ML17300A201
| ML17300A201 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/12/1986 |
| From: | Ball J, Boegel A, Bosted C, Crews J, Fiorelli G, Andrea Johnson, Andrea Johnson, Miller L, Peterson L, Polich T, Sorensen R, Upton J, Zimmerman R Battelle Memorial Institute, PACIFIC NORTHWEST NATION, LAWRENCE LIVERMORE NATIONAL LABORATORY, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17300A197 | List: |
| References | |
| 50-528-86-16, 50-529-86-17, 50-530-86-11, NUDOCS 8606300297 | |
| Download: ML17300A201 (60) | |
Text
8bOb300297 Sb0b13 PDR ADOCK 05000528 9
PDR U. S.
NUCLEAR REGULATORY COMMISSION REGION V Report Nos:
Docket Nos:
License Nos:
Licensee:
50-528/86-16, 50-529/86-17, 50-530/86-11 50-528, 50-529, 50-530 NPF-41, NPF-51, CPPR-143 Arizona Nuclear Power Project P. 0.
Box 52034
- Phoenix, AZ. 85072-2034 Ins ection Conducted:
pri 14, 1986 - May 26, 1986 Inspectors:
$~< R.
Zimm a
Seni r Resident Inspector Dat S gned P~~
G. Fiore i esi ent Inspector Dat Si ned
/zan C. Bost e ident Inspector Dat S
ned
/zan J. Ball, esident I spector Dat Si ned Enhanced 0 erational Team s ect on Conducted:
April 21-27, 1986 Inspectors:
$ov'. L. Crews, nidor Rea tor Engineer Team Leader Dat S gned t-op A
P.. John n,
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1" G. Fiorel i, Palo Verd forcem nt Officer esi ent nspector Dat S gned Dat S
ne
't T. Polic esi en In pector
'iablo Can Dat Si ned R.
C. Sor nsen Pr'oje Inspector Palo Verde Da S gned Consultants:
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,~A. J. Boegel, a
e le Pacific Northwest, Eaboratories Dat Si ned
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W. Upt Laboratories l e Pacific Northwest Dat S gned for L. F. Peter on, awre e
ivermore National Dat Si ned Laboratory Approved By:
C~c f~~ L. Miller, Chic
, Reactor P ojects Section 2
Dat S gned Summary:
Xns ection on A ril 14 1986 throu h Ma 26 1986 (Re ort Nos. 50-528/86-16 50-529/86-17 and 50-530/86-11).
lI Areas Ins ected:
Routine, onsite, regular and backshift inspection by the three resident inspectors plus seven additional team inspection members.
Areas inspected included: followup of previously identified items; review of plant activities; engineered safety system walkdowns; surveillance testing; plant maintenance; preoperational and startup test witnessing; preoperational test procedure and results review; initial criticality witnessing; licensee Event Report followup; allegation followup; periodic and special report review; plant tours; engineered safety features actuation, system problems; and sustained control room and plant 'observations during team inspection.
During this inspection the following Inspection Procedures were covered:
- 30703, 37700, 61700) 61726,62700,
- 62703, 70307,
- 70313, 70323,
- 71302, 71707,
- 71710, 71711) 71715)
- 72570, 72592,
- 72596, 72302,
- 90713, 92700,
- 92701, 92705,
- 93702, 93705, and-94703.
J Results:
,Of the 14 areas inspected, one violation was identified in one area.
,(Failure to follow a procedure during surveillance testing-paragraph 5.d.).
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DETAILS Persons Contacted:
The below listed technical and supervisory personnel were among those contacted:
Arizona Nuclear Power Pro ect (ANPP)
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- Adney, Allen,
- Baird, R.
- Bynum, Cederquist,
- Dennis, Fernow,
- Gross, Grove, G. Haynes, E. Ide, Julllp ~
- Kirby, McCabe,
- Minnicks, Nelson,
- Nelson, Pe'rkins,
- Pollard, Shriver,
- Souza, E.
Van Brunt,
- Younger, Zeringue, Operations Superintendent, Unit 2 Operations Manager Quality Assurance Engineer (Test Surveillance)
PVNGS Plant Manager Chemical Services Manager Operations Supervisor, Unit 1 Training Manager Compliance Supervisor ISC Supervisor Vice President Nuclear Operations Corporate Quality Assurance Manager Startup Manager, Unit 3 Project Transition Manager Assistant Startup Manager, Unit 3 ISC Superintendent Operations Security Manager Maintenance Manager Radiological Services Manager Operations Supervisor, Unit 2 Compliance Manager Assistant Quality Assurance Manager Jr., Executive Vice President Operations Superintendent, Unit 1 Technical Support. Manager Bechtel Power Construction (Bechtel)
D. Anderson, Chief Resident Engineer D. Hawkinson, Project Quality Assurance Manager G. Hierzer, Field Construction Manager T. Horstp Project Field Engineer W. Murphy, Project Superintendent, Unit 3 S. Nickell, Project Superintendent H. Thornberry, Area Project Field Engineer The inspectors also talked with other licensee and contractor personnel during the inspection.
The team inspectors had discussions with several Unit 2 licensed and unlicensed plant operators, shift superviors and maintenance technicians.
present at team insp'ection exit meeting'on April 29, 1986.
, -Attended the resident 'inspector exit. meeting on May 29, 1986.
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2.
Followu of Previousl Identified Items Unit 1 A.
(Closed) 'Followu Item 50-528/84-62-02:
"S rinklers Outside Cable S readin Room Missile Doors."
The licensee had committed to install sprinklers outside the missile doors for the cable spreading rooms.
The inspector verified that the sprinklers were installed.
This item is closed.
B.
(Closed) Followu Item 50-528/84-62-07:
"Revision of Fire Alarm Procedures."
The licensee had committed to revising fire alarm procedures 36ST-9QK01 "Fire Detection and Fire Protection System Functional Test" and 36ST-9QK02 "Fire Detection and Fire Protection System Supervised Circuit Test" to implement the Technical Specifications prior to licensing Unit l.
The inspector reviewed the above procedures which were issued April 9, and 19, 1985, respectively.
The procedures properly implemented the requirements of the Technical Specifications.
This item is closed.
C.
(Closed) Followu Item 50-528/84-62-08:
"No Smokin Si ns."
The Control Building had not had "No Smoking" signs posted in the non-smoking areas.
The inspector confirmed through observation that "No Eating or Smoking" signs had been posted at the entrance to the non-smoking areas of the power block.
This item is closed.
D.
(Closed) Followu Item 50-528/85-04-01:
"Auxiliar 0 erator
~Lo s."
The auxil'iary operator logs were to be revised to include a
-local check of 'the Diesel Generator (D/G) starting air press'ure.~,'he licensee also committed to ensuring that a
-Senior Reactor Operator review of the logs would be conducted i once ai.shift.'he inspector reviewed Operating Department Guide 15, and revised auxiliary operator logs with the local check of the D/G starting -air p'ressure.
