IR 05000324/1989034
| ML19332E882 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/30/1989 |
| From: | Dance H, Levis W, David Nelson, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332E879 | List: |
| References | |
| 50-324-89-34, 50-325-89-34, NUDOCS 8912130102 | |
| Download: ML19332E882 (27) | |
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. UNITED STATES '
" [[ h @ Mooq#o,^ . NUCLEAR REGULATORY COMMISSION [ , [ REolON il k g; - 101 MARIETTA STREET.N.W.
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ATLANTA. oEORot A 30323 ' . 's.a./ . . j - Report No. 50-325/89-34 and 50-324/89-34 Licensee:- Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602-i
- l p-Docket No. 50-325 and 50-324 License No. DPR-71 and DPR-62
~ f ' . Facility'Name: Brunswick 1 and 2 " m W Inspection Conducted: October 2 - October 31, 1989 i.
Inspector:_f A fm d f/ A, ///30/89 _.
W. H. Ruland g/ " // ' ' Dat'e Sig'ned j //Md/87 am i! W. Levis N f f Date-Signed " Vu&/A ku,_ _/ 30Y8 7-b D. 1 Nelso - ' f f/ ate fgned
h Approved By: W 7/ 30 [[
_ o 'H,- C. Dance,\\Section Chief Daf.e SitJned Division of Reactor Projects .f'i SUMMARY jj Scope: q . J ' This routine safety inspection by the resident inspectors involved the~ areas of .;
. maintenance-observation; surveillance observation; operational safety .j li verification-; followup of Diagnostic Evaluation Team (DET) concerns; onsite ' ; ~ . Licensee Event Report review; in cffice Licensee Event Report review; receipt, j stcrage, 'and handling of emergency diesel generator fuel oil; and~ action on j .,
i, . provious inspection findings.
f M.. Results:
. In the areas inspected, one violation considered for escalated enforcement and ! three non-cited violations were identified.
Nine unresolved items were also l JM identified.
' y _ involved inadequate
= The violation being considered for escalated enforcement , design control of the service water system with multiple examples leading to , inoperable nuclear service water headers in each unit for an extended period, ' ,. 'i (paragraph 6.c).
The three non-cited violations were previous DET findings, (paragraphs 5 and 6.b).
8912130102 891130 PDR ADOCK 05000324
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< , ~dfsthe;nine.~unresolveditemsrand' thirty-four,inspectorfollowupitemsidentified-F Linithisi report,f six unresolved items and: thirty-two inspector' followup-items
p- ' wereLidentified as a1 result of the regionalE staff's. review: of Lthe.DETJ.. report,- . , f; ;-;
- (paragraph' 5).
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'< (TYo ' clear.ance problems 'were reported,- with the= licensee's ~initialt followup on -.a
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- previousi clearance: problem found; to.be inadequate. Continued weakness in:this i
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- area' warrants increased-management attention,- (paragraph 4.c).
' - ,. s . ~ . > Th'e licensee l plans /to clean-up dried resin in a' locked high: radiation area,La
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, ' " .pos.itiveimove.ijHowever,ca reportability questi6n:regarding this' event' remains; , ' j(paragraph ~4.d).
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. , Administrative control of-overtime:for operations _ personnel-improved since last L - > (6 / inspected.,7(paragraph 4).
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! ' . . REPORT DETAILS ! 1.
Persons Contacted Licensee Empicyees ' e K. Altman, Manager - Engineering Projects l
- F.2Blackmon, Manager - Operations
_
- S. Callis, On-Site Licensing Engineer'
' <T. Cantebury, Manageri-Unit 1 Mechanical Maintenance - ~ G. Cheatham, Manager,- Environmental & Radiation Control i
- M. Ciemnicki, Security
. R. Creech, Manager ;Vnit 2 I&C Maintenance l W. Dorman, Manager - QA '
- K. Enzor. Manager Regulatory Compliance J. Harness General Manager - Brunswick Nuclear Project
,
- W Hatcher, Supervisor - Security
' . A. Hegler, Supervisor - Radwaste/ Fire Protection i .
- R. Helme, Manager - Technical Support-
-J. Holder, Manager - Outage Management & Modifications (OM&M)
- L, Jones,L Manager - Quality Assurance (QA)/ Quality Control (QC)_
_.
- M. Jones, Manager - On-Site Nuclear Safety - BSEP s
_ R. Kitchen,, Manager - Unit 2 Mechanical Maintenance . J.-O'Sullivan, Manager - Training .
- B. Peeler, Manager - OM&M Planning and Scheduling
~
- R.'Poulk,' Supervisor -' Regulatory Compliance
'
- W. Simpson, Manager.- Control and Administration
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- S. Smith, Manager - Unit 1 !&C Maintenance
- R. Starkey,, Project Manager - Brunswick Nuclear Project
. '
- R. Warden, Manager - Maintenance
' - ' B. Wilson, Manager - Nuclear Systems Engineering-
- 0ther
- licensee-employees contacted ; included construction craftsmen,
- engineers, technicians, operators,- office personnel, and security force ' members.
' ' t -* Attended the~ exit interview ' Acronyms and abbreviations used in-the report are listed in paragraph 11.
2. - Maintenance; Observation (62703)
' i The inspectors observed maintenance activities, interviewed personnel, and reviewed records to. verify that work-was conoucted in accordance with > ! approved procedures, Technical Specifications, and applicable industry -[ codes and standards. The inspectors also verified that: redundant , r U ~ components _ were operable; administrative controls were followed; tagouts I were; adequate; personnel were qualified; correct replacement parts were ! ! , D ~ [i Q.
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o -, j' .i used; radiological controls were proper; fire protection was adequate; i , P quality control' hold points were - adequate and observed; adequate ' , L post-maintenance testing ' was performed; and independent verification
, requirements were implemented. The inspectors independently verified that . " ' selected equipment was properly returned to service.
~; ' Outstanding work requests were reviewed to ensure that the licensee gave k priority to safety-related maintenance. The inspectors observed / reviewed , F portions of the following maintenance activities.
, W r $ DR-89-0110 $LC Heat Trace l - [ PM-86-002 Acceptance Test for 2-SW-V18
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f PM-89-026 Service Water System Inspection and Repair; l " SW Pump Strainer Blowdown Lines Replacement - Unit 2
i-Violations and deviations were not identified.
3.
Surveillance Observation (61726) , . f1 The inspectors observed surveillance testing regt. ired ' by Technical l - Specifications. Through observation, interviews, and record review,. ;he p inspectors - verified ' that: tests conformed to Technical Specification .* j-requirements; administrative controls were. followed; personnel were ' qualified; instrumentation was calibrated; and data was-accurate and + complete.- The inspectors independently verified selected test results and ' p proper return to service of equipment.
[- The inspectors witnessed / reviewed portions of the following test
activities: g , L OPIC-PI-004 Calibration of Robertshaw CR0 Accumulator Gas , L, Pressure Gauges p IMST-LKDET-24R Primary Containment Atmosphere Radiation Monitors Channel Calibration . . ., ' Violations and deviations were not identified.
y-4.
Operational Safety Verification (71707) The inspectors verified that Unit 1 and Unit 2 were operated in compliance with Technical Specifications and other regulatory requirements by direct observations 'of activities, facility tours, discussions with personnel, . reviewing of records and independent verification of safety system status.
