ML16342D416
| ML16342D416 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/16/1996 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D415 | List: |
| References | |
| 50-275-96-13, 50-323-96-13, NUDOCS 9608210029 | |
| Download: ML16342D416 (36) | |
See also: IR 05000275/1996013
Text
ENCLOSURE 2
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-275
50-323
DPR-82
50-275/96-13
50-323/96-13
Pacific Gas
and Electric Company
Diablo Canyon Nuclear
Power Plant,
Units
1 and
2
7-~g miles
NW of Avila Beach
Avila Beach, California
May 28 through June
28,
1996
W.
C. Walker, Senior Resident
Inspector
P.
M. Quails,
Reactor
Inspector
D.
B. Perei ra, Reactor
Inspector
Chris A. VanDenburgh
~ Chief. Engineering
Branch
Division of Reactor Safety
Attachment:
Partial List of Persons
Contacted
List of Inspection
Procedures
Used
List of Items Opened,
Closed.
and Discussed
96082i002'P
9608lb
ADOCK 05000275
8
-2-
EXECUTIVE SUMMARY
Diablo Canyon Nuclear
Power Plant. Units
1 and
2
NRC Inspection
Report 50-275/96-13:
50-323/96-13
The inspectors
reviewed the licensee's
corrective action program and its
implementation
from May 28 through June
28.
1996.
The inspectors
used the
guidance contained in NRC Inspection
Procedure
40500,
"Effectiveness of
Licensee Controls in Identifying, Resolving.
and Preventing
Problems."
The
inspectors
focused
on the licensee's
implementation of the corrective action
program in the areas of operations
and engineering.
The overall approach of
the inspection
was to evaluate the effectiveness
of the licensee's
corrective
action program through review of activities in their normal
sequence
from
identification and processing of a problem to correction
and closeout:
Safet
Assessment
and
ualit
Verification
The licensee
had implemented
an effective corrective action program,
which encouraged
identification and resolution of problems.
The
inspectors
concluded that the corrective action/evaluations,
and the
scope of corr'ective actions to prevent reoccurrence
of events
were
satisfactory
(Section
07. 1).
The licensee's
corrective action process,
procedures
and documents
were
acceptable
to identify, process.
track and conduct root cause analysis
of problems
and equipment deficiencies.
The inspectors
concluded that
the licensee
personnel
had
a satisfactory
knowledge of the corrective
action process
and had experienced
no difficulty in initiating an action
request
or having it approved
(Section 07.2).
The licensee's
operating experience
feedback
program was functioning
effectively, with procedures
that were excellent in forwarding events to
appropriate plant personnel
(Section 07.3).
~
The licensee's
self-assessment
activities were self-critical with many
issues identified.
The inspectors
concluded through interviews with
licensee
personnel
and review of several
self-assessmments
that the
self-assessment
process
was effective (Section 07.4).
Overall. plant housekeeping
and equipment material condition were good
with the exception of'he identified violation regarding the storage of
combustible materials
(Section E2.2).
The licensee
had begun
an investigation into various methods to reduce
the engineering
backlog.
The inspectors
concluded that management
was
involved in the process
(Section
E7. 1).
-3-
The inspectors
concluded that the licensee
was successful
in assigning
important.
high priority work to ensure that safety-related
problems
were resolved in a timely manner.
However.
an inspector
followup item
was identified associated
with corrosion rates of the auxiliary salt
water piping (Section
E7. 1).
Engineering
involvement in the corrective action process
was very good.
The engineers
appeared to have
up to date,
and detailed understanding of
thei r respective
systems
and responsibilities.
A review of the action
request listing with system engineers
indicated that the system
engineers
were identifying. correcting. tracking,
and closing problems
with their systems
and with other plant systems.
The engineers
knew how
to appropriately
document
problems
and understood
the corrective action
system
(Section E7.3).
0
-4-
TABLE OF CONTENTS
EXECUTIVE SUMMARY
I.
OPERATIONS
07
Qual ity Assurance
in Operati ons
.
