ML18152A023
| ML18152A023 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/22/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A024 | List: |
| References | |
| 50-280-89-16, 50-281-89-16, CAL, NUDOCS 8910110225 | |
| Download: ML18152A023 (36) | |
See also: IR 05000280/1989016
Text
i*,'
ff9 tD I \\0 22-~
ENCLOSURE
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-280, 281/89-16
VIRGINIA ELECTRIC AND POWER COMPANY
SURRY UNITS 1 AND 2
MAY 1, 1988 THROUGH JUNE 30, 1989
TABLE OF CONTENTS
I. INTRODUCTION ............................ ~ ...... * .............. : ... l
A..
Licensee Activities ........................................ 1
B.
Direct Inspection and Review Activities .................... 3
I I. SUMMARY OF RESULTS .............................................. 4
I I I . C RITER I A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . . . . . 7
IV. PERFORMANCE ANALYSIS ........... : ................................. 8
A.
Plant Operations ........................................... 8
B.
Radiological Controls ..................................... 12 *
C. -
Mai ntenance/Survei 11 ance .................................. 15
D.
Emergency Preparedness .................................... 20
E .
Sec u ri ty ........................................ * ........... 21
F.
Engineering/Technical Support ............................. 23
G.
Safety Assessment/Quality Verificition .................... 27
V. SUPPORTING DATA AND SUMMARIES .................................. 30
A.
Investigation Review ...................................... 30
B.
Escalated Enforcement Action .............................. 30
C*.
Management Conferences .................................... 32
D.
Confirmation of Action Letters ........................*... 33
E.
Review of Licensee Event Reports .......................... 33
F.
Licensing Activities ...................................... 33
.G.
Enforcement Activity ............................... * ....... 34
H.
Reactor Trips .................. ; .......................... 34
I. INTRODUCTION
The Systematic Assessment of Licensee Performance ( SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance on the basis of this
information.
The SALP program is supp 1 ementa 1 to norma 1 regulatory
process~s used to ensure compliance with NRC* rules and regulations. It is
intended to be sufficiently diagnostic to provide a rational basis for
allocation of NRC resources and to provide meaningful feedback to the
1 i censee
I s management regarding the NRC assessment of their facility I s
performance in each functibnal afea.
An
NRC SALP Board, composed of the staff members listed below, met on
August 30, 1989, to review the observations and data on performance and to
assess
licensee performance
in
accordance with Chapter
11Systemat i c Assessment of Licensee Performance.
11
The guidance and
evaluation criteria are summarized in Section III of this report.
The
Board
1 s findings and recommendations were forwarded to the NRC Regional
Administrator for approval and issuance.
This report is the NRC 1 s assessment of the licensee 1 s safety performance
at Surry for the period May 1, 1988, through June 30, 1989.
The SALP Board for Surry Units 1 and 2 was composed of:
L. Reyes, Director, Division of Reactor Projects (DRP), Region II
(RII) (Chairman)
E. Merschoff, Deputy Director, Division of Reactor Safety (DRS), RI!
J. Stohr, Director, Division of Radiation Safety and Safeguards
(DRSS), RI!
M. Sinkule, Chief, Reactor Projects Branch 2, DRP, RI!
H. Berkow, Director, Project Directorate II-2, Office of Nuclear
Reactor Regulation (NRR)
W. Holland, Senior Resident Inspector, Surry, *DRP, RI!
Attendees at SALP Board Meeting:
B. Grimes, Acting Deputy Regional Administrator, RI!
P. Fredrickson, Chief, *project Section 2A, DRP, RI!
S. Shaeffer, Project Engineer, Project Section 2A, DRP, RI!
G. Wiseman, Reactor Engineer, Technical Support Staff, DRP, RI!
W. Scott, Senior Operations Engineer, Performance and Quality
Evaluation Branch, NRR
D. Roberts, Intern, NRR
A.
Licensee Activities
Unit 1 began the assessment period in day 22 of. a scheduled refueling/
~aintenance outage.
The outage extended much longer than scheduled, and
2
the unit did not return to powef operation until the middle of duly 1988.
With the exception of one automatic reactor trip in A~gust 1988, the unit*
operated at power until the middle of September 1988, when ii was shut
down due to concerns about the operabi 1 i ty of the emergency di ese 1
generators. The outage lasted from September 14, 1988, thtough the end of*
the assessment period. However, Unit 1 was preparing to return to power
operation when the assessment period ended and was operating at power on
July 7, 1989.
Unit 2 began the assessment period at power.
The unit experienced an
automatic reactor trip in May 1988, and remained shut down for repairs for
the next five weeks, returning to ~ower operation in the latter part of
June'. 1988.
The unit operated at power until September 10, 1988 when,
- during shutdown operations for a scheduled refue 1 i ng/maJ ntenance outage,
it tripped from approximately four percent power.
The refueling outag~
lasted longer than originally scheduled due to the parallel outage on Unit
1 and identification of significant safety issues which had to be resolved
for both units prior to restart. Uni£ 2 remained in cold shutdown at the
end of the assessment period while corrective actions that were required
prior to unit restart were being completed.
As indicated by the duration of the unit outages, significant safety
problems were identified whic;h required extensive corrective actions.
Some of the prob 1 ems re 1 ated to a 1 ack of procedura 1 guidance in the
performance
of operations, radiological controls, maintenance,, and
testing; lack of cleanliness affecting safety-r-elated systems; inadequate
identification and root cause resolution of significant conditions adverse
to quality; and a lack of proper planning and requiring accountability for
lower level supervision and craft in the performance of daily work.
After
significant safety issues associated with the original design of plant
systems became known, the *licensee augmented the station staff with
addi ti ona 1 management and engineering resources during the fa 11 of 1988.
Additional management changes and reorganizations continued to be made at
both the station and in the corporate offices well into the assessment
period.
Management and/or organization changes instituted by the licensee during
the assessment period included:
September 1988
November 1988
December 1988
January 1989
February 1989
New Vite President-Nuclear Operations
New Station Manager - Surry Plant
New Health Physics Superintendent - Surry Plant
Reorganization of the engineering organization.
New
Superintendent of Engineering position created and
assigned to both Surry and North Anna
New
Assistant
Station
Manager-Operations
and
Maint~nance - Surry Plant
B.
February 1989
March 1989
April 1989
June 1989
3
New Operations Superintendent - Surry Plant
Reorganization of the corporate org~nization to
specifically. focus
appro~riate
resources
on
the
nuclear program.
Changes included creation of a
Senior Vice
President-Nuclear position,* a
Vice
President-Nuclear Services position, a Vice President-
Nuclear Engineering pos*ition, and an Assistant Vice
President-Nuclear Operations.
These changes also
affected se~eral management positions in the corporate
offices including selection of a new Quality .Assurance
Manager.
New President and Chief Executive Officer
New Vice President-Nuclear Services (position created
in March 1989 restructure.)
Direct Inspection and Review Activiiies
During the assessment period, routine inspections were performed at the
- Surry facility by the resident and regional staffs.
From May* through
.December 1988,
36 inspections were conducted including an Augmented
Inspection Team (AIT) inspection of the reactor cavity seal leakage event
on Unit 1, a Safety System Functional Inspection (SSFI) of the service
water system in September 1988, and special inspections associated with
the
increased radiological
protection area monitoring,
which
was
instituted due to problems identified during the last assessment period.
From January through June 1989, 19 inspections were conducted.
Several of
these inspections were special inspections associated. with technical
problem areas i_dentified *during the licensee's Operational Readiness
Assurance Program (ORAP), which was implemented in January 1989.
Seven
management meetings,
fo~r technical meetings' and three Enforcement
Conferences were also conducted.
The-following is a listing of specific special inspections:
June 20-24, 1988; inspection to review environmental qualification
and Generic Letter 83-28 implementation.
September 1-3, 1988, AIT inspection to review the reactor cavity seal
leakage event.
September 12-16, 26-30, and November 14-18, 1988; SSFI inspection of
the service water and recirculation spray systems.
October 3-7 and 9-14, 1988; inspection to review reactor cavity seal
modifications and corrective actions .
4
.
.
January 23-27 a.nd February 1-2, 1989; inspections to followup on
mo~or operated valve (MOV) and electrical termination issues.
March 27 - April 4, 1989; inspection on motor operated valve (MOV)
issues.
April 10-14
and
May 10-12,
1989;
inspettion for fcillowup
on
electrical issues.
May 1-5, 1989; inspection for followup on SSFI issues.
June 5-9, 1989; in'spection for followup on MOV program implementa-
tion.
II.
SUMMARY OF RESULTS
Surry operated with mixed performance during the assessment period.
- Performance during the first half of the assessment period was poor
overall, but improved ~ignificantly toward the end of the period.
Major
weaknesses were identified in the areas of Plant Operations, Radiological
Controls, Maintenance/Surveillance, Emergency Preparedness and Safety
Assessment/Quality Verification.
