ML20141A959

Forwards SALP Input for Sept 1984 - Feb 1986,per NRR Ofc Ltr 44 & Manual Chapter 0516.Category 2 Assigned for Licensing Activities,Housekeeping & Control Room Behavior.Category 3 Assigned for Operational Events

ML20141A959
Person / Time
Site:	McGuire, Mcguire
Issue date:	03/31/1986
From:	Hood D Office of Nuclear Reactor Regulation
To:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8604040588
Download: ML20141A959 (9)

Text

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Docket Nos.: 50-36$ ,

and 50-370 MAR 311996 MEMORANDUM FOR: Roger D. Walker, Director Division of Reactor Projects Region II THRU: B. J. Youngblood, Director PWR Project Directorate #4 DJvision of PWR Licensing-A, NRR FA0M: Darl S. Hood, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A, NRR

SUBJECT:

UR SALP INPUT - MCGUiGE NUCLEAR STATION, UNITS 1 AND 2 The enclosure provides NRR SALP V input for the period of September 1, 1984, through February 28, 1986. This assessment was conducted according to NP.R Office Letter No. 44 dated January 3, ~2934, and NRC Manual Chapter 0516, Systematic Assessment of Licensec Perfomance. A performance rating of 2 in the area of licensing cctivities for this period has been assigned by NRR. Other functional areas (housekeeping and control room behavior) are rated Category 2, except for the area of operational events which is rated Category 3.

Origitn cisned by:

D. Hacd Gorl S. Hood, Project Manager PWR Project Directorate #4 Divicion of PWR Licensing A. NRi2

Enclosure:

As stated

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f Summary - Licensing Activities

1. Analysis The licensee has declined in performance durir9 this assessment period relative 3

i to the two previous periods. The decline is attrib 2:ed to a need for improve- )

ments in the detail ano adequacy of submittals to the NRC requesting licensing l actions, primarily for changes to technical specifications. The licensee also  !

needs to improve the timeliness of submittais whtii they deal with matters other j than relief from requirements or avoidence of impact on plant operations. The licensee also needs to fmprove analyses and acticns in ccanection with opera-tional esur.ts.

Duke strong points continue to be a highly competent enginenring staff, a heavy involvement with Industry,0wners Group and Standards Committees, and a thorough knowledge of the regulatory environmr.nt.

2. Conclusion The licensee is rated Category 2 in this area.

3. Board Recommendation Licensee should pay increased attention to its submittals to the NRC and should seek to improve the timeliness of various types of responses to NRC requests.

Licensee should strive to be more comprehensive in analyses and actions following operational events.

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ENCLOSURE 1 Docket Nos. 50-369 and 50-370 FACILITY: William B. McGuire f;uclear Station, Units 1 and 2 LICENSEE: Duke Power Company 4 EVALUATION U RIOD: September 1,1984 to February EC,1986 -

FU'_L-POWER LICENSES: July 8, 1931 (Unit 1); May 2'/, 1983 (L* nit 2)

PROJECT KANAGER: Darl S. Hood I. INTRODUCTION This report contains NR'a's input to the MLP Review for McCuire Nuclear Station, Units 1 and 2. The essessnant of the litensee's perfomatice was conducted according to NRR Office Letter No. 44 , NRR Inputs to SALP Pro-cess, dated January 3, 1984 This Office Letter incorporates NRC Manual Chapter 0516 Systematic Asmsent of Licensee Performate.

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SUMMARY

NRC Manua'l Chapter 0516 specifies that each functianal. area evaluated will be assigned a perfomance category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of DAe P!ser Company in the fu.'ctional area of Licensing Activities is rated Category 2. The licensrt -

wat rated Category 1 in the areas of Licensing Activities durir,g the previous two SALP periods.

III. CRITEGIA ,

_ The evaluation criteria used for this assessment are given in NRC Manual '

Chapter 0516 Appendix, Table 1, Eva'luation criteria with Attributes for

• Assessment of Licensee Peefomance.

