ML20132E544

Comments on SALP Repts 50-269/84-31,50-270/84-31, 50-287/84-35,50-369/84-36 & 50-370/84-34 Issued on 841231 for May 1983 - Aug 1984,specifically Category 3 Rating in Plant Operations,Licensing & Radiological Control

ML20132E544
Person / Time
Site:	Oconee, Mcguire, McGuire, 05000000
Issue date:	02/07/1985
From:	Tucker H DUKE POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20132E501	List: ML20132E497 ML20132E516 ML20132E544 ML20132E566
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM NUDOCS 8507170735
Download: ML20132E544 (6)

Text

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MAR 2 71985 Duuz Powra GoMPANY P.o. mox 33:ee CBLARLOrrE. N.C. 38348 mALB,7t'CNER mme.

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Dr. J. Nelson Grace. Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Subject:

• Report Nos. 50-269/84-31 50-270/84-31 50-287/84-35 50-369/84-36 50-370/84-34

Dear Dr. Grace:

By letter dated December 31, 1984, NRC transmitted the Systematic Assessment' of Licensee Performance (SALP) report for Oconee and McGuire. The period of assessment was May 1, 1983 through August 31, 198,4. A meeting was held to discuss this report on January 8, 1985.

Attached please find our comments on the evaluation. As requested, specific comments have been made in response to the Category 3 rating in the plant operations functional area at McGuire. Also included are comments on the areas of Oconee Licensing Activities and Radiological Controls.

Duke believes that on the whole, this SALP adequately represents the quality of performance at our stations with the notable exception of the character-ization of McGuire plant operations. As discussed in the attached, we believe that the Category 3 rating of McGuire Plant Operations is not warranted by the facts.

Very truly yours.

.d .4^< gg Bal B. Tucker HBT: sib Attachment 8507170735 85032 DR ADOCK 050 P

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Attachment 1 Duke Power Company Oconee Nuclear Station Response to SALP Report i Dated December 31, 1984 l

l Introduction i Duke Power Company has reviewed the SALP Report for Oconee Nuclear Station end. in general, endorses the observations and findings made in the report regarding Oconee's performance. Overall, the Report accurately and ef fec-tively appraised oconee's performance, except in the areas of Licensing activities and Radiological Control. In these areas. (Licensing activities and Radiological Control). the Report assigned a Category 2 and identified weaknesses. Duke's comments, contained herein, addresses the weaknesses which were identified in the report.

Licensing Activities The Report noted weaknesses in the areas where responses were needed from the Licensee regarding amendments to the Technical Specifications and written responses to requests for additional information; and that licensee management attention should be focused in anticipating problems, the scheduling of major issue submittals, and in the reviewing of submittals for their thoroughness, completeness and timeliness. Examples of this cited in the Report are: III.D.3.4 " Control Room Habitability; Commission audit of all B&k' plants on their status in implementing NUREG-0737 modifications; and Reload Amendments.

Duke has had a history of providing timely and thorough responses to NRC regulatory items. Duke believes that changes in NRC Project Managers as well as in Duke /Oconee licensing personnel may have contributed to cases cited in the SALP Report.

Radiological Controls The Report noted some weakness in Duke's ability to adequately assess non-routine Radiological evolutions at Oconee and in identifying deficiencies and trends as well. The report specifically identified the non-routine

~ radioactive material shipments and potential sources of neutron radiation; as well as the buildup of radioactivity on the turbine building roof and in chemical treatment pond 3 as examples of the noted weakness in Oconee's Radiological Surveillance and control programs.

Duke management recognizes that additional improvements in Oconee compliance with the regulations can be made and agrees that the violations identified during the evaluation period are not indicative of a programmatic breakdown.

To this end. Duke is pursuing a meeting with the NRC in order to gain a better understanding of the inspection and enforcement criteria in the Radiological Control area.

, I Attachment 2 McGuire Nuclear Station Response to SALF Report Dated December 31, 1984

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l Introduction The Plant operations functional area at McGuire was raced Category 3 in the SALP report. It was specifically requested that Duke advise NRC of actions which are planned to be taken in response to this rating.

1 i

Based on the details provided in the SALP report, it appears that this rating is based upon weaknesses identified with procedural compliance, the number of violations, the number of reactor trips, and weaknesses in imple-menting independent verification. Specific examples in these aspects are discussed in the functional areas of plant operations, maintenance, and As these areas are inter-related, the Duke response will surveillance.

r address these areas collectively.

Incidents 4

Virtually all the violations identified in these areas were the result of plant incidents. Each plant incident is reviewed and a root cause determined The program of incident review j

as well as the appropriate corrective action.

is extensive in that completed incident reports and Licensee Event Reports are reviewed by Duke personnel both at the station and by corporate office.

' Monthly summary reports are prepared for management It is the goal review which track the of management to trend of incidents according to root cause.

reduce the number of incidents that occur not Incidents only from a -afety at one plantperspective are reviewed ,

but also from an availability standpoint.

through our operating experience program at the other plants.

Contributing factors to the number of incidents occurring at McGuire include the complexity of the plant design, the significant number of activities required to be conducted under procedure, and the relative inexperienc plant personnel. Duke personnel are encouraged to identify to supervision The openness of communications allows 4

any incidents that may impact safety.

Duke to address problem areas in a professional manner without fear of retribution.

For each incident that has occurred Duke believes that responsive corrective Where Licensee Event Reports were filed, such actier.s measures have been taken.Likewise, corrective actions are centained in our are described therein.

responses to the Notices of Violation. Such actions have included revisinc e

procedures involved to include explicit details to assure proper performance of the procedures and to prevent recurrence of the event.

undergone training to-assure an adequate knowledge level of surveillance a maintenance activities.

