IR 05000213/1993001
| ML20035A850 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/22/1993 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035A848 | List: |
| References | |
| 50-213-93-01, 50-213-93-1, NUDOCS 9303300046 | |
| Download: ML20035A850 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.
50-213/93-01 License No.
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L Licensee:
Connecticut Yankee Atomic Power Company l
P. O. Box 270
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Hartford, CT 06141-0270
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Facility:
Haddam Neck Plant Location:
Haddam Neck, Connecticut Inspection Dates:
January 10 to February 20,1993 Inspectors:
William J. Raymond, Senior Resident Inspector Peter J. Habighorst, Resident Inspector a
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Approved by:
ourttet b hm 3 aa !93 A.
Lawrence T. Doerflein, Chief Dale
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Reactor Projects Section No. 4A '
Areas Inspected: NRC resident inspection of plant operations, radiological controls,
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maintenance, surveillance, emergency preparedness, licensec event 32 ports, quality assurance audits, previously identified items, and periodic reports. Inspection initiatives included safety-related pump design margins, and facility overtime controls.
Results: See Executive Summary
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9303300046 930322
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PDR ADOCK 05000213 O
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EXECUTIVE SUMMARY HADDAM NECK PLANT INSPECTION 93-01 Plant Operations Safe facility operation was noted throughout the period, and safety and electrical power systems were maintained in the proper configuration. Operators performed routine tagging operations and shift tumovers very well. A discrepancy in the control of scaffolding was promptly corrected by the licensee.
Maintenance and Surveillance
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The inspector noted good maintenance controls during the replacement of a pipe coupling in the service water supply to the 'B' spent fuel pit heat exchanger. The work was well coordinated and implemented to minimize heatup of the spent fuel pool. Surveillance testing completed during the period on the containment recirculation fan, the ' A' emergency diesel generator (EDG-2A), the station batteries, and the service water pumps demonstrated pmper safety system performance.
A technician's error in recording differential pressure from the wrong instruments resulted in the apparent degraded performance of three of four service water pumps on January 28. The l
plant staff responded promptly and conservatively to declare both service water headers inoperable until the invalid test was recognized. An operator error during the test of EDG-2A had no affect on the performance of the test and created no adverse conditions.
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Both personnel errors are isolated and are not indicative of training weaknesses.
Emereency Preparedness A quarterly emergency plan mini-drill conducted on February 9 satisfactorily met the stated objectives and demonstrated improved performance in the deployment of emergency repair I
teams from the operations support center.
Engineering and Technical Support j
An inspection initiative during the period verified that adequate net positive suction head (NPSH) existed for safety related pumps when pumps in redundant trains were operating and taking suction from a common tank. The inspector independently verified that NPSH was satisfactory for the low pressure safety injection, high pressure safety injection and auxiliary feedwater systems.
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t Safety Assessment and Ouality Verification The licensee failed to provide training as required by his commitment in response to a previous NRC enforcement action. Further review is required to identify the cause of this performance issue and to evaluate whether an adverse trend is developing.
The audit by the quality services department (QSD) of the 1992 auxiliary feedwater system design changes was effective and made a positive contribution to performance of the licensee's modification program. While corrective actions in response to audit findings were r
generally appropriate, the bases for two actions are tracked as an unresolved item pending further NRC review (Section 6.4).
Plant staffing is ample to preclude the use of overtime during routine plant operations. When used, overtime is well controlled and within the technical specification requirements.-
Overtime records are well maintained by the administrative section.
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SUMMARY OF FACILITY ACTIVITIES The unit operated at full power until January 17, when the licensee reduced power to 65% at 2:21 a.m. for a pre-planned test of the main turbine control valves. After completing the test successfully, the unit returned to full power at 6.:50 a.m. and remained at full power for the j
remainder of the inspection period. CYAPCo received two replacement 115 kilovolt station service transformers during the period. The transformers will be replaced during the
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upcoming refueling outage (May 1993).
On February 2,1993, the Director of the NRC Region I Division of Radiation Safety and Safeguards toured the facility and interviewed CYAPCo managers. Overall, facility conditions were satisfactory.
2.0 PLANT OPERATIONS (71707 and 93702)
The inspectors routinely reviewed plant operations during normal utility working hours, and portions of backshifts (evening shifts) and deep backshifts (weekend and night shifts). During this report period, the inspectors conducted twenty-two hours of backshift and nineteen hours of deep backshift inspection.
2.1 Operational Safety Verification This inspection consisted of selective examinations of control room activities, operability reviews of engineered safety feature systems, plant tours, review of the problem identification
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systems, and attendance at periodic planning meetings. Control room reviews consisted of verification of staffing, operator procedural adherence, operator cognizance of control room alarms, control of technical specification limiting conditions of operation, and electrical distribution verifications. Administrative control procedure (ACP) - 1.0-23, " Operations Department Shift Staffing Requirements," identifies the minimum staffing requirements.
During this inspection period, the inspectors noted that the control room staffing during power operations met these requirements.
The inspectors reviewed the onsite electrical distribution system to verify proper electrical line-up of the emergency core cooling pumps and valves, the emergency diesel generators, radiation monitors, and engineered safety feature equipment. The inspectors also verified
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valve lineups, positions of locked manual valves, power supplies, and flow paths for safety systems, including the high pressure safety injection system, the low pressure safety injection system, the containment air recirculation system, the service water system, and the
emergency diesel generators. The inspector did not identify any deficient conditions.
