurrence" Requirements
-
Item 4.3, Automatic Actuation of Shunt Trip Attachment
fo.r Westinghouse and B&W Plants
-
Masonry Wall Design, Response to I&E Bulletin 80-11
-
Environmental Qualification of Safety Related Electrical
Equipment
-
Item 1.1, Post Trip Review Program Description and
Procedures
-
Natural Circulation Cooldown (GL 81-21)
-
Control of Heavy Loads _ Phase II
-
Item 3.1.3, Post Maintenance Testing
-
Item 3.2.3, Post Maintenance Testing
-
Items 3.1.1. and 3.1.2, Post Maintenance Testing
Procedures
-
Diesel Generator Reliability Technical Specifications
(GL 84-15)
-
Items 3.2.1 and 3.2.2, Post Maintenance Testing
Procedures
-
Item 4.1, Reactor Trip System Reliability
-
Item 4.5.1, Reactor System Functional Testing
a
17
actions completed.
Included in this
category and used to provide input to this evaluation are:
-
Item I.D.2, Safety Parameter Display System
-
Procedures Generation Package Review
-
Item I.D.1.1, Detailed Control Room Design Review
Program
-
Item I.D.1.2, Detailed Control Room Design Review
Summary Report
-
Item II.K.3.30, Small Break LOCA Outline
-
ICC Guidelines
D.
Investigation and Allegation Review
No allegations were received during the evaluation period. A meeting
was held in the Regional Office on October 5, 1984, at the licensee's
request to discuss allegations received during the previous assessment
period. No action was prescribed against the licensee.
Enclosure 1
33
E. Escalated Enforcement Actions
1. Civil Penalties
Severity Level III violation concerning access control of the
plant, Civil Penalty -
$25,000.
2. Orders
None
F. Management Conferences Held During the Evaluation Period
Conferences held in the Regional Office
-
An enforcement conference was held at the Region II office on
March 26, 1985,
to discuss the radioactive material transport
event.
-
An enforcement conference was held at the Region II office on
July 3, 1985,
to discuss the failure to report the inoperability
of both trains of containment hydrogen monitors.
-
An enforcement conference was held at the Region II office on
January 14,
1986, to discuss the yard drainage system
and
barriers.
G.
Confirmation of Action Letters
None
H. Licensee Event Report Analysis
During the evaluation period,
13
LERs for Unit 1, eight LERs for
Unit 2, and three LERs for Unit 3 were evaluated by the NRC staff to
determine event cause.
Enclosure 1
34
The Distribution of these events was as follows:
CAUSE
NUMBER
Unit 1
Unit 2
Unit 3
Component Failure
5
3
2
Design
Construction/Fabrication/
Installation
Personnel
-
Operating Activity
2
4
1
- Maintenance Activity
1
- Test/Calibration Activity
2
1
-
Other Activity
1
Out of Calibration
1
Other
1
_
Total
13
8
3
I. Enforcement Activity
UNIT SUMMARY
FUNCTIONAL
NO. OF DEVIATIONS AND VIOLATIONS IN EACH
AREA
SEVERITY LEVEL
D
V
IV
III
II
I
UNIT NO.
1/2/3
1/2/3
1/2/3
1/2/3
1/2/3 1/2/3
Plant Operations
1/0/1
1/3/2
Radiological Controls
4/4/4
4/4/5
1/0/0
Maintenance
1/1/1
0/0/2
Surveillance
3/2/2
Fire Protection
Security
2/2/2
2/1/1
1/1/1
Outages
2/3/2
Training
1/1/1
Quality Programs and
2/3/2
Administrative Controls
Affecting Quality
Licensing
1/1/1
TOTAL
9/8/9
15/17/17
2/1/1
Enclosure 1-
35
FACILITY SUMMARY
FUNCTIONAL
NO. OF DEVIATIONS AND VIOLATIONS IN EACH
AREA
SEVERITY LEVEL
D
V
IV
III
II
I
Plant Operations
2
4
Radiological Controls
4
5
1
Maintenance
1
2
Surveillance
3
Fire Protection
Security
2
2
1
Outages
3
Training
1
Quality Programs and
3
Administrative Controls
Affecting Quality
Licensing
1
TOTAL
10
23
2
J.
Fifteen unplanned reactor trips and twelve shutdowns for maintenance
occurred during the evaluation period. Also during this period, Unit 1
was shut down twice and Units 2 and 3 once each for end of cycle
refueling outages. The unplanned trips are listed below.
Unit 1
December 2, 1984 -
Unit 1, during startup after refueling,
tripped from 43% power due to a loose wire in an Amphenol
connector which caused a relay to open,
resulting in
isolation of the generator from the grid.
