IR 05000270/1991202
ML15219A071 | |
Person / Time | |
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Site: | Oconee |
Issue date: | 04/01/1992 |
From: | Gramm R, Imbro E, Wilcox J Office of Nuclear Reactor Regulation |
To: | |
Shared Package | |
ML15219A070 | List: |
References | |
50-270-91-202, NUDOCS 9204090214 | |
Download: ML15219A071 (28) | |
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U.S. NUCLEAR REGIAT KY COMMISSION OFFICE OF NUCLEAR REACIOR REGULATION Division of Reactor Inspection and Safeguards NRC Inspection Report:
50-270/91-202 License No.:
DPR-47 Docket No.:
50-270 Licensee:
Duke Power Coapany Facility Name:
Oconee Nuclear Station, Unit 2 Inspection at:
Oconee Nuclear Station Site, Seneca, South Carolina Inspection Conducted:
December 2, 1991, through February 21, 1992 Inspection Team:
John D. Wilcox, Jr., Team Leader, NRR Jay R. Ball, Sr. Operations Engineer, NRR*
W. Keith Poertner, Resident Inspector, Region II Jeff L. Shackelford, Reactor Engineer, Region II Larry S. Mellen, Reactor Engineer, Region II Bruce A. Breslau, Reactor Engineer, Region II Ronaldo V. Jenkins, Electrical Engineer, NRR Deirdre Spaulding, General Ernineer, NRR
- Team Leader during pre-outage phase Consultant:
Patrick S. Thurman, Parameter, In Prepared by:
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John D. Wilcox, Jr., Team leader Date Team Inspection Development Section B Special Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation Reviewed by:
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Robert A. Gramm, Section Chief Date Team Inspection Development Section B Special Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation Approved by:
1.
Eugene V. Imbro, Chief Date special Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation 9204090214 920406 PDR ADOCK 05000270 G
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- ECUYIVE MRY For two periods between December 2, 1991 and February 21, 1992 (December 2-6, 1991, and February 10-21, 1992), the Nuclear Regulatory Ocmuission (NRC) staff conducted a pilot inspection of shutdown risk and outage management at the Oconee Nuclear Station, Unit The intent of the inspection was to assess the quality of the licensee's outage planning and conduct of the outage with respect to minimizing the risk of initiation of accident sequences during shutdown condition During the first phase, conducted before the outage, the team assessed the following attributes: (1) management involvement and oversight of the outage planning; (2) outage schedule focusing on relationships among significant work activities and the availability of electrical power supplies, decay heat removal systems, reactor coolant inventory control syst, and containment; and (3) operator response procedures, contingency plans, and training for mitigation of events involving shutdown risk. During the second phase, conducted during the outage, the team focused on observing overall control of ongoing outage work activities and testing in order to assess the following attributes: (1) the controls, procedures, and training related to the performance of plant activities during shutdown conditions; (2) the working relationships and communications channels between operations, maintenance, and other plant support personnel; (3) outage planning activities, including the scheduling and supervision of work activities and control of changes to the outage schedule; and (4) the degree of management involvement and oversight of the conduct of the outag The team also completed NRC Temporary Instruction 2515/113, "Reliable Decay Heat Removal During Outages."
The team found that although the licensee had given some consideration of shutdown risk during the outage, these measures need more emphasi In particular, the team considered the planning and scheduling of work activities to be wea Minimal procedural guidelines existed for managing the risks that could occur during shutdown condition The team found that excessive reliance was placed on individuals to schedule work activities during the outage to avoid situations of high risk rather than pre-planning such activitie The team identified several deficiencie For example,.the licensee failed to correctly perform a required nuclear instrumentation reliability check during fuel movemen Equipment clearance tagging errors were identified and a valve interlock had been jumpered out without a safety evaluatio The team also observed inaccurate information was disseminated during a licensed operator training sessio Throughout the inspection, the team determined that the knowledge level and professional behavior of utility personnel were high; however, the team noted during reviews of procedures and ongoing events that same plant procedures were vague and contained information that easily could be misinterprete Examples that reinforce this conclusion include:
an event where licensed operators failed to properly configure a valve lineup to facilitate the filling of the transfer canal; an event in which the radiation monitor (RIA-45) setpoint was not properly set; and indications that electrical bus loads were not clearly identified for certain controlled activitie i
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The team was concerned that the procedures governing the recovery from block tagouts needed improvemen During the inspection, the team found several block tagouts that did not contain formal valve lists for recovery to a normal valve lineu The team noted that controls on block tagout boundaries also needed strengthenin The team was concerned that same station directives contained both management philosophy and detailed procedure Some of the directives were required to be followed verbatim while others contained management goals and objective The latter had no mechanism in place to measure how well these programs were being implemented to satisfy managerent goals and the program objective The team found that the licensee needed to be more self-critical and to have a more questioning attitud Examples that reinforce this conclusion include:
system being left open and exposed to the intrusion of foreign material, debris left in the containment sump area during the outage, an apparent lack of detailed controls over transient combustibles, an example of burned-out light bulbs in an area near emergency equipent, and several avoidable -
difficulties that were observed during a fire dril The licensee displayed same areas of strength, including professional, well organized, timely shift turnover The midshift briefings conducted approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> into the 12-hour shift gave operators accurate plant status and updated current outage activities in progres Te operating crews exhibited positive control over control roam access and maintenance activities during the outag TABLE OF ONTENTS E.CTV SUMMARY...
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- * * * *. INTRODUCTIN
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1 MANAGEMENT INVOLVEMENT AND OVERSIGHT OF OUTAGE PIANNING AND SC[EEDLING
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2.1 outage Schedule...
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2.2 Planning and Preparation of Modification and Work Packages..
2.3 TrainingandProcedures........
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5 Conclusion...........
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7 MANAGEMENT INVOLVEMENT AND OVERSIGHT OF OUAGE IMPLEMETION.
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3.1 Control of Plant Operations and Work Activities.....
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3. Refueling Operations
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3. Assurance of Reliable Decay Heat Removal During the Outage
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3. Operator Response Durix a Fire Drill
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3.1.4 OvertimeControl.........
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12 Control of Maintenance and Surveillance Activities......
3. Review of Work Packages
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3. CoordinationofworkActivities
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3. Euipment Isolation
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3. Post-Maintenance Testing...
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3. Contractor Control and Work Force Managenn....
15 Safety System Walkdown.........
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15 General Plant Area Walkdowns aid Nuclear Equipment Operator Rounds..........
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3.5 Self-Assessment Activities............
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18 EXIT MEETIN.................