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. . ' ' ' q 3 r1 a i The inspectors verified that control room manning' requirements of 10 CFR 50.54 and the Te:hnical Specifications were met. Control operator, ' shift supervisor, clearance, STA, daily and standing instructions,- and jumper / bypass logs were reviewed to obtain information.concerning operating trends and out of service safety systems to ensure that there were no conflicts with Technical Specifications Limiting Conditions for b Operations. Direct observations were conducted of control room panels, instrumentation and recorder traces important to safety to verify operability and that operating parameters were within Technical Specifica-- tion limits.- The inspectors observed shift turnovers to verify that t continuity of system status'was maintained, The inspectors verified the status of selected control room annunciators.
! Operability of a selected Engineered Safety Feature division was verified weekly by ensuring that:- each acco.,$1ble valve in the flow path was in ' L its correct position; each. power supply and breaker was closed for components that must-activate upon initiation signal; :the RHR subsystem g' ' cross-tie valve for each unit was closed with the power removed from the valve operator; there was no leakage of major components; there was proper lubrication;and cooling water available; and a condition did not exist-e ' which_ might. prevent fulfillment of the system's. functional requirements.. Instrumentation essential to system actuation or performance was verified
operable by observing on-scale indication and proper instrument valve ~ lineup, if accessible.
i The inspectors verified that the licensee's HP policies / procedures were followed. ThisLincluded observation of HP practices and a review of area surveys, radiation work permits, posting, and: instrument calibration.
The inspectors verified that: the security organization was properly manned and security personnel were capable of performing their assigned functions; persons and packages were checked prior to entry into'the PA; vehicles. were properly authorized, searched and escorted within the-PA; persons' within the PA displayed photo identification badges; personnel in ! vital areas were authorized; and effective compensatory measures were " employed when required.
The inspectors observed plant. housekeeping controls, verified position of certain containment isolation valves, checked several clearances, and . verified the operability of onsite and offsite emergency power sources.
The. inspectors also reviewed selected overtime records for operations -
! personnel to ensure that licensee's practices were consistent with the requirements of l Generic Letter 82-12. No discrepancies were found. -This L is'an improvement from previous reviews which found that the licensee:had not maintained sufficient controls with their overtime approval process.
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Res; dent Action Item 89-34, Reactor Operator License Verification L This Action Item was the result of an occurrence at another nuclear L power plant where a senior reactor operator with an inactive license L assumed the watch as the operator-at-the-controls.
An individual's i license may become inactive due to changes in the operator's ability.
' to perform licensed duties. An operator's ability could be affected .by physical fitness, mental capacity, changes in behavior patterns, E compliance with requalification program requirements, substance-abuse, etc., and may be identified by the license holder, management, _ < ! training, or others.
In accordance with Regional office direction, an inspection was performed _ to determine the administrative controls that would prevent an operator with.an inactive. license from willfully or inadvertently ' assuming licensed duties.
The inspector determined that no formal program existed, tiowever, the licensee's informal process has been L effective. When 4 change in license status of a. potential watch-stander becomes known, operations management notifies the appropriate shift operating supervisors who control duty assignments.
If the ' status. change was due to.non-conformance with training requirements, training management informs operations by phone and memo.
Likewise, this is done for physical disabilities found during periodic physical e b exams.
Phone notification is made by the training staf f upon- -determination of the disqualification. -The licensee stated that there are no known occurrences when this process has failed to prevent non qualified personnel from performing -licensed duties in ' f: recent. years.
In 1984, a licensed reactor operator returned to licensed duties
'af ter failing an in-house upgrade exam.for senior reactor operatcP.
' Licensed R0s in.SRO upgrade training are not administered annual , requalification exams - successful-completion of SR0 upgrade exams satisfies the requirement for RO requalification exams.
Upon completion of the SR0 upgrade program, it was not recognized that his failure also voided the requalification credit that had been anticipated. This case-was the sub/,ect of Violation 325,324/85-01-01 discussed in Inspection Report 50-325,324/85-01. As a result, the licensee revised training instructions to provide definitive guidance for ' assuring that apnropriate-requalification requirements are identified and administered. The Violation was closed in Inspection Report 50-325,324/87-12.
The inspector verified that two recent disqualifications (failed requalification exams) were properly handled such that neither of the operators stood a license-required watch during the time they were disqualified.
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J ^ L The shif t operating supervisors are' not provided with documentation of current license status of. operators. Upon a known disqualifying ' ' event, individuals are simply removed from the duty schedule.
y [ If an individual's license status is questioned by operations management due to training or physical exam deficiencies, the t y" D training staff must be called in to review records in. order to resolve the question.
The licensee estimated that this could. be accomplished within a few hours if the appropriate training personnel were not onsite and much' quicker if present.- ,, . Operators with active licenses, who are not in the normal shift L, rotation, are required to stand five 12 hour watches per quarter in " accordance with 10 CFR 55.53(e) to maintain their license as active.
h ' The documentation of this process - is formalized by Training.
n Instruction TI-208, NRC Licensed Operator Quarterly Reporting P.equirements.
No discrepancies were noted in this instruction.
The inspector concluded that no administrative safety net existed to prevent unintentional or willful assumption of licensed duties by a disqualified licensed operator.
The on-shift operations management has no means in the control room to independently verify that on- ' watch-personnel are duly licensed.
Since 1984, no violations were identified concerning unqualified personnel performing licensed duties.
b.
LOCA Logic Initiation ' o On October.22, 1989, I&C technicians performing a surveillance in Unit 1, caused an inddvertent LOCA logic initiation.
Meter leads c.
were placed ' across the wrong terminal points when checking for ' voltage and resistance. This caused the start of the IA-Core Spray Pump and all four Emergency Diesel Generators, tripping of four - drywell chiller fans,.and isolation of instrument air to the drywell.
" The l&C. technicians realized their error and immediately informed the control room. The systems were returned to normal within 15 minutes.
No injection to the-vessel occurred as the low pressure permissive for core' spray injection was not' satisfied. Unit 1-was at full power at the time'.- The licensee made an appropriate four hour report to the NRC, Further inspection of this event will be conducted pending receipt of the Licensee Event Report.
c.
Clearance Problems During a routine Unit 2 control board walkdown on October 2,1989, the inspector discovered that two danger tags on valve control switches were misplaced.
Tags 4 and 8, of local clearance 2-1082, . I g i
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y.. - _ b were annotated for Main Steam Isolation Valves B21-F0220 and
- L B21-F0280, respectively, but were -Interchanged the tag for - y B21-F0220 was hung on the, control switch for B21-F028D and vice ! versa. These switches are in the same general location on the Unit 2 -- , f.
control-board. These valves are-the inboard and outboard MSIVs for t c steam line D.
The tags had been hun:. on September 13, 1989. Both !' valves were in the correct position.. (shut).
Therefore, the ' interchanged tags had no dirsect safety significance. Unit 2 was ir, > cold shutdown at the time.
The inspector informed the on-duty.
( control operator who properly informed the shift. foreman, i Subsequently, the tags were removed and rehung correctly in accordance with Al-58. Equipment Clearance Procedure. Coincidently, the on-duty control operator performed the independent verification p ' when the tags were initially hung on September 13. He stated that
inattention to detail was the cause of his error.
Numerous other operator.s who stood watch between September 13 and October 2, also , failed to detect the error. Of greater concern, however, is how this i occurrence relates to a previous misplaced tag problem.
