IR 05000528/1992041
ML20128A009 | |
Person / Time | |
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Site: | Palo Verde |
Issue date: | 01/13/1993 |
From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
To: | |
Shared Package | |
ML20127P830 | List: |
References | |
50-528-92-41, 50-529-92-41, 50-530-92-41, NUDOCS 9302020093 | |
Download: ML20128A009 (23) | |
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- U. S. N'101LM,BMildORY C0'tiSSLQH
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Bf.GT0ff V EcpotLiton 50-528/92-41, 50-529/92-41, and 50-530/92-41 pseket f!pi,, 50-528, 50-529, and 50-530 Licitu1 &LL llPF-41, ilPT-51, and liPF-74
Licenan Arizona Public Service Company P. O. Box 53999, Station 9012 Phoanix, AZ 85072-3999 fatjlity 14amt Palo Verde 11uclear Generating Station Units 1, 2, and 3 JaiM1(Led 1 fiovember 3 through December 14, 1992
[paducted in_spectors J. Sican, Senior Resident inspector 11. Freemar, Reactor inspector D. Kirsch, Technical Assistant F. Ringwald, Resider.t inspector T. Sundsmo, Project inspector Appraved by khr-h IE'V6ng,~ Chief ~ ~
t Q5L 1-\?,,A'.$
Dia'te signed Reactor Projects Se:: tion 2
InsottijAq_ Summary:
Ar3as Inj s eted: Routine, onsite, regular and Lackshift inspection by the resident inspectors and three Region V petsonnel. Areas inspected included:
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e review of plant activities
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- engineered safety feature system walkdown - Unit 3
- surveillance testing - Units 1 and 2
- plant maintenance - Units 1, 2, and 3 l~
- preparations for potential operation at reduced inventory - Unit 1
! * reactor trip with safety injection and containment isolation actuation - '
Unit 2
- emergency diesel generator inoperable - Unit 2
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- coitainment integrity - Unit 3
) * refueling water level ir,dication error - Unit 3 a post-refueling restart - Unit 3 *
- quality assurance audit review - Units 1. 2, and 3 g
- fcilowup on previously identified items - Units 1, 2, and 3 L * review of licensee event reports - Units.1, 2, and 3
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l L During this inspection the following Inspection Procedures were utilized:
. 9302020093 930113?
li PDR ADOCK 050005.20 PDR:
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35701, 42400, 61702, 61706, 61707, 61708, 61709, 61710, 61715, 61726, 62703, 62705, 71707, 71710, 71711, 72700, 92700, 92701, 92702, and 9370 FJfall.in Of the 14 areas inspected, one non-cited violation in Unit 2 was identified regarding failure to follow work control procedures and one non-cited violation in Unit I was identified regarding the premature signing of an independent verification ste fitDfral Conq)gsiqos and_Sanjf_Lc_[jfidinast linn.i.fJcant&fetLinit.t.ru i t tione Violatiplin Two tion-Cited Violations - Units 1 and 2 DAYlittipJln lione
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DerILit.ml 3 new followup items were opened, 11 followup items were closed, and 2 followup items were left ope ElrfngthLJp.lgdi t The licensee's preparations for planned Unit 1 mid-loop operations, including management review, training, and ,
independent Safety Engineering support, were very goo The Unit 3 refueling outage appeared to be well-manage ,
Additionally, Quality Assursnce performed a very good audit of operations / technical specification f FfAhnenDLjolffl i Some maintenance activities are not being completed c properly, as evidenced by the use of incorrect oil hnd the *
failure to install all fasteners upon work completio Vendor information was not thoroughly incorporated, resulting in an avoidable reactor trip, and the licen>ce had to be prompted by the NRC to contact the vendor before this information was recognized. Monitoring was inadequate to prevent inoperability of an Emergency Diesel Generator due to low Jacket water temperatur <
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Dilldt.5 ' Ec.tsons Contacted The below listed technical and 1,upervisory personnel were among those ,
contacted:
Anttop Public Service (APS)
- R. Adne Plant Manager, Unit 3
- D. Blackson, Manager, Central Maintenance 1 4R. Bernier, Supervisor, Nuclear Regulatory Aff airs, Technical
> #*T. Bradiah, Manager, Nuclear Regulatory Affairs
- T. Canno Assist: int Manager, Plant Engineerin . ,
- J. Dennis, Manager, Operations Standards Procurement Engineer, Vendor Engineering Group 's,
- N. Eidsmoe,
- R. Flood, Plant Manager, Unit 2 -
- M. Friedlander, Manager, Procurement Engineering Departmer,t-
- +R. Fullme Manager, Quality Audits-and Monitoring 4
- R. Gouge, General Manager, Plant Support 4W. Haruden, Engineer, ISE ; ,
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f -+ Ide, Plant- Manager, Unit 1--
'R. Kerwin, Manager, Site Maintenance & Mod *D. Lamontagne, Supervisor, Procedure Engineering PE&P
- J. Levine, ' Vice Prasident, Nuclear Production- -
4R. McKinney, Operations Supervisor, Unit 1
- W. Montefour, Senior coordinator, Owner Service o
- D. Mauldin, Director, Site' Maintenan .e and Modificat'ons
- J. Napier, Cogineer, Nuclear Regulatory. Affairs, Operations
+ Penic Srpervisor, ISE :I,
- 4L. Perea, Plant Engineering
- F. Riedel, Operations Mana er, Unit-L
- R. Roehler, Supervisor, Nuc ear Regulatory Affairs, Operations -[$'
- 4R. Schaller, Assistant Plant Manager, Unit 1
- T. Shriver, Assistant Plant Manager, Unit 2 Electrical Supervisor, Maintenance Unit 2
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iM Stewart, f (D. Withers,. Plant Engineer Site ReprJsentallyga
- J.. Draper, Site ' Representative, Southern California Edison - ,
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- R. Henrf, Site Representative, Salt River Project
+ Denotes personnel in attendance at the Exit meeting held with NRC Region ,
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V personnel on November 10, 1992.-
- ' Denotes personnel in attendance at the Exit meeting held with the NRC resident inspectors on December 14, 199 # Denotes personnel'in atter, dance at the Exit: meeting held with the NRC resident inspectors on December 21, 199 .
