IR 05000341/1990002
| ML20012E778 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/22/1990 |
| From: | Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20012E774 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM 50-341-90-02, 50-341-90-2, NUDOCS 9004060286 | |
| Download: ML20012E778 (37) | |
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REGION !!!
Report No. 50-341/90002(DRP)
Docket No. 50-341 Operating Licente No. NPF-43
,1 Licensee: Detroit Edison Company 2000 Second Avenun Detroit, MI 48226
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Facility Name:
Ferst 2
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Inspection At:
Fermi Site, Newport, Michigan Inspectica Conducted: January 1 through February 20, 1990 Insptctors:
W. G. Rogers
$. Stasek M. J. Farber P. R. Pelke h
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Approved By:
W. C. A el n,
hief (11.. /f fo Reactor Projects Branch 2 ate
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Inspection Summary Inspection on January 1 throvoh. february 20. 1990 (Report No. 50-341/900Q2(DRP))
Areas Inspected: ~ Action on previous inspection findings; followup of events; operational salety; maint nance; surveillance; LERs; refueling outage followup; bulletin followup; confirmatory action letter followup; allegations; NUREG 0737
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TMI action items; Emergency Operating Procedures followup; and management meetings.
Results: One violation, identified in Inspection Report No. 50-341/89033(DRP)
was issued. One violation was identified but did not warrant a Notice of
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Violation (Paragraph 6). Oce unresolved item was identified (Paragraph 3) and 12 open items were identified (Paragraphs 7, 9 and Attachment 1). General;y,
the licensee's programs / policies were adequately delineated to accomplish the applicable tasks.
However, in a number of instances personnel failed to carry out the established policies associated with different activities (temporary modifications, STA turnovers, operator aids, maintaining qualification reco ds,
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and completion of NRC commitments).
Though none of these implementation
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inaocquacies resulted in an operational event or cafety compromise they do reflect a weakness in overall licenseo performance.
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Persons Contacted c
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Detroit Edison Company
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- P. Anthony, Licensing
$. Catola, Vice President, Nuclear Engineering and Services
- G. Cranston, General Director, Nuclear Engineering
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- P. Fessler, Director, Plant $afety
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- D. Gipson, Plant Manager
- L. Goodman, Director of Licensing
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M. Hoffman, Supervisor of Procedures Coordination
- K. Howard, Supervisor, Plant Systems
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- P. tiarquardt, General Attorney L
- R. Matthews, Assistant Superintendent, Maintenance
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'R. McKeon, Superintendent. Operations
- W. Miller, General Supervisor, Plant Safety G. Ohlemacher, Principal Engineer, Licensing
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'#W. Orser, Vice President, Nuclear Operations l
J. Pendergast, Compliance Engineer
D. Pleaing, Senior Nuclear Training $pecialist
'#i. Riley, Supervisor, Compliance
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B. Sheffel, Nuclear Production Technical Engineering !$1 F. Svetkovich, Op5 rations Support Engiceer
- B. R. Sylvia, Senior Vice President, Nuclear Operations R. Stafford, Director. Quality Assurance i
- R. Szkotnicki, Principle Engineer, Outage Management W. Tucker, Assistant to the Vice President
- J. Valker, General Supervisor, Nuclear Engineering b.
U.S. Nuclear Regulatory Commission
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'#W. Rogers, Senior Resident Inspector
- $. Stasek, Residerit Inspector
- W. Axelson, DRP Branch Chief
@J. $harkey, Office of Enforcement
@J. Stang, Project Manager, NRR
- M. Farber, Project Er.gineer
- R. DeFayette, Section Chief
- J. Grobe, Director of Enforcement
- T. Kobetz, Reactor Engineer
- F. Brush, Reacter Fngineer
- Denotes those attending the exit meeting on February 23, 1990.
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- Denotes those attending the Enforcement Conference on February 7, 1990,
@ Denotes those participating ir,the Enforcement Conference by telephone.
The inspectors also interviewed others of the licensee's staff during this inspection.
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A,c, tion on Previous Inspection Findings (92701)
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(Closed) Open item (341/89008-14(DRP)):
Corrective Actions associated l
with a main turbine trip in 1988. The licensee implemented potential I
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Design Change (PDC) 8423 which modified the post scrar., set down logic and PDC 9437 which changed the lube oil load.emperature s
setpoint. This matter is considered closed.
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(Closed) Open Item (341/89018-04(DRP: Ramifications of a small
! break LOTX condition with the high pressure coolant injection steam L supply valves open. After discussion with the licensee regarding ! this configuration the licensee stated that this matter of the steam supply valves open and the drain pot valves failed open would be boynded by the instrument line break LOCA and would not constitute i . any' additional safety consequences.
Presently, the steam supply valves are considered the secondary containment isolation valves as i well as the primary isolation containment valves. This matter does i not w rant further followup.
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- Analysis of snubber found l
(0 pen) Open Item (341/89030-03(DRP))The licensee has contracted c.
locked up during refueline outage.
i NUTECH to perform a piping analysis and Stone & Webster to perform ! a hanger analysis of the consequences of the locked up snubber in l the worst desig' basis condition. Completion of these two analyses l was scheduled by February 15, 1990, but one anchor required additional ! aralysis.
This matter will remain as open until the completed ! analyses are reviewed by the inspector.
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[ Closed) Unresolved Item (341/88026-04(DRp)): Failure to resolve a core spray pump mcggering problem before placing pump into service.
! Following preventive maintenance activities on a core spray pump, maintenance personnel identified that the meggering temperature ! was not consistent with th guidelines provided in the preventive
maintenance instruction.
Environmental qualification engineering i personnel were contacted with regards to whether this was a problem.
! , Engineering personnel stated that a DER should be written and the problem would be appropriately evaluated.
A DER was written on this ( matter but this did not become a restraint to placing the pump into . service because the DER was never seen by the shift supervisor. The [ DER was submitted to plant safety and the plant safety individual i reviewed the DER only for reportability and not whether it would i affect components in the plant.
Subsequently, the pump was placed j back into service before the meggering temperature issue was resolved.
r Af ter approximately two months the meggering temperature matter was ! resolved and it was of no consequence to the operability of the pump, t However, the matter should have been resolved prior to placing the e pump back into service. Maintenance personnel were instructed that { any time field problems were identified that required a DER to be .i written, the DER would be submitted to the shift supervisor and not ! to plant safety.
Subsequently, review in '.his area by the inspector l ' ascertained that this appeared to be a rare instance and not the norm; ! , , i
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i . l l ss such the inspector does not consider that a violation is warranted in this area. The inspector will continue to evaluate this area under
! routine inspection activities.
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(Closed) Open Item (341/86035-04 WORP: Equipment history card use.
, I This matt ~r dil be consoTTiGTe~d with unresolved Item 341/87028-06 e ' which was evaluated by the maintenance team in Inspection Report ) , No.50-341/89024(DR$). In the more comprehensive maintenance team ,- inspection, inspectors still consider t. hat the trending of maintenance .related problems or hardware f ailures still requires further i initiatives by the licensee. As such this matter is considered I closed.
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[0 pen)Openitem(341/86019-01(DRp)): Improvement of consnunications
systems within the power block. The licensee had two Engineering ! Design Packages (EDP) to improve the consnunications systems.
The to be used in t$e.was to install a transmitting system to allow beepers first, CDP 7807
facility.
The forecast date for completion of the design package was June 30 1990 but was recently cancelled. The second package, EDP 7808, Installs a number of telephones throughout , the facility within the power block. The package completion is . scheduled for June 30, 1990, and implementation of the pactage is l for refueling outage 2.
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[ Closed) Violation (341/88037-05(DRP)): Inadequate 10 CFR 50.59 saTety evaliTafTon.
I Faragraph 5 of Inspection Report
No. 50 341/89017(DRP), these violttions were reviewed ard it was
determined in the conclusions section that the changes that reqvfred safety evaluations, but only received preliminary safety evaluations, i did not constitute unreviewed safety questions and are additional j examples of violation 341/87021 01 and no violation to be issued.
! As such, this matter is considered closed based upon the full evaluation performed in 2nspection Report No. 50-341/89017(DRP).
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(Closed) Violation (341/89006 02(DRP)): Inadequate flood protection - evaluation.
This natter was considered as example d to violation i 341/89017-01, therefore, corrective actions to this matter will be ! tracked and docunented under violation 341/89017-01.
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(Closed) Open item (341/89008-17(DRP)): Installation of protective i Lovers around EPA breakers.
The licensee installed the protective i - covers under PDC 9297 and the inspector verified installation I l through visual observation.
This matter is considered closed.
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(Closed)OpenItem(341/89008-12(DRP)): Replacement of chlorine i ! detectors.
Under EDP 8239 the inspector reviewed the documentation i associated with an upgrade and change-out of the chlorine detectors.
! Additionally, the inspector performed a visual observation of the l newly installed chlorine detectors.
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(Closed) 50.55(e)$tte r dated January ' Item 84-03: Freezing of the ultimate heat sink reservoir.
In a 17, 1990, from John A. Zwolinski,
Assistant Director for Region III Reactors, Office of Nuclear Reactor l
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, , p9 G bgulation (NRR), to Edward G. Greenman, Director, Division of , P Reactor Projects, Region !!!, NRR considered that the actions that ! , { ' WeJ11conste takes with regard to potential freezing situations with ' e the residual heat re' novel reservoir during extremely cold weather were acceptable. As such, this matter is considered closed.
s 1, [ Closed} Unruolved Item (34U87044-09(D_R$)J: Alternate rod , , insertfon cTeck valve testing. Testing of these check valves s n was not considered a requirement but a prudent operational practice.
r Subsequently, the licensee, in Surveillance Procedures 44.040.009 and 44,040.010 "ATWS Division I togic and Division II Logic Functional c L Test," provided 6dditional testing instructions to verify air header ' pressure depressurtred within,15 seconds, which provided a more T.
representative. test that these check valves were working properly.
l f This natter is considered closed.
