ML17342A831
| ML17342A831 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/27/1987 |
| From: | Shymlock M, Stadler S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17342A829 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.2, TASK-1.A.2.3, TASK-1.C.5, TASK-TM 50-250-87-32, 50-251-87-32, NUDOCS 8708060061 | |
| Download: ML17342A831 (38) | |
See also: IR 05000250/1987032
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/87-32
and 50-251/87-32
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL 33102
Docket Nos.:
50-250
and 50-251
License Nos.:
and
Facility Name:
Turkey Point
3 and
4
'I
Inspection
Conducted:
July 6-10,
1987
Inspector:
S.
. Stadler,
Team Leader
Team Members:
T. J. O'onnor
M. J. DeGraff
R.
D. Starkey
Approved by:
M. B.
Iy
oc
,
hief
Operational
Programs
Section
Division of Reactor Safety
SUMMARY
V/X7r'gP
Date Signed
o87 rtg7
Da
Signed
Scope:
This routine,
announced
inspection
was. in the area of closeout of open
inspection
items.
Results:
One violation
was identified concerning
the failure to implement
approved
procedures
governing operational
experience
feedback,
paragraph 5.t.
87080600hf
870728
ADQCK 05000250
REPORT
DETAILS
Persons
Contacted
Licensee
Employees
- C. M. Wethy, Vice President
- C. J. Baker, Plant Manager - Nuclear
- E. F. Hayes, guality Control
(OC) Supervisor
- J. A. Labarraque,
Technical
Support Supervisor
- W. Bladow, guality Assurance
(gA) Superintendent
- D. D. Grandage,
Operations
Superintendent
- J. Arias, Jr., Regulatory
and Compliance Supervisor
- D.
W. Haase,
Chairman,
Safety Engineering
Group (SEG)-
- G. Salamon,
Compliance
Engineer
- D. R. Whitney, Compliance
Engineer
- M. 0. Kulp, Project Engineer
- J. C. Strong, Electrical
Department
Supervisor
- R. Broadnax,
Support Supervisor - Training
Other
licensee
employees
contacted
included
engineers,
technicians,
operators,
and office personnel.
NRC Resident
Inspectors
D.
R. Brewer, Senior Resident
Inspector
K.
W. VanDyne, Resident
Inspector
- J. B. MacDonald, Resident
Inspector
- Attended Exit Interview
Exit Interview
The inspection
scope
and findings were summarized
on July 10,
1987, with
those
persons
indicated in paragraph I above.
The inspection
described
the
areas
inspected
and
discussed
in detail
the following inspection
findings.
No dissenting
comments
were received
from the licensee.
The
following items from previous inspection reports
were closed:
(Closed)
Escalated
Enforcement
Action (EA) 86-20
VI Failure to Promptly
Identify Conditions Adverse to guality With Respect
to Component
Cooling
Water
Flow Through Residual
Heat
Removal
Heat Exchangers,
Single Failure
Concerns
of
an
Intake
Cooling Water -Control
Valve,
and
Resolution
of
Component
Cooling
Water
Problems
for
Safety
Injection
Pumps.
(Paragraph
3.c)
(Closed)
EA 86-20-V:
Failure
to
Perform
Technical
Specification
'Surveillance
Testing
for Station
Batteries,
Failure
to
Adequately
Establish
and
Implement Procedures
With Respect
to Documentation
of Post
Maintenance
Testing
and
Root Cause of Problems
on Plant
Work Orders,
and
Failure to Take Adequate
Corrective Action With Respect
to Missing Valve
Parts
and
Safety
Related
Condensate
Storage
Tank
Level
Indication
Concerns.
(Paragraph
3.a)
(Closed)
EA 86-20-III:
Failure to Comply With Technical Specification 3.8
and 3.4 Concerning,
Respectively,
System
and Safety
Injection System Operability.
(Paragraph
3.b)
(Closed)
Unresolved
Item
(UNR)
250,251/85-40-13:
Failure
to
Meet
Coranitment to Install Adequate
DC Lighting to Support Local
AFW Operations
During Shutdown
From Outside the Control
Room.
(Paragraph
5.c)
(Closed)
UNR 250,251/85-40-25:
Inspector
Concerns
Pertaining
to Tubing
Sections
of the Nitrogen
Backup to the Auxiliary Feedwater
System
Being
Adequately Supported.
(Paragraph
5.e)
(Open)
UNR 250,251/85-40-29:
Review of Licensee's
Thermal
Overload Size
for Valve Operators
(Paragraph
5.g)
(Closed)
UNR 250,251/85-40-30:
Insufficient Test
Data
and
Review of
Manufacturer's
Calculations
to Insure the Operability of MOVs 3-1403
and
4-1403
Steam Supply to the Auxiliary Feedwater
Pump.
(Paragraph
5.h)
(Closed)
UNR 250,251/85-40-33:
Review Apparent Conflict Between Technical Specification 4.8.2.b
and Vendor Recommendations.
(Paragraph 5.i)
(Closed)
UNR 250,251/86-18-01:
Lack of Documentation to Indicate
Formal
Operability Evaluation.
(Paragraph
5.k)
(Open)
UNR 250,251/86-18-13:
Lack of Procedures
for Loss of
DC Power.
(Paragraph
S.o)
(Closed)
UNR 250,251/86-19-03:
Failure to Provide Requalification
Exams
Within Required
Time Period.
(Paragraph
5.p)
(Closed)
UNR 250,251/86-46-02:
Tracking of Corrective Actions to Findings
of Licensee
Internal Training Assessment.
(Paragraph
S.r)
(Closed)
UNR 250,251/87-07-02:
Implementation of Revised
Required
Reading
Program
and
Resolution
of
Outstanding
Required
Reading
Items.
(Paragraph 5.t)
(Closed)
250,251/87-09-01:
Excessive
Overtime
By
Operations
Personnel.
(Paragraph
5.v)
(Closed)
UNR 250,251/87-09-02:
Utilization of Non-qualified Instructors
to Teach
Systems
and Integrated
Plant Response.
(Paragraph
5.w)
.
(Cl osed)
Inspector
Fol 1 ow-up
Item (IFI)
250/84-25-01/
251/84-26-01:
Inspector
Concerns
Pertaining
to Non-shift Licensed Operators
Performing
the Functions of Licensed Operator
on
a quarterly Basis.
(Paragraph
5.a)
i
e
3.
(Closed)
IFI 250,251/85-22-10:
Completion of
Commitments
to Train
Licensed
Operators
on the
Loss of Inverters
and Associated Vital Buses.
(Paragraph
S.b)
(Closed)
IFI 250,251/85-40-16:
High Radiation
Levels in the Auxiliary
Pump
(AFW) Area Following a
LOCA on Unit 3.
(Paragraph
5.d)
(Closed)
IFI 250,251/85-40-28:
Review the
New Maintenance
Training and
the Qualification Tracking System.
(Paragraph 5.f)
(Open) IFI 250,251/85-40-38:
Determine
Adequacy of Fail Safe Testing for
Flow Control Valve.
