ML17305A759
| ML17305A759 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/23/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305A758 | List: |
| References | |
| 50-528-90-02, 50-528-90-2, 50-529-90-02, 50-529-90-2, 50-530-90-02, 50-530-90-2, NUDOCS 9005160015 | |
| Download: ML17305A759 (59) | |
See also: IR 05000528/1990002
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION
V
Report Nos. 50-528/90-02,
50-529/90-02,
50-530/90-02
Docket Nos. 50-528,
50-529,
50-530
License
Nos.
Licensee:
Arizona Public Service
Company
Facility Name:
Palo Verde Nuclear Generating Station
(PVNGS)
Units 1,
2 and
3
Inspection at:
Palo Verde Site, Wintersburg, Arizona
Inspection
Conducted:
January
8 - April 12,
1990
Inspectors:
C. A. Clark, Reactor
Inspector
C. B. Ramsey,
Reactor Inspector
F. S.
Gee,
Reactor Inspector
D. P. Notley,
NRR/SPLB
Approved by:
uey,
ie
Engineering Section
< "A.
ate
>gne
Ins ection
Summar
Ins ection Durin
the Period Januar
8 - March 23,
1990
Re ort Nos.
9-,
0-
/
Areas
Ins ected:
A routine unannounced
inspection
by regional
and
)nspectors
of the licensee
performance
on closing out
NRC open items,
Inservice Testing (IST) activities,
and routine Fire Protection
program
implementation.
Inspection
Procedure
Nos. 30703,
62705,
64704,
73756,
92701
and
92702 were
used
as guidance for the inspection.
Results:
General
Conclusions
and
S ecific Findin s:
Licensee
personnel 'still appear reluctant to initiate a
HNCR or
immediately within their shift, upon identification of a deficiency,
nonconforming condition, etc.
It appears
that licensee training in
this area requires additional
management
attention to ensure that all
licensee
personnel
completely understand their responsibilities.
900516001..i
900424
ADOCK 0 000 28
Ig
Licensee
performance
in issuing the new revised
Emergency Operating
Procedures
(EOPs)
has
been slow.
Durino this inspection the
licensee identified that these
new
EOPs will not be effective until
approximately July 1991,
a year later than that initially identified
to the
NRC.
Additional management
attention in this area is
needed.
Additional management
attention is needed
in the fire protection
area,
to ensure
adequate
training for personnel
performing fire
protection inspections.
Si nificant Safet
Matters:
None
Summar
of Violations:
One non-cited violation.
Paragraph 2.E(5)-
Inadequate
10 CFR 50.59 Review.
0 en Items
Summar
Twelve open
items were closed, five open
items were left
open, five new unresolved
items were opened.
l
I
0
DETAILS
1.
Persons
Contacted
- R. Badsgard,
Supervisor,
Nuclear Engineering
Department,
- J. Bailey, Vice President
Nuclear Safety
& Licensing
R. Adney, Plant Manager,
Unit 3
- T. Barsuk, Site Lead,
Emergency
Planning
- R. Bernier,
Lead Engineer,
Licensing
- H. Bieling, Manager,
Emergency Planning/Fire Protection
¹* T. Bradish, Manager,
Compliance
R. Bouquot, Senior
gA Auditor, gA8H
- J. Cole,
Lead Metrologist, Measurement
and Test Equipment
- D. Crozier, Supervisor,
Fire Protection
C.
Emmet, Sr. Information Coordinator
- Z. Elenor, Sr. Nuclear Safety Engineer
J. Flomerfelt,
Document Control
R. Flood, Assistant Plant Manager, Unit 2
R. Fountain,
Deficiency Coordinator,
(ASM
- R. Fullmer, Manager,
gASH
¹* F. Garrett, Fire Protection
Engineer,
Risk Management
R. Guron,
NED Electrical Engineer
M. Halpin, Senior Operations
Advisor
¹* R. Henry, Site Representative,
SRR
- H. Hodge, Mechanical
Engineering Supervisor
¹
H. Hypse,
Lead, NED/Electrical
W. Ide, Plant Manager, Unit I
¹* S. Johnson,
Site Representative,
SCE/LADWP/SCPPA
¹* D. Kanitz, Engineer,
Compliance
K. LeRoy, Unit 3 Electrical Maintenance
Super visor
- J. Levine, Vice President,
Nuclear Production
- W. Marsh, Plant Director, Nuclear Production
J.
McGath, Supervisor,
J. Minnicks, Maintenance
Manager, Unit 3
R. Hyers, Senior Advisor, Operation
Standards
C. Nuss, Operations
Advisor
- R. Page,
Support Supervisor,
Measurement
and Test Equipment
M. Powell, Unit I Electrical Maintenance
Supervisor
¹* R. Rouse,
Engineer,
Compliance
J.
Samuels,
EED Electrical Engineer
J.
Schmadeke,
OCS Manager.,
- B. Simpson,
Vice President,
Engineering
and Construction
M. Stewart, Unit 2 Electrical Maintenance
Supervisor
G. Sowers,
Manager,
EED
T. Thompson,
Senior Engineer,
Nuclear Engineering
Department
Denotes
those
personnel
in attendance
at the exit meeting
on January
26,
1990.
Denotes
those
personnel
in attendance
at the exit meeting
on February 9,
1990.
- Denotes
those
personnel
in attendance
at the exit meeting
on March 23,
1990.
The inspectors
also held discussions
with other licensee
and contractor
personnel
during the course of the inspection.
2.
Fire
A.
B..
Protection/Prevention
Program
Im lementation
64704,
62705
Personnel
Staffin /Or anization
Recent reorganization
and personnel
changes
have created
optimism
among the licensee's
staff.
Management
has apparently
demonstrated
acknowledgement
of long-standing
problems in this area
and
made
a
commitment to the fire protection staff to allocate the necessary
resources
to resolve existing problems
and deficiencies.
The licensee's
engineering staff has
been strengthened
by the
addition of a site fire protection engineer within the mechanical
engineering
section.
In addition, the licensee
has allocated
resources
to add
a fire barrier systems
engineer in the Engineering
Evaluation Department.
Trainin
ualifications
Electrical maintenance,
mechanical
maintenance
and
18C Technicians
are assigned fire protection
system maintenance
tasks.
I&C Technicians
receive initial 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> troubleshooting
and
refresher training on fire protection
and detection
systems
in
accordance
with Sections 3.6.1.9, 3.6.2.5, 3.7.2.5
and 3.7.4.15 of
Procedure
No.
15DP-OTR39 ("ISC Technician gualification Requirements
and Training Program Description" ).
Other than
on the job training and mandatory training on station
batteries
and battery chargers,
required
by Sections
3.5.11.1
and
3.6.2.12 of Procedure
No.
15DP-OTR40 ("Plant Electrician
gualification Requirements
and Training Program Description" ),
electrical
maintenance
technicians
do not receive
any training on
fire protection systems.
Mechanical
maintenance
technicians
are not
required to receive training on fire protection systems
by Procedure
No.
The licensee
acknowledged that certain fire
protection
systems
were unique,
and personnel
assigned
maintenance
tasks
on such equipment
should
be provided with the specialized
training required to complete the tasks.
The licensee
indicated
that consideration
would be given to expanding
the training and
qualification requirements
of electrical
and mechanical
maintenance
personnel
to include knowledge of unique fire protection systems.
The onsite Fire Team receives
a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Nuclear Safety Training
Course,
and firefighter certifications are being upgraded to meet
NFPA Standard
No.1001,
Level II qualifications.
Fire Team Advisors were not receiving training in fire protection
or
firefighting to qualify as
a Fire Team Advisor.
Operations
Procedure
No. 40AC-90P02
{Conduct of Shift Operations),
requires
that the fire team advisor
on each shift be
a licensed
Reactor
Operator.
The inspector's
review of Control
Room Shift Logs for the
months of November
and December
1989 indicated that licensed
Reactor
Operators
have
been assigned
duties
as Fire Team Advisor.
However,
according to the logs, it appears
that
an Auxiliary Operator,
or
a
Reactor Operator,
can also be assigned
the duties of Fire Team
Advisor.
This is not consistent with Section 2.5 of Procedure
No.
which requires that
a licensed
Reactor Operator
be
assigned
Fire Team Advisor on each shift.
In response
to this concern,
the licensee
indicated that
a fire team
advisor firefighting program was being developed,
and additional
clarification of Fire Team Advisor qualifications would be made to
Operations shift crews
by February
15,
1990.
Inspection findings in coordinated offsite fire department training
and drills are discussed
in paragraph
4.F of this report.
Fire Protection Interface With Other Plant Or anizations
Previous fire protection interface with operations
and other plant
activities,
such
as maintenance,
work. planning and work control,
appears
to have
been weak.
The licensee is in the pi ocess of
addressing
this weakness
through the formation of a Fire Protection
Review Board which will be chartered
to review and evaluate all
aspects
of the fire protection program to ensure
various regulatory
requirements
and industry standards
are being implemented
by all
affected disciplines.
When this review board process
is
implemented, all fire protection engineering
work between
engineering
groups,
work control, work planning,
procurement
engineering, etc., will be processed
through the fire protection
engineering organization.
An acceptable
action plan to correct this
condition is provided in the licensee's
March 16, 1990, submittal to
Region V.
Preventive
and Corrective Maintenance
The licensee
acknowledged that there is an unacceptable
backlog of
preventive maintenance
tasks
on fire protection
and detection
equipment,
dating back to 1986.
