IR 05000333/1990081

Insp Rept 50-333/90-81 on 900604-08.Major Areas Inspected: Effectiveness of Util Outage Completion Activities,Mod Closeout,Preparations for Startup & Mgt & QA Oversight

ML20055J338
Person / Time
Site:	FitzPatrick
Issue date:	07/16/1990
From:	Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20055J337	List: IR 05000333/1990081 ML20055J336
References
50-333-90-81, NUDOCS 9008020114
Download: ML20055J338 (18)

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U.S. Nuclear Regulatory Commission Docket.No.: 50-333  !

Report No.: 90-81

] i License No.: DPR-59  !

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Licensee:

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New York Power Authority P.O. Box 41 -i Lycoming, New York 13093 Facility: James A. Fitzpatrick Nuclear Power Plant Location: Scriba, New York-I'

Dates: June 4 - 8, 1990 Team Leader: R. J. Urban, Resident > Inspector,-Peach Bottom Team Members: P. D. Kaufman, Project Engineer,:DRP-D. LaBarge, Project Manager, NRR J. R. Stair, Resident inspector,-Susquehanna L. J. Wink, Reactor Engineer,LDRS- l Approved By: / 0"--- 7 !b' O !

j/GlennW.-Meyer,1Chiegf Date- E!

Projects Section 1B, DRP i

INSPECTION-SUMMARY This inspection report : discusses

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s the Outage Completion Team Inspection that assessed- the effectiveness of' New York Power

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l Authority's - (NYPA's) outage completion activities, modification closecut, preparations - for startup, and management and quality assurance oversight, i

INSPECTION RESULTS An Executive Summary and an outline of inspection results.follow !

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-9008020114 900729 ,

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gDP'

ADOCK 05000333 PDC ,

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Executive Summary FitzPatrick Nuclear Power Plant Inspection Report 90-81 The team concluded that most operating procedures had been properly revised to reflect-modifications during the refueling outage and that the. remaining operating-procedures were being revised. The team found one. instance _ in which NYPA was unaware that a Technical Specification change regarding hydrogen injection at higher. levels had not been incorporated into the operatingo procedure The applicable testing had not occurred, and NYPA revised the procedure acceptabl All -operators received appropriate training on modifications, and licensed operators received training on the; final draft version of the new emergency operating procedures.=

Operators were knowledgeable of plant _ status.and alarms ;in: the control room. The team found one isolated instance in which an- G N channel with a deficiency tag was selected on the chart recordt

, Also, the team identified isolated errors regarding an inaccurC o SRM log. reading and=an inappropriate method of correcting' data in-log sheets, NYPA corrected ~the error Modifications were incorporated appropriately into maintenance _and surveillance procedure In-process maintenance-and surveillance activities were being properly performed and were in:accordance with procet. ural requirements. Reviewed surveillance tests had been completed on time and w re satisfactor The surveillance testing backlog was being properly controlled and tracked to support unit start-u There were numerous, open priority:1.WRs that were-not -

formally categorized as to which ones had to be resolved prior to unit startu NYPA's program for controlling modifications was functioning wel Several modifications were reviewed and were acceptable. Procure-ment, control and receipt of materials was satisfactory,- and personnel were knowledgeabl The recently begun system 'engi-neering program appeared to be properly defined and -structure The temporary modification procedure was adequat The onsite technical support group, in'the areas of modifications and system engineers, was supporting restart and operation of the plan PORC meetings were effective, and questioning attitudes by PORC members were eviden Satisfactory coordination and communication between departments occurred during outage meetings, and station management provided adequate oversight of restart activitie QA involvement in other restart attivities was adequat I

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l Table of-Contents 's i

Pace L PURPOSE............................................... 1

! OPERATIONS............................................ 1 Procedure Changes.......................-......... 1 Licensed and Non-Licensed Operator Training...... 2 Control Room Observations....-.................... 3 2. 4 ~ Summary.......................................... 4 MAINTENANCE AND SURVEILLANCE..............-............ '4 Procedure Changes................................=

