ML18010A941
| ML18010A941 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/25/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A940 | List: |
| References | |
| 50-400-92-20, NUDOCS 9212080240 | |
| Download: ML18010A941 (39) | |
See also: IR 05000400/1992020
Text
ENCLOSURE
INITIAL SALP
REPORT
U. S.
NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT
OF
LICENSEE
PERFORMANCE
Inspection
Report
Number
50-400/92-20
Carolina
Power
and Light Company
Shearon Harris
June
2,
1991 to September
26,
1992
92i2080240 92ii25
ADOCK 05000400
I.
INTRODUCTION
II.
SUMMARY OF
RESULTS
III.
CRITERIA
IV.
PERFORMANCE ANALYSIS
TABLE OF
CONTENTS
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2
3
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3
A.
B.
C.
D.
E.
F.
G.
Plant Operations
Radiological Controls
.
Maintenance/Surveillance
Emergency
Preparedness
Security
4
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Engineering/Technical
Support
Safety Assessment/guality
Veri
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fication
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3
5
8
11
12
14
16
V.
SUPPORTING
DATA AND SUMMARIES
.
19
A.
B.
C.
D.
E.
F.
G.
H.I.
Licensee Activities .
Direct Inspection
and Review Activities
.
Escalated
Enforcement Action
Significant Licensee
Conferences
Held Duri
Period
Confirmation of Action Letters
.
Review of Licensee
Event Reports
(LERs)
.
Licensing Activities
Enforcement Activity
ng
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The Appraisal
19
.
20
.
20
20
.
21
.
21
.
21
.
22
.
22
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
licensee
management
regarding the
NRC's assessment
of their performance
in each functional area.
An
NRC SALP Board,
composed of the staff members listed below,
met on
November 4,
1992, to review the observations
and data
on performance
and
to assess
licensee
performance
in accordance
with 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 Shearon
Harris for the period June
2,
1991 through September
26,
1992
'he
SALP Board for Shearon
Harris was
composed of:
E.
W.
B. S.
C. A.
D.
M.
J.
E.
E.
G.
N.
B.
Merschoff, Director, Division of Reactor Projects
(DRP), RII
(Chairperson)
Mallett, Deputy Director, Division of Radiation Safety
and
Safeguards,
RII
Julian, Chief, Engineering
Branch, Division of Reactor Safety,
RII
Verrelli, Chief, Reactor Projects
Branch
1,
DRP, RII
Tedrow, Senior Resident
Inspector,
Shearon Harris,
DRP, RII
Adensam,
Director, Project Directorate II-1 (PD II-1), Office of
Nuclear Reactor Regulation
(NRR)
Le, Project Manager,
Attendees
at
SALP Board meeting:
H. 0. Christensen,
Chief, Reactor Projects
Section
1A,
DRP, RII
D. J. Roberts,
Project Engineer,
Project Section
1A,
DRP, RII
SUMMARY OF
RESULTS
During the assessment
period,
Shearon Harris continued to be operated
in
a safe
and effective manner.
Maj or strengths
were identified in the
areas of security,
emergency
preparedness,
engineering/technical
support
and radiological controls.
Weaknesses
were identified in the safety
assessment/quality
verification section.
Good management
involvement in plant operations activities
and site
walkdowns contributed to the overall safe operation
and good material
condition of the plant.
However, inconsistent
performance
by operators
during transient
and routine operations
resulted
in a declining trend.
Implementation of the radiation protection
program was good.
Efforts to
control radiation exposure
were noteworthy
and effective
as were those
efforts to reduce
contaminated
areas.
Strengths
were noted in the preventative
maintenance
program
and
improvement
was noted in the area of post-maintenance
testing.
Additionally, management
involvement in maintenance activities
was also
exhibited.
Some weaknesses
in the performance of maintenance activities
was observed
including one which caused
a reactor trip.
Strengths
were noted in the emergency
preparedness
area,
specifically
during two annual
graded
emergency
exercises.
Good management
support
was also noted in the area of simulator configuration control
and the
maintenance
of emergency
response facilities and equipment.
Implementation of the security program was good.
Hardware
changes,
training and good management
involvement in this area contributed to
this successful
implementation.
Engineering
and technical
support continued to be good.
Strong
engineering
support
was demonstrated
through refueling activities, the
system engineering
program
and engineering
evaluations
associated
with
plant modifications.
However,
a weakness
was noted for an inadequate
post-trip review.
Licensee
performance
in the area of safety
assessment
and quality
verification was less effective than during the previous cycle.
Weakn'esses
were noted in the corporate
self-assessment
function.
Overall, the licensee's
performance
was considered
to be superior.
Overview
Performance
ratings for the last rating period
and the current period
are
shown below.
Functional
Area
Rating Last Period
Rating This Period
~l
Plant Operations
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
and Safeguards
Engineering/Technical
Support
Safety Assessment/equality
Verification
1
1
2
1
1
1
1
1 (declining)
1
2 (improving)
1
1
2
III.
CRITERIA
The evaluation criteria which were used to assess
each functional
area
are described
in detail in
NRC Manual Chapter 0516, which can
be found
in the Public Oocument
Room.
