IR 05000213/1988006
| ML20151X741 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 04/21/1988 |
| From: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151X735 | List: |
| References | |
| 50-213-88-06, 50-213-88-6, NUDOCS 8805040235 | |
| Download: ML20151X741 (32) | |
Text
. _ _ - - _ _ _ _
_ _ _ _
. _ _ _
.
.
.
,
,
.
.
'
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.:
50-213/88-06 Docket No.:
50-213 License Ne.: DPR-61 Licensee:
Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, CT 06101 Facility:
Haddam Neck-Plant, Haddam Neck, Connecticut Inspection at: Haddam Neck Plant Dates: March 7-11, 1988 Inspectors:
W. Baunack, Project Engineer, Region I (RI)
E. Conner, Project Engineer, RI R. Conte, Senior Resident Inspector (TMI), RI [ Reporting Inspector]
M. Chatterton, Engineer, Office of Nuclear Reactor Regulation J. Hunter, Reactor Engineer, RI S. Peleschak, Reactor Engineer, R1 M //6F Approved by:
-
e LT Bettenhausen, Chief, Projects Branch No. 1 Date Inspection-Summary: Operational safety assessmer.t team inspection of readiness for Cycle 15 startup, with a focus on assurance of readiness for mode changes leading to power operation. This was based on review of operations, modifications, pre-r operational /startup and low power physics tests, and equipment operability.
.'
Inspection Results: No violations or unsafe conditions were noted.
Individual departnents knew the standard prerequisites (such as surveillances) to applicable
. operational modes. They alco knew the non-standard work items, design changes, and software (procedural) items that needed to be completed. However, there was
,
a lack in formal correlation of non-standard items to operational modes, For ex-ample, the Automated Work Order System erroneously indicated numerous open items that appeared to affect mode changes.
-
The licensee's Plant Operations Review Committee (PORC) meeting on March 10, 1988 specifically addressed startup items requiring resolution.
The NRC inspection team identified no new technical issues beyond those already known by the licensee and discussed at this PORC meeting.
Inspection team members noted a substantial in-volvement by the quality services department (quality assurance) and the radio-logical-controls department in outage and recovery from outage activities along with the implementation of a number of good licensee initiatives to assure readi-l ness for startup.
The team noted persistent but non-safety-significant nonadherence to administrative control procedures. This raised a reservation about nonadherence carryover into operating, surveillance, and maintenance procedures. However, existing corrective action systems should identify such carryover before it becomes safety significant.
One unresolved item regarding effective implementation of a procedure was identified.
l The team concluded that there was reasonable assurance of readiness to proceed with I
appropriate mode changes to full power operation.
This assumes satisfactory com-pletion of the items outlined in the PORC meeting noted above.
,
$$f$$$$k$$0h3
.-,
. -
. - - - -
-- - -. -
- --
,
--,-
.-.
. - _..
.
,
.
.
.
.
m TABLE OF CONTENTS PAGE
- 1.
Introduction and Overview...........................................
2.
Plant Operations.....................................................
3.
Equipment Operability................................................
4.
Outage Modifications.................................................
5.
Testing..............................................................
5.1 Low Power Physics Testing...............
.....................
5.2 Preoperational/Startup Testing..................................
5.3 T e s t i n g S umma ry..............
.................................
6.
Assurance of Quality....................................
............
7.
Conclusion........
..................................................
8.
Exit Meeting.........................................................
i J
'
,.
.
.
..
.
.
.
.
";
.
DETAILS
1.
Introduction and Overview
~
1.1 Licensee. Activities-At the.. time of the team's entrance meeting on March 7,'1988, the licensee had completed a hydrostatic test of the reactor coolant system (RCS) in
,
Mode 4..However, they had returned to Mode 5 for' repairs because of small amounts of leakage at certain mechanical seals associated with the
'
RCS pressure test.
At-the entrance-meeting, licensee department supervisors summarized their status, addressed individual initiatives on their assurance of readiness for plant startup, and provided a "punch list" of major work items or surveillances required before entering the applicable modes for system t-operability. Throughout the remainder of the inspection period,. licensee activities centered around repairs _for retest.
By Thursday, the licensee recommenced heatup to Mode 4 for the RCS pressurization retest; but similar leakage was noted, necessitating cooldown to Mode 5 for repairs
,
at-the end of the inspection, March 11, 1988.
'
e 1.2 NRC Staff Activities The purpose of this team inspection was to independently review licensee f
recovery of the plant from the extended Cycle 15 outage. The general objectives were to:
i assess licensee readiness for mode changes leading to reactor
--
startup and power operations; l
.
assess the safety significance of events or current problems in
--
'
terms of preventability, adequacy of initial plant staff response and adequacy cf long term corrective actions; and, assess the adequacy of implementation of selected program elements
"
--
within the listed functional areas, t
.
The following functional areas were covered: plant operations; equipment operability, including corrective and preventive maintenance and post-j
maintenance testing; modification control; testing which included low
<
power physics testing; and preoperational/startup testing. Within each
!
s functional area the inspectors listed the general acceptance criteria i
j and scope of review, findings / conclusions, and an overall summary or t
assessment of the area.
,
1.3 Persons Contacted During this inspection, the following key licensee personnel provided substantial information in the development of the team's findings.
,
,
r i
...,,.--,_____.-.,__,..m_-,--._
-_.- _ ___.. _.._ ___..-___,,,.._. _..,,_ _
'
..
.
.
,
,
y.
...
2.
--
M. Baehr, Lead Planner
- J. Beaucamp, Supervisor, Plant. Quality Services
--
,
--
- G. Bouchard, Unit Superintendent
- B. Danielson,. Maintenance Supervisor
--
-- '
- E. Debarba, Station Services Superintendent
- E. Fries, Senior Engineer
--
'
- T. Galloway, Instrument and Controls Supervisor
--
D. Hefferman, Shift Supervisor
--
- P. L'Heureaux, Engineering Supervisor
--
- D. Miller, Station Superintendent
--
R. Morgan, Shift Supervisor
--
--
- D. Ray, Operations Supervisor
- J. Stanford, Assistant Engineer Superviscr (Reactor Engineering)
--
- Attended the exit meeting (see Section 8).
2.
Plant Operations-2.1 Criteria and Scope of Review References: '(1) NRC Inspection Procedure (NIP) No. 71707, Operational Safety Verification (2) NIP No. 42700, Plant Procedures (3) NIP No. 71711, Startup from Refueling The' team attempted to determine, from a plant operations viewpoint, if the facility (hardware and personnel) was ready for plant startup.
Using the above-noted references, the acceptance criteria for this review were selective sections of the general operating requirements of Technical Specification Section 6 and ANSI-18.7.
The following areas were reviewed:
'
Safety related areas for housekeeping, fire protection, and storage
--
of. transient equipment; Control room activities, including operator awareness of plant
--
.
status and design changes;
--
Procedure adherence and adequacy (limited review);
Valve lineup control; and,
'
--
--
Critical licensee self-review of procedural changes and identified actions, including PORC and other licensee management meetings for
'
L evidence of viable corrective action systems.
Also reviewed were selected sections of the documents listed in Attach-ment 1.
!
I
__ _ _
..
-
.
,
'l
- >
.
.
.
,
,
.
.
.
,
2.2 Findings / Conclusions
,
2.2.1 Building Spaces / Storage
,
'
Overall,. housekeeping.was quite good.
Licensee efforts for improvement ~in this area were noticeable, especially in the residual heat removal-(RHR) vault and in the containment.
