ML20117M362
| ML20117M362 | |
| Person / Time | |
|---|---|
| Site: | Brunswick, 05000000 |
| Issue date: | 01/11/1984 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20117M360 | List: |
| References | |
| FOIA-84-652 NUDOCS 8505170018 | |
| Download: ML20117M362 (19) | |
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-AGENDA PERFORMANCE OVERVIEW BRUNSWICK NUCLEAR PROJECT January 11, 1984 ."
-0 WELCOME . ' Howe .
8 INTRODUCTION - Dietz 8 BSEP UNIT SUMMARIES o Operations i Chase o Maintenance Dimmette o E8RC .
Cheatham o Technical Support -
Bishop
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Regulatory Compliance o Enzer o Administration Beyer ek 0 SUPPORT UNIT SUMMARIES l 0 Training Hopkins o QA/QC Jongs
- . o Onsite Nuclear Safety Helme O CLOSING REMARKS .
Howe g 51 g 8 841019 EDDLEMA84-652 PDR
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' REGULATORY COMPLIANCE O SURVEILLANCE TEST _AND SCHEDULING TRACKING SYSTEM (STST)
O CENTRALIZED RESPONSIBILITY O COMPUTER BASED SYSTEM 0 NO VIOLATIONS NOTED TO DATE O FACILITY-AUTO l1ATED COMMI_TMENT TRACKING SYSTEM (FACTS)
O COMPUTER BASED SYSTEM 0 IMPROVED CONTROLS / MANAGEMENT REPORTING O HISTORICAL DOCUMENTS REVIEW 0 TECHNICALSPECIFICATIONSUPGRAHE O CURRENT T/S IMPROVEMENTS O T/S IMPROVEMENT PROGRAMS 0 PROCEDURAL DEVELOPMENT ;
O REGULATORY PROCEDURES DEVELOPED 0 REGULATORY PROCEDURES CENTRALIZED 0 STAFFING 0 INCREASED FROM SIX IN 1982 TO ELEVEN IN EARLY 1983
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REGULATORY COMPLIANCE (cont.)
0 MAJOR If1PROVEf1ENTS 0 STAFFING O FACTS /STST 0 PROCEDURE DEVELOPMENT 0 MAJOR CHALLEi4GES FOR 1984 0 TECHNICAL SPECIFICATION IMPROVEMENTS 0- MONITORING ATTENTION TO DETAIL IN PROCEDURE IMPLEMENTATION .
O PROVIDE INCREASED TECHNICAL DEPTH TO REGdLATORY COMPLIANCE ACTIVITIES /0RGANIZATION Y
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ENVIRONMENTAL & RADIATION CONTROL ,
1983 ACCOMPLISHvENTS
. STAFF
-0 APPROXIMATELY 50%
THE.ESRC UNIT IS CURRENTLY FULLY STAFFED.
OF THE TECHNICIANS ARE ANSI 00ALIFIED.
0 EACH SUPERVISOR IS REQUIRED TO BE OUT IN THE PLANT DAILY AND DOCUMENT HIS INSPECTION.
-0 EACH PROFESSIONAL MEMBER OF THE TECHNICAL SUPPORT STAFF IS REQUIRED TO PERFORM A WEEKLY FORMAL INSPECTION.
0 1983 NRC INSPECTIONS O EIGHT INSPECTIONS (APPROXIMATELY 250 MAN-HOURS) 0 TWO VIOLATIONS - LEVEL IV SHIPPING PAPERS ON A RADIDACTIVE WASTE SHIPMENT INADEQUATE AIR SAMPLE .
RADh'ASTE VOLUME REDUCTION O FORMAL PROGRAM 0 EDUCATION 0 TECHNIQUES .
O DRUM COMPACTOR ,
O MONITORING / SORTING PROGRAM FOR LOW LEVEL DAh'
'O USE OF CLOTH (LAUNDERABLE) VERSUS DISPOSABLE MATERIALS 0 RESTRICTION OF MATERIALS.FROM POWER BLOCK MULTI-TLD BADGING FOR EXPOSURE CONTROL-0 TO PROVIDE FOR POSITIVE E,XPOSURE CONTROL IN NONUNIFORM RADIATION FIELDS ENCOUNTERED DURING UNIT NOS. 1 AND 2 OUT
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0 UP TO 300 WORKERS PER MONTH WERE MONITORED WITH MUL
' BADGES.
ENVIRONMENTAL & RADIATION CONTROL 1984 G0ALS RADWASTE VOLUME REDUCTION 0l CENTRAL 12ED PROCESSING FACILITY 0 ADDITIONAL EQUIPMENT 0- BOX COMPACTOR 0 . SHREDDER 0 WOOD PLANER 0 GOAL FOR 1984 0 35% REDUCTION FROM 1983 INSTRUMENTATION
- 0 MODIFY EXISTING CAllBRATION FACILITY TO PROVIDE T
-CAllBRATION AND BETTER IDENTIFY BETA SPECTRUM.
O PURCHASE TV CAMERAS TO MONITOR WORK l'N HIG 7
0 PURCHASE AND INSTALLAT10h 0F A RESPIRATOR DEC FACILITY. ,
- CHEMISTRY
. O B0P IMPROVEMENTS 0 INSTALLATION OF A FILTER AND CHEMICAL CONTRO THE~IBCCW. .
POND MODS O COMPLETION OF THE STORM DRAIN BASIN AND SP0ll SUCH THAT AUTOMATIC OPERkTION OF THE BASIN .
POSSlBLE.
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ENVIRONMENTAL & RADIATION CONTROL .
1983 ACCOMPLISW ENTS STAFF
'O THE EERC UNii IS CURRENTLY FULLY STAFFED. APPROXIMATELY 50%
LOF THE TE HNICI ANS ARE ANSI QUALIFIED.
O. EACH SUPERVISOR IS REQUIRED TO BE OUT IN THE PLANT DAILY AND DOCUMENT HIS INSPECTION.
~0 .EAChPROFESSIONALMEMBEROFTHETECHNICALSUPPORTSTAFF IS REQUIRED TO PERFORM A WEEKLY FORMAL-INSPECTION.
0 1983 NRC INSPECTIONS 0 EIGHTINSPECTIONS(APPROXIMATELY250MANh00RS)
O TWO VIOLATIONS : LEVEL'IV SHIPPING PAPERS ON A RADIOACTIVE WASTE SHIPMENT INADEQUATE' AIR SAMPLE .
RADWASTE VOLUME REDUCTION 0 FORMAL PROGRAM-0 EDUCATION 0 TECHNIQUES ;
O DRUM COMPACTOR ,
O' MONITORING / SORTING PROGRAM FOR LOW LEVEL DAW 0 USE OF CLOTH (LAUNDERABLE) VERSUS IIISPOSABLE MATERI ALS 0 -RESTRICT 10N OF MATERI ALS,FROM POWER BLOCK MULTI-TLD_BEGING FOR EXPOSURE CONTROL 0 TO PROVIDE FOR POSITIVE E,XPOSURE CONTROL IN NONUNIFORM RADI ATION FIELDS ENCOUNTERED DURING UNIT NOS.1 AND 2 OUT b UP TO 300 wo:MERS PER MONTH WERE MONITORED WITH MULT1-T EADGES.
ENVIRONMENTAL & RADIATION CONTROL 1984 G0ALS R DWASTE VOLUME REDUCTION 0 CENTRALIZED PROCESSING PACILITY 0 ADDITIONAL EQUIPMENT o ' BOX COMPACTOR 0 . SHREDDER 0 WOOD PLANER 0 GOAL FOR 1984 I
O '35% REDUCTION FROM 1983
]
INSTRUMENTATION 0 . MODIFY. EXISTING CAllBRATION FACILITY TO PROVIDE TWO-POINT CAllBRATION AND BETTER IDENTIFY BETA SPECTRUM.
O PURCHASE TV CAMERAS TO MONITOR WORK IN HIGH RADIATION AREAS.
.0 PURCHASE AND INSTALLATION OF A RESPIRATOR DECONTAMINATION FACILITY.
CHEMISTRY .
0- BOP IMPROVEMENTS' O INSTA'LLATION OF A FILTER AND CHEMICAL CONTROL SYSTEM IN THE IBCCW. .
0 COMPLETION OF THE STORM DRAIN BASIN AND SP0ll POND MODS
.. - - SUCH THAT AUTOMATIC OPERhTION OF THE BASIN DISCHARGE IS POSSIBLE.
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. WORK FORCE MANAG986
. O BEFORE O ACTIO'l ITEM LISTS WERE PAW /NOT UP TO DATE O APPARENT PROBLEM EXISTED, BIR.NOT WELL DEFINED 0 NOW .
O WORK FORCE FANAGEMENT GROUP ESTABLISHED PROVIDING SINGLE PolhT FOR ALL INCOMING /0UTGOING COMMITTENTS O ALL LISTINGS CONSOLIDATED /COM UTER DATA BASED 0 EACH SUPERVISOR RECEIVES WEEKLY STATUS REPORTS, INCLUDIAG A
, PRIORITY REPORT -
0 . TRENDING ESTABLISHED ,
O }NPUT VERSUS OUTPUT r .-
- s. . O PERFORf'ANCE ,_ .
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/ 0 . ACTION}TEMTASKFORCEESTABLISHb
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- 0. 6 EN3INEERS . .
0 9- TO 12-mNTH PROJECT ,
. O -VANAGEMENT BY EXCEPTION IN PLACE O ME -
O VANAGEtGNT BY DIRECTION
. .0 ENGINEERS AND SUPERVISORS WILL HAVE LIVING SCHEDULE O ENABLE REALISTIC ASSESSMENT OF COMPLETION DATES
- 2 .
. ISI o BEFORE .' '
o 1 To 2 PEOPLE ASSIGNED TO ISI o PROGRAM DEVELOPMENT BY OUTSIDE CONTRACTOR
'o HIGH COVTAltNENT LEAKAGES (- 150 SCFH) o NO VT PROGRAM ,
o NJd o 9 CPal PEOPLE IN ISI .
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o' ENTIRE PROGRAM HAS BEEN REVIEWED / REVISED--CONTAltNEMT
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PENETRATIONS / TESTING VERIFIED o SIGNIFICANT SCOPE OF INSPECTIONS DONE DURING LAST REFUELING ON .
UNIT NO. 1 .
.o REDUCEDTOTALCONTAlfNENTLEAKAGETOi95SCFH. ,
, o. ESTABLISHED VT PROGPM AND OWN EPRI QUALIFIED INSPECTORS ~
. O IN HOUSE TRAINING ON LLRT Are ILRT PERFORMED o FlffURE -
O EMPHASIS ON COMPLETION OF 10-YEAR INTERVAL INSPECTIONS 0 COMPUTER DATA BASED PROGRAM- ,
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SYSTEM ENGINEERING UPGRADE .
O PHILOSOPHY OF SYSTEM ENGINEER ROLE ESTABLISHED
. O KNOWLEDGE AND PARTICIPATION IN DAY-TO-DAY SYSTEM OPERATION
'O EVALUATION OF PROBLEMS VERSUS DESIGN O ENSURE QUA'LITY OF DESIGN APPROACH THROUGH ROOT CAUSE ASSESSMENT la DEVE. LOPED SYSTEM ENGINEER QUALIFICATION PROGRAM
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O SYSTEMS AND SIMULATOR TRAINING O CLASSROOM 0 'FSAR/ TECH SPECS /O-LIST / PROCEDURES O MECHANICAL / ELECTRICAL FUNDAMENTALS
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0 QUAL CARDS'FOR SYSTEM SIGNOFFS 0 RESPONSIBILITIES 0 FINAL EXAM AND ORAL BOARD O FIRST GROUP IHROUGH SYSTEMS TRAINING e
l L--
FIRE PROTECTION PROGRAM - ENGINEERING 0 ADDITIONAL IECHNICAL EXPERIENCE BROUGHT IN
-0 ESTABLISHMENT OF A COMMITMENT DOCUMENT 0 CORRESPONDENCE FILES SEARCHED - COMPLETE O COMMITMENTS DEFINED AND CROSS-REFERENCED - COMPLETE O VERIFICATION OF COMMITMENTS IN PROGRESS 0 WORK LOAD ASSESSMENT IN PROGRESS 0 SOURCES REVIEWED AND EXISTING WORK BACKLOG CATALOGED 0 ADDITIONAL RESOURCES ASSIGNED TO WORK BACKLOG
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0-LIST UPGRADE O EXISTING 0-LIST THOROUGHLY REVIEWED FOR INCONSISTENCIES, UNITIZED, AND REFORMATTED O ESTABLISHED PROJECT ENGINEER DEDICATED TO 0-LIST O PROJECT PLAN ACCEPTED BY FANAGEWAT AND CONTRACTOR FOR PHAS$ I APPROVED 0 VAKE IFPROVEMENT IN ELECTRICAL Q-LIST DEFINITION O IPPROVE FIRE PROTECTION 0-LIST ,' -
O ESTABLISH PLAN /VETHDDOLOGY FOR C09 UTER DATA BASED Q-LIST AllED AT
. CQ90NENT LEVEL O RES'JLTS OF PHASE I TO BE USED AS BASIS FOR FLTillRI CONTRACTOR EFFORT i
O ENGifEERING SERVING AS PROJECT FANAGER FOR CALIBRATION PROGRAM UPGRADE O JDENTIFIED INSTRLEENTS O DEVELOPED CG9'JTERIZED LISTING , ,
0 DRAFT CONTROL PROCEDURE .
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PROCUREMENT ENGINEERING .
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t 0 HIGHER PRIORITY ESTABLISHED 1 ' ,_
0 DEDICATED PROCUREMENT PERSONNEL 0 7 ENGINEERS o 1 TECHNICIAN O EFFORT DIVIDED INTO.IHREE AREAS .
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~0 REVIEW OF Q-LIST REQUISITIONS i .
0 SPECIAL GROUP FOR SIGNIFICANT PROCUREMENT PROBLEMS SUCH AS OBSOLETE EQUIPMENT ESTABLISHED O EVALUATION OF ITEMS ON QA HOLD 9
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'. fcE NRC'0A/QC PRESENTATION 1/11/84 SITE QA/0C STAFF .
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' -- 42 VS,(20 IN 1981 AUDITS AND TREND ANALYSIS
-AUDIT UNIT STAFF INCREASED FROM 6 Te 11 ,
UPGRADED STAFF QUALIFICATIONS ,
AUDIT MATRIX DEVELOPED
- NUMBER OF OPEN ITEMS REDUCED (42 AT END OF 1982 VS',
10 AT END OF 1983)
ESCALATION DEFINED 4 9 IREND REPORT PROGRAM IMPLEMENTED
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. MONTHLY AUDIT STATUS REPORT WEEKLY AUDIT ACTIVITY REPORT
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QA SERVICES SECTION FORMED .. ..
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.. l NRC QA/0C PRESENTATION -
i 1/11/84 i SITE QA ENGINFFRING . . , .
H c -- SITE STAFF FORMED AND STAFFED.=( .... 2 ENGINEERS )-
l 5 DEGREED ENGINEERS .
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.- PROGRAM EFFECTIVENESS ASSESSMENTS ,
.. SURVEILLANCE AND MONITORING
.- .. SR0 ADDED INCREASED NUMBER'0F SURVEILLANCES .
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1981 - 25
. - 1982 - 83 *
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- J.983 - 136 .
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. . .. INSPECTION
'- EXPANDED COVERAGE - PREVENTATIVE MAINTENANCE ,
~< - CALIBRATION __
l . - PERFORMANCE IESTING ,
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- WELDING
._fN0NCONFORMANCEREPORTS ~
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.- .- COMPUTER TRACKING 7
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NRC QA/0C PRESENTATION
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MANAGEMENT INVOLVEMENT MONTHLY QA MEETING WITH PLANT MANAGEMENT MONTHLY PNSC QA REVIEW .
QA/0C STATUS PRESENTED AT MONTHLY S'ENIOR MANAGEMENT AND
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PROJECT REVIEW MEETINGS .
.. . - d -- YEAR END QA REVIEW WITH SENIOR SITE MANAGEMENT
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- :- WEEKLY QA MANAGEMENT IOURS OF WORK AREAS . .
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NRC QA/0C PRESENTATION 1/11/8tl
~.- ACCOMPLISHMENTS .
COMMITMENT AND IECH SPEC SURVEILLANCE -
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IN-PLANT SURVEILLANCE .
QA ENGINEERING
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PROBLEMS e
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- 9. FIRE PROTECTION QA ,
N., ELECTRICAL 0-List
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RADWASTE QA
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m -SITE NUO FAR SA TfY ACGTPIiSR U TS e RE-ACTIVE TO PRO-ACTIVE MCDE
- RE-ORGANIZED (REACTIVE BURDEN $FF-SITE)
- INCREASED STAFF (4 TO 8)
- EXPANDED FUNCTIONAL AREAS (3 Te 6)
SELFINITIATEDACTIVITIES
- IMPROVED FOCUS e PROCEDUREREvIEWS
- OPERATIONS PROCEDURE UPGRADE PROGRAM
- RETS
- PROCEDURE REVIEW CHECKLIST
- DEVELOPED TRAINING PROGRAM e WS40A PRE STARTUP READINESS PROGRAM
- COMPLEMENTARY (NOT SUPPLEMENTARY) AcTIv!TY
- IDENTIFY SOFT SPOTS N PROBLEM S
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..h-OWIFNrFS e INCREASEPRO-ACTIVEEFFORTS .
-QA+@3AUDITOFBESU
-SPECIALINVESTIGATIONOFMAINTENANCE e I.ISEOFANALYSISIECml0VES
- PPMGT USES FOR PRIORITIZATION
- DETERMINATION OF IRANSIENT EFFECTS AT ALTERNATE CONDITIONS
- TRENDING (PAST TRANSIENTS)
O CONTINUE IMPROVEMENT (Av01D BACKSLIDE) .
- DEVELOP VIABLE SAMPLING PROGRAMS ,
- IMPROVE FOU OPUP/CLOSE00T ..
- DEVELOP FURTHER PRIORITIZATION SCHEMES
- PROGRAMMATIC FOCUS PATHER IHAN SPECIFICS O
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w A8e UNITE D STATES oq#o g NUCLEAR RETULATGY COMMISSION
[ o REGION 11 101 MARIETTA STREET,N.W.
. 5* a I ATLANTA. GEORGIA 30303
\, * * * * * / .
Jt AUG 211984 Carolina Power and Light Company ATTN: Mr. E. E..Utley Executive Vice President
' Power Supply and Engineering
-and Construction ,~-
411 Fayetteville Street Raleigh, NC 27602 Gentlemen:
SUBJECT:
REPORT NOS. 50-261/84-24, 50-324/84-16, 50-325/84-16, AND 50-400/84-18 The NRC Systematic Assessment of Licensee Performance (SALP) Board has completed its periodic evaluation of the performance of the subject facilities. The Robinson, Brunswick, and Harris facilities were evaluated for the period February 1, 1983, through April 30, 1984. The results of the evaluation are documented in the enclosed SALP Board Assessment. In the past, as a part of the SALP program, we have routinely met with Carolina Power and Light Company officials to discuss the results of the SALP Board's evaluation. The format of the SALP program has recently been revised so that this meeting is no longer a requirement, but may be held as a public meeting at the' discretion of the licensee or NRC. In consideration of this revised format, please contact this office within ten days of the date of this letter to discuss the need for a meeting.
The performance of your Robinson and Brunswick facilities was evaluated in the operational functional areas of plant operations, radiological controls, .
maintenance, surveillance, fire protection, emergency preparedness, security and safeguards, refueling, licensing activities, and the quality assurance program.
Harris was evaluated in the construction functional areas of soils and foundations, containment and other safety related structures, piping systems and supports, safety related components, support systems, electrical power supply and distribution, licensing activities, and the quality assurance program.
The SALP Board evaluation process consists of categorizing performance and the performance trend in each functional area. The categories which we have used to evaluate the performance and the performance trend of your facilities are defined in section II of the enclosed SALP Board Assessment. Any comments which you have concerning our e' valuation of the performance of your facilities should be submitted to this office within 20 days following the date of this letter or the date of the meeting on this SALP assessment (if held).
Your comments, if any, and the SALP Board Assessment, will both appear as enclosures to the Region II Administrator's letter which issues the SALP Board Assessment as an NRC Report. In addition to the issuance of the assessment, this letter will, if appropriate, state the NRC position on matters relating to the status of your safety programs.
g 0?WW 9ff
y Carolina Power and Light Company 2 <-
In accordance .with -110 CFR 2.790, a copy of this letter and enclosure will be placed in the NRC's Public - Document Room unless you - notify ' this office, by
-telephone,1within 10 days of the date ' of this letter and submit written l application to withhold information contained therein within 30 days of the date of this letter. Such application. must be consistent with the requirements of
-2.790(b)(1).
Should you have any questions concerning this letter, we will.be glad to discuss
-them with.you.
Sincerely, I c, Richard . Lewis, Director Division of Reactor Projects
~
Enclosure:
~SALP Board-Assessment for Carolina Power and Light Company cc w/ encl:
P. W. Howe, Vice President Brunswick Nuclear Project C. R. Dietz,. Plant General Manager G. P. : Beatty, Jr. , Manager Robinson Nuclear Project Department . ,
R. E.1 Morgan, Plant General Manager R. A. Watson, Vice President- '.
Harris Nuclear Project R. M. Parsons, Project General Manager
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'U.S. NUCLEAR REGULATORY COMMISSION REGION II SYSTEMATIC ASSESSMENT OF-LICENSEE PERFORMANCE BOARD ASSESSMENT CAROLINA POWER AND LIGHT COMPANY
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H.-B.-ROBINSON STEAM ELECTRIC PLANT UNIT'2 DOCKET NUMBER 50-261 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2
' DOCKET NUMBERS-50-325 AND 50-324 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1
-DOCKET NUMBER 50-400 s
~ '
FEBRUARY 1, 1983, THROUGH APRIL 30, 1984 INSPECTION REPORT NUMBERS 50-324/84-16, 50-325/84-16 50-261/84-24, 50-400/84-18
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CONTENTS.
PAGE
- I. INTRODUCTION ..................................................... l'
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II. -CRITERIA ........................................................ 1
- I I I . 1 S U MMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 A. Overall Utility Evaluation .................................. 2 B. _0verall Facility Evaluation - H. B. Robinson Unit 2 ......... 3 C. Facility Performance - H. B. Robinson Unit 2-................ 4 D .- ' Overall Facility Evaluation - Brunswick Units I and 2_ . . .. . . . 5 E.~ -Facility Performance - Brunswick' Units 1 and 2 .............. 6
'F. Overall Facility Evaluation - Shearon Harris Unit 1. . . . . . . . . 6 G. Facility. Performance- .Shearon Harris Unit 1 ................ 8 H. LSALP Board Members .......................................... 8
-I. SALP-Board Attendees ........................................ 8
-IV.
PERFORMANCE ANALYSIS FOR ROBINSON UNIT 2 ......................... 9 A. Functional' Area Evaluation - Operations ..................... 10 B. Supporting Data ............................................. 27 V. PERFORMANCE ANALYSES FOR BRUNSWICK UNITS 1. AND 2 ............... 30 A. Functional Area Evaluations - Operations .................... 31 B.~-Supporting Data ............................................. 49 VI' . PERFORMANCE ANALYSIS FOR SHEARON HARRIS UNIT 1 . . . . . . . . . . . . . . . . . . 51
=A. Functional Area Evaluation - Construction ................... 52 B. Supporting Data ............................................. 68 4
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I. INTRODUCTION A' formal clicensee performance assessment program has been implemented in
- accordance with the procedures discussed in the FederalERegister Notice of March 22,- 1982. This program, the ' Systematic Assessment of Licensee Performance (SALP), . is applicable to each operator _ of a power reactor or holder of a construction permit (hereinafter referred to as licensee). The SALP program is an integrated NRC staff effort to collect available observa-
= tions of licensee performance on a periodic basis and evaluate performance based on these observations. Positive and negative attributes of licensee performance are considered with emphasis placed on understanding the reasons for a licensee's performance in important functional areas, and sharing this understanding = with' the licensee. The SALP . process is oriented toward furthering NRC's understanding of the manner in which: (1) the licensee directs, guides, and provides . resources for assuring plant sa fety; and (2)_ such resources are used and applied. The integrated SALP assessment is
. intended to be sufficiently diagnostic to provide meaningful guidance to the licensee. The SALP program supplements the normal regulatory processes used to ensure compliance with NRC rules and regulations.
II. CRITERIA Licensee performance is assessed in certain -functional areas depending on whether the facility has been in the construction, preoperational, or operating-phase during the SALP period. These functional areas encompass a wide spectrum of the regulatory program and represent significant nuclear safety and environmental activities. Functional areas may not be assessed because'of little or no licensee activities in these areas, or for lack of .
meaningful NRC observations.
One or more of the following evaluation criteria were used to assess each functional area:
. Management involvement in assuring quality
. Approach to the resolution of technical issues from a safety standpoint-
. Responsiveness to NRC initiatives
. Enforcement history
. Reporting and analysis of reportable events
. Staffing (including management) .
. Training effectiveness and qualification I The SALP Board has categorized functional area performance at one of three performance levels. These levels are defined as follows:
Category 1: Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
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~ Category-2: NRC attention should be maintained at normal levels.
Licensee management - attention and involvement are. evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
' Category 3: Both NRC and licensee attention .should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to . be strained or not effectively used such that minimally satisfactory . performance with respect to operational- safety -
or construction is_being achieved.
The SALP Board has also categorized the performance trend over the course of
'the -SALP assessment _ period. The categorization 'is meant to describe the-general or prevailing tendency (the performance gradient) during the SALP period. The performance trends are defined as follows:
Improved: Licensee performance has generally improved over the course
'of the SALP assessment period.
Same: , Licensee performance has remained essentially constant over the course of the SALP assessment period.
Declined: Licensee _ performance has generally declined over the course of the SALP assessment period.
'III.
SUMMARY
OF RESULTS .
A. Overall Utility Evaluation At z the beginning of the SALP period, the Carolina Power and Light Company (CP&L) was implementing a program to_ improve -regulatory performance. This' program was implemented because of the- licensee's determination to successfully implement its Brunswick Improvement Program (BIP), which was implemented as result of surveillance problems identified'in December 1982. Significant improvements were observed at the Brunswick site, and, as a result, CP&L developed a Robinson improvement program, based on the BIP, and also implemented selected improvements at their Harris construction site. These improvement programs have proven effective in reducing plant operational and
- managerial deficiencies.
e In' August 1983, the company's corporate organization reorganized under a Senior Vice President Nuclear Generation to consolidate the nuclear s
organization under one senior manager. All nuclear line functions were
- - organizationally placed under this position, with the exception of the J, Brunswick facility which remained under the Executive Vice President Power Supply and Engineering ana Construction to provide executive level management attention. In addition, department level positions L
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were formed - at each nuclear site, with corporate Vice Presidents
'< occupying two of these positions, to ensure increased communication between the sites and the corporate office, and which would provide increased onsite authority.
In1 addition to the restructuring of the corporate nuclear line organization,_ changes were made in the direction taken by the corporate support organization, functioning both. in the corporate offices and.at their site locations.
During the evaluation period, the increased licensee management attention applied to. the entire nuclear organization has changed CP&L from being considered as a poor performer during the previous SALP period to a significantly improved utility. The Improvement Program implemented by CP&L has been used as a model by some other Region II
. utilities to follow in development of their own improvement programs.
B. Overall Facility Evaluation - H. B. Robinson 2 During the majority of the assessment period, the Robinson facility was in outages; first to determine steam generator (S/G) tube degradation and then to undergo S/G replacement. This extended outage time resulted in site resources being strained; however, few problems were identified. This good performance was partially due to a facility reorganization which allowed for more direct observation of work activities by facility senior management. The facility also developed a new outage management concept which prevented many potential problems from developing. The licensee took the necessary steps to safely . .
implement the S/G replacement outage even through this outage began months ahead of schedule. Major strengths were identified in the the areas of surveillance, fire protection, emergency preparedness, and refueling. No major _ weaknesses were identified.
Several major achievements occurred during this evaluation period.
These included construction of the Health Physics / Chemistry Building where radioactive work' can be performed with " state-of-the-art" equipment; a training / simulator / Emergency Operations Facility / Technical Support Center building; and a security access area which was started-and which will include a new computer system and upgraded security equipment. Additionally, the steam generators were replaced. Although
' the outage was not complete at the close'o'f the assessment period, it appears that the man-rem actually received will be s_ignificantly below the man-rem projections.
Another achievement, in the area of emergency preparedness, was the development of a logic matrix for use by shift personnel to determine emergency action. This improvement should aide in overcoming the problem of determining where to enter the emergency plan.
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4 Several areas were identified where the greatest opportunity for improvement exist. These areas include the security organization and equipment where manning of the security group has been marginally acceptable in the past and the equipment is antiquated. The licensee has taken recent actions to upgrade both staffing and equipment. If followed through, present plans should result in major improvement during the next SALP period.