(Paragraph 5.j)
(Closed)
IFI 250,251/86-18-02:
Lack of Adequate Criteria for a Safety
Evaluation Determination.
(Paragraph
5.k)
(Closed)
IFI 250,251/86-18-05:
Need to Develop
and
Implement Corrective
Action Program for Motor Operated
Valves (Paragraph 5.l)
(Cl osed)
IFI
250,251/86-18-09:
Control
Over
Plant
Scaf folding.
(Paragraph
5.m)
(Closed)
IFI 250,251/86-18-10:
Configuration Control
Concerns
Over the
Procedural
Requirement
of Valve Lineup Versus'he
Actual Field Position.
(Paragraph
5.n)
(Closed)
IFI 250,251/86-24-01:
Inspector
Concerns
Pertaining
to Post
Accident Sampling
System
(PASS) Calibrations.
(Paragraph
5.q)
(Closed)
IFI 250,251/87-07-01:
Resolution of Training Records
and Files
Involving the
Recertification
of Quality Control
(QC)
Inspectors,
(Paragraph
5.s)
(Open)
IFI 250,251/87-07-03:
Generation
of Electrical
Breaker Setpoint
Document.
(Paragraph
5.u)
The licensee
did not identify as proprietary any of the materials
provided
to or reviewed
by the inspectors
during this inspection.
Licensee Action on Previous
Enforcement Matters
(92702)
On August 18,
1986,
the
NRC issued
a Confirmatory Order
and Notice of
Violation and Proposed
Imposition of Civil Penalties
related to Inspection
Reports
250,251/85-32,
250,251/85-40,
250,251/86-02,
250,251/86-11,
and
250,251/86-26.
This enforcement
action combined violations and unresolved
items
discussed
in these
inspections.
To ensure
that all of the
inspection findings presented
in these
reports
have
been
addressed,
this
section
of the
report
presents
closeout
of the violations
as
they
originally appeared
in the inspection reports.
a.
Escalated
Enforcement
Action
(EA) 86-20-V:
Failure
to
Perform
Technical
Specification Surveillance
Testing for Station Batteries,
Failure to Adequately Establish
and
Implement Procedures
With Respect
to Documentation
of Post
Maintenance
Testing
and
Root
Cause
of
Problems
on
Plant
Work Orders,
and
Failure
to
Take
Adequate
Corrective Action With Respect
to Missing Valve Parts
and Safety
Related
Condensate
Storage
Tank Level Indication
Concerns.
This
EA originated
from violation 250,251/86-26-10,
which
encompassed
previously
identified violation
250,251/86-11-03
and
unresolved
i tems
250,251/86-02-04,
250,251/85-40-01,
250,251/85-40-02,
250,251/85-40-34,
and 250,251/85-40-35.
EA 86-20, V.A.1
EA 86-20, V.A.2
EA 86-20, V.B.1
EA 86-20, V.B.2
EA 86-20, V.B.3.a
EA 86-20, V.B.3.b
closed
closed
closed
closed
closed
closed
(Closed)
EA 86-20,
V.A.l.: Licensee's
Failure to Incorporate
Vendor
Recommendations
for Compensating
Specific
Gravity
Readings, for
Temperature
and Level.
Inspection
Report
250,251/85-40
delineated
concerns
that
Plant
Operating
Procedure
(OP)
9604. 1,
D.C.
System - 'Periodic Tests
and
Maintenance,
did not provide adequate
instructions for compensating
specific gravity for temperature
and level.
Additionally, the
procedure
did not contain
acceptance
criteria for specific gravity
readings.
Procedure
OP 9604. 1 has
been cancelled
and
superseded
by
Procedure
O-SME-003.2,
approval
date
March 30,
1987,
125
VDC Station
Battery Monthly Maintenance.
O-SME-003.2 adequately
addresses
the
subject of compensating
specific gravity readings for temperature
and
level including acceptance criteria.
The
licensee
issued
On-The-Spot
Change
to procedure
4-0SP-201.3,
dated
May 28,
1987,
NPO Daily Logs to add instructional
guidance for
the
purpose
of calculating
the corrected
specific gravity values.
This calculation
provides
the
Nuclear
Plant Operator
(NPO) with
a
means
of properly verifying the specific gravity for the safety
related batteries
as required
by Technical Specification 4.8.2.b
and
interim Technical
Specification 3/4.8.2.l.a.
Additionally, the
licensee will conduct training to ensure
that the
aforementioned
calculations
are
performed correctly.
Based
on this information, the item is. closed.
This item also closes
part of violation 250,251/86-26-10.
(Closed)
EA 86-20, V.A.2.: Licensee
Failure to Adequately
Load Test
the Safety-Related
Station Batteries.
Inspection
Report
250,251/85-40
delineated
concerns
that
the
licensee's
testing of safety-related
station batteries
did not meet
the intent of specification
design
requirements
contained
in Plant
Change
Modification
83-05
(which
replaced
the
safety-related
batteries.)
Additionally, the testing
did not
meet
acceptance
criteria identified in section
8.2 of the
FSAR, which requires
the
batteries
to carry their expected
shutdown
loads, following a unit
trip and
loss of all
AC power for a period of approximately
one
hour, without battery terminal voltage falling below
105. volts D.C.
Procedure
O-SME-003.4,
dated
February 6,
1987,
125
VDC Station
Battery
Annual
Maintenance,
adequately
verifies that the safety-
related
station batteries
are
capable
of supplying
and maintaining
the actual
or simulated
emergency
loads for
a period of one hour.
The test
time criteria is in agreement
with the requirements
of the
FSAR.
A review of the
load profile specified
in .O-SME-003.4 to
simulate
emergency
loads
was not conducted
to determine
the accuracy
of the profile.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-10.
(Closed)
EA 86-20,
V.B. 1: Licensee's
Failure to Provide
Adequate
Documentation for the Justification of Continued
Operation with
a
Degraded Auxiliary Feedwater
(AFW) System.
EA 86-20,
V.B.1 documents
the licensee's
failure to provide adequate
documentation
for justification to allow operation without locating
missing
check
valve
parts
from the
degraded
AFW system.
The
licensee
has
revised Administrative Procedure
(AP) 0190.12.,
dated
February 24,
1987,
Nonconforming Materials,
Parts
or
Components
to
govern the scenario for a component of an existing operating
system
which is found to
be nonconforming.
If a nonconforming condition
exists,
a Plant Work Order
(PWO) shall
be issued,
and if an engineer-
ing specification is affected,
a Nonconformance
Report
(NCR) shall
be
issued.
Additionally, the revision requires
the guality Control
(gC)
department
to ensure
that appropriate
action is taken to resolve
the
NCR, including adding
gC hold points to the
PWO requiring
resolution prior to returning the component to operation.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-10.
(Closed)
EA 86-20,
V.B.2:
Failure to Establish
Measures
to Ensure
that Conditions
Adverse to guality and Nonconformances
are Promptly
Identified and Corrected.