However, out of way spaces had loose tools and equipment along
with residual dirt and. debris,,apparently from last minute work items. This was noticed in Containment (platforms near the reactor coolant pumps), in the RHR vault, and on the second floor of the primary auxiliary building (PAB).
.
Overall, storage of transient equipment was good.
However, improvements were needed on the second floor PAB and the diesel generator building, in that equipment on rollers was not sub-stantially restrained and/or was near safety-related eiuipment.
. A fire extinguisher in the RHR vault was past due (two months)
for its monthly inspection.
Licensee management reported that the maintenance individual assigned to do these checks relied on the auxiliary operator (AO) who routinely goes into the
'
vault to do them. Apparently, poor communications resulted
,
in the A0 net recording the chocks on the inspection card.
Licensee management reported that this was an unacceptable practice and, in the future, the maintenance individual will
'
don protective clothing, as required by Radiation Work Permit (RWP), and go into the RHR vault.
Also, in the RHR vault, the inspector noted an uncontrolled drawing (handwritten diagram of certain steam generator blow-down manifold valves).
Licensee management indicated the dia-
!
gram would be removed and that, if a need exists for such a
,
drawing, it would be properly controlled and posted.
The inspector had no additional comments in this area.
2.2.2 Control Room Activities i
.
Operators were knowledgeable of plant status including appro-priate mode restrictions.
They were also knowledgeable of najor modifications (design changes) to the plant.
Extensive
,
i training (classroom and mock-up) was conducted on major modi-fications, such as for the reactor protection system and for
the safety parameters display system.
,
!
In the plant spaces review and in the control room, operators
~
recorded information in pencil.
There were some erasures noted i
in the p'rimary auxiliary operators' narrative log. When ques-
!
tioned on the acceptability of this practice (instead of using
- -
.. - - - - - - - -
-.-
-
-
--.
..
-
-
-- --
.
.
"
.
.
.
,
,
'
>
f pen) and_on the erasures, licensee maragement indicated that the use of pencil was unacceptable and that the erasure prac-
,
tice'was going to be changed.
In the control room, proper procedure adherence was' noted as observed throughout the week and during the initial ~heatup to Mode 4 on March 10, 1988.
2.2.3 Valve Lineup Status Post-outage system valve lineups [except for certain portions of the safety injection (SI) system] were completed prior to team arrival.
During the spaces review, certain'SI. valves-(SI-V876A and B)
,
were noted to be unlocked.
The inspector attempted to estab-lish if existing controls for lo::ked valves were properly im-plemented. Since the plant was in Mode 5, the locked valve list was not applicable; therefore, no recording was needed for the selected unlocked SI valves.
Later in the week, during the heatup to Mode 4, the inspector verified that the subject
!
valves were restored to their proper locked positions.
Based on this limited review, the inspector identified no misposi-ti,oned valves for the applicabie operational mode.
The inspector noted that there was little independent verifi-cation imposed for verifying proper valve alignment coming out of the outage. Although the locked valve list appeared exten-sive (30 pages of a surveillance procedure), no independent verification (IV) measures were required to be invoked when a locked valve was restored to normal after repositioning.
,
Another surveillanca procedure provices for verifying lineup
>
of key valves when certain "high risk" maintenance procedures are conducted.
However, this surveillance is not required for recovery from an outage ur.less, during that recovery, the ap-
,
plicable maintenance procedures are used. Certain isolated
,
'
surveillance procedures, e.g., auxiliary feedwater, have veri-fication measures within the body of the procedure and these surveillances were apparently current for the applicable opera-tional mode. Overall, it appeared that the licensee was pro-perly implementing commitments made in the 1983-1984 time frame relative to TMI Task Action Plan (TAP) Item No. I.C.6.
However, if valve alignment problems arise during startups, additional IV measures may be warranted for recovery from outagos.
2.2.4 Read and Sign Review of Modifications
The inspector reviewed how the less significant (in scope)
modifications were handled with respect to dissemination of information to the operators.
The systems available were "Read
,
.
'
and Sign" and "Shift Turnover" notes.
The inspector noted these systems to'be in place and in use. The inspector also noted that the "Read and Sign" packages were somewhat outdated in that, on the average, one-half of the personnel listed had signed off for each of the packages issued in the first calen-dar quarter of 1988.
There were a few packages dating back to the last calendar quarter of 1987.
The inspector noted, however, a detailed accounting of record completion for these signed off packages.
'
The inspector reviewed the three books containing read and sign sheets for IE Bulletins and Information Notices (IN), industry.'
~
events, Plant Design Change Records (PDCRs), Abnormal Operating Procedures (AOPs), Normal Operating. Procedures (N0Ps), Emer-gency Operating Procedures (EOPs), fire protection, etc. The data collected is presented in Attachment 2.
There were many read and sign sheets with less than 60 percent signatures for the operations staff.
This condition was discussed with plant management at the exit meeting who committed to take corrective actions.
2.2.5 Corrective Actions
,
Viable systems exist in this functional area, and in others as well, with respect to the identification of problems /defi-ciencies for review and effective corrective action.
In one example to correct deficient plant labeling, the licensee pur-chased computerized equipment to improve the labeling of plant structures, systems, and components.
Labels were outstanding in that they were durable, relatively large, and easy to read.
This was a significant enhancement.
The trouble-reporting system is extensively used.
Plant equip-ment is labeled with an indication of the problem and the operations department uses a computer to correlate trouble re-ports to automated work orders.
Plant Information Reports (PIRs) are also extensively used as a corrective action mechanism, averaging 200-250 a year. Ob-sa e d Plant Operation Review Committee (PORC) review of PIRs u effective in identifying root causes and assuring effective corrective action.
For example, a PIR corrective action was challenged with respect to sufficiency and appropriately modi-fied.
Also, a noteworthy licensee initiative in February 1988 was the decision to use non-nuclear heat from auxiliary boilers to test secondary plant components to identify problems early on without the reactor critical. The licensee viewed this as a valuable endeavor, l-i
.
.
'
2.3 Plant Operations Summary In general, the containment and other auxiliary spaces were ready to support power operations. Additional attention was needed in certain areas for storage of transient equipment and on the cleanup of last minute work items. Control room activities were properly conducted and the operators were knowledgeable of plant status, mode restrictions, and major design changes.
Systems were ready for mode changes.
Equipment problems were identified as needing corrective action prior to the mode changes. A number of good licensee initiatives were noted: plant label-ing, trouble reporting, plant information reporting, and secondary plant testing.
3.
Equipment Operability 3.1 Criteria and Scope of Review References:
(1) NIP 62700, Maintenance Program Implementation (2) NIP 62702, Maintenance Program (3) NIP 62703, Monthly Maintenance Observation The inspector reviewed facility readiness for restart following the cur-rent outage from an equipment operability standpoint.
The major emphasis of this review was placed on maintenance.
The inspector also attempted to verify that all work required for restart had been completed or was scheduled to be completed and that work which had been performed was properly controlled.
Inspection criteria included:
--
Facility technical specifications;
--
American National Standard Institute (ANSI) Standard N-18.7;
--
Administrative Control Procedure (ACP) 1.2-5.1, "PMMS (Production Maintenance Management System) Trouble Reporting System and Auto-mated Work Order;"
--
Preventive Maintenance Program Procedure (PMP) 9.2-0; ACP 1.2-11.3, "Retest;" and,
--
In addition to discussions with personnel, the following were reviewed.
--
Production Maintenance Management System (PMMS) printouts; Followup on trouble reports and work orders currently active in the
--
plant;
.
.
.
_ _ _ _. -
-,
_
_
_ -
_
_
'
.
.
,
.
,
.