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APPENDIX A SUMMARY OF INSPECflON FINDINGS APPENDIX B EXIT MEErING ATTENDANCE SHEET APPENDIX C ABBREVIATIONS NINR CTION For two periods between December 2, 1991 and February 21, 1992 (December 2-6, 1991, and February 10-21, 1992), the Nuclear Regulatory Comission (NRC) staff conducted an announced pilot inspection of shutdown risk and outage management at the Oconee Nuclear Station, Unit The primary objective of this inspection was to assess the quality of the licensee's outage planning and conduct of the outage with respect to minimizing the risk of initiation of accident sequences during shutdown candition A secondary objective was to assess the ability of the licensee to cope with events that could arise during shutdown conditions in response to inadequate planning or inadequate control of plant operations or work activitie rit achieve these objectives, the inspection was conducted in two phases: an inspection during pre-outage planning and an inspection during the outage itself by teams of six and seven inspectors, respectivel The scope of the pre-outage phase of the inspection was as follows:
(1)
Assess the management's involvement and oversight of the outage plannin (2)
Assess the outage schedule focusing on the relationships among significant work activities and the availability of electrical power supplies, decay heat removal systems, reactor coolant system inventory control, and containment contro (3)
Assess operator response procedures, contingercy plans, and training for mitigation of events involving a loss of decay heat removal capability, loss of RCS inventory, and loss of electrical power sources during shutdown condition The focus of the second phase of the inspection was as follows:
(1)
Assess the controls, procedures, and training related to the performance of plant activities during shutdown condition (2)
Assess the working relationships and communication channels between operations, maintenance, and other plant support personne (3)
Assess outage planning activities including the scheduling and supervision of work activities and control of changes to the outage schedul (4)
Assess the degree of management involvement and oversight of the conduct of the outag Oconee Unit 2 is a Babcock & Wilcox (B&W) pressurized water reactor owned and operated by the Duke Power Company (DPC).
The Oconee emergency AC power system is unique in that it utilizes two nearby hydroelectric units feeding, either through the switchyard or via an underground circuit with the capability of energizing the emergency buses for all three unit DPC's individual plant evaluation (IPE) program has recognized vulnerabilities
related to the emergency AC power system as a contributor to a large fraction of the core-mlt risk at Ocone During this inspection, the team observed that DPC had recently taken same actions in response to events that had occurred at the plant or at other plants concerning switchyard access controls, outage management, plant operations during shutdown periods, related procedures, and operator trainin The team generally considered these actions to have been positive, althugh the effectiveness of these actions may not have been fully realized during the Unit 2 outage because they had been implemented only recentl The team has characterized the findings within this report as deficiencies or observation Deficiencies are either (1) the apparent failure of the licensee to cply with a requirement or (2) the apparent failure of the licensee to satisfy a written cumitment or to conform to the provisions of applicable codes, standards, guides, or other accepted industry practices when the commitment has not been made a legally binding requiremen Observations are item considered appropriate to bring to the attention of licensee management, but that have no apparent direct regulatory basi.0 MAGEMENT INVOLVEMENT AND OVERSIGHT OF OUTAGE PLANNING AND SCEDULING ACTIVITIES The team examined the licensee's process for outage planning and schedulin Particular emphasis was placed on determining if the licensee incorporated
. risk management considerations into the maintenance scheduling process and how the licensee used the planning and scheduling process to control work activities relevant to shutdown ris.1 Outage Schedule Before the start of the outage, the team reviewed the licensee's proposed schedule for conducting the Unit 2 outage and also reviewed several work package The team found that the licensee's outage schedule did not appear to incorporate explicit planning with respect to the minimization of shutdown risk The licensee scheduled many significant outage activities to occur within large windows during the outag The team found no attempt on the licensee's part to identify and schedule potentially significant maintenance tasks that could impact overall plant ris Plant Procedure 3.0, "Outage Management Philosophy," stated in part that "the Integrated Scheduling Group (ISG) shall schedule work activities such that a buffer zone of inactivity exists between the active heat removal path and outage activities during reduced inventory conditions."
The team, however, found that no explicit outage scheduling mechanism existed to identify and prohibit possibly conflicting activitie The licensee placed a heavy reliance on knowledge of the individuals involved in the day-to-day scheduling to identify such situation The team concluded that this increased the burden on operations personnel to identify potential high risk situations and to respond to them appropriately during the outag Additionally, Maintenance Administrative Policy Manual 3.3 directed that "maintenance shall be planned and scheduled to consider the possible safety consequences of concurrent and sequential maintenance."
However, the licensee's practice of scheduling significant maintenance activities during large windows of time during the
refueling outage was considered weak and inconsistent with the above directive The team's review of the Unit 2 pre-outage plan identified one licensee self-imposed scheduling constraint to have two electrical power sources available throughout the outag The licensee had prepared other schedules for electrical power conponent wor Although the pre-outage schedule met the procedural requirement in OP/O/A/1102/11, "Controlling Procedure for Cold Shutdown," to have two of the three power sources available, the team did not consider that the schedule reflected the intent stated in Step 2.2.1 of the procedure to "maximize the number of power sources and transformers available to the main buses."
For example, the team found no evidence that the licensee planned to take any action to prohibit work on or to maximize the available power sources during mid-loop operation The team examined one ccmuunication tool developed by the licensee for identifying high-risk periods, entitled "iutdown Risk Status," and found this measure to be a positive step in outage work practice The status tool assigned values to the availability of transformers and critical buses for a calculation using additional inputs for decay heat removal capability, containment opening status, and reactor coolant system (RCS) inventor Overall, the team considered the scheduling of the maintenance activities was wea Heavy reliance was placed on operations support and licensed control roam operators to monitor and screen out unacceptable or high risk work activitie The personnel involved in planning and preparing work packages were technically ccmpetent and dedicated to good work performanc The work process, however, permitted potentially conflicting maintenance activities to take place at the same time, or high-risk activities to be scheduled during inappropriate periods. - The team also determined that the computer program for scheduling outage activities did not contain all of the anticipated work activitie The campiter program for tracking day-to-day work activities that was used by the maintenance coordinators was separate and distinct from the campiter program used for outage plannin Therefore, the team concluded that the existing practices made it difficult for the licensee to analyze and perform contingency planning to compensate for required maintenance activities during high-risk period.2 Planning and Preparation of Modification and Work Packages The team reviewed the licensee's process for developing and preparing individual modification and work package The team interviewed the responsible managers, engineers, and technical support personnel and examined several modification and work package The scope of the review included evaluating how thoroughly the licensee had defined job requirements and coordinated various maintenance activitie In selecting the individual work packages for review, the team paid special attention to those activities that were scheduled to take place during the identified "high risk" windows, and those activities that could affect the various factors that contribute greatly to shutdown risk considerations (i.e., electric power, containment integrity, decay heat removal, and RCS inventory control).
