ML17279A373

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Insp Rept 50-397/87-09 on 870401-0523.Violations Noted: Removal of Underwater Light from Fuel Pool W/O Conducting survey,39 Gas Bottles Secured W/Rope to safety-related Cable Tray Support & Weekly Source Check Not Performed on Monitor
ML17279A373
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 06/17/1987
From: Bosted C, Dodds R, Johnson P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17279A371 List:
References
50-397-87-09, 50-397-87-9, NUDOCS 8707080220
Download: ML17279A373 (16)


See also: IR 05000397/1987009

Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION

V

Report No:

Docket No:

Licensee:

50-397/87-09

50-397

I

Washington Public Power Supply System

P. 0.

Box 968

Richland,

WA 99352

Facility Name: Washington Nuclear Project No.

2. (WNP2)

Inspection at:

WNP-2 Site near Richland, Washington

Inspection

Conducted: April

1 - May 23,

1987

Inspectors:

. T.

Dod s, Senior

es> ent Inspector

Dat

Si

ned

Approved by:

oste

,

Ress

ent

nspector

P.

H. Johnson,

C ief

Reactor Projects

Section

3

a

e

signed

Da

e

signed

Summary:

Ins ection

on A ril

1 - Ma

23,

1987

50-397 87-09

~AI<<:

i

i

p

i

b

h

id

i

P

. room operations,

engineered

safety feature

(ESF) status,

surveillance

program,

maintenance

program,

licensee

event reports,

special

inspection topics,

spent

fuel pool

and refueling activi.ties, simulator upgrade,. initial control rod

drive installation, radiological protection,

management

involvement,

gA

program for MSTE, local leak rate testing,

BWR radiological controls for

drywells during spent fuel movements,

operator attentiveness

to duties,

control of overtime,

and licensee

action

on previous inspection findings.

During this inspection,

Inspection'rocedures

30703,

35701,

35750,

40700,

41400,

60710,

61701,

61710,

61720,

61726,

62702,

62703,

71707,

71709,

71710,

71881,

86700,

90712,

90713,

92701,

92702,

92703,

93702,

and 92700 were

covered.

Results:

Of the

23 areas

inspected,

three apparent violations were identified

pertaining to the control of gas bottles

(paragraph 3),

removal of equipment

from the fuel pool (paragraph 8), and source

check of a constant air monitor

(paragraph 8).

i

8707080220

870617

PDR

ADOCK 05000397

6

PDR

DETAILS

Persons

Contacted

J.

Shannon,

Deputy Managing Director

  • C. Powers,

Plant Manager

"R. Glasscock,

Licensing

8 Assurance

Director

  • J. Baker, Assistant Plant Manager
  • H. McGilton, Manager,

Operational

Assurance

Program

"R. Corcoran,

Operations

Manager

"S.

McKay, Assistant Operations

Manager

~A. Hosier, Nuclear Safety Assurance

Group

(NSAG) Manager

"K. Cowan, Technical

Manager

"D. Walker,

Outage

Manager

"R. Graybeal,

Health Physics

and Chemistry Manager

D. Feldman,

Plant guality Assurance

Manager

"M. Bartlett, Operations guality Assurance

Supervisor

"J. Peters,

Administrative Manager

P.

Powell, Licensing Manager

M. Wuestefeld,

Reactor

Engineering Supervisor

"J.

Landon,

Maintenance

Manager

T. Stanley,

Principal Engineer

"S. Washington,

Sr.

Compliance

Engineer

  • J. Arbuckle, Compliance

Engineer

  • Personnel

in attendance

at 'exit meeting

The inspectors

also interviewed various control

room operators, shift

supervisors, shift managers,

and engineering,

quality assurance,

and

management

personnel

relative to activities in progress

and records.

Plant Status

The plant operated at approximately 71.5X power from April 1 until

shutdown

on April 10, 1987, for the annual refueling and maintenance

outage.

The outage

was expected to be completed

and the plant ready for

startup early in June.

The fuel shuffle was completed

and

20 control

drives exchanged,

ahead of schedule

on May 11,

1987.

Principal

maintenance activities included the removal

and refurbishing of the

internals of both reactor recirculation

pumps, including seal

and

stuffing box modifications to eliminate the type of mechanical

failures

experienced

in the past.

A containment

vessel

(drywell/wetwell)

integrated

leakage rate test will be conducted at the end of the outage.