Corporate Management has discussed with station person There procedural compliance.and is continually emphasized by Station Management o exists an ongoing program to review and improve procedures associated with tne 7300 Frocess Control System.

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• Additionally, Duke continues to suppo,rt 3:neric cf forts d: signed to rolaa requirements that "over test" the plant systema. Duke believes that all of these efforts are responsive to the concern related to plant operation. -

Independast Verification The Nyc has also identified independent verification as an area of concern. The lasscus particular subject has been discussed several times in the past.

learned from Oconee incidents have been used to develop generic guidance for Duke believes that the present program is responsive to all Duke stations.

commitments previously made. We acknowledge the coaments made by individus1 reviewers. Movever, we believe that our program is reasonable and effective.

While it is dif ficult to achieve perfection, Duke will continue to strive to implement independent verification effectively.

Reactor Trips A few explanatory comments may be helpful in placing the reactor trip frequency at McGuire in perspective. First, McGuire is a young plant having just Consequently it has completed startup testing for the second unit in 1984.

been going through its " shake-down" period of system tuning and modification.

A higher frequency of unplanned trips during this period is to be expected, followed by decreasing incidence of trips as systems are debugged. We are beginning to see this behavior.

During 1982, 1983 and 1984, there were a total of 65 unplanned automatic and manual reactor trips. (as defined in current LER rule), as detailed in the following table:

Number of Reactor Trips 1982 1983 1984 Total 16 15 5 36 McGuire Unit 1 11* 18 29 McGuire Unit 2 -

16 26 23 65 Total

• McGuire Unit 2 not consnercial for full year Clearly, with suf ficient maturity an improvement in trip frequency is expected and is occurring. Similar behavior is expected on Unit 2. particularly after i

its first refueling outage when a number of important modifications will be l implemented.

During l

A second comment pertains to reactor trips caused by personnel error.

the period from May 1, 1983 to August 31, 1984, approximately 30% of all reactor trips were attributed to personnel error, including procedural complianc; problems. Approximately 60% of the These trips during this period were caused by data indicate that personnel errors equipment failure or malfunction.

are not the leading cause of trips and are comparable to industry averages for the last five years (personnel error - 201, equipment malfunction - 67%; source

' Ih70).

A third comment partairs to tha emphasis picced tpos 1carning from our trip experience. Following every reactor trip at McGuire a thorough reactor trip investigation is performed. This investigation consists of three phases:

post-trip review, incident investigation, and transient assessacnt. The post-trip review seeks to determine the iussediate cause of the trip identify abnores1. performance of personnel and equipment, and assess the impact on safe plant operation. The incident investigation determines the root cause of the avest svaluates the corrective actions taken. and reconnends additional ,

corrective action if needed. The transient assessment ensures that all aspects of the event are fully evaluated and documented, with particular emphasis on the transient response of important plant systema. This review expands upon areas of identified abnormal performance.

in addition to the reactor trip investigation a Management Tollovup of Abnormal Events meeting is held after every reactor trip. At this meeting, the station manager (or his designee) and the station superintendents discuss the event, make sure that the root causes have been identified, and that the right corrective-actions are identified and assigned for follow-up.

As a long-term program, periodic trending of reactor trips is performed. Reactor trip data is included in monthly Management Information System summaries and annual Operating Experience reports. A Reactor Trip Reduction Program has been established at the corporate level to evaluate and implement corrective actions based on trend data and itens of generic applicability.

In sum =ary, although there have been a significant number of reactor trips at McGuire, station and corporate canagement have been involved in extensive efferts to reduce recurrences of reactor trips and to obtain maximum benefit from those that do occur. The effectiveness of these programs can be seen in the sharp reduction in reactor trips at McGuire 1 in 1984.

Quality Assurance The Quality Assurance (QA) Department's program for evaluating the operations area consists of periodic audits by audit teams from the general of fice as well as routine surveillances by site-based QA personnel. This process is effective in identifying weaknesses, and we plan to strengthen this effort by increased staf fing and training in both groups. We agree that there have been some concerns in the past regarding promptness of corrective action; however manage:en:

has taken steps to resolve this issue. Contrary to the findings of the SALP report we find that there has been a positive trend in the responsiveness by line management to Quality Assurance identified items.

Conclusion The NRC has identified 21 violations and 1 deviation in the three functional areas previously identified. Duke notes that the distribution of these was as follows:

. 5 Violations. 1 deviation denied by Duke.

! . 12 identified and reported by Duke via LER's.

l

. 2 identified by Duke and determined not to be reportable.

l . 2 identified by NRC (These were for failure to report events which are more appropriately under Licensing Activities functional area instead of Plant Operations).

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It is clos noted that severcl incid:sts cccurred that vara tormed by the inspector as "non-cited" violations, and that one Plant Operation Violation Severity III was in fact classified Severity Level IV by Inspection Report 50-369/84-10 this being the one associated with the CCP breaker.

Duka believes that the actions taken it response to the violations have been appropriate. Duke management also recognizes that additional improvement in plant operations can be made, and has prograss in place to achieve that end.

Thus, while the record at McGuire is not perfect, it does not appear to Duke that the level of concern which resulted in a Category 3 rating in plant operation is warranted.

As the above indicates. Duke has been very effective in identifying and correcting problems which in itself is an indication of the quality of our plant operations. We feel that our agressive program of self identification, correcting and reporting should be interpreted as a positive indication of quality plant operations.

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