ML18004B793

From kanterella
Jump to navigation Jump to search
Insp Rept 50-400/87-04 on 870105-09.Violations Noted:Failure to Follow Procedure in Processing of Clearance & Control of Sys Alignment
ML18004B793
Person / Time
Site: Harris 
Issue date: 04/06/1987
From: Mccoy F, Shymlock M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18004B791 List:
References
50-400-87-04, 50-400-87-4, NUDOCS 8704290144
Download: ML18004B793 (27)


See also: IR 05000400/1987004

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50-400/87-04

Licensee:

Carolina

Power and Light Company

P.

0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

Facility Name:

Shearon Harris

Inspection

Conducted:

January 5-9,

1987

Inspector:

c oy

License No.:

NPF-53

f- (- 8"7

ate

cygne

Team Members:

S.

D. Stadler

C.

A. Casto

C.

L. Vanderniet

H. 0. Christensen

Approved by:

ym oc

,

ie

'perational

Programs

Section

Division of Reactor Safety

ate

igne

SUMMARY

Scope:

This routine,

announced

inspection

was

conducted

in the

area

of

operational

readiness.

This

inspection

was

a followup to

an

inspection

conducted

September

22-26,

1986,

documented

in

(Inspection

Report

No.

50-400/86-76).

Results:

One violation was identified, the failure to follow procedure

in the

processing

of a clearance

and the control of system alignment.

This violation

is discussed

in Section

6.

No deviations

were identified.

8704290144

870421

PDa

aDCICV. 0S000400

8

0

The following unresolved

items

(URI) and inspector

followup items (IFI) from

Inspection

Report

No. 50-400/86-76

were reviewed:

NUMBER

TYPE

400/86-76-01

IFI

400/86-76-03

IFI

400/86-76-05

IFI

400/86-76-06

IFI

400/86-76-07

IFI

400/86-76-08

IFI

400/86-76-10

IFI

400/86-76-11

IFI

440/86-76-12

IFI

400/86-76-13

IFI

400/86-76-14

URI

STATUS

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

Closed

DESCRIPTION/REFERENCE

PARAGRAPH

Technical

Upgrade

and

Revision

of the

Emergency Operating

Procedure

(EOP) Network,

Setpoint Study,

and Step Deviation Documents

(paragraph

S.a).

EOP

Training

for

Operations

Personnel

(paragraph

5.b).

Instrument

and Valve Numbers for Auxiliary

Feedwater

(AFW)

System

Missing

from

Procedure

OP-137 (paragraph

5,c).

Resolve

Potential

of Trapped Air in the

AFW/Emergency

Service

Crossover

Lines

(paragraph

5. d).

Commitment to Provide Open/Closed

Indication

on Safety Related

Dampers

(paragraph 5.e).

Resolution of Concerns

Associated

with Air

Supplies

to

Safety

Related

Dampers

(paragraph 5.f).

Independent

Verification of the Opening of

Accumulator

Discharge

Valves

and

Breaker

Racking Out (paragraph

5..g).

Review

Adequacy

of Abnormal,

Annunciator,

and

Operations

Work

Procedures

and

Resolution of Associated

Inspector

Concerns

(paragraph

5.h).

Resolution

of Deficiencies

Associated with

Surveillance

Procedures

(paragraph 5.i).

Resolution of Concerns

Associated with

Stroke Times for Containment

Spray and Purge

Valves (paragraph 5.j).

Inadequate

Substitution

of

RHR

Pump

Preoperational

Test

for

Technical

Specification Surveillance

Test

Requirement

4.5.2.h.2

(paragraph

3).

400/86-76-15

IFI

400/86-76-16

URI

400/86-76-20

IFI

Closed

Closed

Closed

Commitment

to

Evaluate

Surveillance

Requirements

Which

Were

Baselined

with

Pre-Operational

Test Data (paragraph

5. k).

Failure

to

Temperature

Compensate

for

Indicated

Flow During

RHR

Pump

Inservice

Testing (paragraph

3).

Inadequacies

of

PNSC

Review

Involving

Unreviewed

Safety questions

Associated with

AFW High Point Vents (paragraph

5. 1).

The following new items associated

with Inspection

Report

No. 50-400/87-04

were

opened:

NUMBER

TYPE

STATUS

DESCRIPTION/REFERENCE

PARAGRAPH

400/87-04-01

IFI

400/87-04-03

IFI

400/87-04-04

IFI

400/87-04-05

IFI

400/87-04-06

IFI

Open

Open

Open

Open

Open

Open

License

Commitments

to Complete Revision of

EOP Setpoint Study and the Cross-Referencing

of EOP Flow Paths to Associated

Path Guides.

IFI 400/87-04-01

is

related

to

IFI

400/86-76-01

which'as

closed

(paragraph 5.a).,

Provisions

for Operators

or Non-Licensed

Operators to Reset Tripped Diesel Generator.

(paragraph

5.b).

The Licensee's

Commitment to Evaluate

Need

for Additional

EOP Training in the Classroom

the

Plant,

and

the

Simulator

and

Implementation

of

Identified

Training.

IFI 400/87-04-03

is

related

to

IFI

400/86-76-03

which

was

closed

(paragraph

5. b).

Commitment to Resolve Additional

EOP Related

Deficiencies

Identified

During Additional

EOP Training (paragraph

S.b).

Completion of Providing Valve Numbers for

the

Instrument Air System

and Revision of

Effected

Procedures.

IFI 400/87-06-04

is

related to IFI 400/86-76-05

which was closed

(paragraph 5.c).

-Commitment

to

Increase

Administrative

Controls

Over the Required

Reading

Program

(paragraph 6.e.).

400/87-04-07

IFI

400/87-04"08

IFI

400/87-04-09

VIO

400/87-04-10

IFI

Open

Open

Open

Open

Commitment

to

Upgrade

Controls

Over

the

Process

Mhich Allowed A Cancelled

Emergency

Procedure

and

Flow Guides to

Remain in the

Control

Room

During Cancellation

Process

(paragraph 6.f).

