IR 05000373/1998009
| ML20248A591 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/22/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248A578 | List: |
| References | |
| 50-373-98-09, 50-373-98-9, 50-374-98-09, 50-374-98-9, NUDOCS 9805290417 | |
| Download: ML20248A591 (26) | |
Text
l
.
!
'
U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos:
50-373, 50-374 License Nos:
50-373/98009(DRP); 50-374/98009(DRP)
Licensee:
Commonwealth Edison Company Facility:
LaSalle County Station, Units 1 and 2 Location:
2601 N. 21st Road Marseilles,IL 61341
Dates:
March 11 - April 22,1998 Inspectors:
M. Huber, Senior Resident inspector, LaSalle J. Hansen, Resident inspector, LaSalle R. Crane, Resident inspector, LaSalle P. Prescott, Resident inspector, Palisades J. Meynen, Resident inspector, D. C. Cook Approved by:
. D. Hills, Acting Chief Reactor Projects Branch 2 l
l 9805290417 980522 PDR ADOCK 05000373 G
_.
_
_ - - _ _ _
_ _ _ _ _ _ _ _ _ - _ _ _.
_ _ - _ _ _ _ _
.
f
EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC Inspection Report No. 50-373/98009(DRP); 50-374/98009(DRP)
This inspection report included aspects of licensee operations, maintenance, engineering and plant support. - The report covers a 6-week period of inspection conducted by the resident staff.
Plant Operations l
Inspectors observed that operations personnel were knowledgeable of plant and l
.
'
equipment status, maintained accurate records, effectively communicated operational
.
Information, and operated equipment in accordance with approved procedures I
(Section 01.1).
Operations department personnel continued to struggle with some personnel
performance problems which resulted in minor operational events. For example, insufficient controls placed on a temporary alteration for a main turtdne mechanical trip valve linkage and a lack of questioning attitude by contract workers and a field engineer re:ulted in unauthorized removal of that temporary alteration. In addition, inadequate communication between operators resulted in deficient monitoring of operating equipment, contributing to an overflow of the makeup demineralized water system (Section 01.1).
After identifying a standby gas treatment system valve in the incorrect position, the
licensee determined that the electronic work control system database contained numerous locked valve position discrepancies. The inspectors concluded that not all fields in the database had been validated against approved modifications and procedures. The licensee initiated appropriate corrective actions to resolve this configuration control issue (Section 01.2).
The operators did not meet licensee management expectations, resulting in an -
.
unexpected automatic reactor water cleanup system isolation while placing the residual heat removal system in service following maintenance. Specifically, operators did not anticipate the impact of the current reactor water cleanup system configuration and modifications on this evolution. Operating procedures did not wam operators of a
'
potential for a reactor water cleanup system isolation under these conditions. In addition, inspectors identified that instrumentation used by operators during this evolution was not
!
calibrated (Section 04.1).
i The inspectors reviewed aspects of the LaSalle Station Restari Plan and confirmed
.-
related plan actions had been implemented. However, the plan had not yet been fully effective at achieving the licensee's restart goals with respect to the human performance
.
area (Section 08.1).
The inspectors reviewed selected 50.54(f) performance indicators and concluded that the
.
percent of contaminated floor space at LaSalle has been consistently decreasing and that l
the indicator accurately reflected the radiological conditions in the plant. Adequate processes were in place to ensure contaminated floor space goals would be achieved.
'
l
_ - _
__- _ -__ _ _ _ _ _ __ - _ _
.
.
I However, the inspectors determined the indicator used by the licensee to assess unplanned entries into the action statements for Technical Specification Limiting Conditions for Operations provided no useful information as the units had been shutdown and the indicator did not apply (Section 08.2).
l Maintenance During the extended shutdown, the licensee had treen implementing numerous material
.
condition improvements. A number of the resulting system modifications, such as reactor water cleanup and ventilation system changes, had been quite extensive and exemplified a management commitment to fixing long-standing equipment problems (Section M1.1).
The licensee categorized a considerable quantity of plant work as non-outage and plans
.
to complete these activities after startup. Inspectors reviewed many of the items deferred until after startup which are contained in the non-outage corrective maintenance work request backlog, and on an individual basis found none to be safety significant. In fact, the inspectors found the licensee's categorization of individual items included in the extended outage scope to be conservative (Section M1.1).
Completion of maintenance work had been hampered by deficiencies in the scheduling
and planning process. The licensee more recently implemented schedule and planning process changes in an attempt to address these problems (Section M1.1).
Overall, maintenance procedures and documentation reviewed by inspectors were
.
adequate (Section M3.1).
The licensee failed to implement adequate corrective actions for the June 1996 service
.
water event when the licensee did not incorporate the structure safety classification list into the work package preparation process. As a retult, maintenance personnel began work to install fire protection piping supports into a safety related auxiliary building ceiling using a non-safety related work package. This was considered a non-cited violation (Section M3.1).
Overall, maintenance and construction personnel observed by the inspectort adhered to
procedures and were knowledgeable of their respective tasks (Section M4.1).
Human performance errors of minor significance occurred in the control and execution of
.
some maintenance activities. A contractor inappropriately performed control room mntilation system hanger work without proper authorization after a work package re.;sion. This was considered a non-cited violation. In addition, maintenance personnel inadequately secured foreign material exclusion plugs on a reactor core isolation cooling system exhaust steam drain. The errors were primarily the result of a lack of in-depth knowledge by the personnel performing the work activities (Section M4.1).
Enoineerina Inspectors identified that the licensee planned to wait until after plant startup to resolve
.
,
concems regarding the potential of insulation on reactor building closed cooling water and j
primary containment ventilation chilled water piping to clog emergency core cooling I
system suction. strainers. This plan schedule was not conservative and the licensee
!
!
-_
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
.
-
l
.
.
I l
!
l subsequently decided to resolve the issue before startup. This is considered an l
unresolved item pending further review of licensee commitments in this area
!
(Section E1.1).
l Plant Suppori
'
A lack of management attention contributed to various housekeeping deficiencies in high
.
!
radiation areas of the plant. In addition, the inspectors identified an individual failing to self-check and read all radiological postings prior to entering an area being controlled as a high radiation area. The inspectors verified that high radiation area postings were adequate, however, the radiological protection greater program was not effective in this instance (Section R4.1),
i l
L_-_____-________
_ - _ _ _ _
_ - _ - _
_
!
.-
.
!
Report Details y
Summary of Plant Status During this inspection period, the licensee maintained Unit 1 in cold shut down (Operational Condition 4) for a forced outage, and Unit 2 remained shut down for a refueling outage with all fuel removed from the reactor.
!
l. Operations
O1 Conduct of Operations 01.1 General Comments'
a.
Inspection Scope (71707)
The inspectors evaluated operations personnel performance while attending operations department shift briefings, monitoring control room activities, reviewing daily logs, and
-)
interviewing operations personnel regarding plant status.
j i
b.
