IR 05000313/1990024

Insp Repts 50-313/90-24 & 50-368/90-24 on 900910-21.One Apparent Violation Identified.Major Areas Inspected: Operational Safety Team Insp,Operations,Maint,Technical Support Mgt Oversight,Safety Review & Corrective Action

ML20058J908
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/20/1990
From:	Cummins J, Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058J899	List: IR 05000313/1990024 ML20058J895 ML20058J903
References
50-313-90-24, 50-368-90-24, NUDOCS 9012060082
Download: ML20058J908 (39)

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o APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/90-24 Operating Licenses: DPR-51 50-368/90-24 ilPF-6-Dockets: 50-313 4 50-368 Licensee: Entergy Operations, In P.O. Box 551 Little Rock, Arkansas 72203 Facility llame: Arkansas Nuclear One (AN0), Units 1 and 2 Inspection At: Al10 Site, Russellville, Arkansas Inspection Condu ed:pSeptember 10-21, 1990 Team Leader:

J. E. Opt)snins, Reactor Inspector, Operational Date i ProgrWns Section, Division of Reactor Safety Inspectors: J. E. Bess, Reactor Inspector, Operational Programs Section Division of Reactor Safety H. F. Bundy, Reactor Inspector, Test Programs Section Division of Reactor. Safety F. T. Daniels,_ Team Leader, Division of Reactor Inspections ,

and Safeguards, Office of fluclear Reactor Regulation P. H. Harrell,. Project Engineer, Project Section A'

Division of Reactor Projects D. R. Hunter, Senior Reactor. Inspector, Operational Programs Section, Division of' Reactor Safety ,

D. A. Beckman, Consultant

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H. C. Brinkman, Consultant 0 B. Waters, Consultant l ,

/ / 'N 20 po Approved: ))(f p. E.J/iagliardo, Chief, Operational Programs j/

Date

\ Section, Division of Reactor Safety 9012060082 901127 PDR ADOCK 05000313 O PNU

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- Inspection Summary  !

Inspection Conducted September 10-21, 1990 (Report 50-313/90-24;-50-368/90-24)

Areas Inspected: Nonroutine, announced, operational safety team inspection (OSTI)whichincludedinspectionsintheareas-ofoperations,  !

maintenance, technical support, management oversight, safety review, and corrective. actio ,

Results: The team concluded that ANO was generally staffed by competent, knowledgeable personnel who executed their duties in a professional manner and I operated and maintained the units safely. The licensee had implemented or.was '

in the process of implementing a number of changes in management positions, organizational structure, and programs that appeared to be enhancements to the safe and effective operation and maintenance of the AN0 unit One apparent violation was identified, which involved the fact that a procedure had not been maintained current and contained out-of-date i informatio Two unresolved items were identified:

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Testing of control room heating, ventilation, and air conditioning system was not adequate to ensure.the dampers actually closed as require :(Section2.1.6)

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An engineering evaluation had not been performed.to verify that temporary patches, consisting of tape and hose clamps, had not compromised the ,

integrity and capability of the Unit 1 control room heating, venting, air '

conditioning (liVAC) system to function. (Section2.1.6)

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SUMMARY ARKNiSAS HUCLEAR ONE l OPERATIONAL SAFETY TEAM INSPECTION I

From September 10-21, 1990, a team of nine NPC inspectors perforrned an Operational i dafety Team Inspection (OSTI) at Arkansas Nuclear One (AN0), Units 1 and 2, to determine whether the facility was teing operated in a safe manner. The i inspection team primarily observed operating plant personnel and reviewed i activities that interfaced with ano supported the operations department. The ,

team observed approxirrately 80 continuous hours of onshif t operations-related l activities as well as examining the ereas of operations, maintenance, technical support, management oversight, saf ety review, and corrective actio I Overall, the inspection find engs were positive. The licensee had n,ade or was in the process of making a uumber of changes in management positicos, organizational structure, and programs. In making the changes, the licensee appeared to be successfu'ly molding existing AHO strengths, such as corrpetent l personnel with plant knowledge ana skill, with new ideas and initiatives, thereby, making the entire operation more efficient with an increased sensitivity to saf ety. However, trany of the changes were still being developed and had not been fully implemented to permit evaluation of their effectivenes The licensee was in the early stages of developing a program to raise the experience and knowledge levels of personnel performing certain activitics (e.g. , root-cause analysis and condition-report evaluations) and had not completed the staffing of a number of arces (e.g., system engineers). The team identified these as wcaknesses requiring management attention. The licensee acknowledged that the imple.5entation of the new concepts and trethods, and the effort to raise the experience and knowledge level of personnel performing certain activities would take s ee tim The team identified one potential violation related to an instance in which the licensee failed to maintain a controlled procedure current. The team also identified an unresolved item involving the licensee's failure to test certain safety-related instrument air check valves. Because of the potential safety significance and generic implications of this item, Region IV conducted a followup onsite inspection in this area during October 1-5, 1990. The results of that inspection are detailed in NRC Inspection 0,eport 50-313/90-36; 50-368/90-3 The significant strengths and weaknesses that the team noted during the OSTI are listed belo Minor problems were brought to the licensee's attention on a daily basis. The licensee committed to review these problems and to take corrective action as determined to be appropriet Strengths

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Control room professionalism was exemplified by attentiveness to duty, centrol of traffic, and shift turnovers.

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• Housekeeping, lighting .and the material condition of plant equipment had significantly improved in the pest yea *

Good progress had been made in resolving issues identified by the NRC di3 gnostic evaluation team in the operations are *

The qualification review board was en effective means of determining the capabilities of candidates for auxiliary operator, waste control operator, and reactor operato *

The Unit 2 operations program provided operations personnel with exposure to INP0 and other utility operating practice *

The use of maintenance specialists had been implemented to provide an effective means of-directing difficult preventive and corrective maintenance effort *

The maintenance and support staffs had generally accepted management's initiatives.for improving performance and were actively participating in improvement activitie *

The licensee's program improvements had resulted in increased su'pervision and management attention, particularly in the area of maintenanc * Senior management was committed to improving performance, and middle managtment strongly supported the improvement initiatives and displayed a willingness to hel *

The condition reporting process addressed deficiencies in a timely manne Weaknesses Workloads exceeded staffing level capabilities in a number of aras such

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as job order backlogs and procedure upgrades. This combined with the

- workload from the .new preventive maintenance program had a. negathe impact on the ability. tc keep up with essential wor Some maintenance work procedures still required substantial upgrading to make them technically correct and usable. Craft knowledge and skill levels were such that personnel successfully recognized and corrected the procedure problem *

Ho procedure controls existed for plant engineering documents such as temporary modifications and engineering action- request A number of instances were identified in which required information was 1 not' entered on forms included with modification package * There were no guidelines for operators which provided acceptable oil levels in some major components such as the emergency feedwater pump motor bearing, vi l

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. INSPECTION SC0pE From September 10-21, 1990, a team of nine inspectors conducted an operational safety team inspection at Arkansas Nuclear One (ANO), Units 1 and 2, to essess the safe operation of the facility. The inspection effort was concentrated on the effectiveness of the licensee's operations activities to ensure the safe operation of the plant, including the effectiveness of other organizational components in supporting operations. The team observed approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of onshift operation-related activitics including backshift end weekend inspections. In addition, the team inspected the areas of maintenance, engineering and technical support, management oversight, safety review, and corrective actio The inspection was conducted in accordance with the guidance of Inspection procedure 93802,"OperationalSafetyTeamInspection(OSTI)," dated November 27, 1989. The details of the inspection are given belo Attachment A lists the attendees of the exit meeting. During the inspection, the inspectors also contacted other members of the licensee's staff to discuss issues and ongoing activitie . 1HSPECT10N DETAILS 2.1 Operations Theteamspentover80hoursobservingcontinuousoperatino)activitiesinthe Unit 1 and Unit 2 control rooms (including shif t turnovers involving licensed operators performing the duties of shift supervisor, control rocm supervisor, senior reactor operator, or control board operator. The team reviewed system operating procedures and numerous programs with regard to their ability to support ;.lant operations as well as the qualifications of licensed operators and selected fire brigade members. The team also walked down selected systems in both units to campare physical configuration against design documents and procedure The licensee's operations activities generally were conducted in a manner to ensure safe operation of the plant. The specific strengths and weaknesses associated with operations activities are discussed belo . Shift Routine Throughout the inspection, Unit 2 was operating at full power and Unit I was operating at approximately 80 percent power as a result of limits set by sa h ty analysi During all the shif ts observed, the operators were attentive and alert, i reflecting professional attitudes that emphasized control over the units and shift activities. The noise level in the general area was sufficiently low l that it did not interfere with communications among operators. Access control to the control board area from the shift supervisor's office of each unit was l well controlled, with a minimum of extraneous personnel present at any time in l

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the control rooms. However, the shift supervisors had very small offices, and

,non-operations personnel accessed the control. rooms'through those offices, M ich led to increased noise levels and crowded conditions occurring mainly at the beginning of shifts and Fcasionalt during the shifts. The team was concerned that this diminished ti.a ef riciency and effectiveness of the shif t supervisors in performing their 6 ties. The licensee informed the team that it had given high priority to in;reasing the size of the offices within the 1991 !

budget yea "

Control room operators were aware of plant status, component conditions, and system configurations. They appropriately responded to annunciators and

, off-normal conditions. . Turnovers during shift changes were usually thorough and included walkdowns of the control root oanels with the operators that were going off duty. Sufficient time was allotted for the shift turnovers. The shift supervisors provided a good overview of previous shift activities,

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expected evolutions and special assignments during the shift briefings following turnover. Onshift support groups such as d emistry and health .

physics were included in the shift briefings, which appared to be a strenoth in coordinating shift activities with these groups. Another strength was the !

cross-unit awareness of operating shift crews. This became evident when-the Unit 1 shift supervisor observed that the performance of a surveillance test on seismic monitors, which had been p;rformed many times prqviously, resulted in :1 placing Unit 2 in a limitino condition for operation for a short period while I the monitor.was out of servic .)

