ML18151A890
| ML18151A890 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Surry |
| Issue date: | 07/26/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18151A633 | List: |
| References | |
| 50-280-88-05, 50-280-88-5, 50-281-88-05, 50-281-88-5, NUDOCS 8808100291 | |
| Download: ML18151A890 (45) | |
See also: IR 05000280/1988005
Text
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4 .
ENCLOSURE 2
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
~gRs100291 aao726
G
ADOCK 05000280
PNU
50-280/88-05 AND 50-281/88-05
Virginia Electric and Power Company
Surry Plant Units 1 and 2
SEPTEMBER 1, 1986 - APRIL 30, 1988
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance ( SALP) program is an
integra~ed NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based on this
information.
The SALP program is supplemental to normal regulatory
processes used to determine compliance with NRC rules and regulations.
The SALP program is intended to be sufficiently diagnostic to provide a
rational basis for allocating NRC resources and to provide meaningful
guidance to licensee management in order to promote quality and safety of
plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
June 21, 1988, to review the collection of performance observations and
data to assess licensee performance in *accordance with guidance in NRC
Manual Chapter 0516, "Systematic Assessment of Licensee P~rformance
11 *
A
summary of the guidance and evaluation criteria is provided in Section II
of this report.
This report is the SALP Board's assessment of the licensee's safety and
management performance at Surry for the period September 1, 1986, through
April 30, 1988.
SALP Board for Surry:
C. Hehl, (Chairman) Deputy Director, Reactor* Projects Division (DRP)
H. Berkow, Director, Project Directorate II-2, Nuclear Reactor
Regulation (NRR)
E. Merschoff, Deputy Director, Reactor Safety Division
W. Cline, Acting Director, Radiation Safety and Safeguards Division
B. Wilson, Chief, Reactor Projects Branch 2, DRP
C. Patel, Projects Manager, NRR
W. Holland, Senior Resident Inspector, Surry, DRP
Attendees at SALP Board Meeting:
F. Cantrell, Chief, Reactor Projects Section 2A, DRP
K. Landis, Chief, Technical Support Section (TSS), DRP
S. Shaeffer, Technical Support*Engineer, DRP
M. Scott, Project Engineer, DRP *
T. MacArthur, Radiation Specialist, TSS, DRP
L. Nicholson, Resident Inspector, Surry, DRP
I I.
CRITERIA
Licensee performance is assessed in selected functional areas depending on
whether the facility has been in the construction, preoperational, or
operating phase during the SALP review period.
Each functional area
normally represents an area which is significant to.nuclear safety and the
environment, &nd which is a normal programmatic area.
Some functional
areas may not be assessed because of little or no licensee activity, or
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because of a lack. of meaningful NRC observations.
Special areas may be
added to highlight significant observations:
One or more of the following evaluation criteria was used to assess each
functional area; however, the SALP Board is not limited to these criteria
and others may have been used where appropriate.
A.
Management involvement in assuring quality
B.
Approach to the resolution of technical issues from a safety
standpoint
C.
Responsiveness to NRC initiatives
D.
Enforcement history
E.
Operational and construction events (including response to, analysis
of, and corrective actions for)
F.
Staffing (including management)
G.
Training and qualification effectiveness
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories.
The definitions of
these performance categories are:.
Category 1:
Reduced NRC attention may be appropriate.
Licensee
management attention and involvement are aggressive and oriented
toward nuclear safety; licensee resources are ample and effectively
used such that a high level of performance with respect to
operational safety or construction quality is being achieved.
Category 2:
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and
are reasonably effective such that satisfactory performance with
respect to operational safety or construction quality is being
achieved.
Category 3:
Both NRC and 1 icensee. attention should be increased.
Licensee management attention or involvement is acceptable and
considers nuclear safety, but weaknesses are evident; 1 i censee
.resources appear to be strained or not effectively used such that
minimally satisfactory performance with respect to operational safety
or construction quality is being achieved.
The functional area being evaluated may have some ~ttributes that would
place _the evaluation in Category 1, and others that would place it in
either Category 2 or 3.
The final rating for each functional area is a
composite of the attributes tempered with the judgment of NRC management
as to the significance of individual items.
The SALP Board may also include an appraisal of the performance trend of a
functional area.
This performance trend will only be used when both a
definite trend of performance within the evaluation period is d1scernable
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and the Board believes that continuation of the trend may result in a
change of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the
close of the assessment period.
Declining:
Licensee performance was determined to be declining near the
close of the assessment period.
III. SUMMARY OF RESULTS
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A.
Overall Facility Performance
The Surry nuclear power station is staffed and managed by qualified
personnel with a broad background and many years of experience in the
nuclear operations area. Station management changes were made in the
Summer of 1987, due to normal company rotation policies. The station.
manager was transferred to the corporate office, the assistant
station manager for operations and maintenance was promoted to
station manager, the assistant station manager for nuclear l{censing
and safety was promoted to assistant station manager for operations
and maintenance, and the techn i ca 1 services superi n.tendent was
promoted to assistant station manager for nuclear licensing and
safety.
In .addition, new selections were made in the operations,
maintenance, and technical services superintendent positions* and in
the site quality assurance manager position during this assessment
period.
The changes were implemented with no adverse impact on
station operation. It should also be noted that all station senior
, management positions are presently filled with persons who held
Senior Reactor Operator licenses in previous positions with Virginia
Electric and Power Company (VEPCO) prior to reaching their present
management positions.
Corporate
senior management
involvement
in
plant performance
continues to be
!!Vi dent based on ongoing performance i ndi ca tor
monitoring, and the excellent manner in which the company handled the
Unit 2 feed pump suction piping rupture event, which occurred in
December, 1986.
A change in corporate management occurred 1 ate in
the SALP period due to r~organization of the company.
A new vice
president for nuclear operations was installed when the former vice
president was promoted to senior vice president in charge of all
power operation.
Also, the* corporate Quality Assurance Office
increased its effort in providing station management with a means to
review programmatic problem areas and provide appropriate feedback on
problem causes and recommendations for correciive actions.
This
effort has been evident in reviews by the inspectors of maintenance
and operations activities.
Dur.ing the SALP period, the Surry facility had high availability, with
th~ exception of outages on both units associated with inspection and
repair of the feedwater and condensate lines after the Unit 2
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feedwater suction line rupture; and fewer than the industry average
of reactor trips.* During the period, Unit 1 had 5 total reactor
trips (3 automatic and 2 manual) and Unit 2 had 4 total reactor trips
(2 automatic and 2 manual).
This equates to 1.8 automatic reactor trips per year for Unit 1* and 1.2 automatic reactor trips per year
for Unit 2; and this is an improvement over the last SALP period.
In
addition, these automatic trip rates remain below the 1987 industry
average of 3.24 automatic reactor trips per year.
Of the five *
reactor trips for Unit 1, three of these trips were caused by
equipment failures, one was caused by human error, and one was caused
by a combination of human error and equipment failure.
In addition,
Unit 1 had to be shut down once because of high leakage of the
reactor coolant from a loop isolation valve, and once because of
leakage from a main steam trip valve. Of the four reactor trips for
Unit 2, two of these trips were caused by equipment failure, and two
trips were caused by human error.
Regarding
occupational* radiation exposure, data available for
calendar year 1987 inoicate that a total exposure of 712 person-rems
was received by personnel at the Surry station.
This represents a
substantial reduction in occupational exposure for the Surry units.
The
licensee
has
made
significant
improvement
in
reducing
occupational doses to the workers.
The licensee performed satisfactorily in all functio*nal areas as
indicated in the performance analysis of this report.
However,
during the latter part of the period, inadequate management attention
contributed to escalated enforcement actions relating to operability
of heat trace circuits in boric acid flowpaths, and a potential for
overexposure of personnel during maintenance on an i ncore flux
detector.
Referring to subparagraph B below, three functional areas
have changed category level since the last SALP period.
Plant
operations and fire protection have declined to level two, while
training and qualification effectiveness has risen to a level one.
The functional area of radiological controls remained a level two
with a declining trend.
As indicated in the operations section of
this report (IV.A), lack of attention to detail coupled with other
negative attributes accounted for the level change. The fire protec-
tion area (section IV.E) went to a level two based o~ 10 CFR 50, *
Appendix R, and fire fighting equipment problems identified during
the period. The training area was perceived to improve based on INPO
accreditation of all training programs, excellent operators' test
scores, and high marks on an NRC Balance of Plant inspection.
Radiological controls was rated as a level two, based on a generally
good performance over most of the SALP period.
However, due to
problems which occurred recently, *had the area been rated just for
the last three or four months, the rating may have been different.
In conclusion, the licensee is continuing with programs to implement*
new and innovative techniques to improve perf.ormance and quality 1n
the various disciplines involved in nuclear power plant operation .
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These include an expansion of programs in which personnel from the
craft level in the maintenance areas, are being sent to observe
techniques employed by the French and Japanese at their nuclear
stations in order to improve performance at the licensee's s~ations.
Also, during this period, the licensee received full accreditation
from INPO for all of their trairiing programs.
8.
The performance categories for the current and previous SALP periods
in each functional area are as follows:
Functional Area
Plant Operations
Radiological Controls
Maintenance
Surveillance
Fire Protection
Security
Outages
Quality Programs and
Administrative Controls
Affecting Quality
Licensing Activities
Training and Qualification
Effectiveness
IV. PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
Previous SALP
Dates
March 1, 1985
August 31, 1986
1
2
2
2
1
2
- 2
2
2
1
2
Current SALP
Dates
September 1, 1986
April 30, 1988
2
2
2
2
2
2
2
2
2
1
1
During the assessment period, inspections of plant operations
were performed by the resident and regional inspection staffs.
Operations Summary:
s*oth units began the SALP period at full power operation and had
capacity/availability factors of 70.8/73.0 a.nd 64.3/67.5 percent
(Unit 1 and Unit 2, respectively) for the duration of the SALP
period.
Unit 1 entered a refueling/maintenance outage on
April 8, 1988, and Unit 2 completed a maintenance/refueling
outage during the period from October 4, 1986 to December 2,
1986.
Also, Unit 2 conducted a 16 day scheduled shutdown for
inspections and mairitenance in December 1987.
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The
major
interruption to
power
operation occurred
on
December 9, 1986, when Unit 2 experienced the feedwater (FW)
pipe rupture (discussed below).
The uriit did not return to
operation for more than three months.
The licensee shut down
Unit 1 one day after the pipe rupture to conduct inspections and
repairs; the unit returned to operation about two months later.