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4 In-Process Maintenance / Surveillance Activities.-... 5 3 .~ 3 Surveillance Tracking, System..................... 6 3.4 ' Maintenance; Backlog............................... 7 3.5 Summary.......................................... 8 TECHNICAL SUPPORT...................................... 8 Modification Control Program...................... 8 Modification Package-Review...........-........... 9 System Engineers................................. 10 Temporary Modifications.......................... 11 Summary.......................................... 11 MANAGEMENT AND QUALITY ASSURANCE OVERSIGHT,........... 11 Plant Operations Review Committee (PORC)......... 11 , Station Management Involvement................... 12 Quality Assurance Involvement.................... 13 Summary.......................................... 13 EXIT INTERVIEW........................................ 13 l

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Details'

1.- PURPOSE

ThisL inspection was conducted to verify. proper _ closecut of-modifications and to determine _ if systems ware properly restored to an ' operational conditbn following the 1990 ,

Areas. examinea

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refueling outag ;1uded: operations, modification impact on . operator training and procedures,- .

maintenance 'and surveillance activities, and.' technical ,'

suppor The involvement of. station management and tne quality assurance (QA) organization in restart preparations-was also observe >

2.- OPERATIONS ~ Procedure Chances ,

The team reviewed a complete list of modifications and determined that thirteen modifications performed during the 1990 refueling outage significantly 4.mpacted operating procedure Except as dim;ussed below, all operating procedures reviewed were technically adequate, conformed with Technical Specifications and regulatory requirements, and had I been appropriately revised to reflect recent plant modifica-tion The modifications that impacted operating procedures are listed in Attachment The team selected various operating procedures - (Attachment 2) and determined that-the procedures had been accurately revised to-reflect the'modifi-cations. Several additional operating procedures reviewed'by '

the team were being revised at the time.-

During review,of FitzFatrick operating procedure (F-OP) . 89A, Hydrogen Addition > System, the team noted that the procedure ,

stated that there were no Technical- Specification requirements directly associated with this particular procedure. The team was aware of a recent change to - FitzPatrick's Technical Specifications (Amendment #159, issued April 30, 1990) that allowed - the trip level setpoint for the main steam line

radiation monitor to be _ raised for hydrogen additions to feedwater at higher levels for testing purposes. 'However,.the .

setpoint could only be raised'24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to test initia-tion-and had to be returned to normal within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after'

, test' completion. Further inquiry by.the team determine'd that temporary operation procedure (TOP) 110, _ Hydrogen Addition

System. for Reactor Internals Program, and preoperational test procedure '(POT) 89E, In-Core ' Stress Corrosion Monitoring System-Test Program,.were~ issued to control the increased hydrogen. addition' testing, while-F-OP-89A was to be used-only i

during normal hydrogen injection' operations. : A review of the-

TOP and' POT procedures determined that neither incorporated q

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reference to the Technical' Specification requirement'nor a 1

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means-by which compliance would be controlled. .Also, in an

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attached ' safety . evaluation to the Technicalm Specification change request, NYPA committed to administratively prohibit control rod withdrawal in the event of any unanticipated power-reduction to below 20% of rated power during testing, until the trip level -setpoint o for ' the main steam line radiation monitor was readjusted to its normal value. . The' team deter--

mined that neither the TOP nor the POT included this commit- ,

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The team concluded that the noted deficiencies were minor in safety significance because the procedures hadinever been used-Testing was sched - '

for increased hydrogen' addition testin uled to commence sometime after restar '

Nonetheless, the team judged NYPA's- control of the implementation _ of. this Technical Specification chenge to have been weak and concluded that had the testing occurred with the inaccurate procedures, the consequences could have been more significant. NYPA made appropriate changes to the procedures. The team reviewed the procedures and found them to be acceptabl Several other Technical Specification Amendments were reviewed and no abnormalities were foun The team concluded that the incident was isolate .2 Licensed and Non-Licensed Operator Trainino The training programs for licensed and non-licensed operators were reviewed to determine if-pre-startup training had;been provided on recent modifications to the plant'_s design'., The

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review ' included ' administrative controls' established to '

I implement revisions to the training program, the training materials and methods ~ used, _ and. the training - records that L documented completion of required training.

