IR 05000321/1998004
| ML20239A374 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/21/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20239A373 | List: |
| References | |
| 50-321-98-04, 50-321-98-4, 50-366-98-04, 50-366-98-4, NUDOCS 9809090110 | |
| Download: ML20239A374 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
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l Docket Nos: 50-321 and 50-366
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License Nos: DPR-57 and NPF-5-Report No: 50-321/98-04 and 50-366/98-04
[. Licensee: Southern Nuclear Operating Company (SNC)
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l Facill'y:
t E. I. Hatch Units 1 and 2
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Location: P. O. Box 2010 l Baxley. Georgia 31515 i
Dates: June 21 through August 1, 1998 Inspectors: J. Munday. Senior Resident Inspector l J. Canady; Resident Inspector T. Fredette. Resident Inspector
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P. Kellogg, Lead Reactor Inspector, (Sections
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M. Miller, Reactor Inspector G. Hopper. Reactor Inspector, (Section 05)
! L. Hayes Safeguards Inspector, (Sections S2.2-S2.5. S3, S4.2 and S6)
Approved by: P. Skinner. Chief. Projects Branch 2 Division of Reactor Projects
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98o909o110 980821 Enclosure 2 l PDR ADOCK 05000321 0 POR _
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EXECUTIVE SUMMARY Plant Hatch. Units 1 and 2 NRC Inspection Report 50-321/98-04, 50-366/98-04-This. integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of announced inspections by regional. engineering, safeguard, and operator licensing inspector Doerations e' Control room operators demonstrated correct procedural usage, proper annunciator response, three-part communication, proper phonetic alphabet-usage, and peer checks during power reductions on Unit 2. Pre-job briefings were detailed and attended by the appropriate personne Discrepant conditions of minor significance were not consistently documented as deficiencies (Section 01.2).
e -. The sample plan and.the reviewed licensed operator written examinations were satisfactory 'with problems noted with some non-discriminatory questions on the static Part A examinations. The development of the Probabilistic Safety Assessment matrix was noted as a program strength (Section 05.2).
e The conduct and performance of the licensed operator simulator examinations were satisfactory. The evaluators were: thorough in. noting individual-performance discrepancies and the scenarios observed were discriminating. Documentation of individual performance results was satisfactory with the exception of combining observations of the Shift Technical Advisor and licensed operator positions into one grade (Section 05.3).
e Remedial training and evaluations were conducted as required by 10 CFR 55.59. Some documented retraining did not accurately reflect the actual extent of the remedial training (Section 05.4).
e A documentation review for selected personnel who renewed their operating license in 1997 and 1998 indicated that the requirements for i
license reactivation were met (Section 05.5).
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Maintenance e- Licensee management demonstrated conservative decision making by reducing power to troubleshoot and repair the 2B circulating water pump-shaft-bearing sleeve. The plant equipment operator's questioning attitude resulted in a prompt diagnosis of the pump proble Maintenance personnel's attention to detail during the repair activity
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was instrumental in determining that the root cause of the problem was a shaft bearing sleeve set screw that was not counter-sunk (Section M1.1).
e The administration and control of scaffold requi'ements, including con' ttion and evaluation, were not rigidly cornrolled (Section M2.2).
e Maintenance personnel displayed conservative decisnn making, a questioning attitude, and exercised appropriate caucion toward discrepancies identified in the Unit 2 reactor water level instrumentation calibration procedures. Procedure discrepancies were resolved and the recalibration of the water level instruments was accomplished in a competent and professional manner (Section M3.2).
Enainee-ina e The quality of procedures for plant modifications was an engineering program strength as evidenced by the level of detail and precise l instructions. Major modification packages were thorough, detailed. and
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effectively implemented. The assigned engineers were knowledgeable of the design changes and the effect on the systems involved. The design, control, and implementation of major modifications and the modification readiness review program were identified as program strengths (Section l E1.1). l Plant Sucoort e Based on demonstrated ability of alarm station operations in the areas of access control, intrusion detection, monitoring of alarms, and communication capabilities, the inspectors concluded that both the alarm stations' functions and communications systems were effective and met regulatory requirements specified in the Physical Security Plan (PSP)
and implementing procedures. The protected area detection was operational and assessment capabilities were as required by the PSP (Section S2.2. 52.3).
e Both passive and active barriers of the Vehicle Barrier System (VBS) j were in place and operational as required by the PSP and licensee's
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procedures. Frequent adjustments to the airline cable were determined )
to be caused by environmental conditions and the placement of the cable j (Section S2.5). j e The May 1998 PSP submittal met the requirements of 10 CFR 50.54(p).
Security related procedures were adequately written and reflected the requirements outlined in the PSP (Section S3.1. S3.2). -
l e The licensee continued to maintain response capability that could
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intercept the Design Basis Threat and assess the threat as required by the PSP and Safeguards Contingency Plan (Section S4.2).
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Reoort Details Summary of Plant Status Unit 1 operated during the report period at essentially 100% rated thermal power (RTP).
