ML18142A494
| ML18142A494 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Surry |
| Issue date: | 05/10/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18142A487 | List: |
| References | |
| 50-280-85-05, 50-280-85-5, 50-281-85-05, 50-281-85-5, NUDOCS 8506270766 | |
| Download: ML18142A494 (26) | |
See also: IR 05000280/1985005
Text
MAY 10 1985
ENCLOSURE 2
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION
REPORT NUMBERS
50-280/85-05, 50-281/85-05
Virginia Electric and Power Company
Surry Plant Units 1 and 2
September 1, 1983 - February 28, 1985
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
petiodic basis and to evaluate licensee performance based upon this informa-
tion.
SALP is supplemental to normal regulatory processes used to ensure
compliance to NRC rules and regulations.
SALP is intended to be suffi-
ciently diagnostic to provide a rational basis for allocating NRC resources
and to provide meaningful guidance to the licensee's management to promote
quality and safety of plant construction and operation.
An NRC.SALP Board, composed of the staff members listed below, met on
April 11, 1985, to review the collection of performance observations and
data and to assess the 1 i cen see I s performance in accordance with the
guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee
Performance." A summary of th1: g.uidance and evaluation criteria is provided
in Section II of this report.
This report is the SALP Board's assess~ent of the licensee's safety perform-
ance at the Surry Pl ant for the peri ad of September 1, 1983 through
February 28, 1985.
SALP Board for Surry Plant:
P. R. Bemis, Di"rector, Division of Reactor Safety, Region II (RII) (Chairman)
J. P. Stohr, Director, Division of Radiation Safety and Safeguards, RII
D. M. Verrelli, Chief, Projects Branch 1, Division of Reactor Projects
. (DPR), RII
V. L. Brownlee, Chief, Projects Branch 2, DRP, RII
G. E. Lear, Chief, Structural. and Geotechnical Engineering Branch,
Division of Engineering, Office of Nuclear Reactor Regulation (NRR)
Attendees at SALP Board Meeting:
S. A. Elrod, Chief, Projects Section 2C, DRP, RII
D. J. Burke, Senior Resident Inspector, Surry, DRP, RII
D. S. Price, Reactor Inspector, Technical Support Staff (TSS), DRP, RII
K. M. Jenison, Project Engineer, Projects Section 2C, DRP, RII
T. C. MacArthur, Radiation Specialist, TSS, DRP, RII
J. D. Neighbors, Project Manager, Operating Reactors Branch 1,
Division of Licensing, NRR
I I.
CRITERIA
Licensee performance is assessed in certain functional areas depending upon
. whether the facility has been in the construction, preoperational or
operating phase.
Each functional area represents areas which are signifi-
cant to nuclear safety and the environment and which are programmatic areas.
Some functional areas may not be assessed because of little or no licensee
2
activities or lack of meaningful observations.
Special areas may be added
to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area:
A.
Management involvement and control in assuring quality
B.
Approach to resolution of technical issues from a safety standpoint
C.
Responsiveness to NRC initiatives
D.
Enforcement history
E.
Reporting and analysis of reportable events
F.
Staffing (including management)
G.
Training effectiveness and qualif~~ation
However, the SALP Board is not limited to these criteria, and others may
have been used where appropriate.
Based upon the SALP Board assessment, each fun ct i ona 1 area eva 1 uated is
classified into*one of the three performance categories. The definitions of
these performance categories are:
Category 1:
Reduced NRC attention may be appropriate.
Licensee management
attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high lev~l of
performance with respect to 9perational safety or construction is being
achieved.
Category 2:
NRC attention should be maintained at normal levels. Licensee
management attention and i nvo 1 vement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably effective
so that satisfactory performance with respect to ope rat ion a 1 safety or
construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee
management attention or involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear to be strained
or not effectively used so that minimally satisfactory performance with
respect to operational safety or construction is being achieved.
The SALP Board has also categorized the performance trend over the course of
the SALP assessment period. The trend is meant to describe the general or
prevailing tendency (the performance gradient) during the SALP period. This
categorization is not a comparison between the current and previous SALP
ratings. It is a determination of the performance trend during the current
SALP period irrespective of performance during previous SALP periods.
The
3
categorization process ~nVolves a review of performance during the current
SALP period, and categorization of the trend of performance which occurred
during the course of that period.
The performance trends are defined as
follows:
Improving:
Licensee performance has generally improved over the course of
the SALP assessment period.
Constant:
Licensee performance has remained essentially constant over the
course of the SALP assessment period.
Declinihg:
Licensee performance has generally declined over the course of
the SALP assessment period.
III. SUMMARY OF RESULTS
..
Overall Facility Evaluation - Surry 1 and 2
Surry is a well managed site* with -~ professional and knowledgeable
staff.
Acceptable performance by the licensee at the plant level
- was observed.
Strengths were identifi~d in the areas of Radiolo*gical
Controls,
Refueling,
Security, and
Licensing
Activities.
Improve-
ments in the areas of Plant Operations, Radiological Controls, Main-
tenance, Surveillance,
and
Training were
recognized.
The
growing
management
emphasis
on
reduction of. plant trips, which
involves
coordination of the several functional areas, is seen as a factor in
the observed improvements.
Weakness was i dent ifi ed in the Surveil 1 ance
area involving failure to properly control and implement revisions and
amendments to the survei 11 ance programs.
Survei 11 ance programs, once
established, functioned reasonably well.
Functional Area
October 1, 1982 -
August 31, 1983
Plant Operations
2
Radiological Controls
3
Maintenance
2
Surveillance
1
Fire Protection
2
1
Security
1
Refue 1 i ng
1
Training
Not Rated
Quality Programs and
Administrative Controls
Affecting Quality
2
Licensing Activities
1
September 1, 1983 -
February 28, 1985
2
1
2
3
Not Rated
2
1
1
2
2
1
Trend During
Latest
SALP Period
Improving
Improving
Improving
Improving
Not Determined
Constant
.Constant
Not Determined
Improving
Constant
Constant
L
4
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
During the assessment period, inspections of plant operations were
performed by the Resident and Regional inspection staffs.
