IR 05000395/1985047: Difference between revisions

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{{Adams
{{Adams
| number = ML20141N831
| number = ML20155J144
| issue date = 03/12/1986
| issue date = 05/08/1986
| title = SALP Rept 50-395/85-47 for Jul 1984 - Dec 1985
| title = Errata to SALP Rept 50-395/85-47,reflecting Correct Info Re Degradation of Mgt Controls & Eddy Current Testing of Steam Generator Tubes
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| case reference number = RTR-NUREG-0737, RTR-NUREG-737
| document report number = 50-395-85-47, NUDOCS 8605220031
| document report number = 50-395-85-47, GL-83-28, IEB-83-03, IEB-83-3, NUDOCS 8603180181
| package number = ML20155J142
| package number = ML20141N828
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 31
| page count = 8
}}
}}


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May.8, 1986 ENCLOSURE APPENDIX TO SOUTH CAROLINA ELECTRIC'AND GAS COMPANY V. C. SUPMER PLANT SALP BOARD REPORT NO. 50-395/85-47 (DATED MARCH 12, 1986)
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8605220031 860508 PDR ADOCK 05000395 0- PDR :;
ENCLOSURE SALP 80ARD' REPORT U. S. NUCLEAR REGULATORY COMISSION r
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SYSTEMATIC' ASSESSMENT OF LICENSEE PERFORMANCE i,
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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Enclosure I. Meeting Summary A meeting was held on March 18, 1986, at South Carolina Electric and Gas Company's Columbia, South Carolina, corporate office to discuss the SALP Board Report for the V. C. Summer facilit Licensee Attendees:
J. A. Warrer., Vice-Chairman and Chief Executive Officer-T. C. Nichols, Jr., President and Chief Operating Officer E. H. Crews, Jr., Executive Vice President D. A. Nauman, Vice President, Nuclear Operations W. C. Mescher, President and Chief Executive Officer, Santee Cooper William A. Williams, Jr., Special Assistant, Nuclear Operations, Santee Cooper 0. S. Bradham, Director, Nuclear Plant Operations Dave Moore, Director, Quality and Procurement Services John Connelly, Director, Nuclear Services K. W. Nettles, Group Manager, Technical Services D. A. Lavigne, Manager, Materials and Procurement A. M. Paglia, Jr. Manager, Nuclear Licensing H. T. Babb, Group Manager, Nuclear Engineering and Training W. R. Baehr, Manager, Corporate Health Physics and Environmental Programs
  - J. Leach, Manager, Quality Assurance S. R. Hunt, Manager, Nuclear Quality Control R. M. McSwain, Manager, Media and Consumer Information R. B. Whorton, Associate Manager, Licensing Systems NRC Attendees:
i R. D. Walker, Acting Deputy Regional Administrator, Region II (RII)
:  H. C. Dance, Chief, Reactor Projects Section 28, RII J. B. Hopkins, Project Manager, NRR R. L. Prevatte, Senior Resident Inspector, Summer P. C. Hopkins, Resident Inspector, Summer
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II. Errata Sheet - Summer SALP
. 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 operatio 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 repor 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, 198 <
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SALP Board for Summer:
Page Line Now Reads  Should Read 4 10 . . . September 1985. This  . . . September 198 This inspection revealed degradation inspection revealed that of management control in areas the licensee was addressing that included the lack of atten- the following four areas i tion to nuclear system operating to correct this trend:
R. D. Walker, Director, Division of Reactor Projects (DRP), RII (Chairman)    <
i  conditions, outdated and poorly procedure compliance, l controlled procedures, inadequate attention to detail, methods of tracking equipment training, and overall status involving limiting condi- attitude. Additionally, tions of operation, and a generally the inspectors noted an relaxed attitude toward procedure inadequacy in tracking of complianc technical specifications required action statements, feedwater control problems during startup, minimum
C. A. Julian, Acting Director Division of Reactor Safety (DRS), RII J. P. Stohr Director, Division of Radiation Safety and Safeguards (DRSS),
;    operator log entries l    regarding plant status, improved housekeeping needed in the control room, and not specifically addressing the root cause of an even Twelve violations . . .
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:
Basis for Change: To clarify the findings of the September 1985 inspectio . . . selected valves; 100 percent . . . selected valves; eddy current testing of steam selected eddy current
P K.D.Landis, Chief.TechnicalSupportStaff(TSS),DRP,RII ,
, generator tubes; and three year . . . testing of steam generator i
H. C. Dance, Chief, Reactor Projects Section (RPS) 28. DRP, RII '
l tubes; and three year . . .
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 l
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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 area Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Spt.:ial areas may be added to highlight signifi-cant observation 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 appropriat Management involvement and control in assuring quality Approach to resolution of tect ical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Reporting (and analysis Staffing including of reportable events management) Training effectiveness and qualification Based upon the EALP Board assessment, each functional area evaluated is classified into one of three performance categorie 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 achieve 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 achieve 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 achieve 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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l Basis for Change: To correct the scope of the eddy current testing during the l first refueling outage.


