ML14178A383
| ML14178A383 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/08/1993 |
| From: | Ogle C, William Orders NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A381 | List: |
| References | |
| 50-261-93-18, NUDOCS 9309280217 | |
| Download: ML14178A383 (14) | |
See also: IR 05000261/1993018
Text
sa REG&
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report No.: 50-261/93-18
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson Unit 2
Inspection Conducted:
July 10 - August 14, 1993
Inspector:
'
W. T. Orders, Senior Resident Inspect r
Date igned
Inspector:
)
.34
/
C.'R. Og e, esident Inspector
Date
igne
Approved by:
'
H. 0. Christensen, Chief
Date Signed
Reactor Projects Section 1A
Division of Reactor Projects
SUMMARY
Scope:
This routine inspection was conducted in the areas of operational safety
verification, surveillance observation, and maintenance observation.
Results:
One violation with three examples of operators failing to follow procedures
was identified involving; inadequate locked valve control (paragraph 3),
failure to adequately monitor equipment alarms (paragraph 3), and failure to
follow procedure during EDG testing (paragraph 4).
Another violation was identified concerning the failure to maintain design
control of the Reactor Auxiliary Building Ventilation System. (paragraph 3)
A third violation was identified concerning the failure to control work on
safety-related equipment. (paragraph 5)
An Inspection Followup Item was identified involving the potential for alarm
conditions to be disguised. (paragraph 3)
9309280217 930910
PDR ADOCK 05000261
REPORT DETAILS
1.
Persons Contacted
C. Baucom, Senior Specialist, Regulatory Compliance
D. Bauer, Regulatory Compliance Coordinator, Regulatory Compliance
S. Billings, Technical Aide, Regulatory Compliance
- B. Clark, Manager, Maintenance
- T. Cleary, Manager, Technical Support
D. Crook, Senior Specialist, Regulatory Compliance
C. Dietz, Vice President, Robinson Nuclear Project
R. Downey, Shift Supervisor, Operations
J. Eaddy, Manager, Environmental and Radiation Support
S. Farmer, Manager -
Engineering Programs, Technical Support
R. Femal, Shift Supervisor, Operations
- W. Flanagan Jr., Manager, Operations
W. Gainey, Manager, Plant Support
- J. Harrison, Manager, Regulatory Compliance
P. Jenny, Manager, Emergency Preparedness
D. Knight, Shift Supervisor, Operations
A. McCauley, Manager -
Electrical Systems, Technical Support
D. Morrison, Shift Supervisor, Operations
D. Nelson, Shift Outage Manager, Outages and Modifications
A. Padgett, Manager, Environmental and Radiation Control
0. Seagle, Shift Supervisor, Operations
M. Scott, Manager, Performance Engineering
E. Shoemaker, Manager, Mechanical Systems, Technical Support
W. Stover, Shift Supervisor, Operations
- D. Waters, Manager, Regulatory Affairs
0. Winters, Shift Supervisor, Operations
Other licensee employees contacted included technicians, operators,
engineers, mechanics, security force members, and office personnel.
- Attended exit interview on August 18, 1993.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2. Plant Status
The unit operated from July 10 to July 12, 1993, with power at
approximately 70 percent to reduce SW/CW weir discharge temperatures.
Following a power ascension on July 12, 1993, the unit operated at 100
percent until July 16, 1993. A power reduction to 70 percent was again
conducted on July 16 to 70 percent and the unit operated on July 17 and
18 at 70 percent to reduce weir discharge temperatures.
Power was.
raised to 100 percent on July 19 and the unit operated at this power
until a power reduction on July 21.
0C
2
The July 21 power reduction was performed in response to high steam
generator cation conductivity. Following the discovery of elevated
conductivity the unit operated at power levels of 25 percent to 80
percent until the generator chemistry was restored. Following an
increase in power to 100 percent on July 26 the unit operated at 100
percent until the end of the inspection period.
