IR 05000361/1998004

Insp Repts 50-361/98-04 & 50-362/98-04 on 980315-0425. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20248C383
Person / Time
Site:	San Onofre
Issue date:	05/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248C337	List: IR 05000361/1998004 ML20248C333 ML20248C361
References
50-361-98-04, 50-361-98-4, 50-362-98-04, 50-362-98-4, NUDOCS 9806020138
Download: ML20248C383 (28)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION 4

REGION IV

Docket Nos.: 50-361 50-362 License Nos.: NPF-10 i NPF-15  !

Report No.: 50-361/98-04 50-362/98-04 Licensee: Southern California Edison C Facility: San Onofre Nuclear Generating Station, Units '2 and 3 Location: 5000 S. Pacific Coast Hw San Clemente, California Dates: March 15 through April 25,1998 Inspectors: J. A. Sloan, Senior Resident inspector J. G. Kramer, Resident Inspector J. J.- Russell, Resident inspector Accompanying C. L. Lauron, Intern, Office of Nuclear Reactor Regulation Personnel:

Approved By: Dennis F. Kirsch, Chief Branch F Division of Reactor Projects ATTACHMENT: Supplemental Information i

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EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/98-04; 50-362/98-04 This routine announce inspection included aspects of licensee operations, maintenance, engineering, and plant support. This report covers a 6-week period of resident inspectio Ooerations

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Operators were thorough and methodical in preparing for and conducting routine

! evolutions. Close management and supervisory oversight of operational activities was evident. Procedure use and operator communications were excellent (Section O1.1).

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Management oversight and operator skill of the craft were good during conduct of a Unit 3 reactor startup and power ascension. This was demonstrated by clear communications, appropriate annunciator response and good control of steam generator (SG) water levels. Additionally, a nuclear plant equipment operator conducted his rounds in a professional and thorough manner (Sections 01.2, O1.3, and 04.1).

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The licensee did not implement the abnormal operating instruction fcr severe weather, to place Units 2 and 3 in a design basis configuration for a tornado, after sighting funnel clouds and receiving a severe weather warning. An unresolved item was opened to review the information contained in a letter the licensee submitted to address the inspectors' concems about this situation and to further assess the process the licensee used to control the response to the weather conditions. Additionally, the licensee demonstrated weaknesses in screening a proposed change to the abnormal operating procedure for a 10 CFR 50.59 evaluation, and in operator recognition of the difference between control room envelope doors and missile doors (Section 01.4).

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Operations during two off-normal conditions were good. Operators' rapid response to an inadvertent closure of a Unit 3 main feed water regulating valve, with the unit at 100 percent power, prevented the unit tripping on low SG level. Operator response to a loss of Unit 2 automatic pressurizer pressure control, due to a maintenance error, resulted in a minimal pressurizer pressure transient (Sections 01.5 and M1.4).

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A control room supervisor (CRS) demonstrated inadequate knowledge of the required valve configuration for the current plant status. Positions of the containment isolation valves for the waste gas decay tank system were incorrectly positioned after restoration from a leak rate test, resulting in the venting of the waste gas decay tank into containment. This was a noncited violation of Unit 3 Technical Specification (TS) 5.5.1.1.a. Unit 3 was in a midcycle outage at the time, and the worst-case exposure increase to individual personnel in containment was 5 mrem skin dose, which was

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minimal. No unmonitored release to the environment occurred (Section 04.2).

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A violation of Unit 3 TS 5.5.1.1.a was identified as a result of two reactor operators faihng l t

to follow procedure steps in the sequence as written during reactor coolant system valve l testing 5 unit was in Mode 4, and this failure resulted in a slight depressurization of I

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2-two safety injection tanks (SITS), which were are not required by TS for Mode 4 (Section O4.3)

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During a limitcd review of Operations audits, and auditor performance during nuclear plant equipment operator rounds, Nuclear Oversight was found to have been effective in assessing Operations' performance and corrective actions (Section 07.1).

Maintenance

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The inspectors identified a poor practice in measuring ASME Code production welding heat input. The licensee did not measure the heat input variables (voltage, current, and travel speed) during welding of 14 new pressurizer heaters, and so did not validate, during production welding, the assumptions made during qualification welding. This was important to minimize the potential for sensitization of stainless steel during welding. In addition, a previously unrecognized error made by a licensee Quality Control inspector recording weld heat input values during other ASME Code welding done about 9 months earlier was identified by the iicensee (Section M1.3).

A violation of TS 5.5.1.1.a was identified as the result of instrument and Control technicians implementing an incorrect section o' ,)rocedure while troubleshooting a pressurizer spray valve controller. This resultet a loss of automatic pressure control and a small pressure increase while Unit 2 was at full power. The technicians demonstrated inadequate attention to detail (Section M1.4).

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Unit 3 SG midcycle outage inspections were good. The egg crate inspections were conducted in a methodical and well-documented manner, producing high quality result The vendor used good communications and proper verification techniques while performing the Unit 3 SG tube plugging. Management of the inspection process was outstanding (Sections M1.5 and E2.1).

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A violation of 10 CFR 50.59 was identified by the inspectors as a result of the failure of the licensee to perform a written safety evaluation for a plant modification that resulted from leaving 60 feet of cord in a plugged SG tube. A Site Technical Services engineer failed to recognize that leaving the cord constituted a plant modification. The licensee's planned corrective actions were extensive (Section E1.1).

Plant Sucoort

A violation of TS 5.5.1.1.a was ide'ntified by the inspectors as a result of Maintenance l workers demonstrating poor radiological work practices in one instance by passing tools from a high contamination area to a contamination area without having a survey l

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performed, contrary to the licensee's high contamination area control procedure. After prompting by the inspectors the survey was performed, and the contamination on tools was found to be below the limits for a high contamination area. The licensee's corrective actions were prompt and comprehensive (Section R4.1).

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Report Details Summary of Plant Status Unit 2 operated at essentially 100 percent power during this inspection period, except for a reduction to 80 percent power on April 19,1998, for a heat treatment of the circulatory water syste Unit 3 began this inspection period in Mode 5, in the ninth day of a midcycle outage. On March 25,1998, the reactor was made critical. On March 27,1998, the unit entered Mode 1 and was synchronized to the grid. The unit operated at essentially 100 percent power from March 29 through the end of this inspection perio . Operations 01 Conduct of Operations 01.1 General Comments (71707)

The inspectors observed routine and nonroutine operational activities throughout this inspection period. Some of the activities observed included:

- Routine shift turnovers (multiple observations)

- Reactor coolant system fill from midloop conditions (Unit 3)

- Nuclear plant equipment operator rounds (Units 2 and 3)

Operators were thorough and methodical in preparing for and conducting evolution Close management and supervisory oversight of operational activities was eviden Procedure use and operator communications were excellent. Specific comments on activities observed are discussed belo .2 Reactor Startuo - Unit 3 Insoection Scoce (71707)

The inspectors monitored the licensee's performance during reactor startup following a midcycle outage, reviewed Procedure SO23-3-1.1, " Reactor Startup," Revision 17, and verified reactor engineering's calculations of reactivity change between control element assembly withdraw hold point I Observations and Findinos

On March 25,1998, the inspectors observed the operators perform a reactor startup.

