IR 05000302/1997013
| ML20212B913 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/16/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20212B902 | List: |
| References | |
| 50-302-97-13, NUDOCS 9710280286 | |
| Download: ML20212B913 (57) | |
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> EXECUTIVE SUMMARY I Crystal River 3 Nuclear Station i
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NRC Inspection Report 50 302/97 13 Thic integrated inspection included aspects of licensee operations, r engineering, maintenance, and plant support, The report covers a 5 week period of resident ins)ection: in addition, it included the results of !
announced inspections )y regional reactor inspectors and visiting resident i inspector l Ooerations ,
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The licensee was well prepared for the evolution to draw vacuum in the main condenser and successfully verified the secondary plant was ready to support unit restart (Section 01.1).
A Non Cited Violation (NCV 50 302/97 13 01) was identified for improper clearance restoration causing a Reactor Coolant System leak. However, the ;
licensee's actions for this problem were comprehensive and proactive and :
included a significant planned effort to label all instrument valves in the j
plant (Section 01,2). ,
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The inspectors concluded that Operations questioning attitude and !
communications remain a challenge to the licensee, but licensee management !
continues to pursue the problems and implement initiatives aggressively in an effort to improve performanc Licensee system requalification training and STAR (Stop Think-Act-Review)
Simulator training was good, The Star training was very effective at
reenforcing desired o)erator behaviors, However, some problems were noted '
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with system training )ecause of the limited coverage of recent modifications (Sections 05.1 and 5.2). i The inspectors concluded that the licensee's progress to date on the Management Corrective Action Plan (MCAP 11) was satisfactory, The licensee was not yet ready for restart but had plans to get ther Ten, open MCAP 11 items wera on the licensee's restart list. Also, inspectors identified tw additional items on which progress was needed 3rior to restart: personnel errors (quality of work) and availability and (nowledge of licensing and i design basis information (Section 07.1).
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The-inspectors concluded that the licensee's recent assessment of MCAP 11 was generally good. However, the MCAP 11 Assessment Report did not assess the
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current status on MCAP action items with respect to readiness for plant restart, Also, the licensee did not have a-good plan for follow up and ,
closure of the MCAP 11 Assessment Report- findings and-recommendations
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(Section 07,1). ,
L The licensee's response to a viniation and corresponding closure package adequately addressed'the technical issue but was inadequate because it lacked any resolution of the inadequSte corrective action that was the cause of the violation (Section 08.3),
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Maintenance The licensee's maintenance department achieved a significant goal to reduce the corrective maintenance backlog. On September 13 the licensee achieved their goal of less than 200 open corrective maintenance work requests, down from a peak of 768 in May of 1997. (Section M1.li, .
A review of work packages and corrective actions for a s)ent fuel pump rebuild revealed that the licensee's investigation was adequate )ut not especially thorough and the corrective actions were limited (Section M1.2)
The licensee had made significant improvement in improving the coordination of the hydrostatic testing process, but problems continued to occur regarding communications between different group Partici) ants exhibited excellent sensitivity to reactivity management, and work paccage documentation was good (Section M1,3)
A Violation (V10 50 302/97 13 02) was identified for failure to perform an engineering evaluation for the installation of scaffolding in the vicinity of safety related equipment (Section M2.1),
Ennineerina A Violation (VIO 50 302/97-13 03) was identified for failure to follow procedure in controlling circuit breakers when removed from switchgear cubicles (Section E2.1).
The licensee's Final Safety Analysis Report (FSAR) review project, which was completed in March. 1997, was limited in scope. The results of the review indicated that additional FSAR reviews may be required to assure the FSAR was accurate. The licensee's Restart Readiness Review and Configuration Document Integration Project should provide additional assurance that the FSAR accurately reflects the design, operation, and licensing t, asis of the plant (Section E3.1).
Plant Suncort A Non Cited Violation (NCV S0-302/97-13-04) was identified for failure to control tools contaminated with radioactive material in accordance with regulatory and licensee contamination control procedures (Section R1.1).
The inspector concluded that the licensee was implementing good radiological protection controls in accordance with licensee procedures and regulatory requirements. Good interaction between the Health Physics staff and radiation workers were observed in the inspection (Section Rl.2).
A Non Cited Violation (NCV 50-302/97 13 05) of licensee radiation safety procedure requirements was identified for failure to secure access to a high radiation area (Section R1.3).
The sampling and analysis process for the reviewed gaseous effluent samples was adequat The technicians performing the work understood the processes t
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very well. The applicable procedures provided sufficient detail to perform i the work and the procedure was properly utilized throughout the sampling and ;
analysis process (Section R1.4).
A potential problem concerning the accuracy of reactor building gaseous effluent release stort times and volumes was identified by the licensee and will be reviewed by the NRC in a future inspection as an Inspector Follow up Item (IFI 50 302/97-13 06) (Section R1.4).
The 1996 Effluent Report was complete and met Technical Specification requirements. 1he radiological effluents were well within the limits specified in the Offsite Dose Calculation Manual (Section R3.1).
-The 1996 Annual Environmental Monitoring Report met Technical Specification requirements (Section R3.2). ,
The inspectors found the )ractical factor qualification training an excellent training component with tle licensee's computer based training program ,
(Section R5.1).
The inspector concluded the Manager of Radiation Protection met the Technical Specification qualification requirements for the Radiation Protection Manager (Section R6.1).
The fundamental objectives of the annual Emergency Preparedness drill were met and the inspectors considered the drill to be a success. Some minor conmunication problems occurred but nothing that was considered to detract from the drill s intent and purpose (Section Pl.1).
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The inspectors assessed the licensee's performance in the five areas of continuing NRC concern in the following sections: the assessments are limited to the specific issues addressed in the respective section NRC NEA oF CONCERN ASSESSMENT PARAGPAPH l
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0 .1 0 0 0 O M E E8 E E E .1 8 8 5 8 . . . . .
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Management oversight G A A I S G A A G G' G r>gineering Effectiveness A A G A A G G G A Knowle@ of Design Basts A A A A A -G G G A Cmp 11ance with Regulations A A A I G A A G G G <
Operator Performance A A A G G A A S = Superior G = Good A = Adequate / Acceptable I - Inadequate Blank = Not Evaluated / Insufficient Information Section 04.1: Operations Readiness !
j. Section 07.1: Management Corrective Action Plan (MCAP II)
Section 08.1: (Closed) VIO 50-302/94-25-01: Failure to Properly Control the Control Conplex ;
Habitability Envelope (Door Blocked Open for Maintenance Work)
, Section 08.3: (Closed) VIO 50-302/ % -01-01: Inadequate Corrective Action to fix High Pressure
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Injection (HPI) Flow Indication Problems i
Section 08.4: (Closed) VIO 50-302/97-01-01: Inadequate Clearance Tagging Requirements [ Restart
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Issue No. 0-12] '
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Report Details Swrnary of Plant Status The unit remained in Mode 5 throughout the ins)ection period, continuing in the outage that began on September 2, 1996. lie reactor coolant system (RCS)
remained filled to a normal presst,rizer level with a nitrogen over pressure of approximately 40 psig. One train of forced decay heat removal system flow remained in service. Both once through steam generators (OTSG) remained filled to a normal inventory with a nitrogen over pressure to sup) ort use as a backup decay heat sink if needed. On September 13 through Septem]er 1 vacuum in the main condenser was established by using Auxiliary Steam from adjacent fossil fuel plants. The majority of the secondary cycle flowpaths and all major pumps were exercised for post-maintenance testing and to assess the readiness of the plant for startup after being in lay * for over a yea Work on major physical modifications related to the licem restart efforts continued this report period. Work that commenced August 3 to replace the radiator and upgrade cooling airflows for the A Emergency Diesel Generator progressed relatively on schedule. The addition of the Backup Diesel Power Supply to feedwater Pump 7 was nearing completion and containment penetration relief valve work continued to address concerns in NRC Generic Letter 96-06 Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions. Modifications to address EDG loading concerns were completed which added pull-to lock switches on redundant cooling water system pumps and a defeat switch for motor-driven emergency feedwater pump L Operations 01 Conduct of Operations
.01.1 Drawino Vacuum a. Insoection Scone (71707)
Using Inspection Procedure 71707 the ins)ectors conducted routine reviews of ongoing plant operations whic1 included shift turnovert, response to problems, use of procedures, log reviews, system lineup verifications, and review of clearance tagging processes. Signi ficant observations are discussed in the following paragraph b. Observations and Findinas On Saturday. September 13. two days earlier than originally planned, the licensee admitted auxiliary steam into the )lant from the adjacent coal plants (Units 1 & 2) and drew a vacuum in t7e main condenser. The secondary side of the plant had been in lay-up since Crystal River shut down on September 2 of last year. The evolution went very well, and only minor complicatwns were encountered such as valve stem and gasket leakage and intermittent actuations of pump protective features. The encountered problems were quickly corrected. Chemistry results were also extremely favorable and allomd the transition to long cycle cleanup from short cycle earlier than expected on September 13. Levels
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2 of dissolved solids and corrosion products and oxygen in the condensate were very low. The licensee ran both condensate pumps, both feedwater booster pumps, and both main feed pumps. Vacuan was maintained until Friday. September 19 to sup) ort numerous cost rMintenance tests. An Institute of Nuclear Power Operations (IN)0) assist team was onsite
< through the weekend of September 13 and 14 to support the licensee and evaluate their operational readiness. The inspector reviewed the results of their observations and concluded that their review was beneficial to the licensee and their fiMings were similar to problems noted previously by the licensee and the NR As discussed in Section E2.1. 3roblems were observed with previous reportability determinations tlat did not have an adequate technical basis and were not timely, Problems were also noted with internal Operations department conrnunications regarding implementing corrective actio The inspectors frequently observed operations shift turnover briefings and noted improvement over recent inspection periods. Some notable improvements were: operator knowledge of plant activities; briefings now held inside control room rather than outside in break room (all cperators can now attend): more questions and comments coming from building operators. Room for improvement still exists in the areas of operator knowledge of plant activities while off-shift for a few days and consistency amongst shift supervisors in information on plant status conveyed to the shift during turnover briefings (i.e., some shift su)ervisors provide more information to operators during turnover than otlers).
c. Conclusions The inspector concluded the licensee was well prepared for the evolution of drawing a vacuum and successfully verified that their secondary plant was ready to support unit restar .2 RCS Draindown from Imoroner Clearance Restoration a. Insoection Stone (71707)
On August 9. 1997. an error by an operator removing clearance tags and restoring an RCS pressure transmitter (PT) to service resulted in an inadvertent and unrecognized draining of the RCS. The inspectors reviewed the details of the event and the results of the licensee's root cause investigation under PC 97-5264, b. Observations and Findinas The subject RCS P1 was isolated by system root valve RCV-83 which was red tagged closed per electronic clearance order (ECO) 97 08 065. A second valve included on the EC0 for position control was the instrument drain valve described as valve " Valve V-1 - Drain Valve for RC-132/38-PTl&3 " It was unpiugged and opened to drain the PT but was not tagge . ---- - - _ _ - - - . . _ - - - - _ . - - . -
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When the operator went to remove the clearance and restore the PT. he .
went directly to the root valve. RCV 83. Adjacent to this was a high point vent valve for the PT that was labelled "V-1." This valve was closed and plugged already but the operator assumed it was the aforementioned V-1 drain valve and signed on the clearance restoration that the valve was closed with the plug installed. The drain valve V-1 that he should have restored was on a different level in the reactor building and not visible to the operator. He then removed the red tag from RCV 83, opened it, and left the reactor building. This created a !
leak path from the RCS through the root valve. through the V-1 drain valve which remained open. to the reactor building sump. The leak continued for approximately 47 minutes and resulted in a pressurizer level drop of 100 gallons. The drop was noted by control board operators who directed RCV-83 to be closed, stopaing the leak. The inspector considered the operator's actions exhi)1ted a significant lack of a questioning attitude and a lack of verification of the results of his actions. Tfie licensee's investigation also identified this as a root cause. However, their root cause investig6 tion extended beyond this obvious cause and recognized the challenges presented to the operators by inadequate labeling of the valves. The licensee has not had labels on instrument valves downstream of main root valves. Some of the valves have generic labels such as the V 1 designator used on these valves but no nomenclature. The licensee did not have a system for these generic labels which was why two valves on the same PT loop were labelled V-1. The licensee has had other recent problems where labeling has been a contributing cause. As a result of this, the licensee committed to label these instrument valves as part of their corrective action. This was a significant project that will require engineering and operations coordination to develop a system for labeling numbers and affixing the labels. The inspector considered this initiative to be consistent with the resolve of the licensee to enhance programs to eliminate challenges to the operators that the inspector has previously observed. The licensee's investigation also identified unclear expectations for tagging of vent and drains to support work and an inadequate pre-job briefing as contributing causes. They identified appropriate corrective actions to revise the clearance procedure to address these problem '
c. Conclusions The inspector concluded the licensee's corrective actions for this problem were comprehensive and proactive. The plan to label instrument -
valves is a very significant task fc the lice'see. Consequently, consistent with Section Vll.B.1 of t' N ' Enforcement Policy, this licensee identified failure to follo edure is identified as a Non-Cited Violation NCV 50-302/97-13-01. Inv var Clearance Restoration Causes RCS Lea . - .- -. .
