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{{Adams | |||
| number = ML20245B045 | |||
| issue date = 12/31/1988 | |||
| title = Final SALP Rept 50-395/88-32 for Aug 1987 to Dec 1988 | |||
| author name = | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000395 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-395-88-32, NUDOCS 8906220361 | |||
| package number = ML20245B038 | |||
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 28 | |||
}} | |||
See also: [[see also::IR 05000395/1988032]] | |||
=Text= | |||
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ENCLOSURE 5 | |||
l' | |||
FINAL SALP REPORT | |||
U. S. NUCLEAR REGULATORY COMMISSION | |||
REGION II | |||
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE | |||
INSPECTION REPORT NUMBER | |||
50-395/88-32 | |||
' SOUTH CAROLINA ELECTRIC AND GAS COMPANY | |||
V. C. SUMMER | |||
August 1, 1987 - December 31, 1988 | |||
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- _ - _ - _ _ _ _ _ _ -_ _ _ _ - _ - I | |||
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TABLE OF CONTENTS | |||
P_ age. | |||
I. INTRODUCTION ..................................................... 2 | |||
A, Licensee Activities ......................................... 2 | |||
B. Direct Inspection and Review Activi ties . . . . . . . . . . . . . . . . . . . . . 4 | |||
II. SUMMARY OF RESULTS ............................................... 4 | |||
O v e r v i e w . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 | |||
.III. CRITERIA ......................................................... 6 | |||
IV. PERFORMANCE ANALYSIS ............................................. 7 | |||
A. P l a n t O pe ra t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 | |||
B. Radiological Controls ....................................... 11 | |||
C. Maintenance / Surveillance .................................... 14 | |||
D. Emergency Preparedness ...................................... 17 | |||
E. S e c u r i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 | |||
F. Engineering / Technical Support ............................... 20 | |||
G. Safety Assessment / Quality Verification ...................... 24 | |||
V. SUPPORTING DATA AND SUMMARIES .................................... 27 | |||
t | |||
A. Escalated Enforcement Action ................................ 27 i | |||
B. Management Conferences ...................................... 27 | |||
C. Review of Licensee Event Reports ............................ 28 | |||
D. Licensing Activities ......................................... 28 | |||
E. Re a c to r T ri p s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 | |||
F. Effluent Release Summary .................................... 30 | |||
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2 | |||
1. . INTRODUCTION- | |||
The Systematic Assessment of Licensee Performance (SALP) program is an | |||
integrated NRC ctaff effort to collect available observations and data on | |||
a periodic basis and to evaluate licensee performance on the basis of this | |||
information. The program is supplemental to normal regulatory processes | |||
used to ensure compliance with NRC rules and regulations. It is intended | |||
to be sufficiently diagnostic to provide a rational basis for allocation | |||
of NRC resources and to provide meaningful feedback to the licensee's | |||
management regarding the NRC's assessment of their facility's performance | |||
in each functional area. | |||
An NRC SALP Board, composed of the staff members listed below, met on | |||
February 21, 1989, to review the observations and data on performance, and | |||
to assess licensee performance in accordance with the quidance in NRC | |||
Manual Chapter-0516. " Systematic Assessment of Licensee Performance." The | |||
guidance and evaluation criteria are sumarized in Section III of this | |||
report. The Board's findings and recommendations were forwarded to the | |||
NRC Regional Administrator for approval and issuance. | |||
This report is the NRC's assessment of the licensee's safety performance | |||
at V. C. Summer for the period August 1, 1987 through December 31, 1988. | |||
The SALP Board for V. C. Sumer was composed of: | |||
C. W. Hehl, Deputy Director, Reactor Projects Division (DRP), Region II | |||
(RII) (Chairman) | |||
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII | |||
D. M. Collins, Acting Director, Division of Radiation Safety and | |||
Safeguards (DRSS), RII | |||
D. M. Verrelli, Chief, Reactor Prc.jects Branch 1, DRP, RII | |||
E. A. Reeves, Acting Director, Project Directorate II-1, Office of Nuclear | |||
Reactor Regulation (NRR) | |||
R. L. Prevatte, Senior Resident Inspector, V. C. Sumer, DRP, RII | |||
J. J. Hayes, Project Manager, Project Directorate II-1, NRR | |||
Attendees at SALP Board Meeting: | |||
F. S. Cantrell, Chief, Project Section 1B, DRP, RII | |||
H. C. Dance, Chief, Project Section 1A, DRP, RII | |||
L. P. Modenos, Project Engineer, Project Section 1B, DRP, RI! | |||
P. C. Hopkins, Resident Inspector, V. C. Summer DRP, RII | |||
P. A. Balmain, Reactor Engineer, Technical Support Staff (TSS), | |||
DRP, RII | |||
A. Licensee Activities | |||
The assessment period was from August 1,1987 to December 31, 1988. | |||
The unit experienced three plant shutdowns and one power reduction | |||
during the 1987 evaluation period. The first shutdown on l | |||
September 2-12, 1987 was initiated by a reactor trip from 100 percent | |||
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power due to a failed main generator bushing. After repair to the { | |||
bushing, a leak was discovered in the main condenser boot seal which | |||
required replacement in order to draw a vacuum. A second shutdown | |||
occurred from September 24-25, 1987, due to a reactor trip caused by 3 | |||
a personnel error made while replacing a faulty power supply in the ' | |||
rod control cabinet. On October 14-17, 1987, power was reduced to | |||
30 percent to allow for containment entry and equipment qualification | |||
inspections of electrical connections on reactor building ccoling | |||
units. | |||
On October 29, 1987, the failure of the primary and backup power | |||
supplies to a Westinghouse 7300 system process rack, due to a faulty | |||
capacitor, resulted in a reactor trip. On October 30, 1987, with the | |||
reactor subcritical and the control rod shutdown banks withdrawn, a | |||
reactor trip occurred while replacing an indicator light in a source | |||
range drawer. The use of an incorrect type bulb resulted in a blown | |||
fuse and resulted in a reactor trip. The unit was restarted on | |||
October 30, 1987, and remained at power through the end of 1987. | |||
During 1987, the unit had a capacity factor of 63.7 percent and a | |||
unit availability factor cf 67.7% including a 93 day refueling | |||
outage. | |||
During 1988, the unit experienced one scheduled shutdown and six | |||
forced power reductions of greater than 20 percent which exceeded | |||
four hours of duration. The first shutdown occurred on February 16, | |||
1988, when 'a technician contacted a loose terminal post inside a | |||
power range channel drawer while performing a test for quadrant power | |||
tilt ratio. This resulted in a reactor trip. The unit remained shut | |||
down from February 16-19, 1988. A defective test switch for the main | |||
steam isolation valve resulted in a reactor trip and subsequent | |||
safety injection during the performance of a surveillance test on | |||
May 12, 1988. After repair, the unit was restarted on May 13, 1988. | |||
On May 27, 1988, power was reduced to approximately 40 percent for | |||
66 hours while repairing condenser tube leaks. On May 30, 1988, power | |||
was again reduced to 40 percent due to out of specification secondary | |||
chemistry and additional condensor tube leaks. While at 40 percent | |||
power, a reactor trip occurred during testing of the B train solid | |||
state protection system. The cause of this trip was evaluated to be | |||
incorrect operation of the main control board reactor trip switch | |||
during reactor trip breaker testing. The main condensor tube leaks | |||
were attributed to the failure of a flexible flange in the extraction | |||
steam lines. Repairs were completed and the unit was returned to | |||
power on June 10, 1988. On July 5-6, 1988, power was reduced to | |||
40 percent for 34.5 hours to allow repairs to the reactor coolant | |||
drain tank pump. On July 26, 1988, the reactor again tripped during | |||
testing of B train solid state protection system. This event is | |||
similar to the event that occurred on June 10, 1988 and was related | |||
to the operation of the main control board reactor trip switch. This | |||
event was attributed to personnel error and the unit was returned to | |||
power on July 28, 1988. | |||
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4 | |||
n September 16, 1988, the plant shut down and entered the fourth | |||
fueling outage. Major work activities in the outage included core | |||
re oad, eddy current examination of 100 percent of the steam | |||
gen ator tubes, tube plugging, equipment qualification upgrades, a | |||
cont nment integrated leak rate test, inservice inspection; and | |||
valve acking replacement. The outage exceeded the planned schedule | |||
of 75 d s by 28 days. | |||
The nuclea operations division was consolidated by relocating the | |||
vice presid t. nuclear operations and the corporate staff to the | |||
V.C. Summer ant in the last quarter of 1987. -The division underwent | |||
a reorganizati in the first quarter of 1988 to reduce the number of | |||
management and upervisory levels. The relocation moves were | |||
supported by con, ructing new administrative and support facilities | |||
and upgrading exis ing ones. | |||
B. Direct Inspection an Review Activities | |||
During the assessment p ,od, routine inspections were performed at | |||
the V. C. Summer facility 3 the NRC staff. Special team inspections | |||
were conducted as follows: | |||
- | |||
Equipment Qualification pections were conducted in October | |||
1987 and January 1988, wi a follow-up inspection conducted in | |||
October 1988. | |||
- | |||
Operational Safety Team Inspe ion was conducted in November and | |||
December 1988. | |||
II. SUMMARY OF RESULTS | |||
Summer was operated in an overall safe manne during the assessment | |||
period. Strengths were identified in the areas f Radiological Controls, | |||
Maintenance and Surveillance. A significant dec ne in performance that | |||
requires additional managerial attention was iden fied in the area of | |||
Security. | |||
Operations performance was mixed. Strengths were not in training of | |||
shifts as a team and the presence of a shift engineer hift technical | |||
advisor on each shift to coordinate shift activities with ther areas and | |||
thereby permit the shift supervisor to concentrate on safe lant operation. | |||
The establishment of the University of Maryland program to tain degrees | |||
for on shift operators represents a substantive management c itment to | |||
. improved shift expertise and safety. Corporate interest and o rsight of | |||
plant activities was very apparent. However, the use of proced es with | |||
known errors and the failure to maintain control room drawings, and | |||
acceptable sistem configuration control at all times indicated a n d for | |||
management attention. Added management attention is also needed to duce | |||
the number of reactor trips. The fire protection area requires additi nal | |||
oversight to preclude repetitious errors that have occurred during th1 | |||
period. | |||
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On September 16, 1988, the plant shut down and entered the fourth | |||
refueling outage. Major work activities in the outage included core | |||
reload, eddy current examination of 100 percent of the steam | |||
generator tubes, tube plugging, equipment qualification upgrades, a | |||
containment integrated leak rate test, inservice inspection; and | |||
valve packing replacement. The outage exceeded the planned schedule | |||
of 75 days by 28 days. | |||
The nue. lear operations division was consolidated by relocating the | |||
vice president nuclear operations and the corporate staff to the | |||
V.C. Summer plant in the last quarter of 1987. The division underwent | |||
a reorganization in the first quarter of 1988 to reduce the number of | |||
management and supervisory levels. The relocation moves were | |||
supported by constructing new administrative and support facilities | |||
and upgrading existing ones. | |||
B. Direct Inspection and Review Activities | |||
During the assessment period, routine inspections were performed at | |||
the V. C. Summer facility by the NRC staff. Special team inspections | |||
were conducted as follows: | |||
- | |||
Equipment Qualification inspections were conducted in October | |||
1987 and January 1988, with a follow-up inspection conducted in | |||
October 1988. | |||
- | |||
Operational Safety Team Inspection was conducted in November and | |||
December 1988. | |||
II. SUMMARY OF RESULTS | |||
Summer was operated in an overall safe manner during the assessment | |||
period. Strengths were identified in the areas of Radiological Controls, | |||
Maintenance and Surveillance. A significant decline in performance that | |||
requires additional managerial attention was identified in the area of | |||
Security. | |||
Operations performance was mixed. Strengths were noted in training of | |||
shifts as a team and the presence of a shift engineer / shift technical | |||
advisor on each shift to coordinate shift activities with other areas and | |||
thereby permit the shift supervisor to concentrate on safe plant operation. | |||
The establishment of the University of Maryland program to obtain degrees | |||
for on shift operators represents a substantive management connitment to | |||
improved shift expertise and safety. Corporate interest and oversight of | |||
plant activities was very apparent. However, the use of procedures | |||
containing errors, the failure to maintain control room drawings, and the | |||
lack of acceptable system configuration control at all times indicated a | |||
need for management attention. Added management attention is also needed | |||
to reduce the number of reactor trips. The fire protection area requires | |||
additional oversight to preclude repetitious errors that have occurred | |||
during this period. | |||
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5 | |||
The Radiological Controls area was considered a strength. The reduction | |||
of contaminated areas to less than one percent was noteworthy. However, | |||
considering the current problems associated with steam generator tube | |||
integrity and failed fuel, the licensee is faced with challenges that | |||
may require innovative approaches if personnel exposure and contamination | |||
is to be maintained as low as reasonably achievable (ALARA). | |||
The maintenance / surveillance program was well implemented and considered a | |||
strength. The reduction in maintenance work order backlog, implementation | |||
of a predictive maintenance program, and operations support to the | |||
planning and scheduling group are considered strengths. The timely | |||
completion of surveillance tests indicates that the testing program was | |||
well staffed and supervised. | |||
Emergency Preparedness activities' were conducted in an adequate manner. | |||
In the area of Emergency Preparedness, the licensee demonstrated an | |||
ability to adequately implement the essential elements of their Emergency | |||
Plan. However, inspection results showed that a weakness identified in | |||
the training of key staff personnel during the previous assessment still | |||
existed. | |||
The Security area, long considered a strength at this site, experienced | |||
several significant problems which resulted in escalated enforcement late | |||
in the assessment period. Organizational changes in 1988 resulted in | |||
deteriorating security force performance. Management was slow to | |||
recognize these changes until personnal performance had decreased to a | |||
marginal level. Significant management attention is required to raise the | |||
performance of this area back to its past level of performance. | |||
The Engineering / Technical Support function was performed well during the | |||
evaluation period. The engineering staff was consolidated and relocated | |||
to the plant site to provide more rapid response to plant problems. | |||
- However, during the assessment period instances of ina6quate engineering | |||
evaluations and a concern with the adequacy of review of contractor | |||
evaluations were identified. The system engineer program which was | |||
established in late 1987 has been slow in being implemented. Additional | |||
management attention may be required to achieve the desired benefits of | |||
this program. | |||
The Safety Assessment / Quality Verification area performance was good. | |||
.0perations, engineering and management involvement in safety issues was | |||
apparent. The licensee continued to pursue and realize positive benefits | |||
from their efforts in safety system functional inspections and development | |||
of system design bases documents. In response to the excessive reactor | |||
trip problem, a root cause identification training program has been | |||
started. Repetitious trips from the main control board reactor trip | |||