On December 9, 1986, Surry Unit 2 experienced a major feedwater
pipe rupture accident which involved four fatalities. The event
was caused by erosion/corrosion phenomenon in carbon steel
piping containing a single phase fluid.
The licensee's initial
response and the follow-up actions were commendable.
The
licensee provided up-to-date information to the staff and the
media, and arranged for several presentations to provide the
information to the rest of the industry. Because of the generic
implication, the licensee elected to shut down Unit 1 from
December 10, 1986 to February 23, 1987 for inspection and
replacement of defective feedwater piping.
On June 23, 1987, Unit 1 experienced a primary coolant leakage
in excess of 40 gpm through a loop isolation valve.
The staff
was informed immediately and the unit was shut down manually in
an orderly fashion.
The licensee responded to the event in a
proper manner.
The operations summary indicates that with the exception of the
pipe break outage for both units, Unit 2 operated as planned
with only two unscheduled outages; one in the middle of the
period for main turbine balancing, and the other at the end of
the period for repair of an electrical component. *unit 1, on
the other hand, experienced one unscheduled outage early in the
period and nine unscheduled outages during the last eleven
months of the period. The Unit 1 outages lasted an average of 7
days each.
During this SALP period Surry Unit 1 experienced a tota 1 of
three automatic reactor trips and Unit 2 experienced a total of
two automatic reactor trips. This converts to an automatic trip
rate.of 0.28 per 1000 critiq.l hours for Unit 1 and 0.21 per
1000 critical hours for Unit 2.
These compare favorably with
the 1987 industry wide average rate of 0.43 trips per 1000
hours.
The Surry station continues to meet or exceed the
company goal of having no more than two automatic reactor trips
per unit per calendar year (two automatic for Unit 1, and one
automatic trip for Unit 2 during 1987) for the past two years.
Between September l, 1986 and April 30, 1988, Surry Units 1 and
2 experienced 5 and 4 reactor trips, respectively.
This
converts to a trip rate of 0.47 p~r 1000 critical hours (3.0 per
year) for Unit 1 and.0.39 per 1000 critical hours (2.4 per year)
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for Unit 2.
These
rates are comparable
to the
1987
industry-wide average of 0.48 trips per 1000 critical hours (3.0
per year) for Westinghouse plants and are an improvement over
the previous SALP period.
Of the five reactor trips for Unit 1, three trips were automatic
and two trips were manual.
Three of these trips were caused by
equipment failures, one was caused by human error and one was
caused by a combination of human error and equipment failure.
In addition, Unit 1 had to be shut down once because of high
leakage of the reactor coolant from a loop isolation valve and
once because of leakage from a main steam trip valve.
Of the four reactor trips for Unit 2, three trips were automatic
and one was a manual trip. Three of these trips were caused by
equipment failure and one trip was caused by human error.
The Surry facility _has generally been adequately managed and
operated by the corporate office and plant staff during this
assessment period.
The operations staff was knowledgeable and
proficient in normal and emergency plant operations.
Their
response to the Unit 2 pipe rupture event in December 1986 was
excellent, and this performance carried over when required to
respond to transients and to the Unit 1 reactor trips in 1987.
However, lack of attention to detail during the -SALP period
which resulted in violations (b) through (e) of this section.
indicates that additional management attention is required to
minimize operator error during routine operation.
In addition,
violation (d) indicates a generic problem in the procedures area
with
regards
to
initial
conditions
identification
and
disposition of procedure changes.
When required, management
corrective actions are generally complete and technically sound
with appropriate effectiveness indicated.
The licensee's approach to resolution of technical issues from a
safety standpoint was demonstrated in the response to viola-
tion (d). The issues were understood by the licensee and timely
resolutions were provided with a technically sound and thorough
solution.
In addition, adequate training was provided to all
personnel involved in conducting evaluations for unreviewed
safety question determination; and positive results have been
observed during the last part of this period. However, near the
end of the rating period, a lack. of understanding of the boric
acid heat trace system* and management tolerance resulted in
que~tionable operability of the system for an extended period of
time, and resulted in a civil penalty violation that was issued
after the SALP period ended .
. A total of 79 Licensee Event Reports (LERs) were* submitted
during the SALP period.
These are addressed in Section V.H of
this report.
Of the LERs submitted,. four were ranked as
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significant by the NRC screening process.
The most significant
event was the failure of a main feedwater pipe at Unit 2 due to
erosion/corrosion (This event has been repor~ed to Congress by
the NRC as an Abnormal Occurrence).
The licensee has submitted
an extensive re~ort (LER 281/86-020) and updates which provide
detailed descriptions of the event, causes and corrective
actions.
Two
of the significant LERs describe improperly
installed Raychem splices (LER 280/86-035 and 281/86-018).
The
fourth significant LER desctibes a loss of service water to the
charging pump service water subsystem which occurred due to a
leak in the blowdown line for the in-line service water strainer
A large number (12) of LERs associated with the service water
system was observed, especially problems with control/relay room
chillers which were attributed*to low service water flow due to
clogged service water strainers. These events indicate that the
licensee had not taken action to correct the root causes of
these problems; however, additional actions are being taken
during the current Unit 1 refueling outage.
NRC review of the significant events which occurreQ during the
SALP period found that, in each cise, th- licensee had submitted
LERs which adequately addressed the reportable events.
Corporate interest in station activities continues at the
appropriate levels with the "Nuclear Performance Monitoring -
Management Information Report" continuing to provide appropriate
station management attention tq areas being reported.
Utility
policies were for the most part appropriately stated, dissem-
inated, and implemented; however, some weaknesses were noted in
the corrective action process for identification of deviations
(conditions adverse to quality).
The residents discussed the
site deviation threshold with station management and noted an
improvement during the second ha 1f of the SALP peri ad.
The
licensee was responsive to NRC concerns and requests, resulting
in proposals of acceptable resolutions.
During this evaluatio~ period, an inspection was conducted by
the regional staff to assess compliance with Generic Letter 81-21, Natural Circulation Cooldown.
This Generic. Letter
required the licensee. to establish and implement Emergency
Operating Procedures (EOPs)
and training relating to the
possible loss of the reactor coolant pumps during power
operations. Weaknesses were identified in th~ documentation of
differences from the Westinghouse Owners Group (WOG) Emergency
Response Guidelines (ERGs) for the natural circulation cooldown
EOPs.
This was identified by the NRC as a Deviation.
A viola-
tion was issued for inadequate EOPs when it was determined that
the quantitative cooldown curves used in the natural circulation
cooldown
exceeded those specified in the Technical
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Specifications (TS).
No problems were identified concerning the
licensee's training in this specific area.
This inspection only
reviewed three of the 1 icensee' s 42 EOP' s and did not do a
programmatic assessment of the licensee's Procedure's Generation
Package (PGP).
The licensee, during this evaluation period, had the control
room operations personnel on a five shift rotation policy which
provided for adequate coverage whi 1 e a 11 owing for appropriate
training.
Three shifts were working eight hours each day, one
shift was off, and one shift was in training.
In addition, the
licensee usually had one extra licensed senior operator on
shifts which re qui red add it i ona 1 support (i.e., day shift).
Control room formality and behavior were maintained at a high
professional level.
Licensed operators performed their duti'es
in a professional manner which aids in safe and efficient
station operation.
Management involvement in day to day
operation was evident.
The new operations superintendent has
implemented a more formalized policy which should enhance the
operations program.
The human performance evaluation system and
check operator programs continue to improve operator efficiency
and help to. minimize recurrence of mistakes.
Operational
procedures, as indicated by violati.on (e), was one area which
- needed improvement, and additional resources have been dedicated
to this area.
The licensee stressed the reduction of nuisance,
lit annunciators in the control rooms ("black board" concept)
that has result~d in less than 10 lit annunciators per control
room throughout the SALP period.
The licensee's operations
program continued to provide the necessary leadership and
professional attitude which has generally resulted in a high
level of operator performance while insuring safe operation of
the station.
During this assessment period, two Quality Assurance (QA)
Assessments related to operational activities were performed.
Areas
reviewed
included control
room activities, shift
turnovers, post reactor trip investigations, operating logs,
licensee
event
reports,
surveillance
procedures
and
documentation, the overall QA program, equipment labeling; and
opera ti ona 1 performance trending.
A 11 areas_ were assessed as
adequate; however, control room demeanor and post reactor trip
i nvesti gat ions
were
found
to
be
particularly
strong.
Additionally, management attention in the operations area was
especially noticeable as indicated by frequent management
presence in the control room and frequent plant tours. This QA
assessment, however, identified several problems related to an
event (Violation c of Section IV.I) in that the licensee did not
follow the Technical Specification requirement for inoperable
control rods and terminated an Unusual Event prior to corrective*
action being fully completed.
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The following violations were identified:
a.
Severity Level III violation for failure to maintain and
verify operability of heat trace circuitry for boric acid
flow path (88-04).
b.
Severity Level IV violation for failure to provide adequate
detailed instructions and failure to follow procedures
involving
residual
heat removal
pump
(87-05).
Also
discussed under the maintenance, surveillance, and outage
functional areas.)
C.
Severity level
IV violation for inadequate procedures
resulting in a degradation of containment integrity.
(87-26)
d.
Severity Level
IV violation for failure to conduct an
evaluation for a unreviewed safety question determination.
(87-21)
e.
Severity Level IV violation for failure to follow procedure
during performance of a surveillance test.
(88-01)
f.
Severity Level
IV
violation for inadequate emergency
operating procedures for natural circulation cooldown:
coo 1 down curves exceed those in the Techn i ca 1 Speci fi ca-
tions.
(87-32)
g.
Deviation for failure to follow procedures generation
package commitments
in generating emergency operating
procedures for natural circulation cooldown.
(87-32)
2.
Conclusion
Category:
2,
3.
Board Recommendations
The board noted that the effectiveness of the licensee's reactor
trip reduction program continued to provide positive results.
However, the board concluded that an overall lack of attention
to _detai 1 in the plant operations area in conjunction with a
rising industry standard for excellence resulted in a lower
evaluation in this area.
No changes to the* NRC inspection
resources recommended.
B.
Radiological Controls
1.
Analysis
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During the assessment period, inspections were performed by the
resident and regional
inspection staffs.
The
inspe~tions*
included three radiation protection inspections, and five
radiological effluents and chemistry inspections which included
confirmatory measurements using the Region II mobile laboratory.
Also conducted was a special appraisal of the licensee's program
for maintaining radiation exposures as low as reasonably achiev-
able (ALARA) and one inspection to review an event having a
significant potential for personnel exposures in excess of NRC
limits.