The team reviewed Training Department Standing Order N ,

Program Revision Tracking System, that controls changes to the training program based on plant modifications as well as other cause The standing order provided_ adequate administrative l controls to_ ensure that plant modifications were' reviewed by the operations and training departments; .for program impact.-

All modifications scheduled for -implementation during the l- current refueling outage -had - been reviewed . by- appropriate training -and ' operatic os department personne The thirteen

modifications listed in Attachment 1 had a significant, impac ,

on plant operations and were-included in both the licensed and non-licensed operator training _ program '

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The team reviewed training materials : developed to address these modifications. The' training materials were appropriate for operator training on the selected modifications. -NYPA had selected a training method for thisl training _of.small-grou discussions, which appeared to the team'to be an appropriate means of presentation. The team reviewed the lesson plans for )

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the operator requalification training program and determined that the materials developed for the modifications training-were' included with the .ppropriate lesson plan The team reviewed the training' records for modification training (Lesson Plan R90-3.2) and determined that all i licensed and non-licensed operators had received this train--

ingt all 35 licensed operators had received training, and 22 .

of 23-' non-licensed eperators _had; participated (one 'ron-

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l licensed operator was on disability leave) . In addition,_all

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operator t raining personnel and selected management- and- !

supervisory I.ersonnel had attended _this training,- The team questier.ed .on--shif t licensed operators concerning selected modirications. They understood the modifications and how the a would impact plant operation The team also examined thei training records of licensed operators and determined that training had been provided o '

the new emergency operating procedures that_were changed from-a procedure based to_a flow chart _ based format. Spot checks determined that training, both classroom and_ simulator, had: 1 been provided on draft versions of 'these flow chart Discussions with training personnel determined that additional on-shift training was planned for changes made to the final draft flow charts when they are officially issued and approved prior to restart of the uni ; Control Room Observations-The team found all necessary control room instrumentation to

be operable, all readings to be in the . expected range for existing plant status, and no abnormal trends to be eviden The operators were aware of the status of ~ control room alarms I

and the reason for those that were in the alarm stat The team noted that source range monitor (SRM) channel B was bypassed using the joy stick on the control panel, and was tagged in this position under Tagging Order. Number-901325, datnd 5/28/90. A deficiency tag on the recorder dated. 5/27/90 stated that SRM channel B was drifting. However,. the recorder pen selected was SRM channel B rather than another correctly n functioning SRM channe When the reactor 'operatorm was questioned concerning - the team's observation, he indicated

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that the switch was probably~ inadvertently left in this position following daily logging of recorder readings for the.-

, control room logshee The operator immediately.placed1the selector-switch to an~ operable channel.

l The team reviewed control room'logsheets, on which.SRM channel ;

,' B readings from- both the indicator .and the recorder were

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logged' daily, but there was no evidence that the channel was '

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in fact driftin Since it war reading close to the other SRM

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i channel readings, a review of the logsheet would_not revaal the problem with SRM channel ;

The team found minor errors in the logging of'SRM readings, ,

The control' room logsheet showed that the indicator readings logged for all four SRM instrument channels for June 3, 1990,_

were a factor _ of ten higher'than the recorder readings for the previous day and the next da This was apparently due-to- 3

- incorrectly reading the indicator on the control room pane Also, one,SRM reading on June 5, 1990, was changed by writing

- over-it'rather than crossing it out and: initialing. A. review of the logsheets by-shift supervision had failed to de.cect the

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above discrepancie The errors were pointed out to the-control room operators and were' corrected. The team concluded -

that theLincidents appeared-to be isolated-and were minor _in significance - a i

The team also' verified that new computer codes were; being- .

installed in the. plant process computer by General Electric .;

Company personne The new. codes.were written:to implemen l the Supplemental Reload Licensing Submittal dated February 1990. Also, the new Technical Specification uinimum critical-power ratio. (MCPR) limit of -1. 07, which was approved -in Technical Specification Amendment No.- _157 dated April 11, 1990, was include y Summary The team concluded'that most operating procedures had'been properly revised to reflect modifications done. during the

, refueling outage and that'the remaining operating procedures were being revised. The team founca one instance in which NYPA was unaware that a Technical Specification change <regardin hydrogen injection at higher levels had not'been incorporated into the operating procedures. i The applicable testing hadL not ,

occurred, and NYPA revised the. procedure acceptabl All ;

operators received-appropriate training on modifications, an licensed operators' received training _ on the~ final draft-version of the new emergency operating procedure ,

Operators were knowledgeable of plant = status and alarms in the control roo The team found one isolated instance in which'

an SRM channel with a deficiency tag was selected on the chart recorde The' team-identified isolated errors regarding an