Therefore,
these criteria are not repeated
here,
but will be presented
in detail at the public meeting held with
the licensee
management.
IV.
PERFORMANCE ANALYSIS
A.
Plant
0 erations
~Anal sis
This functional
area
addresses
the control
and performance
of activities directly related to operating the facility,
including fire protection.
The plant was operated
in a safe
and conservative
manner
during the assessment
period.
Four reactor trips occurred
from power operation
and one Reactor Protection
System
actuation occurred while the plant was shutdown.
There were
no reactor trips during the last assessment
period.
Two of
the reactor trips this period involved component failure,
one occurred during the performance of a maintenance
calibration procedure,
and
a manual reactor trip was
inserted
when
a main feedwater
pump tripped following
deenergization
of an electrical
bus for a breaker failure.
Three of the four reactor trips occurred during
a one week
period.
The plant had
an excellent continuous
run of 271
days which set
a plant record.
The plant was managed
conservatively
as evidenced
by the decision to shutdown
and
repair boric acid leakage
on
temperature
detector
bypass line even though leakage
was
well below regulatory limits.
Operating activities were generally conducted
in a
professional,
dedicated,
and conscientious
manner.
Shift
turnovers
and the performance of operator
rounds
were
considered
to be good.
Good attention to detail
was
exhibited
by an operator during the performance of rounds to
identify an improper flange
on the turbine-driven auxiliary
pump lube oil cooler.
Also, operator
performance
to control
a plant transient during troubleshooting
on the
digital electric hydraulic control
system
was good.
Operator performance
during plant transients
was
inconsistent,
however,
as evidenced
by poor control of steam
generator
level
and steam pressure
which both resulted
in
unnecessary
safety
system actuations.
In addition,
instances
were noted during routine operations
indicating
a
lack of attention to detail.
In one instance
operators
failed to detect
a mispositioned
switch which rendered
the
quadrant
power tilt alarm inoperable.
In another,
operators
failed to notice
a low oil condition in a safety injection
pump.
Operator actions which failed to properly identify
and document several
adverse
conditions resulted
in three
violations.
Administrative controls regarding plant operations
were
considered
to be effective.
A new program was developed to
control infrequent tests
and evolutions.
The additional
management
involvement, planning,
and interdepartmental
communication which resulted
from this program
had
a
definite benefit to safe plant operation.
However,
areas
in
need of improvement were also noted.
Boric acid system
temperature
monitoring alarm response
procedures
for
radwaste
personnel
did not provide sufficient guidance.
Additionally, the operating
procedure
for removing
a hose
from a demineralizer filter was weak which resulted in
personnel
and area contamination.
Plant housekeeping
was considered
to be good.
Progress
was
made in a new paint and labeling program which was initiated
during this assessment
period.
The practice of weekly
management
inspections
of areas
inside the power block and
specific outside
areas
was continued.
This effort was
effective in identifying housekeeping
deficiencies.
The licensee reinstituted the practice of rotating licensed
personnel
to other departments/work
groups.
Several
licensed
operators
were rotated to the operations
procedure
writers group,
work scheduling
group, real-time trainer
position,
and the load dispatcher's
office.
The licensee
maintains extra licensed
personnel
on shift in excess of TS
requirements.
Additionally, licensed
operators
have
been
transferred
to the training department
and the Nuclear
Assessment
Department
(NAD) to increase
the technical
expertise
in these
areas.
2.
Formal
communication
was observed
between control
room
operators
and between control
room personnel
and auxiliary
operators
in the field.
Use of repeat
backs
was
common.
Day-to-day communications
between shift operating
personnel
and technical
support
system engineers/managers
and
maintenance
managers
was evident.
Operations
management
was
routinely observed
monitoring several
of the planned
shutdowns
and startups.
Control
room drawings
were found to correctly reflect plant
conditions.
However, the
NRC identified deficiencies
in
updating
one set of drawings to accurately depict
modifications which had
been
performed
on the
CCW system.
Operator logs were found to be organized,
and usually
provided sufficient information on plant status
and events.
However,
one instance
was noted where
a deficiency regarding
a service water valve was not adequately
addressed.
The fire brigade duties were assigned
to radwaste
operating
personnel.
A licensed operator
was also assigned
to the
brigade
as
an advisor.
This action allowed less
impact on
main control
board personnel
and allowed more detailed fire
fighting training to be provided.
The fire brigade
response
to several
minor fires was considered
to be satisfactory.
During this assessment
period six violations were cited.
Performance
Ratin
3.
Category:
1
Trend:
Declining
Board Recommendations
The Board determined that there
was
a decline in performance
during this period
as evidenced
by inconsistent
operator
performance
during transients
and
a lack of attention to
detail during routine operations.
Even though performance
remained superior,
in this area,
management
attention to
this trend is considered
appropriate.
Radiolo ical Controls
~Anal sis
This functional
area
addresses
activities related to
radiological controls, radioactive waste
management,
environmental
monitoring, water chemistry,
and
transportation of radioactive materials.
The licensee
continued,to maintain stable
and well qualified
radiological controls staffing.