The licensee's health physics, radwaste, and chemistry staffing
levels were appropriate and compared well to other utilities
having a facility of similar size.
An adequate number of ANSI
qualified licensee and contract health physics (HP) technicians
and qualified chemistry technicians were available to support
routine and outage operations.
The 1 i censee ut i 1 i zes some
contract HP support during non-outage periods.
During outages,
the licensee supplements the HP staff with additional ANSI
qualified health physics technicians and decontamination support
personnel. During outages, the contract technicians who work at
the plant during non-outage situations become coordinators of
the supplemental contractor technicians, resulting in improved
plant interfac~s between contract technicians and the permanent
plant staff.
The knowledge and experience level of the site health physics
and chemistry staffs are good.
The staff has a low turnover
rate and an effective training program which has received INPO
accreditation. The licensee had only three staff members leave
or retire during the assessment period.
During the assessment period, the licensee's radiation protec-
tion organizational structure remained unchanged.
However, the
licensee permanently filled the Supervisor of Health Physics
Technical Services position for the first time since it was
created in 1984.
Key positions in the radwaste management_
program and environmental surveillance programs were also filled
with qualified staff.
The performance of the HP staff in support of routine operations
and outages was adequate.
However,
procedural compliance
appeared to be a program weakness.
At least four procedura 1
compliance violations were identified during ttie assessment
period, two with multiple examples.
The licensee began development of a plan to upgrade the radia-
tion protection program in 1983 to correct a breakdown in the
program identified by the NRC.
In 1985, the licensee formally
issued the Radiation Protection Plan (RPP) which established
policies and responsibilities for upgrading the radiation
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protection program.
The licensee issued an implementation plan
with the RPP in 1985, which established the schedule for
upgrades in specified program areas such as external dosimetry
and ALARA.
The plan has lead to significant improvements in
radiation protection facilities at the station.
Although the
development and implementation of the RPP has been in progress
for nearly five years. at the end of the assessment period, the
licensee had fully implemented only two out of nine major
elements of the program.
The delays in implementing the* RPP are
due, in part, to a lack of strong direction and leadership from
the corporate health physics staff.
The licensee's schedule
calls for the RPP to be fully implemented with upgraded
procedures in place by July 1989.
Near the end of the assessment period, there was an event
involving maintenance on
an
incore detector which had a
significant potent i a 1 for an overexposure of personne 1.
Two
instrument and control (I&C) technicians and one HP technician
~ntered the subatmospheric Unit 2 containment with the plant at
100 percent power to free a stuck i ncore detector.
During
efforts to free the incore detector, approximately 100 feet of
cable attached to the detector were pulled through the polar
- crane wa11* into the work area.
As a result of pulling
approximately three f_eet of activated cable in to the work area,
radiation levels ~n excess of 1000 Rem per hour were measured.
The workers evacuated the work area.
Although radiation doses
to the workers were less than NRC limits, there was a signifi-
cant potential for the workers to receive exposures in excess of
NRC limits.
The civil penalty violations resulting from this
event involved failure of the licensee to evaluate the radiation
hazards present during the work, inadequate procedures for
freeing the detector, and inadequate briefing of all personnel
involved in the work.
This event represented a breakdown in the
facility's management and control systems, in that station
management failed to perform an adequate pre-job assessment of
the potential hazards* involved in the work. A weakness in the
licensee's radiation work permit (RWP) program was evidenced by
this event in that a standing RWP written for minor maintenance
and inspections was used to free the stuck incore detector
discussed above,
rather than a more specific and more
restrictive special RWP.
After the event, the licensee was slow
to initiate an investigation of the event.
t,iowever, once
initiated, technical support from corporate staff was excellent,
as evidenced by
a comprehensive
and technically
strong
evaluation of the workers' doses after the event.
Resolutions of technical issues has been below average, as
evidenced by:
(a) the operation of the demineral izer-based
radioactive waste systems until breakthrough rather than *
maintaining
optimum
water
quality;
(b) strong management
attention has not been placed on vendor personnel to repair the
--
14
filter tape drive mechanism on the new containment air sampling
and monitoring system; and (c) timely resolution of the long-
term problem of buildup of internal radioactive contamination in
the liquid radioactive effluent detection chambers.
At the end of 1986, the licensee had 29,000 square feet (ft2) of
contaminated
area which
represented
32 percent
of
the
radiologically controlled area (RCA) of the plant, not including
the containment buildings.
By the end of the assessment period,
the licensee had reduced. the size of the contaminated area down
to 24,000 ft 2 or 26 percent of the RCA.
Although the total area
contaminated is significantly above that of a good performer in
Region II, the licensee has made excellent progress in reducing
the total area of the plant maintained as contaminated.
In 1987, the personnel contamination reports decreased 340
percent to a total of 465, which included 161 skin contamination
events.
This reduction in skin contamination was partly
influenced by the fact that there was no refueling outage in
1987.
At the end of the assessment period for 1988; the
1 icensee had documented 237 cases of personnel contamination
which included 138 skin contamination events.
The licensee's
corporate
hea 1th
physics *staff eva 1 uated the personne 1
contamination events and has made recommendations to reduce the
nu~ber of events and to improve per~onnel contamination
monitoring and control programs.
The 1986 collective radiation dose was 1178 person-rem per unit,*
which was
approximately 3 times the national average of
397 person-rem per pressurized water reactor (PWR).
From 1983
through 1986, the station's collective dose was significantly
above the national average.
In 1987, the station's collective
radiation dose was 356 person-rem per unit which compares
favorably with the national average of 368 person-rem per PWR
unit.
However, there was no refueling outage in 1987. * The
licensee has established a 1988 goal of 734 person-rem per unit,
which is likely to be significantly greater than the national
average due to the fact that both units will be.in refueling
outages this year~ The licensee has established a long range
goal to be at or be 1 ow the national average for co 11 ect i ve
occupational radiation dose by 1991.
During the assessment period, the NRC performed a special
assessment
of
the
licensee's
program
for
maintaining
occupational radiation dose as low as reasonably achievable
(ALARA).
Although the necessary elements of an effective ALARA.
program were in place, the 9verall effectiveness of the program
Jn reducing the station's collective radiation dose is yet to be
demonstrated.
Management support and involvement in matters
relating to the ALARA program improved during the assessment
period.
Licensee plant and corporate management are routinely
--
15
involved in setting program goals.
The licensee's senior vice
president persona1iy monitors collective dose trends and reviews
instances where dose goals are exceeded.** Management had
dedicated significant attention and resources to collective dose
reduction.
During 1987, management of the 1 icensee 1 s ALARA program was
observed by the !'"esident inspectors on a daily basis.
The
licensee established a goal of 719 person-rem total station
exposure for the ca 1 endar year.
Goa 1 s were es tab 1 i shed and
results displayed daily on the station internal television
system so that each emp 1 oyee could monitor progress in their
departments.
Daily discussions involving the past days
person-rem exposures were held by station management in the plan
of the day meetings.
High expenditure jobs were specifically
discussed including the specific departments using most of the
expenditure for the day.
Results of this management effort
included the station bettering its goal by expending only 712
person-rem in 1987.
The licensee has taken a number of actions to reduce exposures,
including additional training to improve the staff's awareness
of ALARA concepts; procurement of video equipment to provide for
remote monitoring of equipment, area~ and jobs; procurement of a
computerized Visual Information Management System which will
display* approximately 90 percent of the plant for pre-job
planning; allocation of significant resources to reduce the size
of the contaminated area of the plant; removal of. snubbers in
high dose rate areas; installation of fuel with zircalloy grids,
rather than inconel to reduce the source of cobalt; installation
of extended life light bulbs to reduce dose received on light
bulb replacement; and reduction of the exposure rates in the
Auxiliary Building by cleaning out sumps, drains and tanks.
These actions should result in collective dose reductions in the
long-term.
A number of other initiatives (e.g., source term
reductions) in the licensee's ALARA Action Plan have not been
completed and do not have completion dates assigned.
In 1986, the licensee shipped for burial 22,562 cubic feet (ft3 )
of solid radioactive waste containing 1156 curies.
In 1987, 'the
licensee shipped for burial 18,169 ft 3 of solid radioactive
waste containing 29,370 curies.
The majority of the 1987
radioactivity, 28,800 curies, came from irradiated hardware.
The licensee shipped 229 ft 3 of solid irradiated stainless
steel, borosilicate glass, and deposited metal oxides (thimble
plugs and burnable poison rod assemblies in cut up form).
By
the end of the assessment period, the licensee had shipped in
1988 2,942 ft 3 of solid radioactive waste having 156 curies.
During the assessment period the licensee* began shipping dry
active waste to a vendor for volume reduction.
This offsite
- -~'* :, .** '**** ,*f ~ **
,.
- .
16
compactor gives a volume reduction twice the capability of the
onsite box compactor.*
Plant discharges of liquid effluents contained 8.77 curies of
mixed fission products in 1986 and 5.17 curies in 1987.
While
this was an improvement over the plants prior liquid release
history (examples:
14.5 curies in 1983 and 65.5 curies in
1977), releases of IT'ixed fission products in 1987 in liquid
effluents, as in every year since 1980, have been higher than
any. other plant in Region
II.
The principal reason for this
appears to be the plant policy of operating the demineralizer-
based radioactive waste systems to the point of break.through
(onset of high conductivity in the processed water) rather than '
maintaining optimum water quality.
Such operation meets ALARA
limits under the criteria of Appendix I to 10 CFR Part 50, so
long as doses to the public meet the 40 CFR 190 limits.
Releases have consistently been well
below these limits.
Discharges of tritium in liquid effluents averaged approximately
400 curies per year per unit, which is typical of large PWRs.
Radioactive gaseous effluents were lower in 1987, than at any
time since the plant went into commercial operation. Average
releases in the 1980-1986 time period were comparable to other
2-unit plants in Region II.
Annual effluent release summaries
for 1985 - 1987 can *be found in section V.L of this report.
Ope rational expertise with process and effluent monitoring
systems was generally satisfactory.
The licensee resolved a
long-term problem with the liquid radioactive effluent monitors
caused by a buildup of radioactive contamination internally in
the detecti~n chamber and a check source which was too small to
result in a measurable meter deflection upon source check
activation.
This resulted in a violation.
Environmental monitoring activities were adequate. Samples were
changed regularly by well trained personnel. The environmental
samples
were
analyz_ed
by
a contract
laboratory
which
participated in .a cross-chec~ program with the EPA and NRC.
