ML18009A535

equipment

to service,

paragraphs

6.b

and 6.c;

Fail'ure to verify valve leakage following operation of an

RCS pressure

isolation

valve, paragraph

7.a.

A weakness

is identified in paragraph

6.b regarding operators'nowledge

of

priority/emergency

work requirements.

9005160059

900504

PDR

ADOCK 05000400

PDC

The

computerized ~ta

base

and

administrative

controls

established

for

~

scheduling

surveillance

testing

is

considered

to

be

a

program

strength,

paragraph

3.a.

Licensee identified violations are discussed

in paragraphs

6.a

and 6.d.

REPORT

DETAILS

1.

Persons

Contacted

Licensee

Employees

R. Biggerstaff, Unit Manager Site Engineering

J. Collins, Manager,

Operations

G. Forehand,

Director,

QA/QC

C. Gibson, Director,

Programs

and Procedures

P. Hadel,

Manager,

Maintenance

C. Hinnant, Plant General

Manager

D. McCarthy,

NED Site Principle Engineer

S. McCoy, Procedure

Coordinator

C. Olexik, Manager, Shift Operations

R. Richey,

Manager,

Harris Nuclear Project Department

J. Sipp, Manager,

Environmental

and Radiation Monitoring

H. Smith, Supervisor,

Radwaste

Operation

D. Tibbits, Director, Regulatory Compliance

M. Wallace, Senior Specialist,

Regulatory

Compliance

E. Willett, Manager,

Outages

and Modifications

L. Woods,

Manager, Technical

Support

Other

licensee

employees

contacted

included

office,

operations,

engineering,

maintenance,

chemistry/radiation

and corporate

personnel.

Attended exit interview

Acronyms

and initialisms

used

throughout this report

are listed in the

last paragraph.

2.

Review of Plant Operations

(71707)

The plant continued in power operation

(Mode 1) for the duration of this

inspection period.

Shift Logs and Facility Records

The inspector

reviewed

records

and discussed

various entries

with

operations

personnel

to verify compliance

with the

Technical

Specifications

(TS) and the licensee's

administrative procedures.

The following records

were reviewed:

Shift Foreman's

Log; Control

Operator's

Log; Auxiliary Operator's

Log;

Night

Order

Book;

Equipment

Inoperable

Record; Active Clearance

Log; Jumper

and Wire

Removal

Log;

Shift

Turnover

Checklist;

and

selected

Chemistry/Radiation

Protection

and

Radwaste

Logs.

In addition,

the

inspector

independently verified clearance

order tagouts.

No violations or deviations

were identified.

b.

Faci 1 it~ours

and Obser vati ons

Throughout

the inspection

period, facility tours

were conducted

to

observe

operations

and

maintenance

activities in progress.

Some

operations

and

maintenance

activity observations

were

conducted

during backshifts.

Also, during this inspection

period,

licensee

meetings

were

attended

by the inspectors

to observe

planning

and

management

activities.

The facility tours

and

observations

encompassed

the following areas:

security perimeter

fence; control

room;

emergency

diesel

generator

building;

reactor

auxiliary

building;

waste

processing

building;

fuel

handling

building;

emergency

service

water building; battery

rooms;

and electrical

switchgear

rooms.

During these tours,

the following observations

were made:

(I)

Monitoring Instrumentation

- Equipment operating

status,

area

atmospheric

and liquid radiation monitors, electrical

system

lineup,

reactor

operating

parameters,

and auxiliary equipment

operating

parameters

were

observed

to verify that indicated

parameters

were

in accordance

with the

TS for the current

operational

mode.

(2)

Shift Staffing - The inspectors

verified that operating shift

staffing

was

in

accordance

with

TS

requirements

and that

control

room operations

were being conducted

in an orderly and

professional

manner.

In addition,

the inspector

observed shift

turnovers

on various

occasions

to verify the continuity of

plant status,

operations

problems,

and other pertinent plant

information during these turnovers.

