ML18153B314
| ML18153B314 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/01/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B313 | List: |
| References | |
| 50-280-93-16, 50-281-93-16, NUDOCS 9309140254 | |
| Download: ML18153B314 (24) | |
See also: IR 05000280/1993016
Text
ENCLOSURE
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-280, 281/93-16
VIRGINIA ELECTRIC AND POWER COMPANY
SURRY UNITS 1 AND 2
FROM APRIL 5, 1992 THROUGH JULY 3, 1993
9309140254 930901
~
- DR
ADOCK 0500~fi~O t~
TABLE OF CONTENTS
I.
INTRODUCTION ............................................... 1
I I.
SUMMARY OF RESULTS ......................................... 1
Overview ................................................... 2
I I I.
CRITERIA .....*.............................................. 2
IV.
PERFORMANCE ANALYSIS ....................................... 3
A.
Plant Operations ..................................... 3
B.
Radiological Controls ................................ 6
C.
Maintenance/Surveillance ............................. 8
D.
Emergency Preparedness ............................... 10
E.
Security ............................................. 12
F.
Engineering/Technical Support ........................ 14
G.
Safety Assessment/Quality Verification ............... 15
V.
SUPPORTING DATA AND SUMMARIES ............................ .. 18
A.
Major Licensee Activities ............................ 18
B.
Major Direct Inspection and Review Activities ........ 20
C.
Escalated Enforcement Action ......................... 20
D.
Licensee Conferences Held During Appraisal Period .... 20
E.
Confirmation of Action Letters ....................... 21
F.
Review of Licensee Event Reports ..................... 21
G.
Licensing Activities ................................. 21
H.
Enforcement Activity ................................. 22
I.
Reactor Trips ........................................ 22
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated Nuclear Regulatory Commission (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
supplemental to normal regulatory processes used to ensure compliance with NRC
rules and regulations. It is intended to be sufficiently diagnostic to
provide a rational basis for allocation of NRC resources and to provide
meaningful feedback to the licensee's management regarding the NRC assessment
of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
August 9, 1993, to review the observations and data on performance and to
assess licensee performance in accordance with NRC Manual Chapter 0516,
"Systematic Assessment of Licensee Performance."
This report is the NRC's assessment of the licensee's safety performance at
Surry for the period April 5, 1992 through July 3, 1993.
The SALP Board for Surry Units I and 2 was composed of:
J. P. Jaudon, Deputy Director, Division of Reactor Safety, Region II (RII}
(Chairman}
J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP}, RII
B. S. Mallett, Deputy Director, Division of Radiation Safety and Safeguards,
RII
M. V. Sinkule,,Chief, Reactor Projects Branch 2, DRP, RII
M. W. Branch, Senior Resident Inspector, Surry, DRP, RII
H. N; Berkow, Director, Project Directorate II-2, Office of Nuclear Reactor
Regulation (NRR}
B. C. Buckley, Senior Project Manager, Surry, Project Directorate II-2, NRR
Attendees at SALP Board Meeting:
G. A. Belisle, Chief, Reactor Projects Section 2A, DRP, RII
L. W. Garner, Project Engineer, Projects Section 2A, DRP, RII
J. W. York, Acting Senior Resident Inspector, North Anna, DRP, RII
II.
SUMMARY OF RESULTS
Performance in the Operations area was excellent. Unit I generally operated
well and Unit 2 had an excellent operating record. Management's attention to
and involvement in operations was effective. Operator responses to events
continued to be excellent. Operations management was sensitive to the safety
of shutdown operations.
Management's attention and involvement in radiation protection was observed to
be strong.
The licensee continued to maintain an effective internal and
external exposure control program.
The licensee's control of contamination at
the source has been aggressive.
1
Overall plant material condition was good.
Improvements in maintenance
procedure quality were noted. Surveillance program implementation
improvements were noted.
The flow-assisted corrosion program was well
implemented.
Risk management, especially during outages, was strong.
Management support and involvement in the emergency preparedness program was
evident.
The licensee maintained emergency facilities, equipment,
instrumentation, supplies, and individuals in a state of readiness as
demonstrated during the annual exercise.
The licensee continued to refine and enhance security program effectiveness.
The security training program was well planned and executed.
The security
force continued to track and trend safeguards events.
The licensee's performance in providing engineering and technical support was
generally good.
Support for plant modifications was excellent. Support to
operations and maintenance activities was generally good; resolution of
chronic equipment issues needs to be pursued as does resolution of the issues
arising from setpoint calculation control.
An excellent initial licensed
operator training program was demonstrated.
In the Safety Assessment/Quality Verification area, management demonstrated a
strong commitment in identifying problems.
Self-assessments were effective in
the areas of root cause evaluation and quality assurance assessments.
Responses to safety initiatives were, in most cases, technically complete and
thorough.
Overview
Performance ratings assigned for the last assessment period and the current
period are shown below.
Functional Area
Rating Last
Period
Plant Operations
I
Radiological Controls
I
Maintenance/Surveillance
2
I
Security
I
Engineering/Technical Support
2
Safety Assessment/Quality Verification 2
III.
CRITERIA
Rating This
Period
I
I
2 Improving
I
I
2
I
The evaluation criteria which were used, as applicable, to assess each
functional area are described in detail in NRC Manual Chapter 0516.