Resolution

of

Concerns

Involving

Identification of Controllers in the Control

Room

with

No

Control

Power

Potential

Indicating Lights During Normal Operations

(paragraph

6.g).

Deficiency in Configuration

Control

As

A

Result

of De-energized

Breaker

Associated

Mith Steam

Dump Control (paragraph

6.h).

Further

Evaluation

of

Relocation/

Identification of Control

Board SI Switch

Associated

with

December ll, 1986

Safety

Injection Event (paragraph

7).

REPORT DETAILS

Persons

Contacted

Licensee

Employees

~J.

L. Willis, Plant General

Manager

~D. Tibbitts, Director - Regulatory Compliance

"R.

B.

Van Metre, Manager - Technical

Support

"J.

M. Collins, Manager - Operations

"G. Campbell,

Manager - Maintenance

~J.

R. Sipp,

Manager - Effluent and Radiological

Control

"C.

R. Gibson, Director - Programs

and Procedures

"G.

L. Foreband,

Director - equality Assurance/equality

Control

"E.

M. Steudel,

Principal

Engineer

- Special

Projects

"R. T. Biggerstaff, Principal

Engineer - Onsite Nuclear Safety

"C.

L. McKenzie, Principal Engineer - equality Assurance

"L. Veeder,

Operations

  • J.

H. Smith, Operations

"J.

P.

Thompson,

Operations

"W. A. Slover, Technical

Support

"D.

Nummy, Maintenance

"G. T.

Law, Special

Projects

"0.

N. Hudson,

Regulatory Compliance

"A. H. Powell,

HTU

Other

licensee

employees

contacted

included

engineers, 'echnicians,

operators,

mechanics,

and office personnel.

NRC Resident

Inspectors

"G.

E. Maxwell

  • S.

P. Burris

"Attended exit interview

Exit Interview

The inspection

scope

and findings were summarized

on January

9, 1987, with

those persons

indicated in paragraph

1 above.

The inspector described

the

areas

inspected

and

discussed

in detail

the inspection

findings.

No

dissenting

comments

were received

from the licensee.

The licensee

did not

identify as proprietary

any of the materials

provided to or reviewed by

the inspectors

during this inspection.

3.

Licensee Action on Previous

Enforcement Matters (92702)

(Closed)

Unresolved

Item 400/86-76-14

Inadequate

Substitution of RHR Pump

Preoperational

Test

for Surveillance

Test.

This

item

involved

an

inadequate

baseline

creditation of Technical

Specification surveillance

requirement 4.5.2.h.2 for the

RHR pumps

by performance of preoperational

test

procedure

1-2085-P-03,

rather

than

surveillance

test

procedure

EST-205.

The inspectors

reviewed the test

data for the

performance

of

EST-205

conducted

on November 24,

1986,

and confirmed that the results

were satisfactory.

Revision

2 to the procedure,

which was implemented at

the

time of this test,

provided for adequate

temperature

compensation

of the flow element

used

in the performance

of the test.

This test

demonstrated

that

the

RHR

system satisfactorily fulfilled Technical

Specification surveillance

requirement

4. 5. 2. h. 2.

This item is considered

closed.

(Closed)

Unresolved

Item 400/86-76-16.

Failure to Temperature

Compensate

for Indicated

Flow During

RHR Pump Inservice Testing.

This item involved

inadequate

test

performance

and test

data

evaluation

for

RHR

pump

inservice testing

due to failure to temperature

compensate

indicated flow

during

performance

of surveillance test

procedure

OST-1108.

Review of

test

data

obtained

during test

performance

on

December 6-10,

1986,

reflected

satisfactory

results.

Advanced

change

2/2,

which was

imple-

mented at the time of test performance,

provided for adequate

temperature

compensation

of the flow element.

This test

demonstrated

that the

RHR

pump

satisfactorily fulfilled Technical

Specification

surveillance

requirement 4.5.2.f.2 for

pump operability.

This

item is considered

closed.

4.

Unresolved

Items

Unresolved

items were not identified during this inspection.

5.

Followup

Of

Previous

Inspection

Items

From

NRC

Inspection

Report

50-400/86-76

(92701)

(Closed)

Inspector

Followup Item 400/86-76-01

Upgrade of

EOPs

and

Supporting

Documents.

This item concerned

the technical

adequacy of

EOPs

and

the

implementation

of commitments

related to review and

revision of the

EOP

network,

setpoint

study

and

step

deviation

documents.

Based

on the resolution of

NRC concerns

and

a sample review of EOP

procedures

and the'etpoint

study,

the inspectors

concluded that

the

licensee

has

adequately

reviewed

and revised

the

EOP network

procedures

and setpoint study.

Commitments with regard to completion

of step deviation

documents

and cross referencing of EOP flow paths

to path

guides

were not yet required to be completed.

Committed

dates

were

January

31,

1987,

for completion of step

deviation

documents,

and

commercial

operation for

EOP flow path/path

guide

cross

referencing.

Completion of these

two commitments will be

identified

as

inspector

followup item 400/87-04-01.

Based

on

completion of actions

as

described

herein,

and reidentification of

the

above

two outstanding

commitments

to

a

new inspector

followup

item (400/87-04-01), this item is considered

closed.

b.

(Closed)

Inspector

Followup

Item 400/86-76-03

EOP Training for

Licensed Operators.

This item identified concerns with the adequacy

of

EOP training for licensed

operators.

In reviewing the licensee's

actions

in resolving

these

concerns,

the

inspectors

made

the

following observations.

(I)

Lesson

Plans86-410

and

86-304

were

reviewed.

It

was

concluded

as

a result of this review that licensed

personnel

received

adequate

training

on the

methods

of verification of

automatic actions for the flowpaths.

