IR 05000369/1990003

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Insp Repts 50-369/90-03 & 50-370/90-03 on 900123-0223.No Violations Noted.Major Areas Inspected:Plant Operations, Safety Verification,Surveillance Testing,Maint Activities, Facility Mods & Licensee Self Assessment
ML20012D328
Person / Time
Site: McGuire, Mcguire  
Issue date: 03/14/1990
From: Cooper T, Son Ninh, Shymlock M, Vandoorn P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20012D323 List:
References
50-369-90-03, 50-369-90-3, 50-370-90-03, 50-370-90-3, IEIN-88-023, IEIN-88-23, NUDOCS 9003270196
Download: ML20012D328 (15)


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UNITE 3 STATES '

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~g NUCLEAR REGULATORY COMMISSION

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REGION 11 -

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ATLANTA, GEORGI A 30323 '

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Report Nos.' 50-369/90-03 and 50-370/90-03 j

Licensee: Duke Power Company

'422 South Church Street

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Charlotte, NC 28242

' Facility Name: McGuire Nuclear Station 1 and 2.

' Docket Nos.: 50-369 and 50-370 License Nos.:

NPF-9 and NPF-17

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Inspection Conducted: January 23, 1990 - February 23, 1990'

Inspectors:

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J-/Y-90 P. K. Van @oorn, Sertior Resident Inspector Date Signed W3r&N h 3-/V-90 T. Cooper,vResident inspector Date Signed AYh 3-/ V-9'o

.S Ninh, Rttsident Inspector Date Signed Approved by:

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M. B. Shymlock, Section Chief Pate Signed Division of Reactor Projects f

SUMMARY Scope:

This routine, resident inspection was conducted on site in the areas

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-of plant operations safety verification,. surveillance testing, maintenance activities, facility modifications, licensee self

assessment, followup-on previous -inspection findings, fitness -for

' duty training, review of ATWS system, and followup of_ event reports.

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Results:

In the areas inspected, three weaknesses were identified.- One

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involved the failure of licensee pro timing after backseating (para. 2.f.) grams to require valve stroke

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Another involved documen-

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tation weaknesses in the chemistry section concerning training and cause of failed samples (para. 3.c.).

A third weakness involved a

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failure to provide equivalent training to transferred supervisors (para. 4.c.).

Also a non-cited violation was identified involving inadequate work request documentation (para. 6.j.).

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e REPORT DETAILS

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Persons Contacted Licensee Employee G. Addis, Superintendent of Station Services D. Baxter, Support Operations Manager

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J. Boyle, Superintendent of Integrated Scheduling D. Bumgardner, Unit 1 Operations Manager J. Foster, Station Health Physicist

  • D. Franks, QA Verification Manager
  • G. Gilbert, Superintendent of Technical Services

C. Hendrix, Maintenance Engineering Services Manager

  • T. Mathews, Site Design Engineering Manager T. McConnell, Plant Manager
  • R. Michael, Station Chemist
  • D. Murdock, McGuire Design Engineering Division Manager R. Pierce, IAE Engineer W. Reeside, Operations Engineer
  • R. Rider, Mechanical Maintenance Engineer
  • M. Sample, Superintendent of Maintenance
  • R. Sharpe, Compliance Manager
  • J. Snyder, Performance Engineer
  • J.' Silver, Unit 2 Operations-Manager
  • A. Sipe, McGuire Safety Review Group Chairman
  • B. Travis, Superintendent of Operations Other licensee employees contacted included craftsmen, technicians, operators, mechanics, security force members, and office personnel.

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  • Attended exit interview 2.

Plant Operations (71707, 71710)

a.

The inspection staff reviewed plant operations during the report period to verify conformance with applicable regulatory requirements.

Control-room logs, shift supervisors' logs, shift turnover records and equipment removal and restoration records were routinely perused.

Interviews were conducted with plant operations, maintenance, chemistry, health physics, and performance personnel.

Activities within the control room were monitored during shifts and at shift changes.

Actions and/or activities observed were conducted as prescribed in applicable station administrative directives.

The complement of licensed personnel on each shift met or exceeded the minimum required by Technical Specifications (TS).

Several safety related active Removal and Restoration (R&R) tags were randomly selected from the control room log to determine the effectiveness of the licensee's process and control, and

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documentation of R&R tags. The inspectors performed a field walkdown of-selected R&R tags and found the information was accurate.