This
chapter is in the Public Document Room files. Therefore, these criteria are
not repeated here, but will be discussed in detail at the public meeting held
with the licensee management.
2
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
This functional area addresses the control and performance of
activities directly related to operating the units, as well as
fire protection.
Unit 1 generally operated well during the assessment period but
was challenged by several equipment-related problems.
Three trips
occurred, one because of a contractor's error and two because of
degraded or failed relays. Several power reductions were
necessary to repair balance of plant equipment including main
feedwater pumps and electrical distribution equipment.
Unit 2 had an excellent operating record during the assessment
period.
Late in the period, the reactor tripped when a main
feedwater pump failed.
Early in the assessment period, after
being on line for approximately seven months, leaking pressurizer
safety valves forced a controlled shutdown for repairs. Toward
the end of the assessment period, a 61-day refueling outage was
completed.
However, the return to power was delayed, and the unit
was operated for the remainder of the period at a reduced reactor
coolant pressure because of pressurizer safety valve leakage.
Management's attention to and involvement in operations were
effective.
Command and control of evolutions was evident, and
shift turnovers and event briefings were effective in
communicating management's expectations. However, early in the
assessment period, operations established an electrical
configuration lineup that resulted in an unacceptable high head
safety injection/charging pump alignment which required additional
management corrective action. Further assessment of this event is
discussed in the Safety Assessment/Quality Verification section of
this assessment.
The licensee's management maintained a low
threshold for identifying problems, and they became aware of an
increasing trend in operator errors. Examples included valve
mispositions, incorrect tagging, and procedural adherence.
None
of these errors caused serious safety incidents but attracted
increased management attention. Corrective actions directed by
management resulted in a significant reversal in the error trend.
Op~rator responses to events continued to be excellent. Operators
were required to respond to four automatic reactor trips during
this period. During one of these trips, a rapid cooldown was in
progress because of a partia~ly opened main steam valve. The
3
operators diagnosed the event and took immediate corrective action
in accordance with the emergency procedures, thereby preventing an
excessive plant cooldown.
When a fitting on a reactor coolant
system letdown line failed, the operators reacted effectively to
isolate the line and minimize coolant loss.
Licensed operator staffing levels were a continuing strength.
Overtime was minimal except during outage periods.
The five
operating shifts had a minimum of four senior reactor operators
and an average of six reactor operators. This staffing level was
more than required by the station Technical Specifications and the
regulations.
In addition, non-shift senior reactor operators were
effectively utilized during refueling outages for oversight and
support of various outage activities. This support lessened the
administrative burden on the shift operating crew, which allowed
them to concentrate on maintaining plant parameters within safe
1 imits.
The fire protection program continued to be well implemented.
Fire brigade members and operators performed well during drills.
Control of ignition sources and combustible materials was
effective. The diesel generator rooms were kept clean, and oil
leaks from the engines were minimized.
With the exception of a
few minor deficiencies, the fire protection system material
condition was very good.
Housekeeping throughout the plant was good during the assessment
period and continued management commitment in this area was
evident.
Improvements in floor, wall, and equipment coatings were
noted.
Roof and ground water leakage continued during this
period.
Some roofing has been replaced, and further repairs are
continuing under a long-term program.
An enhanced ground water
_program was put in place during this period.
The long-term
results have yet to be realized.
Management support of innovative programs and policies
demonstrated a strong conunitment for safe operation of the plants.
These included the areas of decision making, minimizing the number
of alarmed control room annunciators, plant component labeling,
upgraded procedures, excellent outage planning/scheduling methods,
and implementing procedures and methods for expanding the
operations staff capabilities. These are more fully explained
below.
The plant component labeling program resulted in improved labels
and was close to completion during this assessment period.
The
program has progressed to a point where approximately 90 percent
of the labels have been placed on the individual components.
In
order to maintain relabeling program effectiveness, an
administrative procedure was developed and implemented near the
end of the assessment period for maintaining component labeling
and resolving labeling discrepancies.
4
The operations portion of procedures completed in the Technical
Procedures Upgrade Program was slightly less than the program
goal.
However, the updated procedures were generally of good
quality and, when used, required only one-third the number of
changes as compared to non-upgraded procedures.
Part of this
increased quality has been brought about by assigning a senior
licensed operator as operations coordinator and validating these
upgraded procedures by personnel from other operating shifts.
Operations management was sensitive to the safety of shutdown
operations when in the refueling and cold shutdown modes.
A
detailed daily schedule was developed based on outage activities
and included required surveillances and relevant items associated
with the other unit. This schedule listed suggested times and
priorities for activities and gave operations management an in-
depth picture of day-to-day outage activities, thereby improving
safety awareness.
Several methods were used to expand capabilities and broaden the
experience base for operations personnel.
An Operations Review
Board was formed.
It was chaired by the Operations Manager and
included non-licensed and licensed operators. Their functions
were to review and coordinate deviations, commitment tracking,
quality assurance responses and corrective action items, and
requests for engineering assistance projects assigned to the
Operations Department.
Administrative burdens on management were
decreased by the Review Board's establishment. Rotational
assignments to this Board gave participants experience in
resolving problems and interfacing with other departments.
Assignments on this Board also provided valuable training for
current and future operators. Operations management also created
three new positions for senior reactor operators and implemented
rotational assignments in these positions.