! The reactor startup prejob briefing included the guidance of Procedure SO23-3-1.1, Attachment 2, Step 3.1. The control room communications were clear and included proper repeat backs. Operators appropriately addressed annunciation received during the startup. The licensee used an additional senior reactor operator to provide dedicated i

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, reactivity management oversight. The shift superintendent and Operations management l

provided good oversight and guidance.

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A reactor engineer properly calculated the reactivity added during each control element assembly withdrawal. A reactor operator and reactor engineer independently performed and compared their inverse count rate ratio (1/M) plots to predict criticality, Conclusions Operator performance during the Unit 3 reactor startup was generally excellent. Shift supervision made conservative decisions and provided effective oversight throughout the startu .3 Power Ascension - Unit 3 Insoection Scoce (71707)

On March 26,1998, the inspectors observed Unit 3 control room operators conduct a power ascension from approximately 2 percent to 16 porcent power. This included transferring SG feedwater from an auxiliary feedwater pump to a main feedwater pump, removing the main turbine from the turning gear and the acceleration to synchronous spee Observations and Findinas The control room operators consistently maintained SG water levels within an acceptable range demonstrating good skill of the craft. Operations management was present in the control room, providing active oversight. The shift superintendent was also actively involved. Communications were generally complete. Consequently, the inspectors found that the evolution was conducted in a professional manne Two instances were identified by the inspectors and the licensee during which operator performance was not consistent with procedural recommendations. The licensee planned appropriate procedural changes for these issues:

- Procedure SO23-9-6, "Feedwater Control System Operation," Revision 9, Attachment 9, Step 1.2.4, recommended maintaining differential pressure across the feedwater control valves at 50 - 100 psid, and Step 2.1.2 recommended maintaining SG pressure at 930 - 970 psia. Operators actually maintained feedwater regulator valve differential pressure between 30 - 35 psid and SG pressures at 975 - 979 psia. The actual values were satisfactory and SG level '

was well controlle Procedure SO23-10-1, " Turbine Startup and Normal Operation," Temporary Change Notice 11-1, Attachment 2, directed the operators, upon startup of the main turbine, to trip the turbine if the governor valves failed to open before the stop valves. During actual turbine startup, Governor Valve 2200C failed to open.

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-3-The operators did not trip the turbine. The inspectors questioned this, and the Units 2 and 3 Operations superintendent explained that Valve 2200C had failed to open because the control oil was cold and provided slow respons Consequently, the demand position was significantly different than actual position, which caused the valve to automatically shut. The Operations superintendent indicated that the intent of the procedural step was to ensure that the control circuitry was functioning properl Conclusions Unit 3 operators conducted a power ascension from approximately 2 percent to 16 percent power in a professional manner. Management oversight was good. Two minor instances during which operator performance was not consistent with procedural recommendations were identifie O1.4 Licensee Resoonse to Funnel Cloud Siahtinas - Units 2 and 3 Insoection Scooe (71707. 71750)

The inspectors observed control room operators respond to the observation of funnel clouds over the ocean. The inspectors reviewed Abnormal Operating Instruction SO23-13-3, " Natural Disaster / Severe Weather," Temporary Change Notice 4-2; Attachment 4, " Severe Weather Preparations"; and Attachment 8, " Severe Weather Barrier Inspections." The inspectors walked down portions of Units 2 and 3, and interviewed Operations and Emergency Preparedness personne Observations and Findinos On March 31,1998, the Operations superintendent observed funnel clouds over the ocean south and west of the plant. As a consequence, at 11:54 a.m., control room operators entered Procedure SO23-13-3. The shift superintendent then initiated a procedure modification permit (PMP) to Procedure SO23-13-3 to allow all steps of the procedure to be optional, i.e., performed at the discretion of the shift superintenden While the PMP was being processed, tne shift superintendent directed thet all steps in the procedure only be performed with his permission. The shift superintendent stated, when questioned by the inspectors, that because a warning of severe weather had not been received, the control room missile doors would not be closed. The Updated Final Safety Analysis Report (UFSAR) provides that the control room missile doors would be closed if a tornado warning was in effect, the control room essential air cleanup system (CREACUS) would be placed in the isolation mode, and the condensate storage tanks

, would be partially isolated in order to place the units in a design configuration for a tornad At 12:20 p.m., the Emergency Preparedness manager informed the control room that the National Weather Service had issued a special marine warning until 1 p.m., due to funnel clouds sighted in the area. At 12:45 p.m., while the inspectors were still observing the implementation of the procedure, the Grid Contrnt Center notified the control room of a

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-4-National Weather Service special marine waming due to funnel clouds in the area. The inspectors asked the shift superintendent if the missile doors would be closed, I CREACUS isolated, and the condensate storage tanks partially isolated; the shift superintendent indicated that these actions would not be taken because the weather conditions did not warrant the closure of these doors. The inspectors found that the ( licensee made a conscious decision not to implement steps directed by the procedure, i including the closure of control room lobby missile doors, isolation of the CREACUS, and .

l partialisolation of the condensate storage tanks; however, the operators did not think

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that they were obligated to perform the procedural steps because they did not think that I the entry conditions for the procedure had been met, and that all actions they took were

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l l The entry conditions for entering Procedure SO23-13-3, " Natural Disaster / Severe Weather," Temporary Change Notice 4-2, states "This event may be caused by . .

Notification by the Generation Operations Center or Grid Control Center of . . . Tornado l (or waterspout) waming." The inspectors found that the licensee acted appropriately by initiating Procedure SO23-13-3 based on local observation of impending severe weather.

l The inspectors also found that the entry condition was met by the subsequent notification of a National Weather Service Special Marine Warning from the Grid Control Cente The observation of funnel clouds over the ocean by plant personnel and the notification

by the Grid Control Center were appropriate reasons to implement Procedure l SO23-13-3. However, the intent of Procedure SO23-13-13, to place Units 2 and 3 in a design basis configuration for tornadoes, was not performed.

( The inspectors determined that the operators did not implement Procedure SO23-13-3 after meeting an entry condition. Steps in the procedure were marked "not applicable (N/A)," indicating that these steps were not performed. These steps included closure of the contrni room lobby missile doors, isolation of CREACUS, and partialisolation of the condensate storage tanks. In order to address the issues described above, the licensee sent a letter to the NRC, dated April 28,1998. These issues remain unresolved pending the inspectors' assessment of the information in this letter and the process the licensee used to control the response actions to the weather conditions (URI 361; 362/98004-01).