Inspection
Report
250,251/85-40
delineated
concerns
pertaining
to
the licensee's
failure to adequately
control the design modification
process
for Plant Change Modification (PC/M) 80-77, Unit 3 Condensate
Storage
Tank Redundant
Level Alarms and
PC/M 80-71, Unit 4 Condensate
Storage
Level
Alarms and the various operating
procedures
resulting
from these
PCMs.
As
a result of these
concerns,
the licensee
has
revised Administrative Procedure
0190.15,
dated April 7, 1987, Plant
Changes
and Modifications, which should provide an increased
level of
control in the review, approval
and implementation of PC/Ms.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-10.
(Closed)
EA 86-20,
V.B.3.b:
Failure to Implement Procedures
which
Document Root Cause
Failures
on Safety-related
Equipment.
(Closed)
EA 86-20, V.B.3.a:
Failure to Implement Procedural
Require-
ments for Documentation of Post-maintenance
Testing.
Inspection
Report
85-40
delineated
concerns
pertaining
to
the
licensee's
failure to implement procedures
which call for documenta-
tion of root cause failures or to perform post-maintenance
testing.
In response
to these
concerns,
the licensee
has conducted
seminars
to
reiterate
to the maintenance staff the need for documenting
the root
cause
of a problem
on Plant
Work Orders
(PWOs).
The licensee
has
also
issued
Administrative Procedure
0190.28,
dated
May 29,
1987,
Post-maintenance
Testing,
which provides
guidelines for selecting
and
documenting
post-maintenance
testing
following completion of
maintenance
activities.
Review of completed
PWOs verified that the
maintenance
staff is performing post-maintenance
testing
and
docu-
menting root cause failures.
Based
on this information,
items
V.B.3.a
and
V.B.3.b are closed.
This item also closes part of violation 250,251/86-26-10.
Escalated
Enforcement
Action
(EA) 86-20, III:
Failure to Comply
With Technical Specification 3.8
and 3.4 Concerning,
Respectively,
System
and Safety Injection System Operability.
This
EA originated from violation 250,251/86-26-08,
which encompassed
previously identified violations 250,251/86-26-06
and 250,251/86-11-02
and unresolved
item 250,251/86-02-03.
EA 86-20, III.A
EA 86-20, III.B
closed
closed
(Closed)
EA 86-20, III.A:
Exceeding Limiting Condition for Operation
Due to Inadequate
Management
Controls in Properly Determining Opera-
bilityy
of the Auxiliary Feedwater
(AFW) System.
A nonconforming
condition with the auxiliary feedwater
pump steam
supply valves
was identified
on January
2,
1986
and
no action
was
taken until January 7,
1986.
Results of radiography
indicated that
the
steam
supply valves
had bent guide studs,
however,
no action
was
taken
which
led
to
an operability
concern, with the auxiliary
system.
To resolve
these
concerns,
the licensee
implemented
Plant
Change/
Modifications
(PC/M)86-009 for Unit 4
and
86-011 for Unit 3.
The
PC/Ms replaced
a
number of valves in the system beginning with the
motor operated
steam
supply valves.
These
were changed
from solid.
wedge gate
valves
to globe valves.
Solid wedge
gate valves tend to
Q
o
leak,
are susceptible
to seat
erosion
and,
therefore,
are not the
best
choice
for steam
service.
Globe
valves
are
designed
to
throttle,
are
less
susceptible
to seat
erosion
and, therefore,
are
better suited for steam applications.
Additionally, new tilting disk
have
been installed
both upstream
and downstream of the
motor
operated
steam
supply
valves.
The existing
downstream
stopcheck
valve has
been
completely
removed while the upstream
stop
check
has
been
replaced
with
a manually operated
The
stop
check valves previously used in the system
are subject to disc
flutter under
low flow conditions. Tilting disc
check
valves
are
better suited for steam applications
and, therefore,
should respond
better under low flow conditions.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-11.
(Closed)
EA-86-20,
111.B:
Vio1ation of Technical
Specification
Concerning
the Operability of a Safety Injection Pump.
A violation of Technical Specification 3.4. 1.4 occurred in that Unit
3 start-up
was conducted
with only three of the required four safety
injection
pumps operable.
The fourth pump was inoperable
due to the
discharge
valves
being closed.
The discharge
valves
had
been closed
during
a
previous
maintenance
effort.
When
- maintenance
was
completed,
the
pump
was
tested
for operability
by
a flow path
established
through
a recirculation line.
After the test,
the
pump
was
declared
however,
the
discharge
valves
were
never
opened.
The operability test did not address
verification of valve
line-up.
Also the required plant equipment clearance
review prior to
start-up
was
inadequate
in that it failed to identify the safety
injection
pump discharge
valves
as being closed.
The licensee
has
included into Administrative Procedure
(AP)0103.4,
In Plant
Clearance
Orders,
a
common
equipment
clearance
log in
conjunction with separate
clearance
logs for Unit 3
and Unit 4.
Previously,
common clearances
were maintained
under
the Unit 3 log.
This
new process
should help expedite
the review process
as well as
assist
in identifying equipment
maintained
under
a clearance
order.
The licensee
also places
Technical
Specification
and safety-related
equipment
in the
Equipment
Out of Service
Log along with the
clearance
number.
This requirement
is delineated
in step 5.3.3 of
AP-0103.4,
In Plant
Clearance
Orders
as
well
as
step
8.5.3 of
AP-0103.2,
Responsibilities
of Operators
and Shift Technicians
on
Shift and Maintenance of Operating
Logs and Records.
The inspector
also
reviewed
General
Operating
Procedure
(GOP)-503,
Cold
Shutdown
to
Hot Stand-by.
Within this
procedure
there
are
requirements
that both Clearance
and Equipment Out of Service
Logs
be
reviewed.
Specifically step 4.3 under Precautions
and Limitations
requires
a review of the Clearance
Logs
be performed to insure that
safety related
components
are not on
a clearance
order. Additionally,
step
3. 1.4.8 of the
same
operating
procedure
requires
that the
Equipment Out of Service
Log also
be reviewed.
Based
on this information, the item is closed.
This item also closes
part of violation 50-250,251/86-26-08.
(Closed)
EA 86-20,
VI:
Failure to Promptly Identify Conditions
Adverse
to guality With Respect
to
Component
Cooling Water
Flow
Through
Residual
Heat
Removal
Heat
Exchangers,
Single
Failure
Concerns of an Intake Cooling Water Control Valve, and Resolution of
Component Cooling Water Problems for Safety .Injection Pumps.
This
originated
from previously identified violations
250,251/86-26-01,
250,251/86-26-02,
and
250,251/86-26-03,
and
unresolved
items
250,251/86-10-03,
250,251/86-10-04,
and 86-18-03.
These
items were-
administratively closed since they were redundant
with this violation
and this violation was identified as 250,251/86-26-11.
EA 86-20, VI.A
closed
EA 86-20, VI.B
closed
EA 86-20, VI.C
closed
(Closed)
EA 86-20,-V1.A:
Failure to Promptly Identify and Correct
Conditions Adverse
To guality with Respect
to Component
Cooling Water
Flow through Residual
Heat Removal
Heat Exchangers.
Component cooling water
(CCW) flow through the residual
heat
removal
heat
exchangers
appeared
to
be below flow levels
assumed for in
the
accident analysis.