Attendance

records

were

reviewed

and appeared

accurate

and adequate.

Although training

was not provided for every automatic action,

a sufficient amount

of material

appeared

to

be covered

to enable

proper operator

response

to automatic actions.

(2)

Existing simulator

scenarios

provided

by the facility were

reviewed for inclusion of passive

failures

such

as instrument

and

alarm failures.

The scenarios

provided for

a

number of

manipulations

on these

less

than obvious passive failures.

This

item is closed.

(3)

Attachment III to a letter dated

September

18, 1986, identified

licensee

commitments

to provide additional training for three

EOP related tasks including:

(a)

Locally dumping steam

by manual manipulation of PORVs

(b)

Minimizing secondary

contamination

through local operations

by non-licensed

operators

(c)

Local operation of electrical

switchgear

(4)

A review of the training administered

for these

three

tasks

indicated it to be adequate

to resolve identified concerns.

In

addition, the inspectors verified during walkthrough evaluations

of two non-licensed

operators

that this training was apparently

effective.

Training

was

conducted

on specific identified

EOP

deficiencies

and

on the latest

EOP revisions

under lesson

plan

Rg 86-40.

The inspectors

noted,

however, that this training was

relatively brief,

appr oximately

seven

hours split between

two

major revisions,

and that the simulator was not utilized.

Also,

no front-end evaluation

was conducted

by the training staff to

determine

the most effective

mode of training such

as lecture,

simulator,

or

in-plant.

The

decision

not to perform this

evaluation

may have

been influenced by the unavailability of the

simulator,

which was

undergoing

several

months of modification

work,

and

the

time constraints

imposed

by the fact that the

additional

EOP training was

a five percent

power commitment.

Of

greater

concern

was the failure of the training staff to conduct

any type of evaluation to determine if the training on the

EOP

had

been

adequate

and

effective.

The training staff did

indicate that

some

type of evaluation

such

as written or oral

examination or simulator evaluations

would normally be conducted

for any type of formal training.

This failure to conduct

evaluations

of

EOP training effectiveness

was of particular

concern

considering

the

methods

used to conduct the training,

the

large

number of changes

made,

and the relatively short

duration of the training.

In addition,

several

other factors

which contributed to this concern included the following:

(a)

The

EOP training was split between

two major

EOP revisions

, in less

than

a two month period.

(b)

Although heavy reliance is placed

"on the

use of the flow

path

guides

to provide operators with detailed information

not

on the flow paths,

there

is

no established

cross

reference

between

flow path

steps

and related

procedure

steps.

Until this cross

reference

is established

by the

licensee',

there

should

be adequate

training and evaluation

to ensure

operators

can readily obtain detailed flow path

information from the guide

on

a timely basi's

as

needed.

(c)

The training on

EOP Revisions

1 and

2 was administered

in

November

and

December

of 1986 respectively,

but the annual

licensed requalification examination,

also administered

in

December,

was

based

on the outdated

EOPs.

In

some cases

the

annual

examination, utilizing the pre-revision

EOPs,

was

administered

to individuals after both

EOP revisions

were taught.'raining

on major

and multiple revisions to

EOPs

and then being tested

on the original versions

had the

potential to add an element of confusion for operators.

(d)

The inspectors

performed

a partial walkthrough of the

EOPs

and

flowpaths

with three

randomly

selected

licensed

operators.

Although the walkthroughs indicated

an overall

satisfactory

knowledge

of the

EOPs,

several

areas

of

concern

were

identified to the

licensee.

One of the

operators,

when

required

to refer to the

EOP flowpath

guides,

utilized the outdated

and cancelled

guides instead

of the

revised

flow path

guides

incorporated

into the

,user's

guide.

These

outdated

flowpath guides

contained

erroneous

setpoints

and

referenced

Emergency

End

Path

Procedure

(EPP)

16 which

had

also

been

cancelled.

The

outdated

Flow Path

Guides

and

EPP

16 were under

a cancel-

lation process

and should not have

been in the control

room

as detailed

in Section 6.f.

Since,

however,

the licensed

personnel

had received training on the

new user's

guide and

the revised

EOPs

incorporated

into it, it would have

been

reasonable

to expect

the

operator

to have utilized the

user's

guide versus

the cancelled

flowpath guides.

Another

concern that resulted

from the walkthrough evaluations

was

that problems

were encountered

by all three

operators

in

the restoration

of offsite power.

One operator

indicated

that

he

would dispatch

an auxiliary operator

to the

switchgear

.room to reset

the

lockout (86) relay.

This

lockout relay is actually

located

in the control

room.

Another operator

omitted the reset of the lockout relay

which would have

prevented

the successful

restoration

of

offsite power.

The third individual attempted to locate

a

procedure

for the restoration,

a very positive effort, but

there

was

no procedure

available for restoration

of the

auxiliary transformers.

He did,

however,

correctly talk

through the required steps without procedural

guidance.

Lesson

plans

indicated

that

licensed

and

non-licensed

operators

had

received

training

on local

operation

of

electrical

switc'hgear

which

had

been

a

commitment

in

Attachment III of the

September

18,

1986,

submittal.

The

inspectors

walked

two

non-licensed

operators

through

several

of the

local electrical

operations

required to

support

the

EOPs.

Although the

two individuals displayed

an adequate

knowledge of the material

contained in the

EOP

lesson

plans,

neither could correctly reset

an

emergency

diesel

generator

overspeed trip,

an essential

evolution.

One operator

could not reset

the diesel without prompting

from the inspector

and the other omitted essential

steps

to

successfully 'complete

the evaluation.

In response

to the

concern

over this deficiency,

the licensee

responded that

licensed 'operators

would normally be utilized to perform

this function.

