ML20128P592

Discusses SALP Rept Sent on 910415,meeting on 910423 Discussing Rept & Written Comments & Forwards Summary of Meeting,Slides & Final SALP Rept for 891101-920202

ML20128P592
Person / Time
Site:	Catawba
Issue date:	05/31/1991
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tuckman M DUKE POWER CO.
References
NUDOCS 9610180013
Download: ML20128P592 (29)

Text

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UNITED STATES o

NUCLEAR REGULATORY COMMIS810N I

g REGION li y,

j 101 MARIETTA STREET,N.W.

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ATLANTA, GEORGI A 30323 gay 311991 Docket Nos. 50-413, 50-414 License Nos. NPF-35, NPF-52 Duke Power Company ATTN: Mr. M. S. Tuckman, Vice President l

Nuclear Operations P. O. Box 1007 Charlotte, NC 28201-1007 l

l Gentlemen:

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC INSPECTION REPORT NOS. 50-413/91-05 AND 50-414/91-05 i

This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) report for your Catawba facility which was sent to you on April 15, 1991; our meeting of April 23, 1991, at which we discussed the report; and your written coments dated May 21, 1991.

I have enclosed a summary of our presentation at the meeting, a copy of your written coments, a copy of the SALP slides which were used at the presentation, and the Final SALP report for the period l

November 1, 1989 to February 2, 1991.

l We appreciate your efforts in evaluating the Initial SALP Report and providing comments. The following is our evaluation of your comments:

1 Safety Assessment / Quality Verification Your response states that you were generally in agreement with the NRC's l

Initial SALP Report of Catawba's peiformance except in the area of Safety Assessment / Quality Verification (SA/QV).

However, you expressed concern ir, the SALP presentation ami in your response that the "2" rating in the SA/QV area should have been a "2 improving".

We have reviewed the points addressed in your response and recognized that improvements were made in the area of security as well as in the l

Engineering and Technical Support area.

However, the evaluation of the operations area indicated a decrease in the performance from "2 improving" to a "2" category and the other areas remained at their previous level of performance.

A key element in our assessment of the SA/QV effectiveness, is the degree to which the licensee identifies and corrects substandard or anomalous performance, identifies precursors to potential problems and i

monitors the overall performance of the plant.

It was not apparent to the Board that overall licensee management of the Catawba Nuclear Station has fully developed the ability to identify and take effective corrective i

action for all problems, such that a change from a "2" to a "2 improving" was warranted for this assessment period.

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i Our conclusions do not in any way detract from our recognition of the improvements made by Duke management. in specific areas as noted in the y

Initial SALP Report and as discussed in your response.

l 9610100013 910531 i

PDR ADOCK 05000413 i

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QW llJoh(,

Duke Power Company 2

MAY 311991 Based on our reevaluation of your overall performance during the SALP period, we conclude that your performance rating in the SA/QV area remains a Category "2."

In accordance with Section 2.790(a), a copy of 'this letter and its enclosures will be placed in the NRC Public Document Room.

No reply to this letter is required; however, should you have any questions concerning these matters, I will be pleased to discuss them with you.

Sincerely.

p Stewart D. Eb r

Regional Admi trator

Enclosures:

1.

Meeting Summary i

2.

Duke Power Comments on SALP 3.

SALP Slides j

4.

Final SALP Report i

cc w/encls:

J. W. Hampton, Station Manager l

Catawba Nuclear Station P. O. Box 256 Clover, SC 29710 A. V. Carr, Esq.

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 J. Michael McGarry, III, Esq.

Bishop, Cook, Purcell and Reynolds 1400 L Street, NW

~ Washington, D. C.

20005 North Carolina MPA-1 Suite 600 P. 0. Box 29513 Raleigh, NC 27626-0513 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 (cc w/encls cont'd - see page 3)

i Duke Power Company 3

MAY 311991 cc w/encls:

(Continued)

Richard P. Wilson, Esq.

Assistant Attorney General S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Michael Hirsch Federal Emergency Management Agency 500 C Street, SW, Room 840 Washington, D. C.

20472 North Carolina Electric Membership Corporation P. O. Box 27306 Raleigh, NC 27611 Karen E. Long Assistant Attorney General N. C. Department of Justice P. O. Box 629 Raleigh, NC 27602 Saluda River Electric Cooperative, Inc.

P. O. Box 929 Laurens, SC 29360 S. S. Kilborn, Area Manager Mid-South Area ESSD Projects Westinghouse Electric Corporation HNC West Tower - Bay 239 P. O. Box'355 Pittsburgh, PA 15230 County Manager of York County York County Courthouse York, SC 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 Robert G. Morgan l

Nuclear Production Department Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 (cc w/encls cont'd - see page 4)

=.

i Duke Power Company 4

MAY 311991 cc w/encls:

(Continued)

R. L. Gill Nuclear Production Department Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 H. B. Tucker Senior Vice President-Nuclear Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 i

j

l 1

i ENCLOSURE 1 MEETING

SUMMARY

A.

A meeting was held on April 23, 1991, at the Catawba station to discuss i

the results of our systematic assessment of licensee performance (SALP) evaluation of your facility for the appraisal period of November 1,1989, through Fobruary 2,1991.

The free exchange of views during the meeting was beneficial.

B.

Licensee Attendees:

4 l

W. H. Owen, Executive Vice President, Engineering and Construction H. B. Tucker, Senior Vice President, Nuclear Production 1

i M. S. Tuckman, Vice President, Nuclear Operations T. C. McMeekin, Vice President Design Engineering J. W. Hampton, Station Manager, Catawba The list of licensee attendees above does not include all the Duke Power Company employees that were present at the SALP presentation.

The attendees also included superintendents, supervisors and other Duke l

employees.

This large turnout was beneficial to the SALP process and is highly recommended for future presentations.

i C.

NRC Attendees:

J. L. Milhoan, Deputy Regional Administrator, Region II (RII)

E. W. Merschoff, Deputy Director, Division of Reactor Projects (DRP), RII A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RII G. A. Belisle, Chief, Section 3A, DRP, RII R. E. Martin, Senior Project Manager, Catawba, Project Directorate 11-3, Nuclear Reactor Regulation W. T. Orders, Senior Resident Inspector, Catawba, DRP, RII a

P. C. Hopkins, Resident Inspector, Catawba, DRP, RII J. Zeiler, Resident Inspector, Catawba, DRP, RII 4

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ENCLOSURE 2

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DUKE 90WER i

i May 21,1991 U. 3. Nuclear Regulatory Commission i

Attamien: Document Contro1 Desk j

Washington, D. C. 20555 j

l subject: Catawba Nuclear Stadon, Urlts 1 and 2 Systematic Assessment Of Licensee Piefwrosnoo l

NRC Ins,9aa Report Nos. SN13/9105, SN14/91-05 l

Gendamen, i

Mr. Stewart D. Ebneter's letter dated Apd115,1991 transmitted the initial SALP report for Catawba Nuclear Station fbe the peded November 1,1989 through Pobruary 2,1991.

The report was discussed with Duks Power representadves during a meeting held on April 23, 1991.

j Genem11y, I am in agreement with the NRC Staff's assessment of Catawba's performance j

over the 15 months which the SALP isport addresses. The plant did have a four month period dudag the initist phase of the evaluation peded in which plant apaadaas did not most Duke Power management expectadcas.

Y=== Ham corrective sedons were taken which improved over:11 plant performance, and I am conddent it win condans to irT.i.vis.

As discussed in the SALP report, the improvesnents laidated by Duke Power were also evident to the SALP board members.

d Dwing the SALP maadas on Apri123,1991, I expressed my concern that the 2' reting in the Safbty Assessment /Qualty Vaification (SA/QV) category did not===a=4 represent the perfbrmance of the plant and the supporting organizadons. It is my beBef that a '2 Improving' more accurately decedbes the company's performance in this area as discussed below.

Maay of the programs implemented by Duke Power in the SA/QV category are ganado witha the Nuclear Production Department. The SA/QV programs are the same for all three Duke Power Nuclear Stations, the Gener 10ff!a Nas acdvides are bandled in a generic manner, and the Safety Review Group acivition at the three stadons are very almDar. 'the McGuire Nuclear Station received a Superior rating in the SA/QV category whieb attests to the quality of these vadous programs.