07.1
Licensee Resolution of Problems
.
07. 2
Correcti ve Action Program...
07.3
Operating Experience
Feedback
Program
07.4
Licensee
Self-Assessment
Activities
.
I II .
ENGINEERING
E2
Engineering Support of Facilities
and Equipment.....
E2.1
Review of Facility and Equipment Conformance to the
Sa fety Ana lysi s Report Descri ption
E2.2
Plant Walkdowns
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
E7
Quality Assurance
In Engineering Activities
E7.1
Resolution of Problems
E7.2
Corrective Action Programs
E7.3
Licensee
Self-Assessment
Activities
.
. Miscellaneous
Engineering
Issues
(92700)
Xl
. Exit Meeting Summary
5
5
7
8
10
11
12
12
12
15
15
17
-5-
I .
OPERATIONS
07
guality Assurance
in Operations
07. 1
Licensee Resolution of Problems
a.
Ins ection
Sco
e
40500
In order to determine
how effective the licensee
was in identifying and
correcting problems.
the inspectors
performed
a detailed analysis of
several
operational
events,
interviewed licensed
and nonlicensed
operators,
and reviewed quality assurance
audits
and survei llances to
determine if problems were being entered into the corrective action
program and being adequately
resolved in a timely manner.
The inspectors
reviewed the following operational
events:
~
Licensee
Event Report 95-14,
"Reactor Trip, Plant Explosion,
and
~
Licensee
Event Report 96-04,
"Component Cooling Water
Pump Hot
Shutdown
Panel Surveillance Hissed
Due to Personnel
Error"
~
Licensee
Event Report 95-02,
"Manual Reactor Trip Due to Heavy
Debris Loading and
Damage to the Traveling Screens"
~
Licensee
Event Report 95-17,
"Nanual Reactor Trip Due to Heavy
Debris Loading to the Traveling Screens"
The inspectors
conducted
interviews with approximately
15 licensed
and
nonlicensed
operators
to determine the extent of procedural
adherence,
and of repetitive equipment deficiencies
issues.
The inspectors
also reviewed ten quality assurance
audits
and
survei llances to determine if effective audit findings were entered into
the corrective action program.
Some of the quality assurance
audits
included the following:
Corrective Action Effectiveness Audit 960570014:
"Nuclear Power
Generation corrective action program in resolving deficiencies.
concerns,
or problems that affect nuclear safety."
1996 ANNUAL/BIENNIAL/TRIENNIALFire Protection Audit:
"Compliance
and performance of final safety analysis
report with regards to
inspection of fire protection system operability, inspection
of'ntegrity
of fire barriers,
and verification of f'ire protection
program has
been fully implemented."
Radiation Protection
Program Audit 950291A:
"Plant radiation
protection practices."
-6-
~
1R7 Safety System Outage Hodification Inspection Audit 95014I:
"Audit of various design
and procurement activities associated
with various design changes."
~
Fitness-for-Duty Annual Audit 950241,
"Procedure
and record
reviews,
interviews of fitness-for-duty personnel,
and observation
of the collection process."
b.
Observation
and Findin s
During the interviews, the inspectors
did not identify any procedural
adherence
issues.
The operators
indicated to the inspectors that due to
past
examples of procedural
adherence
problems identified by the
NRC,
operations
management
had briefed,
counseled,
and conducted training on
proper procedural
adherence
for plant operations
personnel.
In
addition. the inspectors
determined
through interviews with the
operators that there were no repetitive equipment deficiencies
and that
any equipment deficiencies
were normally corrected via the action
request- process.
The operators
stated that the response to the action
request
as initiated by plant operators
was fully supported
by the
maintenance craft.
The inspectors
observed that the quality assurance
audit findings were
entered into the corrective action program
and tracked in the plant
information management
system via action requests
or nonconformance
reports.
In addition, the audit findings were tracked until closed in
the plant information system.
The inspectors
generally agreed with the
strengths
and weakness
as characterized
in the reviewed audits
and
survei llances.