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l 17 22 . . . rotopeening and 100 percent . . . rotopeening and 100 inspection of steam generator tubes, percent inspection of the
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  ... hot leg tube sheet area of all three steam generators, sludge lancing and . . .
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l Basis for Change: To correct the scope of the eddy current testing during the i second refueling outage.
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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 perio Declining:- Licensee performance was determined to be declining near the close of the assessment perio 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 protectio A strength was identified in the areas of emergency preparedness, security, radiological controls, and maintenance during the assessment perio 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 identifie 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 L
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IV. PERFORMANCE ANALYSIS A. Plant Operations Analysis During the evaluation period, routine inspections were performed by the resident and regional staff The licensee's performance in the areas of housekeeping, control room behavior and discipline was satisfactory. The plant overall cleanliness was commendabl Operational staffing of key positions with knowledgeable personnel was considered adequat 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 issue Long term programatic changes are still being reviewe 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 problem Many of these changes are recent and insufficient time j    has elapsed to evaluate their overall impact on plant operations.
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l 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 problem 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 pas 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 detai The licensee's investigation, inspection and subsequent repair of Anchor / Darling check valves Wds timely and effectiv 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 circuit (85-34) Severity Level IV violation for failure to follow locked valve procedur (84-23) Severity Level IV violation for failure to identify and take prompt corrective action for a potential deficiency on a reactor protection instrumentation channe (84-29) Severity Level IV violation for failure to implement locked valve control progra (84-30) Severity Level IV violation for failure to demonstrate operability of containment isolation valve (84-37) Severity Level IV violation for failure to follow procedures while withdrawing control rods and approaching criticalit (85-12)
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9 Severity Level IV violation for failure to establish adequate procedures for ECC calculation (85-12)
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I PERFORMANCE ANALYSIS Plant Operations i    - Analysis
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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
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1  Personnel errors noted in the previous SALP continued to plague
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j  concern inspection  thatin a negative September trend 198 might be's, developing inspection led revealedto a special Thi i  degradation of management control e areas that included the lack j  of attention to nuclear system o ating conditions, outdated and
{  poorly controlled procedures, ) adequate methods of tracking l  equipment status involving lie ting conditions of operation, and a j  generally relaxed attitude    ward procedure complianc Twelve i  violations were identified    four separate catem+ie These are
!  violations of plant opera anal limits as notec    . (a), (e) (h),
and (k) below, safety re ted administrative requirements as noted in (b), (d), (f), (j)   and (1) below, failure of operations personnel to maintal  an awareness of plant status as noted in (b), (c), (f), (i)  (j), and (k) below, inadequate procedures as noted in (g) b ow, and failure to follow procedures as noted
. in (i) below. V 1ations (f) and (g) below were issued because of j  the February 28 1985 positive rate reactor trip incident which is discussed in  ection An enforcement conference was held in
!  Region II o  October 8,1985, to discuss the events associated i  with viola on (a) below. A Civil Penalty was subsequently issued
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on Januar 6,1986, and the licensee's response dated February 5, i  1986, a ressed the issue Long term programmatic changes are still eing reviewed.