It was also noted that the licensee periodically reviews all active R&R tags to maintain awareness of all R&R tags, and effect on plant status, b.

Plant tours taken during the reporting period included, but were not

. limited to, the turbine buildings, the. auxiliary building, electrical equipment rooms, cable spreading rooms, and the station yard zone inside the protected area.

I During the plant tours, ongoing activities, housekeeping, security, t

equipment status and radiation control practices were observed, c.

Unit 1 Operations The Unit remained in the refueling outage which began on January 8, 1990 after a reactor trip.

The licensee determined that, other than damage to all bearings except one, no significant turbine damage had-occurred during the January 8 trip and subsequent loss of turbine t

bearing oil.

Defueling had been completed at the end of the period.

Also extensive Eddy Current Testing of steam generator tubes had been completed. Approximately 400 tubes were identified as meeting the TS

~i criteria for plugging.

The majority of the defects are axially oriented and are in the expansion transition zone just above the tube sheet.

This is a known industry phenomenon and is caused by Primary

Water Stress Corrosion Cracking.

A TS change request has been I

submitted to allow sleeving to be accomplished using the Babcock and l

Wilcox (B&W) Kinetic Sleeving Process.

The new on-line date is

May'4, 1990.

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Unit 2 Operations The unit remained on-line the entire period.

Several small power decreases from 100% were initiated for testing and a 50% runback occurred on Februar Main Feedwater (CF)y 13. The runback was caused by a trip of the'A'

pump. A clogged orifice was found in the control oil system.

The orifice was cleared and the hole was drilled slightly. larger.

The licensee plans to inspect and modify the other i

CF pumps.

The unit returned to 100% power on February 16 and was on a licensee record run for Westinghouse units at the end of the period, e.

Fire Doors In response to Non-Cited Violation (NCV) 369, 370/89-37-02, the licensee issued a memorandum to all employees stressing the importance of assuring that all Selected Licensee Commitments (SLIC)

required fire doors remain closed, or proper compensatory actions be

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taken.

Selected Licensee Commitment 16.9-5, Fire Barrier Penetrations, states, in part. that each required fire door be verified OPERABLE by verifying that each unlocked fire door without I

electrical supervision is closed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During times when a barrier is not functional compensatory actions, s'uch as fire watches, are required.

On February 8,1990, the inspector found fire door 600-D leading to the Unit 1 Turbine Driven Auxiliary Feedwater Pump room, unlatched and no compensatory measures taken.

The inspector closed the door and notified the Operator at the Controls.

The licensee investigated and determined that the door would have functioned as a fire barrier and that the type of bolt utilized in i

the door. latch, squared instead of tapered, increases the probability of the door not closing and latching properly.

Inspections are being conducted to determine which doors in the plant have this kind of latching mechanism.

An ongoing program is being conducted in order to improve employee awareness of fire door requirements and to upgrade closure and latching mechanisms where required.

The inspector urged the licensee to aggressively pursue this course of action.

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During routine Control Room surveillance, an entry made in the Unit Supervisor log book concerning 2CF-153B being backseated to stop a

. valve leak was noted. This valve is a Main Feedwater isolation valve with a required stroke time of 30 seconds.

The valve had been manually backseated until the leakage stopped and was not hard on the backseat.

The inspector found that no program exists to control either the backseating process or testing of the valve following the backseating.

Technical Specifications require that inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be performed in accordar.ce with ASME Section XI. Section XI, Part IWV-3200, Valve Replacement, Repair, and Maintenance, requires:

"When a valve or its control system has been replaced or repaired or has undergone maintenance that could affect its performance, and prior to the time it is returned to service, it shall be tested to demonstrate that the performance parameters which could be affected by the replacement, repair, or c

maintenance are within acceptable limits."

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Backseating a valve to stop packing leaks is considered maintenance

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with the potential to affect valve stroke time.

After being notified of this, the licensee performed a stroke time test on this valve, from the backseat.

The valve stroke time was not affected by being on the backseat.

The backseating of this valve is not considered

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safety significant since the valve stroke time was unaffected.

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i The McGuire Operations and Performance groups are working to develop

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a program for the control of backseating and the subsequent testing

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of valves.

