forwards final salp repts 50-269/93-11,50-270/93-11, 50

32
SEP 10 1993 Docket Nos. 50-269, 50-270, 50-287 and 72-4 License Nos. DPR-38, DPR-47, DPR-55 and SNM 2503 Duke Power Company ATTN: Mr. J. W. Hampton Vice President Oconee Site P. 0. Box 1439 Seneca, SC 29679 Gentlemen: SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NOS. 50-269/93-11, 50-270/93-11, 50-287/93-11 AND 72-4/93-11) This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) for your Oconee facility which was sent to you on July 13, 1993; our meeting of July 28, 1993, at which we discussed the report; and your written comments dated August 18, 1993. I have enclosed a summary of our presentation at the meeting, a copy of ttie SALP slides which were used at the presentation, a copy of your written comments, and the Final SALP Report for the period February 2, 1992, through May 1, 1993. We appreciate your efforts in evaluating the Initial SALP Report and providing comments. The following is our evaluation of your comments: Docket Nos. We agree with this comment. The docket number of the Independent Spent Fuel Storage Installation has been added to the Final SALP Report as you requested. Maintenance/Surveillance We understand that your Design Basis Documentation program identified the need for testing the isolation relays at Keowee; however, the-SALP Board concluded that action to accomplish these tests had not been initiated in a timely manner. Therefore, no change is warranted for this section of the Final SALP Report. Engineering/Technical Support Your response provided additional clarification on issues related to the Low Pressure Injection h.2at exchangers, MG-6 relays at Keowee, the Electrical Distribution System Functional Inspection, and licensed operator initial and requalification examination programs. The weakness we noted in the requalification examination construction and instructor cuing techniques can 9310120354 930910 PDR ADOCK 05000269 9 \ PDR j

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Page 1: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

SEP 10 1993 Docket Nos. 50-269, 50-270,

50-287 and 72-4 License Nos. DPR-38, DPR-47,

DPR-55 and SNM 2503

Duke Power Company ATTN: Mr. J. W. Hampton

Vice President Oconee Site

P. 0. Box 1439 Seneca, SC 29679

Gentlemen:

SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NOS. 50-269/93-11, 50-270/93-11, 50-287/93-11 AND 72-4/93-11)

This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) for your Oconee facility which was sent to you on July 13, 1993; our meeting of July 28, 1993, at which we discussed the report; and your written comments dated August 18, 1993. I have enclosed a summary of our presentation at the meeting, a copy of ttie SALP slides which were used at the presentation, a copy of your written comments, and the Final SALP Report for the period February 2, 1992, through May 1, 1993.

We appreciate your efforts in evaluating the Initial SALP Report and providing comments. The following is our evaluation of your comments:

Docket Nos.

We agree with this comment. The docket number of the Independent Spent Fuel Storage Installation has been added to the Final SALP Report as you requested.

Maintenance/Surveillance

We understand that your Design Basis Documentation program identified the need for testing the isolation relays at Keowee; however, the-SALP Board concluded that action to accomplish these tests had not been initiated in a timely manner. Therefore, no change is warranted for this section of the Final SALP Report.

Engineering/Technical Support

Your response provided additional clarification on issues related to the Low Pressure Injection h.2at exchangers, MG-6 relays at Keowee, the Electrical Distribution System Functional Inspection, and licensed operator initial and requalification examination programs. The weakness we noted in the requalification examination construction and instructor cuing techniques can

9310120354 930910 PDR ADOCK 05000269 9 \ PDR j

Page 2: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Duke Power Company 2 SEP 10 1993

only be observed during a requalification examination. During the most recent requalification examination, July 12-22, 1993, which was outside the assessment period, we did not identify any problems with cuing and examination construction. On this basis, we conclude that the problems have been corrected. For the remaining items, we have considered the justification in your request and have modified the SALP Report as described in Enclosure 4.

