IR 05000341/1991002
| ML20217D102 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/11/1991 |
| From: | Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217D004 | List: |
| References | |
| 50-341-91-02, 50-341-91-2, NUDOCS 9107220052 | |
| Download: ML20217D102 (17) | |
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i U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Report No. 50-341/91002(DRP)
Docket No. 50-341 Operating License No. NPF-43 Licensee: - Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name:
Fermi 2 Inspection At:
Fermi Site, Newport, Michigan
. Inspection Conducted: April 29 through May 10, 1991, onsite May 23,'31 and June 3,1991, NRC in-office review Inspectors:
B. S.-Drouin, Team Leader M. L. Dapas-M. A.' Miller E. A. Plettner S. A.
eyn lds Approved By: (, h.
JUL 111391
+~
e yette, Chief
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Reactor Projects Section 28 Date Inspection Summary-Inspection on April 29 to June 3,1991 (Report No. 50-341/91002(DRP))
Areas Inspected: Review of the development and control of engineering design packages (EDP) and associated work requests (WR); review of the field installation of modifications, to include control and quality of work, and the documentation of activities; review of post modification testing (PMT),
to include the development, adequacy, control and documentation of testing activities; radiological controls; and housekeeping and material condition.
Results: The overall process for the design, implementation and testing of emodifications was adequate.
Management planning and control over the modification process was good as-
-evidenced by the ef ficient integration of modifications into the Refuel Outage 2 schedule. The EDP preparation was. good and the licensee's engineering staff representatives responsible for the EDPs exhibited a good sense of " ownership",
appearing to be involved in all phases of the modification implementation process.
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However, in one case, the licensee did not identify critical equipment performance parameters, which were necessary for operability, as acceptance criteria.
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9107220052 910711'
PDR ADOCT 05000341
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field installation-of modifications was good, with good supervisory oversight of work activities, good engineering support, and knowledgeable craf t personnel.-
However, work steps performed nonsequentially without authority, doctmentation errors with associated WRs, and personnel noncompliance with radiological
.c no trols detracted from the overall modification installation effort. Hinor problems with housekeeping were also identified in the work areas.
The nodification testing process was adequate. Some problems were noted in the use of a post maintenance testing procedure and in translating EDP test requirements into adequate test instructions. All required testing appeared to have been completed prior to the modified systems being returned to service.
One violation involvi.ig the appropriate use of acceptance criteria was cited.
(Section3c).
One violation was cited for failure to follow procedures when i
performing work activities (Section 4c).
One violation with four examples was cited'for failure to follow a radiologi:a1 controls procedure (Section 6).
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DETAILS 1.
Persons Contacted a.
Detroit E' ~'i Company
- R. Anderson, Superintendent, Radiation Protection
- J. Dudlets, Supervisor, Engineering Design
- P. Fessler, Superintendent, Technical Engineering
- L. Goodman, Director, fiuclear Licensi1g
- J. Malaric, General Supervisor, Modifications
- R. Matthe'is, Assistant Superintendent, Maintenance
- R. McKeon, Plant Manager
- W. Miller, Director, Nuclear Quality Assurance
- R. Newkirk, General Director, Regulatory Affairs
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- W. Orser, Senior Vice President
- T. Riley, Supervisor, Compliance and Special Projects
- L. Schuerman, General Supervisor, Plant Engineering
- D. Siemasz, Licensing Engineer
- R. Stafford, General Director, Nuclear Assurance b.
U.S. Nuclear Regulatory Conunission
- E. W. Brach, Branch Chief, Performance and Quality Evaluation, NRR
- H. B. Clayton, Branch Chief, Division _of Reactor Projects, RIII
- W Rogers, Senior Resident Inspector
- B. Drcuin, (Team Lt:ader), Project Engineer, RIII
- M. Dapas, Operations Engineer, NRR
- M. Mil'.er, Operations Engineer,fiRR
- E. Plettner, Senior Resident Inspector, Big Rock Point
- S. Reynolds, Senior Project Manager, NRR
- S. Stasek, Resident Inspector
- Denotes those attending the exit r.eeting on May 10, 1991. The inspectors also interviewed others of the licensee's staff during the inspection.
2.
Introduction The purpose of the Modification Implementation Tecm Insaection was to conduct a performance based review of the licensee's trodifications implementation program.
The team consisted o' five inspectors and began with the in-office review of applicable licensee procedu.(- and 18 selected EDPs and associated WRs prior to the onsite inspection. The onsite inspection cornenced April 29, 1991, with 20 EDPs and one potential design change (PDC) reviewed.
Inspection emphasis was'placed on the observation of field installation of modifications cod on the observation of st modification testing.
