ML18057B455
| ML18057B455 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/27/1991 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B453 | List: |
| References | |
| 50-255-91-24, NUDOCS 9201070029 | |
| Download: ML18057B455 (15) | |
See also: IR 05000255/1991024
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91024(DRP)
Docket No. 50-255
Licensee: Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
License No. DPR-20
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
-
Inspection Conducted:
November 5 *through December 16; 1991
Inspectors:
Heller
2A
Approved By:
DATE
1
ection Summar
pection from November 5 through December 16, 1991
(Report No. 50-
255/91024 (DRP))
- Areas Inspected:
Routine unannounced safety inspection by resident .
inspectors of* actions on previously identified items, operational safety
verification, reactor trips, maintenance, outages, and quality program
activities.
No Safety Issues Management system {.SIMS) items were
reviewed.
Results: Of t~e six areas inspected, no violations or deviations ~ere
identified in five a~eas. *One violation wa~ identified (failure to
document bases that an unreviewed environmental question does not exist
Paragraph 7) in the remaining area.
Strengths, weaknesses and open items are discussed in paragraph 9;
"Management Interview." .In summary, strengths were identified in a
conservative operating philosophy, in open communications, in strong
technical documentation to support resolution of an engineering problem;
in control room leadership, in well planned maintenance activities, and in
outage preparations.
Weaknesses were noted in the lack of a complete
response to a Notice of Violation, in plant reliance on an offsite group
to determ.i,ne*Technical Specification .applicability, in component
identifiers not matching checklist description, in the lack of a screening
mechanism £or maintenance activities which could expand the cold-weather
protection envelope, and in poor coordination of the emergency down-power
event that occurred on December 9, 1991 .
9201070029 911227
ADOCK 05000255
Q
1.
DETAILS
Persons Contacted
Consumers Power Company
- G.
- R.
- P.
- K.
J.
R.
- K.
- J.
- R.
- L.
D.
c.
w.
R.
K.
- T.
B.
M.
M.
M.
L.
B.
E.
L.
D.
D.
s.
L.
w.
A.
J.
Slade, Plant General Manager
Rice, Plant Operations Manager
Donnelly, Safety & Licensing Director
Haas, Radiological Services Manager
Hanson, Operations superintendent
Kasper, Maintenance Superintendent
Osborne, System Engineering Superintendent
Kuemin, Licensing Administrator
Orosz, Engineering and.Constrtiction Manager
Morse," Licensing Clerk *
Hice, Chemistry Superintendent
Kozup, Technical Engineer
Roberts, Senior Licensing Analyst
Smedley~ Staff Licensing Engineer
Toner, Electrical/I&C/Computer Engineering Manager
Palmisano, *Administrative & Planning Manager
Nuclear Regulatory Commission (NRC)
- w. D. Shafer, Chief, Reactor Projects Branch 2
B. L. Jorgensen, Chief, Reactor Proj.ects Section 2A
- J. K. Heller, Senior Resident Inspector
- J. R. Roton, Resident Inspector
Denotes some of those present at the Management Interview on
December 18, 1991.
Other members of the plant staff and several members of the contract
security force were also contacted. during the inspection period.
- 2.
Actions on Previously Identified Items (92701, 92702)
- (Open) Violation 255/91017-l(DRP): _Inoperability of Containment Spray
Pump.
The licensee response of December 9, 1991, did not provide the .
information requested by the Notice of Violation.
For example, the
letter did not admit or deny the violation, the cover letter did not
state "Reply to a Notice of Violation", it was not addressed to the
correct person, and the response pertaining to testing components
after installation of .a breaker and fuse was not consistent with the
information provided at the enforcement conference and to the
inspector during the inspection.
These discrepancies were verbally
2
provided to the licensee on December 12.
revised response dated December 1.4.
The licensee submitted a
No.violations, deviations, unresolved or open items were identified.
3.
Operational.Safety Verification (71707, *71710, 71714, 42700)
Routine facility operating activities were observed as* conducted in
the plant and from the main control room.
Plant startup, steady
power operation, plant shutdown, and system lineup and operation were
ob~erved as applicable.