Unit 2 began the report period at 100% RTP. On July 9. power was reduced to approximately 50% RTP to repair the 2B circulating water pump. Power was returned to 100% RTP the following day. On July 25, power was reduced to approximately 80% RTP to perform a control rod pattern adjustment and miscellaneous maintenance activities. Power was returned to 100% RTP later that same day where it remained for the remainder of the report perio I. Operations 01 Conduct of Operations 01.1 General Comments (71707)
The inspectors conducted reviews of ongoing plant operation The inspectors observed shift turnover briefings in the control room and noted that they were generally thorough but informa The inspectors conducted control room tours and observed two power reductions. The inspectors observed ihat the operators were attentive to their duties, responded to annunciators, and properly used procedures. The use of three-part communication was not always consistent, however, errors were generally corrected by other operators. Licensee management continued to emphasize three-part communication Pre-job briefings for work activities were attended by the appropriate personnel and contained adequate detai In general, the conduct of operations was professional and safety-consciou .2 Doerator Performance Durina Power Maneuvers (Unit 2) Insoection Scone (71707)
On July 9 and 25. the inspectors observed operator performance during power reductions to facilitate maintenance and control rod pattern adjustment b. Observations and Findinas
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On July 9. the insoectors observed portions of a reactor power reduction to approximately 50% RTP for maintenance troubleshooting activities associated with the 2B circulating water pump due to unusual pump nois The inspectors observed that operators correctly used procedures, three-
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part communications, the phonetic ' alphabet, and peer checks during the power reductio On July 25. the inspectors observed a power reduction to 80% RTP to perform a control. rod pattern adjustment and miscellaneous maintenance activities. At approximately 92% RTP, annunciator P601-4 (407).
" Service Water. Effluent. Radiation High." actuated _The inspectors noted the operators took the appropriate ~ actions in _accordance with the annunciator response procedure. Although'the annunciator was assumed t be' related to the power reduction, the licensee did not conclusively determine the cause. The alarm cleared after a short period of' tim The inspectors noted that a deficiency card (DC) was not written to document or further investigate the cause of the alarm and discussed this observation'with licensee. management. The. inspectors were informed that a DC probably should have been written to document the alarm-anomaly and that increased emphasis was being placed on the initiation of DC's for less significant issues. The inspectors had identified other recent' examples where minor issues were.not documented as DC The inspectors observed that the pre-job briefing for the work activity was'well conducted and contained the appropriate _ level of detail. The
- inspectors observed several occasions where three-part communication war, not used and other operators present quickly made corrections to enforce the communication expectatio Conclusions Control room operators demonstrated correct procedural usage, proper annunciator response, three-part communication, proper phonetic alphabet usage, and peer. checks. during power reductions for corrective maintenance and' control rod pattern adjustments on Unit 2. Pre-job briefings were detailed and attended by the appropriate personnel. The inspectors observed that-discrepant conditions of minor significance were not being consistently documented as deficiencie .3 Preparation for Unit 2 Refuelino Outaae -(60705)(71707)
The inspectors reviewed selected procedures to be used in the upcoming Unit 2 Fall 1998 refueling outage to verify technical adequacy. Among the procedures reviewed were the following:
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.- 30AC-0PS-003-05: Plant Operations. Revision (Rev.) 18
. 34AB-G41-001-2S: Loss of Fuel Pool Cooling. Rev. 2
. -34AB-G41-002-2S: Decreasing Rx Well/ Fuel Pool Water Level. Re . 34FH-0PS-001-0S: Fuel Movement Operation. Rev. 18 L .
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. 42FH-ERP-012-0S: New Fuel and New Channel Handling. Rev.- _-_ _ _
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The inspectors verified that the procedures contained steps to ensure that the Technical Specifications (TS) and Technical Requirement Manual (TRM) requirements were addressed with regard to shift marning, spent fuel pool storage water level, the receipt, inspection, and . storage of new fuel, and the movement of fuel during the refueling outage. The inspectors also verified that the Fuel Movement procedure, 34FH-0PS-001-OS, Rev. 18 addressed the requirement to have a senior reactor operator with the exclusive duty of directly supervising refueling platform activitie The inspectors performed a routine tour of the refueling floor on July 23 and observed that areas of the refueling floor designated as foreign material exclusion areas were properly established. The refueling floor was clean and uncluttere The inspectors concluded that the procedures reviewed in preparation for the Unit 2 refueling outage were adequate to accomplish the intended
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purpos Operational Status of Facilities and Equipment 02.1 Enaineered Safety Feature System Walkdowns a. Insoection Scooe (37551) (71707)
The inspectors performed a review and walkdown of the Torus-to-Drywell Vacuum Breaker portion of the Primary Containment Isolation Syste b. Observations and Findinas The inspectors verified that control switch line-ups and indications were correct at both the control room and local panels for the vacuum breakers on both units. The inspectors reviewed the recent history of deficiencies for these vacuum breakers. Over the previous two years, eight deficiencies involving vacuum breakers failure to close after testing, were identified. Operators used plant procedures to correct the problem The inspectors reviewed maintenance and inspection practices specified by the vendor for the vacuum breakers and discussed the deficiencies with maintenance and engineering personnel. The proposed corrective actions were also discussed. The inspectors determined that vendor maintenance practices and procedures were incorporated into applicable procedures. The vacuum breaker failures were caused by failures of the l vacuum breaker pallet to actuate the closed limit switch on the vacuum breaker valve seat.