For example,
the licensee
determined in the Corrective
Action Audit 960570014 that there
was
a lower threshold for identifying
and documenting
problems
on action requests.
The audit also noted
an
improvement in maintaining the estimated
completion dates current
on the
Action A requests
(conditions adverse to quality), quality evaluations
(significant conditions adverse to quality),
and nonconformances.
Additionally, the
same corrective action audit identified
a lack of
effectiveness
of some immediate corrective actions in preventing
recurrence of the problem while corrective actions to prevent recurrence
were being implemented.
c.
Conclusions
The inspectors
determined that the licensee
was effective in performing
the identification and characterization
of issues.
In addition, the
inspectors
determined that licensee
management
review, resolution.
and
root-cause
analysis
were appropriate.
Finally. the inspectors
concluded
that the oaerabi lity and reportabi lity determinations,
corrective
action/evaluations,
and the scope of correct".e actions to prevent
reoccurrence
of events
were satisfactory.
-7-
The inspectors
concluded that the quality assurance
audits were
comprehensive.
with audit findings entered into the plant information
system
and findings tracked unti 1 closure.
For the audits
reviewed,
the
inspectors
concluded that quality assurance
audit findings and
corrective actions
were effective in preventing
reoccurrence
of
problems.
07.Z
Corrective Action Pro ram
a.
Ins ection Sco
e
40500
The inspectors
assessed
the effectiveness
of the licensee's
corrective
action program to independently verify that safety significant issues
were being identified. corrective actions
were appropriately
implemented,
and the results
were fully effective.
The inspectors
interviewed key personnel
involved with the corrective action program to
identify each individual's understanding
of the corrective action
process
and willingness to report problems.
The inspectors
also
reviewed the licensee's
process for identification of problems/issues
and equipment deficiencies,
threshold regarding whether problems
were
identified and addressed.
adequacy of root cause analysis
and
evaluations'imely corrective action implementation
versus untimely,
issues
expanded to include generic concerns,
and identification of
adverse trends.
The inspectors
reviewed the following related licensee
procedures
of the corrective action program:
~
OM7,
"Problem Resolution."
Revision
OA;
~
OM7. ID1, "Problem Identification and Resolution-Action Requests."
Revision 6;
~
OM7. ID2, "Guality Evaluations,"
Revision 3A:
OM7. ID3, "Nonconformance
Report
(NCR)-Technical
Review Group
(TRG)
and Event Investigation
Team (EIT)," Revision 3B;
~
OM7. ID4, "Root Cause Analysis." Revision
1A: and
~
OM7. ID8, "Operability Evaluation," Revision 2.
In addition, the inspectors
reviewed the following corrective action
licensee audits,
which evaluated
the effectiveness
of the corrective
action program:
Corrective Action Effectiveness
Audit 960570014;
performed
between
February
2 and April 18.
1996;
and
Nuclear Ouality Assessment
96047009."Technical
Review Group
(TRG)
Effectiveness
Assessment."
performed
between January
3 and
January
Z6. 1996.
0
-8-
The inspectors
also interviewed
20 individuals involved with the
licensee's
problem identification process.
Observation
and Findin s
The inspectors
determined that each of the applicable procedures
and
documents
were acceptable
to identify, process,
and conduct root cause
analysis of problems
and equipment deficiencies.
The inspectors identified that the licensee's
corrective action program
had
an appropriate threshold
for identification and documentation of
action requests.
The inspectors
noted that the root cause analysis
were
comprehensive
and expanded,
where appropriate for generic concerns.
The
inspectors'eviews
indicated that the corrective actions
appeared
to be
effective in preventing
reoccurrences
of events.
The inspectors identified through interviews that identification and
reporting of problems
was not
a concern,
and the approval of an action
request
was not difficult.
Conclusions
The inspectors
determined that the licensee's
corrective action program
appeared
to be functioning well.
Each of the applicable corrective
action process
procedures
and documents
were acceptable
to identify.
process,
track.
and conduct root-cause
analysis of problems
and
equipment deficiencies.