Observations and Findinos I
in general, the inspectors observed that operations personnel were knowledgeable of plant and equipment status, maintained accurate records, effectively communicated operational information, and operated equipment in accordance with approved procedures. However, operations personnel continued to struggle with some
,
performance problems resulting in minor operational events as discussed below.
l
!
Makeuo Domineraliger System Overflow On March 12,1998, a non-licensed operator made an inaccurate log entry and performed.
. an incomplete shift tumover which contributed to an overflow of 3600 gallons of non-
. contaminated well water from a radioactive waste makeup processing system trailer, The operator had placed the makeup processing system in operation as required by the daily ~
rounds but failed to inform the oncoming operator of the operating equipment during shift tumover. Also, the off-going operator had inappropriately identified the system as no longer running in the shift logs. Prior to the oncoming operator checking the trailer, a
- valve failed in the system while it was operating and caused a tank in the raskeup domineralizer system to overflow.
Imoroper Tomoorary Alteration Removal On April 6,1998, contract workers bypassed temporary alteration controls when they i
I reconnected the Unit 1 main turbine Mechanical Trip Valve (MTV) linkage to check the setting of the trip valve. The contractors were performing Work Request (WR)
i No. 950060203-03 to inspect portions of the turbine which necessitated that the MTV be in service. The MTV linkage had previously been disconnected during a turbine Electro-Hydraulic Control (EHC) flushing procedure. A licensee field er.gineer, thinking
i
!
- _ _ _ - _ _ _
_ _ _ _ _ _ _
_ _ _ _ _ _ _ _
_
._
_ _ _ _ -
._
__
.
.,
.
.
.
l that temporary alteration controls did not apply in this instance, provided approval for I
reconnecting the MTV for the turbine inspection work.
The temporary alteration controls in place included an equipment in use tag placed on the MTV and portions of the procedure used to install the temporary alteration. Problems -
with the temporary alteration which caused the engineer to incorrectly believe a temporary alteration was not involved included:
The licensee had inappropriately used an equipment in use tag instead of a
'
.
caution card.
Operations personnel had maintained incomplete documentation of the temporary
-
alteration. Instead of the entire procedure, only portions of the EHC system flush procedure which disconnected the MTV linkage were on file. In addition, the procedural step which disconnected the linkage was not signedi The use of an equipment in use tag to mark this type of system configuration change was abnormal. Upon encountering this abnormal situation, a better questioning attitude by the contractor workers and field engineer should have led them to identifying a problem.
The inspectors reviewed the licensee's corrective actions for this event and they appeared to be appropriate. The licensee planned to review temporary alterations to ensure proper controls were in place or a plan was in place for the removal of the.
temporary alterations. The inspectors did not identify any other concems with additional temporary alterations.
c.
Conclusions inspectors observed that operations personnel were knowledgeable of plant and equipment status, maintained accurate records, effectively communicated operational information, and operated equipment in accordance with approved procedures.
,
However, operations department personnel continued to struggle with some personnel l
performance problems which resulted in minor operational events. For example, insufficient controls on a temporary alteration for a main turbine mechanical trip valve linkage and a lack of questioning attitude by contract workers and a field engineer
.i I
resulted in unauthorized removal of that temporary alteration, in addition, inadequate communication between operators resulted in deficient monitoring of operating equipment, contributing to an overflow in the makeup domineralizer system.
O1.2 Locked Valve Position Discrepancies in the Electronic Work Control System (EWCS)
a.
Inspection Scope (71707)
i The inspectors evaluated the licensee's response to the identification of locked valve position discrepancies in the EWCS. The inspectors interviewed operations and i
engineering department personnel and reviewed documentation including:
LaSalle Operating Procedure (LOP)-VG-01M, " Standby Gas Treatment System
,
(SBGT) Mechanical System Checklist," Revision 6 i
_ _ ________ __--_____ __ _-_ _ _ _ _ _ _ _ _ _
_ _ _
___
_
.
,
l Out-of-Service (OOS) Checklist No. 980000471
=
Design Change Package (DCP) No. 9700402, SBGT Overpressurization
.
Protection Nuclear Engineering Procedure (NEP) 04-01, " Plant Modifications," Revision 5
.
NEP-04-01LA, " Plant Engineering-LaSalle Site," Revision 2
=
LaSalle Administrative Procedure (LAP)-1300-19, " Controlled Design Changes,"
.
Revision 3 b.
Observations and Findinos On March 25,1998, while performing a SBGT system walkdown prior to operating the system, a system engineer identified that 1VG023, the SBGT VQ [ Primary Containment Ventilation and Purge) Crosstie Valve, was open and did not have a locking device installed. The system operating procedure and locked valve checklist required this valve to be locked in the closed position. Operations department personnel subsequently placed 1VG023 in the required locked closed position and initiated a prompt investigation.
The licensee determined that operations personnel had recently placed the valve in the open position during the removal of an OOS checklist which had been generated through the EWCS database. The OOS administrative procedure directed the operator to identify any valves retumed to service in other than the normal position. However, the EWCS database and EWCS OOS checklist incorrectly defined the normal position as open.
While operations department supervision may require the system checklist (which includes locked valve positions) be performed to ensure system configuration following removsl of an OOS, in this instance, the EWCS OOS checklist was used.
The licensee implemented an interim corrective action comparing al! EWCS OOS checklists used for final OOS clearances against the required valve positions listed in the computerized valve verification checklist management system dc* abase (ORION). This database contained valve positions from the system checklists. Operations personnel also compared the listing of locked valves in the EWCS database to the approved valve checklists and identified 137 discrepancies in the EWCS database. Operations personnel verified that the in-plant locked valve positions associated with those discrepancies were locked in the position required by the system checklists and determined that all the valves were locked in the required positions.
j The licensee determined that the EWCS database was not always maintained with the required valve positions consistent with the ORION database and that this situation could result in additional configuration control issues should the EWCS OOS checklist be used to determine the final position of equipment. Operations department personnelinitiated actions to verify and update the valve position information fields in the EWCS database to achieve agreement with the with the valve checklists.
LaSalle Administrative Procedure LAP-1300-19, which addressed the licensee's modification process at the time of the SBGT modification, did not specifically require revisions to the EWCS database to ensure conformancs with the system checklists.
-
_ - _ _ _ _ - _ _ - _ _ _ _ _ _ _ - - _ _ - - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
_ - _ - - _ _ _ _ _ - _ _ - - _ _ _ - - _ _ _ _ _
-- _
_. - - -_ _ _ -
___-__
.
.
Nuclear Engineering Procedure NEP-04-01, Exhibit C, which was issued on February 10,1998, and replaced LAP-130019, required modification engineers to determine if the EWCS database must be updated as part of a plant modification. The licensee also initiated actions to ensure that changes in valve positions incorporated into procedure checklists would also require revision of the EWCS database.
c.