Control room logkeeping of equipment status to determino any limiting conditions for operations was conservatively administered. However, the i following weaknesses associated with logk?eping activities were referred to the licensee for corrective action:.

Procedure 1015.03, " Operations-Log Taking," Revision 14, allowed white-out to be used on certain operational 6rd equipment data logs. --The licensee's QA. department had noted this during-an operations audit, and actions were planned to phase out the use of white-out. In response t the team'.s concern, the licensee issued night orders to both unit control room shift crews to discontinue the practic *

'The-inspectors noted instances in which operator control of documents and other material on the control boards.in both control rooms was lax. Log sheets were placed on the control board bench panels-in the Unit 1 contro room and absorbing tissue,~which was used to facilitate.the changing of !

status boards, was placed on the. Unit 2 bench panels. The team brough ,

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this to the licensee's attention because this practice could result in covering critical status lights or indicators during plant transient The licensee corrected the proble .1.2 Plant: Tours The inspectors toured the plant to verify that the licensee was maintaining the material condition of plant equipment and the plant spaces in an acceptable-2-i

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condition _ In addition, the inspectors also verified that safety-related equipment was in a condition that ensured that the equipment could perform its ,

. intended safety functio During tours, the inspectors noted the following items:

• A confined space was not appropriately posted to ensure that personnel obtained a permit prior to entry into the spac *

Valve handwheel wrenches were t'eing stored on equipment and piping and not properly stored in the holders provide <

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A few creas in the plant needed e.dditional housekeeping attenion. The housekeeping discrepan @ s identified were mino *

Ledders were leaning against a wall in the Unit 2 diesel generator room

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and were not secured to prevent fallin Bolts for the electrical connector box cover on the control room emergency air conditioners were not installe For each of the items identified above, the licensee took timely actions to correct the identified discrepancie During a tour of the Unit 2 auxiliary building, the inspector noted that the oil. level in the bull's eye sightglass for the emergency feedwater pump motor bearing appeared to be low. Attached to the motor was a deficiency tag (Job Request 853018) that stated that oil should be added to the motor bearing since the level was only 1/8-inch in the sightglass. By reviewing the manufacturer' technical' manual, the inspector determined that the vendor recommended maintaining a level at least 1/2 full _in-the sightglass. The licensee was requested to determine the operability of the moto The-licensee contacted the motor manufacturer and verified that the level was satisfactory for operation of the motor. As a conservative. approach to plant'

operations, the licensee added oil to'the motor bearin During review of this item, the inspector noted that the licensee had not instituted a training program to instruct auxiliary building operators on the proper level of oil to be maintained in pumps and motors. The' licensee stated that a training program was in the process of being developed and~ implemente The licensee took short-term action by requiring that each shif t supervisor

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instruct shift personnel on the actions to be taken if-it is suspected that a-level may be low. Review of the licensee's implementation of a training

'1- program is considered.an inspector followup item.- (313/9024-01; 368/9024-01)

Overall, the team noted that the licensee had implemented an effective housekeeping program and had provided a very good level of lighting throughout'

the plant. The material condition of plant equipment was found to be very good.

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2. Independent Verification The licensee had prepared procedures and Station policy Sp-Z, "AN0 Independent Verification Requirements," Revision 1, to implerrent indepenaent verification of valve lineups, hanging and restoration of system tagouts, verification of restoration af ter changes made during surveillance tests, and other activities in response to NUREG-0737, item I. The method for performing independent verification of locked valves during outages and monthly surveillances on Unit 2 was considered a strength. It censisted of performing the initial lineup and noting the required valve position (locked closed, opened, or throttled). In the verification lineup the operator noted the valve position without reference to the reouired position. The two lineups were then compared and any discrepancies noted were then correcte The licensee performed two lineups for rach safety-related or critical plant systems during the 1989 outage. The licensee indicated that the second lineups were performed to meet a commitment made in response to an HRC Diagnostic Evaluation Team finding. The licensee had committed to perform independent verification of all system valve positions for safety-related system However, many of the valve position verifications on both l eeups for low-pressure safety injection system were performed by the same ndivicua Although true independent verification was not perfomed, no vioiation of requirements occurred because the licensee had not implerr4nted procedural requirements. The licensee reviewed other lineups and found that the team's finding was an isolated occurrence. Nonetheless, the licensee proposed to strengthen procedural requirements to ensure that independent verification activities would be correctly performe .1.4 Adequacy of Operations programs and Procedures The licensee's programs and associated procedures appeared adequate to support safe and effective plant operations although one weakness was found in the process for turning over design changc modifications to operation Several operations directivec, covering a range of subjects such as night orders and shift relief /tw nover, were prepared in respense to weaknesses identified by the Diagnostic Evaluation Team in the area of contunications of operations information to shift crews. These directives were comprehensive and contained appropriate communication Station-Administrative Frocedure 1000.02, "Teroporary Modification Control,"

Revision 15, delineated the requirements for using temporary modifications, i

The procedure was fou..! to include all the necessary information and reouirements to implement an effective progra Unit 1 Temporary Modifications 90-1-012 and 90-1-016 and Unit 2 Terrporary Modifications 90-2-022 and 90-2-030 were found to oe properly implemente These modification packages included correct reviews and sign-off signatures and adequate 10 CFR 50.59 reviews performed by a certified reviewer. The on-shift reactor operators and senior reactor operators were knowledgeable about the status of the temporary modifications. However, during review of the

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t Unit 2 temporary modifications, it was determined that the required monthly review of all temporary modifications had not been performed during August 1990. This was the result of a computer input error that: occurred after implenenting a revision to the' surveillance procedure, and it appeared to be an isolated incident not indicative of a significant problem in the timely performance of surveillance test If temporary modifications were going to be in place for more than 90 days, appropriate personnel reviewed the cordition and an expiration date extension was submitted for. approval in accordance with Procedure 1000.02. In addition, controlled drawings were revised to reflect the temporary modificatio Procedure 1000.27, " Hold and Caution Card Control," Revision 14, adequately specified the tagout requirements for systems, equipment, and compcnents that needed maintenanc ,

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Night: orders issued to the Unit I and Unit 2 control rooms appeared .

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infonnative, comprehensive, and detailed and were developed in accordance with !

the associated operations directiv "

t Procedure 6030.001, " Installation. Plan," Revision 9,_ appeared to emphasize the proper steps required to turn over modifications effectively after implementation and testing to ensure that the documentation was updated as-required. The procedure required tha modification engineer to ensure that-control room critical drawings were revised before the turnover. However, Modification Turnover Form 6030.001F did not include the drawing. revision as an item to be confirmed in the control room _by-operations, although it did require procedures and training to be confirmed as completed and approved. No other idocumentation_of drawing updates was provided, except for modifications-

' implemented during outages by sign-offs in Procedures 1102.01 and 2102.01, which-provided direction for precritical and preheatup operations. The licensee indicated that discussions would be held between operations snd )

engineering to ensure that all aspects of modification turnover were properly '

implemente Plant design document and drawing e ntrol. procedures required that the affected

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control room' drawings be revicG and provided'to update the control. room drawing files at the tin * or turnover of a modification to operation '

Procedures also required revised drawings to show temporary modifications and-indicate the' areas affected by pending modifications.

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!' The program for control and' revision of critical plant drawings required by the E . control room operators in performing routine operations, maintenance tagouts, ,

'and off-normal operation diagnosis appeared to be well _ implemented. Control- t

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room shift supervisors indicated that piping and instrumentation diagrams cnd o electrical . single-line drawings were %e two categories of drawings _ most of ten l used although occasionally other drawings such as fire barrier leyout drawings,

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electrical layout drawings, and connection diagrams were required during certain tagout evolutions.

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The deployment of operator aids in the control room area and in plant areas outside the control room were adequate. Copies of piping and instrumentation diagrams that were posted in the euxiliary building for both units to aid waste control operators and other plant personnel in performing their duties were current and consistent with those drawings reaintained in the control roo Portions of procedure attachments, or exhibits, which detailed local operation steps were placed in areas such as the diesel generator rooms, the service water pump inteke structure, and the turbine driven auxiliary feedwater pump These were imprinted on plastic or aluminum sheets. However, the team observed an inconsistent designation of revision status on the exhibits and questiuned the method of controlling the exhibits to ensure they were maintained consistent with the controlling procedures. The licensee responded that a quarterly audit of the exhibits was performed to ensure consistency. Although this audit was not formally proceduralized at the time of the inspection, the licensee planned to do that in the future. The licensee planned to remove the revision number to ease the audit process and minimize the need to change exhibits and to ada the effective date of the exhibit. To ensure that exhibits would be reviewed, licensee representatives indicated that procedural requirements would be added when controlling procedures were revise The extent und quality of equipment tagging and labeling for both units was adequate and consistent with procedures and valve lineups. Many of the valve lineups contained a block for checking if a tag was attached to the corresponding valve, which the team considered a positive measure to ensure replecement of damaged or missing tag .1.5 Staffing and Qualifications of Operations Personnel All licensed operators and senior reactor operators had valid NRC operator licenses, and training in the licensee-administered requalification program was current. The selected training records of fire brigade members indicated they were qualified in accordance with the licensee's training requirements for fire brigade members. The licensee operations management for both units had qualification review bourds to examine the qualifications of candidates for euxiliary operator, waste control operator, and reactor operator. The review boards appeared to be an effective means of determining the qualifications and capabilities of the candidates and ensuring that managerrent concurred with the candidate's shift supervisor and trainers that increased responsibilities could be carried out safely and competently by the individual. The review boards also provided an assessment of the effectiveness of the training program by identifying weaknesses in knculedge or application that could be corrected by improvements in training. The team observed the board identify..ig such training enhancements during two review sessions, one for a weste control operator ready for qualification and one for a reactor operato, nearing the completion of the R0 training progra .1.6 Use of Equipment Setpoints in Operating proceduros The team compared plant equipment setpoints contained in selected systen operating procedures against setpoint values used in annunciator response procedures. The team then compared these values with those contained in-6-