Sufficient numbers of
qualified technicians
were available to support both outage
and non-outage activities,
and the licensee
ensured
a
favorable return rate for contractor technician
support for
the
1992 refueling outage.
The technician continuing
training program was considered
comprehensive
and included
plant systems
overview and performance related training.
In
addition, the licensee actively supported
technician
certification by the National Registry of Radiation
Protection Technicians,
and certified twelve radiation
control personnel.
Hands-on-training facilities utilized
radiation detector simulation to reinforce
ALARA concepts.
The licensee
took steps to improve performance
in the area
of self-assessment
during the period.
In particular,
increased
management
attention to the feedback reporting
system
was evident
by the implementation of causal
factor
trending
and close-out of old action items.
Overall, the licensee
continued to effectively manage
collective dose expenditure
during the assessment
period.
Collective dose for the period was approximately
82 person-
rem.
This dose level
was good since it reflected
expenditure primarily for operating conditions
and spent
fuel operations with 28 outage
days during the period.
The
licensee
also
began refueling outage activities thirteen
days prior to the end of the period.
The licensee
effectively managed
dose for significant activities
including an unplanned
outage to repair
a resistance
temperature
detector valve.
The dose for this activity was
considered
low at approximately 7.4 person-rem.
Licensee
personnel
exhibited effective
ALARA planning which limited
personnel
exposure.
For example,
detailed pre-planning for
work (adding oil to reactor coolant
pumps, repairing valves,
and cleaning waste storage
tanks)
included conservative
power reductions,
mockup training on spare
equipment,
and
the
use of video cameras
and dose rate instruments for
remote monitoring of job performance.
The licensee
also
actively decreased
radiation sources
in the plant by
cleaning waste tanks.
Licensee
planning
and preparation for the
1992 refueling
outage
was thorough,
and the established
goal of 165 person-
rem appeared
aggressive
relative to the scope of work.
The licensee's
contamination control
and housekeeping
practices
were considered
excellent.
The average
contaminated
surface
area continued to trend downward with
respect
to previous
assessment
periods.
The licensee
also
actively tracked valves which exhibited leakage of
contaminated liquid so that appropriate
management
attention
could be applied.
Personnel
contamination
events for the
year
1991
and through September
26,
1992,
were
131
and 44,
respectively.
This is about the
same level
as that observed
during previous single outage
and non-outage
periods.
One
isolated
poor practice
was identified late in the assessment
period associated
with trash frisking operations.
Immediate
corrective actions
were implemented,
and the licensee
initiated actions to evaluate
the need for long-term
training and procedural
improvements.
Improvements
in both radiological
and chemical controls
associated
with fuel stored in the spent fuel pools were
noted during this assessment.
As mentioned in the previous
assessment
report,
the licensee
removed
a significant amount
of crud from the bottom of the spent fuel pools.
Licensee
management
decided to halt any further clean-up of crud
as
a
method of reducing
dose to plant personnel.
Thus,
crud
management for spent fuel continues to provide
a challenge
for contamination control.
Issues
regarding technician training for the operation of
the Post Accident Sampling
System
and the development of a
procedure to remove
an undiluted
sample
from a shielded
container
were resolved.
Although significant progress
has
been
made,
some operability problems identified during the
last assessment
continued.
The licensee
was implementing
corrective actions to resolve those problems.
The plant water chemistry program was effectively
implemented,
maintaining chloride, fluoride, dissolved
and dose equivalent iodine well within their
respective
TS limits.
A sampling
system
was installed for
in-line monitoring of chemistry conditions in the secondary
side of the plant.
The system
was undergoing testing at the
end of the assessment
period.
Secondary
chemistry
was very
good
as evidenced
sludge lancing results
with less than
50 pounds of sludge per generator for each of
the last two operating cycles.
The liquid and gaseous
effluents
program
was
managed
effectively.
During this period, the licensee
continued to
have
some effluent radiation monitors declared
for periods greater
than
30 days.
The licensee
made
a
concerted effort to return effluent radiation monitors to
operable status.
This effort was successful
as the number
of inoperable monitors
was reduced
by the end of the period.
Two non-routine
gaseous
releases
were recorded during this
period.
Liquid and gaseous
effluents for the 12-month
period from mid-1991 to mid-1992 were well within regulatory
limits.
The maximum whole body dose
was less
than five
percent of the allowable limit.
2.
The Radiological
Environmental Monitoring Program
was
implemented effectively.
Collection stations
were
calibrated
and well maintained.
Licensee
sample results
compared favorably with those of the State of North
Carolina.
Overall, the radiological
environmental
data
indicated that plant operations
had
no significant impact on
the environment or public health
and safety.
Shipping
and handling of radwaste
were efficient, reflecting
the competence,
training,
and experience
of the staff.
In
general,
shipping documentation
was in compliance with
requirements.
During this assessment
period,
no violations were cited.
Performance
Ratin
3.
Category:
I
Board Recommendations
None
Maintenance Surveillance
~Anal sis
This functional
area
addresses
those activities related to
equipment condition, maintenance,
surveillance
performance,
and equipment testing.
