Text

Initial SALP Repts 50-269/93-11,50-270/93-11 & 50-287/93-11 for Period of 920202-930501.Performance Maintained at Superior Level in Areas of Radiological Protection & Security
	ML15239A069
Person / Time
Site:	Oconee
Issue date:	07/13/1993
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML15239A068	List: ML15239A067; ML15239A069;
References
	50-269-93-11, 50-270-93-11, 50-287-93-11, NUDOCS 9308050088
	Download: ML15239A069 (46)
	v • d • e

ENCLOSURE

INITIAL SALP REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT NUMBERS

50-269/93-11, 50-270/93-11 AND 50-287/93-11

DUKE POWER COMPANY

OCONEE UNITS 1, 2 AND 3

FEBRUARY 2, 1992 THROUGH MAY 1, 1993

9308050088 930713

PDR

ADOCK 05000269

G

PDR_

TABLE OF CONTENTS

Page

I.

INTRODUCTION.

..................................... 2

II. SUMMARY OF RESULTS................................. 2

III.

CRITERIA.

......................................... 4

IV. PERFORMANCE ANALYSIS................................. 4

A.

Plant Operations

............................. 4

B.

Radiological Controls ......................... 6

C.

Maintenance/Surveillance ....................... 9

D.

Emergency Preparedness........................11

E.

Security ....

............................12

F.

Engineering/Technical Support .................. 14

G.

Safety Assessment/Quality Verification..........16

V.

SUPPORTING DATA AND SUMMARIES ....................... 17

A.

Licensee Activities..........................17

B.

Direct Inspection and Review Activities............18

C.

Escalated Enforcement Activities ...............18

D.

Management Conferences........................19

E.

Confirmation of Action Letters.................19

F.

Reactor Trips/Unplanned Shutdowns..............20

G.

Review of Licensee Event Reports...............21

H.

Licensing Activities....

.....................21

I.

Enforcement Activity.........................22

2

I.

INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and =to evaluate licensee performance on the basis of this

-information. The program is-supplemental to normal regulatory processes used

to ensure compliance with NRC rules and regulations. It is intended to be

sufficiently diagnostic to provide a rational basis for allocation of NRC

resources and to provide meaningful feedback to the licensee's performance in

each functional area.

An NRC SALP Board, composed of the staff members listed below, met on June 8,

1993, to review the observations and data on performance, and to assess

licensee performance in accordance with the guidance in NRC Manual Chapter

NRC-0516, "Systematic Assessment of Licensee Performance". The Board's

findings and recommendations were forwarded to the NRC Regional Administrator

for approval and issuance.

This report is the NRC's assessment of the licensee's safety performance at

the Oconee Units 1, 2 and 3 for the period February 2, 1992, through May 1,

1993.

The SALP Board for Oconee was composed of:

J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP),

Region II (RH), (Chairman)

J. P. Jaudon, Deputy Director, Division of Reactor Safety (DRS), RH

J. P. Stohr, Director, Division of Radiation Safety and Safeguards

(DRSS), RII

A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RH

D. B. Matthews, Director, Project Directorate 11-3,

Office of Nuclear Reactor Regulation (NRR)

L. A. Wiens, Project Manager, Project Directorate 11-3, NRR

P. E. Harmon, Senior Resident Inspector, Oconee, DRP, RH

Attendees at SALP Board Meeting:

M. S. Lesser, Chief, Reactor Projects Section 3A, DRP, RH

W. H. Miller, Jr., Project Engineer, Reactor Projects Section 3A, DRP, RII

W. K. Poertner, Resident Inspector, Oconee, DRP, RH

R. L. Watkins, Project Engineer, Reactor Projects Section 3A, DRP, RH

II. SUMMARY OF RESULTS

Oconee was operated safely during the assessment period. This included

improvement in shutdown operations. Effective command and control over plant

evolutions was exercised. Weaknesses remained in configuration control and

procedural usage. The previously established organizational structure

impaired effective oversight of Keowee by nuclear operations. Following the

loss of offsite power event of October 1992, Keowee was reorganized, and

programs for operator standards and training were developed.

3

Performance in the radiological protection area was superior. The ALARA

program remained strong. The water chemistry and the environmental and

effluent monitoring programs were effectively implemented. The organization

was stable, and the radiological training program was good. Deficiencies were

identified with radioactive material labeling, area posting and adherence to.

radiological control area access procedures.

Preventive and predictive maintenance programs were effectively developed and

implemented. These, along with management efforts to reduce existing backlogs

of work requests and temporary modifications, improved plant equipment

performance. Inadequate controls over maintenance and surveillance activities

contributed to several operational events which included reactor trips and the

October 1992 Loss of Offsite Power event.

Management commitment to the emergency response organization was evident as

the program remained strong. The response team was aggressively exercised

with numerous drills and challenging scenarios. Emergency facility equipment

was well maintained, and a siren system upgrade was fully implemented.

The security program was well managed and supported. Personnel were

effectively trained and knowledgeable of duties and responsibilities.

Initiatives were taken to review fully all operability aspects of a support

facility in order to provide appropriate security measures. Discrepancies

were conservatively documented and addressed. Improvement was noted late in

the assessment period with closed circuit television reliability.

Engineering provided good support for plant modifications, outages and

maintenance. Engineering personnel were knowledgeable and demonstrated a high

degree of ownership over their respective systems. Weaknesses existed in

resolving emergent issues and with system flow model calculations.

Performance in the operator requalification program declined from the previous

assessment period due to weaknesses in examination content and evaluator

techniques.

In the area of Safety Assessment/Quality Verification, performance was

inconsistent. Management was thorough and conservative when addressing

issues recognized as clearly safety significant and licensing submittals.

