IR 05000271/1988014
| ML20206C726 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/04/1988 |
| From: | Haverkamp D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206C716 | List: |
| References | |
| 50-271-88-14, IEB-85-003, IEB-85-3, NUDOCS 8811160382 | |
| Download: ML20206C726 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.:
50-271/88-14 Docket No :
50-271 License No.: DPR-28 Licensee:
Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Brattleboro, Vermont 05301 Facility:
Vermont Yankee Nuclear Power Station Inspection At: Vernon, Vermont Inspection Conducted: August 23 - October 10, 1988 Inspectors:
Geoffrey E. Grant, Senior Resident Inspector John B. Macdonald, Resident Inspector Approved by:
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pog' jl ' R.,pMiverkamp, Chief Date v Rfactor Projects Section No. 3C Division of Reactor Projects Inspection Summary:
Inspection on August 23 - October 10, 1988 (Report No. 50-271/88-14)
Areas Inspected:
Routine inspection on daytime and backshifts by two resident inspectors of:
actions on previous inspection findings; operational safety; security; plant operations; maintenance and surveillance; engineering support; radiological controls; licensee event reports; licensee response to NRC initi-atives; and, periodic reports.
Results:
1.
General Conclusions on Adequacy, Strength or Weakness in the Licensee's Prograg Several programmatic weaknesses were identified within the fire protection program including; lack of continuing system training in the requalifica-tion program; ambiguity in the Technical Specification (TS) bases as to fire protection system operability requirements; and, as a result, a lack of consistency in system operabi;ity determinations has been experienced (Section 6.1).
Increased management sensitivity and attention to the fire protection program is warranted to correct these weaknesses.
8811160302 001104 PDR ADOCK 05000271
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The licensee program to control temporary modifications exhibits some significant weaknesses. Most notable is a lack of Plant Operations Review Committee (PORC) review, approval and oversight of the temporary modifica-tion process. Various program deficiencies and inconsistencies, combined with a lack of independent oversight, indicate that a weakness in the assurance of quality exists in the control of temporary modifications.
The repetition of a violation involving failure to adequately monitor the service water (SW) effluent stream for radiation is indicative of a break-down in the licensee corrective action program.
Failure to adequately ensure effective corrective actions for a past violation indicates insuf-ficient management attention to this issue.
2.
Violations Three violations were identified during this inspection period.
Failure to establish a firewatch in accordance with TS requirements
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(Section 6.1).
Failu-e to obtain daily SW effluent samples when the SW radiation
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monitor was inoperable during hybrid and closed cycle plant opera-tions (Section 8.2).
Failure to perform an adequate review of design changes affecting
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fire protection system control panels (Section 9.1).
3.
Unresolved Items Three Unresolved Items were identified during this inspection period.
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Review of licensee actions to address weaknesses identified in the fire protection program (Section 6.2).
Review of licensee actions to ensure that controlled radiological
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areas are properly posted (Section 8.1).
Review of licensee actions to address programmatic weaknesses in the control of temporary modifications (Section 9.2).
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TABLE OF CONTENTS PAGE 1.
Persons Contacted.....................
2.
Summary of Facility Activities..............
3.
Status of Previous Findings (IP 92701, 92702)*......
3.1 (Closed) Follow Item 84-22-01:
Review of Licensee Response to Rosemount Model 1152-T0280 Transmitters with loose Amplifier Board Mounting Screws
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3.2 (Closed) Unresolved Item 85-10-02:
Review Revision to OP 2132 to Ensure Compliance with TS Requirements....................
3.3 (Closed) Unresolved Iten 85-10-06:
Review of Licensee Actions to Correct Deficie,1cies in Peer Inspection Process.....
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3.4 (Closed) Unresolved Item 85-23-03:
Follow-up of Regulatory Effectiveness Review Findings......
3.5 (Closed) Follow Item 85-30-02:
Review of Fire Protection Program Requirements..........
3.6 (Closed) linresolved Item 86-01-11:
Review of Licensee Actions to Correct Hanger Discrepancies..
3.7 (Closed) Unresolved Item 86-10-10:
Review of Concerns Raised by Former Site Contractor.....
3.8 (Closed) Unresolved Item 87-09-03:
Review Revision to Fuel Movement Procedure
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3.9 (Closed) Unresolved Item 87-04-05:
Review of Licensee Actions to Ensure Conformance with MR Processing Procedures...............
3.10 (Closed) Unresolved Item 86-10-13:
NRC Review of LER 86-02.....................
3.11 (Closed) Licensee Identified Item 88-06-03:
Failure to obtain Daily SW Effluent Sample When SW Radiation Monitor Was Inoperable..........
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Operational Safety (IP 71707, 71710)...........
4.1 Plant Operations Review.
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4.2 Safety System Review.
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4.3 Feedwater Leak Detection System..
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4.4 Inoperable Equipment.
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4.5 Review of Lifted Leads, Jumpers and Mechanical Bypasses......................
4.6 Review of Switching and Tagging Operations......
4.7 Operational Safety Findings.............
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Table of Contents (Continued)
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PAGE 5.
Security (IP 71707)....................
5.1 Observations of Physical Security..........
5.2 Off-site Arrest of Site Contractor...
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6.
Plant Operations (IP 71707, 93702, 64704).........
6.1 Fire Suppression System Alarm and Actuation.....
6.2 Failure to Establish a Firewatch
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6.3 Revies Impact of Extended Period of Record High Temperatures on Equipment Qualification.
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7.
Maintenance / Surveillance (IP 71710, 61726, 62703).....
7.1
"A" EDG Fuel Oil Day Tank Level Switch Failure....
8.
Rsdiological Controls (IP 71707, 92702, 83750)......
8.1 Controlled Area Posting...............
8.2 Service Water Ef fluent Radiation Monitoring.....
9.
Engineering and Technical Support (IP 37700, 37702, 64704, 40500)......................