No significant operating events

occurred during the reporting period.

0 erations Verifications

The resident

inspectors

reviewed the Control

Room Operator

and Shift

Manager log books

on a daily basis for this report period.

Reviews were

also

made of the Jumper/Lifted

Lead

Log and Nonconformance

Report

Log to

verify that there were

no conflicts with Technical Specifications

and

that the licensee

was actively pursuing corrections to conditions listed

in either log.

Events involving unusual

conditions of equipment

were

discussed

with the control

room personnel

available at the time of the

review and evaluated for potential safety significance.

The licensee's

adherence

to Limiting Conditions for Operation

(LCO's), particularly

those dealing with ESF and

ESF electrical

alignment,

were observed.

The

inspectors

routinely took note of activated annunciators

on the control

panels

and ascertained

that the control

room licensed personnel

on duty

at the time were familiar with the reason for each annunciator

and its

significance.

The inspectors

observed

access

control, control

room

manning, operability of nuclear instruments,

and 'availability of on site

and offsite electrical

power.

The inspectors

also

made regular tours of

accessible

areas

of the facility to assess

equipment conditions,

radiological controls, security, safety

and adherence

to regulatory

requirements.

During a tour of the Reactor Building on April 26, 1987, the inspector

observed that 39 apparently

empty gas bottles

had been attached

to

safety-related

cable tray support

PS-4362 in the railroad bay of the

reactor building.

The support held safety-related

cable trays

numbers

S-DIV-2-2200, C-DIV-2-2350, and P-DIV-2-2500.

This appeared

to be

a

violation of Plant Procedure

1.3. 19, "Housekeeping,"

which states

that

gas bottles

are not to be secured

to safety-related

equipment

such

as

conduit, pipes,

etc.

(Enforcement

Item 87-09-01)

Monthl

Surveillance Observation

The inspectors

ascertained

that surveillance of safety-related

systems

or

components

was being conducted in accordance

with license

requirements.

In addition to witnessing

and verifying daily control panel

instrument

checks,

the inspectors

observed portions of the following detailed

surveillance

tests

by operators

and technicians

on the dates

indicated.

PPM 7.4.6.5.3. 1, Standby

Gas Treatment

System Operability Test.

(May 9,

1987)

PPM 7.4.6. 1.2.4,

Containment Isolation Valve and Penetration

Leak Test.

(May 1, 4, 6, 1987)

PPM 7.4.3.7.5.49,

Accident Monitor Instrumentation Calibration for SM-4,

7,

and 8.

(April 22, 1987)

PPM 7.4.8. l. 1.2.6,

HPCS Diesel Generator

Loss of Power Test

(April 26,

27, 1987)"

PPM 7.4.3.3.2.27,

HPCS

Loss of Power/Loss of Coolant Accident Test.

(April 27, 28, 1987)"

PPM 7.4.0.5. 14,

CAC Valve Operability Test

(May 9, 1987-Data

Review)

"Complex surveillance observation/verification following 3 year

mechanical

maintenance

inspection of the

HPCS diesel

engine.

No violations or deviations

were identified.

S ent Fuel

Pool

and Refuelin

Activities

The inspectors verified that prior to the handling of fuel in the core,

surveillance testing required

by technical specifications

and licensee

procedures

had been completed; verified that during the outage the

periodic testing of refueling related

equipment

was being performed

as

required

by technical

specifications

and that reactor building

ventilation and reactor pool/spent fuel pool conditions were maintained

within the prescribed

technical specification limits; observed

several

shifts of fuel handling operations;

verified that good housekeeping

was

being maintained in the refueling area,

and verified that staffing during

the refueling was in accordance

with technical specifications

and

approved procedures.

An accurate

record was maintained in both the

control

room and

on the refueling bridge of all fuel loading changes.

Fuel bundle location was verified periodically and minimum shutdown

margin checks

were appropriately performed during and after the fuel

shuffle.

Following completion of the fuel shuffle,

a total of 20 control rod

drives were

removed

and replaced with spare drives.

The associated

fuel

cell was unloaded to the storage

canal pri'or to each

exchange.

Appropriate nuclear instrumentation

was available

and periodically

checked.

The inspectors

also observed activities associated

with the removal

and/or the replacement of the reactor vessel

head,

steam separator

and

steam dryer.

