IR 05000335/1994009

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Discusses Two Unresolved Items Pending TSs Interpretations Re Insp Repts 50-335/94-09 & 50-389/94-09
ML20136C742
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 03/19/1994
From: Boger B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Lainas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17229A261 List: ... further results
References
FOIA-96-485 NUDOCS 9703120173
Download: ML20136C742 (5)
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? UNITED STATES

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/p* "8%g%,4 NUCLEAR REGULATORY COMMISSION /

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o 101 MARIETTA STMEET, N.W.. SUITE 2900

. j ATLANTA, GEoMGIA 30330190

g*****,/ September 19, 1994

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HEMORANDUM T0: Gus C. Lainas, Assistant Director for Region II Reactors Division of Reactor Projects I/II, NRR FROM: Bruce A. Boger, Acting Director Division of Reactor Projects, RII

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SUBJECT: REQUEST FOR ASSISTANCE IN ADDRESSING ISSUES REGARDING ST LUCIE UNITS 1 AND 2 REFUELING PROCEDURES (TIA 94-023)

St. Lucie Inspection Report 94-09 contains two items which are unresolved I (Attachment 1) pending Technical Specification (TS) interpretations. The licensee had dissenting comments on these issues, as noted in the inspection

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report Exit Interview paragraph. The two items are: URI 389/94-09-02, Adequacy of a single operator on the refueling bridge during core alterations - paragraph This URI involves interpretation of Unit 2 TS 6.2.2.d, which states:

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- "All CORE ALTERATIONS shall be observed by a licensed operator and supervised by either a licensed Senior

'3 Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation. The SR0 in

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charge of fuel handling normally supervises from the control room and has the flexibility to directly supervise at either the refueling deck or the spent fuel pool."  :

i During the St. Lucie Unit 2 fuel shuffle, on March 1,1994, the licensee l had stationed one [ licensed] operator on the refueling bridge to perforn refueling operations. This single licensed person, who was in constant

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communication with the refueling control desk in a control room annex, j was performing actual refueling operations, which included operating the t bridge and crane. The SR0 in charge of the evolution was located remote

'from the refueling bridge, as is allowed by the TS and discussed in FPL  ;

and NRC correspondence (Attachments 2 and 3).  ;

The inspector questioned staffing adequacy because the operator had I earlier attempted to grapple a fuel bundle with the crane at incorrect ]

coordinates due to a move list error. The single operator had not ,

detected the, error by cross check between analog and digital positioning l systems. The inspector questioned whether this one (though licensed]  !

person using the bridge and crane to perform core alterations inet the TS (

requirement and the NRC's intent regarding a licensed operator observing  :

core alteration ]

  1. l 9703120173 970306 PDR FOIA-

. FINDER 96-485 PDR ,

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G. Lainas 2

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The licensee's position was that " observed by a licensed operator"

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refers to the historical practice when nonlicensed persons, perhaps from a centract service company, actually performed the core alteration The licensee believes that ' performing' includes ' observing' when a

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licensed operator performs core alterations. The licensee stated that licensee and NRC correspondence (Attachments 2 and 3), generated during the original Unit 2 licensing process, supports their interpretation that a licensed operator performing core alterations constitutes the TS-required observer. The inspectors reviewed Attachments 2 and 3, and found that they appear to address the location of the SR0 rather than the " observing - performing" questio ,

In addition to compliance with the TS, the inspectors had the following concerns with having only one person on the refueling bridge:

- There was no real-time independent verification of core

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alterations as they were performed. However, the core load was verified in detail by serial number, orientation, etc. when the core shuffle was complete.

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- From the crane operating station on the bridge, the operator did not watch activity in the refueling canal. The operator could look down through plexiglass or move a few feet and look over the edge of the crane bridge with binoculars, but did not regularly do i so. Also, there was a TV camera mounted near the bottom of the l refueling mast, but it was not working. Thus the operator was, in a sense, driving 'on instruments only.'