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l Operations Administrative Procedure 1101.02, "Setpoint," Revision 8, l October 20, 1988. The procedure contained erroneous and out-of-date ,

information for some of the equipment setpoints in the decay heat removal, l emergency feedwater, and core flood system procedures. The specific examples I are described belo I

Procedure 1104.01, " Core Flood Operating Proced we," Revision 18, listcd the setpoint for Loop A, reactor coolant syster (RCS) pressure (PS-1021)

as greater than 750 psig while Procedure 1101.02, page 5, listed the ,

setpoint as 650 psi I

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Procedure 1106.06, listed the setpoint for" errorgency Emergencyfeedwater Feedwater Pump EFW) (Operation,"

condensate Revision 42, storage tank (CST) T41B LEVEL LO (LIS-4205, LRS-4204) as 27.8 feet while Procedure 1101.02, page 49, correlated the listed instrument number with caustic tant level instead of the condensate storage tank level. Similarly, EFW CST T-41B LEVEL LO.L0 was listed in the operating procedure as 5.1 feet using the same noted instrument *

Procedure 1104.04, " Decay Heat Removal Operating Precedure," Revision 46, listed the OECAY HEAT' REMOVAL FLOW LOW for Flow Loops A and B (FS-1401 and FS-1402) as less than 1000 gpm, which requires that written procedures shall be established, implemented, and maintained covering activities that affect the performance of safety-related equipment. Procedure 1101.02, page 12, listed the setpoint as 1500 gp Licensee management responded that some of the information contained in Procedure 1101.02 was known to be incorrect, but it believed the procedure was-adequate for use until the operating procedure upgrade program was complet This was also documented in the licensee's periodic review of the procedure conducted on March 5, 1990. The licensee also stated that the procedure was not intended to be used for changing plant tetpoints but only to complete information on setpoints used in various plant systems. The team was concerned that a controlled safety-related plant procedure was not being. maintained current-in accordance with Technical Specification 6.8.1 and Regulatory Guide 1.33 Revision 1. This' failure to maintain Procedure 1101.01 is an apparentviolation(313/9024-02) of Technical Specification 6.8.1 requiremen The licensee revised Procedure:1101.01 by removing all setpoints from the procedure ~and referencing Engineering Procedure N-517 for appropriately controlled setpoint information. In the-long term, the licensee planned to have its engineering department develop a corrprehensive setpoint identification and control program for all plant equipment in conjunction with the design '

basis document program. The licensee's plans appeared to have features necessary to control setpoint information and setpoint changes adequatel .1.7 System Walkdowns Walkdowns of the high-pressure and low-pressure safety injection systems of Unit 2 and the' decay heat removal and emergency feedwater systems of Unit 1-7-

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showed that system configuration was accurately represented by design documents and operating procedure During the waltdowns, the inspectors observed that equipment was well maintained and items such as handwheels for manual valves and component identification tags were presen l A concern was noted by the inspector while comparing the physical configuration i of the mechanical sec1 telitale drain lines for Low-pressure Safety Injection l Pumps 2P60A and 2P60B with the corresponding Piping and Instrumentation -

Diagram (P&lD) M-2P32 " Safety Injection System," Revision 75. A manual valve was installed in the line for each pump leading to the drain header, but the valves were not indicated on the piping and instrumentation diagrams. The valve in each line was downstream from an open cap used to collect discharges from the seal telltale. Each valve was in its correct open position, and closure of the valve would not have presented a safety concern. The valves did not have tags, and an isometric drawing for the drain line that showed the-valves had no number or otkr identification associated with them. The r

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licensee initieted corrective action to revise procedures and drawings and provide tags to corrcctly represent the valve The inspectors walked down selected portions of the Unit 1 and 2 control' room heating, ventilation, and ai. conditioning (HVAC) system to verify that the system met the design basis requirements provided in the Final Safety Analysis Report (FSAR),thatproceduresprovidedadequateoperatingandannunciator response instructions, and that the system drawings accurately reflected the ;

as-built condition of the system. The portions of the HVAC system reviewed by '

~ the inspectors included the Unit 1 and 2. normal ventilation system, the

- emergency filter. and fan units, and the ventilatico exhaust syste The inspectors verified that the system mot the design requirements provided in the FSAR. No problems were noted during review of the system operating and annunciator response procedures. During review of Drawing M-263, " Control and Computer Rooms HVAC," Rev hion 27, the inspector noted minor discrepancies t between the as-built system end the drawing. The discrepancies were' considered

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to be of a minor editorial nature and did not affect the safe operation of the plant or system operability. The discrepancies were provided to the licensee, who stated that the discrepancies would be corrected during the next scheduled update of the-drawin During review of the normal ventilation system for Unit 1, the inspector

, identified potential problems related to the operability of be control room dampers.- ,

A followup inspection was performed October 1-5, 1990, to evaluate the

operability of the dampers. The results are documented.in HRC Inspection Report 50-313/90-38; 50-368/90-38. As a result of the inspection,- a potential violation was identified and an enforcement conference was held on October 30, 390, to discuss the issues related to this potential . violatio , )

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l During review of the apparent violetion identified with the air system for the control room dampers, the licensee's response to Generic Letter (GL) 88-14

" Instrument Air Supply System problems Affecting Safety-Related Equipment,"

dated March 7, 1989, was reviewed to evaluate the response provided by the licensee with respect to testing the check valves in the accumulator essembly for the dampers. As a result of this review, it was noteo that the licensee had provided inaccurate information with respect to the status of the air system check valve testing program. The licensee's response stated that the current surveillances conducted at ANO en "Q" (i.e., safety-related) components verified the operability of air-operated, instrurre.nt air system component This statement by the licensee was inaccurate in that the licensee was not performing testing on Check Valves IA-43A IA-438, IA-44A, and IA-44B, as well as Solenoid-0perated Valves SV-7910 and 2SV-8607B- This is a potential violation of 10 CFR 50.9 that was also discussed at the October 30, 1990, enforcement conference and will be part of the enforcement l

issues addressed in HRC Inspection Report 50-313/90-30; 50-368/90-38, i As part of the review of this system, the surveillance testing performed to I verify system operability, as required by the Technical Specifications, was I evaluated. As required by Technical Specification 3.9.1.f for Unit 1, the licensee verified that the dampers in the normal ventilation system will shut within 10 seconds upon receipt of an indication of chlorine, smoke, or l radiological problems. The testing was performed in accordance with the i

requirements in Procedure 2104.07, " Control Room Emergency Air Conditioning and Ventilation." The test was performed by applying pressure to the

" bladder-type" dampers and recording the time that it took for the pressure gauge in the air supply line to reach 10 psig. The dampers were constructed of several rubber bladders inside the air duct. Pressurizing the rubber bladders caused the bladders to expand; thus, stopping flow through the duct. Based on the operation of the dampers, it was not apparent how verifying that pressure i in the supply line was at least 10 psig could ensure that the bladders would stop air flow through the duct. The licensee stated that a review would be performed to verify that the test procedure currently used was adequate to verify the operability of the dampers. This item remains unresolved pending

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the completion of the procedure review by the licensee and an evaluation of the l results of the licensee's review by the NRC. (313/9024-03)

During walkdcwn of the Unit 1 air system piping, the inspector noted that sof t patches (i.e., tape wrapped around the piping, covered by a strip of rubber, and held in place by a hose clamp) had been installed on the safety-related portion.of the piping. Review of documentation revealed that a solder joint in the piping had broken loose during the performance of testing of a pressure switch. By the end of the inspection, the licensee had not specifically identified the documentation that authorized the inste11ation of the soft patches. The installation of the sof t patches may involve en unauthorized modification to a safety-related syste This issue renains unresolveo pending the completion of an evaluation by the licensee to determine which document authorized the installation of the patche (313/9024-04)

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2.1.8 Operations Surveillance Testing The team observed surveillance tests conducted during the shift routine portion of the inspection. Portions of tests associated with the following procedures were observed:

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1104.31, " Containment Hydrogen Control," Revision 4

1104.36, " Emergency Diesel Generator Operation," Revision 28, Supplement 1 2104.03, " Chemical Addition," Revision 18 Pump 2P-39B

2304.173, " Process Radiation Maitoring System Quarterly Test," Revision 2

2104.029, " Service Water Auxiliary Cooling Water and Cooling Tower Makeup " Revision 33

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2107.01, " Electrical System Operations, Revision 28

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, ' Testing was conducted satisfactorily in accordance with procedure requirement However, the inspector noted during observation of performance of Supplement 4 to Procedure 2107.01 that the status light indication of safety-related-Inverter 2Y24 was blinking as opposed to being fully on as were the indication lights for the other inverters; nevertheless, it was recorded on the test sheet as "on." The licensee had previously noted this deficiency in January 1990 and a deficiency tag was attached to the inverter cabinet. However, test records did not note the deficiency as an exception. The licensee reviewed cabinet circuitry and confirmed that the blinking light did not affect the operability of the inverter. The team's concern was that test records did not indicate the deficient condition and that shif t management was not' informed of the continuing existence of the deficiency through. review of the test records. 'The licensee stated that further guidance would be provided to shift crews concerning attention to detail in performing surveillance test <