(3)

Plant

Housekeeping

Conditions

-

Storage

of material

and

components,

and

cleanliness

conditions

of various

areas

throughout

the facility were

observed

to determine

whether

. safety and/or fire hazards

existed.

(4)

Radiological

Protection

Program - Radiation protection control

activities

were

observed

routinely to verify that

these

activities

were in conformance

with the facility policies

and

procedures,

and

in compliance

with regulatory

requirements.

The inspectors

also

reviewed selected

RWPs to verify that the

RWP was current

and that the controls were adequate.

(5)

Security Control - In the course of the monthly activities, the

inspector

included

a review of the licensee's

physical security

program.

The

performance

of various shifts of the security

force

was

observed

in the

conduct

of daily activities to

include:

protected

and vital area

access

controls;

searching

of personnel,

packages,

and

vehicles;

badge

issuance

and

retrieval;

escorting

of visitors; patrols;

and

compensatory

posts.

In addition,

the inspectors

observed

the operational

stIKs of CCTV monitors,

the Intrusion Detection

system in the

central

and

secondary

alarm stations,

protected

area lighting,

protected

and vital

area barrier integrity,

and the security

organization interface with operations

and maintenance.

(6)

Fire Protection

- Fire protection activities,

staffing

and

equipment

were

observed

to verify that fire brigade staffing

was appropriate

and that fire alarms,

extinguishing

equipment,

actuating

controls,

fire

fighting

equipment,

emergency

equipment,

and fire barriers

were operable.

No violations or deviations

were identified.

3.

Surveillance

Observation

(61726)

Surveillance

tests

were observed

to verify that approved

procedures

were

being

used;

qualified personnel

were

conducting

the tests;

tests

were

adequate

to verify equipment

operability;

calibrated

equipment

was

utilized; and

TS requirements

were followed.

The following tests

were observed

and/or data reviewed:

OST-1026

OST-1038

OST-1044

OST-1506

Reactor Coolant System

Leakage

Sampling,

Chemical Addition, and Main Steam Drain Systems

ISI Valve Test

ESFAS Train "A" Slave Relay Test

Reactor Coolant System Isolation Valve Leak Test

The inspectors

reviewed

the licensee's

program established

for scheduling

surveillance

testing

(procedure

PLP-103,

Surveillance

and Periodic Test

Program)

and discussed

program

requirements

with licensee

personnel.

A

computer ized

system is

employed

to schedule

surveillance testing.

This

system

is utilized to

generate

a weekly test

summary

of scheduled

surveillance tests for the next four-week period which is distributed to

area

managers

each

week.

Also,

a Daily Batch Report is generated

which

identifies all

surveillance

tests

which

are

past

due,

overdue,

or

completed

with exceptions.

The

system

computes

the

due date for any

surveillance

test

based

on

the

date

or

date

scheduled,

whichever

is earlier,

followed

by

an

overdue

date

which

includes

any extensions

authorized

by the

TS.

Any tests

not completed

within three 'days

of the

overdue

date

receive

additional

management

attention in the morning management

meeting

and are published in a Daily

Immediate

Attention List.

The

computer

data

base

is maintained

by

compliance

personnel

to reflect

changes

in procedures,

TS,

and plant

modifications.

An audit of the data

base

is performed annually.

The

computerized

data

base

and

established

administrative

controls

are

considered

to be

a program strength.

The

computerized

system

discussed

above

only applies

to surveillance

tests

with a longer frequency

than three

days.

More frequent tests

and

event related

tests

are

scheduled

independently

by area

managers.

The

inspectors

rCVTewed the 'operations

department

method for scheduling daily

surveillances

and discussed

this method with operations

personnel.

Oaily

surveillances

are

scheduled

at

specific

times

during

the

day for

accomplishment.

A list of the required tests

is maintained

by the shift

foremen

and this list is annotated

for test completions.

Event related

tests

are

scheduled

within separate

procedures

(annunciator

response

procedures

or operating

procedures)

that pertain to'he specific event.

