IR 05000424/1989013

Insp Rept 50-424/89-13 on 880808-0912.Violations Noted.Major Areas Inspected:Review of 11 Inspector Followup Items & Program Weaknesses Identified in Operational Performance Assessment

ML20247M104
Person / Time
Site:	Vogtle
Issue date:	04/24/1989
From:	Breslau B, Kellogg P, Paulk C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247M088	List: IR 05000424/1988007 IR 05000424/1989013 ML20247M083
References
50-424-89-13, NUDOCS 8906020361
Download: ML20247M104 (11)

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. UNITED STATES ' 2

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101 MARIETTA STREET,N.W.

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1. LLicenseel Georgia 1 Power Company

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• Atlanta,.Ga. 30302~ '

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..: Docket.No.: 50-424 .

License No.: NPF-68  :

Facility Name: LVogtle 1.- ] :

N Inspection: Conducted: March 27 31, 1989- < j

' Inspector: 4l /98Y

' B. Breslau '

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Approved by: a

'. . K411ogg, fateSigndd '!

0perational Programs $fle Section  ;

Division of' Reactor' Safety  !

SUMMARY-  !

Scope: This' routine announced inspection was conducted as a follow-up to h r the'0perational Performance Assessment (OPA)Leonducted August 8 -

September 12, 1988, Inspection Report No' 50-424/88-33. The scope . i of.this. inspection inclu~ded review of eleven inspector follow-up  !

i items as well'as those' items. identified in the OPA as program' a weaknesses,or concerns,. Additionally, items from inspection' reports ~ l-424/86-117,'88-07,'and 88-75 were reviewed to assess the licensee'sL 1 corrective actions concerning four items which had'not'previously  ?

received adequate corrective actio !

Resul'ts: Increased management attention to corrective actions ~is neede The? i initial corrective actions for the following items were not adequate: l

' Incorporating TS cooldown limit curve.in the requalification- i trainin . Review of operations with a ground on the. vital DC bu ;

' Conduct of audit on FASR, controlled copy 12 i Corrective action for a violation concerning failure to -l review the operations required reading boo "

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- Subsequent licensee action during this inspection adequately corrected these-items except for items 4 and 5. Item 4 will be closed and a repeat Violation will be issued with additional examples, paragraph Another Violation was noted for failure to follow procedures, l

. paragraphs 2-.a and l

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i REPORT DETAILS i Persons Contacted j t

LLicensee employees- j EV ; Agro, Superinte'ndent, Plant Administration

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7* Frederick,;QA. Site Manager - Operations

• W.(Kitchens, Assistant Generc1 Manager

• A; Mosbaugh, Performance Test Support. Manager

• Nicklin, Compliance Supervisor ,

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• J. Swartzwelder, Operations Manager Non-Licensee Employee,:0glethorpe Power Corporation

• E-.= Toupin~, Superintendent Nuclear Operations

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Other L: licensee ' employees contacted included instructors, engineers, technicians,. operators, and-office personne .

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NRC Resident Inspectors .l

• R. Aiello, Resident Inspector l

• Attended exit' interview d i

2 .- ' Action on Previous Inspection Findings (92701, 92702)  !

(Closed)LInspector Follow-up Item 424/86-117-09, Review of' Reactor Vessel Level. Indication System (RVLIS).  ;

q The concern that the operator would not have-indication of the failure of !

~ a hydraulic isolator was identified. in a previous inspection. A review of- ,

the RVLIS display showed that the level indication was available on th l general display screen. If a ' hydraulic isolator failed, the level 1 indication would indicate that' the data was bad or invalid, therefore, the .j operator does have indication of the failure. Basec on this information, i this item is close (Closed) Inspector Follow-up Item 424/88-07-02, Licensed operators .were j not reviewing the required reading book, this and other deficiencies noted 2 constituted an apparent violation. However, the licensee identified this weakness and was implementing corrective actions. This item was subsequently reviewed during inspection 424/88-33. The inspectors noted that licensee corrective actions were inadequate in that several operators were not reviewing the required reading book in a timely manne ' Inspection report 424/88-33 issued violation 88-33-05 citing inadequate corrective actions for this finding, therefore, this Inspector Followup Item is considered close '

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. ' (Closed) Inspector Follow-up_ Item 424/88-07-03, Use' of. Technical Specification-(TS) Cooldown ' Limits Curve in Requalification Training for, Licensed l 0perators. Discussions with the . licensee -indicates the lesson