~
,
r
'
Refueling preventive maintenance'and surveillance schedules;
--
-
,
--
Relatddproceduresandcompletedworkorders(Attachment 1);and
'_0ther documentation' associated with work orders and retesting.
--
3.2 Findings and Conclusions
-
Corrective and preventive maintenance, modifications, and performance of surveillances are authorized, controlled, and. documented through the implementation of PMMS.
This computerized system has the capability to
'
generate many lists depending on the features on which a search is con-ducted.
The inspectors were provided with a list of active PMMS work orders scheduled to be performed during the 1987 refueling outage but not yet been completed, as well as work orders which are awaiting retest (post-maintenance testing) as of March 7, 1988.
This list made it appear
!
tha'. a large amount of work remained to be performed just-several days before scheduled plant startup.
Accordingly, this resulted in consider-able inspection attention to this area as described below.
3.2.1 Work Control Measures which related to the control of work and equipment
'
operability were reviewed as folle s.
A listing of trouble reports and work orders-currently active, which were identified during a plant tour, were tracked to the PMMS to ver'ify control of'the work. A total of eight trouble reports and four work orders were followed-up on.
In each
.
instance, they were easily tracked to the PMMS.
r The inspectors obtained a PMMS listing.of all mechanical and electrical refeeling PM_ work orders and verified by a review
!
of records and discussions with personnel that all scheduled
<
refueling PM's had been completed or were being tracked for completion when the necessary plant conditions were achieved.
The completed work orders identified in Attachment I were re-
'
viewed to verify control and documentation of work which had l
been performed.
The work orders were completed essentially l
in full compliance with ACP 1.2-5.1,"PMMS Trouble Reporting
!
System and Automated Work Order." The completed work order
>
packages contained supporting documentation essential to the verification of effective maintenance.
L l
This documentation included welder qualifications, weld history f
cards, fire watch verifications, welding procedure specifica-
,
tions, material issue lists, Plant Design Change Records, tem-i porary procedure changes, relief valve test data, etc. Good i
overall control of work appeared to have been exercised.
How-
"
,
>
- --
_. _ _ _ _ - _, _ _ _ -, _.. _. _.. -. _ - - _ _
.
.
. _ _ -
-
.
.
,
,
.
~
1 ever, certain documentation deficiencies,. identified by both the inspectors and licensee representatives,. indicated that
'
,
full compliance with the, Administrative Control Procedures (ACPs) is not being achieved. This finding was, discussed with Quality Services Department (QSD) personnel, who indicated.that they frequently identified the same deficiency.
Li kewi se, during the last team inspection (86-29), a deficiency dealing
-
<
,
with incomplete documentation of work orders was noted. Also,
'
the resident inspectors are tracking an unresolved item dealing with the same issue (85-21-10).
The performance of maintenance and the use of work orders was discussed in detail with shift supervision.
Shift personnel exhibited a good understanding of the system, which included tagging requirements, operations authorization to perform work, and the acceptance of the completed work by operations, as well as retest requirements.
3.2 2 Post-Maintenance Testing To gain an understanding of the actual status of maintenance and retesting which remained to be performed, detailed discus-sions and record reviews were held with Instrument and Control
,
(I&C), maintenance, and operations personnel, as well as con-trol room operators.
The results of these discussions and record reviews are sum-marized as follows.
The I&C Department had all the information immediately avail-
,
able relative to work orders for which they had responsibility.
All I&C preventive maintenance (PM) work orders and surveil-lance tests scheduled to be performed during the outage had been completed with the exception of those which require specific plant conditions.
Each of those requiring plant conditions was clearly identified.
The Maintenance Department, in conjunction with operations, had reviewed all open Maintenance Department related work or-ders (approximately 180) and determined that all work orders required to be completed prior to restart had been completed.
For practical reasons, several work orders were still scheduled to be performed during the outage.
During the outage, the Operations Department took a shift supervisor off watch and made him responsible for tracking work orders and surveillance testing. Operations personnel,
.
in conjunction with maintenance personnel, have also reviewed PMMS lists and determined that all operations work orders re-quired for restart were completed.
The Operations Department
._
E
-
+
-
.
.,
'
,
~
maintains an extensive list of work orders which.have had all-work associated with them completed, but which are still con--
sidered to be open because, when the.necessary plant conditions are achieved, they are required to be retested (post-mainten-ance testing). These work orders are listed by system-and each has the. required retest-identified.
For many,:the retest con-sists only of a visual inspection of systems at operating pressures.
The Operations Department also maintains a list of all required surveillances.
This list indicated that all required surveil-lance testing had been compl.eted with the exception of six which are awaiting specific plant conditions.
During the above discussions with personnel, most individuals inspectors talked to indicated there were certain problems with the PMMS. Management indicated there is an initiative underway to improve the system, particularly in the coordination between i
operations and maintenance.
3.2.3 Initiatives
-
Other actions taken by the licensee to assure equipment readi-l ness for operation were also noted.
These measures included the test operation of all safety-related pumps and various
>
other pumps, both as part of surveillance testing and in addi-tion to that required by surveillance testing. Many plant
,
valves have also been cycled again as part of surveillance testing and also in addition to that required by surveillance testing. A review of outage startup problems and delays ex-perienced in 1983, 1984, and 1986 was also conducted to assist i
in avoiding similar problems during this startup.
.
3.3 Equipment Operability Summary All work required to be completed prior to startup was completed except for existing plant problems and, where necessary, was scheduled to be s
. retested when appropriate plant conditions were achieved. The computer-ized AWO tracking system erroneously indicated substantial outstanding work.
Work performed was properly controlled in accordance with ACP's, except
[
for certain documentation requirements associated with completed work orders.
This deficiency was previously noted.
l
'
L
!
t
-
,,--,n.e,
.- -
en,
- - - -,
,, - - - ~ - -, - - - -
,
.,,.-------,-,.rm
,v e w w,,
,,---,~.--.en--,,
-, --,--w,~~
.
.
-
.
.
-
_..
.
.
,
,
.
~
.
I All preventive maintenance scheduled for refueling was completed and, where necessary, is being tracked for retest when-the necessary plant conditions are achieved. The operators had a good understanding of the
-
control of maintenance, a
The licensee has taken steps to assure equipment operability when it is
' +
required.
)
4.
Outage Modifications
'
References:
NIP 37702, "Design Change and Modifications Program" At the start of this review, the inspector was given lists of the modifica-tions being made during the outage under the Plant Design Change Record (PDCR)
system. As of March 7, 1988, forty-four modifications were on the "Installa-tions" list (those released to operations) and twenty-eight modifications on
the "Installation Not Complete" list.
The inspector discussed the modifica-l tions related to NRC requirements with the engineering supervisor. Of the
!'
seventy-two modifications being made, twenty-seven of which dealt with 10 CFR
'
50 Appendix R, Environmental Qualification, the Systematic Evaluation Program, IE Bulletins / Notices, Inservice Inspection, Security, NUREG 0737, 10 CFR 50 Appendix K, Probabilistic Risk Assessment (PRA),10 CFR 50 Appendix A General Design Criteria No. 1, and Emergency Planning.
The inspector chose the following four modifications to review in detail.
l
.
POCR-860 - New Safety Parameters Display System (SPDS) Signals
!
--
PDCR-861 - Modernization of the Reactor Protection and Control System
--
PDCh-921 - Loose Parts Monitoring System (LPMS)
i
'
--
PDCR-929 - Internals Vibration Monitoring System (IVMS)
--
>
!
PDCR-860 was needed to complete the SPDS as required by Item I.D.2 of NUREG
'
0737.