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U. S. Nuclear Regglatory Commission May 21,1991 Page 2 i

I recognise that Catawba had some performance problems at th period, and that these pmblems may have been avoided if t frorn the event were initiated eartist.

It should not be discounted, however, that the 3

tremendous improvement in station performanos were a dire i

assessment of the station activities. These haprovements was reco i

basal and contributed to the overan *2' rating in Plant Opemt i

Soondty which was previously a '2 Declining ". Ones again, th of a thorough self assessment of the satica activities and the programs designed to improve perfonnanos. It is evident to me that j

the root cause of the stadon's previous poor performan l

close out the booldog of agulatory issues on 3

i Amandmants over 2 years old were withdrawn. Addhmal anal i

resolve the Main Steam IJae Break laside containme runs of the Steam Genarmaar Tube Rapture scenario were c,ommitt closme with the NRC Staff on this issue. Se=a ;===t attention has t=;,m.t. communloations with the Staff.

j Verification rating be novised to reflect a *2 Is.,v i

1 Very tmly ytr.:rs, i

d e

1 MRH/SALP i

l xe: 8. D. Ebnete 4

P=paal Adminstrator, Region H R. B. Martin, ONRR W. T. Orders senior Resident Inspector i

i

3, ENCLOSURE 3 i

i UNITED STATES i

4 NUCLEAR REGULATORY COMMISSION 1

l l

l SYSTEMATIC ASSESSMENT l

OF i

LICENSEE PERFORMANCE i

(SALP) f.

i i

DUKE POWER t

i COMPANY l

SALP CYCLE 9 i

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NOVEMBER 1,1989 THROUGH FEBRUARY 2,1991 I

i CATAWBA 1 & 2 APRIL 23,1991 i

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SALP PROGRAVI OBJEC-IVES 1.

IDENTIFY TRENDS IN LICENSEE PERFORMANCE 2.

PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES 3.

IMPROVE NRC REGULATORY PROGRAM

4 j

i REGION ll ORGANIZATION i

i i

i i

OFFICE OF THE ADMINISTRATOR

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A D MINIST R ATO R S.EBNETER i

DEPUTY J. MILHOAN i

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j TE PROJECTS l

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CHIE F 8, WILSON i

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l DIVISION OF DIVISION OF DIVISION OF RE ACTOR PROJECTS REACTOR SAFETY R ADI ATION SAFETY AND SAFEGUARDS i

DIR.

L.REYES DIR.

A. GIBSON DIR.

J.STOHR DEPUTY E. MER8CHOFF DEPUTY J. JOHNSON B.MALLETTf DEPUTY

t DIVISION OF REACTOR PROJECTS ORGANIZATION 1

DIVISION OF REACTOR PROJECTS DIR.

L.REYES DEPUTY E.MERSCHOFF REACTOR PROJECTS BRANCH NO. 3 CHIEF A.HERDT 7

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PROJECTS SECTION PROJECTS SECTION NO.3A NO. 38 CHIEF A. BEllSLE CHIEF P. SKINNER CATAWBA HATCH MCGUIRE OCONEE

3 4

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j NRR ORGAhlZATIOh OFFICE OF i

NUCLEAR REACTOR j

REGULATION i

DIR. T. MURLEY l

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l ASSOC. DIRECTOR FOR,

\\SSOC. DIRECTOR FOR i

PROJECTS l

i INSPECTION AND J. PARTLOW j

TECHNICAL ASSESSMENT i

I DIVISION OF j

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ENGINEERING TECHNOLOGY

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DtVISION OF l

RE ACTOR PROJECTS 1/11 DIVISION OF OPERATIONAL EVENTS l

S. VARG A, DIR.1/II l

ASSESSMENT G. L AIN AS, ASST. DIR. Il D. M ATTHEWS, DIR.11-3 DIVISION OF j

REACTOR INSPECTION AND SAFEGUARDS R. MARTIN, PROJ. MGR.

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DIVISION OF RADIATION PROTECTION AND MERGENCY PREPAREDNESS i

DIVISION OF DIVISION OF LICENSEE i PERFORMANCE AND l

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_ REACTOR PROJECTS lil/IV/V OUALITY EVALUATION 4

AND SPECIAL PROJECTS i

i

PERFORMANCE ANALYSIS AREAS FOR OPERATING REACTORS J

A.

PLANT OPERATIONS B.

RADIOLOGICAL CONTROLS C.

MAINTENANCE / SURVEILLANCE D.

EMERGENCY PREPAREDNESS E.

SECURITY F.

ENGINEER!NG/TECHNibAL SUPPORT G.

SAFETY ASSESSMENT / QUALITY VERIFICATION

1 AREA PERFORMANCE CATEGORY 1

LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A SUPERIOR LEVEL OF PERFORMANCE.

NRC WILL CONSIDER REDUCED LEVELS OF INSPECTION EFFORT.

l

AREA PERFORMANCE CATEGORY 2 LICENSEE MANAGEMENT ATTENTION TO I

AND INVOLVEMENT IN NUCLEAR SAFETY OR S4FEGUARDS ACTIVITIES RESULTED IN A GOOD LEVEL OF PERFORMANCE.

NRC WILL CONSIDER MAINTAINING i

NORN AL LEVELS OF INSPECTION EFFORT.

i l

l

AREA PERFORMANCE

\\

l CATEGORY 3 i

l LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED j

IN AN ACCEPTABLE LEVEL OF PERFORMANCE; HOWEVER, BECAUSE OF THE NRC'S CONCERN THAT A DECREASE IN PERFORMANCE MAY APPROACH OR REACH AN UNACCEPTABLE LEVEL, NRC WILL CONSIDER INCREASED LEVELS OF INSPECTION EFFORT.

EVALUATION CRITERIA 1.

MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY 2.

APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT 3.

ENFORCEMENT HISTORY 4.

REPORTING, ANALYSIS AND CORRECTIVE ACTION OF REPORTABLE EVENTS 5.

STAFFING (INCLUDING MANAGEMENT) 6.

TRAINING EFFECTIVENESS AND QUALIFICATION l

CATAWBA NOVEMBER 1,1989 - FEBRU ARY 2,1991 (CYCLE 9) l i

i f ';

.._____ ~~ ~ -- -- - --

MAINTENANCE COMP OTHER FAILU RE il

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PERSONNEL TEST /CALIB DESIGN /

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f CONSTR.

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1 14 %

PERSONNEL (35)

TOTAL l

(49)

LERs i

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?UNCTIONAL AREA DISTRIBUTION For Eighteen Region II Sites SALP CYCLES 8 AND 9 Nt mber of Sites OPS RAD M/S EP SEC ENG/TS SA/QV Functional Areas E CATEGORY l E CATEGORY 2 E CATEGORY 3 i

i

.. - -. - -.. ~..

FACILITY PERFORMANCE

SUMMARY

CATAWBA RATING LAST RATING THIS FUNCTIONAL AREA PERIOD PERIOD l

i PLANT OPERATIONS 2(IMPV.)

2 (OPERATIONS & FIRE PROTECTION) i RADIOLOGICAL CONTROLS 2

2 l

MAINTENANCE / SURVEILLANCE 2

2 EMERGENCY PREPAREDNESS 1

1 SECURITY 2(DECLINING) 1 ENGINEERING / TECHNICAL SUPPORT 2

2(IMPV.)

l (ENGINEERING, TRAINING & OUTAGES)

SAFETY ASSESSMENT /

2 2

QUALITY VERIFICATION (QUALITY PROGRAMS & LICENSING) i i

l l

l i

l VIOLATION

SUMMARY

(CYCLE 9) f i

NOVEMBER 1,1989 THROUGH FEBRUARY 2,1994 i

I I

il ill IV V

! CATAWBA 1

0 0

3 17 0

CATAWBA 2 0

0 2

15 0

REGION ll AVE.