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-The inspectors also interviewed other licensee and contractor personnel i during the course of the inspectio _ Review ofRut Activities - U,n,itLL 2and 3 (717071 ; Unit 1 The unit operated at essentially 100% power throughout the !
ir.spection period except for a reactor trip which occurred on j Dorem%r 8,1992 (paragraph 7). The unit restarted on December 10, 1992, and returned to 100% pow 2r on December 12, 1992, where it remained through the end of the inspection period, ML1 ,
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The unit operated at essentially 100% power throughout the inspection prriod except forLa reactor trlp, safety injection: I
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actuation, and containment isolation actuation which occurred on November 13, 1992 (oarayaph 8). Tha unit restarted on November 15,
1992, and returned to 100% power on Dece.nber 12, 1992, where it "
remained through thC end of-the inspectiort perio M (
Unit 3 entered this inspection period in Mode 6 in the midst of a refueling outaga. Mode 5 was. entered on November 7, 1992. Mode 4 ;
was entered on Novesber 18 and Mode 3 was ent> red on November 1 The reactor was brought to criticality at 1:02 AM on' November'23, ;
e M 2. Following power ascension to Mode 1 on Novembcr 24, problems ;
with the permanent magnet generator on the main turbine caused the-operators to briefly roenter Mode 2 before returning to Mode 1 and synchronizing to the grid on November 25, ending the outage in just under 68 days, two days ahead of schedule. The unit proceeded with- "
a nornial ascension to 100% power. failure of-the water seal on.the
"B" condensate pump _resulted in a more cautious approach to full .;
power due to concerns over being able to maintain adequate main :
feedwater pump suction pressure with only two condensate pumps x ,
available. The plant operated at essentially 100% power for the ,
remainder of_the inspection perio .
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The following plant areas at Units 1, 2,l and 3 were toured by the -<
inspector during the inspec. tion:
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o Auxiliary Buildin o Control Building o Diesel Generator Building-
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o . fuel ' Building .
o Main Steam Support Structure :1 o Redeasto Building
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o Turbine Building o Yard Area ant Perimeter o Containment Building lhe following areas w9re observed during the tours:
(1) DParA1109J,AaLand Rewdi - Records were reviewed against technical specification and administrative control procedure rc7>irement (2) M2R112rinn_inshumant31ja0 - Process instrumer.ts were observed for correlat tween channels and for conformance with technical sp .ation requirements.
(3) Mt.i._Slaffing it - Control room and shif t staffing were observed for confortnance with 10 CFR Part 50.54.(k), technical ~
r specificetions, and administrative procedure (4) EqulRMat llDfML1 - Various valves and electrical breakers were verified to be in the position or condition required by technical specifications and administrative procedures for the applicable plant mod (5) [9gJnmlnLJA991ag - Selected equipment, for which tagging requests had been initiated, was observed to verify that tags were in place and the equipment was in the condition specifie (6) kneraLPjnt_Laufpgathndit_i_o.hi - Plant equipment was observed for indications of system ieakage, improper lubrication, er other conditions that could prevent the systems from fulfilling their functional requirement The inspector noted missing fasteners in Unit 3 on the "A" containment spray pump motor (see paragraph 3), on containment electrical ;)enetration 3EQFNZ570, and on electrical junction box 3ECPNJll. These discrepancies indicated possible poor post-maintenance restoration. While these discrepancies appear to be insignificant with respect to nuclear safety, they were
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all obvious and should have been identified by maintenance, ,
Quality Control, or operations personnel. The licensee initiated Material Nonconformance Reports for eats piece of '
equipment and completed work orders to install the appropriate fasteners. The inspector concluded that the licensee's
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immediate corrective actions were adequat On November 23, 1992, the inspector was informed that the Unit I reactor coolant pump 2A m: tor oil level had lowered to below the alarm setpoint. The plant engineer was contacted and the condition was evaluated. Level was slightly below the plant
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computer alarm setpoint of 28.3% of the indicating rang >
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The plant engineer determined that 0% of the indicating range was approv.irnately 16 inches above the bottom of the reservoir, and still sufficient oil for the lower bearing The plant engineer's history of level and temperature revealed that there has not been appreciable level change and no temperature trend since the last refueling outage. The plant engineer suggested that the best indication of a problem, es)ecially if level indication was lost completely, would be acaring temperatur As a result, operations issued a night order describing the situation, and also added a check of oil level and bearing temperature to the shiftly control room data sheet. The inspector concluded that this action appeared appropriat (7) Fire protegli.ta - Fire fighting equipment and controls were observed for conformance with technical specifications and administrative procedure (8) E] Ant _Chemitir_y - Chemical analysis results were reviewed for I conformance with technical specifications and administrative control procedure '
(9) jitcntty - Activities observed for conformance with regulatory requirements, implementation of the site security plan, and administrative procedures included vehicle and personnel access, and protected and vital area integrit Two security issues were identified and passed to Region V Safeguards inspectors for followu ,
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(10) Ela,n.tJousekeer'ing - plant conditions and material / equipment storage wcre oi, served to determine the general state of cleanliness and housekeepin (11) Ra_dlation protection Controh - Areas observed included cortrol point operation, records of licensee's surveys within the
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radiological controlled areas, posting of radiation and high radiation areas, compliance with radiation exposure permits, personnel monitoring devices being properly worn, and personnel frisking practice (12) Shift Turpoyn - Shift turnovers and special evolution briefings were observed for effectiveness and thoroughness, fio violations of NRC requirements or deviations were identifie . Enginetrid Safety Feature (ESF) System Walkdowns - linit 3 (717101 An engineered safety feature system was walked down by the inspector to confirm that the system was aligned in accordance with plant procedure During this inspection period the inspectors walked down accessible portions of the following system,
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"A" Containment Spray During a walkdown of the "A" Containment spray system on December 1, 1992, the inspector observed that five bolts were missing from the motor r casing and electrical connection cover. The licensee initiated a Material fionconformance Report to document the condition, and replaced '
the fasteners on December 9, 199 The inspector concluded that post-maintenance restoration of the motor ;
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was incomplete and subsequent routine plant walkdowns were not thorough enough to identify these obvious deficiencies. Immediate corrective action was adequat :
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No violations of flRC requirements or deviations ere identifie . Eigygi_1]ance Tq.stino - Unit s 1 and 2 (61726).