% plans. associated with. this concern; did not receive L adequate L corrective actions'by December. 16, 1988. Training conducted after this date did. not contain the updated TS cooldown curve. Subsequently during this inspection,

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adequate corrections were implemented and issued.in requalification training lesson. plan', LO-LP-35205-04, this item is considered closed. However,:it-represents'an additional example of Violation 424/89-13-01, failure'to take, s adequate'. corrective ' actio (Closed)' Violation ~ 424/88-33-01, Failure to Perform a Safety . Evaluatio ~

for a Chan'ge to an Annunciator' Described in the Final Safety' Analysis

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The licensee ' denied that. this violation occurred in its response dated -

November.15, .1988. _ Af ter reviewing the response, the NRC _ determined that the violation. occurred as stated for the reasons provided in our letter to the; licensee dated January 20,.1989. In its response, the licensee submitted ' proposed enhancements that would ensure that the forceful

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implementation of the " black board" concept will not inadvertently hide system : problems. These enhancements included procedural revisions 'and

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changes ~in the method by which annunciator problems are handle The licensee revised the Annunciator Control procedure, 10018-C, on February. 3,1989. The revision added a flow chart that is to be followed when alarms are received. The flow chart leads th_ rough decisions that

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s include. checking for multiple inputs and provides directions on how to handle:such annunciator The Temporary. Jumper and Lifted Wire procedure, 00306-C, which ' i s referenced by '10018-C, was revised on March 10, 1989. This revision

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requires'"the prompt restoration of multiple input annunciators prior to a work order issuance for repair." ~It also requires an expedited review by engineering when a temporary jumper / lifted wire is needed to restore alarm functions for multiple input annunciator The individual who is restoring multiple input annunciator functions is also required to contact the Unit Shift Supervisor to request a Jumper and Lifted Wire clearanc These revisions were reviewed and found to be adequate to prevent recurrence of the violation. Based on the actions taken, this violation is close (Closed) Inspector Follow-up Item 424/88-33-02, Review of Operation with a-Ground on the Vital Direct current (DC) Bu During a previous inspection, a concern was identified relating to operation with a ground on the vital DC bus. The concern raised by the inspector was why management allowed prolonged operation with a ground on

> the " ungrounded" vital DC bus. In the original information provided by the licensee during this inspection, the licensee did not address this ,

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issu Discussions with the licensee. indicated that they had a different understanding of this item and answered it accordingl The licensee stated that the item would be reopened and resolved to satisfy the concer The lic'ensee issued an ' Operations Policy Memo on March 30, 1989, addressing the actions to be taken in the event of a groun These actions ure to prepare and submit a Request for Engineering Review to have the condition evaluated. The licensee stated that these requirements -i would be added to the z.pplicable procedures. Based on the above, this item is close (Closed) Violation 424/88-33-03, Failure to Control the Issuance of l Documents, Including Changes, Which Prescribe Activities Affecting Qualit The' licensee admitted that this violation occurred, as stated, in its i respense dated November 15, 1988. The licensee stated that the corrective actions would be completed by December 31, 198 '

The licensee presented a letter stating that the audit of FSAR Copy 125 -

was completed on December 9, 1988. There was, however, no documentation as to what discrepancies were found or how they were corrected. The licensee had committed to performing a total audit of FSAR Copy 125, but Document Control only performed a page-by page review, replacing missing or incorrect pages without noting which pages were involve Document Control stated that they were not auditors and did not know that they needed to document their actions for the audi The licensee provided a memo dated March 30, 1989, signed by the Document Control personnel who performed the verification, that stated FSAR Copy 125 was accurate and up to date on December 9, 198 A survey, not a quarterly audit, of changes to the FSAR was commenced on March 30, 1989, and completed on April 3, 1989 by Document Control personnel. The survey identified several pages that either should be removed or deleted from the FSAR as well as some missing pages. Included in the missing pages was all of Table 9A.2, and Sheet 90 of Table 3.3.3- Table 3.2.2-1 was the table identified in the violation and, as stated above, was reportedly corrected on December 9, 198 l Based upon the above signed statement from the Document Control personnel l who performed the verification in December, and the survey that was recently completed, this violation is close However, the failure to ascertain the root cause of FSAR Copy 125 missing pages and sections and correct the problem is identified as an example of Violation 424/89-13-01, Failure to Take Adequate Corrective Action to Prevent Recurrenc i