The inspectors reviewed the proposed PMP to Procedure SO23-13-3. The PMP modified Step 2 of the procedure to allow the shift superintendent to determine if specific steps were not required to be performed. The 10 CFR 50.59 screening criteria in the l PMP states, "Does this new procedure / procedure change: Alter system / component performance or the design configuration of a system important to safety?" The licensee i

indicated that this change did not meet this criteria by checking the space labeled "No."

l Several steps of the procedure were not performed under the direction of the shift

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superintendent, including the closure of the control room lobby missile doors. These doors are a design basis requirement in the UFSAR, Section 3.5.3, " Barrier Design Procedures," to prevent missile perforation so as not to impair the intended safety function of the opening. Given a funnel cloud sighting, the nonclosure of the control room lobby doors was an alteration of the design configuration of a system important to safety and met the criteria for an unreviewed safety question evaluation. However, since the PMP was not completed and issued for use prior to the licensee exiting Procedure

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-5-SO23-13-3, and since the PMP was for one time use only, no change to a procedure described in the UFSAR was actually made. Also, the PMP did not preclude closing the missile doors, but made the action optional. However, the licensee's performance of the 10 CFR 50.59 screening was weak in that a question was incorrectly answered, which resulted in an improper conclusion regarding the need to perform a more complete evaluation to determine whether an Unreviewed Safety Question existe Procedure SO23-13-3, " Natural Disaster / Severe Weather," Attachment 8, Step 2.1.3, directed operators to " Perform a Missile Barrier inspection of the following buildings, ensuring doors and plugs are closed or installed . . . Auxiliary Building (e.g., Control Room Lobby Missile Deors . . )." An operator initialed the step indicating that it had been performed. However, the inspectors observed that the control room lobby missile doors were not closed while this procedure was in effect. The licensee determined that the operator who had initiated the step was not cognizant that the doors to the control room, through which he entered and observed close behind him, were not the missile doors. The operator did not verify the door numbers against those stated in the procedure before he initialed the step as complete. The operator was not familiar with the four-door arrangement of CREACUS and missile doors. The inspectors found that this lack of knowledge regarding the difference between CREACUS and missile doors was a weakness in operator training. In response, the licensee initiated a revision to Procedure SO23-13-3 to include a description of the door arrangement, and held a requalification training session for the operator Emergency event classification aspects of the tornado sighting are discussed in Section P3.1 of this repor Conclusions The licensee did not implement the abnormal operating instruction for severe weather, to place Units 2 and 3 in a design basis configuration for a tornado, after sighting funnel clouds and receiving a severe weather warning. An unresolved item was opened to review the information contained in a letter the licensee submitted to address the l

inspectors' concerns about this situation and to further assess the process the licensee used to control the response to the weather conditions. Additionally, the licensee demonstrated we.sknesses in screening a proposed change to the abnormal operating procedure for a 10 CFR 50.59 evaluation, and in operator recognition of the difference between control room envelope doors and missile door I O1.5 Main Feedwater Reculatino Valve Closure - Unit 3 l

l Insoection Scoce (71707)

The inspectors reviewed the circumstances surrounding the closure of the SG 3E088 main feedwater regulating valve and assessed the response by Operatioris and reviewed Procedure SO23-3-3.28, " Remote Shutdown Panel Instrumentation Monthly Checks,"

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-6- Observations and Findinos On April 15,1998, during the performance of Procedure SO23-3-3.28, Attachment 1, Step 2.2.14, operators had placed the master controller for the SG 3E088 feedwater regulating valve in manual to prevent SG level transients; however, when Switch HS1106 was placed in the local position, the main feedwater regulating valve closed. Operators observed a rapid decrease in the SG water level and identified that the main feedwater regulating valve was closed. Operators directed the placement of Switch HS1106 to the control room position, and the regulating valve opened. The operators recovered SG level using manual feedwater contro On April 22,1998, the licensee performed troubleshooting and diagnostics of the syste The results showed no anomalies in the performance of the feedwater control syste The licensee 's evaluation of the problem was still in progress at the end of this inspection perio Conclusions Operators responded aggressively to a SG level transient and prevented a reactor trip on SG low leve Operations Procedures and Documentation O3.1 Excore Startuo Channel Limitino Conditions for Ooeration (LCO)- Units 2 and 3 Insoection Scoce (71707)

The inspectors observed inconsistent LCO entries for the removal of excore nuclear instrumentation startup channels from service. The inspectors discussed the observation with Operations management. The inspectors reviewed Procedure SO23-3-2.15,

"Excore Instrumentation Operations," Revision 11 and Procedure SO23-3-2.15, 1 Temporary Change Notice 11-1 j Observations and Findinos l

On February 26,1998, the inspectors observed that the operators were entering l inconsistent LCO actions when removing an excore startup channel fror.1 service. The inspectors discussed the inconsistencies with Operations supervision. Operations supervision performed a review of the LCO action statements, and on March 11,1998, i initiated an action request to correct the inconsistencies. The licensee revised the standard limiting condition for operation action requirement (LCOAR) sheet for the excore startup channels and planned to revise Procedure SO23-3-2.15 to clarify the LCO actions entered when removing a channel from servic On April 15,1998, the inspectors observed that the shift technical advisor's morning report included an incorrect LCO action statement for removal of the Unit 2 excore startup Channel B from service. The inspectors informed the shift technical advisor that

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-7-the LCO action entered was incorrect. The shift technical advisor, with concurrence from the CRS, believed the correct action statement had been entered. Independently, Operations management called the control room to verify that the correct LCO action was entered, and the control room staff then recognized the error and entered the correct LCO action. The licensee identified that the operators entering the information for the removal of the startup channelincorrectly deleted the applicable LCO action from the revised LCOAR shee On April 15,1998, the licensee again revised the standard LCOAR sheet to further clarify the LCO actions entered when removing an excore startup channel from service. In addition, the Operations superintendent sent an electronic mail message to all control room supervisory personnel to explain the LCO actions entered when removing excore startup channels from service for the various modes of operation. The licensee has a total of seven licensee controlled specifications that address the excore startup channel On April 17,1998, the licensee revised Procedure SO23-3-2.15 to clarify the actions for the removal of the excore startup channels from service, completing the corrective action Conclusions Licensed operators displayed a weakness in knowledge of correct TS LCO actions to enter when an excore startup channel was removed from service. Licensee corrective actions to correct the knowledge weakness were appropriat Operator Knowledge and Performance 04.1 Observation of Ooerations Rounds Outside of Control Room - Ureits 2 and 3 (71707)

On April 9,1998, the inspectors accompanied a nuclear plant equipment operator during portions of his rounds. The rounds included Units 2 and 3 salt water cooling pump rooms and the Unit 3 secondary plant. The operator was knowledgeable; verified the status of equipment parameters important to proper operation, in excess of those required by his hand-held computer; and was attentive to equipment deficiencies within the scope of his rounds. Consequently, the inspectors found that the operator conducted <

his rounds in a professional and thorough manne O4.2 Inadvertent Ventina of Waste Gas Denav Tank (WGDT) into Containment - Unit 3 Insoection Scone (71707. 71750)

l The inspectors reviewed the events surrounding the inadvertent venting of a WGDT into l containment. The inspectors reviewed Procedure SO123-0-2," Control Room l Supervisor's Authority, Responsibilities, and Duties," Revision 3; Procedure SO23-5-1.8,

" Shutdown Operations (Modes 5 and 6)," Revision 8; and Procedure SO23-3-3.51.5, l l