Component cooling water valves were subsequently
repositioned
from 30 to
100 percent
open.
The repositioning
was
completed with no evaluation
or testing
performed to determine
the
effects
on flow to other
components/systems
served
by component
cooling water system.
To fully address
the component cooling water system flow requirements
the
licensee
wrote
and
performed
two special
procedures.
These
special
procedures
were
used to balance
CCW flow.
Special
procedure
(SP)
86-11
was satisfactorily
completed
on Unit
4
on
May 11,
1986
as
noted
in Inspection
report 87-09,
under close
out of IFI
250,251/86-24-09.
Special
Procedure
(SP)
86-05
was also satisfac-
torily completed
on Unit
3
on March 18,
1986,
as
indicated
in
a
letter from the Office of Nuclear Reactor Regulation
(NRR), accepting
the test results
as valid.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-11.
(Closed)
EA 86-20,
Vl.B:
Single Failure
Concerns
of an Intake
Cooling Water Control Valve Failure.
Failure to take
prompt corrective action in evaluating
the safety
significance of a failure of an Intake Cooling Water
(ICW) valve to
close
on
a loss of power and/or it's control air supply resulting in
a
reduction
of
ICW flow to
the
component
cooling water
heat
exchangers.
To correctly identify and maintain adequate
ICW flow the licensee
has
made
changes
to the following procedures:
Off Normal
Operating
Procedure
(ONOP)
3408.1,
Intake Cooling
Water Malfunction
Step 5.2.1,
as listed under immediate operator actions,
requires
control valve CV-2201 to be isolated during
a design basis
event
concurrent with only one
ICW pump running.
This action assures
adequate
flow through the
component
cooling water heat exchang-
ers
by minimizing
ICW flow through
the turbine plant cooling
water heat exchangers.
3/4 EOP-E-0 Reactor Trip or Safety Injection
Step
10,
under the
response
not obtained
column with only one
ICW
pump
running,
requires
dispatching
personnel
to isolate
CV-2201 by closing the manual isolation valve.
This action will
have
the
same
end result
as listed previously under
Procedure
3408.1 Intake Cooling Water Malfunction.
3-0P-019,
Operating
Procedure
for the
Intake
Cooling Water
System
(ICW)
Attachment I,
page
6 of 10 requires
valve 3-50-406
CCW/ICW
bypass
around
Control
Valve
(CV) 2202 to be open.
CV-2202 is
then
shut
and
set
in the
automatic
mode for 110'F.
This
operational
line-up allows cooling flow to be maintained
through
the
component
cooling water
heat
exchanger
regardless
of the
posi tion of the control valve.
Based
on this information, the item is closed.
This item also closes
part of violation 250,251/86-26-11.
(Closed)
EA 86-20,
Vl.C:
Resolution of Component
Cooling Water
Safety Injection
Pump Cooling.
A piping error on Unit 4, Train A and Train
B component cooling water
(CCW) system
was identified by the licensee.
Procedural
controls in
place at the time excluded the use of Unit 4
CCW for safety injection
(SI)
pump cooling.
However, there were cases
noted while Unit 3 was
shut
down
and its component
cooling water system secured that Unit 4
CCW was
used to supply SI
pump cooling.
Because of the piping error,
this operational
line-up could have resulted
in the safety injection
pumps
being
due to insufficient cooling to the
pump
thrust bearings.
In response
to this, the licensee
completed
Plant
Change/Modification
(PC/M)83-008.
This
PC/M modified the piping
i
10
such that the flow reversal
and cross-train-connection
deficiencies
on Unit 4 have
been corrected.
Additionally, 3/4-0P-030,
Component
Cooling Mater System,
has
been
revised.
The procedure
requires
Uhit 3 to supply
CCM for SI
pump
cooling with Unit 4
shutdown.
Conversely,
with Unit 3
shutdown,
Unit 4
Based
on this information, the item is closed.
The item also closes
part of violation 50-250,251/86-26-11.
4.
Unresolved
Items
0
No unresolved
items were identified during this inspection.
5.
Licensee Action on Previous
Inspector Identified Items
a.
(Closed)
IFI
250/84-25-01/251/84-26-01:
Inspector
Concerns
Pertaining
to Non-shift Licensed Operators
Performing the Functions
of Licensed Operator
on
a quarterly Basis.
IFI 84-25/84-26 delineated
concerns
that non-shift licensed operators
may not
be performing'he
functions of licensed
operators.
The
inspectors
reviewed
the list of non-shift licensed operators
against
shift
compliment
logs
to determine
that
the non-shift
licensed
operators
were
performing
the functions of an operator
or senior
operator
as required
by 10 CFR 55.31(e).
Based
on this information, the item is closed.
b.
(Closed)
IFI 250,251/85-22-10:
Completion of Commitments
to Train
Licensed
Operators
on the
Loss of Inverters
and Associated
Vital
Buses.
During 1985 the licensee
experienced
a series
of inverter trips and
the loss of associated
vital buses.
The corrective actions for these
trips. included operator training
on mitigating the loss of inverters
and vital buses,
training
on the
change
over to
new auto-transfer
inverters,
and replacement
of the failing inverters.
The
new,
more
reliable inverters
were installed
and the inspector verified that the
committed training was provided to licensed
operators
as follows:
On-shift training
was
provided
to shift licensed
personnel
between
June
28 and July 18,
1985.
Training was provided
as
an
interim corrective
measure
to ensure that operators
were
aware
of what
equipment
would
be lost with
each
inverter
and
associated
vital
bus
and
how to mitigate
the
resultant
The
inspector
verified that all licensed shift
personnel
completed this training.
11
The 1985-86 Licensed Operator Requalification Training, Cycle 4,
provided
a class
on the replacement
of the
120 volt AC inverters
and
the
operation
of the
new inverters.
Replacement
of the
inverters
was
completed
under Plant Change/Modification
(PC/M)83-117.
The
inspectors
reviewed
the
lesson
plans
associated
with this training
and
concluded
that the training appeared
adequate
to support the inverter change
over and operation.
The licensee
issued
several
Training Briefs associated
with both
the
loss
of
AC inverters
and
the installation of the
new
inverters in 1985.
The inspector
reviewed these training briefs
and
associated
attendance
lists," and this training
appeared
adequate
to meet the intended functions.
Based
on this information, the item is closed.
(Closed)
UNR 250,251/85-40-13:
Failure to Meet Commitment to Install
Adequate
DC Lighting to Support
Local
AFW Operations
During Shutdown
From Outside the Control
Room.
The licensee
had committed in 1981 to install adequate
DC lighting to
support
necessary
local Auxiliary Feedwater
(AFW) operations
during
periods
of control
room inaccessibility
'and
a loss of normal
lighting.
During
a walkthrough of the Control
Room Inaccessibility
Procedure,
ONOP-103,
in 1985, it was determined that the installed
lighting
was
inadequate
to
meet
this
previous
commitment.
In
response
to this deficiency,
the licensee installed
22 additional
lights in the
AFW and nitrogen addition locations
in 1985.