4.

Maintenance

Observation

(62703)

The inspectors

observed/reviewed

maintenance

activities to verify that

correct

equipment

clearances

were

in effect;

work requests

and fire

prevention

work permits,

as

required,

were

issued

and

being followed;

quality control

personnel

were available for inspection activities

as

required;

and,

TS requirements

were being followed.

Maintenance

was

observed

and

work

packages

were

reviewed

for the

following maintenance

(WR/JO) activities:

Replace

motor bearings

and realign the

"A" main feedwater

pump in

accordance

with procedure

CMM-0133, Main Feed

Pump Motor.

Replace

thermal

overload

devices for the

"B" emergency

screen

wash

pump.

Replace

reed switch indication for valve

1SP-916

in accordance

with

procedure

MPT-I0019, Target

Rock Valve Inspection

and Refurbishment.

Adjustment of packing for valve 1SI-l.

Repair rotating element for the "8" emergency

screen

wash

pump.

No violations or deviations

were identified.

5.

Review of Licensee

Event Reports

(92700)

The following LERs were reviewed for potential

generic

impact, to detect

trends,

and to determine

whether corrective actions

appeared

appropriate.

Events that were reported

immediately were reviewed

as they occurred

to

determine if the

TS were satisfied.

LERs were reviewed in accordance

with the current

NRC Enforcement Policy.

a.

(Closed)

LER 90-02:

This

LER reported

that

the

gPTR

was

not

verified within limits while the monitoring alarm

was

inoperable.

This

event

was

previously

discussed

in

NRC

Inspection

Report

50-400/90-02

and

was

the subject

of

a violation (400/90-02-02).

Further action

on this matter will be tracked

by the violation.

b.

(Open)

LER 90-03:

This

LER reported

that

a train of essential

services

chilled water

was inoperable

due to air intrusion into the

co

system.

This

LER will remain

open

pending

completion of the

corrective

actions

as stated

in the

LER.

(Closed)

LER 90-04:

This

LER reported

a missed

leak rate evaluation

which

was

caused

by

a

procedure

deficiency.

This event

occurred

February

27,

1990,

when the plant computer,

which provides

an alarm

upon excessive

leakage,

failed.

Without the computer,

the licensee's

procedures

require hourly manual

logging of indicated

sump level

and

evaluation

of

sump

level, leakrate.

Plant

operators

failed to

evaluate

the

leakage within the

one

hour time

span for two hourly

intervals.

On

March

28,

the plant

computer failed again

and plant operators

failed to comply with requirements

for evaluation of sump leakrate.

The

licensee's

corrective

action for these

two events

included

revising the applicable

annunciator

response

procedure

APP-ALB-001,

Main Control

Board, to incorporate

the r'equirements

and appropriate

cautions

for performing

the

manual

logging of

sump

leakage

and

training operations

personnel

on the procedure

change.

Although this

action

was in progress

after the first event occurred, it was not

completed in time to prevent the second

event

on March 28.

d.

(Open)

LER 90-05:

This

LER reported

an engineered

safety

system

actuation

due to

a radiation monitor spike

caused

by

a loose

connection.

The

licensee

plans

to

revise

surveillance

test

procedure

MST-I0356,

Containment

Atmosphere

- Reactor

Coolant

Leak

Detection

Monitor Operational

Test,

to delete

requirements

for

disconnection

of the coaxial

cable

where

the

loose

connection

was

found.

This

LER will remain

open pending completion of this action.

e.

(Open)

LER 90-06:

This

LER reported

the operation of the plant in

an unanalyzed

condition with waste

gas

decay

tanks

cross

connected.

This

matter

was

previously

discussed

in

NRC

Inspection

Report

50-400/90-04

and

was

the subject of an IFI (90-04-04).

This

LER

will remain

open

pending

completion of the corrective actions

as

stated

in the

LER.

6.