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inaccurate SRM log reading and? an' inappropriate . method of correcting data in log sheets; NYPA. corrected the. error . MAINTENANCE AND' SURVEILLANCE Procedure ChangAq l f

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l The team selected several modifications that were installed- -

during the current outage to verify that- maintenance, and

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lnstrument and control (I&C) surveillance procedures affecte I by. these modifications were properly revise The team, '

reviewed- several modification packages 'to determine if procedural changes were required, and whether the changes were correctly incorporated into the procedure These modifica-tions are listed belo ,

ATWS-Recirc Pump Trip Logic Modification

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F1-85-054, (Div.B). I&C, surveillance procedure (ISP) 175A, Reactor

- and Containment Cooling Instrument Functional Test /Calib-ration (ATWS),.was affected by the modification and the procedure was revise ;

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F1-87-061, . Control Room Design Modification. - Numerous procedures were affected by this modification so the' team selected a maintenance procedure associated .with the torus level. The team verified:that maintenance proce-dure -(IMP)- 13.1, .. RCIC System- Pressure Indication; was properly '.'evised to reflect the torus level modification, .

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D1-90-079, Core Spray System. Procedure. IMP 14.1,-Core ( Spray Minimum -Flow Bypass Flow Indication Switch, was revise Based on-this review of several-selected modifications,.the team concluded that affected surveillance procedures had been adequately revise .2 In-Process Maintenance / Surveillance' Activitigtg

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the A residual heat removal (RHR) service water pump and-motor. The work was necessary due to excessive pump vibration

-,I levels .and was being implemented under Work. Request No.

i 10.73591.- Actual work in progress -was' being- properly con -

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trolled by maintenance procedure MP-46.1, Maintenance Proce-

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dure For RHR Removal -. Service . Water Pumps and . Emergency Service Water Pumps. The disassembly of' the pump 'in the, field i was witnessed by the team. Procedural adherence was evident, and a job leader and necessary craft. personnel were presen The team observed portions of surveillance testing. associated' '

l u with the service water syste>. -Testing.was being controlled-by TOP-115, Service Water Te', tin The team-noted that the procedure was being used at- the work station' in the field, and-

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the data was being gathered by performance engineers, system; engineers, and contract . pereonne Flow rate measurements j

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.weretbeing taken using ultrasonic flow instruments. The team a found that the individuals involved with test were-knowledge- -l

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surveillance tests observed was limited due to the' Integrated Leak Rate Test that was being performed during this inspec-tio The team reviewed two completed surveillance-tests to verify that they were performed as required and that the results were satisfactory and met appropriate acceptance criteria. ST-02P, RHR Shutdown Cooling and Head Spray Simulated Automatic-

! Isolation Test and ST-06D,-Standby Liquid' Control Initiation L andl Demineralized Water Injection Into Reactor Vessel- Test, e

were determined to be satisfactory by NYP The team found that both surveillance tests were completed within the time period required and the test results met Technical Specific-ation acceptance criteri .3 Surveillance'Trackina System The surveillance tracking process was reviewed to verify tha all surveillances were complete and current as required by .

Technical Specifications and'if past-due surveillances were 'I properly tracked- and ' controlled to ensure compliance for start-up. The team reviewed the master surveillance schedule, I&C surveillance test schedule and the once-a-cycle surveil-lance test list to determine the status (ofLall outstanding surveillances and if any surveillances had been misse The team found two minor discrepancies in - the' surveillance test schedule with surveillance test (ST) 01,--VP:of Nuc Gen .

Review, and I&C surveillance procedure (ISP) . 94*S, < Reactor *

Protection System (RPS) Functional Tes ST-01 was due on 12/30/89, with a . - grace period expiration date .of J 3/31/90. .