The performance of reactor operators and senior reactor operators',
shift engineers, and auxiliary equipment operators was observed and
evaluated.
Included in the review were procedure use and adherence,
records and logs, communications, shift/duty turnover, the degree.of
professionalism of control room activities, ~nd performance during a:
plant transient.
a.
General
The* plant began the inspection period at essentially full power.
During the reporting period the unit was derated to
approximately 35 percent power from November 5 through 9, to
resolve condenser tube leakage. The unit was offline from
December 9 through 14, to resolve problems with the turbine-
generator seal oil system.
The plant ended the reporting period
at essentially full power.
b.
Turbine Driven Auxi'liary Feedwater Pump.Inoperable
On N_ovember 13, CV-0521, "Alternate Steam Supply to the Turbine
Driven Auxiliary Feedwater (TDAFW) Pump," failed to stroke open
during a surveillance test.
The valve and the TDAFW pump were
declared inoperable.
Subsequent attempts to open the valve by
.normal means were successful.
The valve stem was lubricated and
an internal corrective.action document (D-PAL-91-187) was
written to evaluate the problem.
The preliminary evaluation of
D-PAL-91-187 determined that the valve was operable based on the
maintenance performed and successful stroking of the valve.
This. evaluation reviewed historical valve performance, which did
not identify any negative trends .. The evaluation did raise the
question*of valve reliability.
To address this question, the
valve was placed on increased stroking frequency (daily and
weekly) until root cause analysis was completed.
The licensee completed a week of daily stroke timing on *t.he
valve ?nd had reduced to weekly stroke testing when the valve
failed to stroke a second time.* The valve and TDAFW pump were
declared inoperable.
While the maintenance department attempted
to open the valve, the Plant Review Committee (PRC) evaluated
3
the problem and considered the available options.
The
maintenance department was able to open the valve by light~y
tapping the top of the stem.
The valve was successfully
stroked, the actuating air pressure increased and the valve
placed on a daily stroking frequency until the next outage.
The
licensee has not been able to determine the root cause and it is
not likely that the root cause will be determined prior to the
- outage.
The inspector discussed the following items with members of the
plant staff.
(1)
(2)
The inoperability of the TDAFW pump was discussed with the *
Operations superintendent and the Director of Safety and
Licensing.
The inspector concluded that th~ decision to
- declare the-TDAFW pump inoperable demonstrated a
.
conservative operating philosophy.
This conclusion was
based on these facts: the other steam supply valve (CV-
OS22B) receives the auto-open signal ~nd was operable; the
operation of CV-0521 was not directly discussed in the
FSAR; no credit was taken in an accident analysis; and the
Technical Specification does not directly discuss
operability. of CV-0521..
The use of mechanical force to open the valve was discussed
with-the Maintenance Superintendent and the Safeguards
System Engineering Section Supervisor.
Both stated that
the mechanical force was minimal arid use of mechanical
force to assist component operation in lieu of corrective
maintenance was not a tolerated practice.
The use and type
of force was documented on the work order and freely
communfcated to plant management.
In addition,. the
applicable Work Order (WO 24105346) clearly identified the*
need to use torce to open the valve. *
\\
The general topic of applying force to assist component
operation and lessons learned at other plants was discussed
at the Management Interview .
. (3)
The corrective actions taken, which consisted of increasing
the actuating air pressure and increasing the valve
stroking frequency, were discussed with members of the
plant staff. All stated that these were interim corrective
measures untii the plant was piaced in a mode that
permitted repair of CV-0521.
The inspector considered enforcement action for failure to take
appropriate corrective action when the valve failed to *stroke
the first time. The inspector does not consider enforcement
action appropriate at this time based on the detailed
documentation contained in D-PAL-91-187.
The documentation
4
c.
d.
included a fault tree analysis of the potential fault paths and
- a reason for not considering a fault path.
Control Room Observations
On December.14, the inspector observed control room personnel
taking the reactor critical through the p'oint of adding heat.
The shift supervisor displayed a strong command presence and a *
high degree of professionalism.