Supporting Data and Summaries

We have revised the Licensee Activities section of the Final SALP Report to include your clarification comments on the October 19, 1992, loss of off site power event. Also, we have revised the Direct Inspection and Review Activities section to indicate the correct number of initial and requalification examinations performed during this assessment period. We have verified that only operator examinations administered during this SALP period were assessed. The management meeting to discuss station blackout and Keowee issues has been included as one of the additional meetings held during the assessment period.

In accordance with Section 2.790(a), a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

No reply to this letter is required; however, should you have any questions concerning these matters, I will be glad to discuss them with you.

Sincerely,

Stewart D. Ebneter Regional Administrator

Enclosures: 1. Meeting Summary 2. SALP Slides 3. Duke Power Comments on SALP 4. Revision Sheet 5. Final SALP Report

cc w/encls: M. E. Patrick Compliance Duke Power Company P. 0. Box 1439 Seneca, SC 29679

cc w/encls: See page 3

Page 3: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Duke Power Company 3 SEP 101993

cc w/encls: Continued

A. V. Carr, Esq. Duke Power Company 422 South Church Street Charlotte, NC 28242-0001

County Supervisor of Oconee County

Walhalla, SC 29621

Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MD 20852

J. Michael McGarry, III, Esq. Winston and Strawn 1400 L Street, NW Washington, D. C. 20005

Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603

Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health

and Environmental Control 2600 Bull Street Columbia, SC 29201

Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035

G. A. Copp Licensing - EC050 Duke Power Company P. 0. Box 1006 Charlotte, NC 28201-1006

Karen E. Long Assistant Attorney General N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602

INPO

Page 4: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Duke Power Company 4 SEP 101993

bcc w/encls: The Chairman Commissioner K. C. Rogers Commissioner F. J. Remick Commissioner E. G. de Planque J. M. Taylor, EDO H. L. Thompson, Jr., EDO J. F. Plisco, Regional Coordinator, EDO

T. E. Murley, NRR S. Varga, NRR L. A. Wiens, NRR F. Allenspach, SALP Coordinator, NRR Regional Administrators, RI, RIII

RIV, and RV K. Clark, RII, PAO A. R. Herdt, DRP, RH M. S. Lesser, DRP, RII W. H. Miller, DRP, RH R. L. Watkins, DRP, RH NRC Resident Inspector DRS and DRSS Branch Chiefs, Document Control Desk

NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678

Mr. John C. Heard, Jr. Chief, Tech. Hazards Branch Federal Emgcy. Mgmt. Agency Suite 706A 1371 Peachtree Street, N. E. Atlanta, GA 30309

* SEE PREVIOUS CONCURRENCE

*RII *RII *RII *RII

WMiller MLesser AHerdt PSthor Jaudon 09/ /93 09/ /93 09/ /93 09/ /9319/93

*RII *NRR *NRR *R RI

PHarmon LWiens DMatthews J son yes 09/ /93 09/ /93 09/ /93 09/ /93 0 /3/93

Page 5: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Duke Power Company 4

bcc w ncls: The Ch 'rman Commiss ner K. C. Rogers Commissi er F. J. Remick Commissio r E. G. de Planque J. M. Tayl , EDO H. L. Thomp n, Jr., EDO J. F. Plisco, Regional Coordinator, EDO

T. E. Murley, R S. Varga, NRR L. A. Wiens, NRR F. Allenspach, SAL Coordinator, NRR Regional Administra ors, RI, RIII

RIV, and RV K. Clark, RII, PAO A. R. Herdt, DRP, RH M. S. Lesser, DRP, RH W. H. Miller, DRP, RH R. L. Watkins, DRP, RH S. Vias, Chief, TSS (2 cop'es) NRC Resident Inspector DRS and DRSS Branch Chiefs,

and Section Chiefs Document Control Des:

NRC Resident Inspector U.S. Nuclear Regulatory Commissio Route 2, Box 610 Seneca, SC 29678

RIIW4 RH RI RI

WMif'er sser AHerdt PSt u 09/1 /93 09/1 /93 09/\ /93 09/1 /93 0 3

RLNRR NRR RJ RH

Valmon & LWiens DMafthews J, son LReyes 09/1/93 09/, /93 09/1 /93 0 /i/934 09/ /93

Page 6: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ENCLOSURE I

MEETING SUMMARY

A. A meeting was held on July 28, 1993, at the Oconee station to discuss the results of the NRC Systematic Assessment of Licensee Performance (SALP) evaluation of the Oconee facility for the appraisal period of February 2, 1992, through May 1, 1993.