2.2 .Mainte, nance The: team observed 6 mechanical and 4 electrical and instrumentation maintenance jobs._and reviewed about 36 maintenance job orders, including both open and closed work packages and various maintenance programs, procedures,.and associated documentation. The. team also held discussions with personnel at all levels of the licensee's maintenance activitie Substantial progress was made over the last year .to improve maintenance programs and their implementation. Separation and the increased sizes of the Uni _t I and Unit 2 maintenance and support staffs had a major.irpact in improving the effectiveness of the maintenance department. The team observed significant improvement initiatives in all major programs including conduct of maintenance, job order (J0) control, parts and material support, and technical support.. The inspectors also reviewed progress in the maintenance area with regard to the licensee's 1990-1994 business plan, finding that although some activities were taking longer than expected, the key plan activities appeared-10-

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to be progressing. The licensee maintenance department personnel were actively participating in the program improvements and appeared generally committed to management's improvement initiatives down through the journeyman and helper level Although progress had been made in establishing all of the programs, some of the programs were not fully im (1) required additional tine to become functional or (plemented and either:2) were proceeding more slowly tha result of resource restraints. The first category included the preventive maintenance (PM) program, the maintenance history program, and the post-maintenance test program. The latter category included procedure upgrades, backlog reduction, and equipment failure trending and analyse .2.1 Maintenance Progrems and Organization The individual maintenance managers for each unit and their direct report staffs were appropriately involved in nearly every aspect of program development and implementation with regard to control of work backleg, planning and scheduling, Kb coordination, work procedure upgrading, preventive maintenance program development, and equipment history / failure trendin ,

The combined maintenance staffs were preparing a " Maintenance Management Principles" handbook that addressed quality, management, and personal performance subjects such as procedure adherence, human performance and self verification, risk judgments, and professionalism. The handbook was expected to be issued shortly. The licensee's work force indicated that the handbook addressed work values and issues that were important to the craft and supervisory employees and would likely be well receive The' licensee's organizational and procedural initiatives were properly oriented and were sufficiently progressing. The instructions provided by procedures and work packages were generally sound and were readily corrected through procedure changes when performance or procedure adherence problems were encountered. The minor problems requiring improvement that were identified by the licensee and the team are discussed belo The lic W ee made major maintenance program revisions during 1990.- Maintenance Administration Procedure (MAP) 1025.003, " Conduct of Maintenance," Revision 35, was issued in August and represented an aggressive maintenance approach addressing many NRC and INP0 initiatives ~ such as procedure content, use, and validation; prioritization and control of emergency work items; verification of proper work performance; and other Initiatives also were underway to upgrade older procedures to meet current industry standards as evidenced by itAP 1000.006, " Procedures Control,"

Revision 33, and MAP 1025,009, " Maintenance Procedure Format anc' Content,"

Revision 8. Most procedures had been updated over the past 5 years, but some still requi ed substantial revision. For exampic, MAP 2402.139, " Disassembly, Inspection and Reassembly of 2SI-10 A, B, C," Revision 0, was followed, by the

- inspector, to repair Unit 2, High-pressure Safety Injection Pump Discharge Valve 2SI-10C. During the time of the repair (September 5-13,1990), it-11-

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required three procedure changes to correct technical errors in the disassembly and reasserably instructions for the valve. in another case, the lack of instructions in a procedure resulted in the valve gland leak off line nipple being over extended into the valve yoke, causing scoring and binding of the lantern ring and eventual gross leakage from the packing. The licensee identified and r rected this shortcoming as docuraented on an unnumbered condition report dated September 14, 1990. Similar lack of instructions involving orientation of internel parts, such as the segmented retaining ring, were overcome W experienced craf tsmen, but could have caused difficulty with less exper br.ced personne The sensitivity of licensee personnel to procedure quality and adherence matters and the kind of problems inherent in existing procedures was further illustrated during conduc+ of Mechanical Periodic Test Procedure 1306.014

" Unit 1 Control Room 1, Auxiliary Control Room Halon Fire System Inspection,"

P,evision 13. The licensee found that spare cardox bottles for the control room did not meet the weight and pressure specifications of the procedure and that the procedure required the bottle be shioped to a vendor for recharging before continuation of the test for the other bottles. Work was stopped until a procedure change to allow testing of the other bottles could be processe Six engineers and a supervisor were responsible for coordinating the preparation, review, and approval of procedures and for validating maintenance, l surveillance, and other procedures and procedure changes. The procedure support staff indicated that they were responding only to high priority, reactive workloads and that they were unable to make significant progress in reducing the backlog of previously identified procedure needs. The craft journeymen were iound to be extensively involved in identifying and correcting procedure deficiencies. Although the team considered this a strength, it did not correct the existing weaknesses. Additional management attention and resources were needed with regard to procedure upgrades and backlog reductio The work instructions provided by safety-related job order work packages were .

extensive and provided good guidance for the craftsmen. However, in som; I cases, the work package instructions were as complex and detailed as a formal .

procedure. The team discussed with the unit naintenance managers and work I planning supervisors the controls and judgment that were used to ensure that a l procedure would be initiated if it did not exist, rather thar relying on work I package instructions. This was a concern because the work package instructions were only subject to informal review by the lead discipline planner or supervisor and did not require review in accordance with MAP 1000.006,

" Procedure Control," Revision 3 The licensee had identified a recent example of a defective work package instruction (JO 813298) that involved repair of a Unit 1 emergency diesel generator eductor during Junc 1990. The work package originally contained incorrect torque values for eductor tube flange connections, which resulted in the craftsmen over-torquing the joint. Although no further problems were identified, the Unit 1 and 2 maintenance managers recognized the need to I consider additional cautions to ensure that the quality of the instructions was J naintained during busy periods when the informal reviews might not occu .

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As part of its plan to shift from corrective to PM, the licensee had identified over 7000 repetitive FM tasks (about 3000 of them safety-related). About two-thirds of the task were already planned, approved, and scheduled over an 18-month interval. Further, during 1990, the licensee established elaborate ,

methods for identifying and analyzing the type and volume of incomplete work (open-job order packages) and assigning safety-sensitive work priorities for work scheduling. The team considered the licensee's initiatives in this area connendable and effectiv The backlog of safety-related (Categor es Q, S, or F) outage and nonoutage job orders on both units appeared reasonable and under control. The nonsafety-related statistics on both units indicated a substantial historical backlog requiring an extraordinary effort to clear. Units 1 and 2 showed a total backlog of about 800 job orders per unit and about 20 percent of those were safe ty-related. The backlog was balance of plant systems, structures, and components. Recent initiatives included reassessing the individual job orders to cancel or reptioritize them and assigning overtime crews to reduce the ,

backlog. However, these efforts were only moderately successful, with the 4 backlog hiding essentially constant. With the advent of the additional PM program i orkloads over the next 18 months, the licensee would lose further ground it backlog. reduction which potentially could degrade the balance of-plant. The unit maintenance nanagers and their staffs indicated a strong understanding of the need to reduce the backlog and avoid an adverse effect on plant operations and safet .2.2 Work Package Review The team reviewed about- 36 job order work packages and found that the packages were completed in accordance with MAP 1025.003 and MAP- 1000.024, " Control of Maintenance," Revision 35. The packages involved a spectrum of safety-related 1

and nonsafety-related jobs and included ~ job order instructions, permits, ,

applicable procedures, environmental qualification data summary sheets, and material requisition forms. Job orders were initiated either manually or l electronically using the system integrated management system terminals located throughout the plant. The preparation of job order packages, which included ,

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development of work instructions, scheduling and coordination, material controls, quality control inspections, and post-maintenance testing, had

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improved significantly over the past yea The licensee's procedures for control of design and engineering input

.information'from vendors and, contractors included well-developed control provisions for calculations, specifications, and' design changes. However, no such control existed for plant engineering documents such as temporary modifications or engineering action requests. Licensee personnel acknowledged

.the need for additional guidance in this area. The manager, systems engineering,' stated that additional. procedure provisions were under consideration'at the close of the inspection. Review of the licensee's actions-to procedura112e plant. engineering documents is an inspector followup ite (313/9024-05;'368/9024-05)

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2.2.3 Maintenance Activities Observed Routine maintenance activities in the areas of instrumentation and control, electricel, and mechanical were reviewed and found to be properly planned, controlled, and performed in a manner that enhanced safe operation of the plant. Stnior maintenance speci611sts and maintenance supervisors provided close surarvision of safety-significant work, end prejob briefings were held for complex or difficult jobs. Quality control and engineering staff involvement and job coverage also was acceptable. Sone minor problems are discussed belo A rupture disk on Unit 2 Demineralizer Tank 2T95 was replaced on September 11, 1990, JO 822539. The installation was not safety-related. The work package instructions required that the flange bolts of the rupture disk only be snug tight. This appeared to be consistent with the guidance of Procedure 1025.020,