The inspectors

question,

however,

whether

during accident

conditions with a loss of offsite power,

a

licensed

operato'r

could

be

spared

from control

room

responsibilities

in order

to

reset

a tripped diesel

generator.

The licensee

should either

ensure that enough

licensed

operators

are

always

on site to accomplish

such

local

operations

during accident

conditions,

or should

provide

adequate

training to ensure

non-licensed

operators

are

proficient.

Resolution

of this

concern will be

identified as

an inspector followup item (400/87-04-02).

The inspector

reviewed

the

lesson

plans

associated

with

Revisions

1 and

2 of the

EOPs,

and it appeared

that the

material

adequately

addressed

the committed

EOP training

areas.

Based

on deficiencies

noted

during this review

the

inspectors

consider that the extent of training and

evaluation associated

with the

EOPs

as they currently exist

may not have

been sufficient to demonstrate

proper response

to all

EOP conditions

by all licensed

personnel.

As

an

interim

measure

of assurance,

the

inspectors

witnessed

plant walkthrough evaluations

of five additional licensed

operators

by

members

of the training staff.

The walk-

throughs

were

based

upon identified concerns

as well

as

the objectives

from the

EOP lesson plans.

Although minor

deficiencies

were

observed,

these

additional

evaluations

indicated

adequate

knowledge of the

EOPs to support

the

plant startup.

Use of the simulator would have provided

more

conclusive

evidence

of

EOP

proficiency

but the

Shearon Harris simulator

was in an extended modifications

outage at the time.

The

inspectors

consider

that

a comprehensive

EOP training program

should

be

implemented

on

an

expedited

basis

consistent

with

completion of simulator modifications

which were in progress

and

restoration of a five shift rotation operation

program.

The licensee

submitted

a letter (file number SHF/10-13510)

dated January

9, 1987,

which committed to further evaluate

the

EOP revisions

to determine

appropriate

additional training to include the most effective method

of training.

The

commitment

included

implementing this training

in the

form of shift drills commencing

in February

1987,

classroom

training as

a part of annual requalification commencing in Harch 1987,

and simulator training

as

required

as

a part of annual requalifica-

tion commencing in June

1987.

The licensee

committed to complete

and

evaluate

this training by August 1987.

NRC review of the licensee's

evaluation

and

scope of programmed training and

implementation of

this training pursuant

to the

above

schedule

is identified as

an

inspection followup item (400/87-04-03).

As a result of observation

associated

with the restoration of offsite

power both during these walkthroughs

and post simulator examinations,

the

inspectors

expressed

concern

that

procedure

details

did not

exist to accomplish this action.

As a result of these

concerns

the

licensee

issued

revision

3 to EOP-EPP-001,

Loss of AC Power to lA-SA

and 1B-SB Busses,

and Advanced

Change

2/3 to

OP 156.02,

AC Electrical

Oistribution,

on January

10,

1987.

Subsequent

NRC review of these

changes

reflected resolution of the specific concern.

The

inspectors

consider,

however,

that during conduct of the

EOP

training committed to in inspector followup item 400/87-04-03

above,

the licensee

should evaluate

general

directions in the

EPPs

and path

guides

generically for similar concerns

and

make revisions

where

appropriate.

Generic resolution of these

types of concerns

during

additional

EOP training is identified as

an inspector followup item

(400/87-04-04).

(Closed)

Inspector

Followup Item 400/86-76-05

Instrument

and Valve

'umbers

for AFM System

Missing

From Procedure

OP-137.

All concerns

addressed

by this

item have

been

completed with the exception of

providing valve

numbers

for the instrument air (IA) system.

The

licensee

is currently walking

down the

IA system

to update

the

drawings

and will revise procedure

OP-137, Auxiliary Feedwater

(AFM)

System,

and other effected procedures

when the valve number informa-

tion

becomes

available.

The completion

and review of addition of

valve

numbers

for instrument air is identified as inspector followup

item 400/87-04-05.

This item is considered

closed.

(Closed)

Inspector

Followup Item 400/86-76-06.

Licensee Evaluation

of the Effect of Air in the AFM/Emergency Service Water

(ESM) Cross

Over Piping

and Resolution of This Concern.

The licensee

reviewed

the subject

NRC concern

and

as

a result

implemented

a modification

(PCR-489)

to maintain water in the

AFM/ESW crossover

piping.

This

modification was

completed

on December ll, 1986.

The Shearon

Harris-

FSAR is currently being

updated to reflect the system modification.

This item is considered

closed.

(Closed)

Inspector

Followup

Item 400/86-76-07.

Local

Open/Closed

Indication

on Safety-Related

Dampers.

The licensee

had previously

committed to provide local open/closed

indication on safety-related

dampers.

The

licensee

accomplished

this

action

by completing

corrective

action

program

item 86H0990

on October 31,

1986.

This

item is considered

closed.

(Closed)

Inspector

Followup

Item 400/86-76-08.

Concerns

on Air

Supplies

to Safety-Related

Dampers.

This item involved the revisien-.

of procedures

OP-168

and OMM-ll to indicate that the air supply line

to 1-CP-1

and

1-CP-7 was locked closed,

and to specifically identify

the

switch removing control

power from valves

1-CP-10

and

1-CP-4.

These

procedures

were reviewed and confirmed to have

been revised,

(Cl os ed)

Inspector

Fo1 1 owup

Item

400/86-76-10.

Independent

Verification.

This item involved review of general

procedures

(GP)

to

ensure

adequate

implementation

of

independent

verification

requirements.

Additionally,

GP-002

did not contain

independent

verification for the opening of the accumulator

discharge

valves

and

racking out of the respective

breakers.

The licensee

revised

GP-002

to include

independent

verification for the accumulator

discharge

valves.

The Onsite Nuclear Safety

Committee

reviewed all

GPs for

proper

independent

verification and

as

a result,

GP-001,

004,

007

and 008 were revised.

This item is considered

closed.