However, the: surveillance schedule indicated that'ST-01 had not yet been performed. ' Also,. : the --team could , not ' find any -

,. information to determine th9 purpose of ST-01'. - After discus-sion with the operations Superintendent,-.the' team determined

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that ST-01, a NUREG-0737 commitment involving.aJreview of the duties and responsibilities . of shift supervisors, had been performed. The' surveillance schedule was; updated to reflect its completion. ISP-94*S was also found to exceed its sched-uled surveillance due date,- ' but not its . required Technical Specification frequency. ISP-94*S was properly deferred per I&C Standing Order No.13'. This standing order permitted the surveillance test to,be deferred with the permission of th ~

assistant I&C superintendent, as long as Technical ~Specifica-tion requirements were maintaine ' Surveillance' tests required to be completed prior to' placing l the mode ' switch to : start-up were identifiable . using ' .the surveillance schedule The team ~ determined that- many operational _ surveillance tests - required prior to reacto startup had not been performed. A total of 21 once-a-cycl j surveillance tests and 8 IGC surveillance tests also remaine j i

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In addition, any surveillance tests that were past-due, but not required to be completed because of the shutdown condi- ;

tion, were also identifiable using these tracking method !

The team concluded that personnel responsfible for the surveil- 1

. lance scheduling system appeared able to ensure that. required surveillances would be complete prior to unit- startup, though

' the tracking system was cumbersome to implement and audit, and ~j required careful attentic The team determined that ' the '

surveillance schedule appeared to be adequately maintained and reflected the present status of surveillance test ,

' Maintenance Backloa Outstanding maintenance work- requests :(WRs) were reviewed 'to I verify that maintenance.related items that may impact = plant' 1 startup, safety-related equipment, or_ system operability, were :

completed or being properly tracked for' completion prior to !

restar WACP-10.1.1, Procedure For Control of Maintenance l and Engineering-Assistance Requests, is used to control work- :l request Management supervisors assign = various priority levels to work requests using, the guidance in procedure WACP- ;

10. The work control' center, which is located in an area !

adjacent to the main control room, is responsible for tracking-the status of WRs and maintaining the computer tracking data )

base. The priority level assigned to a 4R may be changed by work control center personnel to fit the needs and' require-

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ments of current plant status. Based on a-review of priority levels in the procedure,. the ' team was unable to_ determine

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which WRs remained - to be ~ completed prior-to startu It appeared that WR prioritization levels =are base _d on a plant that is operatin The team was informed by the Operations Superintendent that all outage related priority 1 WRs are' reviewed and evaluated prior to startu The team reviewed a specialized' computer printout of all outage related priority 1 WRs to determine which WRs needed to be completed prior to: plant restar A ,

total of 77 WRs were categori:Gd with this particular status !

cod However, the team was still unable to determine exactly which of the 77 WRs had to be resolved prior to start-u j Upon further review into;the WR process, the-team noted-that ,

deficiency tags have WRs associated with them. The team then '

performed a walkdown of several control room panels _with the work control center supervisor, a licensed Senior -Reactor Operator (SRO), to determine which equipment and instrumenta-tion with deficiency tags would be needed fo'r start-up. About 40 deficiency tags were counted in the control roo of these about six were determined by the SRO to -be beneficial 'for startu However, none of the six inoperable components were required to be operable for startup as required'by Technical Specification The team verified that WRs existed for.the above six deficiency tags and their priority codes ranged'from -

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priority-1 to priority ,

The team expressed concern that a WR with a priority of 2 or 3 may not be reviewed and completed prior to restart. NYPA does not have a formal documented revisw process for WRs and

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deficiency tags prior to start-up. Neither procedure F-OP-65, Start-Up and Shutdown Procedure, or plant standing order PSO

1. 2, JAF Outage Management Program, addressed evaluation of WRs:

and deficiency tags as part of the start-up evaluation proces If only outage related. priority 1 WRs get reviewed ,

prior to startup, control' room operators could be deprived of-equipment, ins.trumentation, or alarms that could hnefit plant operation. More emphasis could be placed on el2 (nating-out of service control room equipment, that would beib..aoficial to '

operators during-start-up and power. operation Operations management stated that the priority 2 and 3 WRs identified by i the team would be reviewed prior to startup and other priority, 2 and 3 WRs would also be evaluate The; team determined thatL NYPA review and evaluation of WRs and. deficiency. tags prior to start-up could' be documented . in .a- better ' manne 'NYPA t acknowledged the , team's observations and stated that they would examine this area for future improvement, if warrante ; Summary Modifications performed _during this outage'that were reviewed by the team were incorporated'_ properly into maintenance <and surveillance procedures. In-process maintenance and surveil-lance activities were being adequately-performed and conducted in accordance_ with procedural requirement Surveillance tests reviewed were completed on time and'were-satisfactor The surveillance testing backlog was being adequately' con-trolled and tracked to support unit start-u There were numerous priority 1, open WRs that were not formally categori-zed as to which ones had to be resolved prior to unit startu . TECHNICAL SUPPORT i 4.1 _ Modification Control Procr3Jn NYPA implemented a new program.for controlling' modifications, j in February 198 This program'is comprised of Modification ~  !

