IR 05000302/1986023

Insp Rept 50-302/86-23 on 860704-0801.Violations & Deviation Noted:Failure to Have Adequate Instructions for Performance of Mods to Properly Install Spent Fuel Pool Missile Shields & to Properly Document Mod

ML20214V345
Person / Time
Site:	Crystal River
Issue date:	09/02/1986
From:	Eldrod S, Stetka T, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214V320	List: IR 05000302/1986023 ML20214V317 ML20214V322 ML20214V328
References
50-302-86-23, IEB-85-003, IEB-85-3, NUDOCS 8610020252
Download: ML20214V345 (19)

Text

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' pb UNITED STATES o NUCLEAR REGULATORY COMMISSION y ' ~ REGloN li g j 10f MARIETTA STREET, * g ATLANTA. GEORGI A 30323

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Report No.: 50-302/86-23 Licensee: Florida Power Corporation 3201 34th Street,. South St. Petersburg, FL 33733 y

Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: July 4 - August 1, 1986 Inspectors: '

9-[ km /A f/2- tegyr,SpniorResidentInsfector D' ate' Si N Z.//gned

/C %w A g J.~E. TeTirow, Resident inspecto f 'Vate Signed Approved by:

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' 'Date Signed S. A. Elrod, Section Chief f-Division of Reactor Projects SUMMARY Scope: This routine inspection was conducted by two resident inspectors in the areas of plant operations, security, radiological controls,- Licensee Event Reports and Nonconforming Operations Reports, facility modifications, review of IE -Bulletins, and licensee action on previous inspection items. Numerous facil-ity tours were conducted and facility operations observe Some of these tours and observations were conducted-on backshift Results: Four violations and one deviation were identified: (Failure to have adequate instructions for the performance of plant modifications, paragraph 3; failure to properly document a plant modification, paragraph 5.b.2.a; failure to perform a required surveillance, paragraph 5.b.8.a; failure to properly install the spent fuel pool missile shields, paragraph 5.b.13; and f.ailure to meet a commitment to the NRC, paragraph 3.)

8610020252 860918.. 2 PDR ADOCK 0500

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REPORT DETAILS Licensee Employees Contacted

• J. Alberdi, Manager, Nuclear Site Support

• Bandhauer, Assistant Nuclear Plant Operations Manager

• P. Breedlove, Nuclear Records' Management Supervisor

• J. Bufe, Nuclear Compliance Specialist R. Clauson, Nuclear Instrumentation & Control Engineer

• M. Collins, Nuclear Safety & Reliability Superintendent M. Culver, Senior Nuclear Reactor Specialist

• P. Ezzell, Nuclear Compliance Specialist H. Gelston, Nuclear Electrical / Engineering Supervisor

• J. Gibson, Nuclear Technical Specification Coordinator

• V. Hernandez, Senior Nuclear Quality Assurance Specialist

• P. Johnson, Nuclear Engineering Assurance Engineer

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• P. McKee, Director,' Nuclear Plant Operations

• P. Patel, Supervisor, Quality Systems V. Roppel, Manager, Nuclear Plant Technical Support

• P. Skramstad, Nuclear Chemistry / Radiation Protection Superintendent

• P. Small, Maintenance Department Coordinator R. Thompson, Nuclear Mechanical / Structural Engineering Supervisor

• L. Tiscione, Manager, Nuclear Procurement Engineering Services

• J. Warren, Nuclear Principle Mechanical / Structural Engineer

• E. Welch, Manager, Nuclear Electrical / Engineering Services

• K. Wilson, Manager, Site Nuclear Licensing

• R. Wittman, Nuclear Operations Superintendent Other personnel contacted included office, operations, engineering, maintenance, chemistry / radiation protection and corporate personne * Attended exit interview Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection or. August 1, 198 During this meeting, the inspector summarized the scope and findings of the inspection as they are detailed in this report with particular emphas'is on the Violationo Deviation, Unresolved Items (UNR) and Inspector Followup Items:(IFI).