The following paragraphs summarize the team's observations about planning and scheduling the implementation of specific nuclear station modifications (NSMs) and other work activitie NSM-ON-22853,
"Reactor Building Drain Header Replacement," was scheduled during the primary miscellaneous maintenance work windo This maintenance window extended for essentially the entire duration of the outag Given the completion of the appropriate prerequisites, this modification could be performed any time during the outag The drain header modification required the coordination of maintenance activities that in turn had to be tied to specific plant conditions for completio The job scoping and preliminary planning of the work was extensive and appeared to be comprehensiv In addition, the nature of the modification was such that several individual tasks to be performed could conceivably affect shutdown risk consideration For example, the modification on valve 2-CS-5 affected containment integrit Judicious scheduling or detailed contingency planning would aid in minimizing the risk of this tas However, the team found that the licensee had not attempted to identify the particular time frame when the maintenance would take plac NSM-ON-22448, "Upgrade of Pressurizer Invel/Temperature Instrumentation," was also scheduled during the primary miscellaneous maintenance work windo This maintenance required the plant to be in cold shutdown and had precautions regarding opening penetrations while in a reduced RCS inventory conditio However, due to the nature of the scheduling, portions. of this maintenance could have been performed during the period when the reactor vessel level was being lowered to achieve mid-loop condition Interviews with the licensee suggested that this would not occur because operations personnel would have the final clearance on the maintenance and would not allow work to commence
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while lowering reactor vessel leve This method of planning placed a heavy reliance on the plant operators to manage many aspects of shutdown ris NSM-ON-22806,
"Replacement of Low Pressure Service Water Valve Actuators for 2-LPSW-18, 21, and 24," was also scheduled during the primary miscellaneous maintenance work windo In terms of shutdown risk, the team concluded that it would have been desirable to refrain from this maintenance activity during periods of fuel handlin The outage manager stated that this maintenance task was scheduled to be performed after the reactor was defueled, reducing the risk associated with the wor However, after examining the schedule, the team could not verify that the work was prohibited during fuel handling operation On the basis of the licensee's scheduling program, this maintenance could be performed almost any time during the outag NSM-ON-22583,
"Modification of Unit 2 Annunciator System," was a work package that involved extensive work near various control roam alarms and indicator Although the work was to be performed on non-safety-related equipment, the potential for impacting plant operations was significan The team concluded that the performance of this modification could increase the level of confusion in the control roam and place a greater demand on licensed operators to maintain awareness of plant conditions and ongoing activitie This work was scheduled in a manner similar to several other work packages in that it could be performed at almost any time during the outag Conversations with the modification personnel who were in charge of performing the work indicated that they were prepared to commence the modification when the outage bega However, the licensee's own shutdown risk assessment showed that the highest
. risk window of the outage would occur early in the outage during the period of high decay heat and reduced RCS inventory condition The team concluded that
it would be desirable to minimize any maintenance activities that might distract the control roam operator NSM-)N-22862,
"Replace MCCs 2EP1 and 2WP1 With New MCCs,I" and NSM-CN-22665,
"Auxiliary Power Upgrade," involved the movement of non-safety-related loads fron motor control centers with potentially sensitive equipment (e.g., Spent Fuel Cooling Pump "C" Starter, Power Battery Charger No. 2PB).
Again, the team found that these work activities were not individually reviewed and scheduled to avoid high-risk periods bit were placed in a large outage work windo Errors or mishaps during the implementation of these modifications were seen by the team as having potentially adverse consequences in terms of shutdown ris In summary, there appeared to be informal controls in place and a reliance upon personnel awareness of the NSM activities to ensure that work was accamplished in a manner to minimize the associated risks. In general, the planning and preparation of the individual NSM's appeared adequat The technical personnel in charge of preparing the packages were knowledgeable and dedicate However, the formal approval process for the packages was significantly behind schedul Specifically, the licensee's ISG Directive set various deadlines for planning, notifications, and material requisitions associated with the modifications to be performe In particular, a one-month period preceding the start of the outage deadline had been set for the completion and approval of all NSM work package All pre-outage activities were also required to be sent to the appropriate plant managers and all scheduling input to the ISG was required to be complet However, as of December 5, 1991, (30 days before the scheduled outage) none of these requirements had been mt. Only 17 of 45 NSM packages had received the necessary approval The final pre-outage schedule had not yet been issue The team considered that these planning and scheduling deficiencies made it extremely difficult for an integrated safety perspective to be incorporated into the outage schedule and for adequate contingency plans to be developed should risk-significant situations be identifie Although the capabilities of the planning personnel were considered a strength, the fact that the approval process for the packages was lagging represented a concern to the tea The team also reviewed the licensee's method of scheduling and controlling other types of outage maintenance activitie The team found that related maintenance was performed during common periods of tim This appeared to ensure that system isolation would occur during appropriate plant condition However, the team found that individual maintenance activity scheduling was not performed, thus the potential existed for same unforeseen interactions to occur that could increase overall plant risk. The team concluded that a more integrated look at how individual maintenance item would impact overall plant risk could aid in enhancing the safety of the activit The licensee stated that such an approach to minimize risk was being performed informally at the operational leve.3 Training and Procedures
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The team reviewed the licensee's procedures and training to determine the extent to which the licensee had addressed conditions unique to shutdown operations. The review included evaluating normal, emergency, and abnormal
operatiry procedures to determine the extent to which they contained appropriate cautions or warnings when actions prescribed by the procedures had the potential to cause perturbations in RCS inventory, affect the availability of onsite or offsite electrical power sources, or cause a loss of RCS inventory, decay heat-removal, instrument air, and service water or component cooling wate In response to Generic Letters (GIs) 87-12 and 88-17, the licensee committed to train (on a 2 year frequency) on industry events involving loss of decay heat removal capabilit The team assessed the adequacy of the training materials through discussions with the training department, reviews of lesson plans, and an observation of classroom training on RCS filling, venting, and drainin The team found that the licensed operator requalification program did provide training related to minimizing the risk of initiation of accident sequences arising from inadequate planning or control of plant activities. Although the licensee's trai ning materials adequately covered the risks and precautions related to ensuring adequate core cooling and containment integrity, the team considered that the timing of the biennial classroam training was not sequenced so as to optimize the training effor The licensee's operators were licensed on all three units and periodically rotated through all three unit A crew could conceivably be rotated off a unit before an outage or could cam on shift just after the unit had coupleted an outag This combination of shift rotation and biennial shutdown operations training made it possible for a crew to go nearly 2 years without receiving training on the unique risks associated with shutdown plants before being involved in an outag The team reviewed two recent events at Oconee:
