ML18152A032
| ML18152A032 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/09/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A033 | List: |
| References | |
| 50-280-92-10, 50-281-92-10, NUDOCS 9207020238 | |
| Download: ML18152A032 (30) | |
See also: IR 05000280/1992010
Text
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--*----(-~- -**
. - __ * ..... -_ .... -****- '--'-----,-*.
ENCLOSURE
INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION II.
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-280,281/92-10
VIRGINIA ELECTRIC AND POWER COMPANY
SURRY UNITS 1 AND 2
FROM MARCH 31, 1991 THROUGH APRIL 4, 1992
9207020238 920609
ADOCK 05000280
G
- \\
I.
II.
III.
IV.
v.
TABLE OF CONTENTS
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
SUMMARY OF RESULTS
Overview
.......
. . . . . . . .
1
3
CRITERIA. .................*.*....... *-.................... . 3
PERFORMANCE ANALYSIS ........ .
A.
Plant Operations ****.*...******
B.
Radiological Controls
. . . . . . . . . . . .
C.
Maintenance/Surveillance ************
D.
Emergency Preparedness *..***.
E.
Security ............................ .
F.
Engineering/Technical Support ***.
G.
Safety Assessment/Quality,Verification
- * * * 4
- * * * 4
7
- * * * * * * * * * * * * 9
. ....*...**... 14
. ........ . 16
- *** 17
- 21
SUPPORTING DATA AND SUMMARIES ***..***.**..***********..** 2 5
A.
Major Licensee Activities **.***.**.*.*********. 25
B.
Major Direct Inspection and Review Activities ****** 26
c.
Escalated Enforcement Action.................
.26
D.
Licensee Conferences Held During Appraisal Period ** 26
E.
Confirmation of Action Letters..
- *** 27
F.
Review of Licensee Event Reports
- .*
.27
G.
Licensing Activities......
. **..*************.* 28
H.
Enforcement Activity
- .
- ...*.
- ****** 28
I.
Reactor Trips * * * . * * .
. . * * *
- *
- * * *
- *.* 28
,; '
-.\\
I.
-~ ** *--,-"'* -*-- *** -'---~-*-*~- --**-----'-~- ~._._.- ~-- --
-~.~-*-* *----**-U ~* . -*
lNTRODUCTION
The Systematic Assessment of Licensee Performance (SALP)
program is an integrated* Nuclear* Regulatory Commission (NRC) *
staff effort to collect available observations and data on a
- periodic basis and to evaluate licensee performance on the
basis of this information~
The SALP 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
assessment of their facility's .performance in each
functional area. *
An NRC SALP Board, composed of the staff members listed
below, met on May 5, 1992, to review the observations and
data on performance and to assess licensee performance in
accordance with Chapter NRC-0516, "Systematic Assessment of
L;i.censee Performance."
,
This report is the NRC's assessment of the licensee's safety
performance at Surry for the period March 31, 1991 through
April 4, 1992.
The SALP Board for Surry Units 1 an~ 2 was composed of:
L.A. Reyes, Director, Division of Reactor Projects
(DRP), Region II (RII)
E.W. Merschoff, Deputy Director, Division of Reactor
Safety, RII
B. s. Mailett, Deputy Director, Division of Radiation
Safety and Safeguards, RII
M. V. Sinkule, Chief, DRP Branch 2, RII
M. w. Branch, Senior Resident Inspector, Surry, DRP,
RII
H. N. Berkow, Project Director, Directorate,. II-2,
Office of Nuclear Reactor Regulation (NRR)
B. c .. Buckley, Senior Project Manager, Surry, NRR
Attendees at SALP Board Meeting
P. E. Fredrickson, Chief, DRP Section 2A, RII
A. B. Ruff, Project Engineer, DRP Section 2A, RII
Regional based inspectors and supervisors attended
discussion for the applicable functio~al area.
II.
SUMMARY OF RESULTS
Surry was operated in a safe manner during the assessment
period.
The Plant Operations functional area improved to a
superior level of performance and the Radiological Controls,
2
Emergency Preparedness and Security areas continued to
perform at the superior level.
The improving performance
trend in the Safety Assessment/Quality Verificat.ion area
which was evident during the last assessment period did not
continue during this period.
Both the Engineering/Technical
Support and the Maintenance/Surveillance functional areas
remained at a good performance level~
Several activities
affected more than one functional area.
Material condition
directly impacted the Maintenance/Surveillance functional**
area and indirectly affected other areas such as Plant
Operations.
The upgraded procedures are a definite
improvement.
Some procedure upgrade efforts still lag
others as noted in the Plant Operations and
Maintenance/surveillance areas.
Performance in the Plant Operations area improved to a
superior level, primarily due to the management commitment
to safe operations and to the operators' excellent
performance and their low threshold in identifying problems.
Other contributors were improved plant housekeeping, the
continued innovative use of computer systems and the overall
improvement in operations procedures.
Performance in the Radiological Controls area remained at a
superior level as a result of several contributors.
Management provided strong support to the radiation
protection (RP) program.
Both health physics (HP) and
station personnel worked in concert to reduce the number of
personnel contaminations.
Job planning and w_orker /HP
involvement also continued to reduce the collective dose.
In addition, the new radwaste building contributed to the
high level of performance by significantly reducing the
amount of effluent released from the site.
Improvements in the Maintenance/Surveillance area
performance were noted.
However, when contrasted with
needed material improvements, the overall performance
remained constant.
Although the maintenance backlog
improved from the last period, as did the performance of the
outage and Planning Department, several problems continued
from the last period and contributed to reduced performance.
Specific continuing problems were the prioritization_of
procedures needing upgrading and the slow improvement of the
station's material condition.
Direct management involvement contributed to the continued
superior performance in the Emergency Preparedness
functional area.
This was demonstrated by the ability to
maintain both personnel and facilities ready for any station
emergency.
Performance in the Security area was also maintained at a
superior level.
The professionalism and dedication of the
3
security personnel contributed significantly to this effort.
Prompt response-to identified security problems also
contributed to the high performance level.
Engineering/Technical support performance varied.
Notable
strengths were the motor operated valve (MOV) program,
engineering outage support, and the overall good
communication between Engineering arid other departments.
Areas where improvement was needed included setpoint control
and sensitivity to the potentially serious effects of
station internal flooding.
The improving performance trend noted at the end of the last
assessment_period was not sustained in the Safety
Assessment/Quality Verification functional area during this
period.
Several activities, such as the self-assessment
program and resolution of licensee-perceived safety-
significant issues, remained at a high level of performance.
However, the continued difficulty of resolving recurring
problems detracted from the previous improving trend.
Overview
Performance ratings assigned for the last assessment period
and the current period are shown below.
