IR 05000293/1985026

Insp Rept 50-293/85-26 on 850820-0923.Violation Noted: Failure to Take Corrective Action to Ensure That Reactor Operator Overtime Properly Authorized

ML20133K748
Person / Time
Site:	Pilgrim
Issue date:	10/10/1985
From:	Mcbride M, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133K741	List: IR 05000293/1985026 IR 05000820/2009023 ML20133K738
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-2.B.2, TASK-TM 50-293-85-26, NUDOCS 8510220284
Download: ML20133K748 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-26 Docket N License N DPR-35 Category C Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station Location: Plymouth, Massachusetts Dates: August 20, 1985 - September 23, 1985 Inspector: /0 C!8I M/PcBride.j 6 enior Resident Inspector Date Approved By: .

[o!!9 LDripp,Cpef,ReactorProjectsSection3A Date Inspection Summary: Inspection on August 20 - September 23, 1985 (Report N /85-26)

Areas Inspected: Routine unannounced safety inspection of plant operations in-cluding: Followup of previous inspection findings and TMI Action plan requirements, operational safety verification and ESF walkdown, followup of events and non-rou-tine reports, surveillcnce and maintenance activities, authorization of operator overtime, and health physics activities. The inspection involved 86.5 inspection-hours by one senior resident inspecto Results: One violation was identified (Failure to take corrective action to ensure-that reactor operator overtime was properly authorized, Detail 8). An unresolved item concerning the lack of a recirculation pump surveillance test was identified in Detail Inspector concerns are discussed in Detail 2 concerning the adequacy of licensee corrective actions to prevent safety-related equipment from being out of service for extended periods during testing. Additional concerns regarding control of Maintenance Summary and Control (MSC) forms and regarding the adequacy of response to Radiological Occurrence Reports are discussed in Details 7 and 9, respectivel PDR ADOCM 05000293 G PDR

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TABLE OF CONTENTS Page Persons Contacted .............................................. 1 Plant Status ................................................... 1 Followup on Previous Inspection Findings and TMI Action Plan Requirements (NUREG 0737) ................................. 1 Previous Findings ......................................... 1 THI Items ................................................. 2 Operational Safety Verification and ESF Walkdown ............... 3 Scope and Acceptance Criteria ............................. 3 Findings .................................................. 3 Followup on Events and Nonroutine Reports ...................... 6 Events .................................................... 6 Review of Licensee Event Reports (LERs) ................... 8 Surveillance Testing ........................................... 8 Scope ..................................................... 8 Findings .................................................. 8 Maintenance and Modification Activities ........................ 9 Scope ..................................................... 9 Findings .................................................. 9 Authorization of Operator Overtime ............................. 11 Health Physics Activities ...................................... 12 1 Management Meetings ............................................ 13 Attachment A - Surveillance and Maintenance Items Attachment B - Unauthorized Overtime r

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DETAILS 1. Persons Contacted Within this report period, interviews and discussions were conducted with the members of the licensee and contractor staff and management to obtain the necessary information pertinent to the subjects oeing inspecte . Plant Status The reactor operated near full power throughout the report perio A reactor scram from 32% power occurred on September 1, 1985 and is described in Section 5 of this repor . Followup on Previous Inspection Findings and TMI Action Plan Requiremente (NUREG-0737) Previous Findings (Closed) Unresolved Item (85-01-01): Review actions to implement pro-cedural requirements for authorizing overtime. In January 1985 during NRC inspection 85-01, the inspector noted that no program was in place to ensure that excessive operator overtime was properly authorized in accordance with procedure no. 1.3.34. At that time, the licensec'(ndi-cated that a program would be developed to track overtime for safety re-lated work. However, the proced' ural requirements were not subsequently implemented. This item is closed for administrative purposes, as a violation is being issued for this area (see Section 8).