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4 l The inspectors reviewed procedure. 52PM-T48-007-0S " Torus to Drywell Vacuum Breaker Overhaul." Rev. 3, and observed that the-procedure did not . include any adjustments for the position limit switches. The-inspectors noted that engineering personnel were aware of this issue and
. believed that this contributed to the significant number of " failure-to-close" problems. The licensee was reviewing this procedure for possible
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Equipment operability and material condition for accessible portions of
.the vacuum breaker equipment were acceptable and testing requirements were met. The licensee had identified procedure deficiencies related to vacuum breaker limit switch adjustments and was reviewing the procedure for possible_ revisio .2 Review of Safety Relief Valve (SRV) Setooint Chance Insoection Scoce (71707)
The inspectors reviewed the licensee's process for changing the annunciator.setpoint for SRVs. The inspectors also reviewed procedure 34S0-B21-002-0S, " Safety / Blowdown Valve Leaking Annunciator Setpoint Change",~ Rev, 0. and the_ data package for the setpoint changes for the
"L" SRV on Unit b, Observations and'Findinas On July 20, the licensee raised the tailpipe temperature limit for the 4 Unit 2 "L" SRV from 275 F to 300 F to allow reset of the main control I room annunciato The inspectors reviewed the data package and the !
controlling procedure for raising the setpoint. During the review the )
inspector determined that the setpoint had previously been raised from 230 F to 275 F in March 1998. The procedure allows the setpoint to be raised in two increments; from 230 F to 275 F and from 275 F to 300 The inspectors reviewed the strip chart recorder and noted that the i temperature' had not taken a step increase but had rather increased i gradually over a period of time. The licensee stated that the SRV had l been weeping .slightly since the last surveillance test that required the i
. valve.to be cycled. The inspector noted that the "L" SRV indicated 275.3 F. The tailpipe temperature readings for the other SRVs on Unit 1 and Unit 2 were well below 230 F. The inspectors verified that a L maintenance work order had been initiated to repair the "L" SRV. The
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5 Conclusions The setpoint changes for the Unit 2 'L" SRV tail pipe temperature j annunciator were made in accordance with applicable procedures. The i weeping SRV did not challenge the cooling capability of the suppression pool or plant operation Operator Training and Qualification 05.2 Samole Plan and Written Examination Insoection Scooe (71001)
The inspectors reviewed the licensee's procedures for development of a sample plan and the sample plan used for the last biennial written examination. The inspector also reviewed one Senior Reactor Operator (SRO) and one Reactor Operator (RO) examinatio Observations and Findinas j The inspectors found the sample plan to be satisfactory and in conformance with existing procedures. The inspectors found, however, that the governing procedures for test development from the sample plan were limited in detail. Conformance with acceptable standards such as those contained in NUREG 1021, " Operator Licensing Examination Standards for Power Reactors,~ was dependent upon the experience and training of the licensee's current examination developer l The inspectors noted that the licensee had performed an analysis of the training / testing material versus Probabilistic Safety Assessment (PSA)
data to identify where important events, equipment operability, and operator actions that are significant contributors to core damage frequency were included in requalification training. The analysis revealed that most concerns identified by the PSA were included in requalification. The licensee had constructed a matrix of PSA items versus training material which included Job Performance Measures (JPM),
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simulator guides, and simulator evaluations. The written examination i question bank was not yet included in the analysis. PSA items not covered were identified and proactive measures were taken to develop training / testing material to include the items. The inspectors identified this as a program strength.
, The review of the written examinations revealed that the majority of static exam questions were satisfactory. However, some questions lacked discriminatory value in that an operator could eliminate two or three l possible answers with little use of the simulator. The inspectors determined that the Part B examination questions were satisfactor I
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6 Conclusion i The inspectors concluded that the sample plan and the reviewed written ,
examinations were satisfactory with problems noted with some non- i discriminatory questions on the static Part A examinations. The development of the PSA matrix was identified as a strengt .3 Simulator Examinations i Insoection Scooe (71001) 1 The inspectors reviewed the licensee's administration of simulator examinations to ensure that the licensee effectively conducted operating examinations in accordance with 10 CFR 55.59. "Requalification." Observations and Findinas i
The inspectors reviewed and observed two performance mode scenarios (SE-00009-11 and SE-00026-06) that were administered to one operating cre i The inspectors also observed evaluator and crew debrief session Evaluator comments were appropriate and consistent with NRC ,
observations. The scenarios were challenging and discriminating, j The inspectors reviewed several individual performance evaluations where individuals performed the shift supervisor (SS) and shift technical advisor (STA) positions. The inspectors noted that the licensee combined the comments and grades for the shift supervisor position along with those of the STA position to arrive at a final competency i determination and pass fail decision for the annual operating exam required by 10 CFR 55.5 The STA evaluation should not be combined i with the grades for the SS since it is not a position that requires an i annual operating exa Remedial training for STA position deficiencies, as determined by the facility evaluators, may be appropriate, howeve it should be addressed outside the scope of the 10 CFR 55 conditions of maintaining license requirements. Licensee personnel stated the program would be reviewed for possible change ; Conclusion The inspectors concluded that the conduct and performance of the
. simulator examinations were satisfactory. The evaluators were thorough in noting individual performance discrepancies and the scenarios observed were discriminating. Documentation of individual performance results' was satisfactory with the exception of combining observations of the STA and licensed operator positions into one grad _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ - _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ -
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05.4 Remediation a. Insoection Scooe (71001)
The inspectors reviewed licensed operator Remediation Training and associated procedures to ensure that an appropriate remedial training program was developed. implemented, maintained, and documented as required by 10 CFR 55.5 b. Observations and Findinas The inspectors reviewed requalification failures and events for 1997-1998 that required remediation. The inspector found that the operators were remediated and that the remediation was documente The inspectors noted that there was no published guidance or instructions on the development of remediation packages (content and structure) or for the level of detail required to document an individual's remediation. As a result. the inspectors found that the remediation packages differed significantly in content and level of detail. This practice provided little valuable feedback to the operator or to the overall progra c. Conclusions The inspectors determined that the licensee conducted remedial training and evaluations as required. However. some documented retraining did not accurately reflect the actual extent of the remedial trainin .5 Reactivation of Part 55 Licenses a. Insoection Scooe (71001)
The inspectors reviewed the licensee's records to ensure that personnel operating the controls of the facility were meeting the requirements of 10 CFR 55.53 for reactivation of a licens b. Observations and Findinas The inspectors reviewed the " License Active Status Documentation After Extended Ineligibility" for operators who had reactivated their license in 1997 and 1998. The inspectors noted that the licensee had procedures l in effect which required independent verification of the watch standing i under instruction, plant tour and training requirements, and management
[ review prior to placing an operator on the active list. The inspectors identified several minor administrative record keeping discrepancies.