These
additional
lights
were installed
under
Plant
Change/Modifications
(Unit 3)
and 85-178 (Unit 4), Addition of Component
Lighting for
AFW System;
PCM 85-170, Install Unit 3
AFW Valve Access
Platform;
and
PCM 85-175, Nitrogen Station Additions and relocations.
A review of this additional
DC lighting by the inspector
and
a second
walkthrough
of
the
control
room inaccessibility
procedure
on
February 4,
1987,
indicated
that
the
additional
lighting
was
adequate.
Based
on this information, the item is closed.
(Closed)
IFI 250,251/85-40-16:
High
Radiation
Levels
in the
(AFW) Pump Area Following a
LOCA on Unit 3.
The licensee's
Post Accident Zone
Map indicated potential
very high
radiation levels in the
AFW area following a
LOCA on Unit 3 due to
shine
from the
personnel
hatch.
In the
event
an operator
was
required
to perform local
AFW operations
for Unit 4 during this
period,
excessive
radiation
exposure
could occur.
The licensee
has
revised
Off-Normal Operating
Procedure
7308.1,
Malfunction of the
System,
to contain
a "caution" regarding this
potential.
The
caution
statement
requires
that
Health
Physics
12
coverage
shall
be obtained prior to entering the
AFW area
during
a
LOCA on Unit 3.
Based
on this information, the item is closed.
(Closed)
UNR 250,251/85-40-25:
'Inspector
Concerns
Pertaining
to
Tubing Sections
of the Nitrogen
Backup to the Auxiliary Feedwater
(AFW) System Being Inadequately
Supported;
UNR 85-40-25 delineated
concerns that portions of the nitrogen backup
to
the
auxiliary
supply
system
instrument air
were
inadequately
supported
as specified
by the licensees
specification
No.
5177-J711,
Rev. 2,
Design
Guide for Seismic
Class
I Instrument
Tubing Installation.
As
a result of these
concerns,
the licensee
contracted
with Bechtel
to perform
system
walkdowns
according
to
procedure
5177-499-G-001,
Rev. 2, Procedure for the Walkdown of Small
Piping
and
Instrumentation
Tubing.
This
walkdown determined
the
backup
system
to
be
Non-Conformance
Reports
(NCRs), including NCR-614-86
and 961-86,
were generated
to document
and
accept-as-is
or correct
the
existing field discrepancies.
Additionally, Plant
Change/Modification
(PC/M)85-175
and
85-176,
Station
Additions
and
Relocations,
were initiated
to
relocate
the existing backup nitrogen bottle station for AFW control
valve instrument air and
add
new bottle stations for Units
3 and 4.
The
inspector
performed
a field survey to obtain
general
system
layout and confirm adequate
tubing support.
No discrepant
conditions
were observed.
Based
on this information, the item is closed.
(Closed)
IFI 250,251/85-40-28:
Review the
New Maintenance
Training
and the gualification Tracking System.
IFI 85-40-28 identified that the Maintenance
Department did not have
qualification cards
or on-the-job
(OJT) records
to ensure
that only
qualified personnel
were assigned
to perform tasks.
At present,
the
Maintenance
Department
is in the process
of completing task
sheets
for each
employee.
These
task sheets will be completed
(signed-off)
as
a result of either classroom training,
OJT performance
as judged
by a certified OJT observer,
or incumbent qualification based
on past
job
performance.
The
end result
is that
each
employee will be
identified as to which tasks that employee is presently qualified to
perform.
That
information will be
as
loaded
into the Training
Information Management
System
(TRIMS) computer.
All maintenance
task
sheets
are scheduled
to be completed
by July 31, 1987.
Although no time table
has
been established,
the licensee
intends to
interface
the
TRIMS computer with the Nuclear
Job Planning
System
(NJPS),
which is used
to track Plant
Work Orders
(PWO).
Such
an
interface
would permit identification on each
PWO of those
personnel
qualified to perform that particular task.
In the interim period,
a
13
manual
system will be
used
to track personnel
task qualifications.
Interviews with maintenance
supervision
indicated that plans for a
manual
system
have not been finalized, but a conscientious effort is
being made to institute
a workable system.
Concerning
maintenance
training,
the
licensee
began
a
formal
maintenance
training cycle in January,
1986.
The licensee
committed
to continuously
cycle
at least
12
percent
of 'the
mechanical,
electrical,
and
I8C personnel
through this training.
This should
result
in
a maintenance
individual receiving
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training
every
8 weeks or about
200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> annually.
Finally, the Training Department is scheduled
in September,
1987 to
submit
the
completed
Job
Task Analysis
Package
for Mechanical,
Electrical
and
ISC Maintenance
Departments
to
INPO for accreditation
of the Maintenance Training Program.
Based
on this information, the item is closed.
(Open)
UNR 250,251/85-40-29:
Review of Licensee's
Thermal
Overload
Size for Valve Operators
Inspection
Report
250,251/85-40
delineated
a
concern
over
the
apparent
difference
between
the manufacturer's
recommended
thermal
overload
size
and
the
size
chosen
by the
licensee
to satisfy
Regulatory
Guide 1.106.
Conversations
with licensee
personnel
indicated
that
they
are
developing
a
program
to review and, if necessary,
change
heater
sizes.
This
program
is
encompassing
a
review of applicable
Regulatory
Guides,
manufacturer's
data,
etc.,
and
is
not yet
complete.
Based
on this information, the item will remain
open until
the licensee's
review is complete.
(Closed)
UNR 250,251/85-40-30:
Insufficient Test Data
and Review of
Manufacturers
Calculations to Insure the Operability of (MOVs) 3-1403
and 4-1403
Steam Supply to the Auxiliary Feedwater
Pump.
'nspection
Report
85-40 delineated
a concern
over the'ccuracy
of
calculations
used
to derive the voltage. drop to
DC Motor Operated
Valves
(MOVs) 3-1403
and 4-1403.
The portion of the calculation in
question
was the current value.
The licensee's
calculation utilized
full load current
(8 amps),
wherein
the manufacturer
recommended
using the starting current value (53 amps).
Conversations
with licensee
personnel
indicate
new calculations
have
been
completed.
The values
used
in the calculation
were
53
amps
(starting current)
and
111 volts
DC.
This calculation
revealed
a
voltage available
to
MOVs 3-1403
and 4-1403 of greater
than
90 volts
DC which is within the manufacturer's
requirements.
14
Based
on this information, the item is closed.
(Closed)
UNR 250,251/85-40-33:
Review Apparent Conflict Between
Technical Specification 4.8.2.b
and Vendor Recommendations
UNR 85-40-33
delineated
concerns
that
the Technical Specification 4.8.2.b,
which requires
the licensee
to perform a monthly equalizing
charge
on the safety-related
batteries,
was in conflict with the
recommendations
contained within Gould-GNB maintenance
manual.
A
review of the telephone
conference
memorandum
dated January
10, 1986,
between
representatives
of Gould
and
the
licensee
indicate that
monthly equalizing
charges will only minimally shorten
the expected
battery life. It should
be noted'hat
the licensee
has
submitted
by
letter dated
November 28,
1986, to the
NRC a Technical Specification
change to provide for an as-needed
equalizing charge.