The Surry faci 1 ity was properly operated and managed by site
personnel and well supported by the corporate staff.
The licensee's
staff was knowledgeable and proficient in normal plant operations
and responded well during transient operations such as plant trips
or shutdowns.
Management involvement in plant operations was
apparent throughout the assessment period. Plant evolutions were
well planned with realistic priorities and conservative methodology
for safety related matters. The licensee was quick to take action
when violations were identified by NRC and demonstrated concern
for items identified by int~rnal audit groups.
The licensee's
knowledge of regulations,. guides, standards and generic issues was
acceptable, and interpretations of these documents and associated
issues were conservative.
Licensee technical competence was well
founded both in technical matters and general plant operations.
The plant staff generally responded to plant trips and other
operational events during this review period in a professional,
thorough and competent manner.
The number of reactor trips
remained high at Surry, but the increased management attention and
resources being applied to this item should help to reduce it:*
For example, the Assistant Plant Manager was required to report to
the site to evaluate unplanned reactor trips with the operating
and safety engineering staff members prior to restart of the unit.
The number of unplanned trips were declining at the end of the
assessment period.
In addition, the main feedwater regulation
valves were rebuilt and upgraded to reduce the number of steam
generator level trips at low power (Startup).
Corporate manage-
ment was frequently involved in site activities and reviews, and
utility policies were well stated, disseminated and implemented.
The corrective action systems appeared to identify and address
nonreportable concerns as well as reportable events, which were
properly analyzed and reported.
The licensee was responsive to
NRC concerns and initiatives, and resolved most cases in a tech-
nically sound and timely manner.
A Human Performance Evaluation
staff was established to review and improve human performance.
The staff had already implemented a visible plant area and
component identification program to ensure plant personnel verify
the components or equipment prior to any manipulation or work.
The reactor control room behavior and formality were maintained at
high professional levels.
The licensed senior reactor operators
(SRO) and reactor operators (RO) performed their duties in desig-
nated uniforms supplied by the licensee. Administrative paperwork
5
related to functions such as maintenance and tagouts was performed
outside the control rooms by a third SRO, who was an assistant shift
supervisor.
This reduced traffic in the control rooms.
Recent
control room upgrades included painting, carpeting, NUREG-0737 and
human factors improvements, and the installation of high-technology
central command consoles with enhanced displays and communications
systems for the shift supervisors.
Plant procedures and entry postings prohibited control room entry
to all but those on official business.
The Control Room conduct
and appearance was a major strength in the area of plant operations.
The operational information provided by the licensee in Licensee
Event Report (LER) submittals was brief, accurate, made use of the
Energy Industry !dent i fi cation System component codes and was
generally sufficient .t9 provide acceptable understanding of the
event.
The violations below point .:to specific weaknesses in licensee
programs but do not indicate an overall lack of management involve-
ment.
On the contrary, the licensee's response to NRC initiatives
was timely and adequate.
The resolution of safety and technical
issues was sound and thorough.
Six violations were identified during the assessment period:
a.
Severity Level IV violation for failure to perform sufficient
valve lineup checklists prior to Unit 2 restart from a three
week outage.
b.
Severity Level IV violation for failure to have the alternate
unit's Auxiliary Feedwater pumps available.
c.
Severity Level IV violation for failure to follow procedures
when criticality was not achieved within predicted control
rod position administrative limits.
d.
Severity Level
IV violation for inoperable vent monitors
during a gaseous waste release.
e.
Severity Level V violation for installing an electrical
jumper to bypass the redundant B train reactor trip logic
when the procedures used did not specify this jumper or
bypass.
f.
Severity Level V violation for exceeding the RCS cooldown
rate limit.
2.
Conclusion
Category:
2
6
Trend During This Period:
Improving
3.
Board Recommendation
Licensee management attention was evident in this area. However,
it was noted that a number of reactor trips, event reports, and
violations resulted from personnel errors .. Although operational
activities are professionally performed, a reduction in these
personnel errors would result in improved operational performance.
Licensee management attention should be directed toward a program
for reducing personnel errors.
No change in the level of NRC
staff resources appli~d to the routine inspection program is
recommended.
8.
Radiological Controls
1.
Analysis
During the assessment period, inspections of radiological controls
were performed by the Resident and Regional inspection staffs.
These* inspect i ans included confirmatory measurements using the
Region II mobile laboratory. Additionally, an evaluation of the
NUREG-0737 Post Accident Sampling System (PASS) was performed with
the assistance of an NRC contractor.
The licensee made progress during the assessment period in imple-
menting an extensive decontamination and general cleanup program
for the plant.
A reduction in the number of radioactively
contaminated areas and in certain radiation levels was achieved.
Fuel rod leakage in the Unit 1 core continued to be a problem.
Increased reactor coolant system (RCS) activity resulting from the
leakage caused higher radiation fields in the work areas and
increased radiation worker exposure.
Comprehensive fuel inspec-
tions and replacement programs have reduced, but not eliminated,
the leaks. The licensee implemented improved As Low As Reasonably
Achi~vable (ALARA) and Health Physics (HP) programs at the site to
control and reduce exposure.
There was consistent evidence of
pre-planning and well-stated, disseminated and understood policies
and procedures.
Training, qualification and staffing in the
HP Department improved during the evaluation period.
The HP
organization was modified to function at a higher and more
responsible reporting level, with full
management
support
following implementation of a utility Radiation Protection Plan in
November 1984.