No violations or deviations

were identified; however,

the licensee

informed the inspector that

a source

range monitor had been tested

simultaneously with .insertion of a fuel bundle into the core.

This item

was to be reported to the

NRC within thirty days pursuant to 10CFR50.73.

Initial Control

Rod Drive Installation - Code Waiver

Re uest

During the period of November

1982 to'January

1983, the Washington Public

Power Supply System installed

185 control rod drives

(CRDs) in the lower

reactor vessel

head.

At the time of installation, the Supply System did

not have

an

ASME Certificate of Authorization to use the applicable

N-type symbol or stamp permitting installation of the

CRDs.

A bolted

flange is used to connect

each

CRD to the vessel

head.

This deviation from the

ASME Section III Code was identified by guality

Assurance

when the

gA inspector tried to locate the

Code data

N-5 forms

from the initial installation.

An NCR was issued to document

and

disposition this discrepancy.

The State

Department of Labor and Industries

was informed of the

deviation

and asked to accept the installation as-is

based

upon. the

licensee's

gA program at the time of installation.

While the

CRDs were

not installed

by an

ASME certificate holder, the procedure

included all

the planned

and systematic

actions

necessary

to assure

that the

CRDs were

installed correctly and would perform satisfactorily in service.

The

State

was provided

a copy of relevant installation records to support

this contention.

It was the Supply System's

position that the cost

and risks of removing

and reinstalling the 185

CRDs would have

no real benefit and would not

demonstrate

any increased

safety relating to the actual

use of the

CRDs.

Removal, reinstallation

and repeat of the field hydrostatic pressure

test

has the potential for affecting the pressure

boundary integrity as well

as

undue radiation exposure to personnel.

Additionally, during annual

refueling outages,

CRDs will be systematically

removed for inspection

and

refurbishment

on a staggered

ten year maintenance

schedule.

The State

Department of Labor and Industries, with the Energy Facility

Siting Evaluation Council's

(EFSEC) concurrence,

granted the waiver and

accepted

the installation as-is during a Board meeting

on May 19,

1987.

The inspector

examined the licensee's

supporting documentation for the

CRD installation.

The examination of this documentation

indicated the

CRDs

had been installed

and tested in conformance with the Licensee's

gA

program.

In addition, the initial hydrostatic pressure

test of the

installed

CRDs

on January

29,

1984 had been

observed

by the

NRC

inspection staff.

Simulator

U

rade

A plant specific simulator

was purchased

and installed prior to plant

operation.

The implementation of simulator changes

identified through

plant preoperational

testing

and operation

lagged behind those in the

plant.

Management

has recognized that the simulator and plant were

diverging and

an upgrade

program for the simulator

has

been initiated.

A

review of the simulator upgrade

program was

made,

and direct observation

of the simulator was conducted

during formal licensed training.

The inspector

noted that the simulator reflects most of the current

hardware

changes

that have occurred in the control

room operating boards.

The remaining changes

appear to be scheduled for completion.

Some

simulations

were observed to be lacking; these

were especially evident in

low temperature,

low pressure

feedwater

upset events.

The inspector

was

informed that these conditions

had been

noted

and were scheduled for

change

when the model

was revised.

The inspector

noted that the simulator

upgrade

program plan appeared

to

be well thought out and systematically

implemented.

The objective of the

plan is to have

a certifiable simulator available for licensed operator

training and examination within a four year time frame.

The plan is

designed to meet or exceed

the Electric Power Research Institute (EPRI)

standards

and will comply with ANSI/ANS 3.5-1985 "Nuclear Power Plant

Simulator for Use in Operator Training", the proposed revision of 10 CFR 55,

and Regulation

Guide 1. 149.

Overall, the program for matching the simulator to the plant appeared

to

be on schedule

and progressing

in a controlled and well thought out

manner.

Although the schedule

is not expected to be completed until mid

1990, the training department staff expressed

optimism that the changes

can

be effective before that time.

No violations or deviations

were identified.

8.

Radiolo ical Protection

The inspectors periodically observed radiological protection practices

to

determine whether the licensee's

program was being implemented in

conformance with facility policies

and procedures

and in compliance with

regulatory requirements.

The inspectors verified that health physics

supervisors

and professionals

conducted

frequent plant tours to observe

activities in progress

and were generally

aware of significant plant

activities, particularly those related to radiological conditions and/or

challenges.