Work requests of' selected EDPs which were i m.
complete prior to the-beginning of the onsite inspection were also reviewed to ensure that appropriate control was maintained during field installation, that
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required supervisory reviews were performed, and that the required modification testing was performed and adequate. Actual field observations focused on engineering support to ongoing modification activities, control of work, and knowledce and skill of the craft personnel. AdditionalNRCinspcctioneffortwasrequiredafter completion of the onsite inspection activities to resolve issues concerning the field installation and the testing of modifications.
The inspection report consists of five sections:
Engineering Design Package Review, Field Installation of Modifications, Modification Testing, Radiological Controls, and Housekeeping and Material Condition.
3.
Engineering Design Package Review (37700)(37702)
Through a review of documents and personnel interviews, the following EDPs and one PDC, and associated WRs were inspected to verify conformance with the requirements of Technical Specifications (TS),10 CFR 50.59, the Updated final Safety Analysis Report, the licensee's Quality Assurance Program and 10 CFR 50, Appendix B, Criterion III, " Design Control."
EDP 06641 Replace Existing Rod Worth Minimizer (RWM) System with Microcomputer Based NUMARC-RWM System.
EDP 06740 Reactor Pressure and Level Instr umentation Rack Replacement.
EDP 08321 Replace the Existing Differential Pressure Type Level Transmitters with Displacement Type Level Trar.smitters on Feedwater Heaters 2 North, 2 Center, and 2 South.
Remove Limit Switches and Modify) Status Indication on the EDP 09310 Combination Operating Panel (COP for Reactor Water Clean Up (RWCU) System Testable Check Valves G3300F120 and F121.
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EDP 09828 MSIV Control Room Status Indication.
EDP 09922 Replace the Existing EPA Logic Cards with Modified Type.
EDP 10452 Replacement of Main Steam Isolation Valve Leakage Control System (MSIVLCS) Valves.
EDP 10577 Installation of Banana Jacks for Reactor Building Vent Exhaust Rad Monitor Calibration.
EDP 10610 T46/T48 Isolation Valves Position Indication Modification.
EDP 11222 Replacement of MSIV Parts to Improve Leakage Control.
EDP 11253 Rebuild Ccmbination Operating Panel (COP) Insert H11P6018512.
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EDP 11206 Replacement of Pultipoint Recorders in Control Room, i
EDP 11300 heheater Seal Tank Addition.
EDP 11304 Snubber R(duction for Drywell Instrument Piping.
EDP 11602 Modification of the liigh Point Vent on Division 11 Low PressureCoolantInjection(LPC1)PipingInsidethe J
i Drywell to Reduce Vibration Loading, EDP 11063 SCRAM Discharge Y',)urt V.nt Line Modification.
-i CDP 11577 E11f000 A A 8 Modification of Actuator to Allow f ull Stroking of Valve and Removal of Actuator Indic tion.
EDP 11600 Installation of LP Turbine 1, 2, and 3-Stage 5 Modified j
Blading.
EDP 11689 Modification of CCHVAC Logic Circuitry, Prioritizing Recirc,lodn over Chlorine Mode and Correction of CCHVAC j
Mode Select Switch Logic Requiring the Reset Push !?utton
for Mode Actua', ion.
PDC 12169 MoistureStaaratorReheater(MSP)ReliefYalvePanifold Drain Line 1eroute,
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The EDPs were generally well developed with comprehensive safety evaluations.
The EDPs received a>propriate management attention and were properly planned as demonstrated ay the efficient integration of the LDPs into the Refuel Outage (RF) 2 work schedule end by adherchte to the Rf 2 scheoula for raodification completion.
Coordination between the engineering, nodifications, and meintenance staffs facilitated the translation of LDP design details into work instructions for the field installation of rodifications.
Only one example of nodification rework due to inadegnate engineering was noted and the example was not indicative of ineffective
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engineering support,
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Typical of the effort described above were CDPs 09922 and 11563 which a.
contained well written safety evaluations.
EDPs 00641, 083?l, 11300 and 11354 were examples of EDPs with good engineering sup30rt.
L From walkdowns and inspector discussions of these EDPs, tle inspectors determined that the EDP owners and the modification field engineers were very knowledgeable of the purpose, scope and status of their assigned EDPs.
b.
In the review of ?.he EDPs minor problems were identified involving inattention to detail, the use of " acceptable limits", and one example of inadequte design.
(1) Some examples of inattention to detail were:
EDP 11PPP (WR 0060900514 - MSIV "C" outboard) had two sets of work instruction steps 15 through 19 which were developed during the pla.,ning process and were not identified nor corrected.