An HP superintendent position reporting directly
to the plant manager, and additional HP supervisor positions were
established.
The licensee's health physics staffing level was
adequate and compared well with other utilities having a facility
7
of similar size.
An adequate number of ANSI qualified licensee
and contract health physics technicians were available to support.
routine and outage operations.
The performance of the health
physics staff in support of routine operations and outages was
adequate.
Management involvement was evident in the approach to
resolution of technical issues and responsiveness to the NRC.
Although the licensee made considerable progress in establishing a
program to review outage work with a goal of keeping exposures
ALARA, the actual collective dose received for 1984 (2030 man-
rems) was in excess of the 1680 man-rem goal. A significant part
of the excess was attributed to snubber overhaul, steam generator
sludge lancing and eddy current testing, Appendix R compliance and
resistance temperature detector ( RTD)
rep 1 acement.
While the
ALARA goal was exceeded, a reduction in dose received by workers
was achieved when compared to collective dose received in 1983
(3220 man-rems).
This improvement was attributed to the strides
made in decontamination and general cleanup in the plant.
However,
occupational radiation expo~ures at these pressurized water
reactor (PWR) facilities was well over the 1983, 592 man-rem per
unit, average dose accumulation for all PWR units. A major~factor
in the collective dose was the high background radiation from
the RCS piping and other components at Surry due to fuel leakage.
Radiation levels were several times higher than those at a typical
PWR ..
Licensee management was aggressive in the implementation of a
waste management program and of a 1 eak reduction program for
controlling and minimizing inputs to the liquid radwaste proces-
sing system.
During 1984, the licensee disposed of 33,454 cubic
feet of solid radioactive waste with an activity content of 1162
curies.
The radioactive material shipping program was adequate
and was generally well managed.
The leak reduction program was
placed into operation as part of an overall effort to reduce*
releases.
An innovative approach to treatment of liquid radwaste,
using small series-connected demineralizer vessels produced good
. quality effluent while simultaneously reducing the curie content
of the effluent, cost per gallon treated, and volume of expended
resin per gallon treated.
The chemistry and radiochemistry programs have been well managed.
The Post Accident Sampling System (PASS) was capable of functioning
in accordance with the NUREG-0703 design criteria; however, the
system continued to have valve and instrumentation operability
problems.
Licensee management took actions to assure that the
PASS system would function as required, which in~luded assignment
of personnel to perform system maintenance and calibrations.
A confirmatory measurements inspection indicated that the licensee 1s
radiochemistry and radioactive effluent analyses and accountability
programs were adequate.
The results of gamma spectroscopy analyses
performed by the NRC and the licensee were in good agreement. The
' ,
8
licensee
instituted
an
interlaboratory crosscheck program.
Problems identified in the crosscheck program and other problems
areas were generally corrected in a timely manner.
The laboratory
quality control program was well managed.
Three violations and one deviation were identified during the
assessment period:
a.
Severity Level IV violation for failure to provide appro-
priate personnel monitoring equipment.
b.
Severity Level V violation for failure to meet minimum
experience qualifications of ANSI
Nl8.l-1971 for the
Supervisor of Health Physics.
c.*
Severity Level V yiolation for failure to conduct specific
quality control audits which evaluated compliance with the
requirements of 10 CFR 61.
d.
Deviation for failure t~ complete modifications of procedures
governing the use of scaled sources and documentation~f the
issuance and return of these materials by the specified due
date.
2.
Conclusion
- Category:
1
Trend during This Period:
Improving
3.
Board Recommendation
Management involvement in Radiological Controls was aggressive.
Substant i a 1 improvement was achieved, a 1 though further man-rem
reductions should be pursued.
In order to fully evaluate the
depth of licensee improvements in this area, no change in the*
level of NRC staff resources applied to the routine inspection
program is recommended.
The Board * a 1 so noted that as part of the steam generator
replacement program, the licensee also significantly upgraded the
capability of maintaining high quality water in the secondary
system. After the units returned to power, however, the licesnee
allowed this capability to deteriorate through poor maintenance
of equipment and instrumentation that was needed to monitor water
chemistry.
Although the licensee endorsed the steam generator
owners
group/Electric Power
Research
Institute
(SGOG/EPRI)
guidelines, there was insufficient staff to provide corrective
action or maintenance in a timely manner.
The chemistry program
was staffed with two 10-hour shifts, each day having two two-hour
gaps without chemistry personnel on site.
The chemistry program
was being upgraded, however, to meet the SGOG/EPRI guidelines.
r
9
The licensee should ensure that continued management attention is
devoted to this area.
C.
Maintenance
1.
Analysis
During the evaluation peri ad, i nspecti ans were performed by the
Resident and Regional inspection staffs.
The maintenance program was thorough and technically sound,
procedures and plans were adhered to, and records were adequately
maintained and retrievable.
The licensee had a positive nuclear safety attitude and has
developed a viable preventive and corrective maintenance program.
Maintenance activities exhibited evidence of adequate preplanning
with established priorities, however, the number of outstanding
maintenance requests remaine~ large.
The maintenance procedures
.
and policies were compreh~nsive and were adhered to, but occasional
weaknesses were uncovered in the procedures themselves (violations
b and d below).
Some of these weaknesses were the result of
inadequate instructions from the vendors or manufacturers.
The
licensee recently computerized the maintenance and equipment
hi story files to improve access to and use of these records.
Licensee personnel had a clear understanding of safety and tech-
nical issues and were responsive to NRC requests and initiatives.
Events were properly identified, analyzed, and promptly and
accurately reported.
A special team inspection was performed to assess the licenseels
compliance with Generic Letter 83-28, "Required Actions Based on
Generic Implications of Salem ATWS Events".
This audit assessed
the licensee's post maintenance testing program.