On- ' > September 21, 1989, the inspector - discovered a tag. annotated for. Service Water Valve 2-E11-F075 hung on an adjacent switch for . 2-E11-F073. (This event is discussed in Inspection Report 89-26 and , , k was the subject of Violation 324/89-26-02).
Since the MSIV tags were hung on September 13 - they were in place ! only a few feet away when the SW tag - problem was discovered on
p September 21.
This indicates that the licensee, following discovery of the:SW tag problem, did not-look for other misplaced tags on the -
control board.
This lack of rudimentary corrective action allowed , the MSIV tags to remain undetected.
When the MSIV tags were ' discovered by the inspector on October 2, control room personnel then , searched the control board and found other. tag problems on non-safety
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related equipment controls. The NRC considers immediate corrective-L action. of this sort to be fundamental.
Discrepant conditions'that
' may exist elsewhere in the plant should be quickly. reviewed for-i generic applicability and dispositioned accordingly.
Searching the i control board for other misplaced tags was the minimum immediate corrective action to be taken.
, Al-58 requires that danger tags be properly positioned and affixed.
+' . Independent verification of tag placement is required for some systems, including nuclear boiler (the. MSIVs).
These requirements l were not properly implemented for the MSIV danger tags discussed above. This constitutes a violation of TS 6.8,1.a. Failure to Follow Procedure.
This violation is considered to be a second example of: the violation involving the SW tag problem mentioned above (Violation 324/89-26-02), and as such, should be addressed in the response to that violation. This determination is based on the concurrent nature i and similarity of the two violations.
' (: > ' During this reporting period, the licensee discovered that a Service
Water Valve, SW-V120, had been removed from the system with a danger
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- , tag attached to it (i.e., the valve was part of a clearance boundary). At the close of the reporting period, this event was - still under investigation by ths licensee.
pending further-inspection, ' this event will be. identified as an * Unresolved.
, ' Item: Service Water Valve, SW-V120, Removed.from the. System With Danger Tag Attached, (325/89-34-43 and 324/69-34-43).
!? d.
Radwaste Cleanup Phase Separator Tank Room i[ ' During a routine tour Of the radwaste area and discussion with the.
J radwaste-supervisor, the inspector was informed of significant ' radiological conditions that exist in their cleanup phase separator, p.. tank room.
This room contains two tanks which receive the expended ' resin from the RWCV system for both Units 1 and 2.
A survey of.the '
room conducted by thn licensee on September - 21, 1989, found-approximately six to twelve inches of dried resin on the floor with " ' radiation levels as high as 40 R/hr on contact with the tank.
J Contamination levels just inside the door were 200,000 dpm.
The cause of the resin spilling onto the floor is not known at this time.
, L-The licensee plans to' have this space decontaminated.- p i The inspector concluded that the radiological conditions.in tre room L do not pose a safety -problem at this time.
The room is clearly - i marked as a high radiation area and kept locked. Access to the room is not required for normal operation of the power plant.
Routine' radiological surveys are conducted outside the. area to-note any p change in radiological conditions. The licensee should be commended, l.
in fact, for' staying aware-of related industry issues and starting the clean up_ process, ' i E The inspector did question the licensee concerning the reportability of these radiological conditions to NRC under the reporting require-g ments of 10 CFR 20.403. These reporting _ requirements state that-the NRC must be notified of any event involving byproduct, source, or L special nuclear material that causes or threatens to cause damage to F property in excess of $2000,00.
More immediate notification is - required for ' events where the cost exceeds $200,000,- The expended resin 19 byproduct material as defined in 10 CFR 20.3.
, !- The licensee is currently developing a corporate. position on the reporting requirements of 10 CFR 20.403.
The licensee's initial assessment concluded that the "as found" conditions in the room were not reportable.
Further review of this issue will be conducted by the Regional. radiological protection specialists.
This item is identified as an * Unresolved Item: Radwaste Cleanup Phase Separator i Tank Room Reportability, (325/89-34-44 and 324/89-34-44).
- An Unresolved Item is a matter about which more information is required
to determine whether it is acceptable or may involve a violation or ' deviation.
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, . e.. Plant Incident Report 89-028, Suction Plug Installation-L The ~. licensee issued PIR 89-028 Suction Plug Installation, on.
i October 30, 1989.
That report described a September 17, 1989; event
- where !the Unit 2 refuel crew attempted -to place a recirculation L
nozzle f plug in-the nozzle that provided a flow path for the RHR @ system operating.in shutdown cooling.. The licensee determined that- " the event was caused by personnel error and an unclear procedure.
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- The. inspectors did not have time to review the event' af ter issuance p
of the PIR;. therefore, this item will be an Unresolved Item pending L further NRC ~ inspection:. Nozzle Plug Installed. in - Wrong Reactor Vassel Nozzle, (324/89-34-45).
- A second~ example'of a previous violation was identified.
5.. - Followup of Diagnostic Evaluation Team (DET) Concerns (92701)- The NRC Acting Executive Director for Operations directed the staff to review the DET report, dated August 2, '1989, to identify any violations or areas that. required further inspection. Region II, including the resident' inspectors, have completed that review.
The; results of. the resident. inspectors' review are listed below by DET report section number.
The' resident staff reviewed the following report , sectiont; - ' 2.1.1, Items 1 - 6, 8 - 10
2,1.2, Items 1 - 7, 9 - 11 - 2.1.4, Items 2 and 3 - 2.1.5, Items 5 and 6-- ! - >2.1.6, Items 1 - 3 - , 2.2, 3.2.2.5, 3.2.2.7, 3.2,4, and 3.2.5.1 , - , The regional staff. reviewed-those DET report sections not listed above.
'Their-review produced a list of Unresolved Items and Inspector Followup Items which are included in the exit interview paragraph.
Those items [ will be reviewed during-. future inspections.
' .Those sections listed below were identified as having described potential- .
' violations and.were selected for detailed review by the resident staff.
' The remaining sections under resident staff review were determined not to contain enforcement issues.
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Section 2,1.2.3_- Control Room Log Entries Rudimentary The inspector reviewed events related to several.logkeeping , . deficiencies noted by the DET. For the specific events evaluated by.
! the team.on April 11, 1989 and April 15, 1989, log entries made by the Unit 1 C0 were incomplete and - did not' provide sufficient - . information'to adequately describe these events. On April 11, 1989, . ' the!CC's log did not state the cause of the 1A RFP trip, did not state that the pump was restarted and tripped a second time, and did t . not state that RWCU was manually isolated.
The inspector did find ~ L' that these events were adequately logged on April 13, 1989.
On April 15, 1989, no log entry was made in the Unit-1 C0's log to indicate problems-experienced with the SJAE and the resulting change of a pressure controller setpoint.
logkeeping _ requirements for operators are provided in Administrative-Procedure, AP - Vol. 1.
Section 4.1.8.a of Revision 119, which was in effect during the above events, requires that log entries be , complete, accurate and in sufficient detail to be fully understand- , able to a non-technical person.
Section 4.1.9.a specifies the i ' evaluations / events to be recorded in the C0's log.
The starting
and t, topping of ma.ior equipment, the change of auxiliary system '
configurations, and setpoint changes are among the events noted that
' must be legged.
, 0: The licen'see failed to properly implement their Administrative P_rocedure requirements for logkeeping for the Unit 1 C0's log for the , !- events occurring on April 11, 1989 and April 15, 1989.