ALARA consideration

was given'ach job that was

done during

the refueling outage

and was discussed

frequently at the daily Manager'

meeting, particularly with respect to the big jobs such

as the reactor

recirculation

pumps

and control rod drive replacements.

The various Radiation Work Permits

(RWPs) in use at principal entry

points such

as those for the refueling deck,

the dry well and the wet

well were examined

and found to consider the appropriate

elements.

The

RWPs generally referred the wor ker to the Health Physicist for the latest

specific activity levels in the area.

There appeared

to be sufficient

Health Physicists available to support the activities in progress.

Workers appeared

to have the proper monitoring equipment

and dosimeters

for their area of work, including high radiation areas.

High radiation

areas

were posted

and radiation warning lights were in use where

appropriate.

Personnel

exiting radiation/contamination

zones

were

observed

to conduct frisks in accordance

with the licensee's

procedure.

The inspector

questioned

the propriety of the following practices that

were observed

on the refueling deck.

a.

A radiation area monitor was not in use

on the refueling bridge.

The responsible

Health Physicist agreed that this was

a prudent

policy and promptly located

a portable monitor

on the bridge.

Later, licensee

management

stated that

a permanent

monitor will be

maintained

on the bridge

and that

a Plant Modification Request to

'ffect

this change

had been issued.

On April 26, 1987, at approximately

1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />,

the Health Physicist

set his portable survey meter

on the refueling bridge deck and

assisted

operators

in the removal

and baggin'g of an underwater light

rather than surveying the light as it was being removed from the

pool.

A subsequent

survey, after the inspector questioned

the

activity, did not indicate

any significant radiation levels.

On May

7, 1987, at approximately '1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />,

Operations

personnel

removed

a

television

camera

from the pool that had been

used during control

rod unlatching operations without having it surveyed

as it was being

removed.

The Health Physicist subsequently

performed

a survey

following questioning

by the inspector

and determined that the

radiation level

was less

than

10 mrem/hr.

Failure to perform

surveys of equipment

upon removal

from the fuel pool appears

to be

a

violation of regulatory requirements

(10CFR20.201)

and the

licensee's

Radiation Work Permit 2-87-00138 for refueling bridge

activities.

(Enforcement

Item 87-09-02)

C.

At the time of the inspection

on April 26,

1987, portable monitors

AMS-3 RB4A (CAM) and RRA-RIS-1/AD-03 (ARM) had not been source

checked

since April 13,

1987.

The failure to source

check AMS-3

RB4A was identified to the licensee

as

a violation of Plant

Procedure

11.2.24. 1 which required the

CAM to be source

checked

weekly.

A subsequent

source

check

showed the monitors to be

functioning properly.

(NOTE: the

ARM need only be checked

by Plant

Procedure

when placed in operation,

even though it was being checked

weekly).

(Enforcement

Item 87-09-03)

9.

Monthl

Maintenance

Observation

and Post Maintenance

Restoration

Portions of selected

safety-related

systems

maintenance activities were

observed.

By direct observation

and review of records the inspector

determined

whether

these activities were consistent with LCOs;, that the

proper administrative controls

and tag-out procedures

were followed; open

system controls were in effect as appropriate;

and that equipment

was

properly tested

before return to service. It was specifically observed

that workers tended to clean

up after themselves

at the end'f the day

and were quite thorough in restoring the area at the end of the job.

The

inspector

also reviewed the outstanding job orders to determine if the

licensee

was giving priority to safety related

maintenance

and verify

that backlogs

which might affect system performance

were not developing.

The following maintenance activities were observed:

Repair of Reactor Building Security Door (AU5703)

I

'O'ing seal

replacement

on

RRC

FCV 'A'ydraulic packages

(AU8120)

Replacement

of reactor pressure

scram switch

(AU7839)

Preventive

maintenance

on Condensate

Pump 2-B 4160V breaker

Refurbishment of Main Turbine Governor Valve Hydraulic Actuators

(AU8423)

Preventative

Maintenance

on

RRC Flow Control Valve 'A'ryquil

system pressure

switch HY-PS-A2125

Installation of Emergency Utility for Auxiliary Building (AU8078)

Repairs

on Fuel Handling gripper light

(AV1114)

Preventative

maintenance

on 480 volt breaker per

PPM 10.25.2

Diesel generator

1 modification to ensure

engine to generator

alignment

(AU9506;

PMR 86-329-0)

Diesel generator airstart motor rebuild and replacement

(AU9759)

Diesel generator

18 month inspection

(PPM 7.4.8. 1.2. 14)

HPCS Diesel generator - replacement of brushes

(PPM 10.25.49)

HPCS Diesel generator - welding for shield grating

(AU9032)

HPCS Diesel Generator - 3 year maintenance

inspections'AU9322;

PPM

10.20.14)

HPCS Diesel generator - inspect main bearings

(AU9319)

RWCU High Differential Flow transistor failure (AV1146)

No violations or deviations

were identified.