He confirmed, by interviews and a
sample of'complete'd logs, that the shift supervisor or
'~;assistant shift supervisor reviewed and initialed the logs at least once per shift.
This item is closed.
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(Closed) Followu Item 50-528/85-04-04:
"Seismic Monitorin
~Satem."
A wiring error during installation had caused failure of three circuit cards.
The cards were returned to the vendor for repair.
The inspector reviewed surveillance tests verifying equipment operability following card replacement.
This item is closed.
(Closed) Followu Item 50-528/85-06-02:
"Administrative Control of Auxilia Feed Pum Room Doors."
The door between the auxiliary feed pump rooms is manually operated without a self closing or self latching mechanism.
The licensee had committed to administratively ensure that the door remained closed.
The inspector reviewed procedure 14ST-lZZ24 "Fire Door Position Verification", Revision 3, which required Door CA-06 between the auxiliary feed pump rooms to be checked shut daily.
This item is closed.
(Closed) Followu Item 50-528/85-06-03:
"Revised Fire P~re lan."
The licensee committed to implement a procedure for fires occurring outside the Control Room which would refer plant operators to the plant fire preplans, which were to be revised.
The inspector reviewed the revised fire preplans which were implemented,pri'or to'pril 30,
- 1985, and also reviewed the
'training program, for the full time professional fire department which currently functions in place of the fire brigade.
The revised fire preplans and associated training were found to be acceptable.
This item is closed.
(Closed) Followu Item 50-528/85-06-05:
"Procedure Revisions."
Previously, following a walkdown with 41AO-lZZ44, "Shutdown Outside the" Control Room Due to Fire and/or Smoke",
the following comments were made and the licensee committed to corrective measures.
a.
Specific errors or enhancements to Appendices A, 8 and I were outlined.
b.
Alternative primary pressure control - The procedure did not specify an alternative method of pressure control upon a loss of pressurizer heaters due to a fire in the pressurizer cubicle.
In this inspection, the inspector reviewed procedure 41AO-1ZZ44 "Shutdown Outside the Control Room with Fire and/or Smoke."
The above items, except item (b), were covered by procedure
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)I II change notices and wj.ll be included in the next revision.
Item
,'(b) is covered'~n procedure 41AO-1ZZ10 "Functional Recovery Procedure" Retision, 1.
" This item is closed.
(Closed) Followu
~Item 50-528/85-06"07:
"Minimum Shift Crew for Fire Bri ade."
I The li'censee committed to revise 40AC-9ZZ02,, "Control of Shift Operations", to,specify the minimum shift crew complement required to implement 41AO-1ZZ44 "Shutdown Outside the Control Room" while simultaneously manning the fire brigade.
The inspector reviewed procedure'40AC-9ZZ02 which was modified by a procedure change notice (PCN) to increase minimum shift manning by two auxiliary operators.
Xn addition, to the above, in November
- 1985, a full time professional fire department was established.
This department replaced the fire brigade requirements of the operating staff.
This item is closed.
Unit. 2 (Closed) Followu Item 529/86-04-02:
"Review of Procedures Dealin With Preventin 0 eration'ith,Dr Reference le s."
This item related to the operational checks which should assure the reference legs associated with the pressurizer, steam generators and safety injection tanks level instrumentation were filled.
A review of operating procedures and the Control Room daily data log sheet revealed that, the procedures had been modified to include instructions and cautions to confirm that there was a proper correlation between the multiple level instrumentation associated with these components.
These changes included both Units l,and 2.
This'tem is closed.
3.
Review of Plant Activities A.
Unit 1 During the report period Unit 1 remained in a scheduled maintenance outage until May 23, 1986.
The outage was extended beyond the scheduled duration when problems were identified during testing of the "A" Diesel Generator (D/G).
Water and fuel oil leaks prevented the D/G from completing a required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operational test for the integrated safeguard surveillance test.
Following repair to the D/G, identification of a broken wire in the balance of plant emergency safety features actuation system (BOP ESFAS) in Unit 2, led to the discovery that module connectors in the BOP ESFAS in all three units were
'ot mating correctly.
The connectors were subsequently modifi'ed.;;in the BOP ESFAS cabinets to provide adequate mating (see paragraph 11).
On May 14, 1986, at approximately 8:59 PM the offsite power line from the North Gila substation tripped, at 9:02 PM, the Kyrene line tripped, and at 9:23 PM, the
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Mestwing line tripped.
Licensee investigation the following morning revealed that all three lines had been intentionally grounded by unknown persons.
The locations of the groundings were all 30-40 miles from the plant site.
The grounds were cleared and'the lines were returned to service.
The licensee performed'surveillance testing of the D/Gs at Units 1 and 2 and perfor'med 'wa'lkdowns of onsite electrical distribution equipment, as well as portions of selected mechanical, safety related systems.
No discrepancies were identified during the check of the', above equipment.
In addition, the licensee increased secur'ity su'rveillance both onsite and offsite of the transmission,ne'twork.
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,,On May G6, plant'eat up w'as started and Mode 4 was entered.
Mode 3=was attained'ay 17, and on May 23 the reactor was taken
'" critical':
I Power~<<was"rai:se'd:.toI 100/ on May 26 and remained at:
'100% through~ the. remainder.,'of, the report period.
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,Unit.2
'nit<<2~initial,crit'.cal'ity-,.was achieved on April 18. This was
...,followed, by'.the 'perfornma~nce,of low power physics testing which
, "was comp'leted"on 'April 21:
.A short period of operation
,followed 'at approximately '3'/=of rated power until April 22, for the purpose of performing nuclear instrumentation calibrations, core protection calcul'ator and core operating limit supervisory system tests.
The plant was then taken to Mode 3 on April 22 in order to'-complete testing of'he post accident sampling system.
The full power license.was issued on April 24.
On April 23, Unit 2 experienced an inadvertent main steam isolation actuation due to a personnel error during the conduct of a surveillance test on the system.
The plant was in Mode 3 at the time.
On April 28, during the inspection of wire connections in the train "A" balance of plant engineered safety features actuation system (BOP ES'ZAS) cabinet a loss of power signal was actuated when wires were moved to facilitate the inspection.
The plant was in Mode 3 at, the time.
Following the determination that the actuation was caused because, the BOP ESPAS connectors had limited engagement (paragraph ll) the plant was taken to Mode 5 on April 30.
Both trains of engineered safety features were declared inoperable at the time.
Following replacement of the connectors, the plant was again made critical on May 6, and 20% pow'er was reached on May 21.
On May 25, 1986, while reducing power from 20% to 12/ for a turbine over speed trip test, operator error in controlling feedwater flow caused a reactor trip due to a low steam generator level condition.
After the reactor trip, excessive auxiliary steam loads and overfeeding the steam generators caused main steam isolation, containment isolation and safety injection actuations.
All required systems functioned
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normally.
An Unusual Event was declared.
A review of the first post trip report from Unit 2 indicated that although acceptable, additional, efforts related to completeness and clarification would enhance the quality of the report.