The licensee representatives acknowledged the inspector's comments and did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Inspection Items (Closed) UNR 302/86-14-02: The licensee has provided the inspector with documentation from the manufacturer which states that the environmental qualification test conducted for Rosemount transmitters was performed with

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the electrical connections tightened to 150 inch pounds. The licensee's modification (Modification Approval' Record (MAR) 86-03-17-01) on these transmitters tightened the electrical connections to 24 foot pound Althoug the licensee has not determined how the connections became loose, the in ,,ector considers the modification to be adequate to ensure the connections are tight. The licensee has re-verified that .all applicable electrical connections inside the Reactor Building (RB) are tightened to 24 foot pounds. The inspector reviewed several work packages used to retighten the connections found loose and on June 12, 1986, re-entered the RB with licensee personnel to check the tightness of the electrical connections. No discrepancies were note (Closed) UNR 302/79-40-01: Studies concerning the effect of hurricane winds upon the coal pile 'were completed in 1932 by the licensee's consulting engineer. This study concluded that while the high winds would cause coal pile scatter about the site, these winds would not cause blockage of the intake canal. As the result of the study's conclusions, the licensee has closed Request for Engineering Instruction (REI) 79-8-2 In answer to REI 79-9-7, the licensee has revised procedure AP-1076, Violent Weather, to include a check of the Emergency Diesel Generator (EDG) vent intakes at least twice a shift during high wind conditions. In addition, the new procedure revision includes the requirement to assure that an adequate supply of replacement EDG air intake filters are ay111able onsit (Closed) I?I 302/84-21-01: The licensee revised procedure CP-115, Inplant Equipment Clearance and Switching Orders, in revision 49, to clarify the requirement to conduct an independent verification prior to accepting an equipment clearanc (Closed) IFI 302/84-21-03: Procedure OP-210, Reactor Startup, was revised on August 24, 1984 to provide for the performance of multiple Estimated Critical Positions (ECPs) and Estimated Critical Borons (ECBs). This revision added enclosures to the procedure upon which the ECPs or ECBs could be recorded thus eliminating the former problem of having to record such data in the body of the procedur (Closed) Violation 302/85-26-05: The licensee has completed and the inspector has verified the completion of the following items:

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Quality Control (QC) inspector training regarding the inspection alan for the anchor bolt and bolting requirements was completed on June 25, 198 The review of installation records was completed by July 12, 198 This review verified that 134 of the anchor bolts that had been installed to date or 91% of the 148 anchor bolts that were scheduled to be installed were installed correctl Procedure M0P-408, Installation of Concrete Anchor Bolts, was revised on August 15, 1985, to include a " Concrete Anchor Installation Record" that requires the recording of the torque value for each anchor bolt installatio . - - - .--

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. 3 Action on this item is considered to be complete.-

(Closed) Violation 302/85-26-01: The inspector reviewed the licensee's status of completion on this item as stated in their response letter of August 13, 1985, and identified the following items as complete:

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A lettar was sent to all Site Nuclear Operations personnel from the Director, Site Nuclear Operations, on July 1,1985, emphasizing the procedural requirements for maintaining current clearance orders and work requests (WRs) at the job sit The test supervisor and assistant test supervisor received appropriate counseling regarding procedure adherence and the need to have precise communication between test personnel and maintenance personne Switching and tagging training is reemphasizing the requirements of the revised equipment clearance procedur The followint have not been completed:

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The licensee did not make a new WR in which the required approvals were documente The only WR the licensee had available was a copy of the original WR upon which the Violation was based. It appears that this

corrective action" should have been part of the cause of the viola-tio The licensee's response states that " Procedure for ASME Class 2 and 3 hydrostatic testing" has been revised to mod.ify hydrostatic test rig requirements. Provisions for a snubbing device or alternate device, and signoff to verify the correcting is include The procedure for ASME Class 2 and 3 hydrostatic testing, SP-210, was revised but the revision did not contain ". . .signoffs to verify the correct rig is included."

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The clearance order form was not revised to state that a copy of the clearance order must be present at the work are The response also stated that these actions would be completed by October 31, 198 Failure to complete the corrective actions as stated in the August 13, 1985, response letter to the NRC is considered to be a deviation from a commitment to the NR Additionally, the statement that for Procedure SP-210,-

"Signoffs to verify the corrcct rig is included" has been found to be a false statement. Subsequent to the inrpection, NRC review found this not to be of sufficient importance to merit enforcement action beyond the Notice of Deviatio Deviation (302/86-23-01): Failure to meet a commitment as stated in the response letter to Violation 85-26-01 dated August 13, 198 __

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. 4 For record purposes, Violation 85-26-01 is considered to'be closed and all further activity concerning this item will be tracked by the Deviatio (Closed) IFI 302/85-29-11: The' inspector conducted a walkdown of the Remote

. Shutdown Panel (RSP) to verify that the mimic for the letdown and makeup j system has been correcte (Closed) Violation 302/85-33-01: The ~ licensee has completed and the inspector has verified the completion of the following items:

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The Action Statement entry for Technical Specification (TS) 3.3.3~. , was logged and entered and the required grab sampling was commenced on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequenc Procedure SP-442 was revised on October 1, 1985, to list the radiation monitors under the inoperable equipment section of the procedure and again on November 22, 1985 to require a review of the " Equipment Out Of Service" log prior to making an operational mode change.