Please provide an interpretation (with supporting considerations) of TS 6.2.2.d:

e Does " core alterations shall be observed by a licensed operator" refer to literally directly observing fuel move or does the phrase

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refer more to the process ac'.ivities and supervision involved?

e Is the TS requirement based upon the assumption that contract or

maintenance department rar. cannel, requiring licensed operator i oversight, perform fuel movement?

' * Is the TS requirement based upon the need for real-time

independent verification of core alterations or fuel movement?

e Does the TS require a second licensed operator, in addition to the

[ licensed) refueling machine operator, to observe fuel movement or other core alterations?

e- If so, then does the TS require that supervision of core alterations be performed by an SR0 who is separate from the observer (i.e., a third person)?

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'G. Lainas 3 . URI 389/94-09-03, Adequacy of review and approval of refueling core p alterations (licensee's Recommended Move List) - paragraph 4.a-j This URI involves. interpretation.of_ Unit'2 TS 6.8.1, 6.8.2, and 6. with regard to the licensee's " Recommended Move List." ,

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-- TS 6.8.1.a requires procedures recommended by Regulatory Guide

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1.33, Revision 2, Appendix A. RG 1.33 recommends procedures for- -j i " Preparation for Refueling and Refueling Equipment Operation" and-for " Refueling and Core Alterations." l

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- TS 6.8.1.b. requires procedures for'" Refueling Operations."

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- TS 6.8.2 requires that each of those procedures, and changes j

thereto, shall be reviewed by the FRG and approved by the Plant .

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General Manager prior to implementatio TS 6.8.3 allows temporary changes to those procedures provided: l

- The intent of the procedure is not altere ]

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- The change is approved by_two members of the plant management staff, at least one of whom. holds a Senior Reactor Operator's license on the unit affecte ,

- The change is documented, reviewed by the FRG, and approved 3 by the Plant General Manager within 14 days of l implementatio i J

I The licensee's Recommended Move List (Attachment.4) was the document that detailed the fuel assembly and CEA move sequence. It was developed I during the core load development process and it identified, in order, l each fuel. assembly and CEA to be moved, the location from which it was j to be moved, and the location to which it was to be moved. It not only I addressed moves within the reactor vessel, but also moves between the F fual pool and reactor vessel, and moves within the fuel pool. It was invoked by Test Procedure 3200090, Refueling Operations, which also described steps necessary to deviate from [ change] the list (see Attachment 5). However, the Recommended Move List itself was not part of the test procedure and was not reviewed by the FRG or approved by the

. Plant General Manager. Instead, it was approved by the Reactor Engineering Supervisor. Deviations from the Recomended Move List were approved by the reactor engineer on shift and the refueling coordinator (SRO).

During past refueling' outages, many fuel or CEA movement sequence

.I changes [as many as 90] have occurred due to equipment problem Historically, the Recommended Move List had been part of a procedure but change management was a huge burden and resulted in lengthy delays,

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-tired operators, and wasted radiation exposure. The licensee de-proceduralized it to cope with these problem . ';

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The licensee now considers the Recomended Move List to be a non-

' procedure and therefore not subject to the TS 6.8.2 requirements for review and' approval of procedures and also not subject to the TS 6. !

and TS 6.8.3 requirements for processing changes to procedures. The licensee stated that, since the Recomended Move List's preparation, use, and modification.were directed by a FRG-reviewed procedure, a FRG review should not be required for the list itself. Subsequently, the licensee stated that a' telephone review with other Combustion '

Engineering plants found that the licensee's position was comon in the .;

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industry,

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The inspectors had the following concerns with the licensee's practice i of handling the Recommended Move List as a non-procedure:

- The~ Recomended Move List was an important documen It was used l by reactor engineers and operators for performing safety-related

activities. Errors in it could potentially lead to unsafe j

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conditions of fuel arrangement. However, the licensee was requiring less review and approval for the Recomended Move List ,

than for a safety-related procedur The retention of a record of the Recomended Move List could be of

significant value in determining the cause of an accident or 4 malfunction, as described in ANSI 45.2.9 - 1979, Section 2. '

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However, the licensee often issued a new Recommended Move List and j discarded the old one with no formal review and no record

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! retentio :'

Please determine if the Recommended Move List is considered to be a l procedure, subject to the requirements of TS 6.8.1, 6.8.2, and 6. l St. Lucie Unit 1 is scheduled to begin a refueling outage on October 31, 199 Please let me know if you will not be able to respond to this request by that i time. If you have any questions concerning this request, please contact K. Landis (404/331-5509) or R. Schin (404/331-5561).

