IR 05000219/1988013
| ML20195D171 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/14/1988 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20195D155 | List: |
| References | |
| 50-219-88-13, NUDOCS 8806230057 | |
| Download: ML20195D171 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION I
Report N /88-13 Docket N License N DPR-16 Priority -- Category C Licensee: GPU Nuclear Corporation 1 Upper Pond Road
'Parsipyany, New Jersey 07054 Facility Name: Oyster Creek Nuclear Generating Station Inspection Conducted: April 24 - May 21, 1988 Participating Inspectors: J. Wechselberger E. Collins W. Baunack 7 M. Markley i \
Approved By: .
! N .) 6L M ALcI S owgill, Chief, Reactor Projects Section 1A l'JlW C 'Date Inspection Summary: Inspection on April 24 - May 21, 1988 (Report No. 50-219/88-13)
Areas Inspected: Routine inspections were conducted by resident inspectors and a region-based inspector (237 hours0.00274 days <br />0.0658 hours <br />3.918651e-4 weeks <br />9.01785e-5 months <br />) of activities in progress including plant operations, physical security, radiation control, housekeeping, fire protection and emergency preparedness, including participation in the annual emergency exer-cise (see 88-05). The inspectors also reviewed licensee actions on previous open items from 87-24, Integrated Performance Assessment Team Inspections, made routine tours of the facility, witnessed routine surveillance activities and followed breaker troubleshooting activities for "A" CR0 and 1-2 service water pump breaker The inspectors also discussed the cathodic protection work activities with radio-logical control personnel and conducted a walk down of the core spray syste Results: One violation was identified in the radiological control area involving personnel violation of radiological work permit on the 119' elevation. The licen-see determined that two pump motor breaker problems resulted from a recent overhaul of the breakers, and has initiated corrective actio I 8806230057 880614 PDR ADOCK 05000219 Q DCD
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DETAILS 1.0 Radiation Protection (83724, 83726, 83727, 83728, 83729)
1.1 During entry to and exit from the RCA, the inspectors verified that proper warning signs were posted, personnel entering were wearing proper dosimetry, personnel and materials leaving were properly monitored for radioactive contamination, and monitoring instruments were functional and in calibration. Posted extended Radiation Work permits (RWPs) and survey status boards were reviewed to verify that they were current and accurat The inspector observed activities in the RCA to verify that personnel complied with the requirements of applicable RWPs and that workers were aware of the radiological conditions in the are .2 On May 4, 1988, the NRC inspector noted a Quality Control (QC) inspector performing fuel inspection inside a posted "Contaminated Area" on the 119 ft. reactor building elevation wearing an incomplete set of anti-contamination (anti-C) clothing. Specifically, it was noted that the only anti-Cs worn by the QC inspector were cotton glove liners and that other workers in tr.e same area were wearing full anti-Cs. The QC in-spector exited the area by stepping under the radrope posted barrie The NRC inspector questioned the QC inspector regarding his lack of pro-tective clothing and method of contaminated area access. The QC inspec-tor stated that where he was standing was clear and that the radiation protection (RP) technician could explain - indicating some degree of acceptability to the practic The NRC inspector stated that although he had not yet reviewed the app opriate Radiation Work Permit (RWP), it was unlikely that it afforded contaminated area access without additional protective clothin Discussion with the responsible RP technician indicated that he was un-aware of the QC inspector's radiological practices. The RP technician stated that he had not authorized the QC inspector to enter the contamin-ated area without complying with the clothing requiremeits of the RW When the NRC inspector and RP technician returned to the work location, the QC inspector was again inside the posted contaminated area without the required clothing. The RP technician took some smeacs of the speci-fic location where the QC inspector was standing. Results were less than minimum detectable activity (MDA). Review of radiological surveys indi-l cated that the roped off areas within the posting were contaminated (4,000 dpw). The work activities had a significant potential for gene-rating contamination due to the processing of handling tools in and out of the fuel storage pool. In addition to not meeting RWP dress require-ments, the QC inspector's access technique represents a high potential for the spread of contamination since he did not properly enter and leave the area at the step-off pa _ _ _ _ _ ___-____-______- ___ _- _ --__
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Subsequent inspector review indicated that the QC inspector had entered on RWP No. 880335, "Channel New Fuel /Rechannel Old Fuel". This RWP states that a surgeon's cap, cloth hood, one pair coveralls, cotton glove liners, multiple pair rubber gloves, and two pair cloth shoe covers are required for contaminated areas (i.e. full anti-Cs).
3 Later that day, the NRC notified licensee management and licensin; per- i sonnel of the apparent violation. On May 5, 1988, the licensee requested a meeting to discuss details of the incident. The licensee attributed the problem to be a breakdown in communication and failure of the QC inspector to heed new radiological postirjs installed when the fuel storage shield plugs were removed. During that meeting, the NRC also discussed concern about the number of licensee personnel associated with the fuel channeling evolution who observed the QC inspector's activities and failed to initiate corrective measures. The job supervisor, a Group Operating Supervisor (GOS), and several other operations personnel were present when the NRC inspector arrived at the work location. The re-sponsible RP technician was on duty but failed to identify the QC in-spector's RWP noncompliance and poor contamination control practice The licensee acknowledged the inspectors concern Technical Specification (TS) section 6.11, Radiation Protection program, t requires, in part, that procedures involving personnel radiation exposure shall be approved, maintained, and adhered to. Procedure 9300-ADM-4110.04, Radiation Work Permit (RWP), states in section 7.4.1 and Attachment 1 l that an individual's signature of the RWP signifies that the individual has read, understands, and will comply with the radiological requirements specifie Failure to dress in accordance with the minimum RWP clothing requirements constitutes an apparent violation of.the RWP procedure and TS section 6.11 (50-219/88-13-01).