The opportunity for continued improvement also existed in the area of radiological controls which improved this SALP period, particularly in the area of radwaste control . However, near the end of this SALP period numerous. minor violations were identified. With the exception of the steam generator replacement activity, management control of this area has not been-dynamic. The licensee was addressing this problem at the close of the assessment period.
The opportunity for improvement also existed in the area of regulatory compliance which suffered from a lack of management direction and attention to detail. During this evaluation period a tracking system for regulatory items was developed. However, it had not been satisfac-torily implemented at the close of the assessment period.
The reorganization at H. B. Robinson appears to address the problems at the site. The licensee has recognized the need to have all plant managers and supervisors spend more time on direct observation of work activities, and was agressive in pursuing this issue.
Overall, the performance of the facility staff appears to be improving. . ,
C. Facility Performance - Robinson 2 Tabulation of ratings for each functional area:
Operations (Unit 2)
Trend During Functional Area Category Rating This Period
- 1. Plant Operations 2 Improved
- 2. Radiological Controls 2 Improved
- 3. Maintenance 2 Improved
- 4. Survei11ance 1 Same
- 5. Fire Protection 1 Not Determined
- 6. Emergency Preparedness 1 Improved
- 7. Security and Safeguards 2 Same
- 8. Refueling 1 Improved
- 9. Licensing Activities 2 Improved
- 10. Quality Assurance Program 2 Improved
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.a 1
- o .g D. l 0verall . Facility Evaluation - Brunswick Units 1 and 2 During, the majority of the SALP period, the Brunswick facility was operating under an NRC Order issued in December 1982, confirming the BIP. In implementing the requirements of this confirmatory order, CP&L-not only'took steps to meet the action ' items spelled out .in 'the BIP,-
- but also established measures to identify and implement additional
. improvements. Major strengths were identified in the areas of
-radiological controls, emergency preparedness, security and safeguards, and refueling. No major weaknesses were identified. '
Several major achievements were noted at the Brunswick facility during
.the SALP period. These improvements included the implementation and completion of the BIP. Major highlights of the .BIP. included: the complete rewrite of operations, surveillance, 'and annunciator procedures; an enhanced training program which helped change operator morale and their interface with training (producing a better product),
and allowed satisfactory completion of NRC administered requalification examinations; rewritten and reformatted emergency operating procedures; an increased regulatory sensitivity by most plant staff; an improved dicipline of operations; increased attention by management / supervisors of work activities in the . field; a plant cleanup program that brought Brunswick to a high level of cleanliness; and increased morale of the
-plant staff.
An additional improvement was the increased involvement by the Onsite
. Nuclear Safety (ONS) Unit. The ONS Unit performed a technical review of procedures rewritten under the'BIP; developed a restart program for .
Unit 1, upon completion of an extended outage; and spent more time in the plant performing safety reviews. Additionally, the licensee participated, as part of the boiling water reactor owners group, in 13 of 15 industry wide projects. In many cases, the licensee took the group lead in completing the projects.
Several areas were identified which held the greatest opportunity for improvement. These areas included fire protection, where the implemen-tation of the Appendix R program must receive close management atten-tion to prevent implementation problems in both the safety and regulatory areas; and maintenance, where the licensee has an enormous work effort underway to enhance / develop programs in the areas of procedure rewrite, preventative maintenance and scheduling of work
. . activities, and a trending program for predictive maintenance. During the'past two SALP assessment periods, many of the regulatory compl'iance problems could have been averted had there been stronger management
-attention applied. There has been some improvement during this SALP <
period, but two areas which still need to be addressed are the need for
g ._.
k' L s .more operations experience and knowledge in the unit; and more emphasis on measures'to identify -problems prior to their being escalated to enforcement' issues.
_The reorganization at Brunswick' has resulted in a significant increase in management awareness and control, . particularly in the ' areas of
-operations and' outage management. The effects of assigning a corporate
-Vice President-(VP) to the site became evident _duri.ng this SALP period, as many problems were handled quickly and effectively with the VP dealing directly with administrative-obstacles.
. Brunswick has' made significant improvements over the previous rating- 1 period; the management -focus for the next 'SALP period should be the
'~
. continued application of close oversight of operations.
E. Facil_ity Performance - Brunswick 1 and 2 Tabulation of ratings for each functional area:
Operations (Units I and 2)
Trend During Functional Area Category Rating This Period
- 1. : Plant Operations 2 Improved
- 2. Radiological Controls 1 Improved
- 3. Maintenance 2 Improved
- 4. Surveillance 2 Improved , ,
- 5. Fire Protection 2 -Improved
- 6. Emergency Preparedness 1 Improved
- 7. Security and Safeguards 1 Same
- 8. Refueling i Improved
- 9. Licensing Activities 2 Improved
- 10. Quality Assurance Program 2 Improved F. Overall Facility Evaluation - Harris 1 Constructic.i completion during the SALP period progressed from 77's to 84?4. complete. In December'1983 the licensee announced the cancellation of Unit 2. Even with this cancellation, construction staffing increased to approximately 5000 employees. The major emphasis in
-construction has shifted to completi.on of. systems and components needed to support the orderly testing of systems needed to meet the projected major milestones of cold hydrostatics testing, hot functional testing and fuel loading now projected for June 1985. Major strengths were identified in the areas of soils and foundations, containment and other o
m D,
6 y
7 I
' safety related structures,- and support systems. No major weaknesses
~
J were identified.
L I
- As a p' art o f -- the corporate reorganization, 'a Vice President was assigned to Harris with overall responsbility for construction and g -operations. Changes have been implemented to consolidate the admini-
- l. .strative and site support. functions under control of the Vice President I and remove these burdens from .the managers of constructicn and operations.
Licensee performance with respect to construction was satisfactory.
Licensee management involvement and support for quality construction increased. The staff was well trained and qualified.
Certain areas were identified in which the opportunity for improvement i exists. Included in these areas is pipe hangers and supports where all procedures have been revised and additional supervisory, engineering, craft, and inspection personnel have been assigned. This revised j . program was being initially implemented at the close of the SALP period. It will require strict management attention to ensure success.
A second area which appears.to provide the opportunity for improvement is that of- electrical distribution and supply. This area, although improved, still continued to be plagued by the need for. rework and i repetitious- inspections to achieve acceptable quality. It was t
additionally handicapped by numerous design and field changes required of installations. The licensee has placed additional management emphasis in this area, but additional engineering support and manage- , .
ment oversight are still required.
Several areas achieved improved performance during this evaluation period. Included in these areas was pipe hangers and supports which although improved, is still in need of additional improvement (as discussed above).
Another area where improvements were realized was QA/QC. Major improvements in the QA/QC organization have occurred with the QA/QC Manager for Harris now stationed onsite. The addition of an onsite QA Engineering group and additional staffing in the QA/QC areas have provided a more viable, better trained, and better organized inspection force onsite. A second indep?ndent inspection group separate from the
! - ,QA/QC organization is utilized at the Harris site. This group has been.
given high visibility by the appointment of a new director who reports to ' the construction manager, which is two levels higher than was y previously reported to.
Improved performance also occurred in the area of emergency
! preparedness through the development of a logic matrix for shift personnel to use in entering emergency action levels.
I l
l t
k_
8 e.
Finally, it was recognized that a concerted effort was made to upgrade
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( the. . recei pt inspection program. The result of ' this effort !showed signifi. cant improvement during the period.
G. Facility Performance - Harris 1
- Tabulation of-' ratings for each functional area:
Construction (Unit 1).
Trend During Functional Area Category Rating This Period
- 1. Soils and Foundations 1 Not Determined
- 2. Containnen: and Other Safety 3elatad 5tructures 1 Same
- 3. Piping Systems and Supports 2 Improved
- 4. _ Safety Related Components 2 Improved
- 5. Support Systems 1 Same
- 6. Electrical Power Supply and Distribution 2 Same
- 7. Instrumentation and Controls Not rated Not Determined 8._ Licensing Activities 2 Improved
- 9. Quality Assurance Program 2 Improved
'H. 'SALP Board Members R. C. Lewis, Director, Division of Reactor Projects (DRP), Region II . ,
(RII),. Chairman
.J. A. Olshinski, Director, Division of Reactor Safety (DRS), RII J. P. Stohr, Director, Division of Radiation Safety and: Safeguards (DRSS),RII D. M. Verrelli, Chief, Reactor Projects Branch 1, DRP, RII I. SALP Board Attendees P. R. Bemis, Chief, Reactor Projects Section IC, Reactnr Projects Branch 1, DRP, RII M. V. Sinkule, Chief, Technical Support Staff (TSS), RII D. S. Price, Reactor Inspector, TSS, RII D. O. Myers, Senior Resident Inspector, DRP, RII S. Weise,. Senior Resident Inspector, DRP, RII G. F. Maxwell, Senior Resident Inspector, DRP, RII R. Prevatte, Senior Resident Inspector, DRP, RII A. K. Hardin, Project Engineer, Reactor Projects Section IC, Reactor Projects Branch 1, DRP, RII T. MacArthur, Radiation _ Specialist, TSS, RII
'W. H. Rankin, Reactor Engineer, TSS, RII B. C. Buckley, Project Manager, Licensing Branch 3, Division of Licensing (DL), Office of Nuclear Reactor Regulation (NRR)
G.- Requa, Project Manager, Operating Reactors Branch 1, DL, NRR M. Grotenhuis, Project Manager, Operating Reactors Branch 1, DL, NRR
4 9
IV. PERFORMANCE ANALYSIS FOR H. B. ROBINSON
p w
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I e
10 A. Functional Area Evaluations
' Licensee Ac,tivities During ' the - assessment period, the licensee limited power to below -1955
. Megawatts thermal . The power reduction and a low average temperature program constituted an attempt by the. licensee to reduce the rate of steam generator = (S/G) tube degradation. S/G ' eddy current . inspections were conducted in May, September, and November 1983. Due to the rate at which
- the S/G tubes were degrading, a refueling and steam generator replacement outage was begun in January 1984. The outage was allowed to commence much
' earlier than anticipated, due to resolution of all intervenor contentions presented ,in a hearing before an Atomic Safety and Licensing Board.
Early in the evaluation period CP&L developed a Robinson Improvement Program (RIP), based on the Brunswick. Improvement Program. The stated goals of the RIP were: . to upgrade operating, maintenance, surveillance, and emergency operating l procedures; improve surveillance tracking, scheduling, and audit activities; improve outage management controls and coordination; improve regulatory sensitivity; upgrade training for licensed and unlicensed personnel on modifications and procedural revisions; improve the interfaces between the corporate headquarters and the site; and reduce the plant staff's administrative and offsite support workloads in order to better concentrate efforts on site activities. Implementation of the RIP has progressed well' over the SALP period. Considerable progress has been observed in the areas of training, . outage management control, procedural upgrade, and reduction of offsite impact on the site staff. Continued licensee efforts in these areas will be monitored by this office. . ,
Modifications .in progress at the close of the assessment period included various plant changes which were being implemented as a result of Three Mile Island, a fire protection system upgrade, radwaste facility preparation, and plant secondary system work.
The -Institute of Nuclear Power Operations (INPO) conducted an evaluation of management controls and operating practices during the weeks of November 7 and :14, 1983, and a radiological emergency preparedness exercise was conducted September 20 through 23, 1983.
Inspection Activities The. routine inspection program was performed during the review period. Two special inspections were performed in the area of radiological control ~s to review an inappropriate waste shipment and an unanticipated exposure in the
-reactor vessel cavity sump. A special security inspection was performed to review vital area access controls and managment controls for reporting of security events. Special inspections were conducted on the auality assurance program and Health Physics program associated with the steam generator replacement preparations and activities.
e 11
- 1. Operations
- a. An,alysi s During this assessment period, inspections of plant operations were performed by the resident and regional inspection staffs.
Plant procedural inadequacies and failure of operators to either implement procedures or recognize deficient procedures continued to account for over half of the violations cited in this area.
This weakness in the area of plant procedures was noted in the previous SALP review. The licensee has been responsive to this concern and has initiated a program for upgrading all plant procedures as part of their Robinson Improvement Program. This procedural upgrade effort was about forty percent complete at the end of the SALP period. These procedural upgrades, along with training cf personnel on procedural compliance, have resulted in a reduction of approximately thirty percent in numbers of procedural violations compared to the last SALP review. Only one of ten reportable events assigned to this area resulted from personnel error. The licensee should continue their efforts to improve performance in this area.
Operations staffing and training appeared to be generally adequate, with the exceptions noted above on procedural compliance and maintaining procedures current. In light of the significant number of mode changes performed due to outages to inspect S/Gs, the plant staff appeared to be very observant of Limiting Condi- . .
tions for Ooerations and were generally conservative in applying action statement requirements. The operations staf f exhibited high morale and competency during most operations observed by the NRC. As evidenced by violations (6) and (10) below, a weakness exists in the licensee's control system for meeting reporting requirements. Inasmuch as the reporting requirements changed during this review period, the licensee emphasized operator sensitivity to potentially reportable items in order to prevent further reporting violations, and in addition, the licensee has implemented a " state of the art" tracking system for regulatory items.
Operator licensing examinations were conducted during the evalua-tion period, including both written and oral examinations.
Licensing examinations were given to eight candidates, all of whom passed; and Senior Reactor Operator licenses were issued to all eight persons. The NRC staff reviewed requalification examina-
! tions given to three Reactor Operators and three Senior Reactor Operators by the licensee; all but one Reactor Operator passed.
The staff found the requalification program acceptable. During the evaluation period the training department prepared for accreditation by INPO. (INP0 Accreditation was received on May 16, 1984). The number of instruction hours in the requalification I
r..
W 12 training program was increased due to a new training format. This should help decrease even further the number of procedural v.i ol ati on s . General Employee Training for site personnel was well defined and implemented, while training for craft personnel was less rigidly defined. However, a formalized program was under development. Overall, training support for plant operations continues to improve as a result of increased staffing and work scope. A direct result of the increased training effort was the implementation of a six shift rotation. Examination results indicated that the training program for licensed operators has been effective. The improvements noted during the last SALP assessment period in the licensee's qualification /requalification programs continued to result in a highly successful program for licensing operator candidates. Management attention to this area was obvious, and a continued high level of management attention is recommended, based on the significant number of major plant modification activities currently in progress.
Plant tours by operations supervisory personnel were generally short, lacked depth, and were infrequent. Due to the number of violations identified, periodic, direct observation of plant operations activities by supervisors is needed to improve regula-tory sensitivity and followup on plant activities. Upper plant management has recognized this deficiency and has demonstrated increased emphasis in this area. Site reorganization has allowed .
many administrative burdens to be removed from the Plant General ;
Manager, who is spending a larger portion of his time in the l plant. Licensee emphasis in this area should be continued to . , l include other plant managers / supervisors. l Licensee attention to ensuring indepth corrective actions needs improvement as evidenced by violations (2) and (3). Early in the SALP period licensee management was not sufficiently attentive to proper operation of the low temperature overpressure protection system as evidenced by violations (C), (8), and (10). These I
violations indicated that operation: personnel were still not sufficiently sensitive to reactor vessel protection concerns. The l licensee increased the level of review and audit of operation of the overpressure mitigating system in the latter portion of the l SALP period and continued management attention should create i sufficient sensitivity by operations personnel.
The Robinson Improvement Program (RIP) has been in progress for about one year with approximately one year of work remaining. The ,
program appears to have enhanced sensitivity to regulatory I requirements, as evidenced by the reduction in Severity Level IV violations identified. Management control systems have improved, in that the licensee has reduced the frequency of operations violations and has improved at sel f-identi fication of deficiencies. ;
I
13 E Eleven violations were identified during the evaluation period.
These violations continue to indicate a minor breakdown in the ar.eas of procedure adequacy and operator compliance. The viola-tions identified were:
(1) Severity Level IV violation for f ailure to implement valve lineup procedures.
(2) Severity IV violation for failure to implement adequate corrective actions for a malfunction on safety-related equipment. ;
(3) Severity Level IV violation for failure to implement adequate corrective actions concerning safety system operability.
(4) Severity Level IV violation for failure to establish and '
c implement adequate procedures for containment integrity control and verification.
(5) Severity Level V violation for failure to maintain annun-ciator procedures.
(6) Severity Level V violation for . failure to make a prompt
. report.
(7) Severity. Level V violation for failure to establish procedures for control of nuclear instrument setpoints.
. s.
-(8) Severity Level V violation for failure to meet overpressure mitigating system operability requirements. ;
(9) Severity Level V violation for failure to adequately imple-ment clearance procedures. ;
I (10) Severity Level V violation for failure to make a licensee event report.
(11) Severity Level V violation for failure to maintain valve checkoff procedures,
- b. Conclusion .
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Category: 2 Trend: Improved t
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14
- c. Board Comments Performance in this area was evaluated as Category 2 during the previous'SALP assessment. Licensee management attention in this -
, area was evident. No decrease in licensee or NRC attention in this area is recommended.
Radiological Controls 2.
- a. Analysis l-' '
During the evaluation period inspections of Radiological controls were performed by regional and resident inspection staffs.
The licensee began a steam generator replacement project during the later.part of this assessment period. Preplanning, training, :
and the use of mock-ups for the steam generator replacement project were evident. The licensee continued to have an effective decentamination program which decreased the number of contaminated areas and personnel contamination events. No overexposures or significant radiological events have occurred during this project tnrough the end of the SALP assessment period. The actual man-rem exposure was significantly below that projected and was, at the close of the SALP assessment period, lower than that achieved during any previous S/G replacement outages at other facilities.
During the assessment period, failure to provide adequate control of high radiation areas accounted for two violations. In one case . . !
a Severity Level III violation was cited for licensee personnel entering a high radiation area under the reactor vessel with the -
incore guide thimbles withdrawn. The event' occurred because there ,
was inadequate access control for the area and the area was not properly surveyed. The second violation was for inadequate locking of the access to a high radiation area. Licensee manage-ment subsequently implemented adequate corrective actions. .
The radwaste program, consisting of liquid, gaseous and solid radwaste, accounted for one violation and one deviation. The violation involved a shipment of radioactive material to an unauthorized recipient. The deviation pertained to the failure to adequately train all personnel handling, processing, and packaging of radioactive material as committed. .However, since the previous assessment period significant improvement in procedural and regulatory compliance has been noted. Corrective actions taken'by the licensee were prompt and appeared to be adequate. Other areas of the liquid and gaseous effluent accountability program were adequate, ,
[-
0 15 The radiation protection program continued to exhibit improvement which included an upgrading of procedures, increased management attention, and improved training program and staffing levels.
Considerable management effort 'has been evident in the planning and execution of activities associated with the steam generator replacement. Increased-health physics training, use of mock-ups, and more freqtant supervisory tours have all contributed to a reduction in man-rem expended, and a reducticn in the number of both.NRC and licensee identified deficiencies. The basic program weakness ' continues to be a failure of workers and/or . health physics technicians to follow radiation protection procedures.
This issue was identified in the previous SALP assessment. While some improvement has been noted during this evaluation period, the licensee should continue to stress the need for unambiguous procedures, the importance of quality training and contractor screening, and the unequivocal requirement that procedures be followed or properly revised. Stringent control and monitoring during steam generator repair activities and during modification work should continue in order to ensure that health physics activities are fully understood and correctly performed.
Eight violations and one deviation were identified.
'(1) Seve ity Level III violation for failure to control access to c and adequately survey the reactor vessel sump with the flux thimbles withdrawn.
(2) Severity Level IV violation for failure to ship radioactive , ,
waste in accordance with the recipients license.
(3) Severity Level IV violation for failure to properly label containers as containing radioactive material.
(4) Severity Level IV violation for failure to post a radiation area sign outside a radiation controlled area.
(5) Severity Level IV violation for failure to adequately train personnel in the respiratory protection program.
-(6) Severity Level V violation for failure to perform an adequate survey of material leaving a radiation controlled area.
(7) Severity Level V violation for failure to adequately lock the access to a high radiation area.
. (8) Severity Level V violation for failure to implement radiation work permit procedural requirements.
(9) ' Deviation for failure to adequately train personnel who process and package radioactive material for burial.
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b s
'b. Conclusion
-Category: 2 Trend: Improved
- c. ; Board Comment Performance was evaluated as Category 2 during the previous SALP
_ assessment. Licensee resources appeared adequate in this area.
No decrease in licensee or NRC attention is recommended.
- 3. Maintenance
- a. Analysis During this assessment period inspections of maintenance were performed by regional and the resident inspection staffs.
The licensee has been responsive and has initiated a program for upgrading maintenance procedures as part of the Robinson Improve-ment Program. This procedural. upgrade effort was about fifty percent complete at the end of the SALP period.
As discussed in the previous SALP report, the maintenance program continues to display'one programmatic weakness. -Specifically, all the violations and three reportable events discussed-below were caused or - contributed to by a lack of procedural control. . <
Evaluation of deficiencies identified, their significance, 'and -
inspection hours expended,' however, indicated that fewer deficien-cies are occurring per hour of maintenance at the~ close of the SALP assessment period than at the' beginning. Safety-related maintenance activities have generally been properly and pro-fessionally conducted. The procedural upgrades, along with continued training of maintenance personnel on procedural compliance, should receive continued emphasis from licensee management.
Maintenance staffing levels increased during the review peri.ed at the management, engineer, and technician level. This was appropriate in order to perform an increased workload and to
. improve the quantity and quality - of in-the-field supervision.
Management attention is needed to ensure that maintenance super-visory personnel conduct frequent on-the-job observations of maintenance activities. Staffing levels for personnel conducting technical revisions were marginally adequate to accomplish both maintenance and procedural upgrade activities, therefore, the licensee has obtained contract individuals to supplement their staff. The staff has good morale and a high level of technical expertise. The licensee has also developed and initiated increased on-the-job and plant systems training for- the
p1-3, __
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. g' a 17 Q -
c > maintenance staff in an effort to improve performance, under-standing, and regulatory sensitivity. Communication between the sp . maintenance staff and operations staff.with respect to prioritiza-E tion and control. of safety-related maintenance has been consis-tently ' noteworthy. Improvement has been observed in maintaining equipment that directly supports safety-related systems.
The licensee did not have a centralized maintenance deficiency tracking system in that each plant unit generates its own maintenance deficiency list and controls its separate deficiency prioritization and tracking system, including corrective actions.
The licensee has been responsive and is pursuing a' computerized tracking and trending system to replace the = manual system and provide-better centralized control. Additionally, a trial defi-
,, ciency tagging system used during this review period was success-ful and.is being expanded in scope. The licensee should continue efforts to improve its maintenance deficiency control and tracking program.
m.
, The_ licensee has placed increased emphasis on development of a s
comprehensive preventive maintenance program to reduce component failures. Five reportable events resulted from personnel errors e and/or orocedural inadequacies related to maintenance activities.
Two events affected safety system operability and Sne caused reactor coolant system leakage.
The independent verification controls on instrumescation and control equipment also appeared weak. While no violations were .
identified in this area, the licensee was made aware of this concern and has initiated a program to address the issue as part of the plant' operating manual upgrade.
During the assessment period the licensee was involved with two major _ modifications: the replacement of a portion of the spent fuel storage racks and the replacement of the steam generator tube bundle section for all three steam generators. Inspections were performed in the following areas: welding-structural and piping; nondestructive examination; spent fuel storage racks; review of procedures; visual inspection observation of work and review of quality _ records; and, Inspection and Enforcement (IE) Bulletins 79-02 and 79-14.
QA/QC _ personnel in the maintenance area were well qualified and knowledgeable in procedure requirements. Records were generally complete, well maintained and available.
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18 Eight violations were identified during the evaluation period.
These violations continue to indicate the need to improve existing-
. maintenance procedures and to establish additional procedures to control maintenance activities. The violations . identified were:
(1) Severity Level IV violation for failure to adequately esta-blish, implement, and maintain procedures.
(2) Severity Level IV violation for failure to plug degraded steam generator tubes.
(3) Severity Level IV violation for failure to establish suitable controls on. modification activities affecting service water equipment.
.(4) Severity Level IV violation for failure to correct procedural deficiencies identified in a previous violation.
(5) Severity ' Level V violation for failure to establish _ and implement adequate post-maintenance testing procedures.
(6) Severity _ Level V violation for failure to establish adequate procedures.
-(7) Severity Level V violation _ for failure to establish adequate weld rod controls.
(8) Severity Level V violation for failure to stop work at' hold .
points.
- b. ' Conclusion Category: 2 j, 4 s irend: Improved aw
- c. Broad Comments Performanceywas evaluated as Category 2 during the previous SALP assessment. The conduct of activities' in this area showed a pro'per concern for. nuclear safety. No decrease in._ licensee _or NRC.
attention is recommended.
' 4. . Surveillance
.a. ' Analysis. * <
During this. assessment period inspections of surveillance activities were, performed by the regional and resident inspection
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staff. ,
m 1 m
19 The licensee's surveillance program was generally well established and implemented. Scheduling and completion of surveillances have been timely and have received adequate management attention.
Additional programs for surveillance tracking and auditing have been established and implemented to ensure complete compliance with requirements. Considerable inspection effort has not identified any missed Technical Specification requirements.
However, violations (1) and (2) below indicate inadequate controls to' ensure . proper. testing of the ventilation filtration systems.
Inadequate licensee oversight of contractor support .1ppeared to be contributory to this problem. The licensee should review this program for technical adequacy to ensure comprehensive corrective actions. Reviewed - as a program, surveillance . and inservice inspection and testing activities were well controlled. Manage-ment attsntion in this area was evident. Three reportable events were Identified through surveillance activities, but none were a result of improper performance of surveillance activities. Even though . this program has few regulatory issues identified, the licensee has included surveillance tests in its procedural upgrade program. Three violations were identified during the assessment period:
(1) Severity Level IV violation for failure to conduct adequate surveillance -tests on charcoal and absolute filters for ventilation systems.
-(2) Severity Level IV violation for failure to conduct adequate visual inspections on ventilation system equipment. . .
(3) Severity Level V violation for inadequate functional testing after calibrations.
- b. Conclusion Cathgory: 1 Trend: Same
- c. Board Comments
. Performance in this area was evaluated as Category 1 during the previous SALP assessment. Licensee management involvement -in this area was evident. No decrease in licensee or NRC attention. is recommended.
- 5. Fire Protection
- a. Analysis-During this assessment period, routine inspections were performed by the resident inspection staff.
20 No violations were identified. Fire protection administrative procedures . were generally adequate. The plant fire protection staff was highly motivated, and staff morale appeared high. The licensee utilized the South Carolina Fire Academy for training and this resulted in a highly knowledgeable staff. Staffing levels appeared *.o be above average. Training in fire response appeared to be above average, but training on detailed actuation system design appeared'only average. Contributing to this problem was a lack of up-to-date, correct wiring diagrams for the actuation and detection system. Management attention was applied to rectify
-this contractor support problem-and drawings are being upgraded.
The inspection effort in this area has been considerable due to the problems -identified at the Brunswick Station. The lack of-violations identified and the inspector's observations .showed the H. B. Robinson program to be strong overall and to be receiving high management attention.
- b. Conclusion Category: 1 Trend: Not Determined
- c. Board Comments Performance in this area was not rated during the previous SALP assessment. The Category 1 rating in this area was based on a - -
limited number of inspections perforned by the resident inspectors. No decrease in licensee or NRC attention is recom-mended.
'6. Emergency Preparedness a '. Analysis During the assessment period, inspections were performed by the resident and regional inspection staffs. This effort included two routine inspections and observation of and participation in a full-scale emergency exercise.
A well staffed corporate e'mergency preparedness organization provides support'to the plant organization. All key positions in
'the plant and corporate emergency planning programs were filled.
Corporate management has been directly involved in emergency preparedness activities. An effective tracking system exists for managing emergency preparedness followup issues.
During the inspections, the following essential elements for emergency response were found acceptable: emergency preparedness training; changes to the emergency preparedness program; shift
21 staffing and' augmentation; notification and communications; public-information; emergency classification; post accident measurements
'and instrumentation; dose ' projection and assessment; emergency worker protection; and QA audits of. plant and corporate emergency preparedness program. One violation concerned the licensee's
~ failure to incorporate into the emergency plan and the imple-menting procedures guidance consistent with Federal guidelines regarding protective action decision-making during general emergencies. In response to this violation, the licensee imple-mented a logic matrix for use by-operating personnel to determine emergency actions. In addition, .the licensee has develooed and implemented. an improved emergency response training program for key personnel. .The training program includes more practice drills to increase staff capability to handle abnormal conditions.
The full-scale exercise disclosed that the plan and procedures could be effectively implemented by the licensee's staff, although several areas for improvement were noted by the NRC and the licensee. Licensee critiques of emergency response activities during the annual drill have improved, but management attention should continue to be directed towards this area.
The licensee appeared.to be responsive to the concerns identified.
Corporate and site management appeared to be supportive of.
emergency preparedness programs and issues and were directly involved in site activities during the above exercise.
One violation was identified:
Severity Level IV violation for failure to implement proce-
< dural guidance regarding protective action recommendations.