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Labels were affixed to the applicable radiation monitoring equipment to direct notification of the chemistry department prior to removing the

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equipment from servic Action on this item is considered to be complet (Closed) Violation 302/85-33-05: The licensee has . completed and the inspector has~ verified the completion of the following items:

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Procedure SP-443 was revised on September 19, 1985, to require testing 4 of the automatic load sequencing equipt.;ent in operational modes 5 and 6 in addition to modes 1- Maintenance personnel reviewed these corrective actions during a review of the Licensee Event Report (LER 85-009) that was written to report this event.

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Procedure SP-1358, Engineered Safeguards Actuation System Response Time Test, was successfully completed on July 24, 198 Action on this item is considered to be complet (Closed) Violation 302/85-33-06: The licensee has completed and th inspector has verified the completion of the following items:

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Applicable safety related systems were verified to be properly aligned by the performance of additional system lineups during the period of August 8-29, 198 Procedure CP-115 was revised on October 23, 1985, to state that a

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Personnel counseling was conducted in August 1985 as documented in a memo and as determined by discussions with licensee personne Actions on this item are considered to be complet (Closed) Violation 302/85-41-01: :The licensee has completed and the inspector has verified the completion of the following items:

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Procedure OP-210, Reactor Startup, was revised on June 14, 1985 to require a signoff verification that the ECPs are in compliance with procedure acceptance criteri Personnel involved were counseled regarding their failure to adhere to procedures. This consultation was documented in an Interoffice Corre-spondence dated December 5, 198 Example 1: The operator involved was counseled on November 19, 1985, as documented by an Interoffice Correspondence dated December 5, 198 Example 2: The operators involved were counseled as documented in an Interoffice Correspondence dated October 18, 1985. Additionally, all operators were required to document their review of the applicable section of procedure CP-115 that delineates the requirement to inde-pendently review an equipment clearance prior to implementatio Example 3: A Nuclear Plant Engineering Supervisor held a meeting with the Mechanical Nuclear Plant Engineers on December 4, 1985, to reempha-size the requirements of procedure AI-600 that all work on safety related systems be conducted with an approved Work Reques Example 4: Procedure CP-115 was revised as revision 54 to clarify how the Senior Reactor Operator will document the independent verification of an equipment clearance. In addition a clearance review was con-ducted to verify that no additional clearances existed that had not received.the appropriate independent revie Actions on these items are considered to be complet (Closed) IFI. 302/85-29-09: Action on this item is considered to be complete since the response to Violation 85-41-01 has been received, reviewed (as denoted in previous. paragraphs), and is considered to be acceptabl (Closed) IFI 302/85-29-10: Action on this item is considered to be complete since the response to Violation 85-41-01 has been received, reviewed (as denoted in previous paragraphs), and is considered to be acceptabl (Closed) Violation 302/85-41-02: The licensee has completed and the inspector has verified the completion of the following items:

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The area was resurveyed on October 6, 1985, at 5:30 p.m., to verify the radiation levels and the area was posted as a high radiation are . - - _ . . . . _ . . .. . . .

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A Radiological Safety Incident Report (RSIR) 85-00346 was issued on October 15, 1985, to document the procedure violatio A general meeting was held on October 16, 1985, with Health Physics (HP) personnel to counsel them on the requirements for high radiation areas and their postin An Interoffice Correspondence dated November 21, 1985, was sent to all plant personnel to remind them to notify HP personnel whenever radio-active materials .are moved to insure that proper posting for the affected area is maintaine Actirn on this item is considered to be complet (0 pen) IFI .302/85-41-04: The licensee completed testing of the Safety Parameter Display System (SPDS) in accordance with test procedure T/P-3 of modification (MAR 81-06-38).and has resolved the problems with all but two of the computer points. Problems with computer points 227 and 228 remain to be resolved and the licensee is presently pursuing their resolutio This item remains open pending resolution to the problems with these computer point (Closed) IFI 302/85-41-05: The licensee acted on this item by performing a walkdown of the containment hydrogen monitoring system for the particular valves identified in the repor As the result of this walkdown, the licensee determined that all but two valves (WSV-95 and 96) were labeled correctly and the labeling on these two valves was corrected. As part of the review of this item, the inspector conducted another walkdown of the system and still identified an apparent discrepancy between the installed system and the as-built drawing When notified of this finding, the licensee conducted an additional system walkdown. As a result of this walkdown, the licensee determined that the system had been installed incorrectly in that a section of the piping was crosse The Containment Hydrogen Monitoring system was installed 'in accordance with MARS 79-11-70-01 and 79-11-70-02 to meet the requirements of NUREG 0737, item II.F.1.6, and is a safety related system. While the system will be included in the TS and the change has been submitted to the NRC, this review