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The inspectors reviewed bypass jumpers against the requirements of ACP 1.2-14.1, " Jumper, Lifted Lead, and Bypass Control," with emphasis on their proper installation and the content of the safety evaluations. The inspector also reviewed all jumpers for age, and verified that I
the Plant Operations Review Committee (PORC) completed the evaluations to disposition longstanding jumpers. The inspector found that the jumpers reviewed were in accordance with the administrative requirements.
Tagouts l
The inspector reviewed equipment tagouts for conformance with the applicable sections of ACP 1.2-14.2, " Equipment Tagging." The inspection included observation of work activities
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i and a comparison of plant conditions with the controlled drawings and procedure requirements. The inspector verified that the proper equipment was tagged, technical specification equipment was appropriately controlled, and equipment isolation was appropriate. Tagouts reviewed were: 930019 - Electric Auxiliary Feedwater Pump; 930017
- Sodium Hypochlorite System Upgrade; and, 920376
'C' Service Water Pump. The
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inspector also reviewed other tagging operations by comparing the tags installed in the plant with the tagout sheets maintained in the control room. The inspector determined that the equipment tagged out was appropriately isolated.
l Im-Keeping and Turnovers The inspectors reviewed control room logs, night order logs, plant incident report logs, and crew turnover sheets. No discrepancies or unsatisfactory conditions were noted. The inspectors observed crew shift turnovers and determined they were satisfactory, with the shift supervisor controlling the turnover. All members of the crew discussed plant conditions and -
evolutions in progress. The information exchanged was accurate. The inspector reviewed control room trouble reports for age, planned action, and operator awareness of the reason i
i for the trouble report. Most trouble reports reviewed were recent, with few longstanding
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items.
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At daily planning meetings, the inspector noted discussion on maintenance and surveillance activities in progress, and work control authorizations. The inspector conducted periodic
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plant tours in the primary auxiliary building, turbine building, and intake structures. The inspector determined plant housekeeping was satisfactory.
l Scaffolding Controls l
On February 11, the inspector reviewed scaffolding erected in the turbine building in support i
of construction for plant design change record (PDCR) 1331, ' Modernize the Feedwater l
Control System." The inspector compared the installation with procedural guidance in ADM 1.1-126, " Scaffolding Installation and Storage of ladders." The inspector identified the following deficiencies: a ladder did not extend at least three feet above the point of i
support; and, guard rails were not installed on all open ends. The inspector presented the
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deficiencies to the construction supervisor. The supervisor immediately corrected the deficiencies and discussed them with other department supervisors. The inspector noted that l
the scaffolding deficiencies had no impact on safety-related equipment and had no further l
concerns with the contml of scaffolding at this time.
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2.2 Radiological Controls t
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During routine inspections of the accessible plant areas, the inspectors observed the j
implementation of selected portions of the licensee's radiological controls program. The.
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l inspectors reviewed utilization and compliance with radiation work permits (RWPs) to ensure l
l that they provided detailed descriptions of radiological conditions and that personnel adhered j
l to RWP requirements. The inspectors observed controls of access to various radiologically l
controlled areas and the use of personnel monitors and frisking methods upon exit from those j
areas. The inspectors also verified that posting and control of radiation areas, contaminated
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areas and hot spots, and labelling and control of containers holding radioactive materials were~
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in accordance with licensee procedures. The inspectors determined health physics technician l
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control and monitoring of these activities were good.
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3.0 MAINTENANCE AND SURVEILLANCE (61726,62703)
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3.1 Maintenance Observation
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The inspectors observed various corrective and preventive maintenance activities for l
compliance with procedures, plant technical specifications, and applicable codes and
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standards. The inspectors also verified appropriate quality services division (QSD)
l involvement, use of safety tags, equipment alignment and use of jumpers, radiological and -
i fire preventiori controls, personnel qualifications, and post-maintenance testing. Portions of
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activities that were reviewed included:
I CY-92-10492,- Reorientation of the 'B' Spent Fuel Pit (SFP) Service Water
Supply Header Relief Valve On January 29, CYAPCo maintenance personnel replaced a pipe coupling with a ninety degree elbow under automated work order (AWO) CY-92-10492. The elbow reoriented the
'B' spent fuel pit (SFP) service water supply header relief valve from a horizontal to the vertical position. - The work resulted fmin maintenance personnel inquiry and a vendor recommendation conecrning relief valve installation.
The inspection consisted of: review of the AWO documentation; independent verification of tagging order 920056; verification that activities conformed to administrative control -
procedure (ACP) 1.2-4.7, " Evaluation of a Replacement Item - NEO 6.12;" and, a review of CYAPCo's engineering evaluation of SFP heat-up with service water isolated to the SFP--
heat exchangers. The inspector concluded that the controls and processes for the maintenance
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activity were appropriate. Rephcement item evaluation (RIE) CYOE-93-00006 conformed to i
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the requirements of ACP 1.2-4.7. CYAPCo conservatively predicted a one degree per hour heat-up of the SFP. No actual SFP heat-up occurred during the duration of the work (approximately three and one half hours). The tagging boundary provided two valve protection for the workers from the service water system. The inspector determined that the maintenance activity on the service water relief valve was appropriately controlled and implemented.