A major strength was identiffed in the
Security area.
There was considerable activity in the Plant Operations area, though the
units operated for only a few months.
Operator inattention to detail, -
combined with inadequate management overview, contributed to several
events early in the assessment period.
Although management reaction was
evident for many of these events, root cause corrective action did not
occur until late in the assessment period.
A comprehensive ORAP was
developed for the restart of the units, but was initiated only after
several significant events necessitated some form of management action.
An additional problem, early in the period, was the tendency of operators
to tolerate equipment problems and work around them, rather than insisting
on repair or replacement.
Toward the end of the period, many of the
operations problems were in the process of being corrected.
Use of the
ORAP
provided effective means to identify,
evaluate and
correct
deficiencies.
Several plant management changes also contributed to
improvement late* in the assessment period; and, both management and the
operations staff d,sp l ayed an increased awareness toward attention to
detail, performance expectations and plant safety responsibilities.
The Radiological Controls functional area had not improved significantly
from the previous assessment period.
Early in the period,* an exposure-
related event occurred resulting in escalat~d enforcement action.
This
event and several other violations were directly attributed to inadequate
performance by the radiation protection staff.
During the last half of
the assessment period, the licensee began to more closely monitor work
activities for person-rem exposure and personnel contaminations.
The
s*
amount of contaminated area was reduced, but was still considered high.
Although the number of personnel contami.nations and the collective dose
were also high, a decreasing trend was noted in the number of personnel
contaminations toward the end of the assessment period.
Health physics
(HP) management changes and the development of a radiological engineering
capability resulted in improvement in this area.
Performance in the Mai ntenance/Survei 11 ance functi ona 1 area decreased
since the last assessment period.
A large maintenance back.log existed
during the period and
the preventive maintenance ( PM) program needed
improvement, as evidenced by several large-scale-equipment problems.
In
addition, the lack. of a formal check. valve maintenance program and an
ineffective maintenance root cause and trending program revea 1 ed a
deficiency in the abn ity to correct 1 ong-standi ng protil ems.
Procedures
were also a weakness in this functional area as was post-maintenance
testing. The deficient MDV maintenance program was an,example where all
of the specific: types of problems identified in this functional area
occurred, clearly indicating. a significant programmatic deficiency.
Toward the end of the assessment period, though, an aggressive MDV rework.
program was well underway.
Surveillances were generally performed in the
required time frame, but major problems involving emergency service water
pump
and control
room chiller surveillance testing revealed some
significant deficiencies.
A surveillance strength, though, was the
- maintenance predictive analysis feedback. inio the surveillance program.
Weaknesses were observed in the Emergency Preparedniss (EP) area during
the 1988 annual emergency exercise and during NRC inspections.
Event
classification and the augmentation timeltness of personnel it emergency
response facilities were significant problem areas.
A remedial drill
corrected the classification problem, but an overall improvement in
augmentation timeliness was *not demonstrated.
Some EP program strengths
were noted during the last EP inspection conducted during the period.
As
a result of the problem*s ,observed in the EP area, the 1 icensee has
categorized specific areas for followup analysis and corrective action as
appropriate to improve the overall EP program.
With respect to the Security fun ct i ona 1 area, the 1 i cen see provided
exce 11 ent support within the requirements of its approved p 1 an.
_One
-
weakness was the timeliness of security equipment repair; a problem which
revealed that better coordination of activities between security and
maintenance was needed.
The security force had minimal turnover and was
well trained and supervised.
Procedures were clearly written and training
was thorou-gh.
Early in the assessment period, within the Engineering/Technical Support
functional area, poor performance was demonstrated by the engineering
department, through its failure to correctly determine the design basis
adequacy of the service water system.
Also early in the period,
engineering MOV reviews were inadequate, contributing to the significant
6
MDV problem.* An engineering self-assessment capability was lacking during
the assessment period, as evidenced by a large backlog of engineering
problems and the inadequate safety assessment of several
is~ues.
Engineering Work Request (EWR) problems revealed a deficiency with
training of ~he engineering staff and also deficiencies in EWR procedure
quality.
Engineering support to the equipment qualification (EQ) and
non~destructive examination (NOE) program was good.
Engineering involve-
ment in the ORAP, in a~ MDV task team, and in the initiation of a Design
Basis Documentation program represented a significant engineering effort
later in the assessment period.
In addition, the formation of a systems
engineering group and a design engineering group on site provides the
potential for improvement.
Training, overall, continued to be a strong
-area, with licensed operator training being very effective.
Training
facilities and high quality instructors were also positive assets,
especially during the latter part of the period.
Within the Safety Assessment/Quality Verification functional area, .the
1 icensee failed to take appropriate corrective actions in numerous
instances such as the reactor cavity seal leak event, foreign material/
cleanliness problems, potential gas binding of safety-related pumps, a
degraded ventilation system, and a leaking safety-related pump enclosure.
Early in the assessment period, the license_e did not demonstrate an
adequate safety assessment capability, which contributed to several
events.
Root cause analysis was a 1 so i dent i fi ed as being ineffective.
Other problems identified in this functional area involved not tracking
regulatory commitments and the independent review group not meeting its
regulatory review responsibilities.
The above noted deficiencies occurred
primarily during th~ first part of the asiessment period. Toward the end
of the period, management sensitivity increased and corrective action
became more thorough, safety assessment improved and the 1 icensee al so
began to improve the root cause analysis effort.
With respect to
licensing activities, submittals were of good quality and timely.
Although the mctjor problem areas were not identified through the quality
assurance (QA) program, the QA organization began to improve its problem
identification capability late in the assessment period.
Overview
Functional Area
Plant Operations
(Operations/Fire Protection)
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical Support
(Engineering/Training/Outages)
Safety Assessment/
Quality Verification
(Quality Programs /Licensing)
NR - Not Rated
Rating Last
Period
2/2
2 Declining
2/2
2
2
NR/1/2
2/1
Rating This
Period
3 Improving
3 Improving
3
3
1
2
3 Improving
7
I I I. CRITERIA
Licensee performance is assessed in selected functional areas depending on
whether the facility is in the construction or operational phase.
Functional areas normally represent ar~as significant to nuclear safety
and the environment.
Some functional areas may not be assessed because of
little or no licensee activity*, or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The following eval*uation criteria were used, ~s applicable, to assess each
functional area:
1.
Assurance of quality, including management *involvement and control;
2.
Approach to the resolution of technical issues from a safety
standpoint;
3.
Responsiveness to NRC initiatives;
4.
Enforcement hi story;
5.
Operational and construction events (including response to, analysis
of, reporting of, and corrective actions for);
6.
Staffing (including management); and
7.
Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been
used as appropriate.
On the ba-sis of the NRC assessment, each functional area evaluated is
rated according to one of three performance categories.
The definitions
of these performance categories is as follows:
1.
2.
C~tegory 1:
LiGensee management attention and
involvement are
readily evident and place *emphasis on superior performance of nuclear
safety or safeguards activities, with the resulting performance
substantially exceeding regulatory requirements.
Licensee resourses
are ample and effectively used so that a high level of plant and
personnel performance is being achieved.
Reduced NRC attention may
be appropriate.
Category 2:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good.
The
licensee has attained a level of performance above that needed to
meet regulatory requirements.
Licensee resources are adequate and
reasonably allocated so that good plant and personnel performance is
being achieved. - NRC attention may be maintained at normal levels .
3.
8
Category 3:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not
- sufficient .. The 1*icensee 1 s performance does not sig~ifitantly exceed
that needed to meet minimal regulatory requirements.
Licensee
resources*. appear to be strained. or not effectively used.
NRC
attention should be increased above normal levels.
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 discernable
and th_e Board believes that c*ontinuation 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 and the licensee hftd not taken meaningful
steps to address this pattern.
IV.
PERFORMANCE ANALYSIS
A .
Plant Operations
1. *
Analysis
During the assessment period, inspections of plant operations were
performed by the resident and regi ona 1 staffs.
A 1 so, an AIT
inspection was conducted in September 1988, to review the event
associated with a. loss of reactor cavity water level during the
refueling of Unit 1 in May 1988. *
Performance in this functional area was mixed over the assessment
period.
Early
in
the
assessment period,
proper management
involvement and contro 1 at both the site and corporate l eve 1 s were
not evident.
Approach to resolution of technical issues from a
safety standpoint _was
inconsistent,
enforcement
hi story
was
indicative of programmatic problems, and operational events occurred
which ~ere poorly identified and marginally analyzed.
After
identification of several problem areas by both the NRC and the
licensee, a number of management changes were made at the station.
Duri*ng the assessment period, Unit 1 ciperated at power for two month~
and U~it 2 operated at power for three and one-half months with Unit -
1 experiencing one automatic reactor trip, and Unit 2 experiencing
The three automatic trips in a six
month period of operation was considered high. All trips were caused
by equipment failures.