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(Closed) Inspector Follow-up Item 424/88-33-04, Ability of Plant Equipment-

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Operators (PE0s) to Gain Access in the Event Power is Lost- to the Card

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'have'to return to the control room before they could obtain a key if a security power failure were to occu The licensee revised the Plant Lock and Key. Control procedure, 00008-C, to allow Vital Area Master Keys to be issued to Operations Department shift positions. Additionally,, the Plant Equipment Operator Relief Checklist procedure, 11873-C. was revised to assign accountability of the Vital Area Master Keys to the Operations Department shift positions. .The keys were then laminated on a card and issued to the Auxiliary Building Operator, f 'the Turbine Building Operator, and the Outside Area Operator. This method did not prove to be. effective because the laminate would come off and the keys'would become accessible'.

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On March 28,-1989, the licensee issued an interoffice correspondence to L all _PEOs that described a new, method of obtaining vital area access in the event power was lost to the card-readers. The: Auxiliary Building Operator Jand .the Outside Area Operator will each be issued a key to open-the door to the Control Room where the-Unit One Shift Supervisor may issue Vital

- Area -Master Keys as- needed from the breakglass box. Based on the above, this item is close (Closed) Violation 424/88-33-05, Failure to Take Corrective Action in the-Case of Significant Conditions Adverse to Quality in Order to Prevent Repetitio The licensee admitted that this violation occurred, as stated, in its response dated November 15, 1988. The licensee stated that full compli-ance was achieved October 12, 198 The licensee revised the Operations Reading Book (ORB) procedure,10017-C,

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on October 12, 1988. This revision increased the time allowed to read the material to five weeks and required an audit every five weeks. The first L audit was performed on October 18, 1988, and four people were found to be

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delinquent. The ne.xt audit identified eighteen people delinquent, two were repeats from the first audit. The large number was attributed to changing the format of the ORBS and implementing the revised procedur .o As of March 29, 1989, nine of these individuals had not read tne missed  ;

reading requirements. The next two audits did not identify anyone as  !

being delinquent. The fifth audit identified four who were delinquent, one individual failed to review the required reading book on three occasions and two others were noted as repeat offenders for not reviewing L the required reading book. None of these had read the missed assignment The audit that was performed on March 28, 1989, during this inspection, identified three as being late, two of whom had been in licensee training clas l L

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.The-Operations Superintendent. issued a memo to all who had not read missed Assignment The memo required the personnel identified 1to read the material and sign the list in the Service Building when'it .was accom-plishe As part of uthe' corrective action for this violation, the licensee takes This program calls for a

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credit for its' positive discipline progra k a z verbal counselling for the firs offense, a written reprimand for the second offense',. and an : entry 'into the personnel - file for the thir [ Although this was .to be part of the corrective action, repeat offenders were.' only " coached" on each occasion. The licensee stated that the responsible' supervisor was. unaware of the fact that the individual was a repeat 1 offende This part of the corrective action is considered K ineffectiv The procedure', 20017-C, requires that the material _ remain in the books for five weeks and then be removed. When it is removed, it is to'be checked to see if all have read the material. It is implied, but not stated, that

', the- offenders' supervisor (s) will be actified. This is not occurrin Sometimes the material may remain in the books for-up to nine weeks before removal,"according to the person.who does the audits. When it is removed, the five ' week audit is usually performe During the audit, -the auditor does not verify that- the sign-offs were performed during the required time period, only that they are.there. This was one of the issues identified

'in the inspection that resulted in the violation and it has not been correcte Licensee management stated that the material placed in the required reading books was not required for the operator to be able to perform his ,

day-to-day duties. A sampling of the materials in the ORBS indicated that '

technical specification interpretations, FSAR changes, diesel procedure

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interpretations, and fire protection system information were included ~ in L ,

the. required reading. These appear to be more than just for information purposes only. The ORB procedure requires that the material be read within five weeks and that it is the " duty and responsibility" of the operator to read the material. The procedure does - not state that the operator-does not have to read the material if it is more than five weeks old, but implies that it must be read and signed fo .