9.1 Fire Protection System Panel Design Deficiency.
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9.2 Control of Temporary Modifications..........
10.
Review of Licensee Response to NRC Initiative:
(IP 92701).......................
10.1 IEB 85-03 RAI Response........
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11.
Review of Periodic and Special Reports (IP 90713).....
12. Management Meetings (IP 30703)..............
- The NRC Inspection Manual inspection procedure (IP) or temporary instruction (TI) or the Region I temporary instruction (RI TI) that was used as inspection guidance is listed for each applicable report section.
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DETAILS 1.
Persons Contacted Interviews and discussions were conducted with members of the licensee staff and management during the report period to obtain information per-tinent to the areas inspected.
Inspection findings were discussed periodically with the management and supervisory perscnnel listed below.
Mr. P. Donnelly, Maintenance Superintendent
- Mr. R. Grippardi, Quality Assurance Supervisor Mr. S. Jefferson, Assistant to Plant Superintendent Mr. G. Johnson, Operations Supervisor Mr. R. Lopriore, Maintenance Supervisor Mr. R. Pagodin, Technical Services Superintendent
- Mr. J. Pelletier, Plant Manager Mr. R. Wanczyk, Operations Superintendent Mr. T. Watson, I & C Supervisor
- Attendee at post-inspection exit meeting conducted on October 25, 1988, 2.
Summary of Facility Activities
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Vermont Yankee Nuclear Power Station (VYNPS or the plant) performed a controlled shutdown on August 24, 1988, to repair valve packing leaks which were causing an increasing leak rate in the drywell.
Return to power operations was accomplished on August 28.
The plant remained at essentially full power through the end of the inspection pericd with the exception of several 5*4 power reductions to facilitate off-site line main-tenance.
Throughout the period, weekly power reductions to 90% or 80*4 were conducted to perform routine control rod drive, main turbine and valve surveillances.
An automatic fire suppression system actuation was experienced in the east switchgear room on September 23 (Section 6.1).
Region I specialists conducted an emergency preparedness inspection August 30 - September 1, 1988 (Inspection Report 88-13).
An operator license examination was administered September 26-29, 1988 (Inspection Report 88-15).
An ISI specialist inspection was conducted September 12-16,1988 (Inspection Report 88-16) and a radiation controls specialist inspection was conducted September 26-30, 1988 (Inspection Report 88-17).
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Status of Previous Inspection Findings 3.1 (Closed) Follow Item 84-22-01:
Review of Licensee Response to Rosemount Model 1152-10280 Transmitters with Loose Amplifier Board Mounting Screws.
On' November 7,1984, the licensee submitted a 10 CFR Par +. 21 report notif1 cation that loose amplifier board mounting screws were found on several Rosemount transmitters.
The licensee, in conjunction with Rosemount, performed an evaluation of this event and could not determine a cause for the observed condition. Periodic Inspections of the screw tightness were conducted since, without any loosened screws identified.
The I&C department has incorporated Rosemount installation inspection recommendations into the EQ files of the 1152-T0280 transmitters as a special maintenance instruction.
The inspectors had no further questions.
This item is closed.
3.2 (Closed) Unresolved Item _85-10-02:
Review Revision to OP 2132 to
_ Ensure Compliance with TS Requirements. Revision 9 to OP 2132, "APRM Channels", was issued on May 2,1986, which defined an operable APRM channel consistent with the requirements of TS.
The inspectors had no further questions. This item is closed.
3.3 { Closed) Unresolved Item 85-10-06:
Review of Licensee Actions to Correct Deficiencies in the Peer Inspection Process.
Continued weak-ness in the resolution of NRC and licensee identified peer inspection program deficiencies resulted in the issuance of a notice of viola-tion (50-271/85-25-02). An NRC review of the licensee respor e and corrective actions to the violation determined that the app oriate I
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measures had been taken to resolve the deficiencies and the te ce was closed in inspection report 50-271/86-13.
The inspectors nad no further questions.
This item is closed.
. Closed) Unresolved Item 85-23-03:
Follow up of Regulatory.
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3.4 Effectiveness Review Findings.
A Region 1 Safeguards Specialist Inspection (50-271/87-20) conducted in October 1987 determined that the licensee corrective actions to this issue were adequate.
The inspectors had no further questions.
This item is closed.
3.5 (Closed) Follow Item 85-30-02:
Review of Fire Protection Prog ~ ram Reguirements.
The inspectors reviewed the fire brigade and lire-fighting procedure and routinely witnessed portions of fire brigade drills.
Further, a Region I fire protection specialist inspection (50-271/88-04) conducted in February 1988 determined that fire brigade training and drill records were adequate. The inspectors had no further questions.
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3.6 (Closed) Unresolved Item 86-01-11:
Review of Licensee Actions to Correct Hanger Discrepancies.
The inspectors reviewed the licensee
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actions to resolve the following four inspector identified field pipe hanger discrepancies.
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CST-H19:
This support had been improperly identified by tag.
The licensee ident!fied and verified the 10 supports in the CST pipe trench.
Individual as-built drawings were generated for each support.
b&c) RHR-H160 and HPCI-HD74B:
Both supports had excessive space between baseplate and fixed structure.
The licensee grouted between the baseplates and fixed structures to minimize gap concerns. An engineering evaluation concluded that this did not affect the ability of the support to perform its design function.
d)
RSW-H264:
Discrepancy in the welding of a shini.
The licensee initiated NCR 86-58 to address this weld.
The weld had been performed in accordance with the general notes but the design drawing had not been properly revised. The weld was accepted as is and proper clarifications and drawing revisions were implemented.
The licensee promptly resolved these issues.
The in:pectors had no further questions. This item is closed.
3.7.(Closed) Unresolved Item 86-10-10:
Review of Concerns Raised by i
Former Site Contractor.
In June 1986 a former site contractor expressed concerns to the resident inspector regarding the processing of maintenance requests (MRs), control and use of vendor manuals and
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receipt inspections.