The licensee's
procedures were found to be adequate, with the exception of the
plant administrative procedure for classifying safety related or
non-safety related maintenance work activities. The procedure was
considered too general due to the lack of detail in the "Safety
Classification List".
The licensee expects to have an expanded
and more detailed list formulated by mid-1985.
Management resolution of safety and technical issues was sound and
thorough. The large number of reactor plant trips was not related
to any specifically identified maintenance program deficiencies.
Management response to NRC initiatives was demonstrated by the
licensee through the above mentioned m~intenance program improve-
ments.
10
The four violations identified in the Maintenance area do not
indicate any programmatic breakdown:
a.
Severity Level IV violation for failure to take prompt and
adequate
corrective actions
on
nonconformance
reports
involving several adverse conditions.
b.
Severity Level
IV violation for an inadequate corrective
maintenance procedure for adjusting torque switch settings on
Service Water motor-operated valves.
c.
Severity Level IV violation for failure to perform a written
safety evaluation of the facility change which removed the
component cooling water (CCW) automatic trip valve isolation
function on high flow from the reactor coolant pump thermal
barrier coolers. aqd the primary drain coolers.
d.
Severity Level IV violation for failure to provide adequate
electrical maintenance ~nd testing procedures for maintenance
and testing of the 4160 volt transfer bus.
2.
Conclusion
Category:
2
Trend During This Period:
Improving
3.
Board Recommendation
Licensee resources were adequate in this area.
No change in the
level of NRC staff resources applied to the routine inspection
program is recommended.
D.
Surveillance
1.
Analysis
During the evaluation period, inspections
Resident and Regional inspection staffs.
of *the Inservice Inspection (ISI) programs
were also performed.
were performed by the
Inspections and review
and examination results
Although management was actively involved in assuring the quality
of surveillance activities, as evidenced by well-defined admin-
istrative procedures and additional staffing and training,
repetitive breakdowns in the surveillance program for periodic
testing occurred during the evaluation period.
A particular
weakness which was identified by the NRC and the licensee was the
implementation of Technical Specification (TS) amendments that
revised or expanded the testing programs.
For example, following
a significant addition of fire detection instruments to TS
11
Table 3.21-1, surveillance procedures were not fully implemented.
A Severity Level III violation (violation b) and associated civil
penalty f9r not having the RCS head vents operable as required by
10 CFR 50.44 is a second example of a failure to implement the
revised 10 CFR 50 requirements.
The operational
surveillance
program verified that the vessel head vents were isolated despite
the 10 CFR 50 rule change and a September 13, 1983 NRC letter to
the licensee discussing this matter.
A third example concerned
the failure to fully implement a TS Amendment for NUREG 0737
i terns; survei 11 ances on the contra l room chlorine detectors and
the containment hydrogen analyzers were not initially conducted as
required.
The in-place surveillance and testing programs were
generally conducted as required. Computerization of the surveil-
lance programs was being expedited to improve management of the
programs.
A violation was issued for failure to test a sufficient number
of additional snubbers in accordance with the TS requirements
following initial testing failures.
By following portions of a
draft of an ANSI standard, t~~ licensee divided the snubbers into
small groups and incorporated the grouping into their test *proce-
dures.
Using this procedure, the licensee performed functional
testing on approximately 20 percent of the hydraulic snubbers.
Even though the functional test failure rate was high (20 failed
of the 58 tested on Unit 1, and 23 failed of the 55 tested on
Unit 2}, the licensee's procedure permitted acceptance of those
results without performance of additional testing. The functional
test results were reviewed and accepted by various site management
personne 1 .
By approving the fun ct i ona l test procedures and
accepting the snubber fun ct i ona 1 results, , the 1 i censee demon-
strated that the NRC requirements were not clearly understood
(e.g., using a draft standard as guidance in lieu of NRC generic
letters and Technical Specifications).
Resolution of the technical
issue (snubber failures) from a safety standpoint was not conserva-
tive. The licensee's corrective action was to perform the testing
required on additional snubbers as required by the TS.
When this
testing was performed, approximately 30 percent of the Unit 1 and
25 percent of the Unit 2 snubbers failed to meet the functional
test acceptance criteria.
An indepth review of the problem by the
licensee and NRC disclosed that the high number of snubber test
failures was due to an inadequate service life monitoring program.
This resulted in a Severity Level III violation (violation a) and
associated civil penalty being issued for an inadequate service
life program which resulted in a large number of inoperable
snubbers. The licensee subsequently verified by analysis that no
safety systems were inoperable due to the inoperable snubbers.
A containment integrated leak rate (Type A) test was conducted
on Surry Unit 2, from September 11 through 14, 1983.
There was
adequate management involvement as evidenced by the prior planning
of test preparations and the upgrading of detailed test procedures.
Test personnel demonstrated a knowledge of the test and the issues
12
involved. However, in spite of the effort to identify and correct
leakage problems, the licensee continued to experience containment
leakage problems.
During the test, excessive leakage was identi-
fied which required further isolation or repair before the leakage
acceptance criteria were met.
The test was unsuccessful on the
initial attempt.
Evidence of improvements in the licensee's written Inservice
Inspection (ISI) program and in the timeliness and appropriateness
of their responses to technical issues was noted for the remainder
of the evaluation period as a result of violation e. Also, there
were improvements in the licensee's staffing of this area.
The licensee generally demonstrated a clear understanding of
technical
issues, and was responsive to NRC concerns.
The
reporting and analysis. of surveillance events was prompt and
thorough; however, the corrective actions should be strengthened
to prevent recurrence.
Severa 1 personne 1 and admi n i strati ve
changes as we 11 as addi ti on13,_l survei 11 ance requirements occurred
during the evaluation period which may have affected the tracking
of items and the increased* backlog of work.
Six violations were identified during the assessment period:
a.