Licensee
CAR No. 88-0076
documented
this concern.
An acceptable
action plan to correct this condition is
provided in the licensee's
March 16,
1990, submittal to Region
V.
Essential
and
Emer enc
Li htin
S stems
FSAR Sections 9.5.3.2.2.2
and 9.5.3.2.2.3
describe the essential
and
emergency lighting systems.
The emergency lighting system in each
unit consists of the following:
{I) eight Johnson
Controls,
Model
6VHC-96, lead-acid
and gel-cel batteries
supplying power to
3
fluorescent
emergency lights in the Auxiliary Building and Control
Building; (2) ten Exide Electronics,
Model 3CC5, lead-calcium
batteries
supplying power to Control
Room emergency lighting; (3)
sixteen Saft America Inc., Model Nicad 406601,
Type F, batteries
supplying
power, to the Main Steam Support Structure
(MSSS)
and in
access
and egress
pathways thereto;
and (4) approximately four
hundred-fifty Dual Lite Model, EDE-30, wet cell nickel cadmium,
batteries
supplying power to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> emergency lighting
in the remainder of the plant.
(1)
Desi
n and
Re viator
Re uirements
License
No. NPF-41, Condition 2.C(7) for Palo Verde Uni+ 1,
License
No. NPF-51, Condition 2.C(6) for Palo Verde Unit 2 and
License
No. NPF-74, Condition No. 1.F for Palo Verde Unit 3,
reads in part,
"APS shall
implement
and maintain in effect all
provisions of the approved fire protection
program
as described
in the Final Safety Analysis Report
(FSAR) for the facility, as
supplemented
and
amended,
and
as
approved in the
SER through
Supplement ll, subject to the following provision:
APS may
make changes
to the approved fire protection
program without
prior approval of the Commission only if those
changes
would
not adversely affect the ability to achieve
and maintain safe
shutdown in the event of fire."
SER Supplement
No.
7 documents
the
NRC staff's review of the
licensee's
spurious actuation studies.
Item No.
15 of the
licensee's
November 6, 1984, "Outside Control
Room Fire
Spurious Actuation Study" (Studies
01-NS-110,
02-NS-110
and
03-NS-110)
reads
"Postulated fires in each
FSAR Table
9B fire
zone of the Auxiliary Building, Control Building and Main Steam
Support- Structure will be evaluated for their impact on the
ability to achieve
SSD."
Regarding
emergency lighting, Section
9.5.1.4 of SER Supplement
No. 8 reads
in part,
"The
SER stated
that 8-hour battery-powered
emergency lights are provided in
all areas of the plant necessary for safe
shutdown.
By letter
dated April 15', 1985, the applicant confirmed that this design
concept includes the access
and egress
routes to these areas".
FSAR Table 9B.3-1(C.3) requires
implementation of a quality
assurance
program to ensure that purchased materials,
equipment
and services
conform to Code Compliance
Documents,
Performance
Test Verification Reports,
Pressure
Test Verification Reports,
Certificates of Compliance for'hipment and Material
Certificates of Compliance.
Arizona Public Service
(APS)
Operations guality Assurance
Manual, Revision 5, Criterion 3,
implements
the provisions of FSAR Table 9B.3-1(C.3).
FSAR Table 9B.3-1(D.5) requires fixed emergency lighting with 8
hour minimum battery power supplies
be provided for safe
shutdown
equipment
and in access
and egress
routes thereto.
FSAR Section 9.5.3. 1.3 reads,
"Design and installation of the
plant lighting systems
use the guidance
provided
by the
National Electrical
Code
(NFPA No. 70-1975/ANSI Cl-75) and the
Handbook of the Illuminating Engineering Society".
The results of the inspector's
examination of the licensee's
implementation of these
requirements
are
as follows:
(a)
Control.Buildin , Auxiliar Buildin , Diesel
Generator
Bus
in
an
Su
ort Structure
mer enc
tsn
essan
an
m
ementatsnn
The National Electrical
Code
(NFPA 70-1975/ANSI Cl-75),
Article 400-4, requires that emergency lighting fixtures
and equipment
be designed,
tested
and accepted for a
specific purpose or application
by a nationally recognized
testing laboratory.
The various types of battery
powered
emergency lighting units installed to support operator
actions to achieve
safe
shutdown in the event of a fire at
Palo Verde were tested
and accepted
by Underwriters
Laboratories
Inc., for use in environments
with ambient
temperatures
of 77 degrees
F, as specified in APS Material
Requisition
No. 13-EM-041B, referencing
Underwriters
Laboratory
(UL) Standard
No. 924.
The various battery manufacturer's
literature state that
the manufacturer's
warranty is invalidated if the
batteries
are operated
in ambient temperatures
above
110
degrees
F., or if the batteries
are not maintained in
accordance
with the National Electrical
Code.
FSAR Table 9.4.2 specified the maximum operating
space
temperatures
for certain areas
requiring operator actions
in support of safe
shutdown
as follows:
Auxiliary
Building, 104 degrees
F;
Pump
Room,
120 degrees
F;
Diesel Generator
Room,
140 degrees
F; Diesel Generator
Control
Room,
122 degrees
F and Essential
Spray
Pond
Pump
House,
120 degrees
F.
The battery powered
emergency
lighting units installed to support operator actions to
achieve safe
shutdown in these
areas
apparently
were not
tested
and accepted for operation in the maximum space
temperatures
experienced
in these areas.
Additionally, the emergency lighting units that were
installed in June
1989 in the
MSSS,
and in access
and
egress
routes thereto,
apparently
have not been tested
and approved for use in outdoor wet locations, or the high
ambient outdoor temperature
environments
experienced
at
Palo Verde during summet
months.
Regarding
Johnson
Controls Model 6VHC-96, Dynasty
GC
12V-100 and
12UPS-300 lead-acid
and gel-cel batteries
supplying
power to fluorescent
emergency lighting fixtures
in the Auxiliary Building, the battery capacity ratings
do
not appear to'rovide the power
needed to sustain
8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
emergency lighting for loads in Units
1 and 3.
According
to the licensee's
Procurement Specification
No.
13-EYi-041B, the battery cells a'e required to be of the
proper ratino to meet
125 percent of the battery load
profile requirements
at
a minimum battery temperature
without the battery voltage dropping below 1.75 volts per
cell, to ensure
adequate
capacity at the end of the
battery's
useful life in accordance
with U.L. Standard
No.
924.
The end of the battery's
useful life is defined in
the specification
as the point where the battery
has
reached
80 percent of its 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge rating.
Article 700-6 of NFPA 70-1975
and Section
37.1 of U.L.
Standard
No. 924 requires that the batteries
have
a
capacity rating to supply and maintain not less
than 87.5
percent of the nominal battery voltage for the total load
of the circuit supplying emergency lighting.
The load
profile for lighting fixtures supplied
by Battery Nos.
gBN001 and
gBN003 in Units
1 and
3 requires
86 amp/hours.
However, all of the these existing batteries
in Unit
1 and
two of the batteries
in Unit 3, are only rated for 73
amp/hours
(GC12V-100)
and
88 amp/hours
(12UPS-300).
These
batteries
were replacements
for the original batteries
(6VHC-96), which had
a
96 amp/hour ratino.
According to the battery vendor, the optimum temperature
for maximum battery efficiency is 77 degrees
F.
At higher
and lower temperatures,
the battery capacity is decreased.
The original batteries
(6VHC-96) were designed
to operate
in an optimum temperature
range of 60 degrees
F to 85
degrees
F.
Furthermore,
according to the licensee's
EER No.
89-gD-034, regarding Saft America Inc.'mergency lighting
batteries
installed in the NSSS, which are also designed
to operate in accordance
with U.S. Standard
No. 924, the
batteries
are provided with a disconnect
switch, which
will disconnect
the lighting circuit at 87.5 percent of
the nominal battery voltage.
Based
on the total emergency lighting load profiles (86
amp/hours) for Battery Nos.
gBN001 and
gBN003 in Units
1
and 3, it does
not appear that the original batteries
(6VHC-96), or existing batteries
(12 UPS-300)
are capable
of providing 125 percent of the battery load profile
requirements
at the optimum temperature for maximum battery
efficiency, or at higher and lower temperatures,
where the
battery efficiency is lower.
(2)
There
does
not appear to be sufficient margin in the
GC 12-100 battery capacity to supply power to the lighting
fixtures for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Further, it appears
that two of the
batteries
installed in Unit 2 with the lower load profiles
have
never
been tested,
and
one other failed the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
discharge test
on March 6, 1990.
The above issues
constitute
an Unresolved"Item (528/90-02-01).
Corrective Actions for Emer enc
Li htin
Batter
Failures
FSAR Table 98.3-1(C.8)
provides that measures
be established
to
assure
that conditions adverse to fire protection
such
as
,failures, malfunctions, deficiencies,
deviations,
defective
components,
uncontrolled combustible material
and
nonconformances
are promptly identified, reported
and
corrected.
APS Operations guality Assurance
Manual, Criterion
16, Revision
No. 5, Section 16.2.1.7 "Corrective Action",
implements
FSAR Table 98.3-1(C.8),
and requires
appropriate
evaluation to determine
the cause
and prevent recurrence of
failures that have
an effect on, or influence safe operation of
the plant in an adverse
manner.
Any decision to permit the use
of installed equipment that is nonconforming is required to be
supported
by a documented
evaluation.