Both units* were
shut down
in early
September 1988; Unit 1 for a forced maintenance outage, and Unit 2
9
for a scheduled refueling outage. Neither unit had returned to power
operations py the end of the assessment period.
The long outages
were not attributable to the operations department* s performance;
however, the long downtime appeaied to have a detrimental eff~ct on
operator* a 1 ertness and attention to detail.
Ex amp 1 es of ope.rater
iMattention to detail during the outage included improper operation
of containment isolation valves, problems with valve alignments,
tagging problems, and improper pump(s) operation.
Early in the assessment period, the lack of proper management
overview resulted in an inadequate evaluation of the May 1988, Unit 1
reactor cavity seal event. Operator actions to recover cavity level
during this event were improper.
These deficiencies resulted in a
Severity Level III violation with a Civil Penalty.
Inadequate.
management overview was a 1 so noted during the return to power of
Unit 1 in July 1988, following an extended refueling outage.
That
occurrence involved initial. direction by station senior management \\o
continue with a plant heatup while the unit was in a Limiting
Condition for Operation (LCD) which required that the unit return to
cold shutdown.
Management* changes. made during the. assessment period incl 1,.1ded the
Station Manager (November 1988), the Assistant Station Manager for
Operations and Maintenance (February 1989), and the Operations
Superintendent (February 1989).
These changes resulted in improved
sensitivity to safety and a positive attitude towards the proper
conduct of nuclear power plant operations. This new sensitivity and
attitude were observed during safety committee meetings, Unit 1
readiness restart assessment meetings and restart action item
closeout meetings during the latter part of the assessment period.
In addition to the man~gement changes discussed previously, another
factor affecting the operation of the station after both units were
shut down was the lack of clear direction and appropriate scheduling
of corrective actions.
These actions were necessary to resolve
significant issues that had been identified which affected several
safety systems.
After identification of incorrectly wired (wrong
train) safety-related valves in December 1988, the licensee proposed
a comprehensive ORAP which provided for _an appropriate direction of
the activities needed to be accomplished prior to either units*
restart.
One of the positive actions taken was the implementation of a plant
status .log for each unit.
At the end of *the assessment period, the
initial indications were that this configuration control program had
a positive impact on the safe operation of each unit.
Some examples
were that the control boards were not cluttered with different tags
and information notes and the plant status logs provided a single
location for information relating to work requests, operator aid
notes and component tagout status .
1_0
Staffing levels were adequate. The op~rations department continued to
run with five operating shifts.
The operations department averaged
between 20 and '30 percent overtime, and early in the period some
backshifts were staffed with only two Senior Reactor Operators (SRO)
(minimum Technical Specifications (TS) requirement).
It should be
noted that, at the end of the assessment period, the -operating shifts
had a minimum of three SROs assigned to each shift which was
considered as an enhancement in technical and supervisory shift
capability.
At the end of the previous assessment period and conti~~ing into this
assessment period, operating procedures were identified as requiring
tmprovement.
During the early part of this assessment period, almost
every procedure in use by the operations department had one or more
temporary changes implemented.
This condition placed additional
burdens on the operators in the performance of their duties.
The
licensee acknowledged the poor condition of procedures and initiated
a program that involves the imp1ementation of a uniform method for
procedure writing (Procedures Writers Guide).
The licensee also
outlined a three-year schedule commencing
in
1989
which will
generally upgrade station technical procedures in the operations and
maintenance ar:eas to the new enhanced format.
At the end of the
assessment period, the licensee had
upgr~de~ approximately 50
procedures.
However, the procedur~s. which were used for the Unit 1
restart were not upgraded.
These procedures had been reviewed and
considered adequate for unit s*tartup.
Based on a population of
approximately 2500 procedures to be reviewed for upgrade program
completion, the three-year schedule appeared to be pptimistic.
During the early part of 1989, several operational errors occurred,
including
improper operation of containment isolation valves,
improper valve alignment resulting in flooding of the Unit 2 cavity
area, operati-on -of a charging pump without a suction flowpat_h, and
operation of a containment vacuum pump with the suction flowpath
blocked.
These errors resulted in a violation for failure to follow
- procedures and for inadequate procedures.
Another operational
occurrence that resulted in a violation was a loss of shutdown
cooling to Unit 1 in March 1989.
This problem again indicated
inadequate operator control of a required system.
Although each of
the occurrences resulted from either an inadequate procedure or a
failure of operations personnel to maintain cognizance of system
configuration, the more underlying cause was a 1 ack of persona 1
responsibility for attention to detail.
Management was involved
afte,r each event, providing direction to correct the problems.
However, management sensitivity towards proper operation of the
station and expectations regarding attention to detail and plant
ownership were not evident until the latter half of the assessment
period.
11
Early in the assessment period, the operations department tolerated
malfunctioning equipment and often took compensatory measures to work
around problems rather than have them corrected. This was evidenced
by the continuing problems associated with inadequate service water
to operating control room chillers and the acceptance and lack of *
repair of inoperable radiation monitoring equipment for long ~eriods
of time.
However, near the end of the assessment period, the
operations staff was requiring more accountability and performance of
the operations support departments with operators being
held
accountable for identification of problems affecting operational
readiness.
The licensee continued to upgrade the drawings which were needed *by
operations personriel in the performance of their daily duties and in
emergency conditions. Both units
1 flow diagrams were being converted
to the computer assisted drawing system (CADS) in order to ease
updating.
Several
NRC
reviews of the control
room drawings
identified few discrepancies which would affect the capability of the
operators to handle events.
Also, during conduct of the ORAP for
Unit 1, the flow drawings were used by the system engineers to walk
down the systems addressed in the emergency procedures for Unit 1.
D~ring these walkdowns, no significant problems were identified: At
the end of the period, the review process was still ongoing and the
licensee was continuing to update and correct minor discrepancies.
The operations department identified several discrepancies in the
program associated with establishing and maintaining isolation
tagouts over the 1 ong outages..
Although * add it i ona 1 management
attention was given -to this area, a comprehensive solution to
correction 6f identified problems was not evident. At the end of the
assessment period, the iicensee was in the process of converting to a
computerized tagout program to help improv~ this ~rea.
Based on a
limited review, implementation of this program should improve tagout
control.
The review of the fire protection program implementing procedures,
survei 11 ance procedures, test results, fire fighting equipment and
fire detection systems demonstrated that plant fire protection
features were in service and functional.
The control of combustibles
and general housekeeping in safety-related areas were found to be
training and drills for the fire brigade members met frequency
requirements specified by the fire protection program implementing
procedures.
The
effectiveness of fire brigade training was
demonstrated during an unannounced dri 11 observed by the NRC staff.
In addition,
NRC inspectors observed satisfactory fire brigade
performance during a response to two minor fire events.
The fires
were extinguished immediately and resulted- in no damage to plant
equipment or injury to plant personnel.
B.
2.
12
One Severity Level III violation and two additional violations were
identified during the assessment period.
Performance Rating
Category:
3
Trend:
Improving
3.
Board Recommendations
The procedures ~pgrad& program should be considered a high priority
issue and it's progress should be monitored .to assure timely
completion.
Management needs to assure that the operations staff
does not accept conduct of plant operations with poorly performing
equipment.
The Board recognizes that later in the assessment peribd,
past problems were. ~eing addressed.
The high level of inspection
effort should continue in this area.
Radiological Controls
1.
Analysis
During the assessment period, inspect i ans were performed by the
resident and regional staffs.
The inspections included six radiation
protection inspections and one radiological effluents and chemistry
inspection.
Radiation protection inspections were increased. as a
- result of the previous assessment which concluded that Surry* s
radiation pfotectio~ program was degrading;
The licensee's radiatio*n protection, radwaste and chemistry staffing
levels were adequat~.
In the middle of the assessment period, a new
Radiation Protection Superintendent was named.
A 1 so, the 1 i cen see
recruited a radiological assessor to provide internal assessment of
the radiation protection program.
In response to below average
resol~tion of. technical issues reported in the previous assessment
report, and to remedy the weaknesses identified, the licensee
developed a radiological engineering.capability within the radiation
protection group by adding a staff of seven radiological engineers.*
The performance of the HP staff, in the early *part of the assessment
period, in support of routine and outage operations was poor.
Ele~en
of the fourteen violations of NRC regulations that occurred during
this assessment period could be attributed directly to inadequate
performance
by radiation protection department personnel.
Five
violations of NRC regulations involved requirements for controlling
personnel radiation exposure.
Four violations of NRC regulations
involved either the failure to follow approved procedures or
inadequate procedures.
In addition, the inability to adequately
control personnel exposure continued from the previous assessment
13
period.
Early in this assessment period, a person performing
cleaning and inspection of. the reactor vessel flange received
3.279 rem in one calendar quarter.
This overexposure resulted in
multiple violations characterized as a Severity Level III problem,
and the issuance of a Civil Penalty.