Conclusions After identifying a SBGT valve in the incorrect position, the licensee determined that the EWCS database contained numerous locked valve position discrepancies. The inspectors concluded that not all fields in the database had been validated against approved modifications and procedures. The licensee initiated appropriate corrective actions to resolve this configuration control issue.
Operator Knowledge and Performance (71707)
04.1 Reactor Water Cleanuo (RWCU) System isolation a.
Inspection Scope (71707)
The inspectors reviewed the circumstances surrounding an isolation of the RWCU system when normal shutdown cooling was being placed into service. Procedures reviewed by the inspectors included LOP-RT-13, "RWCU Lineup for Heat Removal,"
Revision 7, and LOP-RH-07, " Shutdown Cooling System Startup, Operation, and Transfer," Revision 40. The inspectors also discussed the event with plant operators and plant management.
l b.
Observations and Findinos On March 26,1998, operators were placing the 1 A residual heat removal (RHR) system into service following maintenance on the RHR shutdown cooling line. After the RHR system was placed into service, the RWCU system isolated due to high temperature on the outlet of the RWCU non-regenerative heat exchanger. The RWCU system was in operation and was the primary means for removing decay heat from the reactor. When the RWCU system isolated, the operators responded to the event appropriately and followed procedures for establishing reactor water level and temperature control. The system isolation was not an engineered safety feature actuation, but instead an isolation to protect the filter /demineralizers from the adverse impacts of high temperature. The licensee initiated an investigation of the event. Several problems which contributed to the event are detailed below.
Operators Did Not Meet Licensee Manaoement Performance Expectations Due to low decay heat and to prevent excessive cooling of the reactor coolant, the operators had isciated the cooling water to the non-regenerative heat exchanger. Before l
placing the RHR system into service, the operators discussed the evolution during a
'
pre-job briefing and addressed the potential impacts on the reactor vessel and coolant temperatures. Due to experience with the RWCU system, the operators focused on the reactor vessel conditions and the potential temperature stratification in the vessel i
l because RHR was not in operation. However, the license had recently modified the
___
_...
._
.
.
RWCU system and the performance characteristics changed in that more flow through the vessel was observed when the RWCU system was utilized for decay heat removal.
When the operators placed the RHR system into service, the operators did not question the impact of the plant configuration and the RWCU modifications on the RWCU system operation. Plant management expectations were not met by the operators because the operators did not anticipate resulting potential problems.
Control Room Instrumentation Deficiencies Following the isolation of the RWCU system, the licensee verified that the calibration of the high temperature isolation instrumentation was acceptable. However, the inspectors identified that the instrumentation used to monitor various other RWCU temperatures, including the inlet temperature and non-regenerative heat exchanger outlet temperature, were not calibrated. Operators were observing RWCU inlet temperature during the evolution. The licensee generated a problem identification form (PIF) to further investigate the extent to which other non-calibrated control room instrumentation was used by operators when performing plant evolutions. Operations personnel also generated an action request to calibrate the RWCU instrumentation.
Limited Procedural Guidance Neither the RHR or RWCU operating procedures provided guidance to operators regarding the potential to automatically isolate the RWCU system on high temperature when placing the RHR system into service while the RWCU system was being used as the decay heat removal system. The RHR and RWCU operating procedures also did not contain information that operators could use to evaluate or mitigate a similar situation.
The licensee subsequently initiated a procedure change request to provide additional guidance to operators for addressing this or a similar event.
c.
Conclusions The operators did not meet licensee management expectations, resulting in an unexpected automatic RWCU system isolation while placing the RHR system in service following maintenance. Specifically, operators did not anticipate the impact of the current RWCU configuration and modifications on this evolution. Operating procedures did not wam operators of a potential for a RWCU system isolation under these conditions. In addition, inspectors identified that instrumentation used by operators during this evolution was not calibrated.
.
Miscellaneous Operations issues (92700)
08.1 LaSalle Station Restart Action Plan Review a.
Inspection Scope (71707)
The inspectors reviewed the implementation status of various restart action plans specified in the NRC Restart Plan for LaSalle Station, dated December 16,1997.
_ _ _ _ _ _ _ _ _ _ _ _ _ _
._-
_ _ _ _ _ - _ -. ______ - _ __ _ - - ___ _ - _ - _ - _
-_
,
.-
b.
Observations and Findinas (Closed) C.2.3.d. - Adeouate Plant Administrative Procedures The inspectors verified the implementation of the licensee's Restart Actis Plan 1.38, Step 5, which consisted of a revision to LaSalle Administrative Procedure (LAP)-900-4, " Equipment Out of Service." As speedied in the restart plan the licensee streamlined the procedure by removing sections with computer related instructions and incorporating the global OOS process into the procedure. The licensee also provided training on the procedure and the global OOS process.
In addition to the LAP-900-4 revision, the inspectors reviewed the licensee's problem identification system database to determine the number of problems identified with inadequate administrative procedures ovsr the past three months. No inadequate administrative procedures were identified by the licensee or by the inspectors during this or the preceding inspection period The inspectors reviewed six Corrective Action Records (CARS) which were initiated by the licensee's Quality and Safety Assessment (Q&SA) Department that proposed various administrative procedure revisions which were required to be addressed prior to restart.
The plant staff completed the review of each CAR and identified some administrative procedures that needed to be revised. The licensee revised administrative procedures to address four of the CARS. The licensee plans to complete additional procedure revisions to address the remaining two CARS prior to Unit i restart. The procedure revisions remaining included addressing administrative aspects of documenting fire drill deficiencies and clarifying the procedure review process. This item is closed.
(Closed) C.2.3.a. - Impact of An_y Manaoement Reorganization. with New Responsibilities Clearly Defined and Understood Since January 26,1998, the licensee had made organizational changes which consisted of the following:
The Plant General Manager position was renamed as Station Manager.
- A Site Business Manager Position was created.
- The construction department was realigned to report to the maintenance manager
+
to improve safety, production, and cost performance.
i The number of direct reports to the Site Vice President was reduced from eleven
-
to six to improve safety, communication, focus, and increase efficiacy.
A Start-up group was created which consisted of Maintenance, Planning and
Scheduling, and Engineering Rapid Response Organizations. An Outage Execution Center was also created and was included in the Start-up group.
The licensee implemented the changes listed above to focus resources on completing l
remaining work necessary for restart of Unit 1 and define responsibilities for testing and l
operation of Unit 1. In addition, the licensee indicated that the new start-up organization
lw_-_
-_ _- -
_ _ _ _ _ _.
. _ - - - _ - _ _ _ _ _ _ _ _ - _ _ - - _ - - - - - - _ - - - - - - -
- - - - - - - - - - - -
-
-_
.
would create dedicated engineering resources to support the ongoing maintenance, modification, and testing activities. Following system maintenance and testing during the outage, the licensee planned to have the maintenance organization that reports to the Plant Manager perform routine maintenance activities.