0 0

<1 11

<1

! PER OPERATING UNIT FOR ASSESSMENT PERIOD

OPERATIONS OVERALL PERFORMANCE IN THIS AREA WAS GOOD STRENGTHS OPERATOR PROFESSIONALISM MANAGEMENT INVOLVEMENT PLANT PERFORMANCE CORRECTIVE ACTIONS CHALLENGES OPERATOR PEiRFORMANCE INADEQUATE CONFIGURATION CONTROL FAILURE TO FOLLOW PROCEDURES SIGNIFICANT OPERATOR ERRORS

• HOUSEKEEPING

RADIOLOGICAL CONTROL

\\

OVERALL PERFORMANCE REMAINED GOOD.

STRENGTHS MANAGEMENT INVOLVEMENT COLLECTIVE DOSE EXPERIENCED STAFF PERFORMANCE CHALLENGES

~ OPERABILITY OF PROCESS MONITORS POST ACCIDENT LIQUID SAMPLING POST ACCIDENT GAS SAMPLING SG BLOWDOWN TB SUMP EFFLUENT CONTROL

i MAINTENANCE /

SURVEILLANCE i

OVERALL PERFORMANCE REMAINED GOOD STRENGTHS i

PROFESSIONAL STAFF e

i EFFECTIVE PROGRAMS l

PREDICTIVE MAINTENANCE l

ISI/IST i

CALIBRATION l

SURVEILLANCE l

NDT

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AFW PUMP WORKSHOP

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l TRAINING I

CHALLENGES PROCEDURAL ADEQUACY /

i COMPLIANCE i

l MATERIAL CONDITION

EMERGENCY PREPAREDNESS OVERALL PERFORMANCE REMAINED EXCELLENT l

STRENG-HS i

l MANAGEMENT INVOLVEMENT PERFORMANCE i

COMMUNICATIONS UPGRADES TRAINING CF ALLENGE ATTENTION TO DETAIL 4

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f a

I i

SECURITY J

I OVERALL PERFORMANCE IMPROVED TO EXCELLENT i

j STRENGTHS MANAGEMENT INVOLVEMENT HARDWAREIMPROVEMENTS i

NEW EQUIPMENT l

IMPROVED RELIA.BILTY OF EXISTING EQUIPMENT INNOVATION SELF ASSESSMENT FITNESS FOR DUTY PROGRAM CHALLENGE MAINTAINING PERFORMANCE

ENGINEERING /

TECHNICAL SUPPORT OVERALL PERFORMANCE REMAINED GOOD WITH AN IMPROVING TREND NOTED STRENGTHS ENGINEERING PROGRAMS DBD MOV IMPROVED TEST CONTROL TAILGATE DOCUMENTS IMPROVED OPERABILITY DETERMINATIONS IMPROVED COMMUNICATIONS SUPPORT TO SITE TRAINING

ENGINEERING /

TECHNICAL SUPPORT (CON'T) 1 CHALLENGES DESIGN CONTROL 1

STAFF TURNOVER IN PERFORMANCE SECTION IMPLEMENTING IMPROVEMENTS j

i

SAFETY ASSESSMENT /

QUALITY VERIFICATlCtN OVERALL PERFORMANCE REMAINED GOOD STRENGTHS SELF ASSESSMENT APPROACH TO SAFETY ISSUES U-BOLTS CIRCUI BREAKER SCREWS STAFF LICENSING CHALLE \\lGES SIGNIFICANT EVENTS CORRECTIVE ACTIONS

O i

i I

ENCLOSURE 4 FINAL SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION (NRC)

REGION II SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-413/91-05 and 50-414/91-05 DUKE POWER COMPANY CATAWBA UNITS 1, AND 2 NOVEMBER 1, 1989 THROUGH FEBRUARY 2, 1991

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$\\lbh5b May 21,1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washmgton, D. C. 20555

Subject:

Catawba Nuclear Station, Units 1 and 2 j

Systematic Assessment Of Licensee Performance NRC Inspection Repon Nos. 50-413/91-05, 50-414/91-05 i

Gentlemen, Mr. Stewart D. Ebneter's letter dated April 15, 1991 transmitted the initial SALP repon for Catawba Nuclear Station for the period November 1,1989 through February 2,1991.

The report was discussed with Duke Power representatives during a meeting held on April 23,1991.

Generally, I am in agreement with the NRC Staff's assessment of Catawba's performance over the 15 months which the SALP report addresses. The plant did have a four month '

period during the initial phase of the evaluation period in which plant operations did not meet Duke Power management expectations. Immediate corrective actions were taken which improved overall plant performance, and I am confident it will continue to improve.

As discussed in the SALP report, the improvements initiated by Duke Power were also evident to the SALP board members.

During the SALP meeting on April 23,1991, I expressed my concern that the "2" rating in the Safety Assessment / Quality Verification (SA/QV) category did not accurately represent the performance of the plant and the supporting organizations. Itis my belief that a "2 Improving" more accurately describes the company's performance in this area as discussed below.

Many of the programs implemented by Duke Power in the SA/QV category are generic within the Nuclear Production Depanment. 'Ihe SA/QV programs are the same for all three Duke Power Nuclear Stations, the General Office Licensing activities are handled in a generic manner, and the Safety Review Group activities at the three stations are very similar. 'Ihe McGuire Nuclear Station received a Superior rating in the SA/QV category which attests to the quality of these various programs.

Hvi 3 i W ^ L a f p.

~

U. S. Nuclear Regulatory Commission May 21,1991 Page 2 I recognize that Catawba had some performance problems at the beginning of the SALP period, and that these problems may have been avoided if the correcie actions resulting from the events were initiated earlier. It should not be discount t.owever, that the tremendous improvements in station performance were a direct result of a thorough assessment of the station activities. 'Ihese improvements were recognized by the SALP board and contributed to the overall "2" rating in Plant Operations, as well as a "1" in Security which was previously a "2 Declining". Once again, these changes were a result of a thorough self assessment of the station activities and the implementation of numerous prograras designed to improve performance. It is evident to me that the station's self assessment cc auously improved over the SALP period and was effective in identifying the root cause of the station's previcus poor performance.

The Licensing Group's performance has also improved. Many initiatives were taken to close out the backlog of regulatory issues on Catawba's dekM Numerous License Amendments over 2 years old were withdrawn. Additional analyses were performed to resolve the Main Steam Line Break inside containment issue, and additional demonstration runs of the Steam Generator Tube Rupture scenario were committed to in order to reach closure with the NRC Staff on this issue. Management attention has also resulted in improved communications with the Staff.

Based upon the considerations detailed above, I request that the Safety Assurance / Quality Verification rating be revised to reflect a "2 Improving" level of performance.

~

Very truly yours, bk Hal B. Tucker MHH/SALP xc: S. D. Ebneter Regional Adminstrator, Region II R. E. Martin, ONRR W. T. Orden Senior Resident Inspector

_7

p KE2 UNITED STATES o

NUCLEAR REGULATORY COMMISSION j'

REGION il 3

j 101 MARIETTA STREET,N.W.

ATLANTA, GEORGI A 30323

%,N[Nos.50-413,50-414

/

Do g 3 5 1991 License Nos. NPF-35, NPF-52 Duke Power Company ATTN: Mr. M. S. Tuckman, Vice President Nuclear Operations P. O. Box 1007 Charlotte, NC 28201-1007 Gentlemen:

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NOS. 50-413/91-05,50-414/91-05)

The NRC Systematic Assessment of Licensee Performance (SALP) has been completed for your Catawba facility.

The facility was evaluated for the period 4

November 1, 1989 through February 2, 1991.

The results of the evaluation are documented in the enclosed Initial SALP Report. This report will be discussed with you at a public meeting to be held at the Catawoa facility on April 23, 1991, at 9:30 a.m.

The performance of your Catawba facility was evaluated in the functional areas of Plant Operations, Radiological Controls, Maintenance / Surveillance, Emergency Preparedness, Security, Engineering / Technical Support, and Safety Assessment / Quality Verification.

-l Overall, the plant's performance was satisfactory.

However, performance in the operations area during the first half of the assessment period was marginal as evidenced by the number of significant safety events which occurred during 1

this period.

Duke's additional management attention to this area has resulted in a marked improvement during the last half of the assessment period.

Therefore, the evaluation of performance in the operations area over the whole period was considered to be satisfactory.

Continued management attention to this area is recommended with particular emphasis on procedure adequacy and compliance.

Performance in the areas of Radiological Controls, Maintenance / Surveillance, Engineering / Technical Support, and Safety Assessment / Quality Verification remained good.

