IR 05000333/1997002

From kanterella
Jump to navigation Jump to search
Insp Rept 50-333/97-02 on 970223-0412.Violation Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support
ML20196G508
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/08/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196G487 List:
References
50-333-97-02, 50-333-97-2, NUDOCS 9705200312
Download: ML20196G508 (27)
v • d • e


Text

. . . _ _.__ _ __. . _ . . _ . _ . _ . _ . _ . . _ ._ __

.

.

U.S. NUCLEAR REGULATORY COMMISSION Region i License No.: DPR-59 Report No.: 97-02 Docket No.: 50-333

.

Licensee: New York Power Authority .

Post Office Box 41 Scriba, New York 13093 l

Facility Name: James A. FitzPatrick Nuclear Power Plant  ;

Dates: February 23,1997 through April 12,1997 l Inspectors: G. Hunegs, Senior Resident inspector R. Fernandes, Resident inspector E. King, Physical Security inspector D. Silk, Senior Emergency Preparedness Specialist Approved by: Curtis J. Cowgill, Chief Projects Branch 2 Division of Reactor Projects i

,

I f

!

!

,

.

  • l I

!

$

.

,

'

9705200312 970508 PDR ADOCK 05000333

'

O PDR _

.

.

EXECUTIVE SUMMARY l James A. FitzPatrick Nuclear Power Plant NRC Inspection Report 50-333/97-02 Operations e The inspectors conducted frequent reviews of ongoing plant operations. An observation concernin0 improper operator activities which resulted in the mistaken withdrawal of a control rod is described in a special NRC inspection report 50-333/9700 Maintenance e Overall, maintenance and surveillance activities were well conducted, with good adherence to both administrative and maintenance procedure Enaineerina

  • On January 24,1997 while preparing to enter shutdown cooling, the D residual heat removal (RHR) pump tripped following the automatic closure of the two shutdown cooling isolation valves. Previous corrective actions for resolution of the long term problem of shut down coolingi isolation events were inadequate. The failure to complete corrective actions for the previous spurious automatic engineered safety feature actuations (shutdown cooling system isolation) in a timely manner placed additional challenges on the operators when taking the reactor plant to a cold shutdown line-up. The licensee has made several procedure changes i the past and had installed a modification to the instrument lines. However, the efforts of the licensee to complete the final corrective actions have not been successful. (VIO 50-333/97002-01)
  • As documented in LER 50-333/95009, engineered safeguards feature actuations have occurred because of the difficulty involved in installing jumpers. Corrective actions developed to improve electrical jumper installation included the installation of a test connection using a generic modification. The long term effectiveness of the corrective actions were being challenged by the fact that the generic modification was not being tracked in a watchful manner. The process for installing jumpers warranted additional attention by the license Plant Suocort
  • The licensee has installed refueling area radboon monitors, maintains several procedures which describe evacuation activities necessary should an inadvertent criticality occur and conducts periodic evacuation drills. Based on this, the licensee meets the intent of the regulations governing criticality monitors, ii

. _ . . _._.- . . _ . . _ _ _ _ . _ . _ . - _ . . . _ _ _ . - - . . _ _ _ _ _ - . _ _ . . _ __._ - . . _. . . _ -

.

>

.

Executive Summary (cont'd)

,

o The licensee maintained an effective security program. Management support was [

evident by the timely completion of the uninterruptible power supply and I assessment aid upgrades and security manning levels. Controls were in place for ~

l . personnel' access into protected and vital areas, alarm station operators were  ;

knowledgeable of their duties and rssponsibilities, and the assessment aids had

'

excellent picture quality. Security cIsining was being performed in accordance with ,

the NRC-approved training and qualification plan, and management controls for  !

'

identifying, resolving, and preventing programmatic problems appeared to be effective. Protected area detection equipment was consistent with the NRC- i approved Physical Security Plan (the P!an) and security equipment testing was being }

performed as required in the Plan. Maintenance of equipment was being performed  !

in a timely manner as evidenced by minimal compensatory postings associated with ,

l security equipment repair i

I i

,

i

l l

l t

'

!

i I

!

i

&

i

.

I

,

,. ,+ , -

. - - . - - - . . .. -~ . . - . - - _ . . --- .. .

,

,

.

TABLE OF CONTENTS EX ECUTIV E S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TA B LE O F C O NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Sum m a ry of Pla nt Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments ................................. 1 01.2 Operational Safety Verification . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 2 Engineered Safety Feature System Walkdowns .................. 2 t

11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 i M1 Conduct of Maintenance .................................. 3 M 1.1 General Ccmments on Maintenance Activities . . . . . . . . . . . . . . 3 M1.2 General Comments en Surveillance Activities . . . . . . . . . . . . . . . 3 M1.3 Conclusions on Condu::t of Maintenance . . . . . . . . . . . . . . . . . . 4 M8 Miscellaneous Maintenance issues ........................... 4 M8.1 (Closed) Unresolved item 50-333/94027-01 ............... 4 M8.2 (Closed) LER 50-333/96008 . . . . . . . . . . . . . . . . .......... 4 M8.3 (Closed) LER 5 0-3 3 3 /9 600 6 . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M8.4 (Closed) LER 5 0-3 3 3 /9 5 014 . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 111. Engineering ......................................... ......... 5 *

E8 Miscellaneous Engineering Issues . . . . ........................5 E8.1 (Closed) LER 50-333/97002 and URI 9 7001 -01 . . . . . . . . . . . . . 5 E8.2 (Closed) LER 5 0-3 3 3 /9 5 00 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I V. Pl a n t S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 P3 EP Procedures and Documentation ........................... 8 P8 Miscellaneous EP Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 ,