Functional Area
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical
Support
Safety Assessment/
Quality Verification
III. CRITERIA
Rating Last
Period
2 Improving
1
2
1
1
2
2 Improving*
Rating This
Period
1
1
2
1
1
~
2
The evaluation criteria which were used, as applicable, to
assess each functional area, are described in detail-in NRC
Manual Chapter 0516.
This Chapter is in the Public Document
Room files.
Therefore, these criteria are not repeated
here, but will be presented.in detail at the public meeting
to be held with the licensee management.
. I
IV. PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
4
This functional area addresses the control and performance
of activities directly related to operating the units,
including fire protection.
Unit 1 operated in an excellent manner during the assessment
period. The unit completed a. run of 379 days of continuous
operation.
The unit experienced two turbine runbacks and
one manual reactor trip during the period.
At the end of
the assessment period the unit was in the middle of a
scheduled 64 day refueling outage.
Unit 2 operated inconsistently throughout the assessment
period due to equipment-related problems.
Equipment
problems resulted in: l)delaying plant startup following a
refueling outage, 2)two automatic reactor trips (one with
safety injection), 3)four forced outages, and 4)two turbine
runbacks.
Overall ope~ator performance was good, with few personnel
errors.
Early in the assessment period, the licensee
identified several operator errors that occurred during the
Unit 1 outage which were attributed to a lack of attention
to detail and sensitivity to control of plant configuration.
The errors included- failure to tag out the correct emergency
diesel generator {EDG) fuel transfer pump, failure to sample
service water (SW) to a component cooling water heat
exchanger, and failure to properly control the emergency
ventilation system configuration.
Operation's management
involvement in review of these events and actions
implemented were effective in improving operator perfor-_
mance.
Throughout the remainder of the period operator
errors were minimal.
Good communications and self-checking
techniques were typical among operations personnel, and
communications between operations and other departments were
also good.
Systems that required maintenance were properly
isolated, returned to service and tested.
Operators had a low threshold_for identifying problems.
Station deviations were-written by operators whenever they
perceived plant problems or whenever personnel actions were
questionable.
Operators continued to respond to events in an excellent
manner.
Operators responded to two automatic reactor trips,
one manual reactor trip and four turbine runbacks~promptly
and conservatively.
Although the turbine runbacks were
challenging, the operators were able to safely maintain the
5
unit at power when responding to the runback events.
Also,
operator actions were good during unit startups, shutdowns
and reduced inventory conditions.
Shift licensed staffing levels continued to be a
strength.
Operating shifts were staffed with a minimum
of four senior reactor operators (except that one shift
had three SROs) and five reactor operators which was
well in excess of Technical Specifications (TS) and 10
CFR 50.54 minimum staffing requirements. Operator
turnover was very low. Overtime worked by licensed and
non-li.censed operators was not excessive and was
closely monitored by management.
At the end of the
assessment period operator*working conditions were
improved by consolidation and upgrading Operations
Department work areas.
The emergency operating procedures (EOP) were updated this*
assessment period to rectify inconsistence that were
identified during the previous assessment period.
The
updated EOPs aided to the operators in responding to events.
The fire protection program was well implemented*.
Fire
brigade and control room staffing for alternate safe
shutdown for fire events were considered effective.
Procedures for implementing the fire protection program were
good; however, a weakness in station policy was identified
involving control of boundary doors for areas protected with
a carbon dioxide fire suppression system *. On two occasions
station personnel identified doors that were improperly
blocked open without a fire watch being stationed, as
required by TS. - This was satisfactorily resolved by
installing signs on*the doors warning personnel that the
doors require special controls when opened.
Housekeeping throughout the plant was generally good during
the assessment period.
This area was identified as. a
challenge during the previou~ assessment period.
Management's commitment to improve standards was evident as
the station's painting program progressed into the diesel
generator rooms and charging pump cubicles.
Housekeeping in
the condensate polishing building, boric acid flats,-turbine
building and auxiliary building was improved by repainting
walls and refinishing floors.
The refinishing of floors
occas.ionally _ resulted in poor .. housekeeplng in adjacent
areas.
Increased management attention, however,
subsequently improved housekeeping in these areas as well.
Housekeeping in the _fuel pool area was excellent.
Management demonstrated a strong commitment to safe
operations throughout the assessment period.
This was
clearly evident by the continued support of policies and
programs implemented.in this and previous assessment periods
L
6
in the areas of decision making, minimizing control room
annunciators, configuration management, *upgraded procedures,
and development of computer programs.
These policies and
programs are discussed in the following.paragraphs.
Generally, management made conservative decisions for
plant operations. -On one occasion Unit 2 was
voluntarily shutdown to repair reactor coolant system
leakage prior to approaching the TS reactor coolant
system leakage limit.
On another occasion a Unit 2
outage was extended in order to perform a modification
that improved plant safety and reduced reliance on
operator compensatory actions._ Occasionally, however,
manual operator actions were used to aid in the
operation of components in *1ieu of promptly repairing
the component.
The station policy to maintain a "black board" condition for
control room annunciators was generally effective in
minimizing the number of lit control room indicators.
Plant component labeling problems were identified in
previous assessment periods.* The Configuration Management
Program to identify and relabel safety related and nonsafety
related plant equipment, initiated during the previous
assessment period, was on schedule.
The majority of the
verification walkdowns were complete and the actua,l labeling
_of plant equipment has commenced with the initial
concentration on the new radwaste facility and then on the
Unit 1 containment.
The program's overall completion date
is scheduled for March 1993.
Also, no problems were noted*
with the use of control room critical drawings during the
~ssessment period.
Operations Department procedures were generally good.
At
the end of the assessment period, the operations portion of
the Technical Procedure Upgrade Program (TPUP) was
approximately one-third complete, which exceeded program
goals.
This program was closely monitored by management.
Reports were routinely issued to keep management informed of
program status and station personnel were surveyed quarterly
in order to evaluate program effectiveness.
Plant startup
and reduced inventory procedures were examples of quality
procedures.
However, procedures that had not been upgraded
were identified as-being --inadequate and contributed to
problems in the areas of high oxygen concentration in the
waste gas decay tanks (WGDT), use of the turbine load
limiter as described in the Updated Final Safety Analysis
Report (UFSAR), and establishment of containment integrity
during refueling operations.
These issues are also
discussed in the Safety Assessment/Quality Verification
area.
.,
_.,__ ' .. *-*-** .... *: ...... .. -.. * .. ________ .._ ------~-~-'----.... *---- *--*~---***-*----***-* *-
.,
7
The licensee continued to be innovative in using computer
systems to improve the effectiveness of-plant operation.
A
new computer program was implemented during the assessment
period to record and trend hours spent in TS action
statements. This new computer program enhanced the ability
to focus on problem areas. The ability* to*retrieve and
display parameters easily continued to be a-strength;
primarily through the extensive use of hand-held computer~-
for taking logs throughout the plant.