Performance exhibited in the Emergency Preparedness area continued to be l

superior.

Upgrades were made to communication systems and personnel were well qualified and trained in the emergency response procedures.

Considerable improvements we.re noted in the security area such as enhanced intrusion detection capability and alarm assessment and the high level of performance by security personnel. Security performance is now exec 11ent.

9svil!D"I'l ypp.

PR 151991 Duke Power Company 2

Any coments you have concerning our evaluation of the performance of your Catawba facility should be submitted to this office within 30 days following the date of our meeting.

These coments will be considered in the development of the Final SALP Report.

Your coments and a sumary of our meeting will be issued as an appendix to the Final SALP Report.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely,

/

/

ufw&vl wW Stewart D. Ebneter Regional Administrator

Enclosure:

Initial SALP Report Catawba cc w/ encl:

J. W. Hampton, Station Manager Catawba Nuclear Station P. O. Box 256 Clover, SC 29710 A. V. Carr, Esq.

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 J. Michael McGarry, Ill, Esq.

Bishop, Cook, Purcell and Reynolds 1400 L Street, NW Washington, D. C.

20005 North Carolina MPA-1 Suite 600 P. O. Box 29513 Raleigh, NC' 27626-0513 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 (cc w/enci cont'd - see page 3)

1 Duke Power Company 3

APR 1519M i

cc w/enci:

(Continued)

Richard P. Wilson, Esq.

Assistant Attorney General 6

S. C. Attorney General's Office P. O. Box 11549 Columbia, SC 29211 Michael Hirsch Federal Emergency Management Agency l

500 C Street, SW, Room 840 Washington, D. C.

20472 North Carolina Electric Membership Corporation P. O. Box 27306 Raleigh, NC 27611 Karen E. Long Assistant Attorney General

)

i N. C. Department of Justice P. O. Box 629 Raleigh, NC 27602 Saluda River Electric Cooperative, Inc.

P. O. Box 929 Laurens, SC 29360 l

Mr. S. S. Kilborn, Area Manager l

Mid-South Area ESSD Projects l

Westinghouse Electric Corporation MNC West Tower - Bay 239 P. O. Box 355 l

Pittsburgh, PA 15230 County Manager of York County York County Courthouse York, SC 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 Robert G. Morgan Nuclear Production Department Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 (cc w/enci cont'd - see page 4)

._.. _ _ _.. ~.

... _ _. _ _ _ ~

Duke Power Company 4

APR 151991 cc w/ enc 1:

(Continued)

R. L. Gill Nuclear Production Department 1

Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007

]

H. B. Tucker i

Senior Vice President-Nuclear Duke Power Company P. O. Box 1007 Charlotte, NC 28201-1007 4

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ENCLOSURE INITIAL SALP REPORT U.S.NUCLEARREGULATORYCOMMISSION(NRC)

REGION II SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-413/91-05 and 50-414/91-05 DUKE POWER COMPANY CATAWBA UNITS 1, AND 2 NOVEMBER 1, 1989 THROUGH FEBRUARY 2, 1991 A g i! n nW a v p p.

TABLE OF CONTENTS Page 1.

INTRODUCTION............,..................................

1 II.

SUMMARY

OF RESULTS.........................................

1 i

III. CRITERIA...............................

3 IV. PERFORMANCE ANALYSIS.......................................

3 1

A.

Plant Operations......................................

3 B.

Radiological Controls 5

C.

Maintenance / Surveillance 7

D.

Emergency Preparedness 9

E.

Safeguards............................................

11 F.

Engineering / Technical Support 13 G.

Safety Assessment / Quality Verification................

15 V.-

SUPPORTING DATA AND SUMMARIES..............................

18 i

A.

Licensee Activities...................................

18 B.

Direct Inspection and Review Activities...............

18 C.

Escal ated Enforcement Acti ons.........................

18 D.

Licensee Conferences Held During Appraisal Period.....

19 E.

Confi rmation of Action Letters........................

20 F.

Reactor Trips.........................................

20 G.

Review of licensee Event Reports and 10 CFR 21 Reports.

21 H.

Licensing Activities..................................

22 1.

Enforcement Activity..................................

22 l

I

I.

INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data-on a periodic basis and to evaluate licensee performance on the basis of this information.

The_ program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.

It is intended to be sufficiently diagnostic to provide a rational basis for' allocation of NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of the facility's performance in each functional area.

An NRC SALP Board, composed of the staff members listed below, met on i

March 18, 1991, to review the observations and data on performance, and to assess licensee performance in accordance with the guidance in NRC Manual Chapter NRC-0516. " Systematic Assessment of Licensee Performance".

The guidance and evaluation criteria are summarized in Section III of this report. The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuance.

This report is the NRC's assessment of the licensee's safety performance at the Catawba Units 1 and 2 for the period November 1, 1989 through February 2, 1991.

The SALP Board for Catawaba was composed of:

E. W. Merschoff, Deputy Director, Division of Reactor Projects (DRP),

Region II (RII) (Chairperson)

A. F. Gibson, Director, Division of Reactor Safety (DRS), RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards, (DRSS),RII-A. R. Herdt, Chief, Reactor Projects Branch 3. DRP, RII D. B. Matthews, Director, Project Directorate 11-3, Office of Nuclear Reactor Regulation (NRR)

W. T. Orders, Senior Resident Inspector, Catawba, DRP, RII R. E. Martin, Senior Project Manager, Catawba, Project Directorate 11-3, NRR Attendees at SALP Board Meeting:

G. A. Belisle, Chief, Project Section 3A, DRP, RII P. C.:Hopkins, Resident Inspector, Catawba, DRP, RII W. H. Miller, Jr., Project Engineer, Section 3A, DRP, RII S. Q. Ninh, Project Engineer, Section 3A, DRP, RII G. R. Wiseman, Reactor Engineer, Technical Support Staff, DRP, RII i

II.

SUMMARY

OF RESULTS Catawba Nuclear Station demonstrated overall satisfactory performance during the assessment period, ll l

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2 Operations performance during the assessment period was mixed. Weakn. esses were identified in configuration control, inadequate or improper procedure usage, inadequate post maintenance testing and plant housekeeping.

Professionalism of control room operators continued to be effectively j

demonstrated.

Effective Pre-test meetings between testing personnel and

)

the operations staff were implemented. Actions were a Mo implemented to improve procedure adherence and adequacy. Management il volvement in plant activities has increased and is focused on the correctiri of identified weaknesses.

Performance in the area of Radiological Controls continued to be effective. Radiological effluent releases remained well within the limits of the Technical Specifications (TS). The program of maintaining the total contaminated _ floor space to a small percentage of the Auxiliary.

Building continued to be effective.

Identified program weaknesses were promptly corrected.

Performance in the Maintenance / Surveillance area was good.

However, weaknesses associated with the adequacy of procedures or usage of procedures continued to be a problem. Management attention to these problems was evident and improvements were noted towards the end of the assessment period.

Superior performance continued in the Emergency Preparedness area during the current assessment period. Management support was evident in the timely resolution of findings from audits, emergency exercises.and drills.

In the Security area, considerable improvements were noted in the performance of security personnel and in the effectiveness of implementing the security programs. Management support is evident due to the number of program enhancements in intrusion detection and alarm assessment capability. Superior performance was demonstrated in this area.

Engineering / Technical Support continued to be effective with improvements noted during the period.

Strengths were noted in the HVAC review committee, design bases documentation program, GL 89-10 program, Maintenance Engineering Services activities, refueling startup procedures and use of pre-test " tailgate" meetings. Weaknesses were identified in high turnover of personnel, especially systems engineers, and examples of inadequate design control.

-Safety Assessment / Quality Verification performance continued to demonstrate a thorough and conservative approach in assessing problems and developing conservative resolutions. The licensee is very responsive in responding to information needs involving the status of the facility or

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issues affecting the operability of systems or components.

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Performance ratings assigned for the last rating period and the current period are shown below.