3. Operational Safety Verification (71707)
The inspectors evaluated licensee activities to confirm that the
facility was being operated safely and in conformance with regulatory
requirements. These activities were confirmed by direct observation,
facility tours, interviews and discussions with licensee personnel and
management, verification of safety system status, and review of facility
records.
To verify equipment operability and compliance with TS, the inspectors
reviewed shift logs, Operation's records, data sheets, instrument
traces, and records of equipment malfunctions. Through work
observations and discussions with Operations staff members, the
inspectors verified the staff was knowledgeable of plant conditions,
responded properly to alarms, adhered to procedures and applicable
administrative controls, cognizant of in-progress surveillance and
maintenance activities, and aware of inoperable equipment status. The
inspectors performed channel verifications and reviewed component status
and safety-related parameters to verify conformance with TS. Shift
changes were routinely observed, verifying that system status continuity
was maintained and that proper control room staffing existed. Access to
the control room was controlled and operations personnel carried out
their assigned duties in an effective manner. Control room demeanor and
communications were appropriate.
Plant tours and perimeter walkdowns were conducted to verify equipment
operability, assess the general condition of plant equipment, and to
verify that radiological controls, fire protection controls, physical
protection controls, and equipment tagging procedures were properly
implemented.
Oil Spill In Lake Robinson
At 8:07 a.m. on July 25, 1993, the licensee was advised by the
Darlington County Sheriff's Department, that a vehicle had been found in
Lake Robinson. This resulted in an oil/gasoline slick on the lake
estimated by the licensee to be approximately 60 square feet in size.
At 10:05 a.m., the licensee was informed by the State of South Carolina
Department of Health and Environmental Control that the slick had
dissipated.
As. a result of licensee notifications to the South Carolina Department
of Health and Environmental Control, National Response Center, and the
Darlington County Emergency Planning Organization, thelicensee made a
3
4-hour non-emergency notification to the NRC in accordance with the
requirements of 10 CFR 50.72 (b) (2) (VI), Offsite Notification, at
10:52 a.m. on July 25, 1993. The licensee also notified the Senior
Resident Inspector immediately prior to the 10 CFR 50.72 notification.
Based on their review of this event, the inspectors concluded that the
licensee met the requirements for NRC notification specified in 10 CFR
50.72. The inspectors have no further questions on this event.
Inadequate Locked Valve Control
On the afternoon of July 26, 1993, the resident inspectors were
performing a routine safety system inspection of the motor driven
auxiliary feedwater pumps. During that effort, it was noted that AFW
valves, FCV 1424 and FCV 1425, the discharge flow control valves for the
pumps, were not aligned as required by the applicable Operating
Procedure OP 402, Auxiliary Feedwater System. The procedure requires
that the two hydro-motor actuated valves be closed with the manual
actuator handle disengaged and locked. The inspectors noted that valve
FCV 1424 was completely unsecured with the lock and chain merely wrapped
around the valve actuator body, but not in contact with the handle of
the manual actuator. The inspector also noted that the chain for valve
FCV 1425 was loosely wrapped around the manual actuator handle but could
easily be removed leaving the valve unsecured.
The inspectors brought their observations to the attention of an
auxiliary operator and subsequently discussed the issue with operators
in the control room. The valves were properly secured shortly
thereafter.
Additionally, on July 30, 1993, the inspectors observed that the chain
intended to lock post accident vent valve, PAV-35 was loosely wrapped
around the manual actuator handle but could easily be removed leaving
the valve unsecured. The inspector brought his observations to the
attention of an auxiliary operator who properly secured the valve.
Operations Procedure OP 402, Auxiliary Feedwater System, requires in
section 6.0, Normal Operations, step 6.1.1 that valves FCV-1424 and FCV
1425 be aligned in the closed position with the manual actuators
disengaged and locked when placing the system in standby alignment.