" Containment Penetration Leak Rate Testing Containment Air Sample Penetrations,"

Revision 3. The inspectors discussed the event with Operations and Health Physics supervisio ,

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-8- Observations and Findinos l On March 13,1998, while Unit 3 was operating in Mode 5, the Operations test group

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performed a localleak rate test on the containment waste gas vent header valves, Penetration 47. As part of the restoration of the localleak rate test, Procedure SO23-3-3.51.5 directed that Valves 3HV7258 and 3HV7259 (both containment waste gas vent header isolation valves) be positioned as directed by a senior reactor operator. The CRS directed the operator to open Valves 3HV7258 and 3HV7259 because that was the normal valve position when the unit was in Mode The CRS did not realize that this provided a flow path from the inservice WGDT into l

containment and was contradictory to Procedure SO23-5- The crew observed radiation levels in containment increasing on a recorder. The crew attributed this to pressurizer heater work, because two days earlier they had observ6d nearly identical indications, which were thoroughly investigated at the time, and were determined to be associated with the removal of pressurizer heaters. The inspectors concluded that the operators missed an early opportunity to identify the venting WGD The valve misalignment was identified and corrected approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the valve mispositioning, when a radwaste operator on the next shift questioned a lower than expected pressure on the inservice WGDT. The operator expected the WGDT to be approximately 295 psig and found the pressure to be 190 psi '

The inspectors questioned Health Physics supervision about the radiological ,

consequences of the event. The licensee performed a gas sample near the vent path !

l inside containment shortly after identifying that the WGDT was leaking. The sample indicated that the gaseous activity was approximately 0.19 DAC. The licensee i determined the activity was from Xe-133, a noble gas, and calculated that the exposure l rate to be approximately 0.7 mrem /hr skin dose. The skin dose was only to exposed j l

skin. The licensee calculated the cumulative dose during the 8-hour release period to be l approximately 1.0 person-rem. The inspectors calculated that worst-case exposure to an individual during the event was approximately 5 mrem skin dose. The inspectors concluded that the individual exposure was significantly less than the 10 CFR 20.1201 limit of 50 rems / year to the ski The inspectors questioned the licensee about the monitoring of the release. The l licensee indicated that a monitored containment vent was in progress during the release and that the levels remained within the limits of the release permit. The inspectors concluded that an unmonitored release did not occur.

l l The licensee initiated an action request to evaluate corrective actions as a result of the l event and issued a preshift briefing to inform the operators of the event and provide a learning opportunity. The licensee planned to revise Procedure SO23-5-1.8 to provide more control of Valves 3HV7258 and 3HV7259, such as placing caution tags on the switches and planned to revise Procedure SO23-3-3.51.5 to provide rw e positive control over Valves 3HV7258 and 3HV7259. The inspectors concluded that the licensee's corrective actions were acceptable.

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9-Unit 3 TS 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2. Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, recommends procedures for authorities and responsibilities for safe operation and shutdown. Procedure SO123-0-2 delineates the authority, responsibilities, and duties of the CRS. Step 6.2.1.3, states, in part, that the CRS will direct and coordinate the activities of the operating crew with approved procedures. The failure of the CRS to direct the activities of the operating crew (closure of Valves 3HV7258 and 3HV7259)in accordance with Procedure SO23-5-1.8 was a violation of TS. This violation was not considered minor because of its actual impact on safety, in that it resulted in numerous people receiving an unnecessary radiation dose. Had the source term been larger, or had the violation not been corrected, the consequences would have been greater. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 362/98004-02).

] Conclusions A noncited violation of TS 5.5.1.1.a was identified as a result of the failure of the CRS to coordinate the activities of the operating crew with approved plant procedures, which resulted in the venting of a WGDT inside Unit 3 containment. A questioning attitude by a radwaste operator regarding an unexplained decrease in the WGDT pressure resulted in the subsequent identification of the ventin O4.3 Inadvertent Draining of SITS - Unit 3 Insoection Scooe (71707)

The inspectors reviewed the circumstances surrounding the inadvertent draining of two SITS. The inspectors reviewed Procedures SO23-3-3.31.9, *RCS Pressure isolation Valve Testing Hydro Pump Method Cold Shutdown and Refueling Interval," Revision 4, and SO123-0-20, "Use of Procedures," Revision 6. In addition, the inspectors discussed the event with Operations personnel and Operations managemen Observations and Findings On March 24,1998, Operations personnel performed Procedure SO23-3-3.31.9, i Section 2.9, as part of check valve testing. A nonlicensed test group operator was the test group director, and control board valve manipulations were being performed by l

reactor operators. Procedure Step 2.9.6 directed the operators to open Valve 3HV9333, l

"HPSI Header No.1 to Loop 2B isolation Valve,"in preparation to repressurize the drain header. The next four numbered steps opened the SIT drain valves. The assistant control operator who opened Valve 3HV9333 asked the control operator if it mattered in what order the four SIT drain valves were opened, because SITS T007 and T009 drain valve switches were near the switch for Valve 3HV9333. The control operator authorized opening the drain valves out of sequence. As a result, SITS T007 and T009 depressurized and drained slightly to repressurize the drain header. Had the procedure

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-10-been followed, the header would have been pressurized from a high pressure safety injection pump, and no SIT drainage would have occurre The inspectors discussed the SIT draining vath the CRS. The CRS indicated that the control operator and assistant control operator did not discuss with him, or inform him of, the change of the order of the procedure steps, and, therefore, he was unaware that the reactor operators had changed the order of steps. The inspectors discussed the reactor operator performance with the Operations superintendent, and indicated the concem that reactor operators were not following procedure and not informing shift supervision when i changing the order of steps. The Operations superintendent shared ;he inspectors'

concer The inspectors discussed the performance of procedure steps out of sequence with the reactor operators involved in the event. The operators acknowledged that they were aware of the requirement to perform procedure steps in sequence, but thought that, in this case, the order did not make a difference, and therefore, did not discuss the changing of the sequence of the steps with the CRS. The operators indicated that one reason they performed the steps out of sequence was due to the proximity of the valve I hand switches to the previous valve manipulated. The operators stated that they immediately realized their error upon receiving SIT annunciatio The inspectors reviewed the safety significance of performing the procedure steps out of sequence. The unit was in Mode 4 and the SITS were not required to be operable until i

Mode 3 with pressurizer pressure 2 715 psia. The licensee determined that the SITS depressurized approximately 5 psi and level dropped 0.1 percent. The inspectors concluded that the safety consequence of the event was negligible. However, the inspectors concluded that the regulatory significance of the procedure noncompliance in this instance was not minor, because the potentialimpact of consciously deviating from approved procedures without appropriate review was a serious regulatory conce Unit 3 TS 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, l Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, )

recommends procedures for procedure adherence. Procedure SO123-0-20 provides l instructions for the use and adherence to procedures. Step 6.2.12, states, in part, that procedure steps shall be followed in the exact sequence written unless otherwise allowed. Procedure SO23-3-3.31.9, in part, included four steps, Steps 2.9.7 through )

2.9.10, that were required to be performed in the exact sequence as written. On March 24,1998, two reactor operators failed to perform Procedure SO23-3-3.31.9, Steps 2.9.7 through 2.9.10, in the exact sequence as written, and performed Steps 2. and 2.9.10 prior to Step 2.9.7. The failure of operators to perform the procedure steps in the exact sequence as written was a violation of TS (Violation 362/98004-03).