As a' result of the unsatisfactory performance during the early part
of the assessment period, the licensee performed an evaluation of
their radiation protection program and identified the following
corrective
actions
to
address
the
programmatic
weaknessei:
1) increased management involvement and control of pre-job prepara-
tions arid assessments; 2) management emphasis on accelerating the
implementation of the Corporate Radiation Profection Plan, including
issuing revised radio l ogi cal control procedures; 3) pro vis i ori for
additional experience in and proper management of the radiation
protection group, as we 11
as adequate radio l ogi cal
engineering
expertise onsite; 4) training and department meetings to review and
emphasize procedural compliance; and 5) a program to enhance overall
procedure quality.
The licensee presented a formal improvement program to the NRC in
July 1988.
New
initiatives for accountabiJity
of_ performance
implemented by the Pl ant Manager and the Radiation Protection
Superintendent .have resulted in imp roved performance by both* HP
supervisors and t.echni ci ans.
However, throughout and subsequent to
the end of the assessment period, problems were observed in station
workers' compliance with HP requirements.
Since identification of
the programmatic improvements, both units have been in extended
maintenance/refueling
outages.
During
these
outage
periods,
significant work requiring HP support was accomplished.
Although the
licensee did not achieve the reduction in person-rem exposure that
could be expected if both uni ts were operating' the licensee did
- closely monitor each job for person-rem exposure and al so closely
monitored the personnel contaminations.
Reviews of the licensee's As
-Low ~s Reasonably Achievable (ALARA) program revealed that all items
identified as problems during a team inspection conducted in the
previous assessment period had been closed.
As a result of the
corrective actions taken by the licensee in response to the ALARA
team inspection, the most significant ALARA program improvement was
the management of collective dose at the station.
During the
previous assessment period, the licensee managed dose by utilizing a
daily collective dose average which was based on previous routine and
outage days.
The
licensee
improved the daily management of
- collective dose by basing the goals on specific ALARA reviews and
dose projections.
At the beginning of the assessment period, the licensee had 24,075
square feet (ft 2 )*of contaminated area, which represented 27 percent
of the radiologically c~ntrolled area of the plant.
By the end of
,.
14
the assessment period, this area was
reduced to 17,524 ft 2 ,
(19 percent), which was under the licensee's goal of 17,792 ft 2 for
1989. Although the reduction in contaminated area Js significant ~nd
can be attributed t6 increased management s~pport for decontaminatiqn
of controlled areas, and the recoating of large portions of the
controlled areas with epoxy, Surry's contaminated area was still
high.
During the assessment period, the licensee recorded 394 personnel
contamination events. This was a downward trend'and is attributed to
the decontamination effort and increased management attention in this
area.
The station's 1989 collective dose goal was established at 502
person-rem.
By the end of the assessment period, the licensee had
accumu1ated 435 person-rem towards this goal.
During this assessment
period, Unit 1 experienced 259 outage days while Unit 2 experienced
263 outage days.
The collective dose during this period was 1938
person-rem.
The cumulative exposure for the amount of outage time
was not considered to be excessive:
During the assessment period, the licensee began construction of a
new radwaste processing facility, which was designed using the latest
ALARA concepts and waste reduction technology.
In the past several assessment period, there continued to be a
significant decreasing trend in total curies released via the liquid
release pathway.
This was partially attributable to improvement in
radioactive waste processing and extended plant shutdowns during the
period.
Liquid and gaseous effluents for the period were within the
dose limits specified in 40 CFR 190, 10 CFR 50, Appendix I ALARA
Criteria, and the radioactive concentrations specified in 10 CFR 20.
No unplanned releases were reported during the assessment period.
J
In the liquid and gaseous effluent monitoring program, there has been
an apparent lack of management attention, in that the licensee has*
been in several continuous Technical Specification ACTION statements.
Examples of this are the inoperability of the component cooling water
effluent line monitor and the waste gas holdup system oxygen monitor.
Compliance has relied totally on compensatory measures.
At the end
of the assessment period, the licensee was actively pursuing redesign
of these monitors.
A radiological confirmatory measurements comparison continued to show
good agreement between NRC and licensee measurements.
One Severity Level III problem, composed of eight violations, and six
additional violations were identified during the assessment period .
2.
Performance Rating
Category:
3
Trend:
Improving
15
3.
Board Recommendations
Positive management initiatives are necessary to assure continued
reduction of cumulative exposure, to ensure that working level
pers6nnel understand the importance of adherence to HP proced~res and
to
expeditiously repair radiation. monitors
needed
for plant
operations.
The Board recognizes that the construction of a new
modern radwaste faci 1 i ty, a decrease in the number of personne 1
contamination events and a downward dose. trend are positive
indicators of your radiological control effort. Based on the overall
assessment, the Board recommends a continued high level of inspection
activity.
C.
Maintenance/Surveillance
1.
Analysis
During this assessment period, ~outine and special inspections were
- performed by the NRC staff. Significant inspection findings in this
area were identified in an SSFI inspection of the service water
system, an AIT inspection of the reactor cavity seal event and
several MDV inspections*.
The maintenance staffing levels appeared adequate, with minimal
turnover rate.
The overtime rate was relatively high due to the
extended outages, even though a significant number of contractors
were used to augment the normal station staff.
The maintenance
department was expanded to include an engineering supervisor, who is
responsible for the predictive analysis group, the PM program, the
MDV coordinator, and the maintenance engineers.
The overall material condition of the plant improved during this
period, primarily due to identified problems driving a more thorough
maintenance approach.
For example, the main control room envelope
chillers and instrument air compressors wert ov~rhauled after being
allowed to degrade to a point where they would not have p~rformed as
required.
The licensee did not routinely use maintenance-specific performance
indicators to evaluate the effectiveness of the maintenance
department.
For example, the licensee did not identify and trend
rework and/or mean time to return equipment to service for management
review and evaluation.
The average age of corrective maintenance
work requests was approximately 200 days.
Although this figure was
16
elevated by a significant number of minor work requests, it did
indicate that a substant i a 1 amount of , back 1 og work remained.
Examples of these minor work requests were leakage reduction work
orders, valve packing. upgrades, and replacement of Grinnel valve
diaphragms due to the age of the material.
Management involvement
was evident regarding temporary modifications (i.e. jumpers, lifted
leads), with adequate emphasis placed on removal of those jumpers
necessary to return safety equipment to service.
PM comprised
approximately 25 percent of the. total maintenance effort.
The
deferral rate of scheduled PM work averaged approximately 20 percent.
~lthough this was an improvement over previous assessment periods,
continued improvement was needed, as evidenced by the extensive MDV
problems and the failure to implement PM requirements specified "for
the diesel driven emergency service water pumps.
The licensee was ineffective in implementing adequate programs to
correct long-standing problems.
For example, the PM program was
scattered throughout several disciplines, with no method to monitor
effe~tiveness.
Also, the licensee did not have a formal ch~ck valve
maintenance program in p 1 ace, even though a need for this type
program was identif_ied as a major weakness following the 1986
feedwater pipe rupture event.
In addition, at the end of the
assessment period, the licensee was developing a formal maintenance
root cause and trending program in respo'nse to numerous audit and NRC
concerns identified during the last assessment period. This program-
matic problem was discussed *in the last assessment period.
Manage-
ment was aware of this shortcoming and initiated efforts to improve.
A change in philosophy regarding program development and implemen-
tation occurred over the_ assessment period, turning away. from tasking
the statioh with developing programs and more to~ard turnkey program
deveiopment at the corporate level.
Training for the maintenance craft was found to be adequate.
The
trainin*g program maintained full accreditation with the National
Academy for Nuclear Training.
Construction was completed on a large
addition to the training center complex that contains additional
classrooms, laboratories-and offices._
Inadequacies. were
identified
regarding
the
identification,
procurement, and staging of parts. A previous failure to adequately
evaluate the suitability of non-qualified replacement parts, coupled
with an inadequate purge of these suspect parts_ from storage,
resulted in potentially unqualified replica parts being installed in
safety related components.
In addition, a problem was identified
regarding the failure to adequately identify and control materi~ls in
several safety-related work activities. At the end of the assessment
period,
the licensee was
implementing a program to increase
engineering involvement in the procurement process .
17
. Similar to the Plant Operations functional area, procedures also
continued to be a significant weakne~s in the maintenance area.
Changes to procedures were frequently required to enable work to.
proceed.
The failure to imp 1 ement adequate procedura 1 control
resulted in a programmatic weakness regarding * foreign materi a 1
exclusion.
This weakness was highlighted by the discovery of debris
that had accumulated for several years inside the poorly maintained
screens of both- containment
Further examples of poor
procedures were identified involving the failure to incorporate
reactor cavity seal design requirements into maintenance procedures,
improper orientation. of flow *orifices, the poor reinstallation of
Appendix R cable tray covers, and the improper torquing of system
closure fasteners.