Initial investigation and periodic follow-up by the inspector of the individual's specific concerns determined that no indications of a problem that would constitute an immediate safety concern existed.
The inspectors previously identified and continue to track as a separate issue weaknesses in the licensee's vendor information program. The inspectors had no further concerns regard-ing the issues raised by the individual.
This item is closed.
. Closed) Unrenolved Item 87-09-03:
Review Revision to Fuel Movement i
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Procedure.
The inspectors reviewed revision 16 to OR02, "liefuei Outage / fuel Movement Periodic Tests" and determined that all appro-priato equipment and interlock tests were directed for fuel movement within the spent fuel pool while at power, as well as when shutdown for refueling.
The inspectors had no further questions.
This item is closed.
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3.9 (Closed) Unresolved Item 87-04-05:
Review of Licensee Actions to Ensure Conformance with MR Processing Procedures.
On nine occasions in early 1987 it appeared that shif t supervisors had authorized the start of a maintenance activity prior to processing the MR.
The shift supervisor is authorized to allow work to be started immedi-ately, prior to additional management review in order to prevent the loss of important plant equipment, personnel injury or a plant trip.
However, in the nine-examples above none of these conditions appeared imminent.
The Operations Superintendent issued an Operations Memo dated June 30, 1987, to the shift supervisors that stressed the requirement to adhere to the normal MR process at all times when immediate actions are not necessary to prevent the loss of important equipment, personnel injury or a plant trip.
The inspectors had no further questions.
This item is closed.
3.10 (Closed) Unresolved Item 86-10-13:
NRC Review of LER 86-02.
The licensee issued LER 86-02 in accordance with 10 CFR 50.73 criteria following an engineering review determination that incorrect assump-tions had been made in the exposure calculation of components in the hydrogen / oxygen analyzer that invalidated its equipment qualifica-tion.
Correct exposure calculations determint that the Viton pump and regulator diaphrams and the Teflon adjusting arms on the alarm units would receive exposure in excess of qualification limits. The Viton diaphrams were replaced with Nordel/Nomax material and gaskets were replaced with Lex 4de material. The alarm units were replaced by units with stainless steel adjusting vanes.
The incorrect exposure assumptions were obtained by using a non-conservative planor source calculation vice a conservative hemispherical source calculation; also a mathematical error had been introduced regarding core fuel inventory.
The Yankee Nuclear Service Division (YNSD)
reviewed similar calculations without discrepancies.
It was concluded that this was an isolated event.
The inspectors reviewed portions of the MRs which directed the component replacements with properly qualified materials. The inspectors had no further questions.
This item is closed.
3.11 (Closed) Licensee Identified Item 88-06-03:
Failure to_Obtain Daily Service Water (S_W) Samples When the SW Radiation Monitor is Inoper-afile.
The licensee identified occurrences when the SW radiation monitor was actually o'
potentially inoperable due to circulating water system configurat. ion (closed or hybrid cycle) and the TS required daily samples were not taken.
The licensee reported these conditions in LER 88-01 and LER 88-01, Revision 1.
Because the licensee promptly reported this condition, had taken or planned cor-rective actions to preclude recurrence, and because this event was not related to corrective actions of a previous violation and was of a low severity level, no Notice of Violation was issued.
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5 implementation of the corrective actions as desc-ibed in the LERs was inadequate, in that SW samples routinely were not obtained when the plant was in closed or hybrid cycle operations. A Notice of Viola-
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tion (88-14-04) has been issued in this report as a result of the inability of the licensee to adequately implement corrective actions.
Resolution of this item will be tracked via the violation.
The licensee identified item is closed.
Operational Safety 4.1 Plant Operations Review The inspector observed plant operations during regular and backshift tours of the following areas:
Control Room Cable Vault Reactor Butiding Fence Line (Protected Area)
Diesel Generator Rooms intake Structure Vital Switchgear Room Turbine Building Control Room instruments were observed for correlation between chan-nels, proper functioning, and conformance with Technical Specifica-tions.
Alarm conditions in effect and alarms received in the control room were reviewed and discussed with the operators. Operator aware-ness and response to these conditions were reviewed. Operators were found cognizant of board and plant conditions.
Control room and shift manning were compared with Technical Specification require-ments.
Posting and control of radiation, contaminated and high radiation areas were inspected. Use of and compliance with Radiation Work Permits and use of required personnel monitoring devices were checked.
Plant housekeeping controls were observed including control of flammable and other hazardous materials. During plant tours, logs and records were reviewed to ensure compliance with station proced-ures, to determine if entries were correctly made, and to verify cor-rect communication of equipment status.
These records included various operating logs, turnover sheets, tagout and jumper logs, and Potential Reportable Occurence Reports.
Inspections of the control room were performed on weekends and backshifts including August 23-26, 29-31, and September 7-9, 12-15, 19, 21, 26-30, and October 3-4, and 7, 1933.
Operators and shift supervisors were alert, attentive and responded appropriately to annunciators and plant conditions.
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4.2 Safety System Review The emergency diesel generators (EDGs), EDG fuel oil, core spray, residual heat removal, standby gas treatment, residual heat removal service water, and high pressure coolant injection systems were reviewed to verify proper alignment and operational status in the l
standby mode.
The review included verification that (1) accessible major flow path valves were correctly positioned, (ii) power supplies were energized, (iii) lubrication and component cooling was proper, and (iv) components were operable based on a visual inspection of equipment for leakage and general conditions.
No violations or safety concerns were identified.
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4.3 Feedwater Leak Detection System Status The inspector reviewed the feedwater leakage detection system and the monthly performance summary provided by the licensee in accordance with VYNPC letter FVY 82-105.
The licensee reported that, based on the leakage monitoring data for August 1988, there were no deviations in excess of 0.10 from the steady state value of normalized thermo-couple readings, with the exception of point #12 on nozzle "C",
and no failures in the 16 thermocouples installed on the four feedwater nozzles.