" Bolting and Torquing Guidelines," Revision 2. However, the rupture disk vendor instructions enclosed with the new part recorrended torquing to specific values. The team pointed this out to the mechanical supervisor who, in i conjunction with engineering, had appropriate instructions added to the work packag Several problems were noted during repair of the Unit 2 High-Pressure Safety Injection Pump C Discharge Stop-Check Valve 251-100(JO852723 September 5-14, 19S0). The valve had a packing leak and appeared to be stuck open and the valve leakoff line was clogged. New parts had been drawn from stores to replace the valve stem, plug, compression spring, and packing. However, all stores tagging and identification paperwork had been removed from the metal parts. The quality status of all parts, except the compression spring, were established through the heat identification numbers etched into the parts. A replacement spring having the appropriate documentation was drawn from store Licensee representatives acknowledged the need to ensure craft personnel were-familiar with quality parts documentation and traceability requirements and initiated action'to brief the personnel involve After reassembly of the valve and while inspecting the pump and valve before ,

pressure testing, the team noted that a portion of the valve packing gland I leakoff. line had a wad of tape on a joint and appeared to be leaking into and I through a plastic drip pocket. The licensee determined that (1) the 00 had I ambiguously identified a line blockage in this line and the craft had unclogged the wrong section of line; (2) the line had been cut some time in the past and a 4-inch section of clear plastic hose had been installed with hose clamps as a ,

" sight glass"; (3) no record of, or authorization for, this ad hoc modification I couldbefound;(4)onthepreviousnight,thelinehadpressurizedduringan earlier test causing the plastic tubing to balloon and eventually burst causing the leak; and (5) the night shift had failed to advise the day shift of any of the above although the night shift had apparently tried to stop the leak with the tape and had installed the drip pocket. The licensee issued a plant engineeringactionrequest(unnumbered)onSeptember 17, 1990, to investigate the cause and ramifications of problem. Review of licensee actions related to .l the licensee's investigation of Valve 2SI-10C leakoff line is an inspector (

followup item. (368/9024-06) l

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Unit 1 Battery 05 load test (JO 822428) performed in accordance with j Procedure 1405.055, "D02, 004, 005 Battery Load Test," Revision 0. An 1 electrician performed the test f or on-the-job training under the supervision of a supervisor. The helper signed off cotiponent position verification blocks (Step 7.3) before actually performing the verifications. Although the helper subsequently performed the verifications correctly, the inspector was concerned that this practice could result in improper performance and/or docun.entatio P.3 Engineering and Technical Support To evaluate the effectiveness of the technical staff in supporting safe l operation of the plant, the team interviewed personnel in various groups, '

i examined work' samples, and reviewed related documentation, including the June 1990 organization chart !

ilost of the engineering and technical support staff groups had been recently l realigned or established in 1990, and management was aggressively implementing the revised organization. Managers and supervisors exhibited enthusiasm for their duties and morale appeared high. Duties and responsibilities had been defined, and the licensee had initiated necessary stuf fing increases and training. Recruiting was still in progress and the effectiveness of the new organization, in some instances, was diluted because of the large number of employees in training. This was particularly true for system engineerin ?!onetheless, the licensee's established plans to complete training should correct this weakness. In addition, the licensee had established appropriate priorities to reduce the sizable engineering work backlog in accordance with a workoff plan scheduled for completion in April 199 Although the engineering effort adequately supported plant engineering needs and the interfaces between the various departments appeared functional, some work procedures had not been developed to reflect newly established responsibilities. Specifically, departmental interface procedures needed to be established and implemented to reflect system engineering's role in responding to day-to-day engineering problem The engineering effort was more reactive than proactive. Although the licensee had plans for proactive activities such as predictive maintenance and the monitoring and trending by system engineers, these plans were not fully implemente .3.1 Organization and Staffing Recruiting and staffing of the newly established engineering groups was being pursued aggressively on a priority basis by the technical managers. The general manager engint.sring was responsible for the design groups, engineering

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support, modifications, and engineering standards and programs. Most of the l personnel in the general manager's departnent were relocated from the Little l Rock office to a new engineering facility onsite on September 1, 199 Approximately 70 individuals in his department were still ccatruting from Little Rock. The trauma of the move resulted in a substantial personnel attrition-15-l

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rate. As of Ju y 11, 1990, 304 positions were authorized in the engineering department with 27 vacancie Unit 1 and Unit 2 system engineering groups were newly established with 62 positions authcrized for both units, 50 of those positions were fille Seven of eight supervisors were recently appointed. Assignment of system engineers by unit and system was planned to occur by October 1,199 The shift engineer program was being initiated to replece the shift technical advisor program that was still in effect. Six shift engineers were hired for l Unit 1 and placed in shift technical advisor training that was scheduled to be completed in March 1991. Seven shift engineers were hired for Unit 2; two of the seven had completed shift technical advisor training and the oth r five were new hires and had been placed in the trainin The support maintenance engineering group was fully staffed with five engineers assigned to routine support of craft and an engineer and three technicians assigned to predictive maintenance programs. Support was provided to both unit A new program in the maintenance engineering department was the unit-assigned maintenance engineers. The Unit I maintenance manager inter.ded to assign five maintenance engineers: three to the mechanical discipline, one to the electrical discipline, and one to the instrumentation and control disciplin He had filled one of the mechanical and tbe instrumentation and control position and had made an offer to a mintenance engineer for the position in the electrical discipline. He was still interviewing engineers to fill the other two positions in the mechanical discipline. He had assigned one contractor to cover the mewhanical ard electrical disciplines. The Unit 2 maintenance manager planned to have two maintenance engineers in each of the three disciplines. He had only one maintenance engineer on board for the mechanical discipline and had offered positions to three additional engineer The design and modifications groups had not undergone significant changes in duties and both were substantially staffed. The engineering support and engineering standards and programs groups were created on February 1,1990, and were substantially staffed and functional. The engineering backlog elimination project was initiated in April 1990, and the project manager was assigned to j report to the manager of engineering standards and programs. The backlog elimination project group was fully staffed and functional with 5 licensee and=18 contract employee The nuclear operations standards group was 13 months old and fully staffed and ,

functional. The manager indicated there were approximately 40 employees l reporting to hi l The duties of the licensing departrent had not undergone substantial changes and appeared to be supportive of the engineering effor l-16-

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2.3.2 Evaluation of Duties and Performance

' A description of the functions ar.3 the apparent weaknesses, or potential improvemer items, with regaru to the engineering and technical support groups 4

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is discu sed belo .3.2.1~ System Engineering ,

The system engineering program was initiated to optimize overall plant performance and reliability. The licensee intended the system engineer to become the focal point for system operational, maintenance, and performance problems. The duties and responsibilities of the system engineer were l established with an underlying emphasis toward a sense of. system ownership that '

would provide impetus toward a more proactive system assessment capabilit This' goal had not been achieved because initial staffing f or the Unit I and Unit 2 system engineering groups had just been completed and training was getting undeniay. The system engineering groups.were functioning in largely a  ;

reactive mode although-it appeared that they were supporting the day-to-day engineering'needs of the plan .;

-i The ultimate goal was for each system engineer to 'be certified and assigned as i a' system engineer on one or more systems. Shift engineer system training was  !

scheduled for the period from September 17 to November 2, 1990. Further plans called for completion of technical staff initial training by the end of 1991 and systems overview, reactor theory, and thermonuclear training by i'

September.1992. :Each system engineer would be required to devote 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> a week attending this training. The licensee assigned oneL person to coordinate system engineer training and-planned to essign those engineers with limited system engineering responsibilities during Outages 1R9 and 2R8.- q

- AN0 System EngineeringLDesk Guide, Revision 2, stated that the system engineer  !

would have responsibility for monitoring and trending of- system performance and-

. maintaining a system history file, as.well'as responding to day-to-day engineering problems. The licensee was revising the oesk guide and had

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assigned one-person to coordinate the preparation of work procedures, including <

departmental interface procedures that would reflect system engineering's key  :

role in responding to day-to-day engineering problems.-

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_ requests (was responsible for the initial response to- plant PEARS).;Because-ofrecent.emphasisonstaffing,  ;

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organization, and training it appeared that system. engineering was not keeping up with PEAR processing. Essentially all PEARS were transferred to the backlog elimination group in May 1990. However, by September l', 1990, approximately e

,7 168 PEARS 'were open'outside the backlog elimination group. The manager of tengineering-standards stated that further work transfer to the backlog Lelimination group would be_made, if necessary. The Unit 2 system engineering

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, manager stated that the PEAR prioritiration and processing system required  ;

refinement. He anticipated that a planner and scheduler for PEARS would be 1-assigne l l

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Development and coordination of temporary modifications (1Ms) was a pritrary responsibility of the system engineering group. Thr:e were 26 open TMs on Unit 1 and 24 on Unit 2. It appeated that these TMs were til technically justified and appropriately reviewed and approved and had no adverse effect on design conficuration. However, a common weakness was noted in that all the packages lacked adequate lebt. ling to ensure page accountability. For example, in TM Package 87-2 0010, subsequent pages of Forms 1000.28A and 1000.28D did not have the TM number indicated and form 1062.04A and Memorandum AN0-89-10435 did not have the TM number indicated anywhu r. T M total number of pages in the TM package was r.ot indicated. A page or a docnment could be lost from the package without anyere being aware. TM 89-1-028 vid not have the required review for as low as reasonably achievable (ALAPA) issues included in the package. This deficiency could have been the result of an oversight or a lost documen .3.2.2 Shift Engineer Program After the shift engineers complete their shift technical aavisor training in March 1991, each shift engineer was scheculed to be assigned to a shift operating crew on their redpective units. Continued training would involve qualification as waste control and auxiliary operators, and selected individuals would attend senior reactor operator training. The licensee was constc.. ring the following duties for shift engineers:

• Processing event notifications,

• Performing monitoring and trending on a shift-to-shift basis,

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Initiating condition report * Taking a first cut at resolving engineering problem * Coordinating with systems ano maintenance engineering to ruolve, engineering probitms, and