The inspectors did not identify any adverse operational or organization effects which would indicate the chaage was ineffective. The start-up organization was focused on outage testing and modification activities. Other organizations reporting to the plant manager maintained focus on normal plant operations activities such as surveillance and preventive maintenance. Furthermore, the inspectors discussed the reorganization with plant personnel who, in general, appeared to understand their roles and responsibilities. When the licensee initially implemented the new organization some plant personnel misunderstood the reporting relationship in the start-up organization. The licensee took effective action to resolve the inspectors concerns with the misunderstanding. In addition, the licensee conducted meetings with all plent personnel to address the reorganization and the remaining outage activities. This item is closed.
(Open) C.2.2.b. - Demonstrated Expectation of Adherence to Procedures The inspectors verified the implementation of the LaSalle Station Restart Action Plan 2.1, Step 2," Follow-up to ensure expectations are understood and are being applied in daily work activities," established to improve human performance for support of safe plant operation. The objective of the strategy was to p.avide a near-term step change in the human performance and team work of site workers. The performance standard dafined was an improving trend in the average days between resets of the Station Event Free Clock.
To accomplish this action step, the licensee conducted supervisory training and implemented several initiatives to facilitate supervisory and management involvement in the coaching and development of plant personnel.
Although the licensee implemented this step of the Restart Action Plan, human performance errors related to failing to follow procedures continued to occur. The inspectors found that the licensee reset the Station Event Free Clock two times during this inspection period due to human performance issues related to procedural adherence.
This item will remain open pending review of additionallicensee actions and continued evaluation of action item effectiveness.
(Open) C.3.1.k. - Procedure Usaae/ Adherence The inspectors verified the implementation of the LaSalle Station Restart Action Plan 2.1, Step 1, " Expectations-Establish clear expectations for human performance and interaction," established to improve human performance for support of safe plant operation. The objective of the strategy was to provide a near-term step change in the human performance and team work of site workers.
To accomplish this action step, the licensee utilized a variety of forums to communicate management expectations for human performance. Methods used included an all station meeting, a video presentation made by senior site management explaining expectations to all new personnel and to all station personnel during periodic nuclear general employee
__
- _ __ _______
__ ______ -
__
__ _ _ - -__ _ _ _ _ _ ___ _ _ _
_ _ _ _ _ - _ _ -
_
_
e.
O
>
training sessions, and one-on-one sessions with all employees and their respective line
'
management.
I The inspectors verified that all related Restart Action Plan steps had been implemented by the licensee. However, as discussed in C.2.2.b, errors continue in the area of procedural adherence. This item will remain open pending review of additional licensee actions and continued evaluation of action item effectiveness.
c.
Conclusions The inspectors concluded that the licensee was making progress in completing the LaSalle Station Restart Plan. However, the inspectors noted that the plan has not been fully effective at achieving the restart goals established in the plan, particularly in the area of human performance improvements.
_
08.2 50.54m Performance Indicators a.
Inspection Scope (71707)
The inspectors reviewed the development of selected 50.54(f) performance indicators, and interviewed operations, radiation protection, and plant management personnel.
b.
Observations and Findinas The inspectors reviewed the following performance indicators:
C6. Unplanned Entries into LCOs flimitina Condition for Operations 1 The licensee developed performance indicator C6, unplanned LCO entries, to assess plant performance regarding the management of LCOs requiring a unit shutdown in 7 days or less. The licensee selected a performance indicator threshold where greater than two unplanned LCOs in a month would require e deviation report be initiated that would describe the actions underway or planned to improve performance. While the licensee had reported in the monthly performance indicator update that there have been no unplanned LCO entries for the past 6 months, the inspectors reviewed several LCO entries which occurred during the inspection period and determined that, while accurate, the indicator provided no useful information. The units have previously been shutdown and, in accordance with NOD-OA.39, " Performance Indicators for Nuclear Operations Division," Revision 3, the indicator only applied to an operating unit.
C7. Percent Contaminated Floor Space l
The licensee developed performance indicator C7, percent contaminated floor space, to assess plant performance regarding management of plant areas that exceed a smearable
.
contamination level of 1000 disintegrations per minute in a 100 square centimeter area.
l The licensee selected a performance indicator threshold where greater than a one percent increase over the site goal (4.2 percent floor space excluding areas that were not accessed or accessed infrequently and those areas routinely used for contaminated work)
would be considered a variance and a report would be initiated that would describe the actions underway or planned to improve performance.
_-_-__-___________-___-
_
. ____
l
.
.
!
I l
The inspectors interviewed radiation protection, maintenance, and operations personnel; i
reviewed plant survey summary documents; and inspected several plant areas. The I
licensee had reduced the percentage of contaminated floor space from approximately 24 percent in January 1997 to 3.5 percent in March 1998. The inspectors observed the percent contaminated floor space performance indicator accurately reflected contaminated areas in the plant and that contaminated areas were trended in accordance with the performance indicator definition. The licensee had maintained the contaminated
,
floor space below the site goal during 1997 and 1998. Maintenance and operations j
l personnel indicated that the reduction in contaminated floor space had increased their efficiency in performing assigned tasks. Also, the inspectors noted that the percent contaminated floor space site goal for the end of 1998 was 2.8 percent.
c.
Conclusions
i The inspectors concluded that percent contaminated floor space performance indicator i
!
accurately reflected contaminated areas in the plant. However, the unplanned LCO entry performance indicator was not a useful criteria for assessing criterion due to the units
!
being shutdown. Also, the inspectors concluded that the licensee had made significant progress in reducing contaminated areas in the plant and that adequate processes were in place to ensure that aggressive percent contaminated floor space goals would be -
achieved.
,
j 08.3 Followup of Inspection items j
(Closed) Inspector Follow-up item 50-373/93022-02: Developing corrective actions that address root causes of the event and developing a method to ensure consistent lubrication of diesel generator cooling water pump (DGCWP) bearings.
In 1993, the licensee inspected lubrication levels of various DGCWPs and found that the
,
oil levels were outside of allowable levels to ensure adequate lubrication of the pump l
bearings. The root cause for the inadequate oil levels was attributed to inadequate l
procedures and the lack of understanding of the operating principles of the oil system on the pumps. To address the problems in the short-term, the licensee revised procedures to ensure that adequate oil levels would be maintained. However, the long-term corrective actions consisted of a modification to the DGCWPs to ensure adequate I
lubrication by converting the lubrication method fmm an oil lubrication system to greased bearings. The pumps have installed fittings for lubrication and the licensee has lubricated the bearings periodically. This item is closed, 11. Maintenance M1 General Maintenance Observations M1.1 Maintenance Observations a.