The licensee is evaluating the significance of point #12 readings.
The inspector had no further questions in this area.
4.4 Inoperable Equipment Actions taken by plant personnel during periods when equipment was inoperable were reviewed to verify that:
technical specification limits were met; alternate surveillance testing was completed satis-factorily; and, equipment return to service upon completion of repairs was proper.
This review was completed for the following items:
September 13, 1988- "A" EDG was declared inoperable due to a
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ground in the fuel oil day tank low level alarm switch.
Refer to Section 7.1 for more detail.
September 23, 1988--east switchgear room fire suppression system
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was declared inoperable after it actuated and discharged the CO2 bottle bank.
Subsequent investigation revealed a
design deficiency common to both switchgear rooms, the cable vault and the control building fire protection system panels.
Refer to Sections 6.1 and 9.1 for more detail.
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4.5 Review of Lifted Leads, Jumpers and Mechanical Bypasses Lifted Lead and Jumper (LL/J) requests and Mechanical Bypasses (M8)
were reviewed to verify that controls established by AP 0020 were met, no conflict, with the Technical Specifications were created, the requests were properly approved prior to installation, and a safety evaluation in accordance with 10 CFR 50.59 was prepared if required.
Implementation of the requests was reviewed on a sampling basis.
LL/J 88-0034, implemented September 13, 1988 and restored September 15, 1988, was issued to isolate a ground detected on the "A" EDG fuel oil day tank low level alarm switch, LSL 108-3A.
This switch pro-vides alarm annunciation only.
Replacement of the switch was per-formed via MR 88-2332. Refer to Section 7.1 for more detail.
LL/Js 88-0037 - 88-0039, implemented September 28, 1988, were issued to shift the power supplies for the electric thermal links (ETLs) and the CO2 firing soleniod valves from the auxiliary 24 VOC supply to the back-up battery supply in the east switchgear room, west switch-gear room and cable vault fire protection panels, respectively. These LL/Js remain open.
Refer to Section 9.1 for more detail.
LL/J 88-0040, implemented September 30, 1988, was issued to shift the power supply in the control room fire protection panel from the auxiliary 24 VOC supply to the back-up battery supply.
This LL/J remains open.
Refer to Section 9.1 for more detail.
4.6 Review of Switching & Tagging Operations The switching and tagging log was reviewed and tagging activities were inspected to verify plant equipment was controlled in accordance with the requirements of AP 0140, Vermont Local Control Switching Rules.
The following switching and tagging orders were reviewed:
88-0919-- issued and restored on September 13, 1988, to support
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maintenance activities on the "A" EDG.
88-0923-- issued and restored on September 13, 1988, to support
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maintenance activities on the "A" EDG.
4,7 Operational Safety Findings Licensee administrative control of off-normal system configurations by the use LL/J, mechanical bypass, and switching and tagging proced-ures, as reviewed in Sections 4.4.4.5 and 4.6 was in compliance with
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procedural instructions and was consistent with plant safety. How-ever, programmatic problems were identified with the control of tem-porary modifications as described Section 9.2.
Licensee actions to minimize equipment out of service and time to return to service was noteworthy.
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Security 5.1 Observations of Physical Security Selected aspects of plant physical security were reviewed during regular and backshif t hours to verify that controls were in ac:ord-ance with the security plan and approved procedures.
This review included the following security measures: guard staffing; vital and protected area barrier integrity; maintenance of isolation zones; and, implementation of access controls, including authorization, badging, escorting, and searches.
No inadequacies were identified.
5.2 Off-site Arrest of a Site Contractor On September 10, 1988, the licensee was informed by a local law enforcement agency (LLEA) that a site contractor had been arrested earlier in thz day for possession of an illegal controlled substance.
The individual was initially stopped by the LLEA for erratic opera-tion of his motor vehicle for which he was also charged.
The licen-see immediately terminated the individual's site access.
The indi-vidual was contracted by Fluor Constructors, Inc. and was authorized unescorted access to the site on August 10, 1988, following comple-tion of the licensee fitness for duty program req'airements.
He had performed non-critical supervised functions.
The licensee response
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to this event was appropriate.
The inspectors had no further questions.
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Plant Operations 6.1 Fire Suppression System Alarms and Actuation On September 21, 1988, at 2:50 a.m. and again at 3:15 p.m. a spurious first detector fire alarm was received for the 416C volt (V) east switchgear room.
Upon response by the fire brigade, the fire pro-tection system was placed in "abort".
Following brigade team inves-tigations which revealed no indications of fire the system was returned to automatic operation.
On September 23,1988, at 4:25 a.m. with the plant at 100% power, a fire alarm was again received for the 4160 V east switchgear room.
Before the fire brigade could respond to abort thi. alarm and investi-gate, a second detector alarm was received and t5e east switchgear room carbon dioxide (C02) fire suppression system actuated and dis-charged the contents of its CO2 bottle bank into the room. The east switchgear room inlet ventilation dampers failed to isolate as designed and the exhaust damper whose automatic isolation is delayed five-minutes remained open. The ventilation air flow forced the CO2
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from the switchgear room through the open exhaust damper.
At 4:58 a.m., the toxic gas monitoring system (TGM) detected high CO2 concentrations in the control room ventilation inlet plenum, wnich is located in close proximity to the switchgear rooms.
The TGM alarmed and automatically isolated the control room ventilation system and actuated the control room breathing air pressurizing system.
In accordance with alarm response procedures, the control room operators donned self-contained breathing apparatus (SCBA) until a satisfactory control room atmosphere sample was obtained seven minutes later, at 5:05 a.m.
Satisfactory switchgear room atmosphere samples were obtained at 5:25 a.m.,
at which time a continuous firewatch was posted until the fire protection system was returned to service on September 29, 1988.