Corrective actions to improve shutdown risk and command and control of

operating evolutions were effective. A questioning attitude towards suspect

test results was not always evident, and management was slow to recognize the

need for increased oversight of Keowee operations.

4

Overview

Performance ratings assigned-for the last rating period and the current period

are shown below.

Rating Last Period

Rating This Period

Functional Area

8/01/90- 2/01/92

2/02/92 - 5/01/93

Plant Operations

2

Radiological Controls

1

Maintenance/Surveillance

2

Emergency Preparedness

1

Security

1

Engineering/Technical

Support

2

Safety Assessment/

Quality Verification

2

III.

CRITERIA

The evaluation criteria which were used to assess each functional area are

described in detail in NRC Manual Chapter MC-0516, which can be found in the

Public Document Room files. Therefore, these criteria are not repeated here,

but will be presented in detail at the public meeting to be held with licensee

management on July 28, 1993.

IV. PERFORMANCE ANALYSIS

A.

Plant Operations

1.

Analysis

This functional area addresses the control and performance of activities

directly related to operation of the facility.

During the previous SALP assessment, weak or deficient operator

attention and control of evolutions during outage conditions was

identified. During this assessment period, command and control of

operations activities improved particularly during shutdown conditions.

Configuration control errors and mispositioned equipment events

continued to occur. Procedural inadequacies, usage weakness and

inattention to detail contributed to several operational events.

Although improvement was achieved in the area of command and control

over licensed activities, there were occasions which demonstrated that

continued efforts are needed. In one case a procedure review was

inadequate when the task was inappropriately delegated. On another

occasion, operators permitted maintenance activities during low power

physics testing, which resulted in an inadvertent cooldown.

5

Operator response to transients and upset conditions was good. Prompt

action by operators prevented over-pressurization of the quench tank

during a system misalignment. Several transients requiring operator

action were handled effectively. Operators generally demonstrated

excellent knowledge of plant systems and processes. Fundamental

watchstanding practices improved from last assessment period. Shift

turnovers were thorough. Preshift meetings and mid-shift Operations

Department update meetings provided effective communications to both

operations personnel and other plant support groups. Log keeping was

adequate, but amplifying details regarding evolutions were inconsistent.

Shift staffing exceeded Technical Specification requirements without the

need of excessive overtime. Operators properly used Abnormal Procedures

and Emergency Operating Procedures when required.

Operators were not required to have extensive knowledge of Keowee

operations. This became evident during the loss of offsite power event

in October 1992. The operators' response to and recovery from this

event was complicated by the lack of appropriate procedural guidance and

overall complexity of the various electrical power system interactions.

Adequate standards had not been established for Keowee operator

performance, duties, responsibilities and knowledge levels. Keowee

operations and management structure was subsequently reorganized to

report to Oconee Nuclear Operations Department.

Performance standards

for Keowee operations were established and implemented towards the end

of this assessment period. Also, some limited training of Oconee

operators on Keowee systems was initiated late in this assessment

period.

Configuration control and procedural adherence exhibited weaknesses that

represented a continuation of problems identified during the last SALP

period. Mispositioned equipment incidents continued to occur during

this evaluation period. Failure to follow approved procedures occurred

in several instances. In some cases procedural requirements and

policies were not clearly understood by personnel.

Procedural steps

were inappropriately marked "Not Applicable" (NA) without a thorough

review and resulted in a violation of Low Temperature Over-pressure

Protection requirements and an inadvertent draining of a portion of the

main feedwater system. Guidance on marking steps NA was implemented

midway in the period and some improvements were noted.

Other examples

included the use of the wrong unit's procedure to calculate an estimated

critical position and a failure to follow a procedure that resulted in

misplaced fuel assemblies during refueling. In one instance, an

Abnormal Procedure for restoring offsite power was considered

inadequate.

Both operators and supervisory personnel exhibited a conservative

approach to technical issues. The Operations Support Group was

instrumental throughout the period in providing both technical and

administrative support to the control room. Work control screening,

outage scheduling and review, and procedure review and revision were

also effectively performed by this group. The Operations Support Group

was staffed primarily with licensed senior reactor operators (SROs) and

reactor operators (ROs). The experience level of both control room

personnel and the Operations Support Group were considered very high.

6

Management continued to work toward the "black board" concept and

improvement was noted by a reduction in the number of lit annunciators

and nuisance alarms. Plant equipment labeling efforts have reduced the

instances of wrong unit or wrong equipment events. Control room

drawings were maintained legible, however, changes resulting from minor

modifications were not always promptly reflected.

Operator attention and control of evolutions during shutdown conditions

improved from the previous assessment period. Management implemented

changes to control room supervisory functions, and defined operator

duties during shutdown conditions. These changes were in response to

several significant events in the previous evaluation period. Control

room decorum and professionalism improved. More formal communications

resulted in a decrease in the number of events. The duties and

responsibilities of the Operator at the Controls were revised to allow

concentration on plant status and evolutions in progress.

Administrative duties and support activities were assigned to other

personnel.

These changes were effective and contributed to improved

performance during shutdown activities.

One Severity Level 3 Violation and nine Severity Level 4 Violations were

identified.

2.

Performance Rating

Category: 2

3.

Recommendations

The Board noted that problems associated with inadequate procedures and

failure to follow procedures continued from the previous SALP period.

Management corrective actions to address this weakness have not been

fully effective. A broad review of procedural usage should be

undertaken to identify the underlying causes.

B.

Radiological Controls

1.

Analysis

This functional area addresses those activities related to radiation

safety, radiological effluent control and monitoring and

primary/secondary chemistry control.

