IR 05000333/1999001
| ML20204J396 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/23/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20204J384 | List: |
| References | |
| 50-333-99-01, 50-333-99-1, NUDOCS 9903300084 | |
| Download: ML20204J396 (31) | |
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i U.S. NUCLEAR REGULATORY COMMISSION l
REGION I
Docket No:
50-333 License No:
DPR-59 Report No:
99-01 l
Licensee:
New York Power Authority Facility:
James A. FitzPatrick Nuclear Power Plant i
Location:
Post Office Box 41 j
Scriba, New York 13093 Dates:
January 11 - February 28,1999 Inspectors:
R. Rasmussen, Senior Resident inspector B. Norris, Resident inspector T. Moslak, Radiation Specialist
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P. Frechette, Physical Security inspector T. Kenny, Senior Operations Engineer T. Shediosky, Senior Reactor Analyst Approved by:
J. Rogge, Chief Projects Branch 2 Division of Reactor Projects 9903300084 990323 DR ADOCK 050003 3
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EXECUTIVE SUMMAR f James A. FitzPatrick Nuclear Power Plant NRC Inspection Report 50-333/99-01 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covered a seven week period of resident inspection and the results of a solid radioactive waste management and radioactive materials transportation inspection by a region based specialist, an integrated security inspection by a regional specialist, and a specialinspection of operator work arounds.
O_perations NYPA appropriately responded to a tripped circulating water pump and identified and extinguished a small electrical fire in the motor junction box. The use of thermography to evaluate the other circulating water pumps was a prudent measure. (Section 01.2)
In the control room, safety systems were aligned properly for current plant operations, and the appropriate Technical Specification (TS) Limiting Conditions for Operation (LCO) actions were implemented for unavailable equipment. Shift personnel were knowledgeable of the reasons for anomalous indications and annunciators. The control room environment was good; the staff exhibited formal communications, access was limited, annunciator response was appropriate, and shift supervision demonstrated good command and control. (Section O2.1)
FitzPatrick personnel established an acceptable process for evaluating, tracking, and correcting operator work arounds. The individual and cumulativo effect of existing operator work arounds did not adversely impact the ability of operators to safely operate the plant. Operator work arounds were resolved in a timely manner commensurate with their safety significance.
(Section O2.2)
During review of a 1997 open item, the inspectors identified that NYPA had determined that the continued used of alternate means for verifying all control rods were inserted following a reactor scram was not consistent with industry practice and did not provide a positive confirmation that the reactor was shutdown under all conditions without the need for boron injection. Following discussions with the NRC inspectors, NYPA revised the Abnormal Operating Procedure (AOP-1," Reactor Scram") to remove the alternate means of verifying control rods were full-in. The failure to adequately resolve this issue in a timely manner is a violation of 10CFR50, Appendix B, Criterion XVI. " Corrective Action." (NCV 50-333/99-01-01) (Section 08.2)
Maintenance During troubleshooting of an unexpected annunciator received during a surveillance test of the emergency diesel generators, NYPA noted that the circuitry was wired incorrectly. The breaker was a spare that had been insta!!ed the previous month, yet the post-work testing did not identify that the annunciator alarmed during that test also. The failure to conduct an adequate test of the breaker is a violation of 10CFR50, Appendix B, Criterion XI, " Test Control."
(NCV 50-333/99-01-02) (Section M1.2)
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L Executive Summary (cont'd)
The NYPA scaffolding control procedure was weak in that it did not address structures constructed of scaffold materials that were not used for personnel. Two scaffold structures located in safety related areas were not adequately installed or controlled. The failure to adequately control scaffolding in the vicinity of safety related equipment is a violation of 10CFR50, Appendix B, Criterion lil, " Design Control." (NCV 50-333/99-01-03) (Section M3.1)
Engineering The annual test of the high pressure cooiant injection (HPCI) system was adequately performed. The conduct of the pre-evolution brief with key personnel absent, and the missed opportunity to note and address pressure gagec indicating off scale high were performance lapses noted by the inspector. The failure to exhibit of questioning attitude with regard to observing system performance beyond the requirements of the test procedure was an example of a lapse in system engineering performance. (Section E1.2)
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Plant Support I
The solid radioactive waste management and transportation programs were adequately implemented as evidenced by an experienced staff carrying out detailed procedures.
Radioactive waste and other radioactive materials were properly characterized, classified, stored, packaged and shipped. (Sections R1, R2, RS)
Performance of the radwaste/ shipping group was adequately monitored by the QA department.
Problem areas were identified through audits, surveillances, and focused assessments. Issues were elevated to the appropriate management level for resolution. (Section R7)
-The licensee was conducting security and safeguards activities in a manner that protected public health and safety in the areas of alarm stations, communications, access controls, assessment detection aids, procedures, and documentation. This portion of the program, as implemented, met the licensee's commitments and NRC requirements. (Sections S1, S2, S3,)
The security force members (SFMs) adequately demonstrated that they had the requisite knowledge and received appropriate training necessary to effectively implement the duties and responsibilities associated with their position, (Sections S4, SS)
The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic needs. (Section S6)
The review of the licensee's audit program indicated that the self-assessment program was being effectively implemented to identify and resolve potential weaknesses. (Section S7)
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TABLE OF CONTENTS l
EX ECUTIVE SU MMARY...................................................... ii TABLE OF CONTENTS..................................................... iv Summary of Plant Status.................................................... 1 1. O P E RATI O N S........................................................... 1 O1 Conduct of Operations........................................... 1
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O1.1 G e n e ral Com m e nts....................................... 1 01.2 Circulating Water Pump Fire................................ 1
Operational Status of Facilities and Equipment........................ 2 O2.1 Verification of Control Room Switches and Indications............. 2 O2.2 Ope rator Work Arounds.................................... 3
Miscellaneous Operations issues................................... 5 08.1 (Closed) Licensee Event Report (LER) 98-08.................... 5 08.2 (Closed) Inspector Follow item 97-05-01....................... 5 08.3 (Closed) Violation 50-333/97-10-01........................... 7 11. MAI NTE N A NC E......................................................... 8 M1 Conduct of Maintena ice......................................... 8 M1.1 General Comments....................................... 8 M1.2 Troubleshooting and Repair of the "D" EDG Output Breaker........ 8 M3 Maintenance Procedures and Documentation....................... 10 M3.1 - Control of Scaffold Materials............................... 10 M8 Miscellaneous Maintenance issues................................ 11 M8.1 (Closed) Licensee Event Report 50-333/98-14.................. 11 Ill. EN G I N E E RI NG........................................................ 1 1 E1 Conduct of Engineering......................................... 11 E1.1 General Comments...................................... 11 E1.2 Annual High Pressure Coolant injection (HPCI) Surveillance Test... 12 E8 Miscellaneous Engineering issues................................. 13 E8.1 (Closed) Violation 50-333/98-01 -01.......................... 13 I V. P LANT S U P P O RT...................................................... 13 j
R1 Radiological Protection and Chemistry (RP&C) Controls................ 13
R1.1 Solid Radwaste Processing, Handling, Storage, and Shipping...... 13
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R2 Status of RP&C Facilities and Equipment........................... 14
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R2.1 Radwaste Tou rs......................................... 14 R5 Staff Training and Qualification in RP&C............................ 15 RS.1 Review of Training Records................................ 15 R7 Quality Assurance and Self-Assessment in RP&C Activities............. 16 R7.1 Review of Audits and Surveillances.......................... 16 R8 Miscellaneous RP&C issues..................................... 17 iv
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Table of Contents (cont'd)
R8.1 (Closed) Violation 50-333/98-01 -04.......................... 17 S1 Conduct of Security and Safeguards Activities........................ 17 S1.1 Security Program Review.................................. 17 S2 Status of Security Facilities and Equipment.......................... 18 S2.1 Inspection of Security Equipment............................ 18
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S3 Security and Safeguards Procedures and Documentation............... 19 S3.1 Review of Security Documentation........................... 19 S4 Security and Safeguards Staff Knowledge and Performance............. 19 S4.1 Security Staff Knowledge.................................. 19
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SS Security and Safeguards Staff Training and Qualification............... 20 S5.1 Security Staff Training.................................... 20 S6
.%curity Organization and Administration........................... 20 W
Security Management Support, Effectiveness and Staffing Levels... 20 S7 Quality Assurance (QA) in Security and Safeguards Activities............ 21 S7.1 Security Audits and Management Controls..................... 21 V. MAN AG EMENT ME ETI NG S............................................... 22 X1 Exit Meeting Sum mary.......................................... 22 ATTACHMENTS Attachment 1 - Partial List of Persons Contacted-Inspection Procedures Used
- ltems Opened, Closed, and Discussed
- List of Acronyms Used v
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Report Details Summarv of Plant Status The unit began the inspection period at 95 percent reactor power, in the process of ramping up from the refueling outage, and achieved 100 percent operation on January 12,1999. The reactor remained at 100 percent power during the hydrogen fire. The unit operated consistently at full power until February 27,1999, when a small electrical fire in a circulating water pump electrical box caused a power reduction to 65 percent. The reactor was at 65 percent at the end of the inspection period.