Inspection Scope (62707)
On March 11,1998, the licensee presented the Unit 1 forced outage (L1F35) schedule to the plant staff. This schedule included the major work items and milestones necessary to
- _ _ _ _ _ _
_ _ - _ _ _ _ _ _ _ _ _ = _ _ _
.
.
support the Unit i restart. The inspectors interviewed several members of the licensee's staff including first line supervisors, maintenance technicians, work analysts, and maintenance management personnel regarding the outage scope, the outage resource plans, and the organizational changes. In addition, the inspectors reviewed the maintenance backlog and outage work scope. In particular, the inspecbrs focused on the 1100 items which were removed from L1F35 to ensure the licensee's review:
maintained proper emphasis on equipment important to safety. The following documents were reviewed:
Nuclear Station Work Procedures (NSWP)-WM-05, " Implementation Of The
+
Fix-It-Now (FIN) Process," Revision 0 NSWP-WM-06, " Minor Maintenance Process," Revision 1
+
NSWP-WM-09, " Maintenance Work Scheduling Process Week E-5 to E+1,"
+
Revision 0 L1F35 System Readiness Review & System Tumover to Operations Program
+
LAP-1300-1, " Action / Work Request Processing," Revision 68
+
LAP-100-47, " Shutdown Risk Management," Revision 2
WC 302, "LaSalle Station Outage Scope Control Guideline," Revision 7
+
b.
Observations and Findinos The inspectors reviewed sevenil aspects of the licensee's restart plan including the L1F35 outage scope and resouice loading, maintenance backlog, work package walkdowns, and shutdown risk p'anning.
L1F35 Outaae Scope and Resourt e loadina The licensee identified over 3600 tacks which needed to be completed as part of L1F35 prior to restart of Unit 1. Eariy in February 1998, the licensee removed approximately 1100 tasks from the outage scope as work not necessary to suppori Unit i restart. The inspectors performed a detailed review of these 1100 tasks removed from the Unit i restart by the licensee. Additionally, the inspectors reviewed the screening criteria, including the generic shutdown risk guidelines, which the licensee used to evaluate the outage scope. The inspectors concluded that the work was appropriately screened and prioritized. The remaining maintenance backlog items, while large in volume, did not appear to contain any individually safety-significant issues. The licensee planned to do another review of the 1100 items removed for L1F35, to ensure items important to safety were not overlooked prior to startup of Unit 1.
The inspectors observed the conduct of the licensee's action request screening committee and noted a thorough adherence to the process described in NSWP-WM-08.
Furthermore, the inspectors observed that overall, the committee members exhibited conservative decision making when determining the classification of requested maintenance and modification activities. The licensee screened about 50 ARs each day,
_.
_ _. _ _ _ _ _ _ _ - _ _ _
-
-
,
o of which 20 percent were added to the L1F35 outage scope. There was no procurement department representative present at the meetings, although parts availability was one of the more significant items that impacted the scheduling of work for L1F35.
At the time of the review, the licensee had not defined the outage scope to the point that resources could be property allocated and the impact of emergent work on the available j
resources for L1F35 was questioned by the inspectors. Licensee management stated
'
that contingency time was built in to the L1F35 schedule through the use of the FIN Team and overtime.
The FIN Team had been established approximately 18 months ago to perform minor maintenance tasks which could generally be completed within one work shift. The team was chartered, in part, to complete minor emergent work which would prevent schedule impacts by allowing various departments te complete planned outage work. The maintenance manager stated that the FIN Team goal was to complete 200 tasks per week, although prior to March 1998, the FIN Team had never achieved this goal. The i
FIN Team had averaged approximately 150 tasks completed per week since December 1997. However, the FIN team exceeded its performance goals of 200 tasks per week for four weeks after the outage began. The inspectors were concemed that the licensee's schedule may be relying too heavily on the FIN Team to complete the L1F35 outage on schedule.
The inspectors reviewed the personnel resource loading plan for L1F35 and determined that the instrument maintenance group, operations department, and other contract labor were the most resource limited. Several members of the licensee's maintenance organization also identified operations support as the limiting resource to completing the L1F35 outage. The inspectors were concemed that reliance on operations overtime may not be adequate to maintain the outage schedule.
Housekeeping issues and Maintenance Backloa i
The inspectors toured the plant and noted that plant housekeeping was poor; however,
,
the inspectors concluded that the licensee had taken action during the last 18 months to improve plant material condition. The licensee implemented over 300 plant modifications to eliminate past equipment problems. Examples of the extensive modifications included:
' The RWCU System was overhauled to correct past operational problems.
- The control room and auxiliary electric equipment room (AEER) ventilation
.
systems were being renovated to address system performance issues.
The suppression pool suction strainers for all the emergency core cooling systems
+
were replaced with new strainers that have twice the effective area of the originally installed strainers.
The inspectors identified some plant equipment which appeared to be abandoned in place; however, this equipment was not marked or posted as no longer in use.
Maintenance management stated that no program existed to address abandoned in place equipment. The inspectors were concemed that maintenance migh*. continue to be scheduled and performed on equipment which was no longer in use or could potentially
.
.
lead to operators manipulating the wrong equipment. Occurrences of problems with abandoned in placed equipment have been widely documented in the industry.
\\
Although the licensee had prioritized their efforts to correct longstanding material condition deficiencies, numerous minor deficiencies and ARs remained in the maintenance backlog. The licensee planned to implement an on-line maintenance program following completion of the outage, however previous attempts by the licensee to implement a rolling schedule were unsuccessful. The inspectors were concemed about the licensee's ability to address the maintenance backlog in an effective and timely manner.
Outane Work Packane Rev>vs Due to past problems with work packages, the licensee began a pre-job review of planned work for L1F35 on February 11,1998. The licensee performed the reviews to ensure that the work packages were complete, parts were available, and potential problems were identified before starting work. As of March 9,1998,87 percent of the work packages had been reviewed and numerous problems were identified with the planned work which needed to be corrected before work could start.
The inspectors performed a detailed review of the first two weeks of the planned outage work. Approximately 11 percent of the scheduled preventive and corrective maintenance tasks were on hold for various reasons. The inspectors determined that outstanding parts issues were the primary reason that more than half of these work activities were placed on hold. The inspectors were concemed that rescheduling the on-hold work activities could have an adverse impact on the licensee's resources towards the end of the outage.
The inspectors identified that a second reason that work packages were placed on hold was due to the large number of Instrument Maintenance Department (IMD) procedures that were not ready for use because they needed updated data sheets for recording calibration and surveillance data to be completed. Because most of the IMD surveillance were scheduled to be performed late in the outage, the licensee concluded that enough time remained to correct the data sheets without delaying outage work. The inspectors were concemed that verification of the proper calibration data for IMD procedures could cause additional work delays if some improper data sheet values were identified late in the outage.
c.