The inspectors
concluded that the licensee
personnel
they interviewed
had
a satisfactory
knowledge of the corrective action process
and were
willing to report problems.
The inspectors
determined
based
on
interviews that none of those interviewed
had experienced difficulty
initiating an action request,
or having it approved.
0 eratin
Ex erience
Feedback
Pro
ram
Ins ection Sco
e
40500
The inspectors
reviewed the operational
experience
feedback
program to
determine its effectiveness
in assessing,
documenting,
and informing
appropriate plant personnel
of significant plant events in an effort to
prevent their occurrence at the plant.
The inspectors
reviewed several
operational
events
records for consistency with the following program
procedures:
~
OM4. 103,
"Assessment
of Industry Operating Experience."
Revision 1:
and
ISEG-1.
" Industry Operating
Experience
Assessment,"
Revision 1.,
0
-9-
The inspectors
reviewed
31 events for consistency with program
procedures.
and applicability to the licensee
including:
~
"Potential for High Post Accident Closed
Cycle Cooling Water Temperature to Disable Equipment
Important to
Safety";
~
Information Notice 96-02, "Inoperability of Power Operated Relief
Valves Masked by Downstream Indications
Dur ing Testing"
~
"Main Steam Safety Valve Setpoint
Variation as
a Result of Thermal Eftects";
~
Significant Event Record 01-96.
"Transformer Explosion and Loss of
Off-site Power";
and
~
Operating
Event 7627,
"Motor Operated
Valve Fails to Close at
Byron l."
b.
Observation
and Findin s
The inspectors
reviewed the operating experience
feedback
program
procedures
and determined
these
procedures
were excellent in providing
directions for forwarding events to the appropriate
licensee
review
personnel.
The inspectors
noted that the procedures
required entering
the applicable event into the independent
safety engineering
group log
for tracking purposes.
After entering into the independent
safety
engineering
group log, the event
was forwarded for evaluation to
appropriate
personnel.
The inspectors
noted that the operational
events
were screened
for
applicability, entered into the independent
saf'ety engineering
group log.
and forwarded for evaluation via an action request.
The
inspectors
determined that the operational
event source
documents that
required appropriate
licensee corrective actions were planned,
implemented,
and tracked to completion.
The inspectors identified that
all closed
reviewed documents
were tracked to completion via the
independent
safety engineering
group log.
c.
Conclusions
The inspectors
concluded that the operating experience
feedback
program
was functioning effectively. with procedures
that were excellent in
forwarding events to the appropriate plant personnel.
The inspectors
determined that extensive
use of communication
between the licensee's
technical
reviewers
and the plant technical
contact
had occurred.
The
inspectors
determined that out of the 31 plant events
reviewed,
no
discrepancies
were identified.
-10-
07.4
Licensee
Sel f-Assessment Activities
a.
Ins ection
Sco
e
40500
The inspectors
evaluated the overall self-assessment
program to ensure
that the major functional areas
such
as operations,
engineering,
and
maintenance
were evaluated
by the licensee's
quality assurance
audit
program.
Finally, the inspectors
inter viewed personnel,
both oversight
and audited, to gain their knowledge
on the effectiveness
of the effort,
and to assess
the timely response
of the licensee
management
and staff
to the issues identified.
b.
Observations
and Findin s
The inspectors
reviewed the operations'elf
assessment
and found it to
be self critical with many issues identified.
The inspectors
observed
that the assessment
identified the following strengths:
~
A conservative
operating philosophy,
~
A management
commitment to safety,
~
Strong operations
performance
during routine and refueling
operations,
and
~
Effective response to plant transients
and abnormal
alarms
The inspectors
observed that this assessment
also identified the
following weaknesses:
~
Examples of failure of operations
personnel
to follow procedures
were demonstrated
in a Level III, five Level IV, and four noncited
NRC violations,
~
Continued effort was needed to assure that corrective actions
were
fully effective.
and
~
Weakness
in operations
oversight
and control of maintenance
and
engineering activities were being corrected
by increasing
operations
awareness
to the work of others,
and taking
a renewed
ownership of several
programs
such
as the ground buggy control
and
integrated plant testing.