- b. Conclusion
. Category: 1 Trend: Improved c.- Board Comments Performance in this area was evaluated as Category 2 during the
~ previous SALP assessment'. It appears that the -licensee ha's ~
devoted the proper amount .of management attention to this area.
The adequacy of the interim emergency facilities is marginal; however, this-problem has been recognized by the licensee and new
< emergency. response facilities are under construction. No decrease in licensee or NRC attention in this area is recommended.
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- 7. Security and Safeguards
- a. Analysis y
During this assessment period inspections of security and safe-guards activities were performed by the regional and resident inspection staffs.
Security staffing was minimal and resulted in violation (4) being issued. Training appeared to be . adequate. The licensee was responsive to NRC initiatives except for minimal staffing of the security force. The licensee continues to expend an excessive amount of time and effort maintaining security equipment that should have been upgraded; this was identified previously as a minor programmatic weakness. While the licensee's compensatory measures have been adequate, increased emphasis on security equipment upgrade and staffing was needed. During the latter portion of the SALP period, action was taken by licensee manage-ment to increase security staffing at the site. The site security group is being transferred to a new manager and the licensee has committed to adding additional security personnel. A major upgrade of the security system was in progress at the close of the SALP period which will include a new security computer system and access control / logging / monitoring equipment. Licensee handling of significant issues and responsiveness to correcting problems has been adequate; and improvement was noted.
Four violations were identified during the assessment period.
These violations were considered isolated and not indicative of' a programmatic breakdown. The violations did indicate some weak-nesses in access controls, security force staffing and contractor management's sensitivity toward security violations. The licensee was responsive and initiated prompt and extensive corrective
- actions, including contractor awareness training. The violations identified were
(1) Severity Level III violation for failure to implement vital area access controls.
(2) Severity Level IV violation for failure of contract security supervisors to notify licensee management of violation
-(1) above.
(3) Severity Level V Violation for failure to implement protected area access controls.
(4) Severity Level V Violation for failure to properly man the central alarm station.
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~b. Conclusion
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Category: 2
~ Trend: Same.
- c. Board' Comments ~-
iPerformance was evaluated as Category 2 during the previous SALP-assessment. Licensee resources were reasonably effective such that: satisfactory - performance with respect to security and
. safeguards was achieved. No decrease in licensee or NRC attention
- in this area is recommended.
I 8. Refueling ca. Analysis During this assessment. period inspections of refueling activities
- were performed.by the regional and resident-inspection' staffs.
A, refueling outage commenced in January 1984 and was in progress
- at the end .of this -a'ssessment . period. No violations .and only minor followup items were -identified. Preparations.for defueling-
-and review of. procedures'were found to be adequate. ? Fuel handling
~
' activities - were observed and found to be in compliance with applicable technical specifications and regulations. The reactor '
- . engineering ' staff was~ adequate, and the licensee.has provided the
- l' reactor engineering section with more.. training 'and interface..
guidance. 'These actions have improved Jliaison .between the plant
'and-the'cor'porate fuel section. The licensee's extensive prepara-
~ tion for this tiongJ outage' has- resulted in reduced ' exposure to; '
workers while meeting outage schedule goals.
~ During - the assessment.. period, the licensee implemented ;a - new concept in outage management. -The.use of the new outage:organiza-tioni.has ' allowed : the licensee to better track ongoing and projected work activities while ensuring the completion 'of docu-
-mentation.
, ,1b. Conclusion .
3 1 ', . Category: 1 ]
L ,
Trend: -Improved Jc. Board Comments-Performance was evaluated as Category I during the previous'SALP assessment. Licensee management attention was aggressive in this
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24 area. No. decrease in licensee or NRC attention in this area is recommended.
- 9. Licensing Activities
- a. Analysis The assessment of licensee performance was based on an evaluation of the following licensing activities:
Project. Management Administration Adequacy of Station Electrical Distribution, (B-48)
Containment Pressure Setpoints NUREG-0737, items II.F.1.4, 5, and 6 Miscellaneous Technical Specification Revisions Steam Generator Repairs Radwaste Scaling Factors Appendix R (Fire Protection)
Radiological Technical Specifications In general, management inv'olvement has improved. Corporate management has usually been involved in site and corporate licensing activities, and responses have generally been timely.
Monthly management status meetings have been established between the NRC and . licensee representatives. Management has generally
- taken a more active role in technical problems and meetings as compared .with the previous reporting period. Improvement was evident during this SALP period in the licensee approach to resolution of technical issues. Generally acceptable resolutions were proposed. Licensee understanding of the issues was apparent and conservatism was generally exhibited, which allowed for timely a resolution of the issues.
The monthly meetings between the NRC and the licensee have allowed for responses to be viable and timely, with infrequent extension requests. Only one issue of those reviewed for this SALP period has continued for an extended period - Appendix R exemptions.
The licensee has recognized the problems with closing out open items and management has taken the initiative in making changes in the o'rganization and staffing to improve this situation. Addi-tional corporate licen'ing s personnel as well as an onsite licensing representative, have been added, to improve communica-tions between the corporate headquarters and the plant site.
Executive management has taken an active role in this area, and the results show improvement over the previous evaluation period.
The recent reorganization ensures that project reporting will come from onsite except in the areas of quality assurance, nuclear safety, and training. Previously project personnel reported to corporate.
25 An overall comparison between the previous SALP period and this period demonstrates a significant improvement in all areas, particularly in management involvement.
.b. Conclusion
. Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP ~
assessment. Management involvement in this area was evident.
- 10. Quality Assurance a'. Analysis During this assessment period, routine inspections were performed by the resident and regicnal inspection staffs.
The corporate quality assurance staff was reorganized in June 1983. Reporting to the Corporate QA Manager are the Construction QA/QC Manager (responsible for the Harris site); the Operations QA/QC Manager (responsible for the Brunswick and Robinson sites);
and the QA Services Manager (responsible for the QA engineering staff, vendor surveillance staff, Performance Evaluation Unit - -
staff (PEU), and the QA training and administrative staffs).
This reorganization has strengthened corporate QA by providing direct management supervision overseeing various staff activities.
The .following changes were in progress at the end of the SALP period:
-Increased management attention was being exercised to assure regulatory compliance relative to auditing activities.
The Corporate QA staff was being increased by five additional personnel.
~
The Corporate QA procedures were being rewritten to make them more understandable and implementable.
A proposed Topical Quality Assurance Program was being written.
A. contract was being considered for increased auditor training.
26 Auditing functions were performed by the FEU. Audits were generally complete and thorough. However, interviews with QA personnel indicated that approximately 75% of the auditor's time was devoted to paperwork reviews. Consequently, audit findings were somewhat limited to verification that records were properly completed. Due to as many as 10 to 12 areas being covered during an audit, findings tend to be shallow even though the audit met regulatory requirements. With an increased amount of audit training and an increased number of personnel, it is expected that audits will become more effective in cetermining the overall acceptability of the quality assurance program. Auditing records and training records for audit personnel were generally complete, well maintained, and available for review.
The licensee was generally responsive to NRC QA initiatives. Of eight previously identified NRC items, seven were closed based on NRC review of completed corrective actions. The remaining item had appropriate corrective actions in progress.
Special inspections were conducted of licensee preplanning for the
-steam generator replacement. Appropriate management controls had been directed to this effort. The onsite QA/QC group was expanded to support this activity.
The licensee has generally adequate QA procedures and policies as evidenced by NRC review and discussions with QA personnel. The onsite QA organization has continued to establish new procedures and revise existing QA inspection and surveillance procedures in' an effort to provide improved inspection techniques in a broader range of technical areas. Licensee records were generally well controlled and easily retrievable. Procurement activities appeared well controlled and documented. Onsite QA personnel at all levels were consistently responsive to NRC concerns and correction of enforcement items. Reviews of onsite QA nonconform-ance reports indicated that surveillance and inspection activities were generally thorough. Corrective actions for the items identified were usually adequate to above average.
Onsite QA staff training appeared adequate, although the viola-tions below indicate some lack of attention to detail. Staff training has improved in the area of plant operations surveil-lance, as the licensee has sent some onsite QA inspectors to the basic plant systems course. This is expected to improve the depth of inspection in the technical area of plant operations. The technical expertise of the onsite QA staff has improved over the assessment period due to increased training and experience and due to supplementing the staff with contractor personnel. Additional enhancement of this area should continue in order to ensure in-depth review of highly technical and specialized functional areas.
i';
o e ,
27 The PEU conducted adequate audits at Robinson. Increased corporate level management attention to the- audit function was noted during the assessment period and corrective actions have generally been implemented to assure that audits were conducted at proper frequencies _with reports and responses issued in .a timely manner. The licensee has not made significant progress in the use of audit teams supplemented by individuals with special expertise.
Increased temporary use of individuals with detailed operations, maintenance, engineering, and health -physics expertise has not been evident' in PEU audits and should be used for technical viability.
Two violations were identified during the assessment period and did not indicate a programmatic breakdown.
(1) Severity Level IV Violation for an inaccurate statement concerning corrective action that was taken in response to a violation and which was not identified during QA inspection activities.
(2) Severity Level V Violation - for failure to establish an adequate inspection program.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. Licensee resources appeared adequate in this area.
No decrease in licensee or NRC attention is recommended. ;
B. Supporting _ Data
- 1. Reports Data
- a. Licensee Event Reports (LERs)
Thirty-four LERs were ' reviewed for Robinson Unit 2 for this assessment period.
These reports were categorized in terms of SALP functional areas as follows:
Operations 10 Maintenance 18
y _
28 Surveillance 3 Quality Assurance 1 Radiation Protection 2 The LERs for this plant were evaluated for completeness and accuracy. Component failure _ prompted the majority of LERs. The event descriptions 'were' clear and detailed, and supplemental information was provided for every LER. In each case, the licensee made an attempt to determine the root cause of the event and possible implications of the event to other plant equipment.
If numerous failures occurred, an investigation was conducted to determine if the problem might be generic. One weakness noted was that submission of supplemental LERs, for LERs having unresolved or incomplete corrective actions, was not timely. Two additional minor weaknesses were noted: inconsistent LER system coding for similar/ identical events and similar occurr.ences not being referenced by LER number.
- b. Part 21 Reports None
- 2. Investigation and Allegation Review One allegation involving the area of health physics was examined by the .
staff. It was not substantiated.
- 3. Enforcement Actions
- a. -Violations Severity Level I, II - 0 Severity Level III - 2 Severity Level IV - 17 Severity Level V - 18
- b. Civil Penalties November 1983 - 520,000.00 for one Severity Level III violation for failure to implement vital area access control.
29 4
March 1984 -
proposed $30,000.00 for one Severity Level III violation for failure to implement radiological and key control procedures associated with personnel entry into the reactor vessel sump,
- c. ' Orders
' March 14, 1983 - confirming licensee commitments on post-TMI related issues.
February 21, 1984 - confirming licensee commitments on emergency response capability.
- d. Administrative Actions None
- 4. Management Conferences March 28, 1983: Enforcement Conference; radioactive waste shipment containing free liquid.
June 28, 1983: Management Meeting; status of planning and preparations for the steam generator replacement outage.
August 16, 1983: Enforcement Conference; safeguards violations.
~~
February 23, 1984: Enforcement Conference; violations of radiation protection requirements and effectiveness of management controls.
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> .V. PERFORMANCE ANALYSIS FOR BRUNSWICK 1 & 2 i
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m 31 A. Functional. Area Evaluation Licensee Ac.tivities
-Brunswick 1 started .the assessment period in cold shutdown for a planned outage. The shutdown occurred on December 10, 1982. During the outage, major-licensee activities at Brunswick 1 included refueling, torus modifica-tion, off gas system replacement, condenser retubing, analog instrument installation, TMI modifications and recirculation piping weld overlay. The unit restarted on August 26, 1983. The unit experienced approximately 275 days of planned outage time, plus 14 days of down time associated with four scrams. At the close of the period, Unit I was at full power.
Unit 2 began the period at power. At the end of the assessment period, Brunswick 2 was in a refueling and modification outage which began March 12, 1984, and is projected to last until early f all. The reactor has been, defueled and work has begun on the torus modification, off gas system replacement, condenser retubing, analog instrument installation, TMI modifications and ten year inservice inspection program. During this period, two completed outages totaling 94 days were undertaken for TMI modifications, diesel generator starting circuit modifications and recircu-lation pipe weld inspection and overlay. The unit has experienced approxi-mately 160 days of planned outage time plus 12 days of down time associated with 5 scrams.
Management attention was focused, during the assessment period, on implemen-tation of programs and completion of the task to upgrade the overall performance of the Brunswick facility, as detailed in the Brunswick Improve-ment Program.
Inspection Activities Increased _ inspection efforts recommended in the previous SALP were manifested in the assignment of a third resident inspector to the site.
Special inspections were conducted for emergency breparedness exercise, related inspections, steam jet air ejector (SJAE) radiation monitor inoperability event, standby gas treatment system (SBGT), deluge system isolation event, TLD tampering event, special safeguards inspection, and TLD transferring . event. Enforcement conferences were held for three of the events: the SS3T deluge system; the SJAE radiation monitor event; and the security event. Brunswick was also the first site to undergo the NRC administered reactor operator and senior reactor operator requalification examinations.
- 1. Plant Operations
- a. Analysis During the assessment period, inspections of plant operations were performed by the resident and regional inspection staffs.
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- y 4
, . - ~
32 Significant improvements ~ in plant operations have been noted during the period, indicating significant management attention'and direction of resources into this area. The Brunswick Improvement Program (BIP) . initiated.during _the last SALP period, required the total . rewrite of operations and annunciator procedures during 1983. This milestone was reached on time and resulted in a high quality tool that was well accepted by the plant staff. The operations unit was reorganized and a new Operations Manager and Principal- Engineer were hired. The reorganization included a new position of Operations Superintendent whose job was to run the day-to-day affairs of the operating shif_ts. This change allowed the operations ' manager to . better focus his attention to opera-tional problems. The reorganization has worked very well.
- Administrative staffing increases to the operating shift have allowed a redirection of. key supervisory individuals on shift from administrative to operational duties. The facility management continue to focus on the needs of the operations staff as shown through the progressive attitude toward the use of computer aids in the control room, control room appearance, human factors upgrade, and staff . incentive programs. This dedication to improvement has resulted in a decrease in operator turnover, overall improved morale, and fewer regulatory violations. A sig'nificant event occurred early in the period regarding the steam jet air- ejector radiation monitor isolation. During the enforcement conference for this event, a high level of intensity toward detailed investigation on behalf of the plant staff to identify and correct root causes of problems was noted. This intense and ~ aggressive attitude _was a direct contributor to the . .
decline _ in the number- and significance of regulatory related events during the 'latter portion of- the . period. The staff continued to be.very. responsive to NRC initiatives.
Minor operator errors continued to occur. Operator inattentive-ness . led ' to suppression pool levels exceeding allowable . limits; loss- of a- diesel generator due t6 failure to utilize appropriate procedure; and unit scram on mode switch changed by reactor operator. _ These errors, though individually not safety signifi-cant, must be overcome for the staff to achieve the expected levels of-' excellence.
~
Training of operations personnel has reached its highest level in plant history with the addition of new on-site training facili-ties, a plant specific simulator and a professional attitude toward the individual needs of students. Improved morale and confidence in the plant staff has resulted.
Licensed operator requalification training has improved due to a new training director being appointed and a new dedication to training shown by senior management. Many retraining program aspects, such as study mater.ial and classroom lectures, have been revised. Requalification training records were well maintained L
33 and readily available. General Employee Training (GET) was being
-upgraded, with the previous two part program being revised to three parts. Implementation began in October 1983. GET training records were well maintained and retrievable. The site is presently implementing a formal Auxiliary Operator (AO) training program which is extensive and should reduce A0 errors, and increase overall knowledge.
During the _ SALP reporting period, replacement examinations were administered to 20 Senior Reactor Operator (SRO) candidates and 17 Reactor Operator (RO) candidates during two site visits. Of the 20 . SR0s , 16 passed and of the 17 Ros,11 passed. The passing rates of 80% for SR0s and 65% of R0s are characteristic of the industry average.
'In June 1983, requalification examinations were administered by the NRC to 15 randomly selected licensees including 8 SR0s and 7 R0s. All candidates received a four category written examination and in plant oral evaluations. Eleven of 15 passed the written examination while all passed the orals. Those who failed the written examination were removed from licensed duties and participated in accelerated retraining prior to being re-examined and returned to duties. On the basis of the written and oral pass rate, the Brunswick requalification program has been evaluated as satisfactory for the current year.
On-shift "real time" training on significant events, occurring both on-site and in the industry, provided for a timely operator-awareness of potential problems. This concept began during this SALP period and has proven to be very beneficial.
Licensee investigation and analysis of reportable events improved with the advent of Operating Instruction 01-22, " Plant Incident and Post Trip Investigatiops" investigations. The redirection of Shift Technical Advisor and operating engineer time into this valuable area resulted in more in-depth reviews of events and led to the utilization of aids such as parameter trending to predict problem areas. This increased effort was warranted as two viola-tions occurred early in the period for f ailure to make timely 10 CFR 50.72 reports (Violations (2) and (4) below). Continued emphasis on analytical problem solving techniques by shift.
personnel may aid in preventing errors associated with procedural deficiencies.
Nine violations were identified during the assessment period:
(1) Severity Level III violation for the improper return of the SJAE radiation monitor to service.
a
[
3 34 (2) Severity Level IV violation for failure to make a timely 10 CFR 50.72 report associated with Standby Gas Treatment
. deluge system.
(3) . Severity Level V violation for failure to implement Operating Procedure, OP 41.
(4) Severity Level V violation for failure to make a timely 10 CFR 50.72 report associated with the SJAE radiation monitor.
(5) Severity Level V violation for an inadequate procedure.
Certain valve stem leakoff valves were not identified on the procedure's valve line-ups.
- (6) Severity Level V violation for failure to follow procedures 1.eading to the existence of outdated procedures in the_ remote shutdown panel.
. l
.(7) Severity _ Level V violation for an inadequate procedure which !
led to an inadvertent reactor scram. The procedure failed.to identify that intermediate range monitors needed to be checked prior to mode switch changes. i i
(8) Severity Level V violation for an inadequate procedure which 1 failed to identify complete valve line ups.
(9) Severity Level V violation for failure to post per 10 CFR 19.- *
- b. ' Conclusion Cagetory 2 i
Trend: Improved ;
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. The Board noted that significant improvement has been achieved during this period. Continued management and NRC atten-tion will ensure'that additional improvements are realized.
- 2. Radiation Controls
- a. Analysis During the assessment period, inspections were performed by regional and resident inspection staffs.
35 The radiation protection program continued to show improvement when compared to findings of the previous evaluation period.
Health physics coverage of work in progress has increased since the previous SALP period. The radiation protection area accounted for one violation ((1) below) with two examples of failure to perform air sampling. One of these examples led to an internal deposition and was due to a worker performing unauthorized work.
The ALARA program was supported by management and contained several exposure reduction elements including the Radiological Information -Management System which was added to -provide a computer based Radiation Work Permit (RWP) Dosimetry record system and a management record system for exposure control and manage-ment.
During 1983, the total collective dose was 3492 man-rem. This is high as compared to about 2000 man-rem average for a two unit BWR, but a reduction from the previous year was evident. The high man-rem exposure for the plant was related to both units accumu-lating over 400 outage days during calendar year 1983.
The licensee has plant systems and other applicable training for
.the health physics technicians. Subjects are chosen to meet staff needs. Qualifications of contract technicians that are used to supplement the health physics staff are verified through a screening proces!, prior to selection.
The licensee's efforts to decontaminate the contaminated areas in-the plant have been very effective.
The health physics organization has specialists in the areas of in plant health physics, dosimetry, respiratory protection, radwaste transportation and ALARA, and a technical support group.
The unit addpd additional technicians and supervision over the past assessment period which made this organization - highly effective in supporting plant maintenance and operations both during outages and normal operation.' The health physics group has developed a good working relationship with other plant organi-zations, which made planning and worker protection easier.
- The radwaste program, consisti.ng of liquid, gaseous and solid radwaste, accounted for ~one violation (3) in the surveillance section below for failure to properly perform a step in the SJAE monitor calibration procedure. The licensee modified the Unit 1 gaseous waste system to allow additional hold up time for decay.
This modification will be added to Unit 2 during a future outage period. The modification is expected to reduce the waste gas releases. During the latter half of the evaluation period, the licensee initiated an aggressive solid waste reduction program.
p 36 Although waste reduction methods were' initiated, the waste volume will run above average for.similar sized plants due to the large number of outage days in the period.
The radioactive waste transportation program received one viola-tion ((2) below). This violation was in part due to inadequate procedures from a vendor for preparation of a cask for shipment.
The radwaste transportation program was well managed.
The environmental monitoring program was effectively managed with adequate staffing and support at the site and the Harris Environ-mental Center, where the radicanalytical work was performed.
Licensee investigation of the cause of elevated Co-60 concentra-tions in sediments from the discharge . canal was adequate. The sampling frequency of sediments was increased to help identify the sourcelof Co-60 and provide corrective actions. The environmental monitoring program was implemented in accordance with Radiological Environmental Technical Specifications.
One QC and confirmatory measurements inspection was performed during the evaluation period using the Region II Mobile Laboratory. No violations or deviations were identified. The inspection disclosed appropriate licensee QC actions in the counting room area to identify and correct an effluent measurement problem. The results for all . liquid, gaseous and particulate samples analyzed showed agreement with the NRC analytical measure-ments. All other aspects of the laboratory program met or exceeded requirements.
Of the two violations identified during the evaluation period, none were indicative of major program weaknesses. The radiation protection, radioactive waste management, transportation, and environmental and quality control programs were well managed. The licensee was. responsive in correcting the causes of the violations identified below:
(1) Severity Level IV violation for failure to perform air sampling.
(2) Severity Level IV violation for failure to prepare a radio-active material shipping cask as required by the NRC certificate of compliance.
b. Conclusion
Category: 1 Trend: Improved m
7 37
- c. Board Comments Performance was evaluated as Category 2 during the previous SALP assessment. Licensee management attention was aggressive in this
' area. No decrease in licensee or NRC attention is recommended.
- 3. Maintenance
- a. Analysis During the assessment period, maintenance activities were inspected by.the regional and resident inspection staffs.
Improvement was noted in management controls and involvement in assuring quality maintenance activities, identified as areas of concern during the previous assessment period. Specifically, previously identified areas of.significant programmatic breakdown, such' as post maintenance testing and calibration of technical specification associated instruments, now have programs esta-blished to address these problems. However, continued expansion and improvement are required to ensure uniformity of work practices. Maintenance instructions in many areas remain poorly understood, leading to decision making at a level which seldom .]
ensures adequate management review. This area was being aggressively addressed with the' addition of . contract support to rewrite maintenance procedures. Supervisory presence in field maintenance activities showed significant improvement over the period. -
The licensee's approach to the resolution of technical issues exhibited conservatism. The incorporation of industry standard as suggested by INP0 and other organizations, led to improved craft skills which compliment the efforts of site QA in ensuring quality work on plant systems. The gooc interface between operations and maintenance caused obvious improvement in .the development of coordinated. staff resolution to complex system problems.
The licensee has been receptive to NRC initiatives. Problems of regulatory concern have subsided during the period as the licensee's programs evolved to address long-standing regulatory issues. Continued sensitivity. in this area should lead to total resolution of regulatory concerns.
The previous SALP assessment addressed a concern in the field of training. The licensee, in response, added three training specialists to the maintenance staff to participate in maintenance on-the-job training. In addition, the maintenance manager was
. participating in SRO license training at the end of this evalua-tion period.
9 38 Improvements in performance were observed in upgraded procedural requirements, attention to detail, uncerstanding of technical issues, and improved surveillance of vendors.
Although marked improvement has been observed, and only two viola-
' tions were identified, the extensive problems identified in the
. previous SALP were not fully overcome. _The licensee has a program in' place, that when fully implemented, will create a high quality maintenance unit.
The violations identified in this reea were as follows:
(1) Severity Level III violation for failure to place an item on
-the Q List.
(2) Severity Level IV violation for inadequate temporary proce-dure change control.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. Licensee resources were reasonably effective, such -
that satisfactory performance with respect to operational safety was achieved. No decrease in licensee or NRC attention in this area is recommended.
- 4. Surveillance and Inservice Testing
- a. Analysis Surveillance and inservice testing activities were inspected by the regional and resident staffs.
General Surveillance During the review period, significant progress was made in program development as a result of management involvement promulgated by the Brunswick Improvement Program. This increased involvement-led to corrective action systems that generally recognized and addressed both reportable and nonreportable events. The quality assurance and on-site nuclear safety groups' involvement has increased the technical overview of surveillance activities and has resulted in - improved performance. Marginal procedures continue to plague efforts to significantly improve the groups'
39 performance. Use of these procedures by less experienced technicians contributed to violations (3) and (4), below. Present management emphasis on procedural improvements, as evidenced by a significant effort to rewrite periodic tests, has been recognized as a major step in correcting this long standing deficiency.
Progress has been seen in the upgrading of technician training, such as through the use of vendor supplied simulators for complex integrated control system troubleshooting of the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems. The stressing of personnel accountability for work, improved training, and-improved procedures provides the basis for adequately stated and understood policies in this area.
The licensee's approach to the resolution of technical issues provided for conservative, sound and thorough resolutions. This is exemplified in the correction of long standing problems with Average Power Range Monitor spiking and feedwater pump controllers performance. A more fundamental understanding of the importance of surveillance in the overall operation of the plant improved departmental relationships and 'resulted in unified approaches to plant problems. The licensee was receptive to NRC initiatives, as well as initiatives by other plant groups, and generally proposed acceptable resolutions. Continued close contact and a technically diversified staff should provide for continued improvement of regulatory understanding in the surveillance area.
Inservice Inspection and Testing (ISI, IST) , ,
Corrective actions initiated by the licensee to strengthen their surveillance and inservice testing programs began to achieve positive results early in the reporting period. The licensee's inservice testing program for pumps and valves reviewed during late July 1983 reflected - the licensee's commitment to a . quality program. The results of this review indicated the following:
The licensee had submitted a comprehensive IST program. When required, the licensee quickly submitted a revision to the IST program that included acceptable resolutions of out-standing items.
- The licensee had established an engineering group specifi-cally for IST s'urveillance.
The licensee had developed a computerized tracking system for IST surveillance testing and was implementing the IST program as required.
With the help of a contractor, all of the IST procedures had been reviewed and updated.
L._
40 Throughout discussions with licensee personnel, there were repeated references to corporate management involvement in the upgrading of the IST program.
- As related to surveillance of welding and inservice inspection activities: CP&L's progress in pre planning, staging, and executing outage activities; housekeeping,' care .and -preservation of equipment;-personnel training and employee attitude; and CP&L's cognizance of vendor personnel and production showed marked improvement.
The violations identified in this area were as follows:
(1) Severity Level V violation for failure to provide a procedure to test isolation of mechanical vacuum pumps.
(2) Severity Level V violation for an inadequate procedure for testing of SBGT system dampers.
(3) Severity Level V~ violation for failure to follow the procedure for calibration of the SJAE radiation monitor.
(4) Severity Level V violation for failure to follow ISI procedure for recording angle beam data.
- b. -Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. The proper amount ' of management involvement was directed to this area. No decrease in licensee or NRC attention is recommended.
- 5. ~ Fire Protection
, a .- Analysis During this assessment period, inspections of fire protection activities were performed by the resident inspection staff.
Early . in the assessment period, serious breakdowns in the imple-mentation of the fire protection program, brought about by poorly stated, poorly understood, or non-existent policies, and general-lack of management's involvement and control, led to a civil penalty _ which was assessed in February 1984 ((1) below). Lack of
.m c
41 personnel training and management support was further reflected in violations (3) and (4), below.
Immediate and significant management attention was observed by NRC subsequent to inspections surrounding events related to.the civil penalty. Restructuring of the fire protection group and placement of an operations principal engineer directly responsible for fire protection activities resulted in an increased visibility and understanding of the role of fire protection in plant activities.
An aggressive, thorough program is underway, dedicated toward identifying and correcting program deficiencies.
Licensee management, in written responses to the civil penalty actions, outlined a far reaching program aimed at elevating the status of the. fire protection function to a level of safety well beyond minimum Technical Specification requirements. This was
.. expected to eliminate future problems in this long standing weak area. The improvements were to include the areas of training and procedures.
An increased number of personnel, additional experience gained in past events, and continued management attention have led to significant improvement through this period.
Violations identified during this assessment period were as follows:
(1) Severity Level III violation for exceeding the limits of a Technical Specification action statement associated with the SSGT deluge system.
(2) Severity Level IV violation failure to post a fire watch where required by Technical Specifications.
(3) Severity Level IV violation for failure to implement surveillance procedures.
(4) Severity Level IV violation for' failing to submit special reports required by Technical Specifications.
, (5) . Severity Level IV violation for failure to follow a procedure associated with positioning of yard fire main valves,
b. Conclusion
Category: 2 Trend: Improved Lt.