Performance of maintenance
and surveillance activities
continued to be effectively performed.
For the majority of
activities observed,
performance of work was good with
proper documentation of removed or replaced
components
and
independent verification of their reinstallation.
Maintenance efforts to decrease
air lock leakage
were
effective.
However,
instances
of inattention to detail
were
also noted.
One reactor trip occurred during the
performance of a maintenance
surveillance test
when
a
pressure
pulse occurred
on the
common leg of the three
reactor coolant flow detectors
while a flow transmitter
was
being returned to service.
One
AFW system actuation
was
reported while troubleshooting
a steam generator level
instrument.
The cause
was attributed to
personnel
error.
An additional
weakness
was noted where licensee
personnel
failed to properly reference
the equipment technical
manual
during an oil addition to the turbine driven auxiliary
pump.
The resultant
improper oil level could have
caused
pump damage if not corrected.
Good pre-planning to reduce
personnel
exposure,
equipment
down time,
and avoid plant transients
was evident for
several
maintenance activities.
This planning included
utilization of spare
equipment for mock-up training, pre-
evolution briefings with operations
personnel,
and
contingency planning.
This demonstrated
supervisory
involvement in these activities.
Specialized
vendor training programs,
the continuing
training program,
hands-on training facilities,
and
a low
turnover rate
have
enhanced
the craft skills and knowledge.
A full-time dedicated
crew of instrumentation
and control
technicians
was maintained to perform testing
and
troubleshooting
associated
with RPS
and
ESF instrumentation.
This has provided consistency
in job performance
and
resulted
in fewer problems
associated
with the testing
and
maintenance
performed
on these
systems.
The backlog of maintenance
work was relatively constant.
Plant management
assigned
an additional
IKC crew which
started to reduce the backlog at the end of this assessment
period.
The overall material condition of the plant was good.
However, specific deficiencies,
such
as oil leaks
on the
safety injection pumps
and several
safety injection valve
motor operators,
needed
improvement.
Sodium hydroxide
leakage
was noted
on several
transmitters
associated
with
the containment
spray additive system.
Also,
a few
emergency
service water vent and drain valves
had signs of
general
corrosion.
The licensee
took action to correct
these deficiencies
and significant improvements
were noted,
especially in the area of. boric acid and sodium hydroxide
leakage control.
The licensee
continued the preventive maintenance
program
for large
pumps
and motors by completing inspections
on the
normal service water pumps.
This program
has
been effective
in ensuring the reliability of this type of equipment.
Strengthening
of the licensee's
predictive maintenance
activities
was demonstrated
during this assessment
period
due to improvements in the vibration and lube oil analyses
programs.
These
included the completion of monthly
vibration tests for normally operating safety-related
equipment,
with more frequent testing
as
needed,
and the
adoption of an expanded list of equipment requiring lube oil
testing.
Vibration analyses
detected
problems with the
jockey fire pump
and
a main feedwater
pump enabling repairs
before
pump failure.
was utilized to detect
hot spots
in large motors,
process
instrumentation
cabinets,
rod drive cabinets,
and the switchyard.
10
As discussed
in the previous
SALP report, efforts to improve
post-maintenance
testing were in progress.
The licensee
has
expanded
the planner's test matrix, completed training on
the
new matrix,
and enhanced
the Automated Haintenance
Management
System database
to improve the post-maintenance
testing process.
Improvement
was noted during this
assessment
period.
The licensee
developed
a formal program for the conduct of
infrequent tests
and evolutions to strengthen
the
communication
and pre-planning
between
maintenance
and
operations
personnel.
Industry guidance
on the conduct
and
substance
of pre-job briefings, training,
and procedures
to
be utilized,
was included.
Likewise, the licensee
developed
a troubleshooting
procedure
incorporating risk-oriented
reviews
by management.
Strong supervisory
and management
involvement was noted for
several
work activities.
Work involving the entry into TS
action statements
received
management
attention.
Haintenance
managers
were observed daily in the control
room
communicating with operations
personnel
on equipment
problems.
Hanagement
was also involved in on-the-job-
training and qualification of personnel.
This action
contributed to improved procedural
compliance.
The surveillance test scheduling
program continued to
perform well.
The reports
generated
from this system
allowed management
to focus attention
on potentially overdue
tests.
No scheduled
tests
were overdue or missed.
However,
on one occasion,
pump testing periodicity was not
increased
as required.
The licensee's
approved inservice
inspection (ISI) program continued to be satisfactory.
program procedural
requirements
and responsibilities
were
clearly defined.
Technical
and supervisory
personnel
were
generally
knowledgeable
in their areas of responsibility.
During the assessment
period, four violations were cited.
Performance
Ratin
Category:
2
Trend:
Improving
Board Recommendations
None
11
Emer enc
Pre aredness
~Anal sis
This functional
area
addresses
activities related to the
implementation of the
Emergency
Plan
(EP)
and procedures,
support
and training of onsite
and offsite emergency
response
organizations,
and licensee
performance
during
emergency
exercises
and evaluated
actual
events.
Good management
support for the
EP program was demonstrated.