The inspectors
observed that the team that performed the self assessment
was multi-disciplined and the findings of the self assessment
were
consistent with previously identified
NRC inspection findings.
The inspectors
determined that the licensee's
nuclear quality services
group was performing the requi red audits in the areas of operations,
engineering,
and maintenance.
E2
E2.1
-11-
The inspectors
attended
two plant safety committee meetings
and reviewed
minutes
from the Nuclear Safety Oversight Committee.
The inspectors
reviewed the oversight committee meeting minutes
and noted that the
licensee identified, in February
1996, that ineffective corrective
actions were
a problem area.
The oversight committee addressed
this
issue
and
recommended that self assessments
be performed
by a multi-
disciplined team to establish
the extent of problems
and to ensure
adequate
corrective actions
were performed.
Conclusions
The inspectors
concluded that the licensee's
self-assessm
nt activities
were self critical with many issues identified.
The inspectors
identified that the team which performed the self assessments
were
multi -disciplined and the findings of the self assessment
were
consistent with previously identified
NRC inspection findings.
The
inspectors
determined via interviews that the self assessments
were
considered to be effective.
Based
on interviews with licensee
personnel,
and the inspectors'eview
of several self assessments,
the inspectors
determined that the
self-assessment
process
was effective.
III.
ENGINEERING
Engineering Support of Facilities and Equipment
Review of Facilit
and
E ui ment Conformance to the Safet
Anal sis
Re ort Descri tion
Ins ection Sco
e
(37550)
A recent discovery of a licensee operating its facility in a manner
contrary to the safety analysis
report description highlighted the need
for a special
focused review that compares
plant practices,
procedures
and/or parameters
to the safety analysis report description.
While
performing the inspections
discussed
in this report, the inspectors
reviewed the applicable sections of the safety analysis report that
related to the inspection
areas
inspected.
Observations
and Findin s
The inspectors
did not identify any inconsistencies
between the wording
of the safety analysis
report
and plant practices,
procedures.
and/or
parameters
observed
by the inspectors.
0
-12-
E2.2
E7
E7.1
Plant Walkdowns
ti
S
(3i55II)
The inspectors
performed
a plant walkdown of the containment penetration
areas for Unit 2 to determine the overall material condition of
equipment
and maintenance of housekeeping.
Observations
and Findin s
The inspector s found that the overall
housekeeping
for this plant area
was good.
However, during the walkdown on June
6,
1996, the inspectors
identified
a large stack of 3-inch rubber
hose at the 100-foot elevation
of the Unit 2 penetration
area with no transient
combustible material
permit.
Lice'nsee
personnel
stated that the hose
had been stored in the
area for over
a year.
The licensee
subsequently initiated
a plant
walkdown and identified twenty other
examples of transient
combustible
material in the plant without a transient
combustible permit.
The
licensee initiated Action Request
A0406282 on June
6
~ 1996, to address
this issue.
Licensee
Procedure
OM8. ID4, Revision 3, dated
December
21.
1995.
paragraph
5.8. 1 requi red that transient
combustible materials
stored in this area
have
combustible material permit.
The
failure to properly control transient
combustible material is
a
violation of Technical Specification 6.8.1.h,
which requires the
licensee to implement the fire protection program procedures
(50-323/96013-01).
Conclusions
The inspectors
did not identif'y any discrepancies
between the safety
analysis report and actual plant conditions.
In fact, the licensee
had
already instituted
a review to determine the extent of inaccuracies
in
the safety analysis report.
Overall, plant housekeeping
and equipment
material condition were good with the exception of the identified
violation regarding the storage of transient
combustible materials.