10.

Mana ement Involvement

Examination of "Housekeeping

Reports"

by Area Coordinators for the months

of January-March

1987 indicate that assigned

actions

were being

accomplished

in a timely manner.

Explanation were provided for any

action that was outstanding for more than 4 weeks, =including an

indication of when corrective action was expected to be completed.

The inspectors

continued to notice the presence

of plant and corporate

management

in the plant evaluating 'plant conditions throughout the

refueling outage.

The inspector

also

accompanied

the Assistant Plant

Manager

on one of his tours.

He stated that it was his policy to tour a

different area at least weekly.

Log book entries

indicated that

operations

management

was frequently on site during the back shifts and

on weekends.

Overall, it is the inspectors'erception

that there

has

been

a

substantive

involvement of all levels of Corporate

and Plant management

at the

WNP-2 facility.

ll.

En ineered Safet

Feature Verification

The inspector verified the operability of the Standby

Gas Treatment,

Standby Liquid Control, High Press

Core Spray

(HPCS), Diesel Generator

2,

and Diesel Starting Air Systems

by performing a walkdown of the

accessible

portions of the systems.

The inspector, confirmed that the

licensee's

system lineup procedures

matched plant drawings

and the as-

built configuration,

and verified that valves were in the proper

position,

had power available,

and were locked as appropriate.

The

licensee's

procedures

were verified to be in accordance

with the

Technical Specifications

and the

FSAR.

No violations or deviations

were identified.

12.

ualit

Assurance

Pro

ram for Measurin

and Test

E ui ment

The inspectors

examined the licensee's

program for the control of

measuring

and test equipment

(M8TE). Plant records

include the

"Calibration Report" which lists test instruments

used

and certifies

them

to have calibrations traceable

to the National

Bureau of Standards

(NBS).

Plant Procedure

1.5.4,

"Control of Measuring

and Test Equipment-Transfer

Standards,"

defines the measures

established

to assure that tools,

gauges,

instruments,

and other measuring

and test devices

used in

activities affecting quality will be properly controlled, calibrated,

and

adjusted at specified periods to maintain accuracy within the necessary

limits.

The proper

use

and control of M&TE was verified by the inspectors

during

the observations

of maintenance

and surveillance activities discussed

elsewhere

in this report.

The inspectors

frequently visited the Tool

Crib during the outage

and verified that equipment controls were being

implemented in accordance

with program requirements.

The licensee's

latest audit of this area (Surveillance

Report

No.

2-86-157,

conducted

January

16-23,

1987) identified eight deficiencies

that have

been appropriately corrected.

The Surveillance

Report was

made

mandatory reading for all maintenance

personnel.

The gA/gC Department's

observation

program includes

M&TE control

as

one of the attributes to be

inspected.

Of 50 activities observed

during the refueling outage,

only

two minor deficiencies

were identified in the area of M&TE control.

The

Plant Manager informed the inspectors

that

he had personally challenged

the Maintenance

Manager to do better by reducing the number of identified

deficiencies'he

observation

program appeared

to indicate

an improving

trend.

No violations or deviations

were identified.

Local

Leak Rate Testin

The containment local leak rate test

(LLRT) program was reviewed by the

inspector.

Through records

review, direct observation,

and independent

calculation,

the program implementation

was ascertained.

Records for

leak rate tests

on boundary penetrations

and valves were reviewed for

frequency

and acceptability,

and to insure that actions required

by the

Technical Specifications

were being met.

For selected

maintenance

outages,

penetrations

and valves were reviewed'o verify that repairs

were preceded

and followed by LLRTs.

Test equipment

used during the

LLRTs was also reviewed to insure that the equipment was.within

calibration during the test.

During the refueling outage,

the inspector witnessed

the testing of

valves

RFW-V-32B and CIA-V-31B and penetrations

X-73e and X-lf.