42
- c. Board Comments P.erformance was evaluated as Category 3 during the previous SALP assessment. Licensee resources appeared to be properly applied in this area. No decrease in licensee or NRC attention is recommended.
- a. Analysis During the assessment period, insp?ctions were performed by regional and resident inspection staffs. These included observa-tion of a full scale emergency exercise. The routine inspection addressed emergency response and the related implementing procedures.
A well staffed corporate emergency respense planning organization provided support to the plant organization. Key positions in the corporate emergency response planning organizations were filled with experienced personnel. Corporate management was committed to emergency response programs and had direct involvement in the annual exercise and followup critiques. The plant emergency planning program includes a highly qualified, full time emergency preparedness coordinator. Plant management demonstrated keen awareness of emergency preparedness issues and was supportive of staff needs. The licensee was responsive to NRC initiatives. I A good working relationship and high degree of cooperation exist between the plant and offsite emergency support organizations.
The following essential elements for emergency response were found to meet or exceed standards: the method for revision, review and approval of emergency preparedness program plans and procedures; ;
emergency detection and classification; notification and communi-cations;- public information; shift staffing and augmentation; training; dose calculation and as se s smer.t ; emergency worker protection; post accident measurements and instrumentation; and, annual QA audits of plant and corporate emergency planning program.
One exercise clearly demonstrated that the emergency preparedness program plan and respective procedures could be effectively implemented by the licensee's emergency organization. During the exercise, the plant emergency director demonstrated firm direction and control over the emergency organization.
Licensee critiques of emergency response activities during the annual exercises were thorough and effective. Tracking systems were established as a means of ensuring corrective action on exercise and drill identified items. Significant improvement in
43 onsite emergency response facilities was also noted. At the end of the assessment period, the licensee's new emergency response facilities were nearly completed. These facilities will be reviewed during the forthcoming appraisal.
One deficiency was identified as discussed below.
The licensee's plan and procedures did not incorporate federal guidance. requiring that protective action decisions be based on ;
plant conditions. The guidance further requires that, in a i general emergency, the licensee make a recommendation for 4 precautionary evacuation of a two-mile radius around the plant.
The licensee was immediately responsive to the NRC finding. In ,
response,. the-licensee initiated development of a logic matrix to assist the shif t supervisor in directing implementation of the emergency plan.
- b. Conclusions Category: 1 Trend: Improved
- c. Board Comments I
Performance was evaluated as Category 1 during the previous SALP l assessment. Licensee management attention in this area was ' '
aggressive. No decrease in _ licensee or NRC attention is recommended.
- 7. Security and Safeguards
- a. Analysis ,
During this assessment period, inspections of security and safe-guards were performed by the regional and resident inspection staffs.
Security staffing was adequate and performed in a professional manner. Training of personnel was thorough, and was reflected in job performance. Personnel morale was good. The licensee was
~
responsive to ~ NRC initiatives. The licensee continues an aggressive program of repairing and maintaining security equip-ment. This effort reduced compensatory measures by 26,000 man-hours compared to the previous period. Site management supported the security program, and security awareness was positive.
Licensee handling of significant issues and responsiveness to correcting problems was good.
i
b 44 Two violations were identified during the assessment period.
Although one Severity Level III violation ((1) below) was issued, no civil penalty was imposed due to prompt corrective action.
Two violations were identified during the period as followst (1) Severity Level III violation for an authorized employee entering the protected area without being searched and without a security badge.
(2) Severity Level IV violation for having a designated vehicle in the protected area which was not secured and which had a key in ignition.
~b. Conclusion Category: 1 Trend: Same
- c. Board Comments Performance wa evaluated as Category 1 during the previous SALP assessment. Licensee resources were effectively used such that a high level _ of performance was achieved. No decrease in licensee or NRC attention is recommended.
- 8. Refueling - -
- a. Analysis During this assessment period, numerous inspection man-hours were expended in refueling operations by the resident inspection staff.
Activities on the refueling floor and in the control ' room showed evidence of prior planning and assignment of priorities. Well stated, clearly defined procedures were utilized for control of activities. Management involvement and control improved signi-ficantly compared to the previous period. This performance improvement is expected to continue.
' During the latter part of the SALP period, the site reorganized and created an outage management section. In previous extended outages, the licensee had not effectively managed the ongoing activities. This was evident- from the .long outage time estimate overruns that occurred. This.new management concept appeared to be the solution to previous problems, in that Unit 2 is well into an extended outage and was within one day of schedule at the close of the assessment period. Strong management and the addition of computerized outage scheduling appeared to have solved previous problems.
b
45
- b. Conclusion Category: 1 Trend: Improved
- c. Board Comments Performance was evaluated as ' Category 3 during the previous SALP assessment. Licensee resources were ample and oriented toward nuclear safety. No decrease in licensee or NRC attention in this area is recommended.
- 9. Licensing Activities a: Analysis The assessment of licensee performance was based on an evaluation on the following licensing activities:
Project Management Administration Response to NUREG 0737 Items Control.of Heavy Loads Environmental Qualification Mark I Containment Spent Fuel Pool Expansion NUREG 0737 Supplement I-Items Adequacy of Station Electric Distribution System
- Masonry Wall Design #
Radiological Effluent Technical Specifications NUREG 0737 Technical Specifications Reactor Protection System Review Pipe Crack Inspection Containment Vent and Purge Review :
Reload Review 17 Additional Technical Specification Change Licensing Actions Direct involvement by corporate officers and other corporate management was highly evident during this period. In particular, close attention to the battery problem, Appendix R, and Environ-mental qualification, showed the positive results of direct involvement of management in producing a high quality product. In the case of the battery problem, a project organization was established with appropriate technical expertise as well as management attention and involvement. Several issues involving amendments which were part of the Brunswick Pilot Effort
- were "On about October 1,1983, a special cooperative effort was begun by CP&L and NRC
-to clear up as much of the Brunswick Licensing backloc as possible in a short time (3 or 4 months). This special effert is referred to as the Brunswick Pilot Effort.
.. i 46
_; ?
' delayed by slow responses and poor co . lunication within CP&L.
Upon bringing the problem to the attention of CP&L management,
. there was 3a quick response to correct the situation for the i'mmediate problem as well as for the long range future. ~'
Steps were taken to increase CP&L-licensing staff, communications, and effectiveness on a permanent basis. For example, a licensing staff member will be located at the Brunswick site and an additional staf f member was' added in the ' corporate office.
Monthly review meetings were instituted to review the status of
. licensing actions.
f 'There appeared to be a clear understanding of most technical A issues, and ' workable approaches were taken to resolve them. The
' overall technical competence was good. Sound technical basis and conservatism were general _ly provided to support the licensee's 1
positions. These attributes were most aptly demonstrated in responding to the actions on the battery problem, where the I'i f w s personnel involved exhibited a clear understanding and conserva-l tive approach to its solution. Responses to NRC initiatives werei usually timely. For those that were late, the licensee usually' ,
al provided advance notice to the NRC. The timeliness problems that developed during the Brunswick Pilot Program were resolved.
- The licensee's staff for implementing licensing actions was adequate. While there was a period during the pilot effort whe're
.the licensee's staff was not as responsive as necessary, steps
<g d were taken by CP&L management to improve the situation. The lice'nsee plans to increase the licensing staff by one at the' plant and one at the corporate office.
The licensee's staff has demonstrated willingness to work with the NRC in a timely manner. They have an understanding _ of ' plant design and operations. Their responsiveness in most licensing issues was impressive. Management capability in licensing was strengthened, and the licensee made a strong commitme,nt to licensing activities.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. The Board noted that considerable improvement was achieved during this period. Licensee performance during the latter portion of the period was at the Category I level. No 4 decrease in licensee or NRC attention is recommended.
,5-s
,}'.
9.
47
- 10. Quality Assurance-
- a. Analysis During this assessment peribd, routine inspections were performed by'the resident and regional ' inspection staffs.
~ The corporate quality assurance staff was reorganized in June 1983. The new organization and functions are described in the Robinson section of this report.
Audit records and training ~ records for audit personnel were generally complete, well maintained, and available for review.
Corporate presence on site recently improved. The last audit revealed an improved attitude toward providing substantive feed-back to the site beyond minor editorial comments. The effort to fully understand findings, and demand conclusive long-term corrective actions-for meanihgful audit findings, can be provided by those persons experienced in the areas being audited. For this reason, the QA organization needs to be innovative in its efforts
.to improve its service to CP&L, such as using qualified personnel from other sites to provide indepth critical reviews.
The corrective action system- generally recognized and addressed
~
nonreportable concerns. With increased management attention to regulatory commitments, audit findings were being tracked and closed in a more timely manner. Where corrective action problems ~
occurred, escalation to a higher level of management was used to obtain resolution. The onsite QA surveillance group was involved with increased open item tracking mechanisms and has obtained timely resolution of identified problems. Procurement activities were generally well controlled and documented. Minor problems were identified with vendor qualifications and distributors. The problem with vend'pr qualifications was evaluated and corrected.
The problem with distributors was under evaluation. The facility experienced a few problems of minor significance in the design control or verification program. Two problems were identified, and involved the need to clarify regulatory specialist and Plant Nuclear Safety Committee review responsibilities. These were being evaluated by the licensee at the close of the assessment period.
The licensee was generally-responsive to NRC QA initiatives. Of fourteen previously identified items, twelve were closed based on NRC ' review of completed corrective actions. The remaining two items could not be closed during the assessment period; however, appropriate corrective actions were-in progress.
The site QA staff significantly improved its onsite presence and its performance reflected the increased attention required by the previcus SALP.
n AS The QA surveillance group performed inspections of licensee commitments to NRC and other agencies-in a prompt and professional manner, which reinforced-and enhanced the overall quality of the site preparation and . issue -of important correspondence. The quality of technical . inspections, in many cases, was very good.
Preparation for, and insight into, the particular area in which the- surveillance was performed was also good. This type of insight was . possible because of the addition of operations experienced. personnel and .0A engineers to the staff. QA management onsite appeared dedicated to continued improvement of both the adminstration and execution of the. program. Examples of recent improvements are: the Director of QA personally reviewed all significant Nonconformance Reports (NCRs); NCRs were categorized according to severity in order to eliminate compla-cency associated with issuance of numerous NCRs on both safety and nonsafety subjects; and, escalation of inadequate responses were streamlined to provide for more prompt management involvement.
This progressive attitude toward the QA function on site improved the relationship of QA with other site organizations. Onsite QA continued to be responsive to NRC concerns.
An area where present and future efforts needed to be increased was the overall QA visibility and involvement. To continue to evolve into a service organization, which provides an obvious return for the manhours expanded, QA needs to take a more aggressive role in interpreting and promoting high quality standards; (e.g., QA expanding hold points in procedures, quality
- inspections which go beyond the scope of specific tasks, and providing a quick and easy mechanism for general employee feed-back). Senior management was dedicated to increasing QA's presence and quality.
One violation was identified during this evaluation period.
Severity Level V violation for failure to have adequate procedures to control the review, approval, and issuance of enhanced control drawings.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 3 during the previous SALP assessment. Improvement was noted. However, NRC and strong management attention should continue.
49 B. Supporting Data
'1. Reports Data
- a. Licensee Event Reports During the assessment period, there were 60 LERs reviewed for Unit 1, and 85 for. Unit 2. The distribution by SALP Functional Area is shown below:
SALP Functional Area Category Unit 1 Unit 2 Operations 34 67 Maintenance 1 0 Surveillance 20 10 Fire Protection 3 1 Quality Assurance 2 7 TOTAL 60. 85 The LERs were evaluated for completeness clarity, understand-ability and adequacy of content. The LERs were assessed to provide sufficient data to give clear and adequate descriptions of the occurrences, their direct consequences, and the corrective actions taken. The LERs were correctly coded and the codes agreed with the narrative descriptions. Supplementary information and followup report were submitted as applicable. The review indic-ates that the licensee provided adequate event reports during the assessment period.
- b. Part 21 Reports ;
None
- 2. -Investigation and Allegation Review Three allegations involving health physics were examined. None were substantiated. One allegation involving improper Quality Assurance practices was not substantiated.
- 3. Enforcement Actions
- a. Violations Severity Level I -
9 Severity Level V -
12
50
- b. Civil Penalties Severity Level III Violation for 540,000.00 for closed deluge valves in the' fire protection system.
- c. Orders No orders relating to enforcement matters were issued.
ld . Administrative Action None
- 4. Management Conference March 18, 1983 - Management Conference - Status of the Brunswick Improvement Program March 28, 1983 - Enforcement Conference - Standby Gas Treatment Deluge System IApril'26, 1983 - Enforcement Conference - CP&L's Action Relative to 0-list Equipment May 18, 1933 - Enforcement Conference - Inoperability of Unit 2 Off Gas Radiation Monitor
- Management Conference - Outstanding CP&L Regulatory July 8L,1983 Issues July 27, 1983 - Enforcement Conference - Breach of Plant Security August 31, 1983 - Management Conference - Restructuring of CP&L's Corporate Organiza,t ion -
December 9, 1983 - Management Conference - Review of CP&L Management Initiated Changes
C>
t 51 VI. PERFORMANCE ANALYSIS FOR HARRIS 1 b
I l
1 i
l l
E 52
~A. Functional Area Evaluations Licensee Activities Between February 1, 1983, and April 30, 1984, the construction project progressed from 77% complete to 84% complete. In December of 1983, CP&L announced the cancellation of Unit 2. Since the cancellation of Unit 2, site staffing has increased for Unit I to'a point where construction
- activities are in progress on three shifts. Currently, the project has approximately 5,000 employees.
Significant construction progress was made in the areas of equipment installation, installation and welding on large and small bore piping, concrete, and structural steel. Although progress was made in the areas of electrical (raceway, cable pulling and terminations), the completion of work in this area was reduced due to rework and reinspection activities on cable tray hangers.
Work efforts -in- the area of pipe hangers accelerated during the assessment period _ but a revision of the inspection program and procedures, which resulted in reinspection requirement for all completed pipe hangers, has reduced the overall progress in this area.
The operations department has become more active and is manning the control room on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis. They now have control of all equipment turned over to operations, maintain- overall sysems status, and control the operation and safety tag -out of equipment. The operations maintenance group performs all' maintenance on permanent plant equipment after installation in the power - -
block. The startup testing group received over 400 turnover packages during this period, and are actively testing these components and systems.
Inspection Activities The _ routine inspection program was performed during this evaluation period.
The Regional Construction Assessment Team conducted an indepth review of site management during the summer of 1983.
- 1. Soils'and Foundations
- a. Analysis Inspections were performed in this area by the regional inspection staff. The NRC examined design criteria, quality assurance implementing procedures, and specifications, and observed backfill operations, calibration controls on soil testing equipment, and quality records for ongoing work in the powerblock. The NRC also examined quality records and controls for the dam inspection program on the main and west auxiliary dams.
L.
53 Examination of procedures and specifications, work activities, and quality records, showed that the licensee has an excellent quality assurance program for control of backfill operations and the dam inspection- program. Procedures and specifications meet NRC requirements and industry standards. Work activities were performed in accordance with the procedure and specification requirements. No violations were identified .i n procedure adequacy, work activities, or do:umentation .of work activities.
Quality records were wel,1 maintained and readily retrievable.
Discussions with QC inspectors indicated they were knowledgeable in specification and procedure requirements, and are documenting their inspections on applicable documents. Staffing in this area is appropriate for the level of activity. involved.
No violations were identified in this area.
- b. Conclusion Category: 1 Trend: Not Determined
- c. Board Comments Performance in this area was not rated during the previous SALP assessment. Licensee management attention and involvement were aggressive in this area. The rating in this area was based upon limited inspection activity. Because of the limited inspection - -
activity, no trend could be determined. .
- 2. Containment and Other Safety Related Structures
- a. Analysis Inspectio s were performed by the resident and regional inspection staffs during the assessment period. The inspections involved:
review. of QA implementing procedures; observation of work activities, including containment structural steel, containment concrete, rebar installation, grounding cable, cadwelding, and embed plates; and, review of quality records.
One violation ((1) below) in the . concrete area was identified involving two examples of inadequate procedures. Procedure WP-29, Grouting, was inadequate in that it did not address the hand method used in mixing the cement and sand ingredients, and did not stress the importance of thorough blending of the cement and sand.
Review of test data for grout cubes showed that some grout cubes
, were under strength as a result of improper blending of the cement and sand. The second example involved procedure TP-36, Structural Steel Inspection. The procedure was inadequate in that it required extra flat washers to be used for oversize holes, but did t
54 l
not provide for documentation of inspection for oversized holes.
With the exception of the above minor violation, QA/QC procedures and ' controls were. found to meet NRC requirements and work activities were found to have been performed in accordance with those QA/QC procedures.
The review of quality records led to the conclusion that they were well maintained and readily retrievable.
Observations by NRC of problems that arose during concrete place ,
ments indicated that licensee supervision was actively involved in having problems with concrete placements addressed and corrected.
Observations and discussions with licensee inspectors indicated that staffing and training were adequate for current work activi-ties. The licensee was - responsive 'in correcting the violation concerning inadequate procedure instructions.
During the assessment period inspection effort was performed in the area of steel structures by regional and resident inspection staff. Included in these inspections were: observation of work for safety related structures outside the containment; procedure review; observation of work and review of quality records for containment penetrations; observation of welding heat treatment and review of quality records for safety related structures within the containment.
Quality assurance / quality control personnel were well qualified -
for their job functions and knowledgeable in procedural require--
ments. Staffing in this area was adequate for the level- of' construction activity. Records were generally complete, well maintained and available.
Two violations were identified which were not indicative of a program breakdown.
(1) Severity Level V violation for inadequate procedures for mixing and blending of cement and sand ingredients of grout, and for failure to document inspection of oversize holes in structural steel bolted connections.
- (2) Severity Level V violation for failure to provide adequate procedures for str'uctural installation.
- b. Conclusion Category: 1
- Trend: Same r
L
r
~ ,
..e _
)
55
-c. Board Comments Performance was evaluated as Category 1 during the previous SALP assessment. Licensee resources were effectively used such that a high-level of performance was achieved. No decrease in licensee or NRC attention is recommended.
- 3. Piping Systems and Supports
- a. Analysis During the evaluation period,1nspections were performed by the.
regional and resident inspection staffs.
Inspections included reviews of the program and procedures; observation of work activities; and review of records in the areas of: pipe welding,- structural welding, welder qualification, welding filler material control, welding repair, pipe supports,
~
pipe storage, and preservice inspection.
In the early portion of this assessment period, the licensee conducted an evaluation of the hanger erection program. This evaluation was prompted by construction management's review of the problems identified, experience gained in the early phases of hanger . erection, discussions with other utilities, program defi-ciencies which had been identified by the licensee and the NRC that required reinspection of previously accepted work, and the '
projected acceleration of work in this area. The results of thi_s '
evaluation indicated a strong need for program revision and additional emphasis in this area. Based upon . the above, the licensee, in July 1983, stopped all inspections and reduced the work activity in this area to permit an orderly revision of this program.
The following ' changes were implemented. The work and inspection procedures were revised and additional training was conducted for engineering, craft, and inspection personnel. The 5 anger construction activities were placed under the control of- the resident mechanical engineer. The piping group was reorganf zed, and staffing levels were increased from 24 to 117 personnel in the piping . group. A resident enginee'r was assigned to the hanger group, and staffing levels in this area were increased approxi-mately 300 percent. The majority of these newly assigned personnel had experience from recently completed nuclear plants.
To provide direct assistance to the erection crews, a hanger engineer- was assigned to each work force foreman to provide guidance and timely resolution of field problems, e
c s
1 4-56 A revised hanger inspection program was implemented in December
- 1983 which in addition to revising the hanger inspection program required reinspection of all previously inspected hangers. This
- program in addition to increased-staffing, incorporated a detailed inspection checklist similar to that used at recently completed inspections. It additionally incorporated a work and inspection
- package concept that contained. all drawings, instructions, changes, . inspection checklists and all associated material used in erection and inspection of the individual hanger.
. The licensee's QA surveillance group and the corporate audit group have conducted inspections on this revised program with no major deficiencies noted. Although an indepth evaluation of this revised program -has not been conducted by the NRC, CP&L QC inspections show that the program will provide for much needed improvements in this area. This program now has the highest level of construction activity on site. During the period January 1984 through - April 1984 over 10,500 points on the hangers were inspected. Of those points only approximately 5% were found to be unacceptable by the stringent criteria applied. Less than 0.5%
required rework and none had major safety significance. QA Surveillance performed an audit of over 1200 QC accepted hanger packages and found only 3 unacceptable. All three defects occurred after QC final inspection. This data leads the NRC to conclude the program is functioning as designed.
Nine violations were identified. Six of the violations (2,3,4, 6, -
8.and 9 below) were unrelated, and did not indicate a programmatic '
breakdown. The remaining three . violations (1, 5- and 7) were identified in the area of pipe hanger installation prior to the implementation of the licensee's December 1983 hanger reinspection program. The licensee has performed a detailed review of com-pleted . hanger packages and only a few minor problems have been
- found. It should be noted that only limited NRC inspections of this area have been made since December 1983, so the effectiveness of this program has not yet been fully determined.
Nine violations were identified as follows:
, (1) Severity Level IV, violation for failure of inspection person-nel to identify unacceptable pipe hanger conditions.
(2) Severity Level IV violation for inadequate control of piping installation inspections.
(3) Saverity Level V violation for improperly supporting piping during installation.
i
57 (4) Severity- Level V violation for failure to adequately control welding.
~
(5) Severity Level V violation for failure to follow hanger
~ installation procedure requirements.
(6) Severity Level V violation for failure of vendor spool piece welds to meet requirements.
(7) Severity Level V violatice for failure to follow hanger
' fabrication and installation procedure requirements.
(8) Severity Level V violation for failure of as-built drawings to reflect actual piping configuration.
(9) Severity Level V violation for failure to provide adequate procedure for heat number verification.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments Performance was evaluated as Category 2 during the previous SALP ,
assessment. -
Although this program would have been assigned a Category 3 rating early in the evaluation period, subsequent major' revisions to the program improved this area to a Category 2 rating for the entire evaluation period. No decrease in licensee or NRC attention is recommended.
- 4. Safety Related Components
- a. Analysis During the assessment period, inspections were performed by the regional- and resident inspection staffs. These inspections concerned: the reactor vessel, reactor vessel internals, safet9 related -components; and, spent fuel storage racks in the areas of: receipt inspection, storage, rigging and handling, and installation. The procedures and controls utilized by the licensee ~during these observations demonstrated evidence of good planning and priority assignment by the licensee. Precautions commensurate with the potential for damage, which could occur to equipment and materials, were evident duriry these activities.
u
E 58 4 .
The licensee has shown marked improvement in the area of receipt inspection. During -this assessment period, the staffing for receipt inspection was increased -from 12 to approximately 30 personnel. A rigorous training and qualification program provided the licensee with qualified inspectors for each area of receipt inspection. The licensee has implemented a trending program to identify vendors that fail to provide material which meets all purchase . specifications, and-it conducts ful.1 receipt _ inspections
- on the equipment received onsite supplied by these vendors. : This program' led to the identification of manufacturing problems which may have otherwise gone undetected.
The licensee increased staffing in the area of storage and maintenance of safety-related items by approximately 50 percent.
The staff was augmented with two engineers to provide increased problem identification, field follow-up, and better coordination.
Procedures was reviewed and modified for the turnover of mainten-ance activities from construction to operations. The operations permanent plant maintenance staff was assigned maintenance responsibility for all equipment once it was installed in the plant. This, in addition to providing more concentrated efforts on equipment maintenance, will relieve the construction staff of this task.
Five violations were identified during the assessment period. All the violations resulted from actions during or before the first five months of the assessment period, with no violations occurring during the 12 months after licensee corrective action. The - .
violations were unrelated, of minor significance, and not indicative of a programmatic breakdown.
(1) Severity Level IV violation for failure to follow motor control center inspection procedure.
(2) Severity Level IV violation for inadequate reactor vessel installation verification procedure.
(3) Severity Level V violation for failure to establish adequate measures to protect the emergency airlock.
(4) Severity Level V violation for failure to implement vendor
~
storage requirements for filters.
(5) Severity Level V violation for failure to follow housekeeping procedure requirements.
- b. Conclusion Category: 2 Trend: Improved
n 59
- c. Board Comments Performance was evaluated as Category 2 during the previous SALP assessment. Licensee management attention and involvement were evident. No decrease in licensee or NRC attention is recommended.
- 5. Support Systems
- a. Analysis During the assessment period, routine inspections were performed by the regional and resident inspection staffs.
In the fire protection area, NRC reviewed the permanent plant fire pump, exterior fire protection yard piping system, and supports for cable spreading room fire barriers.
Overall, management involvement and control of the fire protection features were being accomplished under a well defined and administered quality assurance program which should assure that these features will be properly installed. Responsiveness to NRC initiatives has been timely.
The licensee's fire protection system for construction continued to be strong and remained above industry standards. The licensee representatives conducted frequent safety inspections of the construction activities to assure that the site was protected from fires. The licensee requires site fire protection drills and - -
routinely trains craft personnel in the proper use of portable and temporary fire-fighting equipment. The site fire brigade was well trained and familiar with necessary techniques to be used to extinguish the various types of fires which could occur.
The current permanent plant staffing and training for the fire protection program was adequate for the existing construction phase. No fire protection violations were identified.
In the area of heating, ventilation, and air conditioning, a special inspection was performed by regional, vendor program, and resident inspector staffs. This included a review of procedures,
. r'eview of procurement records, observation of installation activities, and visual examination of completed work.
Some problems were identified with a supplier of some of the air handling units. Licensee management demonstrated involvement in resolving the problems which were brought to its attention relative to this supplier. The licensee was conducting an evaluation of the problems which were identified with vendor materials, and a resolution is expected.
+ -
't 60 One violation was identified during~ the evaluation period. The violation was of minor significance and not indicative of a programmatic breakdown in this area. It should be noted that the action causing the violation occurred prior to the SALP period and no violations.have occurred since the restructuring of the receipt inspection organization. ,
Severity Level IV Violation for failure to establish adequate procurement controls.
- b. Conclusion Category 1.
Trend: Same
- c. Board Comments Performance was evaluated as Category 1 during the previous SALP assessment. Licensee resources appeared' ample and were oriented toward nuclear safety. No decrease in licensee or NRC attention is recommended.
- 6. Electrical Power Supply and Distribution
- a. Analysis During this assessment period, inspections were performed by the - '
resident and regional inspection staffs. The areas inspected included: electrical equipment receipt, storage and installation; raceway and electrical cable installation; quality assurance records, training and qualification of inspection and craf t personnel, corrective actions for 10 CFR 50.55(e) items and NRC identified items.
The installation of cable raceways was basically completed during this assessment period. A violation- ((1) below) issued in May
.1983, resulted in the initiation of a 100% reinspection of all previously inspected cable tray support and hanger welds. The failure to follow inspection procedures requiring the inspection of hanger welds prior to painting and fireproofing the installed hangers has caused the reinspection effort to proceed slowly. To date, approximately 600 of 3500 supports have been reinspected.
Less than 10% of the supports were found to have weld defects.
Approximately one percent of the weld defects identified required repair. The need for reinspection in this area indicated that the inspection program at the time the violation was discovered may have been poorly defined or ineffectively applied by a portion of the QC inspection staff.
em ,,
.c--
61 During. this assessment period, NRC examined 26 installed power cables for proper routing, separation, identification. and termination. Safety-related electrical equipment installations were examined for proper location, seismic mounting, identifica-tion, and . separation. The inspection of cable installation
. activities resulted in two violations ((5) and (9) below). These violations did not indicate programmatic breakdown.
' Various records for the inspection of onsite storage personnel training and qualification, and electrical cables and equipment, resulted in six unrelated violations (Nos. (2), (3),(6), (7), (11) and (12) below). These violations had minor significance compared to the total volume of records maintained, and do not indicate a programmatic breakdown in this area.
Two violations, ((8) and (10) below), were identified in the_ area of operations. One of these violations was the result of periodic battery maintenance performed for three months on the emergency 125v batteries without approved procedural requirements.
Subsequent testing revealed no degradation of the batteries. The other violation ((10) below), was the result of the. following incident: heavy rains caused water to enter an energized motor control center (MCC) shorting the transformer and tripping the power feed to the MCC. The operating staff was not aware of this tripped condition for approximately two hours. The attempt to reenergize the MCC without adequate testing 'resulted in damage to the transformer and MCC cabinet. Tnese two violations indicated that more attention to the use of procedures for performing tasks . .
affecting safety related equipment was required.
During this period, the licensee placed extensive efforts in the revision of procedures, and training of operations, craft and inspection personnel. While licensee nonconformances and NRC violations were identified in these areas, a marked improvement was demonstrated. The quality of work in this area continues to be a source of licensee nonconformances and NRC violations.
The following violations were identified:
(1) Severity Level IV violation for failure to maintain inspec-
- tion status of the electrical raceway supports for class IE cable trays.
- (2) Severity Level IV violation for failure to process non-conformance reports in accordance with procedural require-ments.