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EDP 11502 omitted a discu;sion of as-low as-reasonably-achievable (ALARA), fire protection and security concerns or interfaces.
However ALARA issues were acequately addressed in the associsted work request, WR 0010901031, and there appeartd to be no impact on fire protection and security by the system modification.
(2) The inspectors identified a conci ~ regarding the appropriate characterization of EDP-specified engineering design acceptance criterion in their review of EDP 09922.
The undervoltagt tilne delay limit (UIDL) for the EPA logic cara was identified as an engineering design acceptance criterior, in EDP 09922.
However, the UTDL was characterie ' as acceptable limits when the UTDL was transferred to pr.
a 42.610.02, Div 1, Reactor Protection System (kFSj, actrical Protection Assembly Calibration / Functional lest, in Section 2.8.1, Appendix C, to procedure WG-001, " Fermi Writer's Guide," the term acceptance criteria was characterizcd as the acceptable limits of data required by the Technical Specifications (TS). The definition implied that only values described in TS can be considered acceptance criteria. However, in Appendix A, Revision 3
" Definitions", to the fermi Management Policy and Directives Idanual (FMPDM), acceptance criteria was defined as a limit or limits placed on the variation per.Itted in the characteristics of an item expressed in definitive engineering terms such as diaensional tolerances, chemical composition limits, time limits, operating parameters and other similar characteristics.
The purpose of the UTDL was to preclude spurious EPA breaker trips due to tempori ry electrical power source fluctuations, thereby reducing spurious RPS trips. Although the EPA breaker UTDL was not described in TS, the U1DL did satisfy the definition of acceptance criteria contained in FHPDM, A>pendix A.
As an acceptable limit, the UTDL could be outside t1e range specified in procedure 42.610.02, yet the calibration /
functional test could be considered adequate even though the EPA breaker would no longer be able to perform its design function (protect the RPS equipment). The engineering-review required to change an acceptable limit via a temporary change notice (TCN) to the calibration / functional test procedure, is less rigorous than the review required to change an acceptance criteria.
In this cese the incorrect UTDL range was installed in the EPA logic card on March 10, 1991. The incorrect range was discovered on March 11, 1991, during an engineering review i
of the modification testing (procedure 42.610.02) and a TCH was issued to change the UTDL range. A deviation event report (DER)
91-0113, "Jiolation of NPP-PRI-02 (Temporary Change Notice)"
was issued because the staff was attempting to change acceptable limits" and u TCH was believed to be inappropriate.
However the licensee's staff concluded in DER 91-0113 that " acceptable limits" were not acceptance criteria and therefore a TCH was appropriate to change the UTDL range.
In the case of the EPA breaker, ch6racterizing the UTDL as acceptable limits was
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nonconservative and ir4 creased the potential that a nonconserva-tive UTDL could be installed in the EPA breakers, lhe inspectors did note, however, that all the time delay limits described in EFp 09922 were correctly installed.
The UTDL/ acceptable limits issue was idcntified late during the onsite phase of the inspection.
The licensee's initial position was that the UTDL was not contaired in TS and, therefore, the U10L was properly characterized as acceptable limitc.
The licenste's Nuclear Engineering Departnent deterniir:ed on June 13, 1991, that the UTDL was recuired to be within s)ecified ranges for an epa breaker unit to be considered " opera)le", and therefore, the UTDL should be desipattd dcceptance criteria.
On June 13, 1991, the Supervisor, L-oliance and Special projects, tactified the Region 111 56.ff that the UTDL was considered acceptance criteria based on a new definition of acceptance criteria, which resulted from a June 11, 1991, meeting. The licensee plans to revise all procedures containing acceptance criteria oefinitiont with the new definition which is any paratacter that is a specific lire item in the Fermi 2 Technical Specifications or is otherwise necessary to satisfy the requiremeats for Technical Spccifications operability.
fhe licensee is also evaluating all other parameters identified as
" acceptable limits" against the new definition.
10 CFR 50, Appendix 0. Criterion V requires that activities affecting quality be prescribed by documented instructions, procedures, and drawings of a type appropriate to the circumstances.
Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activitics have been satisfactory accomp?ished. Fermi Management tirective fMDCT1, Revision 1," Calibration, Testing,andSurvei} lance,"
Section 4.5.4.13, required that appropriate acceptance criteria be incorporated into calibration, test, or surveillance procedures. Apptodix A, Fermi Management policy and Directives Manual, included time limits as the type of equipment parameter that should be identified at acce)tance criteria.
The UTOL was essential te the operability of t1e EPA breater and should have been designated as acceptance criteria in procedures 42.610.02 and 42.610.04 Failure to designate the U1DL as acceptance criteria is a violation (341/91002-01(DRP)).