the September 7, 1991, loss of decay heat removal and the September 19, 1991, overpressurization of the low pressure injection (LPI) syste The team concluded that these events reflected the importance of conducting on-going training regarding the risks associated with shutdown before entering an outag The licensee, in response to these events, reassessed the duties and responsibilities of licensed and non-licensed operator The licensee incorporated changes into Operations Manual Procedure (OMP) 2-At the time of this inspection, the licensee's operations staff had conducted special on-the-job training sessions conveying the lines of communication and responsibilities of the unit supervisor, control roam senior reactor operator, and the control roan operators to all licensed operator Additionally, the operations staff had trained two of the five shift crews on procedures associated with shutdown operation Although the team found that materials for the operator requalification training materials adequately covered the risks and precautions for ensuring adequate core cooling and containment integrity during shutdown conditions, one notable exception was observe The team attended a licensed operator training lecture in which the instructor stated that the time to boiling in the core following a loss of shutdown cooling capability was 45 minutes under worst-case condition This information was wrong because shortly after plant shutdown with the RCS inventory reduced, the time to boiling in the-core
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following a loss of shutdown cooling would be approximately 12 to 18 minute In addition, the licensee's response to GL 88-17 and 87-12, as it related to having two independent RCS level indications, stated that the existing indication (LT-5) would be supplemented with ultrasonic level devices. The response further stated that other existing instrumentation (i.e., pumip motor current, suction line pressure, discharge header pressure, discharge header flow, discharge header low-flow annunciator, and pump low-delta-pressure annunciator) provided useful information for operators so they may understand the performance of the RCS and decay heat removal syste Interviews with the licensee revealed level indication from U-5 was very sensitive to differences in pressure between the RCS and containment atmosphere because the reference leg was open to the atmospher A 1-psig difference could cause a level error of approximately 28 inche If RCS pressure were below atmospheric pressure, the reactor vessel level would indicate pressure lower than actua Also, if RCS pressure were greater than atmospheric pressure, the reactor vessel level would indicate higher than actua The team concluded that these two level indication systems met the intent of the generic letter requirements for reliable, accurate water-level indication whenever the RCS inventory was in a reduced conditio The team and the licensee recognized that the licensed operators did not fully understand the system conditions that create pressure differences between the reactor building and the RC The licensee's operations staff had begun on-the-job training sessions to address this issu.4 Conclusion During the first phase of the inspection, the team determined that procedures were adequate and personnel were competent and found no evidence of material or equipment deficiencies that prohibited the safe conduct of the Unit 2 outag The team, however, had strong reservations regarding (1) the depth of the outage planning and scheduling and (2) the licensee's process that (a) placed a heavy burden on licensed operators to identify potential problems and (b) failed to examine risk considerations associated with each work activit Allowing possibly conflicting maintenance activities to take place during the same period made it difficult to perform meaningful risk assessments or to manage the resultant risk The existirn practices also made it difficult to perform adequate contingency planning to ccpensate for required maintenance during the high-risk time frame.0 MANAGEMENT INVOLVEMENT AND OVERSIGif OF OUTAGE IMPLEMENTATION The team observed and assessed the quality of the conduct of outage activities and management involvement and oversight of the Unit 2 outage during the second phase of the inspectio The team also observed plant evolutions during select periods between the two phases of the inspection, specifically the licensee's entry into mid-loop operation shortly after the plant was shut dow The team emphasized the direct observation of operations, maintenance, and surveillance activitie Particular attention was given to the control and coordination of activities from the main control roo Team members also
. attended daily status briefings and observed shift turnover The team conducted numerous tours of plant areas during both day and back shifts in order to assess the adequacy of housekeeping and work practice During the second phase of the inspection, the team found the licensee's in process controls ensured that work activities were performed at appropriate times within the scheduled outage work window Thus, the team's reservations about the outage pre-planning were mitigated somewhat in actual practice through diligent in-process work scheduling to minimize the effects an shutdown ris.1 Control of Plant Operations and Work Activities The team periodically observed the conduct of operations from the Unit 2 main control roam throughout the inspectio Major activities witnessed included filling of the low-pressure injection system after low-point maintenance, filling of the refueling transfer canal before refueling operations, refueling operations, and draining of the transfer canal after refuelin A strength was noted in the area of control room access and control of maintenance activitie The team observed that the unit supervisor maintained a positive awareness and tight control over control roam acces The supervisor screened maintenance activities and controlled the level of activity that was allowed to impact the control roa The team observed shift turnovers conducted by the operating crews and determined that adequate time was allotted to conduct the turnover Plant operations and activities in progress were discussed in detail and the transfer of outage information and problems appeared thoroug The team observed that several shifts conduct mid-shift briefings at which the unit O
supervisor, control roam senior reactor operator (SRO) and the reactor operators discussed the current plant status and activities in progres These meetings appeared to be beneficial to the shift crews involved and this practice was considered to be a strengt The team observed that the operators in the control roam were attentive to the control boards, generally aware of plant conditions, and responsive to alarms or abnormal indication Communications between operators in the control room and the transfer of information up and down the chain of command appeared to be conducted in a proficient manne Procedures were determined to be present and in use during the performance of activities observed by the tea However, the procedures in same cases were not detailed enough and relied on operator knowledge to ensure proper performanc This resulted in three observed incidents of poor control of a plant activity during refuelin These incidents are discussed in more detail in the following sectio. Refueling Operations The team observed deficiencies in the licensee's performance of OP/2/A/1502/07, "Refueling Procedure." The licensee failed to correctly perform a required nuclear instrument reliability chec The procedure required that the reliability check be performed after loading two fuel assemblies and after obtaining a stable neutron count rat However, because the licensee continued to load fuel while collecting the required data for the test, the licensee obtained erroneous dat The licensee did not stop fuel loading until questioned by the tea Two additional fuel assemblies were loaded before fuel loading was stoppe This is Deficiency 91-202-01,
"Incorrectly Performed Nuclear Instrument Reliability Check," in Appendix The plant staff then collected the required data for the reliability test, which was found to be satisfactory, and then recorenced fuel loading The team also noted that the counters, installed for collecting the required data, were giving readings inconsistent with observed nuclear instrument reading The licensee did not recognize the inonsistent readings until questioned by the tea Maintenance was called to investigate and found the counters had been incorrectly configured during installation and that certain filters were actively masking the actual count rate The licensee acknowledged the weakness in this are The team observed the following additional procedural proble The refueling procedure required that a functional check of radiation monitor 2RIA-45 be performed in accordance with IP/O/B/360/33, "Sorento Process Monitor Iow Range Gas Detector Calibration."