(3) Severity Level V violation for failure to require .that procedures be followed, prior to pulling class 1E cables.
p 62 (4) Severity Level V violation for inadequate corrective action on a nonconforming item identified by the licensee.
(5) Severity Level V violation for failure to adequately control j
electrical cable installations. !
(6) Severity Level V violation for failure to follow- procedures for filing certification records.
(7) Severity Level V violation for failure to document completion of_ training requirements.
(8). Severity Level V violation for failure to require that written procedures be provided for periodic battery maintenance.
(9) Severity Level V violation for failure to follow procedures for cable tray removal.
_(10) Severity Level V violation for failure to protect electrical equipment.
(11) Severity Level V violation for failure to follow or revise
' instructions specified on QA hold tags.
(12) Severity Level V violation for failure to retrieve the required QA Inspection Report for work preformed on MCC * '
-1A34-SA.
- b. Conclusion Category: 2 Trend: Same
- c. Board Comments Performance was evaluated as Category 2 during the previous SALP assessment. A large amount of both licensee and NRC inspection activity occu" red during the evaluation period. Although a significant. number of violations were identified,- there was no indication of a programmatic breakdown. The violations did, however, indicate a need for continued management attention in this area.
- 7. Instrumentation and Controls
- a. Analysis One inspection was conducted in this area by the resident inspec-tion staff. Safety-related instrumentation installation was less
FT.
p p ..
63 p
g than ten percent complete, and less than one percent has been inspected and . accepted by the licensee. One violation was P identified which resulted from Field Change Requests not being identified by QA personnel as being nonconforming when they had not been approved within the 60 day procedural time limit. This resulted in a procedure being revised to prevent similar nonconformances from occurring. No similar problems were identified since then.
The following violation was identified:
Severity Level V violation for failure to document discrepancies when required by procedural requirements,
- b. Conclusion Category: Not Rated.
Trend: Not Determined.
- c. Board Comments Performance in this area was not rated during the previous SALP assessment. There was insufficient inspection activity in this area during. the current evaluation period to justify either a rating or a trend determination.
- 8. Licensing Activities
- a. Analysis The assessment of licensee performance was based on an evaluation of the following licensing activiti2s. ;
Meteorology Site Analyses ,
Environmental and Hydrological Engineering
- Materials Engineering Accident Evaluation Power Systems
- Containment Systems Auxiliary Systems Radiation Protection
- Instrumentation and Control Systems Fire Protection Reactor Systems Throughout the review process, licensee activities exhibited evidence of improved prior planning and proper assignment of priorities. Decisions usually were made at a level that ensured
n . _ _
o- ,
64 adequate management review.~ An example of active management involvement was their allocation of necessary resources _to resolve the approximately 400 open items identified in the February 1983, Safety Evaluation Report (SER) to less than the 20 identified in the SER issued in November 1983.
In regard to the licensee's approach to resolution of technical issues from a safety standpoint, the licensee has shown a clear understanding of the safety issues. The licensee provided generally timely responses and the approaches were usually sound, viable, thorough, and acceptable.
Resolutions to questions were generally technically sound and thorough. The licensee was responsive in meeting deadlines for submittals, which usually resulted in timely resolution of issues.
An example of the licensee's responsiveness to an NRC initiative was its response to generic concerns raised by the Advisory Committee on Reactor Safeguards on essential chilled water systems.
Positions of contact personnel at the licensee's corporate office, including their authorities and responsibilities, were well defined. Adequate technical personnel participated in review-meetings resulting in a timely resolution of open items. For the majority of the period, the licensee assigned a full time licensing engineer to expedite licensing actions between NRC and CP&L. ,
During the rating period, the licensee has met a commitment to improve licensing activities between the staff and itself. During this rating period, the licensee's performance had continued to improve, and at the end of the rating period, the performance exceeded the average rating demonstrating that the licensee's involvement and aggressiveness directed toward nuc1; ear safety was evident.
- b. Conclusion Category: 2 Trend: Improved
- c. Board Comments -
Performance was evaluated as Category 3 during the previous SALP assessment. Licensee management involvement was evident in this area.
y 65
- 9. Quality Assurance Program
- a. Analysis Inspections were performed by the regional and resident inspection staffs. A special Region II Construction Assessment Team (RCAT) inspection was conducted to examine various QA activities and engineering disciplines. The QA program,- design. control, procurement activities, and audits were inspected at the corporate 4 office. Site project management, training, material receiving and storage, design control, 10 CFR 21 handling, QA audits and records, and QA inspection of work performance in the civil, piping, and electrical areas were examined during the assessment period.
In early 1983, CP&L management conducted an extensive review and evaluation of numerous inspection activities that were previously conducted at Harris. The reviews covered the pilot INPO evaluation, CP&L self initiated evaluation, MACQA audit, McCormick and Paget's CRESAP, NRC inspections and findings, the SALP (including its recommendations for improvement), and CP&L corocrate QA audits. They also evaluated previous site generated nonconformances, past work and problems encountered in safety related areas, projected increasing work activities, and recurring problems in areas of pipe hangers, electrical, and the vendor quality release (VQR) inspection programs. The reviews indicated that additional management attention and QA involvement was -
required in the above areas. As a result, significant QA organization changes, increased staffing levels, and procedural changes were implemented throughout the assessment period to strengthen and provide a more viable quality assurance program at Harris.
A new manager for Construction Inspection (CT) was assigned, and this position now reports ~directly to the Project General Manager for Construction instead of to the Senior Resident Engineer. The staffing levels for QA/QC and CI inspection groups were increased from 267 to 425 personnel during this assessment period. A new site QA engineering unit was established to provide additional support to the line QA/QC organizations. The QA surveillance group staffing was increased and its activities have increased significantly during this period with special emphasis being placed on areas where construction work accelerated. The QA surveillance activi.ies have strongly emphasized hardware acceptability.
The manager of QA/QC for Harris moved on site and the position of Manager of QA Services Section (QASS) was created to supervise Corporate Quality Assurance Department (CQAD) functions related to engineering, vendor surveillance, performance evaluation, train-ing, and administration. These organizational changes resulted in
66 a stronger, more viable QA program for the Harris site and for direct corporate management involvement in daily QA activities.
QA manuals, organizational structure, and functional relationship of the construction and QA organizations were acceptable and in accordance with the licensee's accepted quality assurance program.
During the assessment period, the Corporate Nuclear Safety Group began an extensive program to interview inspection personnel.
This program was designed to independently address all concerns of QA/QC inspectors. The program was well received and will be ongoing.
Design assurance audits were complete, timely, and technically thorough. The onsite engineering group was considered a strength in that it provided intimate understanding and prompt resolution of construction problems. CP&L management has continued to increase .the staffing of site design personnel and upgrade site engineering expertise and design responsibility with the intent that the onsite design group would eventually perform all plant design -work, thereby providing a knowledgeable site engineering base that would be present during the operational phase. Procure-ment activities were controlled and documented.
In general, QC personnel were knowledgeable of their inspection functions, familiar with acceptance criteria, and proficient in performance of their assigned inspection tasks.
The licensee provided timely and acceptable resolutions to the - -
violations listed below. Violations (2) through (5) below, and one violation listed in the electrical area of the report indicate a weakness in the licensee's QA program concerning records control. These violations generally involve QA records which were not being forwarded to the vault for storage as required.
Although the missing records were generally located somewhere on site, these violations' indicated a weakne'ss in the implementation of controls in this area.
Violation (1) below was corrected by issuing a new nonconformance and corrective action procedure CQA-3, R3, Nonconformance Control.
However, additional clarification was needed regarding methods used to trend and evaluate subordinate nonconformances. A new nonconformance form will be used 'to document all nonconforming conditions identified by QA/QC and the CI group. Previously, Discrepancy Reports (DRs) had been used by CI and Design Deficiency Reports (DDRs) and Nonconformance Reports (NCRs) were used by QA/QC. The new and improved NCR form being used by all site inspection groups has resulted in better control in the identification and processing of nonconformances.
67 Violation (6) below was not a significant problem, . and the licensee committed to proper corrective action. Even though six violations were identified in the QA area by resident and regional inspectors, this area has shown considerable improvement during this assessment period.
The following violations were identified:
(1) Severity Level IV violation for failure to establish measures to assure that conditions adverse to quality were promptly identified, controlled, and corrected.
(2) Severity Level V violation for failure to follow records storage procedures and to promptly correct record storage conditions adverse to quality.
(3) Severity Level V violation for failure to require Deficiency and Disposition Reports to be evaluated and completed accordance with procedures.
(4) Severity Level V violation for failure to properly store radiographic film in an acceptable temperature, and humidity environment.
(5) Severity Level V violation for failure to review QA opera-tional surveillance records and forward them to the QA vault for safe keeping.
(6) Severity Level V violation for failure of the Plant Engineering organization to have a procedure for identifying and correcting deficiencies, deviations, and nonconformances.
b. Conclusion
Category: 2 Trend: Improved
.c. Board Comments
- Performance was evaluated as Category 2 during the previous SALP -
assessment. As was discussed in the above analysis, substantial improvements in staff and organization were made, which was expected to add significant strength to the program. These improvements should also aid the resolution of the issues involving pipe supports and cable tray supports. The increased staffing and organizational improvements should directly increase the organization!s effectiveness. Continued management attention in this area could result in a Category 1 rating in subsequent evaluations.
w
7 4
68 B. Supporting Data
- 1. Reports Data
- a. Construction Deficiency Reports (CDRs)
During the assessment period, 23 reportable CDRs were reviewed.
The distribution of these reports is as follows:
Category Unit 1 Welding 6 Mechanical 6 Electrical 3 QA 2 Design / Analysis 3 Misc. 3 TOTAL 23
- b. Part 21 Reports During the assessment period, nine part 21 reports were issued.
- 2. Investigation and Allegation Review One allegation involving defects in hanger welds was examined by the staff. It was not substantiated. * *
- 3. Enforcement Actions
- a. Violations Severity Level I -
8 Severity Level V -
28 Deviations 0
- b. Civil Penalties None
- c. Orders None
- d. Administrative Actions - Confirmation of Action Letters None m
.g e .. .
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. a..
69
. e
~4. Management Conference
' -February 28, 1983 - Management Conference - Discussion of Self-Evalua-tion Program.
February 23,1984.' Management Conference - Discussion of QA Program Related to Vendor Supplied Materials and Devices
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-[ ATLANTA. GECRGiA 30303 U. S. NUCLEAR REGULATORY COMMISSION REGION II SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE ~
E0ARD RE:CRT CAROLINA POWER AND LIGHT COMPANY
-3RUNSWICK STEAM ELECTRIC DLANT UNITS 1 AND 2 DOCKET NUMBERS 50-325 AND 50-324
- n. B. RCEINSON STEAM ELECTRIC DLANT UNIT 2 DOCKET NUMBER 50-261 SHEARCN 4ARRIS ' NUC'. EAR DCWER DLAN' UN!TS 1 and 2 DOCKET NUMBERS 50-400 anc 50-401 JANUARY 1, 1982 THRCUGH JANUARY 31, 1983 INSPECTION '
REPORT NUMBERS 50-325/83-09, 50-324/83-C9 '
50-261/83-07 50-400/83-10, 50-401/83-10 gy.mcGS7 ~-
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CONTENTS o PAGE I.' INTRODUCTION .................................................... 1 II. CRITERIA ........................................................ 1-III.
SUMMARY
'0F RESULTS .............................................. 2 A. Overall_ Utility Evaluation ................................. 2 B. Overall Facility Evaluation - Brunswick Units 1 and 2. . . . . . . 3 C. Facility Performance Brunswick Uni ts 1 ano 2. . . . . . . . . . . . . 3 D. Overall Facility Evaluation - H. B. Robinson Unit 2......... 3
-E. Facility Performance - H. B. Robinson Unit 2................ 4 F. Overall Facility Evaluation Shearon Harris Units 1 and 2.. 4 G. Facility Performance - Shearon Harri s Units 1 and 2. . . . . . . . 4 H. SALP Board Memoers ......................................... 4 I, SALP Board Attencees ........................ .............. 4 IV. PERFORMANCE ANALYSIS FOR BRUNSWICK UNITS 1 AND 2 ................ 6 A. Functional Area Evaluation - Operations .................... 7 (Units 1 and 2)
B. Supporting Data ............................................ 25 V. PERFORMANCE ANALYSIS FOR H. B. ROBINSON 2 . . . . . . . . . . . . . . . . . . . 32 A. Functional Area Evaluations - Operations ................... 33 B. Supporting Data ............................................ 49 VI. PERFORMANCE ANALYSIS FOR SHEARON HARRIS UNITS 1 AND 2 ........... 52 A. Functional Area Evaluation - Construction (Units 1 anc 2)... 53 B. Succorting Data ........... ...................... ..... . 64
o-
\
!. INTRCDUCTION A formal licensee cerformance assessment Drogram has oeen imolemented in accorcance witn :ne commitments of Task I.S.2 of NUREG-0660, Volume 1, "NRC Action. Plan Develocec as a Result of the TMI-2 Accident". This program, :ne Systematic Assessment of Licensee Performance (SALP) is applicable to all
. power reactors with operating licenses or construction permits (hereinafter referred-to'as licensees). The SALP program is an integrated NRC staff effort to collect available observations of licensee performance on an annual basis and evaluate performance based on these observations. Positive and negative attributes of licensee performance are considered. Emanasis is.
claced on understanding tne reasons for a licensee's performance in impor-tant functional areas, and sharing this uncerstanding with the licensee.
.The SALP process is oriented toward furthering NRC's understanding of the manner in which: (1) the licensee directs, guides, and provides resources for assuring plant safety; anc (2) such resources are useo and applied. The integratec SALP assessment is intendec to be sufficiently diagnos:1c to
. provide meaningful guidance to the licensee. The SALP prog *am suoplements ,
the normal regulatory processes used to ensure compliance with NRC rules and regulations. :
I!. CRITERIA i Licensee performance is assessed in selectec functional areas depending on whether the facility has been in the construction, preoperational. or operating phase curing the SALP review period. Functional areas encompass the spectrum of regulatory programs and represent significant nuclear safety anc environmental activities. Certain functional areas may not be assessec because of little or no licensee activities in these areas, or lack of meaningful NRC observations.
One or more of the following evaluation criteria were used to assess each functieral area:
. Management invcivement ir assuring quality
. Approach to the resolution of technical issues from a safety standpoint
. Responsiveness to NRC initiatives
. Enforcement nistory
. Reporting and analysis of reportable events
. Staffing (including management)
. Training effectiveness and qualification The .SALP Board has categorized functional area performance at one of three performance levels. These levels are defined as follows:
Category 1: Reduced NRC attention may be appropriate. Licensee management-attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety er
. construction is being achieved.
.m'_J..._
y ,,
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~ 'D '
s T 2 Category 2: -NRC attention snoulc ce maintainec at normai levels.
-Licensee management attention.and-involvement are evicent and are concerned with nuclear safety; licensee *esources'are acecuate anc aee reasonably effective such that satisfactory performance ,,itn respect to
~
. operational safety or construction is ceing achieved.
Category'3:
~
, Both NRC and licensee ~ attention should be increased.
Licensee management attention or involvement is acceptable and con-siders nuclear safety, but weaknesses are evicent; licensee resources appear to be strained or not effectively usec such that minimally Esatisfactory performance with. respect to operational safety or con-struction is being achieved.
The functional ~ area being evaluated may have some attributes that would
~
place.the evaluation,in Category 1, and others that would place it in either Category 2 or 3. .The final rating for eacn functional area is a composite of the attributes: tempered with the judgement of NRC management as to the significance of indivicual items.
III.
SUMMARY
OF RESULTS.
- A. Overall Utility Evaluation LThe licensee has three' units in operation at two sites and two units in Q construction'at another' site that'were incluced in this evaluation of
. management control effectiveness.
During this appraisal period, the licensee has snown significant f ; improvement in some areas; but several areas, identified during the previous review period as requiring increased management attention, have not shown improvement. The licensee nas icentified tnose areas and has initiated extensive long-range improvement programs..
The licensee has~ exhibited a positive attitude to NRC initiatives; but, in general, licensee responses nave comonstrated inacequate management >
involvement in licensing activities, particularly in the interface with NRR. Levels of performance were consistent with that noted in the previous review period.
Corporate management's involvement in site activities to assure quality performance, exemplified by the implementation and functioning of the corporate quality assurance (QA) program, has been generally adequate txcept for a continuing weakness in the functioning of the Performance
'ivaluation Unit (PEU). This has seriously hampered the PEU's ability
'to obtain prompt corrective action to audit findings. Increased corportte level management's attention is needed to improve the effectiveness of the PEU.
'Y e
w e
s 3 Improvements in tne area of Raciation Drotection were notec at coin operating sites during this review ceriod. Increased attention to planning and coordinating functions of the current ALARA program were instrumental in recucing exocsures at both sites curing tne 19c2 outages. A significant weakness noted at both operating sites was identified in the area of maintenance. Additional corporate involve-ment is needed to correct these weaknesses.
B. Overall Facility Evaluation - Brunswick Units 1 and 2 The performance of the licensee at the plant level is acceptable.
Major strengths were identified ir, the areas of emergency preparedness and security and safeguards. Positive actions taken during the period were the assignment of a senior manager to the site and cevelooment of a long range improvement plan. Improvements were evicent over the previous SALP period in the area of radiological controls.
Major weaknesses were identified in the areas of plant operations, maintenance, surveillance, fire protection, refueling, licensing activities, and quality assurance. Improvements from the previous SALP were not apparent in.the areas of plant operations, maintenance, and fire protection.
The long range improvement initiative, which is currently being implemented, is exoected to result in improved licensee performance in the weak areas. The licensee nas committed a substantial amount of facility and corporate resources to this improvement program.
C. Facility Performance - Brunswick Units 1 and 2 Tabulation of ratings for each functional area:
Operations (Units 1 and 2)
- 1. Plant Operations - Categcry 3
- 2. Radiological Controls - Category 2
- 3. Maintenance - Category 3
- 4. Surveillance - Category 3
' 5. Fire Protection - Category 3
- 6. Emergency Preparecness - Category 1
- 7. Security and Safeguards - Category 1
- 8. . Refueling - Category 3 9.. Licensing Activities - Category 3
- 10. Quality Assurance - Category 3 D. Overall Facility Evaluation - H. B. Robinson Unit 2
)
The performance of the licensee at the plant level was satisfactory.
, Major strengths have been identified in the areas of surveillance and refueling. Improvement has been notec in the areas of radiological t
4 4 controls anc surveillance testing. Major weaknesses were icenti#iec in
.the areas of maintenance, licensing activities, anc auality assu*ance.
The wea<. ness ir the cuality assurance area 4 5 attributec Oc :ne corporate aucit function. Licensee performance ceclinec in two areas, maintenance and quality assurance, from the previous SALF evaluation.
E. Facility Performance - H. B. Robinson Unit 2 Tabulation of ratings for each functional area:
Operations Unit 2 l '. Plant Operacions - Category 2
- 2. Radiological Controls - Category 2
- 3. Maintenance - Category 3
- 4. Surveillance - Category 1
- 5. Fire Protection - Not Rated
'6. Emergency Precareeness - Category 2
- 7. Security and Safeguards - Category 2
- 8. Refueling - Category 1
- 9. Licensing Activities - Category 3
- 10. Quality Assurance - Category 3 F. Overall Facility Evaluation - Shearon Harris Units 1 anc 2 The licensee performance with respect to construction is satisfactory.
Licensee management involvement and suoport for cuality construction in the various functional areas is evicent. Trainec and Qualifiec staff were deemed to be adecuate for the level of activities involved. In each of the areas evaluated, no programmatic breakdowns were identi-fied.
A major strengn was identified ir ne area of cor.!:ructicn fire protection. A major-weakness was identified in the area of licensing activities wnicn warrants adcitional licensee managemen; attention.
Improvement is needed to upgrade the timeliness, thoroughness, and technical soundness of information submitted to the NRC.
G. Facility Performance - Shearon Harris Units 1 and 2 Tabulation of the ratings for each functional area are as follows:
Construction (Units 1 and 2)
- 1. Soils and Foundation - Not Rated
- 2. ContainmentandOtherSafety-RelatedStructures-Category 1
- 3. Piping Systems.and-Supports - Category 2
- 4. . Safety-Related Components - Category 1
- 5. Scoport Systems - Category 1
t w
+- 5
- 6. Electrical Pcwer'Supoly anc Distribution - Category 2
- 7. Instrumentation and Control Systems - Not Ratec
- 8. -Licensing Activities - Categcry. 3
'9. Quality Assurance - Category 2 H. SALP Board Members R. C. Lewis, Director, Division of Project and Resident Programs
.(DPRP), Region II (RII), Chairman J. A. 01shinski, Director, Division of Engineering and Operational
~
Programs, RII . .
DJ. P. Stohr, Director, Division of Emergency Preparedness and Materials Safety Programs, RII D. M. Verrelli, Chief, Project Branch 1, DPRP, RII D. Vassallo, Chief, Ooerating Reactors Branch 2, Division of Licensing (DL), Office of Nuclear Reactor Regulation (NRR)
I. SALP Board Attendees D. O. Myers, Senior Resident Inspector, DPRP, RII S. Weise, Senior Resident Insoector, DPRP, RII G. F Maxwell, Senior Resicent Inscector, DPRP, RII A. K.-Hardin, Project Engineer, Project Section IC, Projects Eranch 1, DPRP, RII C. W. Hehl, Reactor Engineer, D"cject Section IC, P-cjects Branch I.
DPRP, RII' P. R. Bemis, Chief,- Project Section IC, Projects Branch 1, DPRP, RII~
M. V. Sinkule, Chief,' Operational Support Sec-ion (CSS),
Program Support Staff (PSS), RII G. Requa,. Project Manager, Operating Reactors Branch 1, DL. NRR
- 5. McKay,. Project Manager, Operating Reactors Branch 2 DL, NRR P. Kadambi, Project Manager, Licensing Branch 3, DL, NRR R. 3revatte, Senior Resteent Ins:ector,-DPRP. RII T. MacArthur, Radiation Specialist, OSS, PSS, RII
9
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IV. PERFORMANCE ANALYSIS FOR BRUNSWICK UNITS 1 AND 2
w n 7 A. Functional Area Evaluations - Operations (Units 1 anc 2)
Licensee Activities Unit 1 began the evaluation period in routine power operation. On February 5,1982, the unit was brought to cold shutdown for a planned maintenance outage. A snubber inspection and tne replacement of leaking reactor recirculation pump seals were among the activities accomplished during this outage. The unit was returned to power on February 14 and remained in routine power operation, with the exception of brief shutdowns, until July 1982.
On July 16, 1982, Unit I was snut down to concuct missed surve111ance tests, and accomplish action items containec in NRC Confirmat i on of Action-letters issued on July 2 and July 20. Restart attemots on October 10 and 14 were unsuccessful due to safety relief valve mal _
functions.
Unit I was returned to routine oower operations on October 17, 1982.
- The unit remained at power except for a shutcown on October 22 until brought to cold shutdown on December 11, 1982, for refueling. Unit I remained shut dcwn for refueling for tne -emaincer of this evaluation period.
Unit 2 began the evaluation eerioc in routine oower.coerations and, except for an occasional brief outage, remained at power until tne unit was shut down for refueling on April 24, 1982.
The Unit 2 refueling and integrated leak rate testing outage lasted from April 24, 1982, thro' ugh October 2, 1982. Restart was delayed due to unanticioated snuboer support modifications and the completion of action items contained in the NRC Confirmation of Action letters of July 2 and July 20. 1982. The unit was eturned :: reutine pcwe-operation on October 3, 1982.
' On October 10, 1982, the unit was shut down to repair a crack in the heater ~ drain piping. Repairs were completed and the unit returned to power on Octocer- 18, 1982.
A On October 29, 1982, the unit was again shut down to repair a trav-ersing incore probe tube. During this maintenance outage, a crack in a section of shutdown cooling pipe necessitated extension of the main-tenance outage.
Unit 2 was successfully returnec to routine power operation on December 5, 1982, and continued in this mode, except for an occasional brief shutdown, for the remainder of the' evaluation period.
e s 8 Inscection Activities
-The routine inspection crogram as ce-for ed curi g tne rev'e= ce-ioc.
The following special inspections were performec curing the period:
January 6-7, 1982 in response to the reported failure of the Unit I plant staff to recogni:e the failure of a safety-related water level instrument.
January 19-21, 1982 to review the scram event of January 16, 1982 in which Unit 2 RHR service water pumps failed to start.
July 12-14 and 20-22,1932 in response to reportec failures to conduct required surveillance testing.
June 2-4 and July 20-21, 1982 in response to reports of camaged
.under vessel instrumentation at Unit 2.
September 28, 1982 to January 17, 1983, in response to allegations that contractor personnel tampered with dosimetry.
October 27-29, 1982 to cetermine the facts relating to a shioment of radioactive material, reported by the State of South Carolina to have been in violation of regulatory requirements.
Soecial prestartuo team inspections were conducted on August 24-27 I
and September 7-10, 1982 to determine the status of action items contained in the July 2 and July 20, 1982, NRC Confirmation of Action letters.
A special team training assessment was conducted on January 10-14, 1983 to eva'uate CP&L licensec and non '.icensec operatcr training programs.
A special inspection was conducted on January 10-13.and 17-21, 1983 to follow work activities required by IE Bulletin 82-03.
- 1. Plant Operations
- a. Analysis During the evaluation period, the resident inspectors regularly performed inspections of operations activities.
Additionally, routine ano special inspections by regionally based inspectors were performed.
Poorly stated or ill understood procedures, identified during the previous' review ceriod. continued to cegrace the effec-tiveness of the operating staff and contributec te the m
o 9
Ir. ace:aa e suostantial num:ers of reported cersonnel d laxness errors.
involvement. incicatec by a cemonstratet *es. 3150 management Inese in disefeline of operations anc adherence on coeration's performance.f the violations tc or0ce u nac an acverse affe:: in June 1982 weaknesses were key elements in each oi and February 1983, and in the 65 Licenseere issued during this attributable to personnel error that weNRC f five enforce- concerns in review period. A procecure supervisory controls were discussedriod. at eacn line of operationso ment conferences neld during this review pe upgrade program, renewed emphasis containecon :ydiscipin :ne firmed NRC and adherence to procedures are commi
- 22. 1982.
Order on Decemoer olution of Weakness in the operating staff's h a:proach to rescrev technical issues, also icentified in t eResolutions depth. An often provicec period, were again noted. i g staff approaches but were lacking thoroughness ineering orto apparent reluctance on the part of the operat n aceauately involve availacie technical and engThis we expertise contributed to this weakness.(1) a failure 4n theto promptly exemplified oy two recent events: identify ssure and reactor water cleanup (RWCU) system, ident ion cooling (8) below; and (2) the hasty isolation l of high Dre coolant injection (HPCI) and reactor core iso at 2-82-140.
(RCIC) systems reported in LER fined lines Ineffective communications combined pe*'oc. Th's with poorly of authority and responsibility also icontr oce*ational pe-formance during the rev ew(7) fand (11),Ibelo a Groo; weakness was exemplified in violationsC ER 1-82-149;d and the the insertion trip system isolation, reported in Linadve l locaticns, of fuel assemolies in rodiess reactor vesse discussed in IE Report 83-03*. fication Weaknesses in the licensee's training i factor andto quali i l performance programs were determined to be a contribut tions. marg The ngna several reportable events and thei rather nder-observed on recent operator licensin standing of technical specifications and i cf
'NRC IE Reco-t 83-03 issuance is pending evalu items by tne NRR.
enforcement
v
'~ 10
- ER 2-32-140, ciscussed acove; :ne exceecing of emergency diesei gene *ater limiting concitions #o- oceration ecortec in LER's 2-52-124 anc 1-52-127; anc tre #ailure to satis'y tecnnical specification prerecuisites crior to moving the reactor moce switch to the Refuel position, icentified as violation (9) below. The results of operator licensing examinations, conducted during this and the previous review period, further exemplified this weakness. During the previous review period, a passing grade was recorded for 18 of the 27 reactor. operator cancicates. The examinations conducted during this evaluation ceriod resulted in only three of nine senior reactor operator and 11 of 25 reactor operator candidates receiving passing grades. This record is not indicative of an effective training crogram. Upgrades in the area of training and qualification programs are under-way at Brunswick, both as a licensee initiated training improvement program and as part of the long-range operational improvement program. The supplementary training in technical specifications, that was recently conducted, was a positive step toward improvement in this area.
S'xteen violattens were identiec during the evaluation period in the area of plant ocerations. These violations are-indicative of a programmatic breakdown in.tne operations area. The program lacked ef#ective suce* vision and engi-neering overview, thus fails to adcress root causes and affect more than temocrary solutions to problems. Staff vacancies and management enanges contrisutec to this break-down. Further examples of these inadequate management controls were also demonstrated by the tardy development and implementation of a procecure rewrite program anc tne resolu-tion of the incecendent verification issue. Violations and deviations ideati#'ed du 'ng the aev'ew cer'oc are icer '#'ed below:
(1) Three Severity Level III violations for events sur-rounding a reactor vessel water level instrument mal-function, icentifiec curing tne previous review period, which resulted in a civil penalty issued in June 1982.