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  * Severity Level IV violation for failure to implement the
To mprove plant operations and address the above concerns, the 1 ensee implemented changes to provide improved control over
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requirements of Technical Specifications for an inoperable power range instrumen (85-15) Severity Level IV violation for failure to follow procedures and use the latest revision to calculate estimated critical condition (85-27) 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 inoperabl (85-28) Severity Level IV violation for an inoperable feedwater isolation valve during Mode 3 operation. (85-37) Severity Level V violation for failure to properly document surveillance test activities. (85-04) 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 are B. Radiological Controls Analysis During the evaluation period, inspections were performed by the resident and regional staffs. This included confirmatory measure-ments using the Region 11 mobile laborator 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 staf Two strengths of the health physics program were the quality of the health physics technicians and the experience level of the
l  lant operations. These included assignment of a Duty Operations      ,
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Manager to provide oversight and assistance during plant startup      1
corporate and site health physics staff The staff has a low
, turnover rate and an effective training progra ) i i
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and shutdown; the addition of a seventh shift supervisor to      i
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; y atmosphere; and a team building program to improve. communications
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and provide for identification and resolution of operations problem Many of these changes are recent and insufficient time l
  .o  has elapsed to evaluate their overall impact on plant operations, i
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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 area 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 sample In addition, a systematically high bias was identified for gamma spectroscopic analyses of particulate filters. The licensee participated in the NRC spiked sample analysis progra Licensee analyses were in agreement for three isotopes but were in disagreement for on 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 burde 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 Specification No trends or biases were evident from reported value 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 syste During the evaluation period, the licensee's radiation work permit and respiratory protection programs were found to be satisfactor Control of contamination and radioactive materials within the facility was excellen 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 plan In 1985, there was a 48 percent decrease in the number of clothing and skin contamina-tion incidents when compared to 198 During this eighteen month evaluation period, the licensee's cumulative exposure was 598 man-re 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 license J
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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
I PERFORMANCE ANALYSIS Plant Operations Analysis During the evaluation period, routine inspections were performed by the resident and regional staff The licensee's performance in the areas of housekeeping, control room behavior and discipline was satisfactory. The plant overall cleanliness was commendabl Operational staffing of key positions with knowledgeable personnel was considered adequat 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 that the the licensee was addressing the following four areas to correct this trend: procedure compliance, attention to detail, training, and overall attitud Additionally, the inspectors noted an inadequacy in tracking of technical specifications required action statements, feedwater control problems during startup, minimum operator log entries regarding plant status, improved housekeeping needed in the control room, and not specifically addressing the root cause of an even Twelve violations were identified in four separate categorie These are violations of plant operational limits as noted in (a),
  , intrusions happened when the plant was operating above 50 percent power where . the. condensate. cleanup system .must be bypasse Although chemistry was controlled in an acceptable-manner during
  (e) (h), and (k) below, safety related administrative requirements as noted in (b), (d), (f), (j), and (1) below, failure of opera-tions 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 Region II on October 8,1985, to discuss the events associated with violation (a) below. A Civil Penalty was subsequently issued on January 6,1986, and the licensee's response dated February 5, 1986, addressed the issue Long term programmatic changes are still being reviewe 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 i control room enhancement program to provide a more professional
  .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 resource '
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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 facilitie Two violations were identified: Severity Level IV violation for failure to follow procedural requirements for wearing protective clothing. (84-27) Severity Level .Y violation for failure to achieve the required lower limit of detection for effluent sample (85-19) Conclusion Category: 1
atmosphere; and a team building program to improve communications and provide for identification and resolution of operations problem Many of these changes are recent and insufficient time has elapsed to evaluate their overall impact on plant operation j
  , . 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 progra Maintenance.


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During the evaluation period, routine inspections were performed by the resident and regional staff 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 o
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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 guideline 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) control The craft personnel performing i
During the evaluation period, inspections were performA'd by the !
maintenance and surveillances were knowledgeable of maintenance procedures and plant equipment. Maintenance Work Order (MW0)
!  resident and regional staffs. Refueling activities observed from ;
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 compute 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 initiative The licensee's responses were timely, concise, and adequately resolved technical issue 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 indicatio 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 198 The licensee has additionally developed the capability to perform onsite dioctylphthalate and methol iodide testing of charcoal filters in heating, ventilation, and air conditioning system This testing had previously been performed by outside contractors.
t the control room, refueling floor, and spent fuel pool were found
 
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The expansion of naintenance facility . buildings has provided additional space and equipment for mechanical and instrumentation wor 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 repair >
Use of the Nuclear Plant ~ Reliability Data System (NPRDs) has increased the licensee's awareness of potential.. plant problem 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 disciplin 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 activitie The establishment of outage critiques to identify areas requiring additional attention and tracking was evidence of management involvemen Three' violations were identified: Severity Level IV violation for failure to follow procedure GMP 101.00 (85-13)
F 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) Severity Level V violation for failure to follow procedure (85-08)
^ Conclusion Category: 1 Board Recommendation The Board notes indications of strong management attention in this
  ' area. Decreased NRC inspection activity is recommende '
D. Surveillance 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 activitie Staffing and training was adequate and surveillances were conducted within the proper time fram 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 execute Improvements in tracking limiting conditions for operations applicable to surveillance testing have been implemente 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 Specification Analysis performed by a contractor demonstrated adequate struc-tural integrit The licensee's procedures and records for control of the tendon surveillance program were well defined and explici 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 198 This violation is incorporated as violation (a) in the plant operations section and resulted in a Civil Penalty being issued on January 6,198 Inservice inspection procedures, work, and records performed by the licensee contractor were found to be satisfactor Inservice inspection and inservice testing procedures, work, and records performed by site personnel were sometimes inadequate as indicated by violations (a) through (e) belo 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
i The licensee commenced the first refueling outage on September 28,  l l  1984. Major activities accomplished during try4 83 day outage were  i j  completion of the TMI and Licensing C'ondit,fons modifications;  ;
<
)  inspection and maintenance of the main turbine, main generator  !
Diesel Generators", and their failure to correct an NRC identified
!'
!
rotor, and selected valves; 100 percent , eddy current testing of  t steam generator tubes; and three year maintenance j on reactor coolant pumps "A" and "B" seals. Thef activities associated with
test procedure deficiency which ultimately resulted in violation (a) belo Based on the above problems, the licensee management dedication toward improvement led to increased quality assurance / quality L control (QA/QC) in the surveillance program. This also resulted
        !
; in transferring the Regulatory Support Group, which provides
j  refueling occurred without major problems. Some problems were  :
; administrative and technical oversight over the program, from the Regulatory Compliance area to Planning and Scheduling. This
!
incurred during the outage with schedulingf and interface  !
:  conflicts. As a result, licenbee management estaolished an  1
'
'
change resulted in better coordination and faster resolution of problems.
l extensive " lessons learned" program with an action item list that !
 