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Docket No. 335 DPR-57

.389 DPR NPF-15 i

i Attachments: Applicable portions of j IR 50-335,389/94-09 . Ltr. from FPL to NRC l dtd. Sept. 22, 1981, l regarding SRu Refueling l Supervisor l Attachments cont'd: (See page 5)

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G. Lainas 5 Attachments cont'd:

3. Ltr. from NRC to FPL

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dtd. Sept. 30, 1981, regarding Refueling SRO Recommended Move Lis ' Applicable portions of Test Procedure 3200090, i Refueling Operations

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cc w/ attachments:

. ' Norris, NRR T. Johnson, Turkey Point SRI

S. Elrod, St. Lucie SRI

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K.-Landis, RI !

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R. Cooper, RII E. Greenman, RIII

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B. Beach, RIV K. Perkins, WCF0

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q Oocket Nos. 50-335.!50-389

. License Nos. OPR-67. NPF-16

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.j Florida Powerz& Light Company i ATTN:. J. H.' Goldberg

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C President - Nuclear Olvision

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.P. O. Box.14000

~ Juno Beach, Florida. 33408-0420

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' Gentlemen:

SUBJECT: (NRC INSPECTION REPORT NOS. 50-335/94-09 AND 50-389/94-09)

.L This refers to the inspection conducted by.S. A. Elroo of this office on' ..

41 February 27 - March 26. 1994. The inspection included a review of activities-

authorized for your St. Lucie-facility. At the conclusion.of the inspection, the findings were discussed with those members of your staff-identified in the o enclosed repor 'q T Areas examined during the-inspection are identified in the report. Within

- these areas, the inspection consisted of selective examinations of procedures

} and representative records, interviews with personnel, and observation of activities in progres .

I The enclosed Inspection Report identifies activities that violated NRC requirements that will not be subject to enforcement action because the licensee's. efforts inldentifying and/or correcting the violation meet the criteria specified in Section VII.B. of the NRC Enforcement Polic ,

.Your attention is invited to two unresolved items identified in the inspection  ;

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.; report. These matters will be pursued during future inspectio y In accordance with 10 CFR-2.790 of the NRC's " Rules of Practice," a copy of l this letter and its enclosures will be placed in the NRC Public Document Roo j Should you have any questions concerning this letter, please contact u

Sincerely, p , n i) y' Q %. Y

,- David M. Verre111, Chief '

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Reactor Projects Branch 2

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Division of Reactor Projects

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Attachment 1 Enclosure: '(see -page 2)

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UNITED STATES -

NUCLEAR REGui.ATORY COMMIS510N 9EGION 88 i i V'f S '01 MARIETTA STREET. N.W.. SUITE 2900 8 l l ATLANTA. GEORGIA 30RD 0190  ;

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Report Nos.: 50-335/94-09 and 50-389/94-09

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Licensee: Florida Power i light.Co  ;

' 9250 West Flagler Street

Miami, FL 33102 i

. Docket Nos.
50-335 and 50-389 License Nos.: OPR-67 and NPF-16

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Facility Name: St. Lucie 1 and 2

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- Inspection Conducted: February 27 - March 26, 1994

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Inspectors: , h l _' ,

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S. A. Elroa. Senior Res4 dent inspector Date S/igned r , i

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T. Johnson, Senior Resident Inspector Dat,e Signed _i

    • ! k - -> Li M. S. Miller, ResidentyInspector Dat,e Signed

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. .A 4 - s h ti 1 M. A. Scott, Resident Ihspector Date Sig.ned I *