(0 pen) Unresolved Item (85-20-03)': Review licensee's met. hod of taking reactor protection system (RPS) and primary containment isolation system (PCIS) equipment out of service for surveillance test'.1g. On September 11, 1985, the inspector expressed concern that the licensee had not taken action to prevent RPS and PCIS instrumentation from being removed from j service for extended periods of time. This problem was identified on

August 12, 1985, when main steam line high radiation monitors were re-I moved from service. The inspector subsequently discussed the problem

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l with licensee management on at least two occasion On September 12, 1985, the Plant Manager issued a memo to control room and maintenance personnel restricting the time that an RPS instrument'

channel may be taken out of service for surveillance testing without tripping the RPS channel to two hours. The licensee indicated that the same restriction applied to PCIS instrumentation and that the meno would be modified and reissued. This policy is consistent with the standard L

technical specifications. The licensee also indicated that an amendment to the technical specifications would be submitted to the NRC within 90 days, clarifying the RPS and PCIS operability requirement '

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This item will remain open pending the revision of the licensee's policy memo and submittal of the technical specification chang (Closed) Follow Item (85-21-02): Review licensee's evaluation of secon- .

dary containment integrity. On September 1, 1985 at 7:50 a.m., the lic-J ensee conducted a partial "as ~ found" secondary containment leakage test following a reactor scram. The test demonstrated that secondary con-tainment vacuum was maintained, despite the recent secondary containment damper problems (NRC Report No. 50-293/85-21). The inspector observed the test and verified licensee manometer reading Following the test, the licensee found that the temperature rose only 5 degrees F in the steam tunnel during the reactor building isolatio Reactor pressure was about 800 psig during the test and the main steam isolation valves were open. The licensee indicated that the observed temperature rise during the test was less than expected, based on a cal-culated temperature rise at power of 3 degrees F per minute. The calcu-

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lated temperature rise and the resulting risk of scramming the reactor was previously used to justify not conducting a secondary containment leakage test at power. The licensee indicated that the temperature cal-culation would be reviewe On September 3,1985, a full secondary containment leakage test was con-ducted, prior to reactor startu The reactor building vacuum varied between 0.27 and 0.36 inches of water vacuum during the test. This ex-ceeds the technical specification requirement of 0.25 inches of water vacuu The inspector had no further questions regarding the adequacy of secondary containment at this time. This item is. closed.

11 TMI Items (0 pen) Item I.A.1.3.I', limit overtime for personnel performing safety related work. The guidelines for approval of overtime for licensee per-sonnel who perform safety re. lated work contained in Generic Letter N '

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82-12 were incorporated into licensee procedures in 1984. However, the procedural requirements have not been fully implemented. This item will be closed and the implementation of the guidelines neviewed further dur-

ing followup to the violation in Section 8 of this repor (Closed) Item I.A.1.3.2.A. shift manning. The recommended staffing levels of this item have been superseded by-the staffing requirements '

of 10 CFR 50.54. The licensee maintains shift staffing levels consistent ,

with this regulatory requirement. This item is close (0 pen) Item II.B.2, environmental qualification of safety related equipment. The environmental qualification of post accident monitoring l equipment was reviewed during a recent inspection of the post accident

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sampling system, NRC Inspection No. 50-293/85-2 The environmental  !

qualification of other plant equipment will be reviewed during a planned  !

EQ inspection later this year. Findings from these two inspections will  !

be reviewed during routine followups. This item will be closed after ,

successful completion Gf these activitie !

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. Operational Safety Verification and ESF Walkdown

, Scope and Acceptance Criteria I The inspector observed control room operations, revie * ,e Wt- foss

, and records, and held discussions with control room QemFmo WW i

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spector reviewed the operability of safety-related 3*' e 4tf R m @ [

toring systems. Tours of. the reactor building. t Mee w !3h ,, stati n i

yard, switchgear rooms, diesel generator room' dttry r%, ,mi t.* i l trol room were conducte !

Observations included a review of equipment 4 -14 bis W rity, house- [

l keeping, radiological controls, and equipmens " = + P M ging). [

rThe inspector verified the operability of a selected Engineered Safety l Feature (ESF) ' system, the Standby Liquid Control System, by performing  !

a walkdown of accessible portions of the system on September 19, 198 (

j As found valve positions were compared to station drawings. General }

l housekeeping was also reviewed during the walkdown. The inspector iden-  !

l tified no inadequacies, j These reviews were performed in order to verify conformance with the facility Technical Specifications and the licensee's procedure '

I Findings [

! (1) On August 27, 1985, the high pressure coolant injection (HPCI) sys- l tem was declared inoperable after a hydraulic oil leak was observed j during a routine surveillance tes The leak was in a hydraulic  !

control line for the HPCI turbine stop valve. The licensee indi-

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cated that the line was bent out of its expected alignment, presum-

, ably by individuals stepping on the line while working on the.tur- j j

i bine. The line failure occurred near a reducing fitting and ap- F peared to be a tear in the lin No previous failures of safety  !