Rating Last Period Rating This Period Functional Area 8/1/88 - 10/31/89 11/1/89 - 2/2/91 Plant Operations 2 Improving 2

Radiological Controls 2

2 Maintenance / Surveillance 2

2 1

Emergency Preparedness 1

1 Security 2 Declining 1

Engineering / Technical 2

2 Improving l

Support Safety Assessment /

2 2

Quality Verification III. CRITERIA l

i The evaluation criteria which were used to assess each functional are: are described in detail in NRC Manual Chapter NRC-0516. This chapter is in the l

Public Document Room files. Therefore, these criteria are not repeated here, but will be discussed at the public meeting held with licensee management on April 23, 1991.

l IV.

Performance Analysis A.

Plant Operations 1.

Analysis l

This functional area addresses the control and performance of activities directly related to operating the facility (including fire protection).

The operations group was staffed with five 12-hour shifts. Each shift exceeded TS marining requirements and trained and operated together as a team. A shift manager coordinated shift support functions and performed the collateral duty of the shift technical advisor (STA).

1 l

Control room operator professionalism was well established and evident. Access to the at-the-control area was monitored and controlled.

Pre-shift briefings were conducted effectively using shift turnover forms.

Operators' and shift supervisors' logs were legible and complete, depicting normal conditions, l

off-normal conditions, specials tests and events. Shift assignments were clearly posted in the control room.

Keys for access to locked equipment cabinets and spaces were well controlled.

Although significant lapses in operator performance

4 occurred during this assessment period, typically operator responses during alarms, off-normal conditions, and plant evolutions were prompt and thorough. The licensee has established and was implementing the blackboard concept for alarm annunciators. The number of lit annunciators when operating at power is typically less than ten.

l Plant housekeeping was adequate, although there were instances where debris was left in out-of-the-way places. Management attention has been increased in this area. Housekeeping in the control room remained excellent.

There does, however, continue to be a chronic inventory of leaks from radioactive and j

non-radioactive systems.

l Regular plant tours were conducted by corporate and site management with feedback routinely provided to the plant staff.

Trend reports along with performance indicators were published l

to keep plant personnel and corporate management apprised of l'

probable or potential problems and plant status.

l Several significant events occurred dwing this assessment period which were discussed at a meeting with the licensee in l

June 1990. These events included an over-pressurization of the residual heat removal system, operation in a prohibited mode l

with steam generator block valves isolated, operation in a prohibited mode with inoperable nuclear service water system l

valves to the containment valve injection water system surge l

chamber, an unexpected reactor coola;;t system cooldown and ESF actuation and the inoperability of the containment air return fan for an undetermined period.

In a meeting with the staff on October 25, 1990, the licensee reviewed the status of its Integrated Safety Assessment Group's L

activities as well as other initiatives and programs targeted at improving operational performance. -Since this meeting, overall performance has shown improvement; however, procedural adherence continues to be a prcblem.

The licensee instituted action to improve procedure l'

adherence / adequacy.

Included in this program is an extensive program of procedure upgrade, procedure adherence training, and establishing additional dedicated procedure writing groups.

Management has emphasized that quality is of first and foremost importance in measuring performance at C Mawba. Meetings have been held between site managers and ser.ior management to solidify this message. Additional trt.ining programs have been j

implemented to improve supervisory aad communication skills of supervisory personnel. The operations supervisors will complete l

this training by August 1991.

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The licensee's new program of pre-test " tailgate" meetings that are held between plant testing personnel and the operations staff have been effective.

The " tailgate packages" prepared by testing personnel for such meetings are detailed, and provide the operations group with a clear understanding of test effects l

on plant systems and components.

Improved performance of the l

engineered safety features actuation test was evidence of how effective such tailgate meetings can be.

Control of flammable and combustible materials in safety related equipment areas within the plant was adequate.

Fire Brigade Captains are assigned on each shift to implement the Station i

fire protection program. The frequency of unannounced fire I

drills and the satisfactory performance of the Fire Brigade as l

witnessed by the NRC staff demonstrated that the program was adequate.

Sixteen violations were cited.

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2.

Performance Rating 1

Category:

2 ph l

3.

Recommendations LU 1

The board is concerned with the number of significant events l

that have occurred gring dutdown plant operationT]during the l

first half of this period.

While marked improvements have been noted during the last half of the assessment period, continued l

management attention to this area by Duke and enhanced j

inspection by the NRC is recommended.

B.

Radiological Controls l

1.

Analysis This functional area addresses those activities directly related to radiological controls and primary / secondary chemistry control.

Management oversite and support continued to be effective during the period as evidenced by internal audits conducted by the i

licensee's Nuclear Safety Review Board (NRSB) and the fact that radiological effluent releases were well within the limits of the Technical Specifications (TSs). The radiological controls were adequately integrated into the maintenance process, and the health physics (HP) group gave satisfactory support to maintenance activities. Additionally, informal communications between HP and maintenance and the planning groups effectively aided the maintenance process.

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i The licensee's radiation protection and radiological effluent staff was experienced and well qualified.

Staffing levels were acceptable, remained stable, and an ample supply of radiation protection contractor personnel was available to support the i

refueling outages.

Radiation protection reviews and coverage of operations were adequate during the assessment period. Training for the staff was well defined and adequately implemented for routine and outage radiation control, waste processing, and transportation activities.

The licensee successfully continued efforts to maintain the contaminated floor space in the Auxiliary Building as low as reasonably achievable. At the end of 1990, the contaminated area of the plant was approximately 6,000 square feet or four percent of the radiologically controlled areas of the plant.

This was approximately the same area as the previous year, and is substantially reduced since 1988 when the contaminated floor space was approximately 16,000 square feet. Maintaining contaminated floor space to this reduced level was-largely due to the utilization of a dedicated decontamination crew.

The licensee identified examples of unsecured high radiation areas. Weaknesses in door securing procedures were noted, however, there were no unexpected personnel doses. These weaknesses were quickly addressed by-the licensee's radiation protection staff.

Operability / reliability remained a problem for the post accident 4

liquid sampling system and post accident gas sampling system as well as for some other process / effluent monitors, i.e., steam generator blowdown and turbine building sump. TS requirements were being satisfied via grab samples.

Steps were being taken to remedy these problems through system modification and training.

Management oversite, support and involvement in matters related to radiation protection improved during the assessment period, During this assessment period, the licensee experienced two refueling outages with a substantial workload, including resistance temperature detector (RTD) bypass manifold removal in 4

Unit 1.

Consequently, the stations' 1990 collective dose increased substantially since the previous year.

The licensee did not meet their original Unit 1 outage collective dose estimate (310 person-rem) due to:

(1) the dose rates encountered were higher then expected due to inadequate reactor water cleanup / filtration cycle following the crud

' release; (2) the labor rate estimates were exceeded due to an 1

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increase in the work scope and low initial estimates; (3) an increase in outage duration from 65 to 88 days. After learning from the experiences of the Unit 1 outage, management l

established a new collective dose goal for the Unit 2 outage (268 person-rem). The outage was completed with a collective dose of 243 person rem. The improved performance of Unit 2 was due to:

(1) improved reactor water cleanup and filtration cycle following the crud burst; (2) improved flushing of hot spots, (3)adedicatedshieldingcrew;and(4)moreeffectiveALARA planning.

The chemistry control program was generally effectively implemented.

However, controls in the areas of liquid and l

gaseous effluents were weak which contributed to causing seven i

unplanned releases during the period. The staff performed dose

-assessmentr4nd-impact analyses, took appropriate corrective action, and, in at least one case, requested and received support for a special study from_the corporate staff.

Decreases in liquid effluents were noted for fission and activation products. This improvement was attributed to improved liquid

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waste steam treatment from a newly commissioned liquid radwaste l

facility, as well as good fuel integrity.

One violation was identified.

2.

Performance Rating Category:

2 3.

Recommendations None.

C.

Maintenance / Surveillance l

1.

Analysis l

This functional area addresses those activities directly related to the maintenance activities and the associated maintenance program, including implementation of plant modifications and surveillances of equipment.

Strengths were noted in the areas of maintenance staffing, i

training, and qualification. The licensee has organized many of

.the mechanical maintenance crews by component type in order to promote an increased sense of component ownership and an increased opportunity for innovative techniques and tool development. A strong training program was implemented and the turnover rate in the maintenance department was low.

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l Strengths were noted in the licensee's proactive response to problems with the auxiliary feedwater turbine driven pumps.