A review of testing performed during the previous refueling outage

was

also reviewed.

The total leak rate

was calculated

from the results of

the individual leakage

rates

and compared with the data furnished

by the

licensee's

staff.

The inspector

concluded that the local leak rate

testing program was in conformance with the procedure.

No violations or deviations

were identified.

BWR Radiolo ical Controls for Dr

elis Durin

S ent Fuel

Movements

An inspection

was performed to evaluate

the radiological controls for

access

to and work in the drywell during spent fuel movement.

During

certain spent fuel movement conditions,

very high dose rates

can exist in

the drywell.

A transfer of a spent fuel bundle from the reactor pressure

vessel

(RPV) to the spent fuel pool requires

the fuel bundle to.be lifted

over the

RPV flange, over the drywell and through the "fuel cattle chute"

area,

into the spent fuel pool.

Normal fuel transfers

cause

a high

transitory dose rate in the drywell for short periods of time.

A loss of

power or malfunction could cause

higher dose rates in the drywell, and

a

dropped fuel bundle in the drywell region could cause

very large dose

rates in the upper drywell region.

The licensee's

written procedures,

training programs,

and organization interfaces

were examined.

The fuel

cattle chute

was also reviewed to determine

the adequacy

of the shielding

used to reduce the exposure

in the drywell.

The inspector

determined that the licensee

was aware of the potential

problem with personnel

exposures

during fuel handling and plant

procedures

administratively controlled access

above the 548'levation of

the drywell.

Fuel handling procedures

require that the radiation

protection health physics

group contact the control

room and refueling

supervisor

and that the upper drywell be cleared of personnel prior to

commencement

of fuel handling operations.

Installed radiation monitors in

the drywell above the 548'evel

provide an alarm,

and warning lights

activate,

on high radiation level.

Through conversations

with members of the engineering

department staff,

the inspector

determined that the fuel chute

was site fabricated

from

stainless

steel

and

has

a bottom thickness of approximately

9 j./2 inches.

The lower sides

are approximately

6 inches thick, and the

gamma reduction

factor is approximately

1000 to the drywell.

No weakness

were identified in the licensee's

approach to recognizing the

conditions or implementing administrative corrective measures.

The

installed hardware,

both radiation monitoring equipment

and the fuel

chute,

appeared

to be adequate

to meet the expected conditions.

Operation of the potential

high radiation area warning lights at the 548

foot elevation inside the drywell was verified by the inspector during

fuel handling operations.

0 erator Attentiveness

to Duties

The

NRC order to shut

down Peach

Bottom j. and

2 was discussed

with

licensee

management

and security personnel.

While the licensee did not

believe it would happen at WNP-2, all licensed

personnel

and others

were

informed via an interoffice memorandum

dated April 7, 1987, that if it

happened,

at the very least,

the offender would be removed

from licensed

duties.

The memorandum

contained

several

attachments

directly related to

the order.

Discussions

held with plant security personnel

indicated that the

security force generally alerted plant personnel

when corporate

management

or the

NRC came

on site during the off-shifts. It was not

clear whether the

NRC notification pertained to non-routine

NRC

inspectors

requiring Shift Manager approval

or others.

Nevertheless,

the

10

licensee

stated that this practice will be stopped for other than those

cases

where plant management

approval is required for entry.

According to the Plant Manager,

the plants in Region

V will be developing

a generic plan to assure

that management

and the

NRC will get

a realistic

review of operations

personnel

behavioral

practices.

The inspector

was

assured

by Corporate

Management that "underground" notification practices

would not be tolerated.

Security management

issued

a memorandum to this

effect to the security force.

Also, security issued

a memorandum

pertaining to "attentiveness

to job accomplishments".

These

memoranda

were considered

by the inspectors

to adequately

address

the subject

issues.

In addition, the Managing Director discussed

the Peach

Bottom event

and

its repercussions

on the nuclear industry .in the employee's

"Newsline"

tabloid.

The inspectors

performed

a number of off-shift inspections

during the

report period, including nights (both swingshift and graveyard)

and

weekends.

No buffoonery or other lack of attentiveness

to duty was

observed

in operations

or security.

16.

Overtime

During a review of employee

over time, the inspector

compared

the use of

"Deviation of Overtime Restrictions"

(Attachment

A of procedure

1.3.27,

"Overtime Control" ) to the requirements

of Technical Specification 6.2.2.f and procedure

1.3.27.