switch in 1988 indicate a need for additional management attention in this i | |||
area. QA and QC continue to provide good oversight of safety activities. I | |||
Licensee submittals to the NRC were considered acceptable. | |||
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6 | |||
' | |||
Overview | |||
Rating Last Period Rating This Period | |||
Functional Area 1/1/86 - 7/31/87 8/1/87 - 12/31/88 Trend | |||
Plant Operations 2 2 | |||
Radiological Controls 1 1 | |||
Maintenance / Surveillance 1 1 | |||
Emergency Preparedness 2 2 | |||
Security 1 2 Declining | |||
Engineering / Technical Support NR 2 | |||
Safety Assessment / 2 2 | |||
Quality Verification | |||
III. CRITERIA | |||
! | |||
Licensee performance is assessed in selected functional areas.- depending | |||
on whether the facility is in a construction or operational phase. | |||
Functional areas normally represent areas- significant to nuclear safety | |||
'and the environment. Some functional areas may not be assessed because of | |||
little or no. licensee activities or lack of meaningful observations. | |||
Special areas may be added to highlight significant observations. | |||
The following evaluation criteria were used, as applicable, to assess each | |||
functional area: | |||
1. - Assurance of quality, including management involvement and control; | |||
2. Approach to the resolution of technical issues from a safety | |||
standpoint; | |||
3. Responsiveness to NRC initiatives; | |||
4. Enforcement history; | |||
5. Operational and construction events (including the response, | |||
analyses, reporting, and corrective actions); | |||
6. Staffing (includingmanagement);and | |||
7. Effectiveness of training and qualification program. | |||
However, the NRC is not limited to these criteria and others may have been | |||
used where appropriate. | |||
On the basis of the NRC assessment, each functional area evaluated is | |||
rated according to three performance categories. The definitions of these | |||
performance categories.are as follows: ) | |||
Category 1. Licensee management attention and involvement are readily | |||
evident and place emphasis on superior performance of nuclear safety or | |||
safeguards activities, with the resulting performance substantially | |||
exceeding regulatory requirements. Licensee resources are ample and | |||
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.. | |||
effectively used so that a high level of plant and personnel performance | |||
is being achieved. Reduced NRC attention may be appropriate. | |||
Category 2. Licensee management attention to and involvement in the | |||
performance of nuclear safety or safeguards activities are good. The | |||
licensee has attained a level of performance above that needed to meet | |||
regulatory requirements. Licensee resources are adequate and reasonably | |||
allocated so that good plant and personnel performance is being achieved. | |||
NRC attention may be maintained at normal levels. | |||
Category 3. Licensee management attention to and involvement in the | |||
performance of nuclear safety or safeguards activities are not sufficient. | |||
The licensee's performance does not significantly exceed that needed to | |||
meet minimal regulatory requirements. Licensee resources appear to be | |||
strained or not effectively used. NRC attention should be increased above | |||
normal levels. | |||
The SALP Board may also include an appraisal of the performance trend of a | |||
functional area. This performance trend will only be used when both a | |||
definite trend of performance within the evaluation period is discernable | |||
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 assessment period. | |||
Declining: Licensee performance was determined to be declining near the | |||
close of the assessment period and the licensee had not taken meaningful | |||
steps to address this pattern. | |||
IV. PERFORMANCE ANALYSIS | |||
A. Plant Operations | |||
1. Analysis | |||
During the assessment period routine and special inspections | |||
were performed by the NRC staff. The fire protection program | |||
was examined by a special inspect ton in February,1988 and an | |||
Operational Safety Team Inspection (OSTI) was conducted in | |||
November and December, 1988. | |||
The operations group is well staffed with five shifts that stand | |||
12 hour watches. Each shift includes a shift engineer / shift I | |||
technical advisor, shift supervisor (SRO), control room | |||
supervisor (SRO), reactor operator (SR0/RO), a first and second | |||
assistant operator who may be SR0/R0 or in training for a | |||
license and five to six auxiliary operators. All shift | |||
engineers are degreed and six of eight possess SR0 licenses. | |||
The remaining two are currently in training for SR0 licenses. | |||
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a. ** | |||
8 | |||
he shifts train and operate together as a team. The shift | |||
l, | |||
e ineer coordinates all shift support functions and thereby | |||
fr s . the shift supervisor to concentrate on -safe plant | |||
ope tion. The reactor operators and first and second assistant | |||
oper ors routinely rotate from the control room to auxiliary | |||
opera r watch stations to maintain their proficiency-' and | |||
utilize their experience throughout the plant. The licensee has | |||
experien d only negligible personnel turnover in this area. | |||
To- improve educational and engineering expertise on shift, | |||
management . itiated a college degree program for licensed | |||
operators in 987. This program is conducted by the University | |||
of Maryland an $ffers a Bachelor of Science degree in Nuclear | |||
Science. Thirt 4o of the forty initial candidates are still | |||
participating in program. Any nuclear operations personnel | |||
may participate in is program; however, licensed operators and | |||
license candidates | |||
ggivenpriority. | |||
Administrative contro to ensure control room professionalism | |||
were established and a effective. Access to the at-the-control | |||
area is limited and we 1 controlled. Operator logs were | |||
legible and complete w1 h normal conditions, off-normal | |||
conditions, special tests and events identified. Preshift | |||
briefings were conducted an4 shift turnover forms were used by | |||
all operators. Watchstander and duty technician assignments | |||
were clearly posted in the c trol room. Key controls for | |||
operator access to spaces and quipment were well organized. | |||
Operator response to off-normal nditions and plant transients | |||
was prompt and thorough. This wa exemplified during a loss of | |||
reactor coolant letdown event that ccured in 1988. The rapid | |||
identification of an incorrect cont 1 signal resulted in the | |||
operator transferring control of let wn from the main ontrol | |||
board to the remote shutdown panel an thereby bypassing the | |||
faulty control circuit. This timely re onse prevented a plant | |||
shutdown. The licensee has initiated a ogram to enhance the | |||
black board concept for alarm annunciators | |||
The OSTI identified instances where addi 'onal licensee l | |||
attention was needed tc control valve and rcuit breaker | |||
alignment limiting conditions for operation (LCO), and | |||
legibility of control room essential drawings. e licensee was | |||
very responsive in revising LC0 procedures to duce the | |||
potential for reliance on inoperable systems and - corporating | |||
procedural steps to require independent verificati of valve | |||
and circuit breaker positions. System walkdowns the | |||
OSTI team members identified numerous technical nd | |||
typographical errors in existing system operating proce res and , | |||
attachments used for valve and breaker alignments. hse | |||
l | |||
procedures had been implemented and issued to the field fc use, | |||
without a good review, or validation. It was anticipated la t l | |||
operators would make the needed corrections while accomplis | |||
' | |||
ng | |||
system lineups and verification of lineups. One illegible i | |||
E______---____--_--.___---.--.------ - _ - - - - - - _ - - - -- - - - - - - - - - - - - - -- - J | |||
., , *. | |||
1 | |||
8 | |||
The shifts train and operate together as a team. The shif t | |||
engineer coordinates all shift support functions and thereby | |||
frees the shift supervisor to concentrate on safe plant | |||
operation. The reactor operators and first and second assistant | |||
operators routinely rotate from the control room to auxiliary | |||
operator watch stations to maintain their proficiency and | |||
utilize their experience throughout the plant. The licensee has | |||
experienced only negligible personnel turnover .n this area. | |||
To improve educational and engineering . expertise on shift, | |||
management initiated a college degree program for licensed | |||
operators in 1987. This program is conducted by the University | |||
of Maryland and offers a Bachelor of Science degree in Nuclear | |||
Science. Thirty-two of the forty initial candidates are still i | |||
participating in the program. Any nuclear operations personnel | |||
may participate. in this program; however, licensed operators and | |||
license candidates are given priority. | |||
Administrative controls to ensure control room professionalism | |||
were established and are effective. Access to the at-the-control | |||
area is limited and well controlled. Operator logs were | |||
legible and complete with normal conditions, off-normal | |||
conditions, special tests and events identified. Preshift | |||
briefings were conducted and shift turnover forms were used by | |||
all operators. Watchstanders and duty technician assignments | |||
were clearly posted in the control room. Key controls for | |||
operator access to spaces and equipment were well organized. | |||
Operator response to off-normal conditions and plant transients | |||
was prompt and thorough. This was exemplified during a loss of | |||
reactor coolant letdown event that occured in 1988. The rapid | |||
identification of an incorrect control signal resulted in the | |||
operator transferring centrol of letdown from the main control | |||
board to the remote shutdown panel and thereby bypassing the | |||
faulty control circuit. This timely response prevented a plant | |||
shutdown. The licensee has initiated a program to enhance the | |||
black board concept for alarm annunciators. | |||
The OSTI identified instances where additional licensee | |||
attention was needed to control valve and circuit breaker | |||
alignment limiting conditions for operation ( LCO) , and | |||
legibility of control room essential drawings. The licensee was | |||
very responsive in revising LCO procedures to reduce the | |||
potential for reliance on inoperable systems and incorporating | |||
procedural steps to require independent verification of valve | |||
and circuit breaker positions. System walkdowns by the | |||
OSTI team members identified numerous technical and | |||
typographical errors in existing system operating procedures and | |||
attachments used for valve and breaker alignments. These | |||
procedures had been implemented and issued to the field for use, , | |||
without a good review, or validation. Operators had to make | |||
the needed corrections while accomplishing system lineups and | |||
verification of lineups. One illegible drawing was identified | |||
1_ ____ _ | |||
__ | |||
l | |||
:.. .- | |||
I | |||
j | |||
c | |||
9 l | |||
! | |||
i | |||
during the OSTI inspection; a resulting followup review by the 'l | |||
licensee identified 28 ~ additional drawings with inadequate or | |||
marginal clarity. These items were the subject of violation b. | |||
j l | |||
below. | |||
Over the assessment period, plant housekeeping was considered | |||
average. The control room and main control board were repainted | |||
and new carpet was installed during the 1983 refueling outage. | |||
In general plant areas, a program to upgrade painting, | |||
appearance and protective coatings has resulted in an ' improved | |||
appearance. However, it is noted that the number of leaks from | |||
non-radioactive and radioactive systems, although wrapped with | |||
herculite and routed to drains, have . increased. Operation | |||
should pursue the timely correction of these deficiencies. | |||
Regular plant tours are accomplished by the Vice president | |||
Nuclear Operations, the plant manager and the plant ranager's | |||
staff. Corporate interest and oversight of the plant was | |||
evident from frequent visits and plant tours by senior | |||
management. Monthly trend reports and performance indicators | |||
are published to keep plant and corporate management appraised | |||
of plant status and potential plant.probl' ems. | |||
The plant capacity factor for the SALP period was 72.4 percent | |||
even with a 103 day refueling outage at the end of 1988. A | |||
comparison with the previous SALP shows that the unit forced | |||
outage rate increased from 4.01 to 6.20 percent. The outage | |||
rate-is above the industry mid 1988 one year median of 4.8. The | |||
reactor trips, when compared with the previous SALP increased | |||
from seven to eight. The trip rate, even though some improve- | |||
ment was shown in 1988, is still above the industry one year | |||
median of approximately two. A review of the reactor trips | |||
' | |||
determined that four trips were related to equipment failure, | |||
two trips were due to equipment design and two trips were the | |||
result of personnel errors. Five of eight trips occurred during | |||
the performance of surveillance tests. | |||
Management responded to the excessive reactor trip problem by | |||
initiating actions to improve labelling of procedural steps that | |||
present trip hazards and providing dditional technical training | |||
on surveillar.ce tests which expose the unit to high trip risk. l | |||
Studies are <:urrently underway to justify a reduction in | |||
periodicity of high trip potential surveillance. | |||
The adequacy of the licensee's post trip reviews was questioned | |||
in May 1988 as the result of a reactor trip and reduced service | |||
water flow to the reactor building cooling units during a | |||
subsequent safety injection. The reduced service water flow | |||
problem was not detected during the post trip review. The | |||
- _ _ _ _ _ _ - _ _ _ - . _ _ _ | |||
_ _ _ | |||
,, . i | |||
l | |||
' | |||
10 | |||
I | |||
diligence of the Independent Safety Evaluation Group resulted in | |||
the identification of this problem after the plant restarted. | |||
This item was the subject of a severity level III violation 3 | |||
i | |||
issued in August 1988. (See violation a. below). | |||
A problem was identified on the previous SALP concerning the | |||
correct alignment of swing pumps. The corrective actions taken | |||
and discussed in the previous SALP appeared to be effective and | |||
no new or repeat problems were identified in this area. | |||
Control of combustible and flammable materials in safety related | |||
related areas of the plant was considered good. An identified | |||
exception included an area in the auxiliary building where | |||
approximately 4.5 tons of combustible charcoal had been | |||
temporarily stored. (See violation g below). | |||
The required drills and training of Fire Brigade members were | |||
conducted within the frequency outlined in plant procedures. | |||
Satisfactory performance of the Fire Brigade in an unannounced | |||
drill witnessed by NRC staff demonstrated the effectiveness of | |||
the Fire Brigade training program. | |||
The licensee has experienced events where compensatory fire | |||
watches were not established for degraded fire barriers or | |||
inoperable fire e These events were the subject of | |||
five violations (quipment. | |||
c through g) and five LER's during the | |||
evaluation period. Extensive management attention was directed | |||
to this area. A Fire Protection Officer was placed on each | |||
operating shift to monitor and provide improved response for | |||
degraded fire barriers and protection equipment. This single | |||
point accountability had additionally resulted in improved | |||
communications and better equipment status control. | |||
Staffing in the fire protection area increased in 1988 from a | |||
fire protection supervisor and five technicians to a fire i | |||
protection supervisor; a fire protection coordinator; two | |||
specialists who supervise fire protection officers and | |||
surveillance testing; three technicians and five operation shift | |||
fire protection officers. These changes occurred in the last | |||
quarter of 1988 and have not been implemented long enough to | |||
allow full evaluation. | |||
Seven violations were identified of which five involved | |||
inadequate fire protection or compensatory actions. | |||
L a. Severity level III violation for making a mode change with | |||
{ both trains of RBCU's inoperable. (395/88-13-01) | |||
t | |||
b. Severity level IV violation for illegible control room | |||
! drawings and incorrect valve lineup procedures. | |||
l (395/88-26-03) | |||
l | |||
l | |||
.________ _ | |||
E | |||
j, , | |||
' .. _' l | |||
" | |||
11 | |||
c. Severity level IV violation for failure to take adequate | |||
compensatory action for inoperable fire detection | |||
equipment. (395/88-24-01) | |||
, | |||
d. Severity level IV violation for failure to take adequate | |||
, | |||