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systems during the current cycle have been attributed to this type j of proble The licensee plans to distribute an LER on the incident t to station chiefs in charge of work in the HPCI area. The inspector  !

had no further questions.at this tim !

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. Following the line repair, the HPCI system was tested. During this i test, one of two HPCI steam exhaust line diaphrams leaked steam, I l generating a diaphram high pressure alarm in the control room. The j licensee investigated and found that the inboard diaphram showed i signs of flexure, and apparently had developed pinhole leak l t

The licensee determined that the installed diaphram did not have f

a reinforcing back support. Instead, an older style diaphram (type l D) had been installe The licensee stated that either the type  ;

D or DV diaphram was acceptable and would protect the exhaust line  !

from overpressur However, the type DV diaphram was preferred be-  :

cause it was less susceptible to failure from repeated routine steam i

, line pressure transient !

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The licensee replaced the diaphram with a type DV diaphram and suc-

! cessfully tested the HPCI system. ~ The licensee also verified that

, no additional type D diaphrams were in stock on sit The plant

purchase order codes have been changed to require the type DV dia-phram The inspector had no further questions at this tim No inadequa- e cies were identifie l (2) On August 29, 1985 at 11:40 a.m., the reactor core isolation cooling '

(RCIC) system was declared inoperable after a worker noticed that a part was missing from the RCIC turbine overspeed trip linkag ; This part, a linkage key, is required to be in place for.the over-

speed trip to functio The licensee visually inspected the system ;

l and identified no further problem The key was replaced and the !

RCIC returned to service later that day. The licensee last tested  !

the overspeed trip mechanism during the January 1985 startup. .The f

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RCIC turbine was successfully operated during subsequent surveil-  !

lance testing. The inspector had no further question (3) On September 1, 1985, secondary containment damper A0-N-95 would i'

l not fully close during a damper inspection. This damper is one of two isolation dampers mounted in series in the reactor building i contaminated exhaust syste This damper is not accessible while [

the reactor is at power. The licensee promptly isolated the con-  !

taminated exhaust system and repaired the damper. The inspector i

reviewed the maintenance and post work testing package and had no  !

i further questions. No. inadequacies were identifie I

i (4) On September 3, 1985 while the reactor was shut down, a' diver visu- l ally inspected th.e two salt service water bays for evidence of de- i bris. While some items were found in the bays (a pipe wrench, bolts,  !

pieces of metal), no debris was noted that had the potential to in- ,

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terfere with the salt service water pump }

i The pump suctions for two salt service water pumps were found par- [

tially blocked with debris during August (NRC Report No. 50-293/85-  !

20). Since that time, the licensee has closely monitored pump dis-  !

charge pressures for evidence of further pump blockage. No addi=  ;

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tional problems have been noted. The inspector had no further

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questions regarding debris in the salt service water bays. No in- [

adequacies were identified, j

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(5) On September 8, 1985 at approximately 10:00 a.m., the inspector }

noted a non-licensed reactor engineering technician sitting in front  ;

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of the process computer terminal in the control room with his head resting on the table, apparently asleep. The control room super- j visor was standing next to the technician, but did not rouse the j technician until after the supervisor ' noticed the inspector in the  !

control room. The incident occurred on a Sunday morning at the end e of a reactor startu ,

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The technician indicated that he was somewhat tired, but stated that j he had not been sleepin The technician had worked twelve-hour shifts during the previous week due to two attempted reactor start- .

ups and had assisted in calculating reactor power increases required to maintain fuel warranty limit The technician's supervisor stated that the technician had not been involved with safety related '

surveillance testing on September The control room supervisor stated that the technician had not shown  ;

a previous indication of fatigue during the shif The supervisor i

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~was aware of NRC Information Notice 85-53 which discussed poten-tially distracting activities in the control room.

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The licensee initially stated that the technician was not subject i to the overtime controls in procedure no. 1.3.3 However, Generic ,

Letter No. 83-14, dated March 7, 1983, indicates that overtime ,

should be controlled for all personnel who calibrate safety related  ;

component The reactor engineering technicians routinely calibrate i safety related components, including local power range monitors (LPRM's) and average power range monitors (APRM's).