Selected curveillance tests required to be performed Dy .he technical specifications were reviewed on a sampling basis to verify that: 1) the surveillance.tasts were correctly included on the facility schedule; 2) a technically adequate procedure existed for performance of the >
surveillance tests; 3) the surveillance tests had been performed at the frequency specified in the technical specifications; and 4) test results satisfied acceptance criteria or were properly dispositione ,
Specifically, portions of the following surveillances were observed by the inspector during this inspection period:
Unit _1 frpcedure {Lq1erintion 36ST-9SE12 Excore Safety Channel Calorimetric Compensation 73ST-9CLO7 Containment Ventilation Purge Isolation Valves (8")
Penetration 78 & 79 On December 4,1992, the inspector observed a portion of surveillance-test 73ST-9CLO7 in Unit 1 on CP-UV-4A and 5A, At the conclusion of the test the inspector noted that the LLRT technician initialed step 8.2.17 verifying that the test equipment had been removed and that the valve was i shut following step 8.7.17, and .the mechanic signed the independent verification block, before an independent verification had taken plac The inspector immediately questioned the technician and was told that the independent verification took place because the technician watched th mechanic close the valve. The inspector also noted that operations was planning to follow their standard practice to have an auxiliary operator
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verify the valve closed after the test was complete. Several hours later, the technician told the inspector that an independent verification-was performed by climbing on' top of the cabinets located in the rorn .
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after the inspector raised the question. The inspector-asked the -
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supervisor whether climbing on the cabinets was in accordance with the licensee industrial safety policy. The licensee initiated Condition-Report /Dispnsition Requer- '(CRDR) 0-2-0740 to evaluate these events. The i'
i licensee determined that imbing over the cabinets was not in accordance
with the licensee industrL. safety policy and the technician was ,
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counselled in accordance with the licensee positive discipline progra In addition, the licensco determined that there appeared to be some :
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confusion over who should be signing the independent verification block of the procedure, and issued a clarifying memo. Licensee procedure 02AC-OZZ01, " Independent verification of Valves, Breakers and Components," !
step 3.1.2, requires independent verification when two _ individuals-working together to cause the independent verification to be i
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... completely separate and independent of the initial alignment....The l individual performing the independent verification must not rely on the '
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observed actions of the individual performing the initial alignment...to determine the correct component identification, position, or condition." i I
Step 3.8.2 requires that " ..both the initial and independent verifier will indicate performance by initialing, or signing, and dating the aaplicable step, log entry or line up sheet." The inspector concluded t1at at the time the surveillance test procedure independent verification-block was signed, no independent verification had taken plac The violation is not being cited because the criteria specified in Section Vll.B of the Enforcement Policy were satisfied (NCV 528/92-41-05). lhe; ,
inspector finally concluded that the corrective actions taken oppeared appropriat Mnit 2 ,
Procwh Deseription ,
36ST-95B13 Supplementary Protection System functional Test Procedure 36ST-95B28 pPS Inpot Loop Calibration for Parameter 13, High *
Containment Pressure 42ST-2RC02' RCS Water Inventory Balance 4.4.5.2. One non-cited violation of NRC requirements was identifie . ElAp_t_JJainte_u ngs_,_9A i ts 1. 2. and 3 (6270J ansi 62705)
During the inspection period, the inspector observed and reviewed selected documentation associated with maintenance and problem
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' investigation activities listed below to verify compliance with regulatory requirements, compliance with administrative and maintenance procedures, required quality assurance / quality control-department involvement, proper use of safety tags,_ proper equipment _ alignment and use of jumpers, personnel qualifications, and proper retestin The- J
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' inspector verified that reportability for these activities was correc '
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Specifically, the inspector witnessed portions of the following i maintenance activities: -
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"A" Reactor Trip Breaker Troubleshooting
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o "B ESI' DC Equipment Room Air Cooling Unit Insulation Reinstallation f
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o "B" Emergency Diesel control Room Air flow d/p Switch Calibration On November 18, 1992, the licensee reviewed oil sample analysis results :
from the Unit 1 "A" essential spray pond pump motor. This analysis f'
indicated that the incorrect oil had been ..dded to the reservoir sometime '
during the previous six months. The licensee initiated Condition Report / Disposition Request (CRDR) 1-2-0573. While the closed CRDR did not contain the complete licensee conclusion, the inspector discussed this with the General Manager of Maintenance and Modifications, who _
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stated that the licensee had concluded that this was a personnel ,
performance issue, and not an additional example of programmatic
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weakness. An engineering evaluation _ concluded that the incorrect oil was compatibic with the correct oil and that the mixture did provide adequate ,
lubricatio The CRDR investigation determined that the mechanic obtained the incorrect oil from a container with a label marked Tellus 32 -
which had been obscured such that only the 32 was visible and was confused with the required shell turbo 32. The inspector concluded that -r this error was not complicated by the programmatic concerns regarding mis-oiling addressed in Corrective Action Report 91-0005. The inspector concluded that the licensee's actions appeared appropriat t
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W11L2 o Troubleshooting Spurious Alarms on fire panel 2JQVJiE120 +
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o- Emergency Lighting Battery QDil-t102 Test Discharge
- o Emergency Lighting Battery QDil-N02 Recharge
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fio violations of f1RC requirements or deviations were identifie . preparations fan _Mential Opention qLh!jtged inveninty - Vatt_LDE01
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mL.4fl01).
As a result of a small primary-to-secondary leak in' Unit I steam
generator 1 (about 1.4 gallons per day), a regional inspector was
, dispatched to the site to assess the licensee's pre-outage preparation for_ potential operation at reduced inventory in the Reactor Coolant - ,
System, if the . decision was made to shutdown and repair the lec The--
i following general activities were examined:
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o the degree of management involvement and oversight to the outage-pl anning , .
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o the methodology f or scheduling and control of activities focusing on -
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.i the. control of significant work activities and the availability of electric power supplies, decay heat removal systems, reactor coolant inventory control systems and containment integrity, and o the operator response procedures, contingency plans, and training for mitigation of events involving a loss of decay heat removal capability, loss of reactor coolant inventory, and loss of electrical power sources during reduced inventory condition The inspector assessed management involvement and oversight of outage planning through discussions with engineering, operations, training, risk assessment, and maintenance personnel and by attending outage planning ,
meetings. The inspector found that senior management was heavily involved in setting outage policy and the approach to re&ced inventory operation Short notice outage work activities were care .'ly assessed .