3.2 Surveillance Observation The inspector witnessed selected surveillance tests to determine whether: frequency and action statement requirements were satisfied; necessary equipment tagging was performed; test instrumentation was in calibration and properly used; testing was performed by qualified personnel; and, test results satisfied acceptance criteria or were properly dispositioned.
Portions of activities associated with the following procedures were reviewed:
SUR 5.1-8B, Train 'B' Containment Air Recirculation Fan Damper Test
On January 26,1993, the inspector observed the performance of technical specification (TS)
surveillance SUR 5.1-8B. This surveillance test operates two of the four containment air i
recirculation (CAR) fans with their associated dampers in the ' accident' mode. The
' accident' mode directs airflow through the cha coal filter banks. The inspector reviewed the test method and verified that it satisfied the requirements of TS 4.5.2.a.l. and 4.6.2.b.
The inspector noted the surveillance test results satisfied the acceptance criteria, and the control room reactor operator diligently performed the test.
SUR 5.1-157A, Emergency Diesel Generator EG-2A Fast Start and Load Test
This surveillance test demonstrates the ability to start the ' A' emergency diesel generator (EG-2A), and to achieve rated voltage, speed, and frequency within ten seconds. The surveillance is performed every six months, and was last done in August 1992, (NRC report
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50-213/92-15). On February 9, the inspector observed the performance of sections 4.0 through 6.3 of SUR 5.1-157A. The insp:ctor noted that the operator performing the surveillance was diligent in the review of temporary procedure changes and effectively j
communicated the surveillance objectives with control room personnel. The inspector noted
generally good attention to detail in performance of the surveillance. However, procedural
step 6.3.1 required the operator to adjust generator voltage with the voltage regulator control
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switch. The basis of the step is to match generator output voltage with bus voltage in preparation to synchronize the generator to the bus. The inspector observed the operator adjusting the governor control switch instead of the voltage regulator switch. The inspector
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pointed this out to the operator, who immediately corrected the error, and successfully '
completed the remainder of the surveillance. The operator recognized that he should have l
verified proper switch manipulation by looking for the expected response from voltage meter.
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l The inspector concluded the procedure adherence issue was minor in that it had no adverse effect on successful performance of the surveillance, and it caused no undesirable condition.
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During diesel operation, the inspector observed that speed was at approximately 890 revolutions per minute (rpm) at the time that generator frequency was at 60.1 hertz. The technical specification requirement is that engine speed be equal to or greater than 900 rpm.
The engine came to 930 rpm during the start-up and returned to 890 rpm. The procedure required the operator to observe the tachometer and verify that engine speed stabilize at approximately 900 rpm. Upon further investigation, the inspector learned that the engine tachometer used to verify technical specification acceptance criteria is not classified as a safety related instrument, or subject to routine calibrations. The inspector reviewed the
emergency diesel generator instrumentation calibration program. The remaining instruments used to satisfy TS requirements are periodically calibrated. During the surveillance, the
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inspector identified an additional minor deficiency. The deficiency was a missing valve label tag for the air box drain valve. Procedure step 6.1.15 manipulates this valve. The licensee promptly corrected this deficiency.
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In conclusion, the inspector noted generally good attention to detail during performance of the suneillance. The EG-2A tachometer used to satisfy TS requirements is not classified as a safety related instrument, or subject to routine calibrations. This matter was discussed with the Unit Director at the exit interview, who noted the inspector's concerns for further
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consideration in the program to calibrate diesel instruments. CYAPCo's evaluation and resolution of this issue will be subject to future NRC review (IFI 93-01-01).
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SUR 5.7-148A, In-Sen' ice Testing of the A, B, C, and D Service Water Pumps
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During a monthly in-service test (IST) on January 28, the licensee declared three out of four service water pumps inoperable. Engineering personnel determined that the pumps were in the required action range based on the test results for flow versus developed head. As
- i required by procedure, the IST engineers declared the pumps inoperable, notified the shift supenisor and initiated plant information report (PIR)93-012. Control room operators declared two service water headers inoperable and entered TS 3.0.3 at 3:25 p.m. Based on further review of how the test was actually performed, the licensee determined that the technician had recorded service water differential pressure from the wrong instruments.
CYAPCo declared the test invalid and exited TS 3.0.3 at 3:30 p.m.
SUR 5.7-148A requires recording differential pressure from either PDI-1438A or PDI-1438B
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depending on which service water pump is tested. These instruments measure differential
pressure from an "Annubar" flow sensor in their respective service water header. The
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service water pump flow is calculated using this differential pressure. During the test on January 28, the technician erroneously recorded values from the differential pressure
indication on the discharge strainers instead of the header instruments. After data acquisition i
by the technician, procedure Section 8.3 requires IST engineering to plot flow data for each
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pump and to determine operability. Using procedure (ENG) 1.7-85, " Inservice Testing
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Pump Analysis and Documentation," engineering concluded that the pumps were in the required action range based on the hydraulic performance. During the surveillance, the
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bearing and vibration data for all pumps met the acceptance criteria.
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Upon recognizing the data acquisition error, CYAPCo declared the surveillance invalid and immediately reperformed the surveillance. The licensee assigned the technician who made the error to perform the surveillance a second time. The results of the second test were acceptable. Additionally, IST engineering management held a meeting with all department personnel to discuss lessons learned, to develop a procedural review checklist, to warn
personnel regarding complacency, and to stress the need for appropriate job briefings.