[ Closed)Jointion (34JLS9033-02(lity of the Emergency Equipment ORP)J: 10 CFR 50.12 reportability ' m, of the loss of auto-start capabi
Cooling Water (EECW) and Emergency Equipment Service Water (EESW) pumps.- An Enforcement Conference was held on February 7,1990.
Duri.ng that meeting, the licensee stated that the loss of auto-start t capability for these pumps was limited to High Drywell Pressure and , '!. l.oss of Reactor Building Closed Cooling Water (RBCCW) signal; the t pumps would have automatically started on a loss of offsite power ' signal and could have been manually started in accordance with - procedurcs for loss of RBCCW. The licensee further stated that ' although the pumps were not operable in accordance with Technical Specifications they were still capable of performing their functions as stated in the Updated Final Safety Analysis Report, Sections 9.2.2.1 and 9.2 5.1, NRC regional management reviewed the licensee's assessment, recognized the engineering judgement involved , in the reportability decision, determined that no violation t occurred, and have no further questions in this matter.
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(Closed) Open item (341/89021-05(DRP)): Several concerns identified ! ! during the review of Work ~hequest No. 0010890819 (repair of the i Division I CCHVAC Recirculation Fan T4100C047), Potential Design Change (PDC) 10193 was written to waive the 24 hour belt run-in requirement of Procedure 35.000.224 and PDC 10195 was written to L accept the licensee fabricated shaft since it was made using an , uncontrolled drawing. The inspector determined that the subject PDCs ' are within the scope of the PDC program in that Procedure FIP-CM1-01, " Potential Design Changes," allows a PDC to be generated for ' requesting engineering evaluation and approval of resolution of
plant problems or questions. (PDCs are also written for evaluation i of and approval to proceed with proposed plant modifications and designchanges). Manuf acturing the new shaf t in-house appears to i" be acceptable in that dimensions were taken from the old shaft and l they matched the dimensions on the uncontrolled drawing.
The licensee does not plan to make vendor drawing Buffalo forge Dwg.
! s SW-55683, Revision G, a controlled drawing.
The inspector discussed t the in-house manufacturing of the new shaft with the Material l ,
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. o .. , , a l Engineering Group Superviur; he had no concern in this area since the process was documentec. on a PDC.
The inspector reviewed Work i , Request 0414890721 which documents the latest PM on T4100C047 on November 20,1989 (during the refueling outage). No problems were , !~ identified ciuring the belt and sheave inspection and the belt ' ' tension verification. The need to stock replacement shafts is unnecessary provided that the corrective actions for the original , l fan shaft failure are effective (tracked under LER 89-019). This
item is considered to be closed.
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(Closed) Open Item (341/87020-01(DRP)): Implementation of EXD-Sensor > Action Plan. Under PD O M 1, Rev. A, the licensee modified the shelf ' ! life requirements for the sensors to three years in the spara parts , ' reference system.
The licensee changed the Preventative Maintenance ' Program event numbers V411 and U413 to require changeouts of the sensors every three years. Based upon the completion of these actions this item is closed, p.
(Closed) Unresolved Item (341/89034-07(DRP)): Inadequate impact statements in 44.XXX.XX series surveillance procedures.
Upon , identification of the problem to the licensee DER 90-0030 was ' initiated.
Review of the DER revealed that 16 impact statements
had the equipment associated with one relay omitted. The licensee took a sampling of 36 other 44.XXX.XX series procedure impact ! statements and noted no problems. The inspector reviewed this issue
and determined that a notice of violation was not warranted given ' (1) the minor safety significance associated with the inadequate impact statements, and (2) the corrective actions taken by the licensee were timely and comprehensive, q.
(Oyen) Open Item (341/88035-02(DRP)): 24/48 and 260/130 VDC Battery j Conditions. The inspector examined both Division I and II 24/48 and r 260/130 VDC batteries. The inspectors noted that the Division I , 24/48 VDC battery was missing its label (R3200$001).
Leakage from several cells of the Division II 260/130 VDC battery and a Deficiency Notice Tag related to the leakage that was over one year old were noted by the inspector.
DER 89-0269 was written on February 17, . 1989 to address the inspector's concerns. At the close of this inspection one year later, that DER remains open.
On May 1, 1989, the following entry was recorded, "Another closer look was performed on 130-260 V. Batteries.
! No cracks or leaks were noted.
Moisture condensing at
thermometer caps accumulates and runs slowly from caps
down sides of batteries.
Thisisanormaloccurrance[ sic).
Gassing during float and equalize charging is the cause of ! the apparent leaks.
DNT tags need to be cancelled by tech
group, as recommended by Maintenance. Maint. crews presently l wipe down batteries during quarterly pm's."
( . During a plant tour, the inspectors noted an increasing number of l ' puddles of liquid under cells of both Division I and 11 260/130 VDC batteries.
Using a small amount of baking soda from a box stored .
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Discussions with the system engineer revealed that the technical staff was aware that i l there were battery leaks, the leakage was very small and being ! moni',ored, that the leakage had not affected battery performance, i battery replacement was under consideration, and that the DER would r be appropriately revised. The inspector will continue to monitor
this situation.
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(0 pen) Unresolved Item (341/89002-03(DRP)): Operation without maintaining proper drywell-to-torus dif ferential pressure (dp).
' The NUTECH analysis to address negative dp conditions during
! containment venting operations was subsequently forwarded to
L NRR for review. NRR is currently in the process of evaluating i the analysis.
This item will continue to remain open pending completion of that evaluation, t i (Closed Manuai~L0 pen 11em (341/89011-08(DRP)): Failure of the B Backup s.
5 cram (BUMS) Breaker to operate.
The licensee subsequently i shipped the failed breaker to their Engineering Research Department ' (ERD) for root cause determination.
Per a June 16, 1989 memorandum, ERD found that mating parts within the breaker-to-attachment assembly i experienced mechanical binding thereby not allowing adequate torque ' application to the trip latch actuator.
This appeared to be a , potential characteristic for this type of breaker. However, ! subsequently, during the first refuel outage, a modification , was made to the plant that involved the removal of both the A and ! B BUMS breakers.
The inspector verified that these were the only l application of the ITE Siemens-Allis circuit interrupter model E22$100A at the facility.
This item is considered closed.
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{0_ pen)UnresolvedItem(341/88035-01(DRP)?: Deficiencies identified ' with temporary modifications.
Further deficiencies were identified during a subsequent inspection (reference Report No. 341/89034 Paragraph 2.b) as well as during the current inspection period ' (reference Paragraph 3.b of this report).
The licensee was in
the process of substantially upgrading the temporary modification
program during 1989. With the upgrade since completed, the inspector r will perform a final review of the program and program implementation.
This will be acc0mplished during the next inspection period.
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(0 pen) Open Item (341/89008-16(DRp)): Safety relief valve (SRV) I performance.
Following SRV testing during the refueling outage, 8 of the 15 SRVs were identified as failing their setpoint test.
Fifteen refurbished valves were installed with a 50-50 ratio of stellite and PH13-8MO for the seat material.
The licensee hopes that this will improve setpoint performance as recommended by the BWR Owners Group.
However, five of the fif teen valves tested during , the refueling outage already had PH13-BM0 a the seat material and three of those five valves failed the setpoint test.
The inspector will continue to review SRV performance and licensee initiatives in . this area.
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(0 pen) Open Item (341/89011-09(DRP)): TWR not implemented in accordance with a commitment in an i.ER response. This item will , remain open pending closure of DER 89-0816.
Plant Safety had , i recently rejected Nuclear Training's disposition of the DER.
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(0 pen) Open item (343/89002-06(DRP)): Implementation of on-the-job i training to familiaE12e electricians with the proper techniques and critical performance elements for performing maintenance on the GE.
AKF-2-25 type circuit breaker. The inspector reviewed the work i packages for the PMs performed on the Recirculation Pump Generator ' Field Breakers B31035001A and B3103S0018 on September 27, 1989, and , October 17, 1989, respectively. The individual performing the work e was trained and qualified in accordance with the Electrical Task , Qualification Manual.
The Task Qualification Manuals will be f' computerized by Nuclear Training pending resolution of computer . L software problems.
This item will remain open pending closure of ! r DER 89-1129 and improvements to the Training Document Index/ training ' document revision interface such that plant document revisions are adequately incorporated into training documents.
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(0 pen) Violation (341/89011-03B(DRp)): Mounting torque values were not specified in a work package.
This item will remain open pending ! closure of DER 89-0786.
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(0 pen) Open Item (341/89021-06(DRP)): Concerns with PM event ) evaluations by the licensee's contractor. This item will remain open pending closure of DER 89-1229, p z.
Lopen) Violation (341/89011-06(DRPl): Inadequate fire watch training.
' This item will remain open pending closure of DER 89-0789.
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(Closed) Open Item (341/89008-13(DRP)): Installation of permanent . , test boxes to facilitate testing.
The licensee installed the test t , boxes under EDP 8123 during the refueling outage.
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(Open) Open Item (341/89200-02(NRR)): Higher drywell temperatures ! i than utilized in instrument setpoint calculations.