The licensee
continued the development of additional computer programs
including one for annunciator response procedures and for TS
in.formation.
One violation was issued during the assessment period.
2.-
Performance Rating
Category:
1
3.
Board Recommendations
None
B.
Radiological Controls
1.
Analysis
This functional area addresses those activities related to
radiation safety and primary/secondary chemistry control.
The licensee's RP department had*a highly qualified staff
and station management continued to be actively involved and
supportive of the RP Program.
Management oversight of the
program was, in part, maintained through a corrective action
program that promptly and consistently recognized and
.address_ed non-reportable radiological problems.
The
licensee has several programs for self-assessment and
audits.
For example, quality assurance (QA) performed
radiological audits and comprehensive (two-three month)
assessments, corporate RP performed radiological assessments
and station RP monitored radiological compliance through
radiation problem reports and daily assessments by HP
technicians.
The licensee's program to provide specialized training
exceeded the requirements of the regulations and continued
to make positive contributions to the RP program.
For
example: 1) the licensee sent 36 HP technicians (in training
shifts of six people each) to other utilities for one-week
familiarizations; 2) prior to the recent outage, all site
services personnel received a day of training in dose
reduction; and 3) in preparation for resistance temperature
detector (RTD) bypass manifold removal, tpe licensee
8*
constructed a realist.ic full-size mockup and ensured that
all personnel that would be working on in-plant RTDs were
fully trained.
In addition, the licensee added a group
training mockup (GTM) to its Advanced Radiation Worker (ARW)
Program.
The GTM represents a plant system comprised of
valves, demineralizers, pumps, and electrical cabinets that
are representative of those in-plant.
The licensee
completed the training of 88 percent of mechanical
maintenance personnel as ARW-qualified and continued to
achieve 100 percent attendance at continuing training during
outage periods.
Participation by station personnel from all departments was
effective in controlling contamination.
The
number of
personnel contaminations in this assessment period was 164,
as opposed to 187 in the previous assessment period.
Although progress was slow during the beginning of the
assessment period, the licensee's reclamation project
received increased attention to reduce the amount of
contaminated area from 11,500 ft 2 at the end of the last
- assessment period to 9,645 ft 2 at the end of this period.
The licensee continued to reduce the collective dose at the
station, with the 1991 value significantly.less than the
1990 value.
A primary factor in the station's dose
reduction was the active ALARA staff and worker involvement
in dose reduction.
A result of this effort was that the
dose to individuals working on the ROT bypass manifold
removal project was s*ignificantly less than* projected.
Another factor was the station's efforts to reduce the out-
of-core source term, such as, hot spot flushes, elevated pH,
zircoloy fuel grid spacers, early shutdown boration,
peroxide injection, and removal of the Unit 1 RTD bypass
lines.
A third factor was the HP Engineering personnel and
Station Systems/Design Engineering working together.to
install lead shielding both temporarily and permanently, at
key locations in operating systems both inside and outside
containment.
Some dose rate reductions of 10-fold were
realized.
The licensee used innovative methods of dose and
source term reduction, such as green flashing lights to
denote low dose waiting areas in containment; telemetric
dosimetry to allow HP to monitor workers dose remotely; and
a video disc system for viewing plant systems for planning
and briefing purposes.
The licensee took significant steps to control the amounts
of radioactive effluents released from the site.
For
example, the new radwaste facility, which was brought on
line late in the assessment period,. significantly reduced
the release of radioactivity in liquids from the site.
Since the new radwaste facility was *brought on line during
the latter part of the assessment period, the licensee's
records indicated essentially no curies released.* The tota.l
L
. 9
body and organ doses for these effluents for 1991 were less
than 2 percent of the 40 CFR 190 limits.-
_There were no
unplanned releases that required reporting to the NRC and
there were no significant changes in th~ amounts of
effluents released from the site during the assessment
period.
During the last assessment period, the licensee had
.
continuing problems with radiation monitors.
This was not
observed during this period and the licensee's Radiation
Monitoring System was effeqtively maintained.* The testing
anp calibration of monitors was performed as required.
Only
one monitor was inoperable for a period of greater than 30
days. Alternate sampling and analysis were performed as
required.
The monitor was *replaced and satisfactorily
operated during the remainder of the assessment period *.
The licensee's program for monitoring and controlling
primary chemistry parameters was effective. TS primary
chemistry parameters were maintained within limits.
Other*
primary chemistry parameters were generally maintained
within administrative limits, and when outside these limits,
were r*eturned in a timely manner.
In addition, the licensee
was in agreement with the radioisotopes analyzed as part of
the NRC's Confirmatory Measurements Program.
The licensee's program for radioactive waste shipments was
good in that technicians were adequately trained and
performed their duties competently.
However, there was one
problem where the licensee failed to properly identify the
physical form of radioactive material prior to it being
released for transportation on a public.highway.
'
.
.
One violation was issued during the assessment period.
2.
Performance Rating
Category:
1
3. *
Board Recol'limendations
None
C.
Maintenance/Surveillance
1.
Analysis
This functional area addresses those activities related to
equipment condition, maintenance, surveillance performance,
and equipment testing.
overall.plant material condition was considered to be
satisfactory. * Significant improvements involved
,.
10
installation of auxiliary feedwater (AFW) full flow
recirculation test piping, fuel transfer cart modification,
main feedwater flow element replacement, installation of new
letdown valves, installation of new Ame~ican Society of
Mechcinical Engineers (ASME)Section XI instrumentation,
coating of the SW piping, and ~ecovery of the gas stripper.,
which greatly reduced the gaseous releases to the
atmosphere.
Areas that have been recognized by the licen~ee
as needing additional management attention were control rod
drive (CRD) failures, RTD manifold leaks, containment
personnel airlock malfunctions, sticking SW temperature
control valves for the high head safety injection (HHS!)
pumps, and rain and ground water leaks.
since 1990, failed
or degraded CRDs have resulted in unit runbacks and forced
outages.
Several RTD bypass manifold leaks resulted in
forced outages.
At the end of the assessment period these
manifolds were being removed on Unit 1 and are scheduled to
be removed during the February 1993 Unit 2 refueling outage.
Containment personnel airlock malfunctions resulted in
.
personnel being trapped in the airlock and delayed refueling
activities.
Rain water and ground water leaks onto safety
related equipment continued to be a problem.
Late in the
assessment periog, the licensee completed an evaluation of
the condition of the roofs and the necessary paving and
grading to correct the rain and ground water intrusion
problem.
A five year plan was developed.
A contract for
auxiliary building roof repair was issued and work was
started.
The staffing level in the Maintenance Department, except for
maintenance engineering, was adequate, similar to the
previous assessment period.
The maintenance engineers are
responsible for the Cause Determination Evaluation (COE)
Program.
The backlog of CDEs (formerly named Component
Failure Evaluation Program) was noted as needing improvement
during the previous assessment period and, although some
improvements were made, the backlog increased about.ten
percent during this period.