The licensee carried out several drills to test alternates
for response
positions, initiated
an auto-dial call-out
system
and relocated
the Operational
Support Center
(OSC) in
an effort to protect workers from potential radiation
plumes.
The licensee
continued to provide effective
Emergency
Response
Organization training .hroughout the assessment
period.
With one exception, all personnel
had completed
the
required training.
The licensee
maintained
emergency
response facilities and
equipment in a state of readiness
through equipment
surveillance
and functional testing.
Two equipment
operability problems did occur.
One problem involved
inadequate
maintenance
of the gross failed fuel detector
and
the other was the inoperability of some
Emergency
Response
Facility Information System
(ERFIS) terminals.
Both issues
were corrected,
with the latter resulting in improved
ERFIS
reliability.
The licensee's
audit and critique program
was effective in
identifying routine
and exercise conditions requiring
corrective actions.
Hanagement
reviewed these findings and
.
verified that corrective actions
were taken.
The licensee
implemented its Emergency
Plan in response
to
one event this period.
The event
was correctly classified
as
a Notification of Unusual
Event, with offsite
notifications performed in a timely manner.
'arris
demonstrated
good response
capability for dealing
with site emergency situations during graded exercises
in
September
1991
and August 1992.
During the exercises,
the
licensee
demonstrated it could implement the
Emergency
Plan
and its implementing procedures,
as well as take suitable
actions to mitigate the consequences
of the accident
scenarios.
Emergency classifications
were timely as the
scenarios
progressed,
and operation of the emergency
response facilities and equipment
was good.
Performance
strengths
observed
during the exercises
included good
12
2.
teamwork
and aggressive
play of participants.
Improvement
was noted in the involvement of the accident
assessment
team
and casualty control
team from the
OSC.
The
command
and
control exhibited
by the Technical
Support Center
(TSC)
and
Emergency Operations Facility (EOF)
Emergency Directors
and
the licensee's
critique process
were also exercise
strengths.
All substantive
findings were documented for
review and corrective actions.
Although no exercise
weaknesses
were identified,
some minor problems
were noted
in the areas of notification messages
to offsite authorities
and issuance
of dosimetry to TSC and
EOF personnel.
During the assessment
period,
one violation was cited.
Performance
Ratin
3.
Category:
1
Board Recommendations
None
~Secure it
~Anal sis
This functional
area
addresses
those security activities
related to protection of vital plant systems
and equipment,
and special
nuclear material.
The licensee
implemented
and managed
an effective security
program.
Security management
at both the site
and corporate
level
was skilled and highly visible in program activities.
The licensee
revamped
the training program for supervisors
to enhance
communications.
Many program improvements
implemented
since the last assessment
show site
and
corporate
management's
strong support.
Examples of these
included
enhanced
alarm stations
and assessment
capabilities,
and patrol
and response
personnel
effectiveness.
The security force was professionally
and effectively
staffed,
equipped,
and trained to do their assigned
duties.
The security training staff was dedicated
and knowledgeable.
The licensee
has initiated several
programs that have
enhanced
the security force's professionalism.
The most
effective items were the creation of an improved combat
stress
course
using
new rifles and the purchasing of a new
security radio system that has encryption capabilities.
The licensee
continued to identify and implement methods to
better perform the security program.
The licensee
enhanced
13
2.
their protected
area patrol capabilities
by obtaining
several
security patrol vehicles.
This improved the
effectiveness,
efficiency,
and morale of the security
personnel
by providing weather protection
and increasing
the
patrol
and response
speed of the security officers.
The
acquisition
and issuance
of new smaller
and lighter
semiautomatic rifles have also
improved the response
capabilities of the response
force.
The licensee
has
replaced
the older tube driven closed-circuit television
(CCTV) cameras
with new solid state
cameras,
which has
improved picture quality and coverage.
Alarm
stations'ssessment
capabilities
were enhanced
by the addition of a
Video Capture
system with a new video switcher
and larger
CCTV monitors.
To further enhance
the alarm
stations'ssessment
proficiency,
a Computer Aided Lighting Analysis
program was
used to upgrade
and identify illumination
deficiencies within the protected
area.
Licensee
management
continued to provide trend data to
system engineers
and maintenance
personnel
in order to
maintain security equipment at
an acceptable
level.
The licensee's
Physical Security,
Contingency
and Training
and gualification Plan revisions submitted during this
period were consistent
with 10 CFR 50.54(p),
and were timely
and adequately
coordinated with the
NRC.
The licensee's
staff,
who coordinated security plan revisions
and technical
specification
changes,
were knowledgeable of regulatory
requirements.
During this assessment
period,
no violations were cited.
Performance
Ratin
3.
Category:
1
Board Recommendations
None
En ineerin
Technical
Su
ort
~Anal sis
This functional
area
addresses
those activities associated
with the design of plant modifications,
engineering
and
technical
support for operations,
outages,
maintenance,
and
operator training.
Overall, engineering
continued to provide effective
technical
support to the operation of the facility.
Strong
engineering
support
was demonstrated
through refueling
14
activities; the predictive maintenance
and repetitive
failure analysis
programs;
the system engineering
program
and engineering
evaluations
associated
with plant
modifications.