The inspector reviewed the surveillance procedure and observed portions of the test. The inspector determined that the vibration instrumentation was within calibration, and in-plant instruments were in calibration pursuant to procedure PMP 9.2-~20, " Calibration of IST Gages." The inspector also reviewed outstanding trouble reports on the service water pumps and verified they did not impact coerability. The 'C' service water pump inlet check valve
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was cautioned tagged to identify precautions to be taken during a pump start to prevent the-check valve sticking shut because of a broken internal alignment pin. The inspector noted
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good technician and operator coordination in starting the 'C' service water pump and adhering to the special precautions for the inlet check valve. The time that each pump i
operated at shutoff head was minimized by the techmetan.
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The inspector reviewed the training program for IST technicians to determine if training was a factor in acquiring the wrong data during the surveillance. The inspector noted that IST
personnel undergo training as described in engineering department instruction (EDI)-2.01.
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The training to acquire data for IST surveillances consists of on-the-job (OJT) training,
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external traming for vibrational instrumentation, and practical training. The technician had fulfilled the requirements in EDI-2.01. The final judgement for qualification resides with the IST engineering supervisor. The supervisor had accepted the past performance and OJT results for this individual. The inspector concluded that a training deficiency did not exist for this procedural compliance issue.
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The inspector concluded that engineering personnel appropriately identifial the root cause of
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the surveillance deficiency, operators took conservative actions, and corrective actions were appropriate. The inspector considers the failure to follow procedure by acquiring the data from the wrong instrument to be an isolated case. The inspector concluded that no indication j
of a technician training deficiency existed. The inspector had no further questions regardmg j
this event.
SUR 5.5-16, BT-1 A, B, C, Weekly Station Battery Checks
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On February 18, the inspector observed the performance of this TS surveillance. This surveillance test verifies the station batteries and chargers are o;rrable. The inspector concluded that the test method satisfied the TS surveillance requirement. Test equipment was in calibration, and electricians adhered to personal safety requirements during specific gravity measurements. The inspector noted the surveillance results satisfied the acceptance criteri._
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4.0 EMERGENCY PREPAREDNESS (81700)
4.1 Emergency Plan Drill The inspector observed the conduct of the quarterly mini-drill by CYAPCo personnel on
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February 9,1993. The drill was conducted in conjunction with the Haddam Neck simulator,
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and resulted in the partial activation of the onsite and corporate emergency response facilities.
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i The emergency scenario simulated the loss of reactor coolant complicated by inoperable safety equipment needed to cool the core, and the bypass of reactor containment resulting in the offsite release of radiation. The scenario was written to result in the declaration of a i
general emergency. The emergency response organization correctly recognized the degraded plant conditions, and classified the event as required.
One of the drill objectives was to demonstrate new strategies to rapidly deploy repair teams.
The inspector's review focused on licensee actions to address weaknesses identified in this area, as described in Inspection Item 92-06-01. The licensee revised the following emergency plan implementing procedures (EPIP) to improve response capabilities: EPIP 1.5-42, " Manager of Operations Support Center;" and, EPIP 1.5-43, " Personnel Radiation
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Exposure Control and Dosimetry Issue During Nuclear Emergency." Additionally, a new procedure, EPIP 1.5-53, " Emergency Team Deployment," was validated during the drill.
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The procedure revisions were designed to expedite upgrading exposure limits and modifying in-process activities. The inplant Operations Support Center located in the lower level of the
'B'switchgear building was used as a staging area for the repair teams while waiting i
redirection from the OSC once a task was completed.
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The inspector observed the conduct of the drill from the emergency operations center and the operations support center. The inspector noted the licensee demonstrated improved
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performance in rapidly deploying and controlling emergency response teams. The licensee
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concluded that the drill objectives were met. The inspector did not identify any discrepancies. Licensee performance in this area will be evaluated further during the
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March 1993, emergency exercise.
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5.0 ENGINEERING AND TECHNICAL SUPPORT (71707)
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5.1 Net Positive Suction Head for Safety-Related Pumps
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l This inspection was performed to determine whether acceptable net positive suction head (NPSH) conditions were present for safety related pumps. The basis for the initiative was an i
H. B. Robinson Steam Electric Plant licensee event report (LER) 50-261/89-10. The LER documented that adequate NPSH could not be assured for all combinations of running auxiliary feedwater (AFW) pumps and condensate storage tank levels. The root cause of the
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Robinson event was piping that was incorrectly sized to provide adequate NPSH during operation of all AFW pumps. Based on the design deficiency at H.B. Robinson, the inspector evaluated the NPSH conditions for the low pressure safety injection (LPSI) pumps, high pressure safety injection (HPSI) pumps, and the AFW pumps. The inspector discussed the H.B. Robinson design deficiency with CYAPCo engineering personnel. The inspection
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findings are discussed below.
Low Pressure Safety Injection (LPSI) Pumps In February,1988, Northeast Utilities Service Company (NUSCo) engineering calculation 86-060-609GM, " Refueling ' Water Storage Tank (RWST) Level to Support LPSI Operation,"
calculated the minimum RWST tank level needed to prevent pump cavitation. The calculation assumed both LPSI pumps were in operation, RWST tank temperature was at the technical specification (TS) limit of 120 degrees Fahrenheit (F), and the reactor coolant
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system pressure was thiny pounds per square inch gage (PSIG). The calculation concluded that pump operation was limited due to vortexing rather than NPSH considerations.