This was discussed with licensee management.
The reactor was restarted on May 26,
- 1986, and at the conclusion of the inspection period, preparations were resumed for conducting a turbine overspeed test at 20/ of licensed power.
C.
Unit 3 During this report period, system prerequisite and preoperational testing was continuing.
Activities included flushing of the safety injection/shutdown cooling and auxiliary feedwater systems preoperational testing of the engineered safety features auxiliary relay cabinets and initial reactor coolant pump motor runs.
Construction activities in Unit 3 were estimated to be 99 percent complete by the licensee.
D.
Plant Tours The following plant areas at Units 1, 2 and 3 were toured by the inspector during the course of the inspection:
Auxiliary Building Containment Building Control Complex Building Diesel Generator Building Radwaste Building
,,Technical'upport Center "Turbine Building Yard Area and Perimeter The following areas were observed during the tours:
I 0 eratin Lo s.and Records.
Records were reviewed against Technical Specification and administrative control, pro-cedure requirements.'The inspector questioned the licensee regarding the primary,'method'used by'he licensee to log entry and exit from Technical Specification (T/S) action statement
-requirements, and also raised several examples of inconsistent logging of times in different logs.
Comments regarding logging of T/S action statements were previously documented in'RC Inspection Report 528/85-43, paragraph 3.c.1.
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o A licensee representative stated that the Shift SupervisorsUnit Log was the official record of action statement completion, and the T/S Component Condition Record (TSCCR) Log maintained in the
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Control Room was a backup tracking system.
The inspector noted however, that Procedure 40AC-9ZZ02, "Conduct of Shift Operations",
stated only that entry and completion of T/S action statements should (emphasis added) be logged in the Shift Supervisors'nit Log, and further stated that the TSCCR Log was a
responsibility of the Assistant, Shift Supervisor to be used as a record of equipment which had entered a
T/S action statement.
Ho reference was made to the TSCCR Log as a backup log in this procedure.
o On April 11, 1986, surveillance procedure 73ST-9CL03, "Containment Airlock Seal Test", included an entry in the attached time log which stated that the test performer notified the Shift Supervisor of the failure of the Unit 2 140'nner airlock door at 7:52 AM.
The door was not declared inoperable in the Control Room logs until 8:24 AM.
o Two instances of entry into T/S action statements associated with airlock doors at Unit 2 on April 11 and 29 were not, logged in the Unit I,og.
o Several instances of minor differences between T/S action statement times in the TSGCR Log and the Unit Log have been discussed with Operations supervision at Unit 1 during previous inspections.
The inspector determined that in no instance was there evidence that a T/S action statement had been violated.
The licensee acknowledged the inspector's comments regarding the difficulty in determining the licensee's primary T/S action statement tracking system.
In addition,, the licensee stated that efforts will be made to ensure that T/S action statement entry and exit times are entered consistently between a specific procedure (as noted above in the 73ST-9CL03 example),
the Unit T.og and the TSCCR Log.
The inspector will review the licensee's actions in this area.
(529/86-17-01)
I 2.. Monitorin Instrumentation.
Process instruments wexe observed for 'correlation between channels and for con-
'ormance with Technical Specification requirements.
~.,observed Sor conformance with 10 CFR 50.54.(k), Technical Speci'fications, and adm'inistrative procedures.
4.
F, ui ment Lineu s.
Valve and electrical breakers were verified to'e in the position or condition required by Technical Specifications and Administrative procedures for the applicable plant mode.
This verification included
'routine contxol board indication reviews and conduct of partial system lineups, as detailed in paragraph 4.
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E ui ment Ta in Selected equipment,, for which tagging requests had been initiated, was observed to verify that tags were in place and the equipment in the condition specified.
6.
Fire Protection.
Fire fighting equipment and controls were observed for conformance with Technical Specifica-tions and administrative procedures.
7.
Plant Chemistr Chemical analysis results were reviewed for conformance with Technical Specifications and admin-istrative control procedures.
8.
~Secnrit Activities observed for conformance with regulatory requirements, implementation of the site security plan, and administrative procedures included vehicle and personnel
- access, and protected and vital area integrity.
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Plant Housekee in Plant conditions, and material and equipment storage were observed to determine the general state of cleanliness and housekeeping.
Housekeeping in the radiologically controlled area was evaluated with respect to controlling the spread of surface and airborne contamination.
10.
Radiation Protection Controls s
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Areas observed. included control point operation, records of licensee's surveys within the radiological controlled areas'osting of radiation and high radiation areas, compl~anCe with Radiation Exposure Permits, personnel
- monitoring devices being properly worn, and personnel frisking practices.
Following tours of the Radiological Controlled Area (RCA) by theinspector, the following comments were discussed with the licensee.
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In several instances, frisking stations such as those associated with the West Wraparound Room and safeguard pump rooms were considered to be located further from the contaminated areas than desirable when attempting to minimize the potential for the spread of contamination.
Additionally, some frisking stations were considered difficult to locate, particularly for a new site radiation worker who may not be familiar with the RCA.
The posting of simple maps detailing how to get from the step-off pad to the frisker location was discussed with the licensee for consideration at, various contaminated areas.
o Posting of the proper dressing/undressing order for protective clothing at the contaminated area step-off
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pads,was not provided.
Although the proper method of donninq and, removal of protective clothing is covered in the licensee's radiation worker training classes, postings were considered by the inspector to be another effective tool available in minimizing the spread of contamination.
The licensee acknowledged the inspector's comments and stated that a study would be initiated to evaluate whether improvements could be made regarding frisker locations and personnel aids which might serve to prevent the spread of radioactive materials.
The study was expected to be complete by the latter part of June 1986.
The licensee further stated that extensive decontamination efforts are ongoing and planned, and are expected to significantly reduce the amount of contaminated areas.
The inspector was shown several trending programs maintained by the licensee, including square footage of contaminated and decontaminated areas.
The inspector noted that. the trending programs were relatively recent in development, but appeared that they would serve as a useful tool to Radiation Protection management.
The results of the licensee's study will be followed up during a future inspection.
(528/86-16-01)
No violations of NRC requirements or deviations were identified.
4.
En ineered Safet Feature S stem Walk Down - Units 1 and 2.
Selected engineered safety feature systems (and systems important to safety) were walked down by the inspector to confirm that the systems were aligned in accordance with plant procedures.
During the walkdown of the systems, items such as hangers,
- supports, electrical cabinets, and cables were inspected to determine that.
they were operable, and in a condition to perform their required functions.
The inspector also verified that the system valves were in the required position and locked as appropriate.
The local and remote position indication and controls were also confirmed to be in the required position and operable.
Unit 1 Portions of the following systems were walked down on April 15, May 7, and May 14, 1986.
Auxiliary Zeedwater Systems Trains "A" and "B".
Diesel Generator Systems Trains "A" and "B".
Essential Spray Pond System Trains "A" and "B".
High Pressure Safety Injection Trains "A" and "B".
Shutdown Cooling System Trains "A" and "B".