Performing 10 CFR 50.59 evaluations for temporary change Until this program has been fully implemented and the shift engineers fully trained, the operations managers would be relying on system engineers to perform some of these functions discussed abov .3.2.3 Maintenance Engineering I Maintenance engineers were assigned to the discipline superintendents for unit maintenance. Because the staffing was ongoing for unit-assigned maintenance engineers, this program was not reviewed in detail. Support maintenance engineering was providing support engineering for both units plus the common plant facilities. The unit maintenance managers indicated that the unit-assigned maintenance engineers would provide direct support to the cafts and planning groups. They would coardinate with other engineering groups to respond imitediately to tield proL! cms. The Unit 2 maintenance manager-18-l

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indicated that he would send his maintenance engineers to system engin e t rr,inin The maintenance engineering superintendent stated that the trending of recurring failures had recently been initiated and that operators were trending perfonnance data. There were no administratin procedures to integrate and control the various trending efforts and there was considerable duplication in the efforts. t.s a program, it was not very efficient. The licensee was gathering data to eyeluate the ef ficiency of the overall preventive nainte1ance progra The oil and vibration analysis programs were established in the predictive maintenance area. Thermography equirr;ent had been purchased and used for diagnostic purposes. Personnel were in the process of gathering baseline data for the initiotion of a thermography predictive maintenance program for Unit .3.2.4 Modifications The principal initiating documents for plant modifications were PEARS, engineering action requests, and ccndition report; (CRs). System engineers and the change review board screened these initiating documents to determire if a detailed study (project scoping report) would be needed. Fotore release for construction, an onsite review was performed, and the " test enpy" was approved by the plant safety committee (PSC). If detailed preoperational and functienal testing were required, the modifications test group would prepare testing instructions for inclusion in the test copy of the MP, and they would direct the performance of the testin The recent relocation of the engineering group from Little F,0ck to the site had apparently contributed to the difficulty that was being encountered in finalizing the IR9 outage schedule because of the late arrival of design change packages on site. The outage was to begin October 1, 1990. As of Septaber 18, 1990, 70 of a projected 81 design change packages had been received onsite 40 test copies were available, and 67 had detailed installation schedules. The PSC had 13 test copies waiting to be reviewe Althoughthemodificationpackage(MP)completionratewasaheadofthe schedule for past outages, the nadifications manager stated that they wanted to do better for Outage 2R8 in February 199 Although the MPs that were reviewed had a sound technical basis and met the appropriate criteria, the team identified documentation weaknesses such as:

• Numerous examples of signature blanks and other lines that were left blank. For example, in MP 87-1051, on Form MP&C-001, the "PRN No." and

" Sign-off: Investment Recovery Administrator" lines were blank. On Form 1062.04A, the "SRC Review By" was blank. Also, on Form 302 F1, the

" Approved for Processing By" and " Action Assigned To" lincs were blan * MP 87-1051, which involved installetion of a sprinkler system in the emergency feedwater pump room, had all the " Procedures and Training-19-l

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Ef fected By" forms blank, althcugh Procedure 1104.32 had been revised to reflect the modification. Leaving procedure change information b1,nh in the MP increased the potential for improper equipment operation following turnover to operation .3.2.5 Engineering Support The engineering support grcup was responding to day-to-day requests for assistance by attending the morning status and condition review group meeting This group was responsive to operational safety requirements and provided support in the following areas:

Plant computer engineering and maintenance including the health physics computers and security systems,

Nuclear project controls including plenning, scheduling, and budgetin *

Engineering records and data bases including setpoint documents and technical manuals,

Drafting services, and

Design configuration documentation projec The licensee initiated the design configuration documentation project to validate design documents and reconstitute the design bases. The project, which included an extensive drawing verification scheduled for Outage IR9 was scheduled for completion by the end of 1993. The licensee planned to develop an accurate upper level system <iescription and then to verify that all design documents were consistent with that description. CRs were being issuted when problems were found. Connitnients for essential operating drawings were being met although there was a backlog in some design drawing The team reviewed 28 CRs that appeared to require an engineering response, in most instances the technical bases for the dispositions were sound. Howeve several nre not docuniented well. for instance, CR 1-90-0309 inycived failure to perform inservice testing on the emergency diesel generator air start system. The reportability determination stated that this was a programmatic problem and operability was not in question. When the team, challenged this statement, the engineer produced data to indicate equivalent testing had been performed. However, the data should have been referenced in the dispositio A similar situation existed for CR 2-90-0114, which involved failure to extrapolate the moderator temperature coefficient found during startup to full-power operation at 300 ppm boron. Although there was no explanation as to why this was not a potentially significant oversight, the reactor engineering supervisor stated that periodic reactivity calculations would have alerted them to a serious discrepanc CR 2-90-0017 involved discrepancies in service water pump curve Because the test engineer thought a relief request was in effect for these pumps, he did not pursue resolution of the discrepancies. After the validity of the relief

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request was challenged, the nuclear operations standards group became invohta and discovered that the system had not been properly lir+d up for testing. The licensee had not taken action to ensure that engineering personnel were aware that the existence of a relief request was not a valid technical basis for accepting anomalous operation of safety-related p16nt equipmen CR 1-90-0011, which involved an incorrect quality class assignment on the decay heat removal low pressure injection system, was initiated on January 15, 199 Because of a misunderstanding of an assignment, a positive operability determination was not made until after the team questioned the operability of this system on September 20, 1990, at which time a positive operability determination was made. The licensee had not determined why this failure was not identified in the review process nor had they raised operability questions for other open CR Revisien 7 to Procedure 1000.104 which became effective en April 15, 1990, required that an operability determination be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of CR initietion of the revision. No operability determination problems arreared to have occurred efter that dat In addition there appeared to be a number of unjustified extensions of corrective action response detes. A repert dated September 20, 1990, showed 1438 CRs were open and assigned; 169 were listed as late. Several of the CRs reviewed had been open for what seeind an inordinately long time. Exariples were CR 1-90-0011 from January 15, 1990, to present and CR 1-90-0100 initieted on March 20, 1990, with last action cue on October 1, 1990. Numerous extensions of action dates without documented justification were noted in the CR package .3.2.6 Engineering Standards and procedures The licensee initiated the engineering backlog elimination project in April 1990 to reduce the engineering backlog to a manageable level by dispositioning items systematicelly commensurate with their safety significance before April 1993. As of May 1, 1990, a total of 2077 work items were transferred to the project and had been categorized as follows:

1500 plant engineering action requests,

250 engineering action requests,

250 plant change closecuts, and

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77 othe System engineering screened the items for safety significance before transferring them to the backlog elimination project group. The transferred items were further screeneo by the backlog elimination group for safety significance and 45 items were identified as potentially safety significan Of these 45 items, 42 were determined to not be safety significant, but deserved a higher priority. More information was being gathered for the remaining thre The administrative procedures had been changed to recognize the engineering !

backlog elimination project group. The group was working to existing technical procedures, but did not require any plant services. If additional work was to l

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be assigned to the backlog elimination group, the project plan required assignment of additional resources to avoid an adverse effect on the backlog reduction schedul As of the end of August, the work items had been reduced by 185 itens. The planned reduction was 15 In addition to the backlog *11mination project, this group handled maintenance of the engineering standarcs and procedures, including human factors issues, and administration of special programs including fire protection, environmental qualification, inservice inspection, and inservice testing. Other specialists were also on the program staff including welding engineers and a netallurgis This group was supporting the plant operations on a daily basis through representatives attending status and planning meetings. Staff engineers were interfacing with both the oesign and systems engineering groups on a daily basis. The licensee believed that t' e activities of this group would result in long-terin improvements in engineerins qualit .3.2.7 fluclear Operations Standards The nuclear operations standards group had been fully functier.a1 for approximately 7 months. Its purpose was to take some of the burden of plant safety from first-line supervisors and to ensure that adequate standards and procedures were available to safely maintain and operate the plants. The manager also was chairncn of the PSC. In that position he was able to independently identify items for which procedure changes might be require The PSC was set up to support change review requirements 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day during outages. The procedure backlog had been reduced to a manageable level with approximately 15 quality preventive maintenance procedures that needed to be writte To ensure acquiring appropriate stendards and procedure change information, the nuclear operations standards groups was in the review cycle for design change packages and chances to the plant Technical Specifications. Representatives also attended implementation planning meetings for modification packages. To ensure appropriate engineering input, system engineers were required to sign off for operations and nzintenance procedures, if inservice testing was involved, the engineering standards group was required to sign off the testin Licensee representatives believed that the activities of this group would eventually result in improved operational safet .4 Management Oversight Status, planning, and condition review group meetings were attended by engineering and technical support management. Responsibility for followup on each technical issue was readily assumed by one of the attendees at each meeting. There was a Friday meeting attended by operations, maintenance, and system engineering to discuss open PEARS and to assign priorities. Managers and supervisors exhibited enthusiasm for their duties and showed a high level of appreciation for the functions and problems of other groups. Cooperation-22-

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and coordination in resolving technical problems was good. Morale appeared high with the cyception of some of those employees who were personally affected by the relocation from Little Rock to the ANO sit ,

Specific types of plant meetings, some nianagement tools, and management's goals and objectives are discussed belo . Plant Status Meeting Daily plant status meetings were conducted at 7 a.m. Separate meetings were conducted for each unit. The meetings were chaired by the associated operationsgroup(anassignedshiftsupervisor). The meetings generally lasted 15 to 20 minutes and the agenda addressed planned and unplanned operations and maintenances activities, including any newly developed operations concern The actions and schecules for addressing the items were discussed at the meetings. Additional managenent support was obtained, as appropriat Information from the meetings was relayed to the appropriate group (e.g.,

operations, mechanical, electrical, instrunentation and control, planning and scheduling,andengineering)forimplementatio .