The licensee initiated an action request to evaluate the event. Operations management counseled the operators involved in the event. In addition, Operations management conducted a preshift briefing to inform all operating crews of the event and to use the event as a learning opportunit l m ___ . _ . _ _ . . _ , , _ _ _ _ _ _ ._ _ _ _ . _ . _ _ _ _ . __ _ _ _ _ _ _ _ . . _ _ _ ___

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-11- l In addition, the inspectors determined that the violation was identified through a i

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self-disclosing event with a clear root cause and, therefore, did not warrant enforcement discretio I 1 Conclusions j

A violation of Unit 3 TS 5.5.1.1.a was identified as a result of two reactor operators consciously failing to follow procedure steps in the sequence as written during reactor coolant system valve testing. The unit was in Mode 4, and this failure resulted in a slight depressurization of two SITS, which were are not required by TS for Mode Quality Assurance in Operations 07.1 Review of Licensee Ooerations Assessments - Units 2 and 3 Insoection Scoce (71707)

The inspectors reviewed the following Operations audits and corrective action documents: SCES-711-97, Action Request 971100241, SOS-052-97, LOP 980201232, '

and the Fourth Quarter 1997 Station Performance Report. The inspectors reviewed Procedure SO123-Xll-2.19, * Qualification and Certification of Auditing Personnel,"

Revision 3, and ANSI N45.2.23,1978," Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants." Observations and Findinas i I

The inspectors reviewed the audits and found that they monitored significant Operations activities. The identification of deficiencies and corrective actions was evident. The audits included a verification of the effectiveness of corrective actions as appropriate. A review of the qualifications of the auditors indicated that the auditors met the qualifications of Procedure SO123-Xil-2.19. The inspectors found the performance of an auditor monitoring a nuclear plant equipment operator during rounds to be acceptabl Conclusions During a limited review of Operations audits and auditor performance during nuclear plant equipment operator rounds, Nuclear Oversight was found to have been effective in assessing Operations' performance and corrective action Miscellaneous Operations issues (92712)

O8.1 (Closed) Licensee Event Reoort (LER) 361/97014-00: licensed operators did not have corrective lenses for use with respirator This LER addressed inadequate procedures to ensure that licensed operators requiring corrective lenses could continue to satisfy that condition while wearing self-contained breathing apparatus. NRC Inspection Report 50-361;362/97-20 previously addressed i

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-12-this NRC-identified issue, which resulted in a Severity Level IV violation. The corrective actions for this violation will be assessed as a follow-up to the violation. This LER is close . Maintenance M1 Conduct of Maintenance M1.1 General Comments Insoection Scooe (62707)

The inspectors observed all or portions of the following work activities:

- Emergency Diesel Generator 2G003 starting air leak identification (Unit 2)

- Metal disintegration machining of a pressurizer heater (Unit 3)

- Install mechanical nozzle seal assembly on pressurizer temperature Detector 3TE0101 (Unit 3)

- Clean and inspect Motor Control Center BQ (Units 2 and 3) Observations and Findinos The inspectors found the work performed under these activities to be thorough. All work observed was performed with the work package present and in active use. Technicians were knowledgeable and professional. The inspectors frequently observed supervisors and system engineers monitoring job progress, and quality control personnel were present whenever required by procedure. When applicable, appropriate radiation controls were in plac In addition, see the specific discussions of maintenance observed under Sections M1.3, M1.4, and M1.5, belo M1.2 General Comments on Surveillance Activities Insoection Scoce (61726) 1 l

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The inspectors obs?rved all or portions of the following surveillance activities: l

- Emergency Diesel Generator 2G002 monthly slow start (Unit 2)

- Emergency Diesel Generator 2G003 monthly slow start (Unit 2)

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- Channel B qualified safety parameters display system 18-month surveillance

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Channel B plant protection system functional test (Unit 2)

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Engineered safety features subgroup Relay K304A semi-annual test (Unit 3)

• Verification of reactor coolant system heat up rate (Unit 3)

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Plant protection system logic matrix functional test (Unit 3)

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Containment spray Pump 3P012 inservice test (Unit 3) Observations and Findinas The inspectors found all surveillance performed under these activities to be thoroug All surveillance observed were performed with the work package present and in active use. Technicians were knowledgeable and professional. The inspectors frequently observed supervisors and system engineers monitoring job progress, and quality control personnel were present whenever required by procedure. When applicable, appropriate radiation controls were in plac M1.3 Control of Weld Heat inout - Unit 3 Insoection Scooe (62707)

On March 12,1998, the inspectors visually inspected storage ovens for weld filler material and reviewed Maintenance Procedure SO123-1-11.1, " Welding Filler Material Control," Temporary Change Notice 0- On March 17,1998, the inspectors observed welding of four Unit 3 pressurizer replacement heaters onto the bottom of the pressurizer. The inspectors reviewed Weld j Records 3-98-037,038,039, 040,042, 043,044,045,098,099,101,102,106,111,112, I and 115. These records reflect the welding of 14 replacement heaters (including the four observed) and a cap on a heater location to be abandoned. All of the replacement heater welds were conducted using Weld Procedure Specification 43-8-GT-1, Revision 0, which referenced supporting Procedure Qualification Records 25 and 34. The j inspectors reviewed Weld Procedure Specification 43-GT-1, Revision 0, and Procedure '

Qualification Records 25 and 34. The inspectors also reviewed portions of the ASME Code, QW-256,1983 edition, and interviewed welding supervisory personnel, engineers, and the welder Observations and Findinas I During the inspection of the weld filler material storage ovens, the inspectors observed l that the temperature logs for Holding Oven 1-H-7 contained a recorded reading of 295*F for the day shift, March 10,1998. The temperature specification listed in Procedure

! SO123-1-11.1 was 300 - 400*F. The ovens have a permanent thermometer mounted on the door and were verified by pyrometer three times daily. The 295*F reading was by

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-14-pyrometer. In response, the licensee determined that the low reading was due to operator error in taking the reading (the installed thermometer read 340*F). The licensee generated Action Request 980301031, counseled the attendant taking the reading to alert supervision when an out-of-specification reading was recorded, and revised the log sheet to clearly indicate specifications. The inspectors found the licensee's response to the concern was goo The pressurizer heater welding was a fillet weld of a P43 (inconel Alloy 690) metal to a l P8 (stainless steel) metal using an inconel Filler Metal 52 and gas tungsten arc weldin {