The inspector *noted that *
although the-Operations Superintendent and the Operations
Manager where present throughout the evolution, they remained in
the background allowing the Shift Supervisor uninhibited controi
and.direction of the evolution~ In addition, the inspector
observed the performance of a recently licensed operator
performing the. rod w.ithdrawal steps. *
The manner in which other
members of the shift provided insights and recommendations,
based OI) their experience, Was noteworthy.
50.72 Notifications
During power escalation on December 15, the licensee added
additional non-safety related loads to non-safety related bus
"lE" which caused undervoltage relays to activate on the "lC"
and "lD" safety related busses.
The non-safety related bus and
the safety related busses are fed from a common safeguards bus.
The undervoltage was sensed by both safety related busses and
subsequently caused the auto-start of poth diesel generators.
This undervoltage condition was not' of sufficient duration to
activate the load shed sequencers.
The licensee secured the
diesel generators and continued with the power escalation.
The
~ystem was designed such that undervoltage sensed on either
safety related bus would cause an auto start of both diesel
generators.
Initial reports indicated that the plant electrical loads may
.have been lined-up in an unusual condition.
Subsequent reviews
determined that whil.e the safety related busses wer.e unevenly
loaded, the electrical lineup was not unusual.
The inspector had no additional questions concerning this event.
Additional reviews will be performed when the LER is issued.
In
addition, the li~ensee was informed that Region III Division of
React.or Safety inspection specialists* are reviewing this item.
e.
System Walkdowns
The inspector verified operability of the systems listed below
by using the applicable checklist and confirming that major
flowpath valves were in their correct position.
No items were
found that degraded the systems .
5
(1)
Diesel Generators, *cL No. 22.1
(2)
Feedwater System, *cL No. 12 .1.
The inspector found this checkli_st to be difficult to
utilize.
Valve designators had been ch.anged without
revising the checklist.
The checklist was last reviewed on
May 27, 198.8, and is not due *for its next periodic review
until May 1993.
Due to the seemingly large number of
system designator changes, the inspector indicated _that an
earlier review may be prudent.
(3)
Main Turbine Electro-Hydraulic Oil System, CL No. 8.1
( 4 ).
Engineered Safeguards System Iodine Removal
Instrumentation, CL No~ 3.7
f.
. Cold Weather Preparations
The inspector reviewed* the licensee cold weather protective
measures program.
The program consisted of two operating
checklists - CL-CWCL-1, "Cold Weather Checklist," and CL-CWCL-2,
"Cold Weather Checklist (Electrical)" - which are scheduled
annually.
Each checklist has a thirty day completion window.
The inspector conducted walkdowns of Cl-CWCL-1 and.CL-CWCL-2.
There were no significant problems identified; however, .there
was no formal feedback mechanism to ensure that systems which
have been subjected to maintenance and/or modification during
the past year are considered for-cold weather preparations.
This was discussed at the Management Interview.
g.
Tours
During tour.s of the auxiliary building with two members of NRC
Region III Management, the number and method of control of the
yellow plastic catches used to control the f lowpath of
potentially contaminated liquid was discussed with the Radiation
Protection staff. It was determined that the number of catches
was small and an informal method of control wasappropria:te for
now.
The staff was able to identify those that were in-place
for contamination control because a piece of equipment was
leaking and scheduled for repair; and those that were in-place
because boric acid had been. cleared from-the component and an
evaluation was underway to determine if leaking was present and
a repair was necessary.
There were a couple of catches in-place.
to control the condensation from room coolers. It is *
appropriate to control the condensation in this manner, however,.
if this is a. long term problem th.en a permanently installed drip
pan may be more appropriate.
This was discussed at the
Management Interview.
6
- *
No violations, deviations, unresolved or open items were identified.
4.
Reactor Trip (93702)
The unit was removed from service at 5:22 p.m. on December 9, 1991,
when the air side turbine~generator seal oil system failed resulting
in a reduction of generator hydrogen pressure.
a.
Power Reduction
At approximately 4:30 p.m. an Auxiliary Operator noted that
turbine-generator seal oil pressure was decreasing.
Automatic
attempts by the backup seal oii system and manual intervention
by the Auxiliary Operator, as directed by the Shift Supervisor,
failed to stabilize the decreasing pressure.