by the risk management staff to qualitatively determine the ao.dsabilit l of work tasks from a risk perspective. The Reliability and Risk analysis -
Group performed a qualitative risk assessment of reduced inventory operations by assessing the projected work sequence and scope and the systems projected to be removed from service. A qualitative safet i analysis of critical safety functions, compared to a predefined minimum-criteria, was accomplished, which also considered industry experience i reduced inventory operation. The Plant Manager was involved in all phases of outage planning, clearly articulated his expectations regarding the need to concentrate and focus on safety of reduced inventory
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operation, and actively involved in all operations staff training sessions and outage planning meeting The inspector examined the plant procedures and training of licensed operators and non-licensee outage support personnel to assess the degree to which conditions unique to reduced inventory operations have been addresse The inspector examined the following documents in this regard:'
o procedure 40AC-90P20 Rev.1: Reduced Inventory Operation o Procedure 41 A0-12Zl6, Rev. 02.08: RCS Drain Operations o Procedure 41AO-12Z22, Rev. 05.10: Loss of Shutdown Cooling o EER No. 89-ZC-040, dated 3/24/89: Containment Equipment Hatch Hoists o Procedure 31MT-9ZC05, Rev, 04,01: Open/Close Containment Equipment-Access Hatch and Missile Shield Doors o Independent Safety and Quality Engineering Department. Independent Review of PVNGS Res)onse tc.HUMARC 91-06, " Guidelines for Industry 1 Actions.to Assess Slutdown Management." ISE Assessment No. 92-21,
. dated 8/24/92 ;
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o ANPP letters to the 14RC, in response to Generic letter 88-17 concerning Loss of Decay Heat Removal, dated January 6,1989, !
February 6,1989, and liovember 4,199 {
o lesson Plans for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of classroom lecture on the topic of Reduced Inventory Operations, dated October 31, 1992
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o The Simulator Scenario for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of plant simulator training for 3 all Unit I crews on loss of Essential Cooling Water and Loss of :
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Shutdown Coolin '
The inspector found that the procedures contained appropriate cautions or '
warnings to preclude perturbations in RCS inventory during reduced r inventory operation, and to control the drain down to reduced inventory conditions. The licensee's training of operators focused heavily on the procedures and industry experience in reduced inventory operations. The .
licensee was actively engaged in training support staff for the outag Portions of the licensee's training activities were observed to assess
. the training effectivenes ;
The inspector considered the operator simulator training to be very --.
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effective in focusing operator attention on the aspects of shutdow operation which may not be immediately recalled after a lengthy period of Mode 1 operations. The inspector asked the instructor what the decay heat simulation was during these sessions. The instructor did not know -
what decay heat was being simulated and had to contact the simulator software support group to determine the answer. . fortuitously the ,
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simulated decay heat closely approximated the decay heat that would be
- expected if Unit I had entered mid-loop operations as scheduled. The ,
inspector concluded that anticipating and. simulcting the expected decay
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heat enhances training, and it did not occur as a result of adequati i planning, ,
The inspector noted that the licensee identified-the need for sighificant-enhancement to the procedures to be used for a mid-loop evolution as a result of. procedural reviews which were a part of the preparations for mid-loop operations. The licenseo committed to. incorporating the results '
of these reviews into plant procedures prior. to reduced inventory
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operations. The inspector noted ene additional procedural. discrepancy in 4 Step 8.2.2 of~410P-ISIO1, which referred to 410P-ISP01, which no longer existed since it had been replaced by'400P-95P01. This was- subsequently corrected. The inspector concluded that the identification of the need
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for procedural enhancements to procedures needed for critical evolutions l represented a positive, proactive approach to_ planning and. preparation.' L
.The inspector identified the following procedure deficiencies regarding- .
activities for securing the containment equipment hatc o The procedure for Reduced Inventory.-Operation (40AC-90P20) provided ,
for closure of the containment equipment: hatch within certain t minimum time periods;-however, the following deficiencies were ;
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- Step 3.5.5.1.1 prescribed that the.Containrent Coordinator
" Verify Equipment Hatch is closed and held in place by a ;
sufficient number of bolts such that no gaps exist in the
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scaling surface. If the Equipment Hatch is open ensure operations are initiated to close the hatch." This stes contains inadequate criteria for the minimum number of latch bolts which must be engaged, the relative location of the
- bolts, the' tightness of each bolt, and the acceptance criteria necessary to assure containment closure ("no gsps in the
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sealing surface * is not adequate to assure containment integrity necessary for reduced inventory operations to achieve :
closure for an unmonitored release path). ;
o The comple4.d and approved Engineering Evaluation Request (EER) N ZC-040 ;iovided that a closed containment provides sufficient separation of the containment atmosphere from the outside i environment such that a barrier to the escape of. radioactive -
material is reasonably expected to remain in place following a core melt accident. However, the Attachment 2 merely provided that the :
criteria for a closed containment equipment hatch be for the
- equipment hatch door closed and held in place such that no. gaps exist in the sealing surface." The EER contained no analysis of the '
conditions necessary to achieve equipment h!.tch closure (i.e.:
number of bolts, placement, torque or means of verifying adequate sealing. surface contact).
o The licensee's procedure for opening and closing the equipment hatch and missile shleid doors (31MT-92005) contained the following deficiencies:
- Appendix 0 (fmergency Closure Instruction and Equipment)
actually contained instructions to open the. hatch, not close it, under loss of power conditions using the polar crane and .
power hoists.- The procedure did not reference how power was obtaine ,
- Appendix F was titled to provide instructions for " Temporary Hatch Closing and: Opening." . However, the instructions only '
provided for c1csing using~ Steps 4.5.4 through 4.5.10 of.the- :
main procedure body. Steps 4.5.4-4.5.10 provided closure I instructions using the power hoists. . Step 4.5.10 >rescribed- -r
" Draw hatch cover to body ring face, using the tigitening sequence shown'in_ Appendix B, (D0 NOT TORQUE FASTENERS). If temporary closure,'Only (4) bolts- are required to be tightened,- ;
or'more as designated by the WGS." This stop did noticontain ' '
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adequate criteria regarding which bolts or.the relative .
locations:of the bolts, the criteria necessary to achieve the! :
term " tightened," nor. the criteria necessary to demonstrate - ;
containment: closur he licensue agreed to resolve the above identified deficiencies. The~
inspector considered the above deficiencies to demonstrate the results'of- ,
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less than adequate engir.aering technical resolution of the tersporary i containment closure question and less than adequate review of the l documents providing for temporary containment equipment hatch clocure l activities, j
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As a rer, ult of the inspector's observations and examinations, the .