The control room operators responded appropriately to the CO2 fire suppression system initiation and subsequent TGM actuation.
However, the inspectors noted the determination of the licensee that this event was not reportable to the NRC in accordance with 10 CFR 50.72 criteria.
The inspectors stated to plant management that the thres-hold for a one-hour report per 10 CFR 50.72.b.vi was reached for this event based on the knowledge that:
a known C02 actuation had just occurred directly below the control reom; the TGM had alarmed and actuated due to a real indication of high CO2 concentration in the control room ventilation inlet plenum (85'4 of scale); and the oper-ators were required to operate the plant for several minutes in SCBA's. The licensee subsequently informed the NRC Operations Center (OC) of the event via the ENS phone. A follow up meeting was held with plant management to discuss reporting criteria in response to this event and a previous event (50-271/88-03-05) in which timely notification was not made to the NRC0C, The licensee is reviewing administrative reporting procedure AP 0156 to determine if revision is appropriate.
6.2 Failure To Establish a Fire Watch On September 20, 1988, a truck was positioned in the reactor building to support spent fuel pool reracking activities. Fire control permit (FCP)88-681 '.as issued to identify the presence of the transitory flarnable equipment.
The FCP required that a continuous fire watch be posted at the truck. The FCP also required that the recirculation motor generator (Md1 set foam fire suppression system control switch be placed in "abort" to prevent automatic actuation while the truck was in the reactor build'.3 The sensitivity of the ionization detectors is sufficient to actuate the foam system on detection of combustion products present in the truck exhaust gasses.
The duty shift engineer who approved the FCP determined that the posting of a firewatch was not necessary for the recirculation MG set area because he believed that the foam system remained operable, in that, an
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operator could respond to an alarm condition within normal system time delay periods and manually actuate the system. The shift super-L visor accepted the recommendation of the si.if t engineer and did not declare the foam system inoperable.
However, by definition, placing g
the control switch to "abort" rendered the foam suppression system
inoperable, in that the automatic actuation design function was l
defeated.
Whenever the recirculation MG set foam system is inoper-able, TS 3.13.G.2 requires that a one-hour firewatch be established,
a portable foam nozzle be brought to tne area and confirmation be
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made that a 100 gallon supply of foam. concentrate is available on-i site.
Because the foam system was incorrectly determined to be operable on September 20, 1988, a firewatch was not established and
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portable foam suppression equipment availability was not confirmed while the recirculation MG set foam system was in "abort".
Failure to comply with the requirements of TS 3.13.G.2 is identified as a violation (50-271/88-14-01).
I The immediate root cause of this event was the failure of the shift supervisor, who is ultimately responsible to make proper operability i
determinations, to correctly identify the foam system as inoperable.
Inspector review of the fire protection program revealed several weaknesses which may have been contributing factors to this event.
In general, it appears that the shift supervisors place excessive reliance on the recommendations of the shif t engineers, with regard to firewatch requirements and fire protection system operability determinations.
Review of FCPs pertaining to the recirculation MG set foam system dating back to 1984 indicated that approximately 20'4 of the permits issued which placed the foam system control switch to
"abort" did not require a firewatch to be established.
The TS 3.13 G.1 states that the foam system shall be operable whenever the recirculation MG sets are operating. Discussions with several past and present shift engineers indicated a lack of agreement of what constitutes foam system operability and when it is required to be operable. The TS bases are ambiguous as to the latter. The TS bases require the fire protection systems to be operable when the systems they protect are required to be operable.
However, the TS do not state which plant system is being protected by each fire protection system.
In the case of the recirculation MG set foam system, al-though it is designed to suppress a fire in the MG set area, it is actually protecting the RPS racks directly adjacent to the MG sets.
Fire protection system training is provided to shift engineers dur-ing initial qualification only, subsequent requalification training is limited to fire brigade procedures and responsibilities. Licensee response to these concerns with regard to the fire protection system in general and with regard to the violation above is identified as an unresolved item (50-271/83-14-02).
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6.3 Review of the Impact of the Extended Period of Record High Temperatures on Equipment Qualification During the record high temperatures of August 1988, the VYNPS reactor building ambient temperatures were cbserved to be substantially above normal expected readings.
On several occasions, specific maximum reactor buildi g area temperatures, as defined in the VYtiPS EQ Pro-gram Manual, were exceeded.
The licensee initiated f4CR 88-20 to evaluate the high reactor building temperatures with respect to um-ponent aging and accident analysis, consistent with EQ program (.
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The aging analysis, performed for occupied and unoccup
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volumes, is based on a yearly average temperature derived from assumed monthly average temperatures.
The EQ manual had previously calculated the yearly average temperature for occupied areas to be 79 degrees ( ) F based on an assumed maximum August average temperature of 95'F.
The EQ manual unoccupied areas average yearly temperature was 104*F, based upon constant average monthly temperatures of 104 F throughout the year.
During August 1988 however, the maximum average monthly temperature assumptions for both occupied and unoccupied EQ volumes were exceeded.
The worse case occupied volume average temperature was 104.14 F, recorded in EQ volume 42 (HPCI corner room). Recalculation of the yearly occupied volume average temperature, substituting 104.14 F for the August assumed value, resulted in a 1.5'; increase from the previous average of 79.0 F to 79.51'F.
The new yearly aver-age temperature was determined to have a negligible effect on the life of qualified equipment. The August worst case unoccupied volume average temperature was 112.52*F recorded in EQ volume 35 (drywell access).
A new yearly average temperature was calculated to be 104.71 F.
The EQ components in volume 35 were previously qualified to the main steam tunnel average temperature of 140'F.
Therefore, the change in the unoccupied volume yearly average temperature on qualified equipment 'ife was determined to be negligible.
Original accident analysis assumed a maximum reactor building temper-ature to account for the worst case elevated initial temperaturas identified above.