One position was as a
member of operations management staff; another was as a shift
maintenance advisor; and the third was assigned special projects,
such as labeling and procedures.
By these innovative programs,
management developed personnel with a broader experience base.
No violations were identified during the assessment period.
2.
Performance Rating
Category:
1
3.
Board Recommendations
None
5
B.
Radiological Controls
I.
Analysis
This functional area addresses those activities related to
radiological controls, radioactive waste management, environmental
monitoring, water chemistry and transportation of radioactive
material.
Management involvement in radiation protection was observed to be
strong. This was evidenced by appropriate staffing levels with
well trained and experienced radiation protection personnel, a
strong as 1 ow as reasonably achievable (ALARA) awareness program,
and management support for proactive dose reduction initiatives
and goals.
Licensee management closely monitored radiation
protection performance through quality assurance based assessments
and ensured effective adherence to radiation protection
procedures. Also, throughout the assessment period, the licensee
took the initiative to involve engineering in radiological
problems.
During the assessment period, the licensee maintained effective
internal and external exposure control programs.
One personnel
exposure in excess of administrative limits occurred during the
period; it was attributed to an isolated case of ineffective
communications and poor procedural adherence. A review of
external exposure controls showed that effective use of alarming
dosimetry prevented exposures in excess of regulatory limits.
The licensee's control of contamination at its source continued to
be aggressive.
The reduction of contaminated areas in the plant
to about one percent of the radiologically controlled area has
contributed to improved equipment access and less personnel
exposure.
Personnel contamination events were commensurate with
the licensee's scope of work and were reduced from 164 during the
previous assessment period to 140 during this assessment period.
During this assessment period, the licensee's program to reduce
out-of-core source term and collective dose continued to be
excellent. Through the effective use of mockup training, close
management of realistic collective dose goals, effective
involvement of coordinators, maximum utilization of the enhanced
surrogate tour for pre-job briefings, and hot spot reduction
efforts, the licensee continued to reduce collective dose.
The
licensee's three-year collective dose average for 1989-1991 was
330 person-rem per unit.
The dose average for 1990-1992 was 289
person-rem per unit. The average dose was reduced even though the
licensee continued to be challenged with potentially significant
dose work such as the removal of resistance temperature detectors.
6
The licensee's program to control quantities of radioactive
material in liquid and gaseous effluents was effective. The
licensee has taken significant steps to control the quantities of
radioactive material released in liquid effluents from the
station. The quantities of radioactive materials released in the
liquid waste stream in 1992 were approximately one-seventh of
those released in the previous year. This significant reduction
was attributed to improved fuel integrity, as well as, the more
efficient treatment and cleanup system in the new Surry Radwaste
Facility, which became operational in November 1991 .. The
significant decrease in radioactive materials in gaseous effluents
in 1992 was also attributed to improved fuel integrity. There
were no unplanned liquid or gaseous radioactive releases during
this assessment period.
The estimated potential doses to the
public resulting from the rele~se of liquid and gaseous effluents
for calendar year 1992 were well below the dose limits specified
by the Technical Specifications and were less than one percent of
the environmental dose limits specified in the regulations.
The licensee experienced operability problems with some effluent
monitors.
The cumulative out-of-service time and extensive
maintenance on the Waste Gas Holdup System Hydrogen Monitoring
Instrumentation System eventually resulted in the system being
inoperable for greater than 30 consecutive days.
During this
assessment period, there were continuing short-term operability
problems with both units' Circulating Water Discharge Radiation
Monitors because of electronic spiking, water/moisture intrusion,
and high radiation alarm setpoint problems.
In addition, the
licensee experienced electronic spiking and automatic flow control
problems with the stack radiation monitors and moisture intrusion
problems in the sampling lines of the Process Vent monitors.
These problems indicate a need for increased attention to these
radiation monitors.
During this assessment period, the licensee performed audits of
radiological effluents, the Offsite Dose Calculation Manual, the
Process Control Manual, environmental monitoring, and radioactive
materials management.
The audits were technically sound and well
documented.
The problems identified were of low safety
significance and were adequately addressed.
The licensee's program for processing, packaging, storing and
shipping radioactive solid wastes was effective. The technicians
who performed radioactive waste shipments were adequately trained
and performed their duties competently. Daily solid waste
generation has been reduced through aggressive management
attention, information campaigns, minimizing the use of herculite,
recycling tent enclosure materials, preventing equipment packing
material from entering containment, and use of a radiological
waste inventory tracking program.
One violation was identified-during the assessment period.
7
2.
Performance Rating
Category:
I
3.
Board Recommendations
None
C.
Maintenance/Surveillance
1.
Analysis
This functional area addresses those activities related to
equipment condition, maintenance, surveillance performance, and
equipment testing.
Overall plant material condition was good.
Significant
improvements included modifications to remove the resistance
temperature detector bypass lines, repairs and modifications to
the containment ventilation system, and extensive repairs to the
Unit 2 containment airlock. Although not complete, improvements
were noted for several other degraded material conditions being
addressed as part of a five-year plan. These included ground
water and roof leaks and service water intake structure
degradation.
The availability and reliabi.lity of the control room
and emergency switchgear room cooling system continued to be
impacted by the material condition of the service water supply
strainers and the chiller units. Modifications to add two more
chiller units and implementation of recent Technical Specification
changes that provide greater operational flexibility for the
service water system to allow needed maintenance, are two of the
improvements currently being implemented to resolve this issue.