In letter
NRC-89-0243 dated December 4, 1989, the licensee committed to l reiise the applicable setpoint calculations to account for the h'gher drywell temperature by January 30, 1990. On February 1, ! l 5.990, the licensing supervisor informed the resident staff that ! ' the calculations had been prepared but not reviewed within the j committed timeframe.
The inspector inquired as to what corrective ! actions were implemented to assure that commitments are not missed.
] The licensing supervisor informed the inspector that: (1) this
L matter would be discussed at all major staff meetings emphasizing l the need to inform licensing if a commitment will not be met and ! l make all attempts to meet commitments; (2) an accountability meeting
would be held with the involved parties; (3) a fact finding meeting
was held on February 6,1990, with engineering on this matter; and
i (4) the calculations were reviewed within the week.
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(Closed) Open Item (341/87900-01(DRSS)): Review of'Information __ Notice 87-9. This information notice was adequately reviewed and documented in Inspection Report Ne. 341/88032 Paragraph 5.
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Operational Safety _ Verification (71707) , The inspectors observed control room operations, reviewed applicable logs i and conducted discussions with control room operators during the period l from January 1 to February 16, 1990. The inspectors verified the operability of selected emergency systems, reviewed tagout records and ! verified proper return to service of affected components. Tours of the , reactor building and turbine building were conducted to observe plant j equipment conditions, including potential fire hazards, fluid leaks, i excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenance.
The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the i station security plan.
! , The inspectors observed plant housekeeping / cleanliness conditions and f verified implementation of radiation protection controls. During the , inspection, the inspectors walked down the accessible portions of the ! following systems to verify operability by comparing system lineup with ! plant drawings, as-built configuration or present valve lineup lists; ! observing equipment conditions that could degrade performance; and verified that instrumentation was properly valved, functioning, and
calibrated.
. Standby Gas Treatment System-Divisions I and !! l
260/130 VDC Batteries-Division 1 and II
Emergency Diesel Generator No. 12
Emergency Diesel Generator No. 13
The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.
These reviews and observations were conducted to verify that facility ! cperations were in conformance with the requirements established under
technical specifications,10 CFR, and administrative procedures.
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During a walkdown of Emergency Diesel Generator No.13, on January 8, 1990, the inspector noted that operator aid No. 89-06 was posted on , i the governor control housing and specified the correct speed droop , setting, load limit / maximum fuel position setting, and the mechanical - governor speed adjustment setting.
However, a review of the operator i aid index log revealed that the subject posting, although installed on June 16, 1989, had not been signed on by the NSS as being installed ! in the plant.
Subsequently, the inspector determined that operator ' aids 89-08 and 89-09 posted on CCHVAC control panels also were not i signed on in the index log as being installed. When this matter was communicated with the NASS, the required actions to update the documentation were taken.
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On January 21, 1990, during a review of Temporary Modification i 90-002, which installed temporary piping on a caustic line used for regeneration of the demineralized water storage tank (DST) the } previous day, the inspector noted that the installation record was i not completed. The Nuclear Shif t Supervisor (NSS) apparently did l not authorize the installation of the pipe under the temporary i modification program, the installation itself was not signed as l complete, required tagging was not hung, and " critical" control ' l drawings not redlined. When this matter was communicated to the operating authority, a Deviation Event Report (DER) was initiated, - and actions required of the installation record taken and documented.
' The inspector subsequently ascertained that the temporary pipe was t being installed "at risk" concurrent with preparation of the
temporary modification package due to the short time period available
to make up water to the OST.
The NSS was apparently aware of the ' installation activity itself, but not aware that authorization of l the associated temporary modification was a1>o still needed prior l to placing the lire into service. Although this situation involved ' balance-of plant (BOP) equipment, the temporary modification [ ' administrative control process is common to both BOP and
safety-related equipment. This is another example of weaknesses
in the temporary modification program as currently tracked under } unresolved item 341/88035-01 (further discussed in Paragraph 2.t
of this report).
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During inspector walkdown of Standby Gas Treatment System - Division I, a substantial amount of duct tape was found on the ! drive shaft opening on the exhaust blower housing.
Since corrective
maintenance involving the shaft was performed several days earlier, ! the inspector questioned licensee personnel whether the tape was ! placed as a result of the maintenance.
Following completion of i licensee review', the inspector was subsequently informed that the ' , tape was not placed during that maintenance activity and that the
supervisor in charge of the job remembered the tape was in place i i prior to the start of work, No reason for the duct tape was found.
The inspector expressed concern to plant management in the manner i that the jobsite was left following completion of maintenance on the
exhaust blower. Although placement of the duct tape was 51carly not
an acceptable condition and was known to maintenance peronnel, no attempt to remove the tape was m.ie.
This incident appears similar to other recent inspector observations involving as-left jobsite conditions (reference Unresolved Item 341/89030-04 and Inspection
Report No. 341/89021, Paragraph 3.c).
The reason for these occurrences is not known at this time. The licensee's program requires supervisory
checks for cleanliness at the completion of maintenance on plant ' equipnent. However, despite this, cases continue where equipment is - left in a less than desirable condition.
Pending further inspector l review of this issue, this is considered an unresolved item ? (341/90002-01(DRP)). ,
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Monthly Maintenance Observation (62703) Station maintenance activities on safety-related systems and components , listed below were observed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specifications.
The follos,ing items were considered during this review: the limiting l conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning componentt. or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire preventica controls were. implemented.
Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performance.
The following maintenance activities were observed:
WR E818890823 Rear;or Core Isolation Cooling (RCIC) Flow Controller Loop E51-KK615SS.
- WR 0110891218 RCIC Turbine Cooling Water Relief Valve Leak.
' ' WR 004C890828 RCIC Turbine Lube Oil Filter Replacemt.
- WR 0220900108 Blown Fuse B21-F2B in Panel H21-P083 for Z2 Instrument Nest.
- WR 005C890828 RWCU Pump B Mechanical Seal Leak.
Following completion of maintenance on the RCIC System and panel H21-P083, the inspectors verified that the associated systems / equipment had been returned to service properly.
Pertinent observations were: a.
During the RCIC Flow Controller Loop check, some discrepancies were noted in observed indications; troubleshooting and calibration were required. At the onset of the troubleshooting process, the inspector noted that the I&C technician set up one more test instrument (Fluke 8600 digital multimeter) than called for in the procedure. When questioned, the technician said that he expected at least one of the Flukes would not work properly and that bringing an extra would save him an additional trip to the Measuring and Test Equipment (M&TE) shop. When the technician started t r'.bleshooting, his prediction l
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4 ! was borne out when two of the three instruments had dead batteries.
' The technician was able to use one of the instruments by hooking up a 120VAC power cord. The inspector met with the I&C general supervisor and discussed his observations regarding this occurrence and the technician's expectations for malfunctioning test equipment.
l Review of the situation revealed that the problem was caused by a ! lapse in the controlled charge-discharge routine for the NiCad batteries in the Flukes and the frequent use of the 120 VAC power cord. The NiCad batteries tend to have a " memory" and retain a charge level if they are not frequently cycled.
Failure to maintain i ! the charge-discharge cycle and use of the power cord led to the low charge level retained by the Fluke's NiCads and the subsequent problems experienced by the technicians. Memos were issued by M&TE and the Tools Supervisor reestablishing the controlled
charge-discharge cycle and banning the use of the 120 VAC power cord except under extreme situations.
Long term corrective action i includes phasing out the Fluke 8600 meter and replacing them with a more accurate and reliable meter.
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During the troubleshooting of the RCIC Flow Controller problems, it was identified that a zener diode installed in the circuit to limit input current to 50 milliamps was malfunctioning and preventing full input. A stock check revealed that an exact replacement diode was not available although an equivalent was in stock.
I&C submitted this equivalent to the Materials Engineering Group (MEG) for evaluation and the proposed diode was rejected.
Inability to reach a conclusion on an acceptable equivalent between I&C, Technical Engineering, Nuclear Engineering, and MEG resulted in an approximately 26 hour delay in obtaining the needed part. The inspector discussed the situation with licensee management and expressed concern over the delay in obtaining a commonly available part. A DER was initiated on this event and the Plant Manager issued a memorandum to the Superintendent, Maintenance and Modifications and the General Director, Nuclear Engineering regarding the ineffective communications by this occurrence.
The inspector will review the DER and its corrective actions when it is closed.
No violations or deviations were identified in this area.
5.
Monthly Surveillance Observation (61726) . The inspectors observed surveillance testing required by Technical Specifications and verified that: testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
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.. t- , , f The inspectors also witnessed portions of the following test activities: ' I
24.206.01 RCIC System Pump and Valve Operability Test
24.307.15 Emergency Diesel Generator No Il-Start and j toad Test t b ' 24.404.02 Division I SGTS Filter and Secondary.
' Containment Isolation Damper Operability Test I
24.413.03 Control Room Emergency Filter Monthly ! Operability Test
44.190.006 Feedwater/ Main Turbine Trip System-Reactor
L Vessel ^
44.020.047 NS$$$ - Main Steam Line Tunnel Temperature Division I, Channel Functional Test
44.030.268 ECCS-Reactor Steam Dome Pressure-RHR and CSS In.iection Permissive, Division !!, Channel i B Functional Test ' 44.030.300 ECCS-Drywell Pressure-RHR, CSS and HPCI Actuation, Division II, Channel Functional Test '
44.040.002 ATWS/SRV Low Set-Reactor Vessel Pressure , Division II, Functional Test !
54.000.03 Control Rod Scram Insert Time Test i , During performance of 44.020.047 (SQ), the inspector observed l Instrumentation and Control (I&C) technicians removing trip modules from
the testability panels prior to performing the functional test. On examining the procedure, the inspector found no notes, precautions, steps, or instructions related to this practice. When questioned, the technicians extlained that the modules were being removed to record nameplate data on a Field Verification Form and that the instructions to , complete this form were on the Surveillance Performance Form (SPF).