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inspector concluded that the licensee had:- a l
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o assured that management was effectively involved ~ln the planning and 1 oversight of rutage activities, l
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o the licensee's inethodology for control and scheduling of outage activities appeared adequate, a i, o ISEG involvement was good,-ISEG recomtendations contributed to nuclear safety, ;
i o with the exception of the above identified procedure deficiencies, 1 the -licensee's procedures, contingency plans, and training activities for the proposed reduced inventary operations appeared i adequate.- - .
No violations of NRC requirements or deviations were identifie . Rut.tArltin shttto Ko.oxoJkiertj.yf Nena.1jXLSatencLEelay - Unit 1- -
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H110LAndJul0D On December 8,1992, at 2:30 pH, _ Unit-1 experienced a full load rejection [.
followed by a reactor trip as a result of mis-operation of the negativ sequence relay which opened the main generator output breaker The-
resulting turbine trip caused a reactor trip on high pressurizer -
pressur Plant equipment operated as expected with a few minor exceptions. Thtfeedwater economizer valve was rnanually fast closed when
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the #2 Steam Generator reached 75% on the narrow range indication as a '
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result of excessive feedwater flow to the steam generator. The "D".-
channel of logarithmic safety nuclear instruments.in'dicated 3 decades ,
high as reactor power stabilized at approximately 10Ev7 counts per secon The negative' sequence relay is designed to trip = the . generator to protect 3 ~
it_ against phase imbalance. The device which mis-operated was a General Electric SGC21. Generai Electric.(GE) notified their customers of th potential for this type of failure on.0ctober 1,1987, in Service Advice:
Letter (SAL)-189.1. In addition, GE redesigned the K-board in thet.-
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negative sequence relay.to prevent this mis-operation, re-designated the relay K-board revision "B", and offered field modification kits to--
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correct the problem. When the licensee received this-SAL, the SGCl2- ,
- negative. sequence. relay was installed in the units. When these were . .
- replaced with the SGC21 devices,-the . licensee failed to incorporate ~ this 1 vendor information 'into the relays prior to installing _ them in the -unit Lihe licensee initiated Condition Report / Disposition Request (CRDR) 9-2-- .
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I 0743 tu tvaluate the failure to adequately communicate vendor informatia l l
After the restart of Unit 1, in response to inquiry from Region V, the i
licensee contacted the vendor and Icarned of GC Service Advice Letter 189.1. Negative sequence relays in all units were replaced on line with l
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units which addressed concerns raised by all applicable service letters i iby December 14, 1992. Subsequent licenne investigation identified that the Unit 3 "B" Emergency Diesel Generator (EDG) negative sequence relay wa; replaced on March 19, 1989, with a revision B device, yet the opportunity to identify the transportability of this issue was misse The inspectv concluded that the licensee's post trip review should have !
included identifying generic vendor information applicable to components :
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which caused the trip, including contacting the vendor prior to restar :
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The inspector further concluded that the other licensee actions !
associated with responding to the trip and subsequent restart appeared '
appropriat '
On December 17, 1992, the inspector met witti licensee personnel to discuss additional questions associated with vendor information. During this meeting, four questions were left for additional review.
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First, does the licensee's vendor technical uanual (VTM) upgrade program capture ,
all service Advice letters? Second, are all licensee designated critical '
systems being reviewed by the VTM upgrade program? Third, is CRDR 9-2-0743 addressing whether the present procurement and work control systems will permit installing equipment identified as deficient by ,
vender notification documents? fourth, does the VTM upgrade process ;
evaluate installed piant equipment, or merely plant technical manuals? ,
Answers to these questions will be reviewed when they are available from the licensee (Followup Item 528/92-41-01).
! No violations of HRC requirement: or deviations were identifia l
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' JMactor Trin_wjiMLjiARt3_ladellion and_Cytdainment isolation Actu1119.o_,:-
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htLL2 (9E921 On November 13, 1992, while the unit was at 100% power, a inactor trip' !
and safety injection actuation (Slri) with containment isolation ,
actuation (CIAS) occurred at 1:54 PM. A Notification of Unusual- Event (NVE) was declared at 2:65 PM. The trip occurred as a result of a- y personal erinr while and auxiliary operator (AO) was attempting to stop the."A" Control Element Drive Mechanism Control System (CEDMCS) motor -
generator (MG) for maintenance. The "B" CEDMCS MG was supplying _the
- entire CEDMCS loa The A0 partially depressed the remote stop .
pushbutton for the "B" CEDMCS MG when intending to push the local sto !
uutton for the "A" CEDMCS MG. This stopped the."B" CEDMCS MG and deenergized :all Control Element Assemblies (CEAs). The A0 recognized tho error and released the pushbutton which restarted the "B"-CEDMCS MG. A- l turbina trip on CEA bus undervoltage and reactor trip on low DNBR -l followed. This also initiated a quick open signal to four of>the eight ;
stem byf ass control' valves. Reactor Coolant System _(RCS) pressure decreased to '.819 psi 3, below the 1837 psia setpoint for a 51AS/CIAS 12 >
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initiation. The reactor was stabilized in mode 3 at 2200 psia, 560 * The fiUE was terminated at 2:39 P During the performance of the emergency operating procedure, 42EP-9R001, the procedure directed operators to check, then rely on the boron dilution alarm system (BDAS). This check was completed successfully; however, the sh'ft supervisor later recalled a Technical Specification Comppnent Cor11 tion Record (TSCCR) for BDAS channel 2 which said thet the chantiel was unsat;sf actory. As a result, the operators relied on BDAS channel 2, when prior information stated that it was unsatisf actor Internal discussions between the operations and operations standards organizations concluded that this revealed a programmatic weaknes Final corrective action plans were still being developed at the end of the ins ection period. The inspector concluded that the licensee's 6cknowledgement of the problem and plans to address it appear appropriate. The inspector further concluded that it was appropriate for _
the shif t supervisor to recall the TSCCR and raise the question regarding the functionality of BDA The CED'iCS panel layout and panel markings were not clearly laid out and were potentially confusing. A central section of the left cabinet <
contained the remote operation controls and indications for "B" CEDMCS MG set, while the remainder of the panel contained local operation controls and indications for tne "A CEDMCS MG. The adjacent right cabinet was just the reverse of the left. Start and stop push buttons for both MGs are on both panels. The procedural guidance was not specific to the panel layout and markings, but merely directed the operator to " Depress the LOCAL motor STOP button." While this event was determined to be an operator error, the inspector concluded that these potentially confu:,ing aspects may have contributed to the even The licensee's post-trip investigation confirmed the CEDMCS MC behavior on a partial depressien of the remote stop button. All post-trip reviews
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required prior to a restart decision were completed on ilovember 14, 199 The licensee determined that two factors contributed to the SlAS/CIAS which was an expected plant response. First, the licensee had been operating at 2225 psia rather than the normal 2250 psia since August, 1992, to eliminate pressurizer relief valve simmering. Second, heat production stopped when CEAs dropped into the core approximately one half second before heat removal stopped wnen tie turbine tripped. The inspector concluded that this appeared t asonable. Ihe reactor restart began on tiovember 15, 1992, at 12:54 AM. The generator output breakers were closed on flovember 15, 1992, at 3:07 PM. The inspectar concluded that operator response and licensee actions following the trip appeared appropriate. The inspector noted the positive communication initiated by the licensee to apprise the .nspector of the event, and to keep the inspector informed during the post-trip investigation and restar s tio violations of tiRC requirements or deviations were identifie I
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' Emerg,ency DiemLEgm_rator (EDG) Jnonerable - 9.rdt.J 47170H ,
I On November 19,_1992, at 09:55 AM, the Unit 2 "A" EDG was declare inoper>ible as a result of Jacket water temperature dropping belou 115 ' The auxiliary operator for this area was alerted tor this condition and- .