PDCR-861 was a licensee initiative to upgrade the Reactor Protection System (RPS) and various control systems due to the age of the instrumentation i
and the difficulty in obtaining repair components.
PDCR-921 and PDCR-929 were
!
licensee initiatives to detect and evaluate loose parts in the reactor vessel s
and increased vibration of the thermal shield.
LPMS and IVMS were presented l
"
to the NRC in a meeting on December 1, 1987.
4.1 Criteria / Scope of Review The criteria used to evaluate the quality of the modifications process
,
at Haddam Neck was: ANSI N-45.2.11-1914, "Quality Assurance Requirements e
,
for the Design of Nuclear Power Plants.
-
[
>
<
t
_ _., _,, _ _,. -. _ _... _,,, _ _ _ _ _ _ _ _ _,,., _..
___.,._,,,__,-m__,,
-m_,.._.-,_....
. _.., _ _.,
. _ _. ~. - - _ _ _ _.. _... ~. _,
_
m
-
'
-
.
.
.
'
The inspection involved interviews with the engineering, operations, I&C, maintenance, and training staffs;' review of PDCR and related documenta-tion for each~ modification; and, visual observation of the new/ modified equipment.
4.2 Findings / Conclusions Using the criteria described above, the inspector evaluated the modifi-cation process under four categories: (1) process control; (2) safety assessment; (3) information dissemination; and (4) process management.
Because of the importance of performance testing after modifications are made, all testing is evaluated in Section 5.
4.2.1 Process Control The modification process is controlled by Nuclear Engineering and Operations (NE0) Procedure 3.03, "Plant Design Change Re-cord (PDCR)." -This procedure provides the structure for per-forming the engineering analyses, including safety evaluations, and obtaining management approval, including that of the Plant Operations Review Committee (PORC), to make the proposed modi-fication. A simplified process, the Plant Design Change Record Evaluation (PDCE), has been adopted for minor changes where an engineering evaluation shows no safety or other' requirements are affected. A Northeast Utilities Service Company (NUSCO)
project engineer and a Connecticut Yankee Atomic Power Company (CYAPCO) plant engineer are responsible for each PDCR.
Approved PDCRs are implemented utilizing the Automated Work Order (AW0) system controlled by ACP 1.2-5.1, "PMMS Trouble Reporting System and Automated Work Order." AW0s are entered into the computerized system by the plant engineers or I&C maintenance planners.
Usually, each AWO is for a particular part of the modification.
For example, 207 AW0s have been issued to implement PDCR 861 (RPS). During the inspection, all but four of the AW0s dealing with work on two instrument transmitters and testing of a pres-sure controller were closed out.
The other three PDCRs being reviewed required relatively few (less than nine) AW0s.
Use of the computerized system allows the plant staff to find all AW0s related to a particular PDCR and the status of each AWO.
PDCRs can be modified using a Design Change Notice (OCN). DCNs must readdress safety issues and require another PORC review and approval.
PDCR 861 (RPS) had a total of thirty-two DCNs, including replacement of unacceptable instrumentation, minor modifications for mounting equipment, wiring corrections, etc.
One set of DCNs was identified as a controversy by the oper-ating staff interviewed by the inspector. OCN 400-87 added
__
_ _ _ _ _
-
.
,
.
.
+
a direct source of backup d.c. power to the RPS and control.
. systems in the event of 125 VAC. vital inverter output failure.
This backup power source was available for the old.RPS supply.
DCN 576-87 removed the battery backup power due to an opera-tions problem during-the initial powering of the vital d.c.
buses. The operating staff wanted a backup power supply. Al-though DCN 576-87 removes the backup modules and the under-voltage relays, the cables used for backup were left so that, if future plant modifications provide a better regulated 120 volt AC source, the battery modification can be installed.
All inspector questions were acceptably answered by the plant staff.
4.2.2 Safety Assessments Each of the four PDCR packages reviewed contained safety evaluations (SEs) from the responsible lead and support dis-
-
ciplines.
For example, PDCR 921 (LPMS) package had an elec-
-
trical SE for the overall modification and a mechanical SE for the installation of accelerometer holding brackets, penetra-tions, and cabinets. Other reviews required were security,
>
fire protection, ALARA (as low as reasonably achievable),
,
seismic, and training.
Environmental qualification (EQ), in-
,
service inspection (ISI), and radiological and non-radiological l
environmental reviews were not required for PDCR 921. The reason for selecting the SEs and design evaluations were pro-vided in a design review section in accordance with NEO 3.03.
The inspector reviewed the SEs, the design evaluations, and the design-reviews for each of the four.PDCRs.
For PDCR 861 (RPS) and PDCR 921 (IVMS), early SEs marked up with comments from the plant staff were available for inspector review.
In both cases, significant technical comments were provided to
,
the responsible NVSCO engineer.
Discussions with plant engi-neering resolved inspector questions on the four modifications reviewed.
I 4.2.3 Information Dissemination
,
As the AW0s for each PDCR are being completed, the procedure changes, staff training, and drawing changes necessary to com-L plete the POCR should be in process. NUSCO's method of per-forming each is as follows.
,
n--- - - - - - - -,. - -, - -., - - _, - - - - - - - ---. - - - - -. - - - _ _ _ - - - - - - -, - - - - - _ _ - - - - - _ -. - - _. - - - - - - _ _ _ _ -. -.. - - - - - - - - - - - - - - - - -. - - -. - - -
- - - - - - - - -. - - - - - - - - - - - - _ - - _ - _. - - - - - - - - - - - - - - - - - - - - - - - -, - - - - - - - - - - -
m q"
,
.
.
.
-
.
.
-
.
13.
4.2.3.1 Procedure Changes
,
The plant engineer assigned to each PDCR works with the group supervisors (operations,'I&C, maintenance, etc.) to identify all ' procedures.affected by the proposed modification. The listing of these proce-dures is included in the PDCR package.
The inspector reviewed. changes to the I&C preventive maintenance procedures (PMPs), surveillance proce-dures (SPs), OPS normal operating procedures (N0Ps),
and annunciator procedures (ANNs) for PDCR 860 (SPDS)
and 861 (RPS).
The revised I&C procedures were of notable high quality, using numerous scale drawings-(computer generated) in the body of the procedures.
One problem with the engineering memorandum to OPS regarding completion of procedure revisions was noted.
Although the March 1, 1988 PDCR 861 partial release for operations memorandum from engineering' stated,
"station procedure revisions required as a result of this modification are complete," the OPS procedure revisions for PDCR 861 were not signed by the OPS department head.
The responsible plant engineer said he had been involved with the OPS procedures and was sure they had been completed. He provided a re-placement sheet signed by OPS prior to the exit meeting.
4.2.3.2 Staff Training Because of the large number of modifications planned for the 1987 outage, much of the PDCR training was completed prior to reactor shutdown. This was the case for PDCR 860 (SPDS) and PDCR 861 (RPS). The I&C technicians received their training between February and July 1987.
The operations staff had their training between July and October 1987.
One of the training initiatives was the use of a hy-draulic model of the reactor coolant system to teach f
pressurizer level, pressure control, and other vari-able response to control changes.
The operators
praised the use of this model, saying it was avail-able (on site, and in the control room part of the time) and helpful in understanding control principles.
'
Training for PDCR 921 (LPMS) and PDCR 929 (IVMS) was in progress at the time of the inspection.
Five of the six shifts (including control operators and supervisors and auxiliary operators) had been trained
'
. _ _. _ - - _ - - _ _ - _
__ _
-
-
.
,
.
.
.
.
and the last shift was scheduled for the week after the inspection.