Based
on this information, the item is closed.
(Open) 250,251/85-40-38:
Determine
Adequacy of Licensee's
Fail Safe
Testing for Auxiliary Feedwater
Flow (AFW) Control Valves
Inspection
Report 250/85-40 delineated
a concern over the licensee's
present
means
of fail safe testing for the
AFW system flow control
valves.
Present
means of testing is for the valves to be driven open
and then closed,
using the control switch.
The licensee
states
that
by using the control switch, the air supply to the valve is isolated
and, thereby, satisfies
the requirements
of ASME XI-IWV-3415.
Pending further review of this item in the
NRC Region II office, this
item will remain open.
(Closed)
UNR 250,251/86-18-01:
Lack of Documentation
to Indicate
Formal Operability Evaluation
(Closed)
IFI 250,251/86-18-02:
Lack of Adequate Criteria for
a
Safety Evaluation Determination
UNR 86-18-01
delineated
concerns
that the licensee's
operability
evaluation
should
be formally documented
with the bases
for those
results.
Additionally,
a
mechanism
should
be in place to notify
plant, management
of the significance of evaluations
which may effect
plant operability.
IFI
86-18-02
delineated
concerns
that
the
licensee
had
not
established
adequate criteria to determine
a need to perform
a safety
evaluation.
Review of Open
Item Review Sheets for the Select
System
Assessment
Program
noted the addition of extensive
comments
in the Engineering
Evaluation section which elaborated
on the
need to perform
a safety
evaluation
or justification for not performing
these
evaluations.
e
15
Additionally, concerns
pertaining
to the lack of formal procedures
and
documentation
in the
Phase
1 systems
review process
led to the
developement
of the following procedures:
PTN-EP 5.2,
Rev. 0,
Comprehensive
System
Review
SEG
Phase II,
which identifies
the
actions
to
be
taken
by the
Safety
Engineering
Group
members
during their special
comprehensive
review of the Select
Systems.
PTN-EP 3.2,
Rev. 0, Control of the Integrated
Tasks
Punchlist
for Select
Systems
PTN 3
5 4., which governs
the implementation
and maintenance
of the Integrated
Tracking System,
including the
criteria
which shall
be
met for items
to
be
added
to the
.punchlist.
PTN-EP
3.1,
Rev. 0,
Preliminary
Engineering
Assessment
of
Reportability,
which establishes
the
requirements
for the
engineering
review
and
evaluation
of
items
identified
by
Requests
for Technical
Assistance.
These evaluations
shall
be
performed to determine
the potential
safety significance of all
open items, to establish
the priority for resolution of the open
items, to identify the
need for a detailed
safety assessment
by
Engineering
and to identify a plan of action for close
out of
- the items.
Additional
engineering
procedures
were
developed
to
govern
engineering
safety
assessments,
initial engineering
assessments
of
operability and the processing of requests for technical
assistance.
Based
on
the
above
information,
items
250,251/86-18-01
and
250,251/86-18-02
are closed.
1.
(Closed)
IFI 250,251/86-18-05:
Need
to
Develop
and
Implement
Corrective Action Program for Motor Operated
Valves
(MOVs)
IFI 86-18-05 delineated
concerns
pertaining to the licensee's
need
'to
complete
and
implement
a
work plan to correct
MOV problems.
Specifically, the
MOV's addressed
were MOV-3-750 and 3-751, Residual
Heat
Removal
(RHR) isolation valves.
The work plan
was required to
adjust the
open
bypass
switches
to prevent inadvertent
trip during valve unseating.
The licensee
has
in place,
Plant
Change/Mofification
(PC/M)
Packages86-168
and
86-169.
These
packages
were developed
by the licensee's
Engineering
Department
and
Plant Nuclear Safety Cormittee
(PNSC)
approved
on February
19, 1987.
During the recent refueling outage,
PC/M 86-168
was
completed
on
Unit 3 while PC/M 86-169 is scheduled for completion
on Unit 4 during
the next refueling outage.
This item will be tracked
by the'esident
inspectors.
Based
on this information, the item is closed.
16
(Closed) IFI 250,251/86-18-09:
Control Over Plant Scaffolding.
The licensee
had not maintained
adequate
controls over erection
and
dismantling of plant scaffolding.
This lack of control resulted in
numerous
problems
including erection
over redundant
components
of
safety-related
systems,
interference with valves
and instrumentation,
attachment
to safety-related
components
and conduit,
interference
with emergency
operations
and access,
and the failure to promptly
remove the scaffolding
when related
work was completed.
In addition
the
control
of scaffolding
erected
by plant
personnel
differed
significantly from the
control
over scaffolding
erected
by the
Construction
Organization.
The
licensee
has
made
significant
improvements
in the controls over plant scaffolding.
Administrative
Procedure
O-ADM-012, Scaffold
Control,
and
Plant
Construction
Administrative Procedure
ASP-29, Control of Construction Scaffolding,
have
been
revised
and
upgraded
to provide
these
added
controls.
These
procedures
insure that plant
and construction
scaffolding are
carefully planned
and
coordinated
with the Operations/Maintenance
Coordinator or Nuclear Watch Engineer,
and that scaffolding:
- is fire retardant
- does
not block equipment or component
access
- does not hinder equipment or component operation
- is not attached
to components,
equipment,
piping, conduit, or
security barriers
- does not create conditions where personnel
working in the area
would cause
unwanted activation of valves or switches
- does not interfere with area lighting
- is removed within 14 days of work completion
All scaffolding is provided with control
number
and identification
tag
and is inspected
on
a monthly basis to ensure
compliance.
Based
on this information, the item is closed.
(Closed)
IFI 250,251/86-18-10:
Configuration Control
Concerns
Over
the Procedural
Requirement
of Valve Lineup Versus the'ctual
Field
Position.
IFI 250,251/86-18-10
delineated
concerns
pertaining to discrepancies
between
actual
valve position
and the operational
line-up required
by
3/4-0P-68,
Containment
Spray
System,
Administrative Procedure
(AP)
0103.5,
and the system
drawing for valves
942V and
942W, containment
spray
pumps
3A, 3B,
4A and
4B discharge
header drains.
The inspector
reviewed 3/4-0P-68,
Containment
Spray
System for the above mentioned
valves
and
compared
the procedurally required position against
the
system
drawing
5610-T-E-4510,
revision
71.
No discrepancies
were
noted.
Since the original inspection,
AP-0103.5
has
been cancelled
and
superseded
by O-ADM-205, Administrative Control of Valves,
Locks
and Switches.
0-ADM-205 was reviewed for the above mentioned
valves
17
and
compared
against
both
the
system
drawing
and 3/4-0P-68,
once
again
no discrepancies
were noted.
Based
on this information, the item is closed.
(Open)
UNR 250,251/86-18-13:
Lack of Procedures
for Loss of
Power.
UNR 86-18-13
delineated
the licensee's
lack of procedures
for the
loss of DC power.