B. Licensee Attendees

R. B. Priory, Executive Vice President Power Generation Group H. B. Tucker, Senior Vice President, Nuclear Generation Department M. S. Tuckman, Senior Vice President, Nuclear Generation Department J. E. Groman, Vice President, Generation Services J. W. Hampton, Vice President, Oconee Nuclear Site (ONS) H. B. Barron, Oconee Station Manager, ONS J. M. Davis, Safety Assurance Manager, ONS L. V. Wilkie, Training Manager, ONS S. C. Adams, Community Relations Director, ONS

The list of licensee attendees does not include all of the Duke Employees that were present at the SALP presentation.

C. NRC Attendees

L. A. Reyes, Deputy Regional Administrator, Region II (RH) J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP), RII A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RH L. A. Wiens, Project Manager, Project Directorate 11-3, Office of

Nuclear Reactor Regulation (NRR) K. M. Clark, Public Affairs Officer, RH P. E. Harmon, Senior Resident Inspector, Oconee, DRP, RH W. K. Poertner, Resident Inspector, Oconee, DRP, RH W. H. Miller, Jr., Project Engineer, DRP, RII

D. Public Attendees

D. Cambell, Director, South Carolina Emergency Preparedness Division R. Duggleby, South Carolina Emergency Planning Division W. Corley, South Carolina Department of Health and Environmental

Control J. Morris, South Carolina Department of Health and Environmental Control D. Evett, Director, Pickens County Emergency Preparedness Agency A. Horn, Director, Oconee County Emergency Preparedness Agency M. McCance, Greenville News E. Gorski, Anderson Independent R. Young, WYFF-TV, Greenville, SC N. Nygro, WYFF-TV, Greenville, SC

Page 7: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ENCLOSURE 2

UNITED STATES NUCLEAR REGULATORY

COMMISSION

SYSTEMATIC ASSESSMENT OF

LICENSEE PERFORMANCE

(SALP)