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04 Operator Knowledge and Performance 04.1 Doerations Readiness Insoection Scooe (71707)
The ins)ectors continue to assess examples of Operations performance to gauge t1e o)erators questioning attitudes and communications practice Operations leadiness is a restart restraint item on the NRC Restart Lis Observations and Findinas Problems continued to occur that indicated weaknesses in Operations communications with other departments and inconsistent cuestioning attitudes. The improper clearance restoration discussec earlier in this report was a significant example of poor questioning attitude and verification of actions. Another notable negative example was the notes and memos from the licensing organization that were found by the inspector in the main control room copy of Technical Specifications on August 22. The inspector observed that the memos clarified what specific instrument tag numbers corresponded to required Technical Specification (TS) 3.3.17 Post-Accident Monitoring (PAM) Instrumentation verbal descriptions and what other arocedures would be applicable if an instrument failed. The inspector o) served that a Shift Supervisor used these memos to respond to a question on PAM operability but did not question their presence in the controlled TS copy. While the inspector did not identify anything incorrect in the guidance, the inspector considered the memos to be potential TS interpretations made through an uncontrolled process. One memo dated in February 1996 noted that the guidance given would be incorporated into the TS Bases by July 199 ,
This did not happen. The licensee replaced the control room copy of the TS and performed an audit to verify no other examples were in other copies. This audit revealed some other minor discrepancies with updating of the Technical Specifications controlled copies that were correcte The inspectors did observe several good examples of operator questioning attitude. A clearance was questioned by the operator who hung the tag and this hanger resulted in identification of an inadequate clearance on August 21 (PC 97 '127). Another operator rejected a clearance request to fill and vent a system because this was prohibited procedurally and would result in the clearance process being used in lieu of procedural guidance (PC 97-6142). Operations shiF. turnovers remain goo Operators usually demonstrated good knowledge of plant status and evolutions and appropriate information was conveyed at turnover meeting c. Conclaions The inspectors concluded that Operations questioning attitude and communications remain a challenge to the licensee, but licensee
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management continued to pursue the problems and implement initiatives aggressively in an ef fort to improve performanc The inspector assessed the licensee's performance, with respect to this restart related issue, in the. five NRC continuing areas of concern:
. Management Oversight Good
. Engineering Effectiveness - N/A e Kncwledge of the Design Basis N/A e Conipliance with Regulations Adequate e Operator Performance - Adequate 05 Operator training and Qualification 05.1 STAR Simulator Trainina ,
a. Insoection Stone (71707)
On September 9, 1997, the inspector observed Stop-Think-Act Review (STAR) Simulator training for operators. The purpose of this training was to train operators in communications and STAR techniques, b. Observations and Findinas The STAR simulator is a cabinet with various knobs, buttons, switches, lights, and labels that are situated in such a manner that is confusing and illogical. The labels are confusing because of the way they are enumerate For example, one switch was labeled "2USXF6" and another
"PUXFS6" (subtle differences). A switch to start a motor indicated
" START STOP" and another switch, with the same identification label, indicated "0 PEN-CLOSE." The exercise in this instance was to recognize that starting a motor requires a switch to be manipulated in a START-STOP and not an OPEN CLOSE manner, in addition, it requires the students to question the labeling since two different switches could have identical label The STAR simulator cabinet was connected to a computer terminal so that the instructor could follow the students' progress and anticipate the next manipulating function. An audible alarm was also connected to indicate when a wrong manipulation had occurre There were two students at a time Jerforming the training, with one performing the manipulations and t1e other reading steps in a procedure. Both students were visually isolated from each other, but able to communicate via electronic headsets. This reenforced the need for formal and precise verbal communication The procedure itself contained some potential problem areas for the students. Time was allowed beforehand for the students to review the procedure and ask questions of the instructor. The procedure contained typographical errors, out-of-sequence steps, missing steps, and notes placed in ina)propriate locations. For example, a note placed after one step and at tie top of the next page indicated that the next step must
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did not recognize this beforehand, by tle time they turned the page and ;
read the note, ten seconds would more than likely have passed and thus i caused an alarm. Another time constraint built in was if the students i proceeded too cautiously and used more frequent repeat backs. the '
temperature inside the cabinet would exceed its operating range and the ,
audible alarm would actuate. The procedure itself was written to establish ventilation to avoid overheating of the cabine ;
The licensee indicated the intention to develop other simulators and I offer this training to other plant personnel sometime in the futur I c. Conclusioni The STAR simulator training provided to the operators appeared to be very thorough and effective. Feedbeck received from the operators by the inspector was very positive. Other plant personnel will benefit greatly when similar type simulators ;re developed for instruction in communications and STAR technique .2 EFIC System Trainina a. Insoection Scone (71707. 62707)
On September 11 12, 1997, the inspector observed emergency feedwater initiation control (EFIC) system training. The purpose of this requalification training was to provide Instrumentation and Control (l&C) personnel with a brief system review along with instruction on the latest changes to the system and associated procedure b. Observations and Findinas All of the students in the class had previously received EFIC system training, although in most cases it had been at least two years. Most of the students had not performed any type of work on the EFIC system within that two year period. Because of this. most of the first day of the two day training session was used to review the system and its various purposes and function Many drawings were used in the conduct of this course because of their necessity and value when performing troubleshooting on the EFIC syste The drawings that were used extensively were the 118 series drawings .
(electrical logic diagrams) and the flow diagram for the emergency t feedwater(EFW) system. Recent modifications to the EFW system, specifically. the cavitating venturi modification.- resulted in revisions and changes to various drawings and procedure The revised EFW system flow diagram was not used during this class, even though it had already been issued, Some of the ll8 series drawings used in class were also
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The inspector followed up with questions regarding the effectiveness of the training with a few students. Some indicated that the written i
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examination was very challenging because a lot of material was covered in only two days and that the training should be longer 'n order to cover all the material. Others indicated that the examir.ation was challenging but appropriate for what was presented in the class, c. Conclusions Overall, the EFIC requalification training was adequate. The inspectcr questioned the of fectiveness of the training due to *.he extensive time spent on syst?m review and hurried manner in present,ng the various modifications affecting the EFIC system and associated procedure Better lesson plan preparation would be prudent to e.1sure an effective and thorough training class is provided to students with or without prior system knowledge and experienc Operations Organization and Administration 06.1 Effective September 2. 1997, the following management changes were made:
- Mike Danford assumed the role of Manager. Nuclea.- Safety Assessment Team (NSAT) on an interim f> asis, during the recovery effort prior to restar Mike will rema.n in this position until a permanent replacement is name * Dave Daniels assumed responsibilities for ceordincting the site self-assessment program under Jim Baumstark. Director. Quality Program Quality Assurance in Operations 07.1 Management Correttive Action Plan (MCAP 11)
a. Inspection Scone (40500)
The inspectors reviewed the licensee's status on the actions described in Management Corrective Action Plan (MCAP 11) to verify satisfactory arngress. The NRC Confirmatory Action Letter to Crystal River of iarch 4,1997, included five actions to be taken by Crystal River before restart of Unit 3. Action four of the letter required that FPC " Meet with the NRC to discuss FPC's acceptance criteria for and achievement of satisfactory progress on the actions described in FPC's Mananement CorrectiveActionPlan(MCAP). Phase 11.forwardedbyFPC'sletterof November 12, 199 The five sections in MCAP 11 that were inspected for satisfactory progress were 1) Section A. Leadership Oversight and Involvement: 2)
Section B. Engineering Performance: 3) Section C. Configuration Management / Design Basis: 4) 9ction D. Regulatory Compliance; and 5)
Section E. Operations Performanc The inspectors also reviewed the licensee's recent self assessment of MCAP 1 The stated purpose of the MCAP 11 Effectiveness Assessment
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Report. dated August 22, 1997, was to assess the results of the corrcetive actions intended to address the root and contributing causes of the problem areas, QbservationsandFindinas b.1 Section A - Let tshin Oversinht and Involvement The problem in this area, as described in HCAP 11 was that leadership oversight and involvement in plant issues had been inadequate in emphasizing its safety culture role. This had occurred in areas ranging from communication and reinforcement of core values and expectations to site processes and priorities. Further, where assessments had been conducted, they had neither focused on elements from the safety culture perspective, nor had they been sufficiently self critical to enable assessment of root or apparent cause The inspectors verified that most of the MCAP 11 action items in this area had been completed. Of those that were not completed, the licentee had identified none as restart items. The inspectors noted that the corrective actions had been comaleted for the items identified by the licensee as restart items for t11s area of concer The inspectors assessed that the uncompleted MCAP 11 action items in
< this area were not required for restart. However, the inspectors did identify one item on which progress was needed arior to restart; this was: personnel errors. The licensee's recent iCAP 11 Effectiveness Assessment had rated the three site management areas of human errors, performance monitoring and trending, and related analysis and follow up as "2" (indicating less than adequate progress). Although corrective actions had been completed in the form of human error reduction training, there were indications that this training had not been full effective. Operatorerrorscontinuedtobeexcessive(seesection below). In addition, the inspectors noted that the licensee did not have a plan to reduce engineering errors, which had been a problem area (see tection b.2 below). Unlike Operations or Regulatory Assuranc Engine 9 ring had no )erformance monitoring for personnel errors or quality of work. T1e inspectors further noted that )ersonnel errors had been dropped from the CR3 Top 10 Priorities List. Tiis was part of the change made in the Top 10 List in 1997 to shift focus from programmatic (MCAP type) areas to restart (hardware) item The inspectors reviewed the licensee's )erformance monitoring in this area, and noted that most of it was to se derived from trending of Precursor Cards (PCs). However, the PC trending program was not yet established. Consequently, most of the intended performance monitoring of the leadership oversight and involvement measures of effectiveness had not been accomplishe The inspectors reviewed the licensee's recent MCAP 11 Effectiveness Assessment Report and noted that it rated the overall area of leadership oversight and involvement as a 3. The rating of ~3" indicated that some
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improvement had been made, root causes had been partially satisfied, and full resolution of the problem was pending completion of remaining significant corrective actions. The inspectors found this assessment to !
be reasonably accurate. However, the inspectors noted that the MCAP 11 Assessment Report did not assess the current status on MCAP action items with respect to readiness for plant restart. Also, ins >ectors noted that the licensee's plan for follow up and closure of tie MCAP 11 Assessment Report findings / recommendations consisted of asking Department Directors to review the report and address the recommendations as they deemed appropriate. The plan did not include documenting the actions taken in response to the recommendations, b.2 Section B - Enqineerina Performance The MCAP 11 concern in this area was that the engineering department had ,
not supported plant operations well particularly in maintenance and the application of the plant design basis. The focus of the concern was primarily on design and analytical work, configuration management, and teamwork with other departments. Two root causes and several contributing causes were identified that required corrective action The two root causes listed were 1) safety culture was not effectively emphasized and 2) inadequate consnunication of management expectations with respect to safety cultur The contributing causes included inadequate performance monitoring, trending, self-assessment, detection of adverse trends, inadequate root cause analysis, and ineffective coninunication of problem The inspectors verified that the licensee had completed or made satisfactory progress in implementing the corrective action items listed in MCAP 11 that addressed engineering performanc The licensee had identified one uncompleted MCAP 11 item as a restart item:
MCAP 11 Item B CC2-1: Assure the tracking and trending of measures and indicators for the contributing cause (above) are assessed by engineering managers to uncover l' adverse trends requiring increased management attention and 2) potential common causes of both equipment and human performance issues. The due date was September 30, 1997. This issue was identified as licensee restart item OP The inspectors noted that, while engineering errors had been a concer the licensee did not have a plan to reduce engineering errors. Unlike Operations or Regulatory Assurance, Engineering had no performance monitoring for personnel errors or quality of wor The ins)ectors reviewed the MCAP 11 Effectiveness Assessment Report and noted t1at engineering performance was rated 4 out of , b6s ;1ble 5 ne rating indicated that significant improvement was made W::' the arret engineering managemen Problems and causes had been rewjnized aM corrective actions had been implemented. Corrective actions beyond hCAP 11 had also been implemented. The inspectors found this assessn..nt to be reasonable, but it was not confirmed by performance monitorin _ , ,._ _, _ __ _ ___ . _ . _
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b.3 Section C - Confiauration Manaaement/Desian Basis e The MCAP !! concern in this area was that weaknesses had existed in implementing programs for maintaining plant configuration consistent with the design basis. The problem description identified weaknesses in the following areas: 1) 61screpancies between the plant and design documentation: 2) inaccuracies in the technical content of design documents: 3) incorrect assumption and calculational errors: 4)
discrepancies between operational configuration and supporting design ,
documentation; and 5) irconsistencies among design documents and between the design basis and licensing basis. The root cause was identified as a limited emphash on nuclear safety culture. The contributing cause was inadequate self assessment for 1dentifying and correcting these issue The inspectors verified that the licensee had completed or made satisfactory progress im)1ementing the corrective action items listed in MCAP 11 that addressed t1e above concern. Of those not completed the licensee had identified six as restart items:
MCAP 11 item C-ID-I 1: Implement the Design basis and Licensing Basis as major programs. The due date was Seatember 15, 199 This was identified as licensee restart item QP- MCAP 11 item C RCl-7: Establish a comprehensive management control process for the Design Basis. The due date was December 1. 199 This was identified as licensee restart item OP MCAP 11 item C-ID-I-3: Establish the legal and regulatory status of the FSA The due date was November 30, 199 This was identified as licensee restart items OP 8 and R-2 MCAP 11 item C-ID I 6: Revise procedure N00 11. Maintenance of the Current Licensing Basis, to require engineering review of the FSAR and design basis documents. The due date was November 30. 199 This was identified as licensee restart items OP-8 and R-2 MCAP 11 item C-ID-1-7: Promulgate a procedure for the control of design and licensing basis documentation for the entire nuclear organization. The due date was September 30, 1997. This was identified as licensee restart item OP MCAP 11 item C-ID Vil-6: Improve the definition, understanding, and use of the licensing basis. The due date was Se)tember 1 , This was identified as licensee restart item b2 The inspectors also reviewed the MCAP 11 Effectiveness Assessment Report and noted that Configuration Management and Design Basis was rated '3". .