(3) The design of EDP 11089 incorporated a " sneak" electrical circuit such that the control center heating, ventilation, and air conditioning (CCHVAC) system logic could not be switched from the emergency recirculation mode.
The modi 11 cation to the CCHVAC logic Division (Div) 11 had been installed, and post modification testing (PMT) had been completed when the design deficiency self-disclosed on May 2,1991, at, operators attempted to shift Div 11 CCHVAC from the recirculation mode.
The inspectors determined through interviews and document reviews that the creak circuit was technically difficult to identify due to the interface between CCHVAC logic circuitry and loss of coolant accidtnt (LOCA)
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signals. The licensee performed all iequired technical reviews
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of the design change, and perfortned several additional technkal ieviews (fortnal and informal) to usure an adequate design.
Although the sneak circuit was not identified by the PMT on Div II, the inspectors verified that the licensee's PMT for the Div I i
CCHVAC logic change, which included manipulation of both Div I and !! CCHVAC logic, would have identified the sneak circuit. The recirculation node was the most conservative mode for the Div 11 CCHVAC under most conditions and, therefore, the design error had minor safety significence.
The error was irunediately t
corrected by the licensee.
The inspectors considered the licensee's design review reasonable.
No further action was required.
One violation was identified in this area.
4.
Field installation of Modifications (37700)(62700)
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Through field observations of work being performed, review of documents, and personnel interviews the following EDPs/ PDC anc associated WRs were inspected to verify that modifications were appropriotely installed,
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personnel performing the inste11ations were knowledgeable, applicable procedures were utilind and followed, engineering support was appropriate, and work was controlled.
CDP 06740 Reactor Pressure and Level Instrumentation Rack Replacement.
EDP 08321 Replace the Existing Differential Pressure Type Level Transmitters with Displacement Type Level Transmitters on feedwater Heaters 2 North, 2 Center, and 2 South.
EDP 10010 T46/T48 Isolation Valves Position Indication Modification.
EDP 11253 Rebuild Combination Operating Panel (COP) Insert H11P6010512.
EDP 11300 Reheater Seal Tank Addition.
EDP 11577 E11f050 A & D Hodificction of Actuator to Allow full Stroking of Valve and Removal of Actuator Indication.
CDP 11620 Installation of LP Turbine 1, 2, ar.d 3-Stage 5 Modified Clading.
-EDP 11889 Modification of CCHVAC Logic Circuitry Prioritizing Recirc Mode over Chlorine Mode and Correction of CCHVAC Mode Select Switch Logic Requiring the Reset Push Button for Mode Actuation..
EDP 12080 Retube Main Condenser with Titenium Condenser T"hes.
PDC 12159-Moisture Separator Reheater (MSR) Relief Valve Manifold Drain i.ine Reruute.
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i in addition to EDPs/ PDC undergoing field installation identified ab m, turs and associated Wks (identified in Sectico 3 of the report) con,pleted prior to the beginning of the onsite inspection were reviewed to determine appropriate field installation and the adequacy and c0mpleteness of the WR docunentation.
The quality of the work in progress was good as determined through field observations of work activities. A review of post nodification testing documents of completed EDPs identified no problems specifically attributed to poor field installation. A high level of supervisory oversight was noted at in-progress work activities.
In addition, the licensee task rnanagers responsible for contracts to perform EDP field installations
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demonstrated an appropriate level of involvement over the field installation activities. The huclear Engineering Department engineers and/or the modification field engineers exhibited good " ownership" in discussions and walkdowns of assigned EDPs with the inspectors. Craft personnel were considered knowledgeable and competent based on inspector observations of work activities.
The inspector also attended contractor shift turnover briefings and determined that licensee management emphasis was being of fectively cornmunicated to first line contractor supervisors and work priorities were being controlled.
Control of contractor field installation activities which had been identified as a weakness in past NRC inspections appeared to improve. However, contractor employees were responsible for several radiological controls procedural violations which are discussed in section 6 of the report.
The observations of the following EDPs were generally typical of a.
field installation activities observed by the inspectors.
(1) E0p 11577 - The inspectors observed contractor personnel
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installing the nitrogen supply line to the E11f050 B valve actuator.
The inspectors observed welding on the stainless steel supply line and witnessed a Production Quality Assurance (PQA) inspector perform a visual inspection of the completed weld. lhe contractor personnel, including the welder, and the p0A inspector performed their activities efficiently and effectively. Thu e were no apparent deficiencies or inconsistencies identified.
The inspectors verified that the work instructions were at an appropriate location outside the contamination area and that the work performed was properly recorded in the work package, including the weld data sheets and the p0A inspection sheets.