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_ stheted the jacket water circulating pump and heaters):hich restored.-
a cket water temperature to above 115 ' EDG '"A" was declared operable .
at 10:33'A This condition is normally annunciated locally with the JACKET WTER TEMP 0FF NORMAL annunciator when jacket water temperature is less thai 115 F and in the control roca with the DG A L0 PRIORITY TRBL annunciator wnich-alarms when one of several conditions exist. The DG A' LO PRIORITY TRBL annunciator was-in ab rm and had been acknowledged because the EOG lube oil heaters were in manual because they had failed to start automatically. Most control room annunciator windows will re-flash, when one condition is in alarm ad has baen acknowledged,-to alert operators
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L to a subsequent parameter reaching the alarm setpoint. Since the DG A LO-PRIORITY TRBL alarm design does not cause the annunciator window to'
re-flash when additional inputs reach the alarm setpoint, the operators .
were not alerted when the local JACyrT WATER TEMP 0FF NORMAL annunciator alarmed locally. Non-operations personnel in the diesel.. building
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notified the'.ontrol room when they noticed the local alarm,--but by the *
time the auxiliary operator. arrived and startedithe jacket _ water -
i circulating pump, temperature had dropped below 115 The inspector concluded that the compensatory' actions'for operating the EDG jacket water system in manual was not adequate-to prevent the EDG from being rendered inoperable. The licensee was'stil! considering corrective action at the' close of the inspection period. This wiTl be further follcwed as part of the routine insp;ction effor No violations of NRC requirements or deviations were identifie '
?. 0 . Containment intearity - Unj t 3 (617151 The inspector performed a walkdown of _ containment isolation valves outside containment and verified that isolation valve; appeared to be in-the required position and locked or capped; if required. . The inspector reviewed licensee surveillance procedures. associated with containment
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integrita and noted that 'me normally closed and capped vent' and drain valves associated with per.etrations required to-be open durinn accident conditions did not appear to be incliided in any surveillance.- An exampl of this is valve SIE-VB72, the " A" Low Pressure Safety Inject ion -(LPSI)~
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header drain valve, associated with penetration 19. The Technical Specifications did not ' appear to include .a surveillance requirement for these valves. -However, a mispositioned vent or drain valve could defeat
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the containment isolation function for the affected penetration. The inspector noteu that the-valve is checked and independently verified to be closed in the valve line-up associated with restoration from shutdown ,
cooling to normal" operations. The line-up does not require the valve- to- ),
be cappe ;
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This condition is 'being referred to NRR- for further evaluation. .The *
inspectors will review this-issue following completion of the NRR
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evaluation (followup item 530/92 41-02).
No violations of NRC requirements or deviations were identifie ,
11. Byfueli.e.gJater Level Indication Pror Unit 3 (717071-OnNovember2[1992,whileUnit3wasinMode6,amismatchdevOsed _
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between actual and indicated refueling water level. _ The mismr n as tho '
a result of a pressurizer vent path not being established, since u .
Refueling Water Level Indicating System (RWLIS) reference leg lwas vente to the pressurizer. A high pressure injection system full flow-Injection 1
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test was in progress, increasing water level in the refuelirg cavity'
which r.lso caused an-increase in pressurizer level and pressure. The'-
increased pressurizer pressure caused the indicated' refueling water level to be lower than actual level (132 feet vs.138 feet). The elevation of the reactor vessel flange is approximately 114 feet,_ and the elevation of the top of the refueling cavity is -140 feu. The condition was identified following a report by personnel in containment that the water level was up to the refueling cavity r.Mamers. After discovery of the
. condition, the licensee stopped the in,u tion test and opened a "
pressurizer vent path, resulting in tk. ndicated and actual water levels '
becoming essentially equal, Had this condition not been ritswvered, the refueling cavity' could have overflowed. If the level were being lowered, a falso high indication -
would have been caused, possibly resulting. in the' loss of shutdown-
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toolin .
The licensee initiated Condition Report / Disposition Request (CRDR) 3-2- '
0480 to investigate this even The insportor will review the' licensee's
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evaluation (Followup Item 530/92-41-03). .
No violations of NRC~ requirements or deviations were identifie . P_ost-refselino _ Restart - (Mt 3 (71711 2 72~/00mE1702. 61706. '6J20,L .
61708. 61709. an.d_6.1710)
The inspector observed portions of the post-refueling power ascension, low power physics testing, and power ascension testing in Unit 3. The inspector observed that operational activities, such as maneuvering Control Element A:semblies (CEAs) in support of: rod worth measurements '
and- power ascension at a' controlled rate, were positively controlled with'
adequate oversight by the Shift Supervisor, and with appropriate reactor-
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engineering involvemen .
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-The inspector reviewed procedures 72PY-9RX01, " Reload Criticality and low-
- Power Physics Testing," and 7%PA-9ZZ07, " Reload Pcwer Ascension Test." *
All acceptance criteria in the completed:pm '.iont of the procedure were confirmed to have been met, Additionally, measured and' calculated core .
parameters compared favorably with predicted values.