The rating indicated the work 3rocesses had improved: the review of design basis issues on safety lad been completed; procedures had been revised: the modification process had been revised; a Design Review Panel ensures requirement are addressed: and the utilization of the
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11 corrective action program for precursor cards (deficiencies) had been !
increased for documenting configuration and design issues. The inspectors found this assessment reasonably accurat b.4 Section D - Reaulatory Como11ance MCAP 11 described the problem in this area to be that CR3 did not have a sufficient understanding of NRC regulations and did not assign full compliance with the intent of NRC regulations a sufficiently high priority. Also, there had been a perception that conservative decision making regarding regulatory issues was seen as secondary to plant ;
availabilit The inspectors verified that most of the MCAP 11 actton items in this area were completed. Of those that were not completed, the licensee had identified one as a restart item: l MCAP 11 item D RCl.6: Benchmark key regulatory processes against Systematic Assessment of Licensee Performance (SALP) 1 plants and revise processes as necessary. This was identified as licensee restart item OP-5. with a due date of November 30. 199 The inspectors considered that the other uncompleted MCAP 11 action items in this area were not needed for restart. However, the inspectors identified one additional item on which progress was needed prior to restart. One MCAP item was to conduct an assessment of Regulatory -
Compliance and Licensing, which had been completed in January 199 That assessment identified that the availability and knowledge of licensing and design basis information to the plant staff was not adequate to support 10 CFR 50.59 evaluations, operability evaluations, or TS inter)retations. A Precursor Card on this finding had been written in 'ebruary 1997. but was one of about 4000 low level PCs that had been closed without tracking of corrective actions to completio (The ins)ectors had previously addressed the issue of prematurely closed PCs as 1 1 50 302/97-11 04. Corrective Actions for Approximately 4000 Precursor Cards not Tracked to Com The licensee's OA group was doinq an audit of those 4000 PCs.)pletion). Licensing had a plan to address th availability and knowledge of licensing and design basis information by March 1998, in response to inspector questions. Licensing began developing a plan to adequately improve the availability and knowledge of licensing and design basis information prior to restar The ins)ectors reviewed the licensee's performance monitoring in this area, w11ch included trend charts showing improvement in submittal quality and timeliness for LERs. violations, and other licensing submittals. The inspectors concluded that the licensee's aerformance monitoring in this area was good. While im)rovements had >een made in the quality of licensing submittals, both t1e licensee's monitoring and the inspectors' reviews of submittals indicated that additional improvement was warranted.
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The inspectors reviewed the licensee's recent MCAP 11 Effectiveness Assessment and noted that it rated the area of regulatory compliance a
"3". The rating of ~3" indicated that so'ne improvement has been made, root causes have been partially satisfied, and full resolution of the >
problem was pending completion of remaining significant corrective actions. The inspectors found this assessment to be reasonably accurat b.5 Sgetion E Ooerations Performance in this area. the problem description was that the Operations Department had not attained a level of performance equivalent to those measured as excellent by Institute of Nuclear Power Operations (INPO) and the NRC, Also, outside and internal audits had detailed several areas in need of improvement in order to attain operational excellenc The nspectors verified that most of the action items in this area were complete Of those that were not completed, the licensee had '
identified two as restart items:
MCAP 11 item E-FU-3: Address all identified emergency operating procedure (EOP) weaknesse This was identified as licensee restart item OP 19D. which was scheduled for completion by November 21. 199 MCAP 11 item E-CCl-4: Reduce the abnormal procedure (AP) backlog ,
to less than 10 outstanding comments through the use of contract procedure writers. This was aartially addressed by licensee restart item OP 19C. which scleduled rewriting of certain APs required for restart to be completed by November 21. 199 The inspectors assessed that the other uncompleted MCAP 11 action items in this area were not needed for restart. However, the inspectors did identify one additional item on which progress was needed prior to restar The licensee's recent MCAP 11 Effectiveness Assessment had found that operator errors were excessive. While the Operations Department had completed their MCAP 11 action items in the area of operator performance early in 1997, they continued to have excessive operator errors. The inspectors found that the O recognized the problem and had a new action plan,perations Departmentin monitoring, to address operator errors before restart. The inspectors noted that the Operations Department action plan was not captured in MCAP 11 or the licensee's Restart List, but concluded that it was receiving adequate management attentio The ins)ectors reviewed the licensee's performance monitoring in this area, w11ch included trend charts on operator errors. The inspectors assessed that the licensee's performance monitoring in this area was goo __
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The inspectors reviewed the licensee's recent MCAP 11 Effectiveness Assessment and noted that it rated the area of Operations performance a
~3". lhe rating of ~3" indicated that some improvement had been made, root causes had been partially satisfied, and full resolution of the problem was pending completion of remaining significant corrective actions. The inspectors found this assessment to be reasonably accurat c. Conclusions The inspectors concluded that the licensee's progress to date on the Management Corrective Action Plan (MCAP 11) was satisfactor The licensee was not yet ready for restart, but had plans to get there. Ten open MCAP 11 items were on the licensee's restart list. 41s inspectors identified two additional items on which progress was needed prior to restart: personnel errors (quality of work) and availability and knowledge of licensing and design basis informatio The inspectors concluded that the licensee's recent assessment of MCAP 11 was generally good. However, the MCAP 11 Assessment Report did not assess the current status on MCAP action items with respect to readiness for plant restar Also, the licensee did not have a good plan for follc..' up and closure of the MCAP 11 Assessment Report findings and recommendation The inspectors assessed the licensee's performance, relative to MCAP II, in the five areas of continuing NRC concern:
e Management Oversight - Adequate o Engineering Effectiveness - Adequate e Knowledge of thr Design Basis - Adequate e Compliance wttt hgulations - Adequate e Operator Performance - Adequate 08 Miscellaneous Operations Issues 0 (Clospd) VIO 50-302/94-25 01: railure to Proper 1v Control the Control Comolex Habitability Englone (Joor Blocked Open for Maintenance Work)
a. Inspection Stone (92901)
This violation involved maintenance personnel blocking open a control complex habitability envelope (CCHE) door for maintenance work on the building roof. The inspectors followed u) on the licensee's corrective actions as stated in the response to the 4RC Notice of Violation, b, Observations and Findings The inspectors verified that w sig..s were installed on the control complex habitability envelope doors to identify clearly actions to be taken when work activities affect the doors. In addition the licensee had installed door alarms which sounded when a CCHE do;r was ope The
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licensee had also installed a vestibule, with another door, at each of the three large double CCliE door The inspectors noted that the licensee had installed the door alarr.s and vestibules in response to subsequent additional instances of CCHE doors being inappropriately left open. The inspectors also reviewed the licensee's completion of maintenance training on a related LER and a maintenance study book entry on the event. There had been no recent instar.ces of CCliE doors b. ing left ope Related design issues with control complex habitabiliv enve10)e leakage were being tracked under URI 95 02-02. Control Room Habita]ility Envelope Leakag c. Conclusions The inspectors concluded that the licensee's stated corrective actions, and more, had been completed. These included actions to prevent recurrence of the violation. VIO 50 302/94 25 01 is close The inspectors assessed the licensee's performance, relative to corrective actions for this violation. In the five areas of continuing NRC concern:
e Management Oversight - Adequate o Engineering Effectiveness - Adequate e Knowledge of the Design Basis - Adequate o Compliance with Regulations - Adequate e Operator Performance - Adequate 08,2 (Closed) LER 50-302/94-009 02: Unauthorized Tests involvinn Makevo Tank level and Pressure Inspection Scope (92901)
This LER involved unauthorized tests of makeup tank level and pressure that had been conducted by operators. The issue described in the LER was related to EA 95-126. VIO I.A (01013). Nine Instances Where Operators Violated Procedures for MUT Pressure / Level: VIO I.B (02013).
Conduct of Unauthorized Tests of MUT k'ithout ;0 CFR 50.59 Evaluation:
and V10 1. C.1 (03013), Failure to Take Adequate Corrective Actions for Operator Concerns Regardmg 0P-103B. Curve M. for MUT Pressure /
Temperature limits: which were closed in IR 50-302/97-0 The inspectors followed up on the licensee's corrective actions as stated in the LE b. QDservations and FindirLqi The inspectors reviewed the licensee's corrective actions stated in the LER and concluded that they were encompassed by the corrective actions for the three closed related violations, c. Conclusions The inspectors concluded that the licensee *s corrective actions had been
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im lemented and had been LER 50- -
30 /94 009-02 is closed. previously inspected and documente .3 (Closed) VIO 50 302/96 01 01: Lnadeauate Corrective Action to Fix Hioh Pressure niection (HPI) Flow . ndication Problems a. Insnection Scone (929111 This item was tracked by the licensee as Restart Issue 0-53 on their restart list. It pertained to the condition of the four HPl line flow indicators prior to February 1996. In 1989, as documented in LER 50-302/89 037, the licensee determined that the existing, single, wide-range indicators in each HPI line were inadequate to support the required operator action to balance HPI flow in response to a broken line. Consequently the licensee added four narrow range (NR)
instruments, one in each HPl line, in February 1996, the licensee determined that the failure of the DC power supply t( the NR instruments during a specific accident scenario would again result in inadewate indications for the operators to balance HPI flows. This violation was identified for inadequate corrective action to resolve the issue the first time in 1989. The licensee also issued LER 50-302/96 07 which was reviewed and closed by the inspector in Inspection Report 50 302/97 1 The inspector reviewed the closure package the licensee assembled that justified their closure of Issue D 53 and VIO 50 302/96 01-0 b. Observations and Findinas The inspector noted that the licensee's closure package justified in detail that the currently installed HPI flow indicators were technically adequat The inspector did not identify any problems with the licensee's technical conclusions and verified they were consistent with the bases used for closing LER 96-07 on the same issu However, the licensee's package, which was based on their violation response letter '
dated May 13, did not address the title and basis of the violation, which was inadequate corrective action. The inspector was especially concerned with this omission because the licensee's closure package had been reviewed and approved by their Nuclear Regulatory Assurance Group (NRAG). The inspector discussed the importance of responding directly to the requirement that was cited with the NRAG Hanager and was satisfied that the licensee's sensitivity was now a>propriate. The licensee attributed the root cause of the event to ae personnel error in 1989 but then did not identify any corrective actions ts audress this cause. The inspector determined the cause of the event was related to the inadequacies of the licensee's design process in the past which have already been the subject of recent extensive NRC enforcement (EA 96-365), licensee corrective action, and NRC insSection (Inspection Report i 50-302/97-11). Numerous actions have been taten by the licensee during l
the current shutdown te correct engineering design processes as well as their corrective action system. These have been previously inspected as
, satisfactory and are tracked on the restart restraint list.
l Consequently, the inspector determined the licensee had adequately addressed the root cause of this violation.
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'16 w._ Conclusions .
.The inspector determined the licensee's completedirestart item fully ,
addressed the original technical concerns of the item. Consequently VIO :
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50 302/96 01-01 is closed. However, their violation response letter and closure package were inadequate because they were lacking any resolution-of the inadequate corrective action that was the cause of the violatio ,
The inspector-concluded the omission was another example of the already-reported weaknesses in-the licensee's sensitivity to regulatory '
requirement The inspector assessed the licensee's corrective action aerformance, with respect to thfs restart-related issue, in the five 4RC continuing areas of wncern:
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- Management 0versight - Inadequate
- Engineering Effectiveness -
Good
. -Knowledge of the Design Basis - Adequate e Compliance with Regulations - Inadequate e Operator Performance - N/A 0 . Closed) 910 50-302/97-01-OL Inadeauate Clearance Taaaina Reautrements ,
LRestart .ssue No. 0 12' (71707. 92901)
By letter dated April 23, 1997.-the licensee responded-to Violation (VIO) 50 302/97-01-01 describing the corrective actions they had taken and results achieved. However, the NRC considered FPC's response too narrowly focused and by letter dated May 16. 1997 requested the licensee to provide a supplemental Notice of Violation (NOV) response-that would address more com'rehensive
- corrective actions. By letter dated June 16. 1997 FPC su)mitted its supplemental response, An inspector reviewed t % licensee's comprehensive corrective actions to address this and other protilems related to im)lementation of their-clearance control and tagging program prescri3ed by Compliance Procedure (CP) 115, Nuclear Plant Tags and Tagging Orders. As part of the corrective actions identified in their letter dated April 23, 1997. FPC conducted a formal root / common cause analysis documented by Root Cause (RC) 96-5457 dated April 1. 199 The summary results and additional corrective actions from this analysis were provided in the June 16. 1997.- lette The ins)ector reviewed the licensee's closure package for Restart Issue
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.0-12 w11ch included the applicable incident report, training records, required reading material. CP-115 revisions (Nos. 74 and 75), short term instruction-(STI).-RC:96-5457, et The inspector also met with the Operations Manager to discuss the details associated with the
. accomplishment of these corrective actions. The licensee's corrective actions were generally thorough, complete and well documente However.
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several minor deficiencies were identified: 1) Incomplete training attendance records for STI 9L 008: 2) Incomplete training attendance records for'the Manager. Nu(. lear Powar Operations (MNPO) Event Free
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P 17-Seminar 01: ussing CP-115 Events during Operator Recualification ;
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maintenance slops were provided coaies of and actually reviewed RC 96-5457 and the training summary of C)-115 changes. The inspector discussed these discrepancies with the Operations Manaaer, who managed to locate more complete attendance records for-STI 97-D08, No additional records could be found regarding the Event Free Seminar. In fact, the Operations Manager confirmed there was no su> porting evidence that three of the on shift senior reactor operators (SRO) had attended ,
the required seminar. Also, the SR0s themselves could not *::all the '
specific seminar, Notwithstanding the missed training.1% i serations Manager considered subsequent requalification training on c m ram changes associated with CP-115. Revision 75 to be sufficicm. Lastl *
-he confirmed that the information provided to the maintenance shops for their review was conducted on an informal basis, the only evidence being verbal assurances from maintenance management. The inspector considered 4 these to be reasonable explanation ,
In addition, the inspector reviewed a number of active in plant tagging .
orders, interviewed shift
> _ processing tagging orders, personnel responsible for developing andand the field. All tagging orders and individual tags examined by the inspector.were in 3 roper order, -Responsible personnel were knowledgeable in t1eir duties and familiar with recent changes to the process (i.e., CP-115 revisions). To their credit, these individuals were still exploring potential -improvements in plant processes for tagging and clearance control, and providing suggestions. Furthermor '
the licensee's commitments to assess the long-term effectiveness of their corrective actions by performing a common cause analysis of Precursor Cards (PCs) dated March 1 through December 31. 1997, and-conducting-a special audit of CP-115 compliance by February 24, 1998 were considered positive steps in their determined efforts to prevent recurrence. This VIO is considered close The inspector assessed the licensee *s performance, with respect to this
- restart-related-issue, in the five NRC continuing areas oi concern:
e Management Oversight - Superior r ^e Engineering Effectiveness - N/A
e Knowledge of Design Basis - N/A e Compliance with Regulations - Good
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e Operator Performance - Good
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. OR.5 (Closed) VIO 50-302/97-01-02: Failor.e To Follow Procedures. Resultina in An Inadvertent-Emeraency Diesel Ge v ator-Start IRestart issue No. 0-131 (71707. 92901)-
By letter dated April 23, 1997, the licensee responded to VIO 50-302/97-01-02 describing the corrective actions they had taken and results .