The licensee acknowledged the poor condition of
th~ procedures and initiated* a three-year procedure upgrade program
as discussed in the Plant Operations area.
Significant and numerous problems were identified regarding the
. maintenance of MOVs.
The MOV deficiencies indicated weaknesses in
the technical content of implementing procedures, little involvement
from management and f i rst-1 i ne supervisors and a 1 ack of a we 11 *
structured, comprehensive MOV program.
Resolutions to correct MOV
defici~ncies were often not thorough and in some cases not aahered
to.
During the latter half of the assessment period, the licensee
instituted a major rework program involvi_ng virtually all the safety
system MOVs, after it became apparent that the MOV failure rate was
unacceptable.
A task group consisting of. corporate engineering
staff, plant system engineers and operations personnel
had been
assigned to develop and implement a comprehensive MOV program.
The
implementation of the riew MOV program was well underway toward the
end of the assessment period.
The local leak rate test program implementing procedures and controls
were well executed and had improved since the previous assessment
period.
System features necessary to ensure containment integrity
were found to be adequately maintained.
Post-maintenance testing was identified as a weakness, as evidenced
by the fact that the licensee did not have in place a comprehensiv~
program that addressed post-maintenance testing.
The program that
was es tab 1 i shed to imp 1 ement * the testing requirements of American
Society of Mechanical Engineers (ASME)Section XI was informally
adapted to specify post-maintenance testing of components not covered
by the ASME Code.
Several
examples were identified where the
maintenance scope increased, yet the post-maintenance test require-
ments were not reviewed for adequacy.
In addition, an example was
identified involving the failure to perform adequate post-maintenance
18
testing following a major repair to a safety~related pressure control
valve.
The ASME Section XI 'inservice ~nspection (ISI) test program wis fou~d
to be generally sound,
although two examples were identified
regarding failure to adequately perform required testing.
Midway
through the as*sessment period the licensee issued a revised ISI
manual
that included both new and revised administrative and
non-destructive examination (NOE) procedures.
The admi ni strati ve
procedures established a more comprehensive control of ISI activities
and the NOE procedures, and in most cases, were an improvement over
previously used procedures.
NRC initiatives were well received by
the licensee**as evidenced by the establishment of guidelines
- pertaining to second independent interpretations of radiograph film
and additional radiography being conducted when earlier results were
questionable.
Also, an extensive NOE program to identify erosion-
and corrosion-affected components within suspect piping systems was
impiemented.
Post-refueling startup test activities were reviewed for Unit 1,
cycle 10, which occurred early in the assessment period.
The
assessment of core physics data collected during the startup agreed
well with the predicted p~rformance criteria. The licensee continued
to maintain a sound approach to post-refueling startup activities.
The licensee responded positively to an NRC request for additional
engineering evaluations and testing to confirm power supplies to
plant equipment and train independence, and to conduct additional
load sequencing tests for the emergency diesel generators (EOG).
These requests were in response to SSFI inspections, feactor cavity
seal in~pections and licensee's identified items in areas of system
design control, system configuration control and system maintenance
practices. The licensee's s*taff demonstrated adequate technical and
operational skills in the preparation and performance of complex and
,integrated plant
system testing.
However,
deficiencies were
identified in testing of electrical emergency buses.
An example of
poor coordination and com~unication was noted during performance of
special* testing on the Unit 1 H bus.
In addition, an example of
failure to establish adequate initial plant conditi~ns for electrical
testing of the Unit 1 J bus was identified.
Management was actively
involved in correcting these problems. -
Surveillante tests were generally performed within the allowable time.
interval.
The licensee continued to integrate the data collected
from the predictive analysis group into the official surveillance
program.
A significant problem was identified, however, regarding
the failure to adequately test the capacity of the emergency service
water pumps and their* associated diesel start batteries. The pumps
were in fact found to be incapable of supplying an adequate makeup to
the ultimate heat sink following a design basis accident.
Inadequate
2.
19
surveillance testing was also identified regarding the verification
that the main control room envelope chillers were operating within an
acceptable performance envelope.
The above i terns contributed to
several Severity Level III violations with Civil Penalties.
Although not issued within the assessment period, a deviation was
identified during the SSFI for not including vendor 1 s equipment
maintenance recommendations into site procedures.
These vendor
recommendations pertained to operation of various MOVs, emergency
service water diesels and the recirculation spray heat exchangers.
The possibility existed that these problems could have been avoided
if full implementation of NRC Generic Letter 83-28, Required Actions
Based on Gener*ic Imp*lication~ of Salem ATWS Events,
had been
instituted by the licensee.-
The implementation of the secondary chemistry control program was
successful in maintaining water purity generally within the accepted
guidelines.*
However,
minimal
success in slowing the rate of
corrosion of the secondary system was achieved.
Corrosion products
continued to be transported to the steam generators (SGs) of both
units.* As. a result, large amounts of solid corrosion products were
removed from the SGs during the spring and ,fall of *1988 for Units 1
and 2, respectively. This provided evidence of pipewall thinning and
- the formation of conditions within the SGs known to be conducive to
the corrosion and cracking of SG tubes.
The licensee had installed
an
on-1 ine monitoring system for principal secondary chemistry
parameters.
This system would a 11 ow corit i nuous monitoring and
trending of steam cycle chemistry along with computerized data
logging.
The low turnover rates and the resultant continuity of the
chemistry staff, backed up by a commendable training program and
adequate management sup~~rt, were licensee strengths.
Two Severity L~vel III violations, ten additional violations and one
deviation were identified during the assessment period.
Performance Rating
Category:
3
3.
Board Recommendations
The Board recognizes good performance in the areas of maintenance
training, leak rate testing, the ASME Section XI
ISI program,
post-refueling startup test activities and secondary plant chemistry
control. However, management attention is needed to assure improve-
ment of the PM program, the procurement of spa re and replacement
parts and the implementation of post-maintenance testing.
The Board
recommends a continued high level of inspection activity in this
area .
-.*
D.
20
1.
Analysis
During the assessment period, inspections were performed by regional
and resident staffs. Two routine inspections and two evaluations of
EP exercises were conducted.
The first routine inspection focused on the Emergency Pl an and
implementing procedures; emergency facilities; equipment, instrumenta-
tion, and supplies; organization and management control; training;
and the independent reviews of the ,EP program.
No violations were
identified during the inspection; however,
an off-hours callout
drill, which was requested by the NRC inspector, identified a problem
with augmenting the emergency organization.
The ca 11 out dri 11
consisted of the licensee calling individuals li*sted in the Emergency
Personnel Notification List and obtaining an estimate of the time
. required to respond to the site.
The callout drill did not clearly
demonstrate that the emergency organization could be fully staffed
within
the
required
times.
Also,
the
Emergency
Personnel.
Notification List that sec4rity personnel were going to use was.
several revisions out of date; this was corrected pri'or to the
callout drill.
Although the. liten~ee committed to take c6rrective
actions in this area, the timenness. of the augmentation staffing
continued to be a prob 1 em.
For ex amp 1 e, during the off-;-hour annual
emergency exercise, conducted on November 1, *1988, the excessive time
to activate the Technical Support Center (TSC), *ego* minutes), *and:
Local Emergency Operations Facility (LEOF), (150 minutes), with the
standard being 60 and 90 minutes, respectively, was a problem noted
by the licensee and the NRC.
Later, during the second routine
inspection of the* assessment period, the failure to meet the
Emergency Plan 1s augmentation staffing requirements within the times
set forth was identified as a violation.
The
annua 1 emergency exercise al so
i dent i fi ed the fa i 1 ure to
recognize and classify a Site Area Emergency as a significant
exercise weakness.
The classification was not made in a timely
manner and had to be prompted by the controllers. As a result of the
inability to classify the event, the licensee committed to conduct
retraining in needed areas and redo the exer~ise within approximately
90 days.
An additional problem area identified in the exercise was
the failure to provide accurate arid updated messages to the State and
local response organizations.
Although 1 icensee management appeared responsive in their concern
over the less than satisfactory exercise by committing to redo the
exercise, the remedial exercise that followed did not reflect the
increased management attention and involvement that the situation
2.
21
required.
Observations supporting this statement included the
minimally challenging scenario, the identification of a new exercise
weakness ad_dress i ng the fa i 1 ute to ma i nt_a in contamination access
control to the emergency response facilities, and a* repeat of the
excessive activation times for the TSC and LEOF.
In particular, the
TSC activation time was approximately 25 minutes greater than in the
previous exercise where the licensee had identified the excessive
times to activate as a deficiency requiring corrective action.
The
remedial exercise was successful for demonstrating the required
corrective action of properly classifying a radiological release and
adequately
providing
messages
to
state
and
local
response
organizations; however, a significantly improved overall level of
emergency response effectiveness was not demonstrated.