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  • ~ .* ~. y nu L. Trocine, Resident inspector Date Signed

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I-Q hw .. . _ 10 4 R. Sc n, roJect Engineer Date Signed Approved,by: V If/ R4 u 78 9k Date Sitned )

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/ e. RD/actor

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Lyndis,Projects Chief Section 2B Division of Reactor Projects

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SUleMRY

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Scope: This routine resident inspection was conducted onsite in the areas

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of plant operations review, Unit 2 refueling observations, surveillance observations, maintenance observations, outage

, activities. and fire protection revie t

!' Backshift inspection was performed on February 28 and March 1, 2, 3,

. ,13, 15, 16, 17, 19, and 2 .

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Attachment 1

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Results: Plant Operations area:

'! Operators-performed Unit 2 reduced inventory operations wel .

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Unit.1 operations continued to be good. One non-conservative

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, licensee. entry .into a technical specification limiting

s condition for operation actionistatement was identified,

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involving emergency diesel generator fuel. oil tank ~ leve T Failure to follow refueling procedures resulted in a failed

, attempt.to grapple a fuel assembly oue to bridge

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.mispositioning. (paragraphs 3 and 4) ,

Maintenance and Surveillance area:

I Maintenance activities, both normal and outage related,'were '

generally conducted well. Several procedural weaknesses were identified and were addressed by the licensee. Surveillances

were performed satisfactorily; However.. operator ano procedural.

weaknesses were identified during an EDG surveillance ru (paragraphs 5. 6, and 7)

, Plant Support area:

Health Physics coverage of outage-related maintenance was ,

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strong, as was health physics personnel response to a spill of

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potentially contaminated water. (paragraphs 3 and 6)

i One non-cited violation (NCV) and two unresolved items (URIs) were

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i .NCV 50-389/94-09-01, incorrect Grappling of a Fuel Assemoly, paragraph 4.a.

i URI 50-389/94-09-02, Adequacy of a Single Operator on the Refueling

Bridge Ouring Core Alterations, paragraph URI 50-389/94-09-03, Adequacy of Review and Approval of Refueling

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,4 Core Alterations, paragraph :

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- Attachment 1

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j' above gallon numbers for each tank were converted from feet and

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, inches by the inspector.) The inspector found no clear j necessity' or net safety benefit in pumping the 1A EDG fuel oil i 1 tank level down below its TS-required minimum. In this case, '

placing the 1A EDG in a TS LCO action statement was a non-

, conservative action by the license Also, the inspector found that the licensee tracked and 'I 1 reviewed overall unavailability of certain safety systems, but i did not track or review overall time in LCO action statements :

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for any safety systems. Unavailability and inoperability.are substantially different. For example, in this case the 1A EDG'

was considered to be inoperable for eight hours but was also

, considered to be available during the same tim ,

i Physical Protection

! The inspectors verified by observation during routine activities I j that security program plans were being implemented as evidenced by:

proper display of picture badges; searching of packages and personnel at the plant entrance; and vital area portals being locked and alarme i

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In conclusion, operations for this inspection period were conducted satisfactorily. Operator knowledge and control of Unit 2 reduced inventory operations were considered to be excellent. One licensee voluntary entrance into a TS LCO action statement, involving EDG fuel oil tank level, was considered to be non-conservativ *

4. Unit 2 Refueling Observations (60710)

The inspectors reviewed the licensee's refueling activities and operations including surveillance testing, operating procedures, TS compliance, shift manning, reactor engineering involvement, management

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and supervision oversight, plant conditions, housekeeping, and loose

object contro a.: Unit 2 Refueling and Core Shuffle

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The licensee consnenced Unit 2 refueling and core shuffle activities

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on February 28, 1994. The inspectors monitored refueling frns the ;

control room, the spent fuel area and the refueling bridge. During '

fuel movement, the licensee controlled the move sequence by using a Reconsranded Move List. This list was part of the core reload.PC/M 001-294 for Unit 2 Cycle 8. Fuel movement operations were  ;

controlled by procedures OP 2-1630024, Refueling Machine Operations,.