The licensee continued to maintain a stable and well-qualified radiation

protection staff with no significant changes made to the licensee's

radiological controls organization. The licensee's training program

remained sufficient during the period with program enhancements that

included instructions to plant workers and the revisions to 10 CFR Part

20, as well as the implementation of an Electronic Dose Capture System

and its interface with digital alarming dosimeters (DADs). Early in the

assessment period, continuing training was not being provided for

contract health physics (HP) technicians. The licensee corrected this

by adding training modules focusing on refresher HP theory and practices

and providing additional training to the contract HP technicians.

7

The licensee's program to maintain overall occupational external

exposure as low as reasonably achievable (ALARA) remained very good.

The collective dose for 1992 was 217 person-rem per unit. The

collective dose in 1993 to the end of the SALP period was 24 person-rem

per unit. During the assessment period,-the licensee initiated and

completed replacement of the letdown piping and "J" leg drains from the

steam generators in Units 1 and 3. Replacing this highly radioactive

piping with new piping, thereby reducing high-dose rates in the

containment basement areas, was a significant ALARA initiative.

The internal exposure controls, i.e., contamination control, the

respiratory protection, and the bioassay program, were effectively

implemented to control exposure. No exposures exceeded regulatory

limits.

Licensee performance in the contamination control area continued to be

effective in ensuring that contaminated floor space and personnel

contamination events were maintained below established goals and were

trending down. Contaminated space was typically controlled to less than

seven percent of the radiologically controlled area (RCA).

Personnel

contamination events did not result in any skin doses or intakes greater

than regulatory limits.

During the assessment period, repetitive problems were identified with

radioactive material control practices. Specifically, the NRC

identified:

(1)

recurring instances of radioactive material in the RCA

not being properly labeled as such, and (2) recurring instances of areas

in the RCA containing radioactive material not being properly posted.

As a result of the licensee's investigation of a possible skin dose

overexposure to a radwaste operator, the licensee found that the worker

rarely used the Electronic Dose Capture System to log into the RCA of

the plant. Further investigation revealed that approximately 20 percent

of. personnel working in the RCA were not logged in any radiation work

permit (RWP). This indicated less than fully effective adherence to

procedures and control of work being conducted in the RCA.

During the assessment period, the licensee's audit program was effective

in identifying radiological control program deficiencies. However, the

effectiveness of the audit program was reduced because corrective

actions to findings were not properly implemented. Specifically, of 23

problem identification reports reviewed, 17 had no corrective actions

assigned for deficiencies identified, including several which were

nearly a year old. Furthermore, out of 47 radiological deficiencies

reviewed, all but one were assigned the lowest priority for correction.

Typical issues not resolved included procedural inadequacies, non-ALARA

work practices, and miscellaneous dosimetry problems.

The licensee's performance with regard to maintaining low levels of

radiation doses from effluents was good. The whole body doses were less

than one millirem/year each from the liquid effluents and from the

gaseous effluents released during 1992. Those doses were a small

percentage of their respective limits. Compared to 1991, larger volumes

of liquid radwaste, with higher radionuclide concentrations, were

processed through the liquid radwaste treatment systems during 1992.

8

Although the amount of activity released increased slightly, a small

decrease in the total body dose from liquid effluents for 1992 was

achieved by a reduction of the Cs-137 concentration in the effluent. By

processing laundry waste water through powdered resin before release,.

the Cs-137 concentration in the effluent was significantly reduced.

There was one unplanned release during 1992 which occurred when

approximately 2000 gallons of slightly contaminated water from the Low

Pressure-Service Water System were inadvertently discharged from the

Unit 2 Low Pressure Injection Cooler to Lake Keowee. No release limits

were exceeded during that event.

Effluent radiation monitor performance was mixed. A longstanding

problem with the Low Pressure Service Water (LPSW) monitors was

corrected and the monitors for Units 1 and 2 were returned to service

during the assessment period. System modifications were required to

correct insufficient sample flow from all portions of the LPSW system.

The modification for the Unit 3 system was completed during the previous

assessment period. Late in the assessment period there were two monitors

that were inoperable for several days before the licensee detected that

they were not functioning properly. Weaknesses were identified with the

licensee's corrective actions for restoring the monitors to an operable

status.

The licensee's environmental monitoring program was effectively

implemented. The program results for 1992 indicated that there was no

significant radiological impact on the health and safety of the general

public resulting from plant operations. Dose estimates calculated from

environmental monitoring program data were in reasonable agreement with

dose estimates calculated from effluent release data and were well

within 40 CFR 190 dose limits. The licensee's performance in the

Environmental Protection Agency's interlaboratory crosscheck program

indicated that an effective quality assurance program had been

maintained for analysis of environmental samples.

The parameters required to be monitored as part of the water chemistry

control program were maintained well below their technical specification

(TS) limits. The program also included provisions for implementing,

with few exceptions, industry guidelines for PWR primary and secondary

water chemistry. The activity of reactor coolant was also maintained

well within the TS limits. The activity was slightly higher in the Unit

3 coolant than in Units 1 and 2 coolant due to residual contamination

from leaking fuel in previous fuel cycles. The licensee has since

implemented a policy of reloading fuel with zero defects with regard to

leaking fuel.

There were no transportation incidents involving the licensee's

shipments of radioactive material during the assessment period. The

program was effectively implemented and provided for preparation and

shipment of radioactive material pursuant to the Department of

Transportation's regulations.

9

Five Severity Level 4 Violations were identified.

2.

Performance Rating

Category: 1

3.

Recommendations

None

C.

Maintenance/Surveillance

1.

Analysis

This functional area addresses those activities related to equipment

condition, maintenance, and surveillance testing. In addition to the

routine inspections in this area, an Electrical Distribution System

Functional Inspection (EDSFI) was conducted during this assessment

period.

The licensee's performance in the maintenance/surveillance functional

area was inconsistent throughout the assessment period. Predictive

maintenance and equipment monitoring was aggressively pursued and was

effective whereas weaknesses were noted in areas such as procedural

adherence, documentation of problems during troubleshooting and repairs,

and maintenance/surveillance induced reactor trips and transients.