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8 Conclusions The inspectors concluded that. for personnel reviewed who renewed their operating license in 1997 and 1998, all met the requirements of 10 CFR 55.53 for reactivatio Miscellaneous Operations Issues (92901)
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(Closed) VIO 50-321/97-11-02: Late 10 CFR 50.72 Notification for Unit 1 Enaineered Safety Feature Actuation (Closed) VIO 50-321. 366/97-11-03: Inadeauate Corrective Actions for Late 10 CFR 50.72 Notifications The licensee responded to these violations in correspondence dated February 20, 1998. The corrective actions included counseling the involved individuals and providing training to operations personnel. In addition. procedure 00AC-REG-001-05. " Federal and State Reporting And Federal Document Posting Requirements." was revised to include clarifying information provided in NUREG-1022. The licensee also plans to revise the Unit 1 and 2 Technical Requirements Manuals and Final Safety Analysis Reports to place automatic primary containment isolation valves in " groups" to assist in identification. The inspectors concluded that the licensee's corrective actions were satisfactor II. Maintenance M1 Conduct of Maintenance M1.1 Reoair of 2B Circulating Water Pumo Shaft Bearina Sleeve Insoection Scooe (62707) (92902)
The inspectors observed maintenance troubleshooting. reviewed applicable maintenance work orders (MW0s), and held discussions with licensee personnel with respect to problems on the 2B circulating water pump shaft upper bearing sleev Observations and Findinas ;
A plant equipment operator (PEO) discovered an unusual noise from the 2B circulating water pump. Maintenance troubleshooting activities revealed that the pump's shaft bearing sleeve was out of position and adequate cooling to the bearings could not be assured. Operations management decided to reduce reactor power and remove the pump from service to correct the problem.
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Maintenance personnel determined that one of the two set screws which held the sleeve in place had become loose. A similar problem had I previously occurred on May 22, 1998, on the same pum The. inspectors reviewed MWO 2-98-1553 used to repair the recent problem i and noted that maintenance personnel had installed a third set screw as '
recommended by the vendor. The vendor informed the licensee that the
- screws should be counter-sunk and they subsequently were. However, i during this work. activity, maintenance personnel discovered that the i other set screws were not counter-sunk. The licensee concluded that the root cause of the problem was that the set screws were not counter-sun This type of problem had not previously-been. observed on the other- !
circulating water pumps: however, maintenance personnel stated that the-other. pumps would be monitored closely for this type of problem. The licensee also stated that the other pumps would be inspected at the earliest opportunity to insure that the set screws are counter-sunk into
'the shaf The inspectors reviewed the Maintenance Rule (MR) Scoping Manual and verified that the circulating _ water system was properly reviewed and !'
evaluated for MR applicability. The licensee was still evaluating whether or not the recent problem was a maintenance preventable
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Licensee management demonstrated conservative decision making by I reducing power to troubleshoot and repair the 2B circulating water pump shaft. bearing sleeve. _ The PE0's questioning attitude resulted in a prompt diagnosis of the pump problem. Maintenance personnel's attention to detail during the repair activity was instrumental in determining that the root cause of the problem was a set screw that was not counter-sun f
- H2 Maintenance and Material Condition of Facilities and Equipment i
M2.1 Temocrary Reoair on the Unit 2 Hiah Pressure Coolant In.iection (HPCI) ]
Drain Pot Drain Line 1 Insoection Scoce (37551) (62707) l I
l The inspectors monitored activities associated with the repair of a ,
thru-wall leak on the Unit 2 HPCI drain line to the main condenser. The - !
inspectors' reviewed Special Procedure 34SP-040898-AB-1-25, "HPCI Drain
. Pot Drain Line Isolation." Rev 0, and the applicable MWO. 2-98-160 ~The inspectors attended the pre-job briefing, observed portions of the work activity, and held discussions with maintenance personne ;
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10 Observations' and Findinas On July 13.-the licensee observed water accumulation on the floor of the HPCI room. . Investigation by the licensee revealed a piping leak on a drain pot drain line to the main' condenser prior to its penetration into the torus area. The inspectors toured the area and observed water standing on the floor and steam escaping from the vicinity of the lea MWO 2-98-1600 was developed to repair the lea On July 16. after
. determining that the pipe insulation did not contain asbestos, the
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licensee removed the insulation from around the leaking piping although the repair was not scheduled to be made for several days. The leak worsened after the insulation was removed and the licensee repaired the leak the following da :The inspectors attended the pre-job briefing for the repair and observed that the briefing was detailed with particular emphasis given to the notes and cautions of procedure 34SP-040898-AB-1-2S. The inspectors observed that Health Physics personnel at the briefing provided adequate '!
information relating to the radiation work permit radiation control '
practices, and personnel safety regarding heat stres A similar thru-wall leak on this line was temporarily repaired in April, 1998, as a non-code repair. The licensee stated this piping was being eroded'due to steam / water flow and was scheduled for replacement during !
the Fall'1998 refueling outage.