Page 8: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

DUKE POWER COMPANY SALP CYCLE 10

FEBRUARY 2, 1992 THROUGH

MAY 1, 1993

OCONEE

JULY 28, 1993

LICCOVR.CH3

Page 9: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

SALP PROGRAM OBJECTIVES

1. IDENTIFY TRENDS IN LICENSEE PERFORMANCE

2. PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES

3. IMPROVE NRC REGULATORY PROGRAM

PROJOBJ.CH3

Page 10: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

REGION II ORGANIZATION

OFFICE OF THE ADMINISTRATOR

ADMINISTRATOR S. EBNETER

DEPUTY L REYES

DIVISION OF DIVISION OF DIVISION OF

REACTOR PROJECTS REACTOR SAFETY RADIATION SAFETY AND SAFEGUARDS

DIR. E. MERSCHOFF DIR. A. GIBSON DIR. J. STOHR

DEPUTY J. JOHNSON DEPUTY J. JAUDON DEPUTY B. MALLETT

RII-ORG.CH3

Page 11: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

DIVISION OF REACTOR PROJECTS ORGANIZATION

DIVISION OF REACTOR PROJECTS

DIR. E. MERSCHOFF

DEPUTY J. JOHNSON

REACTOR PROJECTS

BRANCH NO. 3

CHIEF A. HERDT

PROJECTS SECTION PROJECTS SECTION

NO. 3A NO. 3B

CHIEF CHIEF M. LESSER P. SKINNER

CATAWBA HATCH

MCGUIRE

OCONEE -P. HARMON, SRI VOGTLE

BR30RG.CH3

Page 12: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

NRR ORGANIZATION OFFICE OF

NUCLEAR REACTOR REGULATION

DIR. T MURLEY

ASSOC. DIRECTOR FOR ASSOC. DIRECTOR FOR

PROJECTS INSPECTION AND

J. PARTLOW TECHNICAL ASSESSMENT

IDIVISION OF ENGINEERING

DIVISION OF

REACTOR PROJECTS I/I

S. VARGA, DIR. I/II

G. LAINAS, ASST. DIR. II

D. B. MATTHEWS, PD 11-3 REACTOR INSPECTION

L A. WIENS PROJ MGR, OCONEE

DIVISION OF REACTOR CONTROLS AND HUMAN FACTORS

DIVISION OF

REACTOR PROJECTS IIIIIVNR DIV. OF RADIATION SAFETY AND

SAFEGUARDS

DIVISION OF OPERATING

REACTOR SUPPORT

NRRORG.CH3

Page 13: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

PERFORMANCE ANALYSIS AREAS FOR OPERATING REACTORS

A. PLANT OPERATIONS

B. RADIOLOGICAL CONTROLS

C. MAINTENANCE/SURVEILLANCE

D. EMERGENCY PREPAREDNESS

E. SECURITY

F. ENGINEERING/TECHNICAL SUPPORT

G. SAFETY ASSESSMENT/QUALITY VERIFICATION

FNCAREAS.CH3

Page 14: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

AREA PERFORMANCE CATEGORY 1

LICENSEE MANAGEMENT ATTENTION TO

AND INVOLVEMENT IN NUCLEAR SAFETY

OR SAFEGUARDS ACTIVITIES RESULTED

IN A SUPERIOR LEVEL OF PERFORMANCE.

NRC WILL CONSIDER REDUCED LEVELS

OF INSPECTION EFFORT.

CATIDEFN.CH3

Page 15: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

AREA PERFORMANCE CATEGORY 2

LICENSEE MANAGEMENT ATTENTION TO

AND INVOLVEMENT IN NUCLEAR SAFETY

OR SAFEGUARDS ACTIVITIES RESULTED

IN A GOOD LEVEL OF PERFORMANCE.

NRC WILL CONSIDER MAINTAINING

NORMAL LEVELS OF INSPECTION

EFFORT.

CAT2DEFN.CH3

Page 16: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

AREA PERFORMANCE CATEGORY 3

LICENSEE MANAGEMENT ATTENTION TO

AND INVOLVEMENT IN NUCLEAR SAFETY

OR SAFEGUARDS ACTIVITIES RESULTED

IN AN ACCEPTABLE LEVEL OF PERFORMANCE;

HOWEVER, BECAUSE OF THE NRC'S CONCERN

THAT A DECREASE IN PERFORMANCE MAY

APPROACH OR REACH AN UNACCEPTABLE

LEVEL, NRC WILL CONSIDER INCREASED

LEVELS OF INSPECTION EFFORT.

CAT3DEFN.CH3

Page 17: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

EVALUATION CRITERIA

1. MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY

2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT

3. ENFORCEMENT HISTORY

4. REPORTING, ANALYSIS AND CORRECTIVE ACTION OF REPORTABLE EVENTS

5. STAFFING (INCLUDING MANAGEMENT)

6. TRAINING EFFECTIVENESS AND QUALIFICATION

EVALCRIT.CH3

Page 18: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

PLANT OPERATIONS (CATEGORY 2)

OVERALL PERFORMANCE REMAINED GOOD.

STRENGTHS

* CONTROL ROOM DECORUM

* EXPERIENCE OF OPERATIONS STAFF

* OPERATORS KNOWLEDGE OF SYSTEMS AND PROCESSES

* RESPONSE TO TRANSIENTS

* USE OF OPERATIONAL SUPPORT STAFF

* NUMBER OF LIT ANNUNCIATORS

* IMPROVEMENT IN SHUTDOWN RISK CONSIDERATIONS

OCONEE 7/93

Page 19: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

PLANT OPERATIONS

(CONTINUED)

CHALLENGES

* CONFIGURATION CONTROL EVENTS

* ADHERENCE TO PROCEDURES

- ATTITUDES

- MANAGEMENT ATTENTION

* KEOWEE OPERATIONS STANDARDS

Page 20: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

RADIOLOGICAL CONTROLS

(CATEGORY 1)

PERFORMANCE CONTINUED TO BE SUPERIOR.