The routine group activities discussed at the 7 a.m. meeting and group activities conducted after the meeting provided the department / group / plant status information to be discussed at the plan-of-the-day meetin The operations personnel associated with the neetings routinely briefed the shift supervisors, who were closely involved with plant activities (planned and unplanned) and their effect on plant safet .4.2 Plan-of-the-Day (POD) Meeting The ANO POD meetings were conducted at 8:30 The POD was chaired by the Director, Nuclear Operations. The Unit 1 and Unit 2 plant nianagers and staffs reviewed the individual plant status, and the routine and nonroutine matters that affected plant safety and reliabilit The POD neetings seldom exceeded 20 minutes. The arrangement generally provided for the Unit I and Unit 2 counterparts to be seated on opposite sides of the table. The plant managers and the Director, Nuclear Operations were seated at the ends of the table. Other ANO staff members (materials, training, engineering, etc.) were also present at the meetings. These meetings enhanced communications by providing the group managers an opportunity to hear and comment about the normal and abnormal plant conditions and provided a catalyst

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for the involvement of the plant staff in these issues. The operations, maintenance, and testing of safety-related equipment, as well as nonsafety-related equipment, were discussed routinely at the meeting .4.3 ConditionReviewGroup(CRG) Meeting CRG meetings were conducted at 8 a.m. daily, as needed. The CRG reviewed any CRs that were initiated regarding safety-related (Q), fire protection (F), and certain other QA-related (S) matters. The operations group conducted an-23-

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O operability assessn,ent and immediate reportability review and the in-house events analysis group presented the CRs to the CRG. The plant manager chaired the CRG meetings and attendees included QA, assessment, engineering, and other Each CR was reviewed by the CRG and the disposition of the CR was determine If the CR was deemed as significant, a root-cause determination and corrective action plan was required to be prepared by the assigned manage The CPG was fur.ctioning well to evaluate, s;reen, and assign CRs and to !

identify the instances of repetitive CRs. The overall process appeared to be effectiv . CorrectiveActionReviewBoard(CARB)

i The CARB was chaired by the Unit 2 plant nianager on September 12, 199 l CR 2-90-0382, dated August'23, 1990 was reviewed. The CR identified numerous l problems encountered with the control element drive mechanism control system (CLDMCS) during a recent normal plant startup (approach to criticality).

The license had performed a root-cause determination, which id(ntified five independent conditions associated with individual and group control element assenblies. The licensee's CR evaluation group recommended seven corrective actions (1990-1992) to upgrade the CEDMCS perforwance and reliabilit After reviewing the CR, the CARB discussed the lack of complete and comprehensive historical data associated with previous " troubleshooting" activities on the CEDMCS. The CARB determined that the prcblem (documentation of repetitive activities) was likely associated with a nurrber of similar type tasks. The Unit 2 plant manager directed that a specific CR be initiated to address the lack of documentation requirements associated with this and other repetitive-type activitie The problems associated with the CEDMCS performance and reliability and the documentation of troubleshooting and similar activities were being followed by the resident staf The Unit 1 plant manager chaired the CARB on September 10, 1990, and the board reviewed CR 1-90-0350, dated August 30, 1990. ValveCV-2870(recirculation header isolation valve) had f ailed to stroke fully closed under differential pressure following a nanual trip of Turbine-Driven Emergency Feedwater pump P-7A. The valve was found to be 2 1/2 handwheel turns off the closed position (lessthan100gpmrecirculationflow).

The licensee's evaluation included a discussion of the vahe history and a previous failure of the valve in June 1990. The licensee determined that the root cause of the valves failure to not stroke fully closed was insufficient seating thrust under differential pressure conditions. The licensee increased the setting of the valve closing torque switch to 12.460 psi (f rom 11,200 psi)

to provide adequate thrust to ensure valve closure under full differential pressure conditions. The team found this acceptabl .

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letter the CARB (GL 69-10 discussed regarding the usethe of generic concerns calculated expressed thrust values in NRC set up under static conditions rather than actual testing. The liu nsee discussed plans to test Yalve CV-2870 using a recently developed test methodolecy that dircctly measures the valve seating thrust usino strain gauges instalhd on the N ive. The licensee indicated thct mother 23 valves were scheduled to be tested in the near-term during the Unit 1 (IR9 scheduled for 1990) and Unit 2 (2R8 scheduled for 1991) refueling outages. The remainder o' the valves were to t,e tested during subsequent outages. The concerns associated with the motor-eperated valve testing programs will be addressed during the followup to NRC Generic Letter 89-1 .4.5 Special Meetings Meetings were held on September 17 and 18, 1990, to discuss a concern identified by the inspectors associated with the Unit 1 and Unit 2 control room ventilation system. The concern regarded the lack of letl rate testing and/or objective evidence associattd with two instrunent air check valves (IA-43 and 1A-44) and related accumulators, piping, and operator The licensee finally tested the instrument ai check valves on Septerrber 21, 1990, and the valves failed. The licensee placed the control room ventiletion system on recirculation, declared the control room ventilation isolation system to be inoperabic, and closed fire dampers on the supply and exhaust lines. De resident inspector was following the licensee's corrective action Panagement involvement and oversight of the determinations regarding the safety issues were apparent, including the need for control room isolation as a result of radiatio .4.6 Monthly Corporate Management Meetings The routine monthly management review meeting conducted on August 17, 1990, was chaired by the president / Chief Executive Officer and the Exec.itive Vice President, Chief Operating Officer. The next regularly schedtled meeting was planned for September 21, 1990, at the plant. The Vice Presicent - Nuclear and gentral managers attended the meetin These upper managarent meetings typically addressed matters such Os routine items (ANO plant status and significant events), special items (fue'

reliability), plant performance indicators, and the ANO business plan item These meetings supplemented normal comunications and provided executive management contact with INO personnel and were an effective method for enhencing communications and exercising management involvement at AN .4.7 Routine Status Reports

The licensee used a number of routinc status reports to provide the status, tracking, and trending of selected performance indicators. These reports l provided management with the overall status of the maintenance department l f-25-l l

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Selected A!40 performance inticator rcperts (April, Hay, June, and July 1990)

provided data associated wite 33 specific items. Each report included definitien and glossary sectiens that addressed the 33 items and the responsible group (source). Tae reports provided the nanogers with the current ytar data as well as yearly goals in certain instances. The information in most of these routine monthly reports could be related directly or indirectly to plant safety and quality performance. The reports addressed tratters such as overall plant performance, nuclear fuel reliability, health physics, chemistry, maintenance, unplanned automatic reactor trips, unplanned safety system cha penges, emergency power systems, and budget information. The quarterly date toquested by the Institute of fluclear Fower Operations also was contairied in che routine report ine Unit 1 and Unit 2 maintenance department performance indicator reports for July 1990 provided selected goals and actual perf ormance numbers regarding a number of department-related indicators. The information was a sunnary of department data that was tracked and trended on a routine basis (daily and weekly).

P.4.8 Unit Transient Review Program The two most recent transient reports associated with each unit (four reports)

showed that plant management was notified and involved in the assessment and recovery actions in each transient. The most recent report regarding the Unit 2 plant trip from 100 percent power on August 21, 1990, was not firalized (draft)atthetimeoftheinspectio .

Procedure 1000.038, "Significant Event Review Program," provided the l definiticn of a significant event (Section 4.1). The definition was inclusive 1 of an unplanned reactor trip and equipment malfunctions or f ailures (e.g., I manual operator actions in lieu of automatic actions). The procedure addressed the overall reouirements of the report, including the nuclear steam supply system and balante-of-plant responses, additional failures and errors, assessment conclusions, and the significant event review committee report. The more recent unit transient reports included more attention to detail and incre comprehensive documentea evaluations. 111nor discrepancies in the unit l transient reports were identified and discussed with licensee representative The licensee was planning additional cnhancements to the overall unit transient review progra .4.9 Goals and Objectives - Ferformance Expectations A corrprehensive program to develop goals, objectives, and performance expectations at the group and individual levels was in the developn.ent stage The licensee planned to have the performance expectation and monitoring process functioning in 199 The full development and implementation of the overall nucitar department goals and objectives, the Ali0 performance expectations, and the managerrent monitoring ci the estilished goals as a supplement to the All0 business plan were expected-26-

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O to provide an enhanced level of managorent involvernent in the safe and relitble operation of Ali .5 Safety Review The licensee's saf ety review perforriance and the interactions within the plant organizations were controlled and conducted in a it.anner that contributed to plant safet The overall conduct of the members of the safety committces supported and enhanced the licensee staff's ability to safely cperate the plan .5.1 Onsite Review Contrittee The onsite PSC mctbership, policy staternent, and procedures cortplied with the A!!O Technical Specification During the inspection,-the PSC was heavily involved in the review of plant inodification packages for upcoming cutages and procedure revisions resulting f rom a plant. wide erophesis on stricter procedure compliance. The PSC was also reviewing 10 CFR 50.59 saf ety evaluation The PSC chairman inade efforts to assemble inore than the trinimum quorum for emergency reviews, and frequently came to the site with other members to conduct such reviews, even at off hours when telephone reviews night have been conducted. This facilitated a better review and reflected a sincere interest in supporting the plan Regularly scheduled PSC neetings were held twice weekly. Two administrative aids furnished PSC members with documents for review in advance of meetings and promptly distributed meeting minutes. The attendance history was found consistent with requirements of the Technical Specification PSC reviews were extensive and in considerable dept Engineers takirg the initiative to revise procedures and sponsoring proposed changes typically presented them to the PSC for questioning. About half of the PSC's time was spent with procedural revisions initiated by craf tsinen or supervisors who realized that the procedures were incorrect or inccirplete as previously written. The PSC placed high cirphasis on root cause, generic implications, and ensurirg the plant adhered to all design and licensing requirements. The PSC revicws consured large amounts of the members' tirne because root cause and generic implication had not yet become second nature to the licensee's staf Supervisors frequently accompanied their engineers to these PSC reviews. It was not unusual for PSC questioning to require assistance from engineers ot than the presenting engineer. Changes and/or clarifications were sometimes made as a result of PSC review When changes were required, the PSC offered suggestions and support to the engineers. The PSC was firmly insistent on both plant safety and proper I documentation, but its attitude was positive and supportive. Fo safety concerns were identified by the inspectors in this sample of current plant '

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modification packages, 50.59 evaluations, and procedure changes that had received PSC approva j l

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The pSC was effective in ensuring plant safety. The pSC was supportive of the operating staff in emergency reviews and informal training was occurring as a result of the extensive review .