The training for these last two
'
PDCRs was or was scheduled to be covered in requali-fication training by short lectures since the LPMS and IVMS have no direct control room-indications or alarms. The data for both systems will be analyzed by the NUSCO Engineering Mechanics Group.
The inspector reviewed the training requirements and training records and interviewed control room per-sonnel regarding the four PDCRs. Except for the control room operator who had not completed his re-qualification training, the personnel were knowledge-able about the modifications.
Of special note was
'
their ability to use the new SPDS computer functions for any system selected by the inspector.
4.2.3.3 Drawing Revisions
^
The assigned plant engineer is responsible to update
~
the OPS critical drawings by hand and to provide the
-
needed information (marked up prints) via a NUSCO 1'
Drawing Change / Submittal Request to NUSCO engineering.
OPS critical drawings are to be revised and available-within seven working days.
Other drawings are to
,
be revised within ninety days.
'
The inspector reviewed the OPS critical drawings that
!
were to be changed by the four PDCRs being reviewed.
L
'
Both marked up drawings and officially revised draw-ings were found appropriately changed.
The other
system drawings have been requested but not returned from NUSCO (expected turnover is ninety days from request).
4.2.3.4 Record Handling and Quality Involvement
.:
The official PDCR packages are to contain the origi-
!
nals of signed pages, both approvals and data / work
!
records. This is accomplished by keeping the offi-
cial PDCR with the work being performed. The in-spector was concerned that there was no apparent Quality Control (QC) requirement in the PDCR process.
i The licensee responded that Quality Services Depart-ment (QSD) hold points are written into the AWO pro-cess and QSD reviews all AWO packages prior to close-out.
These attributes were selectively verified by the inspector.
The QSD supervisor added that most
h
!
.
.
-.
.
.
-
-
.
'
.
.
.
a.<
.
.
AW0s ready for closecut have QSD items that must be'
corrected prior to his approval.
This resolved the inspector's concern on QSD involvement.
QSD inspectors prepare Nonconformance Reports-(NCRs)
when problems are found during performance of work
+
under an AWO.
The inspector reviewed a number of.
NCRs related.to the four PDCRs.
In one case involy-ing the material traceability of seven cables for the IVMS (NCR 88-030), the first disposition finding of no physical difference between Quality Assurance (QA) and non-QA cable of this type had been changed by the responsible plant engineer. His disposition was to provide a material transfer form ~for trace-ability.
This type of engineering support is viewed as a positive initiative by the team.
4.2.4 Process Management
~
On July 17, 1987, CYAPC0 adopted ACP 1.2-3.2 "Administration of PDCR Turnover and Preoperational Testing." The stated ob-jective of this procedure is to provide guidance for the ad-
,
ministration and implementation of the process controlling turnover and testing of plant design modifications installed
under the PDCR process.
The procedure delegates responsibili-ties, equipment walkdowns, construction turnover, use of Modi-fication Completion Reports (MCRs), partial turnovers (for testing), test administration, DCN processing, and engineering release to operations.
The implementation of ACP 1.2-3.2, as it relates to all aspects of testing, is covered in Section
5 of this report.
The inspector reviewed Partial Releases for Operations for PDCR
861 (RPS) and PDCR 929 (IVMS) and Releases for PDCR 860 (SPDS)
and PDCR 929 (IVMS). PDCR 921 (LLPMS) had not been released
,
to operations at the time of the inspection.
In addition to the procedure revision problem addressed in paragraph 4.2.3.1, the inspector identified several problems with the MCRs.
The MCR is a controlled listing of deficiencies and/or items as-sociated with a PDCR. Although the '! Item Closure Acceptance By/Date" column for the MCR in the PDCR 861 Partial Release
was signed of f, an AWO number and Controlled Routing (CR) num-ber were missing. On the MCR for Partial Release of PDCR 929, six deficiencies had no data in the "Required Completion Date,"
"Corrective Action Completion Date/ Document," and "Item Closure Acceptance By/Date" columns. The responsible plant engineers
.
got these MCRs updated and gave copies of the MCR forms to the inspector.
This is not considered a serious problem, but the inspector emphasized the need for management attention to de-tail in this matter.
i
.
-
'
'
'
-
,,
,
~
PDRCs remain. active until all issues are closed, including pro-cedure and drawing changes. The plant department head docu-ments completion of procedure revisions _and the responsible engineer and his management assures all drawings affected by the modifications are reviewed correctly. The PDCR' originals
'
are kept in a fireproof safe in the plant engineering super-visor's office when they are not actively being used. Com-pleted PDCRs receive PORC/SORC (Plant;0perations Review Com-mittee/ Site Operations Review Committee) review if there are any changes from the pre-modification PDCR.
The PDCR is then released to operations, signed by the engineering supervisor, and sent to nuclear records.
The inspector had no further questions on PDCR process manage-ment.
However, no review of completed PDCRs was performed since the four modifications being reviewed had open PDCR actions.
4.3 Modification Summary The modification control program appears to be well establi:;hed.
In
-
general, proper implementation was noted.
There was a good correlation between PDCRs and related AW0s using the licensee's computerized system.
However, AWO completion status was unclear as noted in Sectien 3.
Train-ing for modifications appeared to be substantial. Minor administrative
'
errors were noted as a result of modification in the areas of procedure issuance / revision, "Read and Sign" program for lesser significance in scope modifications, and modification completion reports.
Safety evaluations were thorough in that they addressed the safety and
,
regulatory aspects of multiple functional areas associated with any par-ticular modification.
Plant staff reviews of these evaluations were substantially critical resulting in revised evaluation is some cases.
,
5.
Testing
5.1 Low Power Physics Testing
'
5.1.1 Criteria and Scope of Review References:
(1) NIP 61702
"Surveillance of Core Power Dis-tribution Limits"
.
(2) NIP 61705
"Incore/Excore Detector Calibra-tion" (3) NIP 61707
"Determination of Reactor Shut-down Margin" (4) NIP 61708
"Isothermal Temperature Coeffi-cient of Reactivity Measurement" (5) NIP 61710
"Control Rod Worth Measurement"
,
___
S? ;
.
,
.
,
'.
-
,
i The criteria used to _ evaluate.the low power physics: test pro-
'
gram were TS 3.10, 3.24.1-3, and 3.17.
- The' assessment consisted of a-review of low power physics test-
' procedures and interviews of' cognizant engineers.
5.1.2 Findings / Conclusions 5.1.2.1 General Initiatives The revision and improvement of test procedures for this cycle were extensive.
Some of.these were a result of TS updates. - A rod drop test immediately after initial criticality was added because of a new requirement in the Physics Test Exemption. The rod
,
coupling check test initiated in Cycle 13 provides reactivity verification of all rods.
5.1.2.2 Cycle 15 Physics Startup Tests In general, the physics test programs consist of standard tests done in a manner consistent with in-dustrial practice. The procedures for these tests
'
have been updated to include revised predictions from the Nuclear Design Report and changes to the Techni-cal Specifications. The procedures are detailed and include an alternative method if the Process Computer is not available. Detailed procedures for correc-tions to be applied to measured data are included.
Acceptance criteria for each test are included.
All acceptance criteria must be met in order to re-
'
lease the plant to operations; however, no remedial actions in case of failure are specified. Discus-sions with key personnel indicate that a complete review, evaluation, and resolution would be under-
,
taken in such a case.
-
A major change in this refueling outage was the re-placement of all control rods (both control and shutdown). While the new control rods are similar to the old ones, there were several design changes:
Cladding material is Inconel 625 versus stain-
--
less steel 304;
Diameter of the absorber material is 5 mils
--
.
smaller in the lower twelve inches of the rod;
,
.
.