Equipment qualification analysis of equipment within the drywell was based on an assumed continuous ambient temper-ature of 194*F. This temperature limit was not approached during the month of August, therefore, the existing EQ assumptions remained valid.
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At no time during the extended period of recori high temperatures were the limiting conditions for continued operation of the plant impacted. The licensee evaluated the high temperatures with respect to EQ concerns in a conservative programmatic manner. As follow-up to this event, the Engineering Support Department is reviewing reactor building area temperatures over the last three years to determine if long-term trends exist which would requirw further EG manual revisions. The inspectors had no further questions in regard to this subject.
7.
Maintenance / Surveillance 7.1
"A" EDG Fuel Oil Day Tank Level Switch Failure On September 13, 1988, at 4:30 a.m.,
the AS-2 battery trouble alarm was received.
- nitial investigation identified a 110 VDC positive ground on the AS-2 battery charger which was attributed to the "A" EDG auxiliary control power circuit.
The
"A" EDG was declared inoperable and the circuit was isolated at 4:53 a.m.
Electrical maintenance troubleshooting traced the source of the ground to the
"A" EDG fuel oil day tank low level alarm switch, LSL 108-3A.
This switch performs only an annunciation function upon low day tank level and was classified as a safety class three (SC3) component.
Due to the immediate unavailability of a SC3 replacement switch, L L 'J 88-0034 was implemented to temporarily lift the switch leads and isolate the ground to allow the "A" EDG to be retu ned to service.
As a compensatory action to the loss of the low level alarm, the auxiliary operators were required to increase the frequency of recording of local tank level indication.
Further I&C rr. dew of the SC3 switch classification determined that only the mechaci.al press-ure boundary portion of the switch was SC3 to ensure tank integrity.
I&C concluded the electrical circuitry of the switch did not affect tank integrity and it did not perform a safety function, therefore, it should be appropriately classified as non-nuclear safety (NNS).
Following completion of the safety classification worksheet to re-classi,'y the switch, the electrical circuit for luvel switch LSL-108-3A was replaced with a NNS switch from stores.
The LL/J 88-0034 was restored and the alarm function of the switch was re-established.
The maintenance department response to this event was noteworthy.
Strong coordination and communication was evident by the electrical maintenance department in identifying the ground ard the I&C depart-ment in the switch replacement.
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Radiological Controls 8.1 Controlled Arn Posting On September 29, 1988, inspector review of in plant posting of con-trolle i radiological areas noted several dsficiencies.
In general, the licensee practice of not roping off or otherwise barricading the personnel entrance point to a contaminated crea was considered a weakness.
Administrative Procedure (AP) 0503,
"Establishing and Posting Controlled Areas" requires the use of various indicator mate-rial to mark off a contaminated area and requires the use of a "step-off" pad if access to the area is necessary.
Several contaminated areas in the plant were noted to have step-off pads but no barrier at the pad.
Between a lack of a barrier at the pad and the specific geometry of some of these areas, inadvertent entry into contaminated areas was possible.
Also noted was a lack of sign posting at the entrance to some contaminat J areas. In some cases the lack of post-ing at an area entrance constituted inadequate posting and violated AP 0503 requirements.
In particular, the northeast corner room required posting as a contaminated area as determined by a September 4 survey. Contrary to these requirements, the entrance to the north-east corner room at the 252 foot level was only posted as a radiation area vice contaminated area. Although these deficiencies were immed-iately corrected by the licensee, other area posting irregularities indicate a licensee review of current postings, posting control and posting accountability is necessary.
This item remains unresolved
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pending further inspector review of licensee corrective actions (50-271/88-14-03).
8.2 Service Water Effluent Radiation Monitoring Inspection Reports (IR) 50-271/88-03 ind 50-271i88-06 detail licensee problems with ensuring adequate radiation monitoring of the service water (SW) effluent stream.
Licensee Event Report (LER) 88-01, Revision 1, described circumstances where potentially a number of times in the past the plant SW effluent stream was not effectively monitored.
These pa:t instances arose from the fact that the SW
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effluent radiation monitor alarm setpoint is set at three times notinal backgt ound per the Offsite Dose Calculation Manual (CDCM).
Derivation of this alarm setonint assumes mixing / dilution with other clean plant effluent streams (notably the circulating water (CW)
systea) during "open cycle" (once through discharge to the river of CW after cooling the main condenser) plant ops ations.
During
"hybrid" or "closed cycle" operations and when the CW system is secured, this silution effect is either not present or is greatly l
reduced. Under these circumstances the SW effluent radiation monitor alarm s9tpoint exceeds 10 CFR Part 20 limits.
Thus, discharges in
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excess of Technical Specification (TS) 3.9.A.1 limits (10 CFR Part 20 limits) could possibly occur without alarm indication or licensee knowledge.
Plant TS 3.9.A.1 in conjunction with TS Table 3.9.1 reoutres the SW effluent radiation monitor to be operable with an alarn setpoint set to ensure that TS 3.9.A.1 limits (10 CFR Part 20 limits) are not exceeded.
If this condition is unable to be main-tained, then TS Table 3.9.1 requires grab sampling of the effluent stream every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As interim corrective action for this situa-tion, the licensee committed in LER 88-01, Revision 1, to perform daily grab sampling of the SW effluent any time the plant was not operating in open cycle.
The licensee past failure to adequately monitor SW ef fluent in accordance with TS as described in LER 88-01, Revision 1, was considered a licensee identified violation and was left open pending final licensee corrective actions (50-271/
88-06-03).
Inspector review of this issue identified a major deficiency.
Al-though Operating Procedure (0P) 2180, "Circulating Water / Cooling Tower Operation" was revised on April 13, 1938, to require notifying the Chemistry Department any time the plant shifted out of open cycle operations, no notification to the Chemistry Department occurred when plant operations shifted from open to hybrid or closed cycles on numerous occasions between August 15 to October 10, 1988.