Thr purpose of the Field Verification Form was to ensure that components installed in the plant were those listed in the plant's data base.
The inspector examined the SPF and noted that it contained no instructions
for the method or point in the procedure to remove these trip units; only directions to complete the Field Verification Form. The inspector
questioned the acceptability of removing trip units from the testability ' panels without procedural guidance and the wisdom of fr-:ing the I&C technicians to decide at what, point in the test procedure it vrould be safe to remove the trip units. The inspector met with I&C supervision and pointed out that this was an activity on safety-related equipment
being performed without a procedure and that an error on the part of the ! technicians while removing a trip unit could cause an actuation or a scram.
I&C supervision immediately mspended the practice until an tvaluation of potential impacts could oe performed. Subsequent discussions between the surveillance group ard I&C led to abandoning the field verification effort and a different method of verifying component identification is under development.
, No violations or deviations were identified in this area.
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Followup of Events (93702) l During the inspection period, the licensee experienced several events, L' some of which required prompt notification of the NRC pursuant to 10 CFR $0.72. The inspectors pursued the events onsite with licensee
and/or other NRC officials.
In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the licensee ' > was taking prompt and appropriate actions, that activities were conducted i within regulatory requirements and that corrective actions would prevent future recurrence. The specific events are as follows: January 8,1990 - Blown Fuse in Testability Cabinet Requires f Initiation of Plant Shutdewn and Declaration of Unusual Event.
January 16, 1990 - ADS Reset Switch Exhibits High Resistance.
January 28, 1990 - Overflow of Raw Sewage Into Storm Drain System requires Notification of State.
February 3,1990 - ENS Inoperable.
February 6, 1990 - Top Lights on North Cooling Tower Inoperable, a.
Regarding the January 8 event, the inspector noted that the shift turnover of the Shif t Technical Advisor (STA) which occurred during the Unusual Event, was not in compliance with the turnover checklist.
Subsequent discussion with the oncoming STA revealed that he had not walked down the control room panels with the offgoing STA but rather performed it alone and did not discuss lit annunciators'with him prior to assuming the shift. Additionally, he failed to review the P-1 and 00-3 computer printouts within one hour of taking the shift. All of the above items are requirements of administrative procedure NPP-OPI-05, " Shift Turnover." The inspector realized that the oncoming STA, as an additional technically qualified person was in great demand and was therefore assigned to do a review of logic diagrams to suppcrt plant actions in response to the Unusual Event.
However, the event and the STA's temporary assignment did not alleviate his responsibility to ensure he was fully cognizant of overall plant conditions prior to relieving the ofIgoing STA. When this matter was communicated to the operating authority, the 'ndividuals involved were counselled as to their responsibilities.
During the remainder of the inspection period, the inspector witnessed numerous shift turnovers of STAS, control room operators, as well as Nuclear Shift Supervisors, and determined that the noted problem appeared to be an isolated occurrence.
Therefore, although a violation (341/90002-02(DRP)) of plant administrative procedures occurred during the one STA turnover,
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.. , .. c . I review has determined that a notice of violation (NOV) is " not warranted in that the violation was isolat e, of minor f safety significance, and licensee followup actions were , ' adequate.
The inspector has no further concerns in this ~.itter , and it is considered closed.
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Regarding the January 16 event, initial measurements made during surveillance testing indicated the B timer reset switch ! exhibited high resistance across its contacts. Under this
condition, the licensee determined the ADS logic would sense a i continuous timer reset condition, and therefore, ADS Channel B
' would not have auto-initiated if required.
Subsequent switch operations were then performed with a decrease in resistance noted with each manipulation.
After 58 switch manipulations, the resistance had sufficiently decreased to an acceptable
level (less than one ohm).
The licensee was unable to determine
a root cause for the initial high resistance and therefore, ' initiated a once per-day resistance check as well as a check any time the switch was manipulated. On February 16, with no
further problems noted, the periodicity was extended to a i once per-two week check. Monitoring activities were continuing i at the end of the inspection period.
The inspector monitored the licensee's followup actions during this time and has no
further concerns on this matter.
' One violation was identified in this crea.
, t 7.
Licensee Event Reports Followup (92700) , Through direct observations, discussions with licensee personnel, and ! review of records, the following event reports were reviewed to determine , that reportability requirements were fulfilled, immediate corrective ' action was accomplished, and corrective action to prevent recurrence had t , been accomplished in accordance with technical specifications.
{ a.
(Closed) LER 90-001: Blown Fuse in Testability Cabinet H21-P083 l Caused Entry into Technical Specification 3.0.3.
An Unusual Event ! was declared and a reactor shutdown was initiated.
Subsequent ! troubleshooting failed to determine the cause of the previous fuse f ailures, however, a third fuse was installed during the F troubleshooting activities and functioned satisfactorily.
Channel i functional surveillances were then performed to verify operability
j of each trip unit.
The Unusual Event was then terminated and i t reactor shutdown halted.
Power had been reduced to approximately l 40 percent before a ramp up was begun to full power. Activities to determine root cause were still underway following the event and the i licensee developed an action plan to further troubleshoot the ! failure.
These actions included review for specific component I degradation, a review of possible hotspots in the circuitry, i analysis of the blown fuses and evaluation of power supply ripple ' (noise) effects. The licensee committed to submit a supplemental report upon completion of the investigation.
The final corrective
actions will be reviewed with the revised LER.
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(Closed) LER 89034: Fire Watches Not Performed in Compliance with > ' Technical Specifications. This LER reported that a number of fire < l watches were not being completed by a particular individual when <
performing fire watch rounds although the individual in question ' p documented that the fire watches were performed.
In a review of l individual computer records it was apparent that a number of the
rounds had not been performed. Management subsequently discharged
!. the individual and performed an analysis of the consequences resulting from the reduced fire protection surveillances. Minimal impact was noted in the overall fire suppression protection capability of the fire system as a result of the missed fire watches.
No violation will be given for this condition given , (1) the licensee clearly indicated to the individual involved what his responsibilities were, (2) the licensee identification of the
condition of missing the fire watches, (3) the aggressive corrective actions taken as a result of identification of the problem; and ' o (4) the minimal safety significance associated with the missed fire watches.
c.
(Closed) LER 89026: Control Center Heating Ventilation and Air Conditioning (CCHVAC) Shifts to Recirculation Mode Because of a Loss , of Contro) Power.
This unplanned ESF Actuation occurred as a result - of replacement of an indicating lamp on the control board.
During the lamp replacement a short occurred.
Due to the design of the ! system this caused the power supply fuse to open and shift CCHVAC into the recirculation mode. All corrective actions have been taken except for the licensee's evaluation of a design change to eliminate ! ' the dependence between th.4 relay logic and the position indication
power supply.
This evaluation is targeted to be completed by March 31, 1990. The inspector will continue to follow.this design change evaluation as an open item (341/90002-03(DRP)). ' t d.
(Closed) LER 89025: Reactor Scram Signal Generated during the i Performance of an Instrument Valve Lineup, e.
(Closed) LER 89005, Revision 1: Secondary Containment . Integrity-Railroad Car Door. Under EDP 10105 the licensee modified
the f acility such that the non-interruptible control air system inflates the reactor building railroad car door seals. The
installation is such that Division I NIAS provides sealing for the
inner door and Division II for the outer door. A Technical l Specification change was submitted by the licensee with regards to i secondary containment integrity and approved by the commission.
The
licensee installed annunciators to inform operators when the seals
for the railroad car doors are underinflated.
Procedure 24.405.03 has been revised to only perform the test of secondary containment integrity when windspeeds are less than 10 mph and the abnormal operating procedure associated with external flooding was revised to [ direct the shift supervisor to use sand bags where appropriate with i the railcar door.
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(Closed) LER 89028 & Revision 1: Safety Relief Valves ($RV) Fail Their Set Pressure Tolerance Test. A similar condition was reported in LER 88009 when the $RVs were tested previously. The setpoint '. drift associated with the $RV testing is a generic problem end is
being addressed by the BWR Owners Group.
Initiatives of the owners . group to improve SRV s&tpoint lifting is being tracked under open i item No. 341/89008-16.
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(Closed) LER 89019. Revision 1: Failure of Division I Control Center Heating, Ventilating and Air Conditioning Recirculation Fan.
Corrective actions for this event are documented in DERs 89-031 and . 89-1151, both of which are currently open.
The following items were ' noted during this review: ,
A previous study had been performed on reducing the fan i vibration levels as documented in a letter from DECO l Engineering Research to Fermi 2 - Startup dated January 31, 1985. The study and subsequent EDP resulted in the recommendation that stiffener plates be added to dampen the , ' vibration.
This EDP has yet to be implemented because the i licensee has yet to decide whether this EDP is warranted.
The Engineering Research Failure Analysis (Report 89C63-32) ' dated November 1, 1989, stated that the visual appearance of the failed bearing is consistent with a lack of lubrication, r
A potential root cause of the lubrication problem is that the , bearing was not initially properly packed with grease.