On January 14,1999, there was a fire in the hydrogen (H ) storage facility at the northwest
corner of the protected area at FitzPatrick. The facility entered the Emergency Plan, declared an Unusual Event, and requested offsite fire department assistance. An NRC Special Inspection Team was sent to the site to review: (1) the actions taken by NYPA during the event, (2) the design and operation of the H system, (3) the design and operation of the
emergency diesel generators (EDGs), and (4) the root cause analysis. NRC Inspection Report 50-333/99-02 documents the results of the special inspection.
1. OPERATIONS
Conduct of Operations O1.1 GeneralComments (71707)
Using NRC Inspection Procedure 71707, the resident inspectors conducted frequent reviews of ongoing plant operations. The reviews included tours of accessible and normally inaccessible areas, verification of engineered safety features (ESF) system operability, verification of adequate control room and shift staffing, verification that the unit was operated in conformance with the Technical Specifications (TS), observations of infrequently performed surveillance tests, and verification that logs and records accurately identified equipment status or deficiencies. In general, the conduct of operations was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections below.
O1.2 Circulatina Water Pumo Fire a.
Insoection Scope (93702)
On February 27,1999, the "A" circulating water pump tripped due to an electrical short circuit. A small electrical fire resulted. The inspectors reviewed the actions taken by NYPA in response to this event, b.
Observations and Findinas The "A" circulating water pump tripped and a small fire developed in the electrical junction box on the motor. An operator responding to the tripped pump identified and extinguished the fire within eight minutes. The fire caused minor damage to the wiring within the electrical junction bo.
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With one of three circulating water pumps tripped, the reactor power was reduced to 65 percent. The circulating water pumps move lake water through the main condenser to iLv"a uste heat from the plant. The circulating water pump motors are large 1000 horse power,4160 volt motors.
The preliminary conchslon by NYPA was that the fire was caused by a high resistance electrical connection between a copper wire and an aluminum wire lug. This poor connection heated up and caused an electrical short which melted a hole in the junction box cover and ignited the fire. The connection that caused the fire was installed by the
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original pump manufacturer and had not been disturbed by NYPA. The formal equipment failure evaluation was ongoing at the end of the inspection period.
NYPA was able to replace the damaged connectors and return the pump to service.
The other two circulating water pumps were checked by thermography to look for hot electrical connections. No other hot connections were identified.
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Conclusions NYPA appropriately responded to a tripped circulating water pump and identified and extinguished a small electrical fire in the motor junction box. The use of thermography to evaluate the other circulating water pumps was a prudent measure.
'02 Operational Status of Facilities and Equipment O2.1 Verification of Control Room Switches and Indications a.
Insoection Scooe (71707)
i The inspectors performed a detailed comparison of the operating panelin the control room against a checklist of expected normalindications and switch positions, b.
Observations and Findinas Using the Operational Safety Verification (OSV) Checklist, the inspectors reviewed the control room switch positions and indications. During the review, the inspectors noted that the unit was at full power, and safety systems were aligned properly for full power operation. All differences between the OSV Checklist and actual plant status were verified for those systems removed from service for maintenance, and the inspectors verified that any applicable actions were implemented for the respective TS Limiting Condition of Operation (LCO). The inspectors also verified that shift personnel were knowledgeable of the reasons for the anomalous indications and annunciators.
While performing the OSV Checklist, the inspectors verified that shift staffing was in compliance with TS requirements. The inspectors noted that the staff exhibited formal communications. Entry into the "at the-controls" area was restricted. Operator annunciator response was appropriate; alarm response procedures were referenced, and shift supervision demonstrated good command and contro _ _ _
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The inspectors noted a good control room environment, in that only personnel requiring access to the at-the-controls area were present and promptly exited the area upon completion of duties. The overall control room environment was good. The turnover briefing for the on-coming shift was thorough, with good two-way exchange of information between supervision and staff.
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Conclusions in the control room, safety systems were aligned properly for current plant operations, and the appropriate TS LCO actions were implemented for unavailable equipment. Shift personnel were knowledgeable of the reasons for anomalous indications and
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annunciators. The control room environment was good; the staff exhibited formal
. communications, access was limited, annunciator response was appropriate, and shift supervision demonstrated good command and control.
O2.2 Ooerator Work Art e lds a.
Insoection Scope (Tl2515/138)
The inspectors reviewed the operator work around program to verify that the cumulative effect of operator work arounds did not adversely impact the ability of operators to safely operate the plant. The inspectors also reviewed the quality of corrective actions taken to resolve work arounds.
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Observations and Findinas Procedures and Criteria FitzFatrick's administrative procedure (AP)-10.01 " Problem identification and Work Control," defined an operator work around as "Any deficiency (equipment, procedural, or other) that would require compensatory operator actions in execution of normal operation procedures, abnormal operating procedures, emergency operating procedures, or annunciators response procedures during off-normal conditions." This procedure contained the means and directions for the Shift Manager (SM) to identify and designate an operator work around. The recognized work arounds appeared on a master list posted in the control room.