compensatory action for inoperable fire detection equipment | |||
and a breached fire barrier. (395/88-03-01) | |||
e. Severity level IV violation for failure to take adequate | |||
L compensatory action for inoperab'e fire suppression | |||
; equipment. (395/88-10-01) | |||
f. Severity level IV violation for failure to take adequate | |||
action for | |||
equipment. compensatory (395/88-19-01) inoperable fire detection | |||
g. Severity level IV violation for failure to establish | |||
adequate compensatory fire protection measures for | |||
increased transient fire loading due to temporary storage | |||
of 4.5 tons of combustible charcoal and for-failure to have | |||
an important procedure at a control panel. (395/88-26-01) | |||
2. Performance Rating: | |||
I | |||
Category: 2 Previous rating - Operation: 2 | |||
Fire Protection: 2 | |||
3. Recommendations: | |||
Management support of operations needs to be improved. This | |||
need is indicated by procedures being issued that still contain | |||
errors that should have been identified by a procedure | |||
review / verification program. Another indication is control room | |||
drawings issued for operations use when numerous drawings were | |||
illegible. Operations personnel need to be more aggressive in | |||
raising these type problems to management's attention and in | |||
pursuing a satisfactory resolution of identified problems. | |||
B. Radiological Controls | |||
1. Analysis | |||
During the assessment period, inspections were performed by the | |||
resident and regional inspection staffs. Inspections were | |||
conducted in the areas of radiation protection, radiological ' | |||
effluents, and confirmatory measurements. | |||
During the assessment period, the licensee reorganized the | |||
chemistry and Health Physics departments in the first quarter of | |||
1988. A chemistry and health physics manager position was | |||
established and filled with a former corporate health physicist. | |||
1 | |||
4 | |||
_ _ _ _ . - - _ _ _ _ - - _ _ . _ . . | |||
___- -_ - - | |||
J g :.. . | |||
t | |||
i | |||
k/ < | |||
-12 | |||
The - former . Manager .of Technical and Support Services at the- | |||
.~ plant was assigned to the position .of. Corporate Manager of | |||
Health ~ Physics.: The licensee also-established the position of | |||
, Radwaste Coordinator and filled the_ position with an engineer | |||
< | |||
who had been serving as a shift technical advisor. | |||
The;11censee's' health physics (HP) and radwaste staffing levels | |||
. | |||
appear; to be slightly lower than other. utilities having a | |||
, facility of similar size. In additior. .to the regular plant HP | |||
technicians,.-the licensee retains 14 ' to 16 contract HP | |||
technicians to augment the HP staff for routine operations. The | |||
smaller-permanent staff has not had any deleterious' effects on | |||
the performance of the HP staff. Tha knowledge'and experience | |||
' level' off the HP- staff were excellent. The overall quality of | |||
the staff was a program strength. | |||
Radiation protection training was considered good. .The. | |||
licensee's general, employee training in radition protection was | |||
well defined. The licensee enhanced training by establishing a | |||
training program for HP supervisors. 'Since this program is in | |||
addition to regulatory requirements, it -indicates management's | |||
support for and commitment to high training standards. | |||
Management support and involvement in . matters related to | |||
radiation protection were demonstrated by upgrading the whole | |||
body counters with germanium detectors and the procurement;of a | |||
standup whole body counter. . Inspection during the evaluation | |||
period indicated that the . radiation protection program received | |||
strong support from other plant departments. | |||
At the.end of 1988, the contaminated area of the plant was less | |||
than one percent of the total . areas monitored. Ma licensee's | |||
aggressive -contamination control program allows plant personnel | |||
to . access containment without protective clothing. Resulting | |||
benefits are a reduction in the amount of radioactive waste | |||
generated and less restrictions on workers and supervisors | |||
during performance of their assigned tasks. | |||
In 1987, the collective dose was 562 person-rem with 547 | |||
person-rem being attributed to a refueling outage and | |||
maintenance on steam generators. In 1986, the collective dose | |||
was'23 person-rem, however, there were no outages in 1986. In | |||
1988, the licensee expended 18 person-rem for normal operations | |||
and 503 person-rem for outage related work. Primary | |||
contributors to the high collective dose in the last two years | |||
have been the increase in reactor coolant system (RCS) | |||
radioactivity and increased steam generator maintenance. In | |||
some high traffic areas of the plant radiation in the residual | |||
heat removal-(RHR) lines has caused dose rates in adjacent areas | |||
to increase by a factor of 20. Significant increases in dose | |||
rates'were also observed during reactor head work, fuel movement | |||
_ - _ _ _ _ ____ _ _ _ __ _- - _____ _ _ | |||
_ _ | |||
y ...- | |||
. | |||
-e 13 | |||
and reactor cavity decontamination. The collective doses' for | |||
1987 and 1988 are representative for plants experiencing steam | |||
generator and fuel problems. | |||
.The licensee has a number of initiatives underway to limit and | |||
reduce dose rates within the plant including elimination of the | |||
resistance temperature detector bypass- manifold, evaluation of | |||
the replacement of primary system filters with smaller mesh | |||
filters to reduce the particulate in the RCS, evaluation of | |||
raising the pH of the RCS, and chemical decon of various | |||
RHR/RCS-systems and/or components in 1989. | |||
The licensee's respiratory protection and radiation work permit | |||
programs .were found to be satisfactory. The licensee | |||
experienced a total of 130 personnel contaminations in 1987, l | |||
76 skin contaminations and 54 clothing contaminations. In 1988, | |||
the number of personnel contaminations increased 240 percent to | |||
141 skin and 171 clothing contaminations. The licensee | |||
experienced 52 discrete radioactive particle contaminations in | |||
1988, due' to failed fuel and the increased amount of system | |||
-maintenance. Previously, the licensee had only three hot | |||
particle contaminations with the majority of the particles being | |||
fission products. The licensee has an aggressive program for | |||
the identification and control of discrete radioactive | |||
particles. | |||
During the assessment period, the licensee contracted with a | |||
vendor to perform super compaction of dry radioactive waste to | |||
reduce the volume of dry radioactive waste shipped to a low | |||
level waste burial facility. | |||
Participation in the NRC spiked sample analysis program for beta | |||
emitting radionuclides showed agreement with NRC results for all | |||
four nuclides. | |||
Liquid and gaseous effluents were within regulatory limits for | |||
concentrations of radioactive material releases. There were | |||
slightly increasing trends in the annual quantities of | |||
radioactive material effluent releases for the past three years. | |||
Annual effluent releases are summarized in the Supporting Data | |||
L | |||
and Summaries, Section V.K. Licensee estimates of doses to | |||
. | |||
maximum exposed individuals were well below the limits in the | |||
L technical specifications. | |||
Radiological audits and surveillance conducted by the licensee | |||
were comprehensive and sufficiently in-depth to identify problem | |||
areas and trends. Management was responsive to the problems | |||
identified. ' | |||
1 | |||
No violations or deviations were identified. | |||
L | |||
. - _ _ _ - _ _ _ - | |||
- _ - - | |||
L . ,~ .... | |||
H, | |||
y | |||
l 14 | |||
l | |||
2. Performance Rating | |||
') | |||
Category: 1 Previous rating: 1 | |||
3. Recommendations | |||
The Board recognized your continuous high level of performance | |||
in this area. The Board does note that there have been | |||
increases in fuel leakage in the recent past with the resultant | |||
potential for increase in radiation levels and contamination. | |||
The Board recommends you continue a high level of management | |||
attention to this area because of this increased challenge. | |||
C. Maintenance / Surveillance | |||
1. Analysis | |||
During the assessment period routine and special inspections | |||
were performed by the NRC staff. Equipment Qualification (EQ) | |||
team inspections were conducted in October 1987, January 1988, | |||
and October 1988. A Containment Integra.ted Leak Rate Test | |||
(CILRT) inspection was conducted in September, 1988. An OSTI in | |||
November and December 1988, evaluated maintenance support of | |||
operations. | |||
The maintenance organization is adequately staffed and trained | |||
to support operation of the plant. The staff is supplemented by | |||
contractors, as needed, to support plant outages. This unit has | |||
experienced a very low turnover of maintenance personnel. | |||
The corrective maintenance and preventive program was planned | |||
and performed in accordance with established procedures. | |||
Supervisors provided adequate direction and assistance, as | |||
needed, to complete activities. QC provided adequate coverage | |||
of safety related activities. Maintenance activities were | |||
scheduled and tracked with a history maintained by computerized | |||
systems. | |||
The predictive maintenance program used vibration analysis, | |||
temperature monitoring, ferrography (lube oil), infrared surveys | |||
and motor operated valve analysis and tests systems (M0 VATS) to | |||
determine the need for equipment maintenance. Success | |||
experienced in this program included vibration monitoring of the | |||
main feed pumps which led to early identification and correction | |||
of coupling grease loss and alignment problems. The use of | |||
vibration analysis and ferrography on the reactor coolant pumps | |||
(RCP) permitted the licensee to extend the scheduled maintenance | |||
on "B" RCP to refueling outage 5. This extension will allow | |||
concurrent motor tear down and seaI replacement on the RCP's for | |||
-__ _ _ _ _ _ _ _ _ _ | |||
_ _ _ _ _ - _ _ _ _ _ | |||
., . | |||
15 | |||
11 future outages. The M0 VATS equipment has been upgraded and | |||
t e data bank has been expanded to approximately 80 percent of | |||
th installed motor operator valves. | |||
The erations Section of Scheduling was staffed with three SR0s | |||
and on R0. The application of licensed expertise was a strong | |||
point i the maintenance scheduling process. Another strong | |||
point wa the daily preparation of a " trip package" which | |||
contained lanned maintenance activities requiring a duration of | |||
less than ight hours to perform. Additionally, a "short | |||
duration out e package" was also planned for those activities | |||
which could b completed in the event plant trip recovery took | |||
longer than ei t hours but less than 72 hours. | |||
A weakness was i ntified in the previous SAll' in the area of | |||
first line superv ory involvement on planning and directing | |||
maintenance activit s. Management has provided team building ' | |||
and additional trai ' to those supervisors. The shift | |||
engineer program has so improved operations interface with | |||
maintenance activities. However, it is still evident from the | |||
excessive time required complete some task, such as M0V | |||
lubricant change and dur the refueling outage, that first | |||
line supervisors are stil ot sufficiently involved in work | |||
planning activities. Altho this weakness was noted, and it | |||
is apparent that licensee se eduled more work than they were | |||
able to accomplish during the time allotted for the fourth | |||
refueling outage, they are comm ded for not cancelling scheduled | |||
work, and for extending the outa to insure that essential work , | |||
was completed. | |||
During a Phase I review of Environm tal Qualification (EQ) of | |||
Electrical Equipment in January 1988, a problem was identified | |||
in the area of EQ maintenance. The EQ aintenance rcanirements | |||
for the lubrication of the Emergency F dwater Pump were not | |||
accomplished for two consecutive 12 mont periods. In response | |||
to the violation "c" below, the licensee rformed an indepth | |||
review of all EQ maintenance requirements a d incorporated the | |||
requirements into a comprehensive EQ Mainten nce Manual which | |||
will schedule specific maintenance task over o tage periods. | |||
A maintenance self-assessment program using INP0 utdelines was | |||
completed by the licensee in March 1988. Base upon that , | |||
assessmat the licensee concluded that they met he INPO | |||
criteria through their established programs. A sma' number of | |||
weaknesses were identified in the area of planning an outages. | |||
l | |||
These items have been assigned to a task manager to nsure | |||
l timely completion. . | |||
! | |||
l The maintenance backlog contained approximately 600 mainte nce l | |||
work requests (MWR) at the end of the SALP period. The bac og | |||
had been reduced by approximately 20 percent in the past 1 | |||
months. Nonoutage MWR's that are over three months old are | |||
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . | |||
_ | |||
... .. | |||
'.. | |||
l | |||
15 | |||
all future outages. The M0 VATS equipment has been upgraded and | |||
the data bank has been expanded to approximately 80 percent of | |||
the installed motor operator valves. | |||
The Operations Section of Scheduling was staffed with three SR0s | |||
and one R0. The application of licensed expertise was a strong | |||
point in' the maintenance scheduling process. Another strong | |||
-point was the daily preparation of a " trip package" which | |||
contained planned maintenance activities requiring a duration of | |||
less than eight hours to perform. Additionally, a "short | |||
duration outage package" was also planned for those activities | |||
which could be completed in the event plant trip recovery took | |||
longer than eight hours but less than 72 hours. | |||
A weakness was identified in the previous SALP in the area of | |||
first line supervisory involvement in planning and directing | |||
maintenance activities. In response to this item, management | |||
implemented additional training and a team building program for | |||
those supervisors. The shift -engineer program has lead to | |||
improvement in operations and maintenance. work and | |||
communications interface. However, it is apparent- from the | |||
increased amount of time taken to complete scheduled outage | |||
work, that adequate input from the field and feedback to the | |||
work scheduling process are not being considered in. | |||
establishing schedules. 'The time allotted for MOV lubricant | |||
changeout during the outage, far exceeded the time allotted. | |||
Improved use of maintenance history data for task time | |||
requirements and training exercises on new tasks could provide | |||
more realistic . planning data. Although this weakness was | |||
noted, the licensee is comended for not cancelling scheduling | |||
work, and extending the outage to insure that essential work | |||
was completed. | |||
During a Phase I review of Environmental Qualification (EQ) of | |||
Electrical Equipment in January 1988, a problem was identified | |||
in the area of EQ maintenance. The EQ maintenance requirements | |||
for the lubrication of the Emergency Feedwater Pump were not | |||
accomplished for two consecutive 12 month periods. In response | |||
to the violation "c" below, the licensee performed an indepth | |||
review of all EQ maintenance requirements and incorporated the | |||
requirements into a comprehensive EQ Maintenance Manual which | |||
will schedule specific maintenance task over outage periods. | |||
A maintenance self-assessment program using INP0 guidelines was | |||
completed by the licensee in March 1988. Based upon that | |||
assessment the licensee concluded that they met the INP0 | |||
criteria through their established programs. A small number of | |||
weaknesses were identified in the area of planning and outages. | |||
These items have been assigned to a task manager to ensure l | |||
timely completion. { | |||
The maintenance backlog contained approximately 600 maintenance | |||
work requests (MWR) at the end of the SALP period. The backlog | |||
had_been reduced by approximately 20 percent in the pas,t 18 | |||
_ _ _ | |||
. _ - _ _ _ _ - _ _ -- | |||
! | |||
16 | |||
! | |||
trended for management attention. The timely review of the MWR | |||
backlog and the relatively small number of MWRs older than three | |||
months were considered strengths. | |||
The licensee's overall CILRT program was conducted in a | |||
controlled and acceptable manner. The CILRT showed evidence of | |||
. prior planning and management. involvement in the use of detailed | |||
-O test controls and experienced leak rate test consultants. A | |||
conservative approach to . technical issues was observed in the | |||
resolution of instrumentation and leakage problems encountered | |||
during the performance of the test. The conduct and quality of | |||
the testing was acceptable. Surveillance test records were | |||