This check verified that the reactor building purge valves would close automatically when the radiation monitor high setpoint value is reache The team witnessed the performance of the functional check and determined that the procedure did not verify that the high setpoint value was set correctl The team questioned the control room SR0 on the adequacy of this setpoin The SRO determined that the setpoint was set non-conservativel The radiation monitor was reset to the correct high setpoint before commencing fuel movemen The team expressed a concern that the operators might not have reset the radiation monitor trip setpoint if the team had not questioned the setpoin The team also observed during the filling of the refueling transfer canal that insufficient water was available in the borated water storage tank (BWST) to completely fill the canal even though a general statement in the procedure required that sufficient volume be availabl In addition, when the operators attempted to transfer water from the "A" bleed holdup tank to the BWSr, they determined that the flow path was blocked after having started the bleed transfer purp because a block tagout interfered with the required flow pat The operations staff initiated a procedure change to align an alternate flow pat Problems with block tagouts and equipment clearances are discussed further in Section 3.. Assurance of Reliable Decay Heat Removal During the Outage The team reviewed the outage activities with respect to NRC Temporary Instruction 2515/113 regarding assurance of reliable decay heat removal during outage The team reviewed the following specific areas:
availability of offsite and onsite power sources to each required shutdown load
availability of dc power, backed by battery, to required loads when battery testing or maintenance is being performed
use of non-standard electrical lineups
operator preparation to manually control electric power systems
- increased vulnerability during reduced inventory and availability of electric power sources
operability determination for loss of field flashing source (i.e., do source) to emergency diesel generators
special tests or procedures that may affect decay heat removal
procedural control The team reviewed Station Procedure OP/O/A/1102/11, "Controlling Procedure for Cold Shutdown, " which stated that at least two of the three following power sources were to be available manually while the unit was in cold shutdown with fuel in the core:
the startup transformer (Cr-1, 2, and 3) from the Keowiee Hydroelectric Station overhead power path
the Keowee Hydroelectric Station underground through transformer CP-4
the 100 kV feeder frmn the central switchyard or the Lee Gas Turbine Station thrcugh transfonner Cr-5 The main transformer 2T was configured in the backcharged mode to supply power to the main feeder buses during the outag A review of the station records indicated to the team that the offsite power source through the 230 kV switchyard was supplied either through the main transformer 2T or the startup transformer CT-The Keowee Hydroelectric Station underground circuit through the CT-4 transformer (an onsite emergency power source) and the circuit through the CT-5 transformer fran Lee Gas Turbine Station were placed in service to support the shutdown loads during the outag The main feeder buses and standby buses that supplied the vital equipment loads were not taken out of service for maintenanc Therefore, shutdown loads received power, as a minimum, during the outage from one onsite power source and one offsite power sourc A review of the station records indicated to the team that no battery testing or maintenance was scheduled to be performed during the outage that would affect the dc power supply to the required shutdown load The team examined the licensee's control of pre-outage planning and staging for temporary power modification Although modifications were not scheduled and staged before the beginning of the outage, the licensee recognized routine power outages would occur and therefore planned to install temporary power skid The team examined the preparation of the temporary power modifications to determine whether they had been analyzed to ensure they could carry sufficient load and could properly activate protective circuitr This review found adequate analysis for electrical fault protectio The examined modifications were either powered fran the switchyard or would be load-shed in the event of a loss of electrical powe All temporary power modifications during the outage provided service to non-safety-related equipment onl The use of other non-standard electrical lineups (i.e., the use of bus tie breakers normally not closed or removal of generator disconnect links for back charging the unit) was controlled under approved procedure 'The team was informed that operating personnel were found to be trained on the use of Abnormal Operating Procedure (AOP) AP/l/A/1700/11,
"Loss of Power,"
which provided for manual control of electric power systems as needed when automatic control system are found to be inoperabl The operations support manager told the team that the ADP training was limited to simuilator exercises only even though a number of in plant actions were required by the procedur A review of the outage schedule and activities worked through Febkruary 13, 1992, indicated that a maximum number of electric power sources were available during the reduced inventory period when fuel was in the vesse Except for brief maintenance periods when either main transformer 2T or startup transformer CT-2 were unavailable, three electric power sources (2T or CT-2, CT-4, and CP-5) were available during the outag The licensee declares the Keowee Hydroelectric Station inoperable when its field flashing source, which is a dc battery bus, is removed from service for maintenance or testin Appropriate operating procedures were noted to identify, in precautions and limitations, the potential loss of-operability for the Keowee unit if the field flashing (dc) source became inoperabl The team reviewed the licensee's procedures governing availability of low pressure injection and low-pressure service wate Although these procedures did not contain significant detail, they were clear about the requirement for ensuring decay heat removal capability when fuel is in the reactor vesse The team noted that the licensee had decided to ensure that both trains of low-pressure injection would remain in service while fuel was in the reacto The outage schedule did not permit maintenance on either train of low-pressure injection or either train of low-pressure service water while fuel was in the reactor vesse Electrical work that could have caused the loss of low pressure injection was also delayed until the reactor was defuele The team did not observe the scheduling of any maintenance or special test procedures that could have adversely affected the required availability of low-pressure injection capability while fuel was in the reactor vesse. Operator Response During a Fire Drill The team witnessed a nuclear equipment operator (NBD) participate in a fire drill. The NED was in the basenent of the turbine building when a fire was announced to the occurring on the third floor of that buildin The NED went to the fifth floor, donned turnout gear and a breathing air bottle, and then proceeded to the fire locatio The team noted that there was no personnel access control through the area in which the NED donned his turnout gea Approximately 25 people not involved with fire brigade activities passed through the area while the NED put on his turnout gea Time was lost because the NED tried on several sets of turnout gear as they were not clearly identified by siz The large cart containing the reserve breathing air bottles and other fire-fighting equipment was taken to the fire location on the elevator, without the fire override ke It was not clear how the equipment would be transported if elevators were unavailabl Additionally, the team observed that the NED was unsure if the portal radiation monitors should be use The NED chose to ignore the monitors and proceeded to the fire are Otherwise, the nuclear equipment operator (NED) observed all the radiological controls while entering the turbine buildin The team discussed these observations with the license. Overtime control The team observed that weak administrative controls existed to preclude an operator from exceeding overtime limit The licensee identified that a licensed operator had exceeded the facility's overtime limits in September 199 The licensee's current practice only identified when the overtime limits had been exceede The licensee stated that it was the individual's responsibility to be aware of the overtime limits and to practice complianc Discussions with several operators suggested they were aware of the facility's overtime policie However, the team concluded that the weak administrative controls to ensure that all operators are aware of the limits could lead to further instances where limits were exceede.2 Control of Maintenance and Surveillance Activities The team reviewed station directives, procedures, and several modification packages and work orders to determine the followinJ:
if the licensee had prepared and performed the work according to station directives or procedures
whether these work packages contained sufficient information to support work in the field
if the work package information was used in the field
if equipment isolation was properly obtained
if the post-maintenance testing was conducted properly In addition, the team reviewed the local leak rate testing process to determine if there was a potential for a loss of containment integrity during local leak rate testin Each of these areas is discussed in greater detail in the following section. Review of Work Packages The team reviewed Station Directive 3.2.1, "Work Request (WR)," and Station Directive 2.3.4, "Nuclear Station Modification (NSM) Program," to determine the specific requirements for the preparation of work package The team also reviewed several work packages that were being prepare These packages contained the necessary documents and were prepared according to station directive However, two of the work packages were not fully completed,, although the maintenance supervisor had reviewed and approved the packages as complet On the basis of discussions with the licensee and the fact that the other work packages reviewed were complete, the team determined this was an isolated case and did not indicate a progranmatic weaknes The team noted that the steps that had not been completed were not safety significan The licensee reviewed the incomplete documents and put in the missing informatio The team also noted that the work packages reviewed contained sufficient information so that the craftsmen could complete the work in the fiel In