At the time of the inspection, it appeared
that appropriate
corrective actions
had not implemented to preclude
emergency
lighting battery failures
and recurrences
as evidenced
by
emergency lighting battery failure data
shown in a February 20,
1990 Failure Data Trending computer printout for the period
1988 through
1989,
and
a high volume of new battery usage
as
shown in a March 20,
1990 Procurement Materials
Management
Information System computer printout for the period
1986
through
1990.
Du'ring the period of May 1987 to October
1989,
70 of approximately
480 emergency lighting unit batteries
had
failed.
Approximately fiftyof the failed batteries
were
required to support
However, appropriate
evaluation of the failures to determine
cause
and prevent
recurrence
apparently
had not been initiated or documented.
Additional deficiencies
associated
with battery
powered
emergency lighting units installed to support operator actions
to achieve safe
shutdown in the event of a fire were identified
and reported,
but apparently not appropriately corrected,
in
that:
(a)
Engineering Evaluation Report
(EER)
No. 87-QD-004, dated
January
28, 1987, identified and documented
problems
associated
with batteries for the emergency lighting units
as follows:
"High temperatures
inside Containment during
operation
cause
loss of electrolyte in'all fixtures; total
loss in many, varying amounts in the rest.
Salt
accumulate
on battery posts
and vent. caps
and is discarded
during
PH cleaning.
Continual repeated electrolyte loss
with demin water replacement will cause
premature battery
failure".
The
same batteries
(Dual-Lite Model EDE-30)
used for Containment
used for safe
shutdown
emergency lighting in the Auxiliary Building,
Control Building and Diesel
Generator Building.
The disposition of EER No. 87-gD-004 regarding the boiling
and evaporation of Containment
emergency lighting battery
electrolyte apparently
provided for float voltage adjustment,
to
a reduced battery float voltage, to an unspecified
value.
The modification to allow adjustment of the float
voltage
was apparently
made to Appendix
R emergency
lighting units installed outside of the containment.
It
appears
that the modification was
made to the lighting
units without using the appropriate
design
change
and
maintenance
work order processes.
It further appears
that
the
EER disposition
was not provided with the appropriate
engineering
evaluation of the effects of reduced float
voltage
on the battery discharge
capacity during emergency
use.
The disposition to
EER No. 87-gD-004 also provided for
replacement of the electrolyte in the batteries
with
distilled water,
topped with mineral oil; again apparently
without appropriate
engineering evaluation of the effects
of this disposition.
It appears
that mineral oil had,
also,
been
added to lead-acid batteries
installed in
Appendix
R applications,
in addition to Nickel-Cadmium
batteries.
NRC discussions
with battery vendors
have
indicated that the deposits of mineral oil on the plates
of lead-acid batteries,
and all battery cells, adversely
affects battery capacity
and performance,
and is not
approved.
Given the temperature
extremes
in certain
locations, there appears
to be
a high probability that
mineral oil would be deposited
on plates.
Certain batteries
have demonstrated
a continuing
failure history (Failure Data Trending).
For example,
15 percent
(70 failures of approximately
480 Appendix
R
emergency lights installed in all
3 units) failed over
a 30 month period (tlay 1987 to October 1989).
The
NRC is concerned that Appendix
preventive maintenance
tasks
have not been
designed
to optimally assure
a continued capability of Appendix
R
lighting units to operate for the required eight hours.
Furthermore,
apparently,
timely preventive maintenance
completion
has not been aggressively
pursued
because,
in
about 84 instances,
the required
annual
capacity test
and quarterly electrolyte level checks
were overdue in
Unit 3 as of March 23,
1990.
(e)
The licensee's
EER No. 89-gD-034
documents
excessive
failures of NSSS installed
emergency lighting when the
battery input voltage
was found to be greater
than the
rated
21VDC.
The batteries
are required to operate at
rated voltage.
However, the
EER disposition
was apprently
based
on the erroneous
reference
to a time versus voltage
profile which indicated that the excessive
voltage
had
no adverse effect on the batteries,
when, in fact, the
excessive
charging voltage is
a direct contributor to
electrolyte evaporation.
(f)
During restart testing,
MSSS emergency lighting 8
hour discharge test failures occurred
as follows:
In Unit I, 7 lighting units failed once.
Five
lighting units failed twice,
and
3 lighting
units failed three times.
In Unit 2,
4 lighting units failed once,
and
2
lighting .units failed twice.
In Unit 3,
3 lighting units failed twice,
2
lighting units failed three times.
The failure rate for the total of 48 emergency
lighting units installed in all three units
was
approximately
40 percent prior to restart of all
units.
Although high failures continued to occur, the
licensee
stated that the root cause of the
failures
was determined to be incompatible parts
and fixtures supplied
by the manufacturer prior
to restart of Units 2/3.
The cor rect parts
were
supplied
by the manufacturer
and installed
by
the licensee prior to restart of the Units 2 and
3.
However, the lighting units continued to
experience
a high failure rate, apparently without
additional evaluation
and corrective actions
being
implemented
by the licensee.
All work orders
reviewed for repair/replacement
of the
MSSS emergency lighting units subsequent
to Unit 2/3 restart
were characterized
as
a work
pr iority 3, which is the lowest priority assigned
to maintenance
work during operations.
It appears
that prompt and technically sufficient
evaluations
and corrective actions of the considerable,
observed
emergency lighting deficiencies
were not
implemented.
The above issues constitute
an unresolved
item.
(528/90-02-02).
(3)
(4)
Post-Fire
Safe
Shutdown
Procedure
Ade uac
Technical Specification 6.8.2 requires that programs
and
procedures
of Specification 6.8. 1 be reviewed periodically as
set forth in administrative procedures.
Specification 6.8.1
requires that written procedures
be implemented
governing the
Fire Protection
Program.
APS Administrative Procedure
No.
01AC-OAP02 implementing Technical Specification 6.8.2, requires
that the Pre-Fire Strategies
Manual
be reviewed at least
once
every
12 months to determine whether any changes
are necessary.
At the time of the inspection, it appeared
that the Pre-Fire
Strategies
Manual
had not been
reviewed since the original
licensing of Unit
1 in Oecember
1984 to determine the adequacy
of operator actions specified to achieve 'post-fire safe
shutdown for fires occurring outside of the Control
Room.
Furthermore,
the Pre-Fire Strategies
appeared
to be inconsistent with the Outside Control
Room Fire
Spurious Actuation Study (Studies
01-NS-110,
02-NS-110
and
03-NS-110) for Fire Zones
47A, 47B, 72, 73,
74A and
74B,
regarding operator actions to interchange
instrument air header
pressure
transmitters.
This is an unresolved
item.
(528/90-02-03)
0 erator Trainin
in Post-Fire
Safe
Shutdown
Technical Specification 6.4 requires that
a training program
be
established
and maintained which meets or exceeds
the
requirements
of ANS 3.1-1978
and Appendix
A of 10 CFR Part 55.
ANS 3. 1-1978, Sections 5.3, requires
establishment
of a
training program for licensed
and non-licensed
operators
to
properly prepare
them for their assignments.
At the time of the inspection, it appeared
that licensed
and
non-licensed
operators
were directed to perform manipulation of
equipment,
by the Pre-Fire Strategies
Manual, to achieve
post-fire safe
shutdown.
It was not apparent that the
personnel
had
been trained to perform the required actions.
1
Regarding Fire Zones
47A, 47B, 72, 73,
74A and 74B, the
Pre-Fire Strategies
Manual directed operators
to locally
operate
switches
and valves in areas
which may not be
accessible
to the operators
in the event of a fire. It was not
clear whether operators
were required to enter these
areas
during the fire to accomplish
manual
actions or to wait until
the fire had
been extinguished.
In either case, it was not
apparent that the appropriate
personnel
had been trained in
safety
and protective measures
necessary
to accomplish
such
actions.
~
~
4
0
~
~
10
For a fire inside the Control
Room, the licensee's
Spurious
Actuation Study 13-NS-109 requires
operators
to provide makeup
to the Essential
Chilled Water System,'ssential
Cooling Water
System
and Emergency Diesel Generator
Surge
Tanks by providing
water from the Fire Water System.
It was not apparent that
operators
had been trained to perform these actions.
This is an unresolved
item.
(528/90-02-04)
(5)
Inade uate
10 CFR 50.59 Review of Fire Barrier Deficiencies
Pursuant to 10 CFR 50.59,
by letter, dated
June
27,
1988, the
licensee
submitted its annual report to the
NRC staff for
review.
requires
licensee's
to submit
proposed
changes
to the facility to the
NRC staff for review
prior to implementation of the change, if the margin of safety
as defined in the basis of any technical specification is
reduced.
Change
No.
58 submitted with the licensee's
June
27,
1988
annual
10 CFR 50.59 report
was not submitted to the
NRC for
prior review.
This change
should have
been submitted to the
NRC for prior review because it revised
FSAR Sections
98.2.12
and 98.2.15 to add deviations for fire zones
73, 37B, 37D, 39B,
74A and
74B to reflect
a significantly reduced
margin of safety
(reduction in fire barrier rating) than originally specified in
the basis of Technical Specification 3/4.7.12.
With respect to
Change
No. 58,
we note that you have obtained
NRC approval of
the as-built configuration pursuant to your request
subsequent
to your initial assessment
of the situation.
Since
1987,
when Change
No. 58 was performed,
several
corrective actions to preclude recurrence of this and similar
deficiencies
have
been
implemented for the licensee's
10
CFP.