Operations Management Manual OMM-009, Locked Valve List, delineates
those valves within the plant which are required to be locked. OMM-009
states that a properly locked valve will have the chain secured between
the valve operator and'body such that it may not be removed unless the
lock is removed. Attachment 6.1 of OMM-009 contains a listing of those
valves, which are required to be locked and the position of each. OMM
009 lists valves FCV-1424, FCV-1425 and PAV-35 as valves which are to be
locked.
Technical Specification 6.5.1.1 Procedures, Tests and Experiments
require in part that written procedures be established, implemented and
4
maintained, covering the activities recommended in Appendix A of
Regulatory Guide 1.33, Rev 2. 1978, including the operation of the
auxiliary feedwater system and combatting emergencies/significant
events.
Contrary to the above, on July 26 and July 30, 1993, respectively,
valves FCV-1424, FCV-1425 and PAV-35 were found improperly secured, in
violation of the requirements of procedures OP-402 and OMM-009. This is
one of three examples which in the aggregate comprise a Violation:
Operations Failure To Follow Procedures, Three Examples. 93-18-01.
Failure To Note Deviation In Indicated Rod Position And Average Bank
Position
At 9:32 a.m. on July 27, 1993, an alarm was recorded on the control room
ERFIS printer indicating a rod misalignment in Group 2. It should be
noted that this "alarm" does not have an audible feature, rather, it is
a "silent" alarm typer message. This alarm occurred as a result of a
deviation between the indicated position for rod B-10, a Group 2 rod,
and its average bank position. The alarm was recorded again at 9:47
a.m. and at 10:02 a.m..
At 10:04 a.m., a message was printed indicating
that the rod misalignment had returned to normal.
This occurred despite
the fact that the indicated position of the rod still deviated from the
average bank position by an amount in excess of the limits specified in
TS 3.10.1.5. Commencing with the 10:30 a.m. printout, and every half
hour thereafter, the position of the rod as indicated on the ERFIS
printout, was shown to be in deviation from its average bank position.
Additionally, a data quality of "BAD" was specified for the rod on these
printouts. The operators on shift failed to detect this condition. The
oncoming operator discovered the situation at shift turnover at 7:00
p.m. that evening.
Following this discovery, the licensee entered AOP-001, Malfunction of
Reactor Control System, at 7:15 p.m. The deviation was attributed to an
indication error for the B-10 IRPI. At 9:30 p.m., following an
adjustment to the indicated position for rod, AOP-001 was exited.
The inspectors independently reviewed the ERFIS computer printouts for
July 27, 1993, and interviewed the reactor operator on watch during
dayshift that day. The inspectors concluded that the reactor operator
failed to note repeated indications of a potential rod misalignment in
excess of TS limits for almost 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. When questioned by the
inspectors, the reactor operator admitted that he failed to consistently
review the ERFIS printout which recorded rod positions. The failure of
the operator to note the indication of a potential rod misalignment is a
failure to follow procedure OMM-023, which specifies that operators
perform thorough general inspection of assigned spaces and that
operators be knowledgeable of equipment parameters.
Technical Specification 6.5.1.1.1.a, Procedures, Tests, and Experiments,
requires in part that written procedures be established, implemented and
maintained concerning the activities delineated in Appendix A of
5
Regulatory Guide 1.33, Rev. 2, February 1978, including procedures for
log entries, record retention, and procedure review. Operations
Management Manual Procedure, OMM-023, Operator Logs and Rounds, states
that an operator shall perform a thorough, general inspection of his
assigned area and that operators should be knowledgeable of equipment
parameters that are to be monitored.
Contrary to these requirements, on July 27, 1993, the reactor operator
failed to note a deviation between the indicated position for rod B-10
and its average bank position which was in excess of Technical
Specification 3.10.1.5 limits, for a period of approximately 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
This is one of three examples which in the aggregate comprise
Violation: Operations Failure To Follow Procedures, Three Examples. 93
18-01.