' Conclusions Maintenance personnel promptly repaired the leak on the HPCI drain pot 4
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drain line after removal of insulation caused the leak to worsen. The inspectors concluded the drain line leak did not affect the operability .
of the HPCI syste i M2.2 Scaffold Control Issues
- Insoection Scope (62707) i The inspectors reviewed procedure 50AC-MNT-003-05 " Scaffold Control."
l Rev. 4. and assessed the implementation of the associated administrative requirement Observations and Findinas During the course of plant walkdowns, the inspectors identified several minor discrepancies. A scaffold erected between the Unit 2 safety related plant service water strainers was wedged tightly between the
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OS..was performed to assess the seismic impact of the scaffold. A '
scaffold in the Unit 2 control rod drive (CRD) pump diagonal was secured in only one place by being tied to the 2B CRD pump suction filter and i there was no identifying tag attached to the scaffold. Several scaffolds did not have toeboards-installed. In general, procedure requirements for toeboards on scaffolds exceeding 6 feet in height was not being adhered to,
,- 'The inspectors found that, in many cases, no formal documentation existed for completed engineering evaluations related to scaffold Evaluations reviewed by the inspectors consisted of electronic mail messages, or other informal documentation. This observation was discussed with licensee management. The licensee initiated a-procedure change request requiring formal documentation of scaffold engineering evaluations. The inspectors noted that a potential existed for scaffolding to affect safety-related system and components. In this case no safety-related equipment was adversely affecte Conclusions These examples of failure to follow procedure were identified as a violation of minor significance, and are not subject to formal enforcement action. The inspectors concluded that the licensee's process' for administering and controlling scaffold requirements was not rigidly- controlled. One engineering evaluation was not completed, other
' evaluations were informal, and protective toe-boards were not always installe M3 Maintenance Procedures and Documentation M3.1 Surveillance Observations'(61726)
The inspectors observed all or portions of the following surveillance ;
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. 57SV-G11-005-1S: Drywell Floor Drain Sump Level Functional Test and Calibration. Rev. 2 e 34SV-R43-006-1S: Diesel Generator 1C Semi-Annual Test, Rev.12 ;
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No deficiencies were identifie M3.2 Unit 2 Reactor Water level Instrument Recalibration .
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l l Insoection Scooe (62707) l The inspectors-reviewed maintenance activities to backfill and .
recalibrates the Unit 2 Reactor Water Level Floodup Range !
instrumentation,
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'The inspectors reviewed MWO 2-98-1500 for-backfilling the reference legs and changing the calibration ranges for level transmitters 2821-N027 and 2C32-N010, which provide reactor water level floodup range indication in
. the control room during unit outages and during emergency condition The floodup indications were about 10-12 inches greater than the narrow
. range level due to elevated instrument reference leg temperatures caused by the loss of a drywell cooling fan in May 1998. Previous reference let backfilling had not corrected the disparity. The inspectors reviewed temporary calibration data provided by corporate engineering to adjust the ranges on the floodup transmitters and the temporary modification for changing.the instrument calibrations. No discrepancies were identifie The inspectors observed technicians preparing to conduct the backfill and recalibration during a weekend shift. The technicians and operations personnel' questioned several steps in the unit calibration procedures for both instruments regarding the placement of jumpers during instrument removal from service and the new calibration data for the transmitters. The inspectors also reviewed procedures 57CP-C32-007-2S " Reactor Level Transmitter / Indicator Loop Calibration," Rev. 4.for transmitter 2C32-N010, and 57SV-821-020-2S " Reactor Wide Range Level Indication." Rev. 0..and observed that updated calibration data had not 1
.been incorporated into the procedure. The technicians decided to '
postpone the recalibration activity until the procedural discrepancies were resolved. The inspectors determined that this cautious approach and questioning attitude was appropriate for a procedure that introduced increased risk for a reactor tri 'The inspectors verified that the procedure discrepancies were subsequently resolved and the instruments recalibrates according to l procedure using the new calibration data. Following calibratio I reactor water level floodup range indications were observed to be l consistent with narrow range level indication j Conclusions i The inspectors concluded that maintenance personnel displayed conservative decision making, a questioning attitude, and exercised appropriate caution toward discrepancies identified in the Unit 2 Reactor Water Level instrumentation calibration procedures. Procedure-discrepancies were resolved and the recalibration of the water level ;
instruments was later accomplished in a competent and professional !
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III Engineering El Conduct of Engineering-El.1 Desian Control-Process Insoection Scoce (37001) (37550)
The inspectors reviewed selected temporary, minor, set point, and major .
modifications-packages, that were developed and controlled by !