(2) EDP 11300 - The insped srs cbserved the rerouting of system piping, the installation of a second reheater seal tank and associated piping, pipe fit-up and welding, and post-weld stress relaxation heater setup. Work for this roodification was performed by contractors. Contractor personnel appeared to be knowledgeable and competent in the work perforned. The inspectors noted that the job foreman and contractor supervisor were present during all observed work activities indicating that adequate supervisory attentien was being provided.
The inspectors observed that the work procedure was present at the work site and was being properly followed. During the
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installation of this raedification, the licensee raised a concern with how to effectively heat treat the north reheater seal tank for post-weld stress relaxation, lhe licensee demonstrated a conservative approach in resolving the concern, b.
The inspectors noted an apparent lack of guidance for rigging ard handling loads in the Turaine Building after observing a large section of twelve inch alpirig being supported by four inch piping, procedure NPP-PH3-02, "ligging Preparation and Load Handling", was prescriptive when discussing the rigging of loads in the Reactor, Auxiliary and Residual Heat Removal (RHR) Building,'s,tandardbut rigging in s
the Turbine Buildit:p was based on nonprescriptive prectices." Licensee management was notified of the inspectors'
observation, and a licensee evaluation of the loading on the four i
inch pipe was performed, with no adverse impact to the pipe being identified.
j c.
In spite o# the overall good performance observed during the field installation of roodifications, extensive errors were noted in the performance of work steps cod the mdocunentation of work activities
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for both in-progress WRs and field-complete WRs. The inspectors noted that numerous WRs had work steps which were performed out of-sequence. Although, the nonsequential performance of work steps had no apparent impact on the modified equipment, work group supervisors or work planners were required to approve by appropriate indication in the work instructions, that work steps could be performed nonsequentially.
This was not done.
Performing work steps out of sequence is a poor practice, and a violation of procedures.
The identifieddocumentationerrors(missingorinaccuratedates, missing signatures-and sign-of fs) did r.ot appear to be safety-Lignificant; however,-the documentation errors did represent multiple examples of a failure to follow procedures and inattention to detail.
Scre examples of the work performance and documentation errors are described below:
(1) EDP 06641 - The inspectors reviewed the work instructions associated with the modification, including WR 0030900322.
NPP-MA1-04, Revision 7 " Conduct of Maintenance", requires work instruction steps to be followed sequentially, unless indicated oth;rwise within the body of the instructions.
However, several
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steps in the WR appeared to have been performed out of sequence, based on the sign-off dates of work steps.
Exarnple:
steps 1.7 and 1.8 were dated 4/28/91 and step 2. was dated 4/15/91; steps 3.7 and 3.8 were dated 4/26/91 and step 3.9 was dated 4/20/91; step 9.2 was dated 5/3/91 and step 10 was dated 4/28/91; steps 11.3, 12.3, and 12.5 were dated 4/19/91 and steps 11.1 and 11.2 were dated 4/20/91. Also, several steps were not signed-off indicating that the work had not been performed.
For example:
steps 4.15, 4.10, 8.4, and 9.1 were not signed-off. After further detailed rcview of the modification pacLege, lengthy discussior.s with the trodification
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field engineer, and field verification, the inspectors were able to determine that the steps that were not signed-off had actually been completed and, further, that the performance of the work steps out of sequence did not appear to affect the intended function of the installed equipment.
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Performing work instruction steps out of sequence without appropriate indication in the work instructions was prohibited by flPP-MA1-04 This is an example of a violation of Technical Specification 6.0.1 for failure to follow procecuits (341/91002-02 (DRP)).
The following were additional examples of WRs, which were associated with other EDPs, that appeared to have work
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instruction steps performed out of sequence without the required indication in the work instructions:
010C890814, 011C890814, 005C890814, 020D900724, 0090901129, 0100901129, f 008D901129. 0070901129. There were also multiple examples o missing or inaccurate dates, and missing signatures and sign-offs.
(2) EDP 06740 - A documentation problem in the procurement of parts was also idtntified in that in a few ihstances requisitions en stores material control request forms were missing signatures in the " Received by" block.
(3) EDP 10610 - The inspect'rs abserved work in progress on WR 002D901031 and noted that procedure NPP 35. CON.22, Revision 22, "New Cable Termination," was being performed.
--The NRC inspectors noted that the first three prerequisite items had not been initialed and dated as completed or marked not applicable, as was the case, until the NRC inspectors brought it to the etter. tion of the PQA inspector assigned to the job.
In addition, the PQA inspector had rot initialed and dated a PQA verification block for work performed seven calendar days before.