The inspectors requested the licensee perform an analysis of other alarm
,features provided by ERFIS to determine if there are other cases in
which alarms would clear as a result of input data being assigned a
quality code of "BAD". This analysis will be evaluated by the
inspectors to ensure that alarms will not inadvertently be cleared
during an accident scenario. Pending this evaluation, this item will be
tracked as IFI 93-18-02: Alarm Features Provided By ERFIS Which Can
Inadvertently Clear.
Failure To Maintain Design Control of Reactor Auxiliary Building
Ventilation System
On July 28, 1993, a member of the licensee's staff noted that a tarp
which had been erected as a ventilation boundary where an exterior
auxiliary building door had been removed, was deflected outward
indicating that the pressure inside the auxiliary building was greater
than that outside. It was ultimately concluded that the Reactor
Auxiliary Building Ventilation System was not maintaining the building
at a negative measure as designed.
System Design
As described in the FSAR, the Reactor Auxiliary Building
Ventilation system is designed, in part;
-
to maintain potentially contaminated areas of the Reactor
Auxiliary Building at a negative pressure
-
to route the ventilation exhaust from the potentially
contaminated areas to the plant vent stack to ensure
continuous monitoring by the radiation monitoring system
-
to assure that the air distribution in the building is such
that air movement is from areas of lesser contamination to
areas of higher contamination potential
0II
6
Background
Based on information available at the time, a review of relative
events preceding this issue revealed the following:
Prior to 1979, numerous modifications were made to the
auxiliary building which may have changed the as-built
design of the Reactor Auxiliary Building Ventilation system.
These included but were not limited to sealing cable and
pipe penetrations, the addition of fire doors, and duct work
changes.
In July 1979, a vendor service company was contracted to
correct known pressure problems in the building thought to
have been caused by the aforementioned modifications.
Between 1979 and 1987, the only major engineering work
performed relating to the system, was the initiation of
TAR/PCN 84-002 which was to correct inadequate ventilation
in some areas of the reactor auxiliary building due to the
aforementioned modifications.
In 1987 maintenance work request WR 87-APNK1 installed a new
shaft in fan HVS-1 when the old shaft failed. Testing
indicated that the building was at a positive pressure after
installation. It is not known if the building was at a
positive pressure prior to the maintenance. The system was
adjusted to reduce supply flow to get a negative pressure in
the building. The as-left flowrate was not recorded.
In 1988, MOD 934, which implemented the changes requested by
TAR/PCN 84-002 was approved and started. Actual
installation was scheduled to be completed in 1989 but is
still ongoing. Although not addressed by the MOD, the
system flow balance was affected by the ongoing work yet a
re-balance was not scheduled to be performed until all work
was completed; in this case, a period of five years.
In January of 1990, another vendor service company was
contracted to perform preliminary data collection to prepare
or the performance of the flow balance of the auxiliary
building associated with MOD-934.
In January of 1992 WR 91-AMYN1 was written to clean the
steam heater coils associated with HVS-1. The system
engineer stated that the coils were very dirty which
contributed to a high suction dp. The high suction dp
reduced the supply air flowrate which (it was subsequently
concluded) made the lower level of the building positive.
No post maintenance test was performed to verify that the
system's flow balance had not been affected. The licensee
7
stated that the lower level of the building remained
positive from this time, until July 1993.
-
In February 1993, weatherstripping and door seals were
installed on doors for fans HVE-2A/B and HVS-1. These
modifications decreased the exhaust flow coming from the
upper corridor. No post modification test was performed to
verify that the system's flow balance had not been affected.
According to the licensee, it was at this time that the
upper level of the reactor auxiliary building went positive
and remained in that condition until July 1993.
-
On July 26, 1993, per MOD 934, the aforementioned exterior
auxiliary building doors were removed. A tarp was installed
in their place. Observation of the tarp indicated a
negative pressure did not exist.