The licensee continued to focus efforts on preventative maintenance.

The thermography program introduced during the previous SALP period was

effective in identifying potentially significant maintenance problems

prior to failure and was effective in identifying leaking valves.

Management efforts were effective in significantly reducing the

maintenance work request backlog. The backlog was maintained at levels

which'were better than management expectations. This contributed to

improved equipment reliability as only one reactor trip from power was

caused directly by equipment failure. Improved controls and efforts to

reduce temporary modifications have also been successful.

The maintenance department was well staffed with experienced and

knowledgeable personnel.

The use of vendors and contractors was

controlled with most maintenance support performed by Duke Power

individuals. Plant material condition and routine housekeeping was

adequate.

During this period, significant operational problems were attributable

to poor maintenance controls. A loss of offsite power event and reactor

trip occurred in October 1992 due to maintenance activities conducted in

the 230 kilovolt switching station control power system. Three other

reactor trips from power occurred during maintenance activities. These

were due to problems during troubleshooting or repair activities and use

of a wrong wiring diagram. Although three refueling outages were

conducted and adequately managed, three unit shutdowns were required

during the period due to inadequately performed maintenance.

10

Problems with independent verification, undocumented work activities and

other poor maintenance practices continued to occur during the period.

Examples include an inadvertent reactor protection system channel

actuation due to performing a surveillance on the wrong unit, improper

wire terminations that were "verified" by two technicians and a Quality

Control inspector, an undocumented activity involving lifting leads and

an Emergency Feedwater Actuation due to poor scaffolding controls.

Surveillance activities caused a unit runback and testing on the wrong

unit caused a plant trip.

The test program for the Keowee Hydrostation did not adequately

demonstrate the ability of the system to perform its design function. A

periodic test had not been performed on the Keowee units to supply power

through the overhead path. Additionally relays required to isolate

portions of the switchyard and to transfer Keowee auxiliary power to an

alternate source were not fully tested. Also, as discussed Section

IV.F. (Engineering/Technical Support), LPSW testing had not been

adequately performed to validate flow model calculations until the NRC

.pointed-out errors in the model.

In other areas, several inadequate

surveillance procedures were identified during the period including one

missed surveillance.

The licensee's inservice inspection (ISI) program was effectively

implemented during this inspection period.

ISI non-destructive

examinations were conservatively performed. The procedures, examination

techniques, and documentation of results were good. Personnel were

knowledgeable in their areas of responsibility. Some problems were

identified involving the failure to document and resolve welding

discrepancies identified by the vendor on ASME Code relief valves and an

untimely and inadequate relief request from postmodification hydrostatic

testing.

Seven Severity Level 4 Violations were identified.

2.

Performance Rating

Category: 2

3.

Recommendations

A significant number of plant transients were attributed to inadequate

maintenance or surveillance activities. Some of these were related to

procedural problems and work controls. A broad review of procedures,

similar to that mentioned in the Operations functional area is

recommended.

11

D.

Emergency Preparedness

1.

Analysis

This functional area addresses activities related to the execution of

the Emergency Plan and its implementing procedures, including licensee

performance during emergency exercises and actual events, interactions

between onsite and offsite emergency response organizations during

emergency exercises and actual events, and support and training of

onsite and offsite emergency response personnel.

Management support and involvement in the emergency preparedness (EP)

program was evidenced by the numerous drills conducted and the emergency

facility and equipment improvements made during the assessment period.

The licensee continued to administer an aggressive schedule of EP

training drills, creating challenges for the emergency response

organization (ERO) that exceeded the training requirements of the

Emergency Plan. These drills (two of which were conducted during off

hours) included annual participation by each of the five Operations

shifts in simulator-driven exercises involving the full ERO. This

approach, combined with formal classroom training, appeared to be an

effective way of maintaining organizational readiness for responding to

an emergency.

The onsite emergency preparedness staff was qualified and continued to

provide comprehensive emergency preparedness training. Offsite support

agency training for fire, ambulance, rescue, hospital, and local law

enforcement agencies was conducted in accordance with commitments in the

Emergency Plan and agreement letters with assisting agencies.

During the annual exercise in August 1992, the licensee demonstrated its

capability to provide for the health and safety of the public by

effectively implementing the Emergency Plan in response to the simulated

accident scenario. The scenario appropriately challenged the licensee's

ERO, and included full participation by the NRC. The licensee

demonstrated the ability to identify emergency conditions, to make

correct classifications in accordance with Emergency Plan implementing

procedures, to take appropriate measures to mitigate the adverse

consequences of degrading plant conditions, and to recommended

appropriate protective actions for the public. The emergency response

facilities were activated fully within the required time periods. The

timely activation and capable functioning of the Emergency Operations.

Facility constituted an exercise strength. An exercise weakness was

identified for failure of the Joint Information Center to quantify or

put into perspective, for the general public, a radiological release

which occurred as a component of the scenario.

The licensee maintained emergency facilities, equipment, instrumentation

and supplies in a state of readiness with thorough equipment

inventories, surveillances, and functional tests. Just prior to the

beginning of the assessment period, the licensee fully implemented an

upgrade of the offsite siren system through the addition of a

computerized feedback capability for monitoring each siren's operation

during any mode of testing or actual activation. This resulted in very

12

high siren availability (approximately 99 percent) during 1992, with the

feedback system successfully identifying siren operability problems for

prompt corrective action.

The 1991 corporate reorganization necessitated major EP program changes

which were implemented during the assessment period. Most of the EP

program responsibilities-previously held by the corporate staff were

transferred to the site. Concurrent with this transfer of

responsibility was the relocation of many emergency response personnel

to the site. Some organizational functions were also shifted from the

Emergency Operations Facility to the Technical Support Center. However,

the totality of the functions performed did not change with the

reorganization, and adequate emergency response capabilities were

maintained.