complete, legible, and readily retrievable. Local leak rate .' | |||
test personnel were well qualified for their job functions and | |||
were knowledgeable in procedural and regulatory requirements. | |||
Staffing in this area was adequate for the level of activity. | |||
. The instrument calibrations facility was found to have well | |||
organized records and well maintained and calibrated equipment. | |||
The licensee's control, issue and accountability of tools showed | |||
a significant improvement during the recent refueling outage. | |||
Tools were more readily available for work performance. | |||
Approximately 9,000 surveillance were conducted during the SALP | |||
period and only two were not documented as have being completed | |||
within the prescribed time limits. Both of the' tests were on | |||
the diesel fire pump batteries. These deficiencies were | |||
identified and corrected by the licensee in a timely manner. | |||
These results indicate a strong and effective program with good | |||
management oversight of this area. However, it is noted that | |||
five of the eight reactor trips occurred during surveillance | |||
tests. Three violations were identified. | |||
a. Severity Level IV violation for failure to properly | |||
implement Administrative Procedure SAP-134 thereby | |||
performing an inadequate post-test review of test results | |||
for surveillance test procedure STP-210.002. | |||
(395/88-07-01) | |||
b. Severity Level IV violation for failure to maintain plant | |||
procedures which provide instructions for operation of the | |||
service water "A" pumps screen wash pump and traveling | |||
l | |||
screen. (395/88-15-01) | |||
c. Severity Level V violation for failure to perform EQ ' | |||
maintenance requirements for lubrication of the emergency i | |||
feedwater pump for two consecutive twelve month periods. l | |||
(395/88-01-01) | |||
: | |||
_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
_ _ _ _ -. . _ _ _ ___ _ __ _____ __ _ _J | |||
_ _ _ _ _ _ _ - _ - _ | |||
' | |||
i | |||
,,, .. | |||
17 | |||
2. Performance Rating | |||
Category: 1 Previous rating - Maintenance: 1 Surveillance: 1 | |||
3. Recommendations | |||
D. Emergency Preparedness | |||
1. Analysis | |||
The inspections conducted during this assessment period by NRC | |||
staff included one routine EP inspection in M6y 1988, and an | |||
Emergency Response Facility (ERF) Appraisal conducted in March | |||
1988. | |||
Based on the inspection activity noted above, the licensee | |||
demonstrated an ability to adequately implement the essential ; | |||
elements of the Summer Emergency Plan during a simulated or | |||
' | |||
actual emergency event. However, declining performance in the | |||
area of Emergency Plan required trair.ing was identified as noted ! | |||
below. | |||
The routine inspection, conducted in May 1988, disclosed a | |||
recurrent licensee problem involving the failure to follow their | |||
Emergency Plan with re. sect to requirements for training. A | |||
violation was identifieo for failure to provide required | |||
training to two key members (Radiological Assessment Supervisor | |||
and Maintenance Supervisor) of the onsite emergency organization | |||
assessment staff in accordance with Emergency Plan procedures. | |||
The licensee's planned corrective action appeared adequate. All | |||
other training of key members of the emergency organization | |||
appeared to be consistent with approved procedures. However, a | |||
similar violation was identified during the preceding assessment | |||
period involving training of key members of the emergency | |||
organization on the fission product barrier approach to | |||
emergency event classification. | |||
During the ERF Appraisal walkthroughs, a Shift Supervisor made | |||
an untimely event classification, as well as an incorrect | |||
emergency declaration in response to a postulated casualty | |||
presented by the inspector. It was noted that an artificiality | |||
in the scenario may have been a contributing factor. However, | |||
the licensee acknowledged that improvements were needed in the | |||
Emergency Plan training program. The General Manager for | |||
Operations connitted to provide additional training for | |||
Emergency Directors to include, as a minimum, event | |||
classification and protective action recommendations. | |||
The March 1988 ERF Appraisal disclosed that the emergency | |||
i response facilities, including the Control Room, Technical | |||
' | |||
Support Center (TSC), and Emergency Operations Facility (EOF), | |||
fully met the regulatory criteria, orders, and license | |||
- _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
_ _ _ _ _ _ _ _ _ | |||
.u. ,. | |||
I i | |||
f l | |||
L 18 j | |||
I | |||
) | |||
conditions issued to implement Supplement 1 to NUREG-0737. The | |||
ERFs provided all necessary equipment, systems, documents, and | |||
supplies to assist the licensee in the identification and 1 | |||
mitigation of plant emergency events, and implemented all | |||
elements of the Emergency Plan required to protect onsite | |||
personnel and the public within the assigned emergency planning | |||
zone. | |||
The licensee maintains the ERFs, and all equipment and systems 4 | |||
therein, in an adequate state of operational readiness for | |||
responding to emergencies.. The licensee also established an | |||
effective management and control program fer the Early Warning | |||
Siren System, and installed a redundant transmitter and encoder | |||
for the . system. Shift staffing augmentation appeared to be ; | |||
i | |||
consistent with regulatory requirements and guidance. Although | |||
no violations were identified during the Appraisal, the licensee | |||
committed to review several dose assessment followup items and | |||
to provide a response. The licensee's response has been reviewed | |||
and determined to be acceptable. | |||
During the assessment period, five revisions were submitted to | |||
'the Emergency Plan for NRC review and approval. The proposed | |||
revisions were determined to be consistent with regulatory | |||
requirements and guidance. | |||
One violation was identified. Although the finding was not | |||
indicative of a significant programmatic breakdown in the EP | |||
program as a whole, it is clear that performance in Emergency | |||
Plan required training has declined. The licensee continued to | |||
demonstrate overall the capability to fully implement key | |||
elements of the Emergency Plan during simulated or actual plant | |||
emergency events. | |||
a. Severity Level IV violation for failure of two key members | |||
of the onsite emergency response organization to complete | |||
training in accordance with Emergency Plan Procedure | |||
EPP-018, Emergency Training and Drills. (395/87-23) | |||
2. Performance Rating | |||
Category: 2 Previous rating: 2 | |||
3. Recommendations | |||
The Board note: that during an inspection after the close of the | |||
assessment period (in January 1989) there was another finding of | |||
failure to provide training to members of the emergency response | |||
team. We encouragt. licensee management to give increased | |||
emphasis to emergency response training and retraining and | |||
recommend increased NRC inspection resources be provided in this | |||
area. | |||
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' | |||
p . 29 | |||
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'l | |||
E. -Security | |||
l | |||
1. ' Analysis | |||
Two routine and one reactive inspections were conducted by the | |||
.NRC staff. | |||
~ | |||
The licensee - expended extensive resources ~ in constructing a | |||
secondary access portal, installing a new security computer, a | |||
new access control system, a' new . secondary alarm station. | |||
upgrading the closed circuit TV system and central alarm station | |||
- | |||
and providing additional protection for the secondary power | |||
supply system. | |||
Historically, this licensee has been one of the Region's | |||
+ ' outstanding . security performers. The problems discussed below | |||
became' apparent during the last half of the rating period. | |||
The ' security organizat'on, after the loss of- the security | |||
manager and the captain in charge of security personnel in late | |||
1987,.was reorganized and incorporated into the Nuclear Protec- | |||
tion Service lwith a new manager, associate manager and several | |||
supervisory changes brought about by attrition. . Changes in | |||
management, supervision style and philosophy were not readily | |||
accepted by the security force. Management was also slow in | |||
recognizing situations which resulted in a deteriorating | |||
security morale and perfonnance. As a result, certain viola- | |||
tions were. identified in the latter part of the SALP period _and- | |||
an Enforcement Conference was held on January 6, 1989 to discuss | |||
the following items: failure to control access .to vital and | |||
protected areas; failure to control access to the | |||
area; failure to control access to a vital area (protected | |||
sleeping | |||
guard); failure to rotate locks and cores after terminating | |||
- members of the security force; failure to implement contingency | |||
- | |||
measure; inadequate perimeter intrusion detection system; and | |||
. inadequate-reporting of safeguards events. | |||
Serious management attention to these weaknesses was provided | |||
after.this series of events which occurred in the last quarter | |||
of 1988. These events and a resulting NRC inspection indicated | |||
that security performance in the area of personnel access | |||
control had reached a level of marginal performance. | |||
The repetitive access control violations indicate: a. breakdown | |||
in the supervisory oversight of the security force; a failure on | |||
the part -of the security force to recognize and correct | |||
problems; and a failure of management to implement effective | |||
corrective measures. The root cause analyses for the first | |||
access control problem was not effective in preventing recur- i | |||
rence. Management also demonstrated a lack of familiarity with ! | |||
basic security requirements as evidenced by the failure to | |||
e | |||
_ _ . _ _ _ _ . _ . _ - _ _ - - . _. | |||
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. | |||
,3 ... | |||
20 | |||
search a vital area when the security force member posted to | |||
control area access was discovered asleep. Further examples of | |||
lack of. familiarity with requirements was evident when the | |||
licensee failed to rotate security locks following the | |||
termination of members of the security' force on several | |||
occasions. | |||
Although the licensee employs a dedicated security maintenance | |||
staff, a lack of attention to detail.a lack 'of technical | |||
< | |||
' expertise or incorrect implementation of regulatory | |||
requirements, was' found by the NRC in the areas of intrusion | |||
detection equipment. Critical self-assessment was lacking, | |||
therefore problems were not identified at an early stage. | |||
After initial identification of the above problems, the licensee | |||
responded by assigning a new General Manager Station Support and | |||
redefinition of responsibilities for licensee and contractor | |||
employees has been implemented. | |||
I | |||
One violation was identified during this assessment period. | |||
.However, subsequent to the end of the assessment period, | |||
escalated enforcement action involving multiple examples of | |||
security deficiencies was issued. | |||
a. Severity level IV violation for inadequate perimeter | |||
intrusion detection capability. (395/87-31-01) | |||
2. Performance Rating | |||
Category: 2 (Declining) Previous rating: 1 | |||
-3. Recommendations | |||
The Board has noted that during the first half of this SALP | |||
period the licensee enjoyed a favorable security program without . | |||
the negative impact of enforcement issues. However, a serious | |||
degradation during the second half of this SALP period that | |||
could result, if unchecked, in a SALP 3 rating. In order to | |||
alleviate this situation the Board recommends that a high level | |||
of management attention continue to be given to this program | |||
area. | |||
F. Engineering / Technical Support | |||
1. Analysis | |||
The Engineering Technical Support functional area addresses the | |||
adequacy of technical and engineering support for all plant | |||
activities. To determine the adequacy of support provided, | |||
specific attention was given to the identification and resolu- | |||
tion of technical issues, responsiveness to NRC initiatives, | |||
enforcement history, staffing, effectiveness of training, and | |||
qualification. The scope of this assessment includes all | |||
- _ - - _ - - --__ _ - . . _ _ _ _ | |||
__ _ | |||
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, , . s. | |||
21 | |||
icensee activities associated with plant modifications, | |||
t hnical support provided for. operation, maintenance, testing | |||
an surveillance, operator training, procurement, and configu- | |||
rat n control. | |||
The li nsee has initiated or continued several major efforts to | |||
improve r maintain the quality of engineering performance. The | |||
Corporat Nuclear Operations Division relocated to the plant | |||
site,in 1 e 1987. This move consolidated engineering proce- | |||
dures, work activities and placed the design expertise close to | |||
plant activi ies. The relocation provides an enhancement to the | |||
operations /en neering interface. In conjunction with the | |||
relocation, a organization initiated a system engineering | |||
program. This ogram is designed to improve overall system | |||
performance tren and provide a designated system interface | |||
for operational an etechnical issues. However, the licensee's | |||
progress in impleme g this program has been slow. | |||
The licensee's progra Yrto document and verify major systems | |||
design bases was contin from the previous assessment period. | |||
The design basis docume jion (DBD) effort integrated system | |||
and component requirement actual as-built information, project | |||
commitments, and engineeri accident analysis and margins. | |||
Sixteen DBDs were completed his assessment period. The DBDs | |||
have provided a good referenc resource for engineering activity | |||
and contributed to the identi cation and correction of plant | |||
problems. This design base ef rt is a long term continuing | |||
activity with approximately 50 BDs planned for future | |||
completion. | |||
The licensee's steam generators co tinue to exhibit the | |||
deleterious effects of primary water tress cracking corrosion | |||
as evidenced by the number of tubes r uiring plugging during | |||
the fourth refueling outage. Steam ge rators A, B and C | |||
presently have 6.0, 10.9 and 6.5 percent their tubes plugged. | |||
Although preventive measures such as Roto ening, shot peening | |||
and stress relieving have been accomplished during previous | |||
outages. These measures and engineering st ies which have | |||
reduced plugging requirements have not provi d an ultimate | |||
solution to this problem. | |||
Engineering performance on specific technical iss es has been | |||
good and overall performance resulted in a modific ion backlog | |||
reduction. Engineering provided timely assistance problem | |||
definition, solution, corrective action, and develo ent of | |||
Justifications for Continued Operation when required t support | |||
plant activities. Specifically, engineering support to apera- | |||
tions and maintenance was effective in the evaluation o' the | |||
hydraulic lock-up of the pressurizer and steam generator vel | |||
transmitters, and re-evaluation of Intermediate Building s am | |||
line break analysis. Response and evaluation to NRC bulleti | |||
related to nonconforming materials from Piping Supplies Inc. | |||
__ | |||
P | |||
' 1 | |||
;p s > | |||
21 | |||
, | |||
licensee activities associated with plant modifications, | |||
technical support provided for operation, maintenance, testing | |||
and surveillance, operator training, procurement, and configu- | |||
ration control. | |||
The licensee has initiated or continued several major efforts to | |||
improve or maintain the quality of engineering performance. The | |||
Corporate Nuclear Operations Division relocated to the plant | |||
site in late 1987. This move consolidated engineering proce- | |||
dures, work activities and placed the design expertise close to | |||
plant activities. The relocation provides an enhancement to the | |||
operations / engineering interface. In conjunction with the | |||
relocation, a reorganization initiated' a system engineering | |||
' | |||
program. This program is designed to improve overall system | |||
performance trending and provide a designated system interface | |||
for operational and technical issues. However, the licensee's | |||
progress in implementing this program has been slow. | |||
The licensee's program to document and verify major systems | |||
design bases was continued from the previous assessment period. | |||
The cesign basis documentation (DBD) effort integrated system | |||
and component requirements, actual as-built information, project | |||
commitments, and engineering accident analysis and margins. | |||
Sixteen DBDs were completed this assessment period. The DBDs | |||
r- | |||
have provided a good reference resource for engineering activity | |||