The Shift
Supervisor ordered an emergency power reduction at 5:14 p.m.
The power reduction was successful, in that power was reduced
from 100 percent to approximately 20 percent in 10 minutes
without the activation of any automatic trips.
However, as
evidenced by the mismatch between turbine and reactor power -
which resulted in two reductions of the Primary Coolant System
Temperature below the minimum temperature for criticality - the
evolution was not well coordinated.
Additionally, the power
reduction was hampered by slow movement of control rod drive .
number 36.
This drive lagged the other control rods in the
group resulting in additional manipul~tions by the operator.
At approximately 5:25 p.m., the operators observed and
confirmed thatthe water level for the "B" Steam Generator
was above the auto isolation setpoint for main f eedwater
and approaching the manual trip setpoint; the operators
initiated a reactor and turbine trip.
The turbine trip was
activated before the reactor trip, resulting in an
automatic reactor trip due to loss-of-load with the reactor
above the loss-of-load setpoint.
b.
Unusual Event
At approximately 5:35 p.m., the Shift Supervisor declared an
Unusual Event because of the potential for explosive quantities
of hydrogen gas in the turbine building.
The Unusual Event was
secured at 12:50 a.m. on December 10, after the generator_had
been purged with carbon dioxide.
During the Unusual Event, the
turbine building was checked for explosive concentrations of
hydrogen; none were found.
In addition, turbine building
ventilation was increased to minimize the risk of explosion due
to hydrogen buildup.
The written statement from the Auxiliary Operator in the
safeguards room, at the time the Unusual Event was announced,
indicated that he did not hear the announcement and was unaware
7
._.
c ..
that an Unusual Event was declared.
Coinmunication problems due
to high noise level were the subject of IEB 79-18.
Discussion
with the NRC Region III Emergency Preparedness Staff identified
the need for an Open Item for a Region III Emergency
Preparedness.specialist to review the licensee program for in-
plant communication (Open Item 255/91024-0l(DRSS)).*
Post Trip Review
(1)
{2)
The post trip review indicated that a number of equipment
problems occurred during the trip.
None hindered the plant
response or the operators' ability to recover from the
trip.
However, they* did raise the frustration level in the
control room which could.have an indirect effect on the
operators' ability to respond.
In addition to the problems
- already discuss~d, the control room annunciator chime
malfunctioned, the offsi_te communicator auto-dialer
malfunctioned, and the telephone number to the power
controller resulted in a recording providing additional
numbers to call.
The post.trip review identified that the two backup trip
breakers failed to open when the associated trip push
button was pushed.
The primary trip contactors did open
- when activated by the reactor.protective system.
Pushing
the. backup trip breaker push button is a post trip
checkl_ist requirement.
Performance of this step wa*s
documented.
Later, because of the sequencing of a startup
surveillance test, the final step of tpe post trip
checklist (which verified the status of the trip breakers)
was not performed but was marked "N/A*".
The surveillance
procedure that was in progress required reset of the
reactor protective system.
In this case, the checklist
step was marked "N/A" because the breakers were closed to.
perform the test.
During a subsequent test, which'
concluded by opening the backup trip breakers, it was
discovered that one of the breakers did not open when the
push button was pressed.
Based on this information and
interviews conducted with the operators onshift during the
trip, the licensee concluded that both of the trip breakers
did not open.
This conclusion w~s based on information
obtained from the operator who stated he reset the reactor
protective system to perform the first surveillance test
without resetting the backup trip breakers *. The licensee's
investigation traced the problem to the push button, which
required a steady push to assure proper make up of the
internal contacts.
This information was provided, as part
of the shift turnover, to oncoming operators prior to
assuming the watch.
In addition, the licensee placed an
operator aid on the control panel next to the switch .
8
d.
Seal Oil
The licensee investigation of the air-side generator hydrogen
seal-oil: system determined that an in-line seal-oil filter
became clogged and resulted in a reduction in seal-oil pressure.
This conclusion was' based on the fact that the backup system
functioned properly and attempts to rotate the filter, after the
trip, were unsuccessful.
This type of filter is manually
rotated once a shift to clean the internal-filter surface.
In
.addition, the licensee performed an air test of the generator
shaft seal to confirm its integrity.
e.