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and Test Procedure 3200090, Refueling Operations. The test procedure referenced the Recosamended Move List and described the j steps necessary to deviate from this lis On February 28, 1994, at 11:43 a.m. refueling operations were stopped during'an attempt to grapple assembly H08 in core loc & tion Attachment 1

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!: Gil. The hoist overload energized several times during the upward

! hoist motion attempts. The licensee discovered a typographica error in the Recommended Move List at step 27. The core coordinate-jP for the bridge was listed as 787.71 and should have been 783.7 i jj Consequently, the bridge was misaligned by approximately 4 inches.

l> The licensee surmised that the grapple engaged the assembly off d center and upward movement was arrested due to actuation of the  :

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}1 hoist overload. The refueling SRO directed reactor engineering to il check for additional errors in the Recommended Move List. Three l? more errors were found and correcte l In followup to this error, the inspector reviewed operating 4h procedure No. 2-1630024. " Refueling Machine _ Operation". In order to l

jI assure the operation has the correct core location, a comparison 1

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check of rough mechanical alpha-numeric grid coordinates was directed. Then, a more exact coordinate was to be made using the digital bridge and trolley indicator The operator, during move

i numoer 27 for assemoly H08 in core location Gil, did not ensure that

!! the two coordinates checked were in agreement prior to attempting to

[ grapple the fuel assembly. Consequently, the typographical error in 4' the Recommended Fuel Movement Litt caused the operator to grapple the assembly in an incorrect position.

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The-licensee stated that the operator in question was recently 1 qualified and his experience may have been a causal factor. Step 4 8.2.ll.B.3.b of procedure 2-1630024 requires the operator to ensure f! that the mechanical indicator for the core coordinates agree with

!! the bridge and trolley digital readouts. TS 6.8.1.a and b, and il Regulatory Guide 1.33, Revision 2, February 1978, Appendix A,-items 2k and 21 reouire procedures for refueling and core alteration to be d written, implemented, and maintained. Due to the minor safety

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significance of this error and the licensee's prompt corrective 1 action, this violation will not be subject to enforcement action

3 because the licensee's efforts in identifying and/or correcting the q violation meet the criteria specified in Section VII.B of the NRC i Enforcement Policy. The failure to adequately follow procedure 2-1630024 in conjunction with the error in the Recommended Move List ji are identified as NCV 50-389/94-09-01, Incorrect Grappling of a Fuel Assembly.

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1 The inspectors reviewed the appropriate logs including the RC0 log

. book,-the refueling log and others. During the February 28 1994,
refueling error associated with step 27, the RCO log book stated i; that the fuel movement had stopped (for almost 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />); housvar, the reason was
not. stated. Further, the restart of refueling:(at o approximately 3:52 ps) was logged in the RC0 log book. The inspectors discussed this issue with operations and plant

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' management.

. On March 1, from approximately 11:00 a.m. to 1:30 p.m., the inspectors observed refueling operations from the containment F including the refueling bridge and from the area of the spent fuel Attachment 1

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pool. During this time, an additional error in step-61 of the i l- Recomended Move List was noted by the licensee in that the fuel '

I movement sheets incorrectly indicated that no CEA was in the fuel e

~4 assembly. The licensee corrected this erro t

j" During this time, the inspector noted that only one licensed operator was on the bridge performing refueling operations. TS

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6.2.2.d requires that all core alterations be observed by a licensed

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i operator and supervised by an SRO with no concurrent-1 '

responsibilities. This SRO may be in the control room, the  :

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refueling bridge, or the spent fuel pool area. The inspector ,

i questioned the validity of having only one person on the refueling

.J bridge, and whether this meets.the intent of a licensed operator

" observing core alterations". The licensee's position was that a I' single operator met this requirement. However, considering the

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error noted above, a second person checking or observing could have prevented this. Pending further NRC review, this issue is '

identified as URI 50-389/94-09-02, Adequacy of a Single Operator on the Refueling Bridge during Core Alterations.