Another procedure, surveillanco test (ST)- 99H, " Operator Work Around Assessment,"
was used to evaluate the aggregate and cumulative impact of the outstanding operator work arounds on crew response to off normal and emergency conditions, review their
- current scheduled repair of corrective action dates, and provide input to revise maintenance, engineering and planning schedules if necessary to alleviate operator burden. This procedure was performed at the Oporations Manager's discretion or quarterly, as a minimum. The review was performed by a team made up of an operations senior reactor operator (SRO), a planning SRO, and an operations training instructor. The inspectors reviewed past evaluations and noted that the master list of operator work arounds was adjusted to reflect the findings of the team.
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The inspectors concluded there were sufficient procedures in place to identify operator
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work arounds and evaluate them for cumulative burdens on plant operators. The inspectors also concluded that FitzPatrick personnel were using the procedures i
effectively.
I identification of Operator Work Arounds j
As delineated above, operator work around identification is the responsibility of the SM.
After review of selected plant identified deficiencies (PIDs) and discussions with plant personnel, the inspectors determined that, during the routing process, the SM evaluated tne PIDs for operator work arounds. Those identified were placed on a master list that is maintained in the control room. All new additions to the master list were discussed during shift briefings for operator awareness.
The master list of thirteen operator work arounds was comprehensive and covered a wide range of plant systems, both safety and nonsafety-related. After interviews with operators and plant supervision, observations of ongoing activities, and review of selected procedures, the inspectors found the operator work around list to be complete.
Also, the inspectors found that plant operators were familiar with the current work arounds. The inspectors concluded that FitzPatrick personnel had an acceptable process for the identification and control of operator work arounds.
Assessment of Individual Work Arounds The inspectors reviewed all thirteen operator work arounds to assess their individual impact on plant operational safety. The inspectors determined each of the work arounds had been analyzed by FitzPatrick personnel and were in the process of being corrected, or in a tracking system scheduled to be repaired when the plant was in a i
favorable mode. The inspectors concluded these !r,ues had low safety significance and
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did not adversely affect the operators ability to safely operate the plant.
Cumulative Effect of Operator Work Arounds
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The inspectors assessed the cumulative burden of the existing operator work arounds and concluded that the burden on the operators was negligible. There was also no appreciable risk associated with the compensatory actions being implemented. The work arounds required little or no operator compensatory actions. The inspectors concluded that the licensee was taking effective corrective actions to eliminate j
significant operator work arounds.
Resolution of Operator Work Arounds The inspectors reviewed actions FitzPatrick personnel took to resolve previously identified operator work arounds. The inspectors concluded the timeliness of the corrective actions were commensurate with the safety significance of the work around issue. Licensed and plant operators interviewed were comfortable identifying work around issues. The inspectors noted that FitzPatrick operators were active in identification and resolution of operator work arounds. As of February 9,1999, there
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were thirteen active open work arounds. Since October 2,1998, nine new issues were identified and fifteen were resolved.
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Conclusions FitzPatrick personnel established an acceptable process for evaluating, tracking, and correcting operator work arounds. The individual and cumulative effect of existing operator work arounds did not adversely impact the ability of operators to safely operate the plant. Operator work arounds were resolved in a timely manner commensurate with their safety significance.
Miscellaneous Operations lasues 08.1 (Closed) Licensee Event Report (LER) 98-08: Automatic Reactor Scram due to Low Reactor Water Level Durino Restoration of "A" Condensate Pumo (90712)
On August 3,1998, an automatic reactor scram occurred due to inadequate filling and venting of a condensate pump following maintenance. The cause of the scram was attributed to an inadequate procedure for the restoration of the condensate pump. The scram, the root cause, and the corrective actions were reviewed and documented in NRC Inspection Report 98-03. A Non-Cited Violation, NCV 50-333/98-03-01, was issued for the inadequate procedure.
The inspectors completed an in-office review of the LER and considered the description and analysis of the event, the root cause, and the corrective actions to be consistent with the inspectors' understanding of the event. This LER is closed.
08.2 (Closed) Insoector Follow item 97-05-01: Use of Alternate Methods to Verifv Full-In
Control Rod Position Indication a.
Inspection Scope (92901)
In May 1997, three control rods did not indicate full-in on the full-core display after a reactor scram. The scram procedure allowed alternate means to verify rod position. At the time, the inspectors questioned the validity of the alternate methods because they
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do not provide a specific control rod position. During this inspection period, the inspectors reviewed the associated deviation / event reports (DERs) and procedures, and discussed the issue with current station management.
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Observations and Findinos The FitzPatrick abnormal operating procedure (AOP)-1, step C.1.5, for a reactor scram, directed the operators to verify all control rods are fully inserted into the core (full-in) by one of several methods: green " full-in" lights on the full-core display (preferred method),
full core rod scan indicating """ (double-asterisk) using EPIC (emergency and plant information computer), or four-rod display. The procedure required additional actions if any control rod was not full-in. During the reactor scram on May 25,1997, when three control rods did not indicate full-in on the full-core display, the inspectors questioned the
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validity of the alternate methods; in that, the second and third options did not indicate a specific control rod position. The double-asterisk on the EPIC Indicates that the control rod is at a location other than an even-notch position from full-in to full-out (i.e.,00,02, 04,.. 48). The four-rod display also indicates only even-notch positions, otherwise the display windows are blank. Following a reactor scram, the rods generally travel to the full-in/over-travel position, which is displayed as """. However, the indication of """ is not conclusive because it can occur at many positions. If any control rod is not full-in, then the operators are directed to enter EOP-3," Failure to Scram."
The inspectors reviewed the history associated with the inability of the operators at FitzPatrick to determine that all rods were full-in using the full-core display, and identified that NYPA had been aware of this problem since at least 1994. The following time line details some of the history associated with this issue:
11/21/94 NYPA identified that actual plant response did not agree with plant drawings. Specifically, following a scram, the EPIC / safety parameter display system (SPDS) should show all rods-in; yet operators reported that this did not happen.
09/16/96 Reactor scram, operators did not enter EOP-3 based on procedural guidance and """ indications. FitzPatrick training department conducted a survey of other boiling water reactor (BWR) facilities, and determined that no other utility used the """ indication following a scram.
03/06/97 The Institute of Nuclear Power Operations (INPO - an ir,dustry peer group) issued a report (SER 4-97 " Incorrect Use of EOPs During a Potential ATWS"), which stated that operators incorrectly applied EOP guidance and did not enter the ATWS EOP when they were unable to verify all control rods inserted.
05/25/97 Reactor scram, three rods did not indicate full-in on the full-core display and operators did not enter EOP-3. NRC inspectors questioned the validity of using the EPIC """ indication as an alternate method and opened an inspector Follow item (IFl 97-05-01).
11/09/98 Disposition for DER 98-2708, stated that "It [the use of """] no longer is Paceptable." The DER was reviewed and approved with by the General Manager, Operations. However, no changes to operating procedures were made.
During thM inspection period, the inspectors reviewed the current version of AOP-1 (Revision 33), and noted that the EPIC """ and the four-rod display were still listed as acceptable methods to verify all control rods full-in. The inspectors determined that NYPA had not changed the procedure, based on their reluctance to enter EOP-3. They told the inspectors that implementing EOP-3, because they were in a potential anticipated-transient-without-a-scram (ATWS) condition, would require additional actions and would delay the normal post-scram cooldown.