-
_
_,
. _ _
,
._
,
.
.
.
,
s
.
..
-18-One piece hub construction; and,
--
~ Higher. internal pressure.
--
Nuclear analysis of the design changes indicated th'at the changes had an insignificant effect on rod worth-and power distribution.
,
A control rod coupling check test will verify that each rod is coupled and does insert negative.reac-tivity into the core. While this test is very valu-able, it does not give any information)about the reactivity worth of the rod banks.. As in previous cycles, only three of the.four control rod banks will be measured during startup tests and the usual ac-ceptance criteria will be used.
Review criteria, somewhat tighter than the acceptance criteria, would have been appropriate, especially since all the control rods were replaced and the nuclear analysis for Cycle 15 was performed by NUSCO for the first time.
The licensee indicated that prediction.to measurement deviations greater than in previous cycles would be investigated. However, no time limit for this investigation or conclusion is specified.
A potential problem is the-loss of a third incore
. thimble. With this loss, only one set of quadrant symmetric incore thimbles is available. With the currently available thimbles, all present technical specifications can be met.
However, loss of any one of several other thimbles will force power reduction or shutdown to meet TS.
5.2 Preoperational/Startup Testing 5.2.1 Criteria / Scope of Review Reference: NIP No. 72701, Modification Testing.
Basic requirements and guidelines for modification testing are described in:
10 CFR Appendix B, Criterion XI;
--
Regulatory Guide (RG) 1.68, Revision 2, "Initial Test
--
Progress for Water Cooled Nuclear Power Plants;"
RG 1.33, Revision 2, "Quality Assurance Program Require-
--
ments;"
t
,
-
.
.
,
,
'
.
'19
>
.
--
RG~1.116, Revision 0-R, "Quality Assurance Requirements.
^for Installation Inspection and Testing of Mechanical
,
Equipment and Systems;"
,
ANSI N18.7-1976,."Administrative Controls and Quality
--
Assurance for the Operational Phase of Nuclear Power
.:
Plants" and,
[
ANSI N45.2.8-1975, "Supplementary Quality Assurance Re-
--
)
quirements for Installation, Inspection, and Testing of Mechanical Equipment and systems for the Construction
!
Phase of Nuclear Power Plants."
'
The requirements and guidelines found in the reference n
documents listed above are implemented through the licen-see's administrative and department level procedures.
~
The inspector reviewed the following procedures and de-
termined that adequate controls over'the modification
>
testing program had been established.
i f
NEO 3.03, Revision 6, dated November 21, 1986, "Prepara-
--
tion, Review, and Disposition of Plant Design Change
-!
Records (PDCRs);
ACP 1.2-3.2, Revision 1, dated October 27, 1987, "Admini-
--
,
t stration of PDCR Turnover and Preoperational Testing;"
ACP 1.2-6.4, Revision 20, dated April 28,1987, "Temporary
--
Procedure Change;" and,
ACP 1.2-6.5, Revision 21, dated September 22, 1987.
.
--
t
.
5.2.2 Findings / Conclusions
,
The inspector reviewed the PDCR associated test procedures
listed in Attachment 2 and determined the following (except
-
for those specific items discussed below):
Testing was conducted using approved procedures developed I
--
>
in accordance with licensee requirements;
'
Pretest briefings were conducted to ensure proper test
,
--
,
'
performance and operation of the equipment; Test procedures and changes were reviewed and approved
--
in accordance with the technical specifications and pro-cedural requirements; f
l
,
?
L
- i
[
!
!
!
.
-
.
- - --
-
.
.:
. _ _____ -.
_ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _.
__ _____.._ ___ -_- ____-_ - _ -.
__
_ _ _.
-
..
,
.
.
,,
.
The review and evaluation of test results were a'dequate
~
--
to determine that acceptance criteria were met;
.
Test-deviations were adequately dispositioned;
--
-
lA/QC were involved in the process; and,
--
The tests performed adequately demonstrated operability.
--
Based on the above review and discussions with cognizant per-sonnel, the inspector determined the following.
5.2.2.1 General The licensee, just prior to the past outage, imple-mented ACP 1.2-3.2, "Administration of PDCR Turnover and Preoperational Testing." The procedure provides guidance for the administration and implementation of the turnover and test processes of modifications installed using the PDCR process.
,
ACF 1.2-3.2 established formal guidance and controls over the testing required to ensure that modifica-tions perform as designed.
The procedure outlines test procedure format requirements, test procedure preparation guidelines, component. level inspection U
and testing requirements, test procedure review and
'
approval of requirements, and test procedure per-formance and evaluation requirements.
ACP 1.2-3.2 also outlined the method of turnover to be used to ensure that all items associated with modifications are completed prior to closing out the PDCRs.
During the turnover process, the resoonsible engineer lists all open items on a MCR and ensures that they are completed prior to closing out the PDCR.
,
The engineering supervisor also utilizes a monthly status report of open PDORs to ensure that all items are addressed.
The licensee also has formal proce-dural controls to ensure that long-term items are
-
!
tracked and closed after the PDCRs are closed out.
The "Controlled Routing" system is used to provide the documented means of assignment, followup, and
>
closecut of the long-term MCR items.
The licensee's initiatives in establishing formal L
guidance and control over the testing and turnover processes and in ensuring that all open items as-
!
sociated with the PDCRs are tracked and closed out
,
-
_ _..- _-
_.
- - - _
.
.
.
.,
'
>
.
'
.
21 ~
are indicative of management's involvement in estab-11shing a quality modification 1 testing and turnover
.
program.
5.2.2.2 Quality of Work While reviewing the test procedures, the inspector-
'
noted that there were many different copies of the MCR in_certain test. packages. The inspector raised a concern with the engineering supervisor regarding the location and control of the most up-to-date MCR.
c!
Subsequent to discussions with the inspector, the
'
engineering supervisor committed to evaluate ACP 1.2-3.2 to incorporate procedural controls over the storage of the.most up-to-date working copy of the MCR.
The inspector had no further questions.
,
l The inspector identified a concern involving the'im-i
<
piementation of the administrative requirements-l specified in ACP 1.2-3.2.
Various examples of the requirements of ACP 1.2-3.2 not being implemented
!
are discussed below.
-
The procedure review sheets (ACP 1.2-3.2, Sec-
--
,
tion 6.2.4), for documenting reviewer comments -
were not used for Test Procedure SPL 10.7-288.
- The reviews were performed and comments were i
written on the draft procedure.
The reviewer
coments were then dispositioned and the re-i viewers signed the procedure cover sheet upon
,
issuance.
The inspector determined that the
review sheets were used for the other test pro-cedures reviewed. The failure to use the review j
sheets in accordance with ACP 1.2-3.2 is con-
,
sidered to be an isolated case.
- ACP 1,2-3.2, Section 6.2.6, requires that all
--
,
applicable data sheets should be clearly iden-
!
tified as to applicable component / step number and attached to the preoperational test proce-i dure whenever department level procedures arc'
i invoked by reference in the preoperational test
!
procedure. Although the data could be retrieved
through the associated referenced back order
numbers, the responsible engineers failed to
enclose the completed data sheets for the de-i partment level procedure invoked by reference in test procedures SPL 10.7-285 SPL 10.7-288, SPL 10.7-304, and SPL 10.7-308.
Upon discussion r
with six engineers and the mechanical and elec-
!
,
_
.--.
.--- _._-_.
'
-
.
%.
r'
trical ' engineering supervisors, the inspector determined that none of the. engineers inter-l viewed were aware of the requirement to' attach-the data sheets from those department level procedures used to conduct modification testing to the preoperational test procedures.