High levels of corporate
engineering
onsite involvement
during modification development
and implementation
were
evident.
The licensee's
administrative controls for
ensuring reliable decay heat
removal during outages
was
noteworthy.
These controls included provisions for
identification of higher risk evolutions
and
key safety
functions, defense-in-depth
contingency planning, training,
and outage risk assessment
reviews.
In addition, this
information was emphasized
during outage
meetings to help
reduce
the potential for loss of shutdown cooling events
during outage activities.
Furthermore,
the refueling outage
plan did not include mid-loop operating conditions.
Excellent technical
support
was evidenced
by reactivity
management for planned
power reductions
and outages.
This
action
was effective in controlling axial flux peaking.
The
power ascension
test
program,
which was created
following a
nuclear instrumentation miscalibration event,
was utilized
to control plant startups without any further mishaps.
Additionally, technical
support personnel
were actively
involved in maintenance activities such
as troubleshooting
the
ATWS Mitigation System Actuation Circuitry and the
emergency
service water screen
wash
pumps.
Another example
of good performance
was the analysis of self-identified
weaknesses
in secondary
side performance monitoring which
resulted
in the installation of a computer workstation that
would access all Emergency
Response
Facility Information
System database
points
and provide real-time display of
secondary
and primary side data.
Some weaknesses
were identified in the area of technica'l
support.
These
included
an inadequate
post-trip review
which did not identify the potential for reactor trip
breaker failure based
on previous industry events,
inadequate
design control of pipe supports
in the boric acid
system
and emergency diesel
generator
lube oil system,
inadequate
incorporation of manufacturers'ecommendations
into procedures for periodic heat trace
panel calibration,
and the omission of several
required
items in the
PM program
for the turbine driven auxiliary feedwater
pump.
The
licensee
recognized
the problems with the
PM program
and
implemented
a technical
manual
review process
to identify
similar items.
Engineering
and technical
support organizational
involvement
in the outage planning process
was
an identified strength.
There were several
system engineers
designated
as
coordinators for various major outage activities including
15
work and electrical
bus outages.
These
individuals were knowledgeable
and organized
as reflected
by
the efficient completion of their assigned
work activities.
In addition to these
designated
coordinators,
many other
system engineers
were involved in other aspects
of outage
planning activities which contributed to the overall outage
efficiency.
The licensee's
system engineering
program
was effective.
System Engineers
took ownership of their systems.
Their
level of knowledge of both system. history and performance
was
commendable.
System engineers
were actively involved in
troubleshooting,
performance monitoring,
and the
coordination of corrective actions.
An example
was
a
containment
temperature
monitoring change initiated to
provide data for equipment qualification concerns.
The
modification involved the installation of resistance
temperature
detectors
at various locations throughout
containment to verify that local temperature
conditions did
not exceed technical specification limitations.
Additionally, the licensee
continued to foster strong
communications
and effective working relationships
between
engineering
and other plant organizations that was evident
during previous
SALP periods.
Hodifications
and engineering
evaluations
generally
contained clear safety reviews
and were considered
to be
technically sound
and acceptable.
Examples
included
modifications to the reactor cavity seal ring instrument air
piping to allow component testing
and calibration prior to
use inside containment,
and annunciator setpoint
changes
to
prevent spurious
alarms
and to more accurately reflect main
feedwater flow limits.
However,
a plant change
request
to
return the component cooling water system to its normal
configuration following a relief valve lifting event failed
to accomplish its purpose
due to lack of interdepartmental
communications.
A lack of progress
to modify emergency
diesel
generator starting air quality was
an example of
inadequate
modification prioritization.
The temporary
modification process
was strengthened
by the inclusion of
jumpers
and lifted leads
A motor-operated
valve testing
and surveillance
program
had
been
developed
which adequately
addressed
most of the
recommendations
Strengths
in the
program included the use of state-of-the art diagnostic
systems,
knowledgeable
and well trained personnel,
extensive
licensee
involvement in industry groups,
and effective
programmatic incorporation of industry experience
and vendor
information.
However, several
concerns
were noted.
The
concerns primarily involved
a potential reduction of the
scope of differential pressure
testing,
the use of static
16
2.
rather than dynamic flow testing to demonstrate
design basis
acceptability,
and the potential for non-conservative
sizing
and thrust calculations
due to failure to incorporate rate-
of-loading effects.
The licensed operator training program continued to be
effective as evidenced
by a
100% pass rate
on the Generic
fundamentals
Examination Section
and initial examinations.
Improvement of weaknesses
identified during the last
assessment
period
was evidenced
by improved communications
among crew members
during an initial examination
administered to eight candidates
this assessment
period.
The requalification program
was found to be satisfactory
when all twenty operators
passed
the NRC-administered
requalification examination.
The licensee
adequately
evaluated its operators.
However, inconsistencies
were
noted in the performance of evaluators
during walkthroughs.
The simulator was
used effectively for training.
The
licensee
has
implemented corrective actions to alleviate
simulator deficiencies identified during examination
administration.
The licensed
operator training staff has
been
supplemented
by three licensed
operators
which should
strengthen
the technical
expertise of the department.