The PQA inspector stated that he had performed the verification and had forgotten to initial and date the verification block on the procedure. The NRC inspectors 150 verified that the steps had been completed as docuniented.
The documentation errors had existed for at least seven days and represented additional exampics of inattention to detail and failure to follow procedure.
The insper tors concluded that the documentation errors (missing sign-offs, and sig n. ores, steps performed out of sequence without appropriate indication in the work instructions, incorrect or missing dates) and the failure of field supervisors to ider,tify and correct work activity documentation errors appeared'to be a result of inattention to detail. Discussions with P0A manaccment and a review of monthly Quality Surveillance Reports of WRs from October 1990 through February 1991 indicated that completeness of documentatica had betn improving. Since the beginning of RF 2, hewever, Quality Surteillance Reports had identified an increase in documentation errors associated with hrs.
The personnel responsible f or the documentation errors included licensee (operations, maintenance, and PQA) and contractor employees.
The inspectors were not able to determine the root cause of the " inattention to detail".
However it was obvious to the inspectors that, in some cases, the work activity documentation errors would have hampered the auditabic reconstruction of installation activities especially when a significant period of time had passed since work completion.
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One violation for failure to follow procedures was identified in this area.
5.
ModificationTesting(37700)(72701)
Through observation of field testing activities, document review and personnel interviews, the inspectors verified that the EDPs included appropriate design change acceptance tests (DCAT), that the DCAT was appropriately translated into post modification testing (PMT)
instructions, and that the FMT was perforrued as required.
Field observations of testing were conducted on the following EDPs.
EDP 06740 Reactor Pressure and Level Instrurcentation Rock Replacement.
EDP 10452 Replacement of Main Steara Isolation Yalve Leakage Control System (MSIVLCS) Valves.
EDP 11266 Replacement of Mu1tipoint Recorders in Controi Pccm.
The inspectors rey ewed completed test documentation for DCAT and PMT on selected EDPs in addition to the field observations identified above.
While the tradification testing process appeared to be ad(quate to ensure that the modified equipment would perform its design function, some problems were noted in the use of a PMT procedure NPP-CT1-06, and in translating DCAT into adequate test instructions, a.
EDP 11222 - The post maintenance testing specified in Index Item No. 12 " Testing", rcquired that applicable tests in Enclosure B.
NPP-011-06, Revision 5. " Post Maintenance Testing Guidelines", be performed.
Enclosure 8 recomended several tests following valve disassenbly.
Initial discussions with the licensee's engineering staff indicated fail safe testing, one of the eight recommende:f tests, was not applicable. The en;,ineering staff concluded on May 10, 1991, that
fail safe testing was applicable and that the intent of the fail safe test (spring-only closure) was satisfied by con.pletion of step 4.5.6 of NPP 35.137.002, Revision 24, "MSIV - Assenhly, Disassembly, Repair and Adjustruent", during which the valve was allowed to strole close without a pncumatic assist.
The inspectors also noted that Section 5.1.3.2.a. NPP-CTI 06, implico that all recomended tests, identified in Enclosure B to the procedure, were required tests and that any reduction in the recommended scope of testing requind the approvel of the maintenance discipline general supervisor (MGS). The inspectors'
interview of the Assistant Superintendent, Maintenance on June 13, 1991, determined that the Paintenance Department considered Enclosure B tests to be only recommended tests and a cha' ige to
NPP-CT1-06 may be appropriate. The Assistant Superintendent further stated that it was Maintenance Department policy that the MGS sign and date all post maintenance testing forms (PMTT).
The inspectors
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noted that the PMTF for WR 0050900514 was not signed and dated by the
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MGS.
This represented another exertple of a documentation error and inattention to detail.
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b.
EDP 11200 - During observations of field testing the inspectors found the instrument and control (180) technicians to be knowledgeable regarding the capabilities and operation of the recorders.
Supervisory oversight of recorder testing was evident and at an appropriate level.
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However, some test instruction problems were noted by the inspectors while observing the DCAT on recorders B31RC01 for the Recirculation System Coolant Temperatures and T47k603A for the Division 1 Drywell Cooling System Area Ternperatures.
The inspectors' initial review of the test instructions implementing the DCAT identified a lack of specificity on how to accomplish certain testing requirements. The licensee intended to verify proper prograntning of the recorders rather than test their functional performance in response to
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simulated inputs. A) er this dcficiency was identified by the inspectors, the licensee revised its testing instructions in an ef fort to clarify testing requirements.
However, the inspectors identified the same lack of functional capability testing in the revised instructions as in the original instructions.