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At the exit interview, the licensee indicated that the' applicability  ;

of the overtime restrictions for reactor engineering technicians '

would be reviewed. This item is unresolved (85-26-01).

l A non-licensed technician had been noted sleeping in the control  :

room during January 1985, NRC Inspection 50-293/85-0 No evidence i of excessive fatigue has been identified during routine inspections  !

of control room activities since then. The inspector checked week- ,

end activities in the control room twice between September 9 and  ;

the end of the inspection period. One of these checks was at 5:45 a.m. on a Sunday mornin No inadequacies were identifie f (6) On September 13, 1985 at 11:30 a.m., the "B" loop of the reactor [

building closed cooling water (RBCCW) system lost pressure when a e

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3/4 inch RBCCW line to the "B" reactor water cleanup pump broke.

The licensee promptly isolated the broken RBCCW line and reestab-  !

, lished RBCCW loop pressurt.. The licensee reported that the loop l had been inoperable for about fifteen minutes to the NRC-via the ENS telephone lin '

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The inspector visually inspected the line break. The line sheared cleanly at a threaded fitting on the RWCU pump. The licensee indi-cated personnel were in the process of shutting the RWCU pump down i because of.high pump vibration when the line faile The pump in- !

! ternals have been replaced and the vibration problem remedied. The i licensee is considering use of a flexible line at the RBCCW piping *

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to the RWCU pump connectio !

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The inspector had no further question No inadequacies were iden- !

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(8) On September 16, 1985, the "B" loop of the low pressure coolant in-jection (LPCI) mode of the residual heat removal system was isolated for environmental qualification modification Compensatory sur-veillance testing of other low pressure core and containment cooling systems was completed prior to isolating the LPCI loo During post work testing on September 20, 1985, the motor operator on a LPCI injection valve M0-1001-29B tripped on thermal overload when the licensee tried to open the valve. The licensee subsequently replaced a failed motor in the motor operato The licensee could not determine whether an electrical transient caused the motor to fail or whether a motor failure caused an elec-trical transient which tripped the breaker on thermal overloa Licensee records indicate that the motor was installed in 1973 and was not modified during the recent environmental qualification wor The motor was subsequently replaced and the LPCI system returned to service. The.MO-1001-29B valve functioned normally during post work testin The inspector had no further questions.

5. Followup on Events and Nonroutine Reports

_ Events (1) On September 1, 1985 at 5:20 a.m., the reactor scrammed from 32%

power on reactor high pressure following a main generator load re-jectio (The technical specifications allow the main generator load rejection scram trip to be bypassed below 305 psig turbine first stage pressure which corresponds to about 45% power.) The load rejection occurred when a 345 kv switchyard circuit breaker opened following electrical arcing in the switch yard. The arcing was caused by a buildup of ocean salt on switchyard insulator ,

Licensee personnel were washing the insulators with high pressure '

water at the time of the arcin Reactor power had been previously educed to backwash the main con- i denser The NRC was notified of the event via the ENS telephone lin Reactor pressure increased following the load rejection and tripped three of four reactor high pressure switches. The control room chart recorder for wide range reactor pressure indicated a pressure peak of 1040 to 1060 psig. No main steam line relief valves lifted i prior to the scra i The reactor pressure switches were set to trip between 1068 and 1073 psig (without water leg pressure) during the most recent calibratio Normal full power operating pressure is about 1035 psig. The lic-ensee subsequently found that the switch trip setpoint for the un-

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I tripped switch had drifted slightly higher to 1078 psig. The in-spector reviewed the calibration history of the switche No evi- -

dence of excessive drift was noted. The technical specifications require the high pressure trip set point be less than 1085 psi Control room personnel did not receive indication that the main

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turbine bypass valves opened during the transient. The valves were ,

i subsequently checked, but no problems identified. Offsite power was maintained following the load rejection via the startup trans- t former. The licensee recovered from the scram using routine methods ,

and subtequently cooled the reactor down to below 212 degrees ;

The dyrwell was subsequently deinerted and a leaking recirculation 1 pump seal replace A reactor startup was initiated on September 5, but the reactor was shut down later that day for additional re- ,

pairs to the recirculation pump sea The reactor was restarted +

on September !