This growth was caused
primarily by an increase in the number of requests.
At the
end of the assessment period, the licensee was preparing to
increase the maintenance engineering staff to decrease the
backlog and to accommodate the increase in the number of
evaluation requests.
Although staffing in this area was
low, the quality of work remained good.
An example of a
thoroughcomponent-failure.analysis involved problems
identified on two of the EDGs when they failed to achieve
rated speed during automatic starts.
Also, the addition of
a new metallurgical laboratory greatly .increased the
technical capabilities for failure investigation of
components.
Maintenance foreman and craft personnel generally
demonstrated good job skills during the assessment period.
L
11
Strengths in this area were identified in the coordination
of numerous maintenance activities associated with
switchyard transformer replacement, trouble shooting
activities on a reactor trip breaker, apd the replacement of
a main steam pressure transmitter.
Problems were identified
with foreign material exclusion in the SW system and
improper control of trouble shooting activities associated
with the CRD system. *
The maintenance training and qualification program was good
and contributed to a thorough understanding of the work.
The presence of equipment, mockup, and dedicated training
specialists at the training facilities allowed the licensee
to train all levels of craft and the maintenance teams.
A high maintenance backlog existed during several of the
previous assessment periods.
A significant amount of
management attention, including improved planning,
availability of parts, and high-level reporting, was applied
to this area and effective results were achieved.
The*
number of non-outage corrective maintenance work orders
decreased by approximately one-half during this assessment
period.
The average age of these work orders also decreased
by almost two-thirds.
Unavailability of parts was a contributor to the maintenance
backlog during the previous assessment period.
The licensee
estaplished a goal of less than ten percent of the work
orders on hold for material unavailability in 1991.
This
goal was met by a large margin, with less than two percent
of the work orders on hold for lack of materials or the
unavailability of parts at the end of the assessment period.
The outage and Planing Department's performance improved
during this assessment period particularly in the area of
planning and scheduling.
Improved planning contributed to a
decrease in work order backlog.
The planning weakn~sses
identified in the previous aspessment period were adequately
addressed and improvements in planning/operation
communication were noted.
This effort contributed to the
decrease in the non-outage corrective maintenance backlog
and the decrease in the average age of the work orders.
The
planning process was made more effective by assigning an
individual planner to a particular maintenance crew.
During
the outages, a.train availability window method for working
on systems helped to better organize the related outage
work.
Maintenance performance of outage related activities during
the Unit 2 outage early in the assessment period was good.
Maintenance engineering support in the resolution of craft
problems was noteworthy.
Individual maintenance crews were
assigned either specific components and/or specific areas of
12
responsibility.
This technique promoted accountability and
ownership.
Good job skills were demonstrated by craft
personnel and foremen.
The efficiency and knowledge that
.was demonstrated during the trouble shopting of a reactor
trip breaker was also a strength in this area.
Two
personnel errors resulted in significant plant problems.
The first involved an event that necessitated a manual trip.
of the reactor when the removal of a fuse caused the
dropping of a second control rod.
The second issue involved
a-partial blockage of SW.flow to the recirculation spray-
heat exchanger (RSHX) when the foreign material exclusion
pr.ogram was not followed and a rain suit was left in the SW
line.
The TPUP progressed better than planned during this period.
This program involves approximately 3100 maintenance
procedures and was approximately 22 percent complete.
The
quality of the new procedures was good. Procedural
adherence, which was identified as a problem during the
previous assessment period, was much improved during this
period.
However, the upgrade of instrumentation and control
(I&C) procedures was approximately 50% behind schedule.
The
schedule problems with the I&C procedures was also noted in
the previous assessment period.
The* lack of detail in older
generic maintenance procedures contributed to equipment
problems.
A specific problem with air operator procedures
involved a containment isolation valve that failed to close
because too many springs had been installed in the valve
seat and a pressurizer spray valve that malfunctioned
because of improper assembly.
At the end of the assessment
period all of* the air operated valve maintenance procedures
were being revised.
The Preventive Maintenance. (PM) Program was effectively
implemented.
-The deferral rate for PMs was very low.
An
isolated weakness was identified in the program when the
licensee discovered that several pressure switches installed
on systems important to safety were not in a periodic
calibration program.
Reliability centered maintenance
studies were initiated and completed for several safety-
related systems.
The maintenance trending program data base
was derived from the*work plan tracking system and station
deviation reports.
This program functioned well and was
noted as an improvement from the previous assessment period.
The MOV program continued to be a strength during this
assessment period.
The licensee displayed in-depth
knowledge and a clear understanding of MOV issues which were
enhanced by participation in several MOV user groups.
Several concerns in the program were identified which
involved engineering assumptions and electrical
calculations.
These program corrections were made in time
r
' '
13
for implementation during the Unit 1 Spring 1992 refueling
outage.
During the previous assessment period, a new Post-
.Maintenance Test Program (PMT) was implemented.
The program
uses a series of matrixes of required tests for each of the
program's safety-related components.
Even though several
problems occurred during the assessment period, the overa~l
program was effective in developing good tests .. one of the
problems occurred during a trip of Unit 2 in August 1991
when the #3 EDG automatically started but did not achieve
its nominal speed and was declared inoperable *.
The root
cause was lack of management oversight and control of
functions related to maintenance activities.
The site
safety committee had approved instructions for governor
adjustment using a fast start of the EDG, which would have.
detected the problem of low speed and inoperability, but the
PMT followers in the work package only required a slow
start.
Implementation of the surveillance program was generally
good during the assessment period.
With the installation of
the new AFW full-flow recirculation flow path, surveillance
for both units' AFW pumps was enhanced.
Performance of
these surveillances was closely tracked because of proplems
identified during past assessment periods.
Post-criticality
testing for Unit 2 startup was adequate.
The accurate
prediction of the reactor power distribution with a fully
inserted rod demonstrated the licensee~s*strength in core
analysis.
However, there were two missed surveillances that
occurred during the previous assessment period but were
discovered in this period.
In one instance the interval
between surveillances on Unit 2 hot channel factors exceeded
the TS requirements and in the other, a containment spray
surveillance exceeded its grace period.
The licensee's
corrective actions .appeared to be effective since instances
of missed survei.llances did not occur during this assessment
period.
However, several surveillances were considered to
be ineffectively implemented in that the procedures were
inadequate.
These examples involved the motor driven AFW
pump undervoltage start relays having improper set-points
designated in the procedure and a relay in the safety
injection system logic sequence not being tested as an
active component.
These surveillances were repeated to
ensure operability.
Three violations were issued during the assessment period.
2.
Performance Rating
Category:
2
V
I
1
14.
3.
Board Recommendations
As in the last assessment period, material condition
. deficiencies continued to contribute to:operations and
maintenance problems *. Although the Board recognizes that
there has been improvement.in this area, continued
management attention is needed.