In t addition, subsequent PMs failed to fill the void in that the applicable PM procedure used called for addition of 0.2 oz. of i grease. Open pillow block bearings should be greased until i grease extrudes from the sides.
PDC 11196 was initiated on January 22, 1990, to propose !
installation of fan and motor vibration and temperature , monitoring probes / sensors on T4100C047 and T4100C048. Nuclear ' Engineering was requested to issue an EDP for implementation of r the PDC during the second refueling outage.
- PMs were performed on T41000047 and T41000048 during the first refueling outage.
One of the bearing assemblies on the i T4100C048 fan was found loose.
Results of the groase analysis
indicated wear and contamination products as well as some
sludging, indicating breakdown of the grease.
' ' The PM events for T4100C047 and T4100C048 have been changed.
l The grease has been changed from Shell A1vania 2EP to Shell f Dolium R in accordance with the vendor manual and DECO i Engineering Research Report 89873-8, P.evision 1.
During each
28-month PM, grease samples will be taken for analysis, the bearings will be inspected for analysis, and pillow blocks will
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Technical Group and bearing temperature monitoring after o< ' run-in.
!t.
e implementation of PDC 11196 and the licensee's evaluation of f additional stiffener plates is an open item (341/90002-04(DRP)). - HN7EEW) LER 89031: Inadequate Surveillance Procedure Renders (Closed h.
!noperable.
Followup of this event was documented in Inspection Report No. 341/89033(DRP) including verification that the inadequate surveillance procedures were properly revised, i' A not'.ce of violation regarding this matter accompanies this . [ inspection report.
No other violations or deviations were identified in this area.
' 8.
Followup of Confirmatory Action Letter (92703) a.
(Closed) CAL-Rl!!-88-20: The o..ly item left to close from this . CAL was to complete inspections of RHR system compression fittings.
During the refueling outage these fitting inspections were completed under Work Request 0080890127. Of the 200 fittings inspected 125 - were acceptable. 49 failed the go/no go criteria,12 failed the tube engagement criteria, and 20 were found to have mixed parts.
. Following the inspection all mixed part fittings were corrected to
similar parts and all inspected connections were tested and left in an acceptable condition. This concluded the last action item to be completed under this Confirmatory Action Letter issued July 15, 1988.
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[ Closed) CAL-RI11-88-09: Two areas were left to be reviewed to
cTose this CAL from the previous inspection (341/89008). The first ! area was to review the licensee's analysis of why valve E11-F015B - closed.
The licensee determined that there were two possible reasons for valve closure: (1) Momentary f ailure of relay A71BK18 or , its seal-in contact (2) korkers performing maintenance on valve l E11F009 accidentally shorting circuitry that would energize the
closure logic for valve E11-F0158.
With regarijs to the first
possibility the licensee conducted non-destructive and destructive ! testing of the relay with no defects identified. With regards to i the second possibility the only live circuitry to valve E11-F009 at
the time of the event was 130 VDC and no are strike or discoloration
of terminal strips was observed which would be present if an t accidental shorting had occurred.
Therefore, the licensee was ! unable to identify the root cause of why valve E11-F015B went l closed.
The inspector concluded that there was no gain in pursuing l this aspect of the CAL any further.
The second area of the CAL yet ! to be reviewed dealt with flash tank and feedwater pump suction [ ttrainer periodic inspections. The inspector reviewed the results ! E t i
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.. ,. e . l of. the flash tank inspections during the refueling outage with eo ' stub tubes observed. The inspector confirmed that flash tank inspections would continue for forced outages due to the coding I, associated with these inspections in the preventative maintenance L program.
= The inspector reviewed the results of the feedwater l' suction strainer inspections which only identified two 1/2 inch nuts in the south strainer, by the end of the inspection period.
The inspector confirmed that the feedwater suction stainer inspections ' ! would also continue for forced outages due to the coding associated I with these inspections in the preventative maintenance program.
This completes all the review items for this CAL I 9.
Refueling Outage Followup ' FuRng the inspection period the Itcensee completed its critique of the refueling outage. There were a number of areas targeted as needing improvement; to date the licensee is formulating corrective actions to these weaknesses.
The inspector will follow those corrective actions as an open item (341/90002-05(ORP)). t 10. Bulletin Followup (92701) {ClosedlBulletin87001: Thinning of Pipe Walls in Nuclear Power Plants.
In a letter dated Arill 21, 1988, the NRR project manager documented that no specific inspection action associated with this bulletin was required.
This matter is considered closed.
11.
Review of Allegations (Closed) Allegation No. RIII-89-A-0094: Qualifications of Mechanical Maintenance Supervisors ln June 19T@, Region III received an allegation that three new mechanical supervisors were not qualified. The inspector determined that the three individuals (Individuals A, B, and C) had been recently hired or appointed to mechanical maintenance supervisory , positions following a maintenance department reorganization.
The licensee is committed to ANSI N18.1-1971, Section 4.3.2, for the qualifications of supervisors not requiring an AEC (NRC) license. The ANSI standard requires a high school diploma or equivalent, and a minimum of four years experience in the craf t or discipline supervised.
Procedure FIP-TQ1-05-SQ, Revision 0, " Selection, Training, a'd Qualification Program Descriptions," was consistent with the ANSI standard.
Following the receipt of the allegation, the inspector randomly selected three other maintenance supervisors, who were not the subject of this allegation, and verified that their qualifications met the ANSI standard.
The inspector discussed Individuals A, B and C with the licensee and obtained all relevant records regarding the document. tion and verification of their qualifications.
Individual A had recently resigned, His effective starting date was June 6,1989, and he resigned on June 9,1989.
During his job interview, Individual A told the Plant Manager that he had no previous employment problems.
Subsequently, the Plant Manager learned that Individual A had
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Individual A resigned when this '.. matter was brought to his attention. However, the inspector determined that Individual A appeared to meet the qualification requirements of the ! ANSI standard as documented on his Qualifications and Experience Verification Sheet dated June 29, 1989.
It is noted that the verification was not completed until 20 days after the individual resigned.
The i inspector also noted that there was no Applicant Letter of Verification l l' on file in accordance with Procedure FIP-TQ1-06, Revision 1, " Verification
of STQPD Selection Criteria."
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l Individual B has Bachelor of Science degrees in mechanical and e b etrical ' engineerirg, a Master of Science degree in mechanical engineering, and
about six and a half years nuclear experience in the mechanical discipline.
This includes experience as a mait.tenance engineer involved with various maintenance activities; experience as a systems engineer . developing preventive and predictive maintenance programs; experience as a senior maintenance engineer writing work plans and procedures and supervising craft personnel; and experience as a senior maintenance ! engineer writing maintenance procedures and developing plant preventive ! maintenance programs.
' l ' Individual C has a high school diploms and some additional education and training. The additional training includes various NDE schools, BWR
Integrated Operational Technology eleven week _ simulator course, INPO > Assessment Training, Management Skills Development Training, BWR Systems l Training, and Maintenance Management Training.
Individual C has about I twenty years experience associated with quality assurance and l construction. This includes about five years at a nuclear station in , quality assurance in a supervisory capacity which included involvement , with inspection activities associated with maintenance and mechanical ! systems, and participation with other Joint Utility Assessments for l Inservice Inspection Programs, Maintenance Programs and Engineering
Assurance Programs, and as a Lead Quality Assurance Engineer ( (welding /NDE); about a year and a half as a senior constructiot engineer i L for a construction firm with responsibility for a period of t*4 for both preventive and corrective maintenance and for identifying prentive l maintenat.:e frequencies; about six months with an engineering company as ! Supervisor Inspection involved with planning, scheduling and inspection , programs for maintenance activities at a refinery; and about one year as ! a radiographer for a shipbuilding firm performing radiographic inspections [ of nuclear components.
, i The qualification records for Individuals B and C were sent to the NRC
Office of Nuclear Reactor Regulation (NRR) for review along with a
request for interpretation of Section 4.3.2 of ANSI N18.1-1971, i specifically in reference to the requirement that a supervisor in this [ category shall have a minimum of four years experience in the craft or j discipline supervised.
In a memorandum dated October 27, 1989, NRR Tound
that both Individuals B and C met the qualification requirements of the
ANSI standard.
This was based on the interpretation that both ! individuals each had more than four years experience in the discipline (s) ' supervised as evidenced by their previous experience described in the , preceding paragraphs.
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.. + . Individual C assumed his current position on April 6, 1989 (reference l licensee internal memorandum NP-MA-89-0137).
Individual B's effective date was June 6,1989. As of July 6, 1989, their Qualification and -
Experience Verification Sheets had not been completed as evidenced by the i FIP-TQ1-06 open files Itsting provided by Personnel Services.
l Additionally, Applicant Letters of Verification were not on file for Individuals B and C in accordance with FIP-TQ1-06. Twenty-nine individuals were listed on the FIP-TQ1-06 open file list as of July 6, 1989.
Examples include the Supervisor - Radiological Engineering (effective start date September 26,1988), a Quality Assurance Specialist , (effective start date February 21,1989), Supervisor - Production QA r (effective start date April 17,1989), and and an inspector (effective ' start date April 28,1989).
Previous problems in this area had been t identified by the licensee, however, resolution appeared to be slow.
Audit Finding A-QS-P-88-04-01 identified that the Qualification and Experienen Verification Sheet was not completed for the General ! Supervisor - I&C in 1988.
This finding was closed in Audit 89-0038 dated March 28, 1989. Observation 11 of Audit 89-0038 was written to call attention to lack of timely completion of qualification forms.
The inspector discussed this issue with the licensee.