STRENGTHS

* RADCON ORGANIZATION

* RADIATION EXPOSURE CONTROL

* RADIOLOGICAL EFFLUENT CONTROL

* ENVIRONMENTAL MONITORING

* WATER CHEMISTRY PROGRAM

* RAD MATERIAL SHIPMENTS

CHALLENGES

* POSTING AND LABELING

* ADHERENCE TO RWP PROCEDURES

* TIMELY FOLLOWUP OF RADCON AUDIT DEFICIENCIES

Page 21: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

MAINTENANCE/SURVEILLANCE

(CATEGORY 2)

OVERALL PERFORMANCE WAS GOOD.

STRENGTHS

* PREDICTIVE MAINTENANCE

* PREVENTIVE MAINTENANCE

* INSERVICE INSPECTION PROGRAM

* REDUCTION OF MAINTENANCE WORK REQUEST BACKLOG

CHALLENGES

* OPERATIONAL EVENTS ATTRIBUTED TO MAINTENANCE/SURVEILLANCE ACTIVITIES

* MAINTENANCE CONTROLS

* PROCEDURE ADHERENCE

* SYSTEM FUNCTIONS NOT FULLY DEMONSTRATED BY TESTING

Page 22: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

EMERGENCY PREPAREDNESS

(CATEGORY 1)

PERFORMANCE REMAINED SUPERIOR.

STRENGTHS

* MANAGEMENT SUPPORT AND INVOLVEMENT

* TRAINING PROGRAM

* DRILL PROGRAM AND PERFORMANCE

* OFFSITE SIREN SYSTEM MONITORING

* EMERGENCY FACILITIES

CHALLENGES

* MAINTAINING PERFORMANCE LEVEL

* IMPROVE INFORMATION RELEASED FROM THE JOINT INFORMATION CENTER

Page 23: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

SECURITY

(CATEGORY 1)

PERFORMANCE REMAINED SUPERIOR.

STRENGTHS

* KNOWLEDGEABLE STAFF

* AUDITS AND CORRECTIVE ACTIONS

* PROGRAM IMPLEMENTATION (ACCESS, ALARMS, ETC.)

CHALLENGES

* ASSESSMENT SYSTEM (CAMERA) RELIABILITY

* COORDINATION WITH OTHER SITE ORGANIZATIONS

Page 24: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ENGINEERING & TECHNICAL SUPPORT

(CATEGORY 2)

PERFORMANCE CONTINUED TO BE GOOD.

STRENGTHS

* SUPPORT TO OUTAGE ACTIVITIES

* SUPPORT TO PLANT OPERATIONS

* INITIAL LICENSING OPERATOR TRAINING

CHALLENGES

* RESOLUTION OF EMERGENT ISSUES

* TIMELY AND EFFECTIVE CORRECTIVE ACTIONS

* SUPPORT TO SYSTEM FUNCTIONAL TESTING TO VERIFY PREDICTIONS (CALCULATIONS)

* LICENSED OPERATOR REQUALIFICATION

Page 25: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

SAFETY ASSESSMENT/QUALITY VERIFICATION

(CATEGORY 2)

PERFORMANCE REMAINED GOOD.

STRENGTHS

* SHUTDOWN RISK INITIATIVES

* NOTIFICATION OF PLANNED REQUESTS

* QUALITY OF LICENSING SUBMITTALS

CHALLENGES

* PROCEDURAL ADHERENCE

* CORRECTIVE ACTIONS

* RECOGNITION OF NEED TO IMPROVE OVERSIGHT OF KEOWEE OPERATIONS

Page 26: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Duke Power Company Oconee NuclearSite J WHAMPTON PO .Bor 1439 ENCLOSURET3- Vice President Seneca. SC 29679 (803)885-3499 Office

(803)8853564 Far

DUKEPOWER

August 18, 1993

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject: Oconee Nuclear Site Docket NoS. 50-269, -270, -287; 72-4 Inspection Report 50-269, -270, -287/93-11 Systematic Assessment of Licensee Performance

Gentlemen:

By letter dated July 13, 1993, the initial SALP report for the Oconee facility was issued. This report covered the time period of February 1, 1992 through May 1, 1993. A verbal presentation of that report was made in a public meeting on July 28, 1993 at the Oconee site.