Control Procedures compiled -in the Modification Control Manua (MCM). This manual is being fully-implemented for:modifica-tions planned 'since its effective date and . for various i previously planned- modification .Some ' modifications! are still being implemented using the old" modification ~ process;- ,

however, as these modifications are~ completed,-the old system ~

is being phased ou An important element of the MCM effort is the estab1'ishment of a

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the position of a Responsible Engineer (RE) to process the -i modification from conception to completio The team found these engineers to ba knowledgeable of their assigned modifi-l

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i i The team reviewed the MCM and -supporting administrative procedures sc . initiating, controlling, implementing, and:  ;

closing out modifications. . The team also reviewed implementa- "

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g tion of the MCC and its- supporting procedures for selected modifications. De team found that the modification packages,

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including Engineering Change Notices-(ECNs), were prepared in_  ?

accordance witu the MCM and approved support procedure Modifications were controlled with appropriate procedures, forms, checklists, and signoffs that established the respon-sibilities of all groups involved. The forms _and checklists were complete with proper signoffs. The team determined that this ' program - is in conformance with the requirements , of; f Technical Specifications, 10 CFR 50.59,- and the . qualit '

assurance progra . Modification Packaae Review

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The team found the modification packages to - be acceptabl Three modification packages were reviewed to verify confor-mance with the-MCM. Essential documentation such as drawings and procedures were reviewed'to ensure appropriate revisions were incorporate One acceptance -test was observed to determine if it met appropriate criteria and-whether it was -=

properly conducted and received required QC witnessing and Gignoff. The following modifications were reviewed:

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F1-85-054, Anticipated Transient Without Scram - Recircu-lation Pump Trip (ATWS-RPT) Logic-Modification.

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F1-88-041, Weld Overlay of Primary System Welds Due to Intergranular Stress Corrosion' Cracking: (IGSCC).

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F1-88-253, Transverse Incore Prob'e (TIP) System Replace-men A preoperational acceptance test of the TIP .

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isolation valves was observe Difficulty was encoun-tered with dirty local power range monitor tubes and will have to be resolved prior to-restart.-

The abcVe modification packages-were begun before the new MCM-effort was implemented; nevertheless, two of the packages were processed in conformance_with the,MCM, and the third-(F1-88- 1 041) contained most of the information require'd by the new'MCM 1

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(e.g.,-cover sheet, Nuclear Safety Evaluation Form, and the Classification Form). This was commendable-that the revised modification processing was applied to these packages.-

Discussions with materials control personnel and review of -

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WACPs govarning the procurement, receipt, and control of material were conducted. The team verified'that appropriate controls were in place to assure that material procured and received for modifications had appropriate design requirements designated and underwent adec;uate . - receip inspectio Personnel interviewed' were knowledgeable of technical and i administrative requirements in the procurement. are ] System Encineers The team interviewed the' systems engineering supervisor and'

reviewed _the systems engineering program.to verify that the program adequately defines responsibilities, training require- ,

ments, and relationships with cther onsite organization I Plant Standing Order (PSO)-1, System Engineering Program, was  ;

. issued to establish a program for using system and component-  !

experts-to improve overall plant performance and reliabilit l PSO-1 defines responsibilities of the systems engineering '

supervisor, and system engineer The systems engineering supervisor is responsible for overall coordination of the

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program. System engineer responsibilities are clearly state .

i l PSO-1 discusses. working relationships with plant operators,

[ but does not mention' working. relationships with other onsite support groups such as maintenance, instrument.and control, radiological controls, - and other technical services depart- I ments. The team noted that the systems ~ engineering department is-relatively new, having been established approximately.one i- year ago; therefore, the relationship with other onsite groups .

was ~ still in a developmental stag Discussions with in-l dividuals from operations concerning their working relation-ship with systems engineers indicated that operations ' has accepted this group as having the potential to provide support l to resolve problems identified by the operations staff..

