ML20141N831
| ML20141N831 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/12/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20141N828 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 50-395-85-47, GL-83-28, IEB-83-03, IEB-83-3, NUDOCS 8603180181 | |
| Download: ML20141N831 (31) | |
See also: IR 05000395/1985047
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ENCLOSURE
SALP 80ARD' REPORT
U. S. NUCLEAR REGULATORY COMISSION
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SYSTEMATIC' ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT NUMBER
50-395/85-47
SOUTH CAROLINA ELECTRIC AND GAS COMPANY
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V. C. SUMMER
JULY 1. 1984 THROUGH DECEMBER 31, 1985
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.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 based upon this
information. SALP is supplemental to normal regulatory pracesses used to
ensure compliance with NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee'c management to
promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
February 13, 1986, to review the collection of performance observations and
data to assess the licensee performance in accordance with the guidance in
NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II of
this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Summer for the period July 1,1984, through December 31,
198S. <
SALP Board for Summer:
R. D. Walker, Director, Division of Reactor Projects (DRP), RII
(Chairman) <
C. A. Julian, Acting Director Division of Reactor Safety (DRS), RII
J. P. Stohr Director, Division of Radiation Safety and Safeguards (DRSS),
RII
L. S. Rubenstein, Project Director, PWR Project Directorate 2. Division of
Pressurized Water Reactor (PWR) Licensing-A, NRR
J. B. Hopkins, Project Manager Division of PWR Licensinq-A, NRR i
V. W. Panciera, Chief, Reactor Projects Branch 2, DRP, RII
R. L. Prevatte, Senior Resident Inspector, Summer, DRP, RII
Attendees at SALP Board Meeting:
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K.D.Landis, Chief.TechnicalSupportStaff(TSS),DRP,RII ,
H. C. Dance, Chief, Reactor Projects Section (RPS) 28. DRP, RII '
J. J. Blake, Chief Materials and Processes Section DRS, RII
T. E. Conlon, Chief, Plant Systens Section, DRS, RII
F. S. Cantrell, Chief, RPS18, DRP, RII
D. R. McGuire, Chief. Physical Security Section, DRSS, RII
W. E. Cline, Chief, Radiological Effluents and Chemistry Section DRSS, RII
T. Decker, Chief. Emergency Preparedness Section, DRSS, RII
A. H. Johnson, Project Inspector, RPS1B, DRP, RII
G. A. Pick, Reactor Engineer, TSS, DRP, RII
T. C. MacArthur Radiation Specialist, TSS, DRP, RII
J. K. Rausch, Reactor Engineer TSS, DRP, RII
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility has been in a construction, preoperational, or
operating phase during the SALP review period. Each functional area
normally represents areas which are significant to nuclear safety and the
environment and which are normal programmatic areas. Some functional areas
may not be assessed because of little or no licensee activities or lack of
meaningful observations. Spt.:ial areas may be added to highlight signifi-
cant observations.
One or more of the following evaluation criteria was used to assess each
functional area; however, the SALP Board is not limited to these criteria
and others may have been used where appropriate.
A. Management involvement and control in assuring quality
B. Approach to resolution of tect ical issues from a safety standpoint
C. Responsiveness to NRC initiatives
D. Enforcement history
E.
F. Reporting (and analysis
Staffing including of reportable events
management)
G. Training effectiveness and qualification
Based upon the EALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Licensee management
attution and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to operational safety or construction is being
achieved.
Category 2: NRC attention should be maintained at normal level. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably effective
50 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 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 each functional area is a composite
of the attributes tempered with the judgement of NRC management as to the
significance of individual items.
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The SALP Board may also include an appraisal of the performance trend of a
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functional area. This performance trend will 'only be used when both a
definite trend of performance within the evaluation period is discernible
and the Board believes that continuation of the trend may result in a change
of performance level. The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving near the
close of the assessmer.t period.
Declining:- Licensee performance was determined to be declining near the
close of the assessment period.
III. SUMMARY OF RESULTS
Overall Facility Evaluation
The licensee displayed an aggressive, safety conscious attitude toward
correcting problems. The level of performance was satisfactory, although
certain weaknesses were evident in the areas of plant operations and fire
protection. A strength was identified in the areas of emergency
preparedness, security, radiological controls, and maintenance during the
assessment period. It is considered significant that the identified
weakness in the fire protection area was identified during the
mid-correction period and that the licensee subsequently demonstrated a
dynamic management attitude toward nuclear safety by the implementation of
aggressive corrective actions for the identified weakness. In addition to
improvement in those areas with identified weaknesses, it was noted that
the trend of serformance was improving in the areas of alant operations and
outages. - No ' instances of declining trend was identifiec.
Mar. 1, 1983- July 1, 1984-
Functional Area June 30, 1984 Dec. 31, 1985
Plant Operations 2 3
Radiological 1 1
Controls
Maintenance 1 1
Surveillance 2 2
Fire Protection 2 3
Emergency 1 1
Preparedness
Security 1 1
Refueling / Outages Not Rated 2
Training Not Rated 2
Quality Programs and 2 2
Administrative
Controls Affecting
Quality
Licensing Activities 2 2
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
During the evaluation period, routine inspections were performed
by the resident and regional staffs. The licensee's performance
in the areas of housekeeping, control room behavior and discipline
was satisfactory. The plant overall cleanliness was commendable.
Operational staffing of key positions with knowledgeable personnel
was considered adequate.
Personnel errors noted in the previous SALP continued to plague
plant operations. A series of problems, violations, and the
concern that a negative trend might be developing led to a special
inspection in September 1985. . This inspection revealed
degradation of management control in areas that included the lack
of attention to nuclear system operating conditions, outdated and
poorly controlled procedures, inadequate methods of tracking
equipment status involving limiting conditions of operation, and a
generally relaxed attitude toward procedure compliance. Twelve
violations were identified in four separate categories. These are
violations of plant operational limits as noted in (a), (e) (h),
and (k) below,(safety
in (b), (d), f), (j ,)related
and (1)administrative
below, failurerequirements
of operationsas noted
personnel to maintain an awareness of plant status as noted in
(b), (c), (f), (1), (j), and (k) below, inadequate procedures
as noted in (g) below, and failure to follow procedures as noted
in (i) below. Violations (f) and (g) below were issued because of
the February 28, 1985 positive rate reactor trip incident which is
discussed in Section K. An enforcement conference was held in
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Region II on October 8,1985, to discuss the events associated
with violation (a) below. A Civil Penalty was subsequently issued
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- on January 6,1986, and the licensee's response dated February 5,
1986, addressed the issues. Long term programatic changes are
still being reviewed.