engineering to verify plant procedures and regulatory requirements were met. The inspectors conducted field walkdown inspections and inspected
. selected portions of the design modification installations. Engineering audits and backlogs were reviewed to assess licensee performance in problem identification and corrective action Observations and Findinas-
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The inspectors reviewed the applicable procedures for plant modifications and concluded that the quality of the procedures was a
. strength as evidenced by the level of detail and precise instruction The inspectors reviewed selected audits of engineering and technical support. The audit findings indicated engineering was implementing an effective program. The inspectors verified engineering efficiently supported plant operations, e Major Modifications The inspectors reviewed selected Unit 1 modifications and Design Change Requests (DCRs) including.the following:
DCR 86-318, " Secondary Containment Penetration Power Cable Separation" DCR 96-30, " Replace HGA and HFA Relays" DCR 95-051 "HPCI to torus from CST transmitters" DCR 96-038 "EDG 1C Series Conversion" DCR 96-0404 " Torus ECCS Strainer Replacement" ;
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The inspectors noted that these major modification packages were j thorough, detailed and effectively implemented. The assigned engineers were knowledgeable of the design changes and the effect on the systems involved. Procedural requirements were met including PM testing and required documentation was revised. The inspectors concluded that the
. licensee *s readiness review program, which provided a review of
, modification packages prior to implementation to ensure that evaluations j and' determinations contained in the package are still valid, was identified as a program strengt l l
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o Minor Design Change (MDC). Temporary Modification (TMM), and Set point Modifications The inspectors review of MDCs. Temporary, and Set Point modifications included the following:
Unit 1 MDC 95-5062. Monitor Steam Cycle / Isolation Temperature ~
Unit 1 and Unit 2 MDC 95-5030. " Install Davit Cranes ~
TMM 98-005 " Refueling Interlock LS" Unit 1 TMM 98-06 and TMM 97-02. " Jumper Contacts in Drywell Chiller Panels A (B)~
Unit 1 TMM 97-35. " Rod Drift Alarm" Unit 1 Set point modification 95-6001. " Flow Biased APRM Rod Block" Unit 1 Set point modification 95-6004. ~0ffgas Condensate Return Pump Discharge Pressure" Unit 2 Set point modification 95-6006. "RBCCW Heat Exchanger Low Outlet Temperature" The inspectors noted that the modification packages were complete and effectively implemented. The inspettors did not identify any safety concerns. The licerisee had a good program to file, control, and track these modifications. The program coordinator was knowledgeable in auditing and tracking these modifications to ensure they were properly implemented and closed ou Conclusion The inspectors concluded that the quality of procedures for plant modifications was a strength as evidenced by the level of detail and precise instruction The inspectors concluded that the major modification packages were thorough, detailed, and effectively implemented. The assigned engineers were knowledgeable of the design changes and the effect on the systems involved. Procedural requirements were met. The design control, and implementation of major modifications were identified as a program strengt The inspectors concluded that the licensee's readiness review program, which provided a review of modification packages prior to implementation to ensure that evaluations and determinations contained in the package l are still valid, was a program strength.
I The inspector determined that the licensee had designed, controlled, and implemented Minor. Temporary and Set Point modifications in a well-managed program. The inspectors concluded that this was a program strength, i
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E8 Miscellaneous Engineering Issues (92903)
E (Closed) VIO 50-321.366/96-06-08: Incorrect Set ooints For Molded Case Circuit Breakers The licensee responded to this violation in correspondence dated July 10, 1996. The inspectors reviewed the completed work orders and verified that appropriate corrective actions for setting the correct setpoints were complete The inspectors verified that the drawings and the Motor Control Center data sheets were revised to reflect the correct information. The inspectors concluded that the licensee had implemented adequate corrective action E8.2 (Closed) VIO 50-321. 366/97-02-05: Measures Did Not Assure That ADolicable Reoulatory Requirements And Desian Basis Were Soecified In Procurement Documents For NUMAC PRNMS Parts The licensee responded to this violation in correspondence dated May 5, 1997. The inspectors reviewed a General Electric (GE) letter dated April 8,1997, and verified that the required codes and standards had been confirmed by the vendor as requested by a Change Order Requests, dated April 4. 1998. The inspectors concluded that the licensee had implemented adequate corrective action E8.3 (Closed) URI 50-321. 366/97-12-11: Timeliness Of Identification Of SLMCPR Errors This item concerned the timeliness of identification of the Safety Limit Minimum Critical Power Ratio (SLMCPR) generic analysis possibly being non-conservative when applied to actual core and fuel designs. GE had determined that a cycle-specific analysis of SLMCPR would remove some possible/non-conservatism of the generic SLMCPR analysis. The licensee, when informed of the potential for non-conservatism, imposed a temporary penalty of .03 in the SLMCPR for both units. This was proven to be conservative when the cycle specific analysis was verified. A review of the licensee's actions and correspondence was conducted by the inspectors. The inspectors concluded that the timeliness of the licensee's discovery of these errors was appropriat E8.4 (Closed) URI 50-321. 366/97-12-12: Timeliness Of Amendment Of Technical Specifications This item concerned the conditions during which the Rod Block Monitor
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(RBM) should be operable. The GE safety reload licensing reports failed l to clearly address the condition under which the RBM should be operable.
[ The licensee was informed by GE of the possible non-conservatism caused j
! by not having the RBM in service on March 3. 1997. The licensee i submitted Licensee Event Report 50-321/97-03, describing the discrepancy
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- 16 between the GE Rod Withdrawal Event analysis, the TS requirements, and the corrective actions that had been taken. The licensee submitted a TS amendment. request on May 9, 1997, to change the operability requirement for the RBM. The inspectors concluded that the licensee took the appropriate action upon notification and that earlier identification could not have been reasonably expecte IV Plant Sucoort R Radiological Protection and Chemistry Controls R1.1 Review of Radiation Worker Control Deficiencies - Insoection Scoce (92901 (92904)
The inspectors reviewed circumstances surrounding a deficiency when a plant equipment operator (PEO) entered a high radiation area on an incorrect radiation work permit (RWP). Observations and Findinas On July 10 two PE0s entered the Unit 2 condenser bay for a leakage inspection ~. One of the PE0s received an * Exceeded Allowable Dose Rate" alarm when logging out of the radiological controlled area access compute Subsequent licensee examination revealed that the PE0 had entered the condenser bay on the incorrect Radiation Work Permit (RWP).