During the assessment period, it was noted that the licensee
fa 11 ed to conduct an eva 1 uat ion to determine if radioactive
materials were contained in licensee-generated sanitary sewage
sludge.
Samples taken by the licensee after this finding showed
2 to 3 pCi/g of activity in the dried sludge, principally Cs-137
and Co-60.
This resulted in a violation.
As part of the confirmatory measurements inspection, the
1 icensee was requested to analyze four. simulated waste or
reactor coolant samples on each of three detectors. Out of the
twelve analyses, the results of one were not in agreement. The
disagreement was resolved on a recount.
17
The licensee was observed to have given increased attention to
corrosion and erosion control.
Good chemistry control was
maintained throughout 1987 and was attributed to the following
factors:
relatively stable plant operation of both the plants;
increased surveillance of condenser tube integrity; improved
efficiency of producing
makeup
water;
operation
of the
condensate cleanup systems;
adherence to contra 1 criteria
recommended by the Steam Generators Owners Group; increased
resources (physical facilities, manpower,
inline analytical
instrumentation) for the chemistry staff; an9 support being
provided by Westinghouse through a maintenance agreement.
Weak
points were observed in the reliability of water treatment plant
and on the continua 1 transport of corrosion products to the
Nine violations were identified:
a.
Severity Level III violation for failure to adequately
evaluate the radiation hazards present during work on an
i ncore detector, inadequate procedures for freeing the
incore detector and for briefing those involved in the
work, and failure to conduct operations in accordance with
- approved procedures (88-10).
b.
Severity Level IV violation for failure to control radio-
active- material in accordance with 1 icensee procedures
(87-35).
c.
Severity Level IV violation for failure to comply with a
low level radioactive waste disposal facilities Agreement
State's licensee conditions (87-03).
d.
Severity Level IV violation for failure to comply with
Department of Transportation regulations for transporting
radioactive material (87-03).
e.
Severity Level
IV violation for failure to adequately
source check an effluent monitor (87-22).
f.
Severity Level IV violation for failure to evaluate the
concentrations of radioactive material in sanitary sludge
(87_-22).
g.
Severity Leve 1 V violation for failure to adhere to
radiation control procedures addressing whole body counter
quality control checks (87-24).
h.
Severity Level V violation for failure to adhere to
radiation control* procedures addressing .Low Level Waste
Storage Faci 1 i ty inventories and surveys, and failure to
.
. . -..-.~-,,-~--.... **-
--
18
condu.ct
performance
checks
for
PCM-IA
personne~
contamination monitors (87-03).
i.
Severity *Level V violation for failure to provide adequate
procedures for the filling of waste disposal cans to 85%
capacity (86-21).
2.
Conclusion
Category:
Trend:
2
Declining
3.
Board Recommendation
The Board notes a declini~g trend at the end of the SALP period
and further notes a continued decline after the end of the SALP
period, including several violations identified during a outage
inspection
and
an
Based
on
this
recent
performance, the Board notes that a more current SALP category
would be a 3.
This, coupled with the lack of identification of
the root cause of the incore detector exposure event, causes the
Board to recommend comprehensive high level management attention
to implementation of radiological .controls by all organizational
components at Surry.
In addition,
the Board
recommends
increased NRC inspection.
C.
Maintenance
.. 1.
An al y s i s
During the assessment period,
maintenance were performed by
inspections staffs.
inspections in the area of
the resident and
regional
While not a regulatory requirement, a special inspection of the
secondary systems, and maintenance in the balance of plant
systems was inspected and found to be satisfactory.
Upper
management involvement was evident by their participation in
plant sta*rtups and shutdowns, daily production meetings, and
post trip reviews for both balance of plant (BOP)
and
safety-related systems matters.
The
licensee takes a sound viable approach* in resolving
technical issues.
For example, many improvements have been
initiated to increase the feedwater control system's reliability
and to reduce challenges to the safety systems. A *self imposed
requirement to test feedwater regulating valves at shutdown and
prior to startups has been instituted to avoid unforeseen
problems.
The licensee has also establi*shed a Predictive
Analysis Group to prevent future problems (see section IV.D).
However, specifically for the BOP/feedwater system, a formal,
,. .. '*-* ... *.
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--
19
we 11 defined program for root cause analysis, documentation,
trending and utilization of information from. the station has not
been established. A review of BOP related events, that are
maintenance related, shows a lack of consistency in establishing
relationships to previous BOP events.
During the evaluation period, an inspection was performed in the
areas of electrical and instrument *maintenance practices,
planning and schedulin~, plant engineeririg interfaces, trending,
and information review programs.
No violations or deviations
were identified.
A weakness was identified involving .the
effectiveness of the licensee's program for trending equipment
failures.
The quarterly trending reports issued by Plant
Engineering do not provide a useful trending analysis of
repetitive problems or determination of root causes.
This
concern was also expressed by the licensee 1 s staff.
The maintenance program continues to be a high priority with
both the station and corporate management.
T~e specific daily
activities are discussed in frequent management meetings with
the assigned priorities displayed on
television monitors
throu*ghout the station.
Added emphasis has been pl aced on
pre-job and post-job briefings and the need to adequately
document the work performed.
As discussed previously (section
IV.B), the failure to perform an
adequate pre-job brief
contributed to
the potential
for an
overexposure while
performing maintenance on the incore detector. The availability
of technically sound and thorough maintenance procedures and the
strict adherence to these procedures continues to be a weakness
in the maintenance program.
Specific maintenance tasks are
sometimes performed using general procedures. This condition
resulted in the improper assembly of a main steam trip valve
(identified in violation (a)), and fa.ilure
_to
adhere to
procedures that resulted in subsequent degradation and rework of
a residual heat removal pump (identified in violation (b) of
section IV.A of the report). In addition, a QA inspection
conducted early in the period resulted in numerous maintenance
procedural deficiencies which resulted in a* violation which is
identified in section IV.I of this report.
The resolution of technical issues as they arise during main-
tenance appears to demon.strate a generally sound and thorough
approach with adequate understanding of the issues.
Senior
station and corporate management have acknowledged that a solid
programmatic approach to obtaining the root cause of problems
has been a weakness in the maintenance program and were taking
steps to enhance this area at the end of this SALP period.
A
major improvement was noted when the maintenance engineering
group was formed early in _the period.
This group of engineers
worked alongside the mechanics to resolve problems and ensure an
adequate failure analysis.
Late in the period, it was decided
. .
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20
that additional engineers would be added to the station staff to
supplement the work being accomplisli*ed by the maintenance
engineers.
These new engineers would become system engineers.
and thereby could provide immediate involvement in resolution of
problems
associated
with
systems
for
which
they
were
responsible. This program was in the implementation stages when
the SALP period ended.
Management response to NRC initiatives was v1able and sound with
acceptable resolutions generally proposed.
The
licensee's
evaluation and resolution of NRC IE Notices have generally been
both timely and thorough.
Each IE Notice sampled was placed on
the commitment tracking *system for reso 1 ut ion with firm commit-
ment dates established.
Overdue commitments are brought to
management's attention. A formal check valve PM program has not
been.implemented in spite of the identification of industry and
site check valve problems; however, a study of check valve
applications has been completed, and work is in progress to
develop such a program.
An improvement in the overa 11 performance of the maintenance
department is noted by the relatively low number of transients
during this . SALP period and 247 days of continuous power
operation on Unit 2. Although Unit 1 experienced several forced
outages, only two were directly attributable to improper
maintenance; and others relating to equipment failure resulted
in licensee corrective actions to prevent recurrence.
The
licensee is progressing with the development of the Quality
Maintenance Team (QMT) concept with all electricians, mechanics,
and welders receiving additional training in health physics, QA,
and nondestructive testing.
Station management consistently
demonstrated a commitment to this approach in the daily
scheduling of maintenance activities and attribute the improved
equipment availability to this program.
A weakness was identi-
fied (violation b) with the control of substitute material in
safety-related components when a field fabricated part in a
valve actuator contributed to it's failure to perform as
desired; however, this substitution did occur prior to the QMT
concept.
Staffing continues to improve with the key positions identified
and the responsibilities adequately defined. The use of previ-
ously 1 icensed reactor operators as maintenance coo-rdinators,
and maintenance foremen as planners, aids in both communications
and
effectiveness.
The
establishment of a
maintenance
engineering staff greatly enhances the capability of the
maihtenance department to adequately evaluate and correct
problems in the field as they arise.
During this assessment period, two QA Assessments related to
maintenance activities were performed.
The
licensee has
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21
strengthened
their maintenance
tagout system,
and
also
increased their usage of a computer system (WPTS) for scheduling
and tracking maintenance activities. The licensee has increased
their attention to using predictive analysis programs for better
overall equipment reliability.
Weaknesses were
identified
relative to the Station Nuclear Safety and Operating Committee
(SNSOC) timely reviews of maintenance procedure and other
procedure changes.
Storage of maintenance related spare parts
was not always adequate in that level A and B required materials
were .found in the same lay down area during one inspection.
This problem was immediately corrected by the licensee.
A problem was
identified related to failure to follow
established controls for maintenance work orders (in section
IV.I, violation a). The apparent root cause is. the failure of
personnel to follow procedures. Multiple examples of incorrect
work orders were i dent i fi ed even though these work orders
received final closeout by maintenance, supervisory, and QA
personnel.
The following violations were identified:
a.
Severity Level IV violation for failure to provide.detailed
instructions in maintenance procedures for safety-related
equipment (main s*team trip valve).
(86-42) Unit 2 only.
b.
Severity Level V violation for failure to provide adequate
control and evaluation of the substitution of replacement
parts in safety-related components.
(88-01)
2.
Conclusion
Category:
2
3.
Board Recommendation
None
D.
Surveillance
1.
Analysis
During the _assessment period, inspections were performed by the
resident and regional
inspection staffs in the areas of
periodic surveillance testing, containment local. and integrated
leak rate testing (ILRT),
and
inser.vice i_nspection (ISI)
programs.
Manag.ement involvement in the scheduling and performance was
adequate as evidenced by the routine reviews of tests being
performed in the daily meetings.
Test records were generally
.. " .. -.....
.
L_
22
found to be complete and available.
A weakness was noted,
however, in the formal identification and evaluation of testing
discrepancies.
The inspectors performed~ comprehensive audit
of the integrated safeguards tests performed during the last
- refueling outages and found, as identified by violation (b)
below, that the records were not complete and the review and
evaluation of discrepancies inadequate.
Decision making was
solely by the operation superintendent performing the test w~th
no overview or technical evaiuation evident.