The licensee
is developing
an interim procedure to
be
used
in the event
a
125v vital
Bus is lost
due to battery
charger failure and
a subsequent
battery failure.
For the long term,
a procedure will be developed,
following completion of a Request for
Engineering
Assistance
(REA), which will direct operators
how to
respond
to loss of indication
and control following a loss of DC.
The
REA associated
with this procedure
should
be expedited
due to
lessons
learned
from loss of
DC at other facilities.
The licensee
has
projected
a completion
date of September
15,
1987 for these
procedures.
This item will remain
open pending completion of these
procedures.
(Closed)
UNR 250,251/86-19-03:
Failure to Provide Requalification
Exams Within Required
Time Period
UNR 250,251/86-19-03
delineated
the licensee's
failure to provide
a
requalification
exam retest within 60 days of the previous
examina-
tion date
as required
by Administrative Procedure
(AP) 0301 Licensed
Operator Requalification
Program.
The Training Superintendent
issued
a policy statement
on
May 19,
1986,
regarding
the
examination
process.
That policy statement
set forth definitive retest
time
restrictions
and directed actions
to be taken if a licensed operator
failed
a requalification
examination.
AP-0301
was
subsequently
revised
and upgraded
on February
19,
1987.
Based
on this information, the'item is closed.
(Closed)
IFI 250,251/86-24-01:
Inspector
Concerns
Pertaining to Post
Accident Sampling
System
(PASS) Calibrations
IFI 86-24-01 delineated
concerns
that the licensee
had not performed
the required calibrations for the
PASS inputs for the nuclear
data
computer
channels.
The
licensee's
Preventive
Maintenance
(PM)
program established
the following PMs for the
PASS:
-PM-94005,
PASS Dissolved
Oxygen Analyzer
-PM-94006,
PASS Liquid pH Analyzer
-PM-94007,
-PM-94008,
PASS Sample
Pressure
18
-PM-94009,
Gas
and Liquid Flow Monitor Calibration
-PM-94010,
PASS Inlet and Cooled
Sample Temperature
Monitor
Calibration
The aforementioned
PMs were completed to satisfy the concerns of IFI
250,251/86-24-01.
The aforementioned
PMs are currently overdue
as
a
result of the current refueling outage
instrumentation
calibration
back'log.
The hydrogen analyzer
and the gas
and liquid flow monitors
are currently the subject of Plant
Change Modification (PC/M) 84-70,
Post Accident Sampling System
Long Term Modifications.
The intent of
this
PC/M is to enhance
PASS operation
and to provide
a higher
on-line reliability factor.
Upon completion of the
PC/M,
and
PM-94009 will
be
revised
- to reflect
the
new
instrumentation
calibration
requirements
and all
PASS calibrations
will be performed.
Based
on this information, the item is closed.
(Closed)
UNR 250,251/86-46-02:
Tracking of Corrective Actions to
Findings of Licensee
Internal Training Assessment.
UNR 86-46-02
delineated
concerns
pertaining
to
the
licensee's
findings during
an internal training assessment.
In 1986,
a
team
consisting of representatives
from the licensees'orporate
Staff,
Training Staff,
and guality Assurance
Department,
conducted
an
assessment
of the Turkey Point Training Program.
The assessment
was
conducted
against
the requirements
of the
NRC, gA, and
INPO.
This
internal training assessment
identified
165 deficiencies
related to
the
above criteria.
Each of these
specific
deficiencies
was
identified as
an action item under
a corrective action
program.
At
the time of this closeout
inspection,
the licensee
had completed the
corrective
actions for in excess
of 140 of the
165 action items.
The
remaining
items to
be completed
were primarily enhancements
to the
training program or related to standardization
between
the licensee's
two nuclear facilities.
In addition, the inspector verified that the
48
items
identified
by the
licensee
as
being
related
to
NRC
requirements
had
been
completed.
The
adequacy
of the corrective
action
has
been
reviewed
by
the
licensee's
guality Assurance
Department.
Based
on this information, the item is closed.
(Closed)
IFI 250,251/87-07-01:
Resolution of Training Records
and
Files
Involving
the
Recertification
of guality
Control
(gC)
Inspectors.
IFI 87-07-01
delineated
concerns
pertaining
to the
licensee's
inadequate
maintenance
of records
and documentation for the periodic
recertification of gC inspectors.
The licensee's
corrective actions
involve the utilization of Enclosure
2 to Administrative Procedure
O-ADM-971, Certification of guality Control Inspectors,
to document
19
the recertification
of
gC inspectors.
Recertification will be
documented
under
the
"Basis for Certification" section
of this
enclosure,
by indicating "continued acceptable
performance
during the
reporting period".
This
method of recertification
appears
to be
adequate
providing that the period of acceptable
performance
was in
the
same inspection
area
as the recertification.
Based
on this information, the item is closed
t.
(Closed)
UNR 250,251/87-07-02:
Implementation of Revised
Required
Reading
Program
and Resolution of Outstanding
Required
Reading Items.
UNR 87-07-02 delineated
concerns
pertaining to the licensee's
revised
required
reading
program
and resolution of the backlog of required
reading
items.
Item I.C.5, requires that operational
experience
feedback
information
be provided to operations
personnel
on
a regular basis,
and that this information be screened
to prevent
obscuring priority information.
This item was
opened
because
the
licensee
was not screening this information and the large
volume of
information being
provided
appeared
to be contributing to untimely
and
inadequate
reviews
by operations
personnel.
The licensee's
corrective actions to this item have included:
Establishment
of
a
revised
operational
experience
feedback
program
by the Training Department.
This program requires
the
Training Staff to screen this information including the numerous
procedure revisions resulting from the Procedure
Upgrade
Program
(PUP),
to. ensure
only relevant
information is forwarded to
operators.
The inspectors
reviewed this process
and noted that
the volume of material
had decreased
significantly.
Upgrading
procedural
controls
over
the
documentation
and
timeliness
of operational
experience
feedback
reviews.
The
Training
Report
Cover
Letter
included
in the
procedures
controlling licensed
operator,
non-licensed
operator
and Shift
Technical
Advisor (STA) training requires that each individual
review the material
and sign the cover letter within 13 weeks of
issuance.
In addition,
the
procedures
prohibit an individual
from assuming shift responsibilities if he or she is greater
than
13 weeks behind
on this required reading.
Removal of the backlog of required reading that had accumulated
in the control
room under
the
previous
program.
This large
volume of backlog
information is in the
process
of being
screened
by the Training Staff.
Safety-related
and relevant
information contained
in this
backlog
is
being
provided to
operators
under
the
revised
program and/or
incorporated
into
requalification training.
Based
on this information, the item is closed.
20
Although
the
licensee's
corrective
actions
to
the
programmatic
controls
over
operation
experience
feedback
training
appeared
adequate
to close
the
open
item above,
the implementation of this
training
was
determined
to be
inadequate.
The licensee
implements
the
requirements
of
Item I.C.5
through
a
revised
operational
experience
feedback
required
reading
program.