CRDM 36
During the power reduction, the movement of CROM 36 was slow,
resulting in manual operation by _the control room operator, to
keep the' rod within the group.
The -problem w'as attribut~d to
the drive package and it was replaced. *The required trip time
of the rod-was subsequently verified and found to be
satisfactory.
The inspector has reviewed' the post trip information and verified
that the problems were resolved prior to returning the plant to
service.
The inspectors have no additional questions at this time.
Additional reviews will be performed when the-10 CFR 50.73, "Licensee
Event Report" is issued .
. one open item and no violations, deviations, or unresolved items were
identified.
-
5.
Maintenance (627031 42700)
Maintenance activities-in the plant were routinely inspected,
including both co~rective maintenance (repairs) and preventive
maintenance.
Mechanical~ electrical, and instrument and control
group maintenance activities were included as available.
The Inspector verified that Limiting Conditions for Operation were
met while components or systems were removed from service, approvals
were obtained prior to initiating the work, activities were
accomplished using approved procedures, and post maintenance testing
was performed as applicable.
The following work order (WO) activities were observed:
a.
WO 24100421:
Diesel Generator K-6B Fuel Oil Pressure switch.
b.
WO 24104033: K-6B Starting Air Pressure Switch Incorrectly
Piped.
c.
WO 24104034:
K~6B Starting Air Pressure Switch Incorrectly
9
- d.
Piped.
WO 24104056 :_
Replace 18 Fuel Pump Cover Gaskets on Diesel
Generator 1-2.
e.
wo* 24104462: *swap Fuel Pumps, Cylinder 7L with 2R,.on Diesel
Ge;nerator 1-2.
f.
WO 24103212:
Preventive Maintenance on Diesel Generator 1-2 Air
Compressor.
g.
h.
i.
WO 24102666:
Preventive Maintenance on Diesel Generator 1-2 A/C
Backup Gasoline Engine.
WO 24102096: *Replace Band Clamp on Air Inlet Pipe/Turbo Charger
on Diesel Generator 1-2.
WO 24104114:
Multi-009 Group, K-6B Air Start Motor Starting Air
Instrumentation.
For several of* the wos listed above, the inspector noted that the
mechanics or technicians involved in the_repair or maintenance
activity demonstrated a thorough understanding of the procedure.
The
procedures were clear and concise as to the work to be performed.
Tools and other documentation required to complete the task appeared
to be staged at the.job site indicating a. detailed pre-job review of
the work order was performed prior to starting the job.
j.
WO 24105743 and Specification Change 91-77:
E-50A Upper East
Handhole Leak.
During a containment tour on December 12, the licensee observed
a steam leak at a secondary side handhole for the "A" steam
generator.
The leak was caused by imp~oper installation of a
handhole cover, resulting in a non-uniform gap between the cover
and the flange.
The steam leak was from the gasket and did not
affect the integrity of the flange, cover, or fasteners.
The
attempted repair included retorqueing the nuts and installation
of an enclosure that was injected with a *liquid sealant.
The
inspector concluded, after consulta_tion _with Region III and
.
NRR, that this was ah acceptable repair because the structural *
integrity of a pressure retaining boundary was not compromised
or degraded.
Because of the ambient temperature, the liquid
_sealant solidified prior to securing the steam leak.
The
licensee was able to reduce the leak by approximately one third
before concluding that additional repair attempts were
unnecessary.
The specification change was provided to Region
III specialists for additional review.
The inspector has no
additional questions at this time.
k.
wos 24101783, 24102631, 24102603: nepair steam leaks on the
10
management of the forthcoming refueling outage.
The inspector
running vent lines for the EGA and E6B Feedwater Reheaters.
The wos documented that through wall pipe leaks exist in the 3
inch running vent lines.
The temporary repair consisted of
enclosures which were injected with liquid sealant.
This
temporary form of repair was acceptable because the lines are
non-ASME code class lines. * The inspector questioned the use of
- this type.of repair because of steam line problems at other
plants.
In addition, the NRC has not generally accepted this
type.repair.