Unit 2 Portions of the following systems were walked down on April 21, and 22, 1986:
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10 Essential Spray Pond System Trains "A" and '"B" No violations of NRC requirements or deviations were identified.
5.
Surveillance Testin
- Units 1 and 2.
a.
Survei3,lance tests required to be performed by the Technical Specifications (TS) were reviewed on a sampling basis to verify that:
- 1) the surveillance tests were correctly included on the facility schedule; 2) a technically adequate procedure existed for performance,.of the<surveillance tests;
- 3) the surveillance tests had been performed at the frequency specified in the TS; and 4) test results satisfied acceptance criteria or were properly dispositioned.
i I I b.
Portions of the following'suryeillance tests were observed by the inspector on the"dates shown:il Uni.t 1
I Procedure, 36ST-1SC01 36ST-9SE02 41ST-1ZZ20 1
iJ Excore Channel log Calibrat'ion,Channel D.
Plant Protection System Calibration.
Remote Shutdown Disconnect Switch and Control Circuit Operability.
Dates Performed April 22, 1986 May 2, 1986 May 6, 1986 May 7, 1986 May 8, 1986 May 8, 1986 41ST-1ZZ19 Routine Surveillance Mode 3-5.
May 12, 1986 41ST-1SI06 36ST"1SM02 Iodine Removal.
Seismic Monitor System Calibration Test.
May 12, 1986 May 13, 1986 73TI-9SA01 36ST-9ZZ02 Retest oj BOP ESFAS.
Remote Shutdown Monitoring System Instrument Calibration.
May 13, 1986 May 14, 1986 Unit 2 d
Dates Performed 42ST-2SI09 ECCS System leak Test.
April 14, 1986
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42ST-2RC02 Reactor Coolant System Water Inventory Balance.
April 18, 1986 42ST-2ZZ23 CEA Position Data Log.
April 18, 1986 73TI-9SA01 BOP ESFAS Functional Test.
May 12, 1986 c
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Portions of the following surveillance tests were reviewed by the inspector on the dates shown:
Unit i Procedure Dates Performed 42ST-2SI09 41ST-1RC01 ECCS System Leak Test.
RCS and Pressurizer Cooldown Rate.
April 14, 1986 April 20, 1986 72ST-1RX09 41ST-1ZZ15 41ST-lDG01 Shutdown Margin.
Weekly Boron Water Source.
Diesel Generator Start and Load.
April 20, 1986 May 5, 1986 May 5, 1986 41ST-1ZZ04 Weekly Shutdown Electrical Checks.
May 6, 1986 Unit 2 Procedure Descri tion Dates Performed 1
73ST-9$ L03 Containment Airlock Seal April 11 (3 tests)
Leak Test.
April 14 (2 tests) d.
The inspector's review of surveillance test 73ST-9CL03, Containment Airlock Seal Leak Test, performed April 11,
- 1986, coupled with'a Security computer printout of entry and exit items for the Unit'2 140 foot Containment Airlock outer door, identified that; following the failure of the inner door seal leak test, ',the outer door was:,"opened to allow test personnel to
, "exit.
Test personnel were stationed between the doors during performance of., the'inner door test.
The above procedure
'equired'hat if the inner door, failed the seal leak test and required repair, 'the outer door, would remain closed until
- repair and retest of the inner door had been satisfactorily completed.
Opening the outer airlock door following the failure of"the inner, airlock door is contrary to Technical
'pecification '6'!8.l.c and procedure 73ST-9CL03 and represents a
.Violation (529/86-17-02).
The 'inspector noted -that a difference exists between the Unit 1 and 2 Technical Specifications (T/S) regarding the required
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12 action with one airlock door inoperable.
Although Unit 1 T/S 3.6.1.3 requires the operable door to be maintained
- closed, Unit 2 T/S 3.6.1.3 allows the operable door to'be open for a
'umulative time not to exceed one hour per year to allow repair of the inoperable door.
In the April ll, 1986, event-
, documented
- above, the test performer knowingly violated the procedure, apparently in p'art due to the'nit 2 one hour per year T/S allowance;
- however, he did not log or maintain a
record of the time the outer"door was open in order to charge time against the one hour maximum.
Two similar instances of knowingly deviating from,plant procedures were documented in NRC Inspection Report 528/85-04, paragraph 7 and 528/85-43, paragraph 9.
Violations were not issued, in these prior instances due to their minor safety impact.
Although the licensee's actions were effective in preventing recurrence of the previous procedure adherence
- issues, this recent instance represents the third occurrence, warranting broader corrective action.
The following concerns were also discussed with licensee management:
0 The inspector's comparison of the Security log to the April ll, 1986, 73ST-9CL03 performance of the 140'irlock inner door seal leak retest, also identified an error in the times recorded for the actual test performance in 73ST-9CL03.
Specifically, the procedure indicates that the retest was successfully completed at 10:16 AM;
The inspector verified the times were erroneously logged through discussions with test personnel.
o
'"On April ll, 1986, the 100'nner door failed a door seal leak test at 12:25 PM; however, it wasn', until after the outer door was successfully tested at 1:00 PM that the Control Room was notified of the inner door failure.
The licensee acknowledged the inspector's comments and stated that the necessity of providing timely and accurate notification of equipment operability as well as attention to detail in completion of official plant records would be emphasized to plant personnel.
One violation of NRC requirements was identified.
No deviations were identified.
6.
Startu Testin
- Unit 2 The inspector witnessed portions of the following tests:
72IC-2RX02 Initial Criticality.
Dates Performed April 18, 1986
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13 72PY-2RZ30 Low Power Physics Tests.
o Control Element Assembly (CEA) Symmetry.
o CEA Group Worth o Boron Reactivity Worth for Various.
o CEA Configurations.
o Isothermal Temperature Coefficient.
April 19, 1986 April 20, 1986 72PA-2SB03 Core Protection Calculat'or April 21, 1986 Verification.
72PA-2SB04 Core Operating Limit Supervisory System Verification.
April 22, 1986 72PA-2RXOl Steady State Core Performance 20/.
May 23,1986 The inspector verified that approved procedures were used, test personnel were knowledgeable of the test requirements, and data was properly collected.
Procedure changes and test exceptions were identified and significant events were recorded in the test log.
Other test related activities such as the use of calibrated measuring and test equipment and completion of test prerequisites were also verified to havebeen accomplished in accordance with administrative control. procedures.
7.
No.violations of NRC requirements or deviations were identified.
J'rep erational X'est Witnessin Unit, 3.
The inspector witnessed 'the performance of a preoperational test to
'verify that the procedure, in use was properly approved and adequately detaile'd to assure satisfactory performance; test instrumentation required by the procedure was calibrated and in use; work was performed by qualified personnel; and results satisfied procedural.'acceptance criteria, or were properly dispositioned.
'I The inspector wi'tnessed the performance of portions of the following system testing activity:
92PE3SB14 Cabinet Test Engineered Safety Features Auxiliary Relay.