required tracking and responses /from affected area ;
(
!        l
 
  ; The plant commenced the seco/ nd refueling outage on October 5, i i  1985. This third fuel loa. ding placed the core in an 18 month fuel !
r
1 cycle. Major work accomplished during this 72 day outage included J  changes to the condensate system to provide constant speed pumps l; j and flow control valve's, main turbine five year inspection,  !
  *
!'  rotopeening and 100 p,ercent inspection of steam generator tubes, l sludge lancing and/ internal inspection of the steam generator ;
  .
 
      :
Extensive effort had been expended by operations and engineering personnel in developing a computerized Technical Specification cross reference progra This program when completed and implemented should reduce administrative burdens on operations and provide a better tracking method to insure compliance when conducting surveillance 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 improvement Five violations were identified: 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) Severity Level V violation for failure to test valves to assure proper functioning of remote valve position indicator (84-31) Severity Level V violation for failure to document the name of individuals recording data. (85-10) Severity Level V violation for failure to implement the requirements of EMP 115.011 during performance of the monthly battery inspectio (85-21) Severity Level V violation for failure to follow procedures for hanger inspection. (85-23) Conclusion Category: 2 Board Recommendation No change in NRC inspection activity is recommende E. Fire Protection 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.
 
L
 
    -
  -
 
  -
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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 revie 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 thoroughnes This was demonstrated by the fact that the licensee's Appendix R analysis did not address the following requirements:
  -
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 hour Identify all the equipment, components, and cabling required to achieve and maintain hot standby and cold shutdown
, condition The circuit analysis did not follow NRC guidance with respect to fuse / breaker coordination, common electrical enclosures, and spurious signal 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 control 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 implemente The licensee's routine fire prevention / protection program were found to be satisfactory except in the areas of fire barrier and fire door integrit 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.
 
t
 
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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 locatio 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 enforcemen Severity Level IV violation for failure to prevent . fire barrier degradatio (84-35)
  . Severity Level IV violation for failure to establish' required fire watch for inoperable fire doo (84-37) Conclusion Category: 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 issue Increased NRC inspection activity is recommende Emergency Preparedness Analysi During the evaluation period, inspections were performed by the
,  resident ind regional staff 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 staffin An adequately staffed corporate emergency response and planning organization ~ routinely provided support to the plan Key positions in the corporate and plant emergency response organizations were fille Corporate management continued to
; demonstrate a strong commitment to maintenance of an effective
:  emergency response program. Corporate management was directly
 
involved in the 1985 annual emergency preparedness exercise and
.
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followup critiqu The licensee continues to promptly and effectively respond to NRC initiatives regarding emergency preparedness issue The licensee continued to demonstrate a strong commitment to emergency response trainin 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 respons 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 event The essential elements of emergency response, demonstrated during the referenced exercise, were determined to be acceptabl 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 guidanc 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-ment 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 mad 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 organization (85-21)
2. Conclusion Category: 1 3. Board Recommendation Decreased NRC inspection activity is reconnended.
 
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G. Security and Safeguards Analysis During the evaluation period, inspections were performed by the resident and regional staff 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 qualit 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 situation 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 system Site management demonstrated a supportive role in maintaining the security program through their knowledge of security requirements and actions and approval of program improvement 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 disturbance Work was also begun on security computer upgrades to enhance personnel accountability within the plant sit Two violations were identifie These violations are not indicative of a breakdown in the licensee's overall security progra The licensee provided prompt and effective corrective ac ion for issues raise Severity Level IV violation for failure of the access control officer to remain within a bullet-resistant enclosur (85-14) Severity Level V violation for inadequate test procedure of intrusion detection systems. (85-33) Conclusion Category: 1 Board Recommendation The Board noted that the spirit and morale of the Security organization is exemplar Decreased NRC inspection activity is recommended, t
 
m e
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,
,
H. Outages Analysis
secondary side, mo'ifications d to the isophase bus duct, removal of f i  the boron inject' ion tank, equipment upgrades for environmental  !
      ,
l  qualification, snd Appendix R modifications.
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 satisfactor 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 area 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 modification 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 physic The second refueling outage demonstrated that management attention directed toward preventing problems that occurred in the first outage was successfu 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 managemen The deliberate and methodical startup without problems was indicative of good management contro .
 