Opening of the
generator breaker resulted in a turbine trip followed by an
anticipatory reactor trip.
December 3, 1984 - Unit 1 tripped from 57% power when "B"
main feedwater pump tripped after the auxiliary oil pump was
shut down. The oil pump was shut down procedurally since the
feedwater pump was at 4100 RPM and the shaft driven oil pump
should have provided sufficient oil pressure.
Since "A"
pump was not operating at the time,
reduced
feedwater pressure caused an anticipatory reactor trip.
January 22, 1985 - Unit tripped from 100% power when moisture
separator reheater valves
(MSRV)
closed,
resulting in a
reactor trip from high pressure. Cause of the valve closure
could not
be determined at the time.
The reactor was
returned to power.
Enclosure 1
36
April 11,
1985 - Unit 1 tripped from 100% power when MSRV's
closed for reasons unknown,
resulting in a reactor high
pressure trip. Following the trip, a thorough examination of
turbine control circuits identified a loose connection on a
card which, when manipulated, signaled shaft overspeed and
caused the MSRV's to close.
April 11,
1985 -
Unit 1 tripped from 17% power due to
fluctuations in turbine header pressure which caused
a
reactor trip. The reactor was restarted shortly thereafter.
April 25, 1985 - Unit 1 tripped from 100% power after most of
the control room Statalarms were lost due to failure of an
inverter and its failure to transfer to another power source.
Power was also lost to the ICS. The reactor remained stable
with positive instrument indications while power was lost.
When power was restored, demands which had built into the ICS
caused feedwater fluctuations which resulted in tripping both
feedwater pumps, causing a reactor anticipatory
trip.
Modifications to the inverters to improve circuit reliability
and additions to the operator training program have been
completed.
January 31,
1986 -
Unit 1 tripped at 3:47 p.m.
from 100%
power due to a turbine trip and anticipatory reactor trip.
The turbine/generator trip was the result of an error by
electricians performing tests and maintenance in the 230Kv
switchyard which tripped one bus being fed by the Unit 1
generator. This caused one generator output breaker, PCB-21,
to open, transferring the entire generator output to a single
breaker,
PCB-20.
PCB-20 was designed to accept the full
load; however,
apparent failure of PCB-20 breaker contacts
caused the breaker to explode.
Unit 2
April 20,
1985 -
Unit 2 tripped from 20% power during power
ascension following refueling outages when power was lost
from a 600 volt motor control center (MCC). This led to loss
of a feedwater auxiliary oil pump, resulting in a trip of the
feedwater pump which caused an anticipatory reactor trip.
Investigation revealed that loss of the MCC was due to a
ground fault in another system.
April 26,
1985 -
Unit 2 tripped from 72% power due to a
problem in the electro hydraulic control system (EHC).
At
the time,
maintenance personnel were working in the
cabinet. A false power imbalance signal was received which
resulted in a reactor trip.
Examination identified no
questionable components. Apparently, the trip was caused by
a mechanic's error.
Enclosure 1
37
July 10,
1985 - Unit 2 tripped from 94% power due to high
reactor coolant pressure resulting from an erroneous signal
which closed the turbine control and intercept valves.
The
trip apparently was caused by a mechanic who was investi
gating a problem with the
control. He plugged in a test meter which introduced a noise
signal causing the valves to close.
January 31,
1986 -
Unit 2 tripped at 11:31 a.m. from 100%
power following a load rejection which caused a generator/
turbine trip and anticipatory reactor trip.
At the time,
electricians were performing maintenance
and testing of
microwave circuits in the 230Kv switchyard. Input of signals
into a circuit unexpectedly caused a breaker fault relay to
actuate, resulting in a generator trip.
February 4, 1986 - Unit 2 tripped from 100% power due to a
technicians error during a surveillance test.
Unit 3
July 23, 1985 -
Unit 3 tripped while in three reactor coolant
pump operation at 74% power due to reactor coolant system
high pressure.
The trip was the result of a feedwater
transient caused by a failed feedwater ratio multiplier in
the ICS.
October 24, 1985 - Unit 3 tripped from 10% power due to loss
of feedwater,
caused by failure of an auxiliary steam
regulating valve to work properly during reactor power
increase following a startup.
January 31,
1986 -
Unit 3 tripped at 7:08 a.m.
from 57%
power. The trip was
caused
by a feedwater
pump flow
transmitter which failed high, causing a feedwater runback
and subsequent reactor high pressure trip.
Only one
feedwater pump was operating at the time, since the unit was
returning to power following a reduction to 15% power in
order to repair a turbine intercept valve.