Retest, after
equipment repairs, was performed using special tests that did
not receive adequate review and approval.
The normal process of
eva1uating discrepancies appeared to have been bypassed for this
rather complex test.
Technical Specification (TS) required surveillances were, with
few exceptions, completed*in a timely manner.
The licensee's
program to track survei 11 ance intervals and identify overdue
tests to key
individuals appears to be effective.
The
inspectors did identify a required TS surveillance, included in
violation (b) below, that had not- been added to the .testing
program after it was added to the TS several years earlier. The
requirement involved the testing of emergency bus undervoltage
and degraded voltage circuitry and was previously identified as
an omission to the testing program with no subsequent corrective
actions performed.
During the evaluation period, inspections were conducted by
regional inspectors of the snubber survei 11 ance program,. post-
refueling
and
zero-power
startup
tests*,
1 eak.age
measurements, and integrated 1 eak rate testing.
The snubber
surveillance program showed evidence of prior planning through
well
defined
procedures.
Records
were
complete,
well-maintained, retrievable, and legible.
Staffing and training
of personnel involved in the snubber surveillance program were
adequate.
The
approach to problems
encountered due
to
functional test failure was timely, technically sound, and
thorough.
Decision making was usually at a level which ensured
adequate management review .
. Unit 2 post-refueling, zero-power startup tests were witnessed
in December 1986.
The tests performed and the procedures used
to perform them were acceptable.
The personnel performing the
test were familiar with test requirements.
The onsite personnel
function primarily as data takers since technical analysis is
performed by corporate office personnel.
Independent analysis by the NRC inspection of thermal power
calculations and RCS *1eakage measurements was performed in
concert with rev.i ews of 1 i-censee procedures.
The differences
between results calculated by the licensee and the inspector
were acceptable. However, the licensee's procedure for leakage
- -* **
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23
measurement needed improvement, which management readily agre~d
to perform.
The
integrated
leak rate test on
Unit 2,
performed in
November 1986, was witnessed by
NRC inspectors.
Management
interest and involvement in leak rate surveillance testing are
indicated by the development of a detailed test procedure which
controls test preparations, activities, acceptance criteria and
system
restoration.
Also,
staffing
and
training
were
satisfactory for conduct of the test.
Management involvement and conservative resolution of technical
issues were observed in the licensee
1 s actions \\aken to correct
the sump pump discharge isolation valve leakage problem.
These
valves had exhibited recurring leakage problems, and the licensee
conducted a thorough investigation to determine the cause. The
results were to change the valve design, modify operating and
test procedures, and perform a number of 1 oca l tests on the
modified system.
The licensee had taken responsible, conserva-
tive action to achieve a quality performance.
Inspections of
the ILRT revealed several technical issues that are indicative
of a non-conservative approach toward resolution.
These
involved data averaging, assumption-of water seals, and status
of' liner weld leak chase.
The latter two issues have not been
resolved and are currently under review by NRC.
While the
issues are not of a nature to indicate a significant breakdown
of management control and quality assurance programs, they do
i~dicate a need for increased management attention to achieve a
high quality test performance.
The licensee generally demonstrated a clear understanding of
technical
issues and was responsive to
NRC concerns.
A
significant weakness in the licensee program for testing heat
tracing circuits on boric acid flowpaths was identified as part
of a civil penalty violation late in the period; the violation
(a, section IV.A) was not issued until after the SALP period
ended.
These circuits, required by technical specifications,
had not been adequately tested since original installation. The
licensee took prompt corrective actions to research and correct
the problems which appeared to indicate a failure to properly
review the applicable procedures, as well as a general lack of
understanding
regarding the heat tracing circuits.
The
reporting and analysis of surveillance events was in most cases
prompt and thorough, although a weakness was identified in
~iolation (d) of section IV.A which is listed in the Operations
functional area, regarding the failure to report special tests
as required by 10 CFR 50.59.
A strong management commitment to the use of extensive
predictive analysis during surveillance testing was evident
during the reporting period.
The licensee utilized equipment
- _.
"'_*. __
24
monitoring techniques that greatly exceed the basic testing
requirements.
This additional testing was often performed even
though it constituted an additional constraint on both resources
and schedules.
The following violations were identified:
a.
Apparent violation for failure to properly position valve
for penetrations for a Type A test (86-36, Unit 2 only);
this issue has not been resolved.
The NRC did not consider
the issue during this SALP evaluation.
b.
Severity Level IV violation for inadequate procedure and
failure to follow procedure in testing of safety injection
system. ( 87-21)
c.
Apparent violation for failure to follow nondestructive
test and ANSI procedures involving radiographic testing has
not been resolved .. It was not considered during this SALP
evaluation.
2.
Conclusion
Category:
2
3.
Board Recommendation
None
E.
Fire Protection
1.
Analysis
During this assessment period, inspections were conducted by the
regional inspection staff of the licensee's fire protection and
fire prevention program including a review of the implementation
of the safe shutdown and related fire protection requirements of
On May 4-8, 1987, an NRC team conducted an
II Appendix R" in spec-
ti on to determine if the protection features provided for
structures, systems, and components important to safe shutdown
were in compliance with 10 CFR 50, Appendix R, Sections III.G.,
III.J., III.L., and III.O. This inspection determined, through
a random sampling of cable routes and components associated with
safe shutdown and alternate shutdown capability, that the fire
protection features provide adequate protection to ensure one
train of equipment is available to perform plant shutdown or
alternate shutdown.
Fire protection. features met the require-
ments of Appendix Rand applicable industry codes, or exemption
request and/or engineering evaluations have been provided
.
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25
justifying the deviations.
The licensee adequately acdressed
associated circuits and breaker coordination, and emergency
shutdown procedures are available for use in the event of a
fire.
Prior to the Appendix R inspection, it was determined that the
power and contra l cables for a 11
on site emergency ci ese l
generators were routed through Fi re Area 2.
Therefore. it is
possible for a fire in this area to result in a loss of charging
pumps for both units (violation (a) below).
The licensee had identifiep this cable interaction discrepancy
and a Special Report, No. 87-10, was submitted to the NRC.
The
licensee initiated prompt corrective action by establishing a
fire wa*tch in the area and initiating a design change to reroute
the Diesel Generator No. 3 cables out of the are*a.
The design
modification package was completed promptly.
Two
inspections of the routine fire protection/prevention
program were also conducted during the assessment period.
The
licensee had issued procedures for the contra 1 of fire hazards
within the plant, surveillance and maintenance of the fire
protection systems and equipment, and organization and training
of the fire brigade.
These procedures were found to meet the
NRC requirements and guidelines. The staff inspection reviewed
the licensee's implementation of the fire protection and
administrative controls.
General housekeeping and con~rol of
combustible and flammable materials were satisfactory.
The fire protection extinguishing systems, detection systems and
fire barriers, and fire barrier penetrations were found to be in
service, or the appropriate limiting condition for operation
requirements of the Technical Specifications had been implemented
except as noted below.
Surveillance inspection, tests, and
maintenance of the fire protection system and features were
satisfactory.
Organization and staffing of the plant fire brigade met the NRC
guidelines.
Fire protection staff positions were identified and
authorities and responsibilities were clearly defined.
The
training and drills for the brigade members met the frequency
specified by the procedures and the NRC guidelines.
Personnel
were well qualified for their duties.
A violation was identified during one of these routine inspec-
tions.due to the licensee's failure to maintain emergency fire
fighting equipment available exclusively for fire fighting use.
In reviewing plant Technical Specification surveillance results
it was found that on numerous occasions-over the one year period
reviewed, that emergency fire fighting equipment was routinely
being
removed
from storage locations specified in plant
- ,*.**** *;*-~*-** v.-.-*. : .***.
..
.. - .. _.,, ............ ,., ............ -.... .
26
procedures.
At the time of the ins~ection, three storage areas
were found to be missing necessary equipment. The equipment was
found being used for non-fire fighting uses by the pl ant
operations department.
Licensee management took immediate
corrective action to replace the r.iissing equipment and also
issued a memo to all plant personnel emphasizing the importance
of this equipment and stating this equipment is to be used for
fire fighting purposes only.
Additionally, the licensee had
established a unique marking sys~em for fire fighting equipment
which identifies it as emergency equipment.
Except for the violations identified, the management involvement
and control in assuring quality of the fire protection program
is evident based upon their involvement in the site fire
protection program to ensure the program complies with NRC
requirements and the prompt resofot ion of nonconformances.
The
licensee's approach to resolution of technical fire protection
issues indicates an apparent understanding of issues.
The
responsiveness to NRC initiatives are technically sound and
thorough.
The following violations were identified:
a.
Severity Level III violation for failure to assure that one
redunda*nt train of equipment, cabling and associated
circuits necessary to achieve and maintain hot shutdown
remains free of fire damage pursuant to the requirements of
10 CFR Part *50, Appendix R, including specifically Section
- . III.G., Fire Protection of Safe Shutdown
Capability
(87-07).
b.
Severity Level IV (Supplement I) violation for failure to
comply with the requirements of Technical Specification 6.4.J and Fire Protection Program procedure 3.5.1 which
requires that fire protection systems shall not be used for
reasons
other
than
the
prevention,
detection
or
extinguishing of fires, or to perform scheduled testing or
training un.less specifically approved in writing by the
loss prevention coordinator. (88-07).
2.
Conclusion
Category:
2
3.
Board Recommendation
Licensee management attention and
involvement
should be
increased to prevent the relatively few but significant
deficiencies noted above.
F.
- . :**~:-*,::.*:* -,-- 0.-*--*-*-.,*;****
I
-
-***:* **~-.--..-...**: r
- ' .. -
..
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- ,
-~--
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- *
.
J **
,,
,*
- ,,
-.*,_;
,
- * --:.~ _;,; -*~**. **
- .
- '
., *** ,'*', *.\\.<. ~7r" *
--
27
1.
Analysis
During the assessment period, inspections were performed by the
resident and
regional
staffs in the area of emergency
preparedness.
These inspections included the annual emergency
preparedness exercises in October 1986 and October 1987, and a
routine emergency preparedness inspection in May 1987.
The routine inspection disclosed that the licensee had an
adequate emergency preparedness program for emergency detection
and classification, protective action decision-making, notifica-
tions and communications, changes to the emergency preparedness
program, dose calculation and assessment, licensee audits,
coordination with offsite agencies, and emergency facilities and
equipment.
Emergency preparedness and implementation of the
Emergency Plan was adequatel~ demonstrated during the feedwa~er
pipe rupture event of December 10, 1986.