2.5.2 Offsite Review Comittee The offsite safety review committee (SRC) r.icmbership, policy statement, and procedures complied with the AN0 Technical Specification During the inspection period, the SRC met once to review two requests for changes to the Technical Specifications. The documents to be reviewed had been sent out in advance to all comittee r~ embers, so that appropriate review time would be allowe The SRC review was extensive and in considerable depth. The SPC emphasind the need to ensure that the pl6nt complied with all design and licensing requirements and that the requests for changes to the Technical Specifications were clearly worded to facilitate NRC understanding of what exactly was being requested. All SRC members were present along with other involved plant persons. The proposed changes were presented to the SRC by the requesting engineers. The depth of SRC questioning reflected substantial review of related documents before the meeting. Review of SRC minutes from previous meetings also reflected a continuing attention to detai The SRC subcemittee, which provided oversight of the pSC, also met during the inspection. They too received documents to be reviewed in advance to allow i appropriate review time. Subcomittee members were present and their coments reflected prior review of discussion topics. The PSC performance was judged to be effective and acceptable to the oversight subcomittee. This reflected appropriate management attention to pSC performanc '

2.5.3 10 CFR part 50.59 Evaluations The licensee's 50.59 implementing review procedure did not clearly state if approval was recuired by the PSC or supervisor on items determined not to l require a 50.59 evaluation. This possibly could result in failure to provide '

verification of the initial determination. The licensing department agreed to address this concern during the 50.59 procedure revision currently underwa In addition, the pSC meetings demonstrated that the pSC was reviewing ,

determinations with regard to evaluations in accordance with the l licensee's 50.59 polic l The 50.59 procedure did not incorporate the Nuclear Safety Analysis Center /125 guidelines for 10 CFR 50.59 safety evaluations. This guidance could have helped eliminate some of the licensee stoffs problems with performing ,

50.59 reviews. The licensing department was considering this issue during its I process of updating the 50.59 procedur A significant number of 50.59 evaluations that had been approved by PSC were revised af ter the SRC subcomittee's review because the 50.59 evaluation questions had not been completely addressed to the satisfaction of the subcomittee. The PSC chairman and other supervisors had been assigned to work with the reviewers to revise the 50.59 evaluation . _ _ . . .

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o Current satisfactory performance of the PSC and acceptable 50.59 evaluation indicated that this was an effective training mechanisn. No unreviewed safety .

question or Technical Specification violations were hentifie Although PSC reviews continued to identify the need for frequent revisions and/or clarifications and significant managemer.1 and staff resources were being used, the program appeared effectiv .6 Corrective Action Programs The licensee's corrective action prog ams, including root-cause determinations, appeared to be reogressing adequately to support operational safet The qualit, assurance (QA)cepartnentappearedeffectiveinsupporting corrective action programs. Plans were in place to adecuately cover all licensee organizations and the 'L990 audits were on schedul '

Audit reports QAP-10-90 (Corrective Actions), QAP-08-89 (Plant Operations), and QAP-04-90(Training)hadidentifiedthefollowingweaknesse '

The need for an improved central tracking system to replace multiple tracking records maintained by various department * The use of temporary procedures / modifications beyond expiration date *

The limitations of the in-house events analysis group section to complete all its dutie During its training audit, the QA department hat recognized the potential generic implications of operator qualification problems that had occurred et the Brunswick plant and had conducted a review of operator qualification /

training at ANO and provided numerous recommendations for improvemen '

To improve its monitoring capabilities, the QA department was using auditors with technical training and service in the areas being audited. For example two QA auditors were qualified as senior reactor operators at ANO. In addition, the QA department was loaning auditors to other sites to obtain a broader perspective and had borrowed auditors from other sites to subject ANO to outside scrutiny. As.a result, the QA auditors were gaining the respect of other site organizations. Informal audits were being requested, which reflected the desire of site organizations to improve. The QA manager attended daily CRG meetings and was actively involved in prioritizing resolutions. QA staff were participants of the CARB that evaluated planned corrective action before implementation. The QA audit reports addressed compliance issues, and also provided reconnendations for saf ety improvements beyond regulatory

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requirement The licensee had hired the manager of the plant assessment group from another site because of his experience. The manager of the safety assessment section was an Institute of Nuclear Power Operations employee on loan to ANO and was selected because he was experienced in this field. The managcr of the other

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two sections of the assessment group, industry events and in-house events, had l operating experience and a good understanding of root cause, generic-29-

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O 1mplications, and professional developments concepts. All three sections were devoting efforts to appropriate areas of self assessmen The plant assessment group had retaired qualified managers and had directed its efforts to appropriate first priority matters. However, efforts were diluted by the need to concuct extensive trainirt. The group was effective in assessing ANO needs and identifying appropriate corrective actions. Support f rom the training department needed to be improved in order to help the plant assessment group adcress its primary function The industry events group was closely monitoring operator actions with particular attention to situations inyciving core cooling. Weaknesses had been idtntified with regard to a lack of attention to detail and to procedural compliance. This section was developing training plans to improve professional attitudes and still The safety assessrnent section had completed in4 tic 1 assessments and identified weeknesses in the staff qualification program ead code compliance program These weaknesses were again attributed to staff lack of fcniliarity with root cause analysis and lack of attention to detail. 15e safety assessment section manager had conducted classroom training ard planned to continue doing such trainin An irrportaat element of the licensee's self-assessirent program was the CR program. The ln4 cuse events section analysis group was heavily involved with ensuring the effectiveness of the program. CR forms were placed in racks distributed throughout the plant. All sployees were encouraged to use CR CRs were taken imediately to the control room for evaluatio HEA picked up all CRs, made an initial evaluation, and presented its recomendations to plant managers at daily CRG meetings. Each CR was evaluated for significance, pricritized, end assigned to a reviewer. Both plant managers as well as QA, engineering, operations, and lic ensing regulerly attended the daily CRG meeting Within 14 days, the reviewer presented initial evaluations and plans for full resolution to a CARB for concurrence. The plant manager for the unit involved, in-house events analysis group licensing, QA, and appropriate operations, engineering or maintenance persons participated in the CARBs. Approximately 40 percent of CRs were being returned to responsible engineers for revisions primarily resulting from the staff's weakness in the areas of root cause and generic implications. The in-house events staff was identifying specific deficiencies to the responsible engineers and working with them to trate corrections. Although this effort resulted in an effective training program, it was draining significant staffing resource Management was devoting a lot of attention and tiroe to the CR progra Although the program appeared to be effective, the high level of management involvement was appropriate while the staff was deve %piro its knowledge of the progre l-30 l

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.* 9 EXIT 1EETING .

The inspection team and other NRC representatives ret with Mr. N. 5. Carns and other licensee personnel on September 21, 1990, to discuss the scope and findings of the inspection. Mr. L. J. Callen, of HRC, Region IV, represented NRC management et the exit reeting. At the exit meeting, none of the '

information discussed was identified as proprietary. Licensee personnel who attended the exit ineeting are identified in Attachment ,

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e ATTACHMENT A ATTEllDANCE SHEET EXIT MEETING - SEPTEMBER 21, 1990 LICEttSEE PERSONNEL TITLE N. S. Carns Vice President, Operations, AHO K. L. Coates Maintenance Manager, Unit 2 D. A. Daniels Manager, Plant Assessments J. R. Douet Assistant Maintenance Manager, Unit 1 R. K. Edington Operations Manager, Unit 2 R. A. Fenech Plant Manager, Unit 2 J. J. Filicato Manager, Licensing R. C. Gillespie !!anager, Central Support L. W. Humphrey General Manager, Quality G. T. Jones General Manager, Engineering R. J. King Supervisor, Licensing R. Lane Manager, Engineering Standards and Programs J. McWilliams Executive Assistant to Director, Nuclear Operations J. H. Mueller fianager, Maintenance, Unit 1 R. H. Scheide Nuclear Safety and Licensing Special R. A. Sessoms Plant Manager, Central C. N. Shively Administrative Assistant, Materials Managerent J. D. Vandergrift Plant Manager, Unit 1 E. D. Wentz Operations Training Superintendent J. H. Yelverton Director, Operations C. Zinenerman Operations Manager, Unit 1 f

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LIST OF ACRONYMS ALARA As Low As Reasonably Achievable CARB Corrective Action Review Board CEDMCS Centrol Element Drive Mechanism Control System CR Condition Peports CRG Condition Review Group CST Condensate Storage Tank EFW Emergency Feedwater FSAR Final Safety Analysis Feport HVAC Heating, Venting Air Conditioning ,

JO Job order 11AP Maintenance Administration Procedure MP Modification Package P&lD Piping and Instrunentation Diagram ,

PEARS Plant engineering Action Request '

PM Preventive Maintenance POD Plan-of-the-Day PSC Plant Safety Committee RCS Reactor Coolant System SRC Safety Reviev. Committee Tl1 Temporary Msdifications e

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