'This item will be closed and a repeat Violation, 424/89-13-01, Failure to-Take Adequate Corrective to Prevent Recurrence, will be issued with additional examples as noted in other paragraphs of this repor .(Closed) Violation 424/88-33-06, Failure to Revise the Analog Channel l

Operational Test Procedure to Contain the Correct Calibration Dat The licensee denied that this violation occurred in its response dated p

November 15, 1988. After reviewing the response, the NRC determined that the violation occurred as stated for the reasons given in our letter to the licensee dated January 20, 198 l i

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The licensee revised the procedure for the trip'le range catalytic combustion analyzer, 24546-C, on August 29, 1988. Based on the revision of the procedure, this violation is close (0 pen) Unresolved Item 424/88-33-07, Review of Acceptability of the Use of a Single Battery Charger on Class IE Batterie The issue of using a single cell battery charger on safety related t batteries was identified at another facility prior to being identified at Plant Vogtle. The licensee has performed evaluations for use of the chargers and reviewed the use of two safety related breakers to provide separation between the non-safety electrical distribution and the IE component The licensee agreed during the previous inspection that the charger would not be used until the evaluation by NRR has been completed for the other facilit Based on the above, this item will remain ope (Closed) Inspector Follow-up Item 424/88-33-08, Review of the Written Trigger Mechanism for Containment Air Lock Surveillance and NRC Review of the Discrepancy Between 10 CFR 50, Appendix J, and TS Regarding Testing After Opening or Closing the Air Loc The concern regarding the trigger mechanism to require the surveillance on the containment air lock was identified during previous inspections. The issue was the wording of the licensee's procedure, the wording of the technical specifications, and the wording of Appendix Appendix J requires that the surveillance be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of opening a containment air lock. The technical specifications state that the time clock is started upon closing an air lock. The procedure agreed with the technical specifications on the surface. The actual practice at Plant Vogtle did not correspond to what was written in the procedure The time clock started when the first door that was opened was closed as the personnel entered the air lock. This is essentially the same time as opening the door,,however, the words say closing. The licensee interprets these as being the same time and has not exceeded any time limits to dat The licensee did agree to revise the Containment Entry procedure, 00303-C, to clarify that the time clock is started upon the initial entry. A marked up copy of the change was provided to the inspectors and was found to be acceptable. Based on the above, this item is considered close (Closed) Violation 424/88-33-09, Failure to Wear the Required Personnel Monitoring Device and Picture Badg A review of the licensee's corrective actions, which included performing a dose rate survey in the area where the individual was working; retraining, and personal counseling by the Health Physics Superintendent, is considered to be adequate for prevention of recurrence of this inciden l Administrative controls were not a contributing factor to this incident, this item is considered close _- _

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(Closed) Violation 424/88-33-10, Failure to Periodically Calibrate Nuclear

' Service Cooling Water Level Transmitters 1-LT-1606 and 1-LT-1607 and Letdown Flow Instrument FT-132 as Required by TS 6.7.1 and 6.7.4,

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Respectivel A review of the licensee's corrective action revealed that the subject components were calibrated and added to the Planned Program for Scheduling and performance. . Additionally, the licensee has re-reviewed Regulatory Guide (RG) 1.97 associated instrumentation and confirmed applicable instruments to' now have a surveillance or repetitive task assigned to I routinely maintain calibration. This item is considered close (Closed) Unresolved Item 424/88-33-11, Review the Plant Programs Covering Periodic Maintenance, Surveillance, and Operations Procedures to Confirm ;

That All RG 1.97 Instrumentation Is Covere A review of the licensee's corrective actions indicates that RG 1.97 instrumentation has been included in the system for surveillance monitorin This item is considered close (Closed) Inspector Follow-up Item 425/88-75-02, The licensee committed to review its procedure for shutting down the reactor and evaluating system /

component challenge The licensee revised procedure 12004-C, Power Operations, Revision 1 This change reflects a procedural change from tripping the reactor first at 20 percent power and forcing P-4 to trip the turbine generator, to tripping the turbine generator first followed by a reactor trip, thus not forcing P-4 to protect the turbine generator. This item is considered close i Additionally, inspection report 88-33 noted areas considered to be weak, ,

these area will be referenced by their respective paragraph numbers and !

discussed as follows:  ! Paragraph 2.a.(3) indicated that logs were not always documented as required. A review of the logs sampled during the previous inspection was performed and resulted in the same finding that the log reviews were not being documented in accordance with the procedure The Information Tag Log review was not being documented in the leg index monthly as required by procedure 10009- The Annunciator Status Control Log was missing the weekly review for the weeks of Januery 20 and 27,1989. These will be identified as two examples of Violation 424/89-13-02, Failure to Follow Procedure i- _ 1