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team determined that the level of experience.of his subordi-nates range from recent college graduates to.approximately eight years of related experienc ~PSO-1 dictates .that individuals shall possess an engineering degree or demonstrate

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a strong technical background. Additional training; stipulated was familiarity :of plant layout, location of assigned system - ,

, components, attendance at the Boiling -Water ' Reactor (BWR)

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orientation course-or equivalent training,' familiarity with the Final Safety Analysis Report, Technical Specifications, operating experience review items, - NYPA ' configuration manage-

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ment plans and procedures, system descriptions, and' operating and maintenance procedures applicable to their. assigned systems.. However, no formal certification program ~ for < the -

system engineers existed at-the time. The team concluded that

, the system engineering program has progressed at a sufficient rate since its inception.

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11 l Temocrary Modifications WACP 10.1. 3, . Temporary Modifications, controls jumpers, lif ted- J 1eads, and temporary modifications. The team reviewed several outstanding lifted leads / jumper request The requests i adequately performed their intended function and were properly

' documented. However, determining which requests needed-to be 4 addressed prior to startup, as well as determining their affect on existing plant status, was difficul .

Review of WACP 10.1.3 did- not' identify any inadequacies; however, the team questioned statements in the procedure that-allow the implementation of' jumpers, lifted leads, and temporary modifications under other approved and controlled'

plant procedure The team-judged that dividing control of these activities throughout too many diverse procedures could .

weaken-the assurance that these activities will consistently

. conform to all requirements. Additionally, revisions to the method of control of temporary modifications can become more complex when divided among many documents. However, the team did not identify'any problems in the plant associated with ,

temporary modifications. NYPA stated that they were currently evaluating their program for potential improvements and .would evaluate the team's observation .5 Summary NYPA has instituted a new program for controlling modifica-tions and it appeared to be functioning wel Several modifications were reviewed and- conformed- to- the MC Procurement, control and receipt of materials was adequate and ,

personnel were. knowledgeable. Tne recently begun system engi-neering program appeared to be properly defined and struc-ture Temporary modification procedure :was adequat The onsite technical support group, in the areas'of modifications and system engineers, was adequately supporting restart and-operation of the plan . MANAGEMENT AND QUALITY ASSURANCE OVERSIGHT

' Plant ODerations Review Committee (PORC)

i The team attended portions of two PORC meetings and concluded l that PORC reviews were effectiv A special PORC meeting (#90-56) was held to review. the ' circumstances surrounding a recirculation sample line that had dead load-and seismic: load in excess of allowable limits due to a past modification that added a valve and a pipe suppor Individuals with expertise

'in the area were in attendance to clarify issues as they arose. PORC metubers displayed questioning attitudes, and good investigative and corrective actions were recommended.

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The - team also attended a regularly scheduled . PORC meeting (f90-57). Items discussed at this meeting were various procedure revisions, temporary procedure changes, occurrence reports and PORC commitments. During discussion of Occurrence

Report #90-157, the PORC determined that.an automatic isola-tion to- the high pressure coolant , -inj ection system steam isolation valve during excess flow check valve testing was not i reportable to the NRC. . The basis for this conclusion was that

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the procedure .in use at the time, ISP-1, Instrument 'Line-

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Excess Flow Check Valve _ (EFCV) Operability Test', contained a

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prerequisite that stated in part that emergency safety system  !

actuations can occur dr- to the transient nature of the testing being performed. Therefore, any actuation is consid-ered -planned and not reportabl The team disagreed and stated that the actuation is expected, not planned, and could be. considered reportabl The team noted that this-type of ,

actuation has been reported by other utilities in the pas However, -based -on the minor safety significance of the actuation and its-thorough root 1cause_ discussion in the PORC meeting, the team determined that a Licensee Event Report was probably not warrante The team. pointed out'that placing these types of statements in procedures can detract from probing-root cause analysis and good corrective actions since-a._ formal report would not be required.- The team stated that better procedures, testing methods, training or . physical modifications that result from in-depth analysis could reduce or-eliminate such occurrence .2 . Station Manacoment-Involvement The team concluded that station management was appropriately involved in restart activities and that -the daily outage meetings provided adequate coordination and communication between departments. The team attended daily morning outage -

r meetings, in which the Resident Manager, Superintendent of l Power and other key supervisory personnel were in attendance.