installation drawings. Inspectars aluso tured the conament, the -ux--ia building, and the turbine building work areas to determine the extent of work documentation used or available for te craftsmen in the field. In each work area inspected, there was an appropriae copy of the work package far that jo During these tours, the team observed a number of instances of systems or equipment not covered or not otherwise isolated from the surrounding environment when niot beirg worked on. Such practices could allow foreign objects to enter these system We team did not identify any actual internal system contamination, but considered the work practices in the area of internal system cleanliness control to be wea. Coordination of Work Activities During the outage, the team observed that the licensee worked diligently to ensure that affected groups were made aware of pending or current work activitie Outage managers conducted morning and afternoon meetings on the status of the outag The team attended several maintenance work meetings at which emerging or current maintenance activities were discusse The team observed adequate distribution of key work status information among the meeting participants during the morning and afternoon meeting The team observed that the review process for changes to the outage schedule occurred reactivel Decisions regarding problem resolution involved senior managers at the proper time after data campilation and consideration by technical personne The team found that changes to the schedule of outage work activities were handled in a controlled and professional manne The team also attended the morning turnover meeting between the night shift manager and the unit outage manage The shift manager performed the duties of the unit outage manager during weekends and on night shift The team observed that communication during turnover was adequate although several item of information necessary to timely decisionmaking were missing during the turnover perio The team observed specifically:
Te work status of transformer Cr-2 remained unclear for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> although the transformer was ready to return to servic *
The low-pressure service water (LPSW) "B" cooler sample chemistry results were ambiguously reported to senior manager This resulted in an order for a second sample before deciding to place the cooler in servic During the morning turnover on February 11, 1992, the night-shift manager reported that a work list ccmpiled by operations personnel had been used rather than the turnover list developed from the afternoon outage meetin Discussion with the licensee indicated that recent organizational changes may have caused confusion regarding the new lines of authorit *
The team noted the close working relationship between the planners and schedulers and the maintenance supervisors and craft personne Work packages
were distributed to the maintenance supervisors and the status of work in progress was discussed at meetings with maintenance personne Another aspect of coordinating and controlling work activities was the licensee's use of the Operations Support Grou These licensed operators performed the initial review of the work packages, taking the burden of this review fran the control roan operator The team noted, however, that the control room SRO provided the final authorization to commence wor The team reviewed the operating logs to determine what equipment problems had been experienced during the outag No significant equipment failures had been identified in the logs; however, several operational problem had occurred because of planned electrical bus outage One incident involved the inadvertent tripping of the Unit 2 reactor building purge fan caused by the closure of valve 2PR-3 due to motor control center (MCC) 2XS2 being taken out of servic The team noted that the operations staff did not possess an electrical load list to understand the effects associated with electrical bus outage This incident may have been avoided had an electrical load list existed and been used in planning the MCC outag. TEquipment Isolation The team reviewed the licensee's process for isolating equipment or systems to conduct maintenanc The two primary procedures reviewed addressed block tagouts of system or components and the removal and restoration of equipmen.
'The isolation of equipment was controlled by the control roan operator Maintenance personnel obtained permission from the control roan operators before performing any maintenanc An observation was made in the area of the control of block tagouts. The team determined that the licensee did not use specific valve checklists while restoring systems or equipment from all block tagout The licensee lacked appropriate restoration checklists for 5 of the 17 identified tagout The licensee acknowledged the need for this type of documentation and stated that improvenents were being mad The team also found multiple examples of safety tags hanging without appropriate verification documentation having been ompleted. This practice was contrary to Station Directive 3.1.1, which required independent verification of equipment isolation before commencing maintenance activitie The licensee acknowledged the deficiencies in this are This is Deficiency 91-202-02, "Lack of Independent Safety Tag Verification,"
in Appendix The team reviewed the Unit 2 logbook documenting removal and restoration of equipmen During this review, the team noted that the reactor building radiation monitor, RIA 49, interlock to liquid radioactive waste isolation valve 2IND-2 had been jumpered out using the removal and restoration proces The team considered this to be inappropriate in that by using the removal and restoration process, the licensee failed to perform a written safety evaluation for what constituted a tenporary modification to the facilit The
licensee agreed that this change should have been made via Station Directive 2.3.5, "Control of Temporary Modifications," rather than by the removal and
restoration proces This is Deficiency 91-202-03, "Lack of 10 CFR 50.59 Safety Evaluation for a Temporary Modification, " in Appendix. Post-Maintenance Testing The team reviewed the post-maintenance testing requirements for the work packages selecte The post-maintenance testing appeared to have been performed at the proper times in the work cycl The team did not observe any problem in this are. Contractor Control and Work Force Management The licensee used a group of mainteienre personnel who were Duke Power Qompany employees, but not permanently assigned to Oconee, for performing outage activitie The licensee maintained direct control of the outage personnel observe The licensee's computerized management information system included a training and qualification data bas The licensee explained that management used this data base when determining employee assignment The team noted that the data base was not current, but there was sufficient information to ensure that properly qualified personnel were appropriately assigned work task The team also noted that the licensee maintained control over work activities and the craft personnel performing these activities through meetings that involved both plant management and lower level supervisor Supervisors met with their crews and distributed pre-approved work package Any work problems or concerns were discussed at these meeting.3 Safety System Walkdown The team walked-down the portions of the low-pressure service water (LPSW)
system that suports the LPI and decay heat coolers 2A and 2B for Unit The labeling and piping configuration generally matched the plant drawing The team noted same discrepancies with Drawing OFD-124A-For example, the root isolation valves for the "A," "B," and "C" LPSW pump strainers were installed in the field but were not shown on the drawin The team discussed these discrepancies with the licensee and the licensee stated that the instrument and electrical (IAE) group was responsible for maintaining root isolation valve The team noted that these valves were identified on instrument and electrical drawings with a number that was not currently on the valv The team was told that this would be addressed in the root valve labeling program which was well under wa The licensee stated that the other discrepancies, including unlabeled or mislabeled items, would also be correcte The balance of the drawings the team reviewed matched the as-built configuratio The team concluded that the drawings were adequate to perform the required operation.4 General Plant Area Walkdowns and Nuclear Bcluipment Operator Rounds The team conducted walkdowns of the plant areas and accompanied NEDs during routine round These areas included normal and emergency power supply components, switchyard areas, the Keowee Hydroelectric Station, the turbine
building, the auxiliary building, outdoor ommon areas, and the Unit 2 containment buildin The NEDs conducted their rounds accordirx to Cperations Management Procedure 2-The team observed that the NBDs were knowledgeable of plant condition The NEDs monitored plant equipmnt and determined if the equipment was operating within expected limit Parameters outside the expected were noted on the rounds sheet The NBDs did not restrict their review to items on the rounds sheets but were also attentive to the status of other plant equipmen The team observed that the NEDs followed appropriate requirements for accessing vital area The NEDs could tell how long an out of-service tag had been hung, but were not always aware of why the tag had been place The NEDs were not directly involved in the management of outage ris However, through their daily rounds, they appeared to have a positive impact on system availabilit The following discrepant conditions were identified by NEDs on routine rounds during this inspection:
a loose bus connector causing arcing in the 6900 V reactor coolant pump motor switchgear
.