The
licensee
performed
a separate
investigation into the storage of
combustibles
and found 20 additional
examples of improper
storage of transient combustibles.
guality Assurance
In Engineering Activities
Resolution of Problems
Ins ection
Sco
e
40500
The inspectors
reviewed
how effectively the licensee
was identifying and
correcting problems.
To accomplish this objective the inspectors
reviewed
and assessed
the engineering
backlog,
selected operability
evaluations to assess
the engineering
analysis,
a listing of recent
corrective maintenance
work orders,
and
a list of modifications in the
-13-
backlog to determine if any were safety significant.
In addition, the
inspectors
reviewed the following four operability evaluations to assess
the engineering
analysis:
95-03.
dated
March 22.
1996
~ "Operability of the Auxiliary Salt
Water System With Potential
External Corrosion," Revision 2;
95-12,
dated
March
15
~ 1996,
"Basis for Operation of Unit 1,
Without Auxiliary Transformer
1-1 and Supplying
12 kV Buses
from
the 230
kV System,"
Revision 3;
95-09 'ated
May 10,
1996, "Acceptability of Continued Operation
with a Small. Steam
Leak on Steam Generator
2-3 Instrument
Tap
Line," Revision 1;
and
95-11.
dated
March 7,
1996, "Operability of Component Cooling
Water with Analyzed
CCW Water Temperature
Higher Than Current
Design Basis." Revision 2.
b.
Observation
and Findin s
Action Re uest Backlo
The inspectors
noted that
a large backlog of action requests totaling
11,071 existed.
The licensee indicated, that of theses
1,074 were
Category
A requests,
which represent
conditions adverse to quality.
The
licensee
considered this to be
a manageable
level
and stated that only
134 of these
were in operations.
However, the inspectors
were concerned
that the backlog in engineering
action requests
had increased
from a
level in February
1996 of 6200 to a level of 6700 in June of 1996 and
the licensee did not have
a clear view of the reason for this increase.
However. the licensee
had begun
an investigation of various methods to
reduce the backlog at the time of the inspection.
Although, the
inspectors
reviewed approximately
300 backlog items, the inspectors
did
not identify any examples of safety-significant
problems that had not
received
prompt corrective actions.
0 erabilit
Evaluation 95-03
The inspectors
noted that the licensee
had established
an aging
management
program in 1992, after the failure of a 4-inch diameter
annubar off of the auxiliary salt water piping due to external
corrosion.
The auxiliary salt water
system is
a safety-related
system,
consisting of two redundant trains,
designed to remove heat
from the
component cooling water system during all modes of operation,
including
a design basis accident.
In order to better quantify the aging aspects
of the buried piping,
an investigative program was initiated in late
1992.
The licensee
also initiated
a site wide corrosion assessment
to
estimate the condition of external
coating
and to project the potential
-14-
for corrosion
damage.
Testing completed in early 1994 was largely
inconclusive.
Another
program was performed to quantify the condition
of auxiliary salt water piping and was completed in early 1995.
The
testing determined that there
was
a potential for excessive
corrosion
on
the Unit 1 auxiliary saltwater piping located in the tidal zone near the
plant's intake structure.
Based
on the inspectors'eview
of Operability Evaluation 95-03 and
discussions
with licensee
personnel,
the inspectors
noted:
(1) portions
of the piping for the system were buried in 1971;
(2) the piping was
coated with fiberglass
and epoxy which had
a projected life of 20 to
25 years;
(3) licensee testing determined that the corrosion rate in the
tidal area
could be as high as
40 mils/year;
(4) the nominal pipe wall
thickness
was 375 mils.
From this information, the inspectors
calculated that, if the coating failed after 20 years,
by 1996 the
portion exposed to corrosive conditions of 40 mils/year could be
175 mils in pipe wall thickness.
The licensee's
evaluation concluded
that
188 mi ls was the minimum pipe thickness for a 2"
X 1.5" pit to
survive
a design basis seismic event.
Assuming worst case,
the
inspectors
questioned
whether
further testing
was necessary,
to
demonstrate
that the coating would not fail.