No violations of NRC requirements or deviations were identified.
8.
Plant Maintenance - Unit 1 and 2
During the inspection period, the inspector observed and re-viewed documentation associated with maintenance and problem investigation activities to verify compliance with regulatory requirements, compliance with administrative and maintenance
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procedures, required QA/QC involvement, proper use of safety tags, proper 'equipment alignment and use of jumpers, personnel qualifications, and proper retesting.
The inspector verified reportability for these, activities was correct.
b.
The inspector witnessed portions of the following maintenance activities:
Il Unit 1 Dates Performed o
RPS Repairs per Work Order 131035.
o Diesel Generator "A" Head and Injector Replacement.
April 17, 1986 April 25, 1986 o
Unit 2 May 5, 1986 May 13, 1986 Descri tion Dates Performed o
Troubleshooting "A" Charging Pump Blown Fuse.
April 23, 1986 o
lA Reactor Coolant Pump Thrust Bearing Seal Replacement.
April 24, 1986 o
Inspection of BOP ESFAS Pin Connectors.
April 28, 1986 o
Removal of BOP ESFAS Connectors.
o Replacement of the Control Element Assembly Position Indicator.
May 5,
1986 May 8,
1986 May 21, 1986 No violations of NRC requirements or deviations were identified.
9.
Containment Inte rated Leak Rate Test - Unit 1 The inspector observed the licensee's performance of the Containment Integrated Leak Rate Test (ILRT) for Unit 1 between April 26-30, 1986.
The ILRT was the first periodic surveillance of the containment structure and was conducted in accordance with the licensee's surveillance test procedure 73ST-9CL02, "Integrated Ieak Rate Test", using the method described in the Bechtel Topical,
- Report, BN-TOP-l, -for short duration testing of containments.
Prior to pressurization of containment, the inspector verified both the inside and outside containment valve alignment of 40 mechanical fn n
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The inspector also verified that electrical penetrations were not pressurized in excess of test pressure and that no other possible pressure sources into the Containment existed.
The inspector found the reactor coolant system to be vented and the shutdown cooling system in operation as required by the licensee's'!Technical Specifications.
The inspector performed an area survey to verify -that temperature detectors and dewcells, used in the performanceof the test, were in calibration.
The licensee began pressurization of the Containment at 3:52 PM on April 28, 1986.
A peak pressure of greater than 64 psia was achieved and a
period of stabilization begun at 9:15 AM on April 29, 1986.
During this stabilization. pe'riod excess leakage out of Containment through t6'e reactor coolant>> system'a's determined to exist as evidenced by d'ecreasing'pressurizer
- level,
'~The source of the leakage was determined to" be through.'the Traiii",'B" shutdown cooling suction isola'tion,Valves.'
This train of shutdown cooling was not in operation'"and, had been isolated for'urposes of the test.
Full closure'f'the isolation valves was achieved by cycling the valves
'pen, then,,closed agai'n.
'Once pressurizer level stabilized, the
'icensee'gai'n increased the pressure in Containment to greater than 64 psia,'>:then secured the',pressurization source and began taking data for' requi,red four hours stabilization period.
With the Stabilization 'crite'ria'met, the licensee conducted an integrated leak, rate test of thirteen hours.
A verification test of 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
';,'ncluding one hour for stabilization after imposition of a known leak rate'was performed;
,All acceptance criteria were met.
The end of the test 95't, upper confidence level for the Containment leak rate based on total time calculations was found to be 0.068 weight percent per day which is below the Technical Specification limit of 0.075 weight percent per day.
No violations of NRC requirements or deviations were identified.
10.
Initial Criticalit - Unit 2 The inspector confirmed that key tests had been performed prior to, or were scheduled to be performed after achievement of initial criticality.
The following tests were reviewed to confirm that acceptable test results had been obtained.
o 73ST-9RZOl-o 42ST-2RC02-o 36ST-9SE04 "
o 73HF-2RC10-CEA Drop Time RCS Water Inventory Balance Excore Startup Channel Functional Test Pressurizer Spray Valve and Control Adjustments In addition the following tests were confirmed to have been comp-
- leted, reviewed, and approved by the licensee, or were of undergoing their final review and approval.
o 73HF-2SF02 -
Post Core CEDM Performance.
o 73HF-2RI01 -
Post Core Movable Incore.
o 73HF-2RC09 -
Post Core Reactor Coolant System Flow
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Measurement,.
o 73PA-2SV01 -
Vibration and Loose Part M
o 36ST-9SB02 -
es Plant, Protection System Functional Test.
Prior to witnessing initial criticalit the ins d
72IC-2RK02 "I 'ti nitial Criticality" and attended a crew briefing conducted by the reactor engineering grou The ins thtb h
a ot channels of roce ure prerequisites had been met and verified 2 and the audible count rate s eaker f source range instrumentation where o
bl opera e,
ra e speaker was operating in accordance w th ec nical Specifications.
i The procedure included adequate precautions to unantici ated c
ions to prevent an neutron multi licat' e
criticality and to ensure proper detect f
h e ec ion o t e safe initial cip ica ion during startup.
The procedure t bl' d
l conditions for reactor startup with a high boron es a
is e
concentration and all control element assembl
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withdrawn exce t for p
or CEA Group 5, which was withdrawn to 75 inches.
The procedure for boron dilution to approach critical r er y.
t provided for periodic sampling and aboratory analysis of the RCS and and formonitor'nd pressurizer boron concentrations an or monitoring RCS boronometer readings durin b
d 1 g
oron i ution or 1/M) lots ve g.
e procedure called for Inverse Count Rat R t (ICRR p
rsus boron concentration and versus time durin boron dilution and mixing to assist in the redict for initial cr't cal't The o
i ica i y.
e procedure also.required verification o
at east one decade of nuclear instrumentation res onse over a
between the startup channels and the lo safet c
final portio f th ions o
e approach to critical.
The inspector witnessed the chemical analyses of b l
s oron samples prior ilution to criticality and monitored the results of periodic boron sample during the final dilution.
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Once the final dilution was complete the react the'observation of the e,
e reactor operator, under ion o t e Assistant Shift Supervisor, initiated the withdrawal of the controlling group 5 rods t ro s to criticality.
ri icality was obtained at 2:45 PM April 18, 1986.
Fol'w'riticalit reactor' y,
or'ower was raised to approximately lOE-4g full o lowing power for data mea'sgrements.
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A,review qf cr'z.tical "data by the inspector indicated that the actual
'critical conditions for 'boron concentration of 1004 5
g oup, 5, compared with pr'edicted values of 1015 b
and 75 inches on'contro es o
ppm oron ontrolling group 5 were well within 1/ delta k/k of 'expected'. values.
The'"inspector noted that during initial criticality, the relief -'crew was working in the Control R e
on ro oom in o
e regu ar y assigned crew, which provided an ample amount of operat'ors to deal with any unexpected events.
The approach t'.o initial cri<icali,ty was performed in a f
l in a pro essional accordance with preapproved procedures, and indicated a
high'degree of understanding of it by those that planned and executed these procedures.