Backseating of valves is not a common practice at the c

i site and is performed manually, when it is performed. The absence of

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' a program for the control of backseating is considered a weakness and

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will be_ tracked by IFI 369,370/90-03-01:

Valve Stroke Time Program

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Weakness.

No violations or deviations were identified,

3.

SurveillanceTesting(61726)

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Selected surveillance tests were analyzed and/or witnessed by the

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inspector __ to ascertain procedural and performance adequacy and

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conformance with applicable Technical Specifications.

Selected tests were witnessed to_ ascertain that current written I

approved procedures were available and in use, that test equipment in use was calibrated, that test prerequisites were met, that system

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restoration was completed and acceptance criteria were met.

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Detailed below are selected tests which were either reviewed or

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witnessed:

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PROCEDURE EQUIPMENT / TEST

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PT/1/A/4255/038 & 03A MSIV Stroke Time Test without Air

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Assist.

(SM-5)

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PT/0/A/4350/40 EVCD Battery Discharge Test.

PT/0/A/4150/05 Pressurizer Safety Valve INC 2

Setpoint Test.

j PT/2/A/4255/04B SV Train B Valve Stroke Timing -

Quarterly.

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PT/2/A/4252/01A Motor Driven Auxiliary Feedwater Pump 2A Performance Test.

PT/2/A/4601/03 Protective System Channel 111 Functional Test.

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CP/0/A/8100/111 Determination of Boron in Aqueous

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Boric Acid Solutions.

CP/0/A/8120/66 Determination of Low Level Anions By Ion Chromatography.

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OP/2/A/4600/21 Loss of Operator Aid Computer,

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b.

On January 31, 1990 NRC issued an Information Notice (IN) 88-23, Supplement 2 Potential For Gas Binding of High Pressure Safety Injection Pumps During A Loss of Coolant Accident, to alert licensees j

to potential problems resulting from the transport of hydrogen from

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the volume control tank (VCT) to the safety-related high pressure

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injection (HPI) pumps during the testing of the VCT outlet isolation valves.

Subsequently, the inspector examined the licensee's test

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procedures and drawings associated with the VCT outlet isolation

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E valves to determine whether the plant is susceptible to potential

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L problems identified in IN 88-23. Supplement 2.

Through discussions

with the licensee engineering staff, the inspector concluded that the

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plant is not susceptible to problems as mentioned above.

These VCT outlet-isolation valves are tested during cold shutdown in accordance

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with the licensee's program requirements.

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c.

The inspector examined the training and qualifications for f

individuals who routinely analyze primary chemistry and radwaste samples.

The results were found to be acceptable.

Through

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discussions with the chemistry training coordinator and chemistry

supervisors, the inspector questioned the chemistry training program

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for infrequently performed tests such as ice condenser sampling and the ability to maintain qualifications.

It was determined that no

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procedural guidelines exist to assure continued qualifications for

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personnel to perform infrequent tasks.

The licensee requalifys

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people as they deem necessary, but there are no procedural

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requirements to do so.

The inspecter was concerned that this could

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lead to inconsistencies and failure to retrain, i

The inspector reviewed several primary syste i chemical analyses and

found that several data points were outside of the warning and

control limits.

There were no reasons documented in the data sheets for the data outside of the limits.

Section 3.11.6.5 of the

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Chemistry Manual states, in part, that when data is outside of the

control limits, the analysis should stop and steps should be taken to l

determine the cause of the discrepancy.

However, there is no requirement that the reason for the discrepant condition be recorded on the data sheet.

This practice can limit the ability to trend problems.

Training. and qualification for infrequently performed tasks and documentation of the cause of discrepant conditions are two issues considered to be a weakness in the licensee's chemistry program.

No violations or deviations were identified.

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Maintenance Observations a.

Routine maintenance activities were reviewed and/or witnessed by the resident inspection staff to ascertain procedural and performance

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adequacy and conformance with applicable Technical Specifications.

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The selected activities witnessed were examined to ascertain that,

where applicable, current written approved procedures were available

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and in use, that prerequisites were met, that equipment restoration was completed and maintenance results were adequate.

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Activity Work Request /Procedule Perform PM/PT Functional 02661B I&E

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test on Containment Pressure Control Train l

l-B-Instruments.