For example, the DCAT verified that the recorder progrerwing would provide a record of a thermocouple burnout, but the DCAT did not simulate a thertroccuple burncut input to verify that the recorder would function as designed. The inspectors discussed all noted functiorial capability testing discrepancies with the licensee. On May 9, 1991, the licensee again revised the testing instructions to incorporate functional capabilities testing of the recorders.
EDP 11620 - The inspectors reviewed the DCAT requirements outlined c.
in the EDP and the translation of those requirernents into work instructions. The DCAT required post-installation testing in accordance with NPP-CTI-06. Following turbine maintenance NPP-CT1-06 required (1)leakagetestsinaffectedareas,(2) lobe
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oil temperattu e and pressure measurerrent, (3) vibration measurement, and (4) tpeed verification. The inspectors identified that PHT instructions did not include measurement of lube oil temperature and.
pressure. On May 9, 1991, the licensee instituted changes to each of the low pressure turbine FMT instructions to include this omitted DCAT requirement.
The inspectors also noted that the PMTF was not signed by the MGS which was contrary to maintenance policy.
The missing MGS signature on the PMTF was another exmple of inattention to detail.
The inspectors determined that reference to generic PMT requirunents contained in NPP-CTI-06 to $6tisfy some EDP testing requirerner.ts did result in some confusion to the licensee's staff.
The inspectors also-noted that the problems associated with the development of instructions to adequately test the functional capabilities of the control room recorders appeared to be unique to EDP 11266 and was due in part to
the technical staff's unfamiliarity with the new recorders and to the
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recorders arrival onsite just prior to RF 2.
The inspectors did rot identify any exarnples of modified equipment being returned to service without the required trodification testing being corrpleted.
The licensee's nodi 11 cation testing process was considered adequate.
No violation or deviation was identified in this arca.
6.
RadiologicalControls(37700)(71707)
14cdification installation work was observed in contaminated and radiation areas.
The observations included the movement of tools and equipraent to and from these areas and the interactions of workers with radiation protection (kP) personnel.
The inspectors noted several violations of licensee's radiological controls (RC) requirements.
rhe inspectors were concerned with the nun:ber and the nature of violations observed during the two week onsite inspection period.
e.
lhe modification work associated with EDP 06321 (replacement of
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feedwater he
- level transmitters) was conducted in the second
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floor Turbin+
ilding stearn tunnel. This area was cor sidered a i
contaminatiot taand,assuch,-radiationworkpermit(RWP) 91 1155
was gencrated provide job specific F:P requirernents. RWP 91-1155 requireo the eing of a f ull set of personal anti-containination 1'
RP coveralls and rubber gloves.
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clothing (PCs), including' Accessing and Working in Radiologically
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f!P-RCl-01, Revision 2, Controlled Areas", provided instructions and overall RC requirements.
During observations of work being perforrned for EDP 08321, the inspectors observed a contractor welder in the contaminated area,
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unzip the coverails, reach inside, obtain a sen from the welder's front shirt pocket with the welder's gloved und coming into contact
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with the shirt, use the pen to record information on a weld data sheet, return the pct' to the shirt zip up the coveralls, er a contiriue to perform work.. As stated a' cove, RWP 91-1155 required a full set of PCs, including RP coveralls end rubber gloves for work in the contartinated area, f!P-RCl-ul also provides instruction on the
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wearing of PCs.
Untipsing the coveralls and exposing the worker's
undergarmentt to poss1 ale contamination was a poor RP practict,
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constitutea irnproper wear of PCs, and a violation of RWP 91-1155.
.The fa Gure to follow RWP 91-1155 c,d FIP-RC1-01 is a failure to follow procedures and therefore is an example of a violation of Technical Specification C.8.1 (341/91002-03a (CRP)).
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b.
Additionally, the ins)ectors cbserved several workers rernoving PCs
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and perforrning whole aedy trisks, as required by RWP 91-1105, when exiting the contamination area. On 11ay 5,1991, the inspector s noted that a contrcctor car > enter did not f risk when leaving the contathinated work area for EDP 08321 and proceeded directly to the dressing reora. When the inspectors brought their observation to the attention of a contractor foreman at the job site, the foreman irrmediately retrieved the carpenter and required the car? enter to
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perform a whole body frisk.
Failure to perform a whole >ody frisk at the nearest frisker location irmediately upon exiting a contarnincted
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i area was contrary to Special Instruction 7 of RWP 91-1165 and is another example of a failure to follow procedures and an exannle of a violation of Technical Specification 6.8.1 (3C '91002-03b ( >RP)).
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c.
During the observation of n.cdification installation activities associated with EDP 11300, licensee RC requirements as specified inthe insp of failure to comply with
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kWP 91-1161.