D.
1.
Analysis
- This functional area addresses * activities reiated to the
Emergency Plan, support for and training of emergency
response organizations both onsite and offsite, and licensee
performance* during emergency exercises and actual events.*
The licensee continued to maintain an excellent. emergency
preparedness program.
Management support was evident
throughout the period as the licensee continued to maintain
in a state of readiness the basic emergency preparedness
elements needed to implement the Emergency Plan and its
procedures in response to emergency events.
Program
strengths included.a strong.management commitment to
emergency preparedness staffing resulting in an effective
base of* expertise at bo_th corporate and site levels.
The
licensee also effectively addressed routine and exercise
inspection findings through the use of a thorough corrective
action program as well as a comprehensive open issues
tracking system.
Other program strengths identified
included an effective emergency response organization
training program and a comprehensive independent audit
function. *
The licensee continued to build on a strong emergency
response capability through numerous self-initiated program.
enhancements.
The licensee conducted several full-facility
activation exercises in order to maintain a heightened state
of overall response readiness.
In addition, the licensee
conducted several specialty drills such as offsite
notification.
Other licensee initiatives during the
assessment period included enhancements in the public
information program, installation of electronic sirens in
tbe early warning system in order to improve the system's
reliability,--use-of new pagers for improving the ability to
notify key emergency response organization personnel, and
implementation of an Emergency Response Data System before
the required time.
During the November 1991 full participation exercise, the
licensee demonstrated the ability to staff the emergency
organization in a timely manner and the staff demonstrated
the ability to effectively implement the Emergency Plan.
I
L
15
The overall emergency response was effective and
demonstrated a high level of proficiency.
During the
exercise, alternates replaced key emergency response
personnel who were called to attend to ~n actual
transportation accident which involved the licensee's
radioactive material.
The alternates performed well,
indicating good emergency organization training, and good
emergency response depth.
Furthermore, the licensee
demonstrated an effective overall incident response
capability in responding to the radioactive material
accident, as discussed in the Radiological Controls area.
The licensee provided extensive resources at the accident
scene in a prompt and overall effective manner which was
integrated with state and local response organizations.
This effort minimized the adverse effects of the accident.
Throughout the exercise, the licensee demonstrated the
ability to perform effective dose projections, and
radiological monitoring, a.nd to make proper protective
action recommendations.
Other observed strengths during the
exercise included:
good emergency response command and
control; prompt activation of the emergency response
facilities; timely event classifications and declarations;
effective communications with state and local authorities;
good assessment and mitigation of plant damage; and a lead
controller communications network that provided effective
exercise control.
Although there were no exercise
-
weaknesses, one issue was identified regarding delays in
access for emergency control teams entering the radiation
control area during emergency conditions.
The licensee
completed corrective action in this area.
overall, the
licensee's performance during the exercise was good, with
the licensee meeting their exercise objectives and
demonstrating a capability to protect the public health and
safety in the event of a radiological emergency.
During the assessment period, the licensee's Emergency Plan
was implemented three times in response to actual events,
each involving the declaration of an Unusual Event. In each
case, the event classification was prompt and correct,
onsite response actions were appropriate, and offsite
authorities were notified in accordance with applicable
requirements.
No violations or exercise weaknesses were identified during
the assessment period.
2.
Performance Rating
category: 1
'
3.
Board Recommendations
None
E.
Security
1.
Analysis
16
.This functional area addresses those security activities
related to protection of vital plant systems and equipment,
and the Fitness for Duty Program.
The Security Program was effectively -implemented during the
assessment period.
Security personnel continued to
demonstrate professionalism and ~edicated performance in the
accomplishment of assigned duties.
Continued strong support
by corporate and station management was evident by the
renovation of the primary personnel access portal to enhance
security control for site access.
This new facility was
equipped with new.and improved x-ray, metal and explosive
detection equipment, and provided larger and state-of-the-
art work areas for security management and administrative
staff.
Also, the delay capability of the perimeter barrier
was enhanced by installation of razor ribbon to increase
penetration time for intruders or potential adversaries.
In response to tactical issues identified during an
Operational Safeguards Response Evaluation, the licensee
promptly upgraded facilities by installing a metal
reenforced barrier over plate glass windows in the access
portal.
In addition, two areas within the new personnel
access portal, exterior to the protected area, were
identified by the NRC as potential penetration paths into
the protected area.
The licensee immediately installed
intrusion detection equipment in both locations to further
enhance detection capability.
Problems with the in-plant security computer occasionally
caused delays in licensee staff being able to access areas
in the plant.
Operations personnel have keys to gain access
to these areas, but do not routinely carry these keys.
Security management recognized this problem and installed a
vital area override system as an interim measure until the
forthcoming in-plant security system upgrades are completed.
Security management-was effective, shift staffing was good
and the quality of training provided the security force was
excellent.
During the Operational Safeguards Response
Evaluation drill runs, the licensee demonstrated strengths
in security management, perimeter barriers, response team
performance, detection, assessments, training, weapons, and
command, control and communications;
Operations personnel
participation in these security response activities was also
a strength.
.
17
The coordination and management of security plan revisions
continued to be excellent.
During the assessment period,
the licensee submitted.a comprehensive re-formatted physical
security plan that clarified requiremen~s and commitments.
The security plan was undergoing an additional revision at
the end of the assessment period.
Implementation of this
revision will enhance the physical*security protection of
safety-related equipment and is scheduled to be completed.in
1997.
The licensee's Fitness For Duty Program was effective and
continued to meet the drug-free work place objective.
This
program was administered by a trained professional staff and
had an aggressive audit and management oversight.
The
Program also continued to test for a broader spectrum of
drugs than required by the NRC.
No violations were issued during the assessment period.
2.
Performance Rating
Category: 1
3.
Board Recommendations
None
F.
Engineering/Technical Support
1. Analysis
This. functional area addresses activities associated with
engineering and technical support, including activities
associated with design of plant modifications, engineering,
and technical support for .operations and operator training.
overall engineering and technical support was effeqtive
during the assessment period~ Notable performance included
the design and installation of a barrier for the condenser
inlet water box that was used during a service
water/circulating.water expansion joint replacement.
This
barrier allowed the required safety trains of the
recirculation spray system to remain in service during the
modification.
Another example was the design and
construction of. the radwaste facility which was placed in
service in 1991. It minimized personnel exposure and was
designed for efficient operation and maintenance.
At the
end of the*assessment period the new Administration Building
was completed.
This was a significant improvement in that
work stations for engineering personnel and other
departments were upgraded and consolidated into one area.
.
'
18
station engineering performance during the Unit 2 outage was
good. The quality and technical content.of engineering
design change packages and work requests provided in support
of the outage replacement of feedwater flow elements and the
installation of new letdown isolation valves were good.