50.59 review process.
For example:
(a)
Fire Protection
Engineering
has
been centralized within
the various engineering organizations.
Corporate
Nuclear
Engineering
has established
a Fire Protection
Engineer
position within the Mechanical
Engineering Section,
and
a
Fire Barr ier Systems
Engineer position has
been
established
within the site Engineering Evaluation
Department.
The actions
appear to have significantly
enhanced
Fire Protection technical capability within the
engineering
organizations
and established
a focal point
for fire protection problem resolution.
(b)
In addition to personnel
and organizational
structure
changes,
revisions to the
10 CFR 50.59 review and
evaluation
process
are currently in progress.
These
revisions
appear to be substantial
and include specific
qualifications
and certifications for. personnel
performing
10 CFR 50.59 reviews;
a revised philosophy
and approach
to
10 CFR 50.59 regulatory interpretations
is expected
to
yield more conservative
review and evaluation results;
implementation of a Screening
and Evaluation process
to
'
11
ensure
appropriate
answers
are provided to applicable
10
CFP, 50.59 questions;
and the recent
Nuclear Safety
Analysis Center
(NSAC) guidelines
are
used for developing
compliance with 10 CFR 50.59 requirements.
This is an apparent violation of 10 CFR 50.59
(528/90-02-05).
Based
on corrective actions
discussed
above that were verified during the inspection,
no
response
is required
and this is considered
a non-cited
violation.
(6)
Emet
enc
Li htin
Illumination Levels
(a)
The licensee's
October 29,
1984 submittal to the
NRC
indicated that
NUREG 0700 was
used
as the design
basis for
the control
room and the remote
shutdown
panel
emergency
.
lighting illumination levels.
NUREG 0700 requires
a
minimum of 10 foot candles
in these
areas.
However, the
licensee's
acceptance
criteria for the control
room and
the remote
shutdown
panel
emergency lighting illumination
levels is
6 foot candles
in peripheral
areas
and
3 foot
candles at control board instruments.
(b)
Thirteen lighting level readings
were taken at various
locations outside the control
room in Unit 3 with a
photometer
(Spectra
Photometer
Nodel
FC-200, Serial
Number
476,
NRC Equipment
Number 000393, with the next
calibration
due date of 7/26/90).
The locations
were the
stairwell outside the control room, the essential
chiller
surge
tank level
and valves,
the chiller room stairwell
exit, and the Emergency Diesel
Generator
rooms.
The
photometer
readings
ranged
from 0.03 to 0.75 foot-candles
with an exception of 1.3,foot-candles
at the emergency
diesel control panel.
In addition, the orientation of the
lamps
on
a lighting unit in the stairwell outside the
control
room were found to be not directed
toward the
access/egress
pathway.
This is an unresolved
item (528/90-02-06)
(7)
Control of Fire Barrier Boundaries
The
FSAR requires periodic inspection/test
of all fire barriers
and Technical Specification 3/4.7.12
implements
those
requirements.
LER No.84-001
documents
the licensee's
omission
of safety related/safe
shutdown fire barriers
from the
inspection
and test program.
Corrective Action Report
(CAR)
No. 87-0095
was issued in 1987 for these conditions.
Since the
issuance
of the
CAR, there
have
been
seven requests,
some of
which were escalated
to the Executive Vice President
level of
management,
to extend corrective action
due dates.
Furthermore,
CAR No. 87-0095
was expanded
in scope
and
identified similar deficiencies with flood, security,
pressure
and radiological barrier seals
which resulted in the generation
of other
CARS.
12
The licensee's staff correctly acknowledged
the broad scope of
these deficiencies
and their potential
adverse
impact
on safe
plant operations.
However, corrective actions to close
87-0095 still have not been
implemented.
An acceptable
action
.
plan to correct these conditions
was provided in the licensee's
March 16, 1990 submittal to Region
V.
Control of Fire Protection
S stem
Im airments
The inspector
was concerned that, apparently, fire protection
deficiencies
have not been resolved in a timely manner
as
required
by the Operations
gA Manual, Criteria, Revision
No. 5.
For example,
as of 8/24/89,
120 EER's were open more than
30
days.
Fourteen
EER's were open greater
than
1100 days
and
90
(70 percent) of the total
number of open
EER's
had been
open
greater
than
180 days for various reasons (i.e.
EED and
NED
interface
problems,
parts problems,
Work Planning/Control
interface problems, etc).
This- has created
a large backlog in
corrective maintenance.
To address
this concern,
the licensee
has recently revised Appendix
A to
(MNCR) (Nonconformance)
control Procedure
No. 73AC-9EE31.
An acceptable
action plan to
correct this condition is provided in the licensee's
March 16,
1990 submittal to Region
V.
Performance
Durin
Extin uishment of Fires
Plant Security, Operations
and Fire Protection interface
problems
have continued to occur since the July 1988 Unit 1
Transformer Fire, during
a Unit 2 unannounced drill on August
2, 1988,
and during
a December 30, 1989, Unit 3 Transformer
Fire.
These past plant responses
to fire emergencies
have
illustrated the
need to establish
and proceduralize fire
emergency policy and instructions in more detail in accordance
with the
FSAR, Appendix R, and Technical Specification 6.8.1.
For example:
V
(a)
An Operations
Manager
was at the scene of the December 30,
1989, Unit 3 Transformers
Fire and determined that the fire
was under control or had been extinguished
and that it was
not appropriate
to declare
an Unusual
Event.
However, the
fire had not been extinguished
and burned for over 10
hours.
This was apparently contrary to Sections
3.2.1
and
3.2.6,
and Appendix B, TAB 4 of Emergency Classification
Procedure
No. EPIP-02.
This is further discussed
in
NRC
Inspection
Report
No. 528/90-07;
529/90-07
and 530/90-07.
(b)
Offsite fire department
assistance
or standby alert was
not requested
during the Unit 3 transformer fire.
However,
had the transformer
exploded
and ignited the
150
foot radius oil spill, the potential
would have
been
introduced for a fire occurrence of proportions
beyond the
capability of the fire team.
Delayed action in alerting
the offsite fire department
could have increased
the
potential for more severe
consequences.
13
In response
to this event,
Fire Team Conduct 'of Operations
Procedure
No.
14DPOFP09
and draft Incident
Command
System
Procedure
No.
14AC-OFP10 are being revised to include
a
process for the earliest possible notification of offsite
fire department
assistance.
I
(c)
The December
30,
1989, Unit 3 Control
Room Log and the
Fire Team Report provided inconsistent descriptions of the
transformer fire event.
The Control
Room Log indicated
that the fire occurred at 1630 and was extinguished at
1632.
The Fire Team Fire Report indicated that the fire
lasted for over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, during which time substantial
communications
were
made with the Control
Room and
Operations,
but none of this was entered in the Control
Room Log.
The specifics
about the fire documented
in the
Control
Room Log and the Operations
Incident Investigation
Report did not accurately
represent
a pattern of
consistency with the Fire Team Fire Reports.
This is
further discussed
in
NRC Inspection Report No. 528/90-07;
529/90-07
and 530/90-07.
According to the licensee,
procedural
methods to improve
consistency
between
these
documents
during fire events
will be implemented.
(d)
Other than the 'Bell Telephone
system, alternate
methods of
communicating with the offsite fire department
are not
proceduralized.
In the event of failure of normal
telephone
systems,
Emergency
Procedure
Nos.
03
(Notification of Unusual
Event Implementing Actions),
14AC-OFP10 (Fire Department Incident
Command
System
and
llGB-OCZ02
Onsite Radio Communications)
specify that
backup communications
is via portable radio.
Procedure
No. llGB-OCZ02 directs Operations,
Security, Medical
and
the Fire Team to use portable radios.
However, the
capability to communicate with the offsite fire department
via portable
radios
has not been provided for and assured.
(10) ~1i
A
The gA/gC audits, surveillances
and monitoring reports
reviewed
by the inspector
appeared
to be satisfactory.
However, the
qualifications of Monitoring Supervisors,
Auditors and
gC
Inspectors
performing fire protection monitoring, surveillance,
and inspections
do not include training on the fire protection
activities they are expected
to monitor.
According to the licensee,
the current proposed
gA monitoring
training program will address
this problem by providing
specialized training in all required areas,
including fire
protection.
Additionally, consideration will be given to the
development of a code compliance matrix (ANSI, IEEE,
ASME,
NFPA, etc) for gA/gC activities.
An acceptable
action plan to
strengthen
the qualifications of gA/gC personnel
is provided in
the licensee's
March 16,
1990 submittal to Region
V.
14
3.
Inservice Testin
of Pum
s and Valves
73756
During the week of January 8-12,
1990 the licensee
was notified that the
NRC would like to observe available
ASIDE Code,Section XI Inservice
Testing (IST) of pumps
and valves performed that week.
An inspector
observed
the following surveillance testing:
A January
9, 1990 test of the Train A Essential
Spray
Pond
Pump per
Procedure
No. 42 ST-2SP02,
Revision 2, "Essential
Spray
Pond
Pump
Operability 4.0.5."
A January
11,
1990 test of Charging
Pump No.
3 (CHE-POl) per
Procedure
No. 41ST-lCH06, Revision 4, "Charging
Pumps Operability
Test 4.1.2.3
and 4.1.2.4."
The performance of these tests
appeared
to be satisfactory,
and the
inspector did not identify any concerns.