To improve plant operations and address the above concerns, the
licensee implemented changes to provide improved control over
plant operations. These included assignment of a Duty Operations
Manager to provide oversight and assistance during plant startup
and shutdown; the addition of a seventh shift supervisor to
provide administrative assistance to the duty shift supervisor; a
- control room enhancement program to provide a more professional
j atmosphere; and a team building program to improve comunications
! and provide for identification and resolution of operations
problems. Many of these changes are recent and insufficient time
j has elapsed to evaluate their overall impact on plant operations.
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Observations of the activities associated with the startuo after
the second refueling outage indicated that management changes and
recently initiated improvements may be accomplishing the desired
results. This startup, low power physics testing and power
ascension was a well planned and deliberate operation with no
significant problems.
The assignment of a licensed Senior Reactor Operator (SRO) with
shift supervisor experience to the planning and scheduling group
and proper utilization of the administrative operations staff,
t' 't is assigned to scheduling, has prevented schedule conflicts
during surveillance testing, maintenance, outages, and plant
operations. The establishment of train related maintenance and
testing weeks, train "A" and "B" on alternating weeks, should lead
to a reduction in maintenance and operations interface problems
and reduce the number of limiting conditions of operation problems
that have occurred in the past.
The licensee provided adequate event reports during the assessment
period. In addition to Licensee Event Reports (LERs), the licensee
submitted special reports describing particular events or main-
tenance activities in detail. The licensee's investigation,
inspection and subsequent repair of Anchor / Darling check valves
Wds timely and effective.
a. Severity Level III violation for system alignment errors that
rendered both RHR trains inoperable and for failure to
recognize the importance of jumpers in the overpower Celta
temperature trip instrumentation circuits. (85-34)
b. Severity Level IV violation for failure to follow locked
valve procedure. (84-23)
c. Severity Level IV violation for failure to identify and take
prompt corrective action for a potential deficiency on a
reactor protection instrumentation channel. (84-29)
d. Severity Level IV violation for failure to implement locked
valve control program. (84-30)
e. Severity Level IV violation for failure to demonstrate
operability of containment isolation valves. (84-37)
f. Severity Level IV violation for failure to follow procedures
while withdrawing control rods and approaching criticality.
(85-12)
9 Severity Level IV violation for failure to establish adequate
procedures for ECC calculations. (85-12)
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h. Severity Level IV violation for failure to implement the
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requirements of Technical Specifications for an inoperable
power range instrument. (85-15)
1. Severity Level IV violation for failure to follow procedures
and use the latest revision to calculate estimated critical
conditions. (85-27)
j. Severity Level IV violation for failure to adequately
evaluate plant conditions prior to performance of a surveil-
lance test resulting in both ECCS trains being inoperable.
(85-28)
k. Severity Level IV violation for an inoperable feedwater
isolation valve during Mode 3 operation. (85-37)
1. Severity Level V violation for failure to properly document
surveillance test activities. (85-04)
2. Conclusion
Rating: 3
i Board Recommendation
Recently implemented changes to provide improved control over
plant operations indicate a strong management response to
weaknesses identified by the number and nature of violations. The
Board recommends a continued high level of Licensee management
attention and increased NRC inspection activity in this area.
B. Radiological Controls
1. Analysis
During the evaluation period, inspections were performed by the
resident and regional staffs. This included confirmatory measure-
ments using the Region 11 mobile laboratory.
The licensee's health physics staffing level was adequate and
compared favorably to other utilities of similar size in that an
adequate number of ANSI qualified licensee and contract health
physics technicians were available to support routine and outage
operations. The radiological effluents control staffing levels
and staff qualifications were acceptable. Key positions in the
radwaste management program and environmental surveillance
programs were filled with qualified staff.
Two strengths of the health physics program were the quality of
the health physics technicians and the experience level of the
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corporate and site health physics staffs. The staff has a low
, turnover rate and an effective training program.
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An individual from the functional area of Radiological Control was
assigned to the Scheduling and Planning Group which resulted in
better controls of the radiologically controlled areas.
Understanding of technical issues and approach to technical
problem solving was generally adequate; however problems were
noted in - the licensee's measurements and measurements control
program. Specifically, the licensee had difficulty in meeting the
lower limits of detection for gas samples. In addition, a
systematically high bias was identified for gamma spectroscopic
analyses of particulate filters. The licensee participated in the
NRC spiked sample analysis program. Licensee analyses were in
agreement for three isotopes but were in disagreement for one.
The licensee was generally responsive at resolving these issues as
evidenced by the corrective measures for the violation and the
agreement to evaluate the high bias found in gamma spectroscopic
analyses. Additionally, prompt action was taken to . correct a
licensee identified deficiency in the computer software for
converting whole body counts to maximum permissible body burden.
The licensee submitted required effluent and environmental reports
during the rating period. Both liquid and gaseous effluents were
within limits for total quantities of radioactive material
released. Licensee estimates of air dose and dose to the maximum
exposed individual was variable between reporting periods but was
within limits as specified in the Technical Specifications. No
trends or biases were evident from reported values.
In July 1984, the licensee discontinued use of the installed
liquit radwaste processing system and began using the services of
a contractor. A review of the effluent release reports from July
1983 to June 1985, indicated a decline in the number of batch
releases, total volumes discharges, and radioactivity concentra-
tion in effluents since the initial operation of the contractors
system.
During the evaluation period, the licensee's radiation work permit
and respiratory protection programs were found to be satisfactory.
Control of contamination and radioactive materials within the
facility was excellent. From January 1985, to January 1986, the
amount of contaminated area decreased from approximately 8000 to
2800 square feet which represents two percent of the radio-
logically controlled area of the plant. In 1985, there was a
48 percent decrease in the number of clothing and skin contamina-
tion incidents when compared to 1984.
During this eighteen month evaluation period, the licensee's
cumulative exposure was 598 man-rem. This compares favorably to
the national average exposure of 815 man-rem observed at similar
PWR facilities. This lower than average collective dose results
from the short operating life of the plant and from the aggressive
exposure control program established and implemented by the
licensee.