. is still ongoing. The crossed piping defeated the independent train design l of the system and prevents the system from being single failure proof.

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Additionally, the post installation testing failed to identify the incorrect installatio The inspector's review of MARS 79-11-70-01 and 79-11-70-02 indicate that

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these MARS were inadequate therefore resulting in the incorrect installation and the failure of the testing to identify this conditio Failure to have adequate instructions for the perfornance of work and l testing on a safety related system is contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V and is considered to be a violation.

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. 7 Violation (302/86-23-02): Failure to have adequate instructions for the performance of plant modifications as required by 10 CFR Part- 50, Appendix B, Criterion For record purposes, IFI 85-41-05 is considered to be closed.and all further action on this item will be tracked by Violation 302/86-23-0 (0 pen) Violation 302/86-07-01: The licensee has completed and the inspector has verified the completion of the following items:

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Nuclear engineering conducted a review of the annunciator panels on February 12 thru 17,1986 and determined that non-safety related parts that are verified to be compatible with the safety related equipment can be used in the safety related equipmen To assure that plant personnel are aware of this engineering resolu-tion, an Interoffice Correspondence was sent to the Manager, Nuclear Plant Operations (who is in charge of plant maintenance) from the Manager, Plant Engineering and Technical Service The review of work activities discussed in the response to this violation remains to be verified since personnel involved in this review were unavail-

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able at this tim This item remains open pending verification of the performance of this work revie (0 pen) IFI 302/86-12-03: During a review of th.is item, the ir.spector determined that an additional system, the emergency diesel generator lube oil system (DL), should be included in section 5.7.2 of procedure CP-11 The licensee is presently reviewing the addition of the portions of the D0, MS, Rd, and AS systems into procedure CP-115. This item remains open pending completion of this revie . Unresolved Items Unresolved items are r atters about which more information is required to determine whether they are acceptable or may involve violations or devia-tion A new unresolved item is identified in paragraph 6.b.1 of this report.

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5. Review of Plant Operations The plant remained in the power operation mode (Mode 1) for the duration of this inspection perio Shift Logs and Facility Records The inspector reviewed records and discussed various entries with i operations personnel to veri fy compliance with the TSs and the

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licensee's administrative procedures.

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. 8 The following records were reviewed:

Shift Supervisor's Log; Reacte.- Operator's 1 Log; Equipment Out-Of-

. Service Log; Shift Relief Checklist; Auxiliary Building Operator's Log;

' Active Clearance Log; Daily Operating Surveillance Log; Work Request Log; Sho-t Term Instructions (STIs); and ' Selected Chemistry / Radiation Protection Log In addition to these record reviews, the inspector independently veri fied clearance order tagout k) violations'or deviations were identifie Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations and maintenance activities in progres Some

. operations and maintenance activity observations were conducted during backshifts. Also, during this inspection period, licensee meetings were attended by the inspector to observe planning- and management activitie The facil' ity tours -and observations encompassed the following areas:

security perimeter fence; control room; ' emergency diesel generator room; auxiliary building; intermediate building; battery rooms; and, electrical switchgear rooms.

During these tours, the following observations were made:

(1) Monitoring Instrumentation - The - following instrumentation was observed to verify that indicated parameters were in accordance

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Equipment operating status; area atmospheric and liquid radiation monitors; electrical system lineup; reactor operating parameters; and auxiliary equipment operating parameter No violations or deviations were identified.