1.3 The inspector met with radiological control personnel to discuss the drywell cathodic protection modification radiological concerns. The l licensee described the corrective actions they were taking in response '
to an apparent violation involving a failure to survey during cathodic 1 protection work in the torus room (50-219/88-11-01). Considering the i previous violations in this area, the inspector questioned the licensee if su'ficient training was being conducted for contractor radiological control personnel to ensure they were aware of previous lessons learned regarding failures to adequately survey nonuniform radiation field The licensee stated that they would review this concern. The inspector also asked about the acceptability of proceeding with the cathodic pro-tection modification during plant operation when the total man-rem dose for the job would be higher. The licensee stated that in order to meet their commitments certain work had to proceed now and that with proper
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surveys a similar event should not occu The licensee also stated that original man-rem estimates will be exceeded fer the cathodic protection
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modification. The inspector had no immediate concern l
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2.0 In-Office Review of Licensee Event Reports (LERs) (90712)
The following LERs were reviewed to determine whether the details were clearly reported, the causes properly identified and the corrective actions appropri-ate. The inspector also determined whether the assessment of potential safety consequences had been properly evaluated, whether generic implications were indicated, and whether the event warranted on site followu (Closed) 87-02: Main Steam Isolation Valve Closure Caused by Operator Error During a plant startup a control room operator erroneously placed an IRM range switch in range 10 while reactor pressure was less than 825 psig. This initiated a main steam isolation valve closure as designed. Corrective action consisted of operator training on this even (Closed) 87-03; Standby Gas Treatment System Initiation Caused by Power Supply Perturbation The standby gas treatment system initiation r esulted from a radiation monitor power supply perturbation. The parturbation resulted from the power supply ribbon cable shorting. The shorting was attributed to equipment aging. Re-placement ribbon cables have been ordered, also an improved design power supply will be installed for all radiation monitor (Closed) 87-04; Technical Specification Violation Caused by Improper Removal of Equipment from Service Due to Personnel Error The root cause of this occurrence was personnel error in that operations man-agement, the senior reactor operator, and the shif t technical advisor on shift did not recognize the Technical Specification violation in the planned tag-out of equipmen Corrective action will consist of operator and shift technical advisor trainin (Closed) 87-05; High Flux Scram Ouring Recirculation Pump Start Due to Discharge Valve Partially Open The APRM high flux scram occurred due to increased recirculation flow as a result of starting a recirculation pump with a partially open discharge valv The valve was partially open as a result of improperly closing the valve after experiencing torque switch problems. Additionally, mechanical regulator problems were experienced following the scram. All five recirculation pump discharge valve torque switches were adjusted and the limit switch for valve close indication was adjusted to indicate full valve closure. Also the pro-cedure for calibration of the mechanical pressure regulator was revise (Closed) 87-06; Technical Specification Violation Caused By Improper Storage of Higher Enriched Fuel Due to Personnel Error Reload fuel bundles exceeding the technical specification allowable (3.19 v .01 wt% U-235) were temporarily stored in the fuel pool. The cause of the event was personnel error in not performing a thorough safety analysis. Cor-
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rective action will consist of revising the technical specifications to raise the enrichment limitations on stored fuel and reviewing the occurrence with engineering personne (Closed) 87-07; Backup Sample Analysis Invalid Due to personnel Error With the radwaste liquid radiation monitors inoperable a release sample was taken prior to the start of a release and one near the end of the release, as require During the analysis of the second sample a chemistry techaician inadvertently used the wrong comouter program, and the sample was lost. The event was reviewed with the chemistry technician and the computer program changed to preclude inadvertent selection error '
(Clos _ed) 87-08; Limiting Safety System Setpoint For Total Recirculation Flow Exceeds Technical Specifications Due To Instrument Drift During the performance of a weekly surveillance test a flow converte) scram setpoint was found to be out of specification (118% vs.117%). The setpoint was adjusted to within limit The apparent cause of the condition was in-strument drif (Closed) 87-09; Operation of the Plant with the Flow Biased Scram and Rod Block Setpoints Outside of the Analyzed Region Due to Recirculation Loop Flow Back-flow This was a voluntary report submitted by the licensee and described a recir-culation pump trip without alarn. Recirculation flow remained relatively constant due to increased flow of the four remaining recirculation pumps and the reverse flow through the loop with the tripped pump. This caused the flow biased average power range monitor setpoints for the scram and rod block set-points to be less conservative than allowed. The root cause of this event was inadequate preventive maintenance and testing of equipment associated with the recirculation pumps. Subseauent transient analysis determined the in-creased setpoints did not cause the safety limits of the reactor to be vio-lated for any postulated transients or accidents. Tha components that caused the loss of the generator field were replaced. The preventive maintenance program for equipment associated with reactor coolant pumps will be improve The safety analysis performed for this event will be reviewed for inclusion in the next annual revision to the updated Final Safety Analysis Repor .( Closed) 87-11; High RPV level Trip / Scram Caused by Lost Feedwater Flow Signal Due to Procedural Inadeqtacy A reactor scram occurred as a result of a high reactor water level turbine tri The high reactor water level was caused when a technician moved a con-trol room panel wire harness which inadvertently disconnected a feedwater flow signal wir The feedwater level control system responded to the apparent loss of flow signal and increased feedwater ficw until the turbine tripped on high reactor water leve The cause of the event was faulty wire termina-tions. Corrective actions consisted of revising the installation specifica-