P8.1 Criticality Accident Requirements . . . . . . . . . . . . . . . . . . . . . . . 9 S1 Conduct of Security 'and Safeguards Activities . . . . . . . . . . . . . . . . . . 10 S2 Status of Security Facilities and Equipment .................... 10 S2.1 Protected Area (PA) Detection Aids . . . . . . . . . . . . . . . . . . . . . 10 S2.2 Alarm Stations and Communications . . . . . . . . . . . . . . . . . . . . 11 S2.3 Testing, Maintenance and Compensatory Measures . . . . . . . . . 11 SS Security and Safeguards Staff Training and Qualification .......... 12 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . 13 ,

S7 Quality Assurance in Security and Safeguards Activities . . . . . . . . . . . 13 S Effectiveness of Management Controls .................. 13 S7.2 Vital Area Access Control of Personnel . . . . . . . . . . . . . . . . . . 14 iv t

- . - . . . . .- . . - - . - ~ - . - - - . - . . . . . - - . .

.

.

.!

.

. f i Table of Contents (cont'd)

a

V. Management Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

X1 X2 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ,

e i

"

ATTACHMENT i

Attachment 1 - Emergency Plan and implementing Procedures Reviewed .

.

d 1

'l i

t

.

i l

i l

1 V 1

I

. . - . --

- _ . _ . . _ . . . _ . _ . _ . _ _ . _ _ _ __ __ _ . _ _ __. _ . _ _ . . _ . . . _ _ _

e g

-

,

5 .

Report Details

'

' Summary of Plant Statn The unit began this inspection period at 100 percent power. On March 3, a licensed reactor operator mistakenly withdrew one control rod from position 22 to 26. The results of the NRC review of this event are documented in a special NRC inspection report

'50-333/97003. On March 21, operators reduced power to 55 percent to complete scheduled maintenance which included scram time testing, cleaning condenser water boxes and inspections. On March 23, power was returned to 100 percent and remained there through the end of the inspection perio . Operations

,

01 Conduct of Operations'

01.1 General Comments  ;

The inspectors conducted frequent reviews of ongoing plant operations. An observation concerning improper operator activities which resulted in the mistaken withdrawal of a control rod is described in a special NRC inspection report 50-333/9700 .2 Operational Safetv Verification

)

The inspectors observed plant operation and verified that the facility was operated safely and in accordance with procedures and regulatory requirements. Regular tours were conducted of the plant with focus on safety related structures and systems, operations, radiological controls and security. Additionally, the operability of engineered safety features, other safety related systems and on-site and off-site power sources was verified. No safety concerns were identified as a result of these tour The inspection activities during this report period included inspection during normal, backshift and weekend hours. Regular tours were conducted of the following plant areas:

l control room secondary containment building  !

radi-clogical control point I electrical switchgear rooms emergency core cooling system pump rooms security access point protected area fence ,

i I

' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic .

.

intake structure diesel generator rooms Control room inctruments and plant computer indications were observed for correlation between channels and for conformance with technical specification requirements. Operability of engineered safety features, other safety related systems and onsite and offsite power sources was verified. The inspectors observed various alarm conditions and confirmed that operator response was in accordance with plant operating procedures. Compliance with Technical Specifications and implementation of appropriate actions statements for equipment out of service was inspected. Plant radiation monitoring system indications and coolant stack traces were reviewed for unexpected changes. Logs and records were reviewed to determine if entries were accurate and identified equipment status or deficiencies These records included operating logs, turnover sheets, system safety tags, and temporary modifications. Control room and shift manning were compared to regulatory requirements and portions of shift turnovers were observe The inspectors found that control room access was properly controlled and that a professional atmosphere was maintained. Daily supervisor meetings were attended to assess personnel focus on risk significant items and plant prioritie Specific plant issues which were followed up on included, turbine building off-gas levels, installation of the fish deterrent system, post accident sampling system maintenance, intermittent "A" station battery ground, "A" recirc pump seal fluctuations, electrohydraulic control system motor fan temporary modification, and licensed operator requalification training documentation discrepancies. These issues were managed effectively by the license O2 Operational Status of Facilities and Equipment 02.1 Enaineered Safety Feature Svstem Walkdowns The inspectors performed a walk down of accessible portions of the following systems and performed general area tours:

  • intake structure

'

Equipment operability, material condit ion and housekeeping conditions were goo __ _. _ _

- . . - . _ _ . _ _ . _ _. _ _ _ . _ _ _ _ .

.

11. Maintenance M1 Conduct of Maintenance M1.1 General Comments on Maintenance Activities Insoection Scope The inspectors observed all or portions of the following work activities:

e 96-06813 Hydraul!c control unit (HCU) accumulator N2 inlet isolation valve

  • 97-01236 On line leak repair for steam leak on moisture separator reheater (MSR) scavenging steam isolation valve e97-09708 Various intake water travelling screen inspections and replacements ;

, e95-03916 Travelling screen preventive maintenance *

l

  • 95-09017 Control rod drive pump breaker preventive maintenance Observations and Findinas
The inspectors found the work performed under these activities to be professional l and thorough. All work observed was performed with the work package present and in active use. Technicians were experienced and knowledgeable of their assigned task. The inspectors frequently observed supervisors monitoring job progress, and quality control personnel were present when required.- When -

applicable, appropriate radiation control measures were in place.

l M1.2 General Comments on Surveillance Activities Inspection Scoce The inspectors observed selected surveillance tests to determine whether approved procedures were in use, details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by knowledgeable personnel, and test results satisfied acceptance criteria or were properly dispositione The inspectors observed portions of the following surveillance activities:

CAP 074 Scram time testing

I l

.

.