= = achieve In this letter the licensee stated that the violation occurred due to personnel error and the responsible Primary Plant-Operator (PPO) had been counseled by tne Opert,tions Manager. Also, a
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)ersonal imarovement plan.Ldated February 7. 1997. was developed for the- +
)P0 using F)C's progressive-discipline program. The PPO was not
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aermitted:to resume his duties until the plan was completed and approved
)y'the Operations Manager. An inspector reviewed the personal improvement plan and discussed it with the current Operations Manage .
-The Operations Manager indicated that the PPO had since completed the ;
plan satisfactorily and his qualifications were restore In addition to the corrective actions identified in their letter dated
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A)ril - 23. 1997. the licensee re examined the time-sensitive nature of t1e procedure steps for functionally restoring an emergency diesel generator (EDG) to service. FPC concluded that the prescribed time >
-frame for performing steps 4.6.30 thru 4.6.34 of Surveillance Procedure
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(SP)-354A(B), Monthly functional Test of Emergency Diesel Generator EDG-1A (EDG-18), was much too restrictive (i.e., PP0 was only allowed 5 -
minutes). Although this principal contributing cause to the PP0's
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failure to follow procedure was recognized and addressed by .the licensee.-it was not included as part of the closeout package for Restart Issue 0 13 nor mentioned in their NOV response. The inspector verified that the latest revision of SP-354A. Revision 45, did incorporate the newly expanded time interval (i.e. 40 minutes) for the PPO to tri) the EDG fuel racks and roll the diesel after a ru However. 5)-3548 had not as yet been revised. The Operations Manager indicated that SP-354B would be revised prior to the next monthly functional test of EDG-18. This VIO is considered close The inspector assessed the licensee's performance, with respect to this restart-related issue, in the five NRC continuing areas of concern:
e Management Oversight - Good e Engineering Effectiveness - N/A e Knowledge of Design Basis - N/A e Compliance with Regulations - Adequate e Operator Performance - Good 1L. Maintenance M1 Conduct of Maintenance M1.1 General Comments (62707)
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The licensee has implemented several changes in the maintenance
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department over the last several months to improve performance. These
- included assigning new management, developing the position of production coordinator in each shop to assist with emergent job problems and scheduling, and developing a maintenance support grou) to perform corrective action investigations and remove some of t1e administrative burden from the shops to allow them to focus on production. Although-the results of these changes have not yet been consistently displayed.
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- the-inspector-concluded they were a good initiative by the license The licensee maintenance department has also. focused on a goal of
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significantly reducing the corrective maintenance backlog. On September
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13, the licensee achieved their goal of less than 200 open corrective maintenance work request This was dcan from a peak of 768 in May of 1997. The inspector concluded this was a significant achievement by the licensee and would allow the licensee to focus resources expeditiously on emergent problem M1.2 Soent fael Coolina Pumo 1A Rebuild (62707)
In June of 1997, the licensee replaced the bearings and mechanical seal for Spent Fuel Cooling pump (SFP) 1A to correct mechanical seal leakag This was performed under work request (WR) 033495 Post maintenance testing of this work revealed excessive noise and vibration when the pump was run. A mechanical rubbing sound was also heard when the shaft was rotated by hand. WR 0344929 was generated to trouble shoot and repair this ]roblem. The troubleshooting revealed that a rubber preload spacer for t1e mechanical seal had not been removed and that the pump impeller had contacted the pump casing. The licensee initiated Precursor Cards (PC) 97-4239 and 97-4611 to investigate the proble The inspector reviewed both of the aforementioned work packages and the apparent cause investigation results for the PCs. The licensee concluded that the preload spacer was not the cause of the noise and vibration but that 3 roper referencing and use of a vendor mechanical seal drawing would lave ensured it was removed. The licensee implemented appropriate corrective actions to prevent recurrence. The cause o' the noise and vibration was determined to be excessive shaft end play as a result of missing bearing end cover shims. Although various circumstances with the pump rebuild led to the decision to omit the end cover shims, the licensee and inspector concluded that a lack of questioning attitude by the mechanics and failure to elevate the problem with the new bearings to su)ervision was the cause. The mechanics made inappropriate assumptions t1at their activities were within the skill of their craft. The only corrective action the licensee implemented for this problem was a review of the problem with all mechanical maintenance personnel. Although the licensee performed an extent of condition review in their PC that noted that they had several other pump problems
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due to maintenance activities in the last three years, they did not take any generic corrective actions to address the problem. The inspector was concerned because several of these problems have occurred in the past year. Licensee managemen'. was focusing on the generic implications of the problems. The inspector verifled the physical problems with the pump were adequately corrected and it was returned to service. The ins)ector did not identify any further or 3Cs and concluded that the licensee' problems with s investigation was the work packages adequate, but not thorough, and the corrective actions were limite .
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Hl.3 Decay Heat Removal System Hydrostatic Testina a. Insoection Scooe (62707)
The inspector reviewed the preparations and observed portions of the
>erformance of hydrostatic testing of a newly installed manual Decay leat system (DH) pump suction valve (DHV-21) performed under WR 0346318 on August 18 through 2 b. Observations and Findinas The inspector observed the pre-job briefing and noted that all involved parties attended, the test was reviewed in detail by the cognizant mechanical supervisor, and questioning was open and encourage This was a vast im)rovement in coordination from previous observations by the inspector of lydrostatic testing in May 1997 that resulted in Violation 50-302/97-07-02. The inspector also noted that proper planning and precautions had been implemented to ensure adjacent systems were not inadvertently pressurized, although not all of the contingency actions were formally incorporated in the work package. The lack of consideration of adjacent systems had been a problem in the testing in May. Several of the participants questioned the use of demineralized water for the test and the potential for dilution of the primary coolant if a test boundary leaked by. They ensured that an analysis was performed to verify that the worst possible leakage would not cause a dilution problem. The inspector concluded that this was excellent sensitivity to reactivity managemen During the performance of the test, the system pressurization had to be suspended due to excessive leakage. The licensee's investigation revealed that a boundary valve was not fully seated when it was manually checked. This valve had been s)ecified to be red tagged closed in the recommended valve lineup that t1e hydrostatic test engineer developed
)er M:.intenance Procedure (MP) 137. System Hydrostatic Pressure Testin .
Revi.eton 30. attachment 1. Procedure MP-137 was encompassed within WR 0340318. However. Operations had decided the valve did not need to be tagged or included on the clearance. Consequently the valve was never checked closed prior to commencing the test. The valve also should have been checked closed as part of the position verification required by step 4.3.1 of MP-137. but this step was misinterpreted by the maintenance supervisor who signed it. While the consequences of this were very minimal. the failure of Operations to resolve their differences in implementing the valve alignment formally were indicative of incomplete communication between Operations and Engineering. The inspector considered these communications critical to ensure Operations correctly implements specific hydrostatic test requirements that are fully understood and recommended by engineering personnel. These incomplete communications were a direct cause of the failure to consider adjacent system 3ressurization in the aforementioned Violation 50-302/97-07-02. T1e licensee initiated PC 97-6106 to identify appropriate corrective actio . __ . _ _ . _ . _ . _ _ _ _ _ . . _ _ _ _ _ ._ _ _. _._ _ _ _ _
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2 The inspectors review of the completed WR package did not reveal any additional problems. The inspector noted that the chronological " Work Performed" notes in the WR were very detailed and were an accurate and informative account of the testing and preparation performanc Conclusions The inspector: concluded the licensee had made significant im)rovement in the coordination of the hydrostatic testing 3rocess, but pro)lems continued to occur regarding communications )etween different group The inspector considered these communications essential to ensure-
. successful implementation of hydrostatic test requirement Partici) ants exhibited excellent sensitivity to reactivity management and worc package documentation was goo H2 Maintenance and Material Condition of Facilities and Equipment i M2.1 Scaffoidina-Control insoection Scooe (62707. 92902)
The inspector reviewed the licensee's program for controlling scaffolding in the plant. The inspector performed walk-downs of various safety related equipment to assess the potential impact from installed scaffoldin Observations and Findinas On August 20, 1997, during a walk-down of the 4160V ES switchgear rooms, the inspector noted that scaffolding was erected in vicinity of both the protected operable train and the inoperable train. Examination of the scaffolding revealed that it was free standing, unrestrained between the two panels in both rooms, with some scaffolding over the top of the-panels. In addition, for the B 4160V ES switchgear, which was the operable train, portions of the-scaffolding were in contact with conduit and cabling where it entered the top of the panels. The scaffolding was '
erected within one foot of the panels, in areas, on both trains. In addition, walkdowns in the main control determined that scaffolding erected in-front of the main control panels was not restrained, affecting safety related component Licensee ProcedureA ' l-1803. Safety Standard for Ladders. Scaffolds, and Ancillary Equipment. Revision 11. section 3.2. Responsibility, has a note that acknowledges that inadvertent movement of scaffolding in the vicinity of safety related or protected train equipment may cause damage to personnel or equipment. - Section 4.0. Instructions. contains a- note
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that states that plant safety and reliability must be considered during erection of scaffolding and ladders; which must be erected with a minimum potential for creating a plant transient. AI-1803. section . Scaffolds- step 4.2.1. stated that the-installation of scaffolding was-
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controlled to allow the Nuclear Operations Department to approve the ;
location of scaffolding .before actual construction. A note in the- '
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procedure, section 4.2. states that scaffoldina in the vicinity of sdfety related equipment will be secured to walls or I-beams to prevent inadvertent movement and damage to safety related equipment or personnel injur Licensee Procedure 01-07. Control of Equipment and System Statu Revision 5. section 6.0 Maintenance and Testing Work Authorization and Documentation. step 6.2 stated.that installation of scaffolding in the plant must be authorized by operations personnel. According to this procedure, an operator must review the actual in plant configuration to ensure no adverse affect on nuclear safety. transient response, or normal operations has occurre . Operations Work Control Supervisor Position. Revision 0, section 1.0 Operations Work Control Supervisor Responsibilities, step 1.6. stated tlat the work control supervisor was the operations re)resentative for the scaffold control program. Step 2.5 states that t1e work control supervisor was responsible for the walkdown and approval of scaffold installation and remova Quality Programs Surveillance (OPS) Report OPS-97-0102 was issued on July 28, 1997, which reviewed the installation and removal of scaffolding. The OPS identified a weakness in the program which allowed scaffolding to be installed in contact with, or in close proximity to, safety related systems, structures and com)onents without prior evaluation and approval of engineering. T1e OPS concluded that AI-1803 was inadequate in addressing the scaffolding program. As a result of the surveillance. PC 97 5315 and PC 97-5606 were issue PC 97-5606 was issued on July 30. 1997, and stated that initial and periodic inspection of scaffr' ding was being performed without any defined instruction or criteria e tablished for installatio This PC was graded as a level D PC on August 4. 1997, and we closed on August 22, 1997, with inclusion in a computer tracking system for procedure comments. NUPOST. which is not part of the licensee's corrective action program. At the time of the inspection, these comments had not been incorporated into the licer.see procedure CFR 50. Appendix B. Criterion III. Design Control, requires that measures be established to assure that appropriate quality standards are specified in documents and that deviations from such standards are controlled. The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews. The scaffolding control program has no documented review of impact on the plant by the installation of scaffolding in the vicinity of-safety related system Experience and judgement are the only criteria used by operations in the approval of scaffolding installatio The procedure did require that scaffolding in the vicinity of safety related equipment be restrained to the wall or to I-beams. The inspector observed that operations was approving installatio'1 of scaffolding in the vicinity of safety related equipment that was not restrained. The lack of specific installation criter sa or engineering
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review of impact on safety related equipment was a violation of the 10 l CFR 50. Appendix B. Criterion III requirement. and will be addressed as l
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. VIO 50-302/97-13 02, Failure to perform a safety evaluation prior.tn
- erecting scaffolding in the vicinity of safety related equipmen I Since the concerns were identified by the inspector..the licensee has -
taken steps to restrain the scaffolding in the 4160V ES switchgear
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rooms. Engineering' performed a review of the existing scaffolding.and concluded that with the restraints,- seismic concerns did not exis Impact-on operation of-the safety related equipment has not been formally or systematically performed 'The licensee maintenance-organization was working with the engineering department to develop-criteria and procedura11ze scaffolding installation practices, to
- prevent adverse impact.on safety related equipmen Conclusions. -
Even though the licensee's GA-organization identified weaknesses in the -
scaffolding control program in July of 1997, changes were not instituted '
to the procedures and erected scaffolding was not brought into compliance when the inspector examined scaffolding in the immediate vicinity C critical-safety related equipment, such as the main control board and the operable 4160V ES switchgear on August 26, 1997. .A lack
- of timely response to the 0A identified concerns resulted in the existing scaffolding remaining in noncompliance and the ins)ectors independently identifying the programmatic inadequacie T1e licensee's .
scaffolding control program was-inadequate, in that it did not require
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an engineering evaluation prior to installing scaffolding where it may
. impact safety related equipmen M8 Miscellaneous Maintenance Issues M8,1 (Closed) LER-50-302/96-018: Failure to Verify RB Penetrations Closed oer
- lS (Closed) LER 50-302/96-018-01: Failure to Verify RB Penetrations Closed
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ner TS (Closed) EA 96-365.96-465. 96-527. V10 B (02013) -
EXAMPLE 5 ONLY:
Three inadeauate Procedures for Containment Penetration Surveillances
- (FPC Restart Items-0-2, OP-15) Insr>ection Scoce (61726. 92902)
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The inspector reviewed the corrective actions developed in response to the violation'of March 12, 1997, in a letter dated -April- 11. 1997, and
' supplemented in~a-letter dated June 16, 1997. The inspector also reviewed the corrective actions for the related LERs: dated July 5, 1996 and November 25, 1996.