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tiens for wire terminations and the Quality Assurance Procedure for inspectian of wire terminat'ons.. Also, approximately 51,000 wire terminations were in-spected and all deficiencies correcte Although no supplemental report was indicated on the original LER a revised LER was submitted which identified an automatic main steam isolation valve closure which occurred 12 days after the scram and was attributed to the same cause. The licensee's tendency to incorporate two reportable events into one report had been previously discussed with the license (Closed) 87-10; Electrical Transient Causes Containment Isolation and Standby Gas Treatment Initiation Oue to Design Configuration Heavy snowfall caused a transient on distribution lines outside the plan the voltage transient caused vital power panels to transfer to their alternate power supply. The transfer caused reactor protection system relays to de-energize causing the containment isolation and standby gas treatment system initiatio Several modifications to correct this condition are being con-sidere .( Closed) 87-12; Inoperable Offgas Drain Line Isolation Valve Caused by Debris Accumulation Oue to Inadequate Preventive Maintenance The off gas system drain line isolation valve failed in the open direction due to debris buildup in the bonnet. The valve was removed and replace To prevent recurrence the valve has been placed on the plant's preventive maintenance progra (Closed) 87-13: SGTS Initiation Caused by Improperly Installed Wire Connector Due to Personnel Error A secondary containment isolation and standby gas treatment system initiation occurred when an electrical connector fell off a recently replaced instrument power supply to several area radiation monitors. The connector on the power supnly was reattached securely, and the connectors on other power supplies also secured to prevent similar problem (Closed) 87-15; Inoperable Intermediate Range Monitors Due to Broken Flexible Connection Caused by Improper Maintenance Improper maintenance of detector drive mechanisms resulted in excessive vibra-tion which resulted in flexible conductor failures. The controlling procedure did not provide proper guidance for maintenance of the detector drive mech-anisms to minimize vibration. Seven IRMs and three SRMs were replaced and repairs and tests were performed un the drive mechanisms. Maintenance proce-dures will be revised and training will be given to technicians working on )
IRMs and SRMs. The preventive maintenance for drive mechanisms will be im-prove (
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(Closed) 87-14, Rev. 1; Drywell Isolation Caused by Incorrectly Lifting a Lead Oue to Using a plant Drawing Which Had Not Been Updated With an electrical lead termination repair in progress an electrician lifted a lead supplying power to the containment high range monitoring system. This caused a containment vent and purge valve isolation. The root cause of the event was a configuration control process deficiency caused by a backlog of documentation awaiting final closeout following system modification. A re-vision to the computerized configuration control system procedures has been implemented. Also, procedures will be revised to require a summary of all drawing changes resulting from a modification to be available at the time the modification is turned over to the plant divisio (Closed) 87-16; Setpoints for-Three of Eight Isolation Condenser Pipe-Break Sensors were Out of Specification Oue to Instrument Drif t During routine surveillance testing three of eight isolation condenser pipe break sensors had drifted above the setpoint specified in the Technical Speci-fications. The cause of the failure is attributed to instrument drit The sensors will be replaced as part of an integrated reactor system upgrade be-ginning during the next refueling outage. This upgrade is being tracked as part of the Integrated Living Schedul (Closed) 87-18; Reactor Building Ventilation Valve Inoperable for Maintenance and not Secured Closed Due to personnel Error While removing a reactor building ventilation system valve from service an operator closed the valve manually but failed to engage the linkage from the hand wheel. The condition was discovered when returning the valve to servic During the event a redundant isolation valve was operable. Corrective actions include operator training, providing procedural guidance for manual valve operation, required reading, and providing pins locally for manual valve operatio (Closed) 87-19; Limiting Safety System Setpoint for Total Recirculation Flow Exceeds Technical Specifications Oue to personnel Error The reactor recirculation flow scram setpoints were left above the technical specification limiting safety system setpoint due to improper pe*formance of a surveillance procedure. The technician responsible for this event will have his qualification reviewed and his previous work will be checked. The sur-l veillance procedure will be revised, instrument technicians will be required to read a critique of this event and this LER. Further, they will be required to read the revised procedure for the proper technique for setpoint verifica-tion and adjustment.
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(Closed) 87-20 L echnical T Specification Required Surveillance Overdue Oue to Inadequate Shift Turnover Caused by Personnel Error The performance of the daily operability check of the main steam isolation valves was postponed due to evaluating an unusual noise in the vicinity of the high pressure turbine. The postponement was not logged nor passed on to the oncoming shift. The shift supervisnr wa. counselled, the incident will be discussed with each shift during the weekly plant status update meeting, and discussion of the incident will be included in regular licensed operator trainin In addition, required reading will be issued to operators to em-phasize the need and requirements for documenting the postponement of sur-veillance test _(Closed) 87-21; TechnicallS ecification Violation Caused by Blocking Open Containment Vacuum Breakers Due to Personne1 Error The review of this event is documented in NRC Region I Inspection Report 50-219/37-1 { Closed) 8/-22; Plant Shutdown Required by Incperable Acoustic Monitor Due to Marginal Splice Design Resulting in Cable Damage During Installation The acoustic monitor cable failure resulted from cable damage during instal-lation due to a marginal splice design. The splice was repaired and all others tested. Spare acoustic monitors were installed which can be connected from outside the drywell. Long term corrective action has included the re-placement of the splices using connectors qualified under 00R guideline (Closed) 87-23; Partial Primary Containment Isolation During Testing Due '
to Procedural Inadequacy A partial primary containment isolation occurred during surveillance testing because the surveillance test had not been revised to reflect two modifica-tions to the plant. The affected procedures and both modif katiens will be reviewed to ensure both modifications are reflected where necessary. This report will be required reading for engineering and operations personne Guidance will be p: ovided to improved engineering reviews of modification .(Closedl 87-24; Failure to Post a Fire Watch for a Non-Functional Fire Barrier Due to Personnel Error in Failing to Follow Procedure Fire barrier material was removed by contractor personnel without notifying the control room. The cor. tractor personnel were not adequately briefed or supervised nor provided with the job package work instructions for the fire barrier removal. Immediate corrective action was to ensure a fire watch was posted. Further corrective actions include job supervisor training, requis ed reading, and improved instructions to contractor _ __ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ .
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(Closed) 87-26; Temporary Variations Found Unacceptable Due to Inadequate Safety Reviews The cause and corrective actions associated with this report are described in LER 87-2 {_ Closed) 87-27; Electrical Storm Induced Containment Isolation and Standby Gas Treatment System Initiation Due to Automatic Bus Transfer Time Exceeding RPS Relay Dropout Time An automatic bus transfer caused by a lightning strike caused several reactor protection system relays to deenergize, causing a containment isolation and standby gas treatment system initiation. To prevent recurrence, GPUN engi-neering has proposed that the power supply for the affected relays be changed to an existing rotary-inverter fed continuous power source. Pending corporate management approval, this will be accomplished during a future outag (Closed) 87-28; Main Steam Isolation Valve Closure Caused by Design Deficiency During Surveillance Test The root cause of the event is that the circuit which was being tested is not configured to facilitate testing. Contributing causes were the jumpering technique of the technician and failure of the control room operators to fully investigate a suspected actuation. This report will be made required reading for instrument technicians, electricians, Plant Engineering Department engi-neers and operators. Also, modifications to facilitate testing are being evaluate (Closed) 87-29; High Reactor Pressure Scram Due to Air. Leak from Dislodged Air Test Pilot Valve Caused by Incorrect Mounting Cap Screw Length The cause of this event is the air test pilot valve mounting cap screws were 1/4 inch shorter than vendor specifications. The dislodged air test pilot valve and all other MSIV air pilot valves were reinstalled with proper length cap screws. The MSIV air pilot valve installation procedure will be revised to identify the proper length screws for future maintenanc (Closed) 87-30; lightning Arrestor I_nsulator Failure Induced Voltage Transient Caused Containment Isolation and SBGTS Initiation Due to Automatic Bus Trans-fer Time Exceeding RPS Relay Dropout Time l
This event is similar to that described in LER 87-2 The corrective action is described in that repor _ _ _ _ ._ .. __ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _
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(Closed) 87-31; Violation of High Radiation Area Technical Specifications Caused by Personnel Error During Response to Fire Alarm During the response to an automatic fire alarm a high radiation area was entered without following proper access procedures. Corrective actiens in-clude operator training, provision of monitoring equipment to operations per-sonnel for emergency use, and review of this event with all operators and their supervisor (Closed) 87-32; A0G H2 Analyzer Not Calibrated in Accordance with Tech Spec Requirements Due to Inadequate Review of Rets Amendment The Augmented Offgas System H2 analyzer had been calibrated using a stand **1 gas sample of a known volume of H2 in air rather than in N2 as required Technical Specifications. The Technical Specification had been recently .;-
sued. Previously the calibration had been performed using a standard sample in ai For corrective action this LER will be required reading for all in- ,
volved departments to stress the importance of a thorough review of plant l procedures and practices for compliance with Technical Specification change Also, Oyster Creek licensing management has altered its policy and is issuing licensing action items for tracking requisite procedure changes resulting from Technical Specification change i 3.0 On-Site Review of an LER (92700)
The following LER was reviewed to determine whether corrective actions de-scribed in the report were addressed and whether these actions were appro-priate to correct the cause of the event. Also, the LER was examined to verify if reporting requirements were met, if licensee. review and evaluation were complete and accurate, and if generic implications existe (Closed) 87-01; Absence of Neutron Flux Control Rod Block Clamping Circuit Due to Inconsistency Between Technical Specifications and Plant Hardware Technical Specifications (TS) change No. 111 required a limit to the neutron flux control rod block setpoint at 108% of rated neutron flux for reactor re-circulation flows of 100% or greater. When procedure changes accommodating
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the new TS change were being reviewed it was discovered, by the licensee, the
average power range monitor unit hardware did not have the capability to meet the new setpoints. Specifically no clamping circuit existec to limit the rod 3'
block setpoint at 108% power at 100% or greater recirculation flow l On site documentation shows : lose communication relative to this matter was )
maintained with NR The licensees' corrective action consisted of admini-
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, stratively requiring operators to manually insert a rod block at 100% reeir- {
culation flow. Inspectors verified the power Operation procedure had been changed to include this requirement. Also, a tag has been placed on the con-sole reminding operators of the administrative requirement. Residents rou-tinely monitor the rod block insertions when required. No deficiencies have been noted.
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Licensee records also show a review of all surveiliance tests against tech-nical specification requirements was conducted by the Plant Analysis Section.
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Several deficiencies were noted and corrective action was take '
The overall evaluation of the LERs discussed in the above paragraphs has been documented in the last SALP Report No. 50-219/86-9 .0 Followup to a Previous Inspection (92701)
l Ouring the period August 10, 1987, to August 21, 1987, an Integrated Perform-
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ance Assessment Team inspection (Inspection Report No. 50-219/87-24) was con-ducted at the Oyster C,eek Station. This team inspection identified a number of areas needing management attention. Several of these areas were responded to by the. licensee in a letter dated January 15, 1988, P. 8. Fiedler, GPUN, to W. F. Kane, NRC. Other items the team considered significant enough for NRC followup are identified in the report as either weaknesses or observation This followup is tracked as open item 50-219/87-24-0 '
During this inspection the licensee's action to address certain tf the in-spection teams findings were reviewed. Licensee actions relating to radio-
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logical controls have been reviewed in NRC Inspection Report No. 50-219/88-1 !
The specific items for which a followup was conducted are identified by the item description and the page on which they appear in Inspection Report N /87-2 (Closed) Observation - Page 4; Overtime authorized by the Operations Manager instead of the Director of Operations or higher as required by procedure 10 '
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A memo (2100-87-2047W/34) was issued from the Plant Operations Director to ,
operations managers which re-emphasized that all overtime in excess of Pro- l cedure 106 requirements must be approved by the Plant Operation Director or by a higher level of management, j (Closed) Observation - Page 5; The team found that the supervisor of the STA's does not regularly visit the control room, nor does he review STA log Discussions with personnel indicate the supervisor of the STA's now visits l
the control room daily. A review of the STA Log Book shows the supervisor of the STA's now initials the log following his review. A memo written in response to a Licensing Action Item also specifies occasional visits to the
! control room by the Manager, Plant Analysis and Human Engineering, and the Director System Engineerin ,
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(0 pen) Observation - Page 6; Management attention in educating the non- '
licensed worker level understanding of risk importance, and in establishing !
operations as a lead proponent of that philosophy is neede The licensee responded to this item in writing. The Licensing Action Item I associated with this finding is due to be completed August 30, 198 l
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(Closed) Observation - Page 7; Operations management to evaluate the practice of operations using an attachment from a controlled control room copy of a surveillance test prc,cedur Discussions with operators show that planned surveillance test procedures are sent to the control room complete with all required forms. Forms from' con-trolled procedures are only used when tests are performed for an unexpected reason; then th3y are promptly replaced. The inspector observed that an ade-quate supply of various forms are neatly stored in newly installed bins in the control' room. Forms for frequently performed surveillance tests were also observed to be filed in the control roo Operators have been instructed to use forms from controlled procedures only when more forms cannot be obtained on short notic (Cicsed) Observation - Page 7; A formalization of the control of operator aids !