4 Observations and Findinas The licensee conducted the above surveillance activities appropriately and in accordance with procedural and administrative requirements. Good coordination and communication were observed during performance of the surveillanc M1.3 Conclusions on Conduct of Maintenance Overall, maintenance and surveillance activities were well conducted, with good adherence to both administrative and maintenance procedure M8 Miscellaneous Maintenance issues M8.1 (Closed) Unresolved item 50-333/94027-01: On line leak repair of a feedwater heater. The unresolved item concerned the shelf life of leak sealant material. The inspector reviewed vendor technical information, the licensee's quality assurance (QA) vendor audit report and portions of the licensee's temporary leak repair procedure. Temporary leak sealants are an elastomer material used as sealant for valves, flanges or pipes until a scheduled maintenance outage can be performed when the leaking part will be permanently repaired. The inspector reviewed a memorandum from the licensee vendor concerning leak sealant compounds. The -

memorandum described nuclear grade sealants and stated that the materials, if stored below 20 degrees F, will exhibit an indefinite shelf life. The memorandum further stated that if properly stored, the integrity and properties of leak sealant compounds are not adversely affected. In 1995, the licensee performed a quality assurance surveillance report no.1766 which verified proper storage of leak sealant materials. The storage and control of nuclear sealants at the licensee's vendor was in accordance with the requirements of the vendor's QA progra M8.2 (Closed) LER 50-333/96008: High Pressure Coolant injection (HPCI) Inoperable Due to Failed Direct Current (DC) to Alternating Current (AC) Inverter. This issue was discussed in NRC inspection report 96-06. The inspectors concluded that the corrective actions were appropriate, inverter f ailure rates were low, and that the post-work testing and the timeliness of the corrective actions were adequate. The licensee determined the cause of the failures to be a random failure of an oil filled capacitor and committed to replacing capacitors in five additional inverters during the 1996 refueling outage. The inspector verified that these actions were complete M8.3 (Closed) LER 50-333/96006: Reactor Core isolation Cooling (RCIC) Isolation Due to Area High Temperature Isolation Signal from a Failed Master Trip Unit (MTU). With the plant operating at full power, an isolation of the reactor core isolation cooling system occurred. After verifying that there was no evidence of a high area temperature problem, the Instrument and Controls group determined that 13MTU-289B was the source of the isolation signal and trip. An equipment failure evaluation (EFE) performed by the licensee determined that the cause of the isolation was the random failure of a transistor in the MTU. The inspector reviewed the EFE and discussed previous MTU failures with the licensee. The licensee is

. ~.-.- - , - - . . ~ - . . - - - - - . - . - - -- -.. .-

,-

.

.

replacing the Rosemount MTUs with a newer model as problems develop with the older units. The inspector concluded that the corrective actions were adequat M8.4 (Closed) LER 50-333/95014: RCIC Auto isolation Instrument Channel Functional Test Missed Due to Personnel Error. The licensee determined during a periodic review of the l&C surveillance program that ISP-150A had not been performed within the required surveillance frequency. The period was exceeded by 5 days. In this event, because of personnel error, the surveillance for ISP-150B had been completed twice, on separate shifts, instead of ISP-150A and ISP-150B, and'-

therefore ISP-150A was not completed. The l&C surveillance schedule is part of a computer based program maintained by the l&C surveillance coordinator. The previous method used to update the schedule involved verification of completed 1

'

surveillance test utilizing a " task sheet", filled out by the supervisors and l technicians upon completion of the test. The licensee determined that this was a potential weakness in the process and changed the current practice to verifying completion of the surveillance by review of the actual ISP. Additional corrective actions included satisfactory completion of the surveillance test and review of test documentation to assure that no other surveillances were missed. The inspector l reviewed the corrective actions for the missed surveillance and found them to be j adequate with sufficient barriers in place to prevent recurrenc Ill, Enaineerina  !

l E8 Miscellaneouc Engineering issues E (Closed) LER 50-333/97002 and URI 97001-01: Shutdown Cooling -

l i

Isolation.

! Insoection Scroe l

!

l On January 24, while preparing to enter shutdown cooling, the D residual heat removal (RHR) pump tripped following the automatic closure of the two shutdown j cooling isolation valves. The licensee determined that the valves went closed 1 automatically after receiving an invalid high reactor pressure (> 75 psig) isolation l signal. The licensee subsequently vented the system and successfully entered shutdown cooling approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following the isolation. This issue was discussed in NRC inspection report 50-333/97001 and was determined to be an i unresolved item pending the completion of the licensee's review of the event. The )

inspectors reviewed the LER, previous corrective actions and operating procedures and discussed the system operation with plant staf Observations and Findinas i

Shutdown cooling is a manually initiated mode of the residual heat removal (RHR)

system that is placed in service during normal shutdown and cooldown. The initial phase of reactor pressure vessel (RPV) cooldown is. accomplished by discharging main steam to the main condenser through main turbine bypass valves. RPV cooldown is completed by aligning the RHR pump suction piping to the reactor

.

l l

l

_ _ _..._. ____..__.__.._ _.___

.

,

e

--

water recirculation loop B suction line. Reactor coolant is pumped through an RHR ;

heat exchanger and back to the reactor pressure vessel (RPV) through a reactor water recirculation loop. Heat from the reactor coolant is transferred to RHR service ;

wate Inadvertent shutdown cooling isolation upon initiation has been a longstanding ;

problem as indicated by LERs90-002, 90-011,90-016, 90-020,93-005, and 93- !