Event Details
On July 27, 1993, the operability of the Reactor Auxiliary
Building Ventilation System was questioned due to the work being
performed under Modification 934. One part of this modification
removed the doors serving the north end of the second floor
auxiliary building hallway. A tarp was erected to provide a
ventilation boundary. Licensee personnel observed that the
direction of movement of the tarp indicated that the air movement
through the hallway was toward the outside environment and that a
negative pressure was not being maintained.
Based on the system's design basis, this condition indicated that
the system was inoperable. The licensee initiated compensatory
actions which restored the Reactor Auxiliary Building Ventilation
System to a functional status. These actions included:
-
On July 28, 1993, operability determination 93-010 was
initiated as a result of the positive pressure. NED was
contacted to support the determination. On July 30, 1993,
operability Determination 93-010 was completed, concluding
that facility did not meet the design basis while a positive
pressure existed.
-
On July 29, 1993, the vendor service company completed an
as-found reading of flows. HVS-1 was measured at 52,664 cfm
when converted to STP. Exhaust flows were measured at
53,108 cfm. The licensee stated that exhaust flow was 444
cfm greater than supply, which they said indicated that the
overall building was at a negative pressure, although the
upper level hallway and the lower level of the building were
at a positive pressure.
8
-
On July 29, 1993, the licensee established a negative
pressure condition in the upper level hallway by partially
opening the door to the room which houses fans HVE-2A & B.
This increased the exhaust from the hallway which resulted
in a negative pressure in the area. Later that evening, the
licensee was able to achieve a negative pressure in the
lower level of the building using similar techniques.
-
At approximately 6:30 p.m. on July 30, 1993, the licensee
performed a building walkdown which confirmed that the
building was at a negative pressure. At the end of this
report period, the unit was operating with the
aforementioned compensatory measures in place.
Conclusion
The auxiliary building ventilation system was incapable of
performing its intended safety function for a period of
approximately 18 months preceding July 1993.
10 CFR 50 Appendix B, Criterion III, Design Control, as
implemented by the CP&L Corporate Quality Assurance Program
requires in part that measures be established to assure that
applicable regulatory requirements and the design basis, as
specified in the license application, are correctly translated
into specifications, drawings, procedures, and instructions of the
type to ensure the design integrity of the structure, system or
component; that measures be established to verify the adequacy of
the design such as by suitable testing; and that design changes be
subject to the design control measures commensurate with those
applied to the original design.
Contrary to those requirements,
The licensee failed to implement adequate measures to
maintain the integrity of the Reactor Auxiliary Building
Ventilation System design in that modifications and design
altering maintenance were implemented which degraded the
system yet neither suitable post modification test nor post
maintenance testing was performed to verify the system's
continued operability. This ultimately resulted in the
system being inoperable from January 1992 until July 1993.
This is a Violation: Failure To Maintain Design Control of Reactor
Auxiliary-Building Ventilation System VIO 93-18-03.
This is a Severity Level IV violation (Supplement I).
0II
9
4. Surveillance Observation (61726)
The inspectors observed certain safety-related surveillance activities
on systems and components to ascertain that these activities were
conducted in accordance with license requirements. For the surveillance
test procedures listed below, the inspectors determined that precautions
and LCOs were adhered to, the required administrative approvals and
tagouts were obtained prior to test initiation, testing was accomplished
by qualified personnel in accordance with an approved test procedure,
test instrumentation was properly calibrated, the tests were completed
at the required frequency, and that the tests conformed to TS
requirements. Upon test completion, the inspectors verified the
recorded test data was complete, accurate, and met TS requirements, test
discrepancies were properly documented and rectified, and that the
systems were properly returned to service. Specifically, the inspectors
witnessed/reviewed portions of the following test activities:
OST-401
Emergency Diesels
(Slow Speed Start)
Diesel Generators "A" and "B"
(A EDG Only)
EDG A Inoperability Due To Erroneous RPM Indications
At 1:25 p.m. on August 2, 1993, the licensee declared the A EDG
inoperable and entered TS 3.7.2.. This occurred after it was observed
during OST-401, Emergency Diesel Generator Slow Speed Start, that the A
EDG indicated engine speed could not be raised to the synchronous speed
of 900 RPM. TS 3.7.2 required that the EDG be returned to service
within seven days. During troubleshooting, the licensee determined that
a power supply in the RPM indicating circuitry was malfunctioning,
thereby, resulting in erroneous engine speed indication.