a primary water leak from a fitting on Unit 2
maintenance technicians performing actions during testing that could have overpressurized a feedwater heater
a degraded fire barrier in the cable spreading roam (A fire watch was established and the penetration was sealed.)
The team found that the material condition of the plant areas inspected generally acceptabl However, the team also found same plant areas that needed attentio Additionally, the team noted that Unit 2 was less well maintained than Units 1 and In particular, the team found that the cabinet containing the Unit 2 turbine electrohydraulic control pedestal contained wood, plastic bags, and oil-soaked rag There was a large accumulation of inappropriate cambustible material, abandoned tools, other work material, and tras The team discussed this condition with the license Corrective actions were appropriately initiate The team confirmed that the corrective actions were completed and were adequat The Unit 2 auxiliary building also had a large accumulation of inappropriate cambustible materials, abandoned tools, other work material, and trash in same area This was especially noted in the Unit 2 high-pressure injection (HPI)
and LPI pump room The team discussed its observations about cleanliness in the Unit 2 auxiliary building with licensee managemen While in the Unit 2 containment building, the team observed a large amount of debris around the containment sump which could have disabled the ability of low-pressure injection pumps to supply wate The licensee stated the debris would be picked u Also noted were unattended work items laying on cables in a cable tray and a radiation protection sign laying on the floo In sumnary, the team noted inappropriate transient cambustible materials in many location The team discussed this with licensee fire protection and safety managemen Licensee management responded by reviewing the plant areas with inappropriate combustibles and then ensuring that these areas had been cleare The team walked-down the areas after they had been cleaned and found them acceptabl During the NED walkdowns, the team observed that the NEDs complied with all radiological requirements and controls when exiting the auxiliary buildin Several exit portals alarmed when exiting the auxiliary buildin The NEDs called the health physics technicians who performed their tasks appropriatel The team noted one instance of tagged radioactive material lying partially outside the boundary of a radiological control zone (RCZ).
This was contrary to the requirements of Station Directive 3. The licensee promptly corrected the situatio During the plant tours, the team also observed that plant lighting was
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generally acceptable except for the area near the 1A motor-driven emergency feedwater pumip suction instrumentatio The lighting level was reduced there because overhead piping and equipment blocked the lighting and no emergency lighting was provided in the are The team walked-down this area with an operations staff enginee The engineer said the bulbs had burned out and would be replace Oe normal and emergency ac power supply components including the 4160 V emergency ac power buses, the main feeder buses, the standby buses, main transformer 2T, the startup transformer C1-2 and the Keowee transformer for the underground feeder Cr-4 were inspecte The team conducted an extensive walkdown of the switchyard areas and couponents that supply offsite power to Unit The walkdown included the switchyard areas associated with the 230 kV transmission, 525 kV transmission, and CP-5 transformer connection to the Lee Gas Turbine Statio The licensee's administrative procedures regarding access control for the switchyard areas were examined and found acceptabl The nuclear power department directive provided adequate direction to limit access to switchyard areas when the ac power system was in a degraded condition or when the plant was in reduced RCS inventory operation The team did find that the CT-5 transformer area access was not controlled to the same degree as other switchyard area Some debris and spare materials were located in the vicinity of the transforme The licensee took corrective action to ensure that the CT-5 transformer area was treated similarly to other transformers with respect to controlling acces The team conducted a walkdown of the Keowee Hydroelectric Station that supplies emergency power for the plan The walkdown included the two Keowee generating units, the power transformer, the control room area, and associated auxiliary equipmen The technician on duty.cited a high equipment reliability factor (approximately 99%) and short outage time (approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, typically).