Additionally, material condition problems with radiation monitor
failures and pressurizer safety valve leakage continued to
challenge the operators.
An upward trend in relay failures was
noted, and several of these failures resulted in two Unit I
reactor trips in 1993.
The single point failure analysis and
preventive maintenance review commissioned by the licensee were
two actions initiated to facilitate early correction of this
degrading material condition trend. Furthermore, management's
commitment to improvements in all areas of plant material
condition was demonstrated by their policy to restore or repair,
during outages, balance of plant components that were temporarily
repaired while operating.
Staffing levels in the Maintenance Department were adequate
throughout the assessment period. Maintenance engineering
staffing was adjusted to reduce the backlog of Cause Determination
Evaluations that was noted in the previous assessment.
At the end
of the assessment period th~ backlog had been reduced from 400
8
to 21, indicating management focus and attention to this area.
The evaluation quality remained good.
Although the maintenance qualification and training program
continued to produce knowledgeable and skilled craftsmen, several
performance problems that involved failure to adhere to
administrative procedures were noted.
Examples included: failure
to verify independently the placing of danger tags and lifting a
wrong lead that caused the isolation of component cooling to the
residual heat removal heat exchanger during system operation.
Post maintenance testing program problems noted in the previous
assessment were not apparent during this period.
Instrumentation
and control equipment that was previously not included in the
program was gradually being added to the data base.
Improvements in the quality of maintenance procedures that were
upgraded through the technical procedure upgrade program were
noted.
The program was proceeding on schedule, but the
instrumentation and control effort was somewhat behind schedule
because of a lack of engineering support in providing the
instrument scaling factors and setpoints necessary for procedure
upgrade.
Management recognized these obstacles to meeting program
goals and made necessary adjustments by assigning additional
procedure writers. Engineering priorities were modified to
provide scaling factors and setpoints in a manner that would
complement the procedure upgrade efforts. There were craft
performance problems noted that were sometimes related to the
quality of non-upgraded procedures.
For example, the positioner
feedback bracket for the main steam power operated relief valve
was not reconnected and the stroke adjustment instructions
conflicted with the vendor's manual.
The backlog of non-outage-related corrective maintenance work
orders was reduced by approximately one-half during this
assessment period, and the average age of the outstanding work
orders was also reduced by approximately one-half. Problems
associated with availability of parts and lack of planning support
that were noted in previous assessments were not major
contributors to the backlog.
Improvements were noted in the Outage Planning and Scheduling
Department's performance during refueling outages. The Unit I and
Unit 2 refuelings were accomplished on time without the need to
operate in reduced inventory conditions with fuel in the reactor
vessel.
An innovative outage scheduling method was developed that
assigned a risk rating factor to work activities being planned.
This method provided a visual display of risk parameters and was
modeled to allow the planner to see the impact of planned
maintenance or modifications on critical outage plant parameters
such as electrical distribution, containment integrity and heat
removal.
For example, all maintenance items that required reduced
9
D.
inventory were rated as red and were scheduled when fuel was
removed from the reactor vessel, thereby reducing risk.
Surveillance program implementation improved from the previous
assessment period. Several technically inadequate procedures,
used to satisfy Technical Specification requirements, were
identified by the licensee through their on-going program and
reported as missed surveillances.
Each time surveillances were
determined to be inadequate they were modified and appropriate
retesting was performed.
Strengths were noted in the non-
intrusive testing of check valves connected to the reactor coolant
system.
Use of this new method resulted in reducing radiation
exposure and the need for a reduced inventory evolution.
Good implementation of the inservice inspection program was noted
during this assessment period.
The procedures, examination
techniques, and documentation of examination results were good.
Supervisors, engineers, and non-destructive examination examiners
were knowledgeable in their respective areas. Only a few minor
problems were identified and they were associated with procedural
adherence during piping examinations.
The flow-assisted corrosion program was proactive and well
implemented.
Industry developed computerized programs, CHECMATE
and CHEC-NDE, were being used.
Over 5000 components per unit were
included in the program.
The program has strong corporate and
site support with dedicated resources and was well documented in
corporate standards and site procedures. Degraded piping has been
routinely identified and replaced with upgraded materials.
One violation was identified during the assessment period.
2.
Performance Rating
Category:
2 Improving
3.
Board Recommendations
None
1.
Analysis
This functional area addresses activities related to the execution
of the Emergency Plan and its implementing procedures, including
licensee performance during emergency exercises and actual events,
interactions between onsite and offsite emergency response
organizations during exercises and actual events, and support and
training of emergency response personnel.
10
Management support and involvement in the emergency preparedness
program were evident by the variety of drills conducted and the
emergency facility and equipment improvements made during the
assessment period.
The licensee continued to maintain emergency
response capability in a state of operational readiness. Staffing
of the emergency preparedness function continued as a program
strength because an effective base of expertise was maintained
intact at the station and at corporate headquarters.
The
licensee's corrective action program for resolving emergency
preparedness issues and inspection findings was very thorough and
effective. Other identified program strengths included a
comprehensive independent audit function and a thorough system of
surveillances of emergency response facilities and equipment.
During the annual emergency response exercise in November 1992,
the licensee demonstrated a capability to effectively implement
the Emergency Plan in response to the simulated accident scenario.