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One : inspection related to plant chemistry revealed that the
1_icensee had experienced two significant intrusions of ion-
exchange resins .into the steam generators .due to failure of an
experimental- cleanup loop on the condensate system. These
, intrusions happened when the plant was operating above 50 percent
power where . the. condensate. cleanup system .must be bypassed.
Although chemistry was controlled in an acceptable-manner during
.the latter phases of the first fuel cycle, ' difficulties were
experienced in chemistry control for several weeks during startup
-of the second fuel cycle. The licensee was revising its water
chemistry program to make it consistent with the recommendations
of the Steam Generators Owners Guidelines; however, the licensee's
resources to implement these stringent guidelines were considered
to be marginal. During a later inspection, imediately after this
evaluation period,. improvements were evident in all areas except
chemical expertise and resources.
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During the evaluation period, the licensee disposed of .27,167
cubic feet of solid radioactive waste containing 211 curies. This
is . quite close to the national average of 27,386 ' cubic feet
shipped by other utilities with similar facilities.
Two violations were identified:
a. Severity Level IV violation for failure to follow procedural
requirements for wearing protective clothing. (84-27)
b. Severity Level .Y violation for failure to achieve the
required lower limit of detection for effluent samples.
(85-19)
2. Conclusion
Category: 1
,3. . Board Recommendation
The Board recommends continued Licensee emphasis in the area of
water chemistry. Decreased NRC inspection activity in this area
is recommended with the exception of the-chemistry program.
C. Maintenance.
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1. Analysis
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During the evaluation period, routine inspections were performed
by the resident and regional staffs.
The maintenance organization had a number of accomplishments. A
uniform procedures guideline was developed to provide consistency
in maintenance procedures, including post maintenance and review
of vendor information. The guidelines and implementation program
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were established prior to receipt of the INP0's good practices
guidelines. INP0's review of the licensee's program indicated
that it met or exceeded the good practices guideline. To further
enhance this program the licensee has trained and assigned
procedure writers to cover each maintenance discipline. All
recently developed or revised procedures met the guidelines. A
two year plan was established to update all existing naintenance
procedures to the guidelines.
The licensee electrical maintenance program was well controlled by
specific procedures. The personnel participating in activities
affecting equipment on the 0-list were aware of the quality
assurance (QA) controls. The craft personnel performing
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maintenance and surveillances were knowledgeable of maintenance
procedures and plant equipment. Maintenance Work Order (MW0)
packages had all the required reviews and approvals prior to the
start of the work. The MWO indicates the proper Q-list classifi-
cation, work was completed and inspected as required, and
post-maintenance testing was conducted. The licensee established
a computer program to assemble, store and retrieve MW0s. The
actual records are stored on microfilm and are accessible by
computer.
A special team inspection was performed to assess the licensee's
compliance with Generic Letter 83-28, " Required Actions Based on
i Generic Implications of Salem ATWS Events". _The licensee's
management was adequately involved in assuring quality and was
responsive to NRC initiatives. The licensee's responses were
timely, concise, and adequately resolved technical issues.
Procurement of new equipment, motor operated valve analysis test
system (M0 VATS), infrared analysis, and ferrographic oil analysis
increased the licensees capability to test, and diagnose equipment
condition. The MOVATS equipment identifies changes in signature
trends which in turn provides for early recognition of potential
problems and provides greater accuracy in the setting of torque,
limit switches and valve position indication. The infrared
analysis has improved identification of defects and potential
problems in electrical and electronic equipment. It was instru-
mental in identifying fuse oxidation problems in electrical
circuits not ordinarily detected by resistance measurements. The
ferrographic oil analysis equipment helped determine the cause of
equipment failures i.e., diesel generator "B"'s failure in 1985.
The licensee has additionally developed the capability to perform
onsite dioctylphthalate and methol iodide testing of charcoal
filters in heating, ventilation, and air conditioning systems.
This testing had previously been performed by outside contractors.
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The expansion of naintenance facility . buildings has provided
additional space and equipment for mechanical and instrumentation
work. The addition of a radioactive instrument calibration
facility and upgrading of the radioactive materials machine shop
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has improved the capability to perform work and reduced.the time
for repairs.
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Use of the Nuclear Plant ~ Reliability Data System (NPRDs) has
increased the licensee's awareness of potential.. plant problems.
Upgrades in the Computer Historical and Maintenance Program System
(CHAMPS) and implementation of data verification has improved the
data-base used for. maintenance planning and scheduling. Staffing-
increases added maintenance planners who provided better scheduling
and coordination of the activities of each maintenance discipline.
The above improvements and increased _ maintenance engineering staff
involvement led to an overall improvement in the areas of planning,
scheduling and timely completion of maintenance activities.
The establishment of outage critiques to identify areas requiring
additional attention and tracking was evidence of management
involvement.
Three' violations were identified:
a. Severity Level IV violation for failure to follow procedure
GMP 101.008. (85-13)
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b. Severity Level IV violation for failure to comply with 10 CFR
Part 50, Appendix A, Criterion 1, in the use of an individual
cell charger on a class 1E battery. (85-15)
c. Severity Level V violation for failure to follow procedures.
(85-08)
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2. Conclusion
Category: 1
3. Board Recommendation
The Board notes indications of strong management attention in this
' area. Decreased NRC inspection activity is recommended.
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D. Surveillance
1. Analysis
During. the evaluation period, inspection were performed by the
resident and regional staffs. These included activities related
to inservice inspection and testing, tendons surveillance, con-
tainment integrated leak rate testing (ILRT), outages, and startup
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testing were conducted in addition to the more frequent surveil-
lance activities. Staffing and training was adequate and
surveillances were conducted within the proper time frame.
The surveillance procedures reviewed, tests that were witnessed,
and examinations of test results, revealed that the licensee's
surveillance procedures were technically adequate and satisfac-
torily executed. Improvements in tracking limiting conditions
for operations applicable to surveillance testing have been
implemented.
While performing containment tendon testing during the second
refueling outage, the licensee discovered that some tendons had
relaxed to values less than specified in Technical Specifications.
Analysis performed by a contractor demonstrated adequate struc-
tural integrity. The licensee's procedures and records for
control of the tendon surveillance program were well defined
and explicit.
On August 29, 1985, the licensee identified through a post reactor
trip review and evaluation that jumpers for the overpower delta
temperature trip circuits had been omitted since initial plant
startup in October 1982. This violation is incorporated as
violation (a) in the plant operations section and resulted in a
Civil Penalty being issued on January 6,1986.