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The inspector reviewed the licensee's post trip review package, j i (Procedure No. 1.3.37) and reactor cooldown surveillance record i No inadequacies were ider.tifie !

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, (2) On September 11, 1985 at 12:46 p.m., the licensee initiated a reac- l

tor shutdown from 100% power after finding a dye penetrant indica-  !

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tion on the torus penetration for the 20 inch HPCI steam exhaust ,

lin The indication was subsequently determined to be a surface  ;

i scratch and removed. The shutdown was terminated that evening at i

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25 i This event is discussed further in Section 7 of this report, f

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(3) On September 20, 1985 at 10:27 p.m., an unusual event was declared {

] and a reactor shutdown from 100% power was initiated after the "A" i i

emergency diesel generator and the LPCI mode of the RHR system were  ;

, found to be simultaneously inoperable. The unusual event and the l l reactor shutdown were terminated three hours later after a fuel pump [

belt had been replaced on the diesel generato l i

The diesel generator was declared inoperable after a drive belt [

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failed for the diesel generator: shaft-driven fuel oil pump during i

a surveillance. test. The test was required to be conducted because  !

! the LPCI system was inoperabl A backup d.c. fuel oil pump auto-  ;

matically started when the belt faile The licensee tested the j

, diesel generator for about two hours after the belt failed before  !

declaring the diesel inoperabl The licensee believed that the y diesel may have still been operable with the backup fuel pump, but did not have operational data with the d.c. pum ,

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The inspector discussed the belt failure with licensee personne The licensee is considering establishing a belt replacement progra Repetitive failures of the fuel pump belts occurred in 198 No previous belt failures have been noted during this cycl The in-

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spector had no further questions concerning the licensee's actions

, at this time. The LPCI inoperability is discussed further in Sec-

tion 4 of this report. No inadequacies were identifie Review of Licensee Event Reports (LERs)

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! Licensee Event Reports were reviewed to verify that the details were clearly reported and that corrective actions were adequat The inspec-tor also determined whether generic implications were involved and if on site followup was warranted. The following reports were reviewed:

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85-20 Failure to Conduct Compensatory Surveillance Tests for an Inoperable Emergency Diesel Generato Main Steam Line Radiation Monitors Found Outside Technical Specification Limit The incident described in LER 85-20 was reviewed during NRC Inspection 50-293/85-21. The incident described in LER 85-21 was reviewed during

NRC Inspection 50-293/85-2 The inspector had no further question No LER inadequacies were iden-tified.

t Surveillance Testing

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! The inspector reviewed the licensee's actions associated with surveil-lance testing in order to verify that the testing was performed in ac-l cordance with approved station procedures and the facility Technical Specifications.

( A list of the items reviewed is included in Attachment "A" to this report, Findings On September 18, 1985, the it.spector noted that the licensee's reactor recirculation pump start check list, No. 2.1.9A did not require that the reactor coolant temperatures n the dome and the bottom head drain be compared and logged priotteach recirculation pump start, as required by Technical Specification 4.6. A.S. The procedure requires that the tem-peratures be compared and logged only if both . recirculation pumps are stopped. The licensee indicated that one recirculation pump probably

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provided enough reactor flow to prevent temperature stratification in the vessel. The licensee agreed to formally evaluate the necessity for logging the dome and bottom head coolant temperatures when the second pump is started. The licensee implemented a procedure change that re-quires.that the temperatures be recorded prior to all recirculation pump start This item is unresolved, pending the completion of the licen-see's evaluation (85-26-02). Maintenance and Modification Activities Scope The inspector reviewed the licensee's actions associated with maintenance and modification activities in order to verify that they were conducted in accordance with station procedures and the facility Technical Speci-fications. The inspector verified for selected items that the activity was properly authorized and that appropriate radiological controls, equipment tagging, and fire protection were being implemente A list of the items reviewed is included in Attachment "A" to this repor . Findings (1) On September 10, 1985, dye penetrant indications were identified on the. torus penetration of the HPCI steam exhaust lin The indi-cations were identified after temporary instrumentation was removed from the HPCI system. The installation of some of the instrumenta-tion caused the HPCI system to be made inoperable earlier this year and was the subject of a special NRC inspection, No. 50-293/85-1 The inspector reviewed the work packages associated with the removal work and discussed the following problems with the licensee:

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The contractor who identified the penetrant indications on September 20 did not promptly notify the licensee. The con-tractor left a written report of the indication on the desk of licensee QA personnel in the afternoon. However, licensee personnel had left for the day and did not find out about the problem until the next morning. The procedure controlling the dye penetrant examination required that the contractor notify the licensee of indications, but did not require that the notification ue immediat Licensee Procedure No. TP85-72 listed the contractor procedures that could be used to install and remove the HPCI instrumenta-tion. Procedure TP85-72 states that a revision to any of the contractor procedures requires a revision to TP85-7 The licensee stated that the revision requirement was specifically

! incorporated into TP85-72 to control contractor procedures.

f The contractor had signed TP85-72, thereby acknowledging the revision requirement.

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However, the contractor revised the procedure for removing the HPCI instrumentation, EP-3-064, and did not revise procedure

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TP85-72. Procedure EP-3-064 was revised at the request of licensee QA personnel to incorporate additional guidance for the removal of instrumentation from the HPCI steam lin Use of the unapproved revision did not cause the work to be degraded. However, the inspector expressed concern that de-spite the additional attention focused on the HPCI instrumen-tation work after inspection 85-16, the licensee's procedural controls were still not totally implemented. The licensee subsequently terminated the site access of the contractor who had performed the HPCI instrumentation wor The current maintenance request (MR) procedure, No. 1.5.3, does l not specify how maintenance summary and control (MSC) attach-ments to MR's should be used. The MSC's are typically filled out after the MR has been approved and have the potential of extending maintenance work beyond the scope of the original authorized M The MSC for the HPCI instrumentation MR (MR 85-357) gave in-structions for installing additional instrumentation on the HPCI control and stop valves and HPCI exhaust line, beyond the instructions on the original approved MR. In this instance, the work was controlled and licensee management was aware of the scope change. However, without specific guidance on how the MSC is_to be used, work can be added via MSC's which ex-ceeds the authorized scope of the original M The licensee acknowledged the potential for abuse of the MSC system and indicated that the maintenance procedure will be revised to in-clude instructions on MSC use. No instances of unauthorized main-tenance scope changes were identified during the inspection perio This item will remain open, pending the issuance of the revised MR procedure (85-26-03).

(2) On September 18, 1985, an electrical ground developed in the "A" bus of the 125 v d.c. station power system due to a steam leak in a RCIC steam line drain valve, no. A0-1301-32. The ground was traced to limit switches used to indicate valve positio After the licensee repaired the steam leak, the switches dried and elec-trical resistance was reestablishe The inspector questioned the environmental qualification implica-tions of the electrical groun The valve limit switches are not required to be environmentally qualified because neither the valve nor the switches are considered essential to RCIC operation. How-ever, multiple grounds in unqualified equipment such as the switches

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J j might adversely affect the 125 v d.c. system. Power ~from this sys-l tem is required to operate several safety systems, including the j RCIC and HPCI systems.

1 At the close of the insoection period, the licensee had not com-

] pleted an evaluation of this potential problem. The licensee's

! actions will'be reviewed during a subsequent inspection (85-26-04).

l (3) On September 23, 1985, the inspector toured the Technical Support Center (TSC) with licensee personnel.. The TSC area is being modi-fied in preparation for the installation of a new process compute '

The inspector reviewed TSC equipment for evidence of degradation j caused by construction activitie Only one potential problem was ,

noted, some of the TSC telephones had been disconnected. Additional

! telephones were available in an adjacent area. The licensee indi-

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cated that the disconnected telephones would be promptly reconnected

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and that licensee construction personnel would be more sensitive to disconnecting TSC equipment in the future. The inspection had no further question i 8. Authorization of Operator Overtime i

! The inspector reviewed the overtime records for on shift licensed reactor i operators (R0s) and noted several instances where excessive amounts of over-

{ time were not properly authorized by the Plant Manager (Attachment B).

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{ The licensee currently has only 10 R0s working on shift. One of these opera- i

, tors has a senior operator license but functions as an R The R0s are re- !

sponsible for routine manipulation of the reactor controls as well as a vari-l ety of nonsafety related wor Licensed senior operators on shift are re-

stricted by their job descriptions from conducting R0 duties.