The scenario appropriately challenged the licensee's emergency
response organization. The licensee demonstrated the ability to
identify emergency conditions, to make correct classifications in
accordance with Emergency Plan implementing procedures, and to
take appropriate measures to mitigate the adverse consequences of
degraded plant conditions. Timely activation and capable support
operations were observed at each of the emergency response
facilities. The licensee had two procedures for making Protection
Action Recommendations which were not internally consistent.
Additionally, the licensee did not always follow these procedures
for developing the recommendations.
The licensee made extensive
procedural improvements following a review of the methodology for
deriving protective action recommendations.
This issue was
resolved prior to the end of the current appraisal period.
The licensee maintained emergency facilities, equipment,
instrumentation and supplies in a state of readiness with thorough
equipment inventories, and adequate surveillances and functional
tests. A new, more suitable location for the alternate
Operational Support Center was identified and established,
resulting in a significant improvement in this capability. During
the previous appraisal p~riod, the licensee fully implemented an
upgrade of the offsite siren system through the addition of a
computerized feedback capability to monitor each siren's operation
during any mode of testing or activation. The siren availability
factor was in excess of 99 percent during 1992, a condition
attributed to the feedback system.
During this appraisal period, no emergency declarations were made,
and no violations or exercise weaknesses were identified.
2.
Performance Rating
Category: 1
11
3.
Board Recommendations
None
E.
Security
1.
Analysis
This functional area addresses those safeguards activities
associated with the plant's safety-related vital equipment, the
accountability of special nuclear material, and the effectiveness
of the licensee's Fitness-For-Duty Program.
The licensee's enhancement of security facilities and equipment
and the effective utilization of security resources contributed
significantly to the security force's capability to protect the
station's vital resources, to respond to unscheduled contingencies
and to have a low incidence of safeguards events.
Staffing of the security organization remained at sufficient
levels during this assessment period. The security force
continued to perform in a professional manner and was provided
dedicated support by site and corporate management.
The continued
low turnover rate of the security force was attributed to
management support and effective supervision.
During this assessment period, the licensee continued to refine
and enhance the effectiveness of the security program through
employment of progressive and innovative techniques to improve
personnel and system performance. These actions included
establishment of a computerized tracking program for maintenance
of security systems and equipment and the installation of vehicle
barriers at the two vehicle gates in the protected area barriers.
A Backup Central Processing Unit was acquired to serve as a
training simulator for new alarm station operators and as a backup
to the operational security computer system in the event of
failure or malfunction.
The barriers installed at the vehicle
gates, designed by the security force, consisted of aircraft
arresting cable, uniquely installed in a manner to preclude or
delay unauthorized vehicle entry.
Installation of the barriers at
the vehicle gates completed establishment of vehicle barriers at
all approachable areas of the protected area perimeter.
In the
area of personnel performance enhancement, several recognition
programs were established including: High Academic Achievement,
High Tactical Achievement and Semi-Annual Security Shift Awards"
The security training program was well planned and executed.
Continued site and corporate management support was evident as
demonstrated by the new training facility. A major strength of
the security training program was the realistic, contingency
tactical drills utilizing Multiple Integrated Laser Engagement
equipment.
Recent drill scenarios were developed and exercised
12
based on information from industry lessons learned contained in
NUREG-1485, "Unauthorized Forced Entry into the Protected Area at
Three Mile Island." Security personnel were provided Basic and
Fundamental System Training to enhance their knowledge and assist
in applying protection strategies. Of specific significance was
the ongoing joint operations/security training scenarios developed
and conducted in the station's training simulator to focus on
communications and developing cohesive relationships in
identifying weaknesses and responding to threats.
The licensee's corporate quality assurance organization continued
to conduct aggressive audits of the security program.
In
addition; internal audits of security programs and security force
activities were conducted by station personnel to evaluate
performance effectiveness, compliance, and site-specific
requirements.
The security organization developed and implemented
an Internal Safeguards Information Audit Program to examine and
evaluate on an annual basis, the handling, control and storage of
Safeguards Information.
As a result of the audit the volume of
safeguards material at the station was reduced by approximately 40
percent.
The licensee's programs continued to be effective in meeting
objectives for Fitness-For-Duty, access authorization and the
prevention of the introduction of contraband items into the
protected area. Reportable events were thoroughly addressed and
reported in a timely manner.
The security force continued to .track and trend safeguards events,
maintenance and priority projects utilizing a computerized data
base.
The licensee did not experience any I-hour reportable
Safeguards Events during the assessment period. A total of 19
Loggable Safeguards Events were documented for the second quarter
of calendar year 1993. Several of these events, related to access
control equipment failure, were attributed to aging of the
existing security access control system.
However, the number of
loggable events remained low.
No violations were identified during the assessment period.
2.
Performance Rating
Category:
1
3.
Board Recommendations
None
13
F.
Engineering/Technical Support
I.
Analysis
This functional area addresses activities associated with the
design of plant modifications, and technical support for
operations, outages, maintenance, and licensed operator training.
The licensee's performance in providing engineering and technical
support was generally good during this assessment period, but some
weaknesses were identified in the Engineering Department's support
of operations and maintenance activities.
Engineering support for plant modifications was excellent; the
quality and technical content of temporary and minor modifications
were generally good.
An example of strong engineering support to
modifications was DCP 91-12, RSHX Service Water Flow Element
Modifications, Units 1 and 2.