Although the Keowee plant was operating under a different organizational structure, close ties existed between the two organization The licensee was, however, unable to provide the team an outage schedule for the Keowee unit.5 Self-Assessment Activities The licensee's process of evaluating shutdown events for applicability to the plant and the identification of appropriate lessons learned is governed principally by Station Directive (SD) 4. SD 4.5.5 noted the process used to identify and resolve problem It further indicated that most of the problem would be handled by "lower tier" program Other lower tier programs included maintenance incident problems, shift incident problems, outage performance problem, security events, procedure deficiencies, radiation protection incident reports, health services (including minor injury reports, accident/near-miss investigations, fire investigations, and employee exposure reports), environmental events, solid/hazardous waste events, and quality assurance department audit/finding Each lower tier program was required to have the following:
root cause analysis
documentation/management awareness
tracking/trending
criteria for issuance of a Plant Incident Report (PIR)
review for generic applicability SD 4.5.5. stated, in part, that opportunities for improvement in outage performance were to be collected and reported in an outage repor However, tracking, trending, and documentation of problem resolutions were not specifically required to be included within the outage repor The post outage performance report process was described in ISG Directive The
intent of the post-outage report, in part, was to include only major problems that occ urred, and to summarize the performance of the various outage sections and group The team noted that an independent safety assessment was not conducted of either the outage schedule/planning process or the Unit 2 EDC-11 aid Unit 3 BDC-12 outage report critique Independent assessments could provide additional perspective regarding risk management beyond that afforded by line managemen The licensee indicated that it would make greater utilization of the operational safety review group in reviewing pre-outage schedule The team was concerned that station directives contained both management philosophy and detailed procedure This was particularly evident in the outage planning and scheduling area Same of the directives were required to be followed verbatim while others contained management goals and objective The latter had no mechanism in place to measure how well these programs were being implemented to satisfy management's goals and the program's effectivenes The team was concerned that the licensee's oversight and feedback mechanisms had not apparently detected that management goals and policies were not being ccmpletely fulfille There were indications that the licensee did not have an aggressive questioning attitude with respect to plant condition Some examles include:
plant systems being unnecessarily left open while work is on-going, same poor lighting levels near important local instrument gauges, the presence of debris in the containment sump area, and the presence of inappropriate combustibles in many plant area These indicate that plant personnel need to became more sensitive to identify and correct conditions that have the potential to
adversely inpact plant systems or operations staff capabilities to perform their function.0 EDIT MEETING On February 21, 1992, the team conducted an exit meeting at the Oconee Nuclear Statio NRC and licensee personnel attending this meeting are listed in Appendix The licensee did not identify as proprietary any materials given to the inspection tea During the exit meeting, the team summarized the scope and findings of the inspectio APPENDIX A SUMARY OF INSPEION FINDINGS DEFICIENCY 91-202-01 Finding Title:
Incorrectly Performed Nuclear Instrument Reliability Check (Section 3.1.1)
Description of Condition:
Between February 10 and 21, 1992, the team observed deficiencies in the licensee's performance of OP/2/A/1502/07, "Refueling Procedure." The licensee failed to correctly perform a required nuclear instrumentation reliability tes The procedure required that the reliability test be performd after loading two fuel assemblies and obtaining a stable neutron count rat However, the licensee continued to load fuel while collecting the required data for the test which resulted in obtaining erroneous dat The licensee did not stop fuel loading until questioned by the tea Additionally, the counting equipment which was installed to collect the required data was incorrectly configure This cordition was not noted by the licensee and was corrected only after the situation was identified by the inspecto Two additional fuel assemblies were loaded before fuel loading was stoppe The plant staff then collected the required data for the reliability test, which was found satisfactory, and then recommenced fuel loading Reference:
(1)
Procedure OP/2/A/1502/07,
"Refueling Procedure."
(2)
10 CFR 50, Appendix B, Criterion V which states that quality related activities shall be conducted in accordance with appropriate procedure A-1
DEFICIENCY 91-202-02 Finding Title:
Lack of Independent Safety Tag Verification (Section 3.2.3)
Description of Condition:
Between February 10 through 21, 1992, the team observed nultiple examples of approximiately forty in number where same block tagout (BIO) red tags had independent verification signatures while same did no For example, tags associated with the following equipment were not properly verified:
2BMDEFWP, 2AMDEEWP, and 2CHPI pump breakers Additionally, there were two unverified tags labeled 2FDW241 and 22 The valve on which the tags were placed were unlabele Station Directive 3.1.1, "Tagging" state that no work shall commence until the safety tags are placed and verifie References:
(1)
Station Directive 3.1.1, "Tagging."
(2)
10 CFR 50, Appendix B, Criterion V which states that quality related activities shall be conducted in accordance with appropriate procedure A-2
DEFICIENCY 91-202-03 Finding Title:
Lack of 10 CFR 50.59 Safety Evaluation for a Tenporary Modification (Section 3.2.3)
Description of Condition:
During a review on February 13, 1992, of the Unit 2 Removal and Restoration Log, the inspector noted that the reactor building radiation monitor (RIA) 49 interlock to valve 2IWD-2 had been junpered out using Station Procedure OP/0/A/1102/06 Enclosure 3.1 rather than a temporary modification as required by the subject directiv References:
(1)
Station Procedure OP/0/A/1102/06 Enclosure 3.1, "Removal of Station Equipment, " and Enclosure 3.2, "Restoration of Station Equipment."
(2) Oconee Nuclear Station Directive 2.3.5, "Control of Temporary Modifications."
(3)
10 CFR 50, Appendix B, Criterion V which states that quality related activities shall be conducted in accordance with appropriate procedure A-3
EXIT MEETING ATTENDEES Duke Power Personnel Barron, H. Station Manager, Gonee Nuclear Station Davis, J. Safety Assurance Manager, Oconee Nuclear Station Foster, W. Mechanical Maintenance Superintendent, Oconee Nuclear Station Hampton, J. Vice President, Oconee Nuclear Station Little, C. I&E Superintendent, Oconee Nuclear Station Mills, T. Generation Service Dept., Oconee Nuclear Station Millsaps, Camponent Engineering Manager, Oconee Nuclear Station Patrick, M. Regulatory Campliance Manger, Oconee Nuclear Station Peele, B. Engineerir Manager, Oconee Nuclear Station Perry, S. Regulatory Conpliance, Oconee Nuclear Station Ridgeway, Shift Operations Manager, Oconee Nuclear Station Rothenberger, G. Work Control Superintendent, Oconee Nuclear Station Sweigart, R. Operations Superintexdent, Oconee Nuclear Station Wilkie, L. Training Manager, Oconee Nuclear Station Nuclear Requlatory Conmission Personnel Ball, J. Team leader, Special Inspection Branch, NRR Belisle, G. Section Chief, Division of Reactor Projects, RII Desai, B. Oconee Resident Inspector, RI Harmon, P. Oconee Senior Resident Inspector, RI Imbro, E. Branch Chief, Special Inspection Branch, NRR Jenkins, R. Electrical Systems Branch, NRR Markley, M. Performance and Quality Branch, NRR Matthews, D. Director, PDII-3, NRR Mellen, Region II Merschoff, E. Deputy Director, Division of Reactor Safety, RII Poertner, Region II Shackelford, Region II Spaulding, D. General Engineer, NRR Thurman, Consultant, Parameter Wiens, Oconee Project Manager, NRR Wilcox, J. Team leader, Special Inspection Branch, NRR B-1
APPENDIX C AOP abnormal operating procedure B&W Babcock & Wilcox BM block tagout BWST borated water storage tank DPC Duke Power Qmpany GL generic letter HPI high-pressure injection IAE instrument and electrical INPO Institute of Nuclear Power Operations IPE individual plant evaluation ISG Integrated Scheduling Group LPI low-pressure injection LPSW low pressure service water MCC motor control center NED nuclear equipment operator NRC U.S. Nuclear Regulatory commission NSM nuclear station modification NUMARC Nuclear Management and Resources Council, In aHP operations manual procedure RCS reactor coolant system RCZ radiological control zone SD station directive SRO
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senior reactor operator C-1