Vortexing at the tank outlet would result in air entrainment at the pump's suction and
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potential pump damage. The minimum RWST tank level to provide enough submergence to prevent vortexing was at 62,475 gallons, or level at a plant elevation of 32 feet six inches.
Ievel at an elevation of twenty-one feet would assure adequate NPSH for both pumps.
The inspector evaluated CYAPCo controls to prevent vortexing of the LPSI pumps. During plant operation, TS 3.5.3 requires RWST inventory to be greater than 230,000 gallons.
During postulated accidents, operators are required to secure LPSI pumps prict to initiating the sump recirculation phase of injection. ERP ES-1.3, " Transfer to Sump Recirculation,"
step 4.f., requires that both LPSI pumps be secured shortly after RWST level reaches 130,000 gallons. Once level reaches 130,000 gallons, operators open the containment sump suction valves, isolate charging suction header relief valves, close the core deluge valves, and then secure the LPSI pumps. The inspector verified the operator's ability to complete these
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steps in a timely manner during a previous review of simulator training exercises as documented in Inspection Report No. 50-213/92-21. The inspector concluded that NUSCo's
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engineering calculation demonstrated acceptable LPSI pump operation, and that appropriate controls exist in the TS and CYAPCo emergency response procedures (ERP) to prevent postulated LPSI pump damage due to vortexing.
i High Pressure Safety Iniection (HPSI) Pumns In September 1986, NUSCo engineering calculation 86-060-580GM, "HPSI Modifications -
Minimum RWST Ievel," evaluated the minimum RWST level to maintain sufficient NPSH during pump run-out conditions. The calculation evaluated three separate cases: one HPSI and two charging pumps running; two HPSI and two charging pumps running; and, one
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HPSI pump running. The calculation showed that vortexing was more limiting than NPSH for the cases evaluated. The worst case condition for vortexing was the two HPSI and two charging pump combination. The minimum RWST level to provide sufficient submergence for vortexing was at 44,625 gallons.
A caution statement in ERP ES 1.3 states that shift over to sump recirculation should be completed before RWST level reaches 43,000 gallons to prevent damage to the HPSI and charging pumps. The inspector questioned CYAPCo personnel on the difference between the 44,625 limit in NUSCo calculation 86-060-580GM, and the 43,000 value in the ERP caution statement. CYAPCo acknowledged the difference, but stated a change to the ERP was not necessary because: (1) the NUSCO calculation has conservatism on the reference point for vortexing, (2) the expectation of timely operator action based on operator performance during requalification simulator scenarios, and (3) the readability of the RWST level transmitter output. The calculational conservatism refers to the assumption that vonexing would occur when level reaches the top of the suction pipe, instead of the centerline of the pipe were
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vonexing is expected to occur. This difference in reference points equates to approximately 3,600 gallons, or a minimum level of 41,025 gallons required to prevent vortexing. Based on discussions with operators and inspector observations of operator simulator training, sump recirculation routinely is completed at greater than 60,000 gallons in the RWST. The minimum graduation on the RWST level indicators is 1,000 gallons.
The inspector concluded that licensee calculations have demonstrated acceptable HPSI pump
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performance based on NPSH considerations. CYAPCo provided acceptable justification for
the difference between NUSCo engineering calculation and the ERP caution statement.
Auxiliary Feedwater (AFW) Pumo In May 1990, NUSCo Nuclear Safety Engineering requested NUSCo Generation Mechanical Systems Engineering to verify adequate NPSH is available for the AFW pumps under worst case conditions. In June 1990, the licensee initiated plant information report (PIR)90-107 and reportability evaluation (REF)90-030 to evaluate available NPSH for the AFW pumps.
The REF was supponed by NUSCO calculation 90-BOP-728-GM, "CY - AFW System Investigation of Pump NPSH Available vs. NPSH required for limiting conditions." The calculation showed that sufficient NPSH was available for the postulated worst-case scenario (main steam line break with one steam generator depressurized).
The initial demineralized water storage tank (DWST) level assumed in the calculation was 46,590 gallons, which was derived from the TS limit adjusted for instrument uncertainties.
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The analysis concluded that a thirty percent margin exists between the available NPSH over the required. The analysis funher concluded that the limiting case was a failure of one AFW pump twenty minutes into the postulated event.
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In addition to the NUSCo calculations, surveillance procedure SUR.5.1-141, " Functional Test
for Auto Initiation Scheme for Auxiliary Feedwater," verifies acceptable performance during
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operation of both AFW pumps, and data is recorded for total AFW flow. Tim inspector i
reviewed the results from the last time the surveillance was performed (in March 1992).-
l Both pumps delivered greater than the design flow rate of 450 gallons per minute (gpm) - the j
actual flow was'460 gpm for each pump.
Based on the results of the REF 90-030 and SUR 5.1-141, the inspector concluded that
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reasonable assurance exists that appropriate NPSH is available for the AFW pumps.
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Conclusion i
Based on review of engineering analyses, surveillance data, and the ERPs, the inspector l
determined that adequate NPSH was available for the LPSI, HPSI, and AFW pumps.