( (2) Safety Systems Walkdown - The inspector conducted a walkdown of

the EDGs to verify that the lineup was in accordance with license requirements for system operability and that the system drawing and procedure correctly reflected "as-built" plant condition (a) During the field verification for drawing FD-302-285, Lube Oil System for the EDG, the inspector noticed that the actual

piping configuration for the lube oil strainer pressure indicator (DL-26-PI) was different from that shown on the drawing. A three way valve (DLV-10) on the inlet piping to this indicator had been replaced by two valves. The drawing still showed a three way valve (DLV-10) installe . . .- - - - .- - -- - . -.

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. 9 The inspector reviewed shop records and discussed this matter with licensee engineering personnel to determine how - the valve replacement was documented and to find' the reason why tLa system drawing did not have the correct system configu-ration shown. Although the valve replacement constituted a modification and physical alteration of. the system, the work was performed by the use of a WR form. This form did not provide the review and approval process required for plant modifications and as a result, did not identify the need for

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a change to the system drawin Procedure CP-114, Procedure for Handling Permanent Modifica-tions, Temporary Modifications, Modification Revisions, Field Change Notices, and Advanced Field Change Notices, step 3.11, requires the use of a MAR to control and document the safety evaluation, review, and approval of nuclear plant modifica-tions. Using a WR to document the installation of a plart modification is contrary to the requirements of procedi.re CP-114 and is considered to be a violation against YS 6.P. Violation (302/86-23-03): Failure to properly review and process plant modification to replace valve DLV-1 (b) Further review of drawing FD-302-285 revealed that two gage isolation valves, DLV-1 and DLV-2, for pressure indicators DL-1-PI and DL-2-PI respectively, did not exist in the field although they were shown on the drawin Discussions with licensee engineering personnel determined that these two valves had been mistakenly left on the system drawing when this drawing was made from the vencor supplied prints. The licensee plans to revise drawing FD-302-285 to delete these valve IFI (302/86-23-04): Review the revision to drawing FD-302-285 to delete valves DLV-1 and DLV- (3) Shift Staffing - The inspector verified that operating shift staffing was in accordance with TS requirements and that control room operations were being conducted in an orderly and profes-sional manner. In addition, the inspector observed shift turn-overs on various occasions to verify the continuity of plant status, operational problems, and other pertinent plant informa-tion during these turnover No violations or deviations were identifie (4) Plant Housekeeping Conditions - Storage of material and components and cleanliness conditions of various areas throughout the facil-ity were observed to determine whether safety and/or fire hazards existe o

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No viol'ations or deviations were identifie (5) Radiation Areas - Radiation Control Areas (RCAs) were ' observed to verify proper identification and implementatior,. These observa-tions included selected licensee-conducted surveys, review of step-off pad conditions, disposal of contaminated clothing, and area postin Area postings were independently verified. for accuracy through the use of a radiation monitoring instrumen The inspector also reviewed -selected radiation work permits and observed the use of protective clothing, respirators, and person-nel monitoring devices to - as:ure that the licensee's radiation monitoring policies were being followe No violations or deviations were identifie (6) Security Control - Security controls were observed to verify that security barriers were intact, guard forces were on duty, and access to the Protected Area (PA) was controlled in accordance with the facility . security pla Personnel within the PA were observed to verify proper display of badges and that personnel requiring escort were properly escorted. Personnel within vital areas were observed to ensure proper authorization for the are No violations or deviations were identifie (7) Fire Protection - Fire protection activities, staffing and equip-ment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actua-ting controls, fire fighting equipment, emergency equipment, and fire barriers were operabl .

No violations or deviations were identifie (8) Surveillance - Surveillance tests were observed to verify that approved procedures were being used; qualified personnel were conducting the tests; tests were adequate to verify equipment operability; calibrated equipment was utilized; and TS require-l ments were followed. The following tests were observed and/or l data reviewed:

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SP-122, Reactor Coolant Saturation Temperature (TSAT) Meter l Calibration; i

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SP-187, Auxiliary Building (AB) Ventilation Exhaust System lesting; i

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SP-317, Reactor Coolant System Water Inventory Balance;

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SP-321, Power Distribution Breaker Alignment & Power j Availability Verification;

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SP-421, Reactivity Balance Calculations; l

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SP-425, Control Rod Drive Patch Panel Access Control; and

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.SP-701, Radiation Monitoring System Surveillance Progra As a result of these reviews, the following items were identified:

(a) During- a review of completed procedure SP-187, performed on May 29, 1986, the inspector noticed that the visual inspec-tion of the AB exhaust system prefilters and High Efficiency Particulate Air (HEPA) filters had not been performed. Step 7.2.5 of. this procedure requires that prior to commencement of in place testing, a visual inspection of the items identi-fied in enclosure 3, Checklist for Visual Check, be per-formed. Sections 2 and 3 of this enclosure requires a inspection of the HEPA filters and prefilters respectivel The comment section of the procedure stated that As Low as Reasonably Achievable (ALARA)~ concerns prevented this inspectio ;

The inspector discussed this matter witn HP personnel and the licensee's ALARA specialist. The performance of the visual inspection was not considered by the ALARA specialist, nor by HP personnel, to contribute significantly to an individual's radiation exposure. Therefore, due to the low radiation exposure expected for this type of work, an ALARA evaluation of this job was not performed. The inspector concluded that

although contamination protective clothing would be required 4 to perform this inspection, the low -oersonnel radiation exposure should not have precluded performance of the inspectio The inspector reviewed completed past data from procedure SP-187 to determine the status of past inspection On July 20, 1985, the visual inspections of the.HEPA filters and prefilters was not done "due to contamination" reasons. On

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July 12, 1983, the inspection of the HEPA filters was not done due to " units locked up".

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Procedure SP .d7 implements the requirements of TS surveil-

, lance 4.7.8.1.b.2. This TS requires in part that the AB 1 ventilation exhaust system shall satisfy the in place testing acceptance criteria and uses the test procedures of Regula-tory Position C.S.a of Regulatory Guide 1.52, Revision 1, July 1976. Regulatory Position C.S.a requires that a visual inspection of the system shall be made in accordance with the recommendations of Section 5 of American National Standard (ANSI) N510-197 Section 5 of this standard further speci-fies in Appendix A, Checklist for Visual Inspection, that an inspection of HEPA filters and prefilters be performed. This visual inspection is required to be performed before each test to reveal deficiencies that would cause the test to fail or would invalidate the test result ._

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. 12 Failure to perform the visual inspections of the HEPA filters and prefilters is contrary to TS 4.7.8.1.b.2 and is con-sidered to be a violatio F Violation (302/86-23-05): Failure to perform visual inspec-tions of the AB ventilation exhaust system HEPA filters and prefilters as required by TS 4.7.8.1. (b) The inspector's review of the completed data for procedure SP-421 indicated an apparent error in the procedure. Work-sheet II, step 5 of the procedure directs the user to Operating Procedure (OP) 103C, Reactivity Worth. Curves, curve 30, to obtain necessary data. This curve refers to another curve, curve 4.9B, to obtain data for the Axial Power Shaping Rods (APSRs) Hot Full Power (HFP)n ' ominal position. Curve 4.98 noes not exist and apparently was renumbered as curve 13B and placed in procedure OP-103D, Withdrawal Limit Curves, as the result of a revision to the original procedure OP-10 This error did not invalidate any calculations since this information is not directly use In addition _ .the inspector noted two other problems with procedure SP-421 as follows:

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Step 4.4 of the procedure states that the procedure was designed to be performed by nuclear operators reporting directly to the Shift Superviso However, review of

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the- procedure data and discussion with licensee repre-sentatives indicate that his procedure is usually done by the Reactor Specialist. The step also conflicts with another procedure, SP-443, Master Surveillance Plan, in that this procedure recognizes that the Reactor Specia-list normally does this procedur Worksheet II, step 5.b, requires the recording of the APSR "HFP nominal position" but does not state the reason this information is recorded nor does the calcu-lation use this information.

, These findings were discussed with licensee representatives at which time these personnel agreed to rake appropriate procedure changes to procedures OP-103C ano SP-421 to correct the errors and to clarify the intent of the procedur IFI (302/86-23-06): Review the revisions to procedures OP-103C and SP-421 to correct the errors and to clarify the intent of the procedure (9) Maintenance Activities -

The inspector observed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as

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. 13 required, were issued and being followed;~ quality control person-nel were available for inspection activities as required; and TS requirements were being followe Maintenance was observed and work packages were reviewed for the following maintenance activities:

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Replacement of snubber RCH-530 in accordance with procedures MP-196 and PT-130;

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Testing of protective relays for EDG-1B in accordance with procedure PM-102;

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Repair of radiation monitor RMG-25;

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Troubleshooting of the control rod drive system;

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Replacement of control rod drive system Absolute Rod Position (API)/ Relative Rod Position (RPI) indicator switching relays;

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Troubleshooting, repair, and calibration of the Reactor TSAT instrument thermocouple amplifiers;