The log entries were. nonexistent in the case of the SJAE problems experienced and incomplete for the 1A RFP trip, the mannual isolation of RWCU, and the restart and second trip of the 1A RFP.
Although adequate logkeeping is a -somewhat subjective evaluation, it is essential that logs provide a complete and accurate recording-of plant events so
' that problems can be identified and corrected. The log entries made on April 11', 1989 and April 15, 1989 did not accomplish this purpose.
Subsequent to the DET noting the deficiency in the logkeeping area,
the licensee re-emphasized the importance of proper logkeeping through meetings with both-the operations manager and the plant general manager.
In addition, licensed operators retraining'will be revised by' January 1990 to place increased emphasis in this area.
TS 6.8.1.a requires procedures specified by Regulatory Guide 1.33, November 1972.
Administrative Procedures addressing logkeeping are specified in Regulatory Guide 1.33, Section A.8. The failure to follow' the logkeeping requirements specified in AP Vol.1, Revision - -119,- is a Violation: Inadequate Logkeeping, (325/89-34-02).
, However,_ this NRC identified violation is not being cited because the criteria specified in Section V.A of the NRC Enforcement Policy were satisfied.
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F h . [ -Section 2.1.2.7 - Stan' ding Instructions Not Deleted /Old E The DET determined that Operations Standing Instructions were.not being used effectively to provide instruction to the operating staff.
L Specifically, Standing Instructions were an unnecessary burden, not I-indexed for easy use,- and not administratively controlled.
Two , b active standing instructions had already been incorporated into procedures..These should have been deleted when they were no. longer.
necessary; V U, The inspector reviewed the Standing Instructions controlling-document, General Operating Instructions, Operating Guideline OG-1, as well as the - current Standing Instructions log.
The inspector determined that the Standing Instruction status sheet, in accordance with OG-1, adequately serves as an index. Each Standing Instruction L is serialized with-a unique number and is listed sequentially on the-status sheet along with dates of issue and removal, and a brief description of the item. The inspector could not identify the two r.
OET ide_ntified Standing Instructions ' that should have been deleted.
[ However, based on the significant number of-long term Standing Instructions deleted during.1989, it is likely that some had been unnecessary for some time and could have been deleted sooner. 0G-1 contains' administrative controls to delete expired Standing , ~ Instructions.
Therefore, unnecessarily retained Standing Instruc-tions are not in strict compliance with OG-1. However, the inspector concluded that -Standing Instructions that become obsolete by i incorporation into procedures simply represent duplicate information, F-provided that no contradiction exists between the instruction and tha resultant procedure change.
Prior to the DET, the large number of act.ive Standing Instructions was-criticized by the inspectors, the licensee's Cresap review, and control room personnel. A revision to OG-1, dated March 24, 1989, added a^.'itional aaministrative controls to force internal review of t long term instructions for which no expiration date was established.
This has contributed to the decrease in the number of active instructions from t.pproximately 56 in January, 1989, to approximately y 12 in October, 1989.
Control room personnel interviewed consider
- this a manageable number, whereas previously it was burdensome for operators to recall important information from numerous instructions - some being several years old.
For example, on February 15, 1989, an unexpected RWCU isolation occurred that could have been anticipated had a one year old Standing Instruction been remembered by the operators.
The inspector concluded that the specific concerns identified by the OET do not constitute a violation.
However, further inspection of the Standing Instructions program is warranted. Inspector Followup . i
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p , , -Item:' Followup on Implementation and Effectiveness of standing H[ . Instructions: Procedure Revision in IAP Item D20, (325/89-34-28 and 324/89-34-28).
~ ' u s L .Section 2.1.4.2'- No Set P.trformance of TS Surveillance Related to TS L 3.8.1.1 The inspector reviewed DET findings in the-surveillance testing area.
. The team. stated that the.offsite to onsite electrical distribution system was not periodically tested as required by the plant's - - Technical Specifications. TS 4.8.1.1.1.b requires that each of the required independent circuits between the offsite transmission
s network and the onsite class IE distribution system shall -be b demonstrated OPERABLE every 18 months during Shutdown by manually
transferring unit power supply from the normal circuit to the t: . alternate circuit.
2 - The' licensee determined that this testing requirement did not apply to BSEP based on their interpretation of what constituted the two-required physically independent circuits between the offsite transmission network and ' the onsite class IE distribution system.
! * The licensee considered the four feeders to the switchyard as their required : physically - independent circuits.
Since these feeders were e .normally energized, the licensee concluded that they had four normal L sources no alternate sources, and that. the requirement to transfer
- from normal to the alternate supply did not apply. Their position on this subject was documented in Technical Specification Interpretation-85-08, dated May 2, 1985.
The. licensee had also submitted a TS
- amendment request to NRR in February 1988, to delete the testing requirement.
. Based on discussions with NRR concerning their amendment request,-the licensee was informed that their interpretation ' of. their two-independent offsite sources was incorrect.
The normal source of , offsite power is from the UAT and the alternate source from the SAT.
Since these discussions, the licensee-has withdrawn their amendment request.
In addition, the licensee updated the Technical Specifica- - tion bases for the electrical po'wer systems section to clarify the f~,= testing requirements of TS 4.8.1.1.1.b.
This change, approved by NRR .on May 25, 1989, states that the testing requirement can be satisfied by transferring loads from the VAT to SAT while performing a unit shutdown.
- The manual transfer from the VAT to SAT is a normal evolution
performed during unit shutdown.
Section 5.2 of 'GP-05, provides the method to perform the power transfer and documents the successful performance of the steps.
Based on the inspector's review of GP-05 .. <
j + . i - .
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,
i i ! . . l and the recent bases change to Technical Specifications for.
l electrical power systems,.the inspector concluded that the licensee
i, has been performing the required TS. testing and that no violation of , i: TS 4.8.1.1.1.b occurred.
- Compliance.with GDC-17 was not reviewed by the. inspector.
NRR's: .; review of DET identified GDC-17 compliance issues is considered an i Unresolved item: Review Electrical Distribution System Re-evaluation ! of IAP Item DI-2 and-Resolve GDC-17 Co.npliance Issues Identified in
( .DET Report, (325/89-34-04 and.324/89-34-04)..
l .
The -inspector also reviewed WR/J0s from November and December,1988, ~ ' to determine if. the ACTION Statement for Technical Specification
3.8.1.1,a was met ~when.one of the two independent offsite sources, i y L SAT or UAT, was out of service. This Technical Specification, which
is applicable _ in-operational conditions 1, 2 and 3, requires that, , when one - offsite source is inoperable, the remaining source be ! verified operable within 2 hours and every 12 hours thereaf ter.
In ! addition, the diesels'must be run within 24 hours and every 72 hour-thereafter.
' From a review of the computer database, the inspector found only one
WR/JO for the time in question.
NR/JO 88-BDCY1 was initiated on ' November 8,,1988,.to have the electricians assist in the hanging of a I clearance for the Unit 1 UAT.
The WR/JO was approved for planning purposes on November 9, 1988.
The inspector was unable to find the.
L original.WR/JO or clearance,which would have shown the time and date- . - the.- clearance was. authorized to be hung and the work to commence.
The licensee maintains their non-safety records for o'nly six months.
[ A review of the WR/JO on the licensee's _ AMMS showed ' that the
electricians charged time to the WR/JO on November 13, 1988.