ACP 1.2-3.2, Section 6.2.4, requires that all
--
reviewer comments be recorded on the Preopera-~
.
tional Test Procedure Review form, which becomes
!
part of the official documentation file for the test procedure. The inspector determ.ined that one engineer was not aware of the requirement to include the review forms in the official i
documentation file for the procedure.
The en-
gineer. stated that he utilized the forms and
'
was keeping them in a separate file; however,
,
the file had inadvertently been thrown out.
>
ACP 1.2-3.2, Section 6.2.11, states that all
--
tests are evaluated by a minimum of two indivi-
,
duals, one of whom is the project engineer.
!
The procedure also states that the evaluation should determine whether test results are ac-
-
ceptable and that the evaluator would sign the
Preoperational Test Procedure Cover Sheet when he/she is satisfied that the acceptance criteria have been met.
Sir.*e the data sheets from the
'
testing performed us*ng department level proce-i dures are not being attached to the preopera-
-
tional test procedure, it is not apparent that the test results of the department level proce-I dures were reviewed by the two evaluators who i
signed off that the evalution was completed.
!
The inspector determined through discussions
,
with the engineers that some did review the data
,
while others did not.
The engineers who were interviewed stated that ACP 1.2-3.2 was too verbose and hard to understand that i
many of the requirements were buried in large para-
graphs. Although the procedure showed the licensee's initiative to establish controls and guidance for modification turnover and testing, its structure
!
contributec to the aforementioned problems.
The licensee informed the inspector that the procedure
,
was being revised in a more streamlined Northeast Utilities procedure including the procedural steps and appending the general philosoph..w
'
-
-
.
,
,
.
.
The identified problems are.of an administrative g
nature in that the ACP was not implemented as it was written and required immediate attention.
The in-spector determined, however, that the test perform-ance and results evaluation appeared adequate.
The inspector informed licensee management that' the en-t gineers could provide information regarding the re-quirements of ACP 1.2-3.2 and their understanding of the proper method of implementation.
Subsequent to the discussions held with licensee management, the station superintendent committed to evaluate by July 1,1988, the use of ACP 1.2-3.2 at Connecticut
.
fankee and to ensure that new Northeast Utilities procedural requirements are understood and imple-mented.
This item remains unresolved pending the
,
resolution of the identified implementation problems
!
and the establishment and implementation of the new
Northeast Utilities procedure (213/88-06-01).
5.2.2.3 Quality Services Department Involvement
!
The Quality Services Department is actively involved l
in the testing phase of the modification process.
i QSD personnel, when requested by the respontible en-i gineer, perform technical reviews of the draft test
!
procedures. QSD also reviews the Automated Work l
Order (AWO) packages prior to use. All testing is
[
conducted under the control of the AWO.
Therefore,
[
QSO personnel review all safety-related test packages (
prior to implementation.
Their personnel, upon com-
pletion of the installation inspection, write a j
. memorandum stating that all Nonconformance Reports
!
(NCRs) have been dispositioned or are being tracked
and that all inspections have been performed.
They
also include a list of all risk released material not yet cleared through the disposition of the NCR.
,
The QSD memorandum must be completed prior to turning the system over for testing.
The test procedures
also contain various QSD witness points and the test
.
packages (AW0s) also receive a final QSD review for completeness.
!
The licensee's use of the AWO process to accomplish
,
the testing of modifications ensures that QSD per-sonnel adequately review the test packages prior te,
!
during, and after test performance.
{
l i
T
!
i
!
!
- - - -. -
_ _ _.
___
__-_ ____ __- ___ - __ _ _ _ ___ _
.
.
.
,
.
,
- ~
+
5.2.2.4
' Training Training was conducted on the requirements of ACP 1.2-3.2 by the training department on July 16, 1987,_
'
one day before the procedure was in effect..The
-
aforementioned problems regarding the implementation of ACP 1.2-3.2 indicate that the training was not
,
fully effective. The engineers were not aware.of various requirements as discussed previously-(paru--
graph 5.2.2.1).
Licensee management maintained that the training to be conducted in the future for the new Northeast
.
Utilities procedure effectively identifies and stresses the procedural requirements so that the engineers responsible for the implementation of.the procedure are aware of their responsibilities.
5.3, Testing Summary
'
,
Test procedures for assuring readiness to startup were properly completed.
An unresolved item was identified with re3pect to effective iu:plementa-I tion of the licensee's turnover and test administrative control proce-
'
'
dures.
The licensee is well prepared for low power physics and power operation
-
testing with respect to procedural control'and adequacy.
-
6.
Assurance of Quality
'
All team members reviewed how the licensee assured quality in the activities
~
leading to plant restart. Addressed below is a composite team view of this area, some aspects of whits may be repetitive within each functional area.
!
Worker attitudes were quite good and workers appeared to be well qualified
,
for their assigned tasks. Personnel were very cooperative with team members
.'
despite their busy schedules at that point in the plant restart schedule.
Overall, there appeared to be a respect for the need for and use of procedures
't
among workers. However, the team noted certain instances (albeit relatively
small in number) of nonadherence to administrative control procedures.
It
[
appeared that procedural nonadherences were persistent with respect to ad-I
ministrative control procedures.
The team expressed the view that plant man-
l agement should be sensitive to negative trends in this area.
The licensee's I
corrective action systems appear to be able to detset such trends, i
A noteworthy effort by licensee management to reverse the nonadherence problem b
- -
is their procedural upgrade program.
Better procedures wu S improved human
factors considerations should improve procedure adherence.
Team members re-
'
-viewed a sample of procedures produced under this program.
The program is
in its early stages and tne resulting procedures are impressive, especially l
,
i I
!
i
- -. -.. _ _.. -.. _ _ _,, _... _ _ ~ _ _ _.,. - _ -, _. - _. -.. - -
-
'
-
.
,
with respect to putting in directions in terms of detailed pictures.
Here again, the licensee purchased computerized equipment to support this effort.
The team considered licensee efforts noteworthy but did not rely on this pro-gram to assess readiness.
The team noted, however, that other factors may be contributing to the non-adherence problem. These are: passive acceptance by first-line supervisors in the interest of getting the job done; inattention to detail by personnel; and infrequent supervisory / managerial review.
For example, the findings in the RHR vault, although not safety significant, reflect infrequent visits to that vault by supervisors and management.
Overall, first-line supervisors appear to be doing a conscientious job. The first-line supervisors' meeting in the early morning (6:45 a.m.) is conducive to airing interface problems among departments and/or reporting to plant man-agers / planners on status of major milestone work.
The information developed at this meeting is used for the daily upper management meeting at 7:30 a.m.
The 7:30 a.m. meeting is similarly conducive to airing plant problems and coordinating work.
Impromptu PORC meetings may follow this meeting to review Plant Information Reports (PIRs) and/or procedural temporary changes.
These impromptu meetings reflect well on the built-in flexibility of the PORC.
The team noted substantial efforts in the area of Technical and Safety Review.
The focal point in this process is the PORC.
Based on a review of the three PORC meetings attended, it appeared that PORC was effective. They seem to have the right balance, for each item reviewed, between considering broad safety issues / effective corrective actions and knowing when to get into the details of the review process.
The PORC review was also critical.
Detailed reviews are expected at a lower level than PORC and cognizant personnel are usually required to represent and explain their work at the PORC meeting.
As an example, certain items were "tabled" because PORC members had questions and no one was present to address them.
The impromptu PORC meeting of March 10, 1988, was effective in identitying residual, non-standard items for entering the various modes of operation.
However, the team noted a lack of a consolidated and formal review process for the licensee to ascertain its own readiness for startup with respect to non-standard (hardware and software) items that are mode sependent.