The
procedures
which
implement this
program; Administrative
Procedure
(AP) 031,
Licensed
Operator
Requalification
Program,
and
AP 0303,
Non-Licensed
Operator Initial Training
and Requalification
Program,
require that all licensed
and nonlicensed
operators
shall
review and
acknowledge
this material within 13
weeks of distribution.
These
procedures
further require that
a licensed
or nonlicensed
operator
who is greater
than the
13 weeks
delinquent shall
not
assume unit
responsibility.
Additionally, Operations
Surveillance
Procedure
200.1,
Schedule of Plant Checks
and Survei llances,
requires
the Plant
Supervisor - Nuclear
(PS-N) to ensure all shift personnel
training
reports
(operational
experience
feedback)
are
up-to-date
on
each
8-hour shift.
Contr ary to the
above,
the inspectors
determined
on June 7,
1987,
that four licensed
operators
had failed to review and
acknowledge
material
dated
March 24
and
March 27,
1987;
greater
than
a 13-week
period.
These
licensed
operators
had
been
permitted to assume unit
responsibilities,
and at the time of the inspection
two were assigned
to the
day shift and
two to the night shift.
In addition,
a large
numbei
of non-licensed
operators
were greater
than
13 weeks delin-
quent
on
one or more training reports
dating
back to January
1987.
These
non-licensed
operators,
including two who had not reviewed
any
of the material
since January,
had also
been permitted to assume unit
responsibilities.
The inspectors
notified the licensee
that they
were
in continuing
noncompliance
with their approved
procedures
covering operational
experience
feedback.
In response,
the licensee
provided training
and
ensured
that all
licensed
and
nonlicensed
operators
were within the
13-week
review period prior to assuming
unit responsibility.
Subsequently,
the inspectors
determined that the licensee's
guality
Assurance
(gA) Department
had issued
a finding in this
same area.
On
June
23,
1987,
gA issued
Corrective Action Request
Operator
Review of Training Reports,
Repeat
Noncompliance.
This is
listed
as
a repeat
noncompliance
because
there
were two previous
gA
findings in the
same area.
dated
December
10, 1986, also
cited that licensed
and nonlicensed
operators
were in noncompliance
with procedures
in that
they were
assuming
unit responsibilities
while greater
than
13 weeks delinquent
on Training Reports.
Manage-
ment's
response
to the
CAR, as detailed in PEN-PMN 87-027, indicated
that the Night Order
Book would
be utilized to reemphasize
to the
PS-Ns
to
ensure
licensed
and
nonlicensed
operators
comply with
procedures
and time limits on Training Reports.
I'n addition, it was
21
indicated
that discussions
were
underway with
PUP to
reduce
the
volume of required reading.
gA determined this management
response
to
be
inadequate,
as
detailed
in
for the following
reasons:
No scheduled
completion date
was assigned.
The
deficiencies
regarding
nonlicensed
operators
were
not
addres'sed.
Both licensed
and nonlicensed
operators
continue to assume unit
responsibility without reviewing training reports
as required
by
procedures.
Management's
response
to
CAR 86-783 indicated that all training was
completed
by January
23,
1987.
In addition,
two corrective actions
were identified including
(1)
the
streamlining
of the training
reports
by the Training Department,
and
(2) increased
awareness
as
implemented
by the Operations
Department.
During
an inspection
in February
1987,
(250,251/87-07),
inspectors
noted that the licensee
had not implemented this proposed
screening
process
for Training Reports,
and
= that
due to the large
volume,
operators
continued
to
be delinquent
in reviews.
In response
to
Unresolved
Item 87-07-02,
the
licensee
implemented
this
proposal
screening
process
which
reduced
the
volume of required
reading
considerably.
Despite
the
previous
gA and
NRC findings,
and
the
revision to the program,
CAR 87-028 noted
on June 23,
1987, that both
licensed
and non-licensed
operators
were in nonconformance
with the
procedures
in assuming
unit responsibility while greater
than
13
weeks
delinquent.
This
CAR again specifically requested
management
not to allow the
delinquent
operators
to
assume
responsibility.
Despite this request,
the inspectors
determined
on July 7, 1987, that
both licensed
and nonlicensed
operators
who were more than
13 weeks
delinquent
on Training
Reports
were
continuing
to
assume
unit
responsibility.
10 CFR 50 Appendix
B Criterion
XVI requires
that
identified deficiencies
be
promptly corrected.
This failure to
adequately
implement the requirements
of
NUREG 0737 Item I.C.5, to
implement
approved
procedures
and to take
prompt corrective action
will be
a violation (250, 251/87-32-01).
(Open)
IFI
250,251/87-07-03:
Generation
of Electrical
Breaker
Setpoint
Document.
IFI
87-07-03
delineated
concerns
pertaining
to the
licensee's
generation
of an Electrical
Breaker Setpoint
document.
The Request
for Engineering
Assessment
(REA) is
scheduled
for February
5
August 8,
1988.
Pending
completion of the
REA
and
subsequent
Setpoint
Document development,
this will remain
an open item.
22
(Closed)
UNR 250,251/87-09-01.
Excessive
Overtime
By Operations
Personnel.
UNR 87-09-01
delineated
concerns
pertaining to excessive
overtime
by operations
personnel.
This
item is administratively closed.
Corrective
action
to
be
tracked
under
Notice
of Violation,
250,251/87-24-01
dated
June 30, 1987.
(Closed)
250,251/87-09-02:
Utilization
of.
Nonqualified
Instructors to Teach
Systems
and Integrated Plant Response.
UNR 87-09-02 delineated
concerns
pertaining to the licensees
use of
nonqualified
instructors
to
teach
systems
and
integrated
plant
response.
items I.A.I.2
and I.A.2.3, requires
that
instructors
who
teach
systems,
integrated
plant
response,
or
simulator to licensed
individuals,
demonstrate
their proficiency
through
successful
completion of
an Senior Reactor
Operator
(SRO)
level examination.
Primarily due to a high failure rate of licensed
instructors
on
NRC requalification
examinations,
the
licensee
had
experienced
a shortage
of qualified licensed
operator instructors.
As
a result,
the licensee
had,
on occasion,
utilized instructors
to
teach
the areas
referenced
above
who had failed
NRC requalification
examinations,
who were
non-licensed,
and contract instructors
who
were not certified to teach
these
areas
or who had not received
any
site specific training.
The
licensee
has
taken
the
following
corrective actions:
r
Prohibited
SRO licensed instructors
who have failed
NRC requali-
fication examinations
from teaching
licensed
operators until,
they successfully
complete
on
NRC examination.
Eliminated contract instructors
who were not commercially
licensed
from the licensed operator
and licensed requalification
training programs.
Contracted
an'dditional
15 instructors,
all of
whom
were
previously
SRO licensed
on commercial facilities.
Implemented
a five week site specific
systems
training course
for contract
instructors.
The
inspector
reviewed
a matrix
designed
to ensure that contract instructors
complete
each area-
of training,
and that they are not utilized to teach
a system or
area prior to receiving the training.
This matrix appeared
to
provide
adequate
interim controls
over contract
instructors
until procedures
can
be developed
and implemented.
Based
on this information, the item is closed.