' Unit I reached cold shutdown at 4:50 a.m.
on November 12, 1988, Technical-Specification 3.8.1.1.a would no longer be applicable after I this time. Based on the information available to the inspector, and since time was charged to the job on November 13, 1988, the inspector- . concluded that the licensee did -not violate Technical Specification
3.8.1.1.e while ' working on the UAT in November' and December,1988.
Section 2.1.'4.3 - No Stroke Time Testing of PCIVs
The inspector reviewed LER 1-89-16, the DET findings that prompted the licensee's investigation and subsequent reportino, -and the licensee's DET ret,ponse concerning the findings.
LER ;-89-16, the , DET findings and the licensee's response are discussed in detail' in > paragraph 6.b of this report.
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. de - .Saction 2.3.5.5 - ONS Not-Reviewing Industry /NRC Advisories and DNS Not - Yerifying Reduction of Hamar Errors ~ The inspector reviewed DET concerns related 'to the ONS organization and their. failure to review industry advisories and NRC issues as
required by TS 6.2.3.1, and their failure to' perform activities to , ensure. that human errors are reduced as much as practicable ~ as
required by TS'6.2.3.2.
l As noted in tb DET report and confirmed by-the inspector, the ONS group reviews' NRC Information Notices, INPO SOERs and SERs and , published.AEOD data. ONS reviews NSSS/ Vendor information only if.the- ' , technical support-organization, which initially reviews the vendor . recommendations, determines that the recommendations will not be , implemented. ONS must then approve this deviation from the vendor!s. ' . recommended actions, NRC Bulletins'and Generic letters are reviewed by the regulatory compliance orgaization and not reviewed at' all by ONS.
TS 6.2.3.1 requires that NRC issues and industry advisories be-reviewed, so :that areas for improving facility safety can be identified.
The E inspector determined that present ONS practices (review of NRC Information Notices, INPO SOERs and SERs, and the review of nonimplemented vendor recommendations), accomplish this-requirement,..NRC Bulletins and Generic Letters require specific actions; by the licensee with review-and approval by NRC.
The ONS . decision not to' review these documents seems reasonable since the-areas for improving facility -safety have already been identified by j ,NRC.
Reviewing only nonimplemented vendor recommendations also is appropriate since, in these cases, the licensee has determined'not to implement some. actions that could affect plant safety. ONS procedure . . ONSI-1 Revision 5, which covers this area, is misleading in that it I states that NSSS/ Vendor Service Bulletins are screened by ONS as part of the OEF process. This item was discussed with i.he manager of ONS.
P The inspector. also reviewed ONS methods of reducing human errors.
~ The' inspector confirmed the DET finding. that no specific program or - ' procedure; existed to accomplish this requirement; The licensee.
stated in their DET response that this requirement was accomplf shed N in the normal; performance of ONS duties.
The inspector reviewed , selected ONS Special Studies, System Assessments and OEF reports and - com:luded that ONS had made specific recommendations to reduce human errors. The placing of warning signs at single failure scram points, HpC1 procedural changes made to prevent turbine overspeeding, and the periodic publishing of DEF ouage remindnes are o few examples of - ' specific recommendations made by ONS to reduce personnel errors.
Based on this review, the inspector concluded that ONS was satisfying TS requirement 6.2.3.?, >
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' . 14' ' + l > k I s h, 'Section 2.1.5.6 - QA Not Performing 100% Review of Technical Specification l Surveillance Requirements Every Three Years ' i .. . > 'As stated.in CP&L's: response to the DET, the licensee admits that the . samping. plan established for the BIP required review -of TS 't surveillance-requirements was flawed.
Thtt ' i s, CP&L failed to; i E continue-to meet the regulatory requiremeM-contained in the BIP order.
However, by letter dated October 26, 1987, the licensee- ' I.
- informed the NRC that they were planning to. change the scope of the TS requirements review, as well as other BIP Action Item III periedic
.i g p reviews.
, + ey' -The licensee' documented -in the above letter that no programmatic
problems. wcre identified during the "100% surveillance" intervals.
" . While the programs audited under BIP Action Item III - 1, 2 and 3 had > - shown no major problem and the licensee was technically justified'in changing-the surveillance, no formal change to the order requirement ' L ' was issued by. NRC, Thus, a violation of the BIP order occurred.. However, since the licensee had informed the NRC of their plans, and: have instituted changes-to their surveillance program under IAP ' 'r Item D1, and to their ISI program under IAP Items D29 and E6, this . ; vi.olation will not be cited. This is a Non-Cited Violation: QA Not Performing 100% Review of TS Surveillance Requirements, (325/89-34-46
and 324/89-34-46), c ( -The only' outstanding BIP issue not addressea by the-licensee related ! to the failure to maintain in place regulatory commitments made to the NRC, CP&L.will be asked to respond to this issue under separate
cover when the NRC considers the BIP order status.
! L Section'3.2.2.5 - No Fire Watches
h The DET documented two examples of the licensee failing to recognize ' all-applicable TS LCOs. These cases had previously been documented - .in-LERs 88-027.and 89-06.
These LERs are discussed in detail and - closed 1n paragraph 6.a of this report.
t Two non-cited violations were identified.
6.. Onsite Review of Licensee Event Reports (92701) The below listed' LERs were reviewed to verify that the information . provided met NRC reporting requirements.
The verification included
e adequacy -of event description and corrective action taken or planned, existerce of. potential generic problems and the relative safety L ! - significance of the event.
Onsite inspections were performed and . concluded that necessary corrective actions have been taken in accordance with existing requirements, license conditions and commitments.
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(CLOSED) LER 1-88-27, Failure to Establish ~ Fire Watch Following Intentional Opening of Unit 1 Reactor Building Airlock Doors for.
-' Outage Passage.
LER - 1-89-06, Failure to Establish Required Fire Watch' Following Intentional Accessing. of Unit 1 Reactor Building > Airlock Doors for Outage Related Passage and Reactor Building i [ Ventilation.
These LERs report two occurrences of failing to post TS required fire - watches on.the Reactor Building 20 foot elevation personnel-airlock .! ' doors.
The primary function of the doors is to provide a. secondary u containment. boundary. _However, they also serve as a fire barrier.
, In:these two cases, control room personnel did not recognize the dual-( function of the doors when they were intentionally blocked open.
' ~ When-initiating secondary containment LCOs per TS 3.6.5.1, the fire , barrier LCO per TS 3.7.8 was overlooked. Consequently, the required , fire watches were not established, t The first case occurred on November 15, 1988, with Unit 1 outage in
_ progress.
The doors were blocked open at 2:40 p.m., with an I appropriate secondary containment LCO in ef fect.- At 3:30 p.m. on I Noveuber 16, 1988, an Operations Fire Protection Specialist on routine rounds noticed the doors had been blocked open, but did not
have the proper associated fire barrier penetration LC0 and hourly fire watch in accordance with TS.3.7.8.. A security guard was stationed on the Turbine Building side of the airlock.to monitor ' personnel access during the entire period.
t , ' The second. case occurred on March 9,1989, during the same outage.
The doors were.open from 2:30 p.m. until 11:30 p.m., when it was discovered by an operations shift foreman. As before, an appropriate i
- secondary containment LC0 was in effect, but no LC0 or fire watch had j
been establi.shed with respect to fire barrier requirements. Again a security guard was stationed at the airlock during this period.
! ! In each case, the practical aspects of a fire watch were met (i.e., ! .the murity guards along with outage related personnel using the acces> could be. expected to detect and report fires in.the vicinity).