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l The R0s have worked a large amount of overtime during the past several months [

l to cover vacations and other routine absences. This situation was discussed '

at a recent meeting between NRC and licensee management (NRC Meeting Report '

50-293/85-25). During that meeting, the licensee indicated that the operating j staff would be enlarged and more operators licensed in the future. Previous NRC concerns about the low number of licensee R0s were discussed in the 1983 and 1984 Systematic Assessment of Licensee Performance (SALP) report [

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The Plant Manager stated that his approval for overtime was logged in the  !

! control room supervisor's log. The inspector reviewed the log, but found no indication that the overtime periods listed in Attachment B to this report I

were authorized by the Plant Manager, ,

Licensee Procedure 1.3.34, " Conduct of Operations", requires in part that the '

Plant Manager authorize overtime for personnel involved in safety related ac- <

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tivities if work time would exceed 16-hr in a 24-hr period, 24-hr in a 48-hr &

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period, or 72-hr in a 7-day period. The inspector noted instances where ,

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overtime exceeding the 16-hr in a 24-hr limit were properly authorized and i

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logged. However, no control room log entries were noted which authorized overtime in excess of the 24-hr in a 48-hr and 72-hr in a 7-day limits.

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.The need to develop a program to implement the 48-hr limit was discussed dur-  ;

1 ing NRC inspection 50-293/85-01. An unresolved item on this issue was opened i at that time. In response to the item, the licensee indicated that a program l'

would be developed to better track anri authorize overtime. However, licensee corrective actions were not sufficient to prevent operators from exceeding

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the 48-hr limit on several subsequent occasions (Attachment B). j

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During the current inspection, the licensee indicated that management was not

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aware that an R0 had worked 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> in a 7-day period (July 14-20, 1985) un-

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til the following week, July 21-27, 1985. In response to this incident, the licensee instituted 12-hr shifts to control the overtim ,

j However, this cor-

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rective action did not prevent subsequent operators from exceeding the 7-day limit without authorization (Attachment B).

I i j 10 CFR 50 Appendix B, Criterion XVI, " Corrective Action", requires that con- [

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ditions adverse to quality be promptly identified and corrected.- Failure to '

properly authorize licensed reactor operator overtime is a condition adverse l

, to qualit Failure to correct this condition following NRC Inspection 50-

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293/85-01 and following the discovery of unauthorized operator overtinie during *

, the week of July 14-20, 1985 are examples of a violation of 10 CFR 50 Appendix i B, Criterion XVI (85-26-05). ,

I i 9. Health Physics Activities

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i On September 16, 1985, the licensee's independent Radiological Assessor l j indicated that the locked high radiation area door to the chemical waste t i treatment room on the -1 ft elevation of the reactor building had been j found open twice. The !.ssessor indicated that he had found the door open

} i that day (September 16) and had previously found it open a month earlie !

I The Assessor indicated that the door locking mechanism was defective,

{ i.e., the door had to be slammed to latch the lock. He indicated tha i i

a Maintenance Request had been submitted a month earlier to fix the lock j but the lock had not been fixed ye !

l The inspector discussed the problem with the licensee. At the time of ,

, the discussion, the licensee had not acted to lock the door by an alter-  ;

nate method. The licensee verified that the Assessor had reported the  ;

door open in ROR No. 85-8-15-756, dated August 15, 1985 and in ROR N !

! 85-9-16-837, dated September 16, 198 l 1 i i In response to the inspector's concern over corrective action, the lic- l l ensee secured the door closed with a chain and padlock. The inspector  :

reviewed a recent radiological survey of the area and noted that the l l radiation levels were less than 800 mR/hr. Technical Specifications do  ;

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not require high radiation areas to be locked unless radiation levels i i exceed 1,000 mR/h The licensee indirated that radiation levels in the .

} room were stabl [

s i A subsequent licensee review of this incident found that the door had q been found open previously and reported in ROR No. 85-5-21-366,. dated  !'