- severity Level
III violation for an inadequate snubber
service life monitoring program.
b.
Severity Level III violation for not having RCS head vents
operable (remotely) from the contra l room by the comp 1 et ion
of the first outage of sufficient duration after July 1,
1982.
c.
Severity Level IV violation for failure to test an additional
10 percent of each type of snubber that failed to meet the
acceptance test criteria during Unit 1 and 2 snubber testing.
d.
Severity Level IV violation for failure to perform monthly
testing of control room chlorine detectors and monthly
channel functional tests of Unit 1 containment hydrogen
-analyzers.
e.
Severity Level IV violation for failure to promptly correct
known deficiencies in ISI procedures and known failures to
supply required ISI reports to the NRC.
f.
Severity Level V violation for inadequate periodic test
procedures and a post-maintenance testing procedure that did
not provide appropriate check-off lists and instructions.
2.
Conclusion
Category:
3 *
13
Trend During This Period:
Improving
3.
Board Recommendation
Only minimally satisfactory performance was achieved in this area.
The timely implementation of new surveillance requirements should
receive increased licensee management attention.
The Board
recommends that NRC staff resources applied to the routine
inspection program be increased.
E.
Fire Protection
1.
Analysis
During the evaluation* perioc;I, inspections were performed by the
Resident inspection staff.
The licensee prepared and routinely implemented numerous admin-
istrative fire protection and prevention procedures which adhered
to NRC guidelines. Adequate fire brigade equipment was available
and was properly maintained.
The fixed fire protection systems
were being properly maintained, inspected and tested in accordance
with TS.
There was consistent evidence of pre-planning and assignment of
priorities, and a clear and conservative understanding of tech-
nical issues by management.
Overall management involvement and
control of the fire protection programs helped to assure their
quality.
Only two minor fires occurred during the 18 month
assessment period,
and these were promptly identified and
extinguished. Responsiveness to NRC initiatives was timely.
The
staffing and training for the fire protection programs were
increased to meet changing NRC fire protection regulations.
One violation was identifjed during the assessment period:
Severity Level V violation for failure to document daily
inspections required by welding and flame permits and failure
to have copies of several welding and flame permits available
in the control room.
2.
Conclusion
Category:
Not rated
Trend During This Period:
Not determined
14
3.
Board Recommendation
There was insufficient inspection activity in this area, during
the assessment period, to justify a rating. Good performance was
evident in those limited areas reviewed.
F.
1.
Analysis
During the evaluation period, routine inspections as well as two
emergency exercises and one speci a 1 inspection were conducted by
the Regional and Resident inspection staffs. The special inspec-
tion primarily addressed the ability of the shift supervisors to
make prompt protective action recommendations.
One of the exer-
cises involved the full-scale partic.ipation of state and local
governments.
The speci a 1 inspection reve~_l ed two specific weaknesses in the
licensee's training progr~m as well as emergency plan implementing
procedures.
One of the weaknesses identified during interviews
with the duty Shift Engineers involved their failure to provide
protective action recommendations following the declaration of a
Genera 1 Emergency, as we 11 as appropriate response_s for genera 1
core-melt seq~ences.
The other weakness was identified following
a review of the Emergency Plan implementing procedures and indi-
cated that no protective action recommendations would be made if a
General Emergency were based solely on plant conditions.
These
findings resulted in violations a and b below.
The licensee's
management was responsive in resolving these and lesser findings.
Licensee management actively supported the emergency preparedness
program and responded to NRC initiatives in a timely manner.
Other than the above mentioned weakness, the training program was
effective in providing appropriate training for emergency response
personnel.
The exercises demonstrated that the plan and required procedures
were effectively implemented by the licensee's staff, although
minor areas for improvement were noted by the NRC and the
1 i censee.
The emergency organization I s performance during the
exercises was acceptab 1 e and the exercise objectives were met.
The licensee's performance during the exercises reflected a
corporate and plant management commitment to maintaining an
effective emergency plan, emergency implementing procedures and a
high level of emergency preparedness training.
The following
essential elements for emergency response were determined to be
acceptable:
emergency classification;
communications;
shift
staffing and augmentation; dose projection and assessment;
emergency worker protection; changes to the emergency preparedness
programs; and provisions for annual quality assurance audits of
corporate and plant emergency planning programs.
- ,'
15
During the assessment interval, the new Local Emergency Operating
Facility (EOF) and Technical Support Center (TSC) facilities were
comp 1 eted * and activated to enhance the emergency response
capabilities.
An adequate working relationship existed between the licensee and
offsite support organizations.
Staffing was at an acceptable
level at the plant site. Additional staff support was available
from personnel resources at the Corporate Offices when necessary.
Two violations were identified during the assessment period:
a.
Severity Level IV violation for inadequate procedures for
protective action decisionmaking.
b.
Severity Level. IV. violation for failure to properly train
emergency personnel
in protective action recommendation
decisionmaking.
2.
Conclusion
Category:
2
Trend During This Period:
Constant
3.
Board Recommendation
Licensee resources were adequate in this area.
No change in the
level of NRC staff resources applied to the routine inspection
program is recommended.
G.
Security
1.
Analysis
During this evaluation period, inspections were conducted by the
resident and regional inspection staffs.
A c;hange in the management of the Surry security organization
occur-red during this assessment period.
Improvement. in the
effectiveness of the security organization was continuously
demonstrated by operational efficiency and by a reduced number of
violations of regulatory requirements identified during the
evaluation period.
The licensee's approach to the resolution of technical issues
relating to security systems and equipment remained sound and was
characterized by viable and thorough approaches.
Programmed
changes to the security program were researched and reviewed in
detail prior to implementation, as evidenced by the thorough study
16
and evaluation of the proposed construction of a secondary access
portal in the protected area barrier.