(information posted in plant to assist the' operators) is neede Steps were taken to remove all non-controlled operator aids by February 29, 1988. Also, Procedure 106 has been revised to specify the control of operator aids. The procedure change was noted to provide clear detailed instructions i for the control of these aid These controls are applicable to all depart- l ment i (Closed) Observation - Page 8; Management needs to instill more a more ques-tioning attitude concerning non-routine plant condition .
l Management has taken a number of initiatives to increase personnel attention i to non-routine plant conditions. These include changes to the tour sheet, emphasizing these aspects in nightly instructions to personnel, added manage-ment tours, improved equipment operator (E0's) training to stress their ac-countabilities especially related to tours. Shift supervisors have toured the plant with E0s to help identify typical problems and daily interaction between operations management and the shifts. Based on discussions with the Plant Operations Director, management will continue to strive for improvement in this are (Closed) Observation - Page 9; Although the procedure directs the GSS to con- l duct critiques of operational events, the operations staff typically prepares !
the critique repor The licensee believes the critique process to be sound. Procedure 106 directs the GSS to conduct a critique to gather pertinent information. This informa-tion is reviewed by the GSS with operation staff and personnel involved in the incident. A designated operations staff member then prepares a repor ,
l This method is believed to produce adequate review and documentation of an event and is not in conflict with any procedure. A recent revision to Proce-dure 106 (revision 46) includes a requirement to prepare reports within ten days of the event and a requirement to track progress on recommendatio ..
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(0 pen) Observation - Page 10; The team found that the Plant Review Group is apparently under utilized by virtue of the fact that the group essentially meets only to review LERs and very few other event This item was not reviewed during this inspectio (0 pen) Weakness - Page 11; The team noted larger plant equipment was not pro-perly labele The licenset is actively working on the labelling of plant equipment. A standard for labelling is being prepared which will provide guidelines for upgrading labels and for providing new labels. This item will be closed when the labelling standard is issue (Closed) Observation - Page 11; The licensee to address the unique difficulty in verifying the proper position of throttled valves and valves in contamin-ated area The licensee has revised Procedure 108, Equipment Control, to provide specific instructions for verifying that valves in inaccessible areas and throttled valves are properly positione (Closed) Weakness - Page 12; The control of gas bottles, equipment on rollers, temporarily stored equipment, and ladders was noted by the team as requiring attentio The licensee has issued Procedure 119.5, Loose Equipment Storage, which pro-vides instruction for the storage of loose equipmen (Closed) Observation - Page 12; The team noted uncontrolled signs and infor-mation in the plant which they felt may lead to personnel errors and indicate a degree of informality in conducting operation The licensee has removed all uncontrolled material from the plant. A revision to Procedure 106, Conduct of Operations, provides instructions for the control of operator aids. Also, Procedure 108, Equipment Control, specifies in detail the required use of tags, in addition, the standard for labelling when it is issued should completely resolve the issu (Closed) Observation - Page 13; The team noted that the reactor building inner equipment airlock door was being kept open when the airlock was not in us Routine resident inspections have verified the inner airlock door is now being maintained close Routine licensee tours verify the door is being maintained closed and a sign is currently being made up which requires that the door be kept closed when not in us (0 pen) Weakness page 15; Housekeeping in the more inaccessible areas of the plant and inattention to detail in housekeeping of accessible plant area re-quires an increased concerted management effort and is currently a weaknes . -- . .. . .-. .-
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In reviewing this item che inspector looked at Station Procedure 119. House-keeping, and determined that presently a Maintenance Construction and Facili-ties housekeeping procedure is being developed and that the current station housekeeping procedure is being cancelled. The inspector discussed this with
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senior licensee management who was unaware of housekeeping procedure changes
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item will be reviewed af ter the housekeeping procedure e.hanges are complet l (Closed) Observation - Page 26; Licensee to formalize the specific lifted lead i identification in the TSSIIL progra The licensee for each TSSIIL Calibration which requires-leads to be lifted s
has developed a Supplemental Data Sheet which identifies the leads to be ;
lifted and provides for the verification of the lifting and the reinsta11ation .
1 of these leads. Supplemental Data Sheets have not yet been prepared for all i calibrations. However, until the program is complete when a calibration comes
- due which requires a lifted lead prior to performing the calibration a Sup- ;
piemental Data Sheet will be prepare '
(Closed) Weakness - Page 26; Instruments in the new radwaste building were not yet incorporated into the preventive maintenance progra !
Plant Materiel has developed 66 PMs which incorporate 368 instruments. Ap-proximately 20 additional PMs remain to be completed. The expected completion date for all PMs is September 1, 198 (Closed) Observation - Page 27: The team felt the changeover of the instrument
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calibration laboratory from two experienced contractor personnel and one lic-ensee person to all GPUN personnel may degrade the laboratory's capabilit ;
In bringing about this change GPUN retained the lead contractor, trained two
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GPUN I&C technicians in metrology, added one calibration supervisor from TMI i and retained one contractor during the t.ransition. The licensee indicated !
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(0 pen) Weakness - Page 29; The team noted that with the licensee's matrix type organization and complexity of the MCF work planning procedures an extra-ordinary paperwork burden is placed on personnel performing work. The indi-
, vidual job foreman becomes heavily involved in administrative duties which i
detract from time spent actually supervising work activitie In response to this item MCF has formed a "Work Simplification Committee".
The charter of this committee is to reduce the paperwork burden on job super-visors and planners. The inspector reviewed a memorandum which described the results of a meeting of the work simplification committe This memorandum described procedure changes and other actions which are being undertaken in I J order to reduce the paperwork burden. This item will be further reviewed when 3 more of the committee's actions become finalized.