May 21, 198 This ROR also indicated that the door had to be slammed

! shut to latch the loc ;

i Licensee radiological management was not aware that the room had radi-I ation levels below 1,000 mR/hr prior.to the inspector's questions in

September 1 The inspector expressed concers, over-the lack of licensee !

l corrective action for the repetitive RORs on this door lock.

l The Radiological Section Head stated that the ROR system was being re- i

viewed. The Section Head indicated that until the ROR system is revised,  !

j potentially significant RORs including RORs concerning locked high radi- l

) ation levels would be immediately bought to the Section Head's attentio j

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The promptness and adequacy of the' licensee corrective ~ actions for ROR I findings will be reviewed during a future inspection (85-26-06). {

} The following information is included in this report to assist NRC man-  !

agement in following radiation exposure at the station. The monthly  ;

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personnel radiation exposure for August 1985 was 72.1 person-rems. The  ;

total yearly exposure through September 4,1985 was 583.8 person-rem l

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1 1 Management Meetings

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! During the inspection, licensee management was periodically notified of the i

! preliminary findings by the resident inspectors. A summary was also provided i i at~ the conclusion of the inspection and prior to report issuance. No written  !

material was provided to the licensee during this inspection, t

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ATTACHMENT A TO INSPECTION REPORT 50-293/85-26 The following surveillance and maintenance items were reviewed during the report perio Portions of the following tests were reviewed:

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Reactor pressure vessel temperatures following the reactor scram on September 1, 1985 and during subsequent startups.

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Secondary containment leakage tests on September 1 and 3, 198 Reactor recirculation pump start check lists, Procedure No. 2.1.9A, completed prior to pump starts in early September, 198 Control rod scram time test results during 198 Fuel handling checklist, procedure no. 4.3-K, dated September 18, 198 Diesel generator operability test on August 30, 198 The inspector observed portions of this test.

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Calibration history of reactor coolant system high pressure switches, Proce-dure No. 8.M.1-17. All 1985 calibrations were reviewe Portions of the following maintenance and modification activities . .re reviewed:

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MR 85-562, Recirculation MG set room door repair MR 85-45-56 and 57, Environmental qualification modifications to RHR pressure switches. The inspector reviewed work in progres MR 85-513, Damper A0-N-90 does not have proper control room indicatio MR 85-517, Damper A0-N-95 does not fully clos MR 85-357, HPCI lo4d and displacement transducers, installation and remova MR 85-561, Dye penetrant indication on the HPCI steam exhaust line torus penetratio MR 84-10-254, Environmental qualification modifications to motor operator for valve M0-1001-28 MR 85-575, Repair. electrical ground on RCIC valve, A0-1301-3 MR 85-507, Inspect and repair HPCI steam exhaust line rupture diaphra The inspector also inspected a failed RBCCW line which cooled the "B" reactor water cleanup pump on September 13, 1985.

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ATTACHMENT B TO INSPECTION REPORT 50-293/85-26 Licensed reactor operators (R0s) worked the following time periods without authori-zation from the Plant Manage Seven-Day Work Periods Week Ending Work Period Hours Worked Comment

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6/29/85 6/23 - 6/29 80 7/6/85 6/30 - 7/6 81

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7/13/85 7/7 - 7/13 77 7/20/85 7/14 - 7/20 97

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j 8/24/85 8/16 - 8/22 87 Two R0s

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8/31/85 8/22 - 8/28 76 8/24 - 8/30 80 Two R0s 9/7/85 8/30 - 9/5 81 Two-Day Work Periods Week Ending Work Period Hours Worked Comment 6/22/85 6/16 - 6/17 32 6/29/85 6/22 - 6/23 32 6/24 - 6/25 32 Two R0s 6/26 - 6/27 32 6/26 - 6/27 34 6/27 - 6/28 32 6/27 - 6/28 34 6/28 - 6/29 34 ,

7/6/85 7/3 - 7/4 32 7/4 - 7/5 32 7/13/85 7/8 - 7/9 29 7/9 - 7/10 32 7/10 - 7/11 32 7/11 - 7/12 32 Two R0s l

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Attachment B 2

Week Ending Work Period Hours Worked Comment 7/20/85 7/15 - 7/16 32 7/16 - 7/17 32 Two R0s 7/17 - 7/18 32 Two R0s 7/18 - 7/19 32 Two R0s 7/19 - 7/20 32 7/27/85 7/22 - 7/23 33 7/23 - 7/24 32 9/7/85 9/4 - 9/5 28 9/14/85 9/7 - 9/8 32

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