I would like to comment and provide additional information regarding the Operator Training assessment (Attachment 1), the Engineering assessment (Attachment 2), and the Maintenance/ Surveillance assessment (Attachment 3). I request that these comments be considered for inclusion into the final SALP report and rating.

In addition, I request that the Docket Number assigned to the Independent Spent Fuel Storage Installation be added to the final SALP report.

Please contact me, or members of my staff, if further information is needed.

Very truly yours,

J . W. an tn

DRP OFFICIAL COPY

Page 27: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

Document Control Desk August 18, 1993 Page 2

cc: Mr. S. D. Ebneter, Regional Administrator U. S. Nuclear Regulatory Commission, Region II

Mr. L. A. Wiens, Project Manager Office of Nuclear Reactor Regulation

P. E. Harmon Senior Resident Inspector Oconee Nuclear Site

Page 28: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ATTACHMENT 1 OPERATOR TRAINING AREA

ENGINEERING/TECHNICAL SUPPORT

The "Summary of Results" section of the preliminary SALP report indicates that "performance in the operator requalification program declined from the previous assessment due to weaknesses in examination content and evaluator techniques."

In Section V.B of the report, Direct Inspection and Review Activities, it is listed that two initial and three requalification examinations were conducted at Oconee. Our records indicate that one initial exam (50-269/93-300, January 1993) and two requalification exams (50-269/92-302, July 1992; 50-269/93-300, January 1993) were administered during the SALP cycle.

The following information is taken from the above referenced Examination Reports. Duke Power believes the Operator Training Program has shown continuous improvement during this SALP period.

A. NRC Examination Report 50-269/92-302

In July, 1992, the NRC administered a requalification examination. Nine of ten Reactor Operators (RO) and thirteen of fourteen Senior Reactor Operators (SRO) passed the examinations.

Based upon these results, the Oconee Requalification Program was determined to be satisfactory. A strength was noted in the construction and maintenance of Job Performance Measures.

Weaknesses were noted in the areas of written examination construction, communications during Emergency Operating Procedures implementation, and evaluator performance.

B. NRC Examination Report 50-269/93-300

In January, 1993, the NRC administered initial written examinations and operating tests to seven SROs. Requalification simulator retake examinations were administered to the RO and SRO who failed the July, 1992 test.

All seven SRO candidates passed the initial examinations and both requalification retake examinees passed. The examiners stated that "both of the operators exhibited noticeably improved performance compared to their former examination results".

Strengths identified were "instructor assistance during exam administration, communications and team interaction, and an improved crew command and control structure."

Page 29: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ATTACHMENT 1 OPERATOR TRAINING AREA

ENGINEERING/TECHNICAL SUPPORT

B. NRC Examination Report 50-269/93-300 (continued)

It was also noted in the report that Oconee had "conducted an extensive pre-examination review ... and was successful in significantly reducing the number of post examination comments compared to previous examinations."

The examiners stated that the previous examination linked many weaknesses to poor communications and command and control. These problems were effectively addressed by management as can be seen in the following statements made by the examiners; "The candidates displayed excellent communication skills and team work between each other, especially during plant transients. The use of formalized repeat back communications and operator involvement in the decision making process was noteworthy."

In addition, the command and control structure was changed such that the Unit Supervisor is in an oversight position. This improved method of command and control revealed none of the problems mentioned during the previous examination. The examiners observed that "communications were clear, concise, and formal" and identified the new structure as a strength.

Duke Power believes the Operator Training Program has improved and requests that the NRC review this information for inclusion in the final SALP report and rating. Duke also requests the NRC to verify that only Operator Examinations which took place during the SALP cycle are included in the report.