(Closed)

Inspector

Followup

Item 400/86-76-11.

Adequacy of AOPs,

APPs

and

OWPs.

The

licensee

committed to

complete

reviews

and

walkdown of all

abnormal

operating

procedures

(AOP), annunciator

panel

procedures

(APP),

and operations

work procedures

(OWP),

and

to resolve specific

concerns

noted

by the inspectors.

All specific

concerns

noted

by the inspectors

in Inspection

Report 400/86-76

have

been

adequately

addressed

or justified.

The

inspectors

consider

these

issues

to

be

appropriately

resolved.

Additionally, the

inspectors

conducted

a selected

review of the revised

procedures.

Selected

portions of the following revised procedures

were reviewed:

APP-ALB-007, Annunciator Panel

Procedure,

Hain Control Board

APP-ALB-010, Annunciator Panel

Procedure,

Main Control. Board

APP-ALB-011, Annunciator Panel

Procedure,

Main Control Board

APP-ALB-012, Annunciator Panel

Procedure,

Main Control Board

OWP-RC, Reactor Coolant

OWP-'RP1,

Rod Position Indication

OWP-RS,

Remote

Shutdown Monitoring Instrumentation

AOP-007, Turbine Trip Without Reactor Trip Below P-7

AOP-008, Accidental

Release

of Liquid Waste

AOP-026,

Loss of Essential

Service Chilled Water System

All procedures

reviewed

appeared

to

be in accordance

with the

applicable

procedures

writer's guides

and appeared

to be technically

adequate.

This item is considered

closed.

(Closed)

Inspector

Followup

Item

400/86-76-12.

Oeficiencies

Associated

with Surveillance

Procedures.

This

item

involved

.

resolution

of deficiencies

in surveillance

test

procedures.

All

previously identified technical

deficiencies

were resolved

through

procedure

changes.

Non-technical

comments

were either'.incorporated

or adequately

justified as

acceptable.

All procedure

changes

had

been

issued

except for changes

to OST 1824,

1B Safety Train

B

EOG 18

Month Operability Test,

Modes

5 and 6; and,

OST-1023, Offsite Power

Availability Verification Weekly Modes 1, 2,

3 and 4.

Resolution of

deficiencies

with these

two procedures

was

not considered

to be

mandatory

for power escalation.

These

changes

were

noted to

be

prepared

with technical

and safety

reviews

complete

and were well

into the review and approval cycle.

This item is considered

closed.

(Closed)

Inspector

Followup Item 400/86-76-13.

Concerns

With Stroke

Times for Containment

Spray

and

Purge

Valves.

This item involved

resolution

of licensee

identified

concerns

with stroke

times of

containment

spray

suction

valves

and pre-entry

purge

and exhaust

valves.

Containment

spray suction valves

CT-102,

71,

105,

and

26

were

modified by

PCR

647 to replace

pinion and

worm gear sets

in

order to reduce

valve stroking to approximately

80 seconds.

This is

well within the Technical Specification required value of 103 seconds

for containment

spray switchover to the

sump

on

RWST low-low level..

These

valves

were satisfactorily tested

by OST-1809, Vital Switching

to Recirculation

Sump:

ESF Response

Time,

18 Month Interval,

Modes

5

and

6,

on

December 8,

1986.

Response

times for opening of the

containment

spray

sump

suction

valves of

RMST low-low level

were

determined

to be satisfactory

by completion of EST-314,

Engineering

Safety

Features

Response

Time Evaluation Switchover to Recirculation

Sump

with

CS,

Attachment II,

Item A

and

Attachment III on

December

12,

1986.

This item is considered

closed.

(Closed) Inspector

Followup Item 400/86-76-15.

Use of Preoperational

Test in Lieu of Surveillance

Test.

This item involved

a licensee

commitment

to re-evaluate

all surveillance

requirements

which were

baselined

with preoperational

test data,

to confirm equivalency of

test

methodology,

and

acceptance

criteria between surveillance test

procedures

and preoperational

test procedures.

The licensee

stated

that this

commitment

had

been

completed

and provided documentation

indicating

that

surveillance

baseline

requirements

had

been

established

by preoperational/startup

test

data

rather

than

by

surveillance test

procedures

in 35 instances.

Of these,

nine of the

surveillance test

procedures

had

been

subsequently

run for reasons

that

were

not associated

with this

committed

review.

For

one

surveillance test procedure

(MST-I0267, Motor Operated

Valve Overload

and

Torque

Switch Bypass Circuitry Test),

the preoperational

test

data

used

to baseline

the surveillance

requirement

was

found by

the

licensee

to not be fully equivalent to the surveillance test

procedure.

The

inspectors

confirmed that'urther

testing

was

accomplished

by the

licensee

prior to fuel

load to correct the

deficiency.

To confirm the

adequacy of the licensee's

evaluation,

the inspectors

reviewed three

procedures

where preoperational

test data

was

used to

baseline

the surveillance

requirement

in lieu of performing the

surveillance test procedure.

One problem was identified with the use

of startup test

procedures

1-5232-P-01

and 1-5232-P-02

in lieu of

surveillance

test procedure

MST-0014,

which implements

the battery

charger Technical Specification surveillance

requirement 4.8.2.1.C.4.

This surveillance test

procedure

requires that every

18 months the

licensee verify that the battery charger will supply at least

150

amperes

at

125 volts for at least four hours.

Review of MST-0014

reflects that this requirement

would be implemented if MST-0014 were

performed.

However, at the time of this inspection,

MST-0014

had

not

been

performed,

and startup

test

procedures

1-5232-P-Ol

and

1-5232-P-02

were

being

used

instead

to satisfy

the surveillance

requirement.

Review of these startup test procedures

reflected that

the

surveillance

requirement

had

been

adequately

implemented for

battery

chargers

1A-SA and

lA-SB, but

had not been

implemented for

battery

chargers

1B-SA and

1B-SB.