and contributed to the identification and correction of plant | |||
problems. This design base effort is a long term continuing | |||
activity with approximately 40 DBDs planned for future | |||
completion. | |||
'The licensee's steam generators continue to exhibit the | |||
deleterious effects of primary water stress cracking corrosion | |||
as evidenced by the number of tubes requiring plugging during | |||
the fourth refueling outage. Steam generators A, B and C | |||
presently have 6.0, 10.9 and 6.5 percent of their tubes plugged. | |||
Although preventive measures such as Roto peening, shot peening | |||
and stress relieving have been accomplished during previous' | |||
outages. These measures and engineering studies which have | |||
reduced plugging requirements have not provided an ultimate | |||
solution to this problem. | |||
Engineering performance on specific technical issues has been | |||
good and overall performance resulted in a modification backlog | |||
reduction. Engineering provided timely assistance in problem | |||
definition, solution, corrective action, and development of | |||
Justifications for Continued Operation when required to support | |||
plant activities. Specifically, engineering support to opera- , | |||
tions and maintenance was effective in the evaluation of the ; | |||
hydraulic lock-up of the pressurizer and steam generator level " | |||
transmitters, and re-evaluation of Intermediate Building steam l | |||
line break analysis. Response and evaluation to NRC bulletins | |||
related to nonconforming materials from Pipina Supplies Inc. of | |||
~ | |||
- _ - _ - _ - - - ._ ._ ] | |||
, , , - | |||
22 | |||
l | |||
rsey, Steam Generator Crack Propagation, Fastener Testing, and | |||
P e Wall Thinning was timely and aggressive. Engineering | |||
su ort and program management to complete all modifications | |||
poss ' le at power, has resulted in a 17 per cent reduction in | |||
outst ding modifications. | |||
e 1987 refueling outage the as-found Pressurizer Safety | |||
During | |||
Valves (P V) setpoints were significantly higher than allowed by | |||
technical )ecifications. In order to determine the cause of | |||
the high ou'. of tolerance PSV setpoints, the licensee performed | |||
extensive res arch into the effects of test temperature and test | |||
medium on PSV setpoint. The licensee's approach to the | |||
resolution of e setpoint deviation demonstrated a clear | |||
understanding of he issue. The licensee's present PSV and Main | |||
Steam Safety Valve (MSSV) setpoin; test program utilizes one of | |||
the most advanced est methods presently available. This | |||
program exceeds the irements of the test code to which the | |||
licensee is committed. | |||
Toward the end of the as sment period, it was identified that | |||
the licensee performed a Jnadequate design evaluation and | |||
modification that changed fire protection deluge sprinkler | |||
control valves for charcoal hterunitsfromtheopenposition, | |||
~ | |||
as described in the FSAR, to 1. e closed position. These changes | |||
were made without adequate e luation and initiation of | |||
appropriate actions to revise he FSAR and operational | |||
procedures where required. These examples suggest an apparent | |||
weakness i_n engineering support th has the potential to leave | |||
an important safety question unre iewed er inadequately | |||
reviewed. | |||
Licensee efforts have been directed the control of | |||
microbiologically induced corrosion, cor cula and soft water | |||
attack in service water piping. EPRI an consultants have | |||
provided assistance in resolving this item. The licensee has | |||
submitted an application to the state depar nt of health and | |||
environmental control requesting permission to chemically treat | |||
this system. With this treatment the license expec ts to | |||
prevent future occurrence of problems such as he reduced | |||
service water flow to the RBCU discussed in the op ations area. | |||
V. C. Sunener has a strong procurement program. The ocurement | |||
staff includes 15 engineers, nine technicians, three i pectors, | |||
and 29 administrative and warehouse personnel. This gr p has a | |||
fully operational commercial grade procurement program ith | |||
testing equipment and technicians to verify material ad | |||
equipment critical parameters. This program has allowed e | |||
licensee to upgrade such parts as transformers, circuit | |||
breakers, switches, relays, fasteners, insulation, and Bellvi e | |||
washers. | |||
m_,_m_n. _ , .u.+-:-.-,------ . - --:---a-- -- - - - - - - - - | |||
_ _ _. .__ . - _ _ _ _ _ _ | |||
' | |||
h 22 | |||
4 | |||
Jersey, Steam Generator Crack Propagation, Fastener Testing, and | |||
Pips Wall Thinning was timely and aggressive. Engineering | |||
support and program management to complete all modifications | |||
.possible at power, has resulted in a 17 per cent reduction in | |||
outstanding modifications. | |||
During the 1987 refueling outage the as-found Pressurizer Safety | |||
Valves (PSV) setpoints were significantly higher than allowed.by | |||
technical specifications. In order to determine the cause of | |||
the high out of tolerance pSV setpoints, the licensee performed | |||
extensive research'into the effects of test temperature and test | |||
medium on PSV setpoint. The licensee's approach to the | |||
resolution of the setpoint deviation demonstrated a clear | |||
understanding of the-issue. The licensee's present PSV and Main | |||
Steam Safety Valves (MSSV) setpoint test program utilizes one of | |||
the most advanced test methods presently available. This | |||
program exceeds the requirements of the test code to which the | |||
licensee is committed. | |||
Toward the end of the assessment period, it was identified that | |||
the licensee performed an inadequate design evaluation and | |||
modification that changed ten fire protection deluge sprinkler | |||
control valves for charcoal filter units from the open. position, | |||
as described in the FSAR, to the closed position. These changes | |||
were made without adequate evaluation and initiation of | |||
appropriate actions to revise the FSAR and operational | |||
procedures where required. These examples suggest an apparent | |||
weakness in modifications control that has the potential to | |||
leave an important safety question unreviewed or inadequately | |||
reviewed. | |||
. | |||
Licensee efforts have been directed at the control of | |||
microbiological 1y induced corrosion, corbicula and oft water | |||
attack in service water piping. EPRI and consultants have | |||
provided assistance in resolving this item. The licensee has | |||
submitted an application to the state department of health and | |||
environmental control requesting permission to chemically treat | |||
this system. With this treatment the licensee expects to | |||
prevent future occurrence of- problems such as the reduced | |||
service water flow to the RBCU discussed in the operations area. | |||
V. C. Sunner has a strong procurement program. The procurement | |||
staff includer 15 engineers, nine technicians, three inspectors, | |||
and 29 administrative and warehouse personnel. This group has a | |||
fully operational commercial grade procurement program with | |||
testing equipment and technicians to verify material and | |||
equipment critical parameters. This program has allowed the | |||
licensee to upgrade such parts as transformers, ci rcuit | |||
breakers, switches, relays, fasteners, insulation, and Bellville | |||
washers. | |||
- - _ - - - . | |||
}} |
Latest revision as of 04:26, 1 February 2022
ML20245B045 | |
Person / Time | |
---|---|
Site: | Summer |
Issue date: | 12/31/1988 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20245B038 | List: |
References | |
50-395-88-32, NUDOCS 8906220361 | |
Download: ML20245B045 (28) | |
See also: IR 05000395/1988032
Text
, .
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ENCLOSURE 5
l'
FINAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-395/88-32
' SOUTH CAROLINA ELECTRIC AND GAS COMPANY
V. C. SUMMER
August 1, 1987 - December 31, 1988
gg62{poIk$ 9s
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TABLE OF CONTENTS
P_ age.
I. INTRODUCTION ..................................................... 2
A, Licensee Activities ......................................... 2
B. Direct Inspection and Review Activi ties . . . . . . . . . . . . . . . . . . . . . 4
II. SUMMARY OF RESULTS ............................................... 4
O v e r v i e w . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
.III. CRITERIA ......................................................... 6
IV. PERFORMANCE ANALYSIS ............................................. 7
A. P l a n t O pe ra t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
B. Radiological Controls ....................................... 11
C. Maintenance / Surveillance .................................... 14
D. Emergency Preparedness ...................................... 17
E. S e c u r i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
F. Engineering / Technical Support ............................... 20
G. Safety Assessment / Quality Verification ...................... 24
V. SUPPORTING DATA AND SUMMARIES .................................... 27
t
A. Escalated Enforcement Action ................................ 27 i
B. Management Conferences ...................................... 27
C. Review of Licensee Event Reports ............................ 28
D. Licensing Activities ......................................... 28
E. Re a c to r T ri p s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
F. Effluent Release Summary .................................... 30
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2
1. . INTRODUCTION-
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC ctaff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance on the basis of this
information. The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations. It is intended
to be sufficiently diagnostic to provide a rational basis for allocation
of NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
February 21, 1989, to review the observations and data on performance, and
to assess licensee performance in accordance with the quidance in NRC
Manual Chapter-0516. " Systematic Assessment of Licensee Performance." The
guidance and evaluation criteria are sumarized in Section III of this
report. The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at V. C. Summer for the period August 1, 1987 through December 31, 1988.
The SALP Board for V. C. Sumer was composed of:
C. W. Hehl, Deputy Director, Reactor Projects Division (DRP), Region II
(RII) (Chairman)
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII
D. M. Collins, Acting Director, Division of Radiation Safety and
Safeguards (DRSS), RII
D. M. Verrelli, Chief, Reactor Prc.jects Branch 1, DRP, RII
E. A. Reeves, Acting Director, Project Directorate II-1, Office of Nuclear
Reactor Regulation (NRR)
R. L. Prevatte, Senior Resident Inspector, V. C. Sumer, DRP, RII
J. J. Hayes, Project Manager, Project Directorate II-1, NRR
Attendees at SALP Board Meeting:
F. S. Cantrell, Chief, Project Section 1B, DRP, RII
H. C. Dance, Chief, Project Section 1A, DRP, RII
L. P. Modenos, Project Engineer, Project Section 1B, DRP, RI!
P. C. Hopkins, Resident Inspector, V. C. Summer DRP, RII
P. A. Balmain, Reactor Engineer, Technical Support Staff (TSS),
DRP, RII
A. Licensee Activities
The assessment period was from August 1,1987 to December 31, 1988.
The unit experienced three plant shutdowns and one power reduction
during the 1987 evaluation period. The first shutdown on l
September 2-12, 1987 was initiated by a reactor trip from 100 percent
- _ - _ - _
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i
power due to a failed main generator bushing. After repair to the {
bushing, a leak was discovered in the main condenser boot seal which
required replacement in order to draw a vacuum. A second shutdown
occurred from September 24-25, 1987, due to a reactor trip caused by 3
a personnel error made while replacing a faulty power supply in the '
rod control cabinet. On October 14-17, 1987, power was reduced to
30 percent to allow for containment entry and equipment qualification
inspections of electrical connections on reactor building ccoling
units.
On October 29, 1987, the failure of the primary and backup power
supplies to a Westinghouse 7300 system process rack, due to a faulty
capacitor, resulted in a reactor trip. On October 30, 1987, with the
reactor subcritical and the control rod shutdown banks withdrawn, a
reactor trip occurred while replacing an indicator light in a source
range drawer. The use of an incorrect type bulb resulted in a blown
fuse and resulted in a reactor trip. The unit was restarted on
October 30, 1987, and remained at power through the end of 1987.
During 1987, the unit had a capacity factor of 63.7 percent and a
unit availability factor cf 67.7% including a 93 day refueling
outage.
During 1988, the unit experienced one scheduled shutdown and six
forced power reductions of greater than 20 percent which exceeded
four hours of duration. The first shutdown occurred on February 16,
1988, when 'a technician contacted a loose terminal post inside a
power range channel drawer while performing a test for quadrant power
tilt ratio. This resulted in a reactor trip. The unit remained shut
down from February 16-19, 1988. A defective test switch for the main
steam isolation valve resulted in a reactor trip and subsequent
safety injection during the performance of a surveillance test on
May 12, 1988. After repair, the unit was restarted on May 13, 1988.
On May 27, 1988, power was reduced to approximately 40 percent for
66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> while repairing condenser tube leaks. On May 30, 1988, power
was again reduced to 40 percent due to out of specification secondary
chemistry and additional condensor tube leaks. While at 40 percent
power, a reactor trip occurred during testing of the B train solid
state protection system. The cause of this trip was evaluated to be
incorrect operation of the main control board reactor trip switch
during reactor trip breaker testing. The main condensor tube leaks
were attributed to the failure of a flexible flange in the extraction
steam lines. Repairs were completed and the unit was returned to
power on June 10, 1988. On July 5-6, 1988, power was reduced to
40 percent for 34.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to allow repairs to the reactor coolant
drain tank pump. On July 26, 1988, the reactor again tripped during
testing of B train solid state protection system. This event is
similar to the event that occurred on June 10, 1988 and was related
to the operation of the main control board reactor trip switch. This
event was attributed to personnel error and the unit was returned to
power on July 28, 1988.
__. ___
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4
n September 16, 1988, the plant shut down and entered the fourth
fueling outage. Major work activities in the outage included core
re oad, eddy current examination of 100 percent of the steam
gen ator tubes, tube plugging, equipment qualification upgrades, a
cont nment integrated leak rate test, inservice inspection; and
valve acking replacement. The outage exceeded the planned schedule
of 75 d s by 28 days.
The nuclea operations division was consolidated by relocating the
vice presid t. nuclear operations and the corporate staff to the
V.C. Summer ant in the last quarter of 1987. -The division underwent
a reorganizati in the first quarter of 1988 to reduce the number of
management and upervisory levels. The relocation moves were
supported by con, ructing new administrative and support facilities
and upgrading exis ing ones.
B. Direct Inspection an Review Activities
During the assessment p ,od, routine inspections were performed at
the V. C. Summer facility 3 the NRC staff. Special team inspections
were conducted as follows:
-
Equipment Qualification pections were conducted in October
1987 and January 1988, wi a follow-up inspection conducted in
October 1988.
-
Operational Safety Team Inspe ion was conducted in November and
December 1988.
II. SUMMARY OF RESULTS
Summer was operated in an overall safe manne during the assessment
period. Strengths were identified in the areas f Radiological Controls,
Maintenance and Surveillance. A significant dec ne in performance that
requires additional managerial attention was iden fied in the area of
Security.
Operations performance was mixed. Strengths were not in training of
shifts as a team and the presence of a shift engineer hift technical
advisor on each shift to coordinate shift activities with ther areas and
thereby permit the shift supervisor to concentrate on safe lant operation.
The establishment of the University of Maryland program to tain degrees
for on shift operators represents a substantive management c itment to
. improved shift expertise and safety. Corporate interest and o rsight of
plant activities was very apparent. However, the use of proced es with
known errors and the failure to maintain control room drawings, and
acceptable sistem configuration control at all times indicated a n d for
management attention. Added management attention is also needed to duce
the number of reactor trips. The fire protection area requires additi nal
oversight to preclude repetitious errors that have occurred during th1
period.