Page 30: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ATTACHMENT 2 ENGINEERING AREA

ENGINEERING/TECHNICAL SUPPORT

Section V.A, Licensee Activities, of the SALP report discusses problems that were encountered with the LPSW system. The report states that "...cooling water flow of the LPSW system through the LPI heat exchangers were found to exceed the manufacturer's specifications. The power level of both units was reduced to approximately 10 percent and modifications were made to reduce the flow through the heat exchangers to meet the manufacturer's specifications."

Duke Power would like to clarify this information. The cooling water flow of the LPSW system through the heat exchangers, during a postulated design basis accident, could have potentially exceeded the manufacturer's specifications. This was discovered on a test performed on Unit 3 and was also determined to be applicable to Units 1 and 2.

Section F of the SALP report contains information on the Engineering/Technical Support area. The first paragraph on page 15, item (5) lists a failure to correct the MG-6 testing deficiency after identification during Keowee Unit 2 testing. The specific MG-6 problem was promptly corrected. A comprehensive program is underway to deal with MG-6 concerns and is part of the Emergency Power Management Plan.

The second paragraph on page 15 discusses the EDSFI report. Duke Power requests that additional, pertinent information from the EDSFI cover letter (ref: 50-269,270,287/93-02) be included in this writeup. The second paragraph of the EDSFI cover letter indicates that "this comprehensive inspection revealed no inoperable systems and provided adequate assurance that the Electrical Distribution System will perform as intended pending further analysis and testing by the licensee".

The last paragraph of Section V.A, Licensee Activities, in the SALP report discusses the October, 1992 loss of off site power event. This should read, "On October 19, 1992, during maintenance activities, a loss of off site power occurred for Unit 2 which was followed by a subsequent loss of one of the Keowee Hydro units."

A June, 1992 management meeting which was held at NRC headquarters on Station Blackout and Keowee issues should be added to Section V.D, Management Conferences.

Page 31: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ATTACHMENT 3 MAINTENANCE/SURVEILLANCE

Section C contains information on the Maintenance/Surveillance area. The second paragraph on page 10 discusses the test program for Keowee Hydro. The report states that "... relays required to isolate portions of the switchyard and to transfer Keowee auxiliary power to an alternate source were not fully tested".

Duke Power would like to clarify this information. The need for these tests had been previously identified by our Design Basis Documentation program. Duke Power was awaiting testing procedure development; complexity of the test and an extensive 50.59 evaluation precluded earlier testing.

Page 32: Forwards Final SALP Repts 50-269/93-11,50-270/93-11, 50

ENCLOSURE 4

REVISION SHEET

SALP BOARD REVISION SHEET

PAGE LINE NOW READS SHOULD READ

Title Sheet 1 INITIAL SALP REPORT FINAL SALP REPORT

6 50-269.. ./93-11 50-269...../93-11 AND 72-4/93-11

8 OCONEE ....... 3 OCONEE UNITS 1, 2 AND 3 AND THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

BASIS: These revisions change the Initial SALP Report to the Final Salp Report and include the name and docket number of the Independent Spent Fuel Storage Installation.

15 13 Injection (LPI)... Injection (LPI)..., (5) failure MG-6 testing to adequately test the MG-6 relays

to verify operability. After the development of an appropriate procedure for testing the MG-6 relays, a long standing operability problem was identified.

BASIS: This change is for clarity. The problem was not the failure to correct the MG-6 testing deficiency, but was the failure to perform an adequate test to verify operability of the relays. Once an adequate test was conducted, a relay which had been inoperable for a long time was identified.

15 15 An Electrical .... Although the Electrical Distribution ..... documentation. System Functional Inspection

revealed no inoperable systems and provided adequate assurance that the electrical system will perform as intended, it also revealed problems in testing, design analyses and design basis documentation.

BASIS: This revision adds the comment that no inoperable systems were identified during the EDSFI inspection.

18 15 through ... the through the LPI heat exchangers, during a postulated design basis accident, could have potentially exceeded the manufacturer's specifications. This was discovered on a test performed on Unit 3 and