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(Closed) Observation - Page 34; The team was concerned about the wark ethic in the workshop. Apparently, worker- are discouraged from returning to the workshup, even if a job has been completed, until the end of the work da The team was concerned that this coula adversely impact on the ALARA progra The licensee has talon a number of actions in response to this item. A two day Radiological Awareness Training was initiated for all MCF personnel. Ten of these training sessions have been completed. Among the training objectives are individual action to reduce exposure, minimize peer exposure, improve the work environment, and promote team work with Rad Co Increased management tours and increased involvement and support by a re-organization of MCF to bette' support the field work through fewer levels of management, and an organization that will better identify the craf ts direct supervisor for guidance and direction has also been implemented to bring about improvement in tais are (Closed) Weakness - Page 36; Based on findings relative to procedures for mini-mods and engineering calculations the team concluded there is a lack of appreciation of the need for clear and effective administrative controls for Plant Engineering activitie A Plant Engineering Procedure No. 124.2, Control of Plant Eng:neering Directed Replacements and Modifications, has been issued which ixplements the require-ments which had previously been established by the Technical Functions Divi-sion relative to the modification control process. Also, plant engineering procedures have been revised to require the use of EP-006, Calculations, and EP-009, Design Verificatio (Closed) Observation - Page 34; The team found that mechanical workers did not appear to have the confidence of plant management and the licensed opere-tor This item was discussed with both Operations and MCF management personne The observation was felt by the liceasee to have some merit, and ongoing steps are being taken in an attempt to improve tne confidence level between manage-ment, operations, and the mechanical workers. The training identified in a previous item stressed making management more available to the mechanical workers. Improved communications have been established through the daily 2:30 p.m. meeting involving operations and MCF. Improved training for me-chanical maintenance petsonnel is being implemented by taking an existing building and converting it to a mechanical maintenance training center. One of the benefits of the improved training should be improved mutual confidence among the various groups. Also, additional personnel Mechanical Maintenance Technicians are presently being recruited to improve the technical competence of the maintenance workers. Management's awareness of this condition, che steps taken to date and those being planned are considered to be the justif t-cation for closing this ite _ _ __ ___ ______
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(Closed) Observation - Page 37; The team believed that tighter control over temporary variations is needsd and understood that a ma;or revision to the equipment control procedure will be implemented shortly. The major revision to Procedure 108, Equipment Control, was implemented on February 28, 198 (Closed) Observation - Page 37; Some Plant Engineering personnel seemed to be bogged down with routire maintenance of plant procedure To reduce the amount of time spent by Plant Engineering personnel maintaining procedures all General Plant Operating Procedures (75 procedures) and all Plant Systems Procedures (139 procedures) have been tran.! erred to Operations.
, (Closed) Weakness - Page 37; Safety-related instrument setpoint calculations are not addressed by either Technical Functions or Plant Engineering Proce-dure On December 28, 1987, Technical Functions issued Procedure ES-002, Instrument Error Calculation and Setpoint Determination. This procedure describes a uniform method for establishing setpoints for instrumentation channel (0 pen) Observation - Page 38; Licensee to clarify FSAR with regard to commit-ments to Regulatory Guide Licensee Action Item 87215.12 was issued to the licensing group to respond to this ite The completion due date for this item had been February 8, 1988, but was extended to May 30, 198 (Closed) Weakness - Page 38; The QA group is not intimately involved in the day-to-day activities conducted by Plant Engineerin QA Engineering in conjunction with Operations QA has instituted an engineering monitoring program. A review of a QA Task Status Log shows that monitoring in the following areas has been conducted or is scheduled to be conducted by June 30, 1988: Mini-Mods, GPUN Drawings, Design Verification, Modifications and System Design Descriptions, Calculations, Inservice Test Program Admini-stration, and Installation Specification (Closed) Observation - Page 39; The team believes a formal commitment to the system engineers program needs to be mad A formal program description has been developed for the system engineers which establishes responsibilities, training requirements, interdepartmental inter-faces, formal system engineer certification process, and schedule for imple-mentatio (0 pen) Observation - Page 40; This item deals with training provided to Re-sponsible Technical Reviewers, Independent Safety Reviewers, and personnel who prepare safety evaluation The review of this item was not completed during this inspectio .
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1 (0 pen) Observation - Page 40; The Plant Review Group is infrequently used ,
during the review of complex safety issue '
This item was not reviewed during this inspectio (0 pen) Ooservation - Page 41: The team noted that the disposition of certain hydraulic control unit (HCU) bolting discrepancies were not well documented and that better documentation and traceability of the disposition of various evaluations as they are performed would lead to more efficient resolutions of questions in the futur The licensee's initial evaluation of this item confined itself to only the HCU issue and did not address the broader issue noted in this observatio The licensee indicated a new Licensing Action Item would be issued to fully address this item. The licensee's complete resolution of this item will be reviewed during a future inspectio (Closed) Observation - Page 42; In evaluating observations relative to inter-faces the team identified the following: The Technical Functions-Rad Con interface needs improvement of the ALARA estimates for long-term job planning and more timely provision of outage !
job information from Tech Functions for on-site Radiological Engineering i review. Initiatives to improve the Technical Functions-Rad Con inter-faces include:
(1) Formal reviews of preliminary and final engineering packages with Rad Con and other interfacing disciplines via the PEDR and EMCR meeting (2) Releasing engineering packages for construction at least six months prior to outage start. Achieving this goal should provide MCF and '
Rad Con required lead time to properly plan the wor ,
(3) Assigning an experienced individual to Technical Functions to pro-l vide direct input on ALARA matters and to facilitate the interface J
with Rad Con personnel.
' Plant Engineering should be consulted earlier in the review of plant problems. Also, system engineers should be more involved in surveillance test results review and in the performance of major test Plant Engineering attends the "Plan of the Day" meeting; each maintenance or construction project is reviewe If problems are identified, they are brought to the attention of Plant Engineering at that time. In ad-dition, Plant Operations chairs a 2:30 p.m. meeting daily which preplans all MCF work; potential problems are forwarded to Plant Engineering dur-ing the meeting. Also the System Engineering Program Description de-scribes the system engineers' involvement in surveillance !