No violations or deviations of NRC requirements
were identified.
4.
Followu
of 0 en Items
92701)
a
~
Closed
50-528/88-01-04:
Followu -H dro en Generation
in
Batter
Room
This item was
opened during
a Safety System Functional
Inspection
(SSFI),
when it was identified that hydrogen
gas concentration
in
the class
1E battery
rooms
was not monitored.
The concern
was that
gases
generated
during recharging of the batteries
could
accumulate
in areas of the battery rooms, in areas of low or no air
flow, to unsafe levels
(above
2 percent
by volume).
The
areas
postulated
in the battery
room where hydrogen
gas
could be
trapped,
wer e areas
formed by the structural
steel
system,
above the
ventilation system exhaust
fan inlet vents.
In an initial attempt to address
this concern,
the licensee
issued
work request
(WR) No. 221481'to monitor the possible
buildup of
gas in the Unit 2 battery room, after float and equalizer
charging.
The results
obtained
from performing
WR No. 221481
were
determined to be invalid, based
on placement of meter used to
measure
and
a question
on the accuracy of the meter used
to measure
The licensee
then issued
two new work requests
(No's 317401
and 317402) to conduct additional testing in Units
1
and 3.
During this inspection it was identified that Engineering Evaluation
Request
(EER)
No. 89-PK-078 was issued
November 3,
1989 to documert
the latest information on this concern.
The information is
identified below:
A dead
space
area
was selected
in the ceiling area of the
battery
rooms for station Battery A, in both units
1 and 3, for
the measurement
of hydrogen
gas concentration/"pocketing"
during
a discharge/charge
cycle.
~
~
A Gastech
Protechter II was utilized for measurement
of
every four hours during the entire test cycle in each
unit.
The Unit I test cycle duration was five days;
and Unit 3
test cycle was
10 days.
This instrument provided
a readout in lower explosive limit
(LEL).
A reading of 100 percent
LEL is equal to 4.0 percent
hydrogen concentration.
No LEL reading greater
than 0.0 percent
was recorded
during
testing in units I and 3.
Based
on the results of these tests,
the license
had determined
that gas "pocketing" in the Class
1E battery
rooms is not
a
problem.
The inspector
reviewed
a sample of licensee
procedures
for energizing
the
125
VDC Class
lE electrical
systems
and
60 month surveillance of
Class
1E batteries.
These
had prerequisites/instructions
to ensure
power was available to essential
exhaust
fans
and that normal exhaust
fans were in operation prior to energizing,
discharging
and charging
the Class
1E batteries.
Based
on the above information, it appears
that the licensee
has
taken appropriate
action for this concern.
This item is closed.
Closed
0 en Item 528/88-06-02:
Cable Tra
Cover Interference
it
utomatic
rin
er
ectiveness
0
This item identified the
NRC concern that automatic sprinkler system
actuation
may be delayed
due to the cable tray covers
channeling
away the fire generated
heat and, if actuated,
individual sprinklers
fire suppression
water would not reach the source of a fire inside
cable trays.
The
NRC staff position
on this issue
was transmitted to Region
V via
NRC internal
memorandum
(G. Knighton to 0. Kirsch) dated August 15,
1988.
The staff position is that, although the cable tray covers
have
an adverse
impact on the performance of automatic sprinkler
systems,
where the spatial
separation criteria of Regulatory Guide 1.75 cannot
be maintained,
the potential degradation of the
performance of automatic sprinkler systems is offset by the benefit
achieved with the installation of noncombustible
cable tray covers.
On this basis, this item is considered
closed.
(0 en
50-528/89-02-01:
Followu -Potential
Overflow of the
Transformer
Oi
Retention
Sum
Pits
The original inspection identified that the licensee
did not have
a
maintenance/surveillance
program established
for the transformer oil
retention
sump pits at the time of the transformer fire.
This was
identified as
an example of the licensee's
inattention to detail ir;
the fire protection area.
At the time of the July 6, 1988
transformer fire, burning oil flowed outside the controlled area
and
spread
the fire.
The concern
was that the oil retention
sump pits
were improperly maintained
and they were filled with water at the
time of the fire, so there
was not enough free volume remaining to
receive the design capacity of transformer oil and water from the
deluge water spray sprinkler system.
This report also identified
that the licensee
indicated that
a maintenance/surveillance
program
would be established
for the oil retention
sump pits.
During this inspection
the licensee identified that site procedure
"Fire Protection
Equipment Testing for the Power Block",
Revision 1, established its maintenance/surveillance
program for the
transformer oil retention
sump pits.
The inspector
reviewed the
procedure,
available information and records,
and identified the
following:
0
The main intent of a maintenance/surveillance
program for the
sump pits, .was to maintain
a large
enough free volume/capacity
in the
sump pits, to receive its design capacity of transformer
oil and water from the deluge water spray sprinkler systems,
in
case of a accident/fire.
To maintain this intended free
volume/capacity of the
sump pits, this area
has to be free of
water,
sand and/or other foreign material.
It appears
that the
licensee
had determined that if the
sump pits were free of
water, etc.
down to the
sump pit flange/flap/check
valves (at
the
92 foot and
91 foot-5inch elevations),
there would be
satisfactory available free capacity in the
sump pits.
The inspector
reviewed procedure
14 FT-9FPOl, Revision 1, and
identified the following problems:
(1)
The procedure
did not identify the applicable
drawings for
the
sump pits,
or provide
a sketch, to aid in
identification of the free volume/capacity required to be
maintained clear.
,(2)
Section 8.9 "Transformer
Sump, Appendix H" did not
identify an effective acceptance
criteria, to ensure
the
required free volume/capacity
was maintained.
This
procedure
also did not provide formal or documented
instructions for removal of unacceptable
amounts of water,
sand,
and/or foreign material,
found in a
sump pit during
an inspection.
Subsection
8.9.1 stated in pat t:
"Monthly-Visually Inspect Transformer Sump...
.
Both the
upper
and lower inspection pit check valves must be
visible to meet acceptance criteria."
Subsection 8.9.2
stated:
"After rain storm-visually inspect transformer
sump using criteria list in 8.9.1."
(3)
Appendix
H did not effectively identify an acceptance
criteria or instructions for removal of unacceptable
amounts of water,
sand,
and/or foreign material
found in
the
sump pits.
17
The identified procedure
problems
and weaknesses
were identified
to the licensee,
and they agre'ed to review and revise the procedure
as required to correct these
items.
A sample review of the completed
Appendix
H inspection records,
for inspection procedure
14
FT-9FP01
'identified inconsistencies
in the way data/verifications
were recorded;
and reinforce the
continuing concern with the adequacy of:
(1)
the inspection procedure,
(2)
training for inspectors
performing these inspections,
(3)
the completeness
engineering
and technical
work performed
in the Fire Protection
Program,
and
(4)
management
involvement in the Fire Protection
Program.
The observed
inconsistencies
in the way inspection data/verifications
were recorded in Appendix H, identified that the licensee's
inspectors
appeared
to have problems,
i,n some cases,
with identifying applicable
acceptance
criteria for
some inspections.
It appears
that once
an
inspector identified
a
sump .that had to be pumped,
and placed
an
informal telephone call to building maintenance
to
pump the sump, it
was
pumped within approximately
seven to ten days.
Per discussions
with maintenance
personnel,
they would pump out all the water they
could;
and in some
cases
record the amount
removed in their shift logs.
A major concern identified during this inspection, is the fact that
the inspection
procedure identified "both the upper
and lower
inspection pit check valves must be visible..."
The monthly inspections
were signed off and the inspectors
did not identify that there
was
only one check valve installed in the
sump pits for Units
1 and 2.
This item will remain open.
d.
0 en
LER 528/529/530/89-02
LO and Ll:
Evaluation of Desi
n
C an
es
ac
a es
P
ssocsate
1t
tmos
enc
um
a ves
92702
.
The
icensee
reported in t is
LER that unqualified
pressure
were installed
on Atmospheric
Dump Valves,
and
guality Assurance
would perform an independent
review of selected
design
change
packages
closed during startup testing to provide
additional
assurance
that wor k was performed
as required.
At the time of the inspection,
the licensee
had completed
Atmospheric
Dump Valve (ADV) modifications
on Units 2/3, The
associated
l}uality Assurance
review of selected
design
change
packages
was also complete.
Of fifteen DCP's reviewed,
one
DCP was
found to be signed,off
as complete, with no objective evidence to
support its implementation.
In addition to the incomplete
DCP, the
review identified that the updating of a supplier drawing was
delinquent in both Units
2 and.3.
Corrective Action Report
(CAR)
90-0002
was issued
documenting=these
deficiencies.
The Unit'I ADV
modifications were incomplete,
but were in progress
at the
conclusion of the inspection.
This item will remain
open pending further licensee
action
and
RV
review.
0 en
Unresolved- Item (528 89-02-02
ualification of Fire
rotectson
ta
to
er orm
asntenance
e
ecame
concerne
t at t e
licensee
s
>re protect>on staff was not qualified
through training and experience
to perform assigned
I8C maintenance
tasks.
In response
to this concern,
the licensee
indicated that procedures
were being revised to delete all
ISC tasks
assigned
to the fire
protection staff.
At the time of the inspection, this action
was
not completed.
This item will remain
open pending further licensee
action
and
NRC review.