(2) Severity Level IV violation for failure to implement corrective action in two independent lineuo verifica-tions prior to radwaste effluent discharges, as commit-ted to in response to a previous violation.
(3) Severity Level IV. violation for failure to implement double verification as required by NUREG 0737 Item I.C.6.
W 9 11 (4) Severit y Level IV violaticn for failure to 4molement procacure CP-43 wnicn esultec in one sucsystem of :ne resicual heat remeval se*vice water system ceing inoce--
able.
(5) Severity Level IV violation for failure to provide procecure content in accorcance with ANSI 18.7.
(6) Severity Level-IV violation for failure to evaluate anc cocument the inoperability cf the stancby liquid control system neat tracing circuit as recuirec by procedure OI-4
- (7) Violation for failure of the Diant Nuclear Safety Committee to adequately review a crocedure; this resultec in the inacvertent scramming of :nree control rocs.
- (8) . Violation for failure to isciate the reactor water cleanup system within the required time interval of an identified instrument malfunction.
(9) Severity Level V violation for not locking the -eactor mode switch in the shutdown position as required by tne tecnnical specifications.
(10) Severity Level V violation for not including in croce-dures the proper alignment of valves necessary for operacility of a containment isolation instrument.
(11) Severity Level V violation for operating aoove tne technical specification value with the concensor vacuum- ow isolatior. snitches cy;assed.
(12) Severity Level V violation for failure to implement clearance procedure I-459, which resulted in a scram; and for failure to implement ooerating procedure OP-43, in tnat service water valve V118 was not positionec properly.
(13) Severity Level V violation for failure to adequately establish an annunciator procedure, and several normal operation and expected transient procedures.
(14) Deviation from a commitment to the NRC, as stated in a response to TMI Item I.A.I.3, to modify procedures to specifically require a senior reactor operator in the control room.
- These violations will be discussec it NRC IE Report 83-03.
n.
9-12
- b. Conclusion Category 3
- c. Board Comments Licensee performance in this area continues to se Category 3 as rated during the previous SALP review period. It is recognized that certain improvements nave been made; however, significant overall improvement is not evident. The licensee has recogni:ed the weaknesses in this area and an aggressive long-range improvement program has been initiated. The licensee should continue increasec management attention anc the NRC inscection effort snoulc be increased by assignment of an additional resident inspector.
- 2. Radiation Protection,. Radioactive Waste Management anc Transporta-tion
- a. Analysis During this oe-4oc, eight insoections -ere cerformec ey regional based insoectors. Additionally, routine inscection in this area were performed by the resident inspectors.
The inspectors found that the Radiation Protection Program showed some improvement when comcared to the findings of the previous evaluation period. The Raciation Protection area accounted for one Severity Level V violation and one devia-tion from licensee commitments anc are described in items (4) and (5) ceiow. The inspector found tne plant ALARA program to be successful. The current ALARA program, which is supported by management, was estacitsnec early in 1932. ~he planning and coordination that the ALARA group did for the 1952 Unit 2 outage was instrumenta; in recucing outage exposures.
The racwaste program consisting of liquia, gaseous anc solic radwaste,-accounted for one Severity Level V violation described in item (3) below. This violation was due to a
= poor chemical separation procedure in the analysis for Sr-89 and Sr-90. The root cause of the violation was inadequate quality assurance interface between the plant and the General Office laboratory that made the analysis. The licensee responded by developing a better enemical separation tech-nique as well as increasing attention to comparisons between General Office laboratory results and technical specification requirements. This violation, and the findings of a QC and Confirmatory Measurements inscection discussed later, indi-cate a need for additional licensee effort in the racwaste chemi stry area.
l 13 i During 1982. :ne genera:ec volume of solic racwaste cecreases as com:arec to previous years. However. :ne volume generatec
. was still significantly higr.e- :har that generated oy otner similar_ facilities in tnis region. ine facility dic not have an effective program for recucing tne quantity of waste gen-erated in the radiologically controlled area nor for reducing the volume of waste so generated. Additional management attention is needed in this area to minimize solid racwaste volume.
The radioactive waste transportation program received one Severity Level IV violation cescribec in item (1) below.
This violation resulted from performing a snipping activity without an adequate activity review. The licensee was responsive in investigating and correcting the racwaste shipping program in order to preclude a similar occurrence in the future. The inspector founc the overall racwaste transportation program to be generally well managed.
One radiological environmental protection inspection was conducted during the aopraisal period. No violations or ceviations were cisclosec. In generai, :ne environmental surveillance orogram acoearec to be aceouately managec and directed toward development of effective off-site environ-mental protection. The management and staff resconsibility for implementation of off-site moritering showed significant improvement regarding adherence to environmental sampling and racioanalytical procecures, and procecures defining required maintenance of monitoring equipment and surveillance systems.
. The radiological environmental oratection program was con-sistent with tecnnical specification reaud rements.
One QC and Confirma:Ory Measurements inspection was perf:rmec during the evaluation period using the RII Mobile Laboratory.
One Severity Level V viciation, item (4) seiow, was icenti-fied for failure to collect stack gas samples in accordance with the aooroved procecure. The inspection revealed the need for upgracing quality control activities associatec witn the collection of stack gas and charcoal samples. This continuing weakness in the radiological measurements area resulted from the lack of adequate management review at the plant level. The results of effluent samples collected and analyzed by both the NRC and licensee during the inspection' showed agreement.
Four violations and one deviation were identified during the evaluation period. The violations do not indicate major weaknesses in the radiation protection, radioactive waste management or transportation programs; however, additional
- e
.s-
- 14 atten 'On is nee ec ir cuili t y con rol for the -acwaste ,
manageren program. he vi:'at'ons anc ces'at'en 1:enti#iec were:
(1) Severity Level IV violation for failure to control a ;
radwaste shipment. }
(2) Severity Level IV violation for failure to collect stack ,
gas samples as required by chemistry procedures, j (3) Severity Level V violation for failure to meet minimum l detectable concentrations in a sample of liquid efflu- i ents as required by the Tecnnical Specifications.
(4) Severity Level V violation for failure to imolement raciation control procecures.
(5) Deviation from a ecmmitment to the NRC, as stated in resconse to T.*I Item II.o.3. for failing to calibrate three gas radiation monitors.
- b. Conclusion Category 2
- c. Board Comments Licensee performance has improvec from a Category 3 curing the previous SALP review period to a Category 2 curing this period. The improvements implemented at the end of the orevious SALP review period to upgrade management controls appear to have been effective. Significant improvement is acpa ent in ce:ontam'nat'on ::nt-ol p-ogram.s due to the effort being expenced by the licensee's staff. No decrease in it:ensee or NRC attenti:n in this area is re: mmencec.
- 3. Maintenance
- a. Analysis During the evaluation period, maintenance activities were routinely reviewed by the resident inspectors. Additionally, supplemental inspections were performed by regional based inspectors.
Weaknesses in management controls and involvement in assuring quality mairitenance activities, identified as areas of concern during the previous review period, continued to forestall neeced crogram imorovements. Poorly stated and ill
w i
15 uncerstoo: procecures eften frustra:ec at;emots to imciement requirec programs as icenti'ie: in violations (5) anc (c) be'ow. Re:u'*ec ceograms, foe assur'r; ma'* ena~ce activi-
- ies have not cegraced system capacilities. anc for provicing necessary data for oecisions regarcing acecuacy of equipment applications, had either not been established or implemented.
Examples of these program deficiencies are found in viola-tions (2), (3), and (4). Weakness in the amount of suoer-vision applied to maintenance activities was again evident curing this review period. An examole of this occurred cueing the diesel generator flexible drive coupling repairs ciscussed in IE Report 82-30.
The licensee's approach to resolution of tecnnical issues often provided viable approaches but imclementation generally lacked thorougnness or depth. An example of this weakness was the resolution of the issues associatec witn the -esicual neat removal (RHR) service water pump low suction pressure switches. As illus:*atec by violation (1) below, corrective action was not always effective in preventing recurrence.
This issue was discussed curing an enfo-cement conference nela on July 14, 1952. Imp-ovements in :nis area nave-occurred over the review period.
The licensee was receptive to NRC initiatives. Droblems cf regulatory concern were identified and reported, but .
^
responses often lacked thoroughness or death. This can be attributec, to some extent, to inacequate engineering over-view.of the maintenance program. Timely training of the maintenance staff on new procedures, o*ocedure changes and mocifications appears to have contricuted to some of the violations identified below. Maintenance staffing and training appeare: generally acequate excep; as notec teiow.
Tne violations icentifiec celon are incicative of a program-matic breakdown:
(1) Severity Level IV violation for failure to take acequate corrective action on pressure switch repairs.
(2) Severity Level IV violation for failure to have a maintenance trending and review prog, ram.
(3) Severity Level IV violation for failure to orovide a calibration program for instruments used to verify technical specification parameters.
(4) Severity Level IV violation for failure to establish an acecuate cos: maintenance testing c-ogram.
16 (5) Severity t.evei V viciation for failure te 'mptemen a calibration procecu e.
(6) Severity Level V violation for fatiure to imoiement an approvec maintenance procedure.
(7) Severity Level VI violation for failure to maintain surveillance activity records.
- b. Conclusion .
Category 3
- c. Board Comments Licensee cerformance, which was evaluated as a Category 3 during the previous SALD period, has net improved during this pericc.
Weaknesses in this area are attributable to inadecuate management controls, inacecuate procecures and inadecuate implementation of existing procedures. Additional licensee management attention and
.NRC inspection effort should be continued.
- 4. Surveillance anc Inservice Testing
- a. Analysis Resident and regional based inspectors routinely observed surveillance and inservice testing activities as_part of their inscection program. The surveillance and inservice testing program was also the subject of special insoections by regional basec insoectors.
During1; bis review pericc. major programatic breakccwr.s ne-e identified in the area of surveillance and inservice testing.
Thirty-eight separate instances of reportacle tecnnical specification non-compliance were identified in this area. A key factor which precipitated these program breakdowns was a lack of management involvement anc control. Little evicence of adequate program planning and assignment of priorities existed; poorly stated, ill understood and technically inadequate procedures for control of these activities con-tributed significantly to orogram deficiencies. Prior program reviews and audits of these areas by the licensee's quality assurance organization were not timely. thorough or
~ technically sound. These weaknesses were the subject of two NRC confirmatory action letters issued in July 1982. A Commission order, requiring implementation of the licensee's improvement program to achieve basic improvements in manage-ment, cpe-ations and cuality assurance performance, was
17 issued in Decencer 1952. NRC enforcement action pr motec cy this breakcewn in management controls. esultec ir. :ne issuance of a civii enalty in :ebrua y 1983.
The licensee's approach to the resolution of technical issues often provided viable approaches, out lacked thoroughness or cepth. Understanding of the issues was frequently lacking in scope, resulting in resolutions being applied to a single unit or system without consideration of similar deficiencies elsewhere. Tnis " tunnel vision" approach to the resolution of_ technical issues, as discussed in IE Report 82-28, preci-pitated the failure to conduct the primary containment leak rate tests as identified in violation (1) below.
The licenseee was receptive to NRC initiatives, but consid-erable NRC effort or repeatec suomittals, were sometimes
-required to obtain acceptable' resolutions. Problems of regulatory concern were identifiec anc promptly reported.
Since July 1982, significant licensee resources have been applied to strengthen management controls in this area and resolve icentified ciscrecancies. a long-range improvement program has been develooed by the licensee and is being implemented. Lasting improvements in this area are expected.
The following violations were indicative of programmatic breakdowns:
(1) Severity Level III violation for failure to establish and maintain procedures for each surveillance test, inspection and calibration listed in technical specifi-cations.
(2) Severity Level IV violation for failure to establish reference ca:a for a pump after mocification. -
(3) Severity Level IV violation for failure to establish a calioration surveillance procecure for the fuei oil ans level instruments for the diesel driven fire pump.
(4) Severity Level V violations for failure to include main steam piping between containment isolation valves and turbine stop valves in the ISI program.
(5) Severity Level V violation for failure to retain ISI calibration block for recirculation system safe-end inspection.
a
6:
18
. c. Conclusion Category 3
- c. Boarc Comments None.
- 5. Fire Protection
- a. Analysis During this assessment period, one inspection was conductec in the fire protection area by a regional based insoector.
Acditional inspections were also performed by the resicent inspectors.
Management involvement and control in the plant fire protec-tion program has not been effective. A program review, promoted by the NRC's Confirmation of Action letters of July 2 and 20, 1982, identified significant orogram break-cowns o-ecipitated y inaceoua:e managemen: controls. Trese breakdowns included failures to perform recuired fire protection surveillances and tests, and inadequacy of most of the fire crotection annuncfator orocedures. Ineffectiveress in initating corrective actions for regulatory non-compliances, as evidenced by repeat violations (2) and (3) below, is alsc indicative of inacequate management control in this area.
l Poorly stated and ill uncerstocc procecures continued to hinder effective implementation of this program. Inadequate fire oroection procecures contributec :0 the viciations nnien resulted in the February 1983 civil penalty violation (1),
uncer sarveillance anc inservice testing. Procecurai deficiencies are discussed further in IE Report 82-25.
It is notea that adcitional personnel have Deen assignec to the fire protection group and routine fire inspection functions have been transferred to the operations division.
Improvement in this area is expected.
(1) Severity Level V violation for failure to implement the !
station fire prevention procedures, in that an accumula-tion of combustible material soaked with leaking oil 4 from the diesel generators was permitted to exist in the diesel generator rooms for an excessive period of time, and was not identified and reported as required.
(82-30)
9 19
~(2) Severity--Level V viciation #or #ailure to crevice the reouirec num er of serv :eatie scare self cor.tairec d
crea:hing a::a-atuses # - tne e r'; ace. .
(3) Severity Level V-violation fer. failure to provice all fire brigade members with the required respirator protectien training.
(4) Severity Level V violation for failure to replace three electrical penetratien. seals in the cable spreading rooms fire barriers following their removal during plant modification work.
- b. ~ Conclusion Category 3
- c. Boarc Ccmments Licensee performance, which was evaluated as Category 3 during the previous SAlp period, has not improved during this review period. .In accition :: Or:cecure implementation problems which were.icentifiec curing tne previous SALP, the ;
quality of procedures and the corrective action program needs '
ime-ovement. The 'ncreasec 'evel cf 'icensee and NRC attention in this area should continue.
- 6. Emergency Preparecness
- a. Analysis During the evaluation period, one small scale exercise was ocservec anc twc routine inspections were concu tec :y tne regional staff. No enforcement items were identified as a i
result of tne exercise or inspections. i The licensee acoeared to be responsive to concerns identified ;
by NRC anc was willing to take corrective action in a timely 1
^
manner. No major problems, which could be considered indi- '
cative of programmatic. weaknesses, were identified during the period. '
i
-Key positions in the emergency preparedness staff were filled at corporate and clant levels. Resconsibilities and authori- >
ties were established. Staffing levels in the emergency !
preparedness staff appeared adequate.
a
20 A training program was esta:1'snec anc 'mplementec for tne emergen:y preca e: ness organi:ation; inis contributec :: an aceccate unce-stanc'r; Of tne 'nd'v'cua' r 'es anc cu peses cf :ne emergency organica: ion.
- Corporate management acoeared to be supportive of emergency preparedness programs and issues anc was cirectly involved in site activities. There was evidence that priorities were correctly assigned in the area of emergency preparedness.
Procedures were cevelocec. and a mechanism for revision was established. Program recorcs were well maintained anc were l generally complete. i
- b. Conclusion Category 1
- c. Board Comments Licensee performance has imoroved from a rating of Category 2 I
-during the previous SALP period to a Category I rating curing (
- n's ceriod. The licensee nas acci'ec .ne Orc:e* amount o#
management attention and resources in this area.
n Ne decrease in the level of NRC insoection effort is ecom-mended.
- 7. Security and Safeguarcs j
- a. Analysis t
Three unannounced routine insoections and one special !
unannouncec ins:e::'on ne e pe #ceme: cy :ne regional staf' Additional routine inspections by the resident inspectors were performed :nrougnou; ne evaluation perioc. No viola- t tions were identified.
A special inspection was concuctec after :ne licensee identified potential willful damage to several incore
. instruments locatec under the Unit 2 reactor vessel. A :
Confirmation of Action letter, dated June 4,1982, detailed i special security and ocerational interim measures which the j licensee took during fuel loading and in preparation of j startup for Unit 2. This damage was subseouently determined 4 to nave resultea from poor maintenance practices and was not i considered willful.
Inrougnou; tn's evaluat on perioc. One iicensee continuec an i
ageressive program to recair anc maintain security-equictent arc na-cware. As a result of tM s e"o ; numercus 'On;_ :erm comoensato*y measures were allesiatec anc memoers of tne security organization were more acvantageously utilized.
Corporate and_ site management supportec the security program and-security awareness was positive, as indicated by their professional approach to-provide.a safe and secure environ- ,
ment-onsite. Tnis was cemonstrated by their responsiveness
'to NRC comments and discussions: and the non-adversary ,
relationsnip that existed with'onsite personnel. The con- ,
. tract security guard _. force was adequately staffec to meet all commitments of the security anc contingency plans. Review of the training and cualification plan, observations of on-tne-job training and structurec training classes. anc interviews .
with security force personnel indicatec that tne security training was being efficiently.and effectively implementec.
This was aise demonstrated by the cositive morale of the security force.
'b. -Cone'usion
-Category 1
- c. Board Comments
. Licensee performance has improved from a rating of Categcry 2 during the previous SALD .period to a rating of Category 1 curing this period. The' licensee has applied the procer amount of management attention in this area. -No decrease in s the level of NRC inspection effort is recommended.
- 8. Refueling
. a. . Analysis ,
7 During :nis review period, Unit 2 uncerwent a refueling outage from April to October 1982, and Unit 1 initiated its refueling outage on December 11, 1982. The resident inspectors reviewed selected evolutions during these refuel-
'ing outages.
Management involvement and control in assuring ouality showed little evidence of prior planning and assignment of priori-ties; poorly stated and ill understood procedures led to several refueling operation problems as discussed in IE Report 83-03,* and resulted in violation (1) below. This weakress in the area of management controls was most aopa*ent l
during tne performance of non-routine refueling operations.
[ 'NRC IE Re: ort 83-03 issuance is pending evaluation of enforcement
[. items by NRC. .
L
c-22 Staf#'n; wea~nesses -e-e ac:a en: cu dng :ne Outages wi:n sey
- 5' icas ce'n; Ocor') ':enti#'ec an: autnerity an: *es: Orsi-C'1 'ti e s Oe' ag ' ' ' :s #' ec. ~"ese weasresses ::a
. 'buted s'gnifi:antly :: :ne recent fuel moveTen; event resulting in violation (2), pelow.
The following violations were icentified during this review ceriod.
(1) Raum'" ~ avaiJ?/Yiolationforfailuretcimolement fuel nandling rocedures: tnis -esulted in entering tne refueling mcce prior to establisning prerecuisite olant conditions.
(2) Seve ' ty ' ava' :V Violation for # ailing to maintain refueling crocecures; this resuitec in tne misoosition-ing of fuel assem:11es into rodless core locations.
- b. Ccnclusion Category 3
- c. Scare comments Licensee :er#caman:e fa this area was not evaluated du*'ag the previous SALP period. During tnis period routine refueling operations were found to be satisfactory, however late .in ne perioc croolems were icentifiec involving non-routine evolutions. Additional licensee management attention is neeced to correct this problem. The increasec level of NRC inscection effort shouic ce continuec.
- 9. .' :ensing A :hi;'es
- a. Analysis The assessment of licensee performance was based on an evaluation of :ne foiiowing licensing activities:
Project management administration Response to NUREG 0737 items
- 10 CFR 50, Appendix R Environmental qualification RPS. cower supolies Operator licensing Spent fuel storage increase Radiological effluent TS
- Tnese violations will be discussed in IE Report 83-03.
23 In generai, management invcivement was inc ns' stent, resulting in varying levels of licensee cerfcemance.
Evicence o# cuality management cacabiiity was acca*ent in selectec areas, but consistent management attention over the full range of licensing activities was not evident. No imorovement was noted in this area since the last-SALP evaluation.
Technical understanding of the issues was generally cemon-strated, but a lack of thorougnness or cepth in the approacn to resolution was noted in several instances. This level of performance was consistent with that noted in tne last SALP evaluation.
Initial licensee responses were generally timely but often requirec extensions of time to complete (e.g., Acpencix R, fuel' storage increase). The licensee had recogni:ed this deficiency and had been. attempted to improve responsiveness by establishing integrated scheduling of licensing actions.
The licensee previously identified a lack of adeauate
'icensing staff as a sicnificant factor in :neir failure t provice timely responses and took actions to augment the licensing staff. This factor was considered in the evalua-tion of responsiveness, discussed above.
In summary, inconsistent cuality in the management of licensing activities and a general lack of timeliness in
! responding to staff requests were identified as significant negative factors.
- b. Conclusion Category 3
- c. Board Comments Licensee performance in this area was not evaluatec curing the previous SALP period. Licensee management attention should be increased in this area.
- 10. Quality Assurance Programs
- a. Analysis During this evaluation period five inspections were performed by regional based inspectors. Two of these inspections were special inspections related to licensee actions resulting from Region II Confirmation of Action letters dated July 2 and July 20, 1982.
24 Aucits were generally complete anc :norougn; newever, ne licensee's corrective act on system for timely resolution of i
pr:ciems icenti'ied by the audit staff was ireffect've anc was a Key contributory element to tne programmatic breakcowns in :ne plant operations and surveillance sections of this report, and resulted in violation (1) below.
In general, the licensee's QA policies were adequately stated and understood as revealed by the inspectors' reviews of QA procedures and ciscussions with licensee personnel. One weakness in this area involved poorly defined corrective action procedures which failed to promptly obtain QA manage-ment assistance in seeking resolution to problems identified by the.QA staff. This weakness'directly resultec in viola-tion (2) below. The ability of the licensee's Performance Evaluation Unit (PEU) was seriously hampered in obtaining prompt corrective action to audit findings due to this procedural inadequacy. The licensee was requested to suomit a supolemental respcnse to this violation; tnis resultec #-om QA management's aoparent reluctance to provide definitive guidance for ooeration of the PEU.
Certain levels of corporate management were involved in site activities as evidenced by frequent visits and communications between the Manager. Coerations-QA/0C, and site OA pe-sonne' However, there appeared to be very little direct involvement in site activities by pEU management.
The onsite review committee appeared to be staffed to meet technical'soecification requirements. Licensee records were generally complete, well maintained, and available as evidenced by the inspector's ability to retrieve the informa-tion needed .o complete the inspection program. The licensee was generally responsive to NRC identified items relating to QA activities as evicencec ey closure of 21 items curing one inspection (Report No. 82-16). Corrective actions to
- problems identified by the site QA surveillance staff were b usually acequate.
The licensee's training-program appeared to need more involvement by management to achieve-the desired level of adecuacy. A surveillance of training activities conducted by the site QA surveillance staff identified numerous problems in this area. Similar problems were identified by regional based inspectors during inspections discussed in IE Report Nos. 82-26 and 83-04. The training area should receive increased licensee management attention to assure that corrective actions identified by the licensee are properly implemented and result in an improved training program.
25
'n ee vic'.ations ci ect y at: 'catacle te CA we-e icenti-i
- 'ec curing :.*is. assessment :er'oc anc are icented celcw. Tne brean.cewr 'n management c:r:rcis :c assure cuality contr'butec :c many of the violations ciscussec in tne operations anc maintenance sections of this report.
(1) Severity Level III violation for failure to correct, determine the cause of and take action to preclude recurrence for, an identified condi. tion adverse to cuality.
(2) Severity Level IV violation for failure to estaclish measures to assure nat conditions adverse to cuality were promptly corrected.
(3) Severity Level V violation for failure to issue an aucit within the time requirec by tecnr.ical scecifications.
- b. . Conclusion Category 3
- c. Board Comments Licensee cerformance, which was evaluated as Category 3 curing the previous SALP, has not improved during this review period. It is apoarent that the QA program was not effective because of the failure to icentify deficiencies in ocera-tional programs and failure to take effective corrective action. The increased level of licensee and NRC attention snoulc be continuec.
E. Sup;:r-in; Casa
- 1. Reports Ca:a
- a. Licensee Event Reoorts (LERs)
.Three hundred and nineteen LERs were reported for Units 1 and 2. The listing of tnese reports into licensee identi_
fied causes is as follows:
Unit 1 Unit 2 Personnel Errors 32 33 Design Manufacturing, Construction / Installation 27 22 External Cause 1 0 Deficient Procedures 9 5 Componen Failure 83 69 0:ner 17 21
4
- 26 These reoc ts were catege ':ec ir terms of SALF 'unct'enal areas as fellows:
Unit 1 Jnit 2 Operations S4 75 Maintenance 5 3 Surveillance 56 51 Quality Assurance 24 21 In general, the LER submittals were usually accectable. The LERs typically provided clear anc concise descriotions of the events. Only one of the more than 300 LERs reviewed was not suomitted on or oefore the due date. However, LERs often did not provice a clear ind' cation of the effects on system function. Relatec or repetitive events were ra*ely speci-fically cited even though a general statement that an event -
was recetitive often would be. Also, root causes anc sym;-
toms were only infrecuently oroviced.
Over 300 LERs were submitted by the licensee for oath units.
Almost 50% of LERs were related to four recetitive events.
These events ne-e: (1) trickie flow errors in eference legs:-(2) precedural deficiencies; (3) failures in tne containment oxygen analyzers; and (4) defective control rod reed switches. The first two events are oe'ng -esolvec generically wnile the latter two pose little~ challenge to plant safety. Twenty-three LERs recorted crocedural problems. This proolem area has previously been identi#1ed as being related to management control over plant systems.
Sixteen LERs committed to providing a folicwup report but only four followuo reports were found in our data case by March 8, 1983. Even discounting events in the last ouarter of tr.e assessment perioc, oniy accut one thire of tne promised followup reports were found. Four LERs reported incorrect ac-ions oy piant personnel. Two of nese were operator'.s failures to recognize plant technical specifi-cation LCO or action recuirements.
- b. Construction Deficiency Reports None o
27
- c. Cart 21 Recorts Ncne
- 2. Investigation and Allegation Review An investigation of circumstances surrounding the damaging of under vessel incore instrumentation at Brunswick Unit 2 was concucted in June 1982. The investigation fincings indicates that the camage was not willful but resulted from poor mainten-ance practices.
An investigation was conducted from September 1982 to January 17, 1983' in resconse to allegatiens that contractor pe-sonnel had been tampering witn eersonal dosimetry. Investigation findings cic not support this allegation.
- 3. Enforcement Actions ,
- a. Violations Severity level I anc II: C Severity level III: 5 Severity level IV: 16 14 Severity level V: 16 Severity level VI: 1 Deviations: 2 bcar The severity level for Suc violations in IE Reoort 83-03 has not been assigned at the time of issuance of this report.
Civil Penalties b.
June 1982 - for three Severity Level III violations involving failure :: mett an-L:0 concerning c:e-acility of reacter vessel water level instrumentation, failure to correct the problem once identified; and, failure to meet all action statement requirements once it was recognizec.
February 1983 - for two Severity Level III violations; one
-for failure to have procedures for and conduct surveillance testing; and the other, for failure to take adequate correc-tive actions in response to audit findings which snould have alerted the facility to the surveillance area problems.
- c. Orders December 22, 1982 - to confirm the commitments contained in the licensee's improvement program and implementation plan.
F' G
28
- c. ACmiris* rat've AC icr.s
'Ccnf'- ati c* cf Actior Lette-s April 8,1982 - confirming licersee commitments to per#crm certain actions deemed appropriate as a result of events involving the misalignment of :nree comoonents in safety related systems.
June 4 198'2 - confirming licensee commitments concerning soecial interim ooerational ano security measures adoctec as a result of camage to under vessel instrumentation at Brunswick Unit 2.
July 2. 1982 - confirming licensee commitments concerning special measures to be accomplisnec as a result of fatiure to icenti#y anc perform surveillance test recuirements.
July 20. 1932 - confirming licensee commitments concerning furtner special measures to be accomolished as a result of determining the existance of accitional failures to icentify anc perfo*m surveillance test recuirements.
- 4. Management Conferences An enforcement conference was held on February 24, 1982, to discuss prooosed corrective actions concerning exceeding a limiting concition for operation anc tne failure of :ne residual heat removal (RHR) service water system to operate.
A conference was nela on.May 23. 1982 to ciscuss the previcus SALF findings.
An enforcement conference was held on July la, 1982, to discuss proposec corrective actions ccncerning e.ents involving misalign-
~
ment of electrical breakers and valves wntch occurred in March 1982. NRC concerns in the areas of operational perfor-mance anc management con rol were also discussec.
A meeting was held on July 20, 1982 to discuss CP&L comments with regard to the previous SALP and the status of the missed surveil-lance test issue.