012 which documented the problem. The licensee had taken what they considered ,

to be extensive corrective actions including operating procedure changes to ensure !

adequate system venting, installation of modifications to reslope instrument lines and monitoring system performance. The following items indicate licensee efforts to resolve the problem since 1993: )

I

-

A November 11,1993, licensee memorandum, JSEM-93-049 Root Cause ,

Analysis of RHR Shutdown Cooling Isolations, noted that the most likely root '

'

cause appeared to be air in the pressure switch,02PS-128A, instrument tubing. Three recommendations were made in the memorandum, including scheduling modification M1-93-035 to remove the air trap in 02PS-128A instrument tubing, opening and inspecting 5 isolation valves, and initiating a modification to install a high point vent near the suction isolation valve, i 10MOV-17. An action commitment tracking system (ACTS) number was '

assigned to the issue and was scheduled to be closed on March 1,199 The air trap was removed, however, the high point vent was not installed. -

-

A December 1,1994, deficiency event report (DER) no. 94-1041 was written to document a problem with the drain valve used for venting the SDC suction piping becoming clogged with debris. Engineering memorandum, JTS-95-OO60 Difficulty In Filling and Venting Shutdown Cooling Suction Piping, documents the closure of the DER. The memo stated that "during the past three outages, it took from 3-8 hours to perform the fill and vent of the SDC suction piping." The memorandum justified the high point vent modification based on time and ALARA savings. PID 95-54812 was submitted to generate a modification installation / review and in May 1995, a work request, WR 94-07707 was written documenting that the modification met the screening criteria of station administrative procedures. The WR was sent to design engineering to generate a modification package. Attached to the WR was a memorandum from the system engineer stating that the modification willincrease plant availability by reducing outage time; reduce challenges to safety systems by adequately venting the RHR SDC suction piping; reduce the likelihood of water hammer and/or SDC isolations; and remove a significant operator work around by eliminating the need to use a 1 make-shift standpipe and numerous valve cycling iterations to vent the l suction piping through valves that were not designed for the task of ventin i Following the most recent event, a January 26,1997 engineering memo, JTS-97- !

0031, documented some of the history stated above and noted that the modification had not yet been scheduled. The recommended corrective actions :

i

!

_ _ . , . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . .

.

again state to install the high point vent modification prior to the next outage end to change the procedure to require a minimum time for venting the syste The most recent LER,97-002, stated that the modification was given low priority due to the absence of SDC isolation problems since 1993. Corrective actions documented in the LER include initiating a modification to provide a high point vent for improved venting capabilities. The modification is scheduled to be completed prior to the start-up from the next refueling outag l I Conclusions i I

The inspectors concluded that the previous corrective actions for resolution of the l long term problem of shutdown cooling isolation events were inadequat l Specifically, the licensee had proposed installation of a high point vent in the RHR :

system that was designed to prevent recurrence of the problem. The failure to complete corrective actions for the previous spurious automatic engineered safety ;

feature actuations (shutdown cooling system isolation) placed additional challenges

'

on the operators when taking the reactor plant to a cold shutdown line-up and resulted in an additional isolation in January, 1997.10 CFR Part 50 Appendix B, !

Criterion XVI, " Corrective Action," requires, in part, that measures shall be i established to ensure that conditions adverse to quality, are promptly identified and !

corrected, in addition corrective action taken to preclude repetition. Corrective actions taken following the May 19,1993, event were insufficient to prevent the reoccurrence of the shutdown cooling isolation event of January 24,1997. (VI /97002-01)

E8.2 (Closed) LER 50-333/95009: Partialinvalid Isolation of Reactor Building Ventilatio Insoection Scoce On April 25,1995, while preparing the reactor building ventilation exhaust radiation monitor for service, an electrical jumper slid off a terminal causing a fuse to blow, and resulted in an ESF actuation. The jumper was being installed to maintain circuit continuity to prevent inadvertent ESF actuation. On May 22,1995 while performing one of the corrective actions for the previous event, the same ESF actuation was inadvertently initiated when an existing circuit lead slipped out of a pair of pliers and grounded. Both events resulted in the isolation of the "A" reactor building ventilation system and "A" side primary containment sampling system and initiation of the standby gas treatment (SBGT) system. The inspectors reviewed the corrective actions for the event to evaluate the effectiveness of the planned corrective actions, Observations and Findinos

'

Corrective actions included installation of modification D1-93-058, Test terminal Lugs / Connectors, which was previously developed to install test connection lugs and ease jumper installation during testing. In addition, the LER stated that i attempts would be made to deenergize the circuits to cvoid any unexpected l

l l

l

.

_. . .. _ _ _ _ _ . _ _ _

.

i l

l l

8 l l

automatic initiations /isolations when installing the modifications. In cases where de-energizing the circuits was undesirable, corrective actions stated that appropriate precautions would be defined with potential plant impact of the work activity fully understood prior to conducting the wor The inspector discussed the modification with the engineering staff and learned that the modification was not completed and at the present time was not scheduled for completion due to low priority. The licensee stated that this modification was of a generic nature and was to be used when needed. The inspector questioned the aggressiveness of the corrective actions as there was very little evidence that the modification had been continued since the LER date. The licensee stated that because of the magnitude of the modification, the original scope was limited to those areas of high priority to the operations staff and equated to approximately 23% of the total modification. During the review of the LER, the inspector j determined that two other events involving jumper installation had occurred since the date of the LER. The inspector questioned the status of the modification as it ;

was apparent that problems involving the process of installing and removing i jumpers were still occurring. The licensee is currently assessing the status, pricrity, and scope of the generic modificatio Conclusions The inspectors concluded that the corrective actions for the first two events involving electrical jumper installation were adequate. However, the inspectors concluded that the long term effectiveness of the corrective actions were being challenged by the fact that the generic modification was not being tracked in a watchful manner. In review of the subsequent events, the inspector determined that the specific corrective actions for the first two' events could not be tied directly to the 1995 events, but the process for installing jumpers warranted additional attention by the license IV. Plant Support P3 EP Procedures and Documentation An in-office review of revisions to the emergency plan (E-Plan) and implementing procedures submitted by the licensee was completed. A list of the specific revisions reviewed is included in Attachment 1 to this inspection report. Based on the licensee's determination that the changes do not decrease the overall effectiveness of the emergency plan and after limited review of the changes, no NRC approval is required, in accordance with 10 CFR 50.54(q). Implementation of these changes will be subject to inspection in the future to confirm that the changes I

have not decreased the overall effectiveness of the licensee's emergency plan, t ,