One violation and four exercise weaknesses were noted during the
three inspections.
The one violation identified during* the
routine inspection was for failure to provide training to
various members of the emergency organization in accordance with
the Emergency Plan.
In reviewing the training for approximately
20 individuals, it was determined that eight personnel. had not
received the initial training or bi-annual emergency response
retraining required by the Emergency Plan.
The exercise weaknesses addressed a number of different aspe~ts
of the emergency response program.
The October 1986 exercise
findings noted a lack of contingency messages for the scenario.
This resulted in confusion and
inconsistencies for both
controllers and
players as
11 0n
the spot" freeplay was
interjected that would
have
impacted other players and
contra 11 ers who were unaware of the new events.
Another
weakness* concerned
the
making
of
protective
action
reconvnendations
(PAR)
by
the Recovery Manager
when
the
responsibility for the same had not been assumed from the
Station Emergency
Manager.
This
responsibility was
ndt
specifically controlled to ensure that only one coordinated PAR
was provided by the licensee to offsite authorities. The other
exercise weakness
from
the 1986
exercise addressed the
untimeliness of communication of .core assessment and plant
status data to the Local Emergency Operations Facility and the
Corporate Emergency Response Center.
In one case, the data
available was more than one hour old. Timely data is needed by
the offsite response facilities to provide effective support to
the onsite emergency facilities.
The 1987 exercise demonstrated that corrective action for the
latter two weaknesses had been taken but minor problems with
message preparation in the scenario were noted.
Another
- ******-..
.
. ..
.
.
- ,, . *""
... *.t;"*.-:*--r;**.-*
. *.
28
exercise weakness was noted regarding the failure to coordinate
press releases with the State spokesperson.
On one occasion it
was noted that the State spokesperson was summoned to the
microphone in the 1 oca 1 Emergency News Center with no prior
knowledge of what the licensee's statements would be.
This
could result in the State spokesperson needing to address an
issue withou: sufficient time to consult with required parties.
The following violation was identified:
Severity Level IV violation for failure to provide training
to members of the emergency organization in accordance with
the Emergency Plan (87-12).
2. * Conclusion
Category:
2
3.
Board Recommendation
None
G.
Safeguards (Security/Material Control and Accountability)
--
- ,,-*.--*~-:--***--*.**:.**w-*;,":** - ~
1.
Analysis
Security
During the inspection period, routine inspections were performed
by the resident and regional inspection staffs.
The
licensee's performance in this area has improved in
comparison with the previous SALP rating period.
The two
violations identified were relatively minor and
are
not
considered to reflect a deficient security program.
The 1 i cen see has deve 1 oped and imp 1 emented a security audit
capability covering all aspects of the security program.
Included in the audit are.alarm exercises, safety implication
assessment, alarm station duties, and event management.
The
licensee's annual
audit (#87-05) reflected an aggressive
approach and resulted in findings being addressed at the
appropriate corporate and site management levels.
The security organization's performance during the December 9,
1986 pipe rupture event was noteworthy.
The security shift
faci 1 itated the response of off site emergency personnel and
equipment, and was instrumental in the initial offsite emergency
reactionary brigade to the accident.
An
11 report
was generated by the security force in an attempt to critique
- :
j
_::_
_
c'_~- _ * .
,
r .*: * .. *
.
-*-~. ::" . ":'
'
- , -..
- ..... ------
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I
--
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2.
29
--its commendable performance and many of its recommendations*have
been implemented.
Corporate and site management's support continue to have a
positive
impact.
Daily
close
superv1s1on,
simplified
procedures, realistic training and a continued sensitivity to
requirements
are
the
characteri sties
of
the
security
organization.
Training and qualification effectiveness were evident as demon-
strated during this evaluation period when backshift security
personnel observed that a 1 icensed operator may not have been
fit for duty when he was entering the station. This information
was reported to the operator's supervisor and appropriate action
was taken.
Materials Control and Accountability (MC&A)
During the assessment period, one regional based inspection was
conducted in the area of MC&A at the Surry site. The inspector
determined that the licensee had established, maintained and
followed written MC&A procedures for controlling and accounting
. for new and spent fue 1 receiving, storing, shipment, inventory
burn-up
calculations,
recordk.eeping
and
reporting.
The
licensee, however, was not aware of the requirement to account
for a 11 non-fue 1 ( i ncore detectors) Special Nucl ea*r Materials
(SNM) as required by the regulations.
A new procedure was
written to ensure that all SNM (fuel a*nd non-fuel) undergo a
semi-annua 1 phys i ca 1 inventory.
Vi o 1 ati on ( c) was issued for
failure to establish and maintain an adequate MC&A procedure
which resulted in a failure to conduct a physical inventory of
all non-fuel on inventory.
The implementation of the new
inventory procedure has not yet been examined by an on-site
inspection.
The following safeguards violations were identified:
a.
Severity Level IV for failure to escort a visitor (86-30).
b.
Severity Level. IV for failure to install an adequate
locking device (87-?3).
c.
Severity Level IV for failure to establish and maintain an
adequate material control and accountability procedure
(87-10).
Conclusion
Category:
2
3.
Board Recommendation
None
30
H.
Outages
1.
Analysis
During the assessment period.
operations were
performed
by
inspections staffs.
inspections of plant outage
the resident and
regional
Unit 2 conducted a refueling outage from October 4, 1986 to
December 2, 1986.
The refueling activities on the unit were
adequately preplanned with realistic assignment of priorities
and contra l of activities.
Refueling procedures were adequate
to accomplish the associated task; however, violation (b) under
the Operations functional area indicated a lack of ap~ropriate
engineering review/documentation for deviation of a maintenance
procedure involved in the rework of a residual heat removal
pump.
Adequate levels of management attention were observed
during refueling; however, violation (a) listed below did
identify a weakness in management overview of the inservice
inspection effort.
Refueling crew staffing and staff training
were observed to be adequate.
Post refue 1 i ng startup test
records were adequate and showed that the testing was conducted
in an acceptable manner.
During the months of December 1986, and January through March,
1987, both units experienced outages due to pipe degradation in
the condensate and feed systems.
These outages were not
scheduled and received additional attention from outside parties
due to the sensitivity of the failure of the piping.
However,
with minimal preplanning, the licensee put in place an effective
outage organization which accomplished the piping inspection and
replacement tasks with minimal delay.
Management attention to
this effort was excellent.
In addition to performing the
physical work,
the licensee evaluated the piping failure
mechanism promptly and provided this information to*the NRC and
the industry as quickly as information was available.
The
licensee also provided a complete report on the event entitled
"Surry Unit 2 Reactor Trip and Feedwater Pipe failure Report".
This report discussed aspects of the event as wel 1 as the
recovery actions tak.en for unit(s) restart, and was presented in
meetings in six different locations in the country to provide
information relative to the failure mechanism
to other
utilities.
Corporate management was involved in site activity
and recovery actions, and decision making was at a level that
ensured adequate management review.
Regional inspectors reviewed the Inservice lnspection/Inservice
Testing (ISI/IST) program
and
procedures,
observed work
activities, and
reviewed selected quality records.
The
31
inspectors found that the ISI/IST program was procedurally well
deiineated.
Training,
qualification and certification of
IS!/IST personnel
has
contributed to good
adherence to
procedures, with only a minimum of personnel errors as evidenced
by violations (a) below and (c) of Section IV.I.
Records were
complete, well maintained, and available.
During this assessment period,
licensee management placed
additional emphasis on reducing the number of outstanding
maintenance backlog items.
During the two week outage in
December 1987 for Unit 2, over 400 outage work orders were
completed.
This work reduced the outstanding work order outage
list by 50 percent.
The licensee has also reduced the total
outstanding work order backlog.
During 1986 and 1987, this
backlog was reduced from approximately 5400 to approximately
2000.
.
During the last month of the assessment period, Unit 1 began a
refueling/maintenance outage.
The outage scope of work was
adequately planned; however, when the SALP period ended, the
licensee was having difficulty maintaining the schedule due in
part to jobs which had never been accomplished in past outages.
Management attention to work i,n progress was evident.
Daily
meetings were held to insure senior management was aware of all
aspects of the work in progress.
Schedules were revised on a
frequent basis to address slippage of work activities and to
redefine priorities based on identification* of new work and
material status.
Technical i terns were appropriately addressed
as they were identified, and engineering involvement was evident
in daily work items.
A QA Assessment inspection related to design control activities
was also performed during this assessment period.
This inspec-
tion reviewed various plant performance data pertaining to plant
events caused by design errors, station deviations reports based
on design control or configuration problems, field changes
issued for eight design packages, design change backlog,
temporary modification control, and construction trouble reports
issued during design change installation.
Addi_tionally, all
aspects of a design change package were reviewed.
These
activities were well controlled. The licensee's design control
program has improved significantly since the last assessment
period. Although several minor problems were identified, these
were caused by lack of attention to detail as opposed to
programmatic problems.
The following violation was identified:
Severity Level
IV violation for failure to provide
appropriate
inservice
inspection
drawings
for
the
--
32
examination of safety related welds on the pressurizer
(86-34).
2.
Conclusion
Category:
2
3.
Board Recommendation
None
I.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
During the assessment period, inspections were performed by the
resident and regional inspection staff in the areas of quality
programs and administrative controls affecting quality.
For the
purposes of this assessment, this functional area is defined as
the ability of the licensee to identify and correct their own
problems.
It encompasses all plant activities, al'l
plant
personnel, as well as those corporate functions and personnel
that provide service to the plant.
T~e plant ~nd corporate QA
staff have responsibility for verifying quality. The rating in
this area speci fi cal ly denotes results achieved by various
groups in the facility as well as th~ QA staff in verifying that
quality.
A QA Effectiveness inspection was conducted in March and April
1987.
This
inspection
reviewed
licensee self-identified
trending indicators and management actions when these trending
indicators were not meeting established goals.
The inspection
reviewed
operations
and
surveillance,
design
control,
maintenance and procurement, and quality assurance. Another QA
inspection was conducted in March and April
1988.
This
inspection
reviewed
operations,
maintenance
and
quality
assurance.
These inspection results are discussed in the
various sections of this report.
All QA auditors were adequately trained through a combination of
previous industry experience, on-the-job training, or both.* Few
auditors had technical degrees.
However, provisions have been
made to use technical experts on audit teams when required.
Many audits being performed are compliance oriented, although
the licensee is changing their auditing techniques to be more
performance oriented.
Based on reviewing audit schedules,
schedule- adherence, and auditor qualifications, the audit
program is being satisfactorily managed.