Conclusions e
During the extended shutdown, the licensee had been implementing numerous material condition improvements. A number of the resulting system modifications, such as reactor water cleanup and ventilation system changes, had been quite extensive and exemplified
a management commitment to fixing long-standing equipment problems. The licensee categorized a considerable quantity of plant work as non-outage and planned to complete these activities after startup. Completion of work had been hampered by deficiencies in the scheduling and planning process. The licensee more recently implemented schedule and planning process changes in an attempt to address these problems. Inspectors reviewed many of the items deferred until after startup which are contained in the non-outage corrective maintenance work request backlog, and on an individual basis found
_ _ __ - _ __ _ _ _ _ - _ - _ _
.
.
l none to be safety significant. In fact, the inspectors found the licensee's categorization of l
individual items included in the extended outage scope to be conservative.
l M3 Maintenance Procedures and Documentation l
M3.1 Work Control Procedures and Work Packsae Documentation
,
a.
Inspection Scope (62707)
l The inspectors examined the licensee's work control process implementation from task l
identification through work package assembly and approval. The inspectors reviewed the implementation of the following related licensee procedures:
'
,
NSWP-WM-08, " Action Request Screening Process," Revision 1
.
LAP-1300-1, " Action / Work Request Processing," Revision 68
LAP-1300-1T2, " Work Package Preparation," Revision 0
.
b.
Observations and Findinas Overall, the inspectors found maintenance procedures, including work packages, to be acceptable. Implementation of maintenance procedures was evaluated and found adequate. However, the inspectors identified one inadequate plant procedure and the licensee identified an incorrect safety classification of a work package. The safety significance was minimal for each. Details are discussed below.
Incorrect Work Packaoe Classification On March 3,1998, licensee maintenance personnel had commenced work on Nuclear Work Request (NWR) No. 97013456-01, to attach two fire protection piping supports to a ceiling in the auxiliary building. The NWR classified the work as non-safety related because the work analyst believed the work was being performed in the turbine building, a non-safety related structure. Maintenance personnel noted that a similarjob in the same area was safety-related due to the classification of the building structure, but began the work anyway and drilled into the ceiling which would anchor the pipe supports. A work analyst subsequently determined that the support was actually being attached to the auxiliary building which is a safety-related structure. The licensee subsequently revised the NWR on March 4,1998, to reflect the safety-related nature of the work. Because the fire protection work considered " regulatory-related" by the licensee and contained the same requirements as a safety-related work request, no physical changes were required due to the revised safety classification.
l The work analyst did not properly classify the work because he incorrectly determined that the supports were to be attached to a non-safety structure. The inspectors found that the work analyst did perform a walkdown of the work, but did not realize that the job location was in the auxiliary building because access to the job site was via the turbine building, with no door or other distinctive feature separating the two buildings. However, the inspectors found that the drawing contained in the WR prepared by the work analyst
)
!-
I
,
___ - _
_ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _
___-
.
..
.
specifically identified the supports as in the auxiliary building, which was overlooked by l
the work analyst.
Additional contributing factors led to the licensee's incorrect safety classification of the
!.
work package for the fire protection supports. The original AR listed the location of the missing supports as in the turbine building. In addition, the EWCS computer generated work request automatically inserted the safety classification of work based on the unique Equipment Part Number (EPN) of the primary piece of equipment being worked. Since the fire protection system supports are not safety related, EWCS defaulted to a non-safety related classification with no consideration given to interfaces with other equipment j
,
or structures. The WR was reviewed by two technically qualified individuals which also
'
could have identified the safety-related nature of the work package, however, they relied on the EWCS default. The inspectors found that the list of structures and their safety classification generated as a corrective action for the June 1996 service water event was I
only incorporated into the EWCS database and not into all relevant procedures used by work analysts for preparing work packages.
The licensee initiated a root cause investigation scheduled for completion by April 30,1998. In addition, immediate corrective actions included reclassification of the work package as safety-related and training of work analysts regarding the importance of proper structuralidentification and safety classification. Work control management planned to revise LAP-1300-1T2 to include a reference to the structure safety classification cross-reference list.
The licensee's failure to incorporate the structural safety classification data generated as a result of the service water event into the work package preparation process described in LAP-1300-1T2 is a violation of 10 CFR Part 50, Appendix B, Criterion XVI. However, the NRC is not citing this violation because it satisfies the criteria delineated in Section Vll.B.2 of the NRC's Enforcement Policy (NUREG-1600). Specifically, the licensee has entered an extended shutdown; enforcement action was not considered necessary to achieve remedial action; the violation was based upon activities of the licensee prior to the events leading to the shutdown; the violation would not be categorized at Severity Level ll; the violation was not willful; the licensee's decision to restart the plant requires implicit NRC concurrence; and the violation was identified by the licensee (50-373/98009-01(DRP); 50-374/98009-01(DRP)).
Missino Toraue Specifications for Control Rod Drive (CRD) Filter Replacement On February 26,1998, the inspectors identified that torque values for the filter housing bolts were not provided in LOP-RD-15, " Control Rod Drive System Drive Water Filter Replacement," Revision 9. The filter replacement procedure required the operator to tighten the nuts on the filter housing in a uniform rotation during reassembly of the filter and subsequently, to pressurize the filter, check for leaks, and tighten the nuts or replace the O-ring on the filter housing as necessary. However, the inspectors determined that torque values were specified by the equipment manufacturer for the filter housing bolts.
Subsequently, the licensee evaluated the CRD filter torque requirements and determined that the bolts should be torqued to 144 foot-pounds. The inspectors determined that the missing torque values had not resulted in operational problems or O-ring failures. To address the potential for other operations procedures to be missing torque requirements,
1
,
-
_ _ _ _ _ _ _
_.
- _ _.
r the licensee reviewed operations department procedures to determine if torque values were required and no additional procedure problems were identified.
c.
Conclusions Overall, maintenance procedures and documentation reviewed by inspectors were adequate. However, the licensee failed to implement adequate corrective actions for the June 1996 service water event when the licensee did not incorporate the structure safety classification list into the work eckage preparation process described in LAP-1300-1T2.
As a result, maintenance personnel began work to install fire protection piping supports into a safety related auxiliary building ceiling using a non-safety related work package.
M4 Maintenance Staff Knowledge and Performance M4.1 Staff Knowledge of and Implementation of Maintenance Procedures a.
Inspection Scope (62707)
The inspectors reviewed the construction and maintenance department's personne:
knowledge of and implementation of the following licensee procedures:
LAP-1300-1, " Action / Work Request Processing," Revision 68
.
NSWP-A-03, " Foreign Material Exclusion," Revision 0
.
b.
Observations and Findinas
Overall, the inspectors found maintenance and construction personnel adhered to procedures and were knowledgeable of their respective tasks. However, two instances of inadequate maintenance personnel knowledge are provided below.
VC/VE Hanaer Modification Work Performed Without Authorization On April 1,1998, the licensee identified that maintenance contractors were performing
,
'
work using WR 970131499-05 without authorization after the work package was revised to introduce a new weld procedure. Specifically, a work analyst revised the work package j
on the April 1,1998, night shift and retumed the package to the work control center.