Conse-quantly, required grab samples of SW effluent were not obtained dur-ing this period. Failure to make required notifications demonstrates poor communications between the Operations and Chemistry Departments and also implies that operators did not follow the revised OP 2180.
Failure to adequately ensure ef fective accomplishment of a violation corrective action indicates a lack of sufficient management over-sight.
Failure to adequately monitor the SW ef fluent system during hybrid and closed cycle operation is a violation of TS 3.9. A.1 and Table 3.9.1 (50-271/83-14-04).
9.
Engineering and Technical Support 9.1 Fire Protection Systen Panel Design Deficiency On September 28, 1938, during maintenance troubleshooting of the east switchgear room Pyrotronics fl protection system panel, a 2 ampere (A) 'use failed in t).e power supply circuit for the ventilation damper ETL's and the CO2 firing head solenoid valves.
The circuit was powered by the auxiliary 24 VDC supply of the CP-30 module, located within the panel.
Further investigation revealed that the CP-30 module power supply was not rated for the current capacity required to supply the loads of the ETL's and the firing solenoid valves.
The ETL's and firing soleroids nominally require 6-9A to actuate, with a maximum of approximately 15.5A, In actual system operation, upon receipt of a second detector alarm, the three inlet ventilation damper ETL's immediately fire, a 30-second time delay i
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circuit initiates for the firing solenoid valves (to allow personnel evacuation) and e five-minute time delay circuit initiates for the exhaust damper ETL (to prevent overpressurization of the room). The current drawn by the three inlet damper ETL's was determined to be 2.4-7.2A and 0.8-2.4A for the exhaust damper ETL (assuming a resis-tance of 10-30 ohms per ETL). The firing solenoid valves were deter-rined to draw 6.0A.
The CP-30 module auxiliary power circuitry for the west switchgear room and the cable vault fire protection system panels was inspected and found to be similarly wired. The licensee immediately declared these fire protection systems inoperable and instituted continuous firewatches of these areas in accorduce with TS 3.13 requirements.
Following engineerirq review and vender r.on-sultation, the licensee implemented LUJ renests (LL/J's 53-0037-0039) to terminate the CP-30 modale auxil3 cry power supplies and to temporarily power the ETL and firing soier.ofd inl e circuits from the backup power 9.0 A/hr batteries internal to ew:n canel (Section 4.5).
The batteries are maintained fully charged !.y internal battery e
chargers. On September 30, contirued licensee review determined that the control room control building Pyrotronics fire protection system panel module PS-31 was also similarly overloaded. The PS-31 module auxiliary power supply was also 24 VDC and fused at 2A.
The module output was used to power:
five control room and seven lube oil room vertilation d mper ETL's; the reactor building cable penetration area and turbine loading bay area deluge valves; and the recirculation MG set fcam system solenoid actuator valve.
A LL/J request (LL/J 83-0040) was implemented to terminate the module PS-31 auxiliary power supply and to temporarily power the loads from the internal panel 9 A/hr battery.
Technically the systems as descrited above had been inoperable since installation, in that, at any t imo a design deficiency could nave prevented the systems f rom perfor.r !n their intended safety func-tions.
The licensee reported tnis condition to the NRC, on September 28, in accordance with the requirements of 10 CFR 50.72.
It is recognized that the systems had succ.entully comple+ed required sur seillance testing in the past.
However the testing is not fully comprehensive, in that the ETL's are not actedly fired but instead the potential voltage 15 measured at this pojat h the circuit.
The switchgear rooms systems have actuated prop d y in the past in response to spurious alarms, as the east switc'ger panel system did on Septcmber 23, 1988.
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The overloading of the internal module auxiliary power supplies appears to be the result of inadequate review and evaluation of the design changes which directed the initial installation and subsequent modification of the Pyrotronics panels and incomplete incorporation of vendor drawings to the appropriate plant control wiring diagrams (CWD).
The first Pyrotronics panel installed was the control building panel in the control room, via PDCR 78-05.
Initially, the module PS-31 auxiliary 24 VDC supply was utilized to actuate only the solenoid vilves.
The PDCR 79-04 backfit various control building ventilation damper ETL firing circuits onto the PS-31 module auxiliary pcwer supply, exceeding the module design capacity.
The original common switchgear room and cable vault upgraded CO2 sup-pression systems were installed via PDCR 79-06. Review of ttis PDCR failed to identify the CP-30 overload condition that existed until discovered during the September 28, 1988 maintenance activities.
The common switchgear room was separated into the east and west switchgear rooms via PDCR 82-14. The existing fire protection system was dedicated to the west switchgear room and a new independent sys-tem was in'talled for the east switchgear room.
The review of this PDCR also failed to identify that powering the ventilation damper ETL's and the firing solenoid valves via the CP-30 module auxiliary power supply created an overload condition. Further, the appropriate fire protection system panel B-191301 series CWD's were inadequate, in that, the drawings failed to incorporate the 2A fuses in the CP-30 and PS-31 module auxiliary power supplies, which were clean ly iden-tified in vendor drawings 5920-6251 (PS-31) and 5920-6262 (CP-30).
Failure to ensure adequate design control review is a violation of the requirements of 10 CFR 50 Appendix B Criterion III (50-271/
88-14-05).
9.2 Control of Temporary Modifications The inspector reviewed the licensee process for initiating, review-ing, irplementing, and restoring temporary rrodifications. Applicable procedures were reviewed to evaluate content and quality in support of the modification process.
Several temporary modifications were reviened to evaluate adherence to existing procedures and sensitivity to safety impact.
The review determined that several weaknesses existed in the licensee program for control of temporary modifica-tions.
Notable deficiencies are detailed below and include lack of Plant Operations Review Committee (PORC) review of proposed temporary modifications, lack of approved procedures for installation and removal of temporary modifications, and inadequate control of tem-porary shielding and scaf folding.