The licensee
stated that various sections of the pipe had been
excavated,
but the evaluation did not demonstrate
that the excavated
iping sections
were representative
of all piping sections.
The
icensee
stated that cathodic protection
had been installed in the
intake structure in 1995 to reduce corrosion rates.
Licensee
personnel
informed the inspectors that they did not believe that any degradation
of the coating
had occurred
and thus the piping was still operable.
The
licensee stated that inspections of the coating.
which were excavated,
near the turbine building, in 1994,
showed
no degradation.
The inspectors
concluded that further information was needed to
determine whether the auxiliary salt water piping would remain
functional following a design basis seismic event.
This issue will be
tracked
as
an inspection followup item (50-275/96013-01)
pending further
NRC review.
c.
Conclusions
The inspectors
did not find any examples of safety-significant
problems
that had not received
prompt corrective actions.
The inspectors
concluded that Operability Evaluations
95-09 '11,
and -12 adequately
demonstrated
system operability.
However. in
reviewing Operability Evaluation 95-03 several
questions
needed further
clarification to properly characterize
and de'.ermine the
ffect of
corrosion rates
on piping in the tidal zone.
-15-
Corrective Action Pro rams
Ins ection Sco
e
40500
The inspectors
reviewed
a listing of recently completed engineering
work
orders,
modifications,
and action requests
and selected
a sample to
determine the adequacy of engineering
involvement.
The inspectors
reviewed
12 selected
work orders,
3 design
changes.
and
10 action requests
for the adequacy of engineering
involvement.
The
inspectors
reviewed the entire design
change
backlog
and
a sample
listing of approximately
300 action requests
to ensure that the safety
significant design
changes
were appropriately prioritized.
Observation
and Findin s
The inspectors
observed that engineering evaluations,
where needed,
had
been properly completed.
The inspectors
further observed,
that system
engineers
were involved with tracking and resolving issues
as
documented
in action requests.
The inspectors
noted that system engineers
were
able to rapidly produce the status of any unresolved
items for their
respective
systems.
The inspectors
noted
no work backlog items which
had not been properly prioritized.in accordance
with the apparent safety
significance of the item.
Conclusions
The inspectors
concluded that engineering
involvement was appropriate
for the work required
and that none of the items reviewed were
inappropriately closed out.
The inspectors
did not identify any safety
significant items in the backlog that wer e not appropriately
prioritized.
Licensee
Self-Assessment
Activities
Ins ection Sco
e
40500
The inspectors
interviewed system engineers to assess
engineering
involvement in the corrective action process.
A total of six engineer s
were interviewed.
Observation
and Findin s
The inspectors
interviewed six randomly selected
system engineers.
The
inspectors
questioned
the engineers
concerning
open action requests
which had been selected
from a review of the open action request
listing.
The engineers
were knowledgeable of each action request
selected.
The inspectors
noted that the engineers
appeared to have
up
to date,
detailed understanding
of their respective
systems
and
responsibilities.
A review of the action request listing with system
E8
E8. 1
E8.2
-16-
engineers
displayed that the system engineers
were identifying,
correcting.
tracking.
and closing problems with their systems
and with
other plant systems.
The engineers
knew how to appropriately
document
problems
and understood
the corrective action system.
Conclusions
Involvement in the corrective action process
was very good.
The engineers
appeared
to have
up to date. detailed understanding of
thei r respective
systems
and responsibilities.
A review of the action
request listing with system engineers
displayed that the system
engineers
were identifying, correcting, tracking,
and closing problems
with their systems
and with other plant systems.
The engineers
knew how
to appropriately
document
problems
and understood
the corrective action
system.
Hiscellaneous
Engineering
Issues
(92700)
Closed
LER 1-94-001-01:
Inadequate fire barrier penetration
seals
resulting from a lack of damming boards
due to
a programmatic
deficiency.
On January
28,
1994, the licensee
determined that
some
seals
may not meet the required fire rating due
to damming boards not installed
on the ends of the seals.