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kalkdowns of the control rod drive system. essential batteries ' nd a 4160
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volt switchgear,La "A" containment spray system,: indicated that the o
n systems were properly: returned to-service.~ :
The inspector concluded that the licensee's procedures wcre adequatcland -
properly _ approved, that Technical Specification requirements had boen:-
met, and that administracive controls over_the restart activities ~were '
adequately impleme.nte >
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No violations of NRC requirements or deviations were identifie ,
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1 Qualilydslurangs Audit Rey _tew - Units l. 2. and 3 Q570ll
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The inspector reviewed Quality Assurance Audit' Report 92-0-]9,- a
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" Operations / Technical Specifications," which was- performed lfrom June 22- 3 through_ August 113 1992,~ by the licensee't Q:lality Audits-and Monitoring s
Department. The audit scope included management-expectations,.
organization, conduct of shift op0 rations, tagging program, training, technical specification conformance, reportability determirations, equipment indicating lights, temporarily approved procedure action
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program, industrial safety,:and corrective action effectivenes '
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Several significant programmatic. deficiencies were identified in the-audit. . Auxiliary Operators (A0s) were found to be-excluded from
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systematic training on abnormal operating proceduru,: although:the auditors documented demonstrated performance-weaknesses by A0s:in this
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area. -Some discrepancies in reportability of events were' identifie The one-time' issuance of operations night orders as an interim correctivei 3" action until procedure changes were- completed was- found to be ineffective if the procedure change was not promptly completed, Some Shift Technical; a
- AdvisorsWere found_ not1to have completed all required initial or-continuing training courses. Aos were found to.be unsure of minimum-
- requirements for logtaking rounds. Temporary approved procedure actions-were not.always properly implemented:in all three units. Other y deficiencies were also identified.
f The audit report was clearly' written, with well-documented bases for.the c k findings. The Executive Summary was insightful, appropriately! direction-attention'to programmatic weaknesses.. All: deficiencies uct immediately corrected were entered into the appropriate; tracking syste The inspector concluded that the scope and nature:of the audit = findings:
' demonstrate that the audit was thorough and meaningful. The presentation-of the audit results was clear and concise. Overall,athis was- a very
- good audi No violations of NRC requirements or deviations were identifie 't b-14, Followun on Previous]y_ identified Items ' Units 1. 2. and 3 (9270]_ and '
, 192702)
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% .(1) .(Clo' sed._Yi.ol atio_rt.12B/12-27-01. ' Alarminq Dosimeter Nol.ht Pe.t -
1 - P.rtedur#_- Unit _j_.(92702).
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ul This item involved tho' failure of a radiation piotection (RP)
technician to-set an alarming dosimeter properly. The licensee ,
counselled the RP technician-in.accordance with the Posit.ive :
Discipline Progiam. - A memorandum and a letter were issued to 1
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manogement and to RP personnel discussing the event'ano .
stressino- th'u' need for attention to detail and '
responsibilities. These pointr have been established =as entire station policies by the Site RP Manager. :The-inspecter has
.also. observed additional steps for the issue and return of -
alarming dosimeters at the Unit 1 control point which appear to fu.*ther reduce the likelihood for recurrence of this even The inspector concluded that these actions appear appropriate to prev 9nt recurrence. Based on the above, this item is close Upit 2 (1) LQpan) Followan Ltfsj21290-78-QL._Plajlt_'jontt_grino-Syftfes .[
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- Djitabbe Errors - thitiL L_3.nd 3 (92701)
This item addresses configuration control of the Core Operating Limit Supervisory System (COLSS) software an'i associated data bases. Quality Deficiency Report- (QOR): 91-0002 addresse resolution.of how the licensee intends.to control- this 3 sof tware . The _QDR ic expected to be complete by April 10,
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1993. Additionally, the_ licensee is re-evaluating the -
appropriate quality classification of COLSS software and associated hardware.(the Plant Monitoring System and Caro Monitoring Computers). 'This item remains open pending the inspector's review of QDR191-0002 and'the clauification ;
evaluatio M (2) 10Jin)_fol1owun item 52.9M2.0,5-04. Essen1;jal Spr.ay Pond __(ESPF Pumo Breaker Fall,ed tg.,Q.gse on Demnt d - Juit ) (9U 01)
This item ln'volvsd th'e failure.of the "A" ESP breaker to close on deman Quality.Daficiency Report, (QDR) 92-0038 was issued a; to evaluate theTemoval and test of the breaker without wor ~
documentat!on..QDR 92-0038 was closed with :the conclusion -that'
racking down and rolling' a Magneblast 'areaker out l orc the cubicle for' visual inspection does not constitute work. The i-QDR further concluded that energizing, tetting, cycling, or- i'
further disassembly is considered work and requires work'
authorizction iSix corrective' actions were identifind and
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completed which includediestablishing and document.ng a 'y definition of work, training _ Unit 2 electricians and shift <
. supervisors, development of an electrical root cause of failure (RCF) guidelines by engineering, the ' development of- model work-orders incorporating the electrical RCF guidelines, and
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inc1'uding thisLO R inLind0stry; events training. The inspector- l T agreed with?the conclusion of the~ QDR that removal;and. cycling' .
of the breaker constitut ed work, consider ed the' corrective' ;
actions' to bc appropriate, :and~ concluded that the: removal: and =
~g test af;the ESP breaker,: without' documentation required by the; licensee's proceduresowas 'a violation of HRC requirement .
-The license?-identified violation is not being. cited-because ths criteria sped;ified in Section Vil.B. of the inforcemen !
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rolicy were satisfied (NCY 529/92- 11-04) ~. jWith regard to th '
licensee's definition of work which now clearly considersL removing a circuit breaker from the cubicle for inspection.to not be work, the inspector raised severai additional question "
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First,.does this policy adequately address possible retest cequirements? Second...dcas this policy adequately address worker safety? Third, does this policy consider the .'
possibility of foreign' material intrusion into the breaker or cubicle? Fourth, does this policy adaquately address the pcssibility--and consequences of breaker mis-alignment? FifthL does.tnis policy adequately control _ manipulation an estoration of contro! power switches and' fuses? Sixth, does .
this policy -permi+. component replacement? - -This-item will remain open pending resolution of these question (3) L(lqL@ - FoHowun IteL529122-03-05.1392Lllar y feedwater (Epl Epo F1a01_LcEster (Pfd AltrpJ._-Jnit 2 -(9270u a
This item involved several PC points in alarm on a group.'. .