0 en
Violation (528/89-02-03
Interface with Phoenix Fire
De artment
9 702
.
e
NRC
ecame
concerned that t e
licensee's
require
fsrefig ting interface with the Phoenix Fire Department
had
not been
implemented.
While some interaction with the offsite fire department,
such
as
Hazardous llaterial Team familiarization tours, production of an
offsite fire department training video tape
and
a group table top
discussion
have occurred.
However, since initial Unit I startup,
required
FSAR annual offsite fire department training, drills,
pre-fire planning and,incident
command strategies
had not been
implemented.
In response
to this previous
NRC Violation, the
licensee
conducted
a drill with the offsite fire department
on
February 4, 1990, during the inspection.
While the results of the
February 4,
1990 drill with the offsite fire department
were
apparently successful,
the following additional
concerns
need to be
evaluated
by the licensee:
(I)
A schedule for future drills, training and pre-fire planning,
established
by the licensee
and coordinated with the offsite
fire department,
would be helpful.
(2)
A site specific radiological training program for the offsite
fire department,
established
and implemented
by the licensee
with auditable
documentation of offsite fire department
personnel
participation,
should
be considered.
This item will remain open pending further licensee action
and
NRC
review.
(0 en
LER 528/529/530/89-05
LO and Ll:
Atmos heric
Dum
Valve
e 1csencies
9z
.
e
licensee
reporte
in t ss
t at
manufacturer i entified Atmospheric
Dump Valve (ADV) deficiencies
could result in the inability to remotely or manually operate
the
ADV's.
I
1
I
19
The licensee's
corrective actions
included redesign of th'e
ADV
'nternals,
initiation logic and dedicated
were
verified complete
by the
NRC prior to restart of Units
2 and 3.
The
Unit I modifications were incomplete,
but were in progress at the
time of the inspection.
This item will remain
open pending further licensee action and
Region
V review.
0 en) 50-528/529/530/89-08-01:
Followu -EOP
U arades
- see
L
R 8 -
-
,
ate
6-6-
This item identified that while a special
NRC Emergency Operation
Procedure
(EOP)
team inspection
concluded that the licensee's
could be utilized by the licensee
operating staff, they do present
significant usage
problems for the operating staff.
Principally
those
problems
were identified as
human factors related
and
included:
inconsistencies
in structure
and format
an overly complex structure
ill defined, excessive,
and buried transitions within the
optimum and functional recovery procedures,
after exiting the
diagnostics
heavy reliance
on operator
judgement
and discretion
the lack of a defined philosophy of use.
These
problems
were recognized
by the operators,
who voiced their
dissatisfaction with the quality and useability of the
EOPs.
The
licensee's
procedure
development
program appeared
to be the chief
cause of the procedural
problems.
The problems with procedural
development
appeared
to be equally applicable to the Abnormal
and
Normal Operating Procedures.
In response
to the original team inspection report, the licensee
issued letter 102-01290-WFC/TDS/JJN of June 6, 1989, subiect
"Emergency Operating
Procedures"
(File:
89-002-493).
Attachment I
of this letter identified completion dates for portions of the
upgrade project and 'an expected
implementation
date for new
EOPs of
July 1990.
During this inspection the inspector
requested
the licensee
to
identify the current status of the milestones identified in
Attachment I of the identified letter.
The licensee identified they
had missed the July 27,
1989 date for revising
EOP Technical
Guidelines,
the October 27,
1909 date for revising
EOPs,
and were
still working on these
items.
It now appears
that because
of
scheduling
problems for access
to the simulator, the revised
procedures will not be implemented until at least July,
1991 instead
of July 1990,
a year later.
20
In response
to the 'inspector's
question
on the number of human
factors
(HF) specialists
the licensee
had working on this project,
the licensee
stated that Battelle
Human Affairs Research
Centers of
Seattle,
had provided one onsite
HF specialist in 1989,
and that
a five man
HF team in Seattle
was
now reviewing the
documents
generated
in 1989.
The licensee identified that
a total
of approximate1y
eleven personnel
were
now working on this project.
The failure to complete the project tasks
by the dates identified to
the
NRC in the June 6, )989 letter and to have identified at least
a
one year delay prior to implementation of new EOPs, without
notifying the
NRC of these delays,
demonstrates
poor licensee
performance
in this area.
Aggressive
management
attention is
required in this area, to ensure
an expeditious
issuance
of these
revised
EOPs.
On February
17,
1990 the licensee identified that
a draft letter to
the
NRC, to identify the current status of the
EOP upgrade project,
had
been prepared
and was under review.
This item will ~emain
open
until the above letter has
been received
by the
NRC, reviewed
and
the
new schedule for issue of the revised
EOP's evaluated.
Closed
50-528/89-09-01:
Followu -IST - Licensee
Procedures
o
ot
ents
at
orrectsve
ct>ons
re
e uvre
or
Unacce ta
e Data
A review of Inservice Testing (IST) procedures
identified these
procedures
did not appear to identify what corrective actions the
licensee
was going to take once trended
dated indicated corrective
action was required,
and who would identify the corrective action.
During the initial inspection
the licensee identified that they were
in the process
of issuing
new IST and System Engineer procedures,
and that this concern
should be addressed
in the
new procedures
and
program improvements.
During this inspection the licensee identified that Revision
2 to
Procedure
73AC-OX102, "Inservice Testing of Safety Related
Pumps
and
Valves",
had
been
issued to address
this concern.
The inspector
reviewed this procedure
and noted that it required the following:
If a 'pump or valve was found unacceptable,
per the criteria of
Procedure
60AC-Op(01, "Control of Nonconforming Items",
a
Material Nonconformance
Report
(MNCR) would be issued to
address
corrective action.
If a valve is placed
on an increased
frequency for testing,
an
Engineering Evaluation Request
(EER) would be issued to address
corrective action.
This initial licensee
action appears
to address
this concern.
The
implementation of this action will be the subject of future
inspections.
This item is closed.
21
(0 en
LO and Ll:
Emer enc
Li htin
S stem
e sc~encies
e
)censee
reporte
sn t ss
that the
emergency
sg tsng
sn all three units did not meet the design basis
or 10 CFR 50, Appendix
R requirements.
Based
on the discussion
provided previously in this report,
and
the licensee's
completion of required modifications for Unit 1
startup, this item will remain
open pending further licensee
action
and
NRC review.
0 en
0 en Item 528/89-12-01:
EE-580
Com uter Pro
ram
Deficiencies
92701
.
This item concerned
deficiencies
in the
licensee
s
e ectrscal distribution system configuration management
computer data
base.
The licensee
acknowledged
the potential significance of these
deficiencies
to configuration management
of the electrical
distribution system.
In parallel with evaluation of the
deficiencies,
the licensee
has hired
a contractor to review work
orders
and design
change
packages
to determine
the validity of
information on cable routing cards.
Plant walkdowns are scheduled
to be performed during each unit's extended refueling outage.
The
Unit 3 plant walkdown is scheduled
to be performed in January
1991.
Unit
1 is scheduled
in April 1991,
and Unit 2 in the Fall of 1991.
This item will remain
open pending further licensee
action and
Region
Y review.
Closed
0 en Item 528/89-28-05:
Control Element Assembl
(CEA
ee
Sw>tc
osstion
em orar
o
s scat
on
1S item
s entsfied t e
NRC s concern for t e
icensee
s removal of Unit 2
CEA P9 from service via Temporary Modification No. 2-89-SB-027.
This item is closed
based
on inspector verification of licensee
corrective actions
which included restoration of Unit 2
CEA 89 to
service
by the removal of Temporary Modification No. 2-89-SB-027.
The Control
Rod position indication circuitry was provided with
proper resistors
to obtain the correct voltage division and
satisfactorily functionally tested.
This work was authorized
by
Work Order No. 00381382.
The work order was completed
on September
20, 1989.
On this basis, this item is considered
closed.
Closed
50-528/89-28-11:
Unresolved-Measurement
and Test
E ui ment
M TE
Procedure
Contro
s Ina
e uate
In August of 1989, the original inspection identified the following:
The
MSTE organization's
practice of having sixty-one custodial
points for issuance
and return of MATE by craft personnel,
did
not appear to adequately
control
MSTE.
Since
MSTE could
be "informally" checked out for use,
accountability for that piece of MSTE was lost.
4
C
4
~
~
22
0
The practice of declaring
any piece of M&TE lost or stolen if
not returned to the
M&TE department within 30 days of its due
date (i.e. overdue
M&TE and issuance
of an "Out of Tolerance
Notice (OTN)), did not promote accountability.
For work that was performed utilizing a piece of M&TE that is
subsequently
declared .lost or stolen,
the existing
procedure
(34AC-OME01) required
performance of an "evaluation"
to determine
the need for rework or retest.
It was determined
that this procedure
inadequately controlled the quality and
consistency of such evaluations,
since specific review
requirements,
level of detail
and criteria were not specified.
Furthermore,
although the procedure
required the evaluator's
approval of the
OTN evaluation,
no criteria was provided for
the supervisor to judge the adequacy
or acceptability of the
evaluation.
During this inspection the licensee
provided
a copy of an internal
letter
064-01467-PLB,
dated
November 20,
1989, subject:
response
to
NRC Inspection
Report
Nos. 50-528; 529; 530;/89-28,
unresolved
item
528/89-28/11,
M&TE.
The inspector reviewed the information in this
letter,
a new Revision
3 to licensee
procedure
"Measuring
and Test Equipment
(M&TE) Users Administrative
Requirements,"
a sample of available
completed
OTN's,
and other
associated
documents.