In.

response to several failures with the' auxiliary feedwater pumps, 4

the licensee sponsored a two day workshop in May 1990, to share operating experience and discuss common problems associated with 4

these turbine driven pumps with other utilities. The j

effectiveness of the workshop was. evidenced by the identifi-cation and detailed discussion of several common problems and the wide contact base generated. The calibrations and standards laboratory was identified as a strength. The laboratory is operated in conformance to a comprehensive program and has excellent facilities and a dedicated and qualified staff.

Scheduling of periodic surveillance activities was implemented effectively with good use of plant computers to track and plan testing. Surveillances were integrated with planned maintenance 4

items to optimize overall system availability and to ensure the i

removal from service of only one train at a time. Daily planning activities were observed to be efficient including planner worksite observation and meetings to prioritize the work list.

During the assessment period weaknesses continued to be noted in the areas of procedural adequacy and compliance. Examples of procedural problems included inappropriate throttling of a refrigerant isolation valve on the train A control room ventilation system, improper actuator installation for the hot gas bypass valve.on train A control room chilled water system, and. incorrect installation of pilot solenoid valves on the high pressure C0 fire protection system for the Unit 2 auxiliary feedwater system pump pits.

Other identified weaknesses included housekeeping problems associated with bedding materials in cable tray areas and inadequate post maintenance testing of a pressurizer PORV.

An integrated scheduling group administers a post maintenance testing program for all work activities which has resulted in an improvement in the scheduling of post maintenance testing activities.

The licensee has initiated a procedure upgrade program designed to enhance the technical quality and useability of maintenance procedures. However, implementation has been slow. Management has recognized the need to accelerate this effort and is currently re-allocating resources toward completing this

program, i

0 9

The Inservice Inspection (ISI) and Inservice Test (IST) programs were observed to be effective.

Personnel were knowledgeable, well trained, and qualified to perform activities within their respective areas of certification.

The licensee's program for establishing and maintaining containment integrity and performing local leak rates was an identified strength. The program included technically correct and comprehensive programmatic controls and local leak rate test engineers who demonstrated a good knowledge of test requirements, procedures and industry practices. The program exceeded normal requirements in the areas of strict controls governing containment venting and draining as well as inclusion of containment isolation valves in the automated valve failure trending program. The licensee's program for ISI on steam generators is particularly comprehensive in that nondestructive eddy current examinations are completed for both the hot and cold leg side of the steam generator tubes.

Seven violations were cited.

2.

Performance Rating Category:

2 3.

Recommendations i

None.

i D.

Emergency Preparedness 1.

Analysis This functional area includes evaluation of activities related to the implementation of the Emergency Plan and procedures, support and training of onsite and offsite emergency response organizations, licensee performance during emergency exercises and actual events.

Management's support to and involvement in the emergency preparedness program was evident. Management was involved in timely followup action on findings from audits, drills, and exercises via a station-wide, computer based system that tracked corrective actions to completion.

The licensee demonstrated the ability to staff the emergency organization with well qualified and appropriately trained personnel during the annual exercise. They also demonstrated the availability of off-shift personnel to staff the TSC and OSC by conducting an unannounced augmentation drill at 6:07 a.m. on a Saturday morning. Licensee personnel reported to the station and met the augmentation criteria specified in the Emergency

l 10 Plan. Emergency preparedness coordination and support was demonstrated in part by a challenging exercise scenario with no significant technical problems. The licensee also demonstrated an effective evaluation and critique process for the annual exercise in the identification of two deficiencies.

The effectiveness of the emergency preparedness staff, both at the site and corporate levels, was reflected in the fact that there l

were no negative NRC emergency preparedness findings during the l

assessment period, l

l The licensee's performance during the exercise demonstrated the ability to identify emergency situations and properly classify l

the emergencies.

The licensee's exercise performance also indicated the ability to mitigate the plant casual.ty and provide l

for the radiological safety of both onsite personnel as well as personnel in the 10 mile emergency planning zone. With the exception of a delayed notification during the exercise, the licensee demonstrated the ability to communicate effectively to State and local authorities. There were two offsite deficiencies identified by FEMA during the exercise. The licensee devoted considerable management attention and resources to these issues, working to assist offsite authorities in resolving the deficiencies.

Progress was being made by the off site agencies in resolving these deficiencies at the end of the assessment period.

During this assessment period, inspection activities indicated that the licensee maintained its emergency response facilities, communications equipment and system monitoring equipment in an appropriate state of readiness and, in fact, upgraded the capabilities for communications. These upgrades include a siren upgrade modification, additional commercial lines to the TSC and additional telephones in the OSC.

Exercise observations reflected effective training of offsite authorities with respect to emergency communications and overall coordination with the plant.

The licensee submitted four revisions to the Catawba Emergency Plan during this assessment period. The changes were primarily administrative in nature with the exception of the incorporation of improved communications and a more conservative protective action recommendation following a General Emergency classification.

The changes were submitted in a timely manner and found to be acceptable by the NRC.

Violations or exercise weaknesses were not identified.

l 2.

Performance Rating l

l Category:

1

l 11 3.

Recommendations None.

E.

Security 1.

Analysis This functional area includes all activitics that ensure the security of the plant, such as access control, security checks, safeguards, and fitness-for-duty activities and controls.

Senior management support for the security program was evident by the level of personnel and equipment resources provided to achieve an impressive improvement in the performance of the security program.

The security program concerns identified in the previous SALP assessment included:

improper access authorization, security badge availability af ter employment termination, security force training and qualification events, and Regulatory Effectiveness Review concerns.

Each of these areas has been effectively.

addressed during this assessment period.

Inspection of the security and safeguards program during this assessment period revealed considerable improvement in the performance of security personnel and effectiveness in implementation of the security program. Licensee initiatives during this period included enhanced intrusion detection capability and alarm assessment, as well as access control into and within the protected area.

These enhancements were accomplished by the installation of additional Closed Circuit Television Cameras (CCTV), microwave intrusion detection equipment and associated monitors and equipment, repositioning and modification of existing equipment and-barriers, and the procurement and utilization of new x-ray equipment. The effectiveness of the licensee's efforts to. improve the security program were clearly demonstrated by the reduction in the number of reportable and loggable safeguards events during the current i

SALP Assessment period as compared to the previous period. The licensee's Tracking and Trending Analysis of human error access control events was effective in reducing events such as the following by fifty percent or more:

misplaced or lost security badges; visitor and escort requirements; tailgating; personnel entry to the protected area without a security badge; and availability of security badges after employment termination.

12 Improvement was also made in the operability and effectiveness of security equipment, specifically in the areas of microwave intrusion detection _ equipment, vital area portal alarm failures, protected area lighting and CCTV.

Improvement in equipment reliability was the result of enhanced maintenance support.

Through management involvement and self assessment, the licensee identified and implemented several innovative actions and program improvements. These. included: utilization 'of security badge neck straps to prevent loss of badges, a security awareness program to improve employee security consciousness, and security management reviews of visitor and escort requirements with all assigned escorts.

1 The ' licensee continues to conduct frequent audits of the-security program and aggressively monitors effectiveness.of security through routine surveillances and field observations. _

Security management remains an active participant in nuclear -

industry activities regarding matters of generic concern.

Improvement in the effectiveness of the security training program was demonstrated by the significant reduction in security rr. lated human error events.

Numerous strengths were noted in the medical, employee assistance, tra!ning, and auditing elements of the fitness for duty program. Of particular significance was corporate support.

1 as evidenced by a Corporate Fitness For Duty Manager and a site coordinator dedicated to program implementation.

The licensee had established,' maintained and followed approved written Material Control and Accountability procedures. These i

procedures were for controlling and accounting of.new fuel, fuel fission chambers; and calibration sources receiving, storing, shipment, inventory, burn up calculations, record keeping and reporting. The licensee was found to be following all applicable NRC guidelines and maintained an adequate and effective program for controlling and accounting for Special Nuclear Material.

During this assessment period, the licensee submitted three changes to their. security plans.

The changes were reviewed by the Region and found to be consistent with the provisions of 10 CFR 50.54(p).

Programmatic problems were not identified with the licensee's system for developing and processing the plan changes.