The inspectors determined that the references to the EPIC indication and the four-rod display in AOP-1 resulted in an inadequate procedure for response to a reactor scram.
The use of """ as a positive indication of rods full-in is non-conservative and could lead operators to be less sensitive to an actual ATWS condition. The fact that NYPA has known about this problem since at least 1994 and did not revise the procedure is an
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example of a significant condition adverse to quality that was not corrected in a timely
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manner. This is a violation of 10CFR50, Appendix B, Criterion XVI, " Corrective Action."
After discussion with the inspectors, NYPA revised AOP-1 to exclude the use of the EPIC """ indication and the four-rod display. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as DER 98-2708. (NCV 50-333/99-01-01) Also, this inspector Follow Item is closed.
On February 19, NYPA approved a procedure change to AOP-1 to eliminate the reference to the """ method of determining all rods inserted. The inspectors reviewed the change and found it appropriate. In addition, they are pursuing a plant modification which should provide positive indication of rod position, the modification is scheduled for installation during the next refueling outage (Fall 2000).
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Conclusiqra During review of a 1997 open itern, the inspectors identified that NYPA had determined that the continued used of alternate means for verifying all control rods were inserted following a reactor scram was not consistent with industry practice and did not provide a positive confirmation that the reactor was shutdown under all conditions without the need for boron injection. Following discussions with the NRC inspectors, NYPA ~ evised r
the Abnormal Operating Procedure (AOP-1, " Reactor Scram") to remove the alternate means of verifying control rods were full-in. The failure to adequately resolve this issue in a tin:ely manner is a violation of 10CFR50, Appendix B, Criterion XVI, " Corrective Action.* (NCV 50-333/99-01-01)
08.3 (Closed) Wistion 50-333/97-10-01: Reauired TS Actions to isolate Secondary Containment and Start the Standbv Gas Treatment System Were Not Comoleted (92901)
In January 1998, a spurious high radiation monitor alarm resulted in a reactor building isolation and initiation of the standby gas treatment system (SGTS). FitzPatrick removed the monitor from service, restored the reactor building ventilation to a normal lineup, and secured the SGTS. The NRC identified that the SGTS would no longer automatically start on high radiation in the reactor building due to the monitor being removed from service.
The inspectors conducted an in-office assessment of NYPA's response to the violation, including reviewing the associated procedures and DERs. NYPA determined the reason for the violation was ineffective work practice; in that the operators failed to recognize the affect of removing the radiation monitor on the only operable train of SGTS. A coatributing cause was a self-imposed urgency to repair the radiation monitor and prevent another spurious reactor building isolation and SGTS initiation. Corrective actions included revising the operations procedure for removing equipment from service to require an independent assessment whenever TS equipment was removed. The inspectors determined that the root cause analysis and corrective actions appear adequate to prevent recurrence. This violation is closed.
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11. MAINTENANCE i
M1 Conduct of Maintenance M1.1 GeneralComments (61726,62707)
Using NRC Inspection Procedures 61726 and 62707, the resident inspectors
' periodically observed various maintenance activities and surveillance tests. As part of the observations, the inspectors evaluated the activities with respect to the requirements of the Maintenance Rule, as detailed in 10 CFR 50.65. In general, maintenance and surveillance activities were conducted acceptably, with the work requests (WRs) and necessary procedures in use at the work site, and with the appropriate focus on safety.
Specific activities and noteworthy observations are detailed in the inspection report. The -
Inspectors reviewed procedures and observed all or portions of the following maintenance / surveillance activities.
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ST-4P High Pressure Coolant injection (HPCI) Surveillance Test i
ST-2XA Residual Heat Removal Service Water Quarterly Test ST-3PB Core Spray Loop B Ouarterly Test ST-3J Core Spray initiation Logic System Functional Test
ST-9BA EDG "A" & "C" Full Load Test and Emergency Service Water
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(ESW) Pump Operability Test
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ST-9BB EDG "B" & "D" Full Load Test and ESW Pump Operability Test -
- WR 99-0531-00 Troubleshoot and Repair Cause of Breaker's (10612] Failure to Close WR 99-1642-00 Troubleshoot Cause of Annunciator 9-8-4-15 Alarming with Breaker 10612 Closed WR 99-1642-01 Repair Correct Wiring for 52 Relay Auxiliary Contacts in Breaker 10612 PTR 99-175 Protective Tag Request: Troubleshoot and Repair Annunciator Circuit for"D" EDG Output Breaker IS-E-07 Installation of Electrical Cable Terminations AOP-67 Main Generator Hydrogen Cooling and Seal Oil System Trouble
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PID 67404 RBCLC Heat Exchanger Outlet Temperature - Control Room
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Reading =4*F Higher than Localindication SP1.04 Standby Liquid Control Sampling and Analysis WR 98-5588 Troubleshoot and Repair "B" RPS MG Set MP-54.01 4.16 KV Magna-Blast Breaker M1.2 Troubleshootina and Repair of the "D" EDG Outout Breaker a.
10DR9ction Scooe (62707)
During the performance of a routine surveillance test to demonstrate the operability of the EDGs, operators noted that an annunciator unexpectedly alarmed indicating that the
"D" EDG output breaker had tripped. In fact, the output breaker remained shu,
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FitzPatrick determined that the Division ll EDGs continued to be operable.
Troubleshooting of the alarm circuit identified that some of the alarm contacts in the breaker were incorrectly wired.
The inspectors reviewed the operability determination for the EDGs and discussed the troubleshooting and repair with the maintenance engineer. In addition, the inspectors observed part of the repair efforts. The subject breaker was rented while other breakers were being refurbished. The inspectors questioned the completeness and validity of the post-work testing for the breaker after it was installed in the "D" EDG output breaker cubicle.
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Observations and Findinas On February 11,1999, control room operators noted that an unexpected annunciator alarmed during the performance of surveillance test ST-9BB, "EDG "B" & "D" Full Load Test and ESW Pump Operability Test." Specifically, after closing the 10612 breaker ("D" EDG output breaker), an annunciator (# 9-8-4-15, "EDG D Load Bkr 10612 Trip")
alarmed. The Control Room Supervisor (CRS) directed the 10612 breaker be opened.
Additional attempts at c!osing the 10612 breaker also caused the annunciator to alarm.
DER 99-242 was written to document the problem and initiate corrective actions. The inspectors noted that the operability determination concluded that the malfunctioning annunciator did not affect the EDG operability. The next day, troubleshooting identified that some of the contacts off of a relay internal to the breaker were incorrectly wired.
The relay wiring was corrected, and the breaker was retested satisfactorily. The inspectors reviewed the WRs and plant tagging request (PTR) for the troubleshooting and repair of the breaker and found them acceptable.
