IR 05000213/1986029
ML20210B551 | |
Person / Time | |
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Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
Issue date: | 01/29/1987 |
From: | Conte R, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20210B518 | List: |
References | |
50-213-86-29, IEB-79-14, IEB-79-24, NUDOCS 8702090186 | |
Download: ML20210B551 (44) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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Docket / Report No. 50-213/86-29 Licensee: DPR-61
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Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, CT 06101 l Facility: Haddam Neck Nuclear Power Plant
Location: Haddam Neck, Connecticut j Dates: November 14 - 21, 1986 i l Inspectors: P. Bissett, Reactor Engineer, RI ,
R. Conte, SRI, (TMI-1)
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- R. Gramm, SRI, (Limerick-2)
i C. Holden, Jr., SRI, (Maine Yankee)
H. Kister, Chief, Reactor Projects Branch No. 1 4 S. Sherbini, Senior Radiation Specialist D. Silk, Reactor Engineer (Examiner)
G. Smith, Security Specialist W. Troskoski, Senior Resident Inspector (Beaver Valley-1)
! Reviewed by: M bI/
R. Conte, Teim Leader
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. Approved b N 4 H. Kistep (Senior Manager
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! Inspection Summary i
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This was an integrated performance assessment inspection which involved 509
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hours of direct inspection and covered the following functional areas: plant operations, radiological controls, maintenance, surveillance, security / safe- ,
, guards, modification / technical support, training, and assurance of quality.
- The purpose of the inspection was to obtain a greater insight into the overall "
- facility / organizational performance to better understand the recent trends in
- performance in the various functional areas. In addition the team was to
- assess whether corrective action programs now in place are properly structured i and focused to be effective. The team was comprised of Region I-based j specialists and also senior resident inspectors from other reactor sites within ,
i Region The inspection results are summarized belo !
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la Inspection Results:
Licensed operators exhibited a detailed knowledge of plant design and of plant conditions. A contributing factor to this is the strong training program which uses a plant-specific simulator. Nonlicensed operators and technicians demon-strated an adequate knowledge of plant design and of plant conditions for their assigned area Improvements in the training program were being made and there was, in general, positive feedback on the value of that training. On the other hand, technical staff (engineer) training appears to be weak and has contrib-uted to poor performance in related functional areas. Improvements in their training are planned but progress has been slow and it is apparently of low priority. With respect to licensed operator and nonlicensed operator / tech-nician training, the team identified no performance deficiencies attributable to the licensee's training program. Plant staffing levels are adequate for routine activities but could be somewhat strained when other considerations such as providing sufficient time for participation in on going training are include In general, the plant is relatively clean and free of significant fire hazard Significant progress was noted in the decontamination of radiologically controlled areas. However, lapses in the detailed implementation of house-keeping and fire protection measures were noted, especially in out-of-the-way areas. The storage of transient equipment having the potential to adversely affect safety-related equipment was poor, and in part may be due to the lack of a station policy addressing this are The team found that the health physics and chemistry departments were staffed by generally competent and dedicated supervisors and technicians. Most of the staff members interviewed showed a reasonably good understanding of their duties and the problems in their areas of responsibility. However, marked differences in the understanding of technical issues and procedures were observed among the different technicians interviewed. Despite the dedication and effort of the staff, there remain several problem areas and weaknesses in the onsite radiological controls program. These problems and weaknesses could be alleviated by enhanced corporate support. Upgrades are needed in computer software and procedure adequacy. Procedures do not reflect current practices and this challenges personnel to properly adhere to procedure The team noted that no major components were out of service and that the main-tenance and surveillance programs provided reasonable assurance as to safety-related equipment operability. However, lapses in attention to detail were noted in following procedures, completing test data and reviewing documentation by responsible department and quality assurance department staffs. The team also noted in certain instances a lack of inquisitiveness on the part of supervision and management as to why equipment was out of servic Technical and safety review of plant modifications is considered a strength
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! apparently because of previous corrective actions. Technical support on site
appears adequate but resources in the plant engineering area are strained apparently because of a relatively high turnover rate. Communications could be
, enhanced between operations and corporate personnel with the focal point being i the plant engineering group. There also appears to be a need for enhanced j site specific knowledge at the corporate level in certain areas, f
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While there is an overall respect as to the need for procedures, a lack of adherence was noted by the team in multiple functional areas and appear to be
due in part to procedures that do not reflect current practice. In addition to i lapses in attention to detail and in the quality of reviews, the experience i level of workers appears to be a factor in the procedure adequacy and adherence l problems. Those that have a high experience level may have an attitude that
- procedures are not needed. The technical and safety review of procedures is adequate resulting in procedures which are generally adequate. However, pro-cedure format inconsistencies and individual step inadequacies exist. Pro-cedures are being upgraded in format and technical content but progress appears j to be slo The quality assurance program is well established and ambitiously supported by the corporate management. Overall, management control programs are adequate
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but they lack a consolidated view and do not set a good example due to the relatively large number of administrative control procedure Many correc-
- tive action systems are in place and they appear to be effective in enhancing
, management awareness of plant problems. However, quality effectiveness reviews l of longstanding issues could be enhanced. Many programs undergoing improvement continue to be in a state of transition without any interim or final resolution
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Overall the team concluded that the licensee operates Haddam Neck safel Although a number of weaknesses were identified none appear to be of a funda-mental nature. This conclusion is consistent with the results of the previous SALP and recent inspection report .
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Ic TABLE OF CONTENTS Page Introduction and Overview . ................. 2 Plant Operations. . . . . . . . . . . . . . . . . . . . . . . 3 Radiological Controls . . . . . . . . . . . . . . . . . . . . 8 Maintenance . . . . . . . . ................. 12 Surveillance Testing. . . . . . . . . . . . . . . . . . . . . 17 Security / Safeguards . . . . . . . . . . . . . . . . . . . . . 21 Modifications / Technical Suppor . ............. 24 Training. . . . . . . . . . . . . . . . ........... 29 Assurance of Qualit .................... 31 10. Previous Inspection Findings. . . . . . . . . . . . . . . . . 35 11. Exit Intervie . . . . ................... 37 Attachment 1 - Persons Contacted Attachment 2 - Detailed Activities Reviewed
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DETAILS 1.0 Introduction and Overview 1.1 Background and Purpose Region I periodically conducts integrated performance assessment inspections to enhance its understanding of licensee performanc The team's essential elements and focus are described in paragraph 1.2 below. All licensees are subject to this type of inspection independent of past strong or weak performance. This inspection process has proved beneficial in enhancing Region I's understanding of licensee performance particulary where there appears to be a change in performance. The Haddam Neck facility was selected as a part of this effort because of the apparent declining trend in performance noted by recent SALP evaluation .2 Inspection Process Initially, the inspection consisted of a review of plant operational activities by three shift inspectors (24-hour coverage) and follow-up inspection on shift-identified items. The essential ingredient to this process was personnel interviews at the working level to identify a basic program understanding in each functional are Followup interviews with supervisors / management and reviews of program descriptions / procedures complemented the team's review of a particular functional are Program / implementation reviews, along with follow-up reviews on shift inspector-identified items occurred in the following areas: plant operations; radiological controls; maintenance; surveillance; security / safeguards; modifications / technical support; training; and, assurance of quality activities. The NRC Senior Manager and Team Leader met periodically with licensee management to inform them of preliminary inspection findings. The Haddam Neck Senior Resident Inspector was used as a technical assistant to the tea After the 24-hour weekend coverage, shift inspectors on the back shifts resumed day shift hours to review their assigned functional areas. Random backshift coverage occurred during the course of the rest of the inspectio The following attributes were considered and examined during the inspection:
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development and implementation of management goals / objectives and how they are understood and implemented at all levels of the licensee's organization; . . - . ._
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planning and controlling of routine activities and the effec-tiveness of program implementation;
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level of understanding by workers and supervisors of the potential impact of their day-to-day actions on nuclear safety;
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attitudes of licensee personnel with respect to nuclear safety;
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involvement by senior management in day-to-day operation of the plant; j
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effectiveness of the training, direction, guidance, and super-
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adequacy of staffing in light of planned accomplishments;
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role of quality assurance / quality control (QA/QC) in monitoring activities and how their reports are used by licensee manage-ment;
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role of licensee in working with and overseeing contractor personnel; and,
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effectiveness of technical and safety review activities.
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In considering the above attribut,es, the quality of the control room
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ties were specifically addressed.
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! 2.0 plant _ Operations '
i J 2.1 Scope and Review i i Operating activities observed by NRC shift and daytime inspectors .
during the period November 14-21, 1986, included the following:
routine power operations and surveillance testing; normal shift duties, including staffing, turnover, logkeeping, plant tours, and i response to alarm conditions; and actions to comply with technical specifications. The inspectors also walked down portions of the
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j auxiliary feedwater, emergency diesel generator, and residual heat j removal (RHR) systems. Acceptance criteria were the general oper-i ating requirements of Section 6 of the Technical Specifications and the applicable limiting conditions for operatio Specific activi-
- ties reviewed are listed in Attachment 2.
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2.2 Operating Activities
Plant operators had detailed knowledge of the plant design and of
- plant conditions and they conducted operations in a safe manner.