During April 1989, an inspection conducted noted that the licensee
had effectively ut i 1 i zed a computerized system to track emergency
response training; that. tbe early warning siren system had been
upgraded; and that the knowledge of classification procedures was
noted as a program strength.
The licensee, through a root cause
analysis approach, has categorized the outstanding EP deficiencies.
Corrective actions for these deficiencies commenced subsequent to the
end of the assessment period .
One violation was identified during the assessment period.
Performance Rating
Category:
3
3.
Board Recommendations
Observations during the assessment period indicated that- although
management expressed their awareness of a need for increased attention
to the EP program, only limited program improvements were actually
observed by the end of the assessment period.
Management attention
is needed to complete the actions the licensee identified necessary
to improve the EP program.
An increased NRC inspection effort is
warranted to monitor and asses~.program improvement.
E.
Security
1.
Analysis
During the assessment period, inspections were performed by the
resident and regional inspection staffs. The evaluation was based on
three routine inspections conducted by the NRC regional staff, in
which no violations were cited;* however, one licensee identified
violation was identified relative to the reliability of the vital
area door locks .
22
The . 1 icensee provided eJ<cel lent security* i_n. accordance with the
requirements of its . NRC""approved
Physi d.l -security . Pl an.
The
licensee retained a some'v/hat unique security organization in that the
site. security force, a *propri-efary force, reports directly to the*
off-s.ite Corporate Director._o.f Nuclear Security, and indirectly
i hterfaces with the on-s_ite Pl ant Manager.
These two management
chains provided very goo~ daily operational support.
The daily performance of the security force and its on-site
supervisor and management was the single greatest strength of the
licensee's program for site security.
Day-to-'day operations of the
security shifts continually met and exceeded NRC criteria and the
1 icensee
committed TS
requirements.
In spite of hardware and
equipment deficiencies, the security force performed at superior
levels.
The 1 i censee I s corporate security department performed numerous
audits o.f the contractor's personnel screening programs, including
the adm1nistration of psychological tests.
At the corporate QA
1 eve 1, * the 1 i cen see continued to experience aggressive annua 1 audits
of its security program:
During the licensee's annual 1988 security
audit, a negative finding was reported relative to the time needed to
complete repairs of degraded security equipment.
A repair time of 11
days versus the 1 icensee' s goal of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> was considered to be
excessive.
There were multi-examples of this deficiency.
While
station outages could have explained some of this delay,_ the NRC
concurred with the auditor's findings and considered this to be an
area where plant support could be improved.
A review of the negative
findings
found
in security inspections (vital area door lock
maintenance, upkeep of the isolation zone; and upkeep of safeguards
cabinets) supported the conclusion that a more effective working
relationship between the security and maintenance organization was
needed.
The proprietary- security force had a minimal t_urnover rate, overtime
did not appear excessive, and the. shifts appeared extremely wel 1
supervi sect and staffed'.
Procedures were very clearly written, and
other documentation was readily available for regulatory tracking
purposes.
Training and requalification continued to be a strong
- point.
Contingency tactical drills appeared realistic and were run
frequently such that each shift was exercised.
Close liaison with
off-site response authorities was also noted.
The licensee's security staff implemented a personalized briefing of
persons who were badged for unescorted access to the station.
This
special briefing addressed required duties and responsibilities
associated _with *being granted unescorted access.
The NRC considered
that this new briefing concept at the time of badging was a positive
F.
2.
23
training attribute with regard to implementation of personnel
awareness of security requirements at the station.
The licensee's use of continuously manned stationary defensive
positions (bullet resistant towers) has assured rapid and accurate
assessment and resolution of protected area perimeter alarms.
Compensatory measures were adequately implemented at the perimeter
barrier through the use of officers in defensive positions.
Five
changes to security plans were
submitted pursuant to
Licensee changes to the security plan met the
reporting requirements of 10 CFR 50.54(p) with respect to timely
notification; however, the changes were not always consistent with
the provisions of the regulation regarding decreases in plan
effectiveness.' There was one request for which the 1 icensee 1 s
processing of changes could have been enhanced by more communication
with the NRC staff prio~ to the submittal.
The explanations which
were included with the submittal did not always provide an adequate
synopsis of the actual
rev1s1ons.
For example, changes were
evaluated by the licensee and considered editorial or minor, while,
in fact they were more substantive and related to access authori-
zation, materials search and equipment
No violations were identified during the assessment period.
Performance Rating
Category:
1
3.
Board Recommendations
The excellent quality of personnel, procedures and training are
recognized by the Board.
The special security briefing is also- a
strength.
Timeliness
of equipment
repairs
needs
management
attention.
Reduced inspection effort should be considered.
Engineering/Technical Support
1.
Analysis
Evaluation of the Engineering/Technical Support functional area was
based on routine and special inspections conducted by the NRC in this
and other functional areas.
Special inspections conducted were an
SSFI on service water and an AIT inspection of the reactor cavity
seal event.
This area addresses the adequacy of technical and
engineering support for all plant activities.
The area includes
licensee activities associated with plant modifications, technical
support - provided
for
operations,
maintenance,
testing
and
surveillance, training, and configuration management.
24
Poor performance of the engineering department was demonstrated by
the calculations produced to support operability of the service water
system and recirculation spray heat exchanger.
This issue resulted
in a Severity Level III violation with a Civil Penalty .. The
evaluations used to determine if the service water system met design
requirements lacked detail and,did not include an in-depth review of
critical data.
The calculations also utilized invalid assumptions.
The evaluation focused on verifying a conclusion that the design
basis requirements were met rather than providing a review of all
pertinent aspects of system performance.
The errors in the service
water system calculations, which were accomplished early in the
assessment period, demonstrated that the engineering department did
not fully util*ize existing regulatory guidance relative io the design
and review process.
Consequently, the licensee failed to reach
adequate conclusions on the operability of the service water systems.
Recirculation heat exchanger calculations utilized inaccurate and
nonconservative design assumptions and inputs.
Environmental effects
on safety related components and control of mechanical specifications
were also elements of weakness in the recirculation heat exchanger
calculations.
Calculations for reactor coolant leakage surveillance employed
incorrect values for constants which provided the potential for
underestimating RCS leakage.
The error in RCS leakage calculations
could have resulted in acceptince of unidentified leakage in excess
of TS limits.
A violation was issued concerning the use of the
incorrect constants.
During the first portion of the assessment period, engineering
involvement was minimal in evaluation and resolution of significant
problems with MOVs.
Engineering did not review MOV actuator test
results in order to evaluate ~efic~encies and determine corrective
actions.
Deficiencies written on MOVs were not evaluated for root
causes, and MOV engineering sketches were inadequate.
The lack of
engineering review of MOV problems resulted in a violation for
failure to properly identify and correct MOV deficiencies.
As a
result of the above discrepancies, a task team was established in the
latter portion of the assessment period and provic:led a positive
impact on the resolution 6f MOV deficiencies.
Early in the assessment period, the engineering organization had not
demonstrated an adequate self-assessment capability.
A specific
example was the lack of administrative control for the backlog of
potential problem reports which were generated i ri the corporate
offices.
Incorrect assessment of safety significance of outstanding
issues was identified as a problem area.
This condition became
obvious when
significant safety issues (i.e., emergency diesel
generator
sequencing
problems
and
control
room
envelope air
conditioning/ventilation problems) were first addressed in the
licensee 1 s corrective action program approximately two years after
25
they were identified.
Also, during review of outstanding station
EWRs for appropriate disposition as a part of the restart ~ffort,
severa 1 of the o 1 der EWRs were .di sc:overed to be i ncomp 1 ete and not
properly closed out.
These conditions indicated that the programs
for proper disposition and ~l oseout of engi neeri n_g documentation
appeared to be ineffective.
Tech~ical support weaknesses were also evident in plant EWR procedure
quality.
Examples of these weaknesses were identified as violations
for failure to ensure that proper technical reviews were being
completed prior to returning safety-related components to service,
and failure to provide ~dequate instructions in EWRs relating to
safety-related activities.
In addition, the* technical staff was
using the EWR process to perform plant modifications, which resulted
in inadequate technical reviews for addition of heat lbads to plant
air conditioning/ventilation systems and improper modification of the
reactor cavity seal backup air supply system without implementating
fequired *drawing revisions.
The above problems were also indicative
of a lack of adequate training of engineering personnel.
The issues identified by the SSFI and AIT resulted in management 1s
recognition of existing *deficiencies in engineering and technical
support.
Improvements
initiated included increased resources,
engineering
improvement
programs,
and
reorganization of the *
engineering department.
A Design Basis Documentation (DBD) Project
which encompasses 80 plant systems was initiated.
The program
consists of. six phases, from document collection to approval and
final issuance of the final DBD.
For the first seven systems, phases
one and two have been completed.
The third phase,
i nvo 1 vi ng
component design basis, was on schedule.