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On September 16, 1988, the plant shut down and entered the fourth
refueling outage. Major work activities in the outage included core
reload, eddy current examination of 100 percent of the steam
generator tubes, tube plugging, equipment qualification upgrades, a
containment integrated leak rate test, inservice inspection; and
valve packing replacement. The outage exceeded the planned schedule
of 75 days by 28 days.
The nue. lear operations division was consolidated by relocating the
vice president nuclear operations and the corporate staff to the
V.C. Summer plant in the last quarter of 1987. The division underwent
a reorganization in the first quarter of 1988 to reduce the number of
management and supervisory levels. The relocation moves were
supported by constructing new administrative and support facilities
and upgrading existing ones.
B. Direct Inspection and Review Activities
During the assessment period, routine inspections were performed at
the V. C. Summer facility by the NRC staff. Special team inspections
were conducted as follows:
-
Equipment Qualification inspections were conducted in October
1987 and January 1988, with a follow-up inspection conducted in
October 1988.
-
Operational Safety Team Inspection was conducted in November and
December 1988.
II. SUMMARY OF RESULTS
Summer was operated in an overall safe manner during the assessment
period. Strengths were identified in the areas of Radiological Controls,
Maintenance and Surveillance. A significant decline in performance that
requires additional managerial attention was identified in the area of
Security.
Operations performance was mixed. Strengths were noted in training of
shifts as a team and the presence of a shift engineer / shift technical
advisor on each shift to coordinate shift activities with other areas and
thereby permit the shift supervisor to concentrate on safe plant operation.
The establishment of the University of Maryland program to obtain degrees
for on shift operators represents a substantive management connitment to
improved shift expertise and safety. Corporate interest and oversight of
plant activities was very apparent. However, the use of procedures
containing errors, the failure to maintain control room drawings, and the
lack of acceptable system configuration control at all times indicated a
need for management attention. Added management attention is also needed
to reduce the number of reactor trips. The fire protection area requires
additional oversight to preclude repetitious errors that have occurred
during this period.
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The Radiological Controls area was considered a strength. The reduction
of contaminated areas to less than one percent was noteworthy. However,
considering the current problems associated with steam generator tube
integrity and failed fuel, the licensee is faced with challenges that
may require innovative approaches if personnel exposure and contamination
is to be maintained as low as reasonably achievable (ALARA).
The maintenance / surveillance program was well implemented and considered a
strength. The reduction in maintenance work order backlog, implementation
of a predictive maintenance program, and operations support to the
planning and scheduling group are considered strengths. The timely
completion of surveillance tests indicates that the testing program was
well staffed and supervised.
Emergency Preparedness activities' were conducted in an adequate manner.
In the area of Emergency Preparedness, the licensee demonstrated an
ability to adequately implement the essential elements of their Emergency
Plan. However, inspection results showed that a weakness identified in
the training of key staff personnel during the previous assessment still
existed.
The Security area, long considered a strength at this site, experienced
several significant problems which resulted in escalated enforcement late
in the assessment period. Organizational changes in 1988 resulted in
deteriorating security force performance. Management was slow to
recognize these changes until personnal performance had decreased to a
marginal level. Significant management attention is required to raise the
performance of this area back to its past level of performance.
The Engineering / Technical Support function was performed well during the
evaluation period. The engineering staff was consolidated and relocated
to the plant site to provide more rapid response to plant problems.
- However, during the assessment period instances of ina6quate engineering
evaluations and a concern with the adequacy of review of contractor
evaluations were identified. The system engineer program which was
established in late 1987 has been slow in being implemented. Additional
management attention may be required to achieve the desired benefits of
this program.
The Safety Assessment / Quality Verification area performance was good.
.0perations, engineering and management involvement in safety issues was
apparent. The licensee continued to pursue and realize positive benefits
from their efforts in safety system functional inspections and development
of system design bases documents. In response to the excessive reactor
trip problem, a root cause identification training program has been
started. Repetitious trips from the main control board reactor trip
switch in 1988 indicate a need for additional management attention in this i
area. QA and QC continue to provide good oversight of safety activities. I
Licensee submittals to the NRC were considered acceptable.
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Overview
Rating Last Period Rating This Period
Functional Area 1/1/86 - 7/31/87 8/1/87 - 12/31/88 Trend
Plant Operations 2 2
Radiological Controls 1 1
Maintenance / Surveillance 1 1
Security 1 2 Declining
Engineering / Technical Support NR 2
Safety Assessment / 2 2
Quality Verification
III. CRITERIA
!
Licensee performance is assessed in selected functional areas.- depending
on whether the facility is in a construction or operational phase.
Functional areas normally represent areas- significant to nuclear safety
'and the environment. Some functional areas may not be assessed because of
little or no. licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each
functional area:
1. - Assurance of quality, including management involvement and control;
2. Approach to the resolution of technical issues from a safety
standpoint;
3. Responsiveness to NRC initiatives;
4. Enforcement history;
5. Operational and construction events (including the response,
analyses, reporting, and corrective actions);
6. Staffing (includingmanagement);and
7. Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been
used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is
rated according to three performance categories. The definitions of these
performance categories.are as follows: )
Category 1. Licensee management attention and involvement are readily
evident and place emphasis on superior performance of nuclear safety or
safeguards activities, with the resulting performance substantially
exceeding regulatory requirements. Licensee resources are ample and
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effectively used so that a high level of plant and personnel performance
is being achieved. Reduced NRC attention may be appropriate.
Category 2. Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good. The
licensee has attained a level of performance above that needed to meet
regulatory requirements. Licensee resources are adequate and reasonably
allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at normal levels.
Category 3. Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to
meet minimal regulatory requirements. Licensee resources appear to be
strained or not effectively used. NRC attention should be increased above
normal levels.
The SALP Board may also include an appraisal of the performance trend of a
functional area. This performance trend will only be used when both a
definite trend of performance within the evaluation period is discernable
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 assessment period.
Declining: Licensee performance was determined to be declining near the
close of the assessment period and the licensee had not taken meaningful
steps to address this pattern.
IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
During the assessment period routine and special inspections
were performed by the NRC staff. The fire protection program
was examined by a special inspect ton in February,1988 and an
Operational Safety Team Inspection (OSTI) was conducted in
November and December, 1988.
The operations group is well staffed with five shifts that stand
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> watches. Each shift includes a shift engineer / shift I
technical advisor, shift supervisor (SRO), control room
supervisor (SRO), reactor operator (SR0/RO), a first and second
assistant operator who may be SR0/R0 or in training for a
license and five to six auxiliary operators. All shift
engineers are degreed and six of eight possess SR0 licenses.
The remaining two are currently in training for SR0 licenses.
. _ - _ _ _ _ _ _ _ _
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8
he shifts train and operate together as a team. The shift
l,
e ineer coordinates all shift support functions and thereby
fr s . the shift supervisor to concentrate on -safe plant
ope tion. The reactor operators and first and second assistant
oper ors routinely rotate from the control room to auxiliary
opera r watch stations to maintain their proficiency-' and
utilize their experience throughout the plant. The licensee has
experien d only negligible personnel turnover in this area.
To- improve educational and engineering expertise on shift,
management . itiated a college degree program for licensed
operators in 987. This program is conducted by the University
of Maryland an $ffers a Bachelor of Science degree in Nuclear
Science. Thirt 4o of the forty initial candidates are still
participating in program. Any nuclear operations personnel
may participate in is program; however, licensed operators and
license candidates
ggivenpriority.
Administrative contro to ensure control room professionalism
were established and a effective. Access to the at-the-control
area is limited and we 1 controlled. Operator logs were
legible and complete w1 h normal conditions, off-normal
conditions, special tests and events identified. Preshift
briefings were conducted an4 shift turnover forms were used by
all operators. Watchstander and duty technician assignments
were clearly posted in the c trol room. Key controls for
operator access to spaces and quipment were well organized.
Operator response to off-normal nditions and plant transients
was prompt and thorough. This wa exemplified during a loss of
reactor coolant letdown event that ccured in 1988. The rapid
identification of an incorrect cont 1 signal resulted in the
operator transferring control of let wn from the main ontrol
board to the remote shutdown panel an thereby bypassing the
faulty control circuit. This timely re onse prevented a plant
shutdown. The licensee has initiated a ogram to enhance the
black board concept for alarm annunciators
The OSTI identified instances where addi 'onal licensee l
attention was needed tc control valve and rcuit breaker
alignment limiting conditions for operation (LCO), and
legibility of control room essential drawings. e licensee was
very responsive in revising LC0 procedures to duce the
potential for reliance on inoperable systems and - corporating
procedural steps to require independent verificati of valve
and circuit breaker positions. System walkdowns the
OSTI team members identified numerous technical nd
typographical errors in existing system operating proce res and ,
attachments used for valve and breaker alignments. hse
l
procedures had been implemented and issued to the field fc use,
without a good review, or validation. It was anticipated la t l
operators would make the needed corrections while accomplis
'
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system lineups and verification of lineups. One illegible i
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8
The shifts train and operate together as a team. The shif t
engineer coordinates all shift support functions and thereby
frees the shift supervisor to concentrate on safe plant
operation. The reactor operators and first and second assistant
operators routinely rotate from the control room to auxiliary
operator watch stations to maintain their proficiency and
utilize their experience throughout the plant. The licensee has
experienced only negligible personnel turnover .n this area.
To improve educational and engineering . expertise on shift,
management initiated a college degree program for licensed
operators in 1987. This program is conducted by the University
of Maryland and offers a Bachelor of Science degree in Nuclear
Science. Thirty-two of the forty initial candidates are still i
participating in the program. Any nuclear operations personnel
may participate. in this program; however, licensed operators and
license candidates are given priority.
Administrative controls to ensure control room professionalism
were established and are effective. Access to the at-the-control
area is limited and well controlled. Operator logs were
legible and complete with normal conditions, off-normal
conditions, special tests and events identified. Preshift
briefings were conducted and shift turnover forms were used by
all operators. Watchstanders and duty technician assignments
were clearly posted in the control room. Key controls for
operator access to spaces and equipment were well organized.
Operator response to off-normal conditions and plant transients
was prompt and thorough. This was exemplified during a loss of
reactor coolant letdown event that occured in 1988. The rapid
identification of an incorrect control signal resulted in the
operator transferring centrol of letdown from the main control
board to the remote shutdown panel and thereby bypassing the
faulty control circuit. This timely response prevented a plant
shutdown. The licensee has initiated a program to enhance the
black board concept for alarm annunciators.
The OSTI identified instances where additional licensee
attention was needed to control valve and circuit breaker
alignment limiting conditions for operation ( LCO) , and
legibility of control room essential drawings. The licensee was
very responsive in revising LCO procedures to reduce the
potential for reliance on inoperable systems and incorporating
procedural steps to require independent verification of valve
and circuit breaker positions. System walkdowns by the
OSTI team members identified numerous technical and
typographical errors in existing system operating procedures and
attachments used for valve and breaker alignments. These
procedures had been implemented and issued to the field for use, ,
without a good review, or validation. Operators had to make
the needed corrections while accomplishing system lineups and
verification of lineups. One illegible drawing was identified
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during the OSTI inspection; a resulting followup review by the 'l
licensee identified 28 ~ additional drawings with inadequate or
marginal clarity. These items were the subject of violation b.
j l
below.
Over the assessment period, plant housekeeping was considered
average. The control room and main control board were repainted
and new carpet was installed during the 1983 refueling outage.
In general plant areas, a program to upgrade painting,
appearance and protective coatings has resulted in an ' improved
appearance. However, it is noted that the number of leaks from
non-radioactive and radioactive systems, although wrapped with
herculite and routed to drains, have . increased. Operation
should pursue the timely correction of these deficiencies.
Regular plant tours are accomplished by the Vice president
Nuclear Operations, the plant manager and the plant ranager's
staff. Corporate interest and oversight of the plant was
evident from frequent visits and plant tours by senior
management. Monthly trend reports and performance indicators
are published to keep plant and corporate management appraised
of plant status and potential plant.probl' ems.
The plant capacity factor for the SALP period was 72.4 percent
even with a 103 day refueling outage at the end of 1988. A
comparison with the previous SALP shows that the unit forced
outage rate increased from 4.01 to 6.20 percent. The outage
rate-is above the industry mid 1988 one year median of 4.8. The
reactor trips, when compared with the previous SALP increased
from seven to eight. The trip rate, even though some improve-
ment was shown in 1988, is still above the industry one year
median of approximately two. A review of the reactor trips
'
determined that four trips were related to equipment failure,
two trips were due to equipment design and two trips were the
result of personnel errors. Five of eight trips occurred during
the performance of surveillance tests.
Management responded to the excessive reactor trip problem by
initiating actions to improve labelling of procedural steps that
present trip hazards and providing dditional technical training
on surveillar.ce tests which expose the unit to high trip risk. l
Studies are <:urrently underway to justify a reduction in
periodicity of high trip potential surveillance.
The adequacy of the licensee's post trip reviews was questioned
in May 1988 as the result of a reactor trip and reduced service
water flow to the reactor building cooling units during a
subsequent safety injection. The reduced service water flow
problem was not detected during the post trip review. The
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diligence of the Independent Safety Evaluation Group resulted in
the identification of this problem after the plant restarted.
This item was the subject of a severity level III violation 3
i
issued in August 1988. (See violation a. below).
A problem was identified on the previous SALP concerning the
correct alignment of swing pumps. The corrective actions taken
and discussed in the previous SALP appeared to be effective and
no new or repeat problems were identified in this area.
Control of combustible and flammable materials in safety related
related areas of the plant was considered good. An identified
exception included an area in the auxiliary building where
approximately 4.5 tons of combustible charcoal had been
temporarily stored. (See violation g below).
The required drills and training of Fire Brigade members were
conducted within the frequency outlined in plant procedures.
Satisfactory performance of the Fire Brigade in an unannounced
drill witnessed by NRC staff demonstrated the effectiveness of
the Fire Brigade training program.
The licensee has experienced events where compensatory fire
watches were not established for degraded fire barriers or
inoperable fire e These events were the subject of
five violations (quipment.
c through g) and five LER's during the
evaluation period. Extensive management attention was directed
to this area. A Fire Protection Officer was placed on each
operating shift to monitor and provide improved response for
degraded fire barriers and protection equipment. This single
point accountability had additionally resulted in improved
communications and better equipment status control.
Staffing in the fire protection area increased in 1988 from a
fire protection supervisor and five technicians to a fire i
protection supervisor; a fire protection coordinator; two
specialists who supervise fire protection officers and
surveillance testing; three technicians and five operation shift
fire protection officers. These changes occurred in the last
quarter of 1988 and have not been implemented long enough to
allow full evaluation.
Seven violations were identified of which five involved
inadequate fire protection or compensatory actions.