The station superintendent indicated that they are working on a computerized system to help in that effort.
Overall, the team noted a number of licensee initiatives.
These initiatives, coupled with the licensee's corrective action systems, are viable to identify problems for effective corrective action during the startup process.
Licensee training efforts to get operators ready for startup in light of major design changes appeared to be substantial.
The effectiveness of th15e efforts will not be realized until well into the power operations period.
.-
_ _ _ _.
_ _ _ _ _ _ _
.
.
Also, the interface between the plant and quality control / services department appears to be substantial.
The startup PORC of March 10, 1988, specifically reviewed outstanding nonconformance reports to assure more effective planning of mode changes leading to power operations.
7.
Conclusion
'
In conclusion, the team had reasonable assurance that the licensee was ready to proceed with appropriate modes up to full power operation, assuming satis-factory completion of the currently identified items / issues as outlined by the licensee for each mode.
The team basis is:
individual supervisory attention to outstanding items (OIs) within the
--
various corrective action (CA) systen; compensatory manual review of work and Ols that predated this startup;
--
the PORC meeting of March 10, 1988 on startup; and,
--
the lack of technical findings by the team on safety significant tech-
--
nical prcolems/ issues.
8.
Exit Interview i
During this inspection, periodic meetings were held with plant management to discuss the preliminary findings.
The final exit meeting occurred on March 11, 1988.
In addition to those marked by an asterisk (*) in paragraph 1.3 and the NRC team members, the following personnel attended the exit meeting.
Licensee G. Bohn, NUSCO - General Construction H. Clw, Health Physics Supervisor, CY R. Heidecker, Operator Training, Connecticut Yankee (CY)
J. LaPlatney, Senior Engineer, CY C. Libby, Supervisor, Assessment Services, CY l
A. Nericcio, Public Information, CY M. Quinn, Chemistry Supervisory, CY E
A. Asars, Resident Inspector (CY), Region I (RI)
L. Bettenhausen, Chief, Project Branch No. 1, Division of Reactor Projects (DRP), RI S. Golembieski, Resident Clerical Aide, (CY) RI V. Pritchett, Reactor Engineer, RI J. Shediosky, Senior Resident Insper: > (CY)
.
.
27 The inspection results as discussed at the meeting are summarized in the cover page of the inspection report.
Licensee representatives did not indicate that any of the subjects discussed contained proprietary or safeguards information and no written material was provided to the licensee.
Unresolved Items are matters about which information is required in order to
.$certain whether they are acceptable, violations, or deviations. An unre-solved item discussed during the exit meeting is addressed in paragraph 5.2.2.2.
. -
-
. _
_
-
.
,-
_
_.--.- __
'
.
,
.
ATTACHMENT 1 50-213/88-06 DOCUMENTS REVIEWED Plant Operations Admir.istrative Control Procedure (ACP) 1.2-3.2, Revision 1, dated October 27,
--
1987, "Administration of PDCR Turnover and Preoperational Testing" ACP 1.2-5.1, Revision 34, dated October 30, 1987, "PMMS Trouble Reporting
--
System and Automated Work Order" ACP 1.2-6.4, Revision 20, dated April 28, 1987, "Temporary Procedure Change"
--
ACP 1.2-6.5, Revision 21, dated September 22, 1987, "???"
--
A0P 3.2, "Temporary Procedure Change"
--
A0P 3.2-8 "Equipment Inventory"
--
Normal Operating Procedure (NOP) 2.1-1, Revision 22, dated November 2, 1987,
--
"Cold Shutdown - Mode 5 to Hot Standby - Mode 3" (Temporary Change Notice's (TCN's)88-153, 192, 220)
NOP 2.3, "Temporary Procedure Change
--
Emergency Operating Procedure (EOP) 3.1, "Emergency Response"
--
Preventive Maintenance FMP 9.2-0, Revision 3, dated November 21, 1985.
--
Modification NEO, Revision 6, dated November 21, 1986, "Plant Design Change Record (PDCR)"
--
Completed Work Orders WO CY 87-11088 - Replace tee between CH-V-266 and CH-V-267
--
WO CY 87-00173 - Repair of CH-FCV-110
--
WO CY 88-02211 - Valve steam leakoff line must be capped
--
WO CY 87-11477 - Repair CHG-VLB-150 - CH-V-275
--
WD CY 87-11794 - Containment Instrument Air Modification
--
.
__
_
-
_. _ _ _ _
~
.
a
'
Attachment 1
WO CY 88-02187 - Pressurization spray control valve PR-A0V-573 packing leak
--
WO CY 87-07064 - Installed containment instrument air system relief valve
--
WO CY 87-07990 - Removal of operator and bonnet C11-FCV-110
--
Test Procedures SPL 10.7-285
"Electrical Functional Testing and Scheme Verification of Control Circuit for Penetrations 7, 10, 30, 38, and 60 Isolation Valves" performed October 13, 1987 SPL 10.7-288
"Preoperational Testing of Replacement Feedwater M0V's" performed January 29, 1988 SPL 10.7-290
"Functional Testing of Penetrations 7, 10, 30, 48, 41, and 60 Isolation Valves Piping Corrections," performed October 3, 1987 SPL 10.7-294
"Flow Test to Determine Component Cooling Water Supply to Reactor Coolant Pump Thermal Barrier" performed January 13, 1988 SPL 10.7-296
"HPSi Stction Piping Hydrostatic Test" SFL 10.7-297
"ECCS Flow Test - Long-Term Recirculation" SPL 10.7-298
"ECCS Flow Testing" SPL 10.7-304
"Functional Test T-484, T-485, T-496, and T-497," performed on October 26, 1987 SPL 10.7-308
"Preoperational Testing for POCR 861" SPL 10.7-309
"LLRT for Penetration P-7, RCP Seal Water Return" performed February 20, 1988 SPL 10.7-314
"LLRT for Penetration P-60, CCW to Neutron Shield Tank Cooler,"
performed on October 3, 1987.
SPL 10.7-315
"LLRT for P-10, Reactor Coolant Letdown" performed February 27, 1988 SPL 10.7-317
"LLRT for Penetration P-38, CCW to RCP Thermal Barrier," performed on October 3, 1987 SPL 10.7-328 - Functional Test of HCP Override Switch for LO-TV-230" performed November 13, 1987
.
.
,
,
Attachment 1
ATTACHMENT 2 READ AND SIGN LOG Document Read & Sign No.
Completion Document Date In Book Signatures Percentage IN 87-46, Undetected Loss 10/5/87 1/22/88 27/60
of RX Coolant"
"ECCS Pumps Made Inoperable 2/5/88 2/10/88 15/60
by HP Covering with Plastic for Decontamination" ED-6 Autostart Signals 1/27/88 1/28/88 24/60
Farley LER on RHR Spill of 1/7/88 1/22/88 27/60
2400 Gallons - Out PRV PDCR 85-777, "N2 Blanket 3/16/87 12/31/87 33/60
System for the DWST" A0P 3.2-8, "Equipment 12/16/87 12/16/87 37/60
Inventory" Fire Protection Technical 10/15/87 10/1687 36/60
Specification OP Inst. No. 73 - CR 11/10/87 11/10/87 39/60
Activities Electrical Flash During 12/14/87 12/31/87 36/60
Racking Out 4.16 KV Breaker A0P 3.2, "Temporary 2/23/88 2/24/88 12/32
Procedure Change" NOP 2.3, "Temporary 2/18/88 2/23/88 14/32
Procedure Change" E0P 3.1, "Emergency Response 2/5/88 2/5/88 19/32 59