Communications with the Regional staff regarding proposed plan changes remains strong, j

,13 Two violations were cited. One of these was a Severity Level III, $50,000 Civil Penalty issued during the assessment period for multiple and recurring violations at all three of the licensee's facilities; however, the violations which caused the Enforcement Action were discussed in the previous SALP.

Two violations were cited.

1 2.

Performance Rating Category:

1 3.

Recommendations None.

F.

Engineering / Technical Support 1.

Analysis l

This functional area addresses those activities associated with the engineering and technical support area including design of plant modifications, engineering and technical support for operations, outages, maintenance, testing and surveillance, outages, procurement and licensed operator training.

Overall engineering and technical support has been effective this assessment period. The Catawba Engineering Division (CED) reached a milestone in its Design Basis Documentation (DBD) program during the period. Seventeen DBDs (5 plant level and 12 system level) have been completed and issued. The DBD program has further clarified the system, structure, and component design bases for completed DBDs as well as enhanced the interface between Design Engineering and Catawba Nuclear Station personnel.

Initial efforts to develop a program in response to Generic Letter (GL) 89-10, Safety-Related Motor-0perated Valve Testing and Surveillance, were comprehensive.

The program is organized at the Corporate level with an MOV Task Force providing a forum of technical information exchange between Design Engineering, Nuclear Maintenance, and each Nuclear Station.

Several deficiencies in the engineering and technical support area were identified during the period. These included:

. inadequate control of design interfaces between Auxiliary Building Ventilation System (VA) and the Radiation Protection clothes dryers, incorrect acceptance criteria for Brown Bovari Type ITE 27H & 27D relays in an ESF calibration procedure, and plant electrical drawings which did not reflect as-built plant 4

conditions.

14 Numerous problems with operability determinations and drawing discrepancies were identified during the last SALP period.

Initiatives in these areas have led to marked improvement during this period as evidenced by a notable decrease in these types of deficiencies.

Formal guidelines were incorporated into the Design Engineering Projects Manual to ensure a uniform approach to performing operability evaluations and conveying these evaluations to the Station in an unambiguous manner.

A number of strengths were identified late in the SALP period during inspections of refueling activities, design changes, modifications and engineering technical support activities.

Significant improvements were noted in the refueling startup procedures.

Each of the startup test procedures are now augmented by a written addendum termed a " tailgate" document, which provides a narrative summary of the test, the impact of the test on TS, notes on configuration control, things to watch out for, test termination criteria, and expected alarms.

Tailgate documents have proven to be of direct benefit in improving comunications between operations and engineering.

The effectiveness of this program was evidenced by the successful and relatively trouble-free completion of the Unit 2 ESF actuation tests.

A strength was also noted in the formation of an HVAC Review Committee, created to resolve problems in the annulus ventilation (VE) system. The program has become the model for completing design basis reviews of ventilation systems.

Programmatic enhancements noted late in the SALP period included improvements in the technical adequacy of modification packages, improved communication and interface between site personnel and design engineering personnel, and enhanced timeliness in providing responses to plant requests for' engineering support.

The organization, staffing level, and experience in the Maintenance Engineering Services (MES) Section was also an identified strength.

I Conversely, there had been a high turnover of personnel in the l

Performance Section during 1990 which resulted in a reduction in the experience level of system engineers. This was identified f

as a weakness.

Technical engineering support for the maintenance organization continued to be effective during the assessment period. The MES continued to provide a vital component of the licensee's program for solving persistent problems and maintaining plant reliability. This group provides support to maintenance in such areas as trending and failure analysis, troubleshooting, j

qualifying parts and assisting in their procurement, and procedure development and periodic review.

t 15 The CED continued to provide offective station support in the area of plant modifications during this SALP period as evidenced by the auxiliary feedwater isolation valve replacement, the auxiliary feedwater pump turbine steam admission valve replacement, and the changes to nuclear service water and auxiliary feedwater system piping to facilitate clam flushing.

Continued management attention to the station modifications process was evidenced by the licensee's response to a weakness identified during the Catawba ND pressurization event.

Inadequate communication between.CED and the Station's Operations Group relative to the impact of modifications on plant operations was identified as a contributor to the event.

Licensee management.has established a required interface meeting between Engineering and Operations at the approximately 80 percent design completion stage to ensure that the impact of modifications on plant operations and procedures are well

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understood, i

The licensed operator training program continued to be effective during this SALP period. During this period, 13 initial i

operator examinations were administered with a 100% pass rate.

Requalification retake examinations were administered to five Senior Reactor Operators, all operators passed. The licensee certified the plant-specific simulator in August 1988,- and has made a significant effort in maintaining the simulator during this assessment period. There is a capable staff of engineers and technicians dedicated to simulator upkeep and no significant performance deficiencies were observed during NRC examinations.

Two violations and one deviation were identified'during the assessment period.

2.

Performance Rating Category:

2 (improving) 1 3.

Board Recommendations None.

i G.

Safety Assessment / Quality Verification 1.

Analysis This functional area addresses those activities associated with the implementation of safety policies; license amendments, exemptions, and relief requests; responses to Generic Letters, Bulletins, and Information Notices; resolution of safety issues (10 CFR 50.59 reviews); safety review committee activities; and, use of feedback from self-assessment programs and activities.

c 16 The licensee's self assessment activities include initiatives by the corporate QA Department,-the onsite QA Section and the Catawba Safety Review Group (CSRG).. An onsite QA group of 7 employees performs surveillance of the routine plant activities-such as plant operations, maintenance activities and technical support..The employees are well qualified. The plant QA surveillances.are performance based with approximately 10% of the surveillances being performed on backshifts and weekends.

Control room activities, shift turnovers and maintenance activities are normally observed.

The response to.the QA J

findings is-thorough and timely.

Additional QA support to the site is provided from the corporate QA organization. This group performs TS required. audits and Self Initiated Technical Audits (SITAs).

The SITAs are j

1 performed at approximately 18 month intervals at each site.

i During this assessment period the bulk of a SITA on the i

Auxiliary Feedwater system was performed.

These audits are detailed,~ thorough and technically oriented.

Site management works closely with the QA organization to resolve audit findings.

The NRC staff considers it a strength that the licensee's management and staff also engages in self assessment activities beyond the scope of the programatic quality assurance 4

activities. These activities assess performance in the functional areas of operations, radiological controls, maintenance, emergency preparedness, security, engineering technical support and safety assurance / quality-verification.

The licensee considers data input to its self assessment from a variety of sources including NRC activities, its own monitoring of the plant and several industry sources.

The licensee directs i

these assessments to focus on areas that include those evaluated previously in this report such as adherence to and the adequacy of procedures, human performance and attention to detail, plant status control as well as extensive sub-areas of the other functional areas discussed above. The staff concludes that these activities have the potential to be very useful in focusing the licensee's attention on areas where improvement is needed and on maintaining performance levels in other areas.

The licensee conducted a self assessment following a meeting in June 1990 to discuss a number of events of concern in the operations area. The licensee did identify lessons laarned from its assessment and initiated corrective actions. The licensee further indicated in a submittal on its corrective action dated August 22, 1990, that it had " embarked on a path to improve nuclear safety and plant reliability through improved human performance". The approach reflected corporate and site involvement and addressed the areas of management actions,

,o 17 communications, configuration control and procedural adherence and adequacy.

The licensee's proposals for amendment of the facility license and Technical Specifications (TS) were generally well prepared, technically accurate and thorough.

The licensee demonstrated initiative on several occasions to approach issues in a manner consistent with previously established regulatory guidance.

Several examples included steam generator tube sleeving, and accumulator pressure and level instrumentation.

The licensee's approach to the resolution of technical issues usually includes strong support for the safety related and design basis aspects of the issue.

An example was the extension of the surveillance interval on the containment ice basket weichts.

Licensee performance in considering the effects of problems on other systems, structures and components appeared strong on several occasions.

Management involvement and concern for the effect of the broken ice condenser ice basket hold down U-bolts, initially discovered in its McGuire station, on operability of the Catawba ice condenser ice baskets is considered a strength.

Subsequently, the licensee continued to demonstrate its concern for the need to ensure the operability of other related structures, systems and components when it shut down Unit 2 and inspected the U-bolts in response to specific findings of degraded U-bolts on Unit 1.