During this assessment period, the licensee's Emergency Plan was

activated twice at the Notification of Unusual Event level.

Each of the

events was properly classified, and notifications to State and local

governments and the NRC were made in accordance with applicable

requirements.

One Severity Level 5 Violation was identified.

2.

Performance Rating

Category:

1

3.

Recommendations

None

E.

Security

1.

Analysis

This functional area addresses those safeguards activities related to

the protection provided to the station's safety related vital equipment,

and the assurance that individuals authorized station access are fit for

duty.

The licensee's safeguards program was well managed at the site level as

evidenced by the professionalism and effectiveness of its proprietary

security force. Officers were well trained, knowledgeable of their

duties and responsibilities, well versed in their procedures, and

adequately equipped. Shifts were appropriately staffed.

The licensee conducted effective quality assurance audits which were

thorough and complete. Corrective actions for the audit findings were

timely and appropriate.

As noted in previous SALP assessments, the licensee's closed circuit

television system, used to assess protected area barrier alarms,

continued to be non-operational in several zones. Several television

13

monitors located inside the alarm stations were frequently out of

service. Thus, the licensee continued to use compensatory measures to

meet its Plan commitments during the period. Toward the end of the SALP

period, camera assessment system reliability had greatly improved.

The licensee completed an engineering evaluation of certain non-vital

piping which, given various operational modes and valve lineups, could

be important to safety and therefore should be protected. This

licensee's initiative in conducting this review was well coordinated

with the NRC and adequate compensatory measures have been implemented

where necessary.

With respect to other elements of the safeguards program, access

controls and alarm station operations were appropriate, barriers and

alarms were maintained as required, lighting was sufficient, and (except

as noted earlier regarding cameras) maintenance and compensatory

measures were adequate.

During this SALP period, the licensee identified several security events

involving inadequate communications. A failure by the Control Room

operators to notify the security shift that a facility important to

safety was not operable resulted in the failure to institute timely

compensatory actions. A failure by Human Resources personnel to notify

the security shift of a positive drug test resulted in an unauthorized

access to the Station. Also identified by the licensee was its failure

to conduct daily communications tests as committed to in its Security

Plan. These were appropriately documented in the Safeguards Event Log.

In addition, the NRC identified several Plan inaccuracies relative to

the Turbine Building security barrier. The licensee took appropriate

corrective actions for the aforementioned events.

The licensee has clarified its generic Corporate Procedure for Reporting

Safeguards Events to ensure that NRC reporting criteria is met. This

has resulted in an overall increase in reporting events in the

Safeguards Logs.

No violations were identified.

2.

Performance Rating

Category: 1

3.

Recommendations

None

14

F.

Engineering/Technical Support

1.

Analysis

This functional area addresses activities associated with the design of

plant modifications and of technical support for operations, outages,

maintenance, licensed operator training and requalification.

Engineering support was strongest in support of plant operations and

planned outages. Weaknesses were evident in the response to emergent

issues not directly related to operability and in corrective actions.

Licensed operator training improved, but some weakening of the

requalification program was evident. The staffing of the engineering

organizations was satisfactory.

Engineering support for plant modifications was adequate. The quality

-and .technical content of temporary and minor modifications was generally

good. Examples included the addition of Vent Valve ICCW-422, relocation

of IC-850 and IC-852, and snubber additions on main feedwater and

emergency feedwater piping. There were also instances found of

inadequate design calculations and reviews, although some of the

inadequacies occurred before this assessment period. Examples included

previous and current Low Pressure Service Water (LPSW) flow model

calculations used to justify operability of the system. After the NRC

identified the errors, the licensee corrected them and then tested the

LPSW to verify operability. The tests demonstrated that the LPSW

systems were degraded in that excessive flow through the low pressure

injection coolers could be achieved under certain design basis

conditions and that LPSW flow through the reactor building cooling units

could be significantly below the assumed accident condition -flow rate.

The flow testing conducted on Unit 3 also identified that the system was

degraded due to a mispositioned valve. Single failure vulnerabilities

were also identified in the design basis documentation previously

conducted.

The licensee's engineering and technical support have been responsive to

station needs. Examples include identification and prompt communication

to the NRC of the need to change a prior commitment relating to post

accident boron dilution flow monitoring, modifications to correct

degraded control voltage to the "S" and "E" breakers, corrective action

for inadequate Keowee auxiliary breaker closing power, and modifications

to the Standby Shutdown Facility makeup pump accumulators. Engineering

has generally provided prompt and well-founded solutions to short-term,

operational problems. The response to other issues in which immediate

operability was not an issue has not been quick or as thorough.

Examples include problems with Keowee X-relays, numerous LPSW issues

(raised by the NRC), and a revised response to NRC Bulletin 88-04

concerning the deadheading of LPSW pumps. Also, the planning for the

replacement of switchboard batteries did not identify potential problems

with operating a battery charger without a connected battery. This

resulted in a loss of offsite power and a reactor trip to Unit 2.

System engineers assumed "ownership" of their assigned systems and

15

actively participated in the resolution of problems. Component

engineering provided good support to maintenance.

Engineering support for the resolution of other emerging issues, not

identified as requiring immediate corrective action, was sometimes

deficient. Examples of problems noted included: (1) the failure to

perform a safety-evaluation for a temporary modification (installation

of an electrical jumper on radiation monitor interlock to Valve 2LWD-2);

(2) the use of incorrect design drawings in the completion of a plant

modification (resulting in a reactor trip); (3) an inadequate

engineering evaluation of the operability of a letdown storage tank

check valve; (4) failure to take prompt and adequate corrective actions

for low indicated service water flow through the 3B Low Pressure

Injection (LPI) Coolers; and (5) failure to correct the MG-6 testing

deficiency after identification during Keowee Unit 2 testing.