Inservice inspection procedures, work, and records performed by
the licensee contractor were found to be satisfactory. Inservice
inspection and inservice testing procedures, work, and records
performed by site personnel were sometimes inadequate as indicated
by violations (a) through (e) below. Also, there was indication
of weakness in the licensee program for training operations
personnel in the performance of inservice inspections.
, A weakness was noted in the licensee's responsivcness to concerns
raised by the NRC. Examples include the licensee's failure to
promptly provide information on unresolved item, " Exercising
Emergency Feedwater Discharge Check Valves to Closed Position",
their failure to provide a final response in accordance to
IEB 83-03, " Check Valve Failure in Raw Cooling Water Systems in
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Diesel Generators", and their failure to correct an NRC identified
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test procedure deficiency which ultimately resulted in
violation (a) below.
Based on the above problems, the licensee management dedication
toward improvement led to increased quality assurance / quality
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- in transferring the Regulatory Support Group, which provides
- administrative and technical oversight over the program, from the
Regulatory Compliance area to Planning and Scheduling. This
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change resulted in better coordination and faster resolution
of problems.
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Extensive effort had been expended by operations and engineering
personnel in developing a computerized Technical Specification
cross reference program. This program when completed and
implemented should reduce administrative burdens on operations and
provide a better tracking method to insure compliance when
conducting surveillances.
Observations of major surveillance tests such as the 18 month
diesel generator test, the engineered safety features response
time testing, and the ILRT indicates that the licensee has a
strong and well managed program. Software improvements in the
CHAMPS system coupled with assembly and incorporation of data from
new maintenance testing equipment such as M0 VATS should lead to
further program improvements.
Five violations were identified:
a. Severity Level IV violation for failing to provide procedural
criteria to examine reactor coolant piping for leakage and
assure proper functioning of check valves. (85 22)
b. Severity Level V violation for failure to test valves to
assure proper functioning of remote valve position
indicators. (84-31)
c. Severity Level V violation for failure to document the name
of individuals recording data. (85-10)
d. Severity Level V violation for failure to implement the
requirements of EMP 115.011 during performance of the monthly
battery inspection. (85-21)
e. Severity Level V violation for failure to follow procedures
for hanger inspection. (85-23)
2. Conclusion
Category: 2
3. Board Recommendation
No change in NRC inspection activity is recommended.
E. Fire Protection
1. Analysis
During the evaluation period, inspections were conducted by the
resident and regional staffs in the area of fire prevention and
protection to assess the status of the licensee's implementation
of the requirements and commitments of 10 CFR 50, Appendix R.
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The licensee attended the Appendix R workshop during the Spring of
1984. As a result of the information gained at the workshop, the
licensee decided to perform a complete review of the fire
protection program. At the time of the June 1985 inspection the
licensee had not completed their entire review.
However, the licensee did not properly implement the requirements
of 10 CFR 50, Appendix R Sections III.G and III.L. The approach
to' resolution of the technical Appendix R issues indicated that an
understanding of these issues was lacking, and the attempts to
~ meet the Appendix R fire protection requirements were lacking
thoroughness. This was demonstrated by the fact that the
licensee's Appendix R analysis did not address the following
requirements:
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Demonstrate that the alternative shutdown capability provided
for the control room, cable spreading room, and relay room
could achieve and maintain cold shutdown conditions within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
- Identify all the equipment, components, and cabling required
to achieve and maintain hot standby and cold shutdown
, conditions.
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The circuit analysis did not follow NRC guidance with respect
to fuse / breaker coordination, common electrical enclosures,
and spurious signals.
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Identify the analysis assumptions associated with the local
control of safe shutdown systems for fires which affect plant
c areas outside the control room complex, nor did the analysis
justify the timeliness associated with these local controls.
The licensee committed to perform an additional analysis
addressing the above discrepancies and submit the results of this
analysis along with the results of their Appendix R reanalysis to
the region and NRR by the end of the second quarter in 1986. In
addition, the licensee on May 29, 1985, identified 11 Appendix R
modifications affecting 23 plant areas to the NRC. On June 21,
1985, the licensee committed to a special two-hour roving fire
watch in the affected plant areas until the required modifications
are fully implemented.
The licensee's routine fire prevention / protection program were
found to be satisfactory except in the areas of fire barrier and
fire door integrity. The plant fire protection extinguishing
systems and detection systems were found to be in service, and the
organization and staffing of.the plant fire brigade met the NRC
guidelines. The fire brigade training and drills for the fire
brigade members met the frequency specified by the procedures and
the NRC guidelines.
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In general,.with the exception of the Appendix R discrepancies,
the site management involvement and control in assuring quality in
the routine plant fire prevention / protection program was adequate
and had resulted in increased staffing _and an upgraded training
program in the fire protection area. Software computer modifica-
tions.were implemented to assist in fire detection and location.
Two violations were identified. Additionally, four potential
violations and one potential deviation against the licensee's
implementation of Appendix R were identified and are currently
under review for escalated enforcement.
a. Severity Level IV violation for failure to prevent . fire
barrier degradation. (84-35)
.b. Severity Level IV violation for failure to establish' required
fire watch for inoperable fire door. (84-37)
2. Conclusion
Category: 3
3. Board Recommendations
The Board noted that-some NRC inspection findings occurred prior
to completion of the licensee's Appendix R reanalysis; however,
the licensee's corrective actions displayed good initiative. The
board recommends continued devotion of Licensee resources necessary
to provide early resolution of remaining issues. Increased NRC
inspection activity is recommended.
1. Analysis.
During the evaluation period, inspections were performed by the
, resident ind regional staffs. Inspections addressed the Early
Warning Siren System (EWSS), implementation of the radiological
emergency olan and procedures, and observation of a full scale
emergency preparedness exercise.
. The annual emergency preparedness exercise disclosed no signifi-
cant adverse finding in the licensee's emergency organization and
staffing. An adequately staffed corporate emergency response and
planning organization ~ routinely provided support to the plant.
Key positions in the corporate and plant emergency response
organizations were filled. Corporate management continued to
- demonstrate a strong commitment to maintenance of an effective
- emergency response program. Corporate management was directly
4
involved in the 1985 annual emergency preparedness exercise and
.
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followup critique. The licensee continues to promptly and
effectively respond to NRC initiatives regarding emergency
preparedness issues.