Another example of proactive
engineering involvement was demonstrated by the Engineering Work
Request program and the Design Change Package backlog reduction
program.
The licensee implemented a Level I Project Modification
Package Backlog Reduction program designed to reduce the backlog
from the 333 in August 1992 to 150 by June 1993.
The backlog
reduction was on schedule as of April 1993 with 172 packages
remaining in the backlog population.
However, a problem was
identified with updating design drawings within the required time
period following the implementation of two design changes.
Engineering and technical support to operations and maintenance
activities were generally good during this assessment period.
Examples of good engineering support included the timely and
effective engineering support provided to assess the pressurizer
safety relief valve issue and in resolving and reducing both
deviation reports and requests for engineering assistance. The
various engineering groups worked well together to resolve complex
problems that could have potentially affected plant operations.
However, some examples of weak engineering support were also
identified. One included an engineering personnel error which
subsequently led to a safety injection because of a spurious
signal generated after replacing a defective relay during the
return of a high consequence limiting safeguards circuit to
normal. Another included a failure during the Unit 2 refueling
outage to control motor operated valve setpoints adequately. A
significant example of weak engineering support was demonstrated
by the licensee's failure to correct weaknesses in setpoint
control identified during the last SALP assessment period.
Inconsistencies between plant instrumentation and channel
statistical allowance calculations continued during this
assessment period. Also a loss of coolant accident reanalysis was
required during this assessment period because of NRC-identified
14
G.
inadequate acceptance criteria for a shortfall of required flow
from one low head safety injection pump.
From January 1992 to May 1993, a total of 654 deviation reports
were assigned to station engineering to resolve.
Engineering was
overdue in responding to 16 deviation reports in 1992.
There have
been no late responses for 1993 through the end of the assessment
period. System engineering involvement was instrumental in
reducing the numbers of deviation reports and requests for
engineering assistance. Satisfactory engineering training was
also demonstrated by the performance levels obtained during this
assessment period.
The licensee's Self-assessment Program included appraising
engineering programs during this assessment period.
Licensee
quality assurance audits of engineering activities verified that
the conduct of these activities demonstrated the licensee's
commitment to improving the quality and effectiveness of
engineering support provided to the plant.
An excellent initial licensed operator training program was
demonstrated during the assessment period as evidenced by the fact
that all candidates passed the Generic Fundamental Examination
Section and initial licensing examination.
The NRC also
administered requalification examinations to 15 operators.
Fourteen of fifteen operators passed the examination. There was
an improvement in administering the process compared to previous
requalification examinations.
The simulator was used effectively
for training. The licensee's simulator instructors were
knowledgeable of the simulator and plant operations. The
simulator adequately modeled scenario events.
One violation was identified during the assessment period.
2.
Performance Rating
Category:
2
3.
Board Recommendations
None
Safety Assessment/Quality Verification
I.
Analysis
This functional area addresses those activities related to
licensee implementation of safety policies; amendments, exemptions
and relief requests; response to Generic Letters, Bulletins, and
Information Notices; resolution of safety issues; safety review
committee activities; and the use of feedback from self-assessment.
programs and activities.
15
A multi-tiered program consisting of both corporate and station
resources was effectively utilized to accomplish safety assessment
and quality verification activities. The Nuclear Business Plan,
Nuclear Oversight Board, Management Safety Review Committee,
Corporate Nuclear Safety, Nuclear Quality Assurance, Management
Review Board, Station Nuclear Safety and Operating Conunittee, and
Station Nuclear Safety incorporated all levels of corporate and
station management in ensuring safe operation. Corporate Nuclear
Safety Integrated Trend Reports, quality assurance assessments,
Management Review Board Performance Annunciator Windows, and the
Station Nuclear Station Deviation Trend and Nuclear Safety
Assessment Reports were examples of self-assessment activities
that were effective in monitoring and evaluating plant performance
and following up with corrective action recommendations when
prriblems were identified.
Human performance problems in the areas
of tagging components, work practices, and recurring equipment
problems, including those associated with radiation monitors and
control room chillers, were identified by these self-assessment
programs.
Staffing and training of self-assessment programs were
superior. These self-assessment programs significantly exceeded
technical specification requirements, and management encouraged
employees to visit counterparts at other nuclear plants to compare
programs and identify possible improvements.
In general, management demonstrated a strong commitment in
identifying problems, but in some instances such as ground water
intrusion, radiation monitor failures, control room chiller
failures, and pressurizer safety valve seat leakage, permanent
corrective actions entailed long-term program commitments.
Therefore, these problems continued to occur throughout the
assessment period, carrying over from previous periods.
Long-term
corrective actions associated with other problems such as the
resistance temperature detector bypass manifold, instrument air
system, containment ventilation system and containment personnel
access hatch were effective once they were fully implemented.
Deviation report trending and the Integrated Trend Report improved
identification of recurring problems. Corrective actions
implemented to verify proper operation of steam traps in the steam
supply lines to the turbine-driven auxiliary feed pumps and
replacing injection/charging pump lube oil temperature control
valves were examples of recurring problems that were adequately
resolved. It was noted during the last assessment period that
Corporate Nuclear Safety recommendations from older event reviews
had not been verified as being completed. This area was reviewed
during this assessment period and considered acceptable.