A temporary change to OST-401 was made to permit the use of a strobotach
to measure engine speed. The OST was successfully completed and the
licensee exited TS 3.7.2 at 4:10 a.m. of August 3, 1993.
After interviewing the system engineer and independently reviewing the
EDG electrical schematic, the inspectors determined that the RPM
indicating circuitry is not used for automatic control of the EDG. It
is used during manual starts of both EDGs. The inspectors concluded that
the unavailability of the RPM device did not render the EDG inoperable.
The inspectors noted that an operator assigned to operate the A EDG
during the troubleshooting flashed the field with an indicated engine
speed less than 900 RPM. This was done in an effort to determine the
actual engine speed by using the installed frequency meter as a check
for the RPM instrument. This is contrary to the requirements of
Operating Procedure, OPP-604, Diesel Generators "A" and "B", which
10
requires that the engine speed be raised to synchronous speed (900 RPM)
prior to flashing the field.
Technical Specification 6.5.1.1.a, Procedures, Tests, and Experiments
requires in part that written procedures be established, implemented,
and maintained concerning the activities outlined in Appendix A of
Regulatory Guide 1.33, Rev 2, February 1978. Appendix A, Item 4.1.2 (a)
requires procedure for operation of the EDGs. Operating Procedure, OP 604, Diesel Generators "A" and "B", requires that the engine speed be
raised to 900 RPM prior to flashing the field. Additionally, OP-604
contains a prohibition against operating an EDG at less than 900 RPM
with field excitation in service.
Contrary to these requirements, on August 2, 1993, the EDG A field was
flashed with an indicated engine speed of approximately 750 RPM. This
is one of three examples which in the aggregate comprise a Violation:
Operations Failure To Follow Procedures, Three Examples, 93-18-01.
Based on the troubleshooting witnessed by the inspectors, it is likely
that the EDG was operating at speeds in excess of 900 RPM while the
speed sensing circuit was inoperable. Hence, the safety significance of
flashing the EDG field was minimal.
5. Maintenance Observation (62703)
The inspectors observed safety-related maintenance activities on systems
and components to ascertain that these activities were conducted in
accordance with TS, approved procedures, and appropriate industry codes
and standards. The inspectors determined that these activities did not
violate LCOs and that required redundant components were operable. The
inspectors verified that required administrative, material, testing,
radiological, and fire prevention controls were adhered to. In
particular, the inspectors observed/reviewed the following maintenance
activities:
W/R JO 93-ADFY1
Receipt And Storage Of New Fuel
W/R JO 93-AHJB1
Adjust Door Latches To Provide Adequate
Seals For HVE-1 Fitter Housing
WR/JO 93-AHAWI
Repair of EDG A Fuel Oil Pump Indicator
Pegged High
WR/JO 93-AHWA1
Repair Governor On A EDG
WR/JO 93-AEE004
Check Brush Tension OnSpeed Change Motor
For EDG
11
Unauthorized Maintenance On Control Room Door
On August 2, 1993, during a routine tour, the inspectors observed
ongoing maintenance on the striker plate for door 49, the south control
room door. The door could not have been secured due to a partially
removed striker plate screw. At 2:23 p.m., as a result of the
inspector's questions to the shift supervisor on this observation, the
door, as well as the control room ventilation system, were declared
inoperable. Accordingly, the licensee entered TS 3.15.1.b. which
required that the inoperable door be returned to service in 48-hours or
the plant be placed in hot shutdown in 8-hours and cold shutdown in the
following 30-hours. Coincidentally , the A EDG was also inoperable due
to having failed OST-401 (see paragraph 4).