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Troubleshooting of the "A" Reactor Building Emergency Cooling Fan (AHF-1A) in accordance with procedure MP-531;

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Replacement of' valve DLV-10 in the lube oil system of EDG-1B;

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Troubleshooting of Emergency Feedwater Flow Control Valve (EFV-57) in accordance with procedure MP-531; and

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Troubleshooting of a main feedwater isolation valve (FWV-15)

in accordance with procedure MP-53 While observing the troubleshooting and calibration activities on the -TSAT instruments, the inspector noted that these activities were being' accomplished in accordance with a work request and the vendor's technical manua These instruments are usually tested and calibrated in accordance with a surveillance procedure, SP-122. This procedure,.however, does not test or calibrate the thermocouple amplifiers and the licensee had not planned on performing such calibrations or periodic tests since the instruments were purchased as vendor calibrated and were not expected to drift. Recent problems with this instrumentation, however, have been traced to failures and calibration drifts in these amplifier This demonstrates the need to perform periodic calibration and testin The licensee plans on developing procedures and calibration. sheets that will provide for periodic calibration of this instrumen-tatio '

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. 14 IFI (302/86-23-07): Review the licensees activities to develop periodic calibration procedures for the TSAT thermocouple ampli-fier (10) Radioactive Waste Controls - Solid waste compacting and selected liquid and gaseous releases were observed to verify that approved procedures were utilized, that appropriate release approvals were

' obtained, and that required surveys were take No violations or deviations were identifie (11) Pipe Hangers and Seismic Restraints - Several pipe hangers and seismic restraints (snubbers) on safety related systems were observed to insure that_ fluid levels were adequate and no leakage was evident, that restraint settings were appropriate, and that anchoring points were not bindin No violations or deviations were identifie (12) Station Batte ry Racks -

The inspector reviewed the as-built installation of the plant's station battery racks to determine if these racks. have been installed in accordance with the' vendor's

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drawings thus insuring that the racks would withstand a design seismic event. . As a result of this review, it was determined that the racks have been installed and maintained as specified in the vendor drawing No violations or deviations were identifie (13) Spent Fuel Pool (SFP) Missile Shields - The inspector reviewed the installation of the SFP missile shields to determine if the licensee's practice of installing the shields over the SFP without

bolting them in place was consistent with plant drawings and desig Plant drawing S-521-116 identifies that the total missile shield

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is composed of individual panels whose quantity and designations are as'follows:

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23 type SP-1;

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1 type SP-2;

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1 type SP-3;

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6 type SP-4;

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1 type SP- This drawing also specifies that each shield panel is bolted in place with four bolt In addition, the Final Safety Analysis Report (FSAR), paragraph 9.3.2.2, states that the missile shield panels are anchored at l

each end and in FSAR paragraph 9.6.1.5 (page 9-43) that the SFP is l

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. 15 covered at all times except when moving fuel for protection against tornado generated missile The inspector's observations of the missile shield status on July 21 indicated that while all the shield panels were installed over the SFP, not all panels were bolted in accordance with the drawing as follows:

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1 type SP-1 had no bolts installed;

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2 type SP-1 had two bolts installed on only one end;

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7 type SP-1 had one bolt installed on each end;

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2 type SP-1 had three bolts installed;

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The type SP-2 had one bolt installed on each end;

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3 type SP-4 had one bolt installed on each end;

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3 type SP-4 had three bolts installed;

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The type SP-5 had three bolts installe The licensee removes and installs the missile shields panels in accordance with procedure SP-434. Review of this procedure by the inspector indicates that the procedure does not specifically require the shield panels to be bolted in place. Furthermore, review of the completed data for this procedure indicates that the last complete installment of the missile shield was performed on January 17, 198 TS 3.9.11 requires that all missile shields be installed over the SFP. Failure to properly install the missile shields as specified in plant drawings is contrary to the requirements of TS 3.9.11 and is considered to be a Violatio Violation (302/86-23-08): Failure to properly install the SFP missile shields as required by TS 3.9.11.