Specifically, for the

1B-SA and

1B-SB

chargers,

'the test

methodology

merely

demonstrated

that

following the service

capacity test of the batteries

and within 24

10

hours

of completion of that test,

the chargers

were verified to

maintain

charge

on the batteries

while the batteries

were loaded to

69

amperes

each for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />

and 59 minutes with no required voltage

maintenance.

The inspector

considered

that this did not meet the

requirement

of Technical Specification 4.8.2. 1.C.4

and that battery

chargers

1B-SA and

1B-SB were inoperable.

Technical Specification 3.8.2.1

requires,

as

a

minimum, that the following OC electrical

source

be operable for Node 1-4 operation.

125-volt emergency

battery

bank

1A-SA and either full capacity

charger,

1A-SA or 1B-SB

125-volt emergency

battery

bank

1B-SB

and either full capacity

charger,

1A-SB or 1B-SB.

The

inspectors

reviewed

the reactor

auxiliary building auxiliary

operator

log sheets

for shift rounds

from December

23,

1986, to

the

inspection

date,

noting that the

licensee

had

stated

that

December

23,

1986,

was

the

date

which they

had

entered

Node 4

operation.

This

review reflected that only the properly tested

A train chargers

had been placed in service.

This

demonstrated

current

and

past

compliance

with Technical Specification 3.8.2. 1

even with battery

chargers

1B-SA and

1B-SB

inoperable.

When this condition was brought to the attention of the

licensee,

action was taken to enter the '1B-SA and

1B-SB chargers

into

the

equipment

inoperability

record

and

to test

these

chargers

pursuant

to MST-0014.

The licensee

subsequently

provided data that

demonstrated

satisfactory

testing of charger

1B-SB

on January 8-9,

1987,

and charger

1B-SA on January

9, 1987.

Based

on

completion

of licensee

reviews,

accomplishment

of the

additional

NRC review,

and resolution of the battery charger problem

noted during the

NRC review, this item is considered

closed.

(Closed) Inspector Followup Item 400/86-76-20.

AFW System High Point

Vents.

The

item involved inadequacies

in the

PNSC

review of a

potential

unreviewed

safety

question

determination

involving lack

of

AFW system

high point vents.

The

inspectors

confirmed that

appropriate

high point vents

had been installed in the

AFW system in

accordance

with PCR-259

on

November 20,

1986.

Also, the inspectors

confirmed that appropriate

high point vents

had

been installed in the

SI and

RHR systems

pursuant

to

PCR-423 with all work completed

by

December

12,

1986.

The

inspectors

also

confirmed that selected

operations

and

surveillance

test

procedures

referenced

the

new

valves.

The

inspectors

also

reviewed

documentation

that demonstrated

that

PNSC

members

had adequately

addressed

the problems

associated

with

the subject

PNSC review and

emphasized

the

need for formality and

rigor in handling potential

unresolved

safety concerns.

These

were

the only remaining actions

requiring completion to resolve the item

and consequently

the item is considered

closed.

6.

Control

Room Operations

Review

The inspectors

observed four different shift crews operate

on both day and

night shifts

during the

course

of this

inspection.

The

inspectors

considered that overall control

room operations,

including communications,

procedure

use,

log keeping, shift turnover and briefings,

alarm response,

control board attentiveness

and.access

control, were satisfactory

and very

professional.

Some specific observations

and

comments

noted during this review are

as

follows:

The

inspectors

reviewed

the

process

by which deficiencies

are

identified,

tagged,

and

work

requests

are

generated.

White

deficiency

tags

are

used

to identify any material

and equipment

problems at the facility.

The tags are readily available at any of

18 deficiency centers

around the site and employees

are encouraged

to

use

the tags.

Each tag is

numbered

and

must

be entered

in

a log

maintained at the deficiency center

.when it is used.

Once the tags

are

hung

and the deficiency entered

in the log, the initiator will

submit

a work request

(MR) in accordance

with Naintenance

Management

Manual

(NNN) 012,

Revision 5, Mork Control Procedure.

These

WRs are

written

on the

automated

maintenance

management

system

(ANNS),

a

site-wide

computerized

system

for tracking

of

MRs.

The

ANNS

evaluates

the

new

MR to determine if the

MR is duplicating

any

previously written MRs or if it effects

any safety-related

equipment.

The shift foreman

or his designee

has

access

to the

ANNS from a

terminal in the clearance

center

and will review the

WRs for approval

and configuration control.

During a tour of the

emergency

service

water

(ESW) building

and

the

emergency

diesel

generators

(EDG),

deficiency

tags

were

observed

on

equipment

and

the

inspectors

gathered

information from the tags.

The inspectors

then proceeded

to

the clearance

center

where

the

ANNS was

used to tie the deficiency

tags to a

MR.

In all but one case the deficiency tag was tied to a

current

WR.

Deficiency tag 01731,

on the lA EDG local control board,

was tied to

a

MR; however,

the

WR stated

work was in progress.

The

inspectors

requested

more information on the

MR from the licensee

and

as

a result of the licensee's

investigation it was discovered that

the work on the deficiency

had

been

completed

but the tag had not

been

removed.

The licensee

corrected the problem by clearing the tag

and closing the

WR.

The inspectors

consider that with exception of

the deficiency noted

as Violation 400/87-04-09,

the current system of

identifying deficiencies

appears

to be adequate.

12

The

inspector

reviewed

Operations

Management

Manual

(OMM) 002,

Revision 2, Shift Turnover Package.

The on-coming shift foreman

has

the responsibility to ensure

the shift turnover package is properly

completed

by the on-coming shift personnel

prior to completion of

turnover.

The shift turnover package

contains

several

attachments

to

be completed

by various control

room personnel.