~
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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) belo Three violations were identifie Severity Level IV violation for failure to perform adequate calibration of load cell used for spent fuel rack drag testin (84-25) 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) Severity Level V violation for failure to follow procedure during receipt, inspection, and storage of new fuel assemblie (84-29) Conclusion Category: 2 Board Recommendations The Board noted 'that innovative management is providing an improving trend in this are No change in NRC inspection activity is reccmmende . Quality Programs and Administrative Controls Affecting Quality i 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 committe The Qual.ity Assurance Department maintained an adequate QA program with the exception of one continuing program deficiency identified in the previous SALP perio This problem was the prompt resolution of audit finding 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 i
 
~ ,
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,
  .
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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 are All pha'ses of material control met or exceeded regulatory require-
  .ment Licensee response to QA findings in this area was timely with adequate corrective actio 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 equipmen * status lists, which were often found to be inaccurat 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. belo 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 traine Responsibility and line of-
..
authority were clearly defined in procedures and policy manual 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 volum 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, t
 
      . _ _ _ _ _ _ _ _ _
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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. belo Two violations were identified: Severity Level IV violation for failure to provide documented safety review and evaluation prior to procedural approval.and implementatio (84-25) Severity Level IV violation for failure to establish measures to assure prompt evaluations of out-of-calibration measuring and test equipmen (85-11)
l Conclusion Category: 2 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 recommende J. Licensing Activities
! 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 perio In general, management involvement continued to improv There was evidence of prior planning and a:signment of priorities,  ,
especially in the area of refueling activities as discussed in  ,
Section 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- lem 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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l The licensee had a good understanding of the technical and safety issues, while proposed resolutions were conservative and soun 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-loo The licensee had been consistently responsive to NRC initiative 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 improvemen The licensee has shown improvement in all areas of the licensing activitie . Conclusion Category: 2 Board Recommendations The Board recognizes an improving trend in this are K. Training Analysis During the evaluation period, inspections were performed by the resident and regional inspection staff 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 area General employee training was adequate and ongoin Training of contractor personnel during outages appeared well planned and organize 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 inciden 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 instructor 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 Departmen 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 technician 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.