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17'o violations of NRC requirements or deviations were identified.
Balance of Plant En ineered Safet Features Actuation S stem On April 24, 1986, during the inspection of the balance of plant engineered safety features contxol system (BOP-ESFAS) modules in response to a vendor notice addressing missing lock washers, the licensee observed a broken wire on multi-pin connector P-7 on the "A" train loss of power (LOP) module.
This wire was repaired, and during an inspection of the repair by the Quality Control (QC) inspector, an "A" train LOP was initiated when the adjacent wires were moved to permit a visual inspection of the repaired wire.
Both the vendor of the equipment, General Atomic, as well as the supplier of the connectors, AMP Corporation were called in to evaluate the problem.
The licensee and vendor evaluations of the event revealed a defect with the connector design.
The problem involved an incomplete engagement of the male and female pins of the multi-pin connector.
Based on these findings, the licensee returned all of the BOP ESFAS modules from the three units to General Atomic for replacement of the male pins with a longer pin.
The licensee's QC and Operations Engineering.representatives were sent to the vendor's shop to observe the connector replacement work.
At the time of the finding Unit 1 was involved in a maintenance outage.
Unit 2 was taken to Mode 5 from Mode 3 since the engineered safety features systems were declared inoperable.
The licensee concluded the broken wire was the result of excessively moving and bending of wires in order for the connectors to make contact.
Licensee evaluation of part work documents revealed that there were other cases of broken BOP ESFAS broken wires.
Most of the broken wires were found in Unit 2.
Based on the experience with the broken wires at Unit 2, the licensee replaced the female connectors on the Unit. 2 LOP and sequencer modules.
An inspection of the replaced connectors from Unit 2 revealed approximately 30/ of the wires had broken strands.
As a result of this new information the licensee replaced all female connectors on Units 1 and 2
Those at Unit 3 will also be replaced in the near future.
Retests of the BOP ESFAS functions were successfully performed at both Units 1 and 2
following the repairs.
During the female connector replacement work at Unit 2 the inspector observed the connector replacement work was authorized and controlled by a properly approved work order.
Instructions as well as QC hold points were provided in the work package.
Observations of the work included the tagging of wires, a check of the crimping tools, the inspection of work by QC and proper control of the removed connectors.
No violations of NRC requirements or deviations were identified.
0
18 12.
Enhanced 0 erations Team Ins ection.
a
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Crew Performance Conduct of 0 erations An NRC inspection
- team, comprised of senior Region V personnel, resident inspectors from Palo Verde and Diablo Canyon, and consultants from the Battelle Pacific Northwest Laboratory (contract operator license examiners) conducted an enhanced operations inspection during the period April 21-27, 1986.
This inspection team observed,(essent'ially around the clock) performance of the Unit 2 operating crews,and support organizations.
The team members witnessed the performance of licensed operator tasks within the Unit 2 Control Room, and accompanied non-licensed operators on routine rounds in areas of the plant outside of the Control Room.
Sur'veillance and maintenance activiti'es were also witnessed, and discussions were held with licensee personnel in the performance of these activities.
The overall performance of operations personnel was judged by the team to be above average when compared to the performance of the operating crews at other similar facilities during early operation.
An observations of particular significance dealt with the detailed turn over of operational information during shift change, including a thorough walkdown of Control Room panels.
The response of the plant operators during an event on April 23, 1986, involving an inadvertent actuation of the main steam isolation system (MSIS) was observed to be particularly effective in mitigating the consequences of the event.
The operators exhibited a good overall understanding of the event and responded promptly in their actions to stabilize plant conditions.
b.
Housekee in and Plant Cleanliness Members of the enhanced operational inspection team toured the plant on several occasions, during which housekeeping practices and general plant cleanliness were evaluated to be good.
An occurrence was observed on April 24, 1986, involving the backup of water from floor drains onto the floor at the 40'levation in'he Unit 2 Auxiliary Building.
An auxiliary plant operator was directed by the Control Room to investigate the condition.
When the auxiliary operator left the area without having coordinated with a health physics (HP) technician, and had apparently walked through the water, he was directed by the Shift Supervisor to await the arrival of an HP technician prior to proceeding further.
The potential for contamination spread appeared to have been handled properly in this instance.
However, the occurrence did
r 1
19 reveal the possible need to emphasize to'plant personnel the importance of treating all such events as involving potentially contaminated sources of water.
The Shift Supervisor subsequently held discussions with all shift personnel on this subject.
The Unit 2 Operations Superintendent indicated at the time of the exit interview on April 29, 1986, that 'this would be a specific subject for discussion at a meeting with his staff in the near future.
J Postin of 0 erational Aids in Control Room
'he enhanced operational inspection team observed several instances where portions of approved procedures, such as pump flow'curves and level versus temperatures curves were posted on or near control panels in the Unit. 2 Contro1 Room.
Discussions
'ith operations personnel revealed that there was not. a formal mechanism to ensure that such documents were of the latest revision of the applicable procedure.
It was,determined that such documents are audited by Quality Assurance (QA) personnel on at least a monthly basis.
During the past three months the documents had been audited on eight seperate occasions by QA with no discrepancies identified.
Licensee management stated that procedural controls would be established to ensure that all such documents are maintained current to the latest revisions of the applicable procedures.
F. 'ui ment Accessibilit for Testin A portion of the surveillance testing of valves in the low pressure saEety injection (IPSI) system was observed by the enhanced operational inspection team.
The measurements of the stroke on LPSI valve 615 were observed.
The valve is located approximately 10 to 12 feet above the floor and approximately three Eeet from an existing walkway, thus'aking access difficult and also presented a potential safety hazard to personnel conducting the test.
The access difficulties were also observed to present potential problems in obtaining accurate measurements of valve str'oke length.
This condition was called to the attention of licensee supervision at the time and also to management representatives at the exit meeting on April 29.
Licensee representatives stated that. consideration would be given to providing more appropriate access to the valve.
I Personnel Error Burin Surveillance Testin On April 23, 1986, while the plant was in Mode 3 an inadvertent main steam isolation was initiated during the conduct of surveillance testing.
Discussions with ISC maintenance supervision and technician personnel revealed that the MSIS initiation resulted when the technician conducting the test,
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20 became confused in conducting specific steps in the surveillance procedure, and in so doing initiated a test of the second trip path'ithout having reset the initiation relays for the original trip path in a prior step in the procedure.
This event was discussed with licensee management in the context of being similar to previous instances of ISC personnel errors for which enforcement action had been initiated by the NRC resident staff.
'icensee management has completed revisions to the surveillance test procedure, to reduce the potential for personnel error.
Independent verification at critical steps in the procedure, were also made to reduce the error potential.
This matter will be included in the followup of the above mentioned enforcement item (50-529/86-02-01) by the NRC resident staff.