!

l l

l l

.

l I

'

9 l l

P8 Miscellaneous EP issues l P8.1 Criticality Accident Reauirements Inspection Scope l

The inspector reviewed applicable procedures and licensee documents to verify that l the licensee has emergency procedures in place for evacuation and performs

'

evacuation drills. Additionally, the inspector interviewed operations and emergency preparedness personnel and performed a field walkdown to observe radiation monitor installation attribute I l Observations and Findinas The licensee is required to meet 70.24(a)(2) which requires that a monitoring device shall have a preset alarm point of not less than 5 millirems per hour nor more than l 20 millirems per hour. In no event may any such device be farther than 120 feet I from the special nuclear material being handled, used, or stored. The area radiation l monitor system is described in FSAR Section 7.13. The new fuel vault radiation '

monitor is considered to be the criticality monitoring device and is located within 120 feet of the spent fuel pool and the alarm setpoint is 20 mr/hr as required by operating procedure i l

10 CFR 70.24(a)(3) requires that licensees need to have emergency procedures in place for evacuation and perform evacuation drills. The inspector noted that the licensee has two primary procedures in place which provide direction for evacuation. EAP-10, Protected Area Evacuation, provides instructions for the evacuation of personnel from the protected area to designated primary assembly -

areas. EAP-11, Site Evacuation, provides instructions for the evacuation of personnel from the site to a remote assembly area, or home. Additionally, alarm response procedure 09-3-1-29 provides direction that if a new fuel storage radiation alarm is received and is unanticipated to conduct an evacuation and Abnormal Operating Procedure (AOP) 53, Loss of Spent Fuel Storage Pool, Reactor Head Cavity Well, or Dryer Separator Storage Pit Water Level, also provide direction concerning area evacuation. The inspector verified that the licensee conducts evacuation drills approximately once per quarte Conclusions The licensee has installed refueling area radiation monitors, maintains procedures which describe evacuation activities necessary should an inadvertent criticality occur and conducts periodic evacuation drills. The adequacy of this monitoring and the emergency procedures governing evacuation from areas near the new fuel storage vault will be determined in the future pending additional internal NRC guidance in this matter. (IFl 50-333/97-02-03)

i l

!

,

_ _ _ __. . _ . . . _ _ _ _ , _ _ _ . _ . . . _ . _ . . . .. _ _ _ _ __ _ _ _ _ _ _

-

.

!

.

.

.

10 I S1 Conduct of Security and Safeguards Activities l

. Insoection Scope

} The inspector reviewed the security program to determine whether the security -

program, as implemented, met the licensee's commitments in the NRC-approved

'

}

. security plan (the Plan) and NRC regulatory requirements. The security program

'

, was inspected during the period of March 11-14,1997. Areas inspected included:

i effectiveness of management control; management support; protected area detection equipment; vital area access control of personnel; alarm stations and i communication; testing, maintenance and compensatory measures; and training and j qualification.

, Observations and Findinas 1 j

4 <

l Management support was evident by the timely completion of the uninterruptible

! power supply and assessment aid upgrades and adequate security staffing levels for

,I effective program implementation. Controls were in place for personnel access to i protected and vital areas and alarm station operators were knowledgeable of their-

~

duties and responsibilities. In addition, protected area assessment aids had ,

! excellent picture qualit )

!

j Security training was being performed in accordance with the NRC-approved l training and qualification (T&Q) plan and management controls for identifying,-

! resolving, and preventing programmatic problems appeared to be effective as j demonstrated by a minimal number of logged and reported security-related events.

j Protected area (PA) detection equipment satisfied the Plan commitments and security equipment testing was being performed as required by the Pla '"

1 Maintenance of equipment was being performed in a timely manner as evidenced by I

minimal compensatory postings associated with non-functioning equipment.

i ( Conclusions i

The licensee was conducting its security and safeguards activities in a manner that j j protected public health and safety and that the program, as implemented, met the j licensee's commitments and NRC requirements.

i.

'

S2 Status of Security Facilities and Equipment ,

i

.

S Protected Area (PA) Dalection Aids i

inspection Scooe

, The inspector conducted a physical inspection of the PA intrusion detection systems i (IDSs) to verify that the systems were functional, effective, and met licensee j commitment i

!  !

1 i

!

- -

_ - -- . . - -. - .. . .- .. .~-.__ - - - -

,

!

l l 1 i

!

. l

' Observations. Findinas and Conclusion On March 13,1997, the inspector observed the testing of the IDSs and determined they were functional and effective, and were installed and maintained as described in the Pla .