An Electrical Distribution System Functional Inspection revealed

problems in testing, design analyses, and design basis documentation.

Similar problems were also found in the Oconee emergency AC power

source. These problems resulted in part from the lack of a thorough

understanding of the design basis of the site's electrical distribution

system.

Operator training was effective.

Improvements were noted in the initial

training of licensed operators. This good performance was indicated by

the successful completion of all seven candidates nominated for licenses

in January 1993. The candidates exhibited good communications and

interactions during their simulator examinations, but had a generic

weakness in radiation protection. The previously noted problems with

simulator fidelity to the plant have been rectified. The performance of

requalification was satisfactory. During the June 1992 requalification

examination, five of six crews and 22 of 24 operators passed.

Weaknesses noted included the content and construction of the written

test and poor or improper cuing during the job performance measures.

This was in contrast to the strong performance of facility evaluators

during the previous assessment period.

Two Severity Level 4 Violations were identified.

2.

Performance Rating

Category: 2

3.

Board Recommendations

None

16

G.

Safety Assessment/Quality Verification

1.

Analysis

This functional area addresses those activities related to the

licensee's implementation of safety policies related to license

amendments, exemptions and relief requests; responses to Generic

Letters, Bulletins and Information Notices; resolution of safety issues;

reviews of plant modifications performed under 10 CFR 50.59; safety

review committee activities; and the use of feedback from self

assessment programs and activities.

Management performance in the area of safety assessment and quality

assurance was inconsistent. Efforts to correct weaknesses in command

and control were effective, however many repetitive problems continued

in the area of procedural compliance by personnel.

Prompt followup to

deficiencies was not always evident. Licensing documentation and

submittals were generally very good.

Management implemented several corrective actions to improve the

operation of the station in areas previously identified by the NRC as

weak or deficient. Improved performance was noted in shutdown risk and

control room command and control. Initiatives to improve the conduct of

outage activities and the reduction in shutdown risk vulnerability were

noteworthy. Of particular note was the reduction in control room

distractions, efforts to more fully inform employees of outage

activities, and an independent safety assessment of the outage schedule.

The Nuclear Safety Review Board was objective and thorough in its review

of operations and problems at Oconee. Management was responsive.to the

comments and recommendations from the Board.

In the area of Keowee operations and design, management was slow to

recognize the need for corrective action to address previously

identified NRC concerns and weak areas. In September 1992 a management

meeting was held at NRC request to discuss these issues. The licensee

indicated that while some changes to procedures were appropriate, major

operational, organizational and procedural changes were not necessary.

However, in October 1992, a loss of off site power event occurred and

followup inspections identified significant weaknesses in these areas.

It should be noted that the licensee's Significant Event Investigation

Team, dispatched to site to review the event, was effective in

determining root causes, safety implications and provided

recommendations for corrective action.

Following these inspections, a

comprehensive Emergency Power Management Plan was developed. This plan

was intended to substantially improve the overall operation and

maintenance of the Keowee facility. An organizational change was also

made to incorporate the Keowee station under Oconee station line

management.

At the conclusion of this assessment period the

effectiveness of these changes remained under evaluation.

Issues which the licensee recognized as clearly safety significant were

normally resolved aggressively. Actions were conservative and thorough,

and involved early interaction with the staff. Examples included 100

per cent steam generator tube inspection, corrective action for degraded

17

control voltage for "E" and "S" breakers and corrective actions related

to the emergency electrical system after the Unit 2 Loss of Power event.

At times, the failure to further probe into questionable indications led

to untimely identification of adverse conditions. Examples included the

failure to investigate abnormal LPSW flow during valve testing and

failure to promptly investigate abnormal position indication on a Keowee

breaker. Management efforts to address the large number of operator

errors and procedure violations have not been fully effective as they

continued to occur in a number of areas in the plant.

A significant improvement was noted in the quality and timeliness of

Inservice Inspection and Testing relief requests since the last

evaluation period. Most amendments and relief requests were processed

without the need for additional clarifying information or supplements to

the original submittal.

When additional information was required, the

licensee was very responsive in providing the requested information

promptly.

The licensee provided responses to NRC requests within the time frame

requested or provided written notification if circumstances prevented

meeting the requested schedule. These responses were generally clear,

precise, and sufficient. Examples include responses to Generic Letter 91-11, Vital Instrument Busses and Tie Breakers, Generic Letter 88-20,

Independent Plant Examinations, and Generic Letter 87-02, Seismic

Qualification of Mechanical and Electrical Equipment in Operating

Plants. However, in one instance, an inadequate response to Bulletin

88-04, Safety Related Pump Loss, was not corrected until NRC requested a

revised response.

Licensee Event Reports (LERs) in most cases were timely and well

written. One report, LER 269/92-12, concerning various problems with

the Unit 1/2 LPSW system, was submitted late.

Two Severity Level 3 Violations and two Severity Level 4 Violations were

identified.

2.

Performance Rating

Category:

2

3.

Recommendations

None

V.

SUPPORTING DATA AND SUMMARIES

A.

Licensee Activities

A major reorganization was announced in November 1991, including relocating

Design Engineering to the site. Implementation of the reorganization was

completed in July 1992. Additional management changes during this assessment

period included the April 1, 1993, reassignment of Mr. R. L. Sweigart, former

18

Superintendent Operations, to Superintendent Work Control and Mr. G. E.

Rothenberger, former Superintendent Work Control, to Superintendent Operation.