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The controlling procedures foi administration of the temporary modif-ications process for electrical and mechanical systems is Adminis-trative Procedure (AP) 0020, "Temporary Electrical Jumpers, Lifted Leads, and Mechanical Bypasses". Review of this procedure noted some fundamental deficiencies. Nowhere in the temporary modification pro-cess does a proposed modification receive PORC review.
Technical Specification 6.2.A.6. d and e charge PORC with the responsibility of reviewing proposed changes or modifications to plant systems and to review plant operations to detect any potential safety hazards. On a bi-monthly basis the Shift Engineer reviews and informally evaluates outstanding temporary modifications and provides a summary of the results to PORC for review.
This process does not fulfill the PORC responsibility to review proposed changes or modifications.
Cur-rently, PORC does not review the safety evaluations (10 CFR 50.59 reviews) which accompany those temporary modifications affecting safety systems. Lack of this review detracts from the PORC responsi-bility to review plant operations to detect potential safety hazards.
A second deficiency was noted in the lack of a programmatic require-ment to install and remove temporary modifications using an approved procedure.
Technical Specification 6.2.A.6 requires PORC to review proposed procedures and provide recommendations to the Plant Manager.
Because PORC does not review proposed temporary modifications, no PORC review of an installation or removal procedure occurs. Because Ap 0020 does not require a detailed written procedure to be developed for temporary rrodi fication installation or removal, rarely is one generated or used. Generally, the modification request forms (VYAPF 0020.01 and 0020.02) are used to control the installation a.d removal of lifted leads / jumpers (LL/J) and mechanical bypasses (MB).
Use of these forms does not invoke normal procedural control activities such as precautions, prerequisites, detailed sequential performance steps, post-installation retests, parts required, quality control, and removal steps. Lack of these attributes represents a potential for a loss of quality control in the installation and removal process. A third deficiency was noted in the LL/J requests process.
If the originating department supervisor determines that a safety evaluation (10 CFR 50.59 review) is not required, then the Engineering Suncort Supervisor (ESS) is not afforded an opportunity to review the request. Lack of an ESS review removes a potential quality check in the request process. Making the sole determination of the need for a safety evaluation places a burden on the department supervisor to be well informed as to what actions constitute departures from the plant as described in the FSAR, knowledgeable of technical specifications, and of the safety significance of the modification.
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The controlling procedure for administration of temporary loads on plant systems (including lead shielding and scaffolding) is AP 0019,
"Control of Temporary Loads on Piping, Equipment and Structures".
The inspector noted during review of AP 0019 that PORC review of temporary lead shielding and scaffolding is net accomplished.
For reasons analogous to those already covered for temocrary LL/J and MB modifications, PORC review of temporary load installations is not required.
Additionally, AP 0019 allows unrevieM installation of shielding loads on safety-related systems for perads up to 30 days.
There is no apparent basis for this delay and it represents the potential for an unreviewed safety question to e ist for up to 30 days. Direct load applications of staging and scaffolding are also covered by AP 0019.
However, such applications apparently do not require safety evaluations or ESS review.
The licensee reasoning that differentiates between the controls necessary to install similar weights of lead shielding or staging on safety-related systems has no apparent basis and is unclear. Another area of weakness in AP 0019 is a lack of formal control of staging or scaffolding that represents a seismic hazard to safety-related equi. ment. These are applications where material is erected in the vicinity of safety-related equipment and has the potential for interfering with normal operation and/or accessibility, or where the possibility exists of an interaction dur-ing a seismic event.
Potential detrimental interaction between seismically unqualified temporary structures and safety-related equip ent requires pre-installation analysis to determine potential unreviewed safety questions do not exist.
The licensee program for control of temporary modifications contains several weaknesses.
Lack of PORC involvement in the process repre-sents a significant deficiency.
Overall, administration if the process within the limited requirements of the program has been acceptable with no apparent major problems.
However, the lack of independent oversight, limited reviews, and programmatic inconsis-tencies combine to represent a potential for future failures of the control process. Lack of PORC approved procedures to control instal-lation and removal of temporary modifications, lack of PORC review of proposed tempors v modifications, lack of PORC review of temporary moJification safety analyses, and inconsistencies and omissions in the program scope require licensee review and action.
Inspector review of licensee corrective actions remains an unresolved item (50-271/88-14-06).
10.
Review of Licensee Response to NRC Initiatives 10.1 IE Bulletin 85-03 9AI Response As requested by action item e. of Bulletin 85-03, "Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings," the licensee identified the selected safety-related valves, maximum differential pressures and the program to assure valve operability in VYNPC letter dated May 14, 1986. Review of this
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response indicated the need for additional information which was enclosed with a resident inspector memorandum dated March 30, 1988.
A copy of the requested information was also enclosued with a Region I letter dated June 2, 1988 (Inspection Report 50-271/88-06).
Review of the VYNPC response to the request for 4.dditional informa-tion dated May 5, 1988, determined that the licensee selection of the applicable safety-related valves to be addressed and the valves'
maximum differential pressures meets the requirements of the bulletin and that the program to assure valve operability requested by action item e. of the bulletin is now acceptable.
The results of the inspections to verify proper implementation of this program and the review of the final response required by action item f of the bulletin will be addressed in additional inspection reports.
11. Review of Periodic and Special Reports Upon receipt, the inspector reviewed periodic and special reports submit-ted pursuant to Technical Specificatiuns.
This review verified, as applicable: (1) that the reported information was valid and included the NRC-required data; (2) that test results and supporting information were consistent with design predictions and performance specification; and (3) that planned corrective actions were adequate for resolution of the problem. The inspector also ascertained whether any reported information should be classified as an abnormal occurrence. The following report was reviewed:
Monthly Statistical Report for plant operations for the month of
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September 1983.
12. Management Meetings At periodic intervals during this inspectior, meetings were held with senior plant management to discuss the findir gs.
A summary of findings for the report period was also discussed riter the conclusion of the inspection and prior to report issuance. No proprietary information was identified as being included in the report,
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