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= - b. -Observations-and Findinos The responses to the violation example for.the inadequate procedures to
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assure containment inNrity address several corrective actions t .
resolve the concern. Licensee procedures SP-324. Containment inspection and SP-341 Monthly Containment Isolation Valve Operability Check were revised to include containment isolation valves identified to be excluded from the existing procedure. The inspector reviewed the licensee root cause analysis and extent of condition review, which included extensive containment walkdowns, and determined that the licensee properly identified the totai containment isolation valve population. Procedure SP 324. Revision 35 became effective on June 20, 1997, and SP-341. Revision 31 became effective on July 25, 1997. Both procedures were verified to include the valves previously omitte The licensee committed to revising Procedure SP-346. Conteinment Penetrations Weekly Check During Refueling Operations. to include appropriate isolat on valves and to address leakage pathways potentially created during refueling outages. This was committed to be completed prior to the next refueling outage the next time this procedure will be use The inspector verified that this commitment is being tracked in the licensee's corrective action system and is scheduled to be completed prior to the next refueling outag The licensee created a new series of drawings, the 315 series, which were penetration drawings. A Document Change Notice (DCN). 97 042A was issued on June 13. 1997, to control the development and issuance of these drawings. Valve and instrument tags as shown on the drawings were verified by the licensee during extensive containment walkdowns. The inspector reviewed a sampling of the drawings and found them to be detailed and comprehensiv Licensee Procedures. NEP-210. Mo11fication Approval Records. Revision 16. issued on March 31, 1997, a. NEP 254. Plant Equipment Equivalency Replacement Evaluation. Revist 3 sued on March 31. 1997, were revised to provide guidance to .. ,. engineers for handling changes to items which affect containment integrity. The inspector reviewed the changes to the procedures and determined that in reaard to changes which affect containment integrity, open items are required to be opened and dispositioned to update affected documentatio Corrective actions for LER 50-302/96 018 and LER 50-302/96-018-01 were reviewed and were similar to those developed for the violation response, with additional initial corrective actions to address immediate concerns. Enaineering provided a listing of penetrations which had not been previously surveilled to the operations department. The SSOD maintained a required action log entry to require that the penetrations be surveilled in accordance with TS requirements until the issuance of the procedure revisions. The inspector verifled that the penetrations were all verified to be in the correct configuratio c. Conclusions The licensee has adequately addressed the concerns relating to restart for the issue, which includes both LERs and the example of the violation
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$ : addressed in the inspection. Both l.ERs are closed, and example 5 of- ::
violation B of EA 96-365 are closed. The remainder of EA 96 365 remains:
open, pending inspection of each issu _
s The inspector assessed the licensee's performance, with respect to this restart-related issue, in the five NRC continuing areas of concer .
Management Oversight - Adequate -
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-Engineering Effectiveness - Adequate Knowledge of Design Basis - Adequate Compliance with Regulations - Adequate-Operator Performance - Adequate
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. IIL. Enaineerina
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- E2 Engineering Support of Facilities and Equipment E2.1 Seismic Qualification of Circuit Breakers Insoection Scooe (37551. 62707)
- - The inspectors reviewed documentation for the licensee's- review of the-issue of seismic qualifications for circuit breakers in various-configurations, including connect, test disconnect, and racked ou This review included precursor cards (PC), licensee evaluation of NRC generic communications, and reportability determinations performed by the licensee.
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- Observations and Findinas
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On April 21, 1997, the licensee issued PC 97-2032 to address a concern on a maintenance 3ractice that allowed a circuit breaker to be racked i out of the bus ca)inet and be stored on the floor. Two concerns were
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discussed; whether the cabinets-were seismically qualified with the L breakers removed and whether an interaction problem existed with the breaker stored on the floor outside of the cabinet. A reportability
, determination on April 21, 1997, was made that until an engineering
evaluation was performed, a final reportability determination could not +
be made.
I :On June '4,1997, engineering personnel issued a memorandum discussing the issue. The memorandum' discussed the two concerns and stated that the first concern was resolved by a review of. plant switchgear using earthquake experience data per the Seismic Quality U) grade Group (SQUG)
standards. A separate interoffice communication,_NOE 96-0235, was -
referenced and documented that review. Suggestions from this NOE were F discussed as being reviewed and incorporated into Request for
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' Engineering Assistance (REA) 97-0570, dated June 4, 1997, to address the second concern. - As of the completion of this inspection period, the recommendations from the REA had not been incorporated into any plant procedure . . . . - - . - - -. - - . - .-
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26 N0E 96-0235, dated December 31, 1996. contained four attachment documenting di.~ferent aspects of the seismic reviews of 460V and 4160V circuit breakers, performed by a consultant. These attachments are dated between December 6, 1996 and December 23, 1996. The original evaluation report, dated December 20. 1996 addressed both 480V and 4160V breakers. Due to the physical construction of the 480V breakers, only three >ositions can be set: connect, test, and disconnec For the three areaker types in use at the site, the consultant determined that the 480V switchgear has a positive and adequate load path for all directions of motion. The review of the 4160V breakers addressed four possible configurations: connect. test, disconnect, and racked-out (left in the enclosure). The consultant concluded that the 4160V switchgear have a positive and adequate load path for all directions of motion for all positions except racked-out. The consultant concluded that for the racked-out position, licensee Procedure OP-703, Plant Distribution System. stated that the 'reaker was to be removed from the enclosur No procedure existed thoc allows the breaker to be racked-out and left inside the enclosure with the door closed. The N0E did not address the seismic qualifications of the er. closure with the breaker remove Attachment D to N0E 96-0235, dated December 19, 1996 stated that during a walkdown of the 4160V switchgear to review the seismic adequacy of the breakers in the test. disconnect, and racked-out positions. the consultant noted that unracked breakers were stored in the walkway between the switchgear panels. The attachment states that the potential interaction issue had not been previously identified and was not addressed in the earlier evaluations and needed to be addressed. The report included a list of recommendations for revisions to licensee storage practices to prevent interaction during seismic events. These recommendations were reviewed by the licensee and some were included as proposed corrective actions in REA 97-057 On July 18, 1997, the NRC issued Information Notice (IN) 97-53. Circuit Breakers Left Racked Out in Non-Seismically Qualified Positions. This IN was issued to alert licensees to the potential that some safety-related circuit breakers in their racked-out positions may not be seismically qualified. The IN notes that removal of the circuit breaker from the switchgear will result in mass redistribution of the switchgea Mass redistribution of the switchgear may then change the frequency of the switchgear and its dynamic response during a seismic event and may invalidate the original seismic qualification of the switchgear. The IN states that the situation needs to be evaluated to ensure that the removal of the circuit breaker will not invali hte the original seismic cualification of the switchgear. On July 30, 1997 PC 97-5635 was issuec to document the review of the I The PC was closed on August 22. 1997, with the comment that these concerns were being appropriately addressed by engineering and are being tracked under PC 97-2032, which remains ope The inspector reviewed the reportablility determination from June . The licensee concluded that the issue was not reportable based on the reevaluation of PC 97-2032. The first concern was resolved per
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. verbal communications with engineering personnel and the second concern .
~ was. resolved based on N0E 96-0235 conclusions. The inspector reviewed
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the N0E, the attachments, and the PC. -There was no documentation attached to support the verbal communication from engineering to close the first concern. The inspectar discussed the issue with engineering-and was-informed that the-attachments to the N0E 1mplied that the issue-had been evaluated. The inspector reviewed the N0E-and found no mention 1 of the seismic qualification of- the switchgear with the breakers racked-4 cut and remove The second concern had been closed besed on the N0E; ;
however, the attachments identified the potential- seismic interaction as being of concern and stated-that it needed to be addressed. As a result of the incuiries of the inspector, on September 4,1997, the licensee obtainec a clarification from the consultant for the original-attachments to the NOC which addressed the seismic qualifications of the 4160V switchgear with breakers racked out and removed from the panel '
The inspector determined that the reportability deteraination performed by the licensee on June 7.-1997, did not include the necessary technical basis to justify the conclusion reache On September.10,:1997, discussions with management personnel in maintenance and operations revealed that the REA had been distributed to those departments on June 4, 1997, who were responsible'for revising the
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3rocedures'which control the removal and storage of the 4160V breakers, aut, the REA had not been transmitted to the procedure writers for either group. The licensee has now distributed this document to the responsible personnel in both departments, and the required revisions
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were '.,eing developed. The changes recommended by the REA include stor,ng the breakers in a marked off setdown area that includes loose cha'.ning of the breaker to a building structure at approximately 2/3 height of the breaker, to. preclude sliding or overturning of the breake The inspector examined the A 4160V ES switchgear room. At the time of the ins)ection, the unit was in Mode 5 with the A 4160V ES bus
- inopera)le and not required to be operable. Examining the switchgear room revealed nine breakers being stored on the floor. Five were
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-unrestrained against a wall. Four were stored in-front of the cabine None of the five breakers stored against the wall had their wheels
. chocked, Three of- the four breakers on the floor in front of the panel
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had a single chock on the side away from the cubicle, The fourth breaker had no chocks, On August 18. 1997, a building o)erator had written PC 97-6020 stating that the yellow chock blocks )eing used
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- throughout the plant, including the 4160V ES switchgear rooms, were ineffective in preventing breakers from moving. Even though this
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observation was made-several: weeks prior to the inspectors _ examination, no corrective actions had been take Technical S)ecification 5.6.1.1. Procedures, requires that written
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procedures )e established and implemented covering the applicable arocedures recommended in Regulatory Guide 1.33, Revision 2. Appendix rebruary 1978.- This includes procedures for equipment contro Licensee procedure CP-115 -Nuclear Plant Tags and Tagging Orders,
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Revision 75, step 4.5.9.3 states that all breakers outside of a cubicle are to have their wheels chocked. The inspector's examination of the A 4160V ES switchgear room revealed that six breakers were removed from cubicles without their wheels being chocked and that three additional breakers were chocked in such a manner as to be unable to restrain motion of the breakers. This is identified as a failure to follow licensee Procedure CP-115. for storing breakers removed from cubicles, and will be tracked as VIO 50-302/97-13-03, Failure to follow procedure for controlling breakers removed from switchgear cubicles, Conclusions The reportability determination made on June 7. 1997, was not timely for an issue identified on April 21, 1997, and based on a report issued during December of 1996. The decision reached in the June 7. 1997, determination was not su] ported by the evidence available in the December 1996 report. Tlat information was not available until the clarification issued on September 4,1997, in response to questions by the inspecto Internal communications in both the maintenance and operations departments were weak, as demonstrated by the fact that the REA, including storage requirements for removed breakers, was transmitted to managers in both departments on June 4. 1997. but neither procedure writers nor department heads were aware of the existence of the REA when interviewed in September 1997.
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Procedures for controlling removed breakers were inadequate to address concerns with potential interactions between the breakers and cubicles during a postulated seismic event. Adequatt - rections did not exist to store circuit breakers removed from cubicles to prevent interactions during a seismic event as determined by the licensee during the evaluation from December 199 Examinations by the inspector revealed that the licensee failed to follow the procedure for controlling breakers removed from switchgear cubicle E3 Engineering Procedures and Documentation E3.1 FSAR Review Project
' Inspection Scone (37550)
The inspectors examined the licensee's Final Safety Analysis Report (FSAR) review project. The purpose of the licensee's FSAR review, which was accomplished during May 1996 through March 1997.