Downstream of the weld power supply the weld machine was set at 65 amps. The weld l power supply was nonadjustable for voltage and current. The actual voltage and current '

applied to a weld is a function of arc length. The heat input into a weld is a function of voltage, current, and travel speed. As documented in NRC Inspection Report 50-361; 362/97-08, actual current may vary from the current setting of 65 amp For each of the 14 weld locations performed to install new pressurizer heaters, approximately two bead layers were used per weld location. Each layer consisted of one bead of fdler material. Approximately four starts and stops of arc current were used for j each layer. The welding was performed by two different welders. Consequently, '

approximately 112 separate starts and stops of weld bead layers were performed. Each weld start and stop provided the potential for variance in arc length and travel speed, as the welder struck a new arc and changed his body position as needed. Voltage, current and travel speed were not directly measured for any of these weld location NRC Inspection Report 50-361; 362/97-08 cited a violation for failing to measure or monitor specified limits for heat input variables, contrary to the requirements of the weld  !

procedure specification. Of the many starts and stops of weld beads discussed above, l none of the production welds had the heat input variables measured directly. Because of l the importance of minimizing the potential for sensitization of stainless steel during welding, the inspectors determined that failing to measure the heat input to production welds was a poor practice. However, this was not a violation, because no evidence existed that the heat input limits had been exceeded and the licensee's program did not require direct monitoring of heat input variables. The corrective actions for the violation cited in NRC Inspection Report 50-361; 362/97-08 had not been reviewed by the NRC inspectors as of the end of this inspection perio The corrective actions for the previous violation included interim monitoring of production welds and training of welders performing test welds during which heat input was directly measured. The inspectors determined that these corrective actions were completed as of the end of this inspection period. The inspectors found that the training discussed was beneficial. However, confirmation of actual production weld values would have ensured that differences between the production weld conditions and the test weld conditions did not provide for unacceptable heat inputs during the production welds.

! The inspectors found that no portions of the ASME Code were violated. The post-weld I

examination included a final visual and liquid dye penetrant examination, which was satisfactory for all heaters replaced.

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-15-The licensee, in response to the inspectors' questions conceming production weld heat input monitoring, reviewed Nuclear Oversight Division monitoring of actual production values during the Units 2 and 3 Cycle 9 refueling outages. Licensee personnelidentified that on July 7,1997, a Quality Controlinspector recorded an observed heat input greater than that allowed by the weld procedure specification in effect. This was for a nozzle weld on reactor coolant system Pressure Instrument 3PDT-0789-1. This greater-than-allowable recorded heat input was not noted by the Quality Control inspector, nor the supervisor during the review of the observation. The inspectors interviewed the Quality Control inspector and found that the value for travel speed had been recorded in erro The actual heat input for the weld had not been exceeded, but the Quality Control inspector had made an error in recording travel speed, and had been mistaken about the heat input limits. The inspectors also found this indicative of a poor practice in monitoring actual production weld heat inpu Conclusions The inspectors identified a poor practice in measuring ASME Code production welding heat input. The licensee did not measure the heat input variables (voltage, current, and travel speed) during welding of 14 new pressurizer heaters, and so did not validate the assumptions made during qualification welding. This was important to minimize the potential for sensitization of stainless steel during welding. In addition, a previously unrecognized error made by a licensee Quality Control inspector recording weld heat input values during other ASME Code welding done about 9 months earlier was identified by the license M1.4 Loss of Pressurizer Prensure Control- Unit 2 Insoection Scoce (62707)

The inspectors reviewed the circumstances surrounding a momentary loss of Unit 2 pressurizer pressure control and reviewed Procedure SO123-ll-9.3, "Foxboro Spec 200 Micro Systems Verification and Configuration," Temporary Change Notice 3-1. The unit was at fu!' power at the time of the even Observations and Findinos On March 5,1998, licensee Instrument and Control technicians were attempting to access data from Unit 2 pressurizer Spray Valve A Controller 2 HIC 0100A. The maintenance was authorized by Operations using Work Authorization Request 2-9800446 and was being performed in the main control room with the consent of the control room operators. During the maintenance activity, Controllers 2 HIC 0100A and 2PIC0100 failed, causing a loss of automatic pressurizer control. Operators took l manual control of pressurizer heaters and spray, after pressurizer pressure rose l

from 2253 psia to 2258 psia. Operator response was good. Pressurizer pressure remained within operational and TS limits.

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-16-Under Work Authorization Request 2-9800446, the technicians were troubleshooting a l valve position indication problem. Maintenance Order 98021495000 directed an initial i

investigation of the problem, and the technicians were attempting to upload data from the controller to a blank computer disc. The technicians initiated Procedure SO123-ll-9.3, Section 6.5, " Downloading a CCC Database From a Disk to a Controller," which caused the controller parameters to download from the blank disk, causing the failure of the controller. The technicians had intended to perform Section 6.7, " Uploading a CCC Database to a Database Disk," but made an error. Failure to implement the proper portion of this procedure was a violation of the procedure. This procedure is applicable to Regu!atory Guide 1.33, and its procedures are required to be implemented by TS 5.5.1. The root cause of this occurrence was cognitive error by the Instrument and Control technicians in failing to implement the correct section of Procedure SO123-ll-9.3. This cause was obvious. This violation was not considered minor because prompt operator response was required to stop the transient induced by the violation that, left uncorrected, could have caused a reactor trip (Violation 361/98004-04).

Licensee corrective actions included initiating Level 3 Event Report 980300295. This event report documented corrective actions including stopping work on Foxboro controllers unless a special prejob briefing was held, changing Procedure SO123-ll- to clearly define terminology, coaching the technicians involved in the occurrence described above, and briefing ali instrument and Control personnel regarding the occurrence. The inspectors found these corrective actions adequately addressed the violation, and no further response is require Conclusims Instrument and Control technicians demonstrated inadequate attention to detail by implementing an incorrect section of a procedure while troubleshooting a pressurizer spray valve controller, resulting in a loss of automatic pressure control and a small pressure increase, while Unit 2 was at full power. A violation was identified for failing to comply with TS 5.5.1.1.a which requires that the maintenance procedure used for troubleshooting be implemented correctly. Operator response to the transient was goo M1.5 SG Tube Pluggino - Unit 3 a. Insoection Scooe (62707)

The inspectors monitored SG tube plugging activities. The inspectors reviewed Procedure SO23-XXVil-20.3, " Field Procedure for Remote and Manual Rolled Plugging,"

Revision b. Observations and Findings On March 20,1998, the inspectors observed vendor personnel perform SG plug insertions into SG 3E088. The technicians used good communications and proper

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l-17-verification and documentation of the plug insertions. In addition, the inspectors observed vendor personnel attempt to recover a cord stuck inside SG 3E089. Although the vendor was unsuccessful in removing the cord, the tube was successfully plugged I

and rolled locally from inside the SG as discussed in Section E c. Conclusions I

The vendor performing the SG tube plugging used good communications, adhered to procedures, and displayed professionalis Ill. Enaineerina E1 Conduct of Engineering E Failure to Evaluate Cord Left in SG Tube - Unit 3 a. Insoection Scoce (37551)