The licensee was responsive to NRC initiatives and made a
concerted effort to meet or exceed minimum regulatory requirements
in the area of security.
An example of the licensee's initiative
in this regard was the installation of heavy concrete barriers
along the protected area perimeter and approaches to the protected
area via the vehicle parking area to preclude forced penetration
of the protected area by vehicle.
The security management staff and operational security force were
adequately
manned
with
qualified personnel.
Problems' of
regulatory concern were identified and reported.
The licensee's efforts. to ensure resolution of operational and
functional security issues continued to be positive, and reflected
effective managerial attention and corporate support.
The violation identified below was attributed to personal error by
the security officer responsible for conducting an appropriate
search of personnel prior to entry into the protected area:
Severity Level IV violation for failure to perform a hands-on
- search.
2.
Conclusion
Category:
1
Trend During This Assessment Period:
Constant
3.
Board Recommendations
A high level of performance was achieved in this area. The Board
recommends that NRC staff resources applied to the routine inspec-
tion program be reduced.
H.
Refueling
1.
Analysis
During thts evaluation period,
refueling
inspections were
performed by the Resident and Regional inspection staffs.
Surry Unit 2 restarted from a three month refueling outage on
September 25, 1983.
The next refueling outage will begin in the
spring of 1985.
Unit 1 conducted a refueling outage from
September 26, 1984 to December 26, 1984.
17
Unit 1 refueling activities were adequately preplanned with
realistic assignment of priorities and control of activities.
Refueling procedures were complete, accomplishing the associated
tasks efficiently and safely.
Adequate levels of management
attention were observed during refueling. Refueling crew staffing
and staff training were observed to be adequate.
The licensee
conducted fuel assembly movements, containment purging and system
venting operations, all of which were adequate.
The refueling
cavity seal ring assembly was rebuilt and tested to ensure proper
sealing prior to defueling. Corporate fuel management representa-
tives as well as site management were directly involved in the
refueling and the fuel inspection activities.
Refueling was
accomplished in accordance with adequately preplanned, properly
reviewed and approved procedures.
Technical problems encountered
during refueling were promptly resolved in a competent and safety
conscious manner.
Unit 2 post-refueling startup test records were adequate and
supported a conclusion that the tests had been performed accept-
ably.
Administrative errors* led to one violation with two
examples for failure to follow procedures.
After experiencing one stuck rod on Unit 1, an acceptable,
detailed analysis of the situation considering its impact on
accident analyses, was conducted and an operating strategy was
developed before the Unit was returned to power.
An abnormally
high number of fuel failures were experienced during this period.
The licensee 1s approach to the management and correction of this
abnormally high number of fuel failures was both timely and
appropriate. The high number of failures did not reflect unfavor-
ably on the way th~ plant was refueled or operated.
Instead the
failures appeared to result from poor cleanliness control during
steam generator replacement, as well as-potential vendor manufac-
turing inadequacies.
After twelve years of two unit operation, the Surry high-density
spent fuel storage racks are nearly full.
The 1 icensee proposed
the construction of an on-site dry cask spent fuel storage
facility, which is under review by the NRC.
In the interim, spent
fuel is planned to be shipped to North Anna and a Department of
Energy facility in Idaho during the summer of 1985.
One violation was identified during the assessment period:
Severity Level V violation for failure to record test data in
accordance with a periodic test procedure.
2.
Conclusion
Category:
1
18
Trend During This Period:
Not determined
3.
Board Recommendations
Management involvement in this area was oriented toward nuclear
safety.
The Board recommends that NRC staff resources applied to
the routine inspection program be reduced.
I.
Training
1.
Analysis
During the assessment period, routine inspections of plant
training programs were performed by the Regional and Resident
inspection staffs. A *speciaL comprehensive assessment of Surry
training programs was conducted by a six member inspection team to
determine the overall effectiveness of plant training.
Although
several weaknesses were identified, plant training was determined
to be adequate for the support of safe plant operation.
The licensee's General Employee Training (GET) program was well
defined and implemented for all plant personnel.
GET records were
complete and well maintained.
The training and qualification
programs were strengthened and upgraded during the eva 1 uat ion
period, and equipment manufacturers/vendors courses were provided
on a regular basis.
Management was responsive to NRC initiatives and concerns and
aggressively sought to improve the quality of plant training
programs throughout the assessment period.
The deve 1 opment and
implementation of program upgrades and revisions continued through
efforts to fully achieve Institute of Nuclear Power Operation
(INPO) accreditation. Changes included reorganization on both the
corporate and plant levels, culminating in a corporate training
organization responsible for the management of training program
develGpment,
implementation,
administration
and evaluation.
Strong management i nvo 1 vement coup 1 ed with improvements in the
administration of training programs and the certification of
instructors resulted in improvements in the quality of plant
training towards the end of the assessment period.
During the assessment period, eight SRO and seven RO candidates
were administered license examinations.
candidates passed the examination.
The passing ratio for SRO
candidates was below the Region II average and the past perfor-
mance record for Surry.
Apparent weaknesses in the licensed
operator training program contributing to this below average
19
performance were the lack of current systems texts, the lack of
- adequate lesson plans, and the new examination format and content.
The licensed operator requalification program was in transition
from knowledge-based methodology to performance based methodology.
The lack of a formal method for review, revision and approval, and
the lack of up-to-date texts hampered the administration of
requalification training.
Other weaknesses included the failure
to formally incorporate operational experience into applicable
training and the lax security of examination question banks and
answer keys. It is anticipated that improvements in these areas
will be forthcoming.
Non-licensed personnel
training programs
experienced steady
improvements throughout the assessment period as a result of
implementing the new performance based training methodology.
Improvements included * the development of a Qua 1 i ty Assurance
Enhancement Course to supplement GET and the development of a
controlled study course for continuing education in the mainten-
ance area. The lack of a training program for staff engineers was
a major weakness in the licensee's training program.