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was to ensure that the information contained in the Enhanced
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. Design Basis Document (EDBD) and implementing plant procedures was consistent with the descriptions in the FSA Observations and Findinos L
l The FSAR Review Project was accomplished using an Action Plan l
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29 which provided an outline with a description of the objective of-the review, the method of implementation, and the schedule for completion. The findings from the review were categorized as A through E. as defined in the Action Plan. Findings A. B. and E-were tracked as Nuclear Operations Tracking and Expediting System-(NOTES) items per the licensee's corrective action progra Category A findings, which totaled 49 findings, were editorial (typos, incorrect references, etc.). The 103 Category B findings, which were defined as clearly bounded by the FSAR. were also tracked as NOTES items. Category E findings were identified for potential deficiencies in documents other than the FSAR. These totaled 67 findings and involved documents such as the EDBD in which discrepancies were identified during the FSAR review. The 13S Category C findings, which were identified as those clearly bounded by the FSAR. were documented on Precursor Card Problem Reports were initiated for the nine category D findings, which were defined as issues not clearly bounded by the FSAR but which recuired Mditional review. The extent of the review completed uncer the Action Plan involved one individual for ten months, with assistance from two other individuals on a part time basi The inspectors reviewed approximately one-half of the 363 findings identified in the FSAR review. The inspectors noted that there were numerous duplicate findings. That is, often the same issue was identified more than once since it may have affected more than one plant procedure or document. The inspectors reviewed the licensee's corrective actions to resolve the findings and verified the FSAR review findings had been included in the licensee's corrective action program. The inspectors verified findings af fecting restart were so identified and corrective actions were appropriate. Corrective actions included revisions to plant operating procedures, editing the FSAR, and clarification of information in the EDBDs. The licensee determined that none of the findings from the FSAR review project were reportable, and none af fected operability of any safety related systems. The inspectors reviewed six of the more significant findings and verified that they were not reportable and did not af fect operabilit Conclusions The inspectors concluded that the licensee's FSAR review project performed under the Action Plan was limited in scope. The results of the review indicated that additional FSAR reviews may be
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required to assure the FSAR is accurate in all respects. The licensee's Restart Readiness Review and Configuration Document Integration Project should provide additional assurance that the FSAR accurately reflects the design, operation, and licensing basis of the plan .. - - _
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The inspectors assessed the licensee's performance, relative to the FSAR Review Project, in the five areas of continuing NRC concern:
e Management Oversight - Adequate e Engineering Effectiveness - Adequate e Knowledge of the Design Basis - Adequate o Com)liance with Regulations - Adequate e Operator performance - N/A E8 Hiscellaneous Engineering Issues E (Closed) EA 96-365.96-465. 96-527. VIO A (01012. 01022. and 01032): EDG Loadina US0s due to inadeauate 10 CFR 50.59 evaluations: three examDies (one modification and two orocedure chanaes)
LGlosed) LER 50-302/96-020. Unreviewed Safety Questions Concernina Diesel Generator loadina Caused by Internretation of Reaulatory Reauirements Other than Prescribed Inspection Scope (9290 These three violations and LER involved inadequate 10 CFR 50.59 evaluations for a modiftcation, an emergency operating procedure (EOP)
change, and an operating procedure (0P) change. Each of these changes increased EDG loading to beyond what was described in the FSAR or T The changes involved unreviewed safety questions or a required TS change and the licensee made the modification and procedure changes without obtaining the required prior NRC approval. The ins;ectors followed up on the licensee's corrective actions as stated in tie response to the NRC Notice of Violation and in the LE b. Observations and Findinas The inspectors reviewed the following procedures and training less7 plans:
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CP-213. Preparation of a Safety Assessment and Unreviewed Safety Question Determination (10 CFR 50.59 Safety Evaluation). Rev. dated June 3. 1997
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Nuclear Operations Engineering Standard OES-3. 10 CFR 50.59 SA/US00 Expectations. Rev. 2. dated July 11, 1997
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AI-300. Plant Review Committee Charter Rev. 40. dated March 2 AI-400C. New Procedures and Procedure Change Process. Rev. 1 dated March 31, 1997
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Al-400F, New Procedures and Procedure Change Process for E0P APs, and Supporting Documents, dated March 31, 1997
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.NEP 210. Modification Approval Records..Rev.16. dated March 31, 1997
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NEP 213. Design Analyses / Calculations, Rev. 10, dated March 31, 1997
- NEP-224. Emergency Diesel Generator Load Calculations. Rev. dated March 31, 1997
- NEP-261 Design Verification. Rev. 5. dated March 31, 1997
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Nuclear Operations Training Department Special Technical Trainin NUC ST-0067, 10 CFR 50.59 Safety Evaluation Training Safety Assessment and Unreviewed Safety Question Determination Training, Rev. 2 dated March 22, 1997
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Nuclear Operations Training Department Special Technical Trainin ST-1223. Introduction to the Technical Specifications and Final Safety Analysis Report, Rev. 0, dated March 7, 199 The inspectors noted that the licensee had committed to keep the plant shut down until the design issues identif6d in their October 28, 1996, letter to the NRC were satisfactorily resoi,'d. EDG loading was included in those design issues. The resolution of those design issues
)rior to plant restart was also included in an NRC Confirmatory Action
.etter of March 4, 199 The System Readiness Review Program was nearing completion and was tracked as licensee restart item D-23. An NRC Safety System Functional Inspection (SSFI) is scheduled to review that program's effectiveness prior to restar The licensee plans to update the Final Safety Analysis Report (FSAR). Enhanced Design Basis Document (EDBD), and Analysis Basis Document (ABD) prior to restart, to show EDG and EFW equipment dependencies and limitations and to include the swing B makeup pump as being a selected engineered safeguards (ES) load, and those plans are tracked by licensee restart item R-20. The licensee also
)lans to conduct training of operators, on the design basis and design
) asis accidents, by December 31. 1997, and those plans are tracked by licensee MCAP item C-ID-III-1. The EDGs are being uprated and the completion of the modifications. EDG loading calculations, and related licensing submittals prior to plant restart are tracked by licensee restart items D-06A and R-20. The NRC will review the EDG uprate design along with the related license amendment request. Also, completion of l EDG loading calculations is also tracked by open NRC restart item EA 96-365, V10 B (02013). Use of Unverified Calculations to Support Modifications. The emergency operating procedures (EOPs) are being revised )rior to plant restart and the completion of those changes is tracked )y licensee restart item OP-19D. An NRC inspection is scheduled to review the revised E0Ps prior to plant restar The inspectors verified that licensee management had conveyed expectations-for effective 10 CFR 50.59 evaluations to those individuals
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. ' involved in the process. This included an engineering stand-dow revised procedures.:and training. The-formation of the Safety Analysis Group (SAG) and the Design Review Boards, their effectiveness.'and the-improvement in quality of 50.59 evaluations were previously reviewed by the NRC and documented in NRC ins mction reports 50-302/97-06.-97-0 and 97-09. Inspectors verified tlat the SAG had completed a review of previous modifications to '.dentify any additional examples of inadequate 10 CFR 50.59 evaluations. Inspectors also verified that Plant Review Comittee expectations had been enh6nced. -In' addition inspectors verified that procedural changes had Laen made to better define the responsibilities of the design engineer, verification engineer. EDG Load
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Management Program, and verification of calculations. including case-studies. . In addition, inspectors verified that revised procedures included requirements for reviews of emergency operating procedures and operating procedures by engineers, Conclusions The inspectors concluded that most of-the licensee's corrective actions.-
had been implemented. Those remaining were in progress and were in a licensee tracking system. Also, the more significant outstanding corrective actions (System Readiness Review Program. EDG uprate, and E0P revisions) are scheduled for further NRC review. The licensee's-corrective actions included actions to prevent: recurrence of the violation, and represented effective improvements. EA 96-365.96-465, 96-527. VIO A (01012. 01022 and 01032) and LER 50 302/96-020 are close The inspectors ascessed the-licensee's performance, relative to corrective actions for this violation, in the five areas of continuing NRC concern:
e Management Oversight - Good e Engineering Ef1ectiveness Good e Knowledge of the Design Basis - Good
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e Compliance with Regulations - Good e Operator Performance - N/A E8.2 FClosed) EA 96-365.96-465. 96-527. V10 A (01042): EFW NPSH US0 due to nadeauate 10 CFR 50.59 Safety Evaluation for a Modification (Closed) LER 50-302/97-001: Ineffective Chance Manacement Results in Unrecoonized NPSH-Issue Aftectino EFW Availability a, Insoection'Scoce (92903)-
This violation and LER involved an inadequate 10 CFR 50.59 evaluation
- for a modification that increased the probability of failure of the turbine-driven EFW pump. -This change involved an unreviewed safety
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question and the licensee made the change without-obtaining the required prior NRC approval. The inspectors followed up on the licensee's corrective actions as stated in the response to the NRC Notice of Violation and in the LE b. Observations and Findinas In addition to the corrective actions discussed above, the inspector verified that the licensee had installed EFW flow limiting venturi The modification design.10 CFR 50.59 evaluation, installation, and initial testing had been inspected and documented in previous inspection reports. Completion of the modification prior to restart was tracked as licensee restart items 0-05 and 0-06A. In addition, the licensee was completing a failure modes and effects analysis of the LOCA LOOP and loss of DC power scenario, and was tracking completion of that as restart item D-8. Licensee completion of this failure modes and effects analysis was also scheduled for NRC inspection prior to restart. Also, the inspector verified that engineering staffing levels had been increased and that the licensee was working toward increasing system design margins through physical means (modification or testing) as opposed to analytical means, c. Conclusions The ins . ;s concluded that most of the licensee's corrective actions had been implemente Completion of the modification prior to restart was in a licensee tracking system. The licensee's corrective actions included actions to prevent recurrence of the violation, and represented effective improvements. EA 96-365.96-465. 96-527. VIO A (01042) and LER 50-302/97-001 are close The inspectors assessed the licensee's performance, relative to corrective actions for this violation. in the five areas of continuing NRC concern:
e Management Oversight - Good e Engineering Effectiveness - Good e Knowledge of the Design Basis - Good e Compliance with Regulations - Good e Operator Performance - N/A E8.3 (Closed) EA 96-365.96-465. 96-527. VIO A (01052): EFW US0 due to Removina the Automatic Open Sional from ASV-204. Reducina the Reliabi hty of EFP-2 a. Insoection Scope (92903)
This violation involved an inadequate 10 CFR 50.59 evaluation for a modification that increased the probability of failure of the turbine-l l
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driven EfW pum This change involved an unreviewed safety question and the licensee made the change without obtaining the required prior NRC approval. The inspectors followed up on the licensee's corrective actions as stated in the response to the NRC Notice of Violatio b. Observations and Findinas In addition to the corrective actions discussed above, the inspectors verified that the licensee was installing a modification to restore the automatic opening signal to ASV 204. The modification design and 10 CFR 50.59 evaluation had been inspected and documented in previous inspection reports. Completion of the modification prior to restart is tracked as licensee restart item 0-05 c. Conclusions The inspectors concluded that most of the licensee's corrective actions had been implemente Completion of the modification prior to restart was in a licensee tracking system. The licensee's corrective actions included actions to prevent recurrence of the violation, and represented effective improvement EA 96-365.96-465, 96 527. V10 A (01052) is close The inspectors assessed the licensee's performance, relative to corrective actions for this violation, in the five areas of continuing NRC concern:
e Management Oversight - Good e Engineering Effectiveness - Good e Knowledge of the Design Basis - Good e Compliance with Regulations Good e Operator Performance - N/A E8.4 LQgen) Unresolved item 50-302/97-07-03: Reactor Buildina Liner Plate Dearadation (92903)
During the inspection documented in NRC Inspection Report 50-302/97-07. NRC 1dentified the containment liner plate at the junction of the liner plate and elevation 95 concrete floor appeared to be corrode The extent of the corrosion was indeterminate since the liner plate had already been recoate The licensee initiated a precursor card to document and disposition this issue. The licensee's corrective actions included removal of the coatings and any corrosion areas from the liner plate for a height of approximately ten inches above the concrete floor slab and imalemented a nondestructive testing program to determine the t11ckness of the liner plate and depth of corrosion. The measured liner plate thickness was compared to the calculated minimum plate thickness value of 0.312 inches determined by licensee engineers. The inspectors reviewed the results of the ultrasonic testing (UT) which was performed to determine the actual thickness of the liner plate. The UT
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measurements were taken in areas not affected by corrosion to :
Jobtain.the most accurate data on plate thickness. The irregula corroded = surfaces would have affected the accuracy of the UT dat ,
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- These measurements showed that the installed liner plate had an-average thickness of approximately 0.390 inches, which exceeded the specified value of 0.376 inches. The inspectors also reviewed ';
the results of visual examinations of the liner plat '
The areas inspected extended below the concrete slab since the licensee removed gasket materials and a portion of the one inch thick cork bond breaker placed between the concrete and liner plate below the
-top of the concrete floor. During the visual inspections the licensee measured the depth of the' corrosion and subtracted this amot.nt from-the plate thickness measured using UT. One area was measured which had a depth of corrosion of 0.065 inches.-in an area where the measured UT alate thickness was:0.372 inches. The actual' remaining plate thic(ness in the corroded area was 0.307 inches after the corrosion depth was deducted. This was less than the minimum plate thickness (0.312 inches) specified by licensee engineer The corrosion was classified as. pitting, with the deepest corroded area (0.065 inches) identified by the licensee to ,
be a single pit. The licensee was in the process of-performing an engineering evaluation to-determine if additional repairs, that is, weld repairs were required. Pending further review of the licensee's corrective actions by NRC this URI will remain open,
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' E8.5 (Ocen) VIO 50 302/96-01-06. Failure to Correctly Translate Desian Basis j of Service Water System into Procedures Drawinas. and Instructions (Restart Issue No. D-54) (92903)
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(Ocen) LER 50-302/96-005-01. Inadeouate Failure Modes Review Creates Possibility of Coolina Water Flow Outside of Desian Limits (929031 This item concerned the licensee's identification of an unanalyzed failure in the Nuclear Services Closed Cycle Cooling Water (SW) syste The SW system is flow balanced for only-two Reactor Building Cooling
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Units (RBCU) to be in operation. During certain accident condition .
- where a third RBCU was placed in operation. SW total flow would increase and individual flows would decrease. This would cause an increase _ load on the Emergency Diesel Generator (EDG) above its approved load limit and would also
- result in lower than recuired flows to individual components. The cause was an error mace by Engineering personnel during the preparation of a design change for the RBCUs which did not consider all failure modes.
. The licensee's immediate corrective actions were to declare the SW system inoperable until'one of the RBCUs _was isolated by closing manual valves in the SW system and to notify the NRC via 10 CFR 50.7 The inspector reviewed 'he licensee's closure documentation and interviewed Operation and Engineering personnel. The short term corrective ~ actions to prevent exceeding EDG loading and ensure adequate SW flow were: 1) the C RBCU has been red-tagged out-of-service with a
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Shift Supervisor's tag out: 2) Operations Procedure OP-417. Containment Operating Procedure, fievision 72, has a statement to preclude the use of C RBCl, cs an ES selected fan: 3) an Engineering review and identification of any other similar scenarios in the SW system; and 4)
complete the revision to the Design Data Sheet to provide additional instructions for the determination of failure effects. The inspector concluded that the licensee's evaluation and short term corrective actions were adequate. Consequently, this item is acceptable for restart and can be closed on the NRC restart restraint lis However, during the interviews, the inspector identified the existence of a pending modification. MAR 97-07-0101. The MAR will incorporate an interlock to prevent loading two RBCUs on one EDG and exceeding its loading limits. This modification will need to be reviewed as a long term corrective action and is scheduled for completion in 199 Consequently, these items will remain open pending completion of the MA The inspector assessed the licensee's performance, with respect to this restart-related issue, in the five NRC continuing areas of concern:
e Management Oversight - N/A e Engineering Effectiveness - Adequate e Knowledge of Design Basis - Adequate o Compliance with Regulations - N/A e Operator Performance - Adequate IL Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls Rl.1 Control of Bynroduct Materials Inspection Stone (8375Q1 The Inspectors reviewed a licensee identified problem concerning the discovery of tools having measurable byproduct contamination outside the licensee's primary Radiological Control Area (RCA). Observations and Findinas During the extended outage the emergency diesel generators were outside the licensee's RCA. On August 21, 1997, maintenance personnel working in the diesel generator area reported the discovery of a bag marked " hot side" to the Health Physics (HP) staff. Health Physics Technicians (HPIs) dispatched to the work area found a climbing harness in the bag having fixed radioactive contamination of approximately 500 counts per minute (cpm) when measured with a thin window Geiger Muller detecto The activity was egyivalent to approximately 25.000 disintegrations per minute (dpm)/100 cn The harness was returned to the RCA and HPIs performed radiation surveys on other tools and equipment located in the diesel generator work area. No additional contaminated items were
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identified. A precursor card, number 97-6132, was initiated to document .
the problem for corrective action On August 27. 1997, personnel working in the diesel generator area reported the discovery of a hammer having faded radioactive material tape on the handle. A HPT was dispatched to the work area to retrieve the hammer. A survey of the harmier identified fixed radioactive 2 contamination at a concentration of approximately 5.000 dpm/100 cm .