I They were familiar with plant procedures; and, in general, correctly inplemented those procedure The team observed good supervision ,
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of activities by the operating crews. Auxiliary operators were cognizant of plant design and of plant conditions in their assigned space Operators were quick to respond to a loss of telephone communication capability that occured on November 18, 1986. When a control board annunciator alarmed, indicating a loss of Comex ability, the oper-ators verified that no other unexpected conditions existed (some switching gear receives backup signals from Comex, but they were unaffected). The operators then assessed the extent of the loss of Comex, declared an Unusual Event (based upon loss of telephone communications with the NRC Operations Center), and carried out the emergency plan notifications. The condition existed for approx-imately one-half hour before communications were re-established and the plant returned to normal operation The operators also reduced power on November 18, 1986, to support maintenance on the No. 2 feedwater regulating valve (FRV) positione The positioner had been operating erratically for several days and was subsequently replaced. The reactor and secondary system operators coordinated the down power transient in a slow and deliberate fashion. The control room supervisor monitored the evolution. Instrument and control (I&C) technicians replaced the positioner and the plant returned to 100 percent powe .3 Equipment Control Equipment was removed and returned to service using procedure 1.2 -
14.2, Revision 8, " Equipment Control." Operators were knowledgeable of the requirements of this procedure. Three different tags are used by this procedure to isolate, provide caution, or allow testing of systems. The senior operators in the control room determine boundar-ies for system clearances and approve the isolation of each syste The supervisor for whom the clearance was issued is responsible for assuring the adequacy of those boundarie Deficiencies in plant equipment are reported under the Trouble Report (TR) system. This system is integrated into the maintenance planning system. When conditions are identified that require attention, a TR is issued and a tag hung. Each TR is then assigned a priority and a responsible department for resolution. The TR's are converted to work orders for corrective maintenance, if applicable. The team iden-tified isolated cases where TR's were delayed for administrative rea-sons, but these were correcte In general, the system is effective in identifying deficient conditions and in initiating corrective act-fon in a timely manne '
The team also noted an extensive use of Plant Information Reports (PIR's) (over 200 issued this year). The threshold for PIR's is extremely low. A detailed root cause analysis is accomplished for each PIR. This extensive use of PIR's placed a burden on the Plant
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5 Operations Review Committee (PORC), so licensee management formed a separate PIR committee that meets generally after the 7:30 morning meetin This alleviates the PORC workload and causes the more significant issues to be sent to PORC. The team noted that PIR's are effective in enhancing management awareness of plant events and problem .4 Procedures During the course of this inspection, operators were generally ob-served to follow plant procedures in the conduct of their dutie Team members reviewed a variety of operating procedures and had the following comment . System lineups require only major valve alignments. Each plant system is aligned according to a normal operating procedure. As an example, during a plant startup, when the steam system is warmed, a valve alignment of the major valves associated with the steam system would be accomplished prior to conducting Normal Operating Procedure (NOP) 2.19-1-D, " Warm-up and Pressurization of the Main Steam System." Proper alignment of instrumentation valves and lower priority valves, such as drain valves, rely on proper operation of system instrumentation and reliance on several other control systems such as tagging, hydrostatic testing, et The team was concerned that the combination of these systems relies on the recognition of a problem as indicated by instrumentation (which should be a second check) versus verifying actual valve alignment (which should be the first level of control). There are some cases when valve location would not readily allow veriff-cation of position; and, in these instances, it may be appropriate to rely on indication. The inspector discussed these concerns with plant managemen . Some instructions to plant operators are contained in Operating Department Instructions (ODIs). A review of ODIs revealed that some of these instructions should be included as plant procedures since they contain specific instruct-ions on plant systems. Additionally, some tracking systems utilized by plant operators contain memoranda on the sal-ient points of the controlling instruction (tagging, temporary procedure change). These memoranda serve to alert the operators of changes to the system but may also unintentionally confuse the instructions since they are neither controlled nor PORC reviewe The station utilizes a " Controlled Routing" (CR) system to assure required reviews and action items are completed in a timely manner. The team reviewed this system as it applied
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to Temporary Procedure Changes (TPC's) and found it to be effective in controlling required action .5 Operations Staffing The team reviewed the Operations Department staffing as it re-lated to updating plant procedures. Since the plant recently imple-mented a six crew training rotation, the impact will be a reduction in the availability of senior operators for review of procedure changes. The team did not identify any specific problems with their procedure reviews but they were concerned that major revisions to the Technical Specifications (TS) or major modifications to plant systems could impact on the ability of the operations staff to keep their procedures current. Licensee management was aware of this potential problem and they are attempting to mitigate this with enhanced staffing using experienced operators for procedure review activitie .6 Control Room Environment During this inspection, the control room environment in which the operators function was observed. By design, the control room is small. During each shift, four licensed operators are stationed in the control room. Auxiliary operators (AO's) receive direction from the control room and periodically enter the control room to report plant status. All plant tagging and surveillances are approved in the control room. The team had the following observation Because the control board operators split the areas of their respon-sibility, each operator monitors one half of the control board and remains cognizant of the other operator's actions. The operators were noted to closely coordinate their activities. There were very few lighted annunicators; and, of those that were lit, operators were knowledgeable as to wh Background noise in the control room was at a reasonable level and it was adequately controlled during shift turnover with additional personnel in the are A red line is ueilized to indicate an area reserved for the oper-ator The operators must have full view of their panels and un-restricted access to plant controls. Tagging activities are accomplished outside the controlled (red line) area. Permission must be obtained to enter this area. The team observed that the control area was not consistently controlled apparently due to a lack of familiarization among shift and plant personne .7 Material Condition of Safety-Related Areas The team conducted numerous inspections of plant area In general, the plant is clean and reflects the pride personnel have in its operation. A major effort has been undertaken to clean and release
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formerly radiologically-controlled areas. The result is better access to primary systems for plant operators and maintenance personnel. However, some deficiencies were identified as addressed belo . Well-traveled areas of the plant are clean. Some of the peripheral areas do not appear to get the same attention, especially in the radiologically-controlled areas. During tours of the residual heat removal (RHR) cubicle, numerous items remained scattered following maintenance activitie Included were tools, extension cords, painting equipment, towels, and temporary lead shielding (see also section 7 on the control of lead shielding). Loose tools were noted throughout the plan . Lubricating oil for a variety of pumps / motors on both the primary and secondary sides of the plant was stored locally in unapproved containers. This was considered to be a fire hazard and contrary to administrative control procedures. Further, monthly inspection checks had not been made on two portable fire extinguishers. The extin-guishers on the north walls of the "A" and "B" emergency diesel generator rooms did not have the monthly check for October 1986. The team also noted that the extinguisher did not have the October 1986 semi-annual service checks like most of the other portable extinguishers throughout the plant. The licensee reported that an open work order existed and the extinguisher had not been reached ye (The team noted that the other extinguishers in the same room had semi annual checks completed.) The failure to properly inspect the fire extinguisher as noted above is
repetitive of an apparent violation (213/86-20-02)
identified in July 198 . The team noted that the licensee had not established a policy or administrative procedure concerning the proper storage of equipment in safety-related areas. As a result the team noted heavy equipment, especially on rollers, not reasonably restrained from impacting safety-related equip-men In the switchgear room, several breakers on rollers were stored, unrestrained, along a side wall. One was within 6 feet of the "A" battery fencing. In the "B" emergency die-sel generator (EDG) room, a breaker on rollers was stored close to the vital switchgear. An unrestrained ladder in excess of 15 feet was leaning against a wall near the north wall (cooling system end of the EDG). Throughout the prim-ary auxiliary building, large tool cabinets, welding machines, and other heavy equipment on rollers were
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unrestrained and near safety-related equipment; such as, near a containment isolation valve, the containment purge system, or containment atmospheric monitor syste The team was concerned that the licensee was not meeting the intent of 10 CFR 50 Appendix A, General Design Criteria 2 and 4, which require that structure, systems, and com-ponents important to safety be designed to withstand effects of natural phenomena and that they be appropriately protected against dynamic effect, including the effect of missiles, pipe whipping, and discharging fluids that may result from equipment failure and from events and condit-ions outside the nuclear power unit. Further, an indus-trial incident could lead to this unrestrained equipment affecting safety-related equipment or initiating a chal-lenge to a safety-related syste The team learned that the plant staff was responding to a corporate engineering memorandum, dated July 14, 1986, on the same subject. A " Controlled Routing" document was issued on that memorandum. The memorandum suggests an administrative control procedure be established to control this type of equipment. The due date on this action is January 1, 1987. The team noted that a previous unresolved item (213/86-20-01) on gas bottle storage in the control room was still an open issue. Accordingly, the scope of this unresolved item is expanded to storage in all safety-related areas, pending completion of licensee action as noted above and subsequent NRC Region I revie .8 Summary Operating crews were knowledgeable of plant design and plant status and they demonstrated operating the plant safely. They were familiar with plant procedures and exhibited good control of plant activitie Trouble reporting, plant information reporting, and tagging / work order processing appear to be working well in support of plant activ-ities and in enhancing management awareness of plant problems. Some weaknesses were noted in system lineup procedures. Management at-tention is needed for housekeeping in infrequently accessed areas; such as, the residual heat removal cubicle. More emphasis on per-sonnel awareness of fire protection requirements is necessary to control transient combustibles; such as, lubricating oil. Management attention is needed to address the control of heavy equipment in safety-related area .