When the day shift retumed to work, the maintenance supervisor obtained the work package but failed to notice that a major revision was made which required operations approval prior to continuing work. The supervisor, who was a contractor, was aware that the WR was revised, but was not aware of the approval process for a major work package revision as specified by LAP-1300-1, Step 3.6.5.
The licensee's immediate corrective action was to stop work on the hanger modification
,
and to begin an investigation of the problem. Subsequent actions included training of construction supervisors and foremen, and a verification that all contract work packages being worked had the appropriate authorization. In addition, the licensee planned to provide a visible indication on the cover of work packages which have been revised. The inspectors reviewed the licensee's corrective actions and found them adequate.
_ ____________ - ___ - _____
-.
.
The failure to adhere to the requirements of LAP-1300-1 is a violation of 10 CFR Part 50, Appendix B, Criterion V. However, the NRC is not citing this violation because it satisfies the criteria delineated in Section Vll.B.2 of the NRC's Enforcement Policy (NUREG-1600).
Specifically, the licensee has entered an extended shutdown; enforcement action was not considered necessary to achieve remedial action; the violation was based upon activities of the licensee prior to the events leading to the shutdown; the violation would not be categorized at Severity Level ll; the violation was not willful; the licensee's decision to restart the plant requires implicit NRC concurrence; and the violation was identified by the licensee (50-373/98009-02(DRP); 50-374/98009-02(DRP)).
Inadeauste Foreian Material Exclusion (FME) Boundaries On March 16,1998, the inspectors identified two missing FME plugs on the reactor core isolation cooling system (RCIC) exhaust steam drain. This was the third instance of the RCIC plugs being found missing. The first was identified by the inspectors as described in NRC Inspection Report Nos. 50-373/374-98004. The second was identified by the licensee on March 14,1998. The licensee determined the FME plugs did not remain installed because the plugs were not adequately secured to prevent ejection by pressure changes in the reactor building. The inspectors interviewed maintenance management and maintenance personnel who installed the FME plugs and determined that the licensee's evaluation appeared acceptable.
The licensee's procedures required that FME covers be secured so that they would not be dislodged by a pressure drop / surge of the system on which they were installed.
However, maintenance personnel did not consider the potential for building pressure changes to affect the RCIC drain system. The licensee's mechanical maintenance and construction departments conducted training with their respective personnel on proper FME protection and the requirements of plant procedures goveming FME. Maintenance department management planned to include proper FME placement as a discussion topic in the department continuing training program. The inspectors reviewed the licensee's corrective actions and found them to be adequate.
c.
Conclusions Overall, maintenance and construction personnel observed by the inspectors adhered to l
procedures and were knowledgeable of their respective tasks. However, human
'
performance errors of minor significance occurred in the control and execution of some maintenance activities. A contractor inappropriately performed control room ventilation
{
system hanger work without proper authorization after a work package revision and
!
maintenance personnelinadequately secured foreign material exclusion plugs on a RCIC exhaust steam drain. The errors were primarily the result of a lack of in-depth knowledge by the personnel performing the work activities.
M8 Miscellaneous Maintenance issues M8.1 (Closed) Unresolved item (URl) 50-373/374-97006-05: Review of check valve maintenance practices, including maintenance procedure adequacy, post-maintenance testing (PMT) practices, and the check valve program.
_ _ _ _ _ - - - _ _ _ -
NRC inspection Report No. 50-37N97006; 50-374/97006 discussed a problem with a leaking bonnet on a check valve with a pressure seal design. The leak was of particular concem to the inspectors because the valve was recently repaired. The licensee had check valve maintenance procedures for various types of check valves. In particular, maintenance procedures were used for check valves with pressure seal bonnets. To address the leak in the bonnet, the licensee changed the gasket material used to prevent leaks. The inspectors verified that the licensee evaluated the gasket material change.
The inspectors reviewed PMT for safety-related and non-safety related check valves. For safety related check valves, the licensee's inservice testing program required that PMT be performed to verify that check valves adequately perform their safety function.
However, non-safety related check valves may not require flow testing or some type of diagnostic testing to verify that the check valve was operating acceptably following maintenance. The licensee's check valve program coordinator was reviewing the PMT practices for check valves and the licensee's Nuclear Tracking System (NTS) was tracking the review (NTS ltem No. 373-100-97-00605.00). This item is closed.
Ill. Enaineerina E1 Conduct of Engineering E1.1 Corrective Actions for Potential Emeroency Core Coolina System Suction Strainer
Clocaina Concem Scheduled For After Plant Restart I
a.
InsDection Scope (37551)
j
.
The inspectors reviewed the licensees actions to address licensee identified concems j
regarding insulation installed in the drywell.
l b.
Observations and Findinas
!
On June 25,1997, the licensee initiated a problem identification form (PIF) after identifying that insulation on the reactor building closed cooling water system (RBCCW)
and primary containment ventilation chilled water piping was missing metal flashing in
,
several places in the containment. The concem communicated in the PIF was that,
.;
during loss of coolant accidents (LOCA), the insulation could deteriorate, migrate to the j
suppression pool, and challenge the emergency core cooling system (ECCS) suction
strainers. In addition, the licensee identified that aluminum insulation installed during initial construction had a paper and polyethylene film vapor barrier which could also clog the ECCS suction strainers during an accident. Licensee management reviewed the PlF and determined that an evaluation of the insuistion and its impact on the ECCS strainers needed to be resolved prior to the completion of the current outage (L1F35).
The licensee had originally planned to complete all actions related to the potential clogging for ECCS strainers by the completion of L1F35. However, on April 3,1998, the inspectors identified that engineering personnel had inappropriately planned to complete the evaluation on November 1,1998. As a result, the licensee performed an investigation l
and initiated corrective actions which included the removal of all aluminum insulation on RBCCW piping in the containment and the replacement of the aluminum insulation on
_
__
.
.
,
l
!
containment ventilation chilled water piping with stainless steel. In addition, the licensee planned to review their responses to Generic Letter 85-22, " Potential for Loss of Post-LOCA Recirculation Capability Due to insulation Debris Blockage," and information Notice 88-28, " Potential for Loss of Post-LOCA Recirculation Capability Due to insulation Debris Blockage," to ensure their adequacy. All corrective actions were planned to be
'
completed by restart. However, this issue is considered an Unresolved item pending the inspector's review of the licensee's responses to the NRC correspondence (50-373/98009-03(DRP); 50-374/98009-03(DRP)).
c.
Conclusions inspectors identified that the licensee planned to wait until after plant startup to resolve concems regarding the potential of insulation on RBCCW and primary containment ventilation chilled water piping to clog emergency core cooling system suction strainers.