Self-assessments were effective in the areas of root cause
evaluation, quality assurance assessments and methodologies and
approaches for assessing quality assurance and station
performance, Startup Assessment Program, shutdown management,
post-trip review, operationa~ and event review, and Level I
16
Project Tracking.
During the assessment period, the quality of
licensing basis documents improved.
The Updated Final Safety
Analysis Report and Design Basis Document improvement programs
continued to progress and a Technical Specification review program
was implemented.
Weaknesses were identified in the areas of long-
term corrective actions for improper high head safety
injection/charging pump configuration, safety evaluation screening
and commitment tracking system.
Improper high head safety
injection/charging pump configuration resulted in degraded safety
system capability. During the previous assessment period,
enforcement action was taken for a similar occurrence. Although
the impact of these events was similar, they had different root
causes.
The problem was attributed to inadequate change control,
and the licensee implemented appropriate corrective action.
Deficiencies were noted with safety evaluations for certain
procedures that were used to operate plant systems differently
than described in the Updated Final Safety Analysis Report, and
several commitments were closed without performing the required
actions.
Throughout the period, management continued to maintain a low
threshold for identifying problems.
Station deviations were
written by station personnel whenever they perceived that a
problem existed. The improper high head safety injection/charging
pump configuration was identified by the licensee. Station
deviations provided a major input to the licensee's self-
assessment programs.
The details and quality of the safety reviews conducted by the
Management Safety Review Committee and Station Nuclear Safety and
Operating Committee in this assessment period were good.
The
Management Safety Review Committee was sensitive to operator
errors and members were objective in evaluating Technical
Specification changes.
The Station Nuclear Safety and Operating
Committee effectively monitored proper implementation of the
corrective actions associated with deviation reports as well as
evaluating substitution of manual manipulation for automatic
actions.
During the assessment period, a significant effort was expended in
the licensing area in which the licensee was aggressive in
providing the necessary information to resolve issues effectively.
Frequent meetings and discussions between licensee and staff were
also held to address licensing and other technical issues. The
licensee's submittals continued to be timely and of high quality,
reflecting an in-depth understanding of the technical issues and
regulatory requirements as well as an effective oversight review
process.
Examples of high quality submittals were amendments
relating to upgrading of Section 4.0 of the Technical
Specifications, non-essential service water isolation actuation
logic, and changes in acceptance criteria for mechanical snubbers.
Another example of a high quality submittal was the May 10, 1993,
17
request to change a prior commitment relating to the station
blackout rule. This submittal was clear, accurate and of
sufficient detail to allow the NRC staff to make an evaluation
without a request for additional information.
The continued use of the "top 10" licensing issues management
scheme was a very effective tracking system which focused
attention on those issues judged to be of high priority to both
the licensee and the NRC staff. The "top 10" list appropriately
balanced safety significance and cost benefit considerations. The
"top 10" list was continually updated, in coordination with the
staff, as issues were brought to closure and new issues arose.
Safety reviews by on-site and off-site safety groups continued to
be accomplished in a manner that provided assurance that the
proposed activities were properly analyzed and did not compromise
the safe operation of the plant.
Responses to NRC Bulletins, Generic Letters, and other regulatory
requests were, in most cases, technically complete, and thorough.
The quality and the timeliness of Licensee Event Reports were very
good during this assessment period.
The reports were well written
and provided objective assessments of the root causes of events,
their safety significance, and corrective actions.
Two violations were identified during the assessment period.
2 *.
Performance Rating
Category:
1
3.
None
Board Recommendations
V.
SUPPORTING DATA AND SUMMARIES
A.
Major Licensee Activities
Unit 1 began the assessment period, April 5, 1992, in a refueling
outage.
The outage was completed in May and the unit returned to
service at that time. Operation of the unit was inconsistent and
resulted in three reactor trips, caused respectively by personnel error
and degraded relays, and balance of plant equipment problems including
main feedwater pumps and electrical distribution equipment.
At the end
of the assessment period, July 3, 1993, the unit was in service.
Unit 2 began the assessment period, April 5, 1992, in service. In
February 1993 a coastdown for a refueling outage started, and after 230
consecutive days of being in service, the unit shut down for refueling
in March 1993.
The outage was completed in May 1993 and the unit
returned to service. The unit ha~ one reactor trip on June 20, 1993
18
resulting from the failure of a main feedwater pump.
The unit returned
to service the same day and operated at reduced power for the remainder
of the assessment period while repairs were being made to the main
feedwater pump.
Management and/or organizational changes instituted by the licensee
during the assessment period:
September 1992 - L. M. Girvin became the Vice President, Nuclear
Services.
September 1992 - E.W. Harrell became Vice President, Nuclear
Engineering Services.
September 1992 - F. K. Moore became Vice President, Procurement.
January 1993
- T. E. Capps became Chairman of the Board of
Dami nion Resources.
The following major activities and modifications of both units were
completed during this assessment period:
Construction continued on a new mechanical equipment room to*
accommodate two new control room and emergency chillers.
New design rotating screens were installed in the high and low
level intake structures.
The resistance temperature detector bypass loops were removed.
Replacement of the roofs on the auxiliary building, Unit 2 valve
pit and fire pump building continued in an effort to minimize
rainwater and groundwater leakage into the facility on safety-
related components.
The containment ventilation systems were modified to reduce the
likelihood of control rod drive failures due to overheating.