In the course

of

completing

OMM-002, the control boards

are walked down by the control

operator

(CO),

the

senior

control

operator

(SCO),

and the shift

foreman.

OMM-002 also

requires

a

review of the following to be

completed

by the shift foreman:

Clearance

Book

Hot Work Permits

Key Log Book

Shift, Foreman's

Log

Surveillance Test Schedule

Equipment Inoperability Record

Minimum Equipment List

Temporary Bypass,

Jumper,

and Wire Removal

Log

Night Order Book

Ouring the course of the inspection the inspectors

observed

several

shift turnovers

paying particular attention

to the completion of

OMM-002.

. In all

cases

the shift turnovers

appeared

to be conducted

in

a

thorough

and professional

manner

and

appeared

to adequately

comply with OMM-002.

The inspectors

reviewed the

equipment inoperability record (EIR) to

determine if there

was adequate

control of inoperable

equipment.

The

EIR is maintained

in the Clearance

Center

and is utilized by the

shift foreman

or designee

to track inoperable

equipment that is

Technical Specification

dependent.

The shift foreman designee

in the

Clearance

Center

reviews

and

approves all work requests

(WR) and

clearance

tagouts.

When

a

WR or

a tagout effects

a Technical

Specification related piece of equipment,

an EIR is completed

and the

shift foreman is notified.

If a Limiting Condition for Operation

(LCO)

has

been

entered,

the

EIR is

used

as

a tracking

mechanism,

timing the

LCO deadlines.

The EIRs in effect are reviewed

each shift

change

and the running clock on

any

LCOs is updated.

New EIRs are

attached

to

OMM-002 and are reviewed

by the on-coming shift foreman.

The method

appears

to be

an adequate

means

of tracking inoperable

equipment

and

ensuring

that

LCOs

are

not violated

and that all

personnel

are

aware of any active

LCO.

The use of the running time

update

on the

EIR appears

to

be

a good tool for preventing

the

violation of a known

LCO time requirement.

0

13

Oue to the current work load of the shift foreman,

the licensee

has

allowed

a senior

control operator

(SCO) to function

as the shift

foreman's

designee.

The

designee

is stationed

in the clearance

center

and is tasked with maintaining configuration control of the

facility.

The utilization of the

SCO as the designee

does

appear to

streamline

the operation of the control

room,

and at present

appears

to

reduce

the 'amount of paperwork requiring the attention of the

Shift Foreman.

Some

concerns

were raised,

however,

as to the extent

that the designee

can perform the duties

and responsibilities of the

shift foreman.

Instead of issuing changes

to the specific procedures

to specify conditions

under which the shift foreman designee

can

be

used,

the

licensee

issued

a

memorandum

effectively changing all

references

to approval

signatures

of the shift foreman to mean shift

foreman or designee.

The memorandum also stated

the designee

was to

be identified for each shift.

The inspectors

questioned

the generic

application

by memorandum

regarding the designee

and was informed by

the licensee

that the procedures

specifically intended for designee

authority will, in fact,

receive

a

change

request

and that the

memorandum will be then cancelled.

The inspectors

also noted several

instances

where

no designee

was listed in the shift foreman's

log.

The

licensee

acknowledged

these

missing

entries

and initiated

corrective action to rectify the problem.

Ouring the control

room observation,

the inspectors

reviewed the

licensed

operator

required

reading binder.

It was

noted that

one

individual

had not reviewed the binder for approximately

two months.

The

licensee

informed the

inspector

that

the

apparent

cause

of

this

non-review

was

caused

by the

existence

of two different

required

reading

binders of which only one

was

known to exist by

the individual

involved.

The licensee

stated

that the individual

involved would

be brought

up to date,

that the

two binders

would

be

consolidated,

and that

the

required

reading

program would be

enhanced.

Further

NRC review of additional administrative controls

associated

with required

reading

program

is identified

as

an

inspector followup item (400/87-04-06).

Ouring

a walkthrough of the emergency operating procedures

flowpaths

and supporting

flowpath guides,

one licensed operator referred to an

outdated

and erroneous

flowpath guide and end path procedure

EPP-16.

A cancellation

process

had

been

implemented early in Oecember

1986,

for the

flowpath guides

and for EPP-16.

Revised

flowpath guides

were incorporated

into the User's

Guide which was available to the

operators

in the control

room,

and training had been provided on the

user's

guide.

.The

licensee

had failed,

however,

to

remove

the

cancelled

flowpath guides

and

EPP-16

from the control

room or to

provide

attached

notification that

they

were

not to

be utilized

during the cancellation

process.

In response

to

NRC concerns,

the

licensee

removed these

procedures,

which contained

erroneous

informa-

tion and setpoints,

from the control

room on January

8, 1987.

The

licensee's

procedure

cancellation

process

needs

to be revised to

ensure

that operators

are not provided with two sets of conflicting

information, particularly where related to emergency plant operations.

Resolution

of this deficiency will be

an inspector

followup item

(400/87-04-07).

During control

room observation,

the inspectors

noted that several

controllers

for plant

equipment

had

no control

power indication

lights, i.e.,

both the

red

and green lights were extinguished.

The

licensee

indicated that this equipment

was intentionally de-energized

during

normal

plant

operations,

and

indications

were that

the

operators

were

aware

of the

equipment

status.

The concern

was,

however, that there

was

no control board indication such

as

a note,

tag, or dot to emphasize that

no control power indication is a normal

status

for these

controllers.

Even though the operators

appeared

to

be familiar with the status

of this particular equipment,

having

no

lights and

no notation could potentially mask a loss of control power

for other safety-related

controls.

Similar circumstances

at other

facilities have

allowed the loss of control over a valve or pump to

go unnoticed for an

extended

period,

and through multiple shift

changes

and control

board walk-downs.

Resolution of this concern

will be an inspector followup item (400/87-04-08).

The inspector

witnessed

a shift turnover briefing on the morning of

January 8,

1987.