Reviewing followups to
audit findings identified a weakness in that full implementation
of c.orrect i ve action for some audit findings was not always
verified.
However, overall corrective actions for audit
'
.'f-** , *,,' ~--*- '~, .<
., ~.
. /
.r ... '
33
findings were being adequately followed up and proper management
attention resulted in appropriate corrective action resolution.
Procurement activities were generally satisfactory except for
issues identified and discussed in the maintenance area of this
report.
Additionally, a weakness was identified regarding a
lack of a feedback mechanism from receipt inspections to the
approved vendor list.
Neither corporate nor site QA*personnel
developed a system to track vendor performance, vendor reject
rate, and vendor deficiencies found during receipt inspections.
Consequently, action was not being taken to modify purchase
order requirements based on vendor performance.
A review was performed on all SALP sections in an attempt to
capture perceived strengths and weaknesses related to management
controls affecting quality.
The
following are some perceived strengths in management
controls affecting quality:
The licensee has demonstrated the ability to correct problems
relating to the thinning of the feedwater pipe identified
following the pipe rupture in December 1986.
The
fo 11 owing are some perceived weaknesses in management
controls affecting quality:
The 1 icensee has not demonstrated the abi 1 ity to correct
recurring problems related to; lack of attention to detail
regarding operator errors during routine operation, poor timely
resolution related to the boric acid heat trace system
deficiencies, and programmatic deficie.ncies including multiple
examples of procedural noncompliance relating the radiological
control program.
The following violations were identified:
a.
Severity Level IV violation for failure to follow main-
tenance procedures involving eight examples dealing with
site work orders (87-06).
b.
Severity Level IV violation for not adequately implementing
the emergency plan (88-11).
c.
Severity Level IV violation for having inoperable control
rod banks while the unit remained critical (88-11).
d.
Severity Level V violation for failure to follow document
control procedures (87-30).
--
- 2.
Conclusion
Category:
2
3.
Board Recommendation
None
J.
Licensing Activities
1.
Analysis
34
During the SALP period, the licensee continued to show an active
i nvo 1 vement of. management in assuring the qua 1 i ty of submi tta 1 s
for licensing actions.
The management is alert to issues
involving plant safety and public health and safety.
The
management takes an active part in resolution of any problems in
the normal licensing reviews.
Decision making is consistently
at a level that ensures adequate management review.
The
licensee's
submittals
in
most
cases
are
timely* and
well-prepared. Most applications submitted by the licensee
during this SALP period were wel 1 written with the safety
analysis fully supporting the requested action.
Also, the
corporate management is frequently involved in site activities.
There were some i so 1 ated cases where addi ti ona 1 management
involvement was
desirable.
For
example,
the licensee's
submittal for the Technical Specification change related to main
steam trip valve stroke time was not submitted in a timely
manner to avoid unnecessary p 1 ant shutdown.
However,
the
management response to the problem was excellent after the staff
highlighted the situation.
The licensee's request for an
administrative change to the NA-1&2 and Surry TS regarding the
licensee's corporate reogranization (April 1, 1988) was not
submitted in a timely manner even though the NRC was advised of
the scheduled change.
Overall,
the
licensee's management
has
continued to be
consis.tently involved in licensing activities and has demon-
strated excellent control in a number of situations, including
the main feedwater pipe* rupture accident at Unit. 2.
The licensee demonstrates clear understanding of the technical
issues involved in licensing activities.
The
licensee's
evaluations for no significant hazards considerations are
thorough and clear in most cases. The licensee keeps abreast of
industry approaches to the resolution of general plant ~afety
issues. Management participates in many group~ representing the
nuclear industry.
The licensee takes a conservative approach
when there is an
issue which may *have potential safety
significance for plant safety. For example, the responsiveness
..
35
in resolving technical issues was demonstrated by a design
modification for the inside containment recirculatior. spray
system to faci 1 i tate fl ow testing of the pumps as req~i red by
the ASME Code.
The licensee was very responsive to the staff's
concern that these pumps should be flow tested.
Also, the.
response to the feedwater line break in Unit 2 was exemplary.
The licensee evaluated the cause of the accident ar:d took
appropriate corrective actions in.an expeditious manner.
The licensee has been very responsive to NRC's initiatives in
almost all cases.
VEPCO maintains a system which tracks the
commitments for responding to NRC' s requests for information.
Commitments generally are met unless adequate justification is
provided in advance and agreed upon by the staff for extension.
The licensee resolves technical issues in a timely manner and
has cooperated in providing the resources when requested by the
staff on a voluntary basis.
For example, the licensee provided
support during several visits to the Surry site by NRC staff and
the contractors in efforts related to NUREG-1150 studies.
In
addition,
the
licensee supported the efforts related to
risk-based performance indicators and other studies.
There was one instance where the licensee was not ful Ty
responsive to the staff's request:
This relates to the
Technical Specification change for Inservice Inspection and
Testing.
The licensee's response to the staff's request was
considerably late.
The Project Manager discussed this problem
with the licensee's staff and has been assured that problems in
this area will be corrected in the future.
The NRR Project Manager attended several Enforcement Conferences
in Region II offices.
In most conferences the licensee was
well-prepared to discuss the issues and they were well received
by the staff. The staff has identified several instances where
the licensee's 50.59 reviews were not adequately performed or
documented.
The 1 icensee has made some changes in the 50.59
review process and it is expected that licensee's performance in
this area will improve.
The licensee continues to maintain adequate staff for licensing
activities. The licensing group exhibits a high degree profes-
sionalism and cooperation with the staff.
The licensing staff
is intimately familiar with the NRC regulatory framework, and
also has good knowledge of plant operation.
The licensee main-
tains a staff at the site which interfaces with the licensing
staff at the headquarters in licensing activities.
The person
in charge for the staff at the site has in-depth knowledge of
plant operation and has been very helpful in assisting the PM
during plant visits and for providing quick information during
Also, the licensee's operations staff is very
cooperative with the NRC staff.
.
.*
2.
Conclusion
Category:
1
3. . Boa rd Recommendation
36
Although the Board assigned a category 1 rating in the
functional area of licensing, it should be noted that there were
several instances, as discussed in the evaluation, where the
responsiveness of the licensee's submittals fell short of the
category 1 criteria. The licensee should strive for improvement
in this area during the next rating period to e 1 i mi nate
deficiencies of this type.
No change in NRC staff resources is
recommended.
K.
Training and Qualification Effectiveness
1.
Analysis
During this inspection period, a training inspection was
performed by* regional inspection staff.
The review of the licensee's training program involved licensed
operator training, licensed operator requalification training,
non-licensed operator training, exam bank security, simulator
procedure review, emergency pre pa redness, security force, and
ISI/IST program (see section IV.H).
The requalification training program, based on record reviews
and interviews, is well developed and implemented. Staffing was*
thin in the past but appears to be adequate now.
Management is
actively involved in the program evolution.
The program is
fully accredited by INPO with no outstanding items.
The licensee has corporate staff dedicated to the evaluation of
the
training
program.
The
program
includes evaluation
i ndi ca tors and criteria for determining the adequacy of each
training area.
A schedule is maintained that evaluates each
area on a monthly, quarterly, semi-annual, or annual basis.
A
discrepancy report is written when an indicator does not mee~
its acceptable level.
The* discrepancy report requires the
person responsible for the indicator to sign and attach an
action plan if necessary. Management is then required to review
the discrepancy report and sign off. The inspectors found this
audit capacity of the training program to be very good.
One
violation was identified (section IV.F) in the emergency
preparedness area.
Operator training in BOP areas also has changed as necessary to
address identified problems.
For example, additional simulator
training in feedwater controls during startups and shutdowns has
-
- -****.--*
-
~,-*,.* *****
- ....
.I
- .
- ::~~ .. -.,
.,_, .......
.
--
37
been implemented* due to experienced feedwater control problems.
The frequency of these problems has reduced.
The check operator program continues to provide good feedback to
the Operations training group.
The check operator has been
observed by
inspectors to be monitoring
actual
operator
responses to transients~ The check operator feedback appears to
be one of the-reasons that operator response to emergencies has
been good.
Two sets of replacement operator license examinations were
administered during this SALP period.
The operating and written
examinations administered in February 1987 resulted in 3 of 3
Senior Reactor Operator (SRO) candidates and 2 of 2 Reactor
Operator (RO) candidates passing.
The operating and written
examinations administered in March 1988 resulted in 2 of 2 SRO
candidates and 2 of 2 RO candidates passing. The requalifica-
tion program was not evaluated during this SALP period.
The replacement examination passing rate was 100~~. which is
considerably higher than industry average.
2.
Conclusion
Category:
1
3.
Board Recommendation
None
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
Unit 1 began the assessment period at power.
The unit experienced
one forced maintenance outage in September 1986, prior to shutting
down for extensive feedwater and condensate system piping repairs in
December 1986.
The unit returned to power operation in late
February 1987, and operated at power until the middle of May 1987,
when the unit was tripped from full power due to failure of a loop
isolation valve stem.
From the middle of May 1987, until the unit
entered its scheduled refueling/maintenance outage in April 1988,
Unit 1 experienced nine unscheduled outages lasting an average of
seven days each. At the end of the evaluation period, Unit 1 was in
day 21 of a scheduled 62 day outage.
Unit 2 began the assessment period at power.
The unit operated at
power until early October 1986, when it entered a scheduled refueling
outage.
The unit comp 1 eted the refue 1 i ng outage and returned to
power operation in early December 1986. Approximately one week after
returning to power operation, Unit 2 experienced an automatic reactor
.,
,
_>
',.'
- *** > ~-' :*,. *
i-.*---.-~-*****,-,*.-,*-~*-******:***--.,-,--
38
trip followed by a main feedwater pump suction line rupture.
The
unit was brought to cold shutdown and extensive repairs to the feed-
water and condensate piping systems were accomp 1 i shed.
The unit
returned to power operation in late March.1987, *and with the
exception of one forced outage in early April to balance the main
turbine, Unit 2 operated at power (247 days) until the unit was shut
down in December 1987, for a scheduled snubber inspection/maintenance
outage.
The unit returned to power operation in late December 1987,
and operated at power for the remainder of the evaluation period with
the exception of one forced outage in March 1987, to repair a vital
bus power supply.
B.
Inspection Activities
During the assessment period, routine inspections were performed at
the Surry facility by the resident and regional inspection staffs.
From September to December 1986, 15 inspections were conducted
including the special inspection associated with the Unit 2 pipe
break event.