Recirculation spray heat exchanger service water V-cones were
installed to improve flow instrumentation readings.
Service water piping inspection and coating were completed.
The following major activities and modifications of Unit 2 were
completed during this assessment period:
A cold leg safety injection check valve was replaced without going
to reduced inventory when fuel was removed from the reactor
vessel.
Hinges on the containment personnel hatch outer door were replaced
along with the escape hatch und equalizing valves.
19
The five year main turbine overhaul was performed.
High head safety injection/charging pump under-voltage trip was
modified.
B.
Major Direct Inspection and Review Activities
During this assessment period 29 inspections were conducted by resident
and regional-based inspectors.
Nine meetings were held with licensee
management, including one Enforcement Conference.
C.
Escalated Enforcement Action
An Enforcement Conference was held in the Region II office on
June 10, 1992 associated with the electrical configuration lineup for
high head safety injection pumps such that Technical Specification
operability of the pumps in the automatic mode was defeated.
On
July 13, 1992, a Notice of Violation and a Proposed Imposition of Civil
Penalty was issued in the amount of $50,000.
The licensee acknowledged
the violation and paid the penalty on August 12, 1992.
D.
Licensee Conferences Held During Appraisal Period
July 31, 1992 - Meeting at Region II's office, Atlanta, Georgia, to
discuss several topics including operation and key indicators, the
surveillance and updated final safety analysis reviews, and the
precursor trending program.
The meeting was also used to introduce the
new Vice-President of Nuclear Services (Mr. L. M. Girvin).
August 5, 1992 - Meeting in Rockville, Maryland to discuss accumulation
of gas in low-head safety injection piping.
September 24, 1992 - A counterpart meeting at Virginia Electric and
Power Co.'s offices, Glen Allen, Virginia, to discuss current issues,
open enforcement conferences, ASME Code relief philosophy, licensing
activities overview, status of hydroid growth problems and Updated Final
Safety Analysis Report upgrade program.
December 7, 1992 - Meeting in Rockville, Maryland to discuss initiatives
for reducing regulatory requirements marginal to safety, optimization of
nuclear oversight activities and top ten licensing priorities.
March 24, 1993, Meeting at Region Il's office, Atlanta, Georgia, to
discuss the self-assessment results.
April 21, 1993 - Meeting at Rockville, Maryland to discuss reassessment
of the need for installing one, versus two, non-safety grade diesel
generators to mitigate the effects of a station blackout.
April 30, 1993 - Meeting at Rockville, Maryland to discuss the new
approved nuclear separate business unit and the initiative for reducing
regulatory requirements marginal to safety.
20
May 3, 1993 - Meeting at Region !I's office, Atlanta, Georgia, to
discuss the Design Basis Documentation Program and corrective actions on
identified findings.
E.
None
F.
Confirmation of Action Letters
Review of Licensee Event Reports
During the assessment period, a total of 21 Licensee Event Reports were
analyzed.
The distribution of these events by cause, as determined by
the NRC staffr is as follows:
G.
Cause
Unit I or Both
Unit 2 Totals
Component Failure
4
5
9
I
Design
I
Construction, Fabrication
or Installation
Personnel Error
Other
Total
- Operating Activity
2
- Maintenance Activity
1
- Test/Calibration
Activity
3
- Other
2
13
3
8
2
4
3
2
21
Note I: With regard to the area of "Personnel Error," the
NRC considers lack of procedures, inadequate procedures, and
erroneous procedures to be classified as personnel errors.
Note 2:
The "Other" category is comprised of Licensee Event
Reports where there was a spurious signal or a totally
unknown cause.
Note 3:
The above information was derived from a review of
Licensee Event Reports performed by the NRC staff and may
not completely coincide with the licensee's cause
assignments.
Licensing Activities
During the assessment period, a significant effort was expended in the
licensing area which resulted in the issuance of 23 license amendments,
15 reliefs, and 42 other licensing actions.
21
("* ... ,
- .
H.
Enforcement Activity
FUNCTIONAL
AREA
NO. OF VIOLATIONS IN SEVERITY LEVEL
IV
III II I
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical
Support
Safety Assessment/
Quality Verification
TOTAL
I.
I
I
I
1
4
1
I
May 7, 1992, Unit I Turbine Trip/Reactor Trip:
The unit had an automatic turbine trip followed by a reactor trip when
contractor maintenance personnel improperly attempted to stop an oil
leak on the thrust bearing test valve.
The unit was restarted the same
day.
January 8, 1993, Unit 1 Reactor Trip/Safety Injection:
While securing from a scheduled High Consequence Limiting Sequence on
Train A (degraded relay replacement), the unit tripped from 100% power
and a safety injection was initiated. A second safety injection was
initiated during the performance of corrective action for the first
event.
February 9, 1993, Unit 1 Reactor Trip:
During the process of securing from a monthly PT for testing reactor
trip breakers, a degraded relay caused the reactor to trip
automatically.
(The trip occurred simultaneously with the opening to
the '8' bypass breaker; the degraded relay was associated with the 'A'
reactor trip breaker train.)
June 20, 1993, Unit 2 Automatic Reactor Trip:
After loss of a main feedwater pump on an instantaneous ground, an
automatic reactor trip occurred on steam flow/feedwater flow mismatch in
coincidence with low steam generator water level in steam generator A.
22