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Perform PM/PT on Power 07161A I&E

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Range NIS Channel N42.

Perform PM/PT on EVCD 02503B I&E Battery Quarterly

Inspection.

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Investigate and repair 140740 OPS problem with 2 EVIC static

inverter, j

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During observation of preventive maintenance on Power Range NIS Channel N42 the inspector noted that Section 111 of the Work Request t

(WR), Job Sequence Description incorrectly referenced procedure

PT/0/A/4600/14/A for performing the work.

Even though the WR was

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incorrect the crew used the correct procedure.. This is another

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example of a previously identified weakness relative to adequacy of

preprinted WR descriptions.

(See reports 369,370/89-32 and 369,370/89-37).

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The inspector ' determined that the maintenance training and qualifications program for managers, technical and non-exempt staff

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was well described in the administrative policy, station directives and Employee Training and Qualification System (ETQS) manual,

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However, the inspector identified a weakness in that the program does i

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not establish training and qualifications requirements for. new

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supervisors transferred from other divisions.

Through interviews with the Maintenance Nuclear Production Department (NPD) staff, the inspector learned that there are at least four first line supervisors who were recently transferred from Construction Maintenance Division (CMD)' to NPD since January 1,1989.

It was noted that no formal

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assessment has been performed by Maintenance NPD to determine whether or - not the first line supervisor's previous CMD training and

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qualifications are equivalent to the Maintenance NPD training and

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qualifications.

This is considered a weakness in the licensee training program.

The licensee indicated that corrective action would be implemerited.

No violations or deviations were identified.

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Licensee Event Report (LER) and Part 21 Followup (90712,92700)

The bElow listed Licensee Event Reports were reviewed to determine if the t

information provided met NRC requirements.

.The determination

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adequacy of description, verification of compliance with

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Technical Specifications and regulatory requirements, corrective action taken, existence of potential generic problems, reporting requirements

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satisfied, and the relative safety significance of each event. Additional inplant reviews and discussion with plant personnel, as appropriate, were

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conducted for those reports indicated by an (*).

The following LERs are closed:-

j 369/89-06, Rev. 1 Non Safety Related Components Installed Between Safety Related Solenoids and Valve Operators on a Containment Isolation Valve-Design Deficiency..

(Viola-tion 369,370/89-16-02 issued).

369/89-13 Unit 1 Operated at Greater than 100% Thermal Power Because of Inappropriate Actions and Procedural Deficiencies.

(Violation 369/89-21-01 issued).

  • 369/89-16 TS. Required Flow Estimates of the Unit Vent Sample Device Were Not Performed Because of a Failure to Follow Procedure.
  • 369/89-18 Both Trains of the Control Area Ventilation and Chilled Water System Declared Inoperable Because of Equipment Failure.
  • 369/89-20 Abnormal Degradation of Steel Containment Vessels Due to Corrosion Caused by Standing Water in the Annulus (also described in Report 369,370/89-24).

369/89-21 Both Trains of Annulus Ventilation Were Found to be Inoperable Because of Design Deficiency.

(Violation 369,370/89-24-03 issued).

(Violation 369,370/89-14-01 issued).

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369/89-26 Both Trains of Control Area Ventilation System Were Inoperable Because of a Design Deficiency That Deleted a Check Damper.

369/89-28 Control Area Ventilation Was Technically Inoperable Due to a Gap Around the Control Room Air Handling Unit

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369/89-31 TS 3.0.3 Entered Due to an Inappropriate Action During.

Maintenance on the Control Area Ventilation System.

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370/88-03-TS Limit for Crane Load Over the Spent Fuel Storage Pool Was Exceeded Due to Management Deficiency.

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Unit Operated in Violation of Technical Specification

  • 370/89-07 3.1.2.la and 3.1.2.3 Because Both Centrifugal Charging

I-Pumps Were Inoperable During Refueling.

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Automatically Started Because of an Inappropriate

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Action.

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  • 369/89-19 An inadvertent Unit 2 Engineered Safety Features E

Actuation Occurred Because of an Inappropriate Action and a Defective Procedure.

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  • 370/89-08 Technical Specification Required Shutdown Boron

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Surveillances Were Missed Because of a Failure to

Follow Procedure.