During 1987, 35 inspections were conducted including a
special
inspection associated with
10
CFR
50,
Appendix
R
requirements.
From January through April 1988, 13 i nsp_ect ions were
conducted including a special team inspection for balance of plant
maintenance and a special inspection associated with the incore
detector withdrawal event in March 1988.
C.
Investigation and Allegation Review
No significant investigations or allegations occurred during this
SALP period.
D.
Escalated Enforcement Actions
1.
Civil Penalties
a.
A severity level III violation for failure to implement
fire protection requirements of 10 CFR Appendix R with no
civil pena 1 ty.
b.
A severity level III violation for failure to maintain and
verify operability of heat trace ci~cuitry for boric acid
flow path ($50,000 civil penalty).
c.
A severity level III violation for failure to adequately
evaluate the radiation hazards, having adequate procedures,
and following approved procedures while working on a stuck
incore detector ($100,000 civil penalty).
2.
Orders
None
"'~- ................... '.
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... *:," .
. .**
39
E.
Licensee Conferences Held During Appraisal Period
Management Meeting held on April 13, 1987, to discuss implementation
of the Fire Protection Issues.
Enforcement confer*ence held on May 19, 1987, to discuss the failure
to meet the requirements of 10 CFR 50, Appendix R, with respect to
the independence of cabling associated with alternative safe shutdown
equipment.
Enforcement conference held on August 26,
1987, to discuss a
violation of containment integrity.
Enforcement conference held on
September 24,
1987,
to discuss
deleting the turbine valve freedom testing without performing a 10
CFR 50.59 safety evaluation and failure to perform a Technical
Specification required surveillance.
Management Meeting held on January 13, 1988, to discuss circulating
and service water repairs.
Enforcement conference held on March 28, 1988, to discuss inoperable
heat tracing on certain safety-related boric acid lines.
Enforcement conference. he 1 d on Apri 1 21, 1988, to discuss the
findings of the investigative task force formed to review the incore
detector maintenance radiation exposure event of March 3, 1988, and
subsequent corrective actions.
F.
Confirmation of Action Letters
No Confirmation of Action letters were issued in this period.
G.
Discretionary Enforcement
October 13, 1987, Unit 1 main steam line trip valves
March 30, 1988, Unit 1 nuclear service water system repairs
April 1, 1988, both units, organizational changes
Above dates refer to NRC letter issuances.
H.
Review of licensee Event Reports
During the assessment period there were 79 LERs reported.
The
distribution of these events _by cause, as determined by the ~RC
staff, was as follow:
..... -.-r:.,- ... * ...
- ,"., l*
-
- .**.:*
- *
r-
,. *- ~***
I.
--
I L . . . . ---. *-. . . *----- .. ". --
40
Component Failure
Design
Construction, Fabrication, or
Installation
Personnel
Operating Activity
Maintenance Activity
Test/Calibration Activity
Other
Out of Calibration
Other
Total
Licensing Activity
1.
NRR/Licensee Meetings
SALP Meeting
Management Briefing Meeting
Unit 1
17
13
4
10
6
5
1
3
2
--
61
ISI/IST Program and Recirculation Spray Pumps
Steam Gene~ator Tube Rupture Analysis
!ST Program Review Meeting
2.
Commission Briefings
Unit 2 Feedwater Line Rupture
3.
Schedular Extension Granted
None
4.
Reliefs Granted
Reactor Vessel Nozzle Surface Examination
Relief from first 10-year inspection interval
Relief from inservice testing requirements
Relief for component cooling water and
. *... . ...... , ... ' . , .... ~.
- *
- ~ ' .. --: *- ... --._
Unit 2
6
1
1
4
l
3
0
2 a
18
Total
23
14 s
14
7
8
1
5
2
79
Dates
3/12/87
4/7/87
11/9/87
12/23/87
3/29/88
2/25/87
10/29/86
4/15/87
1/6/88
2/25/88
5.
41
Recirculation spray heat exchangers
Exemptions Granted
Appendi x-R, 10 CFR 50
6.
License Amendments Issued
Titles
Amendment Nos.
Organizational changes
Deletes inservice inspection
requirements for reactor vessel
closure head cladding
Extension of OL to 40 years
Revises frequency of audit of
security program
Transfer of canal door over
spent fuel pool
MSIV closing time TS
FQ(Z) and accumulator water
volume TS affected by revised
LOCA analysis
New improved fuel, control rod
insertion limit and fully
withdrawn position
TS changes in Section 3.7 and
4.1 which included 83-28
item 4.3 and WCAP 10271 changes
smoke detector Tech. Spec.
Organizational changes
109
110
111
112
113
114
115
116
117
118
119
7.
Emergency Technical Specification Issues
None
8.
Orders Issued
None
109
110
111
112
113
114
115
116
117
118
119
2/25/88
Dates
9/9/86
11/21/86
12/31/86
2/3/87
3/10/87
11/17 /87
12/10/87
1/6/88
2/17/88
3/15/88
4/28/88
', --... --*-. .---:-*.-- . *-
~ .. '
. .
. *_' '*
J.
42
Enforcement Activity
UNIT SUMMARY
FUNCTIONAL
NO. OF DEVIATIONS AND VIOLATIONS IN EACH
AREA
SEVERITY LEVEL (SL)
D
V
IV
III II
I
UNIT NO. 1/2 1/2
1/2 1/2 1/2
1/2
Plant Operations
1/1
5/5
t:.
Radiological Controls
3/3
5/5
t:.
Maintenance
1/1
0/1
Surveillance
1/1"'
Fire Protection
1/1 1/1
1/1
Security
3/3
Outages
1/1"'
Quality Programs and
Administrative Controls
1/1
1/3$
Affecting Qual~ty
Licensing Activities
Trainin
TOTAL
1/1
5/5
18/21 3/3
Notes t:.
88-04 and 88-10; two Severity level III violations with
civil penalties issued after SALP period ended and are
counted here.
"'
$
86-36 (Severity level IV, Unit 2 only, outages) and 87-21
(~L V, surveillance) both are under NRC review, not counted
here.
88-11, two Severity level IV violations , Unit 2 only, are
counted here, but the report was issued after the SALP
period.
K.
a.
Unit 1 on September 19, 1986, from 20: power.
Event was due to
indication of second dropped control rod requiring manual reactor trip in accordance with procedure.
b.
Unit 2 on December 9, 1986, from 10~ power.
Event was due to
closure of C steam generator main steam trip valve resulting in
steam generator Clow low level trip signal.
c.
Unit 2 on March 16, 1987, from 0% power.
Event was due to
personne 1 error 1 n performance of a periodic test during
preparation for startup.
~ ,. ..
- *:
'
.
.
'
'
.*
. -.
. -- ._ .. ,*-:-;*
'** -.. _.--** .
--
43
d.
Unit 2 on April 4, 1987, from 11~~ power.
Event was due to
generator anti-motoring turbine trip due to governor valve
leakage resulting in turbine trip/reactor* trip.
e.
Unit 1 on May 16, 1987, from 100~~ power.
Event was due to
partial loss of flow in A reactor coolant loop due to failure of
A hot leg loop stop valve allowing valve to partially shut
blocking loop flow and resulting in low flow trip.
f.
Unit 1 on August 7, 1987, from 100~~ power.
Event was due to
failure of* the cooling capability of the 18 main transformer
resulting in operator action to manually trip the unit.
g.
Unit 1 on September 20, 1987, from 100% power.
Event was due to
trip of B reactor coolant pump breaker due to a phase to ground
fault in the B phase at the electrical connection on the pump
resulting in B reactor coolant pump breaker open unit trip.
h.
Unit 1 on February 16, 1988, from 100!'~ power.
Event was due to
personnel error during performance of surve i 11 ance testing of
the reactor protection logic.
i.
Unit 2 on March 27, 1988, from 100~~ power.
Event was due to
failure of power supply to vital bus III which resulted in loss
of cooling flow to A Reactor Coolant Pump and required manuil
reactor trip in accordance with procedure.
L.
Effluent Summary for Surry
Activity Released (curies)
1.
Gaseous Effluents
Fission & Activation
Products
Iodines and Particulates
2.
Li gui d Effluents
Fission & Activation
Products
.. -~-* -* ~-- --- -~--.~-.-* -.
1985
2.07E+3
2.67E-2
8.52EO
1.09E+3
1986
1987
1. 99E+3
3.08E+2
2.09E-2
2.09E-2
8.77EO
5.17EO
8.73E+2
8.15E+2
. '
~ ....... \\
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.. __ .* ..
. . **:
.* .
. . ,""
-
List of Acronyms
CRO
cw
HPES
ISC
IEB
IEN
IFI
LER
MOVAT
MWO
NOOPS
NODS
NPROS
NRC
NSE
O&M
OMC
OP
QAOIN
QAOPS
QAOS
QCAR
QMT
QS
RS
--~ ~-~*: .... ' ,. ___ .. --* -
ENCLOSURE 3
'
I
Balance of Plant
Control Room Operator
Commitment Tracking System
Deviation Report
Executive Director for Operations
Human Performance Evaluation System
Health Physics
Instrumentation and Controls
Inspection and Enforcement Bulletin
Inspection and Enforcement Notice
Inspector Followup Item
Institute of Nu~lear Power Operations
Licensee Event Report
Motor Opeta-ted Valve Analysis and Testing
Maintenance Work Order
Nuclear Operations Department Policy Statement
Nuclear Operations Department Standard
Nuclear Plant Reliability Data System
Nuclear Regulatory Commission
Nuclear Safety Engineering
Operational Experience Review
On The Job Training
Operation and Maintenance
Operations Maintenance Coordinator
Operating Procedure
Operational Performance Assessment
Preventive Maintenance
Plan Of The Day
Power Operated Relief Valve
Performance Test
Quality Assurance
Quality Assurance Department Instruction Nuclear
Quality Assurance Organization Policy Statement
Quality Assurance Organization Standard
Quality Control
Quality Control Activity Report
Quality Maintenance Team
Quench Spray
Reactor Coolant Pump
Recirculation Spray
Radiation Work Permit
Systematic Assessment of Licensee Performance
... , -.--.-** ..... .
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.*.
-
. -
~- .
. -'.,. . .
.
~-
.. ,. ..
,. .
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ss
TS
WGOT
. . .
,. - . -**- - -:~,.-. -
( .. ,-..
2
Senior Reactor Operator
Sh1f\\- Supervisor
Technical Specification
Unresolved Item
.
Waste Gas Decay Tank
Work Order
Work Request
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