Based
on the information reviewed
and
discussions
with the licensee,
the licensee
has:
Changed
the
MSTE program to require all
M&TE to be issued
from
a central tool room (Central Depot), to only individuals that
have
been
approved
by management.
Identified that the transfers of M&TE to an individual in
another organization
must
be through the Central
Depot.
Identified that the assigned
individuals and their supervisors
will be held responsible for each
item of M&TE.
,.Additional guidance
has
been provided to the
OTN Evaluators.
Based
on the information reviewed
and discussions
held with licensee
personnel, it appears
the licensee
has
taken actions to address
this
concern.
n.
This item is closed.
Closed
50-528/89-28-13:
Unresolved - ALARA Tt ainin
For
Maintenance
Personne
A review of training programs for workers involved in reactor
coolant
pump
(RCP) repairs in Units I and 3, identified that the
magnitude
of radiation, contamination levels
and potential
dose
rates
these workers were exposed to, were similar to those that
a
worker assigned
to inspect
and repair
might
23
experience.
Although no mock-ups were available for training
workers, the licensee
had developed training lesson
plans
and
a
review of training records
disclosed that six licensee
employees
had
received training during the period of 1987 to 1988.
There were
forty-six contractors
performing unit I PCP work and sixteen
contractors
performing Unit 3
RCP work, and none of these contractor
employees
were provided with RCP training by the licensee.
Discussions
with the licensee's
staff disclosed that .it was decided
not to provide the
RCP workers with any specialized training since
only workers with prior RCP work experience
had been selected for
this work.
In response
to the initial team's
concern
over the number of RCP
workers not receiving
RCP training, the licensee's
ALARA staff
informed the team that consideration
would be given to the need for
providing
RCP training to workers for any future
RCP work.
During this inspection the inspector
reviewed
a licensee letter (ID
No. 218-00795-PWH/JBS)
dated October 31, 1989, entitled 'Unit 2 1990
Refueling Outage
Job Specific Training Requirements'.
This letter
identified:
That the licensee
was currently pursuing the procurement of a
mock-up assembly for future
RCP Training.
Recommended
that at least
one individual on each
RCP crew has
had prior experience
or has attended
formal training dealing
with the particular evolution being performed.
Many other, training methods
(video tape, incidental
mock-up
training, pre-job briefing, etc.) will be utilized during the
outage,
and pre-planning
phases.
Management
was requested
to make every attempt to facilitate
these
recommendations
as
an ongoing effort to improve work
practices
as well as minimizing personnel
radiation exposures.
Based
on the above information and discussions
with licensee
personnel, it appears
the licensee
is addressing
this
NRC concern.
This item is closed.
0 ~
(Closed
0 en Item 528/89-28-14:
Im ro er Desi nation of Level
A
are
ouse
tora
e
ss
stem
s ent)
se
t e
licensee
s
apparent
improper storage of computer
hardware items.
This item is closed
based
on inspector verification of licensee
corrective actions
which included vendor confirmation of Level
A and
Level
B storage
requirements
and establishment
of additional
personnel
training and administrative procedural
instructions
(12DP-OMCOB and
12DP-OMC09) for Inventory Control
and Procurement
Engineering to appropriately classify levels of storage protection.
24
The fourteen safety related
computer
hardware
items designated
as
requiring Level
A storage,
but found in the
Leve'1
8 storage
area
during the inspection,
were verified through vendors to require
Level
B storage
in accordance
with ANSI N45.2.2.
The Level
A
storage
designation
was incorrect for these all fourteen items.
The results of the licensee's
review of all warehouse
material
storage classifications identified that additional
Level
A materials
and approximately
5000 Level
C warehouse
materials
were incorrectly
classified.
All of the materials
were reclassified
and
have
been
stored
under conditions which meet the appropriate
requirements
of
This item is considered
closed.
(Closed
0 en Item 528/89-28-15:
Incom lete Warehouse
Inventor
ontro
roce ures
1s
1tem
s entl
1e t e
ac
o
esta
ss
e
proce ures
or controlling required levels of protection
for warehouse
material storage.
This item is closed
based
on inspector verification of licensee
corrective actions which included vendor confirmation of material
storage
requirements;
deletion
and consolidation of seventeen
separate
procedures
into one procedure
(12AC-OMC01) for material
control,
and implementation of proper instructions in Material
Control Procedure
No.
12AC-OMCOl for warehouse
material
storage
protection
based
on environmental
considerations
and important
physical characteristics
rather than material safety function.
The
procedure
provides instructions to assure
that the requisite quality
of all warehouse
storage materials is preserved
from the time they
are fabricated until they are installed in the plant.
This item is
considered
closed.
(Closed
Unresolved
Item 528/89-28-07:
Incorrect As-built Drawin
s
92701
.
T 1s item
s entifie
apparent
iscrepancles
)n
sometrsc
Drawing No. 13-P-SPF-701/Revision
14 and 13-P-DGF-701/Revision
14,
regarding as-built pipe supports for the Unit I Emergency Diesel
Generator
Essential
Spray
Pond
and Starting Air Systems.
This item is closed
based
on inspector verification of licensee
corrective actions
which included investigating the Isometric
Drawing deficiencies.
The determination
was that the as-built and
drawing configuration was not correct because
Piping Isometric
Drawings were not intended to be consistent with pipe support
calculations
and as-built installations.
Instead,
Hangar Detail
Drawings are
used
as design output documents relating the design
calculations to the actual
pipe support installation for
configuration control.
Configuration Management
Program
Procedure
No.
Revision I, Appendix C, lists Isometric Drawings and
Pipe Hangar Detail Drawings as configuration management
design
output documents.
During the inspection,
Pipe Hangar Detail
drawings
were not provided to the inspectors for the as-built pipe
support verification of the Unit I Emergency
Diesel
Generator
Essential
Spray
Pond
and Starting Air Systems.
25
Although the Hangar Detail Drawings are maintained consistent with
the actual
pipe support installations,
the licensee's
Engineering
Excellence
Program currently underway is revising Piping Isometric
Drawings to show general
pipe support locations, for information
only, as unit specific information on certain safety related
drawings.
This item is considered
closed.
Closed
0 en Item 528/89-36-02:
Inade uate
A ueous
Film
ormsn
oam
u
is stem
~ ents
se
the
concern t at the
icensee
s reserve
supply of firefighting foam
extinguishing agent
(AFFF) was inadequate.
As
a result of a September I, 1989 electrical/oil fire in Phase
B on
Devers line in the Switchyard, the licensee
performed
an evaluation
to determine
the minimum quantity of alcohol
based
foam (AFFF)
inventory that should
be available for extinguishment of the worst
case electrical/oil fire at the site.
EER No. 89-FP-102
was
initiated for this concern
and was dispositioned
by establishing
a
minimum quantity of AFFF to be stored
on site and ensuring that
measures
were taken to replenish
the supply as necessary.
The
minimum quantity was determined to be
180 gallons.
During tours of
Procurement
Engineering
and Warehouse Material Storage,
the
inspectors verified that the supply is replenished
when the minimum
quantity reaches
300 gallons.
On this basis, this item is
considered
closed.
s ~
Closed
- Unresolved
50-530/89-18-01:
ISI-Licensee
Procedures
ow
se of
or
ontro
Documents for Non- on ormance
Items In
ace
o
ER
This item identified that various Inservice Inspection (ISI)
procedures
contained sections
which stated
"An EER per procedure
73
AC-OEE01 (or another
approved
nonconformance
document) shall
be
initiated for all items reflecting an unacceptable
condition."
Taken alone, this reference to the
EER process
appeared
to implement
the, intent of 10 CFR Part 50, Appendix B, Criterion XVI, which
states
in part,
"Measures shall
be established
to assure that
conditions adverse
to quality, such as...
Nonconformances
are
promptly identified and corrected...
cause of condition is
determined
and corrected action taken to preclude repetition. ..."
The item of concern identified with these
ISI procedures
was that
a
subsection of these
procedures
stated,
"This
EER process
is not
required to be initiated when the unacceptable
condition can
be
readily corrected in accordance
with procedure
30AC-9ZZOl, Work
Control", without defining how or when this substitution could be
made.
Procedure
30AC-9ZZ01, Revision 4,
"Work Control" was reviewed
by the inspector.
This procedure did not appear to implement the
intent of 10 CFR Part 50, Appendix B, Criterion XVI for
nonconformances,
identified during ISI examinations.
The licensee
agreed that this could be interpreted
as
a questionable
area,
but
that they use procedure
430 P-9ZZll, Revision 2,
"Mode Change
Checklists," in conjunction with the
EER and work control processes,
to ensure
the implementation of 10 CFR Part 50, Appendix B,
Criterion XVI requirements.
1~
g
~ ~
26
To resolve this concern,
the licensee identified that they would:
Review the controlling ASME Section
XI ISI Administrative
Control
(AC) Document,
73AC-OXI01, Revision '0,
"ASIDE Section
XI
Inservice Inspection," to evaluate
what changes
might be
required to ensure
any significant nonconforming condition
identified during an ISI examination
was evaluated
per the
process
(or any other approved
nonconformance
document).
At
the time of the initial inspection there
was
no other approved
nonconformance
document,
although
one was being evaluated
by
the licensee for issue in the future.
During this inspection
the inspector
reviewed the following:
Licensee
Response
Letter 102-01289-h'FC/TDS/JJN,
dated
June 5,
1989.