With an inoperable control
room ventilation system, the licensee was unable to satisfy the
requirements of TS 3.7.2.d for continued operation with one operable
EDG. As a result, the licensee entered TS 3.0. which required that the
unit be shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and placed in cold shutdown within the
next 30-hours. The door was repaired and following successful
completion of OST-750, Emergency Ventilation System Bi-Weekly Test, and
OST-625, Fire Door Inspection, the licensee exited TS 3.0 and TS 3.15.1.b at 5:39 p.m. that afternoon.
The inspectors interviewed the fire technician and shift supervisor
involved and reviewed the OSTs completed prior to declaring door 49
operable. The inspectors concluded that maintenance had been conducted
on the door beyond that approved by the shift supervisor. The fire
protection technician recognized that the supplemental maintenance
rendered the door inoperable, but did not communicate this information
to the control room.
Technical Specification 6.5.1.1.1a., Procedures, Tests, and Experiments
requires in part that written procedures be established, implemented,
and maintained concerning the activities delineated in Appendix A of
Regulatory Guide 1.33, Rev. 2, February 1978. Appendix A, Item 9.e.
requires general procedures for the control of maintenance work. Plant
Program, PAP-013, Maintenance Program, requires that shift supervisor
permission be obtained before maintenance is performed on plant safety
system. On August 2, 1993, maintenance personnel initiated repairs on
the south control room door without having obtained the shift
supervisor's permission. This resulted in the door, as well as the
control room ventilation system, being declared inoperable.
This is considered to be a violation, Failure To Follow Procedure
Resulting In Unauthorized Maintenance (93-18-04).
Following the restoration of the door to service, the licensee reviewed
the requirements of TS 3.15. As a result of this review, the licensee
concluded that the entry into TS 3.0 was unwarranted and that the 48
hour LCO associated with TS 3.15 was the limiting requirement. The
licensee indicated that appropriate annotations would be made in the
plant records to reflect this subsequent decision. The inspectors have
no further questions of this event.
12
6. Exit Interview (71701)
The inspection scope and findings were summarized on August 18, 1993,
with those persons indicated in paragraph 1. The inspectors described
the areas inspected and discussed in detail the inspection findings
listed below and in the summary. Dissenting comments were not received
from the licensee. The licensee did not identify as proprietary any of
the materials provided to or reviewed by the inspectors during this
inspection.
Item Number
Description/Reference Paragraph
93-18-01
VIO: Operations Failure To Follow Procedure,
Three Examples ( Paragraphs 3, and 4).
93-18-02
IFI: Alarm Features Provided By ERFIS Which Can
Inadvertently Clear (Paragraph 3)
93-18-03
VIO: Failure To Maintain Design Control of
Reactor Auxiliary Building Ventilation System
(Paragraph 3)
93-18-04
VIO: Failure To Follow Procedure Resulting In
Unauthorized Maintenance (Paragraph 5).
7. List of Acronyms and Initialisms
Abnormal Operating Procedure
cfm
Cubic Feet Per Minute
CFR
Code of Federal Regulations
Design Basis Documentation
ERFIS
Emergency Response Facility Information System
Flow Control Valve
Final Safety Analysis Report
High Efficiency Particulate Airborne
HVE
Heating Ventilation Exhaust
HVS
Heating Ventilation Supply
IFI
Inspector Followup Item
IRPI
Individual Rod Position Indication
LCO
Limiting Condition for Operation
Modification and Design Control
NED
Nuclear Engineering Department
NRC
Nuclear Regulatory Commission
OMM
Operations Management Manual
OP
Operations Procedure
OST
Operations Surveillance Test
Personnel Access Portal
PAV
Post Accident Venting
13
Revolutions Per Minute
Standard Temperature Pressure
SW/CW
Service Water/Circulation Water
SWBP
Service Water Booster Pump
TAR/PCN
Task Assistance Request/Plant Change Notice
TS
Technical Specification
W/R
Work Request
WR/JO
Work Request/Job Order