Again HPTs conducted additional radiation surveys in the area. The technicians found a carpenter's speed wrench marked " caution radioactive material" in a tool box in the are Three other tools in the diesel generator area were found tiaving contamination at concentrations between 5.000 to 50,000 dpm/100 cm'. Precursor card number 97-6206 was initiated to document the problem. In response to the findings, meetings with maintenance personnel working in the diesel generator area were held on August 27. 1997, to address the radiological control requirements-for tools exiting the RC The HP staff began surveying other tool storage areas outside the RC Surveys were made in the Fabrication Shop Cold Machine Shop, and Maintenance Support Building. The licensee estimated approximately 4.000 to 5.000 tools were surveyed by the staff on August 27 and 28, 1997. On August 27, 1997, a tubing tool was found in a Cold Machine r Shop tool box having contamination of approximately 8.000 dpm/100 cm ,
Four contaminated topls having radioactive contamination between 12,000 to 50.000 dpm/100 cnr were found in the Cold Machine Shop Tool Room on August 28, 199 The inspectors reviewed Radiation Safety Procedura (P.SP) 101. Basic Radiological Safety Information and Instructions for Radiation Workers, revision dated July 9, 1997. Paragraph 3.1.17.2 of the procedure required HP personnel perform a radiation survey of equipment being unconditionally released from the RC HP personnel were required to verify no radioactivity was present and all radioactive material indicators, stickers, and tags were removed or deface Title 10 CFR Part 20.1801 required the licensee to secure from unauthorized rerr Mal or access licensed materials that are stored in controlled or unrestricted area Title 10 CFR Part 20.1501(a), required in part, that each licensee make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations and are reasonable under the circumstances to evaluate the extent of concentrations or quantities of radioactive material and the potential radiological hazards that could be presen The regulations applicable to nuclear power reactor licensees do not
)rovide for release of materials for unrestricted use that are known to 3e contaminated at any level. The licensee's failure to control
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licensed byproduct contaminated materials and make adequate radiation surveys to detect fixed byproduct contamination was identified as a violation of Title 10 CFR 3 art 20.1801. 20.1501, and licensee procedure
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requirement However, the licensee identified the violation and had taken corrective measures to prevent recurrence. Consistent with-Section Vll.B.1 of the NRC Enforcement Policy, this licensee identified and corrected violation was treated as a Non-Cited Violation, NCV 50-302/97 13 04. Failure To Control Licensed Byproduct Materials and Make Adequate Contamination Surveys of Contaminated Tools Released from tt7 Licensee's RC c. Conclusions A NCV of regulatory requirements and the licensee's contamination control procedures was identified for. failure to control contaminated tool RI.2 Radiation Controls a. Insoection Scoce (83750)
Radiation Protection (RP) control activities were observed to verify that the activities were performed in accordance with the facility procedures and regulatory requirements, b. Observations and Findinos The inspectr's observed the following within the licensee's RCAs:
housekeeping radiological postings and labeling, work activities within radiation, high radiation and contaminated areas, and the condition of radiation monitoring equipment. The inspectors also observed interactions of various plant staff with HPTs concerning appropriate RP measures prior to performing tasks in the RCAs. The inspectors made inde)endent radiation surveys in the licensee's Auxiliary. Intermediate, and teactor Buildings, and surveyed RCA boundaries and facilities outside the RC Radiological housekeepir.g within the Auxiliary Building was good. All areas surveyed by the inspectors were properly posted and consisten No unlabeled containers of radioactive materials were identified. All radiation monitoring equipment found in the RCA was operational and calibrate c. Conclusions The inspector concluded that the licensee was implementing good RP controls in accordance with licensee procedures and regulatory requirements. Good interactions between the HP staff and radiation workers _were observed in the inspectio R1.3 Hioh Radiation Door Controls
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a. Insoection Scoce (83750)
The inspectors reviewed the events concerning the licensee's d:scovery of an unlncked high radiation area on May 22, 199 . .. . - . - - .. . . _ ~
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39 b. Observations and Findinas Licensee Technical Specification (TS) 5.8.2 required high radiation areas with radiation levels = 1 rem /hr at 30 cm from the source be provided with locked or continuously guarded doors to prevent unauthorized entry. The keys for those high radiation areas were required to be maintained under the administrative control of the Shift Supervisor on duty or health physics su>ervision. Doors were to remain locked except during perio ' of access ay authorized personne On May 22. 1997. Instrumentation and Control (I&C) personnel checked out a high radiation key for the Make-Up Prefilter Room. The work area was a high radiation area controlled by a locked gate. While in the room the workers were distracted and caused to depart the area. The I&C technicians failed to lock the Make-Up Prefilter room gate when they left the room. Approximately 30 minutes later a HPT touring the area found the gate to the room open with the key still in the lock. The HPT secured the area and the licensee began an investigation into the even At the time the event occurred the HP staff was controlling the area as a locked high radiation are The licensee did a good job of investigating the event and produced Root Cause Report 97-3530. Make-up Prefilter Locked High Radiation Door left Unattended. The licensee documented the event as a violation of TS 5.8.2. 10 CFR 20.1601, and RSP-101. Corrective actions included:
Staff review of radiation workers res)onsibilities (RSP-101):
Placing a " Responsibilities For High Radiation Area Key Sign-Out" document in the high radiation key log for workers to review when t ecking out a high radiation key; and Pro)osed gate modification to install a audible alarm that would sound w1en the gates were ope The inspectors initially believed the May 22 event was a violation of licensee TS 5.8.2. However, upon review of a licensee radiation survey for the area made May 22, 1997, the inspectors concluded the licensee was not in violation of TS 5.8.2. The radiation levels at 30 centimeters from the radiation sources in the area were not in excess of be 1.000 mrem /hr dose rate criteria specified in the licensee's T While the inspectors concluded no violations of TS 5.8.2 had occurred, the inspectors found the licensee had intended the I&C personnel maintain positive control of the Make-up Prefilter Room at the time the key was issued. Step 4.4.3 of licensee Procedure RSP-101. Basic Radiological Safety Information and Instructions for Radiation Workers, required radiation workers ensure all gates, doors, and other access control mechanisms were secured when access to a high radiation area was left unattended.- Failure to secure the Make-up Prefilter Room was a violation of the licensee's RSPs. However, the licensee identified the violation and had taken corrective measures to prevent recurrenc Consistent with Section VII.B.1 of the NRC Enforcement Policy this licensee identified and corrected violation was treated as a NCV NCV 50 302/97-13-05. F'ilure To Secure Unattended High Radiation Area Door.
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40 Conclusions A NCV of the licensee's radiation safety procedure requirements was identified for failure to secure access to a high radiation are Rl.4 Efiident Release Insnection Scone (84750)
The sampling and analysis of a continuous gaseous radioactive waste release for the Auxiliary Building Exhaust was observed to verify applicable licensee procedures for radioactive gaseous effluents were properly utilize Observations,and Findinas The inspectors reviewed applicable licensee procedures for the preparation of a gaseous effluent release. The inspectors observed the sampling and analysis of the Auxiliary Building exhaust and reviewed the gaseous release permit. The results of the analysis were all below measurable concentrations as the unit had been shutdown for approximately 12 months. The analysis results were documented in accordance with licensee procedure Licensee personnel reported that there was a procedure problem with the Reactor Building (RB) purges. There was some confusion'on whether operators were recording the correct start time of all RB purge Precursor Card 97-6145 was initiated to cause proper review of applicable procedures. The problem concerned the following procedures:
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OP-417. Containment Operating Procedure, revision dated August 25, 1997: and
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SP-335C. Radiation Monitoring Instrumentation Functional Test of RM A1. A2. A6. All, and A12; revision dated April 11. 199 According to licensee persontel, when a functional test of the monitoring system was performed prior to the beginning of the release, the time of the functional test may not be recognized as the start time of the release. If the release start time incorrectly excluded the time of the preceding functional test approximately 40 minutes of release time may not be included in the release calculations. The unaccounted for volume during that period could be greater than one million cubic feet. The licensee had only initiated a review of the concern and the extent of the problem was unknown. A review of the gaseous effluert release volume will be made in a future NRC inspection. The item is tracked as an Inspector Follow-up Item (IFI) 50-302/97-13-06. Review Accuracy of Gaseous Effluent Release Start Times and Volumes.
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c. Conclusions The sampling and analysis processes for the reviewed gaseous effluent release were adequate. The technician performing the work was very knowledgeable of the procedure processes. The applicable procedures provided sufficient detail to aerform the, work and the procedures were properly utilized throughout tie sampling and analysis proces A potential problem with determining Reactor Building (RB) gaseous effluent release start times and volumes was identified by the licensee and will be reviewed by the NRC in a future inspection as IFI 50-302/97-13-0 R3 RP&C Procedures and Documentation R3.1. Annual Radioloaical Effluent Release ReDort a. Insoection Scone (84750)
The Annual Radiological Effluent Release Resort for 1996 was reviewed to identify any adverse trends and to verify tlat the requirements of TS were me b. Observations and Findinas Licensee TS 5.7.1.1.c required the licer.see submit an annual Radiological Effluent Report covering the operation of the unit in accordance with 10 CFR Part 50.36a. The TS also required the material arovided be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM) and Process Control Program and in conformance with 10 CFR 50.36a and Appendix I. Section IV. The release of radioactive material to the environment from Crystal River for 1996 was a small fraction of the 10 CFR Part 20. Appendix B and 10 CFR Part 50. Appendix I limit The inspectors compared the reported measurements in the 1996 report with those of previous years and did not identify any adverse trends. The licensee appeared to be effectively managing radiological effluents to maintain offsite doses as low as reasonably achievable, c. Conclusions The 1996 Effluent. Report was complete and met TS requirements The radiological effluents were well within the limits specified in the ODC . . - - - . .- -_ - . . . - - - - - -
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LR3;2. Annual Radioloaical Environmental Ooeratina Reoort .
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The Annual Radiological-Environmental Operating Report for 1996 was
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reviewed to identify any adverse trends and to. verify.that the requirements of TS were me Observations and Findinas Licensee TS 5.7,1,1.b required the licensee submit an Annual -.
Radiological Environmental Operating Report summarizing and tabulating-the results of all radiological environmental samples and environmental *
radiation measurements taken during the perio =
Sampling of the facility environs was performed by the State of Flortoa Department of Health.-. Bureau of Radiation Control. -The State of Florida also performed the required analyses. -participated in the Environmental Protection Agency's Interlaboratory Comparison Program and performed the '
annual Land-use Censu The inspectors compared the reported radiation measurements in the-1996-report with those of previous years. There were increases in the
' radioactivity observed in sediment and oyster samples. -The increases-were attributed to an increase in radioactive liquid eJf t. ants released during 1996.. The liquid affluent increased from 0.2 cm.s in 1995 to 0.5 curies in 1996. The licensee attributed the liquid effluent increases to the two shutdowns in 1996 versus none in 1995.
, Conclusions The 1996 Annual Environmental Monitoring Report met TS requirement The report indicated that plant operations in 1996 had not resulted in any significant impact on the environmen R5 Staff Training-and Qualification in RP&C R5.1 Radiation Worker Trainina and Qualification in RP Insoection Scoce (83750)
The inspectors reviewed elements of t.he licensee's RP General Employee c Training'(GET).