Procedure
73AC-OXIOl, "ASME Section
XI Inservice Inspection,"
Revision Ol,
PCN No. Ol, dated
October 6, 1989.
Procedure
60AC-OQQ01, "Control of Nonconforming Items,"
Revision 1, dated October 2, 1989.
Licensee Letter 102-01289-MFC/TDS/JJN identified the following:
'Procedure
73 AC-OXI01 would be revised to specify conditions
which could be corrected
using the work control process
and
those that require
an engineering evaluation.
As an interim measure
to restrict elevation of a plant
operating
mode,
procedure
73AC-OXI01 would be revised to
reference
procedure
430P-9ZZll (Node Change Checklist) to
ensure that all code respectable,indications
would be
dispositioned prior to entry into a mode where the indications
would adversely affect safety.
As long term corrective action,
a Nonconformance
Report
(NCR)
program is being developed
and will include
a mode restraint
designation.
Based
on discussions
with licensee
personnel
and review of applicable
documents, it appears
the licensee is adeouately
addressing
this
concern.
This item is closed.
5.
Licensee
Performance
in Handlin
Emer enc
Diesel Generators
Noncon ormsn
Con
>talons
During an inspection of the licensee activities for the Unit 2 Emergency
Diesel Generator,
Train A inspection,
per procedure
"Diesel
Engine
18 month Inspection", Revision
No. 5,
PCN No. 02, the following
concern
was identified:
27
A January
9, 1990 inspection of the Unit 2, Train and Diesel
Engine
identified that cast
aluminum valve covers
showed evidence of
contact
between the top of the valve covers
and the bottom edge of
the sheet
metal jerk pump shrouds/shields
installed
over the
associated
fuel oil line and injector jerk pump associated
with the
applicable cylinder.
The evidence of contact
ranged
from paint
removal, to gouges
approximately
3 inches
long by 3/16 inch wide to
depths of 1/8 to 1/4 inch.
Some of the gouges
appeared
to be
recent.
On January
9,
1990 the inspector questioned
the licensee
personnel
performing the
18 month inspectio'n about the nonconforming
conditions/gouges.
a.
The inspection
group had
no information on the gouges,
no
repair instructions
and did not plan on taking any actions at
that time.
b.
When asked if the
same
sheet
metal shield removed
from a
cylinder/valve cover was reinstalled
on the
same cylinder, the
inspection
crew stated "if possible,
but it was not an
inspection
procedure
requirement."
Later an
NRC tour of all
Emergency Diesel
Engines in Units 1,
2 and 3, identified that
some sheet
metal shields
had cylinder numbers identified with
temporary markings
on them.
c ~
The tour of all emergency diesel
engines
in Units 1,
2 and 3,
identified that they all had
some evidence of contact
between
the sheet
metal shields
and valve covers for some cylinders.
It appeared
that
on the average,
the Unit 1, Train
8 Engine
appeared
to have the largest
average
clearances
between
the
sheet
metal shields
and valve covers.
On January
23,
1990 the inspector
asked the Emergency
Diesel
Engines
System Engineer if the eighteen
month inspection of the Unit 2,
Train A diesel
engine
had documented
the nonconforming
gouges in the
engine cylinder valve covers,
in either
a Material
Nonconformance
Report
(MNCR) or an Engineering Evaluation Request
(EER).
The
System Engineer identified that no
MNCR or EER had
been
issued
on
the gouges,
but he had
been notified that an
NRC inspector
had
questioned
the inspection
group about the existing gouges.
The
System Engineer identified that
he believed there
was
an old work
order that had
been
issued
on the gouges in the Unit 2 engines,
and
that the e'xisting gouges
did not present
a safety concern,
since:
The valve covers
were just
a dust cover.
The licensee
had already authorized
the reduction of the valve
cover wall thickness
in some areas,
by removing metal
from the
inside of some of the valve covers, to provide additional
clearance
between the valve cover and the cylinder rocker arm
assembly.
~
J
L
~
Jt
~
~
h
28
When asked if the licensee
had performed
and documented
an
engineering
analysis of the valve cover gouges
found in Units I, 2
and 3, or issued
r epair work orders for Units
2 and 3, the licensee
identified that they could not find any documentation that any of
these actions
had been performed.
Since
an engineering
analysis
was
not performed for the identified problem in Unit 2, it appeared
the
license took no actions to correct the similar problems in Units I
and 3.
On January.25,
1990 the licensee
issued
EER No. 90-DG-005
on the
Unit 2 Emergency Diesel
Generator 'A', identified the following:
Work Order No. 00380337,
was issued
September
15, 1987, to trim
metal
from the fuel oil "jerk pump" shields.
An engineering
evaluation of this action
was not performed,
either
on the shields or on the gouging of the valve covers.
A walkdown of all diesel
engines,
in all units, by the system
engineer,
showed that, without exception,
every engine
has
one
or more shields that were or had
been in contact with the valve
covers.
During this licensee
walkdown, it was also noted that
some shields
were in contact with the high pressure
fuel lines,
and/or fuel supply lines.
The valve covers
are intended to be an oil containment
and dust
cover, these
covers
are not intended to be
a pressure
retaining
device.
Engineering
recommended
that the jerk pump shields
be "trimmed"
on the bottom to provide
a clearance
of approximately I/2 inch
between the shield
and the valve cover,
and high pressure
fuel
lines.
While the shield is removed for "trimning", the valve cover
shall
be inspected
by maintenance
to ensure
the "rubbing" has
not created
a hole through the valve cover. If a hole is
..identified, or there is an excessive
"gouge", in the opinion of
maintenance,
a work request is to be submitted.
New work requests
were identified for both engines
in all three
units.
This
EER disposition is deemed to be Design Equivalent
Rework
to return the equipment to original design.
During discussions
with licensee
management,
the inspector
identified that:
L
This was another
example of the work control group issuing
a
work order, instead of requesting
an engineering evaluation.
The licensee
stated that in 1987 they coul.d issue
a work order,
today in 1990, they would have to issue
a
MNCR or EER.
Eg I
~
(g
Three years
appeared
to be an excessive
amount of time to correct
an identified nonconforming condition, that increased
the amount
of valve cover damage
each additional
hour the Unit 2 engines
were operated with contact
between the two items.
The licensee
stated that this work was low priority work, and the schedule
would not allow performance until the next schedule
outage.
The licensee
performance
and followup on identifying similar
nonconforming conditions in the Units I and
3 engines
appeared
to be inadequate,
once this condition was identified in Unit 2
in 1987.
The licensee
agree that they could have
been more
aggressive
in following up on this item in 1987, but the
procedures
in effect at the site today, should ensure that
either
an
EER or NNCR is issued
and Engineering
Evaluation/Followup would be required for all units involved.
Based
on the above information, the fact that the nonconforming
gouges for all three units are
now documented
in an
EER and the
licensee
implementation of the
new NNCR program,
and additional
training of licensee
personnel
in documenting all identified
nonconforming conditions, etc., the licensee
appears
to be
addressing
this concern.
No violations or deviations
were identified.
~
~
6.
Followu
on Items of Noncom liance
and Deviations
92702
a.
Closed
50-528/89-28-09:
Enforcement - Failure to Record
Com
et>on
o
roce ure
te
s
This item identified that
a technician
had not signed off four steps
of an Operational
Computer Systems
Troubleshooting
Work Order No.
00372377.
While it was identified that this was
an isolated
occurrence, it was
an example of the licensee's
failure to follow
established
procedures.
In response
to this violation the licensee
issued letter
102-01530-WFC/TDS/TRB,
dated
November 30,
1989 to the
NRC.
This
letter identified:
That the affected technician
was counseled
on attention to
,detail
and previous
work was evaluated for missed
steps
or
other violations.
No discrepancies
were identified.
All Operational
Computer System
(OCS) maintenance
personnel
were counseled
on "Attention to Detail" and the importance of
documenting work as it is performed.
To address
the overall issue of procedural
compliance,
the
licensee is currently evaluating additional actions to ensure
there
can
be
no misunderstanding
by employees with regard to
management
expectations
in this area.
The details
and schedule
of the evaluation
were contained in a letter
102-01525-JNB/TDS/GEC,
dated
November
17, 1989,
issued to the
NRC (Region V).
~
1
<4A
'
c>
I
30
After reviewing the above information, it appears
that the licensee
has
taken appropriate
action for this item.
This item is closed.
7.
~D
Open items are matters that have
been discussed
with the licensee,
that
will be reviewed further by the inspector,
and that involve some action
on the part of the
NRC, the licensee,
or both.
8.
Unresolved
Items
Unresolved
items are matters
about which more information is required in
order to ascertain
whether
they are acceptable
items,
items of
noncompliance,
or deviations.
Unresolved
items disclosed
during the
inspection
are discussed
in paragraph 2.E(1)(a), 2.E(2), 2.E(3), 2.E(4),
2.E(6)
9.
Exit Interview
An exit meeting held with the licensee's staff on March 23,
1990 at the
site,
and in the Region
V office on March 30,
1990 in the Region
V
offices.
The items of concern in this report were discussed
at that
time.
The licensee-acknowledge
the scope
and content of the inspection
findings.
The licensee
was further advised of the major
NRC concerns
in
the emergency lighting area during
a teleconference
on April 16,
1990.
The licensee
acknowledged
an understanding
of those issues.
% D
s
~t
4
I
t