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' The inspectors'noted that the Recommended Move List and changes were

not specifically reviewed by the FRG nor approved by the Plant

<j Manager, but instead were approved by the reactor engineering i

,j supervisor. Each movement is also a core alteration. TS 6. '

requires procedures for refueling operations and core alteration , TS 6.8.2 requires those procedures to be FRG reviewed and plant  ;

manager approved. Pending further NRC review, this issue is  ;

ii identified as' URI 50-389/94-09-03 Adequacy of Review and Approval

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of Refueling Core Alterations.

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, The inspectors discussed these concerns with licensee management and l J on March 2, at about 10:30 am, the licensee suspended refueling

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operations. The licensee initiated the following corrective {

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actions:

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Revision of Test Procedure 3200090 to incorporate the f

Recomended Move List in the procedure and to track changes to ,

the Recoamended Move List in an Appendix to the procedur l

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Revalidation of the Recommended Move Lis FRG review and approval of the Recommended Move List per-TCs 2-

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94-076 and 07 Initiation of a formalized deviation sheet signoff for-Fuel

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Movement Change Documented qualifications of each refueling operato Implemented infrequent evolution process, including detailed

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briefing, per AP 001002 Stressed the importance of RCO log keeping during briefing Added a second person on the refueling bridge to ensure proper fuel wovement l The inspector met with licensee management and attended the morning

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shift briefings on March The inspectors verified corrective

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i actions and observed portions of the continuing refueling operation ,

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The inspectors also reviewed QA activities associated with the Unit '

2 refueling. Based on discussions with QA management personnel, the inspector determined that QA had performed audits, surveillances and performance monitoring of refueling activities including:

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new fuel receipt,

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refueling preparation TS compliance, t -

monitoring of refueling activities in the control room, on the

., refueling bridge and in the SFP,

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procedure review, and j -

CEDM unlatchin Independent QC verification of the final core configuration and QA

~ review of core physics testing were planned. QA/QC did not identify any deviations, violations, or problem areas. The inspectors c observed that QA/QC were not present during the February 28, 1994, error nor during the times the inspectors were present in the refueling areas and facilitie )

b. CEA Shuffle I Following correction of the refueling process, the inspector monitored portions of the CEA shuffle on March 10. After completing

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the fuel assembly shuffle per the approved Recommended Move List, 1 the licensee moved CEAs to their new required positions. The ;

inspector noted that, taward the end of the CEA shuffle, operators ;

found that two CEAs had been mis-located. The reactor engineer then made changes to the core load procedure to locate and move CEAs to correct the conditio The inspector verified that the procedure l allowed the reactor engineer to make these change l

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c. Core Load Verification I linnediately after the CEA shuffle, the inspector observed the Unit 2 core load verification. This evolution was conducted from the refueling crane, using an undentater camera suspended by a pole from j the crane handrail and two video displays en the crane dec '

Licensee personnel involved in the evolution included an SRO.in charge, an RO crane operator, a reactor engineer, and a quality control-inspector. The operators positioned the camwa whilarthe engineer and QC inspector each read and recorded the fuel assembly

' and CEA numbers. They also made a video tape record of this evolutio The inspector noted that, while the numbers on the CEAs and new fuel assemblies were clearly legible, many of the numbers on the partially used fuel assemblies were obscured by corrosion and small flakes of loose metallic oxidation (the engineer stated that this Attachment 1

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was from the CEA shuffle) and were very difficult to read. The engineer and QC inspector had to discuss and relook at many such 4 numbers before they agreed on what the number was. After both had i

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viewed, recorded, and agreed upon all CEA and fuel assembly numbers, i they compared their recorded numbers with the approved core map from I

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the core load procedure. Three of the fuel assembly numbers did not I match. Then the camera was repositioned to each of those three fuel assemblies until the reactor engineer and the QC' inspector agreed