Review of Nonconformance

Reports

(71707)

Significant

Operational

Occurrence

Reports

(SOORs)

and

Nonconformance

Reports

(NCRs)

were reviewed to verify the following:

TS were complied

with, corrective actions

as identified in the reports

were accomplished

or

being

pursued

for completion,

generic

items

were identified

and

reported,

and items were reported

as required

by the TS.

a.

SOOR

90-44

reported

that

a

120 volt

AC electrical

conductor

overcurrent

protective

device

was

inadequate.

As

discussed

in the

FSAR,

section

8.3. 1. 1.2. 15,

these circuits are

typically provided with two protective devices;

either

two circuit

breakers

in series,

or

a circuit breaker

in series

with

a fuse.

Lfcense~ngineering

personnel

discovered this discrepancy

during

a

comparison of surveillance test

procedures

with engineering calcula-

tions.

During the

comparison,

engineering

personnel

noticed that

penetration circuit PP-1B311

(SB)

had

a

30

amp breaker installed

as

the secondary

overcurrent protective device in series with a six amp

fuse installed

as the primary overcurrent protective device.

It was

determined

that the existing

30

amp breaker did not provide sufficient

protection

against

instantaneous

short circuit current to prevent

damage

to the penetration.

The configuration presented

in the

FSAR,

section 8.3. 1. 1.2.15

and figure 8.3. 1-10, includes

a bounding case of

a

15

amp breaker

in series

with

a

20

amp

fuse for

120 volt AC

electrical

penetrations.

The licensee's initial investigation into

this event determined that the

30

amp breaker

had

been installed in

the circuit during initial plant construction.

Upon notification of this condition,

operations

personnel

declared

the

electrical

and

implemented

the

requirements

of the

TS.

Plant modification

PCR-5157,

Secondary

Protection

to

ARP-19

Penetration

Circuits,

was

implemented

to

install

20

amp

fuses

in series

with the six

amp fuses.

This

modification

was

completed

on

March

19

and

the

was

subsequently

declared

operable.

This matter is considered

to be

a

licensee

identified

and is not being cited

because

criteria

specified

in section

V.G. 1 of the

NRC

Enforcement

Policy were

satisfied.

(90-06-01):

Failure

to maintain

an

conductor protective

device.

SOOR

90-45 reported that the post maintenance

testing

performed

on

spent fuel pool containment isolation valve 1SP-916

was not adequate.

During the

performance

of

a surveillance test

on March

15,

1990,

valve

1SP-916 failed to provide full closed indication.

The valve

was

declared

and

priority/emergency

maintenance

was

authorized

by the shift foreman to repair the valve.

The licensee's

procedures

allow this type of maintenance

to be performed without the

usual

preplanning

and documentation,

provided that the documentation

is followed up and reviewed afterwards.

At 3:05 a.m.,

on March

16,

the valve limit switch was replaced

to

correct the valve indication problem.

A cycling test

and verification

of isolation time was

performed

as post maintenance

testing

and the

valve was declared

operable.

Later on March 16, the work request

was

generated

and

reviewed

to determine

appropriate

post

maintenance

testing.

This

review determined

that

performance

of

a

Type

C

containment

leak rate test

was also required prior to considering

the

valve operable.

Subsequent

reviews of the generated

work request for

completion signatures

by maintenance

and operations

personnel

failed

to detect

the required additional

post maintenance

test.

On March

22, licensee

i nservice testing

personnel

reviewed the completed work

request

and noticed that all post maintenance

testing

had not been

performed.

The lienee's

administrative

controls

established

for inoperable

equipment

(procedure

OMM-3, Equipment

Inoperable

Record)

specifies

that prior to declaring

equipment

operable,

the required

post maintenance

testing

must

be completed.

Failure to complete the

Type

C containment

leakrate test prior to declaring

valve

1SP-916

is contrary to the requirements'f

procedure

OMM-3 and is

considered

to be

a violation.