There were three refueling outages during this assessment period. Refueling

outages were completed in March 1992 for Unit 2, September 1992 for Unit 3,

and January 1993 for Unit 1. These outages were satisfactorily completed with

no major problems.* However, the Unit 3 refueling outage required extensive.

decontamination activities due to the contamination which occurred inside

Unit 3 Containment following the November 23, 1991, break of a 3/4-inch tubing

connector on the Reactor Coolant System. During the Unit 1 refueling outage,

a larger than normal number of degraded steam generator tubes were identified

which were required to be plugged. This was attributed primarily to revised

tube plugging criteria.

In September 1992, the licensee determined that both trains of the Units' 1

and 2 LPI system were inoperable. The cooling water flow of the LPSW system

through the LPI heat exchangers were found to exceed the manufacturer's

specifications. The power level for both units was reduced to approximately

10 percent and modifications were made to reduce the flow through the heat

exchangers to meet the manufacturer's specifications.

On October 19, 1992, during maintenance activities, a loss of off site power

occurred for Unit 2 which was followed by a subsequent loss of the Keowee

Hydro Station.

Since this event, the licensee has placed the Keowee Hydro

Station under the Oconee management and has implemented a number of procedure

changes to improve the reliability of the emergency power supply for the

Oconee Station.

B.

Direct Inspection and Review Activities

In addition to the 36 routine NRC inspections and two initial and three

requalification examinations performed at the Oconee facility, the following

three special inspections were conducted:

December 9, 1991

February 21, 1992

Shutdown Risk Inspection

October 20 - 28, 1992

Augmented Inspection Team (AIT) Loss of

Off-site AC Power Supply

January 25 - March 5, 1993

Electrical Distribution System Functional

Inspection (EDSFI)

C.

Escalated Enforcement Activities

1.

Orders

None

2.

Civil Penalties (CP)

Two Severity Level III problem violations (IR 91-32/EA 91-167) were

issued on February 3, 1992, involving ten specific violations related to

the degradation of the decay heat removal event of September 7, 1991 and

19

the over-pressurization of the LPI system piping on September 19-20,

1991. ($125,000) Although both of these events occurred during the

previous assessment period, the violations were issued during this

assessment period on February 3, 1992.

A Severity Level III violation (EA 92-211) was issued on December 28,

1992, and involved the failure to take adequate corrective action to..

resolve a reduced Low Pressure Service Water System flow condition

through the Unit 3B Low Pressure Injection system cooler. ($100,000)

The licensee requested mitigation of the civil penalty. Subsequent to

this assessment period, an order to pay was issued which the licensee

complied with.

D.

Management Conferences

February 5, 1992: A meeting was held in Region II for Duke to discuss

the items identified during the Design Basis Documentation Program

evaluation of the Oconee electrical systems and the corrective actions

initiated on the identified problems.

June 24, 1992: A meeting was held in Region II for Duke to discuss the

shutdown risk procedures to be implemented for future Oconee refueling

outages. Also, discussed were Duke's Problem Investigation Program,

procedure adherence and configuration control programs at Oconee.

July 17, 1992:

An enforcement conference was held in Region II to

discuss the circumstances associated with the May 8, 1992, Unit 1

reactor trip in which one of the two required Emergency Feedwater System

flow paths was not operable and the operation of Unit 1 from May 11

through 24, 1992, with only one of the two Emergency Feedwater System

flow paths operable.

September 17, 1992: A meeting was held at the Oconee facility to

discuss the operation, management and maintenance of the Keowee Hydro

Station.

November 24, 1992: An open enforcement conference was held in Region II

to discuss the circumstances associated with the mispositioned valve in

the Unit 3 Low Pressure Service Water System.

March 29, 1993: A meeting was held at NRC Headquarters to discuss

electrical issues at Oconee.

Several additional meetings were held with Duke Power throughout the

assessment period to discuss a variety of other subjects including

licensing activities, safety initiatives, Oconee's self-assessment, the

Emergency Data System and the development status of a Babcox and Wilcox

digital module for use in the reactor protection system.

E.

Confirmation of Action Letters (CAL)

Following the October 19, 1992, Unit 2 reactor trip and loss of power

event, a CAL was issued to address the cause of the event. On October

26, 1992, a conference call was held and the licensee discussed

enhancements to be made to the Keowee Hydro Station and Keowee

20

operations. These commitments were documented in a letter to the NRC

dated October 27, 1992.

F.

Reactor Trips/Unplanned Shutdowns

Seven automatic reactor trips occurred. Five of these were attributed

to maintenance/surveillance activities, one to equipment failure and one

to operator error. These trips are as follows:

Unit 1

May 7, 1992: The unit experienced a reactor/turbine trip from 100

percent power due to a connector coming loose on the generator exciter

field. (Maintenance/Surveillance)

May 8, 1992: The unit tripped from 14 percent following a turbine trip

due to the loss of suction to the "lA" main feedwater pump which was

caused by pressure swings while lowering hotwell level.

(Operations)

Unit 2

October 19, 1992: The unit tripped from 100 percent power on the loss

of off-site power which occurred during switchyard battery modification

work when a battery charger was placed in service without a connected

battery. (Maintenance/Surveillance)

Unit 3

February 27, 1992: The unit tripped from 100 percent power following a

turbine trip due to human error. A technician was testing the loss of

generator stator cooling on Unit 2 which was shutdown in a refueling

outage but inadvertently performed the test on Unit 3.

(Maintenance/Surveillance)

June 24, 1992: A turbine/reactor trip occurred from 100 percent power

while technicians were replacing low pressure service water

instrumentation. A fuse blew in the Integrated Control System when an

incorrectly wired card was installed. This caused a momentary loss of

power to the steam generator water level instrumentation which resulted

in a turbine/reactor trip.