The inspectors verified through discussions with both operations and health physics (HP) personnel that the PEO. in the process of logging onto the intended High Radiation RWP for the condenser bay entry, had
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changed his current operations " blanket" RWP to the intended RWP by changing the last digit on the access computer touch screen but failed to also change the first digit. The RWP used was more conservative than the proposed high radiation RWP. The HP expectation to verify the printed RWP ticket for this PE0 was not me The inspectors verified that all other necessary actions by HP personnel to support the condenser bay entry were accomplished. Full HP oversight was performed for both PE0s in the condenser bay. The total dose
, received by the PE0 using the incorrect RWP was 10 mrem and well within l limits of the correct RW The inspectors determined that corrective actions taken by the
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' operations and HP departments, including counseling the PEO. determining
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contributing root causes, and issuance of a " Rad Bulletin" publicizing the incident for all plant personnel, were sufficient to prevent recurrenc The inspectors determined that recent corrective actions implemented 'as a result of previous violations in this area would not have prevented this occurrence.
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c ., Conclusions Personnel error and,a lack of attention to detail contributed to an individual signing onto an incorrect RWP. Although this RWP incident was the second recent RWP problem, the' inspectors concluded that-management corrective actions were_ appropriate to prevent recurrenc This repeat failure to follow procedure occurrence was ' identified as a
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violation of minor significance and was not subject to formal enforcement actio : S2 -~ Status of Security Facilities and Equipment (71750)
S2.1 Routine Security Observations On July 11. the inspectors observed that security personnel performed a thorough search of a tow vehicle and trailer that entered the protected area. The inspectors also observed that the driver of the tow vehicle was properly escorted into the protected area by security personne The inspectors toured the protected area and observed that the perimeter fence was intact and not compromised by erosion nor disrepair. The
. fence fabric was secured and barbed wire was angled as required by the licensee's Physical. Security Plan (PSP). Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an individual. The inspectors observed that personnel and packages entering'the protected area were searched either by special purpose detectors or by a physical patdown for firearms, explosives and contraban Badge issuance was observed, as was the processing and escorting of visitors. Vehicles were searched, escorted and secured as described in applicable procedure The inspectors concluded that the areas of security inspected met the requirements of the PSP and applicable procedure S2.2 Alarm Stations and Communications Insoection Scooe (81700)
.The inspectors evaluated Central Alarm Station (CAS) and Secondary Alarm
' Station (SAS) operations to determine if the licensee was effectively monitoring security operations. Additionally, the inspectors determined-if communications were continuous and appropriat . Observations and Findinas !
' Commitments for alarm station operations and communications were specified in.the PSPi Rev. May 1998, and procedures 82SS-SEC-031-55.
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'" Alarms Station Operations." Rev.- 2, and 82SS-SEC-003-55 " Security Communications," Rev. Review of security operational activities in the CAS and SAS and monitoring of security communications confirmed that the alarm' stations were equipped in accordance with commitments contained in the PSP, and were capable of communicating and effectively controlling the securit force during routine and contingency operations. Alarm station operators'were knowledgeable of their duties, appropriately trained, and capable of effective utilization of access control. intrusion detectio monitoring of alarms, and communication equipment available in the alarm
. stations. The inspectors verified that the CAS and SAS were independent and diverse to the extent that no single act could remove the capability of the security force to call for assistance or otherwise respond to a threat. There were no operational activities observed in the alarm stations that would~ interfere with the execution of response to alarms or other contingencies. Intrusion detection equipment annunciated audibly and visually, as required. The alarm stations were continually manned by trained alarm: station operator Conclusions Based on demonstrated ability of alarm station operations in the areas of access control, intrusion detection, monitoring of alarms, and communication capabilities. the inspectors concluded that both alarm stations' functions and communications systems were effective and met regulatory requirements specified in the PSP and implementing procedure S2.3 Protected Area Detection and Assessment' Aids Insoection Scone (81700)
The inspectors verified that the licensee *s protected area detection was operational as described in the PSP and that assessment of the protected
- area was adequate to assess an intrude Observations and Findinas Protected area detection and assessment requirements were outlined in the licensee's PSP.. The inspectors observed operation in the CAS and
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noted protected areas alarmed as require Closed camera television consisting of fixed and pan-tilt-zoom was used by the: licensee to provide assessment. This assessment was supplemented
'with foot and vehicle patrols. Through observation, the inspectors determined that switching sequences were independent at the CAS and SAS and were displayed on at least two monitors.
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< Conclusions The inspectors determined that protected area detection was operational and assessment capabilities were as required by the PS '
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S2.4 Testino and Maintenance l
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, Insoection' Scone (81700) I
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The inspectors ascertained that testing and maintenance of security related equipment was completed as required by the PS i
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b; Observations and Findinas *
l The PSP required the licensee to test security equipment once every .
seven day Procedure 82IT-SEC-001-55. " Testing Security 1 Systems / Equipment." Rev.6 outlined the licensee's operability testing i process which assured security equipment was functiona The inspectors observed quarterly testing of two perimeter zones and determined the tests were conducted in accordance with the procedur ,
Both zones alarmed appropriately. Also, the inspectors reviewed j operability test records for the period of June 25 to July 1.1998, to j determine if the licensee was conducting operability testing on equipment at the required frequency. Records reviewed indicated the licensee had conducted tests as require The inspectors reviewed the latest Maintenance Work Orders for security '
related repairs and determined those requests were entered into a tracking system. The time required to implement corrective maintenance for security related equipment was minima Conclusions The licensee conducted testing and maintenance .for security related equipment as required by the PSP and the implementing procedures.
