ML18004B793
| 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.:
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
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).
Training
for
Operations
Personnel
(paragraph
5.b).
Instrument
and Valve Numbers for Auxiliary
(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
(paragraph 5.e).
Resolution of Concerns
Associated
with Air
Supplies
to
Safety
Related
(paragraph 5.f).
Independent
Verification of the Opening of
Discharge
Valves
and
Breaker
Racking Out (paragraph
5..g).
Review
Adequacy
of Abnormal,
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
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
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
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
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
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
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
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
and
Supporting
Documents.
This item concerned
the technical
adequacy of
and
the
implementation
of commitments
related to review and
revision of the
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
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
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
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
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
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
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
lesson
plans,
neither could correctly reset
an
emergency
diesel
generator
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
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
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
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
training committed to in inspector followup item 400/87-04-03
above,
the licensee
should evaluate
general
directions in the
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
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
(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
The licensee
had previously
committed to provide local open/closed
indication on safety-related
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
This item involved the revisien-.
of procedures
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
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
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
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
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
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
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
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,
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
Specifically, for the
1B-SA and
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,
125-volt emergency
battery
bank
and either full capacity
charger,
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
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
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
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
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).