The inspectors reviewed the circumstances surrounding the plugging of an SG tube with a cord left in it. In addition, the inspectors discussed the event with the SG enginee j l

b. Observations and Findinas On March 20,1998, the inspectors observed a vendor plug a tube and leave approximately 60 feet of cord inside the tube in the SG 3E089 cold leg. The cord nad previously become stuck in the tube during installation of a U-bend stabilizer in the tub On March 20, the (tube plugging) vendor performed a nonconformance report (NCR) that documented an existing material evaluation of the cord, and concluded that the results were within the limits of the vendor's cleanliness / consumable materials specification, and also that allowing the material to remain in the primary or secondary system did not i create a corrosion concern. The vendor's NCR did not includ i a 10 CFR 50.59 safety evaluatio On March 27,1997, the inspectors requested of copy of the licensee's NCR. On March 31, the licensee initiated an action request that included an NCR assignmen The NCR, which included a 10 CFR 50.59 screening, was completed on April 1. The NCR indicated that the cord contained low levels of potentially corrosive chemicals and a that the cord would melt under operating temperature conditions. However, the licensee concluded that ieaving the cord in the SG tube was acceptable. The licensee had entered Mode 4 on March 24 and performed a unit startup on March 27, without performing a written safety evaluation.

l The licensee documented the corrective and preventive actions taken or planned in

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Action Request 980302691. Tu licensee corrective actions included the following:

revise the SG program procedure to reference the requirements of the Quality Assurance Topical Report /UFSAR; revise the Topical Quality Assurance Manual, Chapter 4-D,

"Nonconformances," for clarity; revise tne supplier purchase order to require notifying a

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-18-licensee representative of all nonconformances ider ffied for processing under the licensee's nonconformance program; review the work performed during the Cycle 8 and 9 refueling outages and the Cycle 9 midcycle outages under a suppliers quality assurance program to ensure that any nonconforming conditions identified by the supplier were adequately addressed by the licensee; and include a segment on the guidance for dealing with supplier nonconforming issues in the next available management and supervisory development trainin CFR 50.59(b)(1) requires, in part, that the licensee shall maintain records of changes to the facility to the extent that these changes constitute changes to the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. The UFSAR Table 5.2-4, " Reactor Coolant System Materials," includes a list of SG materials and does not include the cord left in the SG tube. On March 20,1998, the licensee made a change to the SG configuration, as described in the UFSAR, by plugging a SG tube containing approximately 60 feet of cord material, which contained low levels of corrosives and which remained in the tube. The licensee did not perform a written safety evaluation for the change prior to returning the SG to service. The failure to perform a written safety evaluation was a violation of 10 CFR 50.59 (Violation 362/98004-05). Conclusions A violation of 10 CFR 50.59 was identified by the inspectors as a result of the fa: lure of the licensee to perform a written safety evaluation for a plant modification that resulted from leaving 60 feet of cord in a plugged SG tube. A Site Technical Services engineer failed to recognize that leaving the cord constituted a plant modification. The licensee's planned corrective actions were extensiv E2 Engineering Support of Facilities and Equipment E2.1 SG Eao Crate insoection - Unit 3 I Insoection Scoce (37551)

The inspectors observed a small cross-section of the activities associated with the licensee's inspection of the egg crate (tube supports) in the Unit 3 SGs, including i gathering of the video data, tracking the inspection progress, and grading the condition of individuallattices. The inspectors attended a routine meeting of the egg crate inspection i group on March 16,199 Observations and Findinos The video images of the egg crate lattices and the nearby SG tubes were very clear and brightly illuminated. The camera was stabilized in the SG during the inspections to aid in the control.

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-19-The images correlated well with the SG configuration depicted in the SG structural drawing, providing high confidence that the specific locations being observed were precisely known. Additionally, the licensee performed an independent verification audit of the video probe position on 50 percent of the video camera inspection locations (drops) and identified no error The inspections were being conducted in a methodical and well-documented manne Each drop was tracked on a detailed drawing indicating which probe was used. A separate computer database was also used to track the inspection progress and result The grading of tne lattice conditions was qualitative, but appeared to be conservativ The licensee performed supplemental drops to confinn the grading of areas that had not been able to be adequately viewed during previous drop Procedurer were in use for each aspect of the inspection and assessment. The personnel performing the inspection and grading were very knowledgeable within the scope of their responsibilitie Conclusions The quality of the egg crate inspections of the Unit 3 SGs was very high, providing excellent confidence in the validity of the results. The management of the process was outstandin IV. Plant Support R4 Staff Knowledge and Performance in Radiological Protection and Chemistry R4.1 Passina Tools Across a Hiah Contaminated Area Boundarv - Unit 3 Insoection Scooe (62707. 71750)

The inspectors observed contractor maintenance workers pass tools out of a high contaminated area into a contaminated area. The inspectors reviewed Procedure SO123-Vil-20.10.6, "High Contamination Area Control," Revision 1, and discussed the observation with Health Physics supervisio i Observations and Findinas  !

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On March 16,1998, the inspectors observed maintenance workers pass tools out from I under the pressurizer skirt area from a high contaminated area to a contaminated are The inspectors questioned the workers about the practice of passing tools across the l

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high contaminated boundary. The workers immediately recognized the error in Health Physics practices and proceeded to the Health Physics control point inside containment to get frisked for activity. A Health Physics technician accompanied the workers back to I the job site and surveyed the tools that were previously inside the high contamination area. The survey results indicated that the tools had a contamination level of l

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-20-approximately 5000 disintegrations per minute per 100 square centimeters and that there was no spread of contaminatio Unit 3 TS 5.5.1.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, recommends procedures for contamination control. Procedure SO123-Vil-20.1 provides, in part, instructions for controlling the spread of contamination. Step 6.5. directs personnel to " survey contaminated tools and equipment removed from high contamination areas or contamination area buffer zones not contaminated with hot particles for distributed contamination" in accordance with the licensee's surveying procedure. The failure of the workers to have the tools surveyed when removed from the high contaminated area was a violation of TS. The inspectors considered that this violation was not minor because of the potential spread of contamination, particularly if the incident recurred several times (Violation 362/98004-06).

The licensee initiated an action request to evaluate the event. The licensee placed a radiation control area hold on workers involved in the evert The licensee determined that the workers had performed other activities during the midcyc'e outage and were familiar with radiological work practices used in high contaminated areas. In addition, the workers were informed of the radiological conditions during the prejob briefing for the jo The licensee surveyed the area immediately after the event and concluded that the postings for the area were consistent with procedures and normal Health Physics practice The licensee performed several corrective actions as a result of the event. The workers 1 were counseled by their contractor supervision on the need for self checking. Health l Physics supervision met with the workers to discuss the event and to review work I practices. Health Physics supervision reviewed the event with contractor supervisors, engineers, and foremen during the daily meeting. The licensee issued a memorandum to the Health Physics staff and Health Physics management reviewing the event. The licensee planned to include the event as an Health Physics lesson learned, and planned to perform a corrective actions effectiveness audi The licensee did not agree that the failure to survey the tool was a violation of NRC requirements. The Health Physics manager stated that a survey was not required prior to removing the tool from the high contamination area, and that other aspects of the licensee's contamination control program would have effectively prevented any l