This event was also caused in part by a weakness in the chemistry manual. The licensee has revised the appropriate section of chemistry manual to provide adequate guidance for the letdown and pump discharge samples and reviewed this event with all appropriate personnel.

  • 370/89-13 An Iodine-131 Dose Equivalent Sample Was Not Valid Because of a Management Deficiency and an Inappropriate Action.

The following 10CFR 21 Reports were reviewed to verify that the licensee

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u had the information and had determined that these were not applicable or

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had. implemented appropriate corrective action.

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P2189-15 Westinghouse Ambient Compensated HFB3125A Molded Case Thermal / Magnetic Circuit Breakers Failed to Meet Instantaneous Trip Portion of Time / Current Curves.

l This item affected spare breakers which have been.

returned to the manufacturer.

PT2189-19 Dresser Industries Pressure Reducing Sleeves

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Manufacturer by Pacific Pumps May Have-a Brittle Crack Failure Due to Inadequate Heat Treatment.

Determined

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to be not applicable.

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i No violations or deviations were identified.

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Followup on Previous Inspection Findings (92701, 92702)

The following previously identified items were reviewed to ascertain that

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the licensee's responses, where applicable, and licensee actions were in compliance with regulatory requirements and corrective actions have been i

completed.

Selective verification included record review, observations, and discussions with licensee personnel.

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a.

(Closed)

Violation 370/88-23-01:

Failure to Follow Procedure / Inadequate Procedures. The licensee responded to this item in a letter dated October 6, 1988.

The inspector verified that the licensees corrective actions had been implemented. The licensee has-also implemented additional management corrective actions relative to

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procedure compliance which are described in the licensee response to violation 369/89-05-02.

Another violation involving inadequate procedures for stroke testing of valves has been issued (See NRC P.eport 369,370/89-37 and NRC letter to Duke Power Co. dated November 22,1989).

It appears that the corrective actions for the subject violation were incomplete and did not prevent a second violation from occurring.

Further followup inspection will be performed relative to the more recent violation.

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(Closed)

Violation 369,370/88-24-03:

Severity Level III Violation Regarding Operability of the Hydrogen Skimmer System.

The licensee responded to this item in a letter dated February 15, 1989.

The inspector verified implementation of the corrective actions which included system modifications, retesting, improvement of the program for operability determinations and improvements in the program for 10CFR50.59 safety evaluations, c.

(Closed)

Violation 369,370/88-29-01:

Severity Level III Violation Regarding Inadequate Post Modification / Maintenance Testing.

The licensee responded to this violation in a letter dated February 15, 1989.

The inspector verified implementation of the corrective actions which included specific valve fixes, changes to valve installation procedures, review of other valve modification packages and work requests, and program improvements which included changes to Station Directive 3.2.2:

Identifying and Performing Plant Retest, and issuing Maintenance Management Procedure 1.6:

Maintenance

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Activities Associated with Functional Verification. The licensee is continuing to evaluate the test program as new system design basis documents are issued as a result of the ongoing Design Basis Review program, d.

(Closed)

Violation 369,370/89-11-01:

Inadequate Procedures and Drawings Leading to Loss of Residual Heat Removal on Three Occasions.

The licensee responded to this item in a letter dated July 5, 1989.

The inspector verified implementation of corrective actions which included procedure and drawing changes, a drawing audit, providing general guidance for filling and venting, and implementation of a specific venting procedure for the Residual Heat Removal System.

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(Closed)

Violation 369,370/88-32-01:

Failure to Submit PSI Relief Request.. The inspector verified that the proper relief request was submitted in response to this item, satisfying the commitment made by the licensee.

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(Closed)

Violation 369,370/89-05-02:

Failure to Follow Procedure for Maintenance.

The inspector verified that Maintenance Manual _

Section 5.0, Use of Procedures, was incorporated into the Mechanical

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Maintenance Orientation Training Lesson Plan and that' all required.

personnel successfully completed training on this topic.

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(Closed) Violation 369/89-21-01:

Violation of Maximum Core Power of 3411 Thermal Megawatts Given in License NPF-9.

The inspector verified that all of the licensee's corrective actions had been implemented.

These actions included procedure revisior.s. computer software modifications, and personnel retraining.

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(Closed)

Inspector Follow-Up Item 369,370/88-31-04:

Verify Improvement of Procedure OP/0/A/6100/06 and Implementation of Program for ECP Data.