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I 6.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION (40500,71707,90712, and 92701)
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6.1 Plant Operations Review Committee
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I The inspectors attended three Plant Operations Review Committee (PORC) meetings and j
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verified the member attendance met the Technical Specification 6.5 requirements. The l
l-meeting discussions included procedural changes, proposed changes to the Technical l
Specifications, Plant Design Change Records, and minutes from previous meetings. The
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inspectors noted the PORC meetings were characterized by frank discussions and questioning of proposed changes. A good questioning attitude was clearly demonstrated in the PORC j
review of PDCR 1248, " Reactor Coolant Pump Seal Water Return Containment Isolation l
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Valves," and the temporary modification to the chlorination system. Also, the inspectors
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noted PORC assured clarity and consistency among procedures, as exemplified by ACP
1.0-6, "On-Call." PORC postponed items for which adequate review time was not available.
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to allow committee members time for further review and comment. Dissenting opinions were
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encouraged and resolved to the satisfaction of the committee prior to approval. The inspector l
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concluded the committee closely monitored and evaluated plant performance.
l 6.2 Review of Written Reports j
i The inspector reviewed periodic reports and Licensee Event Reports (LERs) for clarity, j
validity, accuracy of the root cause and safety significance description, and adequacy of
.j corrective action. The inspectors determined whether further information was required. The :
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inspectors also verified that the reporting requirements of 10 CFR 50.73 and Technical Specification 6.9 had been met. The following reports were reviewed:
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Monthly Operating Reoorts 92-12. 93-01 and 93-02
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LER 93-001-00, Fire Door Opened Without Entering Limiting Condition of Operation and
- Establishing Fire Watch
i CYAPCo reported a condition prohibited by technical specification 3.7.7. A fire door was f
opened without establishing a fire watch. The fire door between the turbine building and the j
' A' switchgear room was open for several minutes with maintenance and security personnel
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present to allow painting of the door frame. The licensee determined the cause of the event
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was the failure of Building Maintenance and Security employees to take actions as noted on i
door signs and plant procedures. CYAPCo's short-term corrective actions were to close the
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fire door and advise the personnel involved on the procedural requirements governing
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technical specification fire doors. The inspector verified that the Building Maintenance and
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Security personnel received counseling on the applicable procedural requirements. For long-term action, the licensee will evaluate the corrective actions for previous similar' events to determine what further actions are appropriate.
The inspector compared this event to that described in LER 92-019-00, where a security
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guard propped open a door to the "A" switchgear room without realizing the door was a fire j
protection gas suppression system barrier. One corrective action from LER 92-019 was to change security procedure SEC 1.3-41, " Application of Compensatory Safeguards Measures."
The revised procedure required the security shift supervisor to notify the operations shift supervisor prior to accessing area doors designated as technical specification fire door or door I
associated with fire suppression systems, and to obtain concurrence to open the door.
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Training was provided on the procedural revision to the security guard force in late July 1992. The operations supervisor was not notified for the event in LER 93-01 since the
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guard failed to notify the security shift supervisor, and thus failed to follow procedure SEC j
1.3-41. The inspector concluded that a contributing cause of the LER 93-01 event was that
the July 1992 training did not fully address the communication between the guard force and l
the security shift supervisor for opening a fire barrier. Independent of the inspector's i
observation, the licensee provided training to the guard force in February 1993, identifying j
fire barrier doors, and emphasizing that the security shift supervisor must be notified prior to i
opening fire doors.
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The inspector determined the licensee performed an appropriate root cause evaluation for the -
t open fire door reported in LER 93-001 and the corrective actions were acceptable. The'
licensee is evaluating past LER corrective actions in this area, (i.e., Fire Door technical
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specification violations) will update this LER as necessary. The inspector had no further questions' regarding this issue at this time.
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1 6.3 Follow-up of Previous Inspection Findings
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The inspectors routinely review licensee actions taken in response to open items and findings from previous inspections. The inspectors determine if corrective actions are appropriate and i
thorough, and w': ether the previous concerns are resolved. The inspectors close items when they determine that corrective actions would prevent recurrence. Those items for which additional licensee action was warranted remain open. During this inspection, the inspectors I
reviewed the following item:
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6.3.1 (Open) VIO 50-213/91-01-01: Containment Isolation Valve Operability This issue concerned NRC's determination that the licensee failed to assure operability for l
letdown containment isolation valve (LD-TV-230). The NRC enforcement for this matter l
was issued by letter dated February 25,1992. CYAPCo responded by letter, dated l
April 2,1992, to describe its actions to prevent recurrence. This NRC inspection reviewed
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the licensee's corrective actions.
CYAPCo determined the root cause for the event was personnel error. Corrective actions included the completion of reponability evaluation form (REF) 91-53, providing improved l
guidance on completing operability determinations in NEO 2.2.5 " Operability and Reportability Determination," and, training on lessons learned from the event.
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The inspector verified operability determination in REF 91-53 was appropriate.
I Administrative control procedure (ACP) 1.2-2.30 *1dentification and Implementation of NRC l
Reporting Requirements - NEO 2.25," requires the REF originator to determine the need for performing and operability determination and the procedure attachment provides the needed guidance.