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.b Observation's and Findinas-Title 10 CFR Part 19.12 required the licensee provide radiation- j protection. instructions to radiation worker The licensee was:one of the first to utilize the computer as an instructor of GET and had utilized com3 uter based training for several years. In addition to completing the RP training on t.u computer, the L
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licensee developed practical factors to supplement the trainin Students were required to demonstrate knowledge and precautions associated with various radiation protection controls. The practical factors included reviews of radiation worker precautions, responsibilities, and tours within the licensee's RCA with qualified HP personnel. The tours provided the students the opportunity to see and utilize radiation protection equipment, radiological posting and
' labeling, radiation work permits, and radiation surveys in the RC Students were encouraged to ask questions throughout the training, Conclusions The inspectors found the practical factor training an excellent training component with the licensee's computer based training progra R6 RP&C Organization and Adr.inistration R6,1 Oraanization Chanaes Insoection Scone (83750)
The inspectors reviewed changes in the RP Organization since the last radiation protection inspection in 199 Observation Land Findinos Licensee TS 5.3.1 required, in part, each member of the unit staff meet or exceed the minimum qualifications of ANSI N18.1.1971 for comparable positions, except for the Radiation Protection Manager (RPM), who shall meet or exceed the qualifications of Regulatory Guide 1.8 September 197 The designated RPM is responsible for providing aroper program oversight and technical direction. The previous RPM, the ianager of RP, vacated the position in 1996. The position was temporarily filled by a RP Supervisor during that period and a new Manager of RP was appointed in November 1996. The inspector reviewed the qualifications of the new Manager of RP and found the individual qualified for the RPM positio The licensee had also changed the reporting and organization structure of the RP&C organization in April 1997. Prior to the changes the Nuclear Chemistry Department resorted to the 03erations Department and the RP Department reported to tle Maintenance Jepartment. In the revised organization the Managers of Nuclear Chemistry and RP departments report to the Manager of Nuclear Chemistry and RP, a new Josition. The Manager of Chemistry and RP reported to the Director of luclear Plant Operations. The new Manager of Chemistry and RP was the former RP . .. - - - - - - _ -
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44 Conclusions The inspectors concluded the Manager of RP met the TS qualification requirements for the RP P1 Conduct of EP Activities Pl.1 [.meroency Drill Observations a, jnspectionTcone(71750)
On September 3, 199 inspectors observed the licensee's annual emergency preparedness drill, from both the technical support center (TSC) and the simulator control room. On Se inspector attended a critique of the drill. ptember 5, 1997, an Observations and findinas The 1' pector observed in drill activities in the simulator control room. The u mulator operating crew used good command and control and were always aware of plant conditions because of frequent crew update Throughout the drill, a few communication related issues surfaced. One issue was in obtaining sufficient persorinel from o)erations (non-licensed operators) to )articipate in the drill. ) rill controllers reported an exercise velicle accident prematurely. Another issue was with information reported by the state regarding steam generator tube leak rates. Leak rates of greater than 200 gallons per minute were still being reported by the state after the leak rates had decreased when the reactor coolant system was depressurize Lastly, it took .
approximately half an hour before the simulator control room received word it a fire nad been extinguishe The i ector observed the emergency preparedness drill in the TSC. The licens. 's responsa was in compliance with procedure: however. It was observed that the briefings held by the emergency coordinator (EC) did not occur on a regular basis, but when the need was determined by the EC. At times, this appeared to interfere with the personnel maintaining awareness of plant status, for example, it was noted that approximately 20 minutes following the simulated evacuation of the auxiliary building, the security representative in the TSC was unaware that the evacuation had been initiated and had not taken action to assure that the building had been evacuated, Following notification, security was able to assure timely completion of the simulated evacuatio c. Conclusions
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The fundamental objectives of the drill were met and therefore the ins)ectors consider the drill to be a success. Some minor communication proalems occurred, but nothing that was considered to detract from the drill's intent and purpos . . - _ ___
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S1 Conduct of Security and Safeguards Activities j 51.1 f[gview of Lost Security Badae Incidents (71750) ;
As part of the licensee's implementation of their licensee exemption on ,
July 24 to allow security badges to W taken offsite, the inspectors !
reviewed the results of the licensee's efforts to correct a problem with {
individuals losing their badges while in the )rotected area. The i
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, ins)ectors observed that licensee management lad made correcting this pro)lem a significant priority starting in May of -1997. One step taken was to purchase and strongly encourage the use of nylon lanyards to affix and retain an individual's badge. Anotner step was the !
involvement of an individual's supervisor following each occurrence and l the develo) ment of a consistent and progressive discipline proces ;
Although t1ese initiatives did not achieve significant results through i
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June, the inspector observed that only six lost badge events were reported in July and none in August as of the 25th, nese were ,
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significant reductions and indicated "to licensee's efforts w'.re successfu In response to several problems with contractor peraonnel losing their f badges in June, the licensee strongly encouraged contractors to also develop a policy-to address individual accoun'abiliry to minimize the number of lost badges. The licensee did not specify any particular type of policy for the contractor to develop. One contractw adopted a t policy on June 13 that any last badge would result in site terminatio In response to concerns about the negative effect this policy would have on an individual being reluctant to report a lost badge to Security and '
looking for it instead the inspector verified the contractor revi:ed l the policy on July 14 to require a case by case review of each lost !
badge incident, The inspector reviewed each of the six lost badge occurrence reports for July and verified that in four of the occurrences the individual notified security about the missing badge and in the other two the individual was unaware that his badge was missing. One of ,
these latter two examples involved a contractor employee after the new policy was implemented July 14. The corrective action taken was appropriate considering the extenuating circumstances involved with the loss.- The inspector concluded that individuals were not reluctant to report missing badges to allow security-to remove their access ability i until they could be located. The inspector did not identify any concerns with the licensee's actions and concluded they were successful ;
ct significantly reducing lost badge incident V.Manaaement Meetinas
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X1 Exit Meeting Summary z The inspection scope and findings were summarized on September 22. 199 Proprietary information is not contained in this report. Dissenting-comments were not received from the license ;
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PARTIAL LIST OF PERSONS CONTACTED Licenste R. Anderson. Senior Vice President. Nuclear Operatic.1s J. Baumstark. Director Quality Programs J. Cowan, Vice President. Nuclear Production R. Davis, Assistant Plant Director Operatior,s and Chemistry R. Grazio. Director, Nuclear Regulatory Affairs G. Halnon, Assistant Plant Director Nuclear Safety B. Hickle. Director, Restart J. Holden Site Director D. Kunsemiller. Manager. Nuclear Licensing M. Marano. Director, Nuclear Site & Business Support C, Pardee. Director. Nuclear Plant Operations W. Pite, Manager. Nuclear Regulatory Compliance M. Rencheck, Director, Nuclear Engineering and Projects M. Schiavoni. Assistant Plant Director. Maintenance T. Taylor. Director. Nuclear Operations Training NBC D. Billings. Resident inspector, Oconee (September 9 through 11. 1997)
J. Jaudon. Director, Division of Reactor Safety, Region 11 (August 20 through 21. 1997)
W. Holland, Reactor Inspector, Region 11 (September 8 through 10. 1997)
K. Landis, Branch Chief, Region II (August 20 through 21, 199')
M. Miller. Reactor Inspector, Region 11 (September 15 through 19. 1997)
S Ninh, Project Engineer. Region il (August 20 through 21. 1997)
L. Raghaven, Project Manager. NRR (August 20 through 21. 1997)
T. Ross Senior Resident inspector, Farley (August 19 through 22. 1997)
R, Schin. Reactor Inspector, Region 11 (August 20 through 21, September 15 through 19, 1997)
M. Thomas. Reactor Inspector. Region 11 (September 15 through 19, 1997)
INSPECTION PROCEDURES USED IP 37550: Engineering IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Ob wrvations IP 62707: Conduct of Maintenance IP 71707: Plant Operations IP 71750: Plant Support Activities IP B3750: Occupational Radiation Exposure IP 84750: Radioactive Wasu 'atment and Effluent and Environmental Monitoring IP 92901: Follow up - Operations IP 92902: Follow up - Maintenance IP 92903: Follow up - Engineering i
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ITEMS OPENED, CLOSED, AND DISCUSSED OpfDtd Tvoe / Item Number Status D.escriotionandReference i
V10 50 302/97-13 02 Open Failure to perform a safety evaluation prior to erecting scaffolding in the vicinity of safety related equipment. (Section '
M2.1)
VIO 50 302/97-13 03 Open Failure to follow procedure for controlling breakers removed from switchgear cubicles, (Section E2.1)
IFl 50 302/97-13 06 Open Review Accuracy of Gaseous Effluent Release Start Times and Volume (Section R1.4)
Closed lyne/ItemNumber Status Descriotion and Re h nr3 NCV 50-302/97 13-01 Closed improper Clearance Restoration Causes RCS Leak. (Section 01.4)
VIO 50 302/94-25-01 Closed failure to Properly Control the Control Complex Habitability Envelope (Door Blocked Open for Maintenance Work). (Section 08.1)
LER 50 302/94-009 02 Closed Unauthorized Tests involving Makeup Tank Level and Pressure. (Section 08.2)
V10 50-302/96-01 01 Closed Inadequate Corrective Action to Fix HPI Flow Indiution Problem (Section 08.3)
V10 50-302/97 01 01 Closed inadequate Clearance Tagging Requirements. (Section 08.4)
VIO 50-302/97 01-02 Closed Failure To follow Procedures, Resulting In An inadvertent Emergency Diesel Generator Star (Section 08.5)
LER 50-302/96 018-00 Closed Failure to Verify Reactor Building Penetrations Closed per Technical Specifications. (Section M8.1)
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48 LER 50 302/96 018 01 Closed failure to Verify Reactor Suilding i Penetrations Closed per Technical Specifications. (Section M8.1)
VIO EA 96 365. 96 465. Closed Three inadequate Procedures !
96 527, V10 B (02013) for Containment Penetration Surve111ances. (Section H8.1)
V10 EA 96 365. 96 46 Closed ED3 Loading US0s due to inadequate 96 527. V10 A(0101 CFR 50.59 evaluations: three 01022 and 01032) examples (one modification and two !
procedure changes). (Section E8.1) .
LER 50 302/96 020 Closed Unreviewed Safety Questions Concerning Diesel Generator Loadin Caused by Interpretation of Regulatory Requirements Other than Prescribed. .(section E8.1)
V10 EA 96 365. 96 46 Closed EFW NPSH 050 due to inadequate 96 527. VIO A 01042) 10 CFR 50.59 Safety Evaluation for A Modification. (Section E8.2) !
LER 50-302/97 001 Closed ineffective Change Management Results in Unrecognized NPSH Issue Affecting EFW Availabilit (section E8.2) :
VIO EA 96-365. 96 465. Closed EFW USQ due to Removino the 96 527. VIO A (01052) Automatic Open Signal from ASV 204 Reducing the Reliability of EFP- (section E8.3)
NCV 50 302/97 13-04 Closed failure To Control Licensed 8yproduct Materials and Make Adequate Contamination Surveys of Contaminated Tools Released from the Licensee's RCA. (Section R1.1)
NCV 50-302/97-13 05 Closed failure To Secure Unattended High Radiation Area Door, (Section R1.3)
Discussed Tvoe / Item Number Status Descriotion and Reference IFl 50 302/97 11-04 Open Corrective Actions for Approximately 4000 Precursor Cards not Tracked to Completion. (Section 07,1)
URI 50 302/95 02 02 Open Control Room Habitability Envelope Leakage. (Section 08.1)
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V10 EA 96 365.96 46 Open use of Unverified Calculations to l 96 527. VIO B (02013) Support Modif ications. (Section E8.1)
URI 50 302/97-07 03 Open Reactor Building Liner Plate ,
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Degradation. (Section E8.4)
VIO 50 302/96 01 06 Open Failure to Correctly Translate Design Basis of Service Water System into Procedures. Drawings, aid t
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Instructions. (Section E8.5)
LER 50-302/96-005 01 Open inadequate Failure Modes Review Creates Possibility of Cooling Water Flow Outside of Design Limit (Section E8,5)
LIST OF ACRONYMS USED ABD Analysis Basis Document Al - Administrative Instruction AP - Abnormal Procedures .
AR - Air Removal BAST Boric Acid Storage Tank CNIB Corrective Action Review Board CCHE - Control Complex Habitability Envelope CFR - Code of Federal Regulations CFT - Core Flood Tank CPM - Counts Per Minute CREVS - Control Room Emergency Ventilation System CR3 Crystal River Unit 3 CT - Current Transformers DBD - Design Basis Document DH - Decay Heat DHP - Decay Heat Pump .
DHV - Decay Heat Valve DNPO - Director. Nuclear Plant Operations DPM - Disintegration Per Minute EA Enforcement Action ECCS Emergency Core Cooling System EDBD - Enhanced Design Basis Document EDG - Emergency Diesel Generator eel - Escalation Enforcement item EFIC - Emergency Feedwater Initiation and Control EFW - Emergency Feedwater
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E0P - Emergency Operating Procedure ES Engineered Safeguards ESOPM - Environmental and Seismic Qualification Program Manual FLA - Full Load Am)eres FLUR First Level Jndervoltage Relays FME Foreign Material Exclusion FPC - Florida Power Corporation
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FSAR - Final Safety Analysis Report FSP - fire Service Pump FTI Framatome Technologies. In GET - General Employee Training GL - Generic Letter HP - Health Physics HPI - High Pressure injection HPT - Health Physics Technician HVAC - Heating Ventilation and Air Conditioning 1&C - Instrumentation and Controls IFl - Inspector follow-up Item INP0 - Institute of Nuclear Power Operations IPAP - Integrated Performance Assessment Process IR - Inspection Report ISA - Instrumer.t Society of America 151 - Inservice Inspection Kw Kilowatts LER - Licensee Event Report LOCA - Loss of Coolant Accident LOOP - Loss of Offsite Power LPI - Low Pressure injection MAR - Modification Approval Record MCAP - Management Corrective Action Plan MREM - Milli Roentgen Equivalent Man MSLB Main Steamline Break MUT - Make-up lank MUV - Make up Volve NCV Non cited Violation NEP - Nuclear Engineering Procedure NGRC - Nuclear General Review Committee NOTES Nuclear Operations Tracking and Expediting System NOV - Notice of Violation NPSH - Net Positive Suction Head NP&SM - Nuclear Procurement and Storage Manual N0A Nuclear Quality Assessments NRC - Nuclear Regulatory Commission NRR - Office of Nuclear Reactor Regulation OCR - Operability Concerns Resolution
.00CM Off site Dose Calculation Manual 01 - Operating Instruction 0]T On The Job Training OP - Operating Procedure PC - Precursor Card PM - Preventi"e Maintenance PMRG - Plant Modification Review Group PMT Post Maintenance Test PORV - Power Operated Relief Valve PPO - Primary Plant Operator
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PR - Problem Report PRC - Plant Review Committee PT - Liquid Penetrant Test 0A - Quality Assurance-
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RB - Reactor Building RCA - Radiologically Controlled Area RCBT - Reactor Coolant Bleed Tanks RCP - Reactor Coolant Pump RCS Reactor Coolant System REA- Request for Engineering Assistance RG - Regulatory Guide l
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RM Radiation Monitor RP Radiation Protection RPM Radiation Protection Manager RP&C Radiological Protection and Chemistry RSP - Radiation Safety Procedure SALP - Systematic Assessment of Licensee Performance SBLOCA Small Break Loss of Coolant Accident SEL - Securit Event Log SIR Securit Information Reports SLUR Second evel Undervoltage Relays-SM - Shift Manager SP - Surveillance Procedure SOUG Seismic Quality Upgrade Group SR - Surveillance Requirement SR0 - Senior Reactor Operator i SSC System. Structure or Component SSFI Safety System functional Inspection i SS00 - Shift Supervisor on Duty TC - Temporary Change TDB0 - Topical Design Basis Document TS - Technical Specification URI - Unresolved Item l US0 - Unreviewed Safety Question VIO - Violatica WI - Work Irstructions WR - Work R' quest WS! - Welding Services. In t i
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