Training and*
continued training programs for engineers were under development
at the close of the assessment period.
The licensee had developed a comprehensive training program for
Qua Hty Assurance/Quality Contra l (QA/QC) personnel . A training *
coordinator
has
been
appointed
to
maintain
personnel
qualifications.
QA/QC training records were well maintained and
easily retrievable.
The licensee maintained an effective security training qualifica-
tion program which produced well-trained security personnel.
The licensee had an effective and fully adequate Emergency
Preparedness training program and records.
No violations or deviations were identified during the assessment
period.
2.
Conclusion
Category:
2
Trend During This Period:
Improving
3.
Board Recommendations
The involvement of management in this area was evident.
Non-
licensed training was a major strength of the licensee's training
programs.
No change in the level of NRC staff resources applied
to the routine inspection program is recommended:
l
20
J.
Quality Assurance and Administrative Controls Affecting Quality
1.
Analysis
During this evaluation period, routine inspections were performed
by the Resident and Regional inspection staffs.
An auditing
program review was also conducted.
The corrective action for some 1983 audits was veri1ied completed
by QA personnel and closed.
However, 1984 audits in these same*
functional areas identified certain repeat findings. These repeat
QA findings indicated that the audited organization 1s management
may not be directing sufficient attention to internal audit
findings to assure effective corrective actions.
Licensee QA
audit findings, when escalated to management attention, were
adequately addressed.
Minor problems were identified with
auditing activities as indicated in violation c. Auditing records
were complete, well maintained and readily available.
The measuring and test equi.pment program was procedurally we 11
defined; however, problems existed in program implementation.
Certain environmental controls in the mechanical and instrumenta-
tion laboratories were not satisfactory for calibration of gauge
blocks and micrometers.
Implementing procedures had not been
prepared for use in the mechanical certification laboratory or in
the instrument laboratory, although
personnel
had
generic
administrative procedures for most work done in these laboratories
(violations a and b). The design change program underwent consid-
erable upgrading based on corrective actions taken to resolve QA
audit findings.
New manuals were implemented to clarify personnel
responsibilities. Drawing updating associated with plant modifi-
cations needed additional management attention to provide more
timely completion.
An independent contractor performed a review and assessment of the
Periodic Test and Surveillance Program.
QA personnel also
identified problems in these areas during an audit. Based on the
audit and contractor identified -problems, increased responsibility
for these areas was assigned to the Performance Test Group.
Admin~strative controls were being written to reflect these
changes.
Licensee responsiveness on identified NRC concerns appeared
adequate in that three.pr.eviously identified QA problem areas were
appropriately resolved.
Three violations were identified during this assessment period:
a.
Severity Level IV violation for failure to control environ-
mental conditions during calibration activities.
21
b.
Severity Level IV violation for failure to provide procedures
for calibration activities.
c.
Severity Level V violation for failure to fully implement
certain QA procedures.
2.
Conclusion
Category:
2
Trend During This Period:
Constant
3.
Board Recommendation
The conduct of activities in this area was satisfactory.
No
change in the level of NRC staff resources applied to the routine
inspection program is recommended.
K.
Licensing Activities
1.
Analysis
The licensee continued to demonstrate active participation in
ljcensing activities and had kept abreast of current and antici-
pate~ (with one exception) licensing actions. In particular, the
licensee's management at times had proposed actions to facilitate
licensee understanding and NRC review of issues such as Appendix R
exemptions (where the* technical staff routinely met during
development of the exemption requests).
The licensee management
consistently exercised good control o~er its activities and had
maintained effective communication with the project manager even
though experiencing severa 1 changes in management staff during
this period.
As referenced above, one area ( amendment 101 -
snubber inspection interval) where management attention could be
increased was in the area of potential amendment requests such
that situations could be avoided that required rapid NRC staff
response.
The interaction of the licensee, including visits and management
discussions/meetings, with the NRC staff had resulted in clear
understanding of safety issues.
Sound techni ca 1 approaches were
taken by the licensee's technical staff toward their resolution.
Conse.rvatism was exhibited in relation to significant safety
issues on a routine basis. Thoroughness in the approach to the
technical issues was demonstrated by the number and complexity of
the licensing actions completed during this period.
Consistently sound technical justification was provided by the
licensee for deviations from staff guidance. The good communica-
tions between the licensee and NRC staff were beneficial to both
L
22
the processing of licensing actions and minimizing the need for
additional information.
The licensee had been responsive to NRC initiatives in all but a
few situations.
One in particular related to a response on a
Technical Specification related to high enefgy lines. However, in
all other instances the licensee had made every effort to meet the
established commitments as illustrated by its response to TMI
action items, Appendix Rand Environmental Qualification of safety
related electrical equipment.
When original commitments could not
be met, the licensee was prompt to discuss the problems and
provide new schedules.
The licensee has a licensing staff which was sensitive to the
requests by the NRC and seeked to assure timely responses. During
the period, the 1 i cens.ee made a rea 1 i gnment in its management
organization to provide more emphasis on licensing.
2.
Conclusion:
Category:
1
Trend During This Period:
Constant
3.
Board Recommendation
A hiEh level of performance in the licensing area was achieved.
V.
Supporting Data and Summaries
A.
Licensee Activities
At the beginning of this assessment period, Surry Unit 1 was Operating
at full power and Surry Unit 2 was in the last month of a three-month
refueling outage.
Unit 2 was returned to power operation on September 28,
1983.
During the ensuing months from September 1983, until February 28,
1985, Units 1 and 2 were periodically shut down for planned maintenance
or snubber inspection outages.
The outages typically lasted from one
to three weeks.
The Unit 1 refueling outage commenced on September 26, 1984, and
continued through December 26, 1984.