Twenty deviation sheets

generated

since January

1987 were reviewed.

Three

of the Deviation Approval Sheets

involved five individuals not being

~ approved to exceed

the overtime limitations of either working greater

than

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or working greater

than

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a

48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

The inspector determined that on February

13,

1987

a

deviation approval

was signed

by the Shift Manager to allow three

mechanics

to exceed

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period while machining tools

needed for fuel channeling

inspection.

Two of the mechanics

apparently

worked

17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />

and 17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period without approval.

On

February

13,

a Shift Technical Advisor worked

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

period.

On the next day, February 14,

he apparently

worked ll hours

providing technical

engineering

support to operators

performing

dechanneling

of spent fuel without authorization to exceed

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a

48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

On March 23, two mechanics

were granted

approval

by the Shift Manager to

exceed

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to complete welding on

a Reactor

Feedwater

Drain Line (RFH-P-B).

Both men worked 17.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />

on March 23,

and the next day March 24, worked

a normal eight hour period apparently

exceeding

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period without approval.

In addition, the inspector

noted that

on February 25, the Shift Manager

authorized

two mechanics

to exceed

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period to

11

provide startup mechanical

support,

which they .did.

The inspector

noted

that Technical Specification 6.2.2f.3 allows the Plant Manager,

his

deputy, or higher management

to approve

exceeding

the overtime limit for

safety-related

work, and procedure

1.3.27 allowed the Plant Manager,

the

Assistant Plant Manager,

the Operations

Manager,

the Assistant Operations

Manager, or the Shift Manager to approve deviations to the overtime

procedure.

The procedure

did not differentiate between safety or non

safety-related

work. In reviews of the workers'ime reports,

the

inspector

could not determine if the overtime

had

been

performed doing

safety related tasks.

The inspector also noted that the appendix to

1.3.27 ("Request for Deviation to Overtime Restriction" ) did not

recognize

the proviso of Technical Specification 6.2.2f.3

and procedure

1.3.27-A.3,

"A break of at least eight hours shall

be allowed between

work periods,

including shift turnover time."

From the time reports,

the

inspector

was unable to determine if this portion of the procedure

had

been violated; however, it was discussed

with management

along with the

above noted procedure deficiencies.

This issue is unresolved

pending

further evaluation during the next inspection period (87-09-04).

Licensee

Event

Re orts

The resident

inspectors

reviewed the following report and supporting

information on site to verify that licensee

management

had reviewed the

event, corrective action

had

been taken,

no unreviewed safety questions

were involved,

and

violations of regulations

or Technical Specification

conditions

had been identified.

Post Tri

Review - Licensee

Event

Re ort 87-02

0 en

On Narch 22,

1987, the reactor

was manually scramed following a trip of

both feedwater

pumps.

Post

scram operator error(s)

caused

the reactor

pressure

vessel

(RPV) to be overfilled on three occasions.

Details of

the trip were included in inspection report 397/87-04.

The

NRC was

notified of the event in a timely manner;

however, plant conditions

changed

(reactor vessel

level increased)

after the shift manager

assessed

the status of the plant and began his notification to the

NRC.

A later

review of the plant conditions

from the licensee

event report

(LER)

indicated that at the time of NRC notification the reactor vessel

level

was higher

than reported.

The resident

inspector interviewed the shift

manager

and confirmed that

he was

unaware of the change in plant

conditions

when the notifications were made

and later he did not perceive

the high

RPV levels to be

a "worsening plant condition" as discussed

in

10 CFR 50.72.

The Shift Manager did not enter the site emergency

plan

because

he felt the situation did not meet the requirements

of the plan

implementing procedures.

The inspector later verified that the level

2

actuation for a short period

had

been identified by the licensee

as being

an expected

operational

result for a loss of feedwater

pump scram

and was

excluded

from the emergency

plan.

The inspector

was told that the licensee

is in the process

of preparing

a

report dealing with high

RPV levels

and flooded steam line conditions.

The report is to include

an analysis of liquid discharge

through the

SRVs

including

a safety assessment

of off normal scenarios

involving these

plant conditions.

12

The inspectors

attended

the Followup Review Committee meetings

and the

final Plant Operations

Committee

(POC) meeting

on the trip for the

purpose of assessing

the effectiveness

of the post trip review.