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~ P b f Paragraph- 2.a.(5) identified a weakness withi the issuance of; as-built - notices T( ABNs). This issue was reviewed by 'the H

~ . inspector and the'same issues still existed as was noted in

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These conditions involved the~ use of a red stamp' to notify the 4 Q'

operator to check for ABNs or other cha'nges to ' the drawin ~

, ' While the' use of -such a stamp is considered an adequate method -

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ic ' for . identifying changes .to drawings, the.. application of the

,P  ! stamp is not controlled by procedur This resulted in many

' discrepancies in the marking of the' drawing ? Another1 condition that' was previously noted concerned the -

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<1egibility of the. drawings. Although drawings were legibility, many..were still difficult to read. ~This is due to either a poor reproduction. process or to poor quality orid nals. The resident inspector.will be monitoring the licensee's actions to improve legibility of drawing A new issue was identified during this inspection that involves 7^

the issuance of ABN Procedure 00101- C , Drawing Control Revision 6, states that "(a)11 controlled distribution of drawings, = ABN's and Design Change Notices issued by Nuclear Operations- shall be on yellow paper and distributed in accordance with the Drawing Distribution Matrix." . Issues of ABNs on white paper were found that dated as far back as August

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198 The licensee stated that, in order o issue the ABNs

. within a few hours, the ABN would - be issued en white paper 1 initially and replaced with .the yellow copy within-a few day Eventhough the licensee had procedures to control these actions, a conscious decision was made to deviate from the procedure without attempting to revise the procedure to address the actual

• method of controlling the drawings. .This is identified as another ' example of Violation 424/89-13-02, Failure to Follow Procedures ~. Paragraph 2.a.(6) identified a weakness that concerned not

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issuing temporary changes to procedures (TCPs) with the working K copies of the procedures. The licensee committed to issuing the _

m TCPs with the working copy and to place the TCP -in the Nuclear Operation Records Management System. Both of these commitments were verified by the inspector as having been implemented and the weakness corrected, o , Paragraph 2.a.(8) identified a weakness in labelin The !

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licensee has developed a program to upgrade labeling throughout i both unit This program is a long term project, however, progress was apparent and the effort should result in a strong labeling program, Paragraph 2.a.(9) identified a weakness in allowing fire doors to remain ajar when passing throug No occurrences were observed during this inspectio ,,

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1 Paragraph : 2.a.(10) identified - a~ weakness in ensuring that Controli Room recorders were inking and' operating properly. -The Resident' Inspector cited the;1icensee for'this same weakness'in a subsequent report. ..The licensee responded and the Resident'

Inspector closed out the violatio page; 22 indicated that the licensee-~ had

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g .- ; Paragraph . experienced problems in scheduling and completing surveillance-

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The. inspector reviewed procedure 00404-C, Surveillance Test Program, Revision 10. This procedures provides administrative controls and responsibilities ' for identifying,. scheduling, performing, and tracking. of surveillance to satisfy TS, ASME-Boiler & Pressure Vessel code Section XI items and -identifies -

other commitments determined by. the General Manage Addi-

.tionaly, the inspector interviewed individuals responsible for administering the surveillance test program and work planning control; reviewed the tracking and alert mechanism implemented, and t noted that the licensee has taken positive control, this F .. area is no longer considered a weaknes Paragraph 4.6 noted that .the qualifications of the auditors

' performing the operations audits indicated an overall lack of commercial nuclear power experienc The licensee has 'not integrated additional personnel into the Quality: Assurance (QA) group who possess adequate commercial nucla r power experienc The licensee's plan to include additional individuals with operations experience and rotation of individual from the Operations group into QA -for periods of time has not materialized. However, the licensee has taken action to supplement their audits with outside experience when areas are questionable to the experience level of their auditors. This was confirmed by the inspector upon review of completed audits since this item was previously noted. This is considered an adequate method for addressing the lack of o commercial nuclear power experience issu . 3'.-

Exit Interview (30703)

The inspection scope and results were summarized on March 30, 1989, with those persons indicated in paragraph 1. The inspectors described the inspection findings and discussed in detail the inspection findings belo No proprietary information is contained in this inspection report.

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,. 10 i --  :. Item Number' . Status Description / Reference Paragraph 424/89-13-01 Open Violation - Inadequate corrective action (paragraph 2)

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f: 424/89-13-02 Open Violation - Failure to follow procedure,

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(paragraphs 2.a & 2.b)

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