The licensee continued to demonstrate a strong commitment to
emergency response training. Accordingly, the 1985 annual
emergency preparedness exercise disclosed that personnel assigned
to the emergency response organizations were adequately trained
and demonstrated the required familiarity with the designated
areas of emergency response. Emergency preparedness familiariza-
tion training was conducted in accordince with the emergency
response plan and implementing procedures. As a result, emergency
response personnel were cognizant of their responsibilities and
authorities and demonstrated a full understanding of their
assigned functions during simulated emergency events.
The essential elements of emergency response, demonstrated during
the referenced exercise, were determined to be acceptable.
Observation and critique of the annual emergency preparedness
exercise disclosed that the Emergency Preparedness Plan and
procedures could be effectively implemented by the licensee,
although several minor areas for improvement were observed by the
licensee and NRC. These items were formally documented and the
licensee committed to correction consistent with regulatory -
requirements and guidance.
Siren test procedures and guidelines had been implemented and
assured that operation of the early warning siren system (EWSS)
was consistent with the licensee's prompt notification require-
ments.
During routine operations, however, it was noted that the Shift
Supervisor failed to promptly classify and declare a Notification
of Unusual Event (NOUE), and initiate notification of offsite
organizations and agencies attending loss of both emergency diesel
generators for greater than one hour. Upon recognition of the
arror, required declaration and notifications were made. This
violation was reviewed and closed by the resident staff. The
violation was not indicative of a programmatic breakdown.
Severity Level IV violation for failure to promptly declare
an NOUE and initiate notification of offsite organizations.
(85-21)
2. Conclusion
Category: 1
3. Board Recommendation
Decreased NRC inspection activity is reconnended.
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G. Security and Safeguards
1. Analysis
During the evaluation period, inspections were performed by the
resident and regional staffs. Security force staffing was
adequate and consistent with that of plants of similar size. The
security staff had been satisfactorily trained to perform required
duties. The training program was intensive, innovative, and
produced a security force of high quality. Members of the
security force who were interviewed are highly motivated and very
knowledgeable of their duties and responsibilities. The security
force and plant personnel interacted well as indicated by
observation during personnel processing at shift change and
further evidenced by cooperation given security during non-routine
security situations. Plant personnel displayed good security
awareness as was evident by the low number of security incidents
dealing with lost badges, inadequate escorts, and misuse.of the
access control systems.
Site management demonstrated a supportive role in maintaining the
security program through their knowledge of security requirements
and actions and approval of program improvements.
Design work had been completed and work was in progress for the
installation of a low-frequency grounding network to reduce
disturbances on electronic intrusion monitoring systems. These
modifications should enhance this system's capability to
discriminate between actual intrusions and minor disturbances.
Work was also begun on security computer upgrades to enhance
personnel accountability within the plant site.
Two violations were identified. These violations are not
indicative of a breakdown in the licensee's overall security
program. The licensee provided prompt and effective corrective
ac ion for issues raised.
a. Severity Level IV violation for failure of the access control
officer to remain within a bullet-resistant enclosure.
(85-14)
b. Severity Level V violation for inadequate test procedure of
intrusion detection systems. (85-33)
2. Conclusion
Category: 1
3. Board Recommendation
The Board noted that the spirit and morale of the Security
organization is exemplary. Decreased NRC inspection activity is
recommended,
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,
H. Outages
1. Analysis
,
During the evaluation period, inspections were performed by the
resident and regional staffs. Refueling activities observed from
the control room, refueling floor, and spent fuel pool were found
to be satisfactory.
The licensee commenced the first refueling outage on September 28,
1984. Major activities accomplished during the 83 day outage were
completion of the TP' and Licensing Conditions modifications;
inspection and maintenance of the main turbine, main generator
rotor, and selected vc ves; 100 percent eddy current testing of
steam generator tubes; and three year maintenance on reactor
coolant pumps "A" and "B" seals. The activities associated with
refueling occurred without major problems. Some problems were
incurred during the outage with scheduling and interface
conflicts. As a result, licensee management established an
extensive ' lessons learned" program with an action item list that
required tracking and responses from affected areas.
The plant commenced the second refueling outage on October 5,
1985. This third fuel loading placed the core in an 18 month fuel
cycle. Major work accomplished during this 72 day outage included
changes to the condensate system to provide constant speed pumps
and flow control valves, main turbine five year inspection,
rotopeening and 100 percent inspection of steam generator tubes,
sludge lancing and internal inspection of the steam generator
secondary side, modifications to the isophase bus duct, removal of
the boron injection tank, equipment upgrades for environmental
qualification, and Appendix R modifications.
The licensee has strengthened the planning and scheduling group by
adding SRO, HP, and administrative staff personnel to assist in
scheduling. These changes significantly improved the interface
between operations, maintenance, and health physics.
The second refueling outage demonstrated that management attention
directed toward preventing problems that occurred in the first
outage was successful. This outage showed good preplanning,
coordination and prior training for the activities that were
accomplishec The startup, low power physics testing, and power
ascension after the outage was closely monitored by the staff and
licensee management. The deliberate and methodical startup
without problems was indicative of good management control.
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In August 1984, while performing spent fuel rack drag testing of
the new spent fuel racks, the licensee failed to adequately
calibrate the load cell, to perform the pre-operational crane
inspection, and to have a qualified crane operator during crane
usage. These violations are indicated as (a) and (b) below.
Three violations were identified.
a. Severity Level IV violation for failure to perform adequate
calibration of load cell used for spent fuel rack drag
testing. (84-25)
b. Severity Level IV violation for failure to have a qualified
crane operator during crane use and to perform pre-opera-
tional crane inspections. (84-25)
c. Severity Level V violation for failure to follow procedure
during receipt, inspection, and storage of new fuel assemblies.
(84-29)
2. Conclusion
Category: 2
3. Board Recommendations
The Board noted 'that innovative management is providing an
improving trend in this area. No change in NRC inspection
activity is reccmmended.
1. Quality Programs and Administrative Controls Affecting Quality
i
1. Analysis
During this evaluation period, routine and special inspections
were performed by the resident and regional staffs. The following
areas were reviewed: QA program, QA/QC administration, audits,
procurement, receipt, storage and handling, surveillance testing
and calibration, measuring and test equipment, offsite support
staff, and offsite review committee.