Subsequently, as of February 1990, there were no open qualification files.
Additionally, a recent licensee audit found no problems in this area.
Revision 2 of FIP-TQ1-06 was issued on September 15, 1989. Changes include the requirement that a safety evaluation be conducted if an individual does not possess all of the necessary cualifications for a long term or permanent assignment, and the withholding of protected area unescorted access until selection criteria have been verified.
The inspectors will continue to monitor the verification process to ensure that licensee corrective actions in this area remain effective.
" Based on this review, the inspector dotermined that Individuals A B, and C were qualified for mechanical maintenance supervisory positions.
This allegation is considered to be closed.
No violations or deviations were identified.
12.
NURFG-0737 Followup (Closed) TMI Item 1.C.1: Guidance for the evaluation and development of procedures for transients and accidents.
Following the Three Mile Island accident the Office of Nuclear Reactor Regulations developed the Three Mile Island Action Plan (NUREG 0660 and NUREG 0737), which required licensee's of operating plants to reanalyze transients and accidents and upgrade Emergency Operating Procedures (iri.
Under the Fermi Operating . License an attachment to item 3 of the L1:rtse Conditions, the licensee was required to submit to the NRC Staff for review and approval, Procedures Generation Package (PGP) to meet the requirement of Section 7 to Supplement 1 of NUREG 0737 and, prior to startup from the first refueling outage. Detroit Edison would complete training cn and have implemented Emergency Operating Procedures based upon the PGP.
In an inspection from July 5-14, 1988, a headquarters team reviewed the proposed Emergency Operating Procedures and proposed Procedures
f: - .. .. , C), F Generation Package and documented those reviews in Inspection Report No. 50-341/88200. Within 60 days of the inspection report the licensee implemented the new E0Ps.
In the inspection report a number of items - were left outstanding. Attachment 1 to this current inspection report documents a followup to this original E0P inspection.
The majority of f open issues were closed with a few issues remaining that are identified as open items. However, the licensee's action to date are sufficient to , ' close the Three Mile Island Item 1.C.I. dealing with development, training, and implementation of the new Emergency Operating Procedures.
Af ter performance of the NRR followup inspection the resident staff received F additional information from the licensee on a number of the open items.
That information and the inspector's review is provided below: , { Closed) Open Item (341/89201-02(DRP)): Implementation of EDP 8472 which would instaT1 an improved recorder for torus temperatere.
Subsequent to the NRR E0P followup inspection the recorder was verified installed by the resident inspector.
Therefore, this open item is closed.
(Closed)_Open item (341/89201-03(ORP)): Adequacy as to whether sufficient head existed in the condensate storage tank to vent the hose
being used for alternate boron injection.
Subsequent to the NRR E0P followup inspection E0P 29.000.01 enclosure for alternate boron injection Section 1 was revised to assure that sufficient head was available for performance of the venting evolution. Therefore, this open item is closed.
(DP box audit res(ets.
Closed) Open Item (341/89201-04(DRP)): Retention time associated with-E The operating authority reviewed the retention time for the audit results with the licensee's quality assurance organization.
The results of the review were that maintaining the current audit results was sufficient.
Therefore, this open item is closed.
, (0 pen) Open Item (341/89201-05(DRP)): Installation of primary containment water level indication above the 631 foot level. The installation is scheduled to be completed by March 31, 1990.
13. Management Meetinos (30703) a.
.On February 7. 1990, an enforcement conference was held regarding loss of EECW/EESW auto-start caoability as documented in Inspection Report No. 341/89033(DRP).
The conference entailed a statement as to the purpose of the meeting, the concerns raised by the inspection findings, a chronology of events and potential violations by the NRC.
The licensee made a presentation addressing all the NRC concerns.
The NRC decisions regarding the conference are discussed in the cover letter of this inspection report, b.
On January 16, 1990, a periodic management meeting was held between DECO and NRC management in the Nuclear Operations Canter at the Fermi site, The topics discussed were as follows:
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Outage Accomplishments - The licensee provided a perspective on the number of work items associated with RF 01 and how emergent r i work swelled in snubber inspections from 100 to $21, engineering
design package implementation from 97 to 177, and corrective maintenance swelled from 463 to 1197. Coupled with some of , these significant increases, surveillances increased from 546
i to 1981.
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QA Oversight - The licensee indicated that there were 31,000 l
man hours of QA involvement for RF 01 and that the overall ., quality of work was quite good. The number of DERs initiated t L during RF01 outage of 1989 versus the LLRT outage of 1988 was
l lower with 31% fewer DERs written in 1989 versus 1988, t I
Scrams - The licensee provided a discussion of the two scrams ' ! which occurred during power ascension from RF 01 and the root l cause associated with the scrams.
, , Improper Rosemount Transmitter Installation - The licensee went
through the chronology of the event and corrective actions , associated with the improper installation.
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Accountability Action. Plan (AAP) - The licensee provided a history as to why the AAp was formulated. Inclusive in that history were the two previous topics (scrams & improper l transmitterinstallation).
The root causes for these and i similar problems were determined to be: (1) lack of attention l to detail; (2) lack of pride of ownership; (3) inconsistent work practices; (4) week control room administrative activities;
and (5) too complex work practices / programs.
The corrective , actions to these weaknesses is contained in the letter dated i December 26, 1989, to the NRC from DECO.
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The failed fuse ECC$ testability cabinet event was presented to [ the NRC with the licensee indicating that flexibility in the r i Technical Specification action statement would be beneficial.
The NRC indicated that such a matter would require significant
technical review. The preliminary root cause of the fuse was ( presented as a failed capacitor on a printed circuit board, j
14. Open items j Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action i on the part of the NRC or licensee or both. Open items disclosed during t the inspection are discussed in Paragraphs 7, 9 and Attachment 1.
j 15. Unresolved Items i i Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations or ! deviations. An unresolved item disclosed during the inspection is l discussed in Paragraph 3.
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Exit Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1) , on February 24, 1990, and informally throughout the inspection period and '- ' summarized the scope and findings of the inspection activities. The inspectors also. dis, cussed the likely informational content of the ea-inspection report with regard to documents or processes reviewed by the } inspectors during the inspection.
The licensee did not identify any such ,
- .ig documents / processes as proprietary, The licensee acknowledged the
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findings of the inspection, ! m , i l' ! .h.- ! ! !' l l- , ! [ !. t
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[ c , ! ATTACHMENT 1 During the period July 5 through July 14, 1988, a special safety inspection of the licensee's emergency operating procedures (EOPs) was conducted at the Fermi 2 plant.
The purpose of the inspection was to verify that E0Ps were technically correct; tnat their specified actions could be physically accomplished using existing equipment, controls, and instrumentation; and that the available procedures could be correct 1/ carried out by the plant staff.
Although the inspection team generally concluded that draft EOP in force during the inspection appeared adequate, several deficiencies and potential areas for improvement were noted.
A special safety inspection was condcuted by the Office of Nuclear Reactor Regulation on July 31 through August 2, September 25-29, and November 3, 1989, to review licensee responses to the items identified by the E0P inspection team.
The item and their disposition are specifically addressed below: DISP 051T10N OF E0P ITEMS Item 1: "(EOP) validation resulted in discrepancies requiring procedural step reverifications following E0P changes. The changes were incorporated but the reverifications were never documented."
The licensee stated that previously identified E0P reverifications had been documented following the inspection and that licensee procedure NPP-PR1-03, " Emergency Operating Procedure Development Process," currently governs the preparation, review and validation of all E0Ps. The inspector reviewed selected reverification documents and found them to be acceptable.
This item is c'losed.
Item 2: "Several changes to the E0Ps since the original validation in 1987, although individually minor, collectively could warrant augmented validation before implementation."
The inspector reviewed the licensee's E0P validation documentation and noted that all E0Ps were validated prior to implementation.
Concerns icentified during the 1988 E0P inspection were acceptably addressed.
This item is closed, i
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a , c , . .. o. Item 3: "7he licensee's validation team concluded that the text-based E0Ps were an improvement but that E0P flowcharts would ,! significantly enhance the useability of the procedures."
The licensee stated that it was investigating whether the use L of flowcharts would significantly improve emergency response ! capability.
1he E0P item is closed; however, completion of the licensee's evaluation of the use of flowcharts as well as development of guidance for flow chart preparation as discussed in item 46 below is considered an open item (341/89201-01).
L ltem 4: Two deviations between the Plant Specific Technical Guidelines (PSTGs) and the E0Ps were found to be adequately resolved , ' during the E0P inspection; however, they were not identified . in the implementation lists as deviations.
The inspector noted that the pertinent deviations were specifically included in the licensee's differences document.
' This item is closed.
Item 5: "The NRC team considered that the graphs used in the primary ! containment control procedure required reverification following recent calculational revisions."
! The inspector found that E0P NPP-29.000.02, " Primary Containment Control," had been revised to reflect revisions by General Electric to the drywell pressure calculations.
The inspector noted that both reverification and revalidation of the changes had been performed and documented.
This item is closed.
Item 6: '" Entry conditions for area radiation levels, HVAC exhaust ' radiation levels and area water levels of the secondary containment control procedures required revision."
The inspector noted that E0P NPP-29.000.03, " Secondary Containment Control and Radioactivity Release Control," had been revised to include area entry conditions for both radiation and water levels.
Both maximum normal operating levels and maximum safe operating levels for specific areas i were included.
This item is closed.
Item 7: The administrative procedure governing the E0P preparation process was not prescriptive enough to capture references to .I~ source documents.