6. Review of Licensee Event Reports and Nonconforming Operations Reports Licensee Event Reports (LERs) were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriate. Events, which were reported immediately, were reviewed as they occurred to determine if the TS were satisfie LERs 86-01, 86-08 and 86-10 were reviewed in accordance with the current NRC enforcement polic LERs 86-01 and 86-08 are close (1) LER 86-01 reported the failure of a Reactor Coolant Pump (RCP)

shaft and the failure of valve EFV-57 to operate properly. The cause for the failure of the shaft on RCP-1A was due to fatigue cracking. The licensee has been unable to identify the stresses which caused the initiation and propagation of this cracking. The licensee has subseouently replaced all four RCP shaft The-licensee has also completed troubleshoot'ing of valve EFV-57. The inspector observed parts of this troubleshooting and reviewed the

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. 16 completed work records associated with this troubleshooting. The licensee was unable to reproduce conditions under which the valve would fail to operate properly. Although the licensee has been unable to determine the cause for the failure of the valve to operate properly, the valve has been subsequently tested and operates satisfactor (2) LER 86-10 reported the violation of TS 6.2.2.a which requires two Senior Reactor Operator (SRO) licensees on watch during plant operation in the hot standby mode (Mode 3). During the period 8:00 p.m., on June 15, 1986, to 8:00 a.m., on June 16, 1986, a backup SRO licensee acted as an assistant nuclear shift super-visor. On July 3, 1986, a licensee quality programs audit finding determined that the backup SR0 licensee had not performed the duties of a SRO within the required four month interval of 10 CFR 55.31.e and therefore was not certified to perform the duties of a SR Therefore during the period of June 15 to June 16 the licensee had only one certified SR0 on shif The licensee instituted the following corrective action to prevent recurrence of this event:

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All backup licensees are scheduled to stand monthly watches to ensure that the four month requirement is not exceede The Nuclear Operations Training Department has changed the computerized tracking system to track certification watches on a four month interva Reports of impending or actual loss of qualification will be forwarded to the licensee affected, Operations Superintendent and Operations / Training Liaiso The backup licensee involved is participating in a remedial training and requalification progra This matter is considered to be a licensee identified violation in which appropriate corrective actions were taken to prevent recurrenc LER 86-10 will remain open pending completion on the backup licensee requalificatio The inspector reviewed Nonconforming Operations Reports (NCORs) to verify the following: Compliance with the TS, corrective actions as identified in the reports or during subsequent reviews have been accomplished or are being pursued for completion, generic items are identified and reported as required by 10 CFR Part 21, and items are reported as required by T All NCORs were reviewed in accordance with the current NRC Enforcement Polic __ ____ - __- -__. - - - _ _

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. 17 (1) NCOR 86-99 reported that a main feedwater pump isolation valve (FWV-15) failed to close when the feedwater booster pump's discharge valves (FWV-7 and FWV-8) closed. The licensee has completed troubleshooting of this problem and has identified a missing wire from valve FWV-15's motor control circuit. This wire has been replaced and the valve now operates satisfactory. The licensee is continuing to investigate why the wire had been removed. This matter is considered unresolved pending a review of the licensee's investigatio UNR (301/86-23-09): Investigate the cause of the missing wire from the motor control circuit of valve FWV-1 (2) NCOR 86-86 reported the potential that a high energy line break (HELB) could affect the operability of the Woodward governor on the turbine driven emergency feedwater pump (EFTB-1). Analysis by the licensee's consulting engineer indicated that this potential did not exist, however, the analysis also indicated that the governor should be refurbished at least every ten year The licensee is consulting with the governor's manufacturer to deter-mine what parts should be refurbished and then will add the governor to the plant's periodic Preventative Maintenance (PM)

schedule for refurbishmen IFI (302/86-23-10): Review the licensee's progress to add the Woodward governor on EFTB-1 to the plant's PM schedule for refur-bishmen (3) NCOR 86-96 reported that the design nozzle loadings on EFTB-1 may be exceeding the manufacturer's specifications'. This finding was discovered during an on going analysis by the licensee's consul-ting engineer on EFTB-1. As a result of this finding, the licensee has contracted with another consulting engineer to perform additional computer evaluations that will utilize more modern computer techniques. These evaluations are expected to be completed by October, 198 IFI (302/68-23-11): Review the results of the licensee's reeval-uation of the design nozzle loading on EFTB- . Review of IE Bulletins (IEB)

The inspectors reviewed the licensee's response to IEB 85-03, Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings, and determined that this response does not address all the con-cerns expressed in the bulletin. Specifically, the maximum differential pressure expected during both opening and closing of certain valves was not included in Table 2 of the licensee's response. For other valves this table does not appear to show the maximum differential pressure that some valves

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! are subjected t Thi's matter was discussed with licensee personnel. The licensee plans to address this matter in a revised response to this bulleti This bulletin will remain open pending review of this revised

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