IV. METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) cno those technical reviewers who expended significarit amounts of etfort c;i K.Guire licensing actions during the current rating period. Using the guide-lines of NRC Manual Chapter 0516, the PM and each reviewer applied spr ofic ,

> evaluation criteria to the relevant licensee perfomar,ce attribt;*.cs, as  ;

delineated in Chapter 0516, and assigned an overall rating category (1, 2 i or 3) to each attribute. The reviewers included this infomation as port of I each Safety Evaluation Report tt'ansmitted fo the D! vision cf PWR Licerising-A )

(or its predecessor, the Division of Licensing). The PM, tfter reviewing the j inputs of the technical reviewers, combined this Snfomation witihis own '

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assessment of liceasee perforrnance and, using appropriate weighting factors, arrhed at a composite rating for the licensee. A writtan evaluation was then prepars:d by the PM and circulated to NRR management for comments, which were incorporated in the final draft.

The basis for this appraisal was the licensee's performance in regards to both plant-specific requests (prirurfly for amendments to change Technical Speciff-ca tions) and responset, to generic issues. These items included those which were either tancluded or sufficiently active during the rating period to pro-vide a basis for assessment.

Plant-Specific Licensing Actions

- Delete surveillance of SG hlowdown - Excore Thermocouple Schedule valves - Increase hacer of RC Loops

- Response to DP0 Tech Specs #ad Position Indication Systern

- Urit 2/ Cycle 2 Reload - Admin. Controls ard Reporting

- Unit 1/ Cycle 3 Reload - RTS Ontage Times

- Storage of Oconee Spent Fuel - Fire Pump Power Source at Unit 2 - Containment Pressure Control System

- Surveillance of Ice Ccndenser Dcors - Doghouse Water Lea l Inst, t - Snobber Inspection Sainple Plan - Increase irt Number of Operable

- SsrYcillshce of CL Accumulator RC Loops

- Surveillance of UHI - UHI Deletion

. - Working Hours of Plant Staff - Operate at 46% power without UHI

- Dose Projections of Kosmal Releases - [ncrease Conte,inment Leak Rate

- Use of ASME Code Cases N-411 eno N-397 - Retention of Fost-Trip Records ,

- Safeguards Generic Licensing Actions

- GL 83-28 (Salem ATWS) Items 1.1, 1.2 - GL 84-14 Replacemenc and Requsl.

!_ 3.1, 3.2, 4.1, 4.2, 4.5.1 Training Programs

- RVLIS and Subcooling Monitar - Detailed Control Room Design,,

- Control of Heavy Loads (Phase I & II) Review

- Safety Parameter Display System - Hydrogen Control

- Eliminatht> of Large primary Pipe Ereaks i

V. ASSESSMENT OF PERFORMANCE ATTRIBUTES A. Ucqsing Activities The licensee's performance evaluation is based on a constderation of six of.the seven attributes specified in NRC Manual thapter 0516, These ere:

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-- flanagement Involvement and Control in Assuring Quality 1

-- Approach to Resolution to Technicol Issues from a Safety Standpoint 1

-- Responsiveness to NRC InitiativeJ I

-- Enforcement History

-- Staffing

-- Training l l

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1 For the remaining attribute (Reporting and Analysis of Reportable Events), no basis exists for an NRR evaluation for the functional area of Licensing l Activities.

1. Manage. ment Involvement and Control in Assuring Quality There is evidence of prior planning and t,ssignment of priorities, and decision making appears to be at a level that ensures management review. Well stated, controlled, and explicit procedures are in place for control of activities.

Reviews are generally timely, and technically sound. Communications with NRR is frequent and effective.

! Managemut involvement was particularly evident during NPC reviews and meetings on licensees requests involving plant modifications (e.g., storage of Dionee spent fuel in McGuire Unit 2 pool, UHI deletion, RTD bypass removal). Effective management involvement was also evidenced by crapletion of environmental qual, ification of electrical equipment within the schedule specified by 10.CFR 50.49.

Increased management attention is needed to impreve the adequacy and centent of Duke's proposed technical specificction amendments. 59vera! submittals were returned by NRR without processing because tiiey contained ambiguous and inadequate bases for No Significant Hazards Considerations. Five submittals were denied s

by the NRC in total or in part bEause of inadequate technical justification.

The absence of appropriate restrictfor.s on applicability within Duke's request for operation at 40 power without UHI for the Unit with 0FA fuel, and the absence of an effective implementation date for the spent fuel pool rerack amend-ment, .'esulted in amendments requiring followup action after issuance. Sta ff review of one cubmittal involving Doghouta Water level Instrumentation was complicated by the absence of any descriptive system infonnation in the sub-mittal or in the FSAR.