During this briefing, the night Shift Supervisor

informed the

day Shift Supervisor that the

steam

dump valves

had

failed to operate

on

demand

by the control

room operators.

An

on-shift investigation

by operators

had discovered

a clearance

tag

hanging

on breaker

PP-lA circuit.

Mith this breaker

tagged in the

de-energized

position, there

was

no control power supply to the steam

dump valves.

In response

to

NRC concerns,

the licensee

conducted

an

investigation

to locate

supporting

documentation

for the clearance

tag.

The tag appeared

to be written for clearance

OP-86-4575,

but

no record of work or processing

of the clearance

could be located.

The clearance

had not been completed

and could not be located in the

Active Clearance

Book, the

Hold for Test Binder, or the clearance

files.

The

licensee

also

interviewed

various

Maintenance

and

Operations

personnel

and

reviewed operating

logs but could not find

any physical

evidence that the clearance

was ever worked or processed.

Procedure

AP-020,

Clearance

Procedure,

Revision I, contains specific

requirements

to

ensure

the

proper

processing

of clearances

and

associated

tags including:

Active clearances

will be maintained

in the Active Clearance

Binder.

Cancelled

clearances

that

are

held for testing will

be

maintained in Hold for Test Binder.

A running log of all active clearances will be maintained at the

front of each clearance

binder.

15

If a

clearance

is transferred,

the old clearance

will be

attached

to the

new clearance

and placed in the clearance

log.

If a clearance

is cancelled,

the

tags

shall

be

removed

and

destroyed.

If a clearance

is cancelled,

the system shall

be re-aligned

in

accordance

with AP-020-1-1.

Weekly, the operating

supervisor

shall initiate an audit of the

Clearance

Log Binder.

A physical verification of installed tags

against

the binder shall

be conducted.

After placing clearance

tags,

the tag preparer shall notify the

operator "at the controls"

and

document

the tag

and equipment

position

on the clearance.

The clearance

holder physically verifies component position and

tags

and signs the clearance.

Following completion

of work, the tags,are

removed

and

the

components

restored

to normal line-up.

The control operator or senior control operator shall sign that

the clearance

tags

have

been

removed

and the component

line-up

restored.

The Shift Foreman shall

review the completed

clearance

and sign

it.

Technical Specification 6.8.1 requires that procedures

be implemented

in

accordance

with

Regulatory

Guide

1.33,

Revision 2,

1978,

Appendix "A".

Appendix "A", Item 1.c,

recoranends

procedures

for

equipment

control, i.e.,

locking

and

tagging,

and

Section 9.e

recommends

procedures

for control of work and clearances.

Contrary

to all of the above,

the licensee left the steam

dump valves

tagged

in the

inoperable

position

from

November

1986

to

January

1987,

without Operations'wareness

or supporting

documentation.

The

licensee

believes

that

the clearance

was

probably cancelled,

but

failed to follow procedures

in documenting

the disposition,

removing

the tag,

and restoring

the proper system alignment.

This fai'lure to

implement

a procedure

p6r Technical Specification 6.8.1

was carried

as unresolved

at the exit interview and later changed

to a violation

(400/87-04-09),

via

a telephone

conversation

with the licensee.

It

should

be noted that the failure to adequately

control tagging

and

system

alignment

could

have

serious

implications if applied

to

safety-related

system.

Although the licensee

indicated that they

have

one additional

level of control over safety system alignment,

a

Configuration Control

Log, in this specific instance,

several

levels

of control evidently broke down.

0

Review Of Significant Operational

Occurrence

Reports

(SOOR)

The inspectors

reviewed all

SOORs that

have occurred

since

Oecember

15,

1986, for operator errors.

SOOR events occurring during this time frame

included

SOORs86-016 through

86-021.

In the review of the

SOORs the

inspectors

noted that only three

involved operator errors

and that these

were all associated

with heat

up/cooldown rate

problems resulting

from

difficulty in controlling

these

evolutions

within the

parameters

established

for cold temperature

operation.

None of these

events

appeared

to be of significant concern.

The

inspectors

also

reviewed the safety injection actuation

event that

occurred

on

Oecember

11,

1986.

The

event

was

the result of running

operational

surveillance

test

(OST)

1813 which required

a transfer of

control

from the main control

board

(MCB) to the auxiliary control panel

(ACP).

Mhen the operators

returned control to the

HCB from the

ACP, there

was

an SI signal

actuating all

B train components.

After verifying the

reason

for the

SI to

be

due to the functioning of electrical

relays

removing in-place SI blocks during switch actuation,

the operators

decided

to reset

SI and terminate flow to the vessel.

In the process of resetting

the SI, the operator

turned the

SI actuate

switch instead of the reset

switch thereby reinitiating SI

on both trains.

The licensee initiated

OHN-004, Post Trip/Safeguards

Review, to determine proper operation of all

safety

equipment.

Review of the

Post Trip Review reflected that after

review of the problem, the licensee

determined that the arrangement

of the

SI actuate

and reset

switches

on the

NCB needed to be modified to prevent

the

inadvertent

SI

actuation

from occurring

again.

The

inspectors

reviewed

PCR-000174

which addressed

the relocation of the switches.

The

inspectors

consider that the SI actuate

switch should

have

been addressed

to prevent

the

operator

from repeating

the

event

in

SOOR-015.

The

inspectors

interviewed

several

operations

personnel

and were told that

this type of an incident is commonly done

on the simulator indicating to

the inspectors

that the

SI actuation

switches

needed

to

be modified to

prevent

recurr ences

of this event.

The licensee

stated that something

was in the process

of being written that will address

the relocating of

the SI actuation

switches,

however, it was not available for review at

this time.

The final determination

of corrective actions for this event

will need

further review

by the

NRC staff

and will be

an inspector

fol 1 owup item (400/87-04-010).