The inspector verified that the procedural changes necessary to satisfy the concerns raised by this issue were completed

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and implemented, i.

(Closed)

IFI 369,370/88-31-13:

Verify Improvements in Train Designations.

The inspector verified that the required changes to the IWV submittal, procedures, and flow diagrams were revised.

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IFI 369,370/89-15-05:

Work Request Discrepancies.

The inspector noted that the actions taken addressed one of the weaknesses discussed in the item, lack of a procedural requirement for personnel entering descriptions of maintenance work to also enter their name and the date, but did not address the other weaknesses noted in the report.

Maintenance Management procedure 1.5, " Work Request Processing",

Section 5.1.2, was revised to require that each entry in Section V of the Work Request.be signed and dated by the person making the entry.

The inspector, in his normal review of Work Requests, found a high percentage that do not contain the required signature and date.

These multiple examples of failure to follow MMP 1.5 constitute a failure to follow procedure.

Adequate corrective actions have been t

initiated and there have been no previous violations whose correcth&

actions would have corrected this problem.

This NRC identified violation is not being cited because criteria specified in Section V.A of the NRC Enforcement Policy were satisfied. This is identified as a Non-Cited Violation, 369/370/90-03-02:

Failure to Follow Maintenance Procedure for Work Request Documentatio (+--.

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(Closed)

Violation' 369/89-01-04:

An Inadvertent Reactor Coolant System Dilution on December 1,1988.

This event was caused by inadequate Operations and Chemistry procedures.

Appropriate procedure changes-have been made to incorporate steps for flushing the Chemical and Volume Control System (CVCS) cation bed

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demineralizer to the boron sampling system recycle holdup tank, and

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to include verification of ' primary chemistry whenever a CVCS

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demineralizer is loaded and ready for service. Operations procedure,

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OP/0/B/R200/80 has been established for use and control of all CVCS

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L demineralizers.

The inspector verified that training of appropriate

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personnel has been conducted to ensure a thorough understanding of l

the cause and consequences of this event, as well as procedural

y changes made.

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(Closed)

Inspector Followup Item.369,370/88-31-26:

Verify

Improvements in CMD Personnel Training.

The inspector reviewed the

licensee response to this item dated August 1, 1988 and a meeting was

held with CMD management to discuss the training and qualification program status.

The inspector determined that the project control

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manual has been revised to require the identification of any special

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qualifications required by the craft.

A training and qualification

plan for craft workers who work on modifications has been developed

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and is being implemented.

All training will be complete by August 1990.

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No violations or deviations were identified.

7.

Observations of Fitness for Duty (FFD) Training

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(Closed)

TI 2515/104:

The inspector observed the licensee's FFD awareness training for vendor / contract employees with unescorted access to the plant on~ February 7,1990 to determine whether the required training

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is being conducted to implement' the new NRC requirements contained in 10CFR26 effective January 3,1990, and to determine acceptability of licensee FFD program implementation.

The inspector verified that the

following areas were covered in the training' session:

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Licensee policy and procedures, including the methods that will be

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used to implement the policy;

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The personal, public health, and safety hazards associated with the

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abuse of drugs and misuse of alcohol;

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The effects of prescription drugs, over the counter drugs and dietary

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conditions on job performance and chemical tests results, and the

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role of the medical review officer; Employee assistance programs provided by the licensee;

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What is expected of employees and what consequences may result from

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lack of adherence to the policy;

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Alcohol and drug test appeals process; j

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Behavioral observation techniques for recognizing / detecting effects l

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of alcohol and drug.use in work place;

The procedure for reporting problems to supervisory or security

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personnel.

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The inspector noted a vendor employee sleeping through the training session. No action appeared to be taken until the issue was raised by the

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inspector.

Further discussions were held with licensee management, who indicated that the proctor was aware of the individual's actions _ and was

unsure what to do when the inspector first talked to the proctor.

Subsequently, it was noted that the affected person will not be given

credit for training and in fact is being considered for removal from the

vendor work force.

l No violations or deviations were identified in this area.

8.

Evaluation of Licensee Self-Assessment Capability (40500)

a.

The inspector reviewed Quality Assurance Department (QA) Audit Report NP-89-21 (MC) covering operations activities at the McGuire station.