, with the numbers from the approved core load ma l l

The inspector concluded that the licensee's core load verification was adequate but was hampered by fuel assembly numbers being i obscured by corrosion and small flakes of loose metallic oxidatio l

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In conclusion, while evolutions were generally conducted satisfactorily, j the inspectors found several aspects of the Unit 2 refueling operation to j be of concern. These concerns were relayed to the licensee, and plant e

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management acequately addressed the issues. Failure to properly prepare and follow refueling procedures resulted in a failed attempt to grapple a fuel assembly due to bridge mispositioning. Questions related to TS-required levels of staffing on the refueling bridge resulted in a UR . Surveillance Observations (61726) I Various plant operations were verified to comply with selected TS requirements. Typical of these were confirmation of TS compliance for reactor coolant chemistry, RWT conditions, containment pressure, control room ventilation, and AC and DC electrical sources. The inspectors

! verified that testing was performed in accordance with adequate procedures, test instrumentation was calibrated, LCOs were met, removal

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and restoration of the affected components were accomplished properly, test results met requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate j management personnel. The following surveillance tests were observed: OP l-22000508, "lB Emergency Diesel Generator Periodic Test and

'j! General Operating Instructions" The inspector witnessed the performance of IB EDG surveillance test perfomed March 16. The test was performed satisfactorily; however, the inspector noted weaknesses associated with operator performance and procedural adequac In preparing to perform the surveillance test, step 4 of the subject

, procedure requires that the water level in both EDGs' radiator

expansion tanks be checked. The inspectnr noted, immediately prior to the performance of this step, that the water level in the 181 i expansion tank was out-of-sight high in the tank's level sight glass l (the procedure required that the level be visible between two points ;

marked on the sight glass). The inspector witnessed the SNPO performing this evaluation to observe the sight glass and initial Attachment 1

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20 Exit Interview

The inspection scope and findings were summarized on April 25, 1990, with those persons indicated in paragraph 1, above. The inspector described the areas inspected and discussed in detail the inspection results listed

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,below. Proprietary material is not contained in this report. Dissenting comments were received from the license ! The licensee took issue with NCV 389/94-09-0 In this instance, an .

l operator mispositioned the refueling machine and failed to grapple a fuel .

j assembly due to incorrect coordinates in the Reconsended Move List. The

licensee stated that, while a cross check of machine coordinates

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following the move may have prevented the failed attempt to grapple, such a cross check was not procedurally require The licensee also took issue with URI 389/94-09-02. In this case, the inspector questioned whether a single licensed operator, perfoming core alterations on the refueling bridge, met the intent of the TS requirement for a licensed operator to " observe" core alterations. The licensee's

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position was that a licensed operator performing core alterations

constituted the TS-required observer. The licensee indicated that they possessed NRC correspondence, generated during the original Unit 2 j] licensing process, which supported their interpretatio The licensee also took issue with URI 389/94-09-03. In this case, the j inspector found that the Recommended Move List (for fuel shuffle) was not reviewed by the FRG and was not approved by the plant manager. The j licensee stated that the Recommended Move List's preparation, use, and t modification were directed by an FRG-reviewed procedure and that an FRG review should not be required for the list.

I Item Number Status Descriotion and Reference i

, 389/94-09-01 open NCV - Incorrect Grappling of a Fuel

Assembly, paragraph 4.a.

I 389/94-09-02 open URI - Adequacy of a Single Operator on the

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Refueling Bridge During Core Alterations,

'4 paragraph 4.a.

p

!~ 389/94-09-03 open tRI - Adequacy of Review and Approval of

< Refueling Core Alterations, paragr$ 4.a.

.4 10. Abbreviations Acronyms, and Initialisms AFW Auxiliary Feeduster (system)

, AWS Assistant Nuclear Plant Supervisor .

Ccu component Cooling Water

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CEDM Control Element Drive Nechanism CET Core Exit Thermocouple i

CFR Code of Federal Regulations CVCS Chemical & Volume Control System

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Attachment 1

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