Rating: Category 2  ;

2. Approach to Resolution of Technical Issues from a Safety Standpoint

• The licensee understands the technical issues and the responses are generally sound. The licensee considers car'efully and thoroughly *.he impact of various NRC requests and positions on the plant. Conservatism is generally exhibited.

This resulted in efficient reviews by NRR for licensee's request associated

( with reload amendments for Unit 1 Cycle 3 and Unit 2 Cycle 2, storage of Oconee fuel at Unit 2 UHI deletion, increased containment integrated leak rate criterion, detailed control room design reviews and safeguards programs, i

The licensee understands well the regulatory environment and takes an active role from the safety standpoint. Duke often takes tne lead or is an active  ;

participant with the nuclear industry to help retolve matters of generic Concern.

For example, the licensee participated in the Westinghouse Owners Group to develop improved steam generator tube rupture and small-break LOCA methods.

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Licensee also plays a leadership role in current NRC-Industry efforts to improve Technical ,$pecifications. In response to NRC positions regarding records on RTS Breaker Maintenance, Duke has committed to work with appro-priate ANSI committees to determine generic positions regarding the appro-priate retention period for cost-trip records.

NRR recomends continued and more frequent use of combined facility submittals when requesting tectnical specification changes. This should provide a needed improvement in cocedination and consistency of position among Duke facilities while providing for more efficient use of man power resources. It should also provide for more timely requests on the part of each individual facility. For example, the request on McGuire to increase the number of operable and operating RC loops consistent with the safety analyses occurred more than a year after the same correction had been identified on Catawba.

Rating: Category 2

3. Re:ponsiveness to NRC Initiatives The licensee usually provides timely responses to NRC requests for information.

Responses to technical itsues are generally complete and acceptable resolutions are initially proposed in most cases. The licensee has provided timely response to a large number of staff surveys and telephone requests, such as the surveys regarding diesel generator requirements for cold fast starts.

Duke attemots to meet deadlines and notifies NRR when they cannot be met. How-ever, it appears that the licensee is more responsive to those issues that Duke considert, as having hioher priority (these issues affecting plarit cperation or modifications and involving relief from requirements). Issues to which Duke assigns lower priority frequently require schedule extensions.

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Although licensee's responses are generally timely, a notable delay of several months occurred in the case of licensee's reply to NRR's request for comments; regarding a technical reviewer's differing professional opinion based upon an earlier review of the McGuire Technical Specifications. This delay has impacted the Comission's schedule for completing review of the plant-specific items identified in the NRR request.

Rating: Category 2

4. Enforcement History NRR provided technical support to Region II regarding the technical resolution of several matters which were associated with enforcement actions. NRR finds that the initial approach by Duke to establish operability of the Nuclear Service Water System by opening unit cross-connect valves and a November 3, 1985, decision to repair during startup valves which isolate the Volume Control ,

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l Tank, demonstrate a rieed for timely and improved coordination between Station and Corporate licensing staff in the interpretation of Technical Specifications and Section XI Code requirements. NRR believes Duke should assume a more aggressive role in pursuing design changes to imnrove effective sustained operation of the Auxiliary Building Filtered Ver.t.ilation Exhaust System during humid conditions. From our review of licensee's responses to enforce-ment issues, NRR finds licensee's resolutions to be generally technically sound and effective.

Rating: Category 2 i

5. Reporting and Analysis of Reportable Events I . There is no basis for an NRR evaluation of this attribute with respect to the functional area of licensing activities.

6. Staffing The assessment is based primarily on (1) licensing activities associated with Technical Specification changes regarding Forking hours and overtime for station personnel involved with safety-related activities, (2) review of safeguards activities, and (3) observations during site visits. The licensee appears to be adequately staffed with key positions identified and filled.

Engineering resources appear to be ample with favorable turnover rates.

Licensee performs its own A/E work and plans to provide services for others l as well.

Rating: Category 2

7. Training and Oualification Effectiveness

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The assessment is based on NRR review of licensee's Requalification Program for NRC Licensed Personnel and the Operator Replacement Training Program for

• the McGuire Nuclear Station, submitted in response to Generic Letter 84-14. The NRC found that the programs meet or exceed the criteria of 10 CFR 55 and NUREG-0737 and, therefore, are acceptable. The assessment is also based upon safe-guards programs which were found to meet or exceed staff requirements.