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3.0 Radiological Controls 3.1 Scope and Review Inspection in the areas of radiological controls and radiochemistry included reviews of organization and staffing, facilities and equip-ment, records, ALARA, procedures, and training, as well as observa-tions during conduct of various radiological operations and tours of the radiological control areas. The general acceptance criteria for this area are 10 CFR Part 20, Section 6 of the Technical Specifica-tions, and related American National Standard .2 Facilities and Equipment This area of the licensee's operation was found to be adequate. The chemistry laboratory was found to be well equipped and well main-tained. Survey and counting equipment was found to be adequate in number and in fair condition. Weak areas included the calibration facility, daily quality control, and computer utilizatio The calibration source used in the calibration facility was of the well type and was used in a manner that is not in accordance with American National Standards Institute recommendations for good practices in instrument calibration. Although this deviation from good practice probably does not present an immediate safety problem, it could cause difficulties in interpreting instrument readings during calibratio The calibration facility is a temporary trailer-type space and may not be adequate for housing a high activity panoramic calibration source because of shielding consideration Although daily quality control is performed on the counting instru-ments and gamma spectrometer, it is limited in scope and does not include some tests that are generally considered useful in identify-ing problems in the counting equipment. The results of the daily tests are reviewed by supervisory personnel, but they are not presented and maintained in a manner that would allow easy trending of the data over a period of time. Also, there were no clearly established and understood quality control limits on the parameters obtained in the daily test Photon sources are used to check the response of survey instruments before each issue. However, the source activity is insufficient to test the upper ranges of the instruments and such ranges are thus not checked before us There were no data available at the time of the inspection to indicate that testing the instruments on the lower ranges gives assurance that in the higher ranges they would also operate adequatel Computers are used in a number of daily radiological control activi-tie Some of the software supporting these activities appeared to be well suited for the function but other software was found to be weak in that it did not provide sufficient power to perform the
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required functions efficiently and fully. This finding included daily quality control software, which was found to be cumbersome to use and did not include all the desirable quality control test The ALARA computer software was found to be lacking in its ability to easily perform all the correlations between the quantities in the ALARA data base that would be useful as a tool to identify the sources of expo-sures. The. software was also found to be cumbersome in its ability to present data in a convenient forma The elements contained in the ALARA data base were apparently not evaluated from a management point of view to ensure that they contained all the items that may be needed in studies of exposure histories and exposure patterns. Such correlation studies would assist in identifying exposure problem area .3 Records Exposure, calibration and dosimetry records were reviewed for accu-racy and completeness. The records were found to be well organized and up to dat .4 ALARA The area of ALARA was the subject of a recent NRC inspection repor Since that above-mentioned inspection, there appears to have been an increased effort by the licensee to improve performance in at least one of the areas identified as a programmatic problem, namely, timely planning of major outage jobs. This was evident during team review of a pre-outage meeting and based on discussions with licensee per-sonnel involved with outage planning. The licensee expects this effort to result in improvements in ALARA performance. Because the upgrade effort was in process, ALARA was not reviewed further during this inspectio .5 procedures Procedures were reviewed to determine the adequacy of the number of procedures in use as well as their qualit The number of procedures was found to be adequate, and procedures were in existence to address all the areas reviewed in this inspection. Detailed inspection of randomly selected procedures showed, however, that the quality of the procedures was, in many instances, deficient. Many of the procedures reviewed contained significant typographical and technical errors and technically inaccurate or incorrect statements. Many key concepts were poorly defined and misleading. There were also inconsistencies between different parts of the same procedure as well as between procedures. Finally, some procedures were found to be difficult to follow in a step-by-step fashion to perform the described tas Specifics were discussed with cognizant licensee management who, in general, were aware of these types of deficiencies and were taking corrective steps for improvemen .
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3.6 Training The training center has recently completed development of a training course for technicians. The team reviewed the contents of this course and found that it represented an improvement in the quality of the training material and the scope of subject matter. However, two factors may result in reducing the effectiveness of this train-ing. The proposed rate at which the material is to be presented appeared to be excessively high. This would probably result in a poor understanding and retention of the material presented. Also, the formal training material does not appear to be meaningfully and clearly connected to the concepts and techniques contained in the procedures. This may result in some key concepts and methods used in the procedures escaping presentation and discussion in any formal foru .7 Staffing and Organization Staffing for normal operations appeared to be adequate. Staffing during outages is augmented by contractor personnel. Selection of contractor personnel is based on a well-controlled system that is designed to ensure that contractor personnel have sufficient exper-ience in the areas of outage work to which they are assigne The weaknesses in the areas noted above (sections 3.2, 3.4, 3.5, and 3.6) may be a result of weaknesses in the organization and staffing on site. A possible contributing factor may be the apparent absence of continuous and involved technical health physics support on sit The effect of this absence is apparent in the existence of technical problems that have been identified by site personnel but have re-mained unresolved for long periods of time, and problems that have been identified only during inspections by outside agencies. Site personnel do not appear to have ready access to professional health physics support, nor the continuous oversight that such technical presence could provid Although a health physicist position is provided in the site organi-zation, this arrangement has not been effective in the past. This may be because the occupant of such a position does not have any direct role to play in the daily operation of the plant and no direct authority to have any influence in ensuring: (1) that jobs are performed in a technically sound manner; (2) that current health physics practices are adopted on site where possible; and, (3) that the various departments on site adhere to the requirements of good ALARA practices. Stated another way, there does not appear to be a forceful health physics presence on site. This onsite organization does not seem to be completely aware of all radiological activities, problems and weaknesses on site, or familiar with current health physics theory, regulations, recommendations of national and inter-national committees and good practice methods in the industr Further, it does not appear to have sufficient authority to ensure o
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that unsound practices are promptly discontinued, problems quickly resolved with the assistance of corporate resources if necessary, and radiological controls practices are strictly adhered to by everyone on sit .8 Summary The general findings were that the health physics and chemistry de-partments were staffed by a generally competent and dedicated staff of supervisors and technicians. Most of the staff members inter-viewed showed a reasonably good understanding of the their duties and the problems in their areas of work. However, marked differences in the understanding of technical issues and procedures were observed between different technicians interviewed. Although this is to be expected in any facility, the licensee should consider an expanded retraining program for all technicians using the training material recently developed by the training cente Several of the staff, particularly the supervisors, had proposed to management a variety of methods to improve performance and reduce exposure to radiation. Some of these proposals have been adopted and have proved successful. Despite the dedication and effort of the staff, there remain several problem areas and weaknesses in the radiological controls program on site. Overall, operations and corporate staff support of the radiological control program appears to be wea .0 Maintenance 4.1 Scope and Review Plant maintenance programs were reviewed to determine their effect on the safe operation of the plan In addition to a program review, NRC team members witnessed ongoing maintenance activities, discussed maintenance-related activities and administrative controls with appro-priate personnel They also assessed present staffing levels and re-viewed management involvement in the maintenance area. Interviews were held with maintenance and I&C department supervision, technic-tans and tradesmen and interfacing departments such as Operations and Engineering. Also evaluated was quality assurance / quality controls (QA/QC) involvement in maintenance activities. The team also re-viewed the backlog of scheduled maintenance to determine the impacts if any, on safety-related equipment operability. Acceptance criteria for this review included ANSI N18.7-1976 and the licensee's (NRC approved) quality assurance pla .2 Maintenance Organization Maintenance activities are controlled and conducted by the mainten-ance and instrument and control (I&C) departments at Haddam Neck. A mechanical and electrical group make up the maintenance department
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and the I&C department is a separate entity. Both departments report to the Unit Superintendent who has the overall responsibility for the conduct of maintenance activities at the site. The organization structure is sufficient to achieve effective program implementatio .3 Automated Work Orders Control of maintenance activities is accomplished through the use of numerous administrative procedures, including administrative con-trol procedures (ACPs), administrative procedures (APs), nuclear engineering organization procedures (NEOs), quality assurance department instructions (QADIs), and lower tier department instruc-tions. The inspector held discussions with maintenance and I&C department personnel to evaluate those controls in place used to identify, schedule, track, and document maintenance activities, including both corrective and preventive maintenance. All mainte-nance activities are controlled via an automated work order (AWO)
which is part of the production maintenance management system (PMMS).
The PMMS is a computerized maintenance information retrieval system which provides a mechanism for organizing and controlling maintenance activities, including job scheduling, follow-up, documentation, et The scheduling and subsequent initiation of any particular work activity is accomplished 1) directly through the initiation of an AWO, or 2) indirectly through a trouble report, which in turn, generates an AWO. The trouble report system enables all plant personnel to identify maintenance problems which, in the past, often resulted in a duplication of AW0s. To correct this problem, the licensee recently initiated the use of a trouble report tag, which has minimized the duplication of AW0s and improved the work coordination among different work group The team reviewed the records of both random and selected main-tenance activities performed on safety-related equipment to verify the followin Required administrative approvals were obtained prior to initia-tion of work activitie Approved procedures and/or instructions were use Appropriate post-maintenance testing was completed prior to de-claring a system or equipment operabl Hold points were appropriately identified and complete Qualified test equipment and tools were identifie Procedures and appropriate data sheets were properly complete .