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The licensee committed to train technical managers and supervisor by summarizing the event i
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CYAPCo initiated the training on January 28,1993. A failure to implement a commitment l
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from NRC enforcement actions was previously discussed in report 50-213/92-15. This item l
remains open pending further review of the licensee program to implement commitments to the NRC.
6.4 Audit A30198, Auxiliary Feedwater System Modification l
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The inspector evaluated the timeliness, thoroughness, and acceptability of correction actions in response to audit A30198 on the auxiliary feedwater (AFW) system modification.
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Northeast Utilities Service Company's (NUSCo's) quality services department (QSD)
assessment and staff services organization performed the audit.
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The basis for the inspection was to followup on NRC concerns with the commercial grade dedication process as documented in reports 50-213/92-902 and 50-213/92-10. Additionally, the inspector evaluated CYAPCo's project service departments (PSDs) self-assessment audit of the auxiliary feedwater system modification.
Background The scope of the audit was to assess the auxiliary feedwater system modifications associated with project assignment (PA)90-095. The audit team evaluated the modified design, the preoperational testing, and the turnover of the modified system to the operations department.
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The audit occurred between August 1991 and April 1992.
The auxiliary feedwater modification was completed in early 1992, and replaced the turbine steam admission valve control system for both auxiliary feedwater pumps. The steam admission valve pneumatic actuators and turbine governor valve mechanical actuators were replaced with electro-hydraulic actuators. A new microprocessor based digital control system controls the actuators. Hydraulic power packs, each with one non-Class lE alternating current motor and one Class 1E direct current motor, provided the valve operating force.
New pump discharge pressure transmitters and magnetic speed sensors were installed. The pressure transmitters were Class 1E devices, and were environmentally and scismically
qut.lified.
The audit resulted in five findings and two unresolved items. The findings involved an improper evaluation of item suitability for commercial grade procurement; the failure to evaluate the acceptability of engineering services provided by the vendor; QSD inspection hold points at the vendor were bypassed by the assigned project engineer; inconsistent procedural guidance for revisions to plant design change records (PDCRs); failure to complete the necessary information for 'early release for construction" of the PDCR; failure to notify the QSD inspector to witness a pre-operational test; and, a non-conforming condition identified during installation of the control cabinets. QSD assessment services requested a response to the audit findings sixty days from issuance of the report. The licensee organizations responsible for responding to the sadit findings were the project services division (PSD), and CYAPCo engineering. Audit A30198 identified weaknesses in the procurement activities to procure engineering services and to dedicate the commercial grade items associated with the modification. A concern of the audit team was that a commercial grade supplier (Woodward Governor Company), provided eng;acering services
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and their services were not properly dedicated.
Independent of the QSD audit, a self-assessment evaluation began in April 1992, and was completed in July 1992. PSD, CYAPCo Instrument & Controls, and the CYAPCo engineering departments participated in the self-assessment. The objective of the self-assessment was to evaluate improvements in the modification process (for PA 90-095), and to examine design scope change details to decide if an independent technical review of the final product should be completed. The evaluation developed six lessons learned. The lessons
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learned were: allow time to design a project; enhance understanding of design and licensing l
basis for all involved parties; avoid over-reliance on vendor reputation; improve communica-tions between the design organization and the operations depanment; and, avoid too much j
emphasis on initial project scope drawings and distribution.
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At the close of the inspection period, QSD closed six of the original seven items as satisfactorily addressed by either PSD or CYAPCo engineering. The remaining open item concerned the dedication of commercial grade supplier engineering services. The corrective actions for audit A30198 were procedural changes, changes to purchase order hold-point inspections, dispositions to a non-conformance report (NCR), and a change to how a work order is annotated to highlight the need to notify QSD. The inspector found that the license implemented the corrective actions within six months of the audit report issuance. PSD proposed actions were documented to QSD within sixty days, and CYAPCo engineering responses were within eighty days. The inspector independently verified the licensee implemented the procedure changes as described in the audit response.
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Results To evaluate adequacy of the corrective actions, the inspector reviewed the engineering organization's significance determination of each finding. In regard to the audit finding concerning project engineer (PE) bypass of QSD hold points for a commercial product, the licensee stated that this issue was insignificant s nce the PE who developed the hold points i
also authorized removal of the hold points based on outage schedule commitments. In accepting the response to the audit finding, QSD did not address why the exclusion of the
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inspection hold points did not adversely effect the outcome of the modification. PSD actions to prevent recurrence included an informational letter to all engineers describing the need for
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timely issuance of purchase orders, and emphasizing that a failure to follow the pmcedural
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requirements impacts quality related aspects of an order.
A second issue in the audit consisted of the failure of the job supervisor to notify the QSD inspector prior to commencement of a post-modification surveillance test. The corrective action included enhancing the method used in the work package surveillance procedure to identify the required notification. The inspector noted however, that this action did not address the fundamental " attention-to-detail" issue of job supervisors during the review of work orders.
A third issue of the audit concerned the pre-construction approval of the plant modification.
The finding was that pursuant to " Design Change Notices for Design Documents" insufficient work scope was identified for early release. CYAPCo engineering provided the early release for construction memorandum and argued that it contained sufficient information of work scope within the provisions of NEO 5.11. QSD review of CYAPCo's action concluded that
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the issue was closed. The inspector reviewed the issue and concluded that engineering had provided an insufficient justification for its conclusion that the electrical tie-in of the auxiliary feedwater controls did not affect the operability of the 'A' and 'B' direct current buses. The inspector did not identify an actual equipment operability issue; however, the documentation to justify the early release could be improved. CYAPCo engineering supervisor agreed with the inspector's findings.