During follow-up discussions with the maintenance engineer, the inspectors questioned why the problem had not been discovered when the current breaker was installed in the cubicle in January 1999. On January 14,1999, during the performance of ST-9BB, the
"D" EDG output breaker failed to close; the installed breaker was replaced with the current breaker. As part of the planned preventive maintenance program for the 4.16 KV breakers, a rental breaker of similar design was being used as a substitute while the original breaker was sent off-site for refurbishment. Because the rental breaker was not an identical design, Temporary Modification 98-080 was developed and approved. The temporary modification did not consider the auxiliary relay during the review. After the rental breaker was installed in the 10612 breaker cubicle, the only post-work testing was a physical inspection and a cycling of the breaker in accordance with an operating procedure. Based on the inspectors questions, NYPA reviewed the alarm history for the January 15 run and determined that the annunciator also alarmed on that occasion; the operators did not notice during the January test that the annunciator alarmed. The post-work test did not identify that the alarm relays were not properly wired. The failure to conduct an adequate test of the rental breaker installed in the "D" EDG output cubicle is a violation of 10CFR50, Appendix B, Criterion XI," Test Control." This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as DER 99-0254. (NCV 50-333/99-01-02)
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Conclusion During troubleshooting of an unexpected annunciator received during a surveillance test of the emergency diesel generators, NYPA noted that the circuitry was wired incorrectly.
The breaker was a spare that had been installed the previous month, yet the post-work testing did not identify that the annunciator alarmed during that test also. The failure to conduct an adequate test of the breaker is a violation of 10CFR50, Appendix B, Criterion XI, " Test Control." (NCV 50-333/99-01-02)
M3 Maintenance Procedures and Documentation M3.1 Control of Scaffold Materials a.
Insoection Scope (71707)
While conducting plant observations, the inspectors noted several temporary structures constructed of scaffold material. The inspectors reviewed procedures AP-5.10," Control of Scaffolding," and AP-17.02, " Housekeeping and Cleanliness Control."
b.
Observations and Findinos The inspectors observed two temporary structures constructed of scaffold materials that were located in safety related areas. One structure, located in the reactor core isolation cooling (RCIC) pump room, was built to provide a rigging point for a heavy floor plug.
The second structure, located in the west crescent area, was constructed to hold and store unused scaffolding parts. Both of these structures were observed in direct contact with adjacent plant equipment, and were not tagged and tracked as required by the scaffold control procedure.
After discussions with NYPA, the inspectors determined that the structures in question were not considered scaffolds by NYPA at the time of installation, and therefore did not fall under the scaffold control procedures. Additionally, because the structures were not tracked as scaffolds, the structures were not reviewed for acceptability following the refueling outage. The RCIC structure was promptly removed, and the scaffold rack was moved such that it was no longer in contact with the piping.
The inspector; determined that the conditions observed in the field, although not desirable, were not prohibited by NYPA procedures. The NYPA proceJures gave specific guidance for some instrumentation and electrical compnents, but did not address requirements for the desired spacing to otner safety related components. The inspectors considered this a weakness in the NYPA procedures.
The failure to adequately control scaffolding in the vicinity of safety related equipment is a violation of 10CFR50, Appendix B, Criterion lil, " Design Control." However, this Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as DER 99-274. (NCV 50-333/99-01-03)
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c.
Conclusions The NYPA scaffolding control procedure was weak in that it did not address structures constructed of scaffold materials that were not actual scaffolds. Two scaffold structures located in safety related areas were not adequately Installed or controlled. The failure to adequately control scaffolding in the vicinity of safety related equipment is a violation of 10CFR50, Appendix B, Criterion Ill, " Design Control."(NCV 50 333/99 01-03)
M8 Miscellaneous Maintenance issues (92702)
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M8.1 (Closed) Licensee Event Reoort 50-333/98-14: Relav Failure Causes Trio of RPS
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Power Supolv and ESF Actuation (90712. 92700)
l This LER identified the failure of the "B" reactor protection system (RPS) motor generator (MG) set on November 11,1998, resulting in a half-scram signal and a half-containment isolation signal. Primary containment integrity was not required at the time due to the reactor being shutdown during a refueling outage. With the exception of
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20AOV-83 (the drywell floor drain sump discharge valve), all of the containment isolation i
valves were either closed or de-energized due to the outage. As expected, valve 20AOV-83 closed when the "B" RPS MG set tripped and de-energized the "C" RPS bus.
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Operators transferred the RPS bus to the alternate transformer supply, and reopened
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Troubleshooting identified that a 20-year old relay (GE Model CR120A) had failed open.
The failure was attributed to aging related to the relay being normally energized. The relay was replaced and the "B" RPS MG set was restarted. Corrective actions included a verification that the relay on the "A" RPS MG set had been replaced in 1988, and plans to develop a preventive maintenance program to replace other normally energized CR120A relays.
The inspectors reviewed the troubleshooting efforts and the associated WR 98 5588, and completed an in-office review of the LER and considered the root cause and corrective actions to be reasonable. The description and analysis of the event, as j
contained in the LER, were consistent with the inspectors' understanding of the event.
j The LER is closed.
111. ENGINEERING E1 Conduct of Engineering E1.1 General Comments (37551)
Using NRC Inspection Procedure 37551, the resident inspectors frequently reviewed design and system engineering activities and the support provided by the engineering organizations to plant activities.
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E1.2 Annual Hiah Pressure Coolant Iniection (HPCI) Survoillance Test a.
Insoection Scope (61726)
Surveillance test ST-4P, "HPCI Annual Transient Monitoring Test (IST) [ inservice testing]," was performed on February 9,1999. The inspectors attended the pre-evolution brief, observed portions of the test, and reviewed the Technical Specifications and Final Safety Analysis Report.
' b.
Qhservations and Findinos The pre-evolution brief covered precautions, communications, key points of the evolution, and potential problems. Although well conducted, the brief was not attended by all of the key test personnel. Specifically, the system engineer and performance engineering were not in attendance.
The test was conducted in accordance with the procedure. Operators used three point communication and the test director was effective in coordinating the various aspects of the test.
Dun 6; the test, the inspectors noted several pressure gages associated with the turbine steam sealing system indicating in excess of their maximum range. The inspectors questioned the significance of the indications and the impact on the operation of the HPCI turbine.
NYPA responded that the high gland exhaust pressures were Indications of excess seal leakage, but did not constitute an equipment operability concern. The seal pressures varied as a function of turbine load, and excessive steam leakage from the turbine was
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not observed. The HPCI turbine seals were replaced during the last outage, and NYPA j
was aware of some wear on the shaft.
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Although the steam sealing system pressure indications were beyond the scope of the test, the indications did provide insights into overall HPCI system performance. This j
opportunity for monitoring system performance of an infrequently operated piece of i
safety equipment was not effectively utilized by system engineering. NYPA opened a tracking item to evaluate the range and use of the installed pressure gages.
c.
Conclusions The annual test of the high pressure coolant injection (HPCI) system was adequately performed. The conduct of the pre-evolution brief with key personnel absent, and the missed opportunity to note and address pressure gages indicating off scale high were performance lapses noted by the inspector. The failure to exhibit of questioning attitude with regard to observing system performance beyond the requirements of the test procedure was an example of a lapse in system engineering performanc a
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j E8 Miscellaneous Engineering issues E8.1 (Closed) Violation 50-333/98-01-01: Inadeauate Secondary Containment Testina (92903)
A violation of NRC requirements resulted from inadequate testing of reactor building ventilation valves. The test did not account for a single active component failure, and therefore did not test the system in the appropriate configuration. NYPA responded to this violation by addressing the specific test issue, reviewing related tests, and reviewing engineering programs to assure appropriate guidance was given for test procedure development and review.