Upon discovery of the condition,' the doors were immediately closed, . LCOs for TS 3.7.8 were activated, and hourly fire watches established > prior to reopening the doors.
Corrective action for the first case' , consisted of retraining operations personnel. With the occurrence of
the second case, the licensee concluded that retraining alone was not.
' adequate corrective action. By June 16, 1989, conspicuous signs had been placed on all secondary containment boundary / fire doors that require annotation of LCO numbers prior to blocking open the door.
' There have been no known occurrences of missed fire barrier ' requirements on dual function doors since placement of the signs.
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(CLOSED) LER 1-89-16, Failure to Perform Technical Spe:.lfication
. Required Stroke Time Testing on PCIS Valves.
" . [ The inspector reviewed the LER, the DET findings - that. prompted.the !
- licensee's investigation and subsequent reporting, and the licensee's
, DET response concerning the finding. The DET found.that the-licensee'
, ' had omitted several valves from their list of ' containment isolation , j! 'C valves listed ;in 5D-12, that were listed in the plant's Technical- ' p .. Specifications.
Since the valves were not listed in:SD-12, which is ' ' the licensee's controlling document for the listing ' of PCIS valves - ' ' the TS required testing to verify operability may not have been performed.
j The licensee's evaluation of this ' finding is contained _in EER 89-0195,- dated June 2, 1989. The licensee concluded that Appendix J . L_ testing on the valves listed in Table 1 of the LER was not required
L' since.none of the valve * constituted a potential atmospheric leak + O path.from primary containment, The licensee also determined that the " TS requirement to verify that.the isolation valves go to the required position every 18 months was being satisfied by current plant
surveillance testing. Deficiencies were found, however, with respect
to the isolation times specified in. TS being verified during the > L quarterly Secticn F valve testig required by TS 4.6.3.3.
The speci fit: deficienci: > found.were: valve 1&2-E41-F041, HPCI torus t . suction valve, was not stroked and timed closed within the required.
"' isolation time of 80 seconds; and valve 1-E11-F049, RHR drain to L radwaste, may not have met the required isolation time of 30 seconds.
The Section XI valve testing performed by the licensee had timed the
E41-F041 valve in the open direction only.
In addition, its stroke time, like the others' referenced in the LER, was based on established , baseline times and not on.the TS required time. When the licensee ' r compared the actual stroke times recorded for the valves and compared J , them to the-TS required times, valve 1-E11-F049 was found to have . slightly exceeded its stroke time. A stroke time of 28 seconds was ' established to ensureithat the 30 second isolation time was met since " the valve stroke is timed from light indications, which is. provided > from limit' switches-set at 4% and 96% of valve stroke. The recorded-
stroke time i;or the -1-EM-F049 valve was 29 seconds.
After the discrepancies were known, the licensee performed the necessary adjustments on the 1-E11-F049 valve so that it met its TS ' stroke time requirements. The 1&2-E41-F041 valves were also timed in the closed direction with satisfactory results.
The licensee also updated PT-8.2.2.b and PT-9.2 to implement the stroke time require-L ments-for the valves listed in table 1 of the LER.
The inspector verified that these changes were made.
L h i , L- ! .
_ _ _ _ _ _ - _ _ _ . ft a , b ' g i , f.[ '~ 17-t The deletion of the TS testing requirements without prior NRC review l and approval and the specific failure to satisfy TS 4.6.3.3 requirements for. stroke time. testing is a Violation: Failure to ' . Perform TS Required: Stroke Time Testing, (325/89-34-03 and
324/89-34-03). However, this NRC identified violation is not being b cited because criteria -specified in Section V.A of the NRC Enforce- ' ment Policy were satisfied.
Im The inspector found two deficiencies with the. LER.
The LER stated L that the1 basis existed to delete 'all the valves listed in table 1 J from the TS. This statement is not correct ~ for the E41-F042 valve.
Thi s - valve is a containment isolation valve and is listed in the licensee's. procedure, 50-12, as such. Also, the LER did not address
the corrective action taken with the E41-F041 valves not being timed in the closed direction.- In fact, as stated in the LER, the valves- , L for. both units were timed closed with satisfactory results. These-items were discussed with the licensee.
-The licensee has - subsequently issued a. supplement to the LER to clarify these points.
c.- (OPEN) LER' 1-89'-19,. Failure of -the Service Water System to Meet l Design Requirements.
Based;on questions raised by the DET, the licensee re-evaluated the- -~ design bases of several portions of the service water systems -for.
both units. The licensee listed two major operability concerns thu existed prior to any corrective actions: Whether the system. could have provided required flows under .-- worst-case conditions.
.Whether the SW pumps and motors would have continued to operate ' - under-all-possible flow conditions.
i The licensce did not reach a conclusion about the exact impact of the-design end maintenance deficiencies. Specifically, they stated that !'had - - worst-ca se accident conditions occurred, sufficient- ..., cooling to all safety-related components'may not have occurred."
.The' inspectors concluded that the following problems rendered the nuclear service water headers of both units inoperable: (1) Prior to April 10, 1989, the isolation capability of a non safety-related service water load was not single failure proof.
Valve 1/2-SW-V106, is a-normally open valve that isolates the , non-safety Reactor Building closed cooling water heat exchangers from the remaining safety-related loads on the nuclear header.
' At that time, the valve would automatically shut when a LOCA with a LOOP occurred, isolating the non-safety load. The V106 i I i r - j %
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, n . was the only valve that performed that function.
In the event , p of a single failure (V106 fails to shut), flow would be diverted ' from the safety-related loads to the RBCCW heat exchangers and L -
other Reactor Building loads.
,,, i- . (2) Nuclear SW to conventional SW boundary valves showed excessive ! U^ leakage..The licensee performed Special Procedure 2-SP-89-023,.
Service Water Cross-Leakage Flow, and calculations in ' F EER-89-0135 for Unit,2, and determined that a: bounding value - from leakage from the nuclear header to the conventional header .[ with_ the conventional' header depressurized was about 1900 GPM.
- . F Thus,- with no operator action taken during the first ten mir,utes of a LOCA/ LOOP to re-start a.CSW pump, up to 1900 GPM could have been diverted from the nuclear to conventional header, diverting flow from the nuclear header supplied diesel generator jacket _l water coolers.
.Likewise, the Unit 1 Special Procedure i SP-89-024, Rev. '2, and the licensee's further evaluation determined that the value of Unit I cross-leakage was about half.
' the Unit 2'value.
, -(3) The licensee had previously allowea operation of both units with , ! only 2 operable nuclear SW pumps per site (see Technical . Specification Interpretation 84-L6C, dated October 7, 1987).
. ' ThislTSI was an interpretation of TS 3.7.1.2 which required "the ' , ' U serv 1ce water system nuclear header shall be OPERABLE with at least three OPERABLE service water pumps."
g
(4) The service water system was designed for a capacity of 8000 GPM-for each pump up to a suction temperature of 90 degrees F.
The i required SW pumps could not supply the design flow rates to the safety-related loads under worst case. accident conditions up to a service water injection temperature of-90 degress F.
i ' This is a violation of TS 3.7.1.2 and has existed since each unit's startup. Further, the licensee had ample opportunity to discover the problem. Sargent & Lundy, by letter-dated February 3, 1968, informed > the licensee-that four non-safety relays could fail and prevent the i V106 valve from closing during 'an event (see URI 88-05-01). The licensee concluded, during a PNSC meeting, that a V105 failure would , not cause an operability problem.