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Acceptance criteria were me Appropriate reviews were completed as require Records were assembled, stored and retrievable as part of the maintenance histor The team determined that the attributes listed above were incorporated into the maintenance program / procedure .4 Maintenance Activities Direct observations of several preventive and corrective maintenance activities were performed during the inspection. This provided verification of the completion of the above attributes (paragraph 4.3) and afforded the team the opportunity to assess actual work practices, and communication and coordination between various work groups. The team found the workers and first line supervision to be well qualified, conscientious, and cognizant of their impact on plant operations. First line supervisors were adequately involved and provided additional guidance when deemed necessar However, co-ordination of efforts between various work groups could be improved as noted belo Activities sampled as a part of this review are listed in Attachment . Freeze Protection During the team's review of heat tracing circuitry failure at the screen house and for a level transmitter for the demineralized water storage tank, it was determined that problems of this nature have persisted as cold weather arrive In some instances, modifications have been com-pleted to provide permanent corrective action for protec-tion against freezing of safety-related process, instru-ment, and sampling lines. In other instances, only temp-orary action was completed. Further review of this problem indicated however, that the licensee does not have in effect, a formal, well-characterized freeze protection (FP)
and/or heat trace (HT) program. Although, an annual PM does exist for alerting the PMMS planner as to when it is due, this PM is no more than a reminder to check and record heat tracing panel circuit amperag (It should be noted that this action was instituted just this year.) Further discussions with the maintenance supervisor and operations personnel revealed their plans to improve and formalize the existing FP and/or HT PM into the PMMS Syste . - - - _ _ .
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By memorandum to the Station Services Superintendent, the Maintenance Supervisor initiated assignment for a controlled routing to improve and formalize the FP & HT PMMS. This action was initiated prior to the conclusion of this inspection. The team's review of this memorandum in-dicated that all of the team's concerns would be addressed, including:
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Formalization of the program, including procedure development;
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Documentation improvement;
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Trending; and,
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Multidisciplinary review of FP and HT related problem The licensee has committed to develop a formal PM program for FP and HT by July 198 For administrative purposes, IE Bulletin 79-24, " Frozen Lines," (see paragraph 10.1) will be closed and subse-quently carried as an unresolved item (213/86-29-01) pend-ing further development of the FP and HT program. The team had no further questions in this are . Diesel-Driven Fire Pump Preventive Maintenance Observation of performance during the conduct of preventive maintenance on the diesel-driven fire pump (P-5-1A),
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indicated a need on the part of the licensee to improve l coordination and communication efforts between all depart-ments involved. This PM, which encompassed fuel, oil and filter replacements, took almost 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete during 3 separate day shifts, whereas past history indicates that this PM is normally accomplished in less than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Since the licensee works only one shift per day during normal plant operation, the fire pump had to be taken -
out-of-service three consecutive day The team emphasized the importance of minimizing the down-time of important plant equipment such as the diesel-driven fire pumps. From a probabilistic risk assessment perspec-tive, this fire pump is a critical component because it provides independent power and a backup source of water for containment spray. The team noted that improved communi-cations between the involved departments present during the first-line supervisor's meeting could have effectively minimized the number of times, and also length of time the fire pump was out-of-service (005).
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Difficulties were encountered with the procedure itself, and in obtaining parts and materials, including locating the parts and also gaining access to the storeroom as a result of restricted storeroom hours. As a result, actual work did not commence until almost 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the pump was tagged 00S by operations on the first day of maintenanc , ,.
Although the PM took an excessive amount of time to com-plete, the team found it to be conducted by well-trained, conscientious individuals. Extra effort was expended by maintenance personnel in maintaining the cleanliness of the work area. Procedures were adhered to and post-maintenance testing was successfully completed following work each of the three days. The team had no further comments in this are . Automated Work Orders Documentation During the review of in process and completed AWO packages, the team noted some concerns, over the manner in which AW0s and accompanying documents were completed. These concerns, having been previously identified during other inspections, were once again brought to the attention of plant manage-ment. Some of these concerns included the following:
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Lack of detail when completing " actual / remarks / parts used" and "cause of problem" sections of the AWO;
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Correctness of dates; .
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Various sections of the AWO not being completed as required; and,
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Inadequate final reviews of completed AW0 The licensee acknowledged the team's concerns and stated that efforts were underway and would continue in order to bring about improvements in this area. The team had no further comment .5 Coordination Meetings The licensee has instituted a daily morning coordination meeting; normally headed by one of the PMMS planners. This meeting was begun approximately four months ago and was instituted to improve communi-cations and coordination between all departments on site for main-tenance activities scheduled to take place that day and the following day.
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Personnel in attendance at these meetings represented operations, maintenance (mechanical electrical), I&C, health physics, betterment and construction and QA. Team members attended several of these daily meetings and noted that the above personnel were normally presen Interaction between personnel present was adequate however, the team felt that a more in-depth, detailed questioning of certain items could havr. alleviated some of the concerns identified by the team. Some of these concerns included why freeze protection problems recurred and the length of time the diesel-driven fire pump was out of service, neither of which were addressed in any detail at these meeting Licensee management should again review exactly what they are attempting to accomplish at this meeting. The team had no fur-ther comment .6 Trending The team reviewed the licensee's program for the trending of maintenance to identify repeated maintenance or degraded equipment performance which could indicate that underlying problems were not being corrected. The I&C Department, through the I&C open item pro-gram, essentially trends the performance of instrumentation based upon calibration results. An instrument calibration review (ICR) is conducted for each instrument that is inoperable or fails to meet its calibration acceptance criteria. The Assistant I&C Supervisor then performs a review to determine if a degraded trend in instrument performance is developin If so, an evaluation as to what correct-ive actions should be taken is performed. The team verified various aspects of this program for implementatio No formal trending procedures or program exist to trend maintenance (mechanical and electrical) problems. The maintenance supervisors and assistant maintenance supervisors informally monitor equipment failures through their reviews of AWO's LERs, etc. Trending of safety-related pumps and valves that fall under the Inservice Testing
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(IST) program is performed by the onsite engineering group. A maintenance supervisor stated that the forthcoming revision of the PMMS software should provide a better means for tracking and readily identifying repetitive equipment failures and maintenance trends for i balance-of plant equipment.
4.7 Summary The maintenance and instrument and controls departments were found to be adequately staffed and the personnel well trained. A strong sense of pride among workers with other division personnel was
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evident, as there was accountability for work quality to first line supervision and higher managemen Personnel safety is clearly stressed at all levels. Department supervisors are, in general, knowledgeable of ongoing activities. Corrective action for recurrent freeze protection problems appears to be weak and those problems appear to be due to lack of definitive procedures to be implemented
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prior to the onset of cold weathe License management also needs to be more sensitive to activities that take excessive time to complete especially on critical plant components, such as the diesel-driven fire pum .0 Surveillance Testing 5.1 Scope and Review The surveillance testing program was reviewed to verify that the lic-ensee had developed, maintained, and implemented written procedures and administrative policies necessary to ensure the operability of safety-related systems. Approved test procedures were reviewed for technical adequacy; tests were witnessed to verify proper conduct and resolution of identified problems; and discussions were conducted with operators, technicians, first-line supervisors, and various de-partment heads to determine their understanding and involvement in the program. Acceptance criteria included specific TS surveillance requirements and ANSI N18.7-197 .2 Surveillance Procedure Implementation 5. Emergency Diesel Generators The inspector observed the full load run of emergency diesel generator (EDG) 2B on November 17, 1986, per SUR 5.1-17, "EDG Manual Starting and Loading Test," for the redundant system checks of PMP 9-5-21. The 2B diesel air start system was disabled, the twenty cylinder air petcock valves were opened and the diesel was manually jacked per SUR 5.1-16, " Check for Inleakages," to verify that no water had accumulated in the cylinders. In discussions with the operators, the team was informed that this evolution was conducted once per day. Since the diesel is effectively disabled for five to ten minutes, the team questioned whether this procedure would be performed when the other emergency diesel generator was out of service for any rea-son. Licensee personnel acknowledged that the condition has existed. The team raised a concern that this practice unnecessarily removed all on-site emergency a.c. power from service under those conditions. This is unresolved pending further licensee and NRC staff review of the practice of jacking one EDG, while the other is out of service (213/86-29-02).
5. Fire Pump During performance of SUR 5.2-9, " Fire Protection System Tests," on November 11, 1986, the diesel-driven fire pump failed to cold start on the first attempt but was success-fully started on the second. Discussions with the shift supervisor indicated that there were two contributing
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factors to this problem. First, the service water building heaters were not operating. Secondly, the building air louvers were partially blocked open by wire mesh placed there for security reasons. This event was primarily caused by the licensee's failure to take adequate winter-ization precautions as discussed in paragraph 4.4.1 of this report, and, to a lesser extent, failure of the licensee to coordinate multiple regulatory requirements to arrive at a satisfactory solution that envelopes both operations and security goal . Pressurizer Pressure During performance of SUR 5.2-4 for channel 1 of the pres-surizer pressure trip setpoint check, the instrument and control (I&C) technicians verbally informed the reactor operator that the pressurizer pressure control system would have to be placed in manual and closely monitored for the duration of the test. After acknowledgement, the I&C technician proceeded with the setpoint check. Shortly after initiation, the operator noticed that pressure was rapidly dropping as both spray valves were open. The test was immediately interrupted, spray valves closed, back-up
heaters energized, and the pressure stabilize It was s @sequently determined that the reactor operator failed to plisce the pressure control system in manual and system j response was as expected for the test signal. This is an
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example of operator inattention to detail in following facility procedure .3 Surveillance Program Implementation The administrative control procedure (ACP) 1.2-11.2, " Review of Test Data," establishes measures to require that test results be evaluated to assure that test requirements have been satisfied and that test deficiencies are correctly documented and reported to appropriate
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levels of management. To accomplish this objective, department heads or their designated alternates shall evaluate and approve the test results as soon as possible after test performance and no later than the end of the allowed grace period for surveillance tests. After completion of this review, a final department review is required within thirty day s The ACP 1.2-11.2 also requires that data sheets and checklists be
- i forwarded to QA for review, which is to be completed within thirty
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days of receipt from the department (sixty days from test comple-J tion).