A strength was again demonstrated in the assessment of the circuit breaker contact carrier loose screw problem. All remaining contact carriers in both the Catawba units,nd the licensee's other nuclear power stations were inspected and the problem was reported in accordance with 10 CFR 21.

The licensee's engineering and technical support staff is experienced and is well qualified and knowledgeable of licensing issues.

The licensee's resources, both in level and degree of preparation, are adequate to effectively deal with issues.

The licensee was very effective in responding to information needs involving the status of the facility, the status of particular issues concerning the facility and to issues affecting the operability of facility structures, systems or components.

Two violations and one deviation were cited.

2.

Performance Rating Category:

2

'~

f 18 3.

Recommendations None.

V.

Supporting Data and Summaries A.

L'.censee Activities ~

Unit 1 began and ended the assessment period in an operational mode.

The Unit was shutdown for a 88 day refueling outa9e from January 27 to April 25, 1990. The Unit was also~ shutdown for three short unscheduled maintenance outages lasting from four to 12 days to perform repairs on a Chemical Volume Control Pump, Incore Detector, Ice Condenser Ice Bed Temperature Monitor System, a steam generator blowdown valve, electrical grounds on the Main Turbine and inspection of Ice Condenser U-bolts.

For the assessment period the Unit experienced an overall availability factor of about 74%.

Unit 2 began and ended the assessment period in an operational mode.

The Unit was shutdown for a 110 day refueling outage from June 9 to September 29, 1990 which was approximately a 44 day extension over the originally scheduled outage due to unscheduled maintenance activities and leaking Core Exit Thermocouple Nozzle Assemblies. The Unit also' experienced two unscheduled short outages which required the unit to be shutdown for three and six days tc perform repairs on a steam generator blowdown isolation valve and for inspection of Ice Condenser U-bolts.

For the assessment period the Unit experienced an overall availability factor.of about 73%.

B.

Direct Inspection and Review Activities During the assessment period, 35 routine and 4 special or reactive inspections were performed. The special inspections included:

March 22-26, 1990:

Overpressurization of RHR April 17-28,1990:

Interfacing System LOCA Inspection June 11-15, 1990:

Reg Guide 1.97 Inspection October 31 - November 30 Maintenance Team Inspection 1990 (3 wks)

C.

Escalated Enforcement Actions 1.

Orders None.

2.

Civil Penalties A Severity Level III Violation with a $50,000 CP was issued on December 19, 1989, relating to operability and reliability of the Auxiliary Feedwater System.

19 A Severity Level III Violation with a $50,000 CP was issued on December 21, 1989, for failure to implement provisions of the physical security program at each of the three Duke sites.

A Severity Level III Violation with a $100,000 CP was issued on May 29, 1990, involved RCS pressure transmitter instrument root valve closure which resulted in over pressurization of the Reactor Coolant system.

D.

Licensee Conferences Held During Assessment Period November lu, 1989 NRC/ Duke interface meeting held at Catawba.

November 28, 1989 Catawba self-assessment meeting for previous SALP period held at Catawba.

January 16, 1990 NRC/ Duke interface meeting held at Catawba.

January 31, 1990 Catawba SALP presentation at Catawba.

January 31, 1990 Meeting held at Catawba to discuss Civil

' Penalties on Security and Auxiliary Feedwater System.

February 22, 1990 Enforcement Conference held at NRC Region II to discuss inoperability of Unit 1B Containment Air Return Fan.

April 3, 1990 Meeting held at NRC Region II to discuss the implementation of the Security Program at Duke nuclear sites.

April 25, 1990 Enforcement Conference held at NRC Region II to discuss March 20 over pressurization of Reactor Coolant System, isolation of Steam Generator PORVs and isolation of Nuclear Service Water to Containment Valve Injection Water System Surge Chambers.

June 18, 1990 Meeting held at NRC Headquarters Office to i

discuss operational safety and performance at Catawba.

l July 12, 1990 Enforcement Conference held at NRC Region l

11 to discuss June 11 inadvertent diversion of reactor coolant water to RWST.

July 16, 1990 NRC/ Duke Interface meeting held at Duke's Corporate Office.

l l

i l

20 1

July 19, 1990 Meeting held at FRC Headquarters with NRR to discuss Catawba's Steam Generators.

i September 27, 1990 Meeting held at NRC Region II to discuss Duke's Inservice Inspection Program.

October 25, 1990 Meeting at NRC Headquarters to discuss operational safety and performance at Catawba.

November 5, 1990 i.forcement Conference held at NRC Re91on II Office to discuss the failure to implement the Security Program compensatory

)

measures when the Standby Shutdown Facility is degraded and operator's improperly signing procedures.

December 11, 1990 NRC/ Duke Interfsee meeting at McGuire.

January 16, 1991 Meeting at NRC Headquarters with NRR to discuss required TS revisions due to conversion to B&W fuel assemblies.

January 31, 1991 Duke's self-assessment presentation for current SALP period to NRC staff at a meeting in NRC Region II.

E.

Confirmation of Action Letters l

None.

F.

Reactor Trips and Unplanned Shutdowns Unit 1 experienced four unplanned manual reactor shutdowns and Unit 2 experienced one reactor trip and two unplanned manual reactor shutdowns during this evaluation period. These were as follows:

1.

Unit 1 Reactor Trips:

None.

Unplanned Reactor Shutdowns:

November 23, 1989:

Unit was taken off line to repair Chemical Volume Control Pump 18. The outage was extended to repair an Excore Detector.

Unit was returned on line on December 1, 1989.

l

e'

.r 21 June 8, 1990:

Unit was taken off line to repair Nuclear Service Water Pump 1B. While unit was down.. repairs were also made'to Ice Condenser Ice Bed Temperature Monitor System.

Unit was returned on line on June 20.

October 5, 1990:

Unit was taken off line to repair a steam generator blowdown valve and was returned on line on Oct.ober 9.

January 4,1991: Unit was taken off line to investigate i

electrical ground problems on Main Generator and perform required repairs. While Unit was down Ice Condenser U-bolts were inspected.

Unit returned on line on January 11.

i 2.

Unit 2 Reactor Trips:

October 7, 1990:

Unit tripped after Main Feedwater Pump 2A tripped due to high pump discharge pressure caused by a pressure switch short. Unit was returned on line October 9.

Unplanned Reactor Shutdowns:

January 4, 1990: Unit was taken off line to repair a Stes:1 Generator 2B blowdown inside containment isolation valve. Unit and was returned on line on January 7.

l January 5, 1991:

Unit was taken off line to inspect Ice Condenser U-bolts and was returned on line January 10.

l G.

Review of Licensee Event Reports (LER)

During the assessment period 49 LERs were analyzed.

The distribution of these events by cause as determined by the NRC staff is as follows:

I Cause Totals Unit 1 Common Unit 2 Component Failure 7

4 1

2 Design 3

1 1

1 Construction, Fabrication, 4

2 1

1 or Installation i

Personnel Operating Activity 10 3

2 5

Maintenance Activity 2

0

_1 1

Test / Calibration Activity 18 10 3

5 l

Other 5

3 1

1

-Other 0

0 0-0 T5 hts

-U T

T T

.s JF 22 i

Note 1:

Three voluntary LERs were not counted.

Note 2:

With regard to the area of personnel, the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel error.

Note 3:

The "Other" category is comprised of LERs where there was a spurious signal or a totally unknown cause.

Note 4:

The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignments.

H.

Licensing Activities During the assessment period, 14 TS amendments were approved by the staff.

Sixteen previous TS amendment requests were withdrawn by the licensee. The 11.censte also submitted one waiver of compliance, one relief request, 49 routice miscellaneous reports and responded to 10 Generic Letters and three Bulletins.

I.

Enforcement Actions Functional No. of Deviations and Violations in Area Each Severity Level (Unit 1/ Unit 2/

Common)

DEV.

V IV III II I

Plant Operations 7/7 2/1 Radiological Controls 1/0 Maintenance / Surveillance 4/5 Emergency Preparedness Security 1/1 1/1 Engineering / Technical 0/1 2/1 Support Safety Assessment / Quality 1/0 2/1 Verification Totals 1/1 17/15 3/2 J

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