The inspector evaluated the effectiveness of pre-construction release of several recent PDCRs against the provisions of NEO 5.11. The inspector noted improved evaluations supporting early release of PDCR's 1311,1335,1316, and 1317 in December 1992, and January 1993.
The remaining corrective actions appear to appropriately resolve the audit issues with
acceptable actions to prevent recurrence.
QSD evaluated the audit responses based on the proposed corrective actions. In regard to the
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finding on dedication of commercial grade engineering services, QSD did not accept the response by PSD. PSD stated that dedication of the individual components supplied by the vendor was the intention of PA 90-095. As of the end of the inspection, PSD recognized that dedication of engineering services was appropriate for this modification, and will propose corrective actions to address this item.
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Lessons learned from the licensee's self-assessment are currently being applied to modification work for the upcoming refueling outage. Examples include operations department involvement in project status meetings, and development of project " freeze" dates within one year of the scheduled outage.
The inspector concluded the overall effectiveness of the QSD audit was positive. The self-l assessment of the AFW modification by people directly involved in the process was a very good initiative. Corrective action depth was appropriate in most of the issues. The inspector determined further licensee action is needed: to better define the bases for the conclusion that product quality was acceptable without the hold point inspections; and, to address the
performance by the job supervisor to notify QSD prior to a smveillance test. This item is unresolved pending further NRC review oflicensee actions (UNR 93-01-02).
6.5 Control of Overtime The inspector reviewed the use and control of overtime at Haddam Neck. The purpose of this inspection was to verify the licensee met its regulatory commitments for operating plant personnel overtime guidelines, as designated in administrative procedure ACP 1.2-1.2,
" Overtime Controls for Personnel working at the Operating Nuclear Stations (NEO 1.09),"
l dated September 9,1991.
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The inspector reviewed the weekly time reports, the computerized time summaries maintained
by the Plant Administrative Section, and the authorizations for use of overtime kept on file l
per ACP 1.2-1.2, Figure 7.2, " Authorization to Exceed Established Overtime Limits." The review covered periods of routine plant operations as well as outages (January-March 1992). -
The review included a sampling of personnel from the following plant groups: operators,
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engineedng, instrument & controls, maintenance, radwaste technicians, chemistry technicians, and health physics technicians.
j The inspector reviewed the computerized summaries of hours worked, including the amount
of planned and unscheduled overtime worked, and compared them against the shift, daily and weekly overtime limits set in ACP 1.2-1.2.
The inspector also checked that the licensee
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approved any overtime worked in excess of the limits. The inspection findings are
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summarized below.
j The inspector noted that the time sheets and overtime summary records maintained by the j
administrative sections, were well organized and readily retrieved. He record organization facilitated the review of overtime use by large sections of the plant staff over large pedods of l
time. The inspector noted that, during periods of routine plant operations, very little
l overtime is used. Overtime used during periods of plant equipment problems was generally j
less that the ACP 1.2 limits. Overtime worked during holiday periods was'within the j
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guidelines, and approved if over the limits.
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Overtime worked during the outage was either within the limits, or approved if over the _.
limits. The inspector identified one discrepancy involving an engineer who worked 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />
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over two consecutive days for the week ending March 14, 1992. There was no authorization
~l form on file for this instance. Inspector interviews with the individual and administrative personnel established that the excessive overtime was approved and that supervisory personnel
were monitoring the individual's fitness to work. Thus the intent of ACP 1.2-1.2 was met--
and the missing record is considered to be an isolated discrepancy.
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In summary, the inspector determined there was sufficient staffing to minimize the use of
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f overtime. When used, the licensee controls overtime within the guidelines of ACP 1.2-1.2
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and the technical specifications.
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6.6 Quality Services Department System for Categorizing Audit Findings e
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services department (QSD) audit and surveillance findings. The system was developed as
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part of Millstone Station's Performance Enhancement Program.
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The system applies numerical ratings to the audit findings based on the consequence and complexity of the issue. Consequence includes a consideration of the impact on public and/or personnel health and safety. Complexity is based on breadth and scope, past performance, and the number ofjurisdictional entities involved in the resolution of the finding. The severity of both the consequence and complexity of each audit finding dictates the required line management response time. The licensee discussed examples of each severity category with the inspectors.
The inspectors verified procedural revisions to NEO 3.07, " Response to Audit Findings," and
Quality Services Department Instructions QSDI-AG-1.01, " Performance, Reporting, and Follow-up of Assessment Services Audits," and QSD-2.03, " Performance, Reporting and Follow-up of Surveillance Activities." The licensee plans to implement this system beginning
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March 1,1993. The inspectors noted the effectiveness of these changes have yet to be
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determined.
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7.0 EXIT MEETINGS During this inspection, the inspectors held periodic meetings with station management to discuss inspection observations and findings. At the close of the inspection period, the inspectors held an exit meeting on March 2,1993, to summarize the conclusions of the
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inspection. The inspectors did not provide the licensee any written material nor did they identify any proprietary information related to this inspection.
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