During the assessment
period,
no violations were cited.
Performance
Ratin
3.
Category:
1
Board Recommendations
None
Safet
Assessment
ualit
Verification
~Anal sis
This functional
area
addresses
those activities related to
licensee
implementation of safety policies;
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
use of feedback
from self-assessment
programs
and
activities.
Licensee
performance
in the area of safety
assessment
and
quality verification was satisfactory.
However,
as
mentioned in the previous
assessment
report,
the licensee
had not achieved
the desired results
from its first level
assessment
process,
which included individual self-checks,
17
management
supervision,
independent
verification> post-
maintenance
testing
and corrective action program trending.
With regard to onsite self assessment,
plant management
continued to perform frequent inspections
and tours of
various plant areas
focusing
on the general
cleanliness
and
material condition of equipment.
These activities
had
a
positive effect on plant housekeeping.
Nanagement
involvement
was evidenced
by the coaching of personnel,
the
conduct of infrequent activity pre-evolution briefings,
and
direct observation of critical work involving TS equipment
inoperability.
The Adverse Condition Report system
has
been fully
implemented.
Due to the lower threshold for reporting
problems than with the previous
system,
the data
base
has
grown considerably
which has allowed more meaningful
problem
trending.
Self-identification of problems continued to be
a
strength in this assessment
area.
However, four violations
were cited regarding the failure to adequately identify,
document,
and correct deficiencies,
as mentioned
in the
Operations
and Engineering/Technical
Support sections of
this report.
Good participation
and advance
preparation
by plant nuclear
safety committee
members for those
items discussed
in
committee meetings
was noted.
Minutes from the meetings
contained
accurate
documentation of the committee's
activities.
Corporate responsibilities
included quality verification
surveillances
and independent
evaluations.
In contrast to
the good on-site self assessment
effort, corporate
activities were initially found to be deficient in several
areas.
For most of the rating period, little change
was
noted in the minimal involvement of the guality Verification
(gV) organization.
This organization
had recently
begun to
assist
the plant organizations
in self-assessment
field
surveillances
during which
a
gV inspector is temporarily
assigned
to the other group,
observes
a work activity, and
reports discrepancies
to the area
manager.
Although two
self-assessment
field surveillances
were found to be of high
quality, only two were performed.
Near the end of this
assessment
period,
gV involvement was increased
and the
licensee
hired two additional
personnel
so that field
surveillances
could
be continued throughout the outage.
The initial performance of onsite quality assessments
was
considered
to be poor.
Audits were found to be fragmented
and lacked sufficient documentation
to draw meaningful
conclusions
or measure
effectiveness.
Audits were not
always forwarded to senior licensee
management
in a timely
18
manner.
The licensee
made extensive efforts to correct the
violations
and weaknesses.
Improvement
was noted near the
end of this assessment
period
as to the adequacy of audit
documentation
and timeliness of submittal to higher
management.
The
amendment
requests
for changes
to TS were adequate
in
providing "no significant hazards
considerations"
evaluations.
Licensee
management's
involvement in
interacting with the staff during meetings,
site visits,
and
the review of licensing/technical
issues,
and in the timely
submittal of license
amendment
requests
remains effective.
One exception
was noted
when the licensee failed to submit
a
timely request for a TS change
regarding surveillance
requirements for the emergency
core cooling system.
No
emergency
TS changes
were requested
during this period.
Some licensee
strengths that were observed
in the last
were sustained
during this assessment
period.
The licensee
was effective
and pro-active in identifying potential
safety
problems during their review of documentation
related to
license
amendment activities
and generic industry
communications.
When
a safety concern
was identified, the
licensee
addressed
all aspects
of the issue to satisfy all
regulatory
as well as plant safety aspects.
Examples
included the identification of a discrepancy
involving the
safety injection switch-over time from cold leg to hot leg
recirculation during the long-term cooling phase of a loss
of coolant accident
and implementation of the Station
Blackout Rule.
The licensee's
responses
to Bulletins and Generic Letters
had
bee'n timely and met staff requirements.
The licensee
demonstrated
a conservative
approach
to issues
and
had
placed
a high priority on the assessment
of industry
experience
to improve plant safety
and performance.
Plant
management
conservatively
decided to shut the unit down in
response
to boric acid leakage
from valves in the reactor
coolant
system
even though leakage
was well within TS
limits.
Industry experience
was shared with all on-site
managers
and system engineers
and programs
were established
to address
industry concerns
which included the main turbine
emergency trip system,
fuse control
and replacement,
and
solenoid valve reliability.
During this assessment
period, longstanding deficiencies
in
the design
and testing of the high head safety injection
system were resolved
by design
changes.
The
10 CFR 50.59 review process
at Harris was consistent
with approved industry guidance
and
was considered
to be
a
strength
because
trained, tested,
and experienced
reviewers
19
were maintained
by technical discipline;
and the. necessary
procedures
were in place.
In addition,
two independent
reviewers routinely performed the required evaluation to
confirm the conclusions.
During this assessment
period, five violations were cited.
2.
Performance
Ratin
3.