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From a random review of completed surveillance tests, the team identified the following apparent deviations from the guidance con-tained in ACP 1.2-1 SUR 5.7-108, " Containment Integrated Leak Rate," was per-formed April 1-8, 1986. Final department review and approval was not completed until September 1986, about four months from reactor startu l
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Calculation No. "CY-XX-XXX-001," " Containment Local Leak Rate for IRLT-1986 Refueling," prepared April 25, 1986, did not receive a full review until September 18, 1986. This cal-culation obtained data necessary to verify the acceptance criteria of SUR 5.7-108 (above). This handwritten calcula-tion appears to be a separate entity outside the formal procedure review and approved process of Technical Specific-ation 6.8, " Procedures."
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SUR 5.2-19, " Reactor Coolant T-Cold Interlock Test," con-ducted April 10, 1986, was not reviewed by QA until September 26, 198 These examples indicate that the personnel and management lacked attention to detail to assure that the test result reviews are conducted in a timely manner. Additionally, the QA department, which receives the test data sheets, failed to identify this program anomaly, indicating a lack of attention to detail in their review which ultimately diminishes the effectiveness of their independent revie Other minor concerns in conduct of the test program were also iden-ti fi ed. Examples include: use of pencils and white-out in several yearly tests (such as, SUR 5.7-108); use of an out-of-calibration timer (SUR 5.7-70, performed October 14,1986); use of informal data sheets not part of the test (SUR 5.3-45, " Reactor Coolant Flow Measurement, performed August 12,1986); lack of a double verifica-tion of removal of the shorting bar bypass for the steam generator high level function (SUR 5.2-71, step 6.3. 14, " Side Range Level t Calibration - Auto Auxiliary Feedwater"); and an unauthorized proce-l dure change to correct the identification of state blocks in the reactor coolant system (RCS) loop isolation valve interlock test performed every outage (Nonconformance Report (NCR)86-346 sub-sequently identified this).
From the variety of discrepancies, it appears that the first line and department level reviews need to be strengthened to assure that all personnel fully implement the station's policy and procedures.
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5.4 Surveillance Procedures The team reviewed test procedures selected from a random sample of several station discipline For the limited review conducted, procedures appeared to be adequate. This review, however, identified an inconsistency in the application of procedure format. Some proce-dures required sign-offs or check-offs, verifying that action had been performed in Section 6.0, " Procedure," while others placed this in Section 7.0, " Check-Off." Many procedures documented the shift supervisor's permission to conduct the test in Section 4, "Prerequist-tes," and had required check-off initials in this section, as well as Section 5, " Precautions." Other procedures did no This practice was discussed with the I&C supervisor and selected by a team member as representative of the various station discipline The team was informed that past practice had been to assign each I&C specialist (senior or top grade technician) the responsibility for writ-ing a group of surveillance tests. As systems were modified and pro-cedures reviewed, the one-to-one correlation between Section 6, " Pro-cedure," and Section 7, " Check-Off," was lost. To correct this weak-ness, the licensee plans to have a full-time procedure writers dedica-ted to rewriting the surveillance procedures to the consistent guide-lines recommended by Institute of Nuclear Power Operations (INPO).
The inspector noted that additional resources may be necessary as the plant implements a new, more standardized version of technical specifications, due in 198 .5 Summary The surveillance tests generally were found to be technically ade-quate and properly scheduled. There is an overall inconsistency in
! the procedure format within departments that has been recognized by l the station and is only recently being addressed. Personnel perform-l ing surveillance testing were generally aware of its impact on nuc-
! lear safety and were adequately trained and conscientious in this regard. However, additional attention to detail by both personnel conducting the test and supervisors reviewing the completed proce-dures is warranted. Administrative guidelines are not rigorously implemented in regard to procedure adherence and identification and correction of procedure deficiencies not directly related to meet-ing the acceptance criteria. Also a more timely final review of out-age tests by cognizant departments is needed. Though the program was found to be adequate, further improvement will necessitate stronger management involvemen .
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6.0 Security /Sa feguards 6.1 Scope and Review The inspector performed an in-depth review of the licensee's NRC-approved security program to verify proper implementation in all aspects of the program. Details are described belo .2 [ecurity Plan and Implementing Procedures A review of the licensee's security plan disclosed that it was ade-quate to implement regulatory requirements. A review of the security implementing procedures disclosed that the requirements contained therein generally exceeded the security plan commitment .3 Management Effectiveness Management is involved in the security program and continues to be supportive. The licensee has five security shift supervisors that provide around-the-clock oversight of the contract security guard force. Management continues to develop security program enhancements as demonstrated by the plant operations training program developed for the security shift supervisors to make them knowledgeable of the operation of vital equipment located within vital areas and its func-tions in safe shutdown of the plant and prevention of the release of radioactivit .4 Security Force Organization The licensee utilizes a contractor security force with oversight by licensee security shift supervisor The security force has a turn-over rate of approximately 40 percent which is mainly attributable to the strong economy in the area. The licensee and the contractor have implemented several programs to address the turnover rate, but no positive solutions were apparent at the time of the inspection. The contractor guard force is structured so that there is one supervisor for every two guards. This favorable supervisor to guard ratio and full-shift oversight by the licensee's security shift supervisors significantly offset the problem of the high turnover rat .5 Security Program Audit Two comprehensive program audits of the security program were conducted during the previous year by corporate management.
! One minor discrepancy was noted in the most recent audit and it was corrected prior to the completion of the audit.
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6.6 Records and Reports A review of a random sample of the records and reports required pursuant to regulatory requirements, disclosed no discrepancies. All records reviewed were complete and were being maintained for the appropriate periods of tim .7 Testing and Maintenance The inspector observed testing of alarms, card readers, and the back-up power supply during this inspection. All testing was done in accordance with procedures. Security equipment is generally reliable and, when it did fail during this inspection, maintenance support was observed to be timely and effective. A review of maintenance work requests by the inspector indicated that this was the general cas Security computer support is provided by off-site corporate computer specialists and is adequate. Additional off-site security computer software sunport could enhance the implementation of the security programs that have been proposed by the security departmen .8 Locks, Keys, and Combinations The inspector's review of the security keys, cards keys, locks, and lock combinations disclosed they were controlled and protected in conformance with the security plan and licensee implementing proce-dures. The access control system was effective and appropriate for program function .9 Physical Barriers, Protected and Vital Areas The inspector, accompanied by licensee security management, inspected the protected area fence and selected vital area barriers. A weak-ness in one barrier was identified. The barrier was a single pro-tected area / vital area barrier and was constructed of metal sandwich material and aluminum louvers covered with light wire mes A guard was posted in the area for other reasons at the time the
- weakness was identified by the inspector. The licensee took I
immediate action to maintain the compensatory measures because of the barrier weakness and initiated immediate action to have the barrier louver upgraded. During the inspection, the material to upgrade the barrier was ordered, and delivered to the sit Fabrication of an upgraded barrier was started. In parallel with ordering and fabricating the barrier, a plant design change review (PDCR) was initiated. When the PDCR is complete, the upgraded barrier will be installed and the compensatory measures can be terminated. The licensee also has initiated a study to validate the integrity of all vital area barriers as a result of this findin _-
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6.10 Security Power Supply On November 15, 1986, the primary power to the security system was removed to facilitate work on a transformer. The backup power supply started as designed, and powered the security system for approxi-mately four hours. The inspector noted the security system was operating on the backup power within one minute after disruption of primary powe .11 Lighting The inspector toured the protected area during the hours of darkness several times during the inspection and found the lighting to be ade-quate to meet regulatory requirement .12 Compensatory Measures On November 15, 1986, the inspector observed the implementation of compensatory measures prior to the disruption of the primary security power supply and during the period the security system was powered by the backup power supply. The compensatory measures were effective and in compliance with procedure .13 Assessment Aids, Detection Aids, Communications, and Alarm Stations
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The inspector noted that the assessment aids, detection aids and communication systems were effectively installed, well maintained, and tested in accordance with procedural requirements, which generally exceed regulatory requirements. The alarm stations were well laid out for ease of operation. The central alarm station (CAS) air
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conditioning has recently been upgraded with a dedicated unit. Pre-viously, the CAS received air conditioning from another location and
- temperature could not be controlled. The temperature fluctuation had the potential to damage the security computer and disc drive units, therefore, a dedicated air conditioning unit was installed.
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6.14 Access Control, Personnel, Packages, and Vehicles Throughout the inspection, the team observed the access control func-tions and noted all functions were in compliance with procedural re-quirements. Review of procedures disclosed they were well written and in conformance with all regulatory requirements. The licensee has recently begun to rent the tractor portion of a tractor trailer as an aid in training the security force in the proper vehicle search procedures.