The Qual.ity Assurance Department maintained an adequate QA program
with the exception of one continuing program deficiency identified
in the previous SALP period. This problem was the prompt
resolution of audit findings. The July 1984 inspection indicated
that the QA audit organization was not providing corrective action
due dates, resolution of findings were not well managed by site QA
staff, and escalation procedures were inadequate. These concerns
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were expressed to . licensee man'agement during the inspection 'and-
also during a telephone conversation conducted- on July '16.1984,
'
- with the Vice President - Nuclear Operations (VP-NO). .In response
to these concerns, the .VP-NO stated that a management directive
'(MD-16) would be revised to clarify what measures were'needed to
assure _that conditions adverse to quality were promptly corrected.-
A reinspection in this area identified that MD-16'had been revised
'
but some responses to QA findings were < still being delayed; .
~
however, this delay was administrative ~ (i.e., mail delays).
Continued implementation of MD-16 should prevent ~ future problems
in this area.
All pha'ses of material control met or exceeded regulatory require-
.ments. Licensee response to QA findings in this area was timely
with adequate corrective action.
The ~ surveillance testing and calibration program was well
organized and executed. Personnel were well trained and records
properly maintained. The measuring and test equipment (M&TE)
program exhibited several weaknesses. The. system devised to
control and account for M&TE was weak with respect to equipment.
- status lists, which were often found to be inaccurate. Excessive
time was taken to complete evaluations of out-of-tolerance field
standards and lab personnel were unable to demonstrate the'
completion status of individual evaluations. These problems were ,
the basis for violation b. below.
The offsite support staff was well organized. Communication was
good between the support staff and the site, and the support staff
was cognizant of on-going plant conditions. The ' staff was
professional and well trained. Responsibility and line of-
..
authority were clearly defined in procedures and policy manuals.
The offsite review comittee activities generally met organiza-
tional and administrative requirements. Potential discrepancies
were resolved in a timely manner. The committee had demonstrated
a high degree of resolve to conscientiously review the technical
merit of all review comitments, despite the enormous volume.
This was shown by meeting more often than required and by
delegating review responsibilities.
p' The licensee was developing a QA finding trend program to provide
improved methods for classifying and tracking deficiencies. The
program should provide assistance in identification and control of
recurring items. It should additionally provide better informa-
tion to management for problem identification. It is anticipated
that the program will be fully implemented in early 1986,
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The licensee has procedural controls that require that a safety
review and evaluation be performed prior to procedure approval and
implementation. An example was identified where this process was
not followed and is the basis for violation a. below.
Two violations were identified:
a. Severity Level IV violation for failure to provide documented
safety review and evaluation prior to procedural approval.and
implementation. (84-25)
b. Severity Level IV violation for failure to establish measures
to assure prompt evaluations of out-of-calibration measuring
and test equipment. (85-11)
l
2. Conclusion
Category: 2
3. Board Recommendations
The Board noted good management initiative in this area, however
weakness in the corrective action area should be monitored closely
by the Licensee and NRC to insure'the initiatives are effective in
producing the desired improvements. No change in NRC inspection
activity is recommended.
J. Licensing Activities
! 1. Analysis
The performance evaluation was based on NRC evaluation of the
licensee's performance in support of licensing actions involving a
significant level of activity during the current evaluation
period.
In general, management involvement continued to improve. There
was evidence of prior planning and a:signment of priorities, ,
especially in the area of refueling activities as discussed in ,
Section H. Good management involvement and control was also
evident in the areas of spent fuel pool reracking, response to
Generic Letter 83-28, and the rod control system electrical prob-
r- lems. The area where management involvement and control needs
to be improved was in contractor oversight. Two license amend-
ments were examples of this. Shutdown margin for modes 3, 4, and
5 and thermal design flow reduction were both changed after
submittal to the NRC. This was due to the contractor's analyses
being incorrect and not up-to-date.
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The licensee had a good understanding of the technical and safety
issues, while proposed resolutions were conservative and sound.
Examples of this . technical approach and resolution were the
installation of the P-9 interlock and the power lockout capability i
for the RHR suction line isolation valve. The RHR suction line
isolation valves power lockout capability was an especially
difficult area to resolve due to the conflicting impacts of fire
protection, low' pressure system protection, and low temperature
overpressure protection. Overall, an improvement had been seen in
this area in both quantity and quality of submittals describing
the licensee's~ approach to resolution of technical issues from a
safety standpoint. There were just two instances where the
licensee's approach was lacking. In one instance, full load
rejection capability, the licensee's resolution was very good, but
the initial submittal did not contain a sufficient description of
the resolution. In the other instance, RCS flow measurement
uncertainty change, the submittal had to be withdrawn because the
analysis was based on a 4-loop Westinghouse plant instead of a
3-loop.
The licensee had been consistently responsive to NRC initiatives.
The licensee met deadlines with respect to requests for additional
information, such as confirmatory order requirements for
NUREG-0737 Supplement 1 Technical Specification submittals
including special reports, and environmental qualification of
electrical equipment. The responses were technically sound and
thorough in almost all cases. The licensee had also been working
to improve their significant hazards determinations with
noticeable improvement.
The licensee has shown improvement in all areas of the licensing
activities.
2. Conclusion
Category: 2
3. Board Recommendations
The Board recognizes an improving trend in this area.
K. Training
1. Analysis
During the evaluation period, inspections were performed by the
resident and regional inspection staffs. Training was not
evaluated separately during the previous SALP assessment period
but was discussed under the various functional areas such as
operations, maintenance, etc.
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A special training assessment that was conducted the week of
February 11, 1985, concluded that the plant training programs were-
adequate to support the licensed activities. Management attention
and involvement was apparent by their support of programs and
staffing increases in the functional training areas. General
employee training was adequate and ongoing. Training of
contractor personnel during outages appeared well planned and
organized.
A limited training review was conducted on July 22 and 23, 1985,
by NRC staff from headquarters and a Region II inspector. Of
particular interest was the involvement of licensee training in
the February 28, 1985, high startup rate and subsequent positive
rate reactor trip incident. The initiating factor in the
incident was determined to be an incorrect estimated critical
position (ECP) calculation performed by the shift technical
advisor (STA). In addition, senior reactor operator (SRO)
supervised on-the-job training was being conducted. The SR0
assumed that the STA's ECP calculation was correct, and failed to
observe instrumentation while the trainee was pulling control rods
to 100 steps (reactor tripped at 75 steps). Training implications
in the above incident include the need for the licensee Training
Department to (1) maintain administrative control over sequencing
the total training program so as not to allow a trainee to perform
a critical task while in the initial training stage, and
(2) ensure that SR0s are properly prepared for duties and
responsibilities as on-the-job training instructors. The
licensee's corrective actions included clarifying the techniques
for calculating an ECP and developing a training segment to
address the incident. Further, licensee management, in a letter
dated November 19, 1985, asserted that on-the-job training is now
a cooperative effort between the Operations and Training
Department.