The
technical reviews of completed modifications were timely and
fully supported unit startup from the refueling outage.
Station engineering developed a priority evaluation process
to support outages and verify that modifications were
implemented in a timely fashion.
This review and
prioritization of engineering work requests and design
change packages assigned to Nuclear Engineering Services was
implemented at the end of the assessment period and
- scheduled to be completed in June 1992.
Technical support activities of welding and non-destructive
examination were effective during the assessment period.
However, some ISI drawings and sketches contained errors in
piping and welding configurations, which caused confusion
- when comparisons were made between the field condition and
the ISI drawings.
System engineer involvement with the verification portion of
the Design Basis Documentation Program was good.
During
this effort, design engineering discovered that the existing
calculations for the intake canal were incomplete and did
not document all design input values and loading conditions.
Conservative actions were taken to assure appropriate
compensatory measures were put in place until the
calculations could be corrected.
The MOV program continued to be a strength during this
_ assessment period.
The licensee displayed in-depth
knowledge and a clear understanding of MOV issues which were
enhanced by participation in several MOV user groups.
The
program was generally consistent with the recommendations of
Strengths were noted in the program
relative to training, recognition of the need to measure
valve torque in testing, and the corrective action program.
several concerns in the MOV program were identified by the
NRC which involved engineering assumptions, and electrical
calculations.
Several of these program corrections were
made in time for implementation during the Unit 1 Spring
1992 refueling outage.
At the beginning of the assessment period, weaknesses were
noted with setpoint control.
Discrepancies existed between
the set-points specified in the setpoint control program
procedures and the I&C implementing procedures.
Other
design problems in instrumentation occurred during the
assessment* period including the failure to ensure that
instrument accuracies assumed in the design change
I
19
calculation were used by the site organization.
This
resulted in a request for relief from ASME Section XI
requirements.
Another problem associated with steam flow
protection setpoints required the TS ba~ed value to be
reduced due to instrument scaling uncertainties.
In both of
these examples, engineering developed conservative interim
positions until the final resolution could be developed.
The control of setpoints was assessed and program changes_to
strengthen this area were under development at the end of
the assessment period with a late 1992 implementation date.
Good communications were observed between engineering,
construction, and operations departments during trouble
shooting and corrective action for a licensee discovered
problem with Unit 2's AFW system piping.
This piping, which
is partly underground, had been incorrectly routed during
initial piant construction.
This configuration error was
discovered during a modification for the AFW pumps'
recirculation flowpaths and was promptly addressed and
rapidly resolved.
One area where the licensee should have been more aggressive
was in reporting and reacting to the results of the
individual plant examination (IPE) efforts.
In early 1991.
the licensee identified a significant core damage frequency
that could result from postulated internal flooding of the
Units 1 and 2 turbine buildings.
The licensee established
an independent team to reaffirm the flooding vulnerability
and reported its findings in a final August 30, 1991. IPE
submittal.
The licensee should have been more proactive in
notifying the NRC when the flooding vulnerability was first
identified and should have defined, committed to and/or
implemented appropriate mitigative actions prior to
submittal of the Ii?E report.
However, following submittal
of the report, the licensee was responsive to the NRC
concerns and implemented inspections, procedural changes,
training, and limited plant modifications.
As a result of
- NRc involvement, the scope of the original planned
modifications and activities was expanded and the
implementation schedule accelerated.
Station engineering provided good support to operations and
provided operability determination information to the shift
-supervisor as needed.
Equipment failures, for the most
part, _got immediate-attention.
However, an operability
determination issue for the #2 EOG operating at reduced
frequency was delayed for several days because of
engineering workload and no priority support from corporate
design engineering.
The reduced frequency event occurred as
a result of a conflict in the work governing documentation
- which went undetected by station personnel.
'
20
Corporate engineering effectively continued the support of
the predictive and PM program to monitor erosion-corrosion
wear rates and initiated several changes in plant water
chemistry and processes to aid in this reduction.
Corporate
engineering undertook a comprehensive overview of the
inspection program to optimize the component replacement-
program as a function of safety and efficiency.
Recent station and corporate engineering support of special
testing and response to emerging issues was excellent.
One
example involved the timely technical evaluations provided
for the replacement of a leaking switchyard station service
transformer whose failure could have caused a loss of the
power supply to the emergency buses.
A second example
involved special testing of the SW supply to the RSHXs which
identified problems of flow restriction and radiation
monitor sampling pump design deficiencies.
A third example
involved engineering response to concerns with containment
shroud cooler efficiencies which may have contributed to the
CRD coil failures and dropped rods discussed in the
Maintenance/Surveillance area.
This emerging issue was
addressed with minimal impact on an already demanding
outage.
An effective licensed operator training program was
demonstrated by a 94% pass rate on initial and
requalification examinations administered during the
assessment period.
The Generic Fundamentals Examination*was
administered to fourteen candidates.
A 100% pass rate was
achieved on the examination.
This was an improvement over
the results achieved during the previous assessment period.
The licensee provided quality questions on the written
requalification examination and the Job Performance
Measurements.
The licensee's pre-review of the NRC written
initial examination was of limited effectiveness in that
several post-examination changes were required due to
technical inaccuracies which were not reflected in the
reference materials and not detected in the pre-review. The
simulator scenarios were well written and constructed.
Equipment simulation was sufficient to test the candidate's
knowledge level of plant operation and procedure usage.
Instructors effectively evaluated the candidates
performance.
One.violation was issued during the assessment period.
The
licensee denied this violation and the denial was under NRC
review at the end of the assessment period.
2.
Performance Rating
category': 2
I
It'
21
3.
Board Recommendations
None
G.
Safety Assessment/Quality Verification
1.
Analysis*
This functional area addresses those activities related to
licensee*implementation of safety.policies;. amendments,
exemptions and relief request; response to Generic Letters,
B~lletins, and Information Notices; resolution of safety
issues; reviews pf plant modifications performed under 10
CFR 50.59; safety review committee activities; and the use
of feedback from self-assessment programs and activities.
The senior plant and corporate*management structure
continued to be stable and effective.
The licensee's self-
assessment program continued to identify and refocus
attention and improved overall performance.
The self-
assessment by Corporate Nuclear Safety (CNS) determined that
recommendations from several of the older event reviews had
not been followed up and there was no way to verify that
corrective action was complete.
CNS modified their issue
tracking_ and trending program to strengthen this area and
provide the needed followup reviews.
The continued.use of
the Performance Annunciator Panel Program ena~led management
to focus. on areas that warranted additional attention.
The
new integrated QA audit process was*effective and all
required audits were performed.
The station continued to
conduct performance*-based observations to augment the
required audits.
The number of assessments performed was
somewhat constrained by resources and prioritization was
necessary.
However, staffing levels were adequate.and
personnel well-experienced to perform the assigned
functions.