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6.15 Personnel Training and Qualification / General Requirements and Safeguards Contingency Plan Implementation Review The inspector observed that, as a matter of policy, the licensee requires all central alarm station / secondary alarm station (CAS/SAS) operators to qualify for promotion to the rank of sergeant before assuming CAS/
SAS operator responsibilities. The inspector's observations of CAS/SAS operations and a review of training material demonstrated the effectiveness of the CAS/SAS training. Training for guard posts was also reviewed and found to be effective. Although the inspector noted that the high turnover rate resulted in a heavy workload for the security training department, the training department was ade-quately handling this heavy workloa The licensee's security organization conducts drills of each contin-gency plan scenario on each shift at least twice a year. This re-sults in approximately 180 contingency plan drills per year. The active simulation of safeguards contingency events reinforces the overall proficiency of the security organizatio The inspector reviewed records of past drills and observed a drill during the in-spectio .16 Summary The team determined that the security program is well managed, effective, efficient, and exceeds basic regulatory requirements. No violations of NRC requirements have been identified in the security program since January 1980 and the security program has been con-sidered to be a strength primarily because of strong licensee man-agerial oversight. Management's continuing support of the security program is evidenced by the security program improvements noted during each Systematic Assessment of Licensee Performance (SALP)
rating period and during this inspectio .0 Modifications / Technical Support 7.1 Scope and Review The control of plant modifications from inception through implementa-l tion was assessed. Design change documents and the associated safety evaluations were reviewed for technical adequacy and conformance with applicable requirements as delineated in the licensee (NRC approved)
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quality assurance plan. The field implementation of a current modifi-cation and the licensee control of the installation contractor was
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examined. The training of plant and project engineers was reviewed to assess whether personnel were familiar with plant systems and pro-cedural controls. The team also reviewed plant engineering staffing with respect to current workload and internal and external communica-tions channels for plant engineering activities.
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7.2 Turbine Building Sprinkler Modification The team monitored an in process modification involving the turbine building sprinkler system. The associated design documentation in-ciuding the specification, plant design change request, drawings and work orders were reviewe The betterment construction personnel were found to be closely monitoring the work of the installation con-tractor. The design documents were found adequate and the appropri-ate installation codes and standards were referenced. The work activ-ities involving system tagout and isolation, dismantling the old sprinkler system, providing an augmented fire watch, and installation of the new sprinkler were found to be satisfactorily performe .3 Operations Critical Drawings A portion of the plant drawings including piping and instrument dia-grams (P& ids) and one line electrical prints are designated as opera-tions critical drawings. The drawings are maintained in the control room, Technical Support Center (TSC) and Emergency Operations Facility (EOF). The control room drawings were reviewed on a sample basis and found to be the most current revision. The redline incor-poration of "P" type (plant generated) drawing change requests (DCRs)
was verified for one plant as-built modification. The team attempted to verify redlines for "S" type (corporate generated) DCRs. This verification could not be made due to the inability of the document control database to identify which open "S" type DCRs should be currently redlined. The site quality assurance personnel that per-form surveillances of this area had not previously audited "S" type DCRs for proper redlining. The team was informed that all plant P& ids are currently being updated to ensure that the plant as-built configuration is properly represented. The licensee review should identify and correct any situations where the plant modifications were not properly incorporate .4 Temporary lead Shielding The installation of lead shielding is controlled by plant procedures to ensure that the proposed installation is reviewed by engineering with respect to the impact on plant equipment operability. The in-l spector identified that lead associated with temporary shielding re-quest (TSR) 8631 was covering reactor coolant pump seal return lines in the residual heat removal (RHR) system pit. Plant engineering provided letter EN-86-407 that directed the shielding to be removed in April 198 Due to a personnel error, the directive was never issued. Plant engineering will perform a reevaluation of the three l unauthorized shielding installations that were not removed in accordance with letter EN-86-407.
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The shielding on safety-related equipment (RHR pump suction) was immediately removed. A piping stress analysis was initiated to assess the piping response with the shielding in place. The team was provided Plant Information Report (PIR)86-202 and Nonconformance Reports86-451, 86-452 and 86-453 regardir1 the unauthorized shield-ing installations. The team was additio1> ly informed that the engineering procedure ENG 1.7-6 is curri atly under revision to add further controls to preclude a recurrence of this proble .5 Overvoltage Bus Conditions The team identified that several plant busses were experiencing an overvoltage condition. Discussions with project and plant engineers identified that the problem had been identified during the last out-ag " Controlled Routing" No.86-387 documented the issue and engineering is considering adjusting transformer taps to correct the situation. Plant electrical engineering stated that +10% voltages are allowed with respect to motor nameplate rating. The team review-ed the HPSI overvoltage alarm setpoint and found it acceptable with respect to the HPSI motor ratin .6 Design Input Verification Plant engineers performed safety-related design activities through involvement with plant design change Request (PDCR) initiation. The engineers have access to drawing aperture cards for plant system During interviews with plant engineers, the inspector was informed that the aperture cards are used to create drawings which are then used for design activities. The team was additionally informed that the engineers do not generally feel compelled to perform a drawing verification with the master document index to ensure the most current drawing is being used. The site administrative procedures state that, with the exception of drawings in the plant records vault, all drawings are for information only and must be verified prior to us The fact that the drawings are not checked can lead to the use of improper design inputs. The PDCR process includes additional verification steps prior to final design issuance at which point the use of an improper design input could be detected. Cogni-zant licensee management indicated that engineering personnel will be reinstructed as to the proper use of drawings as design input.
- 7.7 Engineering Personnel Training The training of both plant and project engineering personnel was re-viewed. Project engineers are provided with the opportunity to take a Haddam Neck plant systems training course that lasts approximately two weeks. The team reviewed the associated training manuals. The team was informed that the project engineers utilize the read-and-sign method for indoctrination on the applicable nuclear engineering
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and operations procedure Team members interviewed several plant engineers and found that procedure training is conducted in an
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informal manner. The engineers are given the procedures to learn without any supervisory followup to ensure that the applicable pro-cedures are thoroughly understood. The current plant engineering training regarding procedures is a weakness that appears to have contributed to the use of inappropriate design input documents discussed above. The inspector was informed that a new plant engineering training program is being developed to cover all facets of plant operation in which the engineers are to be knowledgeabl The training will last approximately five years. The planned train-ing should rectify the shortcomings in the current training provided to plant engineer .8 Plant Engineering Staff The team reviewed the current plant engineering staff organizatio Several plant engineers currently hold or formerly held reactor operator licenses for the plan Two assistant supervisors have attended the reactor operator training schools. The supervisory staff includes experienced personnel who have been on site for a number of years. Several vacancies currently exist in the organiza-tion and eight contractor personnel are used to augment the permanent engineering staff. Discussions with plant engineers identified that the staff had suffered a significant loss of personnel during the last year. The perception of plant engineers that senior engineer positions are not available onsite may be centributing to the personnel loss. The success of the long range training effort and performance of daily engineering activities will be dependent upon the retention of experienced personnel within the plant engineering departmen .9 Project Assignments A conceptual project modification is originally proposed and reviewed by the Project Assignment Review Committee (PARC) located at the corporate office in Berlin, Connecticu If the funding is approved, the modification is translated into a project assignment (PA). A project engineer is held responsible for implementation and closure of the PA. The team reviewed plant and project engineer assignments and was informed that personnel are currently working on primarily the engineering for upcoming 1987 PA modifications with a lower j priority on the closecut of old pa In particular, the team was informed that PA 80-132 had been field completed two outages ago, yet i
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the PA has not been administratively closed. The open backlog of field completed pas appears to detract from the ability of plant and project engineering to focus on current and planned modification activities.
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7.10 Interface between Plant and Project Engineering The team was informed that plant and project engineers meet on at least a monthly basis regarding current project assignments. The project engineers stated that additional meetings are held on-site with plant engineering. During interviews with both plant and pro-ject engineers, the team was informed that the communication inter-face has been improving between those organizations. As noted in a recent TS change request, it appears corporate engineers need to en-hance their knowledge of site specifics. The TS change request addressed an exemption only for one manual valve while other contain-ment isolation valves are needed to be open during power operation This information was apparently not factored into the licensee's submittal on which the NRC staff issued a license amendmen .11 Plant Design Change Requests A plant design change request (PDCR) is initiated to describe the engineering, design, procurement, quality assurance, construction monitoring and testing required for a facility modification. The inspector reviewed several PDCRs and found them to be consistent with the applicable procedural requirements. The PDCRs had received the appropriate levels of design review and independent design revie Interdisciplinary design reviews were provided where required. The design inputs were documented in the form of Regulatory Guides, national codes, drawings and calculations. Detailed pre-operational test plans were included to provide verification that the modifica-tions were satisfactorily installed. The PDCR m cess has recently been enhanced to provide a Plant Operations Review Committee (PORC)
review of the draft PDCR to provide additional time to assess and evaluate the proposed change. Plant engineering performs a group discipline review of PDCRs in lieu of assigning the task to a single engineer. A management tracking summary is available which can identify problem areas in the process of PDCR issuance which require additional resources. The current schedule for the 1987 outage PDCRs appear to provide sufficient time for plant staff review of the upcoming modification .12 Technical and Safety Review I The team reviewed several safety evaluations associated with plant i design change requests (PDCRs) and temporary plant modification These evaluations documented a verification that an unreviewed safety question did not exist. The engineering discipline safety evalua-tions were examined and the reactor engineering involvement in pro-i viding the integrated evaluation was reviewed by the team. The
! safety evaluations contained postulated failure mode evaluations as
- neces sa ry. The safety evaluations were found to be compreheoive and i
very detailed.
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7.13 Summary The engineering design output documents were found to be technically adequate. The informal plant engineering training program has contributed to a situation where engineering personnel were not cognizant of the administrative requirements regarding pre-use document verification. The retention of experienced plant engineers needs to be assessed to assure that sufficient personnel are avail-able to support the department's responsibilities. Engineering per-sonnel should preclude further instances of engineering directives not being adhered t While the PDCR process has been enhanced with respect to additional controls and reviews for future modifications, the expeditious closure of field completed PDCRs and pas needs to be implemented. Technical and safety review of modifications is considered a strength.