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significant contamination control problem. He stated that roving Health Physics technicians periodically survey the areas and would have surveyed the tool and the high contamination boundary. Because 10 CFR Part 20 does not specifically require that the tool be surveyed prior to removal from the high contamination area, the licensee did not consider that a violation occurre Conclusions

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l -21-Maintenance workers demonstrated poor attention to radiological postings in one instance by passing tools from a high contamination area to a contamination area without l having a survey performed until prompted by the inspectors. This was a violation of the l high contamination area control procedure and consequently a violation of Unit 3 TS l 5.5.1.1.a. The tools were subsequently surveyed and found below the limits for a high

! cor';,nination area. The licensee's corrective actions were prompt and comprehensiv P3 Emergency Preparedriess Procedures and Documentation l

P3.1 inconsistent Emeroency Classification - Units 2 and 3 Insoection Scooe (71750)

i As a result of the issues discussed in Section 01.3, the inspectors reviewed Procedure SO123-Vill-1, " Recognition and Classifications of Emergencies," Revision 10, Attachment 2, " Units 2/3 and Site-Wide Event Category Tabs." Observations and Findinas The inspectors found that the criteria for classification of emergencies in this procedure was inconsistent with NRC guidance given in NUREG-0654, FEMA-REP-1, Revision 1, November 1980, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

Procedure SO123-Vlli-1 states that a criterion for declaring an unusual event is "For Modes 1-2: A natural disaster, including . . tornado . . causing inoperability of any !

system listed in Attachment 5 to the extent that eactor shutdown has been initiated as

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specified by the applicable Technical Specification." Attachment 5 lists the vital auxiliaries of the plant. The procedure also states that a site area emergency is declared

"For Modes 1-3: A natural disaster, including . . tornado . . . causing the loss of ability to achieve or maintain hot shutdown." The guidance 3 . n in NUREG-0654 states that an initiating condition for the notification of an unusual event is " Natural phenomenon being experienced or projected beyond usual levels . . any tornado on site." The guidance also states that an initiating condition for an alert is " Severe natural phenomena being experienced or projected . . any tornado striking facility."

In response to the inconsistency, the licensee generated Action Request 980400889 to review the emergency action levels to ensure consistency with NUREG-0654. The j inspectors will review licensee's conclusions and any changes to Procedure SO123-Vill-1, as a followup item (IFl 361; 362/98004-07).

> P8 Miscellaneous Emergency Preparedness issues (92904)

P8.1 (Closed) Violation 361/97027-01: failure to seismically restrain containment fire extinguishers. The inspectors verified the corrective actions described in the licensee's response letter dated March 17,1998, to be acceptable and complete. No similar

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problems were identifie l V. Management Meetings l

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X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the exit meeting on April 29,1998. The licensee acknowledged the findings presented, and commented on several of the issue )

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The Vice President, Engineering and Technical Services, stated that citing a violation against a general procedure for operator responsibilities was ambiguous in that the i licensee could not predict when operators could be cited for rendering an incorrect l judgment, as in the case of the alignment of the waste gas system. The inspectors responded that the surveillance procedure specifically tasked the CRS to determine the correct position for the valve, but that the CRS did not adequately research the configuration and or use the correct procedural guidance for the valve positio The Vice President, Engineering and Technical Services, stated that he disagreed that a violation of NRC regulations occurred when the operators consciously performed procedural steps out of sequence, resulting in inadvertently slightly draining and depressurizing a SIT. He considered the occurrence isolated and without safety consequence, and therefore, he concluded that there was no regulatory significanc The licensee disagreed with the characterization that a weakness existed regarding monitoring of weld parameters. The licensee's program, although not explicitly stated in procedures, relied on training and qualification to assure that the weld parameters were correct, and that there were no requirements for measuring or monitoring actual parameters while performing production welding. The 14 welds, with several starts and stops each, should not have been characterized as missed opportunities to monitor the parameters, because the licensee had no expectation for the parameters to be monitored. Additionally, some monitoring was performed, but not documented, in the j sense that supervisors occasionally observed the appearance of the welds during the l welding process. The inspectors responded that the starts and stops were missed l opportunities to monitor the parameters, and reiterated that a violation had recently been {

issued for failing to monitor the parameters and having exceeded the allowable heat l input for a wel '

The licensee disagreed with the inspectors' application of Enforcement Guidance Memorandum 97-012 with respect to citing a violation for Maintenance personnel having used the wrong section of a procedure while working on a pressurizer pressure controller, resulting in a plant transient. The licensee considered that the effort expended to determine the cause of the event was not trivial, and that, therefore, the enforcement guidance allowed the violation not to be cited. The inspectors considered that the cause was immediately apparent, precluding the use of discretion. The licensee's final root caut,e assessment, to determine the factors that led to the personnel performance error, was not yet completed at the time of the exit meetin o

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i-23-Regarding the licensee's failure to survey a tool before removal from a high contamination area to a contamination area, the licensee did not agree that a violation of NRC requirements had occurred. The Health Physics manager stated that, although the failure was identified by the inspectors, a survey was subsequently performed. In addition, he stated that it was a management expectation that the tooh be surveyed when being moved to lower contamination areas, but contended that a survey would have eventually been performed without the inspectors' prompting. Additionally, a !

survey at that time was only one element of a defense-in-depth approach to controlling the spread of contamination, and that this was more conservative than specifically required by NRC regulations. The inspectors responded that the applicable licensee procedere specifically required that the tool be surveyed, although no time requirement was give The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifiat

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C. Anderson, Manager, Site Emergency Preparedness J. Fee, Manager, Maintenance G. Gibson, Manager, Compliance D. Herbst, Manager, Site Quality Assurance M. Herschthal, Manager, Station Technical (Acting)

J. Hirsch, Manager, Chemistry (Acting)

R. Krieger, Vice President, Nuclear Generation J. Madigan, Manager, Health Physics D. Nunn, Vice President, Engineering and Technical Services T. Vogt, Plant Superintendent, Units 2 and 3 R. Waldo, Manager, Operations INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: F lt Operations IP 71750: Plant Support Activities IP 92712: Inoffice Review of LER IP 92902: Followup - Maintenance IP 92904: Followup - Plant Support ITEMS OPENED AND Cl.OSED l Ooened 361; 362/98004-01 URI licensee response to funnel cloud sightings 361; 362/98004-07 IFl event classification Ooened and Closed

362/98004-02 NCV inadvertent WGDT venting into containment l

362/98004-03 VIO SIT draindown 361/98004-04 VIO loss of pressurizer control

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362/98004-05 VIO failure to perform written safety evaluation 362/98004-06 VIO tools passed acrcss high contaminated area bounday

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2-Closed 361/97014-00 LER licensee operators did not have corrective lenses for use with respirators 361/97027-01 VIO failure to seismically restrain containment fire extinguishers LIST OF ACRONYMS USED CREACUS control room essential air cleanup system CRS control room supervisor LCO limiting condition for operation LCOAR limiting condition for operation action requirement LER licensee event report NCR nonconformance report PDR Public Document Room PMP procedure modification permit SG steam generator SIT safety injection tank TS Technical Specification UFSAR Updated Final Safety Analysis Report WGDT waste gas decay tank i,

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