t l
i l  The license. has strengthened the planning and scheduling group by  !
i adding SRp{ HP, and administrative staff personnel to assist in  ;
scheduli g. These changes significantly improved the interface  :
betwee operations, maintenance, and health physic j j  Thej econd refueling outage demonstrated that management attention  i
!  di7ected toward preventing problems that occurred in the first  '
j  outage was successfu This outage showed good preplanning,  i
:  coordination and prior training for the activities that were
        {'
j  accomplishe The startup, low power physics testing, and power i  ascension after the outage was closely monitored by the staff and
;  licensee management. The deliberate and methodical startup g* without problems was indicative of good management contro ;        j i @
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e
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E
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The security staff training program was intensive, innovative, and produced a security - force of high quality as discussed in Section The licensee continued to demonstrate a strong commitment to
H. Outages Analysis During the evaluation period, inspections were performed by the resident and regional staff Refueling activities observed from the control room, refueling floor, and spent fuel pool were found to be satisfactor The licensee commenced the first refueling outage on September 28, 1984. Major activities accomplished during the 83 day outage were completion of the TMI and Licensing Conditions modifications; inspection and maintenance of the main turbine, main generator rotor, and selected valves; selected 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 area 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 turoine five year inspection, rotopeening and 100 percent inspection of the hot leg tube sheet area of all three steam generators, sludge lancing and internal inspection of the steam generator secondary side, modifications to the isophase bus duct, removal of the boron injection tank, equip-ment upgrades for environmental qualification, and Appendix R modification 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 physic The second refueling outage demonstrated that management attention directed toward preventing problems that occurred in the first outage was successfu This outage showed good preplanning, coordination and prior training for the activities that were accomplishe The startup, low power physics testing, and power ascension after the outage was closely monitored by the staff and The deliberate and methodical startup
emergency response training as discussed in Section 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 Academ Programs were being developed for training of fire protection technicians and tracking of all areas. These programs are scheduled to be implemented in early 198 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)
licensee managemen l without problems was indicative of good management contro I l
  (8 of 12) passed the examinations. These percentages are slightly below the natio al averag One violation wa identifie Severity Leal IV violation for failure to insure that a control room supervisor possessed a valid Senior Reactor Operators li anse. (85-13) lAnclusion Category: 2 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 recommende SUPPORTING DATA AND SUPMARIES 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
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Upgrading Incore RTD circuitry
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Modification to cold overpressure protection system (COPS)
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Relocation of RCS wide range pressure transmitters outside containment
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Relocation of Diesel Generator instrumentation due to vibration
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Added acoustical monitors to pressurizer safety valves
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Alarm lights in high noise areas
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Alternate source range detector to shutdown panel
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Modifications of main generator rotor
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100% eddy current testing of steam generator t"bes Second Refueling - October 5, 1985
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Modifications to condensate system-
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Main turbine five year inspection
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Rotopeening of steam generator tubes
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Boron injection tank removal
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Steam generator secondary maintenance
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Modifications to isophase bus duct
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Appendix R modifications to B diesel generator
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EQ limit switch replacement on heating, ventilation, and air conditioning (HVAC) dampers
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Reactor building tendon inspection B. Inspection Activities During the evaluation period, routine inspections were performed by the resident and regional -inspection staff In addition, a number of special team assessments and inspections were conducted during this period:
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plant operatior.s team inspections
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radiological control / mobile laboratory inspection training assessment
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containment integrated leak rate testing
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I Salem ATWS event inspection
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containment tendon surveillance inspection
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fire protection team inspection
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emergency preparedness
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early warning siren system inspection
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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:
7 Enclosure
Major Licensing Actions
  - Low Temperature Overpressure Protection System
  - Spent Fuel Pool Rerack
  - P-9 Interlock
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Thermal Design Flow Reduction
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Full Load Rejection Capability
  - Class IE and Non-1E Cable Tray Separation  '
  - Control of Heavy Loads, Phases I & II
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Electrical Rod Control Problems
  - Response to GL 83-28, Salem ATWS
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Shutdown Margin, Modes 3, 4, & 5
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BIT Tank Removal
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Type C Leak Rate Tests
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Service Water Intake Structure
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Fire Protection
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ICC Instrumentation
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ASME Section XI Relief Requests License Amendments Issued Amen N Date  Description 25 July 2, 1984 Surveillance requirement and action statement added to Hydrogen Monitors 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
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32 Nov. 8, 1984 Seismic Monitoring Instrumentation 33 Nov. 13, 1984 Reactor Bldg Sump. Iso valves - CPCOPD 34 Nov. 30, 1984 P-9 interlock
I III. Licensee Comments I
~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 hours 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%
Licensee comments submitted in response to the V. C. Summer SALP Board Report follow:
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 perio Neither was of any safety or health significanc {
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27 Escalated Enforcement Actions 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: $50,00 (Issued Date: January 6, 1986) Orders Non 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 pla 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 pump Confirmation of Action Letters Non Review of Licensee Event Reports and 10 CFR 21 Reports Submitted by the Licensee 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 caus 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 Activit Maintenance Activity  5
  - Test / Calibration Activity 11
  - Other  3 Out of Calibration-  0 Other  3 TOTAL  46 CFR Part 21 Reports 84-029 Defective Brown Boveri Speed & Transfer Switch
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84-030 Defective HVAC Unit 85-016 Feedwater Isolation Valve 85-017 Separation of Vital Power Cable Trays 85-032 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 Emergency Preparedness  1 Security  1 1 Refueling / Outages  1 2 Quality Assurance and  2 Administrative Controls Affecting Quality Licensing Activities Training  1 TOTAL  9 23 1 J. Reactor Trips Eleven unplanned trips and six manual shutdowns occurred during this evaluation period. The unplanned trips are listed below: 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 booste Corrective action taken to L
 
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prevent recurrence was to adjust the volume booster so that it would not function except during large signal demand . 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 leve . 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 equipmen . February 28, 1985 - A positive rate trip occurred from approxi-mately 6% power following a premature power range criticalit The reactor protective system functioned as require 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 procedure Contributing to the failure was a calculated estimated critical position, which was in error by more than 100 rod steps. Improved procedures have been provide . 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 tri Corrective action taken was to replace the test switch and test all MSIV . 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 car The card was replaced and a preventive maintenance program was established for the rod control system cabinets to prevent recurrenc . 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 u
 
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of the Steam Dump System to respond properl 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 progra . August 20, 1985 - Reactor trip from 100% power on a false signal for loss of reactor coolant system flo An I&C Technician replacing FT-345 caused a pressure spike to redundant flow trans-mitter . August 24, 1985 - Reactor tripped from 10% power on Intermediate Range High Flux. Following replacement N36 detector, setpoints
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were not properly reset prior to a power increase. The licensee initiated improved procedural controls to ensure hold points are clearly Jefined and tracke . 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 ascensio 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 event . 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 testin 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, m
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Latest revision as of 05:11, 17 December 2020

Errata to SALP Rept 50-395/85-47,reflecting Correct Info Re Degradation of Mgt Controls & Eddy Current Testing of Steam Generator Tubes
ML20155J144
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 05/08/1986
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155J142 List:
References
50-395-85-47, NUDOCS 8605220031
Download: ML20155J144 (8)
v • d • e


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May.8, 1986 ENCLOSURE APPENDIX TO SOUTH CAROLINA ELECTRIC'AND GAS COMPANY V. C. SUPMER PLANT SALP BOARD REPORT NO. 50-395/85-47 (DATED MARCH 12, 1986)

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8605220031 860508 PDR ADOCK 05000395 0- PDR :;