An enforcement conference was held on August 24, 1982 to discuss
-the status of action items contained in the Confirmation of Action letters dated July 2 and July 20, 1982. A preview of the post startup Brunswick Improvement Program was presented by CP&L.
w 29 A =ceference was ne'c on Novem:ee 10. '952. :o ciscuss re:ent a::fons taken oy ?&L to im:-ove tre overall performance at'tre Brunswick #a c i '. 4 :y . Tne status of t9e teng arge im rovement program was also ciscussec.
A meeting was held on November 17, 1982, to discuss integrated and local leak rate test programs performec at tne site.
An enforcement conference was. held on November 24, 1982, con-cerning violations _ involving racioactive materials shipments to
~
the Barnwell Low Level Waste Management acility.
An enforcement conference was held on December 22, 1982, regarding a number of personnel errors wnich resulted in non-compliance w tn d regulatory reouirements.
A meeting was held on January 11, 1983. to ciscuss implementation of the NRC Confirmatory Orcer issued De:emoer 22, 1982.
- 5. Reactor Trips ,
Unit 1 - Twelve *eactor shutcowns occue-ed as follows:
2/18/82 Scram on hign reactor pressure curing tes: closure of turbine control valve. ,
4/19/82 Scram on loss of power to reactor system logic resulting from error in :ne swit:ning of electrical breakers 5/5/82 Scram cue to spurious hign steam flow signal r
6/1/S2 S -a. :n turbine ::nt- ' va've "as: :'esu-e resulting from low condenser vacuum pressure transmitter failure 6/2/82 Scram on reactor high pressure due to rapid closure of all four turoine oypass valves 6/2/82 Scram curing startup on intermediate range monitor high flux caused by feedwater transient 6/7/82 Scram on closure of main steam isolatio'n valves resulting from spurious spike in radiation monitor coincident with an undetectec olown fuse 6/28/83 Scram on loss of voltage to emergency power buses caused by under voltage condition which occurred when a circulating water Dumo was started l
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30 7.ICcS2 Scram en tur:ine c:ntrol and stoo valve closure resulting from malfunction in power supciy for the tur 'ne contro :i-cuitry l~ '
7/16/82 Scram on intermediate range monitor nign flux
- caused by feecwater transient 10/12/82 Manual scram insertec after safety relief valve
~\ _ failed to reclose after testing i x 'id/21/82'Scramresultingf*ommalfunctionintheturbine generator load imoalance test circuitry
, Unit 2 - Nine reactor shutdowns occurred as follows:
1/13/82 Scram on high flux due to flow inc* ease initiated by recirculation pump runaway
( S, 1/16/82 Scram on turbine trip due to low condenser vacuum
-1/20/S2 Scram on spurious scram discharge volume level resulting from '.evel swi:cnes be'ng bum:ec Oy maintenance personnel
-2'3/82 Scram en scurious so4ke in main steam line high ,
radiation signal 3/13/82 Scram on low reactor water level resulting from momentary decrease in feedwater flow while switching reactor feecwater pumps 9/30/82 Scram on high intermediate range monitor flux resu'.:ing from Group 1 isolation. Group 1 ise a-tion occurred during unbypassing low condenser vacuum iogic witn :ne associatec monitoring instru-ments valved out
~
10/10/82 Scram cue to loss of voltage to emergency cuses resulting from unsuccessful attempt to transfer emergency bus electrical feed to startup trans-former 12/22/82 Scram due to spurious power-load imbalance signal which occurred when a' technician was working on related circuitry 1/3/83 Scram on spurious Grouc 1 isolation during routine surveillance testing of main steam line high temperature isolatien logic
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V. DERFOR %NCE r ANALYSIS FOR H. S. ROBINSON UNIT 2 3
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< 32 A. :UN TIONA. AREA E.'ALJATICNS - 0FERATICNS Licensee Activities .
A refueling outage and a ten year inservice inspection occurred during the perioc February 26 through August 12, 1982. Major inspections were conducted on the reactor vessel, reactor coolant pumps, and steam genera-tors. Hydrostatic tests were conducted on the majority of plant fluid systems. Modifications during the outage inciuced TMI and secondary system work.
The licensee limited power to celow 1955 Megawatts, thermal, during tne SALP review-period. The power recuction and low average temperature program constituted an attemot by the licensee to reduce the rate of steam generator tube degradation.
The Institute of Nuclear Power Operations (INPO) conductec an evaluation of management controls anc operating practices during the weeks of July 26 and August 2, 1982.
Inspection Activities-
'A Raciological Emergency Appraisal was nela January 25 :nrougn :eoruary 4,
~1982. An NRC Task Force on Pressuri:ed Thermal Shock visitec tne site on April 5-7, 1982. A plant procedures and drawing control team inspection was concuctec May 10-14, 1982.
- 1. Plant Operations
- a. Analysis .
During this evaluation period two inspections were performec by
~
regional based inscect0rs and routine inscections of the area were performed by tne resident inspector.
A weakness was noted in the area of plant procecures. Speci-
-fically, most procedural violations resulted from either poorly stated or out-of-date proceiures, :r f-om operations pe-sonnel
- failing to implement procedura1' requirements. One reportable event involved valve misalignment on safety relatec equipment by operations personnel. While the licensee was responsive and initiated programs for upgrading procedures and for training plant personnel on procedural compliance, this effort has, thus far, not been effective in reducing procedural violations.
These shortcomings were the subject of an enforcement conference conducted December 22, 1982.
Operations staffing and training appeared to be generally adequate, with the exceptions noted above on procedural compliance anc maintaining procecures current, Jne large numcer of newly cualif.ied personnel in the operations staff appeared to contribute
- 4 33 t0 tne :*ccecural Croc ets.
i e lant staf', gene a'ly, were se*y 1 observant of Limiting Concitions of Ope *atiens (LCO) :encitiens,
- anc were conservative in apelying action statement requirements.
Cecision making was generally at a sufficientIy nign level to ensure acequate review.
The licensee was highly successful in licensing operator candi-dates. _The licensee's licensed operator qualification and requalification programs have shown significant improvement in the areas of lesson plan quality, emphasis placed on mitigating core damage, olant mcdifications, and feedback of operating experience.
Deficiencies identified by the NRC in the area of pressurized thermal shock have received aporopriate management and training attention.
As icentified in items (6) anc (12) belew, licensee attention to commitments and modifications concerning the low temoerature overpressure protection system was not cirected at a sufficiently high level to ensure compliance. Due to reactor vessel embrittle-ment concerns, the licensee snould increase its ciligence in this area of NRC commitments.
Operator license examinations were conducted during tne evaluation period. This precess. included both written anc oral examinations.
Examinations were given to eight candidates, all of whom cassec.
R0' licenses were issuec to six persons and SRC licenses were issued to two persons.
Fourteen violations and one deviation were identifiec during the evaluation period. These violations are indicative of~a minor programmatic breakdown in tne area of procecure acecuacy and operator compliance. The violations and ceviation identified were:
(1) Seve*'ty Levei IV viciation 'c* 'ailure to imolemeat draw -c e
~
control procedures.
(2) Severity Leve! IV violation for 'ailure te maintair valve checkoff procedures.
(3) Severity Level IV violation for failure to review and correct potential safety hazards.
(4) Severity Level IV violation for failure to maintain operating and abnormal procedures.
(5) Severity Level IV violation for failure to control superceded valve lineup procecures.
f:!-
. 34 (c) Severity Level IV viciation fc- fatture te im:lemer: .a've locking procecu*es.
(7) Severity Level IV viciation for failure te imoiement valve position controls.
(8) Severity Level IV violation for overpressure protection system inoperability.
-(9) Severity Level V violation fo'r failure to follow procedures for shift turnover and logkeeping.
(10) Severity Level V violation for failure to maintain annuncia-tor procecures.
(11) Severity Level V violation for failure to report flow-instrument inoperability.
(12) Severity Level V viciation for failure to establish proce-dures.
(13) _ Severity Level V vio'atier. for failure to follow fuel movement procecures.
(14) Severity Level V violation for failure to issue adeouate instructions for identification of masonry wails.
(15) Deviation for failure to install equipment as committec. t Subsequent to the evaluation period the licensee prepared and submitted the Rooinson Improvement Program (RIP). Tne program is designed to enhance sensitivity to regulatory requirements and stre9?thep the management con:*ol systems related ic the 0:e-a-tional and safety aspects of the facility.
- b. Conc,lusion Category 2
- c. Board Comments No decrease in licensee or NRC attention in this area is recom-
~
mended.
- 2. Radiation Protection, Radioactive Waste Management and Transportation
- a. During the evaluation period eight insoections were performed by regional based inspectors. Additionally, routine inspections in this area were performed by the resident inspector.
W 35
- It was fcJnc 19a! tne Raciation P*otection Program nas snown some 'mpr vemert when comca-ec to the findings of the crev'ous evaluation cerioc. The licensee's program atic efforts to
- improve in ne raciation protection area was evicent in nealtn.
physics controls. The licensee has an effective cecontamination program wnich has descreased the number of contaminated areas and
. personnel contamination events. Preplanning, training, and use of mockups have become more prominent in the licensee's conduct of maintenance and inspection.
A ten year inservice inspection refueling outage was concucted without any overexposures or significant personnel contamination.
However, it was noted that the program was deficient in air L samoling, and in high radiation area control. The scope of work permitted under a routine RWP was excessive.
. The plant did not have a routine air samoling program consistent with industry stancarcs. During 1982, al' constant air monitors (CAMS) except the stack monitor, were taken out of service cue to maintenance problems, and no additional routine air sampling program was established. .The air sampling program in effect during 1982 consisted of air sampling only for specific. work which reouirec air sampling.
The insoectors also found that the job specific air sampling program neecea to be more aggressive in order to ensure regulatory compliance. It was found that the respiratory protection devices used by plant personnel were not sufficient to ensure worker exposures were maintained as low as reasonably acheivable.
A wide scope of work was cerformec under routine RWPs. For example,.RWP for decontamination work in all areas of the auxil-liary building. Records for cecontamination work we-e found :: be non-retrievable because workers conducted tneir own surveys and dic not cocument them. Plant management was responsive to this inspector concern and now limits the use of the routine RWP.
Radiation and contamination survey documentation for work controllec by specific RWP's appearec to De adecuate. '
During the evaluation period, failure to provide adequate control
. of high radiation areas accounted for three violations. In one case, licensee personnel did not lock a high radiation area after being' notified of tne condition. Additional violations resulted from individuals being in high radiation areas without the instru-ments required by technical specifications, anc another for fail-ure to properly post high radiation _ areas. Licensee management was responsive in this area and corrective action appeared adequate.
36 The racwaste p*ogram, consisting of liaLic. gaseous anc so'ic
- racwaste. accounted fer one Severity Level IV violation for discosal of contaminatec oil. The cause of the release indicated a weak program'for sampling anc release.cf oil. The licensee cid not-have procedures describing sampling technique, sample volume, Lor minimum detectable concentrations-for release. Final correc-tive action-for the release of waste oil from the plant is still under licensee evaluation. Other areas.of the liquid and gaseous effluent. accountability program appeared to be adecuate.
- Transportation of radioactive materials accounted for one Severity
-Level III violation, item (1) below, wnich resulted in an enforce-ment conference. The~ violation stemmed from an initial inacequate
~
evaluation to determine if the contents of drums being shipped had been satisfactorily solidified. Although the process control program had been developed to ensure solicification of liquics, the licensee had no previous experience in processing the type of substance contained in the drums being shippec: nor did he evaluate available evidence that the process was ineffective in solidifying the drum contents. In addition, personnel responsiole ,
for-radwaste shipping permitted the shipment of drums to proceed even though-significant external rusting of the drums was evident.
The licensee was responsive in tnis area and has establishec requirements in the radwaste solidification area that shoulc preclude the recurrence of this type problem. The overall transportation program was acequate as eviaancec by naving only one violation in this area.
In the general area, ten violations were identified during the evaluation period. These violations collectively indicated a failure to follow health physics procecures at the worker /tecn-nician level. This is indicative of a need for detailed proce-dures, increased De*sonnel training on crecedures, and orocedu*al compliance to ensure that routine health pnysics practices are unde-stood and cor*ectly pe*#crmed.
One radiological environmental protection inspection was performed during the appraisal period. Inspections were also performed by the. resident inspector. No violations or deviations were disclosed. The environmental monitoring program was well managed and directed toward continued maintenance of effective off-site environmental protection. Management controls and organizational responsibility for program implementation (including environmentai sampling and sample analyses, retention and storage of required environmental data, development anc implementation of an effective quality assurance-program) were consistent with technical specifi-cation requirements and accepted industry practi.:s. Plant staff and staff training appeared above average, and staff morale was
4--
37
'n';n. -me 'icersee nac m. entec in:reasec effort in :nis area te ore:are;f:r the imo'ementation of fortncoming eaciclogical effluent anc environmental technicai 5:eci" cat'ons.
One quality 1 ontrol . anc confirmatory measurements inscettion using the RII mobile laboratory was performed curing the evaluation
' period.and no violations were identified. Correction of weak-nesses identified in an earlier inscection oemonstrated licensee responsiveness to resolving problems identified by the NRC. The results cf effluent samples collected and analy:ed by both the NRC and licensee during the inspection showec agreement. All aspects of the lacoratory orogram were satisfactory.
(1) Severity Level III violation for failure to control racio-active waste shipment packaging.
(2) Severity Level IV violation for failure to control a high raciation area and failure to implement control procecures for other-high radiation areas.
(3)' Severity Level IV violation for failure to implement control precedures for nigh raciation areas.
(4) Severity Level IV violation for failure to establisn a procedure that orovided for cersonnel exit from a locked high raciation area.
(5) Severity Level IV violation for improcer discosal of licensec material.
(6) Severity Level V viciation for failure to post nign radiation areas.
(7) Severity Level V violation for failure to implement proce-cures'for the cor. trol Of *acica:tivity.
(8) Severity Level V violation for failure to follow health.
physics procecures.
(9) Severity Level V violation for failure to establish or implement health physics procedures.
(10) Severity Level V violation for failure to follow health physics procedures.
- b. Conclusion Category 2
1 38
- c. 3:a*: Comments Licensee performance improved from a Category 3 curing tne ore- ;
vious SALP ceriod to a Category 2 curing tnis period. Continuec improvement will .the needec :: ensure that the radiatior control program is sufficient to handle the proje:ted steam generator replacement work. No decrease in licensee or NRC attention is recommended.
- 3. Maintenance
- a. Analysis During this evaluation period one inspection was perfo-med by regional based inspectors. Additionally, routine inspection in this area was performed by the resicent inspector.
The majority of safety-related maintenance nas been performed consistent with regulatory recuirements; however, some weakness was noted in maintenance procedure adequacy. Specifically, several of the violations and reportable events discussed below were caused or centributed to by orocecures containing insuffi-cient guicance anc signoffs. Inattention to cetails curing the procedure review and approval process was also contributory.
While licensee procedures have generally been adequate to conduct maintenance wnen used by experiencea personnel, prooiems nave occurred in activities involving less experienced personnel and/or ,
infrecuent maintenance activities. The licensee has rec:gni:ec a need for imoroved procedures for several years, anc recently both permanent and contractor staffing were increased to address the problem. The licensee's efforts nave resulted in some program-matic improvements, but considerable numbers of maintenance procecures need further develoceent and *evision. These shcrt comings were tne subject of an enforcement conference conducted Decemoe- 22, 1982.
Maintenance staffing' appeared to be adeouate, and licensee manage-ment has conductec accitier.a! training on the importance of quality procedures and procedural compliance. This effort was.
directed at improving the quality of maintenance prior to comple-tion of 'the longterm procedural upgrade. Maintenance personnel generally communicated well with the operations staff to assign a proper priority to the maintenance of safety related equipment.
Additional emphasis needs to be given to the importance of main-taining the equipment that directly supports safety related systems.
r-39 Ien C # :Se n*reteen reto*:3Cle everts fo" :n's *a". we#e 309 to ccmcenent fad ures. newever res ew cf these *ep *:s incicate d
almost no cor-elation wi:n maintenance act'vities. Four eeocr:-
acie events cic ressi from perscnne' errors ancfo- cre ecurai inacecuacies relatec to maintenance activities. Two events affectec safety system operability and one caused reactor coolant
. system leakage. A special report issued by tne licensee described the failure, during surveillance, of a reactor _ trip breaker caused
.by-inacequate cleaning and lubrication of the undervoltage trip cevice.
Five violations were identified during the evaluation period.
These violations are generally indicative of the need for improvec maintenance procecures. Tne violations identifiec were:
(1) Severity Level IV violation for fai ure to implement mocifi-cation controls during maintenance.
(2) Severity Level IV violation for failure to acequately review a maintenance procedure prior to approval and use.
(3) Severity Level IV violation for failure te control ma'r.:en-ance activities.
(4) Severity Level IV violation for failure to establish adecuate 1 calioration proceaures.
(5) Severity Level V violation for failure to imetement ecuicment control policies on completion of maintenance.
- o. Conclusion Category 3
- . Scard Comments Licensee-performance, which was evaluated Category 2 during the previous SALF perioc, has declined du*ing tnis perioc. Li:er.see management attention should be increased.
- 4. Surveillance
- a. Analysis Operationai Surveillance During this insoection period seven inspections were performed by regional based inspectors. Routine inspections were performed oy the resident inspector.
< 40 Ine ifcensee's surveil'.an:e Dr: gram was generally weil estao isnec
'anc imp'er.ented. Seneculing anc como'etion of surveillance nas oeen timely anc has receivec acecuate anagerent attention.
Accitional orograms for surveillance tracking anc auciting have been establisned to ensure complete compliance witn recuirements.
An in-depth review of surveillances required during the refueling period were conducted and no violations were identified. Several procedures for performance of surveillance activities were poorly written. -However, reviewed as a program, surveillances and inservice testing activities were well controlled. There were no reportable events in tnis area. There were four inspections in tne area of inservice insoection (ISI) non-destructive examination (NDE) activities by regional based inspectors during this inspec-tion period. Majo" ISI activities involved the ultrasonic inspection of the reactor vessel belt-line region and the radi-ograpnic examination of welas in a main cociant pumo. When some bolts insice the main coolant Dumo were found to be cegracec, tne licensee aggressively pursued the cause anc extent of tne eroblem.
This ir;volvec cismantling the other two main coolant cumps and extensive evaluation of all failed bolts. There were no viola-tions or deviations found during the inspection of the ISI/NDE activities.
Three violations were icentified curing the evaluation perioc:
(1) Severity Level IV violation for failure to estaDlish an adeouate surveillance procedure.
(2) Severity Level V violation for failure to perform surveil-lance at the proper frequency.
(3) Severity Level V violation for failure to establish and im:lerert ade: Late :ac:edures 'o* containment leak " ate testing.
- b. Conclusian .
Category 1
- c. Board Comments Licensee performance has improved from Category 2 during the previous SALP to Cagetory 1 during this period. Altnough 4
improvement was observed in this area, the potential exists for the same problems to cevelop as witn the Brunswick surveillance program. No decrease in NRC inspection effort is recommended.
+ * . , - , - - , - *
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41
- 5. F're Dr:tection-
- a. Analysis.
During this evaluat'en pericc, routine inspections were performec by the resident inspector.
No violations were icentified. A review of fire protection special reports revealec some weaknesses in the licensee's post-mocification testing ~ program for-the major fire protection equip-ment upgrace. The licensee has Deen responsive to these proclems anc nas taken or initiated aopropriate corrective action.
Overall, the level of plant fire safety was greatly improved.
.The plant fire protection staff aopeared to be highly motivated and knowlecgeacle. Staffing levels anc training appearec to be above average. Fire _ protection acministrative crocecures were generally acecuate.
-b. Conclusion Category - N0t Rated
- c. Board Comments There was not sufficient inspection activity in tnis area curing i the evaluation period to justify a rating.
i
- a. Analysis During tne eva'uat'cr eeied. the -egiona' sta#' c:nducted a routine inspection, an emergency preparedness appraisal, and observed an exerc'se.
During the emergency preparedness appraisal two deficiencies were icentifiec in tne areas of training and notification procedures.
A Confirmation of Action Letter dated February 22, 1982, was issued-concerning the deficiences. The licensee was responsive to the letter and fulfilled his commitment to correct the deficien-cies.
During the licensee annual exercise (October 1982), an emergency preparedness deficiency was icentifiec in the area of accident classification procedures. As a result, a Confirmation of Action letter (dated November 1, 1982) was issued. The licensee responced to the ceficiency by revising procedures and conducting training.
S 42 00*ccrate management accearec : ce succert'se of emergency planning.* esp 0nse prcgrams. Inere was evicence tnat priorities nac cese establishec anc resconsibil' ties ass'gnec 'n the area of emergency preparecness. Licensee recorcs anc cocumentation of program activities appearec to ce complete.
From an enforcement stancpoint, the licensee's corrective action has generally been timely anc effective. Although some program-matic weaknesses were identified by NRC and corrected by the licensee recurrence was rare. Licensee critiaues of emergency resconse activities during drills has not been as aggressive and candid as needed at times. Improvements are necessary in this area.
Emergency preparedness staffine levels at the plant and corporate office apoearec to be adeouate. Key positions have been fillec at
~
the elant and corporate offices. Authorities and responsibilities have been defined for key positions.
A training program has been defined and implemented for members of the emergency response'organication. A program for professional cevelopment of the emergency creparecness staff had been defined.
Two violations were identified curing the evaluation period:
(1) Severity Level IV violation -for failure to meet frequency recuirements for audits of the emergency olan and implement procedures.
(2) Severity Level V violation for failure.to conduct recuired tests and drills.
- c. Conclusicn Category E
- c. Board Comments No decrease in licensee or NRC attention is recommended.
- 7. Security and Safeguards
- a. Analysis During this evaluation period four inspections were performed by regional based inspectors. Routine inspections were performed by the resicent inspector.
I
43 Ine it ensee nas responsive tc NRC *nd 'at'ves. Tne licensee's si te se:urit) canagemen was ennance: by :orporate managemen; w'tn an ap acent earrasis on security. Secue' y staffing anc training accearec :: :s acecuate. Personnel morale was nign. The licersee extendec an ex:essive amount of time anc effort maintaining security equipment that snould have been upgraded; this was icentifiec as a minor programmatic weakness. According to the physical security event reports received, equioment failure was
. generally a root or contributing cause. While the licensee's compensatory measures have ceen acequate, increased empnasis on
~
ecuipment uograce is neecec. Licensee management has initiated actions to imorove the system.
Four violations were identified dur'ng the evaluation period.
These violations were considered isolated and not indicative of
. programmatic creakcown. Ine violations icentifiec were:
(1) Severity Level-IV violation for failure to report a enange to the security plan.
(2) Severity Level IV violation for failure to perform security cregram a'.cits at the -ecui-ed frecuency.
(3) Severity Level IV violation for failure to provice acequate vital area access control.
(4) Severity Level V violation for failure to search a package.
- b. ~ Conclusion Category 2
- c. Board C:rmer s Ne de:rease 'n :e-see er NRC attention 's re:: mended.
- 8. Refueling
- a. Analysis During this evaluation period one inspection was performed by a regional based inspector. Routine inspections were performed by the resident inspector.
Extensive inspections were conducted in the areas of refueling preparation, operations, maintenance, surveillance, and startup testing. No violations were observed, and only minor followup i.
items icentified. Startup testing procedures were adequate, but would benefit from minor changes in format and clarification. The
i -44
- eacter eng4*eering staf# aac tnei- t-aining were acectate, anc the licenses has taken steos te crov4ce tre reactor enginee* with accitional training ano liaisen with the corporate fuels section.
- b. Conclusion Category 1
- c. Board Comments Licensee performance, wnich was not rated curing the previous SALP oeriod was Category 1 during this period. The proper amount of licensee attention has been expended. No cecrease in
-licensee or NRC attention is recommenced.
- 9. Licensing Activities
- a. Analysis
- The. assessment of licensee performance was basec on the evaluation of the following licensing activities:
Project management administration Response to NUREG-0737 items 10 CFR 50, Accendix R Environmentai qualification Operating licensing Control of heavy loacs Pressurized thermal shock (PTS)
Cycle 9 reload Radiological effluent technical specification In gene-al, management involvement and control in assur'ng cuality was inconsistent, resulting in varying levels of licensee oerfermance. Evidence o' cuality macagement capability was apparent in selected areas, but consistent management attention over the full range of licensing activities was not evident.
The licensee's approach to resolution of technical issues was acceptable. Technical understanding of the issues was generally demonstrated, but a lack of thoroughness or depth in the approach to resolutions occasionally resulted in lengthly requests for additional information.
Responses to NRC initiatives generally were not timely and
+
frequently required extensions of time to complete. Several issues have been outstanding for extended periods (e.g., RETS, Control of Heavy Loads, Appendix R, Cycle 9 Reload, and PTS).
r
45 Ine li:ensee nas re::gr :ec proclems in this area anc recently d
mace :nanges in nis organi:ation anc sta##ing to im:-ove th's si Lation. Acditierai 'icensing cers:cnei nave Oeen adoec. as well as an onsite licensing representative,.c im: rove communi-cations ~between tne corporate headouarters anc :ne plant site.
The licensee has requestec a meeting with the NRC staff to discuss initiatives that have been taken and that will be taken to schedule and expeditiously respond to plant soecific, multiplant anc TMI open items.
Overall, the performance of the licensee has been satisfactory.
However, there were a substantial numDer of marginal areas.
Inconsistent cuality in management of licensing activities, a generai lack of timeliness in resconding to staf# ecuests, and completeness anc depth of submittals were icent'fiec as signifi-cant negative factors.
- b. Conclusions Category 3
- c. Boarc Comments Licensee performance, whien was not evaluatec curing tne previous SALP oeriod. was Category 3 during this ceriod. Licensee manage-ment attention snould be increasec.
- 10. Quality Assurance
- a. Analysis ,
During this assessment period, two inspections were performed by regdonal 4csce:::-s ir the :caty assu-an:e area. One :ner QA-related problem, violation (4), was identifiec in another functional area.
In general the licensee has adecuately statec and understood QA
. policies as evicencec by a review of QA procecures anc ciscussions with licensee personnel. However, one weakness in this area was related to procedures tnat failed to involve QA management in the prompt resolution of problems identified by the QA staff. This issue is discussed in more detail in the Brunswick section of this SALP report; the~ problems are common to botn plants.
Licensee records were generally well controlled. Violation (6) was identified in this area, but appeared to be an isolated example. Procurement activities were generally well controlled and documented; however, increased management attention appears ne:essary as evidenced by violation (5) below.
'% x
+4 46 Ine licenses was genera' b *escens'we tc NRC icent'#'ec ' tens "e'atine te OA act vities as evicencec by closu*e of 13 o*evi0usly 4
icentifiec unresolvec anc inspector followuc items as cescrioec in inspection report Nc. 32-24 One item invciving ceveic: ment of a trend evaluation crogram hac been ocen since 1979 incicating a need to' improve _the timeliness of actions taken to resolve certain
. issues.
Corrective actions for items identified by the site QA surveil-lance staff were usually aceouate. QA audit findings were hamperec by DEU failure to issue all audits in a timely manner, violation (6) celow, and failure of the audited group to resconc to certain audit findings in a timely manner, violation (4) ceiow.
Audit staff training generally appeared adecuate; however, exper-
- tise was weak in the area of plant operation. The licensee nas indicated a desire to improve the abilities of its inspectors and, wnere appropriate, supplement audit teams with special
. excertise. The NRC encourages this effort in light of the numoer of violations listec in the plant operations section of tnis report.
The corporate level Performance Evaluation Unit (PEU) concucts aucits at both operating sites. Certain levels of management were involved in site activities as evidenced by frecuent visits and communications oetween tne Manager, Operations QA/QC ano site QA personnel and by the Manager, Corporate QA Department. However, the Principal 0A Specialist who supervises the PEU did not apoear to be directly involved in site activities.
DEU audits we*e not conducted at the required frecuency as evidenced by violations (2) and (3) and one adcitional example discussed in tne sa#eguards section of this recort. Aud't ee: cats anc resoonses were not always issuec in a timely manner as evi-cenced by vio'at ions (4 aad (6) be10w. Site QA peas 0nne' pe*# cams a surveillance function and corporate management appears to ce involved in this activity as previously discussed. The audit function is perfcrmed by the PEU and there appeared te be little, if any, corporate management attention in this functional area.
Increased corporate level management attention is needed to improve the overall effectiveness of PEU audits.
Staffing for.the PEU appeared to be inadequate as evidenced by the
- failure of this group to perform and issue audits in a timely manner. However, additional personnel were in training. The l increased audit staff should help alleviate this problem.
r l
47 Eign: .dhiations we-e iceq;ifie: curing tre assessmen: pericc.
Four cf nese viola:icns (2. 3. 4. anc 5) incicate a neec for improvec management control of tre OA audit orogram. The viola-tions icentifiec were:
(1) Infraction concerning failure to report conditions related to the radiation amorittlement of the reactor vessel.