Identification by the licensee of an actual configuration problem in
the middle of the assessment period resulted in a program to verify
the integrity of the Unit 1 plant configuration in accordance with
emergency
procedures.
The
ORAP
represented
a
considerable
engineering commitment of resources to ensure that actual plant
configuration was in accordance with approved pl ant drawings and
procedures and also ensured that divisional power supplies to
safet~-related compo~ents were correct.
During the assessment period, the licensee realized that the
engineering staff was not focusing appropriate resources to the needs
of the station.
In order to correct this condition, the licensee
reorganized the engineering department and established a larger
engineering staff at each nuclear station. The formation of a system
engineering group and a design engineering group provided a major
improvement potential.
A reorganization of technical resources
provided consolidation of nuclear support resources on the corporate
- level arid a stronger on-site engineering presence.
This reorgani-
zation appeared to .be a strength, in that during the latter part of
2.
3.
26
the assessment period,* increased systems and design engineering
capabilities on-site allowed for more timely resolution of Unit 1
restart technical issues.
Technical support related to EQ was good.
The engineering staff was
kn owl edge ab 1 e of . EQ issues and NRC-i dent i fi ed defi ci enci es were
resolved.
Operator training, as evidenced by the performance on the replacement
examination, was effe-ct i ve.
A 11
12 candidates passed both the
operating and written portions of the examination.
Reference
material sent to the NRC for exam preparation was well organized and
detailed.
The quality of the reference ~aterial and a review effort
by the licensee prior to the exam contributed to it's high quality.
'
.
Training facilities and instructor quality continued to be one of the
strengths.
This was particularly evident during the latter part of
the assessment period.
During this timeframe, additional training
was conducted with regard to new system modificati6ns and operating
requirements.
In addition, special refresher training was provided
to operators for Unit 1 restart and was conducted in an excellent
manner.
Training* for the maintenance craft was found to be adequate.
The training pregram maintained full accreditation with the National*
Academy for Nuclear Training. Also, all programs at the* station have
received
accreditation
from
the Institute of Nuclear
Power
Operations.
Construction was completed on a large addition to the training center
complex.
The new structure includes nine additional classrooms, new
instructor offices,
five
laboratories
(mechanical,
electrical,
chemistry, HP, and instrumentation and control), a technical library,
and a practical factors area for general employee training.
This
modern training addition provides facilities for the station to
properly train personnel in all requisite areas and is expected to
increase plant proficiency in -the future.
One Severity Level III problem, composed of four violations, one
additional violation and one deviation were identified during the
assessment period.
Performance Rating
Category:
2
Board,Recommendations
Management needs to continue the improvement of engineering support
to the station and to closely monitor the engineering organization
for effectiveness.
The reorganization of the engineering organi-
zation, the initiation of the Design Basis Documentation effort and
)
27
the conduct of the ORAP provided indication that *this area was
improving.
Based on the mixed performance in this area, the Board
had difficulty in determining the .final performance rating. A high
level of inspection effort should be maintained.
G.
Safety Assessment/Quality Verification
1.
Analysis
During the. assessment period, inspections were performed _by the
resident and regional inspection staffs and licensing reviews were
conducted by the NRR staff.
Inspections evaluated the licensee 1s
corrective action
program,
performance
of appropriate
safety
evaluations, root cause analysis of plant events, the corporate
offsite independent review group 1 s functions, the licensee 1 s on-site
safety committee functions, and the quality function as used in the
monitoring of the overall performance of the plant.
During the early part of the assessment period, significant
weaknesses in plant and corporate management leaderihip and skills
resulted_ in lower than desired expectations and accountability.
These weaknesses were illustrated by multiple examples dealing with
the failure to take aaequate corrective actions, and the failure to
conduct appropriate safety and root cause evaluations._ These problem
areas resulted in several. Severity Level III violations with Civil
Penalties.
Numerous examples of management 1s failure to take adequate corrective
actions, as exemplified in the last assessment period by the failure
to verify boric acid heat tracing operability, _continued to be
identified in this assessment period.
These examples were as follows:
the Unit 1 reactor cavity seal failure event, where management failed
to take necessary corrective action due to not understanding the
event, as .discussed in the Plant Operations section; the failure to
identify and correct a longstanding adverse condition involving
inadequate housekeeping and improper maintenance of the containment
sumps, as discussed in the Maintenance/Surveillance section; the
failure of the licensee 1s corrective action program to identify a
potential for gas binding of safety-related pumps;. the failure to
promptly identify a degraded condition of the control room and*
emergency switchgear ventilation system; the failure to promptly
correct leakage of water around safety-related pump room roof plugs
until prompted by the NRC; and failure to completely resolve a
non-original
equipment
manufactured parts
problem
when
first
discovered several years ago.
-
The preceding examples of failure to take adequate corrective actions
were mostly identified in the first half of the assessment period.
After identification of the programmatic deficiencies, licensee
management took action to change the threshold for identification of
28
conditions adverse to quality.
During the latter part of the
assessment period, licensee-identified station deviation reports
increased by a factor of lO over previous numbers and problem
identification sensitivity of the station staff was improving.
Weaknesses with regards to proper safety reviews were identified in
the last assessment period, as exemplified by a failure to properly
evaluate the consequences of an event which involved a worker 1 s
unnecessary exposure to an extremely high radiation field.
This type
of problem continued to be identified during this assessment period.
Four previously discussed examples highlighted this continuing
weakness.
In addition, the lack of management sensitivity to safety evaluations
of degraded conditions at the beginning of the assessment period was
evident.
An example was during the restart of Unit 1 in July 1988,
when senior station management indicated to licensed operators that
Un.it 1 heatup should continue even though the operators had indi-
cation of containment boundary leakage which required the unit to
retur~ to cold shutdown.
The
preceding examples
of failure to conduct proper safety
evaluations were mostly identified in the first half of the
assessment period. After identification of the programmatic problem,
licensee management
1 s attitude and sensitivity to the conduct of
proper safety evaluations and reviews improved. During the latter
part of the assessment period, frequent monitoring of the station
safety committee meetings and other event reviews indicated an
improvement in this area.
Another problem area that was identified. during the previous
assessment period and continued into this assessment period was
inadeq~ate root cause analysis of events, failures, and/or condition5
adverse to quality.
-
The licensee recognized in the latter part of the assessment period,
that root cause evaluations were not being accomplished.
After
identification of the problem, the licensee implemented a root cause
analysis procedure at the station focusing on system engineer
eva 1 uat ions.
However, a forma 1 corporate root cause eva 1 uat ion
program was not initiated until near the end of the assessment
period.
A weakness was also identified with the licensee 1 s capability to
properly track regulatory commitments and ensure that measures were
in place to prevent their deletion from a procedure without proper
review.
An example of this problem occurred when abnormal procedures
were revised in response to an NRC Bulletin commitment.
Due to a
lack of proper tracking, this commitment was deleted in a later
procedure revision, contributing to inadequate operator response
during the cavity se~l leak event.
This problem was indicative of a
29
significant weakness with regards to ensuring compliance with
commitments.
During the latter part of the assessment period, an evaluation of the
1 i censee I s self assessment capability was cdnducted.
The assessment
concluded that the on-site review committee was performing an
adequate review as required by TS.
However, a major weakness was
observed during the review of the corporate independent review group.
The review, which resulted in a violation, concluded that this group
was not complying with TS because they were not conducting the
required reviews of all safety evaluations, violations, reportable
events, and on-site safety review committ~e actions. The review also
concluded that this TS function had not been complied with for an
extended period of time.
Based on these observations of the off-site
review function it appeared that corporate management did not
effectively use self-assessment to assure quality in activities.
The licensee's initial approach to the resolution of technical issues
from a safety standpoint contained in NRC Bulletin 85-03, MDV Common
Mode Failure~ During Plant Transients Due
to Improper Switch
Setting~, was neither conservative nor thorough.
The MDV Task Team's
subsequent design review identified deficiencies that should have
been identified during the bulletin review.
Also, numerous station
deviati~ns were written on valves covered by the bulletih after the
1 i cen see reported comp 1 et ion of the program.
The same type of
inadequate review was cor:iducted of NRC Bul 1 et in 84-03, Refue 1 i ng
Cavity Water Seal, and was noted as part of the cause of the cavity
seal event discussed earlier in this functional area.
Licensee submittals such as amendment requests and relief requests
were of good quality and submitted in a timely manner.
The licensing
staff was professional and thorough and 1n most instances scrutinized
their submittals for both technical content and conformance with
regulatory requirements.
Increased use of technical personnel on audit activities resulted in
audit findings of greater technical substance than in the previous
assessment period.
The method for closing audit findings, including
the recurrent ones, was changed in August 1988.
This new method
involved evaluating the corrective action for an audit finding, on
more than one occasion and then presenting the decision to close a
finding for approva 1 by the manager of the audit group.