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(< . . . - .. ' .. f I The inspector noted that the administrative procedure reviewed ' by the E0P inspection team had been superceded by licensee ! procedure NPP-PRI-03. * Emergency Operating Procedure b Development Process." NPP-PRI-03 requires that both E0P preparers and reviewers identify and record all source documents used during E0P development.
Source documents are specifically identified in the licensee's Differences Document.
The Differences Document identifies those source documents which support both the 'BWR Owner's Group Emergency Procedure p Guidelines (EPGs) and the PSTGs.
This item is closed.
Item 8: The licensee did not have a means to determine "whether an ' E0P is affected when a setpoint change or modification occurs."
The inspector noted that all engineering tesign packages, I drawing changes, vendor manual updates atd temporary modifications are formally routed through the operational support group which has responsibility for updating the E0Ps.
The inspector noted that several E0P revisions had been initiated by the operational support group as a result of recent modifications.
This item is closed.
Item 9: "(EOP) Reverification activities did not require a Writers Guide adequacy review."
Review of NPP-PR1-03 revealed that the E0P review requirements checklist "EOP Written Correctness Evaluation Criteria" specifically identifies the Writer's Guide as the reference document required to be used for reviewing E0P revisions, This item is closed.
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Item 10: " Additional guidance should be provided regarding potential sources of radiation, temperature and sump levels associated
with different plant areas."
The inspector noted that E0P NPP-29.000.03, " Secondary Containment Control and Radioactivity Release Control," has - been revised to include a table of potential sources of water by building area as well as identification of instruments for temperature and radiation readings and expected levels.
This item is closed.
- Item 11: "A sketch of reactor building areas and levels feeding each sump would be beneficial for implementation of the secondary containment control E0P."
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, c c ,. .. The inspector noted that reactor building area sketches and a tabular description of potential sources of water for each sump j' had been incorporated into E0P NPP-29.000.03, t ? This item is closed.
> ^ Item 12: E0P NPP-29.000.02, " Primary Containment Control" "contains a three page calculation to determine drywell average temperature that can require 15-20 minutes to perform."
- r The licensee stated that average drywell temperatures would be obtained via the safety parameter display system (SPDS) which is powered by an uninterruptible power supply. The manual calculation remains as a backup method for determination of average drywell temperature.
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This item is closed.
!, Item 13: "The Primary Containment Pressure Control Section of the EOP i i required actions based on curves of torus pressure and level.
Instrumentation for the torus level did not span the full
height of the torus, so calculations were necessary to i r.
! determine level during certain emergency conditions.
There was ! no explanation of how to calculate torus levels the first time t ? this curve was referenced in the EOP."
The inspector noted that E0P NPP-29.000.02 had been revised to - explain how to determine torus levels outside the range of available instrumentation the first time the calculation is referenced.
] This item is closed.
' Item 14: The average torus water temperature " calculation was still 'I time consuming and could divert operators from responding to
, the event."
i ' The licensee stated that a recorder which would display the I average torus water temperature was being installed in the ( control room under Engineering Design Package (EDP) number
8472.
EDP 8472 will resolve a human engineering deficiency <
(HED) and is scheduled to be completed prior to startup from i the current refueling outage. Average water temperature is - also obtainable through SPDS which 15 equipped with an i uninterruptible power supply.
! r ! The E0P item is closed; however, completion of EDP 8472 and i > ! demonstration that the recorder is operable will be tracked as ( an open item (341/89201-02), j , i $ , f I
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. . .. ' I ', - . i , ... . ' I Item 15: Clarification of the override statement for Drywell > f Te'rperature Control to operators to verify that certain , y automatic act1ci.s had occurred.
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The inspector noted that the override statement for Drywell [ ' Temperature Control had been revised to direct operators to ' verify that automatic actions had occurred or to taanually , perform the action.
. s This item is closed.
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.t - Item 16: "The first two steps, DW/T and DW/T-1 of the Drywell t Temperature Control section in the E0P...were redundant."
' y.... x The licensee revised the EOP such that the steps were in. i agreement with those in the EPGs and are no longer redundant.
This item is closed.
Item 17: The comparison table in the tocu water level control section - - of E0P NPP-29.000.02 used for enermining maximum primary containment water level limit was too small to read.
' The inspector noted that the E0P had been revised and that the' table was easily readable.
i ' This item is closed.
Item 18: "The team considered that the licensee should review the-i interface between the E0Ps and the operating procedures to i ensure clarity."
, < , } n The inspector noted that the Writ'er's Guide states that steps ' , t-excerpted from other plant procedures should be repeated in the
' E0P text; however, if the excerpted portion required more than one page, the aornoriate procedure should be referenced rather i than included in the E0P.
f The licensee stated that in some cases, inclusion of steps, " regardless of-length, from other procedures would enhance ' performance of the E0P.. It also stated that inclusion of steps , ' from other procedures in the E0Ps would be considered on a cast by case basis.
t . This item is closed; however, the resident inspectors will continue to monitor the licensee's practices in this area.
' Item 19: The team noted that the primary containment wetwell was called the " torus" in some applications and the " suppression y pool" in other applications.
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i The licensee stated that the two terms were defined as [ synonymous in the Differences Document and that plant staff L ~ were trained that both terms apply to the primary containment
_, , wetwell. The inspector interviewed members of the plant staff and determined that plant staff understood that both terms ! C l1 referred to the wetwell.
! t i " ThiF item is closed.
! i Item 20: "One of the prestaged (EOP) tool boxes in,the turbine building , i was too tall for the operator to easily lif t equipment out of it."
i L The inspector inspected all of t,he E0P boxes in the turbine I building and found that this deficiency had been corrected, i ' This item is closed.
Item 21: Couplings between hoses used for alternate boron injection s procedure using the standby feedwater system were difficult to f rotate.
The inspector inspected the couplings currently used for
connecting the subject hose and found them easy to rotate, t This item is closed.
Item 22: - The licensee made no provision-to vent the_ hose used for I alternate boron injection using the standby feedwater systeri: prior to use.
The inspector reviewed the revised E0P and noted that provision l to vent the subject hose had been explicitly included in the
E0P.
Review of the procedure raised a question as to whether-
o , sufficient head-existed in the condensate storage tank (CST) under accident conditions to adequately vent the air from the
- hose.
The' E0P item is closed; however evaluation of the functional I adequacy of the method used to vent the ho.,o for alternate , boron injection with CST water will be tracked as an open item
(341/89201-03).
i Item 23: The licensee connitted to conduct surveillance of the i pathway for bringing boric acid into the turbine building for D-alternate boron injection by the Turbine Building Auxiliary Operator (TBAO).
The inspector noted that surveillance of the subject pathway ' was included on the TBA0 daily rounds and that the pathway was . clearly marked as a " keep clear" area.
This item is closed.
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, , e f ' Item 24: "The licensee corrrmitted to provide means via forklift [',, extenders to place chemical barrels on the platform adjacent to the tank (used for alternate boron injection)."
@ ', The inspector observed that adequate provision for moving boron "! barrels onto the pictform adjacent to the tank had been added.
This item is closed.
' Item 25: The licensee committed to revise the procedure (Alternate Boron' Injection, Section 3 - Boron Injection with Condensate /Feedwater Systems) which re-energizes valve controls ! for valve N21-F006 and to minimize the differential pressure across the valve prior to opening.
The inspector noted that tne E0P had been revised to reenergize . the subject valve and to caution the operators to minim *,ze the pressure across valve prior to opening the valve.
This item is closed, o Item 26: The team was concerned that tygon tubing used for venting control rod drive over piston volumes was incapable of withstanding high temperatures which may be present during venting.
The inspector noted that the tygon tubing had been replaced by braided flexible steel hoses which were rated.to withstand the expected conditior,s.
This item is cl u ed.
Item 27: The licensee committed to develop and ;>erform periodic , surveillances of E0P equipment boxes prestaged throughout the ' plant.
The inspector reviewed the licensee's E0P box audit procedures and inspected the E0P boxes. Audit procedures and box contents were found to be satisfactory. T,he inspector noted that audit forms are only retained until completion of the next audit at . which time previous audit forms are diccarded.
l The E0P 'a - is closed; however review of the licensee's practices regarding retention of the audit forms will be i tracked as an cren item (541/89201-04).
i Item 28: Thr. team noted that tools and equipment were generally left s',attered throughout the plant.
The licensee was in the middle of its first refueling outage ! during the fullowup inspection,. I ! I
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This item is closed; how ver, the resident inspectors will
i continue to monitor licensee housekeeping practices.
l , Item 29: The licensee stated that improvements to the plant paging ! System were planned.
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? !- This item is closed in that the concern is tracked under'open
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item (341/86019-01(DRP)). - ! Item 30: The team noted that the torus and drywell parameters for the
torus vent paths and the drywell vent paths were reversed. This discrepancy was not caught by the licensee's verification j process.
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The licensee stated that this had previously been resolved and that no revisions to the E0Ps were necessary in that the l, discrepancy affected the Appendix C calculations only.
This item is closed.
j Item 31: The licensee committed to revise the surveillance procidure ! fr>r the fuel pool ventilation exhaust radiation monitoring i
l' system trip settpoint to reflect a maximum trip.setpoint value of 6.1 mrem /hr.
The inspector noted that the surveillance procedures for all four channels' had been revised to reflect the corre.:t trip ! setpoint.. This item is closed.
P Item 32: -Instruments to accurately determine primary containment water level above the 631 foot level did not exist.
' The licensee stated that it informed the NRC by letter dated ,..