The

Followup Review Committee

was

composed of the members specified

by Plant

Procedure

1.3.5,

"Reactor Trip and Recovery".

The Chairman of the

Committee

by procedure

is the cognizant Shift Engineer/Shift Technical

Advisor.

The Committee

appeared

to concentrate

on the time line for the

event

and the initial cause of the event with little interest in the

resolution of the .human errors that resulted in the overfilling of the

RPV.

The Committee did not appear to have

any questions of the operators

and Shift Management

who were in attendance.

Shift Management

made

some

explanations

of crew member actions,

but the Committee

members did not

appear to take any actions

towards understanding

the operators'ehavior

or understanding

of the situation.

Specifically, the Nuclear Safety

Assurance

Group

(NSAG) member did not appear to address

the operator

performance

problems,

nor did the guali.ty Assurance

member in attendance

take

an active roll in insuring that operator performance

issues

were addressed

by the Committee.

However, subsequently

the Plant Manager did directly

interview the operators

and ascertained

the pertinent factors pertaining

to personnel

errors.

It appeared

to the inspector that the Committee's

main objective

was the

composure

and refinement of the licensee

event report (LER) rather than

the determination of factors which affected operational

decisions.

However, the Committee's report did recommend

several

hardware

changes

and the

need for additional operator training.

Management

agreed,

during

the exit interview, to assess

overall

Committee effectiveness,

'including

leadership.

Items scheduled

to be implemented in the future include: determining

whether to deenergize

nonclass

loads fed from class I power only in the

event of a loss of power; evaluation of changing

some level

2 trips to

level 1; evaluation of an automatic trip of .the condensate

booster

pump

on a high

RPV level; and increased

operator training on feedwater

upsets

and high

RPV level conditions.

These

items will be evaluated

as part of

the

LER corrective action followup.

No violations or deviations

were identified.

18.

Licensee Actions

On Previous

NRC Ins ection Findin

s

The inspectors

reviewed 'records,

interviewed personnel,

and inspected

plant conditions relative to licensee

actions

on previously identified

inspection findings:

(Closed) Inspector

Followup Item 86-06-05:

Amber warning lights on

panel.

The independent

Nuclear Assurance

Group

(NSAG) identified several

warning

lights on the control panel that had the potential to distract or provide

confusion to the control

room operator.

NSAG noted that (1) the lights

should

be removed or (2) they should

be upgraded

and procedures

should

be

reviewed to include these

special

purpose lights.

The inspector

reviewed

NSAG correspondence

that showed these lights to have

been deactivated;

0

13

they have

been

scheduled

to be removed during refueling outage

3 and were

being tracked

on the Plant Tracking List (PTL).

Due to the removal

from

service, plant procedures

were not modified to include these lights.

This item is considered

closed.

(Closed)

Inspector

Followup Item 86-09-01:

Examine

NSAG identified

operational

event reports that should

be included in procedure

reviews.

The inclusion of lessons

learned

from industry operating experience

reports

appears

to be

a subject for consideration

in the review process.

In discussion with NSAG members,

the inspector learned that the operating

experience

reports

are reviewed

by NSAG and passed

on to the training and

operating groups,

and when conditions are identified that specifically

apply to this unit, procedures will be changed to reflect the learned

experience.

NSAG members

were concerned that the biannual

review of procedures

was

being performed without benefit of defined formal review criteria.

The

inspector

reviewed

a letter sent from the

NSAG group to plant management

expressing this lack of established

procedure

review criteria. This item

will be examined during a later inspection.

(87-09-05)

19.

Ph sical Securit

Security activities were observed for conformance with regulatory

requirements,

implementation of the site security plan,

and

administrative

procedures

including vehicle and personnel

access

screening,

personnel

badging, site security force manning,

and protected

and vital area integrity.

Exterior lighting was checked during backshift

inspections.

No violations or deviations

were identified.

20.

Review of Periodic

and

S ecial

Re orts

The licensee's

monthly operating reports for March and April 1987 were

examined

and found to reflect the inspector's

observations

for those

months.

The "1986 Radiological

Environmental Monitoring Program

Annual

Report"

was

examined.

No anomalies

were identified.

21.

Mana ement Meetin

The inspectors

met with the Plant Manager and/or his assistant

approximately weekly during this period, to discuss

inspection finding

status.

On May 21,

1987, the inspectors

met with the Plant Manager

and

members of his staff to discuss

the inspection findings during this

period.