A significant portion of the QA assessments were
at the request of the Station Manager and this process
demonstrated that both the plant and QA were striving to
improve performance and overall quality.
Control of
operator overtime, use of operator aids, and implementation
of justification for continued operation commitments were
examples of assessments that complemented plant operations
and appeared to have improved safety.
The licensee' .. s corporate -staffing and committee structure
performed timely and detailed assessment of emerging safety
issues.
The licensee's safety review function is
accomplished through the use of both the onsite [Station
Nuclear and Safety Operating Committee (SNSOC)] and offsite
[Management Safety Review Committee (MSRC)] committees as
well as. the industry experience review group (IERG).
The
details and quality of the safety reviews conducted by the
onsite safety review committee in this assessment period
I
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22
were good.
An example of a strength identified in this area
was the thorough and in-depth safety oversight review of the
troubleshooting and repair of a Unit 2 reactor trip manual
pushbutton failure.
In contrast to th~s strength, however,
was a decision to place the recirculation mode transfer key
switches in the refueling position, which defeated the
automatic transfer mode and violated TS requirements.
Discussions in the MSRC meetings were frank and straight-.
forward with the consultants significantly contributing by
providing a broader perspective through alternative view-
points.
The licensee exceeded the TS requirements for
committee staffing and meeting frequency in all areas.
Timely evaluation of the Salem turbine damage and the French
reactor CRD mechanism nozzle cracks were two examples of
IERG involvement.
In the case of the turbine damage issue
turbine overspeed testing was suspended until the licensee
determined that plant procedures were acceptable.
Licensee
management maintained several oversight groups that are in
addition to those required by TS. For example: 1) the plant
manager utilizes a Management Review Board to review items *
of interest and provide feedback, and 2) the Senior Vice
President, Nuclear, receives advice from a Nuclear Oversight
which includes executive managers from other utilities.
Strengths were identified in the timely resolution of safety'
issues *which the licensee *considered as* safety significant.*
Examples included the installation of a second means of
level indication for reduced inventory operations ahead of
the original commitment date and prior to entry into reduced
inventory.
Another involved the correction of a problem
with switchyard breaker logic, that was being compensated
for by requiring operator .actions during an unplanned outage
even though the non-mandatory repairs extended the outage.
The commitment to problem resolution was also evident, by
the established low threshold for deficiency identification.
Several examples such as steam flow setpoint errors,
charging pump switch alignment, and SW radiation sample pump
deficiencies demonstrated the licensee's ability to identify
long-standing problems of incorrect design or calculations
assumptions.
- However, during this assessment period, the licensee*
continued to have some difficulty in resolving conditions
adverse to quality.
For example, there were several cases
that indicated a willingness to live with recurring problems
such as seal head low level alarms on an outside
recirculation spray pump and a low head safety injection
pump.
Recurring failures of the SW temperature control
valves needed to cool the HHSI pump lubricating oil system
were also not promptly corrected and a failure to identify
and correct the installation of an improperly sized air
tubing for the feedwater regulating valve contributed to
,
I.
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t
23
valve instability which may have been the initiator of an
operational transient.
The licensee's implementation of safety. evaluation
assumptions into station procedures were, for the most part,
effective.
However, several examples of not incorporating
safety evaluation assumptions into plant procedures were
evident during the assessment period.
First, a TS change to
radioactive gas storage requirements was improperly
implemented through station procedures and resulted in non-
conservative operator actions when the WGDT oxygen and
hydrogen concentration exceeded the TS limit.
Second, UFSAR
described actions associated with control of the tu,rbine
load limiter were not incorporated in station procedures,
contributing to a brief increase in unit power that exceeded
the license power limits.
Finally, a 10 CFR 50.59 safety
analysis commitment for inspecting the control rod guide
tube flexures for Unit 2 during a refueling outage was not-
factored into station procedures.
This oversight allowed
unit operation for two cycles with possible loose parts.
During the previous assessment period, the licensee
identified that the UFSAR was not current as to past
modifications to the facility.
However, the licensee did
not recognize that some of the data from portions of the
original FSAR also needed upgrading.
Several instances of
errors in the UFSAR and plant procedures resulted in
operations and testing that violated the assumptions used in
some of the transient analyses and TS bases.
Management
recognized the need for an accurate UFSAR and modified their
update program to include a quality review.
During the previous assessment period, deficiencies were
identified with the implementation of an effective root
cause evaluation program and also ensuring the appropriate
training for evaluators.
Root cause training continued into
this assessment period and was accomplished for a l~rge
number of personnel from dif(erent organizations throughout
the plant.
During this assessment period, root cause
analyses were effective in identifying needed corrective
actions to improve performance.
For example, the
determination that several of.the CRD failures (discussed in
the Plant Operations and Maintenance/Surveillance areas)
were temperature related resulted in the development and
implementation of -ventilation modifications to improve CRD
cooling during the Unit 1 refueling outage late in the
assessment period.
Commitment tracking.was identified in previous assessments
as not being effective.
Improvements were noted during this
assessment in that IPE commitments_ that were being revised
on a frequent basis were effectively tracked and completed
by the licensee without any missed commitments.
I
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24
Additionally, for the Unit l1mini-outage late in the
assessment period, the licensee's program was effective in
identifying those commitments that were required to be
completed during the first shutdown of ~ufficient duration~
Considerable licensing activity took place during this
assessment period.
For the most part, licensing submittals
were timely and of high quality, demonstrating the
licensee's thorough understanding of technical issues and
regulatory requirements as well as a conservatism in the
approach to safety.
Examples of high quality submittals
we.re amendments relating to: (1) opposite train operability
testing, (2) engineered safety features instrumentation
upgrade, and {J) surveillance frequency for recirculation
spray and containment spray check va.l ves.
The analyses of
the no significant hazards issues were complete and correct.
However, while submittals in most cases were timely, some
responses to requests for additional information were late.
Responses to NRC Bulletins, Generic Letters, and other
regulatory requests were, in most cases, timely, technically
correct, and satisfied staff concerns.
One example of good
technical completeness was the licensee's response to
Bulletin 88-08 relating to thermal stresses in piping
- connected to the reactor coolant system.
Although no
response was required related to Supplement 3 of the
Bulletin, the licensee did address it.
However, the
licensee's response to Generic Letter 88-14, "Instrument Air
System Problems Affecting Safety-Related Systems" has been
protracted.
There have been three submittals to date, the
latest of which was found deficient.
Moreover, one proposed
modification to the containment air system, which was later.
abandoned, contained a flaw that should have been detected
earlier by the licensee.
The fl*aw would have increased the
radiological gas release during normal plant operation by a
factor of 2 to 10, depending on the specific modification
selected.
The use of the "top 10 11 licensing issues mana,gement tool,
which is updated on a continuous basis and submitted
. quarterly, continued to be an effective method of focusing
on the high priority issues.