The other issue related to the service water system is the inadequate design control. These problems were documented above and in Section ,
3.6.5.2 in.the DET report.
The specific examples of inadequate design control with service water are included in Section 3.6.5.2 of - -the DET report, and constitute a violation.
Both issues discussed above will be identified as a Violation: Inadequate Design Control of the Service Water System with Multiple Examples Leading to Inoperable Nulcear Service Water Headers in Sach Unit for an Extended Period, (50-325/89-34-47 and 324/89-34-47).
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s ' , M Two violations, (one non-cited).were identified, es , { 7.
In Office Licensee Event Report Review (90712) L:[ The below. listed LER was reviewed to verify that the information provided p met NRC reporting. requirements.
The verification included adequacy of [ event' description 'and corrective action taken or planned, existance of Q potential' generic problems and the relative safety significance of the-h event.
E (CLOSED) LER 2-89-12, Motor iailure of Unit 2 Reactor' Protection p.
System Motor Generator Set 2B Resulting in B Logic Auto-Scram Signal L."
and Groups 2, 3, and 6 Isolations.- u l Violations and deviations'were not identified.
E 8.
Temporary Instruction 2515/100 (25020) p,.
(CLOSED) TI-2515/100, Proper Receipt, Storage. and Handling of Emergency C, Diesel Generator Fuel 011.
This TI was originally inspected.and documented in Inspection Report 325,
- 4
/ 324/89-05. No further inspection was performed this reporting period.
, Continuing licensee action to resche QA/QC identified deficiencies will be. tracked asi an -Inspector Followt.r Icem: Proper Receipt, Storage and - g Handling of Emergency Diesel Generator Fuel Oil, (325/89-34-10 and 324/89-34-10).
Violations and deviations were not identified.
( 9.
Action on Prev ous Inspection Findings (92701) (92702) a.
(CLOSED) VIOLATION 325/88-24-01 and 324/88-24-01, Fire on Diesel Generator Building Roof.
.The inspector reviewed the circumstances of the event and the l licensee's response to the Notice of Violation dated. 0ctober 13, m-1988.
The primary contributor to the event was the installation of _ 8x8 wood timbers to support the No,1 DG exhaust silencer without SF review and permission..The licensee has provided. training on this event to the appropriate personnel and changed their procedures so that the installation of cribbing or scaffolding in or on a Q list structure receives a doc'umented SF review. The inspector verified these' actions were taken by documentation review.
' b.
(CLOSED) Unresolved - Item 325/89-09-01 and 324/89-09-01, Service Water System Design Deficiencies. This item was previously inspected in inspection report No. 89-14.
See paragraph 6.c for closecut , U action.
Violations and deviations were not identified.
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- x (4 ' 7' 10.'. Exit. Interview (30703), ' -
The 1.nspection scope and findings were summarized on November 1,1989, o with those persons indicated in paragraph 1.
The inspectors described the - ' .. %, areas inspected and' discussed in detail.the. inspection. findings -listed; . H , 'below and in the Summary. Dissenting' comments were not received from the licensee, Proprietary information is not contained in this report. Note i that the " References" shown below are sections in the DET report.-
- Item Number Description / Reference Paragraph l-t 325, 324/89-34-01
'IFI - Followup on DC Motor Operated Valve ' ~ Reviews. (Reference 3.6.8.3).
h s > 6,, 325/89-34-02-VIOLATION (Non-Cited) - Inadequate Logkeeping, ' (paragraph 5), , , e F.
'325, 3d/89-34-03 VIOLATION (Non-Cited) - Failure to Perform TS L Required Stroke Time Testing, (paragraph 6,b), p 325, 324/89-34-04-URI - Review Electrical Distribution System g C Re-evaluation of-IAP Item D1-2 and Resolve GDC-17 ' K.
Comp'11ance Issues Identified in DET Report, B' (Reference 2.1.4.2), , 325,-324/89-34-05- .URI - Esaluate the Adequacy.of. Licensee's Actions to Investigate System Design Integrity Issues for Safety Systems Other Than HPCI and Service-Water, g " Including Adequacy of Preoperational Test Results, (Reference 2.1.6,3), L' 325, 324/89-34-06 VRI - Review NCRs 88-055 and 88-056 for. Actions.
Taken to Improve Written 10 CFR 50,59 i Evaluations, -(Reference 2.1,6.5).
c'
325,'324/89-34-07 URI - Review Statistical Techniques Used for Root Cause Analyses of Field Revisions and Technical Adequacy of Corrective Actions for PM-88-019 and ' . - PM-83-143, (Reference 2.1.6.4), '325, 324/89'34-08 URI - Review Licensee's Program for - . Interpretation and Implementation of TS, ! h 325, 324/89-34-09.
URI - Review Simultaneous Performance of MSTs.
HPCI 13M and HPCI 21R, (Reference 2.1.4,7), b 325, 324/89-34-10 IFI - Proper Receipt, Storage and Handling of Emergency Diesel Generator Fuel Oil, (paragraph 8).
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325, 324/89-34-11 IFI - Followup on Implementation and Effectiveness of Communications Strategy in IAP Item Al.. 325, 324/89-34-12 IFI - Followup on Implementation and Effectiveness of Technical Support' Improvements-in IAP Item B1, (Reference 2.1.3.9 and !' 2.1.6.12b), 325, 324/89-34-13; IFI Followup on Implementation and , Effectiveness of Nuclear Engineering Improvements in IAP Item B2, (Reference 2.1.6.12a).
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325, 324/89-34-14 .IFI'- Followup on Implementation and , Effectiveness of Nuclear Training Improvements in IAP Item B3,-(Reference 2.1.2.12).
!' 325, 324/89-34-15 IFI - Followup on Implementation and ' Effectiveness of Outage Management Modification
Improvements in. IAP Item B6,-(Reference 2.1.6.12c).
325, 324/89234-16-
- IFI - Followup on Implementation and Effectiveness of Nuclear Prioritization Process in IAP Item C1, (Reference 2.1.3.7).
T 325, 324/89-34-17 IFI - Followup on Implementation and - Effectiveness of TS Database Accuracy Sample in-1AP Item D1-1, (Reference 2.1.4.1).
-325, 324/89-34-18 IFI Followup on Corrrection of TS. Sampling Plan Flaw in IAP Item D1-4 and Determine Its Effectiveness with Respect to Periodic Rev.iews of TS Requirements, ISI/ Appendix J, and Commitment Verification, (Reference 2.1.5.6).
325, 324/89-34-19 IFI - Followup on. Implementation and Effectiveness of Maintenance Backlog Improvements- - - in IAP Item D2, (Reference 2.1.3.6), n 325, 324/89-34-20 IFI - Followup on Implementation and . Effectiveness of MOV Maintenance Program D Improvements in IAP Item D3, (Reference , 2.1.3.10).
325, 324/89-34-21 IFI - Followup on Implementation and b ' Effectiveness of Developed Post-Maintenance Testing. Guidance in IAP Item D4, (Reference
2.1.4.10).
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,, m . t.g g'.. .. 22- - ? 325, 324/89-34-22 IFI - Followup on Implementation and Effectiveness of Design Related Procedures Update ' < - to Reflect Organizational-and Responsibility Changes in IAP Item 08, (Reference 2.1.6.8 and 2.1.6.12a).