L a. Severity level III violation for making a mode change with
{ both trains of RBCU's inoperable. (395/88-13-01)
t
b. Severity level IV violation for illegible control room
! drawings and incorrect valve lineup procedures.
l (395/88-26-03)
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c. Severity level IV violation for failure to take adequate
compensatory action for inoperable fire detection
equipment. (395/88-24-01)
,
d. Severity level IV violation for failure to take adequate
,
compensatory action for inoperable fire detection equipment
and a breached fire barrier. (395/88-03-01)
e. Severity level IV violation for failure to take adequate
L compensatory action for inoperab'e fire suppression
- equipment. (395/88-10-01)
f. Severity level IV violation for failure to take adequate
action for
equipment. compensatory (395/88-19-01) inoperable fire detection
g. Severity level IV violation for failure to establish
adequate compensatory fire protection measures for
increased transient fire loading due to temporary storage
of 4.5 tons of combustible charcoal and for-failure to have
an important procedure at a control panel. (395/88-26-01)
2. Performance Rating:
I
Category: 2 Previous rating - Operation: 2
Fire Protection: 2
3. Recommendations:
Management support of operations needs to be improved. This
need is indicated by procedures being issued that still contain
errors that should have been identified by a procedure
review / verification program. Another indication is control room
drawings issued for operations use when numerous drawings were
illegible. Operations personnel need to be more aggressive in
raising these type problems to management's attention and in
pursuing a satisfactory resolution of identified problems.
B. Radiological Controls
1. Analysis
During the assessment period, inspections were performed by the
resident and regional inspection staffs. Inspections were
conducted in the areas of radiation protection, radiological '
effluents, and confirmatory measurements.
During the assessment period, the licensee reorganized the
chemistry and Health Physics departments in the first quarter of
1988. A chemistry and health physics manager position was
established and filled with a former corporate health physicist.
1
4
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The - former . Manager .of Technical and Support Services at the-
.~ plant was assigned to the position .of. Corporate Manager of
Health ~ Physics.: The licensee also-established the position of
, Radwaste Coordinator and filled the_ position with an engineer
<
who had been serving as a shift technical advisor.
The;11censee's' health physics (HP) and radwaste staffing levels
.
appear; to be slightly lower than other. utilities having a
, facility of similar size. In additior. .to the regular plant HP
technicians,.-the licensee retains 14 ' to 16 contract HP
technicians to augment the HP staff for routine operations. The
smaller-permanent staff has not had any deleterious' effects on
the performance of the HP staff. Tha knowledge'and experience
' level' off the HP- staff were excellent. The overall quality of
the staff was a program strength.
Radiation protection training was considered good. .The.
licensee's general, employee training in radition protection was
well defined. The licensee enhanced training by establishing a
training program for HP supervisors. 'Since this program is in
addition to regulatory requirements, it -indicates management's
support for and commitment to high training standards.
Management support and involvement in . matters related to
radiation protection were demonstrated by upgrading the whole
body counters with germanium detectors and the procurement;of a
standup whole body counter. . Inspection during the evaluation
period indicated that the . radiation protection program received
strong support from other plant departments.
At the.end of 1988, the contaminated area of the plant was less
than one percent of the total . areas monitored. Ma licensee's
aggressive -contamination control program allows plant personnel
to . access containment without protective clothing. Resulting
benefits are a reduction in the amount of radioactive waste
generated and less restrictions on workers and supervisors
during performance of their assigned tasks.
In 1987, the collective dose was 562 person-rem with 547
person-rem being attributed to a refueling outage and
maintenance on steam generators. In 1986, the collective dose
was'23 person-rem, however, there were no outages in 1986. In
1988, the licensee expended 18 person-rem for normal operations
and 503 person-rem for outage related work. Primary
contributors to the high collective dose in the last two years
have been the increase in reactor coolant system (RCS)
radioactivity and increased steam generator maintenance. In
some high traffic areas of the plant radiation in the residual
heat removal-(RHR) lines has caused dose rates in adjacent areas
to increase by a factor of 20. Significant increases in dose
rates'were also observed during reactor head work, fuel movement
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and reactor cavity decontamination. The collective doses' for
1987 and 1988 are representative for plants experiencing steam
generator and fuel problems.
.The licensee has a number of initiatives underway to limit and
reduce dose rates within the plant including elimination of the
resistance temperature detector bypass- manifold, evaluation of
the replacement of primary system filters with smaller mesh
filters to reduce the particulate in the RCS, evaluation of
raising the pH of the RCS, and chemical decon of various
RHR/RCS-systems and/or components in 1989.
The licensee's respiratory protection and radiation work permit
programs .were found to be satisfactory. The licensee
experienced a total of 130 personnel contaminations in 1987, l
76 skin contaminations and 54 clothing contaminations. In 1988,
the number of personnel contaminations increased 240 percent to
141 skin and 171 clothing contaminations. The licensee
experienced 52 discrete radioactive particle contaminations in
1988, due' to failed fuel and the increased amount of system
-maintenance. Previously, the licensee had only three hot
particle contaminations with the majority of the particles being
fission products. The licensee has an aggressive program for
the identification and control of discrete radioactive
particles.
During the assessment period, the licensee contracted with a
vendor to perform super compaction of dry radioactive waste to
reduce the volume of dry radioactive waste shipped to a low
level waste burial facility.
Participation in the NRC spiked sample analysis program for beta
emitting radionuclides showed agreement with NRC results for all
four nuclides.
Liquid and gaseous effluents were within regulatory limits for
concentrations of radioactive material releases. There were
slightly increasing trends in the annual quantities of
radioactive material effluent releases for the past three years.
Annual effluent releases are summarized in the Supporting Data
L
and Summaries,Section V.K. Licensee estimates of doses to
.
maximum exposed individuals were well below the limits in the
L technical specifications.
Radiological audits and surveillance conducted by the licensee
were comprehensive and sufficiently in-depth to identify problem
areas and trends. Management was responsive to the problems
identified. '
1
No violations or deviations were identified.
L
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2. Performance Rating
')
Category: 1 Previous rating: 1
3. Recommendations
The Board recognized your continuous high level of performance
in this area. The Board does note that there have been
increases in fuel leakage in the recent past with the resultant
potential for increase in radiation levels and contamination.
The Board recommends you continue a high level of management
attention to this area because of this increased challenge.
C. Maintenance / Surveillance
1. Analysis
During the assessment period routine and special inspections
were performed by the NRC staff. Equipment Qualification (EQ)
team inspections were conducted in October 1987, January 1988,
and October 1988. A Containment Integra.ted Leak Rate Test
(CILRT) inspection was conducted in September, 1988. An OSTI in
November and December 1988, evaluated maintenance support of
operations.
The maintenance organization is adequately staffed and trained
to support operation of the plant. The staff is supplemented by
contractors, as needed, to support plant outages. This unit has
experienced a very low turnover of maintenance personnel.
The corrective maintenance and preventive program was planned
and performed in accordance with established procedures.
Supervisors provided adequate direction and assistance, as
needed, to complete activities. QC provided adequate coverage
of safety related activities. Maintenance activities were
scheduled and tracked with a history maintained by computerized
systems.
The predictive maintenance program used vibration analysis,
temperature monitoring, ferrography (lube oil), infrared surveys
and motor operated valve analysis and tests systems (M0 VATS) to
determine the need for equipment maintenance. Success
experienced in this program included vibration monitoring of the
main feed pumps which led to early identification and correction
of coupling grease loss and alignment problems. The use of
vibration analysis and ferrography on the reactor coolant pumps
(RCP) permitted the licensee to extend the scheduled maintenance
on "B" RCP to refueling outage 5. This extension will allow
concurrent motor tear down and seaI replacement on the RCP's for
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11 future outages. The M0 VATS equipment has been upgraded and
t e data bank has been expanded to approximately 80 percent of
th installed motor operator valves.
The erations Section of Scheduling was staffed with three SR0s
and on R0. The application of licensed expertise was a strong
point i the maintenance scheduling process. Another strong
point wa the daily preparation of a " trip package" which
contained lanned maintenance activities requiring a duration of
less than ight hours to perform. Additionally, a "short
duration out e package" was also planned for those activities
which could b completed in the event plant trip recovery took
longer than ei t hours but less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
A weakness was i ntified in the previous SAll' in the area of
first line superv ory involvement on planning and directing
maintenance activit s. Management has provided team building '
and additional trai ' to those supervisors. The shift
engineer program has so improved operations interface with
maintenance activities. However, it is still evident from the
excessive time required complete some task, such as M0V
lubricant change and dur the refueling outage, that first
line supervisors are stil ot sufficiently involved in work
planning activities. Altho this weakness was noted, and it
is apparent that licensee se eduled more work than they were
able to accomplish during the time allotted for the fourth
refueling outage, they are comm ded for not cancelling scheduled
work, and for extending the outa to insure that essential work ,
was completed.
During a Phase I review of Environm tal Qualification (EQ) of
Electrical Equipment in January 1988, a problem was identified
in the area of EQ maintenance. The EQ aintenance rcanirements
for the lubrication of the Emergency F dwater Pump were not
accomplished for two consecutive 12 mont periods. In response
to the violation "c" below, the licensee rformed an indepth
review of all EQ maintenance requirements a d incorporated the
requirements into a comprehensive EQ Mainten nce Manual which
will schedule specific maintenance task over o tage periods.
A maintenance self-assessment program using INP0 utdelines was
completed by the licensee in March 1988. Base upon that ,
assessmat the licensee concluded that they met he INPO
criteria through their established programs. A sma' number of
weaknesses were identified in the area of planning an outages.
l
These items have been assigned to a task manager to nsure
l timely completion. .
!
l The maintenance backlog contained approximately 600 mainte nce l
work requests (MWR) at the end of the SALP period. The bac og
had been reduced by approximately 20 percent in the past 1
months. Nonoutage MWR's that are over three months old are
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all future outages. The M0 VATS equipment has been upgraded and
the data bank has been expanded to approximately 80 percent of
the installed motor operator valves.
The Operations Section of Scheduling was staffed with three SR0s
and one R0. The application of licensed expertise was a strong
point in' the maintenance scheduling process. Another strong
-point was the daily preparation of a " trip package" which
contained planned maintenance activities requiring a duration of
less than eight hours to perform. Additionally, a "short
duration outage package" was also planned for those activities
which could be completed in the event plant trip recovery took
longer than eight hours but less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
A weakness was identified in the previous SALP in the area of
first line supervisory involvement in planning and directing
maintenance activities. In response to this item, management
implemented additional training and a team building program for
those supervisors. The shift -engineer program has lead to
improvement in operations and maintenance. work and
communications interface. However, it is apparent- from the
increased amount of time taken to complete scheduled outage
work, that adequate input from the field and feedback to the
work scheduling process are not being considered in.
establishing schedules. 'The time allotted for MOV lubricant
changeout during the outage, far exceeded the time allotted.
Improved use of maintenance history data for task time
requirements and training exercises on new tasks could provide
more realistic . planning data. Although this weakness was
noted, the licensee is comended for not cancelling scheduling
work, and extending the outage to insure that essential work
was completed.
During a Phase I review of Environmental Qualification (EQ) of
Electrical Equipment in January 1988, a problem was identified
in the area of EQ maintenance. The EQ maintenance requirements
for the lubrication of the Emergency Feedwater Pump were not
accomplished for two consecutive 12 month periods. In response
to the violation "c" below, the licensee performed an indepth
review of all EQ maintenance requirements and incorporated the
requirements into a comprehensive EQ Maintenance Manual which
will schedule specific maintenance task over outage periods.
A maintenance self-assessment program using INP0 guidelines was
completed by the licensee in March 1988. Based upon that
assessment the licensee concluded that they met the INP0
criteria through their established programs. A small number of
weaknesses were identified in the area of planning and outages.
These items have been assigned to a task manager to ensure l
timely completion. {
The maintenance backlog contained approximately 600 maintenance
work requests (MWR) at the end of the SALP period. The backlog
had_been reduced by approximately 20 percent in the pas,t 18
_ _ _
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!
16
!
trended for management attention. The timely review of the MWR
backlog and the relatively small number of MWRs older than three
months were considered strengths.
The licensee's overall CILRT program was conducted in a
controlled and acceptable manner. The CILRT showed evidence of
. prior planning and management. involvement in the use of detailed
-O test controls and experienced leak rate test consultants. A
conservative approach to . technical issues was observed in the
resolution of instrumentation and leakage problems encountered
during the performance of the test. The conduct and quality of
the testing was acceptable. Surveillance test records were
complete, legible, and readily retrievable. Local leak rate .'
test personnel were well qualified for their job functions and
were knowledgeable in procedural and regulatory requirements.
Staffing in this area was adequate for the level of activity.
. The instrument calibrations facility was found to have well
organized records and well maintained and calibrated equipment.
The licensee's control, issue and accountability of tools showed
a significant improvement during the recent refueling outage.
Tools were more readily available for work performance.
Approximately 9,000 surveillance were conducted during the SALP
period and only two were not documented as have being completed
within the prescribed time limits. Both of the' tests were on
the diesel fire pump batteries. These deficiencies were
identified and corrected by the licensee in a timely manner.
These results indicate a strong and effective program with good
management oversight of this area. However, it is noted that
five of the eight reactor trips occurred during surveillance
tests. Three violations were identified.
a. Severity Level IV violation for failure to properly
implement Administrative Procedure SAP-134 thereby
performing an inadequate post-test review of test results
for surveillance test procedure STP-210.002.
(395/88-07-01)
b. Severity Level IV violation for failure to maintain plant
procedures which provide instructions for operation of the
service water "A" pumps screen wash pump and traveling
l
screen. (395/88-15-01)
c. Severity Level V violation for failure to perform EQ '
maintenance requirements for lubrication of the emergency i
feedwater pump for two consecutive twelve month periods. l
(395/88-01-01)
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2. Performance Rating
Category: 1 Previous rating - Maintenance: 1 Surveillance: 1
3. Recommendations
1. Analysis
The inspections conducted during this assessment period by NRC
staff included one routine EP inspection in M6y 1988, and an
Emergency Response Facility (ERF) Appraisal conducted in March
1988.
Based on the inspection activity noted above, the licensee
demonstrated an ability to adequately implement the essential ;
elements of the Summer Emergency Plan during a simulated or
'
actual emergency event. However, declining performance in the
area of Emergency Plan required trair.ing was identified as noted !
below.
The routine inspection, conducted in May 1988, disclosed a
recurrent licensee problem involving the failure to follow their
Emergency Plan with re. sect to requirements for training. A
violation was identifieo for failure to provide required
training to two key members (Radiological Assessment Supervisor
and Maintenance Supervisor) of the onsite emergency organization
assessment staff in accordance with Emergency Plan procedures.
The licensee's planned corrective action appeared adequate. All
other training of key members of the emergency organization
appeared to be consistent with approved procedures. However, a
similar violation was identified during the preceding assessment
period involving training of key members of the emergency
organization on the fission product barrier approach to
emergency event classification.