The inspectors reviewed the revised test procedure (ST-39D, " Reactor Building Leak Rate Test"), and observed the performance of the test. The test procedure adequately addressed the deficiency identified in the violation. This violation is closed.
IV. PLANT SUPPORT Using NRC Inspection Procedure 71750, the resident inspectors routinely monitored the performance of activities related to the areas of radiological controls, chemistry, emergency preparedness, security, and fire protection. Minor deficiencies were discussed with the appropriato management, significant observations are detailed below. Specialist inspectors in the same areas used other procedures during their reviews of plant support activities; these inspection procedures are listed, as applicable, for the respective sections of the inspection report.
R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Solid Radwaste Processina. Handlina. Storaae and Shiooina a.
Insoection Scoce (86750)
The implementation of the solid radioactive waste (radwaste) program was reviewed relative to waste processing, waste characterization, the development / application of scaling factors, and shipping activities. -This review included examination of performance related to implementing the Process Control Program (PCP), including associated procedures and records, interviews with cognizant personnel, and direct observation of work activities. Nine shipping records were reviewed for shipments of radioactive waste and other radioactive materials made since the last inspection. Direct observation was made of a limited quantity shipment prepared during this inspection.
The review was conducted using the selected criteria contained in various NRC and Department of Transportation (DOT) regulations including 10CFR20,10CFR61, 10CFR71,49CFR100-179, the applicable certificate of compliance for an NRC licensed shipping cask, and applicable NRC Branch Technical Positions.
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Observation and Findinas The PCP was an accurate description of the facility's waste types generated and waste processing methods. A detailed sampling procedure was implemented to establish scaling factors for determining the curie content of hard-to-detect radio nuclides.
Scaling factors were appropriately developed from sample data, per Part 61 requirements, and properly used in characterizing waste shipped.
The radioactive waste / material shipping program was adequately implemented.
Shipping records and supporting documentation for recent shipments of dewatered ion exchange resin, dry active waste (DAW), and contaminated laundry were reviewed.
Manifests were properly prepared; radioactive waste / materials were properly characterized and classified as to their DOT type; the appropriate shipping container, labels, and placards were used; and the relevant radiation and contamination limits were met.
Current certificates of compliance for high integrity containers (HICs) and shipping casks were on file. Up-to-date NRC licenses for facilities receiving shipments and current copies of DOT /NRC regulations were also on file. Individuals responsible for implementing the waste characterization and shipping programs were knowledgeable of the regulatory requirements contained in these documents.
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Direct observation was made of the shipping staff finalizing preparations of a limited quantity shipment, containing contaminated scaffolding components, on February 11, 1999. The package was properly labeled with the security seal in place; documentation was properly prepared. The staff appropriately followed the guidance contained in procedure " Radioactive Material Shipping," RP-OPS-05.01, Revision 0, in preparing this shipment.
c.
Conclusion The solid radioactive waste management and transportation programs were adequately implemented as evidenced by an experienced staff carrying out detailed procedures.
Radioactive waste and other radioactive materials were properly characterized,
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classified, stored, packaged, and shipped.
R2 Status of RP&C Facilities and Equipment R2.1 Radwaste Tours a.
Insoection Scope (86750)
Tours were made of various radwaste processing and radioactive material storage areas including the Radioactive Waste Building, the Interim Radwaste Storage Facility,
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the Turbine Building and the Reactor Building to assess the adequacy in controlling radioactive materials, including access controls, area posting, waste minimization efforts, and material conditio.-
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b.
Observations and findinas The Radioactive Waste Building, Interim Radwaste Storage Facility (IRSF), Turbine Bu!! ding, and Reactor Building were satisfactory maintained and properly posted with access appropriately controlled. Drums and boxes containing contaminated materials were properly labeled and in satisfactory material condition. Independent measurements of radiation levels on storage containers and general room areas confirmed documented readings. Housekeeping was satisfactory in all plant areas with no degraded material conditions evident.
Processed waste was expeditiously removed from the site. A significant storage capacity was available in the IRSF with only 9 of 70 storage cells filled with HICs awaiting shipment. No significant volume of DAW was in storage in the IRSF. DAW was temporarily stored in two trailer vans that are shipped when full.
Various waste reduction practices including use of reusable equipment and identifying /
. segregating / monitoring of contaminated tools were initiated to limit the generation of radwaste. Potentially contaminated materials / waste were properly segregated from uncontaminated materials through a " Green is Clean" program.
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Conclusions Radioactive waste processing and storage areas were properly maintained, posted, and in satisfactory material condition. Processed waste was expeditiously removed from the site. Contaminated waste / material containers were properly labeled, segregated by waste type, and monitored.
R5 Staff Tralning and Qualification in EP&C R5.1 Review of Trainina Records a.
Insoection Scope (86750)
Training of personnel responsible for classifying radioactive waste and preparing radioactive waste / materials for shipment was reviewed to determine compliance with the requirements of 49 CFR 172, Subpart H and NRC Bulletin 79-19. Training records of selected individuals were reviewed and discussed with Radiological and Environmental Services Depaitment management.
b.
Findinas and Observations A training matrix had been established to ensure that individuals responsible for classifying, packaging, and shipping radioactive waste / materials received the required training at the required frequency. All responsible individuals were confirmed to have met current training requirements.
Individuals authorized, based on their training and experience, for performing independent reviews of radioactive shipment paperwork were dedgnated in writing by i
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plant management annually. These individuals were also confirmed to have received the required training.
The relevant lesson plans for training radioactive waste handlers and shippers were reviewed and were found to be of sufficient scope and depth to ensure responsible individuals were cognizant of the regulatory requirements for shipping radioactive waste / materials.
c.
Conclusions Personnel responsible for classifying radioactive waste and shipping radioactive materials met NRC and Department of Transportation training and retraining requirements.
R7 Quality Assurance and Self-Assessment in RP&C Activities R7.1 Review of Audits and Surveillances a.
Inspection Scope (86750)
An audit and recent surveillances of the Process Control Program (PCP) and of radioactive waste handling / processing / storage activities were reviewed and compared to the criteria contained in the Quality Assurance Program,10 PR 20, and 10 CFR 71, Subpart H.
The effectiveness of these management controls in identifying problems, analyzing causes, and implementing corrective actions related to implementing the solid radioactive waste program was assessed, b.
Observations and Findinos The biennial audit (A99-03J) of the PCP was being conducted during this inspection.
The audit checklist was reviewed and discussed with the lead auditor. The audit scope was found to be an in-depth, performance based effort addressing implementation of the PCP and associated procedures, and Technical Specification compliance.
The inspector reviewed findings from the previous audit (A97-05J) and concluded that issues were appropriately resolved through corrective ActiortCommitment Tracking system (ACTS) items, elevated to the appropriate managemerit lovel and accepted for closure by the Quality Assurance (OA) Department. Corrective actions were made in a timely manner.