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Enclosure I. Meeting Summary A meeting was held on March 18, 1986, at South Carolina Electric and Gas Company's Columbia, South Carolina, corporate office to discuss the SALP Board Report for the V. C. Summer facilit Licensee Attendees:

J. A. Warrer., Vice-Chairman and Chief Executive Officer-T. C. Nichols, Jr., President and Chief Operating Officer E. H. Crews, Jr., Executive Vice President D. A. Nauman, Vice President, Nuclear Operations W. C. Mescher, President and Chief Executive Officer, Santee Cooper William A. Williams, Jr., Special Assistant, Nuclear Operations, Santee Cooper 0. S. Bradham, Director, Nuclear Plant Operations Dave Moore, Director, Quality and Procurement Services John Connelly, Director, Nuclear Services K. W. Nettles, Group Manager, Technical Services D. A. Lavigne, Manager, Materials and Procurement A. M. Paglia, Jr. Manager, Nuclear Licensing H. T. Babb, Group Manager, Nuclear Engineering and Training W. R. Baehr, Manager, Corporate Health Physics and Environmental Programs

- J. Leach, Manager, Quality Assurance S. R. Hunt, Manager, Nuclear Quality Control R. M. McSwain, Manager, Media and Consumer Information R. B. Whorton, Associate Manager, Licensing Systems NRC Attendees:

i R. D. Walker, Acting Deputy Regional Administrator, Region II (RII)

H. C. Dance, Chief, Reactor Projects Section 28, RII J. B. Hopkins, Project Manager, NRR R. L. Prevatte, Senior Resident Inspector, Summer P. C. Hopkins, Resident Inspector, Summer

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Enclosure t .

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II. Errata Sheet - Summer SALP

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Page Line Now Reads Should Read 4 10 . . . September 1985. This . . . September 198 This inspection revealed degradation inspection revealed that of management control in areas the licensee was addressing that included the lack of atten- the following four areas i tion to nuclear system operating to correct this trend:

i conditions, outdated and poorly procedure compliance, l controlled procedures, inadequate attention to detail, methods of tracking equipment training, and overall status involving limiting condi- attitude. Additionally, tions of operation, and a generally the inspectors noted an relaxed attitude toward procedure inadequacy in tracking of complianc technical specifications required action statements, feedwater control problems during startup, minimum

operator log entries l regarding plant status, improved housekeeping needed in the control room, and not specifically addressing the root cause of an even Twelve violations . . .

Basis for Change: To clarify the findings of the September 1985 inspectio . . . selected valves; 100 percent . . . selected valves; eddy current testing of steam selected eddy current

, generator tubes; and three year . . . testing of steam generator i

l tubes; and three year . . .

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l Basis for Change: To correct the scope of the eddy current testing during the l first refueling outage.

l 17 22 . . . rotopeening and 100 percent . . . rotopeening and 100 inspection of steam generator tubes, percent inspection of the

... hot leg tube sheet area of all three steam generators, sludge lancing and . . .

l Basis for Change: To correct the scope of the eddy current testing during the i second refueling outage.

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I PERFORMANCE ANALYSIS Plant Operations i - Analysis

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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

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, was satisfactor The plant overall cleanliness was commendabl Operational staffing of key positions with knowledgeable personnel was considered adequate.

1 Personnel errors noted in the previous SALP continued to plague

plant operations. A series of problems', violations, and the i

j concern inspection thatin a negative September trend 198 might be's, developing inspection led revealedto a special Thi i degradation of management control e areas that included the lack j of attention to nuclear system o ating conditions, outdated and

{ poorly controlled procedures, ) adequate methods of tracking l equipment status involving lie ting conditions of operation, and a j generally relaxed attitude ward procedure complianc Twelve i violations were identified four separate catem+ie These are

! violations of plant opera anal limits as notec . (a), (e) (h),

and (k) below, safety re ted administrative requirements as noted in (b), (d), (f), (j) and (1) below, failure of operations personnel to maintal an awareness of plant status as noted in (b), (c), (f), (i) (j), and (k) below, inadequate procedures as noted in (g) b ow, and failure to follow procedures as noted

. in (i) below. V 1ations (f) and (g) below were issued because of j the February 28 1985 positive rate reactor trip incident which is discussed in ection An enforcement conference was held in

! Region II o October 8,1985, to discuss the events associated i with viola on (a) below. A Civil Penalty was subsequently issued

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on Januar 6,1986, and the licensee's response dated February 5, i 1986, a ressed the issue Long term programmatic changes are still eing reviewed.