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18 Health Physics technician work hours do not conform to those of other site workers, creating problems in continuity of work and HF coverag Rad Con, Operations. and MCF shift rotation schedules have been synch-ronize (0 pen) Observation - Page 43; The team believes that if management insists on a more universal understanding of their philosophy certain problems can be eliminate The licensee's completion of this item had been extended several time The current completion date is May 15, 198 (0 pen) Observation - Page 43; Management goals not as well understood at lower levels than at higher levels of managemen The licensee's completion of this item has been extended. The current com-pletion date is May 30, 198 (0 pen) Observation - Page 43; Improvement is needed in the areas of risk per-spective and understanding the design basis of the plan This item was not reviewed during this inspectio (0 pen) Observation - Page 44; The team felt it would be prudent to have con-tinuing feedback from reviews of the long-term programs to determine what ad-ditional real time improvements need to be applied until each program is fully and successfully implemente This item was not reviewed during this inspectio The above review closes open item 50-219/87-24-0 The remaining open items identified above will be tracked as open item 50-219/88-13-0 .0 Engineered Safeguard Feature System Walkdown (71710)
On May 16 and 17, 1988, inspectors performed a walkdown of the accessible portions of Core Spray System I. During this walkdown the inspectors verified l that the system valve lineup was in agreement with the Process and Instrumen- I tation Diagram (P&ID), the P&ID was in agreement with as-built conditions in I the field, and the lineup of the system was in accordance with the current system operating procedure. During these verifications the inspectors iden-tified that one electrical breaker identified in the system electrical lineup was labeled in the plant a "spare" and was in the "off" positio This breaker provided electrical power to system instrumentation. As a result of this the inspectors verified through observation that the instrumentation was energized and presented this concern to operations managemen It was determined that this breaker supplied multiple plant systems and that this power supply had been moved to another instrument panel during Appendix R l
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modifications. As a result of this modification, plant operating procedures had been updated to reflect the current plant configuration, but Station Pro-cedure 308, Emergency Core Cooling System, had not been update The inspec-tors verified that another system electrical lineup incorporated this breaker, and the inspectors verified that the breakers was correctly "checked and verified" to be in the proper positio The licensee subsequently reported that a procedure change had been submitted to Station Procedure 308 in order to specify the correct electrical lineu The inspectors identified other minor discrepancies to the licensee that were not of a safety concer In addition, the inspectors determined that house-keeping in the vicinity of Core Spray I was satisfactor .0 Monthly Surveillance Observations (61726)
6.1. On May 21, 1988, the inspector observed the complete performance of Sur-veillance 602.4.002, Main Steam Isolation Valve (MSIV) Closure and In-Service Test (IST) by Plant Operations department. This surveillance required completely closing each MSIV, one at a time, and timing the valve stroke time in the open and close direction. In addition, the correct response of the Reactor Protective system (RPS) was verifie The inspector verified the surveillance procedure was properly approved, the current revision was used, prerequisites were met, the procedure met technical specification requirements, and that test results met technical specification requirement No safety concerils were identifie .2 On May 18, 1988, the inspectors observed partial performance of Surveil-lance 607.3.002, Containment Spray Automatic Actuation Test. One in-spector observed performance from the control room and the 7ther observed i performance from locations in the plant. The inspector verified that l the procedure was correctly approved, the current revision was used, and that the performers were qualified. No safety concerns were identifie .3 On May 4, 1988, the inspector observed the surveillance specified by Procedure 604.3.020, "Drywell H202 Analyzer Surveillance performed by the I&C department, licensee personnel initiated the surveillance at approximately 10:00 a.m. after securing the necessary authorization Some "As found" hydrogen indications were outside the specified accept-ance criteria for the "A" channel. Appropriate adjustments were made on the analyzer panel located on the 75 ft. reactor building elevatio The inspect - observed "As Left" indications to meet procedure acceptance criteri No anomalies were identified on the 'B" channel. Inspector evaluation of documentation submitted for supervisory review indicated that "As Found" deviations were appropriately documented in the surveil-lance procedure and in a deviation report. The inspector had no further question .
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7.0 Plant Operational Review (71701, 62702)
7.1 Routine tours of the control room were conducted by the inspectors during which time the following documents were reviewed:
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Control Room and Group Shift Supervisor's Logs;
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Technical Specification Log;
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Control Room and Shift Supervisor's Turnover Check Lists;
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Reactor Building and Turbine Building Tour Sheets;
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Equipment Control Logs;
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Standing Orders; and,
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Operational Memos and Directive .2 Routine tours of the facility were conducted by the inspectors to make an assessment of the equipment conditions, safety, and adherence to operating procedures and regulatory requirements. The following areas are among those inspected:
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Turbine Building
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Cable Spreading Room
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Diesel Generator Building
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Reactor Building The following additional items were observed or verified: Fire Protection:
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Randomly selected fire extinguishers were accessible and in-spected on schedul Fire doors were unobstructed and in their proper positio Ignition sources and combustible materials were controlled in accordance with the licensee's approved procedure Appropriate fire watches or fire patrols were stationed when equipment was out of service.
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Jumper and equipment mark-ups did not conflict with Technical Specification requirement Conditions requiring the use of jumpers received prompt licen-see attentio Administrative controls for the use of jumpers and equipment mark-ups were properly implemente Vital Instrumentation:
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Selected instruments appeared functional and demonstrated parameters within Technical Specification Limiting Conditions for Operatio Housekeeping:
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Plant housekeeping and cleanliness were in accordance with approved licensee program ,
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The inspector observed that a small amount of lubricating oil was leaking from a Control Rod Hydraulic (CRD) pump and was dripping onto Core Spray pump 'A' motor and associated piping. .
This condition was identified to the licensee who took correc-tive action to clean the area and also to initiate the work request to correct the CR0 oil leak. The inspector concluded there were no immediate safety concerns or fire hazards as-sociated with the oil lea No inspector concerns were identifie .3 The inspectors reviewed the licensee's efforts to troubleshoot the 1-2 service water pump breaker after the pump initially failed to start on May 17, 198 The operators were successful in starting the pump on a
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subsequent attempt, but after discussions with Plant Engineering chose to declare the pump inoperable. Starting the pump after an unsuccessful l
attempt may give operators the confidence that the pump is available but could hinder further investigation efforts in determining the root cause.