Violation (400/90-06-02):

Failure

to

complete

post

maintenance

testing prior to returning inoperable

equipment to service.

The licensee

has

recently

experienced

problems with performance

of

priority/emergency

work.

In

NRC Inspection

Report 50-400/89-34

the

licensee

was

issued

a violation for failing to generate

a work

request

(89-34-02,

example 2).

The licensee attributed the cause for

this nonconformance

to be due to a lack of familiarity on the part of

plant operators

with priority/emergency

work requirements.

Apparently

the licensee's

corrective action for that violation was not completely

effective

and this area is still considered

weak.

SOOR

90-57

reported

that following work

on valve

1SI-1,

boron

injection

tank inlet isolation valve,

required

post

maintenance

testing

was not performed.

On March 22,

1990,

packing

was adjusted

on

valve

1SI-1

to

stop

leakage.

The

work request

for this

maintenance

stipulated

that

a

stroke

timing test

be

performed

following maintenance.

However,

the valve

was

declared

without completing the required

post maintenance

testing.

Following

additional

reviews of the completed

work request,

licensee

personnel

identified the missed testing

on April 9,

and the appropriate test

was

subsequently

performed.

This matter is considered

to be another

example of the violation discussed

in paragraph

6.b of this report.

SOOR 90-54 reported that

an individual's

exposure

was not reported

as

required.

On

Oecember

15,

1989, following the termination of

employment

of

a contracted

security officer,

no report of this

individual's exposure

was

made to the

NRC or to the individual within

30 days

as required

by

10 CFR 20.408

and

10 CFR 20.409.

Licensee

personnel

discovered this during routine issuance

of the individual's

dosimetry

on April 3,

1990.

The licensee's

corrective action will

consist of revising administrative controls for terminating contract

employees

to include

contracted

security

personnel.

This is

a

licensee

identified

and is not being cited

because

criteria

specified

in section

V.G. 1 of the

NRC

Enforcement

Policy were

satisfied.

(90-06-03):

Failure

to report

an individual's radiation

exposure

upon termination.

7.

Follow=up of~site

Events

(93702)

a ~

b.

On April 5,

1990,

the licensee

indicated that valve 1SI-359,

RHR

hot leg recirculation valve to the

RCS,

was operated

on February

13,

1990 without the subsequent

performance of a leakage verification as

required

by

TS 4.4.6.2.2.d for isolation valves

associated

with the

RCS.

The licensee

declared

the untested

valve inoperable at 1:00 p.m.

and

complied with the action requirements

of

TS 3.4.6.2.c.

Valve

leakage

was

subsequently

verified within limits by 4:30

p.m.

on

April 5.

This matter

was identified by the licensee

during

a review of the

IST program.

The inspectors

discussed

this matter with licensee

personnel

and discovered that the valve was routinely operated

once

a

quarter in accordance

with the licensee's

IST program,

since

March

1987, yet

no

leakage

verifications

were

performed following these

valve operations.

The inspectors

counted

approximately

13 valve

operations after which no leakage verification had

been performed.

Although this matter

was identified

by the licensee, it is being

cited

due

to the failure of licensee

personnel

to identify the

problem for approximately

three years

even

though there

was

ample

opportunity to do so.

Violation (90-06-04):

Failure to verify valve

leakage

following

operation of valve 1SI-359.

During the performance of procedure

OST-1124

on April 15,

1990,

the

supply

breaker

to the 6.9

KV emergency

bus

inadvertantly

opened

deenergizing

the

bus.

This condition resulted

in the automatic

actuation

of the

emergency

diesel

generator

on

a

bus

undervoltage

condition.

The emergency

diesel

generator

operated

as

designed

and

reenergized

the bus loads.

Upon loss of bus

power,

containment isolation valves associated

with

radiation monitor

REM-3502 A, Containment

Leak Detector, lost power

and closed.

This action resulted in a loss of process

flow into the

monitor

and

caused

the monitor to alarm

which resulted

in the

automatic isolation of the containment

purge system.