(2) Severity Level IV violation for failure to conduct an audit of the Emergency Pian anc imolementing proc'ecures at least
-once per 24 months anc for failure to conduct an audit of.
the fire' protection program and implementing procedures at least once per 24 months.
(3) Severity Level IV violation for failure to concuct an audit of tne fire protection and loss prevention program by an outsice cualifiec fire consultant. at intervais no greater than tnree years.
(4) Severity Level IV violation for failure to submit audit responses within the allowable time.
( 5~) Severity Level ~IV violation for failure to orovice written procedures for tne control, storage, anc preservation of cuality controlled material and ecuioment recuired by Tecnnical Specification 6.5.1.
(6) Severity Level V violation for failure to transmit aucits to management within the allowable time.
(7) Severity Level V violation for failure to procerly store radiographs.
(8) Severity Level V violation for failure to follow QA proce-cares.
~
- b. Conclusion Category 3
- c. -Board Comments Licensee performance, which was evaluated as Category 2 during the previous SALP, has declined during this' period. This is attrib-uted to lack of management support of tne corporate Performance Evaluation Unit. The licensee should increase management atten-tion in this area. The NRC should continue the increased level of attention in this area.
7 48 E. 3.70.~5 'd 75
- 1. Te:e- s Data
- a. Licensee Eve-: Reports (LERs)
Nineteen LERs were reviewee for Robinson Unit 2 for this assess-ment period. The dispersion of these reports into licensee identifiec proximate cause coces is as follows:
Personnel Error 4 Design Manufacturing Construction / Installation 4
. External Cause O Deficient Deccedures 1 F Component Failure. 10 Otner 0 Tnese reports were categori:ec in terms o' SALP funct'onal areas as.follows:
Operations 11 Maintenance 1 Surveiltance 6 Quality Assurance 1 The LERs for this plant were evaluatec for completeness anc accuracy for the period January 1, 1982 to January 31, 1983.
Component failure prompted :ne majority of LERs. The event
. descriptions were clear and detailec and supplemental information was provided for every LER. In each case, the licensee mace an attempt to cetermine tne root cause of the event anc cossible imolications of the event to other plant equipment. If numerous
'ailures ceca--ed, ar favestigat'on was conducted te dete*m'ne if the proolem might be generic.
- b. Part 21 Reports None
- 2. ' Investigation and Allegation Review One investigation concerning reactor vessel surveillance capsule data occurred during the review perioc.
7 49
- 3. En#c-ce er.: ac tions
- a. Violat'ons Severity Level I. II - 0 Severity Level III - 1 Severity Level IV - 25 Severity Level V - 19 Severity Levei VI - 1
-In'raction - I
- b. Civil Penalties None
- c. Orcers None
- d. Administrative Actions (1) .Cen'irmation of Action Lettees February 22, 1982 - involving significant deficiencie: from the Radiological Emergency Aporaisal inspection.
November 1, 1982 - involving emergency preparedness deficien-cies identifiec during an emergency exercise.
(2) Management Conferences A conference was held on May 28, 1982, to discuss the previous SALC "qd'9gs.
A ccnference was held er Ncvemcer 24, 1950, te cisc.ss radioactive waste shipping and packaging violations.
Ar. enforcement conference was neic Decemcer 22, 1982, to discuss concerns about violations of regulatory requirements and the effectiveness of management controls.
4.
Reactor Trips Eight reactor shutdowns were as follows:
8/15/82 Low level steam generator 8/21/82 High level in steam generator due to faulty feed water regulator valve (twice)
== _ _ . _
+= ,
..-- 3.-
- .- 50 (
9 05 E: : ".esel stea: ;enera.:-
9c09.32 Loss of concensate oume
, 9/21/S2 Low level steam generator. cue to 'eedflow, steam flew mismatch 10/24/82' High temperature on turbine exhaust hood
=12/31/80- V.S!V failed closed causing low steam generator level 1/08/83 Reactor trip creaker opened automatically.
l I
I i
i o
=
d s
VI. DERFORMANCE ANALYSIS COR SHEARON 4ARRIS UNITS 1 AND 2 I
l 52
-A. Functiona'. Area Evaluation - Construction -(Units 1 anc 2)
.- L':ersee Activ' ties Juring this evaluation perioc, construction progressec at a rate consisten; with the projected schedule. The licensee had significantly increased the manning for the CP&L Site Design Group. Emphasis was placed on increasing manpower to accommocate.the increased construction activities as they relate to mechanical, piping-and electrical efforts. _The site QA/QC staff has also
-significantly increased.its manpower during this reoorting perioc. The QA/QC staff was increased primarily to accomodate additional inspection
' responsibilities which it acquired, i.e to inspect start-uo and test personnel and their work effo.rts, anc also to accommocate the increased site
~ activities as they relate to welding, mechanical, material control and QA/QC records and their review. The QA/QC group has been dividec into two separate' groups. The QA group new is totally responsible for all-of the
. surveillance activities, and is not responsible for first-line inspection functions. The QC group has been assigned first-line inspection activities in selected l areas. Both of these groups now report to the site QA/QC director.
The manning.of tne start-u and task-greuc has also been increased signi-ficantly to accomnacate the turnover schedule. The licensee nas increasec its turnover activities with a 125-week schedule starting January 1,1953.
This schedule, if followed. should alicw fuel loading on schedule, in r
' June of 1985.
During tne evaluation period the licensee conducted four major aucits: k
. Cresac, McCormick and Padget Inc., conducted an audit of the licensee's management functions. Tne audit started abou: April 13, 1982, and was finaliced-on October 1, 1982.
INPO conducted an audit of the licensee's overall management, design anc constr ction functions assccia:ec witn :ne Harris site. The a.ci team consisted of approximately 30 members and covered the period of June 14'through June 29, 1982.
. MAC (Management Analysis Company) conducted an audit of'the licensee, whien primarily covered the quality assurance aspect of tne Harris site, during the period of September 21 through September 30, 1982.
. The licensee conducted a Self-Initiated Evaluation of the activities at the Harris site. The audit covered the period of.0ctober 11 through Novemoer 12, 1982. Tne audit report was publisned on December 10,
' 1982, and included the Quality Assurance section taken from the MAC audit which had been previously conducted.
L
53
'As a result'of tne Self-Initiatec Evaluation, a recort was generatec wnicn
- recuirec various'cro6cs to icncuct sel#-cor*ective actions by certain cates.
Inefteam wn'en concuctec :ne aucit will be recuitec to follow u tc assure tna: aceouate corrective actions nave Oeen taken. The aucit was objective Lano provicec the licensee witn. opportunities for improvement, anc also-indicated that the company, in general, is performing safe and satisfactory construction work at the site.
In October 1982, the. licensee assigned a corporate nuclear representative,
~
(retirec vice chairman of tne licensee's Board of Directors), to interact between the Chief Executive Officer and Senior Manager for all site aspects
-of-construction. The licensee had required all their emoloyees and tne
. senior constructor (s) employees to' attend a video tape procuction wherein four of the licensee's executives ccnfirmec their commitments to cuality.
Inspection Activities Forty-two. inspections were conductec during this period; twelve of these inspections were routine inspections concucted by the resicent inspector, and the remaining were conducted by Region II personnel.
= 1. Soils anc1Founca: dons-
-a. Analysis During this evaluation period six inspections were performed my r regional based inspectors. Additionally, routine inspections were performed in this area by the resident inspector.
The insoections involved examination of QA implementing proce-cures, soils testing laboratory, recorcs anc oackfilling of the excavations for Units 3 and 4 which have been cancelled. The majority cf the scils anc foundatics wc-k'had been ccmc'eted for Units 1 and 2. The remaining activities in this area were primarily ccccerned with oncergrounc piping systems.
The QA/QC procedures and controls met NRC requirements. The recoros were generally complete, well maintainec, anc retrievac;s.
Equipment in the testing laboratory was properly calibrated and testing and oackfill operations were concucted in accorcance with
. ASTM standards, procedures, and specification requirements. No violations or deviations were identified.
.The licensee's activities in this area met industry standards and were considerec to ce adequate.
- b. Conclusion Category - Not Rated
( __
' ts
. ~......:
.'"e's aa 't :
- t;e.-r> !!d #?Clent .. 34e Or *Y ' t .
a ea to justify a -a 'r.3
- 2. C:ntai rent and Otner Safety Relatec Struc.u'es
- a. Ana'ysis i C' rin- tnis evaI ta*.;c- ne*iod tw&'vc i spect'Oni Involv i ng ? 's .-
tJeal Orcrit3 a*C
~.5 e ' s *.C tt. re s we "e C e r* * "* a 3 aciona'
.2. s ed i n s p K to r '. .
~ e ir.specti?rs ' v0'.:c e's-*-at';- : - [ ' ' .? ;, d e.i ; se;;c-OUres. c; teds, : ncr$te tGitt g la*:*3*.: f. 4 0 **" 3:t',#*'e5 .
13s:c atec witr. :cncr te ciacements a c proc-a.t rev %. o:serva-ticn Of work. Pa.c r2 View e' coality w'r. alloc'a ec w .h sa#et;. .
i related s*. eel itructuras.
ne QAiQ,. ;.re:acuees a a cent-o.:s et Ns... . tg 're. tents. ,te c o ce s sere generally wel' mairtaiaed anc c0molete. 'A t L P ine e .ce0ti?.
': tre v:o'uti;e octe bel:4
, 4;-k a:t'vit' s weet 'ormed a ac cr.tance witn .*ccecure ind :cecif'cattor -eau e ents "anage.ent i nv c h e.?.e - t . rsso' t'on of techa' cal is.ues s ta" - -
and training were ace:cate for the :evel of sctivity n. .vec.
The u .
licensee was resocr. 've in correctine the violatior ':sted -
erow. 3 Severi ty '.< vel '/ . i ci a ti c 'e r 'A' ' . et .: o c. -1,, 'ie'd - -e c:ac ete test :s'i :tes, ,
,/ A s .:.e tv. e c > .- h e v.- ..<e- w/ 5 .r..h . . a. *
,,, .,.$cr r .
..g..., ,i -,
.. . , ,,,..,,,. .. , , . w . . , . , n , 4
.$ ~ ' ~ l5 0 'n . . .s.%. %. 1, &*. $.
.._ ...:p. ., t
- 3. -
. ~ .g
, y& %. . y e r t ec . . Q y.n. ,.<. .~c s.:t s ,. r4
.. icarc Corter,t$. ,/ "' P
~ '"' ' ' ' ' " l i * ' '*'-
% I c.v. . . %. w.'.".:-
f~
- L hc dee m..e .' pf.: -v ,pM-~ 4 ((, { '
~
. Picing s.ystem3 ans Supcort systems
- a. Analysis Curing th's evaluaticr' nerioc eight inspect'on, were re-ice w? ,
eg4 0nci cased insce:t:,*,. Acciticaai's, "O, tire 4 r:,gectio s w -e as for.r.ec by the resicer.: inspectnr. Insee:.t'ons incit.ded r8aie,.
- f ; regra-: : n c edu vi. baervattens c' cek and worA acti.1-ties, and.re<tew of quality reccrds, in tne areas of : ee welcing, seai welding. wa'de- cu ali fi:ttien s . we'cr; ' iller r ste-ial
- entrc':, repair nel: ice, 0:piag supter:3. Licin; a asedly ste' a:e ar.d pre >e .at i er. and creserv'ce 4nses:ti:-
7-55 Review of :ne violations coes not incicate a creancewn of :ne program. Ne recetitive viciations we-e identiffec,'and cor*e:tive actions accearec to be premet and ef#ective. Imp *over.erts 9ac ceen made in.this area as ev i cencec cy :ne fact tna; all :ne violations except the violation (1),below, in :ne preservice inspection area were identified within the first sixty days of the reporting period. The preservice inspection violation was identified during the first inspection in that area.
The organization in this-functional area appearec to be acecuately staffed with trained and oualified personnel. Procedural require-ments implementec in this area appeared generally satisfactory.
-Seven viciations were identified during the periac as folicws:
(1) Severity Level IV violation for failure to icentify in welcing records the inspectors that perfornec :ne inscec-tions.
(2) Severity Level IV violation for failure to perform weld
' inspections with qualified inspectors.
(3) Severity Level V violation for failure to follow visual inspection proceoures.
(4) Severity Level V violation for failure to follow procecures for inspection of welds and reporting of discreoancies.
(5) Severity Level V violation for failure to establish adequate measures to assure purchased services, including preservice inspection, conform to procurement documents.
(6) Seve-ity Level VI v i c'at'en 'or faure te f:l'ow .e'c'n; procedure specifications.
- b. Conclusion Categcry 2
- c. Board Comments No decrease in licensee or NRC attention is recommended.
=.
O-
+ 56 L Sa#ety-Related Components-
-a. Analysis
'During this evaluation period, five inspections performed by regional based inspectors addressed this area. Additionally,
--the resident _ inspector performed routine inspections in this a rea .- The insoections involved review of program and procedures, observation of work and work activities, and review of quality records'in the areas of reactor vessel, steam generator and pressurizer storage and protection, installation, anc storage of other safety related equipment. Management involvement and controls for assuring quality in the area of protection, instal-lation, and storage of p fety-related equipment were generally adequatef P M @ 4he'two-violations,related te protection and storage, identified below, indicateM weakness in these areas dic-exist early in the reporting period. There is evidence of_ prior planning and assignment of priorities and procecures for control of activities:are generally adeouate and aopear to be understood.
The corporate quality organization was usually involved in site activities, but some confusion regarding the division of respon-sibili iest between Co&L OA and tne site Construction Insce: tion Group hindered program implementation. Records were generally available anc complete.
The licensee was receptive to NRC initiatives. Responses generally reflected an understanding of the issues, but'resolu-tions were sometimes ceiayea anc lacked thorougnness as discussec in IE Report 32 0 uA W awa-nlified bv violations (?) ad ( 1). -
r 7-M[ The organization in this functional area appeared to be adequately sta##ed with trai9e:: and qualified perso"nel.
The violations ' centi'ied below viere not const::ered incicative of any programmatic breakdown.
(1) Severity Level IV violation for failure to require tne vencor to manufacture a reactor makeup water pump in accordance with the seismic shock analysis for the pump.
(2) Severity Level V violation concerning safety-related equip-ment not properly protected from the environment and adjacent construction activity. 400 00)
(3) Severity Level V violation concerning safety-related equip-l- ment not procerly protected from the environment and adjacent construction activity. (0 02) -
l-
- b. Conclusion Category i
57
- c. Boarc Comments. .
.N . ci, t ew.e. .. m Et . ; b c .e . ; th 5.h n . ..- .' u a e. . , . -
- c. Support Systems -
un, .m udy
- a. Analysis During this assessment period one inspection was conducted in the fire-protection area by a regional based insoector. Additionally, inspections were also performed in this area by the resident inspector.
Only~a small portion of the oermanent fire protection features had '
been installed at the time of the regional inspector's inspection.
'However, it appeared that the systems 'were to be installed and testec under an. adequate cuality assurance program.
.An adecuate construction site fire protection program was provided to prevent loss in the event of fire. Daily safety inspections of .
construction actvities were conductec to assure that adecuate fire
, protection / prevention features were in effect. Craft personel were trained in the proper use of portable and semi permanent fire fignting ecuipment. Tne site fire brigade was well trainec and familiar with necessary tecnnicues to be used to combat various types of fires which can occur on tne site. The construction site fire protection equioment and systems acceaeed to be adeauately
~
maintainec, inspected anc testec for construction operations.
Management appearec involved anc very suoportive of the plant's fire protection program. Responsiveness _to NRC initiatives had ,
been timely. Major fire protection discrepancies had not been ;
, identified. The staffing and training in the fire protection 'LJ program at the current construction level apoeared adequate.
No violations were identified in the area; however, one deviation was founc:
Deviation for the failure to store and maintain the permanent piant fire protection pump ~anc appurtenances in accorcance with plant storage procedures.
- b. Conclusion Category 1
- c. Board Comments Licensee performance, which was not rated during the previous SALP, is Category I and is limited to the construction fire protection program. Licensee resources and management attention appear to be at the proper level. No cecrease in NRC inspection effort is recommended.
1
\
h
- l c 58
- 6. Electrical Dewer: Su:ciy anc 3'stricut on i
. a '. -Analysis .
During this' evaluation perioc eight inspections were cerformed by regional basec inspectors. Additionally, inspections in this area
.,s
_ were performed by the resident inspector.
A weakness was noted in the welding and welding inspections of
'. electrical =ttems and supports as indicated by the first three B ; '- violations listed below. These items involved welding and welding' inspections associated with electrical supports and
- vendor supplied electrical equipment. Two of the violations related to welding by off-site manufacturers. These off-site
< 'n welding problems were not identified by the on-site receipt s J ' inspections and/or source inspections by the manufacturer or CP&L. The licensee has been prompt in resconcing to these items.
Corrective action included: -increased surveillance of manufac- i s turer's shop activities; increased on-site inspection recuirements v for material; re-inspection of material / equipment tnat may have
-nonconforming welds; and an improved training program for welding o 'inscection cersonnel. In addition, welding inscection supervisers were to perform a more extensive evaluation of emoloyees in this '
area. .
One violation related to storage anc protection of electrical
. equipment. The licensee responded to this item promptly and
% .took action to empnasize to site personnel the importance of W proper storage and protection of electrical equipment. The 4 .
- licensee's corrective action concerning storage and protection
- f' :~- of electrical equipment from adverse environmental conditions
[3
- and adjacent construction activities was reviewed by NRC and consiceaec to be acceptacie.
.m 1
Three viciaticns concernec prececural requirements ir whicn actions were performed out of sequence, requirements were not fully implemented by craft personnel or reouirements were not C.. implementec in :ne ~ specifiec time period.
- m The-final violation concerned a field change request that allowed -
the 1nstallation of equipment to a mounting criteria that differed
~
from the mounting configuration for the seismic qualification of the equipment.
Ine licensee's approacn to the resolution of tecnnical issues has been normally sound and characterized by viable and thorough approaches and has been responsive to NRC issues. The organica-tion'in this functional area was considered to be adequately staffed with qualified personnel.
94, h * 'w p .
, . w. _
- 55 g 6. Electrica Ocwe* Succi > anc D4stricut'on
- a. Analysis .
During tnis evaluation perioc eigns inspections were cerformed by regional based inspectors. Additionally, inspections in this area were performed oy the resident inspector.
A weakness was noted in the welding and welding inspections of electrical items and supperts as indicated oy the first three violations listed below. These items involved welding and 4, welding inspections associated with electrical supports and vendor supplied electrical equipment. Two of the violations related to welding by off-site manufacturers. These off-site welding problems were not identified by the on site receipt
> inspections and/or source inspections by the manufacturer or CP&L. The licensee has been prompt in resconding to these items.
Corrective action included: increased surveillance of manufac-turer's shop activities; increased on-site inspection recuirements fov material; re-inspection of material / equipment tnat may have nonconforming welds; and an_ improved training program for welding inscactice eersonnel. In acdition. welding inscecticn suceevisers were to perform a more extensive evaluation of emoloyees in this area} 7 One violation related No stdrage anc protection of electrical
% eouipment. The 1icensee regponded to this item promptly and took action to emphasice to site personnel the importance of proper storage and protection of electrical equipment. The licensee's corrective action concerning storage and protection of electrical ecuipment from adverse environmental conditions and adjacent construction activities was reviewed by NRC and consice-ed to be acceptac'e.
Inree vic'.ations cencernec procacura'. requirements in ohien actions were performed out of sequence, requirements were not fully implemented by craft personnel or recuirements were not implementec in tne specifiec time period.
The final violation concerned a field change request that allowed the installation of equipment to a mounting criteria that differed from the mounting configuration for the seismic qualification of the equipment.
The licensee's approach to the resolution of tecnnical issues has been normally sound and characterized by viable and thorough approaches and has been responsive to NRC issues. The organica-tion in this functional area was considered to be adequately staffed with oualified personnel.
59 Ir ::ta'. eignt vic'.at'cns sere icentifie: curir; tre evaluation Cecice. Trese sio'.ations we*e not indi:at've :f a :-:grammati:
creak cown but were tne esult of a failure to creoare aceouate pro:e:gres to im:;ement NRC recui*emer.ts anc licensee commitments or to trair personnel anc make them aware of tnese *ecuirements and commitments. As indicatec above, the licensee has taken action to rectify these issues. These violations are identified below.
(1) Severity. Level IV violation for nonconforming vendor welds on seismic electricai aceway suppcrts.
(2) Severity Level IV violation for inaceouate field welds on cable tray supports.
.(3) Severity Level IV violation for nonconforming vencor welcs in electrical panels.
(4) Severity Level IV violation for failure to implement proce-dural requirements, in tnat welding of equipment to emoeds was performed prior to satisfactory acceptance of eouipment set inscettion.
(5) Severity Level V violation for failure to properly store anc protect electrical ecuipment from adverse environmental conditions anc acjacent construction activities.
(c) Severity Level V~ violation for failure tc imolement proce-dural requirements,.in that craft persennel failec to meet torcuing recuirements on cable tray fasteners.
(7) Severity Level V violation for failure to implement proce-durai -eeuieerents wi th *esce:t te dasce:t ca anc a'ntea.an:e i
of electrical penetration assemolies.
(8) Severity Level V violation for failure to verify that electrical cabinets were seismically cualified to present mounting configuration,
- b. Conclusion Category 2
- c. Board Comments No decrease in the amount of licensee or NRC attention is recommended.
60
- 7. Instrumentation anc Centrol
- a. Analysis No routine inspections were performec in this area cue to the early stage of construction activity.
- b. Conclusion
^
Category - Not Rated
- c. Board Comments There was not sufficient licensee or NRC activity in this area to justify a rating.
B. Licensing Activities
- a. Analysis The evaluation was based on the following licensing activities:
Reservoir eeanalysis subsecuent to cancellation of Units 3 and 4 Environmental enginee-ing review Reactor Systems review of the FSAR Instrumentation and control reviews Racwaste systems review Mechanical engineering review The main area of concern was that the information suomittals were frequently not timely, taorougn, nor technically sound. Evidence for such inacecuacy was nctec pa*:ica'.arly in the reservcir reanalysis, accuracy of information in the Environmental Report, anc tecnnical information on tne racwaste systems. Inis incicatec a lack of management involvement in assuring quality of licensing l documentation in submittals to the NRC.
With regard to resolution of technical issues from a safety stand-point, the licensee seems to be committed to meet all the nuclear safety standards but the program lacks thoroughness and depth in its responses to NRC initiatives.
In the area of the applicant's staffing of personnel there was an apparent lack of sufficiently qualifiec people to provide technical depth for timely submissions in some areas.
Based oneg, view of the licensino activities described in the first paragraphy.s this sectionfthe NRC and applicant / attention needs to be increased as follows:
61
( ". ) maintair.'ng tr.e a::gracy of :ne infc-matior. orosicec for NRC
- ev ew.
d (C) ensur ng suffi:ient suostance in an in# rmation suomittal su:n tnat repeatec questions are not recuired.
(3) maintaining the qualified staff necessary to accomolish the above objectives,
- b. Conclusion Category 3
- c. Board Comments Li:ensee performance, which was not rated curing tne previous SALP period, was rated Category 3 during tnis period. Licensee management attention shoulc be increased to corr,ect weaknesses.
- 9. Quality Assurance Program
- a. Analysis One corporate QA inspection and two site QA inspections were performed by regional based inspectors during the assessment perica. In accition, routine inspections were performec Oy tne resident inspector. The QA program, design control, procurement activities, anc audits were the functional areas inspectec a :ne corporate office. Site procurement, receiving, storage, and maintenance; imolementation of 10 CFR Part 21; QA inspection of structural concrete anc soils cackfill activities; and, onsite design activities were the functional areas inspected at the site.
Four violations and one deviation listed in other parts of this
-eport we-e ' der. i#iec in the Overall im;iementati:n of the QA program. These problems involved equipment that was not stored to prevent its damage by the environment, was not protected from acja:ent wor ( activities, or was not properly maintainec. The violations applied to ASME Section III valves, fuel handling building cranes, permanent piant fire protection equipment, and electrical penetrations. These storage and maintenance violations demonstrate the need for improved licensee management and craft attention in tnis area. These problems are not considered a breakdown in the licensee's QA program.
CP&L audits its architect-engineer (Ebasco) and nuclear steam system supplier (Westinghouse) with particular attention paid to design functions (i.e. , oriented more towards technical engineering review and assessment versus the usual program compliance verification). Additionally, CP&L audits vendor-to-vendor interface actions. Although the audit frecuency for A/Es
r A
- 62 anc T. ajo- sa;;Iders i s "e;ui e: oni) once eve *y treee yea *s : &. ,
accitec in's f an:tions treee times per year tc ensure meeting al'
-apolicaole recuirements of Acconcix 5. This resulted in greater :
ceptn anc overai' : overage in trei- cesign aucits. Tne aucits ,
were generally c =plete anc :norougn. Records were generally [
complete, well maintained and retrievable. The corrective action [
systems generally. recognize and adoross nonreportaole concerns. .
Procurement activities are generally well controlled and docu-mented. As identified by violation (1) below, the corporate Performance Evaluation Unit (PEU) missed certain annually recuired construction site act'vity audits during calendar year 1981. Although not audited oy coroorate PEU. these activities were covered through surveillance and monitoring by the site QA/QC unit.
CP&L management nas gradually increased tne numoer of site cesign personnel, upgracing tneir engineering expertise and cesign respcnsibility with the intent that the onsite cesign group will eventually handle all plant design, thereby providing a Knowledge-
- able site engineering base that will be present during the operational phase. Increased licensee involvement in design activities should orove ceneficial tc the utili ty. The li:ensee and A/E resolutien of tecnnical safety issues was viable, generally conservative anc thorougn in approacn. and generally provided timely resolution.
The licensee's responsiveness to bulletins, circulars, and notices was :ensiderec acce: table anc generally sound. Tne inspectors reviewed the CP&L program, Drocedures, anc applicable correspon-dence for IE Bulletins, Information Notices and IE Circulars.
CP&L continually assessed their internal audit and independently authori:ed nuclear insoector orogram findings. Monthly or0 ject review meetings were conducted with senior management to review n:t :nly ; annin; s:hedules b.: anginee-i ; an CA attars Of concern pertinent to the Harris plant. Senior Management Reviews were concucted on a six-month frequency along with specia! meetings for specific items of concern at n; estacifsnec frequency to discuss status and implementation of the QA program.
CP&L reorganized the QA program by creating a new Corporate QA Department which reports directly to the Executive Vice President for Power Supply ano Engineering anc Construction. This reorgani- '.
zation consolidated into one department the QA functions from Tecnnical-Services, Nuclear Safety anc Research, and-tne Nuclear Operations departments. Currently included in the Corporate QA Department are Engineering and Construction QA/QC, Operations QA/QC, the Performance Evaluation Unit, and the Training and Procedures Unit. The above consolication should imorove QA E effectiveness in that all OA units are now in tne same organ-ization and receive uniform OA training, direction, guidance, and procedures.
4 63 Staf#ing o# OA Osit ons ao: eared te ce acecuate.
i Key pos'ti0ns we*e icentifiec anc authorities anc *esconsioilities were cefir.ec.
Management inceoencence nas been retainec and strengtnenec by tne cecision to civice the site CA/0C group into two se:arate entities. Both of tnese groucs now recort to tne site QA/QC director. Both corporate and site OA staffing have increased witn '
expanded work load. The corporate OA auditors were qualified to the licensee's procedures and ANSI N45.2.23 requirements.
Two violations were identified during this evaluation period.
The licensee has been promet in responding to NRC violations and their corrective actions have been acceptable to Region II.
The violations icentified were:
(1) Severity Level IV violation for failure of the corporate OA staff to aucit certain structurai activities curing calendar year 1981.
(2) Severity Level IV violation for failure to analy:e cut recar for acceptability,
- b. Conclusions Category 2
- c. Board Comments No decrease in licensee or NRC attention in :nis area is ,
recommenced.
S. Supporting Data
- 1. Recorts Data
- a. Construction Deficiency Reports (CCRs)
Twenty-four CDRs were reviewed for this assessment period. The cistricution of tnese reports into cause relatec categories is as follows:
CATEGORY NUMBER Welding 12 Mechanical 4 Diesei Generator 3 Electrical 2 OA 1 Design 1 Misc. 1
n-64
- b. Part 2: Reperts inree recor:s nave been fssaec.
- 2. Investigation anc Allegation Review No major investigation or allegation activities were performec during the review period.
- 3. Enforcement Actions
'a. Violations Severity Level I, II anc III: 0 Severity Level IV: 9 Severity Level V: 9
- Severity Level VI: 1 Deviations: l'
- b. Civil Penalties Nene,
- c. Orders No orders relating to enforcement actions were issuec.
- d. Acministrative Actions q Confirmat1ctr of Action Letters (CALs)
No CALs were issued.during the review period.
4 Management Conferences' A conference was held on May 28. 1982, to discuss the previous SALP findings and is documented in Region II report 400/401/S2-14
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