' September 27, 1989, of its intent to install appropriate instrumentation by March 31, 1990.
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t The E0P item is closed; however, completion of installation of the subject instrumentation and proof of its operability will
be tracked as open item (341/89201-05).
F Item 33: Resolution of difficulty obtaining and communicating drywell
and torus hydrogen, oxygen and pressure parameters.
~ , i The inspector noted that this item is being handled as an HED.
f ' , . Final resolution of this and other HED items identified as Items 53, 54 and 55 in this report, will be followed by the i resident staff.
Resolution of these four items will be l followed by the residents as open item (341/89201-06).
The E0P item is closed.
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fi - ,, ]' ' e g-q , . ., - ' ' t, e. 4 , ~. . P , f Item 34:' Interviewswiththetraihingstaffrevealedthatsimulator [ i limitations resulted in limited dynamic training on the E0Ps.
' - n , " '" The' licensee stated that upgrades to the simulator software are ! L currently underway.
The 50P item is closed; however, completion C of the simulator software upgrade will be tracked as open item- , i ? (341/89201-07), - p " Item 35: The licensee committed to training non-liceased power plant
i operators on the use of the E0Ps, including the enclosures, ' before implementation of the E0Ps.
, b ' The licensee stated that'all non-licensed power plant operators ' including appropriate members of plant management had been i , trained on the E0Ps.
The inspector reviewed a sample of the ' training records and found them to be acceptable.
, ' This item is closed.
Item 36 through Item 41: .
' ' The following items deal with issues surrounding containment ' venting. These E0P items are closed; however, final resolution , E of these concerns will be tracked collectively as open item , ! (341/89201-08). The items are summarized below for
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Item.36:. Vent paths chosen for emergency containment venting did'not
include all available vent paths.
The E0P item is closed; however, final resolution of this concern will be tracked and followed by the resident staff as a . portion of open item' (341/89201-08).
Item 37: Evaluation of whether standby gas treatment piping integrity can support containment venting without inadvertent releases into the auxiliary building.
The E0P item is closed; however, final resolution of this concern will be tracked and followed by the resident staff as a portion of open item (341/89201-08).
Item 38: Performance of an engineering analysis for the standby gas treatment system, exhaust system ductwork, reactor building a blownut panels and valves to ensure their operability under differential pressures expected during venting.
j The E0P item is closed; however, final resolution of this concern will be tracked and followed by the resident staff as a portion of open item (341/89201-08).
l i Item 39: Consideration of opening vent path from primary containment to torus early in E0P.
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g w . ' cc , L The E0P item is closed; however, final resolution of this i F concern will be tracked and followed by the resident staff as a portion of open item (341/89201-08).
' Item 40: Revision of E0Ps to provide direction for containment venting' [ manually in the event that either electrical power or control l air.is lost.
! L The E0P item is closed; however, final resolution of this - ' n concern will be tracked and followed by the resident staff as a , portion of open item (341/89201-08).
,, b . . Item 41: Evaluation of proposed modification to provide capability to ! vent with pressures as high as 90-100 psig.
The E0P item is closed; however, final resciution of this concern'will be tracked and followed by the resident staff as j - a portion of open item (341/89201-08).
Item 42: Reestablishing drywell cooling dependent on accident scenario.
The E0P item is closed; however, review and revision of the E0Ps to allow operators to restore drywell cooling based on plant conditions will be tracked as a portion of open item , (341/89201-09).
t Item 43: The Writer's Guide needed to provide expanded descriptions of the proper and improper use of conditional and logic statements.
' The licensee stated that the Writer's Guide had been revised to ' reflect the guidance put forth in NUREG-0899, Section 5.6.10 ! and Appendix B.
The inspector noted that the subject section ' of NUREG-0899 had been included verbatim.
< , - , , This item is closed, t t Item 44: The Writer's Guide did not specify that the place-keeping aids (blanks for checkoffs) should be placed along the right ? margin of the page.
The inspector noted that the Writer's Guide had been revised to ' specify location of the blanks for checkoffs used as " place-keeping aids and that place keeping aids had been added to the E0Ps.
L This item is closed.
Item 45: The Writer's Guide did not specify criteria to be used to determine whether steps should be referenced or included in ! i E0Ps.
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l , , q , i IL As noted in the discussion of item 18 above, guidance for i inclusion of steps from other plant procedures has been n
addressed.
Each occurrence will be treated on a case by case
' basis and will be monitored by the resident inspectors. This ' . item is closed.
u - , Item 46: The Writer's Guide did not specify the criteria to be used l L in developing and presenting flowcharts as aids to support the ~' ! E0Ps.
- I As noted in the discussion of item 3 above, the licensee has
, , yet to determine whether development and use of flow charts o.
will occur.
Should flowcharts be deemed necessary, the [ Writer's Guide will be revised to provide associated guidance and criteria. This item is closed; however revision of the . _ Writer's Guide to provide such guidance in the event that flow l charts are used will be tracked as open item (341/89201. 01).
Item 47: The Writer's Guide should be revised to specify type font < and size for use in printing the E0Ps.
. The inspector noted that the Writer's Guide has been revised to specify E0P type font and size.
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This item is closed.
, a Item 48: The Writer's Guide did not specify the criteria to be used 'for "non-sequential", " recurrent", or " time dependent" steps as ' . stated in NUREG-0899, Sections 5.7.2 through 5.7.8.
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, The licensee stated that use of such steps in its E0Ps is not i allowed and that any steps which must be repeated were l explicitly included in the E0P data forms contained within the ! , E0P supplements. The licensee also stated any such trends would ' [ be noted by the SPDS display in the control room.
' This item is closed.
'; Item 49: Clarification of the use of capitalization in the Writer's , Guido.
, , e' The inspector noted that the Writer's Guide had been revised to , specify when and how capitalization was to be used in the E0Ps.
This item is closed.
, Item 50: The Writer's Guide could specify that the page number, as ' , well as the reference, for non-emergency procedures should be U. ' given.
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r . . ! ' As noted in the discussions of items 18 and 45 above, the j h licensee has included guidance for inclusien of steps from ! L other procedures in the Writer's. Guide.
For those cases where , h the pertinent procedure is referenced rather than included in ' the E0P, the licensee stated that it preferred not to include l e L 'the procedure page number.
It stated that as procedures are L revised, page numbers would change and a revision to the parent
L procedure would then necessitate a revision to the E0P. The > b licensee &lso stated that evolutions dascribed in other plant , procedures were well known by the operators and would not cause ' ' delays in performance of the E0Ps.
! , The E0P item is closed; however, the resident inspector will l monitor operator training to assess whether specifying page
' ' numbers of other plant procedures in the E0Ps is warranted.
Item 51: The Writer's Guide could state' specific criteria for providing locations for out-of-control-room components, j The inspector noted that the Writer's Guide had been revised to ! state, " Location information for components or parts that might ' otherwise be difficult to find should be'provided whenever ! practical."
i This' item is closed.
- < Item 52: The Writer's Guide could specify that the procedures are page numbered in a fashion that provides the total number of i pages.
- The inspector noted that the Writer's Guide has been revised to require that the total number of pages (e.g., page 7 of 12) be printed or each page of the E0Ps.
- , e This item is closed.
Items 53 through 55, in conjunction with item 33 deal with resolution of
L human engineering deficiencies. Resolution of these 4 items will be
tracked by open item (341/89201-06).
Items 53 through 55 are defined below.
. i j Item 53: Evaluation of color bands on gages in the control room.
The E0P item is closed; however, final resolution of this
concern will be tracked and followed by the resident staff . as a portion of open item (341/89201-06).
' , Item 54: Use of three different ranges on instruments T50-R802 A L and B.
The E0P item is closed; however, final resolution of this concern will be tracked and followed by the resident staff as a portion of open item (341/89201-06).
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. m . L Item 55: Two pen recorder for DRYWELL DIFFERENTIAL PRESSURE and .; [ SUPPRESSION POOL DIFFERENTIAL PRESSURE was misnamed, E provided the only narrow range indication for torus-pressure and used a questionable scale. The E0P item is closed; however, final resolution of this concern will be ! tracked and followed by the resident staff as a portion of openitem-(341/89201-06).
Item 56: The Writer's Guide, Administrative Procedures, operator ., training and E0Ps did not provide a preferred method of t place-keeping beyond checkoff blanks.
l The inspector noted that a preferred method of place-keeping in , the form of " medium sized paper clips" was specified in both I the Writer's Guide and in operator training.
' l' This item is closed.
Item 57: Licensee evaluation of a preferred place-keeping method that , is procedurally supported and trained on a periodic basis.
- As noted in the discussion of item 50 above, the preferred place-keeping method is defined and operators are trained to i t use them.
This item is closed.
Item 58: ;Use of the logical condition "WHEN - BUT JNLY IF" without ! definition of the criteria for use in the Writer's Guide.
The licensee stated that the subject logical condition occurred , only once in the E01:. The phrase "WHEN - BUT ONLY IF" has j since been deleted from the E0Ps.
This item.is-closed, f Item 59: The team noted a need for a technical editor for E0P reviews.
The inspector noted that currently all E0P revisions have undergone a review by the same technical editor. Also, E0P J review checklists provide sufficient criteria to assure a ! technical review is performed against the requirements of the Writer's Guide.
However, the inspector noted that the licensee ' currently has only one person acting in the role of technical - editor and stated that training of an additional reviewer would provide coverage when the current technical editor is unavailable.
The licensee acknowledged the inspector's comment.
This item is closed.
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