The licensee had received INP0 accreditation for the Operator,
Health Physics and Chemistry Programs. The licensee had a site
specific simulator in place and had increased the time for
operator and shift technical advisors (STAS) on the simulator with
more emphasis on events and problems occurring at the plant. The
simulator was also used in the 1985 emergency preparedness drill
to provide more realism to the drill. The training department was
in the process of developing a training program for engineers and
managers. A comprehensive training program, which follows INPO
guidelines, had been developed for mechanics, electricians, and
instrumentation and control technicians. The mechanical,
instrumentation and control and electrical maintenance programs
are scheduled for INP0 accreditation review in 1986. Maintenance
personnel training has been expanded to include training on motor
operated valve analysis test system (M0 VATS), infrared analysis,
and ferrographic oil analysis as discussed in Section C.
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The security staff training program was intensive, innovative, and
produced a security - force of high quality as discussed in
Section G.
The licensee continued to demonstrate a strong commitment to
~
emergency response training as discussed in Section F.
Management attention in the fire protection area resulted in an
upgraded training program. Regular training drills were conducted
for fire brigade members and annual realistic training was
corducted for all brigade members at the South Carolina Fire
Academy. Programs were being developed for training of fire
protection technicians and tracking of all areas. These programs
are scheduled to be implemented in early 1986.
The _NRC conducted three site visits to examine replacement
licensee candidates. Sixty percent of the Reactor Operators (R0s)
(12 of 20) and 67 percent of the Senior Reactor Operators (SR0s)
(8 of 12) passed the examinations. These percentages are slightly
below the natio al average.
One violation wa identified.
Severity Leal IV violation for failure to insure that a
control room supervisor possessed a valid Senior Reactor
Operators li anse. (85-13)
2. lAnclusion
Category: 2
3. Board Recommendation
The Board noted that significant resources have been expended on
the training facility and program. However, the low pass rate on
licensing exams when compared to the national average can be
attributed to training and should see improvement during the next
SALP period. No change in NRC inspection activity is recommended.
V. SUPPORTING DATA AND SUPMARIES
A. Licensee Activities
During this evaluation period, major licensee activities included
normal power operations, two refueling outages, and extensive
modifications and repairs as follows:
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First Refueling - September 28, 1984
Upgrading Incore RTD circuitry
Modification to cold overpressure protection system (COPS)
Relocation of RCS wide range pressure transmitters outside
containment
Relocation of Diesel Generator instrumentation due to
vibration
Added acoustical monitors to pressurizer safety valves
Alarm lights in high noise areas
Alternate source range detector to shutdown panel
Modifications of main generator rotor
100% eddy current testing of steam generator t"bes
Second Refueling - October 5, 1985
Modifications to condensate system-
Main turbine five year inspection
Rotopeening of steam generator tubes
Boron injection tank removal
Steam generator secondary maintenance
Modifications to isophase bus duct
Appendix R modifications to B diesel generator
EQ limit switch replacement on heating, ventilation,
and air conditioning (HVAC) dampers
Reactor building tendon inspection
B. Inspection Activities
During the evaluation period, routine inspections were performed by the
resident and regional -inspection staffs. In addition, a number of
special team assessments and inspections were conducted during this
period:
plant operatior.s team inspections
radiological control / mobile laboratory inspection
training assessment
.
containment integrated leak rate testing
I Salem ATWS event inspection
containment tendon surveillance inspection
fire protection team inspection
early warning siren system inspection
quality assurance inspection
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C. Licensing Activities
The basis for the appraisal in this area was the licensee's performance
in support of licensing actions that were either completed or had a
significant level of activity during the rating period. Actions that
involved a significant level of activity during the current rating
period are listed below:
Major Licensing Actions
- Low Temperature Overpressure Protection System
- Spent Fuel Pool Rerack
- P-9 Interlock
-
Thermal Design Flow Reduction
-
Full Load Rejection Capability
- Class IE and Non-1E Cable Tray Separation '
- Control of Heavy Loads, Phases I & II
-
Electrical Rod Control Problems
- Response to GL 83-28, Salem ATWS
-
Shutdown Margin, Modes 3, 4, & 5
-
BIT Tank Removal
-
Type C Leak Rate Tests
-
Service Water Intake Structure
-
Fire Protection
-
ICC Instrumentation
-
ASME Section XI Relief Requests
License Amendments Issued
Amend.
No. Date Description
25 July 2, 1984 Surveillance requirement and action
statement added to Hydrogen Monitors
T.S.
26 Sept. 24, 1984 Changed the low temperature
overpressure protection system from
a PORV-system to a RHR relief valve
system
27 Sept. 27, 1984 Spent Fuel Pool Rerack
28 Oct. 12, 1984 Changed time constants T1 and T in
overpressure and overtemperature DT
equations
29 Oct. 15, 1984 Power lockouts RHR suction line
isolation valves
30 Oct. 24, 1984 Reactor Bldg Cooling Unit Fan Motors
Eddy Current brakes - Containment
Penetration Conductor Overcurrent
Protection Device test (CPCOPD)
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31 Oct. 24, 1984 MOV Thermal Overloads
.
32 Nov. 8, 1984 Seismic Monitoring Instrumentation
33 Nov. 13, 1984 Reactor Bldg Sump. Iso valves - CPCOPD
34 Nov. 30, 1984 P-9 interlock
~35 Jan 2, 1985 10 CFR 50.73 Reporting Requirements
36 Jan. 24, 1985 Clarificatior, of SR0 qualification
requirements
37 Jan. 31, 1985 RCS Fl ow - adds Region III of
operation
38 April 1, 1985 Non-class IE cable requirements
39 April 1, 1985 TS change repurge exhaust monitor
40 April 30, 1985 Change in overtemp delta-T trip -
setpoint equation and in steam
generator water level low-low trip
setpoint
41 May 6, 1985 Deleted snubber TS Tables
42 May 14, 1985 Modified surveillance freq. for
Spent Fuel Pool Ventilation System
43 June 24, 1985 Permits 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for repair before
shutdown, when more than one control
rod is electrically inoperable
44 August 26, 1985 Deletes Boron Injection System
45 Sept. 25, 1985 Thermal Design Flow Reduction of
1.9%
46 Nov. 7, 1985 S/D Margin - Modes 3, 4, and 5
47 Nov. 23, 1985 Type C Leak Tests
48 Dec. 20, 1985 Service Water Intake Structure
D. Investigation and Allegation Review
Two allegations were received during the assessment period. Neither
was of any safety or health significance.