The audit was heavily weighted toward field observation covering areas such as Control Room observation (including backshift).

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compliance with Technical Specifications, valve positioning,

procedure implementation, procedure field walkdowns, housekeeping observations, operator rounds and simulator observations.

Findings

indicated a good technical knowledge of requirements and were

reflective of a performance based audit.

Findings were identified

.j in areas such as communications during simulator exercises,

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housekeeping, procedural weaknesses, control of procedures and data curves at local plant control stations, labeling..and validation of Emergency Procedures, j

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The inspector noted in the monthly Problem Investigation Report (PIR)

Status Report that overdue corrective actions on PIRs is increasing

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and the number of outstanding PIRs is steadily increasing.

The

licensee Compliance group is aware of this trend and requested that QA perform an audit in this area.

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All of the PIRs that are listed as overdue are assigned to offsite organizations, such as Nuclear Production Department-General Office, Design Engineering, and Quality Assurance. The audit determined that the root cause of the large number of PIRs remaining open can be attributed to the significant amount of design related corrective i

actions required.

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The Compliance Section will meet with the Departments with large numbers of overdue PIRs and establish new completion schedules and update the PIR status list.

The Compliance group is aggressively addressing control of the PIR program, but results of the actions taken are not apparent yet.

No violations or' deviations were identified.

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9.

ReviewofCompliancewithATWSRule,10CFR50.62(TI2500/20)

The inspector reviewed the licensees implementation of the Anticipated L

Transient Without Scram (ATWS) rule.

The licensee approved design is described in a letter to the NRC dated June 1, 1988.

The ATWS system serves as -a backup to normal safety related systems to assure a turbine trip and Auxiliary Feedwater system start upon loss of Main Feedwater (CF).

The system at McGuire monitors CF control valves, bypass valves, isolation valves and pumps. The system functions upon loss of both CF pumps or loss of CF flow.

Annunicators are provided in the Control Room for Turbine Trip on ATWS, CF pump trip, CF control valves less than 25% open, and CF flow path closed for 30 seconds. A panel light indicates when the system is actuated and the panel also has a Reset and Bypass pushbutton.

The system is bypassed below 40% power.

Although the system is not safety rel ated, some quality assurance (QA) requirements are required for components.

The system is required to be operable which is assured by a maintenance and testing program.

The inspector observed the installed system for conformance to design requirements, reviewed the preventive maintenance program, reviewed the testing program (implemented by procedure PT/1&2/B/4700/59), reviewed the QA requirements (implemented by the Administrative Policy Manual), and verified that plant personnel understand operation and maintenance of the system by interviewing maintenance personnel and operators. The inspector also verified that the system met commitments to the NRC and that operation of,the system was incorporated into operations procedures.

The inspector noted that Unit 2 Operations Procedure OP/2/A/6100/03:

Controlling Procedure for Unit Operation, did not contain a caution note at. step 2.22 of Enclosure 4.1 similar to the corres)onding Unit 1 procedure.

The caution was for plant reliability involving monitoring CF valve positions.

However, the licensee indicated that the note should be in both procedures and that a correction would be made.

The' ATWS system is a licensee comitment contained in the licensees Selected Licensee Comitments (SLIC) document.

The inspector verified that the system was being treated as a Technical Specification (TS) system such as by logging status when the system is inoperable and stamping any work request as TS related work.

The licensee is in the process of obtaining a SLIC related stamp to be used on work requests.

No violations or deviations were identified, a

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t The inspection scope and f'indings identified below were summarized on

February 23, 1990, with those persons indicated in paragraph I above.- The

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following items were discussed in detail:

i Inspector Followup Item 369,370/90-03-01:

Valve Stroke Time Program

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Weakness (paragraph 2.f.)

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L Weaknesses in the chemistry program involving documentation of the

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cause of discrepant conditions and training) and qualification for infrequently performed tasks (paragraph 3.c.

7; Weakness _involvingtrainingoftransferredpersonnel(paragraphL4.c.)

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Non-Cited viole, tion 369,370/90-03-02:

Failure to Follow Maintenance j

ProcedureforWorkRequestDocumentation(paragraph 6.j.).

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The licensee representatives present offered no dissenting comments, nor-did they identify as proprietary any of the information reviewed by the j

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inspectors during the course of their inspection.

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