During the ERF Appraisal walkthroughs, a Shift Supervisor made
an untimely event classification, as well as an incorrect
emergency declaration in response to a postulated casualty
presented by the inspector. It was noted that an artificiality
in the scenario may have been a contributing factor. However,
the licensee acknowledged that improvements were needed in the
Emergency Plan training program. The General Manager for
Operations connitted to provide additional training for
Emergency Directors to include, as a minimum, event
classification and protective action recommendations.
The March 1988 ERF Appraisal disclosed that the emergency
i response facilities, including the Control Room, Technical
'
Support Center (TSC), and Emergency Operations Facility (EOF),
fully met the regulatory criteria, orders, and license
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f l
L 18 j
I
)
conditions issued to implement Supplement 1 to NUREG-0737. The
ERFs provided all necessary equipment, systems, documents, and
supplies to assist the licensee in the identification and 1
mitigation of plant emergency events, and implemented all
elements of the Emergency Plan required to protect onsite
personnel and the public within the assigned emergency planning
zone.
The licensee maintains the ERFs, and all equipment and systems 4
therein, in an adequate state of operational readiness for
responding to emergencies.. The licensee also established an
effective management and control program fer the Early Warning
Siren System, and installed a redundant transmitter and encoder
for the . system. Shift staffing augmentation appeared to be ;
i
consistent with regulatory requirements and guidance. Although
no violations were identified during the Appraisal, the licensee
committed to review several dose assessment followup items and
to provide a response. The licensee's response has been reviewed
and determined to be acceptable.
During the assessment period, five revisions were submitted to
'the Emergency Plan for NRC review and approval. The proposed
revisions were determined to be consistent with regulatory
requirements and guidance.
One violation was identified. Although the finding was not
indicative of a significant programmatic breakdown in the EP
program as a whole, it is clear that performance in Emergency
Plan required training has declined. The licensee continued to
demonstrate overall the capability to fully implement key
elements of the Emergency Plan during simulated or actual plant
emergency events.
a. Severity Level IV violation for failure of two key members
of the onsite emergency response organization to complete
training in accordance with Emergency Plan Procedure
EPP-018, Emergency Training and Drills. (395/87-23)
2. Performance Rating
Category: 2 Previous rating: 2
3. Recommendations
The Board note: that during an inspection after the close of the
assessment period (in January 1989) there was another finding of
failure to provide training to members of the emergency response
team. We encouragt. licensee management to give increased
emphasis to emergency response training and retraining and
recommend increased NRC inspection resources be provided in this
area.
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E. -Security
l
1. ' Analysis
Two routine and one reactive inspections were conducted by the
.NRC staff.
~
The licensee - expended extensive resources ~ in constructing a
secondary access portal, installing a new security computer, a
new access control system, a' new . secondary alarm station.
upgrading the closed circuit TV system and central alarm station
-
and providing additional protection for the secondary power
supply system.
Historically, this licensee has been one of the Region's
+ ' outstanding . security performers. The problems discussed below
became' apparent during the last half of the rating period.
The ' security organizat'on, after the loss of- the security
manager and the captain in charge of security personnel in late
1987,.was reorganized and incorporated into the Nuclear Protec-
tion Service lwith a new manager, associate manager and several
supervisory changes brought about by attrition. . Changes in
management, supervision style and philosophy were not readily
accepted by the security force. Management was also slow in
recognizing situations which resulted in a deteriorating
security morale and perfonnance. As a result, certain viola-
tions were. identified in the latter part of the SALP period _and-
an Enforcement Conference was held on January 6, 1989 to discuss
the following items: failure to control access .to vital and
protected areas; failure to control access to the
area; failure to control access to a vital area (protected
sleeping
guard); failure to rotate locks and cores after terminating
- members of the security force; failure to implement contingency
-
measure; inadequate perimeter intrusion detection system; and
. inadequate-reporting of safeguards events.
Serious management attention to these weaknesses was provided
after.this series of events which occurred in the last quarter
of 1988. These events and a resulting NRC inspection indicated
that security performance in the area of personnel access
control had reached a level of marginal performance.
The repetitive access control violations indicate: a. breakdown
in the supervisory oversight of the security force; a failure on
the part -of the security force to recognize and correct
problems; and a failure of management to implement effective
corrective measures. The root cause analyses for the first
access control problem was not effective in preventing recur- i
rence. Management also demonstrated a lack of familiarity with !
basic security requirements as evidenced by the failure to
e
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,3 ...
20
search a vital area when the security force member posted to
control area access was discovered asleep. Further examples of
lack of. familiarity with requirements was evident when the
licensee failed to rotate security locks following the
termination of members of the security' force on several
occasions.
Although the licensee employs a dedicated security maintenance
staff, a lack of attention to detail.a lack 'of technical
<
' expertise or incorrect implementation of regulatory
requirements, was' found by the NRC in the areas of intrusion
detection equipment. Critical self-assessment was lacking,
therefore problems were not identified at an early stage.
After initial identification of the above problems, the licensee
responded by assigning a new General Manager Station Support and
redefinition of responsibilities for licensee and contractor
employees has been implemented.
I
One violation was identified during this assessment period.
.However, subsequent to the end of the assessment period,
escalated enforcement action involving multiple examples of
security deficiencies was issued.
a. Severity level IV violation for inadequate perimeter
intrusion detection capability. (395/87-31-01)
2. Performance Rating
Category: 2 (Declining) Previous rating: 1
-3. Recommendations
The Board has noted that during the first half of this SALP
period the licensee enjoyed a favorable security program without .
the negative impact of enforcement issues. However, a serious
degradation during the second half of this SALP period that
could result, if unchecked, in a SALP 3 rating. In order to
alleviate this situation the Board recommends that a high level
of management attention continue to be given to this program
area.
F. Engineering / Technical Support
1. Analysis
The Engineering Technical Support functional area addresses the
adequacy of technical and engineering support for all plant
activities. To determine the adequacy of support provided,
specific attention was given to the identification and resolu-
tion of technical issues, responsiveness to NRC initiatives,
enforcement history, staffing, effectiveness of training, and
qualification. The scope of this assessment includes all
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21
icensee activities associated with plant modifications,
t hnical support provided for. operation, maintenance, testing
an surveillance, operator training, procurement, and configu-
rat n control.
The li nsee has initiated or continued several major efforts to
improve r maintain the quality of engineering performance. The
Corporat Nuclear Operations Division relocated to the plant
site,in 1 e 1987. This move consolidated engineering proce-
dures, work activities and placed the design expertise close to
plant activi ies. The relocation provides an enhancement to the
operations /en neering interface. In conjunction with the
relocation, a organization initiated a system engineering
program. This ogram is designed to improve overall system
performance tren and provide a designated system interface
for operational an etechnical issues. However, the licensee's
progress in impleme g this program has been slow.
The licensee's progra Yrto document and verify major systems
design bases was contin from the previous assessment period.
The design basis docume jion (DBD) effort integrated system
and component requirement actual as-built information, project
commitments, and engineeri accident analysis and margins.
Sixteen DBDs were completed his assessment period. The DBDs
have provided a good referenc resource for engineering activity
and contributed to the identi cation and correction of plant
problems. This design base ef rt is a long term continuing
activity with approximately 50 BDs planned for future
completion.
The licensee's steam generators co tinue to exhibit the
deleterious effects of primary water tress cracking corrosion
as evidenced by the number of tubes r uiring plugging during
the fourth refueling outage. Steam ge rators A, B and C
presently have 6.0, 10.9 and 6.5 percent their tubes plugged.
Although preventive measures such as Roto ening, shot peening
and stress relieving have been accomplished during previous
outages. These measures and engineering st ies which have
reduced plugging requirements have not provi d an ultimate
solution to this problem.
Engineering performance on specific technical iss es has been
good and overall performance resulted in a modific ion backlog
reduction. Engineering provided timely assistance problem
definition, solution, corrective action, and develo ent of
Justifications for Continued Operation when required t support
plant activities. Specifically, engineering support to apera-
tions and maintenance was effective in the evaluation o' the
hydraulic lock-up of the pressurizer and steam generator vel
transmitters, and re-evaluation of Intermediate Building s am
line break analysis. Response and evaluation to NRC bulleti
related to nonconforming materials from Piping Supplies Inc.
__
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' 1
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21
,
licensee activities associated with plant modifications,
technical support provided for operation, maintenance, testing
and surveillance, operator training, procurement, and configu-
ration control.
The licensee has initiated or continued several major efforts to
improve or maintain the quality of engineering performance. The
Corporate Nuclear Operations Division relocated to the plant
site in late 1987. This move consolidated engineering proce-
dures, work activities and placed the design expertise close to
plant activities. The relocation provides an enhancement to the
operations / engineering interface. In conjunction with the
relocation, a reorganization initiated' a system engineering
'
program. This program is designed to improve overall system
performance trending and provide a designated system interface
for operational and technical issues. However, the licensee's
progress in implementing this program has been slow.
The licensee's program to document and verify major systems
design bases was continued from the previous assessment period.
The cesign basis documentation (DBD) effort integrated system
and component requirements, actual as-built information, project
commitments, and engineering accident analysis and margins.
Sixteen DBDs were completed this assessment period. The DBDs
r-
have provided a good reference resource for engineering activity
and contributed to the identification and correction of plant
problems. This design base effort is a long term continuing
activity with approximately 40 DBDs planned for future
completion.
'The licensee's steam generators continue to exhibit the
deleterious effects of primary water stress cracking corrosion
as evidenced by the number of tubes requiring plugging during
the fourth refueling outage. Steam generators A, B and C
presently have 6.0, 10.9 and 6.5 percent of their tubes plugged.
Although preventive measures such as Roto peening, shot peening
and stress relieving have been accomplished during previous'
outages. These measures and engineering studies which have
reduced plugging requirements have not provided an ultimate
solution to this problem.
Engineering performance on specific technical issues has been
good and overall performance resulted in a modification backlog
reduction. Engineering provided timely assistance in problem
definition, solution, corrective action, and development of
Justifications for Continued Operation when required to support
plant activities. Specifically, engineering support to opera- ,
tions and maintenance was effective in the evaluation of the ;
hydraulic lock-up of the pressurizer and steam generator level "
transmitters, and re-evaluation of Intermediate Building steam l
line break analysis. Response and evaluation to NRC bulletins
related to nonconforming materials from Pipina Supplies Inc. of
~
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, , , -
22
l
rsey, Steam Generator Crack Propagation, Fastener Testing, and
P e Wall Thinning was timely and aggressive. Engineering
su ort and program management to complete all modifications
poss ' le at power, has resulted in a 17 per cent reduction in
outst ding modifications.
e 1987 refueling outage the as-found Pressurizer Safety
During
Valves (P V) setpoints were significantly higher than allowed by
technical )ecifications. In order to determine the cause of
the high ou'. of tolerance PSV setpoints, the licensee performed
extensive res arch into the effects of test temperature and test
medium on PSV setpoint. The licensee's approach to the
resolution of e setpoint deviation demonstrated a clear
understanding of he issue. The licensee's present PSV and Main
Steam Safety Valve (MSSV) setpoin; test program utilizes one of
the most advanced est methods presently available. This
program exceeds the irements of the test code to which the
licensee is committed.
Toward the end of the as sment period, it was identified that
the licensee performed a Jnadequate design evaluation and
modification that changed fire protection deluge sprinkler
control valves for charcoal hterunitsfromtheopenposition,
~
as described in the FSAR, to 1. e closed position. These changes
were made without adequate e luation and initiation of
appropriate actions to revise he FSAR and operational
procedures where required. These examples suggest an apparent
weakness i_n engineering support th has the potential to leave
an important safety question unre iewed er inadequately
reviewed.
Licensee efforts have been directed the control of
microbiologically induced corrosion, cor cula and soft water
attack in service water piping. EPRI an consultants have
provided assistance in resolving this item. The licensee has
submitted an application to the state depar nt of health and
environmental control requesting permission to chemically treat
this system. With this treatment the license expec ts to
prevent future occurrence of problems such as he reduced
service water flow to the RBCU discussed in the op ations area.
V. C. Sunener has a strong procurement program. The ocurement
staff includes 15 engineers, nine technicians, three i pectors,
and 29 administrative and warehouse personnel. This gr p has a
fully operational commercial grade procurement program ith
testing equipment and technicians to verify material ad
equipment critical parameters. This program has allowed e
licensee to upgrade such parts as transformers, circuit
breakers, switches, relays, fasteners, insulation, and Bellvi e
washers.
m_,_m_n. _ , .u.+-:-.-,------ . - --:---a-- -- - - - - - - - -
_ _ _. .__ . - _ _ _ _ _ _
'
h 22
4
Jersey, Steam Generator Crack Propagation, Fastener Testing, and
Pips Wall Thinning was timely and aggressive. Engineering
support and program management to complete all modifications
.possible at power, has resulted in a 17 per cent reduction in
outstanding modifications.
During the 1987 refueling outage the as-found Pressurizer Safety
Valves (PSV) setpoints were significantly higher than allowed.by
technical specifications. In order to determine the cause of
the high out of tolerance pSV setpoints, the licensee performed
extensive research'into the effects of test temperature and test
medium on PSV setpoint. The licensee's approach to the
resolution of the setpoint deviation demonstrated a clear
understanding of the-issue. The licensee's present PSV and Main
Steam Safety Valves (MSSV) setpoint test program utilizes one of
the most advanced test methods presently available. This
program exceeds the requirements of the test code to which the
licensee is committed.
Toward the end of the assessment period, it was identified that
the licensee performed an inadequate design evaluation and
modification that changed ten fire protection deluge sprinkler
control valves for charcoal filter units from the open. position,
as described in the FSAR, to the closed position. These changes
were made without adequate evaluation and initiation of
appropriate actions to revise the FSAR and operational
procedures where required. These examples suggest an apparent
weakness in modifications control that has the potential to
leave an important safety question unreviewed or inadequately
reviewed.
.
Licensee efforts have been directed at the control of
microbiological 1y induced corrosion, corbicula and oft water
attack in service water piping. EPRI and consultants have
provided assistance in resolving this item. The licensee has
submitted an application to the state department of health and
environmental control requesting permission to chemically treat
this system. With this treatment the licensee expects to
prevent future occurrence of- problems such as the reduced
service water flow to the RBCU discussed in the operations area.
V. C. Sunner has a strong procurement program. The procurement
staff includer 15 engineers, nine technicians, three inspectors,
and 29 administrative and warehouse personnel. This group has a
fully operational commercial grade procurement program with
testing equipment and technicians to verify material and
equipment critical parameters. This program has allowed the
licensee to upgrade such parts as transformers, ci rcuit
breakers, switches, relays, fasteners, insulation, and Bellville
washers.
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