8.0 Training 8.1 Scope and Review In this area of inspection, observations were made of the knowledge and abilities of operators and various plant personnel as they per-formed their daily activities to evaluate the effectiveness of train-ing. In addition, observations of the performance of training classes and discussions with plant and training personnel were con-ducted to aid in the evaluation of trainin .2 Findings Throughout the inspection, the team determined that the operators were knowledgeable and capable of performing their duties by demon-strating an understanding of plant systems and operations. Obser-vations of various non-licensed personnel, as they performed their tasks, gave indication that they also were knowledgeable and capable of performing their assignments. No observations were made of plant personnel actions that were indicative of training deficiencie The licensee is presently engaged in attaining Institute of Nuclear Power Operations (INP0) accreditation for their training program The licensed operator training program is closest to accreditation by the INPO board. The non-licensed programs are to be accredited in less than a year. In the meantime, the programs are in a state of transition as efforts are being made to complete qualification cards and on-the-job training (0JT) program Plant personnel were interviewed to determine if the training they received was considered to be an aid in performing their specific job tasks. Licensed operators indicated that the classroom training was relevant and had many compliments regarding simulator trainin Non-licensed personnel spoke highly of the relatively new programs and said they were applicable to their job .
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An SRO upgrade class was audited. The instructor used a variety of media to aid the presentation. The instructor followed the class outline in addition to stimulating student thought by qulzzing stu-dents with hypothesized scenarios. There was healthy interaction between the instructor and students and the students had a high level of interest in the subject matter presented. A simulator session, scheduled later in the week would appear to reinforce classroom presentation Non-licensed training has recently (April-May 1986) started a con-tinuous training program that will be attended by both new trainees and presently qualified personnel. The continuous training begins with two weeks of administrative training (procedures, hold points, tagging, etc.) and then progresses through various hands-on training that cycles over an approximate two year period. Foremen have an ambivalent attitude towards training. They readily accept the benefit of better trained personnel but bemoan the task of scheduling work with selected personnel attending training in light of resource restraint The training department has a system in place to track changes in the plant (plant design change requests (PDCR), procedure changes, LERs, etc.) that may need to be incorporated into the training program Also, there is an engineer assigned to the training department who is responsible for following PDCRs from the corporate office and eval-uating any possible impact on training. There is also a system in place for individuals to request additional training that would be evaluated to determine if the request warrants attentio A few negative observations were made. The licensed operator candi-dates may not be fully aware of existing conditions in the plan For example, in regard to the static electricity problem that affects the nuclear instrumentation (NI) and radiation monitor (RM) panels in the control room, it is disturbing that a licensed operator candidate was touching the RM panel during his NRC plant walk-through examina-
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tion. Also, the auxiliary operator (AO) training program may have
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selected emergency conditions (reactor trip, steam generator tube rupture, and loss of all a.c. power). A writter, examination was re-l viewad and no questions were asked regarding one of the selected i emergencies and an interview with a qualified A0 indicated a weakness l in his knowledge regarding the same subject.
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8.3 Summary i Both licensed and non-licensed personnel thought that the quality of
the training they have received over the last several years has increased. This is due to the licensee striving towards INP0
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accreditation and the experience level of the instructors. Based on i observations of various activities and interviews with plant
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personnel, the trainir.g programs are satisfactory overall and should stabilize once INP0 accreditation is achieved. No significant training deficiencies were found except those noted in the technical support are Further, the licensee's training programs are in a state of transi-tion primarily in regards to INPO accreditation. Therefore, these programs are at varying degrees of depth and quality. The licensed operator training area is well established and it is considered a strength. To a lesser extent the nonlicensed operator and technician areas are improving but progress appears to be slow. There is positive feedback from workers in this area on recent training im-provements. At the other end of the scale, technical staff (engineer) training appears weak and it appears that it has affected past poor performance. Licensee plans to enhance technical staff training appear to be adequat .0 Assurance of Quality 9.1 Scope and Review In addition to management controls, the scope of inspection effort in this area included an overview of quality assurance (QA) and quality control (QC) involvement in daily plant activities to assess their overall effectiveness and the proper implementation of selected sections of the licensee's NRC-approved Quality Assurance Pla Discussions were held with the onsite QA supervisor, the corporate QA specialist, and other QA/QC personnel. Also, completed audits, surveillance, and monitors were reviewed in various areas and the findings were evaluated for significance and licensee management respons .2 Corporate QA The corporate QA specialist primarily coordinates and, in most in-stances, serves as the lead auditor for these audits performed under the cognizance of the Nuclear Review Board. The team reviewed 3 of the 10 audits completed thus far in 198 These 3 audits covered refueling activities, surveillance testing and maintenance activi-tie The team noted that the audits were relatively thorough and complete and that auditors have the necessary expertise for the audits assigned. As an example, Audit A60228 identified procedural deficiencies (clarity, content, etc.). Also, within this audit, the NRC team noted that similar deficiencies had been identified in previous audits conducted in 1981, 1983, and 1985. These findings coincided with similar findings by the NRC during this inspectio . . .- _ -
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1 9.3 Onsite QA/QC The QA/QC organization is represented on-site, thus enabling this independent group to actively monitor daily station activities. They routinely attend plant and departmental morning meetings to maintain an awareness of ongoing work activities and any changes thereof that may have occurre The QA/QC group performs inspections (QC hold points), monitors, and surveillances. Staffing levels presently include 2 individuals per-manently stationed at the warehouse to perform receipt inspections; 3 individuals, who perform QC inspections; 3 individuals, who perform monitoring and surveillance activities, and one superviso Increased emphasis has recently been placed on the conduct of QA activity surveillance Initially started in June of 1986, the formalization of this activity began officially in September 198 The surveillance program on plant activities encompasses the wit-nessing of any plant activity and the subsequent reporting of related observations to appropriate plant management. The actual conduct of the surveillance, identification of any problem areas, and resultant notification of responsible station management is expected. to take but a couple of days. Resolution of findings and subsequent correc-tive actions are also expected to have a quick turn-around tim Since activity surveillances do not have all the formalities normally associated with audits or monitors, management can quickly be apprised of quality-related problems or potential problems, and just as quickly institute corrective actio Areas to be surveilled are determined every six months, based upon the results of a review of the previous six months performance indicators. This would include but is not limited to a review of Plant Information Reports, Nonconformance Reports, Licensee Event
, Reports, NUSCO audit findings, and INPO finding Over 70 surveillances were noted as having been completed within the last 5 months. Management appears to be responsive to surveillance findings, however as noted previously, lack of procedural adherences and procedural inadequacies were frequently identifie Quality control personnel review all safety-related AWO's for identi-fication and approval of quality-related aspects prior to initiation
' of a work activity. QC inspection hold points are normally permanently incorporated into applicable procedures but may also be added during this pre-work revie The QC group also performs a final review of work packages upon completion of the work activity to verify completeness prior to forwarding to records for permanent storage. Detailed checklists are utilized during this review to ensure that all program and work activities have been completed as required. The inspectors noted, l
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however, that even with this final review, AWO packages still exhibit missing documentation, incorrect dates, and incomplete sections similar to that noted in the surveillance area (section 5).
Increased management attention in this area is neede .4 Facility Procedure Implementation The procedure adherence problem was identified in multiple functional areas. As noted in previous sections of the report, facility pro-cedures were not strictly followed in the following areas: house-keeping, fire protection, radiological controls, maintenance, and modification control. The team concluded that, while there was an overall respect as to the need for procedures, instances where procedures were not followed were too numerous and significant and reflective of an attitude of the worker This attitude appears to correlate to the experience level of individuals. The more experienced workers may think that they know how to perform the activities based on several procedure revisions past; and, accordingly, they may not refer to the current revision to assure compliance. Throughout the inspection, the team noted instances in which minor evolutions were conducted from memory with-out procedures at the work sit Licensee management needs to re-verse this potentially negative attitude with regard to the use of procedure .5 Facility Procedure Adequacy
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For the limited review conducted during the inspection, the team noted that, overall, procedures were adequate to carry out activities safely. However, minor problems were noted as follows: programs or sub-areas were not adequately defined or implementing procedures lacked detail (such as in the maintenance and radiological controls areas) or numerous procedures cover one programmatic topic (such as administrative control in the fire protection area); procedure format and content was inconsistent (plant operations and surveillance areas); and, procedures do not reflect current practice (radiological controls area). Additional details on these topics were addressed in previous sections of this repor Perhaps the most noteworthy team observation on the program / procedure adequacy problems was the extensive number of administrative control procedures (ACPs) which represented a lack of consolidation of station ACPs. Safety-related and nonsafety-related ACPs fill three relatively large notebook binders. As an example, eight ACP pro-cedures cover the fire protection program. Within this area, one ACP deals specifically with control of oil into the control roo This lack of consolidation dilutes the focus of managment policy and challenges the worker's ability to find the applicable directive This lack of consolidation could also be the source of inconsistency
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when several ACPs cover a special area such as control of combus-tiles. This also could be a source of a program inadequacy such as the team noted on the control of heavy equipment in safety related areas or in the freeze protection area. The clarity, consistency, and overall adequacy of ACPs should lead all department and facility procedure Compounding the procedure adequacy problem was the licensee's bien-nial review process. The methodology takes credit for a biennial review whenever a procedure is revised since the entire procedure is reviewed completely. Many departments have a substantial checklist of items to look for during the biennial revision. Therefore, a minor procedure enhancement / revision could be a burden with the biennial review process conducted concurrently. Considering schedule pressures and strained resources, the quality of the biennial review
upon procedure revision may be lacking. The licensee's computerized procedure tracking system appears to be effective in identifying procedures due for biennial review if they were not revised in the past two year Past license /NRC experience has identified strained
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resources and poor quality in the procedure revision process. In light of the above, the licensee should consider separating the bien-nial process from routine review process and enhance the quality of biennial review as a separate functio .6 Technical and Safety Review The team considered the technical and safety review in the modifica-tion control area to be a strength. This appears to be a direct result of licensee corrective actions for past problems in this area. This area could be enhanced with more site-specific knowledge at the corporate engineer level and better interfacing between site and corporate. The licensee is working at improving these aspect The technical and safety review of procedures is adequate. Weak-nesses in this area appear to be recognized by licensee management but progress appears to be slow in strengthening the area (see also paragraph 9.5). The observed PORC meeting reflected licensee corrective action to avoid detailed levels of review on procedure revision at the PORC meeting. However, procedure adequacy problems appear to be attributed to the individual or sub-committee quality of review indicating a lack of attention to detai Related to safety review of activities, there were signs of a lapse in supervisory questioning. Freeze protection problems and the ongoing 00S (3 day shifts) of the diesel-driven fire pump (a critical component because of its independence of a.c. power) were apparently unnoticed by supervision and management. This lapse of supervisory inquisitiveness on a routine occurrence led the team to believe that
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there appears to be less substantial involvement and attention on the part of supervision and management with respect to the safety sig-nificance of routine activitie .7 Corrective Action Numerous correctiv~e action systems are in place at the facility for the identification of problems along with appropriate root cause analysis and proposed corrective actions. Noteworthy are the non-conformance reports, trouble reports, plant information reports and the work order system. There also appears to be a review for the quality of resolution of outstanding issues by the QA/QC department and other corporate functions such as the Nuclear Review Board. How- !