Specific
QA/QC problems were identified, though, during conduct of the SSFI in
the middle of the assessment period. A violation was noted in which
QC identified work orders containing design change deviations and
nonconformances that were not addressed in the corrective action
program.
In addition, effective maintenance activity corrective
actions had not been taken as evidenced by recurrent QA audit
findings.
After identification of these QA/QC problems, the QA
v.
A.
2.
30
department t,ook appropriate actions.
All of the significant defi-
ciencies discussed in this functional area were not aggressively
identified and pursued through the use of the licensee's QA program.
Late in the assessment period, though, the QA organization demon-
strated an improved capability to identify problems in safety-related
plant activities.
This conclusion was based on monthly discussions
between the resident inspector and QA management.
During the latter part of the assessment period, some of the
aforementioned changes did provide an indication that problems
attri butab 1 e in pa'rt to an inappropriate management attitude and
significant weaknesses in plant and corporate management leadership
and ski 11 s * were changing. Past management practices which had
resulted in lower than.desired expectations' and accountability were
also improvtng. A positive change with regards to sensitivity and a
lack of attention to detail was also noted.
The licensee's ORAP,
which was instituted in January 1989, and the management restart
readiness confirmation which was conducted prior to Untt 1 re~tart
were indicative that past programmatic problems were being addressed.
Three Severity Level III problems, composed of eight violations, one
Severity Level III violation and one additional violation were
identified during the assessment period.
Performance Rating
Category:
3
Trend:
Improving
3.
Board Recommendations
Management needs to continue the imp 1 ementat ion of the corrective
action, safety assessment and root cause analys-i s programs that
successfully- improved the performance in the latter part of the
assessment period. The Board recognizes that late~ in the assessment
period management was demonstrating an improved sensitivity toward
safety issues.
Inspection effort in this area should remain high.
SUPPORTING DATA AND SUMMARIES
Investigation Review
None.
B.
Escalated Enforcement Action
1.
Violations
Severity Level III violation issued on June 13, 1988 for failure to
31
verify operability of re qui red boric acid heat trace circuitry as
required by TS
(CP -
$50,000).
This violation occurred in the
pre~ious assessment period, but was issued during this period.
Severity Level III violation issued on June 13, 1988 for failure to
adequately evaluate radiation hazards, have adequate procedures, and
follow procedures while working on a stuck incore detector.
(CP -
$100,000).
This violation occurred in the previous assessment
period, but was issued during this period.
Severity Level III problem, composed of eight violations, issued on
August 25, 1988 for failure to control an individual 1 s occupational
radiation dose to less that 3 rems per calendar quarter and to meet
other 10 CFR 20 occupational dose requirements.
(CP - $100,000).
Severity Level III violation issued on November 10, 1988 for failure
to have adequate procedures to ensure that system cleanliness and/or
foreign material exclusion was being maintained on safety-related
systems.
(CP - $50,000).
Severity Level III violation issued on May 18, 1989 for failure to
provide adequate procedures for operation and testing of the
- inflatable seal portion of the reactor cavity seal. (CP - $100,000).
Severity Level III problem, composed of two violations, issued on May
18, 1989 for failure to conduct an adequate 10 CFR 50.59 evaluation
of the reactor cavity seal design and failure to conduct an adequate
evaluation of the cavity seal failure event.
(CP - $100,000).
Severity Level III vi.ohtion issued on May 18, 1989 for failure to
promptly identify and correct a significant condition adverse to
quality involving potential gas binding of the high pressure safety
injection pumps.
(CP - $75,000).
Severity Level III problem, composed of two violations, issued on
M~y 18, 1989 for failure to promptly identify and correct significant
conditions adverse to qua 1 i ty i nvo l vi ng
inadequate capacity of
control
room
chillers
and
degraded
condition
of
control
room/emergency switchgear room ventilation system.
(CP - $50,000).
Severity Level III problem, composed of four violations, issued on
May 18, 1989 for failure to promptly identify and correct significant -
conditions adverse to quality with regard to the use of non-qualified
replacement
parts
for
safety related
components,
wetting
of
safety-related electrical components, and lack of implementation of
an effective component failure trending and root-cause analysis
program.
(CP - $50,000).
Severity Level III problem, composed of four violations, issued on
C.
32
May 18, 1989 for failure to correctly translate into specificitions,
drawings and procedures the design bases for operabi 1 i ty of the
recirculation spray heat exchangers and the emergency service water
pump house equipment; the effects of added loads on the-125 VDC vital
bus batteries; and the effects of minimum wa 11 thickness for a
component cooling water heat exchinger.
(CP - $25,000).
Severity Level I II. vi o 1 at ion issued on May 18, 1989 for failure to
comply with TS requirements re 1 ated to fl owrate operability of the
emergency service water pumps.
(CP - $100,000).
2.
Orders
None.
Management Conferences
1.
June 8, 1988
2.
July 6, 1988
Technical meeting at Region II to discuss issues
on recirculation spray heat exchangers.
Enforcement Conference at Region II to discuss
the Radiation Protection Program.
3.
September 16, 1988
Enforcement
Conference
at
Region
I I
on
4.
October 26, 1988
safety-related sump cleanliness issues.
Management meeting at NRC Headquarters on the
cavity seal event,
and
restart issues.
5.
November 17, 1988 _ Management meeting at the station to review the
status of the Radiation Protection Program.
6.*
December 8, 1988
Technical meeting at NRC Headquarters to discuss
EOG sequencing issues.
7.
December 22, 1988
Technical meeting at NRC Headquarters to discuss
8.
January 5, 1989
9.
January 26, 1989
restart issues.
Management meeting at Region II to discuss
restart issues.
Enforcement Conference at Region II on design
control and corrective action problems affecting
v~rious plant systems.
10.
February 28, 1989
Management meeting at the station on current
issues,
configuration management,
ORAP,
and
restart issues .
11.
March 30, 1989
12.
April 19, 1989
13.
April 26, 1989
14.
May* 22, 1989
33
Technical/Management meeting at NRC Headquarters
on restart issues.
Techriical meeting at NRC Headquarters to discuss
fo~lowup on masonry wall design.
Management meeting at Region II ori the overall
improvement action plan.
Management meeting at the station to discuss the
status of restart issues.
D.
Confirmation of Action Letters
E.
F.
1.
September 6, 1988
Refueling cavity seal leakage.
2.
November 2, 1988 *
Surry res ta rt issues
3.
March 9, 1989
Surry restart issues
Review of Licensee Event Reports (LERs)
During the assessment period 67 LERs for Unit 1 and 2 were analyzed.
The
distribution of these events by cause,. as determined by the NRC staff, was
as fo 11 ows:
Cause
Unit 1
Unit 2
Total
Component Failure
20
10
30
Design
10
0
10
Construction, Fabrication,
1
1
2
or Installation
Personnel
- Operating Activity
9
1
10
- Maintenance Activity
1
2
3
- Test/Calibration Activity
7
2
9
- Other
0
0
0
Other
2
1
3
Total
50
17
67
Licensing Activities
In support of licensing actions, frequent meetings were held with the
licensee to address licensing and other technical issues.* During this
assessment period there were 50 licensing actions completed, i.e., 22
amendments, 8 reliefs, 12 Multi-Plant Actions (MPA), 2 exemptions, and 6
other licensing actions .
G.
H.
34
Enforcement Activity
ENFORCEMENT ACTIVITY
FUNCTIONAL
NO.- OF VIOLATIONS/PROBLEMS IN SEVERITY LEVEL
AREA
Dev.
V
IV
III
II
I
Plant Operations
0
0
2
1*
0
0
Radiological Controls
0
1
5
1
0
0
Maintenance/Surveillance
1
1
9
2
0
0
0
0
1
0
0
0
Security
0
0
0
0
0
0
Engineering/Technical
1
0
1
1
0
0
Support
Safety Assessment/
0
0
1
4
o*
0
Quality Verification
TOTAL
2
2
19
9
0
0
a.
Unit 2 on May 16, 1988, from 100% power. * Event was due to an
undetermined fa i 1 ure of the e 1 ectro-hydraul i c contra 1 system which
caused the main turbine governor va 1 ves to close resulting in a
low-low level SG automatic reactor trip.
b.
Unit 1 on August 15, 1988, from 100% power.
Event was caused by a
spurious
actuation
of the
11A
11-train-Hi
consequence
limiting
safeguards relay during the performance of a normal surveillance test
procedure resulting in the automatic reactor trip.
c.
Unit 2 on September 10, 1988, from approximately'4% power.
Event was
caused by erratic operatfon of a governor valve controller which
caused the first stage impulse pressure to increase greater that 15%.
When impulse pressure increased greater than 15%, with the generator
output breakers open, a turbine trip signal tripped the main turbine.
The impulse pressure increase also caused permissive P-7 to reinstate
(P-7 indicates reactor power greater than 10%)~
An automatic reacto~
trip was then initiated due to the turbine trip with permissive P-7
reinstated.