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To mprove plant operations and address the above concerns, the 1 ensee implemented changes to provide improved control over

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l lant operations. These included assignment of a Duty Operations ,

Manager to provide oversight and assistance during plant startup 1

and shutdown; the addition of a seventh shift supervisor to i

provide administrative assistance to the duty shift supervisor; a l
@,o control room enhancement program to provide a more professional
y atmosphere; and a team building program to improve. communications

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and provide for identification and resolution of operations problem Many of these changes are recent and insufficient time l

.o has elapsed to evaluate their overall impact on plant operations, i

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I PERFORMANCE ANALYSIS Plant Operations Analysis During the evaluation period, routine inspections were performed by the resident and regional staff The licensee's performance in the areas of housekeeping, control room behavior and discipline was satisfactory. The plant overall cleanliness was commendabl Operational staffing of key positions with knowledgeable personnel was considered adequat 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 that the the licensee was addressing the following four areas to correct this trend: procedure compliance, attention to detail, training, and overall attitud Additionally, the inspectors noted an inadequacy in tracking of technical specifications required action statements, feedwater control problems during startup, minimum operator log entries regarding plant status, improved housekeeping needed in the control room, and not specifically addressing the root cause of an even Twelve violations were identified in four separate categorie These are violations of plant operational limits as noted in (a),

(e) (h), and (k) below, safety related administrative requirements as noted in (b), (d), (f), (j), and (1) below, failure of opera-tions 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 Region II on October 8,1985, to discuss the events associated with violation (a) below. A Civil Penalty was subsequently issued on January 6,1986, and the licensee's response dated February 5, 1986, addressed the issue Long term programmatic changes are still being reviewe 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 i control room enhancement program to provide a more professional

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atmosphere; and a team building program to improve communications and provide for identification and resolution of operations problem Many of these changes are recent and insufficient time has elapsed to evaluate their overall impact on plant operation j

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i i Outages

Analysis p

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During the evaluation period, inspections were performA'd by the  !

! resident and regional staffs. Refueling activities observed from  ;

t the control room, refueling floor, and spent fuel pool were found

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to be satisfactory.

i The licensee commenced the first refueling outage on September 28, l l 1984. Major activities accomplished during try4 83 day outage were i j completion of the TMI and Licensing C'ondit,fons modifications;  ;

) inspection and maintenance of the main turbine, main generator  !

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rotor, and selected valves; 100 percent , eddy current testing of t steam generator tubes; and three year maintenance j on reactor coolant pumps "A" and "B" seals. Thef activities associated with

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j refueling occurred without major problems. Some problems were  :

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incurred during the outage with schedulingf and interface  !

conflicts. As a result, licenbee management estaolished an 1

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l extensive " lessons learned" program with an action item list that  !

required tracking and responses /from affected area ;

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The plant commenced the seco/ nd refueling outage on October 5, i i 1985. This third fuel loa. ding placed the core in an 18 month fuel  !

1 cycle. Major work accomplished during this 72 day outage included J changes to the condensate system to provide constant speed pumps l; j and flow control valve's, main turbine five year inspection,  !

!' rotopeening and 100 p,ercent inspection of steam generator tubes, l sludge lancing and/ internal inspection of the steam generator  ;

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secondary side, mo'ifications d to the isophase bus duct, removal of f i the boron inject' ion tank, equipment upgrades for environmental  !

l qualification, snd Appendix R modifications.

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i l The license. has strengthened the planning and scheduling group by  !

i adding SRp{ HP, and administrative staff personnel to assist in  ;

scheduli g. These changes significantly improved the interface  :

betwee operations, maintenance, and health physic j j Thej econd refueling outage demonstrated that management attention i

! di7ected toward preventing problems that occurred in the first '

j outage was successfu This outage showed good preplanning, i

coordination and prior training for the activities that were

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j accomplishe The startup, low power physics testing, and power i ascension after the outage was closely monitored by the staff and

licensee management. The deliberate and methodical startup g* without problems was indicative of good management contro ; j i @

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H. Outages Analysis During the evaluation period, inspections were performed by the resident and regional staff Refueling activities observed from the control room, refueling floor, and spent fuel pool were found to be satisfactor The licensee commenced the first refueling outage on September 28, 1984. Major activities accomplished during the 83 day outage were completion of the TMI and Licensing Conditions modifications; inspection and maintenance of the main turbine, main generator rotor, and selected valves; selected 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 area 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 turoine five year inspection, rotopeening and 100 percent inspection of the hot leg tube sheet area of all three steam generators, sludge lancing and internal inspection of the steam generator secondary side, modifications to the isophase bus duct, removal of the boron injection tank, equip-ment upgrades for environmental qualification, and Appendix R modification 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 physic The second refueling outage demonstrated that management attention directed toward preventing problems that occurred in the first outage was successfu This outage showed good preplanning, coordination and prior training for the activities that were accomplishe The startup, low power physics testing, and power ascension after the outage was closely monitored by the staff and The deliberate and methodical startup

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licensee managemen l without problems was indicative of good management contro I l

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7 Enclosure

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I III. Licensee Comments I

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Licensee comments submitted in response to the V. C. Summer SALP Board Report follow:

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