ever the effectiveness of these reviews remain in questio A good number of programs or areas within programs are in a contin-ual state of transition. Some problems involve long-standing issues such as procedure adherence and procedure adequac Enhanced manage-ment attention is warranted to bring the programmatic upgrades to final resolution in a timely manner without straining existing resource .8 Summary The team's overall assessment of QA/QC activities indicates that this
, group is actively involved with plant activities. The QA/QC staffing
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is considered adequate, however increased emphasis in the surveill-ance area could present a strain on present resources. The quality l assurance program is well established and ambitiously supported by the corporate function.
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Management tends to be responsive to QA/QC identified concerns, however emphasis should continue to be placed on " attention to detail" concerns and procedure adequacy. Management control programs are adequate but they lack a consolidated view due to the large number of administrative control procedures. Several procedures are l adequate but inconsistencies and individual step inadequacies have been tolerate Certain procedures do not reflect current practices, which compounds
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the procedure adherence problem. There is an overall respect as to the need for procedures but nonadherances were noted across multiple functional areas. The experience level of individual workers appears to be a contributing factor on having adequate procedures and properly implementing the Many corrective action systems are in place and they appear to be effective in enhancing management awareness of plant problems. How-ever, quality effectiveness reviews of longstanding and open issues could be enhanced. Many programs continue to be in a state of tran-sition without near term and definitive resolution date . .
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10. Previous Inspection Items Because of the nature of this inspection, the team did not attempt to verify or document the closecut of previous inspection findings. During the course of the inspection it became evident that certain issues identi-fied in previous inspection reports needed to be readdressed and/or ex-panded in scope as noted belo .1 (Closed) NRC Bulletin No. 79-14 (213/79-BU-14): Freeze Protection /
Frozen Line The concern of this bulletin involves the potential for freezing of safety-related process, instrument and sampling lines. The licensee stated, in its response dated October 31, 1979, that ammeters which monitor heat tracing circuits are routinely checked by plant operator In addition, annual preventive maintenance is performed prior to each winter to verify that each circuit fulfills its design function The team reviewed the freeze protection preventive maintenance performed this year. In a number of cases where the circuits showed incorrect operation, corrective measures were taken at the time. The auxiliary operators continue to check heat tracing circuit on their rounds once per shif The team had no further questions on this specific issu However, it appears that the measures were not completely effectiv During the inspection, the team noted continued freezing / cold weather problems with safety-related equipment as noted in the previous report sections. The team concluded that the licensee met its commitments in this area. However, the team questioned the effect-iveness of the measures. (see section 4).
10.2 (0 pen) Unresolved Item (213/86-20-01): Adequacy of the Installation of Breathing Air Bottle in the Control Roo The bottles remained in the control room but are at a new locatio The bottles on a " dolly cart" are restrained from rolling but it did not appear that they were adequately restrained from overturning and becoming a missile hazard with respect to control room panel More significantly, the storage of heavy equipment that could become a missile hazard is poor throughout safety-related spaces. This is apparently due to a lack of policy in this area. This issue is ex-panded to include the adequacy of the anchorage and support of tran-sient equipment temporarily or permanently stored in safety-related area (See section 2 for details).
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10.3 (0 pen) Violation (213/86-20-02): Monthly Inspection of Portable Fire Extinguisher Additional examples of this apparent violation are described in Section .4 (0 pen) Unresolved Item (213/86-27-06): Operator Surveillance Missed Inoperable Lock on Safety Injection Valve An in-office review of License Event Report (LER) 86-042-00, Operator Surveillance Missed Inoperable Lock on Safety Injection SI Valve, was conducted. The event described in the LER was a licensee identi-fled violation, in that a valve required to be locked open according to the Technical Specifications was found unlocked . The details of the event were described in Inspection Report 50-213/86-27. The pur-pose of this review was to determine if reporting requirements were met, if the report was adequate to assess the event, if the cause was accurately reported, and if corrective actions appear adequate. The inspector found the LER met these requirements. Future inspection will review this area when corrective actions are complete 213/86-27-0 . Exit Interview The team discussed the inspection scope and findings with the licensee management at a final exit meeting conducted November 21, 1986. The inspection results as discussed at the meeting, are summarized in the cover page of this inspection repor Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable, violations, or deviation Unresolved items discussed during the exit meeting are addressed in para-graphs 2.7.3, 4.4.1, 5.2.1, and 1 .
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INSPECTION REPORT 50-213/86-29 ATTACHMENT 1 PERSONS CONTACTED The following is a list of key licensee supervisory or management personnel contacted during this inspection. There were other technical and administrative personnel who also were contacte R. Ashburner, Supervisor, Betterment Construction W. Bartron, Maintenance Supervisor J. Breauchamp, Quality Assurance Supervisor W. Becker, Supervisor, Generation Electrical Engineering D. Bement, Nuclear Records Supervisor G. Bouchard, Superintendent, Station Services i R. Brown, Operations Supervisor H. Clow, Supervisor, Health Physics B. Danielson, Instrument and Control Supervisor J. Drago, Assistant Engineer Supervisor (Reactor Engineer)
J. Ferguson, Unit Superintendent R. Graves, Station Superintendent G. Hallberg, Security Supervisor M. Kai, Supervisor, Transient Analysis P. L'Heureux, Assistant Engineer Supervisor (Mechanical)
B. Moyer, Stores Supervisor L. Nadeau, Manager, Generation Projects Connecticut Yankee B. Nevlos, Supervisor, Health Physics J. Opeka, Vice President, Generation M. Quinn, Supervisor, Chemistry ,
D. Ray, Engineering Supervisor P. Strickland, Supervisor, Technical Training
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INSPECTION REPORT 50-213/86-29 ATTACHMENT 2 DETAILED ACTIVITIES REVIEWED Portions of the'following activities were reviewed:
Operations-1 0bserved signoff for surveillance PMP 9.2-45, " Functional Verification of
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Automatic Initiation of Auxiliary Feedwater Solenoid Valves"
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Auxiliary Operator tagging verification for temporary modification 86-078 on
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the water treatment-syste '
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Observed electrical maintenance activities associates with work order
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CY-85-04060 for hi-pot testing of the MCC-11 transformer feede , _
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Observed dismantling and installation of new turbine building sprinkler system in accordance~with PDCR 86-84
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Performance of containment hatch leak test surveillance SUR-5.1-62 " Personnel
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Observed' shift supervisor plant walkdow y Surveillance' Tests - -
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SUR 5.3-40, " Core QPTR Determination," November 20, 1986;
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SUR 5.2-9, " Nuclear Instrument Power Range Bi-Monthly Test,"
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SUR 5.1-15,'" Fire Protection System Test," November 20, 1986;
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SUR 5.2-4, " Pressurizer Pressure Setpoint,"-November 20, 1986; l
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SUR 5.1-16, "EDG Check for Inleakage," November 17, 1986; and,
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SUR 5.1-17, "EDG Manual Starting and Loading Test," November 17, 1986;
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Maintenance Activities
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Preventive maintenance on the diesel-driven fire pump
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Heat trdcing repairs to screenhouse service water valves
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Preventive maintenance on 4160V/480V station service transformer
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Feedwater regulating pilot valve repairs Meetings
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Housekeeping and fire protection meeting en November 20, 1986
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PORC meetings on November 17 and 20, 198 morning meetings (Monday through Thursday)
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0800 first-line supervisors meeting (Monday through Thursday)
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Sixth 1987 refueling / maintenance outage meeting
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