RWP 91-1151, Special Instruction 4 required workers to
" bag all tools and equipment or have RP survey items prior to removal l
from a contaminated area." Contrary to this requirentent, the inspectors observt contractor workers passing tools and equipment such as weld ; 1, a s, levels, and sections of chain rigging hoists,
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through 'iping panetration p 17171 from the first floor of the turbine 3uilaing ste&m tunnel (a contaminated area) to the second tloor of the steam tcnnel (a radiologically clean area) without
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bagging or performing a required RP frisk of thest items.
The
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inspectors idcntified the condition to the involved contractor workers, their SLpervisor, and to the licensee's RP staff. The work
- drea Wbs then secured by the licensee and RP personnel irisked the-l area to ensure no spread of contamination had resulted.
The licensee l
generated a Deviation Event Report, DER 91-0319, to document the
incident. The failure to comply with a RC procedure represents enother example of a violation of Technical S accification 0.8.1 for failuretofollowprocedures(341/91002-03c(OtP)).
d.
During a general walkdown of the reactor building, the inspectors
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observed a hose that was partially inside and outside of a designated contamination area. A length of hose was coiled inside a radioactive material (R/J4) bag located inside the contamination area und the rernaining length of hose was coiled outside crea boundary. The inspectors identified the condition to a RP technician who promptly corrected i
it by placing the hose entirely in the contaminated area and inside
the RN1 bag.
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While resolving the RAM bag concern, the inspectors observed a contractor worker violate a sosted contamination area boundary.
To aerforn maintenance on a snuaber located in the overhead of the
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Reactor building second floor a contractor worker, not in PCs, clinted a ladder affixed to the south side of the drywell and used the drywell exterior for sinport as he transited along a piping line to the location of the snutoer, in doing so, the worker violated a contamination crea boundary posted across the ladder.
The inspectors expressed their concern with the observed worker's actions to the RP technician who was with the inspectors.
The RP technician then left the area to obtain some swipes.
The RP technician determined that neither the contractor nor the area in which the contractor was working were contaminated.
The contractor worker violated a radiological posting which is contrary to section
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5.1.1 of procedure FIP-RCl-01, Revision 2.
The contractor worker's actions represent another example of a violation of Technical Specification 6.8.1 for failurt. to follow procedures (341/91002-03d(DRP)).
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On May 7,1991, the ins,ectors conducted a mecting with licensee
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saanagement to discuss t1e RP observations.
The licensee could not explain the root cause for the observed RP violations other than to attribute root cause to personnel error. 1he licensee believed its Rp
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training for contractors w6s adequate.
Licensee corrective actions included disciplinary action taken against the contractors involved l
and daily disstmination of information by licensee and contractor management to their respective employees enncerning the RP violations.
The inspectors were not able to assess the effectiveness of the licensee action.
One violation with four examples of failure to follow procedures was identified in this area.
7.
{LousekeepingandMaterialCondition(37700)(71707)
The inspectors performed selected system and component walkdowns while reviewing modification installation activities, in general, the material condition of the plant appeared good for a plant in a refuelino outage although there were exceptions. For example, walkdowns of the'drywell and the reactor and turbine buildings occasioully identified work areas where housekeeping was poor. One such area wcs in the vicinity of valves B2100f437and02100T438(EDP10452--MSIVLCSreplar.cment)wheretoolshad been left in the area after work activities had been completed.
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The inspectors also observed work Leing performed on South Seal Oil pump Differential Pressure Regulator, N3000f1250.
The work request for this job (WR 0030891211) required a level III clean zone be established.
This required access control for personnel and naterials.
The innectors noted that only a few of the tools inside the clean zone had seen logged-in and that the clean zone was not roped off properly.
Discussions with maintenance department supervisors determined that a contractor work crew for the main turbine overhaul contract had been in the area performing work on related equipment and disrupted the level 111 clean zone.
The reason for the contractor crew's violation of the clean zone could not be established by the end of the inspection.
The incident
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was not safety significant and therefore no further action was warranted, liowever, the NRC has documented similar housekeeping problems in the ]ast, most recently in NRC Ins)ection Report No. 50-341/91004(DRP).
After t1ese housekeeping issues were arought to the attention of licensee managerent, a notable improvcreent was observed.
No violation or deviation was identified in this area.
8.
Exit Interview The inspectors inet with licensee representatives (denoted in section 1)
on May 10,- 1991, and informally throughout the inspection period and summarized the scope and findings of the inspection activities.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
On June 10, 1991, the General
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i Director, Regulatory Affairs was notified that the inspection period had been extended to June 3, 1991, to include inspection effort that addresseo modification installation and testing concerns identified subsequent to
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the Mhy 10, 1991,-exit meeting.
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17.
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