Both uni ts operated at power
during February 1985, -which ended the evaluation period.
Unit 1 operated at reduced power (80%) from June 19, 1984, until the
shutdown for refue 1 i ng on September 26, 1984, due to an i mmovab 1 e
control rod (B-6).
One of the two L-shaped corner clamps atop the fuel
assembly, which hold the upper assembly leaf springs in place, had
broken off and fallen into the assembly causing the stuck rod.
All
parts were recovered and no additional failures were observed.
23
Due to the nearly full spent fuel storage facilities, the licensee
plans to begin shipment of spent fuel to a DOE facility in Idaho.
An
on-site dry cask spent fuel storage facility has also been proposed and
is-under review by the NRC.
B~
Inspection Activities
During the evaluation period, routine inspections were performed at the
Surry facility.
Of these inspections, several team inspections were
performed.
The performance appraisal inspection team inspected the
areas of safety review and investigative functions, QA audits, design
changes and modifications, maintenance, plant operations, corrective
action systems, training and procurement.
A radiological assessment
team inspected the areas of TMI action items, internal exposure,
control, surveys, posting, labeling and control, radiological work
permits, HP procedures, HP staff qualifications, licensee audits and
notifications, and reporting.
A special team inspection concerning
Generic Letter (GL) 83-28; "Generic Implications of the Salem ATWS
Events", reviewed the areas of post trip review, post maintenance
testing, equipment classification*, vendor interface, reactor trip
system reliability and QA audits of GL 83-28 activities.
One-- team
inspection involved the annual emergency exercise, and another team
inspection reviewed the licensee training and qualification programs.
Routine resident and regional inspections were performed throughout the
18 month as~essment period.
C.
Licensing Activtties
There were a total of 94 active actions at the beginning of the assess-
ment period for the Surry units. Actions were added to the multi-plant
and plant specific actions for a total of 170 actions by the end of the
period.
Eighty-nine actions were closed during the assessment period.
These actions and a partial list of completions consisting of amendment
requests, exemption requests, responses to generic letters, TMI items
and licensee initiated actions follow:
72 Multi-Plant Actions (28 completed).
Some of the completed actions
in this category are:
0
0
0
0
0
0
0
0
0
0
0
Adequacy*of Station Electric Distribution System Voltages
Natural Circulation Cooldown
Engineered Safety Features Filters
Asymmetric Loss of Coolant Accident Loads
High Energy Line Break and Consequential System Failure
NUREG-0737 Technical Specifications (Generic Letter 82-16)
Control of Heavy Loads (Phase I)
Appendix J Technical Specifications
Fuel Handling Accident Inside Containment
NUREG-0737 Technical Specifications (Generic Letter 83-37)
Detailed Control Room Design Review Program Plan
l
'
..
'
24
_58 Plant Specific Actions (41 completed).
actions in this category are:
Some
of
the
completed
0
0
0
0
0
0
0
0
0
0
Exemption on Fire Protection Schedule
Delta Flux and Rod Insertion Limits Technical Specifications
Containment Isolation Valves Technical Specifications
ISI Second Ten Year Interval (Surry 1)
Reduction of Boron Concentration in Boron Injection Tank
Extend Burnup to 45,000 MWD/MTU
ASME Relief Requests
Core Reload Methodology Audit
Appendix R Exemptions
40 TMI (NUREG-0737) Actions (20 completed).
Some of the completed
actions in this category are:
0
0
0
0
0
Plant Shielding (II.B.2.2)
Post Accident Sampling (II.B.3.2)
Inadequate Core Cooling G~idelines (I.C.1.2.A)
Thermal Mechanical Report (II.K.2.13)
Potential for Voiding in RCS (II.K.2.17)
D.
Investigation and Allegations Review
There were no significant investigations or allegation activities
during the assessment period.
E.
Escalated Enforcement Actions
1.
Civil Penalties
A Severity Level I II violation concerning inoperable snubbers
which resulted in a civil penalty in the amount of forty thousand
dollars was assessed on July 30, 1984.
A Severity Level III violation concerning inoperable Reactor
Cool ant System Vents which resulted in a civil pen a 1 ty in the
amount of forty thousand dollars was assessed on February 1, 1985.
2.
Orders (those related to enforcement)
None.
F.
Management Conferences Held During the Appraisal Period
April 17, 1984
An enforcement conference was held to discuss the
operability of Units 1 and 2 reactor head vents and
snubber maintenance.
l
~-
25
G.
Review of licensee Event Reports and 10 CFR 21 Reports submitted by the
Licensee.
During the assessment period, there were 49 LERs reported for Unit 1
and 47 LERs reported for Unit 2.
The distribution of these events by
cause, as determined by the NRC staff, was as follows:
Cause
Unit 1
Unit 2
Component Failure
11
17
Design
1
4
Construction, Fabrication, or
Installation
1
2
Personnel
- Operating Activity
8
5
- Maintenance Activity
10
10
- Test/Calibration Activity
2
2
Other
4
3
Out of Calibration
2
3
Other
10*
1
TOTAL
49
47
It was noted that for Unit 1, 91% of the LERs were confined to three
categories:* 49% due to personnel error; 22% due to component failure;
and 20% fe 11 into the
110ther
11 category.
For Unit 2, 78% of the LERs
fell into two categories:
36% due to component failure; and 42% were
caused by personnel error.
H.
Inspection Activity and Enforcement
FUNCTIONAL
AREA
NUMBER OF VIOLATIONS IN EACH SEVERITY LEVEL
V
IV
III
II
I
Plant Operations*
2
Radiological Controls
2
Maintenance
Surveillance
1
Fire Protection
1
Security
Refueling
1
Training
Quality Assurance and
Administrative Controls
Affecting Quality
1
TOTAL
8
4.
1
4
3
2
1
2
17
2
2
l