'U display for.AFW pump bearing; temperatures with thefpump= stopped in an operable, standby condition.- Tne licensee initiated 1 :
- Condition Report / Disposition Request (CRDR) 9-2-0171 to ensure -
corriective action was taken. CRDR 9-2-Ol R is' closed.. The-
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inspector observeil the PC page di: play land noted that the AFW ' pump bearing temperatures were no .' longer constantlyDin alar t
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The insnector noted additional actions documentedin the' CRDR-which addressed other computer point def iciencies.. Interviews:
with_ operators revealed that operators' hed noticed : increased, 1 attentien tb -cesolving longstanding 'PC discrep Ancies 'since thist
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- CROR was initiated. _The1 inspect 6r encouraged the licensee to
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cent inue! thisi e f fort. Based on the review of. the1CRDR.and
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obser ved corrective : actions, this item .1s' closed; y
(4) JClosgji) Vicht,imtS,PJL92-3h0?. Auxiliqrylull.dLqq Flopdin Enit ? (927 '
This-itemcinvolved the failureiof operators to follow the alarm:
response procedure resulting in flooding of a portion of the
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auxiliary building. The licensee counselled,the operators involved. :The General Hanager of Plant-Support: issued'a J
- memorandum to Unita Plant Managers,' Unit AssistantzPlant'-
Managers,:aad Unit Operations Mpnagers,4 which discussed this-
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event Land'the- similar event discussed -in inspectinn report 529/91-49, and' requested manopers to be especially alert to
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> operator response.to annunciators when in the control' roci6. In addition, S e memorandum advises managers to question onerators-when alarm response procedures are no_t immediately referenced ;
The licensee will be incorporating the'se: events-in operator t'equalification training beginning in Jar.uary 1993. The ;
-inspector concluded that these actions-appear; appropriate.--
Based on a -reviaw of the licensee's completed andipla6ned : ,
actions, this nem is close c. -U. nit 3 a
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(1) 1 Closed) Fellowuo Item 520/91-50-01. ' Grease in.Limitoraue 'SB-1 -
[_o.jnpensalpr Stack Hoysina - Unit 3 (91LOJ1 {
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This item resulted from the identification'.of a largo quantity of grease in the compensator stack housing of Limitorque--SB-1 r operators, which ccold render the associated valve'inoperab The licensee inspected all six operators: of this type-(two per unit)- and found grease in them'all. However, the as-found testing of the valves indicated that the grease did not affect-operability. - The licensee. removed the' grease and the grease fittings, per a Limitorque maintenance bulletin. This item is-closed on the basis of these action Uniti.1 & Jnd (1) LC]Agedt Violatio.n R8/92-jI-01 Incomnlete htfiLd.Jng30ementb -
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Units 1. 2. and 3 1922!)fu 3 This violation addrersed roultiple examples'of bolts and studs which were not fully engaged with the' associated nutt-on.-
various safety-related compoisents in all three units;
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The licensee evaluated each example of_ incomplete thread
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engagement. .Most examples were found acceptable for= use as is.
E Some components were reworked either because they were not; acceptable for use as is, or because the-rework was easier than the engineering calculation.
L An evaluation of the identifico examples revealed that 45 . ..
[ examples were from origirial construction,. and _were encompasred L in a previous statistical evaluation, documented in Deviation-Evaluation l Report (DER) 84-53. In response to a.similar11ssue
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L L' observed during NRC inspection 530/84-07, the licensee had.
4' sampled 250 'of 2,046 valves and found no safety significant-conditions', concluding that valves previously installed in
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l Units 11, 2, and 3 were acceptable-for their intended use and no-- 7 L
further sampling is required. Based on this previous' '
l evaluation, the . licensee determined that no additionalTampling- -
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is warranted by_the recent observation ,
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' Thel licensee' determined that the requirement- for full Lthread engagement should not be chahged, though1 technically acceptable ~
exceptionsJshould be allowed. The licensee performed calculhtion 13-MC-XM-204, " Thread En9agement for Partially _~. -
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-Engaged Fastenerc,' to provide acceptance ~ criteria for14s-foun cases of _ incomplete? thread engagement ~or for the a:ceptance of incomplete thread engagement =yhen'iticannot-be practicably: '
obtained at the time of the work evolutio ' Forty-five 'of _the recently identified exampics werel determined' 's to be due to' reinspection criteria being_more stringent than criteria' applicable to the original installation er rost recent rewor .
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n Eight examples wera determined to be due to failure to follow established procedures. The. root cause for these examples was not determine The. licensee oetermined that some procedure changestwere required and some training was necessary:tu ensure that- <
appropriate personnel were ' aware of thread. engagement _
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requirement Based-on.the' inspector'sreviewofassociateddocumerhatIonand based 'on~ discussions with licensee personnel; the inspector :
-considered the licensee's corrective actione and acticns to -
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prevent 1 recurrence to be adequate. LThis:; tem is ' close One non-cited 1 violation of NRC requirements was identified
_(paragraph 14.b).
L 15. Review of licfqnsee Event Reports (L181 - Uatts 1. 2. and 3 (927001 L
Through direct observations,- discussion with licensee personnel,^or ,
review of the records,_ the following LERs were-close l l ..
u nil 1-
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92-02, Revision LO " Missed-Technical SpecificationtAction-
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While' Radiation-Manitcr Was Inoperable" -
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92-09, ~ Revision LO- " Seismic. Qualification of Foxboro' >'
' Equipment' ,
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-This item.wa's discussed in' inspection:
L-report:528/91-411\n par & graph 12 > N6 new~
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L issues were raised-byfthe,LER. Th'isfitem L f E lis close L
" Reactor-Trip. Caused lby Actuation of the; l
92-12,- Revision LO .
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- Sub-Synchronous. Trip"
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.92-13, Revision _LO- "Telodyne Republic Feedwater Isolation ~- '
Valve ' Actuators 4-Way Valve _ Body Probless'-
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92-04, -Revision "Inynlid Control Room,' Containment...and-
. fuel Building. ESF Actuations" l
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c- ' Val 15.L I.._pnd 3 }
%- 14 ,- Revision LO ' Operation in'Ex' cess of Licensed Condition
for Thermal Power" 16. f.xit_Meetjna (71797)
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Exit meetings were 'neld on November 10, December-14 6ndl December
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R1, 1992, with Licensee Mar,agement,. Region.V personnel,'.and the Resident-Inspectors during which tne observations and conclusions in this report *
were generally discusse ;
- TSc. licensee did not identify as proprietary any materials provided to or: 4 reviewed by the inspectors during the inspectio .
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