Ten OA surveillance reports, conducted during the period February 1998, to November 1998, were reviewed by the inspector. These surveillance reports addressed the adequacy of radwaste staff training records, verification of high integrity container inspections, various radwaste processing activities, receipt inspections of shipping casks / liners, and radioactive material / waste shipments. The reports were generally focused on verifying that procedures were compiled with and that management
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3 expectations were met. DERs and ACTS items were appropriately initiated for deficiencies identified.
At management's request, assessments were performed on the status of specific aspects of the radwaste program, such as the GREEN-IS CLEAN program and efforts to better predict and minimize dry activated waste generated during outages. Findings i
and recommendations from these focused assessments have been appropriately
addressed by ACTS items.
c.
Conclusions Performance of the radwaste/ shipping group was adequately monitored by the OA department. Problem areas were identified through audits, surveillances, and focused assessments. Issues were elevated to the appropriate management level for resolution.
R8 Miscellaneous RP&C lasues (92904)
R8.1 (Closed) Violation 50-333/98-01-04: Failure to comply with radiation protection instructions as described in three separate examples 1) worker's use of an unauthorized exit from a radiological controlled area (RCA),2) worker did not wear a personnel dosimeter when entering the RCA, and 3) worker did not log onto a radiation work permit before entering the RCA. The inspectors reviewed the root cause evaluations and corrective actions described in the licensee's response letter dated June 17,1998.
The corrective actions were reasonable and complete. This item is closed.
S1 Conduct of Security and Safeguards Activities S1.1 Speurity Proaram Review a.
Inspection Scope (81700)
I Determine whether the conduct of security and safeguards activities met the licensee's commitments in the NRC-approved security plan (the Plan) and NRC regulatory requirements. Areas inspected included: alarm stations; communications; protected area (PA) access control of personnel, packages and vehicles.
b.
Observations and Findinas Alarm Stations: Multiple observations of operations in the Central Alarm Station (CAS),
and the Secondary Alarm Station (SAS) provided verification that the alarm stations j
were equipped with appropriate alarms, surveillance and communications capabilities, j
Interviews with the alarm station operators found them knowledgeable of their duties i
and responsibilities. It was also verified, through observations and interviews, that the alarm stations were continuously manned, independent and diverse so that no single act (
wuld remove the plants capability for detecting a threat and calling for assistance and
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the alarm stations did not contain any operational activities that could interfere with the execution of the detection, assessment and response functions.
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Communications: Document reviews and discussions with alarrn station operators, demonstrated that the alarm stations were capable of maintaining continuous intercommunications, communications with each security force member (SFM) on duty, and were exercising daily communication methods with the local law enforcement agencies as committed to in the Plan.
PA Access Control of Personnel. Hand-Carried Packaaes and Vehicles: On February 23,1999, personnel and package search activities were observed at the personnel access portal. It was determined that positive controls were in place to ensure only authorized individuals were granted access to the PA and that all personnel and hand carried items entering the PA were properly searched. In addition, on February 24,1999, the physical search of two vehicic9 at the vehicle entry point was observed. The searches were thorough and vehicle entries were properly documented.
c.
Conclusions The licensee was conducting its security end safeguards activities in a manner that protected pt.:l:e health and safety and that this portion of the program, as implemented, inet the licensee's commitments and NRC requirements.
S2 Status of Security Facilities and Equipment S2.1 lasnedgn of Security Eauioment a.
Inspection Scope (81700)
Areas inspected were: Protected Area (PA) assessment aids, PA detection aids, and testing, maintenance and compensatory measures.
b.
Observations and Findinas PA Assessment Aids: On February 23 and 24,1999, the effectiveness of the assessment aids was evaluated, by observing a security force member (SFM)
l conducting a walkdown of the perimeter of the PA. The walkdown was observed using the closed circuit television (CCTV) in the central alarm station and secondary alarm station. The assessmen.sids had good picture quality and zone overlap. Additionally, to ensure Plan cornmitments are satisfied, the licensee has procedures in place requiring the implementation of compensatory measures in the event the alarm station operators are unable to properly assess the cause of an alarm.
PA Detection Aids: During the camera walkdowns on February 23 and 24,1999, multiple observations of an SFM conducting performance testing of each zone of the perimeter intrusion detection system (PIDS) were conducted. The appropriate alarms were generated in every zone on each attempt. The equipment was functional and effechv6 and met the requirements of the Pla o
c.
Conclusions The licensee's security facilities and ' equipment were determined to be well maintain'ed, I
reliable, and meet the lhensee's commitments and NRC requirements.
Security 6.;l Safeguards Procedures and Documentation i
S3.1 Review of Security Documentation
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a.
Insoection Scope (81700)
Areas inspected were: Implementing procedures and security event logs, b.
Observations and Findinas
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Security Proaram Procedures: Verification that the procedures were consistent with the Plan commitments, and were properly implemented was accomplished by reviewing selected implementing procedures associated with PA access control of personnel, packages and vehicles, testing and maintenance of personnel search equipment and performance testing of PA assessment and detection aids.
' Security Event Loas: The Security Event Logs for the previous twelve months were reviewed. Based on this review, and discussion with security management, it was determined that the licensee appropriately analyzed, tracked, resolved and documented safeguards events that the licensee determined did not require a report to the NRC.
c.
Conclusions Security and safeguards procedures and documentation were being properly
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implemented. Event Logs were being properly maintained and effectively used to
analyze, track, and resolve safeguards events.
S4 Security and Safeguards Staff Knowledge and Performance
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i S4.1 Security Staff Knowledae a.
Insoection Scope (81700)
Area inspected was: security staff requisite knowledge.
b.
Observations and Findinas Observations of a number of SFMs in the performance of their routine duties were conducted during the inspection period. These observations included alarm station
. operations, personnel, package and vehicle searches, and performance testing of the perimeter intrusion detection system (PlDS). Additionally, interviews of SFMs were conducted. Based on the responses, it was determined that the SFMs were
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knowledgeable of their responsibilities and duties, and could effectively carry out their assignments.
c.
Conclusions The SFMs adequately demonstrated that they had the r3quisite knowledge necessary to effectively implement the duties and responsibilities associated with their position.
S5 Security and Safeguards Staff Training and Qualification SS.1 Security Staff Trainina a.
Insoection Scope (81700)
Areas inspected were: security training and qualifications, and training records.
b.
Observations and Findinas Security Trainina and Qualifications: On February 23,1999, six randomly selected training and Qualification (T&O) records of SFMs were reviewed. Physical and requalification records were inspected for armed and supervisory personnel. The results of the review indicated that the security force was being trained in accordance with the approved T&O plan. In addition, on February 23,1999, observation of a force-on-force field exercise was conducted. The exercise pre-brief was well organized, with a strong emphasis on safety. The field exercise was conducted in compliance with all safety rules. The post-exercise critique was well organized and provided an effective means for lessons learned to be fed back into the training process, i
Trainina Records: Review of training records indicated that the records were properly l
maintained, accurate and reflected the current qualifications of the SFMs.
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Conclusions Security force personnel were being trained in accordance with the requirements of the T&O Plan. Training documentation was properly maintained and accurato. Based on the observed field exercise, the inspector concluded the training provided by the training staff was effective.