Ino erabilit of Loss.of Power/Load Shed Module Due to Broken Wire The enhanced operations inspection team was notified on April 24, 1986, of the discovery by plant technicians of a broken wire within the loss of power/load shed module in the train "A" BOP ESFAS cabinet in Unit 2. It was determined that the broken wire (on multi-pin connector P-7) would prevent the opening of normal and alternate supply breakers to the associated 4.16 KV vital power bus upon actuation of an under
'oltage condition on the bus.
Since closure of the emergency diesel generator (EDG) breaker is interlocked 'to the opening of the normal and alternate supply breakers,-the defect w'ould have prevented the closure of the EDG breaker in the event of loss of the normal power to the bus.
This condition was reported to
,the NRC.
I Repairs were completed within approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of determination of the significance of the broken wire, and the module was retested successfully.
A prompt investigation was initiated by the licensee's staff into the circumstances of the failure, and was continuing at the time the enhanced inspection was terminated.
(See paragraph ll for the final resolution).
4 7
Discussions with,licensee representatives revealed that at least five broken wires of a similar nature had been discovered in the Unit 2 Loss"of Power/Load Shed Modules over the past year.
Prom their preliminary review of the connector failures and history of prior failures, members of the enhanced operations inspection team made the following observations to licensee management at the exit meeting on April 29, 1986:
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21 Maintenance records did not provide sufficient information to determine the significance of prior wire failures in terms of their effect on component operability, since they were identified only to a multi-pin connector and not a particular pin or wire number.
ii.
The maintenance records did not provide specific information on the mechanism or location of prior failures, thus an assessment of the generic significance (assembly defect, etc.)
was difficult.
iii. The number and apparent similarity of wire failures oyez the past year strongly suggested the need to further evaluate the potential generic significance of the failures, particularly in terms of vendor fabrication of the modules.
Licensee management indicated that these observations'ould be given serious consideration in their continuing investigation into the connector failures.
(528/86-16-02)
No violations of NRC requirements or deviations were identified.
J 13.
Licensee Event Re ort (LER) Zollowu
- Units 1 and 2.
I The following LERs were reviewed and closed.
The inspector verified that reporting requirements had been met, root causes had been identified, corrective actions appeared to be appropriate'nd violations of Technical Specifications had been-identified.
Unit 1 85-30 Supplement 2 - Auto Actuation of BOP ESFAS Due to Radiation Monitor Software Error.
1 Both ECCS Trains were Declared Inoperable Due to Cack of Section XI Testing.
Unit 2 86-07 Surveillance Test Performed I.ate.
86-14 MSIS Actuation,Due to Personnel Error.
86-15 RPS Actuation in Response to I,oss of Seal Injection Flow.
86-01 Suzveillance Performance Exceeded Maximum Allowable Time.
No violations of NRC requirements or deviations were identified.
14.
Review of Periodic and S ecial Re orts - Unit 1.
Periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9.1 and 6.9.2 were reviewed by the inspector.
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22 This review included the following considerations:
the report contained the information" required to be reported by NRC require-ments; reports were submitted within the required time frames; test results and/or supporting information were consistent with design predictions and performance specifications; and the validity of the reported information.
Within the scope of the above, the following reports were reviewed by the inspector.
Monthly Operating Report for March, 1986.
Annual Radiological Report for 1985.
Annual Report of Changes Made Pursuant to 10 CFR 50.59 (inspec-tors technical review has not yet been performed).
No violations of NRC requirements or deviations were identified.
15.
Desi n Chan es and Modification - Units 1 and 2.
The following design changes and modifications were inspected to assure that the changes were reviewed and approved in accordance with 10 CFR 50.59 and that the reviews were technically adequate.
The inspector also verified that the, changes and modifications were conducted in accordance with the Technical Specifications and 7P412.00.00, "Policy for Plant Changes".
A post modification review of test records was also conducted to verify that the scope of testing was sufficient to demonstrate the operability of the modification and that test results met the requirements of Technical Specifications.
The modifications that were inspected were:
o 1-86-CX-031 Circulating Water Hypoch3.oride Piping Modification.
J o
2-86-SQ-019 Radiation Monitoring System Cabinet Wiring Modifications.
o 1-86-ZA-020 Cable and Temporary Wiring Installation for Integrated Safeguards Testing in Unit 1.
o 1-86-SQ-024 Radiation Monitoring System Cabinet Wiring Modifications.
o 1-86-XA-023 Instrument Air Valve Modification.
From a review of the above modifications, the inspector determined that the changes were made in accordance with the prescribed procedures and regulations.
No violations of NRC requirements or deviations were identified.
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23 1.
Alle ation RV-86-A-013 Characterization A construction journeyman electrician formerly employed by Bechtel expressed concerns related to inadequate
- training, inadequate tagging procedures and instructions to ensure personnel safety, unqualified engine'ers, a warped Unit 3 diesel generator busbar and the absence of documenta'tion of high voltage terminations in the Unit 3 "A" Diesel Generator transformer cabinet.
Im lied Si nificance to Plant Desi n Construction or 0 erations Improper training, instructions, direction or installation of electrical components could effect the operability of safety related equipment.
The allegedly deficient equipment was located in Vnit 3 which has yet to conduct its test. program to confirm equipment and systems perform as designed.
Assessment of Safet Si nificance a
~
Trainin and ualifications Based on discussions with Bechtel management, the inspector was informed that journeymen electricians were hired with the expectation that they could perform the tasks required of craftsman with that level of experience and qualification.
Some training is provided to cover special work or administrative controls.
Evidence of this was provided to the inspector in the form of training session
- logs, and safety and quality meeting minutes.
These sample documents indicated technical training was provided covering such activities as termination of conductors, use of Hilti tools, equipment tagging procedures, use of special connectors and use of construction work orders.
The area of contractor training was audited by the licensee's Quality Assurance (QA) department in December of 1984.
The audit concluded that the training activities met the intent of program requirements.
A review of the experience and qualifications of three field engineers and a Quality Control (QC) inspector whose qualifications were challenged by the former construction electrician established that two of the persons possessed degrees in engineering with at least 10 years of electrical construction experience associated with nuclear projects.
The third engineer received college training for 2 years and also had 10 years of electrical
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24 construction experience on nuclear projects.
A fourth person assigned as'a QC inspector held an Associate of Arts degree in construction technology and building construction, held an ANSI Level II certificate in installation inspections at Palo Verde and had 10 years experience in electrical QC work.
b.
Clearance Procedures c ~
Procedures which govern the control of equipment being worked on to ensure personnel safety are contained in two
, tagging and clearanc'e procedures.
One procedure, 40AC-9ZZ14, "Station Tagging and Clearance" is used to control equipment under the jurisdiction of the licensee's Startup organization.
This equipment. could be worked on by construction forces.
The other is a Bechtel procedure WPP/QCI 33.0, "Construction Tagging" Procedure.
This r
procedure prescribes the requirements governing Bechtel controlled equipment.
The WPP/QCI also referenced and supported the requirements, of the licensee's Startup department clearance and tagging procedure.
The inspector noted numerous training sessions'ad been held on this subject.