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Maintenance repairs on security related equipment was timel )
l .S2,5 Vehicle Barrier System l Insoection Scooe (81700) The inspectors verified-that the vehicle Barrier System (VBS) remained in place and operational as required by the PS i L___--_-____--____-_-____ - -
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l 20 Observations and Findinas The inspectors performed a war.down of the VB Exterior concrete filled bollards were in place and appropriately spaced. Other passive barriers in place included airline cable, water and land structures, and jersey barriers, which were appropriately anchored. The inspectors noted that the airline cable had been frequently adjusted and in l conjunction with the licensee, determined the sagging" of cable was due L to weather conditions and the actual placement of the cables. Active !'
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barriers were operational and in good working condition, as. evidenced by minimal problems since the last inspection. Compensatory measures !
. utilized by the licensee for degraded VBS components were in accordance I
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with the PSP. The licensee completed the required annual inspection of i -the VB ;
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Both passive and active barriers of the VBS were in place and operational as required.by the PSP and licensee *s procedure S3 Security and Safeguards Procedures and Documentation S3.1 Security Proaram Plans l
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' Insoection Scooe (81700)
The inspectors reviewed the last PSP change submitted pursuant to
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10 CFR 50.54(p) to determine if the requirements were met.
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The licensee submitted a PSP revision, dated May 1998, to clarify portions.of the December 1996 subinittal, as described in NRC Integrated Inspection Report Nos. 50-321. 50-366/97-11. Clarification areas
- . discussed were the use of designated vehicles and certain compensatory r
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measures. The licensee's May 1998 submittal clearly documented these
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[- The' inspectors ' determined that the May 1998 PSP submittal met the l- 4 requirements of 10 CFR 50.54(p).
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.21 S3.2 - Security Procedures- Insoection Scoce-(81700)-
- The inspectors determined if procedures implemented the requirements stated in the licensee's PSP; Observations and Findinos The inspectors reviewed selected procedures and' determined that they were' adequately written to reflect the provisions of the PSP. The licensee continued.to review and upgrade procedures on a frequent basis to remove redundancy and better. clarify the requirement Conclusions The licensee's security related procedures were adequately written and reflected the requi_rements outlined in the PS S4 -Security and Safeguards Staff Knowledge and Performance S4.2 Resoonse Capabilities Insoection Scoce (81700)
The inspectors verified the licensee's response capabilities to-determine if the strategy was sound and the response force could intercept the design basis threat (DBT) as required by the PSP and Safeguards Contingency Pla b; Observations and Findinos
- The inspectors reviewed the licensee's response strategy and determined that it was sound and would protect vital equipment from the DBT, and that the guard force.could interject themselves and assess the threa .
The inspectors noted the. response force was trained in squad tactics in both attack and defensive positions. The licensee conducted unannounced drills in order to determine the adequacy of the response forc (pnClusions' ,
Tne licensee continued to maintain response capability that could intercept the DBT and assess the threat as required by the PSP and Safeguards Contingency Pla .s h
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S6; Security Organization and Administration-S6.1 Manaaement Sucoort and Effectiveness (81700)
The inspectors determined that management supported security needs as evidenced by reducing the amount of overtime and providing additional support where neede .V. Manaoement Meetinas Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion' of the inspection on August . The licensee acknowledged the findings presente The inspectors asked the' licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee Anderson, J. , Unit Superintendent Betsill. J., Assistant General Manager - Operations Curtis. S.. Unit Superintendent lCoggin. C.. Engineering Support Manager Davis. D. Plant Administration Manager Fornel. P.. Plant Maintenance and Modification Manager
- Fraser. 0. . Safety Audit- and Engineering. Review Supervisor Googe. M., Performance Team manager Hammonds. J. .- Operations Support Supe'rintendent Kirkley. W..-Health Physics and Chemistry Manager Lewis. J., Training and Emergency Preparedness Manager Madison. D., Operations Manager Moore. C.. Assistant General Manager - Plant Support Roberts. P., Outages and Planning Manager Thompson.-J., Nuclear Security Manager Tipps. S., Nuclear Safety and Compliance Manager Wells, P., General Manager - Nuclear Plant l INSPECTION PROCEDURES USED IP 37001: 50.59 Safety Evaluation Program IP 37550: Engineering IP 37551: Onsite Engineering IP 60705: Preparation for Refueling
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IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71001: Requalification Inspection
.IP 71707: -Plant Operations IP.71750: Plant Support Activities LIP 81700: ' Physical Security Program for Power Reactors IP 92901: Followup - Operations
.IP 92902: Followup - Maintenance / Surveillance IP 92903: Followup - Engineering IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-321/97-11-02 VIO Late 10 CFR 50.72 Notification for Unit 1 Engineered Safety Feature Actuation (Section 08.1)
50-321, 366/97-11-03 VIO Inadequate Corrective Actions for Late 10 CFR 50.72. Notifications (Section 08.1)
50-321. 366/96-06-08 VIO Incorrect Set Points for Molded-Case Circuit Breakers (Section E8.1).
50-321. 366/97-02-05 VIO Measures Did Not Assure that Design Basis
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were specifled.in procurement documents (Section E8.2). {
50-321. 366/97-12-11- URI Timeliness of Identification of SLMCPR
. Errors (Section E8.3).
50-321. 366/97-12-12 URI Timeliness of TS Amendment (Section E8.4). )
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