This plan was not conservative and the licensee subsequently decided to resolve the issue before startup. This is considered an unresolved item pending further review of licensee commitments in this area.
IV. Plant Suncort R4 Staff Knowledge and Performance in Radiological Protection and Controls R4.1 Limited Manaaement Attention to Plant Hioh Radiation Areas a.
Inspection Scope (83750)
The inspectors reviewed high radiation Radiological Work Permit (RWP) records to determine if management had been in the areas of the plant where housekeeping deficiencies were identified.
,
b.
Observations and Findinas On March 11,1998, the inspectors identified that 3 of 23 managers had been in high radiation areas of the plant, which included the RHR comer rooms and the lower j
elevation areas of the reactor building surrounding the primary containment drywell (raceway). In previous inspection reports, the inspectors identified several housekeeping deficiencies in the high radiation areas of the plant listed above. Inspectors performed i
this review of the high radiation RWPs to assess the extent of management oversight in these areas.
Subsequently, the inspectors discussed the level of management attention to housekeeping issues provided through tours in high radiation areas with the site Quality and Safety Assessment (Q&SA) manager. During the discussion, the Q&SA manager stated that he had made numerous tours in the RHR comer rooms and reactor building raceway. However, the inspectors discovered that the Q&SA manager utilized an incorrect RWP for the areas he had toured.
The in;pectors verified that the high radiation area postings were clearty visible at all entry points. The inspectors also interviewed other plant managers that had not signed
___-
_ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
_
. _ _ _ __
_ _ _ _ _ _
__
_ _ _ _
- _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _
_
,
onto a high radiation RWP to ensure that they had not entered the RHR comer rooms or the other areas controlled as high radiation areas. No other unauthorized entries into high radiation areas were found and the inspectors concluded that the unauthorized entry by the Q&SA manager was an example of an individual failure to self-check and read all radiological postings prior to entering a controlled area. In addition, the radiological protection greeter program, instituted by the licenses to ensure proper RWP usage and awareness of plant radiological conditions, did not ensure in this instance that the individual understood his responsibilities when entering various radiological controlled areas of the plant.
The licensee planned to increase plant management presence in all plant areas.
Furthermore, the licensee conducted training with the individual involved and his supervision. The inspectors found the licensee's corrective actions adequate.
c.
Conclusions The lack of management attention contributed to the various housekeeping deficiencies in high radiation areas of the plant, in addition, the inspectors identified an individual failing to self check and read all radiological postings prior to entering an area being controlled as a high radiation area. The inspectors verified that high radiation area postings were adequate, however the radiological protection greater program was not fully effective in this instance.
F8 Miscellaneous Fire Protection issues F8.1 (Closed) LER 50-373/98004: Missed Technical Specification Fire Watch Due To Human Performance Error. The issues related to this LER were discussed in Section F4.1 of Inspection Report 50-373/374-98004. This LER is closed.
V. Mananoment Meetinas X1 Exit Meeting Summary
The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on April 22,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. The licensee identified none.
I
L__1 _
- - - - - _ _ _ _ - _ _ _ _ _ _ _
_-_-_ ___-____ __- _ -___ _ __ - _ _ _ _ __ ____ -________-_______ _ _-_ __ _.
- _ _ _ _ _ -
- - _ _. _ _ _ _ _ _ _ _ _ _ _ _
l PARTIAL LIST OF PERSONS CONTACTED i
i F. Dacimo, Site Vice President C. Berry, Chief of Staff
T. O'Connor, Plant Manager
S. Smith, Restart Manager G. Campbell, Engineering Manager W. Riffer, Quality and Safety Assessment Manager
G. Heisterman, Maintenance Manager D. Sanchez, Site Training Manager D. Boone, Site Support Manager D. Farr, Operations Manager M. Hill, Engineering Assurance Manager
,
H. Pontious, Acting Regulatory Assurance Manager
l P. Bames, Restart Plan Manager R. Palmieri, System Engineering Supervisor
N. Hightower, Health Physics Supervisor D. Bowman, Chemistry Supervisor J. Pollock, Support Engineering Supervisor
E. Connell, Design Engineering Supervisor
J. Henry, Shift Operations Supervisor
R. Chrzanowski, Site Quality Verification
- Present at exit meeting on April 22,1998.
i
_ - _
_
_.
. _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _
..
. -.
..
.
..
.
_
_
I INSPECTION PROCEDURES USED
IP 37551 Onsite Engineering IP 62707 Maintenance Observation IP 71707 -
Plant Operations IP 71750 Plant Support Activities ITEMS OPENED AND CLOSED Open 50-373/374-98009-01 NCV Ineffective corrective action 50-373/374-98009-02 NCV Failure to follow procedure 50-373/374-98009-03 URI NRC review of licensee responses to NRC generic communication regarding ECCS suction strainer clogging Closed 50-373/374-98009-01 NCV Ineffective corrective action 50-373/374-98009-02 NCV Failure to follow procedure 50-373/98004 LER Missed Technical Specification Fire Watch Due To Human Performance Error 50-373/374-97006-05 URI Review of check valve maintenance practices, including maintenance procedure adequacy, post-maintenance testing (PMT) practices, and the check valve program 50-37di^3022-02 IFl Developing corrective actions that address root causes of the event and developing a method to ensure consistent lubrication of DGCWP bearings l
l-
.
-_____._._---_a_-
, -a-.-.-
-.--.-
x
_ - _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ _
- _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _. ___ _ _ _ _ _ _.
l l
LIST OF ACRONYMS USED AEER Auxiliary Electric Equipment Room AR-Action Request CRD Control Rod Drive DCP Design Change Package
,
l DGCWP Diesel Generator Cooling Water Pump DRP Division of Reactor Projects ECCS Emergency Core Cooling System EHC Electro-Hydraulic Control
EPN Equipment Part Number
.
'
EWCS Electronic Work Control System FIN Fix-It-Now FME Foreign Material Exclusion IMD instrument Maintenance Department IFl
!nspection Follow-up item
'
LAP LaSalle Administrative Procedure LCO Limiting Condition for Operation LER Licensee Event Report LIP LaSalle Instrument Procedure LOCA Loss of Coolant Accident LOP LaSalle Operating Procedure MTV Mechanical Trip Valve MUDS Makeup Demineralized System NCV Non-Cited Violation NEP Nuclear Engineering Procedure NOV Notice of Violation NRC Nuclear Regulatory Commission NSWP Nuclear Station Work Procedure NTS Nuclear Tracking System OOS Out-Of-Service PIF Problem Identification Form i
PMT Post Maintenance Testing
'
Q&SA Quality and Safety Assurance RBCCW Reactor Building Closed Cooling Water System RCIC Reactor Core isolation Cooling System RHR Residual Heat Removal RWCU Reactor Water Cleanup RWP Radiation Work Permit SBGT Standby Gas Treatment System
,
URI Unresolved item WR Work Request I
l
}
26