I The meetings were run by the planning superintendent and major work to,be completed prior-to restart was discussed by each

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department superintendent. The teams noted that there was not'

an overall detailed document-to track the status of items-to be completed prior to restart including work-. requests, surveillance tests, adverse qualit;> condition reports (AQCRs).,

valve checkoff lists, and modifications. However, department'

superintendents had general tracking documents at- their disposal to track these item Status of these issues were presented orally during the meetings;and an overall schedule was kept on the blackboard in the meeting room. Management was actively involved in the meetings by asking thorough questions of their . subordinates and by providing positive directio :

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. Quality Assurance Involvement The team reviewed quality assurance department activities to determine the adequacy of nonconformance tracking and involve--

ment with restart activitie l NYPA uses a Status of Nonconformances A 'nd Corrective Actions tracking syste This system' contained all open.AQCRs_to

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y dat The system contains relevant information such as a !

description, the system, responsibility,-outage relationship, .'

and various issue, response,-completion.and-QA verification date For outage tracking purposes,- the QA- department .

separately prints all AQCRs that most be closed prior to

I restar The team - reviewed this list - and - determined that- ,

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there were 8 AQCRs that had'to be closed or dispositioned prior to restart, The team also reviewed all open.AQCRs and agreed that:all stattup related AQCRs were being tracked by the QA departmen ,

The QA department recently developed a startup checklist-that would be used by their personno.1 to monitor operators from-startup to the run mod The QA personnel will also be monitoring reactor engineering-activities during startup and power ascensio The QA department recently instituted - a ;

" Quality Assurance observation and Monitoring Checklist" that f would be used to perform broad, . basic audits -.of = various i activities in the plan .4 Summary PORC meetings were well facilitated and useful, and question-ing attitudes by PORC members were eviden Technical '-

Specification and procE2ral requirements relative to PORC were me Outage meetings provided adequate coordination and communication between departments and provided edequate i management oversight of restart activities. The eight:AQCRs required to be closed prior to restart were being -well-. tracked l'

by the QA departmen QA involvement Ja other restart activities was adequate, i EXIT INTERVIEW l During the inspection, the team leader periodically informed the Superintendent of Power of preliminary inspection find-ing An exit meeting was held on June 8, 1990,~with the Resident Manager and members of his s.taff to summarine the inspection scope and finding ~

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, W Attachment Selected Plant Modifications i

Modification Title '

F1-75-253 RHR Keep-Full System F1-85-054 ATWS ARI-& RPT: System Upgrade-F1-86-003B Site Utilities Expansion Project -(Fire Protec- ,

tion Water Supply)  !

F1-86-094 Fire Protection & Residual Heat Removal Ser- ,

vice Water Removable Cross-Connection F1-87-052 Installation of Power Disconnect . Switch , and' j Relocation of Isolation-Switch for 10MOV-18

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F1-87-164 Drywell Pneumatic Supply Pressure Alarm F1-88-028 Vibration Monitoring System for Recirculation- I Pumps & Motors-(Phase I)

,1 F1-88-086 . Elimination of the Rod ' Sequence Control- System F1-88-253 Traversing Incore Probe System Upgrade'

Governor ' Shutdown ' Solenoid',- Emergency Diesel

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F1-89-036 Generator F1-89-046 In-Core Stress Corrosion Monitoring System

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F1-89-094 Removal of Time Delay ' Relays in HPCI & RCIC System' Steam Line Leak Detection & Isolation F1-89-096 Second. Level = Undervoltage- Relay Setpoint 2 Change for Emergency Buses, Transformer TAP ~

Changes

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Attachment Ooeratina Procedures Reviewed

'I F-OP-13,- " Residual Heal Removal System," Revision 51, May 17,1990 {

F-OP-15,. "High Pressure Coolant-Injection," Revision'30,-May 9, 1990?

. . . i F-OP-19,. " Reactor Core Isolation Cooling System," Revision 22, May-23,-1990 F-OP-27, " Recirculation System," Revision'30, May 23, 1990- I

.-i F-OP-33, " Fire Protection,"-Revision 18, January-24, 199 h

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F-OP-64, " Rod Worth. Minimizer,"LRevision 8, May 16, 1990 F-OP-69, " Rod Sequence Control System," Revision 6, May 23, 1990 ~t F-OP-89A, " Hydrogen Addition System," Revision 7, May 30, 1990

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