S2.2 Alarm Stations and Communications Inspection Scope i The inspector observsd the Central Alarm Station (CAS) and Secondary Alarm Station (SAS) to determine whether they: (1) were equipped with appropriate l alarm, surveillance and communication capability, (2) were continuously manned by l operators, and (3) use independent and diverse systems so that no single act can remove the capability of detecting a threat and calling for assistance, or otherwise ,

responding to the threat, as required by NRC regulation i l Observations and Findinas i

l Observations of CAS and SAS operations verified that the alarm stations were  ;

equipped with the appropriate aiarm, surveillance, and communication capabilitie I

Interviews with CAS and SAS operators found them knowledgeable of their duties ,

l and responsibilities. The inspector also verified through observations and interviews l that the CAS and SAS operators were not required to engage in activities that

'

'

would interfere with the assessment and response functions, and that the licensee had exercised communication methods with the locallaw enforcement agencies as committed to in the Plan. Additionally, the inspector evaluated the effectiveness of

'

the assessment aids, by observing on closed circuit television (CCTV), a walkdown

! of the protected area. The inspector determined that the assessment aids in both alarm stations had excellent picture quality.

1 Conclusion The alarm stations and communications met the licensee's Plan commitments and

! NRC requirement S2.3 Testina. Maintenance and Comoensatory Measures Inspection Scoce l

The inspector reviewed applicable programs to determine whether tiscy */,ere properly implemented and will ensure the reliability of security related equipment, including proper installation, testing and maintenance to replace defective or l

l marginally effective equipment. Additionally, the inspector determined that when security related equipment fails, the compensatory measures put in place are j comparable to the effectiveness of the security system that existed prior to the failure.

.

!

l (

l .

-- - - . - - . . . - . . - - - . . - . . . - .. . .. - . . _ . - - - ._ _ .... -

<

l ..

i . .

12 Observations and Findinas The inspector reviewed testing and maintenance records for security-related

equipment and found that documentation was on file to demonstrate that the 4 licensee was testing and maintaining systems and equipment as committed to in the Plan. A priority status was being assigned to each work request and repairs were

.

normally being completed witnin the same day a work request necessitating i compensatory measures was generated. The inspector also noted that the working i l relationship between security, maintenance and the instrumentation and control-

! (l&C) departments were excellent as evidenced by no open work requests related to i security equipment during the review of maintenance record .;

l 4 Conclusions *

1 Documentation on file confirmed that security equipment was being tested and j

, maintained as required. Repair work was timely and the use of compensatory '

measures was found to be appropriate and minimal.

,

(

S5- Security and Safeguards Staff Training and Qualification

.  ! Insoection Scope

.

f  :

The inspector reviewed security training to determine whether members of the l

'

security organization are trained and qualified to perform each assigned security ..

j related job task or duty in accordance with the T&O Pla !

s

b .- Observations and Findinas 4 ,

'

I On March 13,1997, the inspector met with the security training coordinator and  ;

discussed training initiatives associated with ~ enhanced contingency response drills ,

'and tactical response training. Tha dbcussions revealed that the licensee's j rarotective strategies included tha use of time lines, target set analyses and - i i- hardening of defensive positions. Additionally, as a training initiative, contingency drills were being performed once every three days per shift. The inspector reviewed documentation associated with the performance of contingency response drills and noted that 192 drills were conducted in 1996 and 44 drills were conducted during 1997 as of the time of the inspection. The inspector also observed classroom requalification training associated with the use of force and determined that the  :

instructor was very knowledgeable of the subject matter and all course material was presented to the class in a professional manner. Additionally, the inspector interviewed a number of security force members (SFMs) to determine if they  :

,

possessed the requisite knowledge and ability to carry out their assigned dutie , Conclusions

Security training had been conducted in accordance with the T&O plan and that the

number and nature of contingency response drills were appropriate. Based on the

+

>

'

i

[

.

, - . . ,. .-. . , . . . _ , . -- , , ,,., - - ~ _ . . . -

__ . . . _ _ . _ _ _ _ . _ __ .._ _ _ ~ _ _

.

.

'

SFMs responses to the inspector's questions, and inspector observations, the training provided by the security training staff was considered 'sffectiv S6 Security Organization and Administration inspection Sco.pg The inspector reviewed of the level of management support for the licensee's physical security program, Observations and Findinas The inspector reviewed various program enhancements made since the last program inspection, which was conducted in July 1996. These enhancements included the l timely completion of the uninterruptible power supply and assessment aid upgrades l and security staffing levels were adequate for effective program implementation.

'

The inspector reviewed the Security Manager's position in the organizational structure and reporting chain. The Security Manager reports to the General Manager Support Services, who reports directly to the Site Executive Officer,

,

Additionally, the inspector noted that the fitness-for-duty and access authorization l programs, being safeguards related, report directly to the Security Manager.

l

! Conclusions Management support for the physical security program was determined to be effective. No problems with the organizational structure that would be detrimental to the effective implementatio~i of the security ar d safeguards programs were observed or reporte S7 Quality Assurance in Security and Safeguards Activities S7.1 Effectiveness of Manaaement Controls * Inspection Scone i The inspectc,: seviewed the licensee controls for identifying, resolving and preventing programmatic problem Observations and Findinas I

Licensee corrective action controls included the implementation of a departmental l self-assessment program and the performance , f the NRC-required annual quality assurance (QA) audits. The licensee also utilize 4 industry data, such as violations

'

of regulatory requirements identified by the NRC at other facilities, as criteria for self-assessment. The inspecter reviewed 133 self-assessments conducted during 1996 and 19 self-assessments conducted in 1997, along with applicable documentation. The inspector found that performance errors were being reduce .

_ _ _ . _ _ _ _ . - . _ _ - _ _ _ . _ _ _ _ . _ . _ . _ _ . _ . . . . - _ _ _ . _ . _ . _ _ . _ . _ _

!

+ _ ,

14 i i Conclusions

The licensee controls for identifying, resolving and preventing programmatic ;

problems were effectively implemente S7.2 Vital Area Access Control of Personnel

- Inspection Scooe  !