Similar events

were reported

by the licensee

in LERs 88-13 and 88-35

and are discussed

in

NRC Inspection Report 50-400/88-40.

The licensee

is presently investigating

why this event reoccurred.

IFI (90-06-05):

Review the licensee's

investigation into the cause

for repeated

loss of power to the "A" emergency

bus while performing

undervoltage testing.

,

Verification~ Quality .Assurance

Regarding

Diesel

Fuel

(71707)

(Closed)

TI 2515/93:

The inspector verified that the licensee

included

the

emergency

DG fuel oil in its Quality Assurance

Program.

A review of

the

licensee's

fuel oil purchasing

specification

sheet

and

fuel oil

analysis

sheet,

was performed.

The results of this inspection acceptable

and this item is considered

closed.

9.

Licensee

Action

on Previously Identified Inspection

Findings

(92702

&

92701)

(Closed) Violation 89-34-01,

Failure to perform surveillance testing

for an inoperable

emergency

diesel

generator.

The inspector

reviewed

and verified implementation of the corrective

actions

as stated in the licensee's

response letter dated

February

26,

1990.

b.

c ~

(Open) Violation 89-34-02,

Failure to adhere

to the requirements

of

plant procedures.

The inspector

reviewed

and verified implementation of the corrective

actions

as

stated

in the licensee's

response

letter

dated

March 2,

1990.

Action remaining to

be accomplished

on this matter includes

the revision of procedure

OST-1804,

RHR Remote Position Indication

and

Timing,

and other

procedures

to include appropriate

cautions

when

RWST suction

valves

are

cycled.

This action is

due to

be

completed

December

31,

1990.

(Closed)

Violation 88-33-01,

Failure

to follow approved fire,

protection procedures.

The inspector

reviewed

and verified implementation of the corrective

actions

as stated in the licensee's

response letter dated

November 29,

1988.

d.

e.

(Closed)

IFI 88-33-02,

Concern

with licensee

using

compensatory

measures

to meet the fire protection program.

The licensee

has

reduced

the

number of circumstances

requiring the

use of compensating

fire watches

by

a factor of approximatesly

two-thirds.

A 100 percent

inspection of fire bar rier penetrations

was also completed

and discrepancies

corrected.

(Closed)

IFI 90-04-04,

Review the licensee's

corrective action to

prevent cross connection of waste

gas

decay tanks.

The licensee

has

issued

LER 90-06

on this event documenting corrective

actions

taken to prevent

recurrence.

For record

purposes,

the IFI

will be closed

and future action tracked

by the LER.

10

Exit Intervi@F (30703)

The inspectors

met with licensee

representatives

(denoted in paragraph

1)

at the conclusion of the inspection

on April 20,

1990.

During this

meeting,

the

inspectors

summarized

the

scope

and

findings of the

inspection

as they are detailed in this report, with particular emphasis

on the Violations

and

Inspector

Follow-up item addressed

below.

The

licensee

representatives

acknowledged

the inspector's

comments

and did

not identify as proprietary

any of the materials

provided to or reviewed

by the inspectors

during this inspection.

Item Number

Descri tion and Reference

90-06-01

90-06-02

90-06-03

90-06-04

90-06-05

NCV:

Failure to maintain

an

conductor protective device,

paragraph

6.a.

VIO:

Failure to complete

post

maintenance

testing

prior to returning

equipment

to service,

paragraphs

6.b and 6.c.

NCV:

Failure to report

an individual's radiation

exposure

upon termination,

paragraph

6.d.

VIO:

Failure

to verify valve

leakage

following

operation of valve 1SI-359,

paragraph

7.a.

IFI:

Review the licensee's

investigation

into the

cause for repeated

loss of power to the "A" emergency

bus while performing undervoltage

testing,

paragraph

7.b.

Acronyms

and Initialisms

AC

ALB

APP

ARP

CCTV

CFR

CMM

IFI

KV

LER

MPT

MST

NCR