E , - 325, 324/89-34-23 IFI - Followup on Implementation and Effectiveness of Corrective Action Program Improvements in-IAP Item D9, (Reference 2.1.1.7, 2.1.3.8, 2.1.5.2 and 2.1.6.14).
, 325, 324/89-34-24-IFI - Followup on Implementation and
Effectiveness of Institutionalization of Corporate Corrective Action Program in IAP Item DIO,(Reference 2.1.1.7, 2.1.3.8 and 2.1.5.2).
. 325, 324/89-34-25 IFI - Followup on Implementat' ion and Effectiveness of Improvements Made to-10CFR50.59 Reviews in IAP DII,.(Reference 2.1.6,5).
, 325, 324/89-34-26 IFI Followup on Results of Licensee's Review of Recently Issued Procedures to Ensure Intent of PAM in IAP Item D13, (Reference 2.1.4.4).- - 325, 324/89-34-27 IFI - Review Simulator Certification Submittal (IAP Item D18) for Acceptance, (Reference 2.1.2.13).
325, 324/89-34-28 IFI - Followup on Implementation and Effectiveness of Standing Instructions Procedure Revision in IAP Item D20, (Reference 2.1.2.7).
325, 324/89-34-29 IFI - Followup on Results of Site Work Force Control Group's Charter / Guidelines Review in IAP Item 021, (Reference 2.1.3.3).
, 325, 324/89-34-30 IFI - Followup on Implementation and Effectiveness'of New Tagging and Labeling Program in IAP Item D22, (Reference 2.1.4.8).
325,'324/89-34-31 IFI - Followup on Implementation and Effectiveness of Engineering Support Small Projects Approach in IAP Item 024, (Reference 2.1.6.6).
- 325, 324/89-34-32 IFI - Followup on Adequacy of E0P Revisions and Validation /Verificartion in IAP Item D28, (Reference 2.1.2.8).
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- 325', 324/89-34-33 IFI -. Followup on Implementation and
' ' Effectiveness of ISI Nuclear Generation Group [, Guidelines in IAP Item D29, (Reference 2.1.4.5).
325, 324/89-34-34 ~IFI - Followup on-Implementation and.
Effectiveness of Brunswick' Procedures Update to ' , Reflect Organizational and Responsibility Changes C , jig as in IAP' Item D31, (Reference 2.1.6.3).
! l( 325, 324/89-34-35 IFI - Followep on-Implementation-and~ I, h: ' Effectiveness of Actions Taken to Ensure'Overall IAP Improvements are Implemented / Adjusted and t Performance Monitored as in IAP Items El and E2, t < 325, 324/89-34-36 IFI - Followup on Implementation and ! h Effectiveness of Corporate Quality Assurance Department Improvements in IAP Item E4, [l' (Reference 2;1.5.3).
! L 325, 324/89-34-37 IFI - Followup on-Implementation and ' Effectiveness of Independent Performance ' Assessments in IAP Item ES, (Reference 2.1.5.3).
o
b I-325, 324/89-34-38 IFI - Followup on Implementation and L Effectiveness of PT Procedure Revisions in IAP L Item E6~, (Reference 2.1.4 6).
I 325, 324/89-34-39 IFI - Followup on Implementation and Effectiveness of Actions to Resolve People-Issues in IAP Item Gl.
, ! ' 325, 324/89-34-40 .IFI - Followup on Implementation and Effectiveness of. Total Quality Process Initiatives in IAP Item G2.
' 325, 324/89-34-41 IFI - Followup on Implementation and Effectiveness of "0wnership" Initiatives, Including Pro'cedural Adherence and Attention to
ll Detail as in IAP Item-G3, (Reference 2.1.6.4).
L-325, 324/89-34-42 IFI - Followup on Disposition of Vendor
Recommendations, (Reference 2.1.6.7).
325, 324/89-34-43 URI - Service Water Valve, SW-V120, Removed from the System with a Danger Tag Attached to It, (paragra'ph 4.c).
L 325, 324/89-34-44 URI - Radwaste Cleanup Phase Separator Tank Room Reportability, (paragraph 4.d).
L ' - t y '
[ ' ' l .. . .t
324/89-34-45 URI - Nozzle Plug Installed in Wrong Reactor . < Vessel Nozzle, (paragraph 4.e).
' 325,.324/89-34-46 VIOLATION (Non-Cited) - QA.Not Performing 100% Review of TS. Surveillance Requirements, , (paragraph 5), h 325, 324/89-34-47 VIOLATION Inadequate. Design Control. of the - E Service Water System with Multiple Examples Leading to Inoperable Nuclear - Service. Water - ,' Headers in Each Unit ~for an - Extended Period, (paragraph 6.c).
,>, L Licensee management was informed that a : previous violation discussed in paragraph 9 was closed during this inspection.
F1 II.
List of Acronyms and. Abbreviations [ AE00_ Alternating Current AC Office of Analysis and Evaluativa of Operational Data t AI . Administrative Instruction L AMMS .: Automated Maintenance Management System g; A0 Auxiliary Operator , [ .AP Administrative Procedure L BSEP Brunswick Steam Electric Plant C0 Control Operator b-CRD-Control Rod Drive
CSW Conventional Service' Water .DET . Diagnostic Evaluation Team . I OR Direct Replacement !E EDO Executive Director of Operations .EER-Engineering Evaluation Report E0P-Emergency Operating Procedure .ESF.
' Engineered Safety Feature U F: Fahrenheit ~ GP General Procedure GPM Gallons Per Minute .HP' Hea1th Physics!. . ' ' HPCI High Pressure Coolant Injection > IAP: Integrated Action Plan I&C Instrumentation and Control
- IE NRC Office of Inspection and Enforcement IFI
. Inspector Followup Item - .INPO.
Institute of Nuclear Power Operations
- IPBS Integrated Planning, Budgeting and Scheduling SISI Inservice Inspection LCO Limiting Condition for Operation LER-Licensee Event Report
_ .- , - , . - -- .. ~n
_ _ _ _ _ _ - -. , 1# u t.
, F4;o :" .';19 gm --
, . l LL-Low Level D, LOCA Less of Coolant Accident.
- MOV Motor Operated Valve MSIV Main Steam-Isolation Valve (
NRC; Nuclear-Regulatory Commission L .NRR Nuclear Reactor Regulation ' NS$$- Nuclear' Steam Supply System OEF, l Operating Experience Feedback' ONS.
Onsite' Nuclear Safety PA Protected Area-F lPAM Procedures Administration hanual- [ PCIS Primary Containment Isolation-System-i PI Pressure Indicator PIR-Plant Incident Report PM-Plant Modification iPNSC Plant Nuclear Safety Committee PT Periodic Test OA-Quality. Assurance QC-Quality Control 'R. Rem ~ ,
RBCCW Reactor Building Closed Cooling Water I RFP, Reactor Feed Pump RHR Residual Heat Removal RWCU-Reactor Water. Cleanup SAT Startup Auxiliary Transformer t SD . Shutdown.
f LSER1 Safety Evaluation Report L SJAE Steam Jet. Air. Ejector- ! SLC Standby Liquid Control ! SOER 1 Sequency.of Events. Report ., STA-Shift Technical Advisor l- - L SW-Service Water-TI Temporary-Instruction , TS- -Technical-Specification ' -TSI Technical Specification Interpretation-UAT. . Unit Auxiliary Transformer b .URI! Unresolved Item - ' 'WR/JO Work Request / Job Order ' < g.
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