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E. Escalated Enforcement Actions
1. Civil Penalties
Severity Level III violation for system alignment errors rendering
both trains low head safety injection inoperable on August 23,
1985, and omitted jumpers from the overpower delta temperature
trip circuits since initial plant startup in October 1982. Civil
Penalty: $50,000. (Issued Date: January 6, 1986)
2. Orders
None.
F. Management Conferences Held During the Evaluation Period
An enforcement conference was held at the corporate office on August 6,
1985, to discuss deficiencies in the implementation of the fire
protection plan.
An enforcement conference was held in the Region II office on
October 8, 1985, to discuss isolation of both trains of low head safety
injection, the jumpers omitted from overpower delta temperature circuit
cards, and .the construction strainers in the suction of both reactor
building spray pumps.
G. Confirmation of Action Letters
None.
H. Review of Licensee Event Reports and 10 CFR 21 Reports
Submitted by the Licensee
1. Licensee Event Reports (LERs)
During the evaluation period, a sample of 46 LERs submitted by the
licensee were evaluated by the NRC staff to detennine the event
cause.
The distribution of these events were as follows:
i
Cause Number
Component Failure 14
l Design 5
Construction, Fabrication,
or Installation 0
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Personnel
- Operating Activity. 5
- Maintenance Activity 5
- Test / Calibration Activity 11
- Other 3
Out of Calibration- 0
Other 3
TOTAL 46
2. 10 CFR Part 21 Reports84-029 Defective Brown Boveri Speed & Transfer Switch
85-016 Feedwater Isolation Valve
85-017 Separation of Vital Power Cable Trays85-032 Failure of Diesel Generator Exciter Regulator
I. Enforcement Activity
FUNCTIONAL- NUMBER OF DEVIATIONS AND VIOLATIONS
AREA IN EACH SEVERITY LEVEL
0 V IV III II I
Plant Operations 1 10 1
Radiological Controls 1 1
Maintenance 1 2
Surveillance 4 1
Fire Protection 2
Security 1 1
Refueling / Outages 1 2
Quality Assurance and 2
Administrative Controls
Affecting Quality
Licensing Activities
Training 1
TOTAL 9 23 1
Eleven unplanned trips and six manual shutdowns occurred during this
evaluation period. The unplanned trips are listed below:
1. July 29, 1984 - Trip on Lo-Lo Steam Generator Level B caused by
feedwater control valve erratic operation. The erratic operation
of the valve was attributed to the deadband adjustment on the
control valve's volume booster. Corrective action taken to
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prevent recurrence was to adjust the volume booster so that it
would not function except during large signal demands.
2. September 28, 1984 - During power reduction for initial refueling,
intermediate range (N-35) High Flux Trip Bistable did not reset
prior to power being reduced to less than 10%. The intermediate
range high flux trip setpoint has been adjusted to a higher power
level.
3. December 27, 1984 - Trip caused by improper connection of test
equipment. An I&C technician advertently imposed a test signal on
the output of N-44 power range channel. This signal caused the
feedwater control valves to close. This condition in coincident
with B Steam Generator low level bistables being tripped caused
the reactor trip. Corrective action taken to prevent recurrence
was to train I&C technicians on the installation and use of test
equipment on plant equipment.
4. February 28, 1985 - A positive rate trip occurred from approxi-
mately 6% power following a premature power range criticality.
The reactor protective system functioned as required. The
premature criticality was caused primarily by the failure of the
shift supervisor to be fully aware of plant status, to closely
monitor instrumentation and to anticipate criticality whenever
rods were being withdrawn as required by station procedures.
Contributing to the failure was a calculated estimated critical
position, which was in error by more than 100 rod steps. Improved
procedures have been provided.
5. March 17,1985 - Trip caused by A main steam isolation valve
(MSIV) closing during testing. A faulty test switch caused the
closure of A MSIV which cause a shrinkage of A Steam Generator
level to the 10-10 level setpoint causing the reactor trip.
Corrective action taken was to replace the test switch and test
all MSIVs.
6. April 18, 1985 - Trip caused by dropped rod during troubleshooting
of rod control system. The dropped rod caused a rriactor trip on
the power range negative rate trip signal. The rod control system
failure was determined to be a defective slave cycler counter
card. The card was replaced and a preventive maintenance program
was established for the rod control system cabinets to prevent
recurrence.
7. April 29,1985 - Trip on Lo-Lo Steam Generator Level B caused by
feedwater isolation due to a low feedwater temperature and a low
feedwater flow condition. The feedwater transients during a down
power ramp were attributed to two failures. First, the load
decrease circuitry for the Main Turbine failed to function
properly and this condition was further complicated by a failure
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of the Steam Dump System to respond properly. Corrective action
to prevent recurrence was to replace the load decrease circuit
board and repair the steam dump system, along with a scheduled
preventive maintenance program.
8. August 20, 1985 - Reactor trip from 100% power on a false signal
for loss of reactor coolant system flow. An I&C Technician
replacing FT-345 caused a pressure spike to redundant flow trans-
mitters.
9. August 24, 1985 - Reactor tripped from 10% power on Intermediate
Range High Flux. Following replacement N36 detector, setpoints
<
were not properly reset prior to a power increase. The licensee
initiated improved procedural controls to ensure hold points are
clearly Jefined and tracked.
10. August 24, 1985 - Reactor tripped from 25% power on Low Low Level
in steam generator A. Trip was caused by feedwater isolation on
low feedwater temperature and flow during power ascension.
Feedwater isolation was caused by a transient in the dearator tank
level. The licensee has implemented procedural controls and
increased operator training to reduce the potential for similar
events.
11. September 20, 1985 - Trip from turbine trip caused by loss of all
main feedwater pumps during testing of the condensate system. The
loss of all feedwater pumps was caused by the loss of all
condensate pumps by unknown cause during condensate pump testing.
Corrective action to prevent recurrence was to require review and
approval of the Director of Nuclear Plant Operations for special
or integrated testing outside the normal surveillance and
maintenance testing program,
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