Based on a review of the procedures the inspector concluded the procedures, contained the proper controls for assuring personnel safety.
Diesel Generator Transformer Cabinet. Busbar 'Zerminations/
j 4
The inspector reviewed documentation for field termina-tions of high voltage cable located in both the "A" and "B" Diesel Generator transformer cabinets in Unit 3 and found all required'ocumentation to exist.
A physical inspection of the terminations in both these cabinets did identify a situation in the "B" Diesel Generator trans-former cabinet, 3JDGBB03, in which the termination lug for phase A of 3EPE01BC1CB was not in full contact with the busbar to which it was connected due to warpage of the busbar. 'he licensee wrote NCR EG 7854 to document this situation.
The NCR was dispositioned to replace the warped portion of the busbar which was accomplished on May 16, 1986.
Staff Position One of the concerns dealing with a warped busbar was substantiated.
Inspection of the other busbars did not reveal a problem.
The warped busbar was repaired.
, Action Re uired No additional action is required.
This 'allegation is closed.
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25 2.
Alle ation RV-86-A-020 A.
Characterization Fire barrier foam in a large number of Unit 1 penetrations is bad.
Im lied Si nificance to Plant Desi n Construction or 0 erations.
Bad foam could provide inadequate fire barriers, with some potential for the loss of more, than one train of a safety system in a fire.,
Assessment of Safet Si nificance The inspector independently examined a random sample of approximately one hundred foam fire barriers in Units 1
and 2.
Two of those examined were of questionable quality and were pointed out to licensee representatives, who took action to followup on the inspector's concern.
The licensee's assessment subsequently determined that these two foam barriers were of satisfactory quality, per engineering evaluation.
There was no evidence of inferior foam on a widespread scale.
In a subsequent conversation with the alleger, the inspector requested that. the alleger provide more specific information.
He identified a specific example, penetration
/f148 in the Unit 2 Control Room, where a void was discovered.
He felt that the whole barrier should have been removed
'and reinstalled.
Instead only a small portion had been patched to repair the void.
The inspector reviewed Bisco procedure SP-107 which allowed repair of foam barriers in this manner.
Also, the inspector interviewed numerous experienced Bisco personnel who indicated that it was common practice to do so.
The justification for this was that, large or numerous voids in fire barriers were found mostly in larger wall or floor seals and can be identified though feel by applying hand pressure to the foamed barrier.
The inspector examined penetration jf148 and found it to be satisfactory and properly controlled by Contractor Work Order 8143464.
Finally, the alleger mentioned to the inspector the name of a Bisco foam installation 'technician who had retained a list of areas where bad foam was installed.
The inspector interviewed this individual.
This individual stated that he was not keeping a list of areas with bad foam.
He had once had'a concern involving, two lots of foam in Unit 3, but his concern had been
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26 resolved to his satisfaction, through his management and quality assurance organization.
Staff Position The inspector was unable to substantiate this allegation.
'haracterization Construction Work Order (CWOs) in Unit 1 are being field modified without review.
(This was in regard to fire barriers being installed by a subcontractor).
Im lied Si nificance to Plant Desi n Construction or 0'erations.
Modifying CWOs without proper engineering review could lead to inadequate fire barriers.
Assessment of Safet Si nificance The inspector reviewed the licensee's procedure for the handling of CWOs, 30AC-OZZ09, Contractor Work Orders.
It was determined that it would be a violation of procedure for a Bisco engineer to change CWOs. It would also be a
violation of the procedure for a Bisco engineer to direct workers to perform work not covered by a CWO.
The alleger had identified a fire penetration, gl65, that had been removed on a verbal order from an engineer wi'thout a work order.
The inspector interviewed the engineer in question and one other Bisco engineer who stated they were'aware o'f the fact that they were not authorized to change CWOs.
'he Bisco Internal Work Release (IWR) is the design
- document, generated by Bisco engineers, that instructs Bisco technicians on how to install a particular fire seal.
The IWR is therefore the Bisco implementing document for CWO authorized work, and contains such information as penetration size and depth, type of fire
- barrier, type of ma'terial to use, and fire barrier drawing numbers used as references.
Since the IWR is the implementing document, authorized by licensee procedures, it can be changed by Bisco engineers as long as it does not change the scope of the CWO.
The inspector also interviewed several Bisco craft
The craft workers stated that they had never been asked to do work that was not authorized on a CWO and were aware of the procedural requirement not to do so.
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27 inspectors and the QA manager were all aware of these requirements.
After a subsequent conversation with the alleger, the inspector located penetration gl65 in the Control Room.
After close examination, this foam seal was observed to be satisfactory.
f,l The inspector located the.CWO which did the work on penetration gl65 in Unit 1.
The CWO appeared to authorize both removal and reinstallation of a number of fire seals, including f/165.
Staff Position The inspector was, unable to substantiate this allegation.
Action Re uired The licensee's quality investigations organization is also addressing these allegations as a result of exit interviews with certain contractor personnel.
These allegations will remain open pending completion of the licensee's investigation.
3.
Aile ation RV-86-A-021 Characterization Procedural violations are being committed by Bechtel construction field engineering personnel in order to quickly accomplish work.
Im lied Si nificance to Plant Desi n Construction or Failure to properly control and document work in accordance with established procedures could result in improper installation of equipment needed for operation and safe shutdown of the plant.
Assessment of Safet Si nificance The alleger provided a package of examples of alleged procedural violations which he had previously provided the licensee through their QA Hotline Program.
The inspector reviewed the licensee's investigation of the alleger's concerns.
The inspector found that the licensee had substantiated in part the alleger's concern that procedural violations had occurred;
- however, none of these violations were shown to have resulted in the improper installation of equipment.
The inspector reviewed recent licensee actions with regard to assuring procedural compliance within the construction force.
The inspector found that a Corrective Action Request (CAR 5-86-22) had
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28 been issued by the licensee specifically addressing the performance of work in violation of established procedures as a result of concerns raised by licensee management that were unrelated to those expressed by the alleger.
An interoffice memo was circulated within the construction force reemphasizing the priority of performance of work in compliance with quality program requirements and procedures.
The CAR was closed by the licensee on April 14, 1986.
Discussions with field engineers employed in positions similar to that of the alleger found that those interviewed believed procedural compliance was considered to be of a priority over either cost or schedule by their management.
Staff Position The inspector was able to substantiate that minor procedural violations of a non-safety significant nature had occurred but had not resulted in improper installation of safety related equipment.
The licensee's corrective action under CAR 5-86-22 was considered adequate to address the allegers concerns.
The inspector was unable to substantiate through the review of recent licensee actions or discussions with field personnel that
'procedural violations were committed in order to accomplish work in a more timely manner.
Action Re uired No additional action is required.
This allegation is closed.
The inspector met with 'licensee management representatives period-ically during the inspection and held an exit on May. 29, 1986.
The scope of the inspection and the inspector's findings, as noted in this report, were discussed and acknowledged by the licensee representatives.
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