S6 Security Organization and Administration S6.1 Security Manaaement Support. Effectiveness and Staffino Levels a.
Inspection Scope (81700)
Areas inspected were: management support, effectivoness and staffing levels.
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Observations and Findiras l
Manaaement Support: Review of program implementation since the last program inspection disclosed that adequate support and resources continued to be available to ensure effective program implementation.
Manaaement Effectiveness: A review of the management organizational structure and reporting chain revealed that the Security Manager's position in the organizational structure provides a means for making senior management aware of programmatic needs.
Staffina Levels: The inspectors verified that the total number of trained SFMs immediately available on shift met the requirements specified in the Plan.
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Conclusions The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic needs.
S7 Quality Assurance (QA)in Security and Safeguards Activities S7.1 Security Audits and Manaaement Controls a.
insoection Scope (81700)
keas inspected were: audits, problem analyses, corrective actions and effectiveness of management controls.
b.
Observations and Findinas i
Audits: No new audits were conducted since the previous core inspection. An audit is scheduled for May 1999; and will be reviewed during the next scheduled inspection.
Problem Analyses: A review of data derived from the security department's self-assessment program was accomplished. Potential weaknesses were being properly identified, tracked, and trended.
Corrective Actions: A review of the corrective actions implemented by the licensee in response to the QA audit and self-assessment program indicated that the corrective actions were technically sound and were performed in a timely manner.
Effectiveness of Manaaement Controls: The licensee had programs in place for identifying, analyzing and resolving problems. They included the performance of annual QA aucits, a departmental self-assessment program and the use of industry data such as violations of regulatory requirements identified by the NRC at other facilities, as a criterion for self-assessmen s
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Conclusions The review of the licensee's audit program indicated that the audit findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weakness.
V. MANAGEMENT MEETINGS X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on March 11,1999. The licensee acknowledged the findings presente,
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ATTACHMENT 1 i
PARTIAL LIST OF PERSONS CONTACTED 1.icensee
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M. Abramski, Licensing
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J. Alexander, Administrative Coordinator, Radiological & Environmental Services (RES)
N. Avrakotos, Emergency Preparedness Coordinator G. Brownell, Licensing Engineer P. Brozealich, Operations Manager T. Carswell, Radiation Protection Technician M. Colomb, Site Executive Officer R. Converse, Ger-
- 'anager Maintenance D. Cristafulli, Rr 4ction Training Program Administrator R. Deasy, aw., Compliance j
J. Gnojek,
' utmm - tection Technician Shipping
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K.Hobbs,
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,s General Supervisor
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D. Lindsey, Ph s.anager
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R.Locy, Training Manager J. McCarty, OA Manager i
A.McKeen, Radiological & Environmental Department Manager C. Moreau, Quality Assurance Specialist L
E. Mulcahey, Radiological Engineering General Supervisor R. Patch, Director Quality Assurance K. Peper, Health Physics General Supervisor T. Phelps, Radiological Supervisor Shipping K.Pushee, Respiratory Protection Supervisor J. Ratigan, Radiological Engineer D. Ruddy, Director, Design Engineering J. Solini, Senior Quality Assurance Engineer R. Steigerwald, Licensing Manager K. Szeluga, Dosimetry Supervisor T. Telfke, Security Manager D. Vandermark, Quality Assurance Manager V. Walz, Operations
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A. Zeremba, General Manager Support Services JNSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 61726:
Surveillance Observations IP 62707:
Maintenance Observations IP 64704:
Fire Protection Program IP 71707:
Plant Operations IP 71750:
Plant Support IP 81700:
Physical Security Prograrn for Power Reactors IP 82701:
Operational Status of the Emergency Preparedness Program IP 83726:
Control of Radioactive Materials and Contamination, Surveys, and Monitoring A-1
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Attachment 1
' IP 83750:
Occupational Radiation Exposure IP 86750:
Solid Radioactive ' Waste Management and Transportation of Radioactive Materials IP 92700:
Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92702:
Followup on Corrective Actions for Violations and Deviations IP 92901:
Followup - Plant Operations IP 92902:
Followup - Maintenance IP 92903:
Followup - Engineering IP 92904 Followup - Plant Support Temporary Instruction No. 2515/138 " Operator Work Arounds" j
ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened NCV 99-01-03 Failure to Adequately Control Scaffolding in the Vicinity of Safety Related Equipment
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NCV 99-01-02 Failure to Conduct an Adequate Post Work Test j
NCV 99-01-01 Failure to Take Appropriate Corrective Actions for an Operations j
I Procedure Deficiency
_GlQSid IFl 97-05-01 Use of Alternate Methods to Verify Full-In Control Rod Position Indication LER 98-08 Automatic Reactor Scram due to Low Reactor Water Level During Restoration of "A" Condensate Pump LER 98-14 Relay Failure Causes Trip of RPS Power Supply and ESF Actuation NCV 99-01-03 Failure to Adequately Control Scaffolding in the Vicinity of Safety Related Equipment NCV 99-01-02 Failure to Conduct an Adequate Post Work Test NCV 99-01-01 Failure to Take Appropriate Corrective Actions for an Operations Procedure Deficiency VIO 98-01-01 Inadequate Secondary Containment Testing VIO 98-01-04 Failure to Comply with Radiation Protection Instructions i
VIO 97-10-01 Required TS Actions to isolate Secondary Containment and Start the Standby Gas Treatment System Were Not Completed Discussed none
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A-2
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Attachment 1 LIST OF ACRONYMS USED ACT Action / Commitment Tracking ALARA As Low As Reasonably Achievable AOP Abnormal Operating Procedure AP Administrative Procedure ATWS Anticipated Transient Without a Scram BWR Boiling Water Reactor CAS Central Alarm Station CCTV Closed Circuit Television CRS Control Room Supervisor DAW Dry Active Waste DER Deficiency and Event Report DOT Department of Transportation EDG Emergency Diesel Generator
.EOP Emergency Operating Procedure EPIC Emergency and Plant Information Computer ESF Engineered Safety Feature ESW Emergency Service Water HIC High Integrity Containers HPCI High Pressure Coolant injection INPO Institute of Nuclear Power Operations IRSF Interim Radwaste Storage Facility IST Inservice Testing LCO Limiting Conditions for Operation LER Licensee Event Report MG Motor Generator NCV NON-Cited Violations NRC Nuclear Regulatory Commission NYPA New York Power Authority OSV Operational Safety Verification PA Protected Area PCP Process Control Program PID Plant identified Deficiencies PIDS Perimeter Intrusion Detection System PTR Plant Tagging Request GA Quality Assurance Radwaste Radioactive Waste RCA Radiologically Controlled Area RCIC Reactor Core isolation Cooling RP Radiation Protection RP&C Radiological Protection and Chemistry RPS Reactor Protection System RPV Reactor Pressure Vessel SAS Secondary Alarm Station SFM Security Force Member
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Attachment 1 SGT Standby Gas Treatment SLC Standby Liquid Control SM Shift Manager SPDS Safety Parameter Display System SRO Senior Reactor Operator the Plan NRC-approved physical security plan T&Q training and qualification TSSR Technical Specification Surveillance Requirement WR '
Work Request i
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i A-4 2