The inspector reviewed.the licensee's programs to determine if the licensee has l positive control over personnel access to the vital areas such that unescorted access during non-emergency conditions is limited to authorized personnel who need access to perform dutie I Observations and Findinas l

--The inspector determined, based on discussions with security management and a t review of records that contained the status levels for control room access, that 797 ;

of 1143 (70%) badged employees had been authorized for unescorted access to the l control room. .The licensee stated that because the control room is the plant work i

,

control center, a large number of plant personnel must have access in order to.be !

able to carry out their work. The licensee stated that even though several programs were in place to ensure the trustworthiness and reliability of employees, further limiting access to vital areas would be pursued. The licensee is in the process of re-evaluating access to all vital areas so that access is limited only to personnel who, need to perform duties in the specific vital area.

l c.- - Conclusion The licensee further stated the vital area access lists were currently in the process of being pared down after the last refueling outage that ended in December 199 This issue will be reviewed during a subsequent inspection. (IFl 50-333/97002-02)

V. Manaaement Meetinas j X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on April 17,1997. The licensee acknowledged the I findings presente The inspectors asked the licensee whether any materials examined during the inspection  !

! should be considered proprietary. No proprietary information was identified, i j .l

! ' X2 Review of UFSAR Commitments f A recent discovery of a licensee operating their facility in a manner contrary to the Updated

! Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused

review that compares plant practices, procedures and/or parameters to the UFSAR

,

description. While performing the inspections discussed in this report, the inspector i

i'

!

__ _ _ _ _ . _ _ _ . . - . . . _ _ ___ _ . . - - - _. .

,

l -

l e

! 15 reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedure and/or parameter Since the UFSAR does not specifically include security program requirements, the inspectors compared licensee activities to the NRC-approved physical security plan, which is the applicable document. While performing the inspection discussed in this report, the inspector reviewed Section 7.2 of the Plan, Revision 18 dated December 3,1996, titled,

!

" Testing and Maintenance of Communications Systems." The inspector determined, based j on discussions with security supervision and management reviews of applicable procedures l and records, and interviews with alarm station operators, that the security communication systems were being tested and maintained as described in the Plan.

,

-

!

!

l l

,

!

!

l I

' "

v

- _ - _ _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ . _ _ - _ .

.

.

PARTIAL LIST OF PERSONS CONTACTED Licensee P. Brozenich, Operations Manager M. Colomb, Plant Manager M. Leonard, Corporate Security Manager D. Lindsey, General Manager, Operations R. Locy, Training Manager J. Maurer, General Manager, Support Services D. Ruddy, Di 9ctor, Design Engineering T. Teifke, Security Manager D. Topley, General Manager, Maintenance D. VanDermark, Quality Assurance Manager

<

NRC

,

C. Cowgill, Chief, Projects Branch 2 l

__ ___ _ ____________________ _

, . -. - . - . __

,

.

INSPECTION PROCEDURES USED 37551 Onsite Engineering 62707 Maintenance Observations 61726 Surveillance Observations 71707 Plant Operations 71750 Plant Support 81700 Physical Security Program for Power Reacters ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-333/97002-01 VIO Inadequate corrective actions to prevent shutdown cooling isolation 50-333/97002-02 IFl Vital area access control 50-333/97-002-03 IFl Adequacy of emergency procedures governing evacuation from areas near the new fuel storage vault Closd 50-333/94027-01 URI On line leak repair of feedwater heater 50-333/95009 LER Partialinvalid Isolation of Reactor Building Ventilation 50-333/96006 LER RCIC isolation Due to Area High Temperature isolation Signal from a Failed Master Trip Unit (MTU)

50-333/95014 LER RCIC Auto isolation Instrument Channel Functional Test Missed Due to Personnel Error 50-333/96008 LER HPCIInoperable Due to Failed DC to AC Inverter ;

50-333/97002 LER Shutdown Cooling Isolation 50-333/97001-01 URI Modification to install vent to prevent shutdown cooling isolation Discussed None

_ , _ . __ _ _

.

. 18 LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers BWR Boiling Water Reactor CAS Central Alarm System CCTV Closed Circuit Television CDF Core Damage Frequency CFR Code of Federal Regulations CREFAS Control Room Emergency Fresh Air System DAW Dry Active Waste DP differential pressure dpm disintegracions per minute ECCS Emergency Core Cooling System EDG Emergency Diesel Generator ESF Engineered Safety Feature FME Foreign Material Exclusion FR Federal Register FWLCS Feedwater Level Control System HCU Hydraulic Control Unit HPCI High Pressure Coolant injection IDS Intrusica Detection Systems IFl Inspection Followup Item IPE Individual Plant Evaluation IR Inspection Report ISEG Independent Safety Engineering Group ISI Inservice Inspection IST Inservice Testing LER Licensee Event Report LSA Low Specific Activity MSIV Main Steam isolation Valves NCR Nonconformance Report NCV Non-Cited Violation NDE Non-Destructive Examination NRC Nuclear Regulatory Commission OSHA Occupational Safety and Health Administration PA Protected Area PEP Performance Enhancement Program PCRVICS Primary Containment and Reactor Vesselisolation Control System ppm parts per million PSA Probabilistic Safety Assessment l psig pounds per square inch gage l QA Quality Assurance i QC Quality Control RCA Radiological Controlled Area RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal RP Radiation Protection  ;

'

RP&C Radiological Protection and Chemistry RWCU Reactor Water Clean-Up j

. _. ... __ _ . . _ . . . . . _ . _ _ _ _ . . . _ _ . _ . _ _ - . . _ . , . - _ _ . _ . _ . . . _ . _ _ . = . _ _ _ _ _ _ _ . _ _ _ _ _ . . _ . ..