(Maintenance/Surveillance)

September 29, 1992: The unit tripped from 73 percent power due to low

reactor coolant system pressure from a defective Group 5 control rod

drive programmer. (Equipment Failure)

January 26, 1993: A turbine/reactor trip from 100 percent power

occurred due to low main feedwater pump discharge pressure which was

inadvertently caused by a technician during trouble shooting activities.

(Maintenance/Surveillance)

21

G.

Review of Licensee Event Reports (LERs)

During the assessment period, 30 LERs were analyzed. The distribution

of these events by cause as determined by the NRC staff was as follows:

Cause

Total Unit 1 Common Unit 2 Unit 3

Component Failure

5

2

3

Design

9

8

1

Construction/Fabrication

1

Installation

Other

2

1

Personnel

- Operating Activity

6

4

1

- Maintenance Activity

3

1

2

- Test/Calibration Activity

2

1

- Other

2

1

TOTALS

30

8

15

2

5

Notes:

1.

With regard to the area of personnel, the NRC

considers lack of procedures, inadequate procedures,

and erroneous procedures to be classified as personnel

error.

2.

The other category is comprised of LERs where there

was a spurious signal or a totally unknown cause.

3.

One Special Report was submitted. Also, two LERs were

submitted but were later rescinded. These reports are

not included in the above tabulation.

4.

The above information was derived from a review of

LERs performed by the NRC staff and may not completely

coincide with the licensee's cause assignments.

H.

Licensing Activities

During the rating period, approximately 175 active licensing actions

were submitted for the three Oconee units of which 97 were completed.

There were 33 licensing amendment requests of which 24 were completed.

22

I.

Enforcement Activity

No. of Deviations and Violations in Each Functional Area:

V

IV

III

II

I

Plant Operations

-

9

1

Radiological Controls

-

5

Maintenance/Surveillance

-

7

Emergency Preparedness

1

-

Security

Engineering/Technical

-

2

Support

Safety Assessment/Quality

-

2

-

Veri fi cation

TOTALS

1

25

3

-

NOTE:

Two of the Severity Level 3 violations and the Severity Level 5

violation were identified during the previous assessment period, but

reports were not issued until this assessment period.

ENCLOSURE

INITIAL SALP REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT NUMBERS

50-269/93-11, 50-270/93-11 AND 50-287/93-11

DUKE POWER COMPANY

OCONEE UNITS 1, 2 AND 3

FEBRUARY 2, 1992 THROUGH MAY 1, 1993

TABLE OF CONTENTS

Page

I.

INTRODUCTION....

.........................

..... 2

II. SUMMARY OF RESULTS................................. 2

III.

CRITERIA

......................................... 4

IV.

PERFORMANCE ANALYSIS................................ 4

A.

Plant Operations

............................. 4

B.

Radiological Controls ......................... 6

C.

Maintenance/Surveillance ....................... 9

D.

Emergency Preparedness...

..................... 11

E.

Security

................................... 12

F.

Engineering/Technical Support .................. 14

G.

Safety Assessment/Quality Verification.............16

V.

SUPPORTING DATA AND SUMMARIES ....................... 17

A.

Licensee Activities..........................17

B.

Direct Inspection and Review Activities............18

C.

Escalated Enforcement Activities...................18

D.

Management Conferences...................

..... 19

E.

Confirmation of Action Letters............

..... 19

F.

Reactor Trips/Unplanned Shutdowns...............20

G.

Review of Licensee Event Reports................21

H.

Licensing Activities.....

....................21

I.

Enforcement Activity..........................22

2

I.

INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and to evaluate licensee performance on the basis of this

information.

The program is supplemental to normal regulatory processes used

to ensure compliance with NRC rules and regulations. It is intended to be

sufficiently diagnostic to provide a rational basis for allocation of NRC

resources and to provide meaningful feedback to the licensee's performance in

each functional area.

An NRC SALP Board, composed of the staff members listed below, met on June 8,

1993, to review the observations and data on performance, and to assess

licensee performance in accordance with the guidance in NRC Manual Chapter

NRC-0516, "Systematic Assessment of Licensee Performance". The Board's

findings and recommendations were forwarded to the NRC Regional Administrator

for approval and issuance.

This report is the NRC's assessment of the licensee's safety performance at

the Oconee Units 1, 2 and 3 for the period February 2, 1992, through May 1,

1993.

The SALP Board for Oconee was composed of:

J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP),

Region II (RII), (Chairman)

J. P. Jaudon, Deputy Director, Division of Reactor Safety (DRS), RH

J. P. Stohr, Director, Division of Radiation Safety and Safeguards

(DRSS), RH

A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RH

D. B. Matthews, Director, Project Directorate 11-3,

Office of Nuclear Reactor Regulation (NRR)

L. A. Wiens, Project Manager, Project Directorate 11-3, NRR

P. E. Harmon, Senior Resident Inspector, Oconee, DRP, RII

Attendees at SALP Board Meeting:

M. S. Lesser, Chief, Reactor Projects Section 3A, DRP, RII

W. H. Miller, Jr., Project Engineer, Reactor Projects Section 3A, DRP, RII

W. K. Poertner, Resident Inspector, Oconee, DRP, RH

R. L. Watkins, Project Engineer, Reactor Projects Section 3A, DRP, RII

II. SUMMARY OF RESULTS

Oconee was operated safely during the assessment period. This included

improvement in shutdown operations.

Effective command and control over plant

evolutions was exercised. Weaknesses remained in configuration control and

procedural usage.

The previously established organizational structure

impaired effective oversight of Keowee by nuclear operations. Following the

loss of offsite power event of October 1992, Keowee was reorganized, and

programs for operator standards and training were developed.

3

Performance in the radiological protection area was superior. The ALARA

program remained strong. The water chemistry and the environmental and

effluent monitoring programs were effectively implemented. The organization

was stable, and the radiological training program was good. Deficiencies were

identified with radioactive material labeling, area posting and adherence to