Category:
2
Board Recommendations
II
The Board continued to be concerned
over the lack of
Corporate activities
on self assessment
and field
surveillance efforts.
Management attention in this area is
warranted.
SUPPORTING
DATA AND SUMMARIES
A.
Licensee Activities
The plant began
the assessment
period at
100 percent
power.
On
June 7,
1991, the plant was shutdown to perform additional post-
maintenance
testing
on
a reactor trip switch.
Full power
operations
resumed
on June 9,
1991.
On March 6,
1992, the reactor
was
shutdown to repair leaking valves
on the
C
RTD bypass
This outage
ended
a record continuous
run of 271 days.
The plant returned to normal
power operations
on March 12,
1992.
The plant was shutdown for refueling outage
No.
4 on September
12,
1992.
B.
Significant management
changes
occuring this
SALP period included
the creation
and filling of the
new President/Chief
Operating
Officer position who reports directly to the existing Chief
Executive Officer.
In addition,
a new Site Vice President
was
assigned.
A new Chemistry Manager
was also assigned
during the
period.
Direct Ins ection
and Review Activities
During the assessment
period,
one special
audit,
31 routine
and
five special
inspections
were performed at the Harris facility by
the
NRC staff.
The special
audit and inspections
were:
June 3-7,
1991; Inspection of Activities Associated with
Reactor Trip Breaker Failure Following the June 3,
1991 Trip
September
23-26,
1991;
Emergency
Preparedness
Program
Review
October
21 - November
16,
1991;
Program
Review for Changes
to Plant Environs
20
~
April 6 - 10,
1992; Motor-Operated
Valve Inspection
~
August
3 - 7,
1992; Audit of the High Head Safety Injection
Alternate Miniflow System
and Related
Issues
~
August
31
- September
4,
1992;
Emergency Operating
Procedures
Followup Inspection
Escalated
Enforcement Action
Orders
None.
2.
Civil Penalties
(CP)
Severity Level III problem
(EA 91-076) for improper
maintenance activities which led to one channel
of the
reactor protection
system being inoperable
($50,000 CP).
CP issued for activities which occurred during
SALP cycle 9.
Si nificant Licensee
Conferences
Held Durin
The
A
raisal
Period
During the assessment
period there
were seven significant
management
conferences
with the licensee.
These
were:
~
June
12,
1991;
Management
Meeting to discuss Harris'elf-
assessment
(cycle 9).
~
July 3,
1991;
Enforcement
Conference to discuss
improper
maintenance activities which rendered
one Reactor Trip
System instrumentation
channel
(cycle 9).
~
August 1,
1991;
Management
Meeting to present results of
SALP cycle
9 assessment.
~
June
9,
1992;
Management
Meeting to discuss Harris'elf-
assessment
(cycle 10).
~
August 20,
1992;
Management
Meeting to discuss
technical
and
management
issues
associated
with the high head safety
injection (HHSI) alternate miniflow system.
~
September
10,
1992;
Management
Meeting to discuss
the
Harris'PEEE submittal
schedule.
~
October
14,
1992;
Enforcement
Conference
to discuss
apparent
inadequate
corrective actions
associated
with the
alternate miniflow system.
Confirmation of Action Letters
21
Confirmation of Action Letters
None.
Reactor Tri s
The unit experienced
four reactor trips at power during this
assessment
period
and
one reactor protection
system actuation
occurred
on July 13,
1992, while the plant was in the hot standby
condition.
The trips were:
~
June 3,
1991; Automatic reactor trip from full power while
performing
a maintenance
calibration procedure
on
a reactor
coolant system flow transmitter.
~
July 12,
1992; Automatic reactor trip from full power due to
a failed main condenser
boot seal
and resultant
low
condenser
vacuum.
~
July 15,
1992;
Hanual reactor trip from 30 percent
power due
to the loss of the main feedwater
pump following
deenergization
of an electrical
bus for breaker removal.
~
July 17,
1992; Automatic reactor trip from full power due to
a failed main condenser
boot seal
and resultant
low
condenser
vacuum.
Review of Licensee
Event
Re orts
LERs
During the assessment
period,
22
LERs were analyzed.
Special
reports
were submitted during the period by the licensee
but are
not included in the table.
The distribution of these
events
by
cause,
as determined
by the
NRC staff,
was
as follows:
Cause
Component Failure
Design/Procedures
Construction/Fabrication
Installation
Personnel
-Operating Activity
-Maintenance Activity
-Testing/Calibration Activity
-Other
Other
Totals
22
Licensin
Activities
22
During this
SALP period,
30 licensing activities were resolved.
This included nine license
amendments,
and
14 other licensing
actions.
Review was also completed for seven multiplant
activities.
The most significant of these
were
and the Station Blackout Analysis to meet
which is
due to be implemented
in 1994.
Enforcement Activit
FUNCTIONAL
AREA
NO.
OF VIOLATIONS IN SEVERITY LEVEL
I
II
III
IV
V
DEV
Plant Operations
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/
guality Verification
TOTAL
1*
4
1
1*
15
1
- This violation, issued during this period,
was discussed
in the
previous
SALP.