The licensee's staff was
effective in anticipating and identifying potential problems
related to TS and regulatory requirements so that resolu-
tions can be obtained on a non-emergency basis.
The licen-
see maintained an adequate and competent staff both at the
plant and at the corporate office to support licensing
activities.
Shutdown risk management greatly improved during the
assessment period.
Sensitivity to loss of equipment needed
to respond to transients or accidents during shutdown
operations increased.
As part of these improvements the
25
licensee developed and implemented a new program,-
Shutdown/Refueling Shutdown Critical Parameters.
This
program provided an additional m~thod of monitoring plant
parameters and systems important to safety during outages.
The program also developed a seven day look-ahead matrix to
evaluate the effect of scheduled maintenance on critical
plant parameters.
Emphasis on shutdown risk resulteq. in the
elimination of two scheduled mid-loop operations during the
Unit 1 refueling outage.
However, at the end of the assessment period a weakness in
the area of shutdown risk management was noted when Unit 1
refueling operations were performed in parallel with
maintenance on main steam valves.
Controls were not in
place to prevent breaches of containment integrity and
resulted in .a violation of-TS which occurred due to the
installation of improperly sealed blanks over containment
openings.
Six violations were issued during the assessment period.
2.
Performance Rating
category:
2
3.
Board Recommendations
The Board is concerned that the improving trend noted at the
end of the last assessment period was not sustained during
this period.
The inability to prevent the recurrence of
several safety problems contributed to the above rating.
Management attention is needed to get these areas back on
track.
V *. SUPPORTING DATA AND SUMMARIES
A.
Major Licensee Activities
Unit 1 began the assessment period at power.
During this
assessment period the unit completed a run of 379 days of
continuous operation.
The unit experienced one manual reactor trip during the period.
At the end of the period,
the unit was in day 36 of a scheduled 64-day refueling
outage.
Unit 2 began the assessment period in a refueling outage.
Equipment-related problems occurred throughout the
assessment period which resulted in a delayed startup from
the refueling outage, two automatic reactor trips {one with
a safety injection), four forced outages, and two turbine
runbacks.
At. the end of the assessment period, the unit wa_s
operating at full power.
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26
One management and/or organization change occurred during
the assessment period.
Near the end of*the assessment
period the Vice Presidents of Nuclear Operations and Nuclear
Services exchanged positions.
B.
Major Direct Inspection and Review Activities
During the assessment period, 35 inspections were conduct~d.
Six of these were special inspections:
(1) evaluation of
the annual emergency exercise; (2) evaluation of the
licensee's activities to reduce the vulnerability.for
internal flooding; (3) an inspection associated with
implementation of the MOV program; (4) administration of the
operator requalification examination; (5) a security
operations safeguards response evaluation; and (6) a
followup to the EOP team inspection.
Eight management
meetings and one enforcement conference were also conducted
during this assessment period.
c.
Escalated Enforcement Action
A Severity Level III Violation with a civil penalty was
issued for the failure of EDG # 3 to perform its safety
function with the loss of off-site power.
A Severity Level III Violation with a civil penalty was
issued for inoperability of the automatic start feature for
the HHS! pumps.
D.
Licensee Conferences Held During Appraisal Period
June 17, 1991 - Meeting at Surry Nuclear Information Center.
to present the SALP Board Assessment.
August 19, 1991 - Meeting at Region II to discuss North Anna.
and Surry emergency preparedness plans and programs.
September 17, 1991 - Enforcement Conference at NRC Region II
office to discuss the failure of the# 3 EDG's safety
function during a loss of off-site power, and inoperability
of the automatic start feature of the HHS! pumps.
October 9, 1991 - Meeting in Rockville, Maryland to discuss
and obtain additional information on the licensee's internal
flooding analysis portion of their IPE.
October 17. 1991 - Meeting in Rockville, Maryland to discuss
status of all active licensing issues.
November 21, 1991 - Meeting in Rockville, Maryland to
discuss the reanalysis of the internal flooding issue as
described in the IPE Report.
'
' .. * * *
27
January 10, 1992 -
Management meeting at NRC Region II
office to discuss the licensee's self-assessment.
February 27. 1992 -
Management meeting in Rockville,
Maryland to discuss status of all active licensing issues.
.
- ..
March 30, 1992 - Meeting in Rockville, Maryland to discuss
various licensing issues, current plant status, and IPE.
E.
Confirmation of Action Letters
None
F.
Review of Licensee Event Reports {LERs}
During the assessment period, a total of 38 LERs were
analyzed.
The distribution of these events by cause, as
determined by the NRC staff, is as*follows:
Cause
Unit 1 or Both
Unit 2
Totals
Component Failure
4
6
10
Design
3
1
4
Construction, Fabrication
or Installation
1
0
1
Personnel Error
- Operating Activity
6
2
8
- Maintenance Activity
3
2
5
- Test/Calibration
8
'2
10
-
Other
0
0
0
Other
Total
25
13
38
Note 1:
With regard to the area of "personnel error," the
NRC considers the lack of procedures, inadequate procedures,
and erroneous procedures to be classified as personnel
errors.
Note 2:
The "Other" category is comprised of LERs wh.ere
there was a.spurious signal or a totally unknown cause.
Note 3:
The above information was derived from a review of
LERs performed by the NRC staff and may not completely
coincide with the licensee's cause assignments.
- '*
I(
... ~
. ...s..--
____ _.. _____ -* ***. _..:..~---* -
- ----~--*-----*----*-*--*----**-***---****~-.
28
G.
Licensing Activities
During the assessment period, 32 license amendments, 4
relief requests and 30 other licensing actions were issued
or processed.
- *
H.
Enforcement Activity
FUNCTIONAL
AREA
NO. OF VIOLATIONS IN SEVERITY LEVEL
Plant Operations
Radiological Controls
Maintenance/Surveillance
Security
Engineering/Technical
Support
Safety Assessment/
Quality Verification
TOTAL.
IV
1
1
2
5
10
III
II I
1
1
2
- Violation has been denied by the licensee and is being
reviewed by the staff.
I *
On January 2, 1992, Unit 1 was manually tripped from 56%
power when control rod H-2 dropped when trouble shooting
control rod E-5.
The CRD movable coil fuse for H-2 was
erroneously removed for trouble shooting E-5.
On August 2, 1991, Unit 2 experienced a safety injection and
a reactor trip from 94% power.
The cause of the event was a
combination of voltage spiking problems tripping the high
steam flow reference comparator and failed instrument
channels causing low steam line pressure.
On December 17, 1991, Unit 2 restarted after repairing a
flange leak, but at 30% power the unit had an automatic reactor trip when SG level control problems caused a high
level in 'B' SG.
The high level set point tripped the main
feed pump.
The turbine subsequently tripped which was
followed by a reactor trip.