,

, 19 i

RWP Radiation Work Permit  !

SAS Secondary Alarm System  !

'

SCO Surface Contaminated Objects SFM Security force member l SRV Safety Relief Valve l The Plan NRC Approved Physical Security Plan i l T&Q Training and Qualification  :

TS Technical Specification  !

UE Unusual Event ,

UFSAR Updated Final Safety Analysis Report l

[' VIO Violation '

l I

'

i l

l

.

l

!  :

i

! l l t l

i i

!

[ 1

'

i

,

!

!

l

[ i

i

,

!

l

i

, - - . _ . - _ -

_ . . - _ __ _ _ . . _ _ . ._ _ _ _ . . . . _ _ . _ _ . _ _ ..

t

, ATTACHMENT 1

[ EMERGENCY PLAN AND IMPLEMENTING PROCEDURES REVIEWED ,

Document Document Title Revision

,

Plan Section 1 16 l Section 2 14 Section 3 8 Section 4 13 Section 5 31 Section 6 19 Section 7 18 Section 8 19 Section 9 11 Appendix A 14 Appendix B 4 Appendix C 19 t

'

Appendix D 4 Appendix E 4 Appendix F 9 l

'

Appendix G 2 Appendix H 20 Appendix l 7 l

Appendix J 5 l l Appendix K 4 1 l Appendix L 9 l l Appendix N 9 I

LAP-1 Emergency Plan implementation Checklist 21 l IAP-2 Classification of Emergency Conditions 17 EAP- Offsite Notifications 36 l EAP-2 Personnel Injury 21 l EAP-3 Fire 19 i EAP-4 Dose Assessment Calculations 27 EAP- Release Rate Determination 7 EAP- Onsite/Offsite Downwind Surveys and

,

Environmental Monitoring 6 j EAP-6 in-Plant Emergency Survey / Entry 15

! EAP-8 Personnel Accountability 34 AP-9 Search and Rescue Operations 9 AP-10 Protected Area Evacuation 13 l AP-11 Site Evacuation 15 AP-12 Dose Estimated From An Accidental Release of Radioactive Material to Lake Ontario 9 AP-13 Damage Control 11 AP-1 Technical Support Center Activation 18 AP-1 Emergency Operations Facility Activation 15

, AP-1 Operational Support Center Activation and i Operation 13 AP-1 Habitability of the Emergency Facilities 13 i AP-15 Emergency Radiation Exposure Criteria and Control 10 AP-16 Public Information Procedure 6

__

.

.

, Attachment 1 2 Document Document Title Revision AP-17 Emergency Organization Staffing 73 AP-19 Emergency Use of Potassium lodide (KI) 17 EAP-20 Post Accident Sample, Offsite Shipment and Analysis 8 EAP-22 Operation and Use of Radio Paging Device 27 EAP-23 Emergency Access Control 10 EAP-24 EOF Vehicle and Personnel Decontamination 8 EAP-26 Plant Data Acquisition System Access 11 EAP-27 Estimation of Population Dose Within 10 Mile Emergency Planning Zone 8 EAP-28 Emergency Response Data Systems (ERDS)

Activation 5 EAP-29 EOF Ventilation Isolation During an Emergency 4 EAP-34 Acceptance of Environmental Samples at the -

EOF /EL During an Emergency 3 EAP-35 EOF TLD issuance During an Emergency 6 EAP-36 Environmental Laboratory Use During an l Emergency 4 I EAP-37 Security of the EOF and EL During Drills, Exercises and Actual Events 4 3

. EAP-40 EOF Radio System 3 J EAP-42 Obtaining Meteorological Data 11 1 EAP-43 Emergency Facilities Long Term Staffing 34

EAP-44 Core Damage Estimation 4

)

i EAP-45 Emergency Response Data System (ERDS)

Configuration Control Program 5 SAP-1 Maintaining Emergency Preparedness 13 SAP-2 Emergency Equipment Inventory 22 SAP-3 Emergency Communications Testing 51,52 SAP-4 NYS/ Oswego County Emergency Preparedness Photo identification Cards 6 SAP-5 Offsite Emergency Plan Inventory 10

<

SAP-6 Drill / Exercise Conduct 13 1 SAP-7 Monthly Surveillance Procedure for On-Call Employees 31

-

SAP-8 Prompt Notification System Failure / Siren System False Activation 10 SAP-10 Meteorological Monitoring System Surveillance 6 SAP-11 EOF Document Control 7 SAP-13 EOF Security and Fire Alarm Systems During Normal Operations 2

) SAP-16 Utilizing EPIC IDT Terminals From Destiny System 3 SAP-17 Emergency Response Data System (ERDS)

Quarterly Testing 6 SAP-19 Severe Weather 3 SAP-20 Emergency Plan Assignments 12

. . . _ _ _ . _ _ _ . _ _ . . _ _ . - - . . _ _ , . ____.m___.___.__ . _ _ . - _ . . , . . . . . ~ ~ . . _ . _ . _ _ _ _ . . _ _ . . , _

i

'

.

l

, Attachment 1 3 1 i

Document Document Title Revision

.

SAP-21 Placement, Testing and Operation of Wireless .

Telephone Equipment in Plant Environs 1 1 SAP-22 Emergency Planning Program Self Assessment O

'

l

'

i

<

l l

<

l

'

l.

,

!

<

I

,

1 I

l I

!

t

f

,

!

l l

)

,

t i

,

'

&

i

., . - ,. - - , . - , -. , - . , , - n.. ,. . . . . , , - ,. . . , . - -,

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000333/1997002&oldid=2978812"