Rating: Category 1 B. OTHER FUNCTIONAL AREAS

1. Housekeeping and Control Room Behavior During site visits on June 21 September 9 and October 8, 9, 21 and 22,1985, the staff toured several plant areas including the Auxiliary Building, Turbine I Building, Control Room, and Safe Shutdown Facility. The staff found the plant to be in relatively gorJ order with respect to cleanliness, and housekeeping.

l Activities in the control room were observed to be conducted in a professional I manner with assigned personnel appearing to be alert and atteni.ive to duty. l Staff morale appeared to be high. Most personnel seemed to exhibit pride in I their facility and in their l,5s. '

Rating: Category 2 l l

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2. Operational and tonstructicn Events During the report period McGuire 1 veported 32 everts to the NRC Operations Center as required by 10 CFR 50.72, Six of these involved reactor scrams and ]

eight involved tne actuation of Engineered Safety Features (ESF). Of the six 1 reactor scrams, all were from reactor power levels of greater than 90%. Sub- ]

sequent to these scrams, s) stems generally functioneel as designed. The only exception was after a dual-unit scram caused by lost of instrument air. That )

particular scram was complicated by the burning out of both VCT isolation valve i motor operators. The condition of the motor operators wss not recognized i until approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> after the event and was not reported to the NRC for 10 weeks.

McGuire Unit 2 reported 44 events during the report period,19 involving reactor scrams and nine involving ESF actuations. Of the 19 reactor scrams reported by McGuire 'i,10 occurred during power operetions of 90% or greater,  ;

4 occurred during hot-standby or shutdown, and the remaining five at low and )

intermediate power levels (3-60%). Two of the scrams from full power were complicated by subsequent failures: on October 26,.1985 after a turbine i trip / reactor trip, operators were maintaining SG levols using bypass valves i when a leaking main feedenter regulator valve caused SG-3 level to rise to the hi-hi setpoint, isolating main feedwater and auto-startf ag auxiliary-feed.

! This appeared to be a random failure and the leaking valve was subsequently rese3ted successfully. The second scram with complication.s occurred on j l July 12, 1985 when technicians testing the reactor trip breakers and bypass 1 trip breakers caused two separate main feedwater isolations. This occurrence appears to be a procedural and training icidequacy. j i

McGuire was a topic of discussion at six Operating Reactor Events Briefings.

The most notable of these discussions addressed the dual unit trip that occurred on November 2,1985, as a result of the loss of instrument air. Two months later a subsequent briefing described degradation of the high pressure

1. injection system occurring during the startup on the day following that same .'

4 November 2,1985 loss of instrument air. These events appear to provide ,

evidence that the licensee's follow-up analyses and actions are not thorough

-j enough. Other examples for briefings are the recurrence of upper head in-jection problems on both units (10/19/84, 10/30/84, 11/1/84) and cross-connect l problems with the Nuclear Service Water System (10/9/85, 3/11/86) affecting i both units.

Events at the McGuire site are generally reported within the required time ,

period following the occurrence. Reporting appears to be accurate and conservative. The licensee sometimes provides updates and courtesy calls to assure that events are being communicated properly. l Based on the above observations, we are of the opinion that the licensee '

has been responsive in reporting events, but has not been comprehensive in some of the follow-up analyses and actions subsequent to events. l l Rating: Category 3 l

F 7-0 VI. CONCLUSION Based on NRR's assessment of licensing activities and other functional areas during the period from September 1,1984 to February 28, 1985, the overall rating for Duke Power Company's performance for the McGuire Nuclear Station, Units 1 and 2, is Category 2. This decline from previous assessments primarily -

reflects a need for Duke to provide increased attention to the detail and adequacy of submittals to the NRC requesting changes to the Technical Spec-ification, and a need to improve the timeliness of submittals other than those seeking relief or impacting plant operations. It also reflects a need for the licensee to be more comprehensive in follow-up analyses and actions after operating events. The licensee's approach to the resolution of technical issues is generally sound and conservative; and the licensee is usually responsive to NRC initiatives.

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