The licensee established
a program to walkdown all requi red fire barrier
seals to document the installed configuration and to ensure that all
required seals
have
a basis for qualification.
The licensee
established
compensatory fire watches in all required plant areas
since initial
plant licensing.
The inspectors
reviewed the licensee's
program to establish
seal
qualification.
The program involved updating station drawings,
additional fire testing.
changes
to work control documents,
and
a
100K
walkdown of all fire barriers.
The inspectors
concluded that the licensee's
program would correct the
seal deficiencies
and should prevent
a recurrence of the problem.
This
licensee
event report is not
a violation because
required licensee
compensatory
measures
had been established
and in place since initial
licensing.
This item is closed.
Closed
LER 1-95-003:
Fire barriers outside design basis
due to
inadequate testing qualification basis.
On March 15,
1995, the licensee
determined that certain requi red fire barriers
were of indeterminate
fire rating.
The licensee
used pyrocrete for fire barriers in
configurations which had not been tested to ensure that it was
a rated
3-hour barrier.
-17-
The licensee
had established fire watch tours of the required barrier
areas
since the plant was initially licensed.
The licensee
performed
additional evaluation
and determined that
some of the barriers
were not
required.
At the time of the inspection.
the licensee
had fire tests
planned to test the pyrocrete in the installed configuration.
The inspectors
reviewed. with the licensee,
the barriers which were not
required
and agreed with the licensee's
conclusion.
The inspectors
inspected
the barriers in question
and noted
a low combustible material
loading in the areas.
The inspectors
discussed,
with the licensee,
the
type of testing planned.
Based
on those discussions it appeared that
the tests, if successful,
would demonstrate
that the barriers
are
acceptable.
If the tests
were not successful
the licensee
stated that
other options
such
as
a license exemption or material
replacement
would
be considered.
The inspectors
concluded that this licensee
event report was not
a
violation because
compensatory fire watches
had been established
since
initial plant licensing.
The inspectors
concluded that licensee
corrective actions
planned should be adequate
to correct the
deficiencies.
Xl
Exit Heeting
Summary
An exit meeting
was conducted
on June
28,
1996.
During this meeting,
the inspectors
summarized the scope
and findings of the inspection.
The
~ licensee did not express
a position on the inspection findings
documented
in this report.
The licensee staff acknowledged
the findings
presented
at the exit meeting.
The licensee did not identify as
proprietary any information provided to, or reviewed by, the inspectors.
~,
Licensee
ATTACHMENT
PARTIAL LIST OF
PERSONS
CONTACTED
M. Angus.
Manager.
Regulatory
and Design Services
C. Belmont. Supervisor.
Nuclear Performance
Monitoring
W. Blunt, Engineer.
Nuclear Safety Engineering
M. Culala,
QC Specialist.
Nuclear Quality Control
R. Curb,
Manager.
Outage Services
T. Grebel, Director, Regulatory Services
J.
Gregerson.
Engineer.
Balance of Plant Systems
Engineering
D. Hampshire,
Senior
Engineer,
Balance of Plant Systems
Engineering
D. Miklush, Manager,
Engineering Services
J. Shoulders,
Director, Engineering Services
J. Strickland, Civil Supervisor,
Engineering Services
D. Taggart. Director, Nuclear Quality Services
R. Whitsell, Auditor, Nuclear Quality Assurance
NRC
C. VanDenburgh,
Chief. Engineering
Branch
LIST OF
INSPECTION
PROCEDURES
USED
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving,
and
Preventing
Problems.
IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power
~Reactor
Facilities
IP 37500:
Engineering
LIST OF
ITEMS OPENED
CLOSED
AND DISCUSSED
0~en ed
50-323/96013-01
50-275/96013-01
VIO Failure to have adequate fire protection material
control.
IFI
Adequacy of the operability evaluation for the
ASW
buried piping
Closed
50-275/94-001-01
LER
Inadequate fire barrier penetration
seals
50-275/95-003
LER
Fire barriers outside design basis
due to inadequate
testing qualification basis