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l Operators may be concerned regarding the availability of a particular piece of equipment, but this should be weighed against consideration for future troubleshooting of the equipmen The inspectors' review of the licensee effort to investigate the problem indicated that the licensee was conducting a thorough evaluation of 1-2 service water pump breaker failure. This effort included the removal 1 l
of the installed breaker for examination by the vendor and the installa- l tion of a spare breaker which had been previously upgraded by the vendo The breaker originally installed had been overhauled by the licensee I
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under the vendor's supervision. The licensee determined that this was the first AKA-25 breaker maintained under a 5 year overhaul program and that the trip shaft was not installed correctl At the conclusion of the report period the licensee was examining the three other AKA-25 breakers that had recently been overhauled and had declared the 1-2 service water pump operable. The inspector had no fur-ther concern .4 The inspectors reviewed maintenance activities on the "B" recombiner in the Augmented Offgas (A0G) building during the report period. The "B" recombiner had experienced vibration problems and the icensee was in the process of conducting post maintenance te!. ting (PMT) when three me-chanics were contaminated. The workers were contaminated as a result of noble gases and daughter products released from the "B" recombiner during PMT. Skin contaminations resulted from short lived particulate; the highest reading measured was 7000 counts on one individual's hea The individuals were showered and released after a short time. The lic-ensee stopped work on the job until the maintenance activity could be properly evaluated. The licensee rewrote the PMT procedure to preclude a dead leg pipe from emitting noble gases after a system air purge was conducted. This dead leg section of pipe released the noble gases during the previous PMT activity that contaminated the worker Further PMT was conducted using the revised procedure without a similar occurrenc The inspectors concluded that the original PMT procedure was not adequate to prevent the worker contamination from the dead leg section of piping and that supervision needed to be more closely involved to ensure that the PMT procedure cegld be implemented without problems. When supervi-sion became involved an adequate PMT procedure was developed and the PMT of the "B" recombiner was effectively conducte .5 The inspectors reviewed Station Procedures 328.1, Battery Room "C" HVAC, and 340.3, 125 Volt DC Distribution System "C". Station Procedure 32 indicates that "C" Battery Room temperatures should be maintained at approximately 60 degrees F or greater during all modes of operation while Station Procedure 340.3 requires "normal battery room ambient temperature should be maintained at approximately 77 degrees F. Minimum and maximum temperatures are 50 degrees F and 104 degrees F respectively." The in-spectors reviewed these procedures with the licensee, who stated that they would review the procedures for accuracy. The inspector was con-cerned that two different procedures specified different requirements for the same parameter. Inspection report 88-04 discusses a similar I
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situation with differential pressure opening requirements for the MSIV' I l
The inspector did not consider this as significant since a minimum tem- !
perature of 50 degrees F ambient temperature is adequate to maintain
, battery operabilit .6 The inspector reviewed the increase in drywell equipment drain tank pump (0WEDT) run times and followed the licensee's action to electrically l backseat the "A", "B" and "0" recirculation pump discharge valves. The l l
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"E" recirculation pump discharge valve had already been backseated while the "C" valve remained unbackseated, The backseating was effective in decraasing the DWEDT pump run times which is an indication of identified leakage trends. The inspector had no concern ,7 On May 21, 1988, the licensee reduced load to less than 40% to conduct an MSIV full closure surveillance and other maintenance activities. The inspector witnessed portions of these activitie In addition to MSIV surveillance, the licensee conducted maintenance on the "E" recirculation pump motor generator set, replaced the accumulator on control rod hy-draulic control unit 10-15, replaced V-III valve on HCU 06-43, timed control rod drive mechanisms, performed balancing of the "B" recombiner on augmented offgas system and inspected the trunnion room fan belt .0 Control Rod Drive Hydraulic Pump Trip (71707, 62705)
On April 30, 1988, the "A" Control Rod Drive (CRC) hydraulic pump motor breaker tripped during an attempt to start and the pump was declared inoper-able. Plant Engineering investigated the trip and, finding no damage to the motor, concluded that the electrical current surge upon starting a cold motor actuated the instantaneous overload trip, The instantaneous overload trip setpoint was increased and subsequent attempts to operate the pump were suc-cassful. The pump was declared cperable; however, Plant Engineering felt that it was necessary to demonstrate starting capability with the motor at ambient temperature, This was performed on May 5, 1988, and the pump was successfully starte During this test, the licensee further inspected the breaker with the vendor, and it was discovered that the clearance between the overcurrent trip paddle and the overcurrent trip solenoid plunger was not correct. The specified clearance is 0.1 inches and the actual clearance was ze-o, Based upon this, the licensee has concluded the probable cause of the initial breaker trip to be mechanical shock combined with no clearance between the overcurrent trip solenoid plunger and the over urrent trip paddle, resulting in actuation of the breaker trip ba The licensee adjusted this clearance to the specified value and satisfactorily tetted the breake .
The licensee further concluded that this misadjustment occurred during recent performance of the breaker five yecr overhaul and breaker modification to install a solid state trip syste Since this breaker was the first breaker overhauled during the effort to overhaul the breakers of this type, the lic-ensee elected to reinspect seven other "priority" breakers in order to deter- j m:ne if this condition exists on them as well. These breakers are CR0 B, four '
containment spray pumps, the mechanical vacuum pump, and the turbine auxiliary oil pump. At the end of the inspection period, two containment spray pumps )
and the CRD B pump had been satisfactorily inspected. The inspector will j review the results of the remaining inspections, i l
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9.0 Electromagnetic Relief Valve Setpoint Change (71707)
On May 9, 1988, the licensee adjusted the alarm setpoint of the acoustic monitors for the electromagnetic relief valves (EMRV) from 30% of full scale to 40%. The inspector reviewed this change with Plant Engineering and re-viewed the safety evaluation associated with the setpoint change. The in-spector concluded that the setpoint change was properly executed and that station procedures were enrractly revised to reflect the change. The inspec-ter had no other questions in this are .0 Review of Periodic and Special Reports (90713)
Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specification requirements were examined by the inspectors. This review included the following considerations: the report includes the infor-nation required to be reported to the NRC; planned corrective actions are adequate for resolution of identified problems; and the reported informatior, is vali During this inspection period, a review was conducted of April Operating Repor .0 Observation of Physical Security (71881)
During daily tours, the inspectors verified that access controls were in ac-cordance with the Security Plan, security posts were properly manned, pro-tected area gates were locked or guarded and that isolation zones were free of obstructions. The inspectors examined vital area access points to verify that they were properly locked or guarded and that access control was in accordance with the security pla .0 Backshift Inspec_ tion (71707)
NRC inspections of licensee activities on backshifts were conducted on the following days:
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May 11, 1988
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May 21, 1988 13.0 Exit Interview (30703)
A summary of the results of the inspection activities performed during this report period were made at meetings with senior licensee management at the end of this inspectio The licensee stated that, of the subjects discussed at the exit interview, no proprietary information was included.
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