The licensee stated that the repairs were
temporary and will be removed during the next outage.
wos
24-101996, 24103059, and 24103068 were issued to make permanent
repairs during the outage.
No violati_ons I deviations I unresolved or open i terns were identified.
~--
outages (86700)
The inspector reviewed various activities associated with the project
examined the management techniques and tools utilized to ensure that;
the outage was planned* in a safe and risk~free manner.
Several
- strengths were noted during this review.
The licensee utilized
"system windows" to sequence work at the system level.
By overlaying
these system level work schedules onto various plant requirements,
such.as shutdown cooling, the licensee can determine when a system*
can be released for work without impacting plant safety.
Additionally, the licensee utilized the Artemis scheduling package
and the precedence scheduling technique.
The Artemis system is *
capable of handling large numbers of activities allowing the licensee
to schedule below the work order level.
This' allows for better work
load forecasting and resource loading.
The precedence *scheduling
technique allows the licensee.to develop schedules that reflect real
time accomplishm~nt. This a*11ows for the maximum utilization* of
limited outage time and better development of controlling path work~
No violations, deviations, unresolved or open items were identified.
7.
Quality Program Activities
Plant Procedure CH 3.42. "Betz Clam Trol 1 Treatment of Service Water.
System~"
The intent of CH 3.42 was to provide for treatment against zebra
mussel infestation and prevent blockage caused by their rampant
growth.
The inspector interviewed the author of the procedure and
reviewed the non-radiological environmental evaluation, the
unreviewed safety question evaluation,** the safety review, the *
environmental impact review and the Environmental Protection Plan.
The inspector's observations are discussed below.
11
a.
The licensee unsuccessfully treated the firewater system for
During the summer of 1991, the firewater system
was used to facilitate soil compaction of the independent spent
fuel storage installation foundation and support fire fighting
. activities at a nearby housing subdivision.
These activities
created the potential to contaminate the firewater .system with
~ebra mussels.
The firewater -system is an alte~nate source of
feedwater to the auxiliaryfeedwater pumps.
The firewater
system piping configuration to the auxiliary feedwater pumps
includes a section of piping (approximately 3 feet) which is
exposed to the elevated ambient temperature of the auxiliary
feedwater pump room. _ If a colony of zebra mussels is
established in this -- leg of piping, the colony rilay continue to
grow during the winter months because the ambient room
temperature may keep the piping and water above the zebra*
mussels_' dormant temperature.
This concern was expressed to the
licensee.
b..
The safety evaluation implied that fouling of heat exchangers
due to deceased zebra mussels will occur approximately one week
after.the treatment.
Discussions with NRC inspectors at power
plants that have dealt with zebra mussels,-- indicated that
fouling due to deceased zebra mussels may occur three weeks
after treatment.
This information was provided to the licensee~
c.
The Environmental Impact Review sheet (part of the support
documentation for .CH 3.42) requires ,an evaluation to determine
if the proposed procedure-modification resulted in an unreviewed
environmental question as defined in Section 3.1 of Appendix B,
"Palisades Environmental Protection Plan (EPP) to the Palisades
Facility Operating License."
The response was "no".
No review
comments were provided to document the bases_ for this response.-
Section 3.1 of the EPP requires an environmental review to
determine if activities which may affect the environment could
create an unreviewed environmental question.
One of *the areas
to be considered pertained to activities that were not evaluated
in the EPP and may have a sufficiently adverse environmental_
impact.
The use of Betz Clam Trol was not previously evaluated
in the EPP.
Section 3.1 also requires that records shall
include a written evaluation which provides the bases for
determining why an activity does not create an unreviewed
environmental question and does not constitute a decrease in the
effectiveness of _the EPP.
As stated above, the licensee determined that the activity did
not involve an unreviewed environmental question.
However, the
licensee did not provide a written evaluation which provided the
bases that the activity did not involve an unreviewed-
environmental question or decrease the effectiveness of the EPP.
12
Failure to include written bases is a violation of Section 3 *. 1
of the EPP.
compliance to the EPP is a requirement of the
Facility Operating License, paragraph 2.c.(2) (Violation
255/91024-02(DRP)).
- During interviews.with plant personnel, the inspector was
informed that it was not past practice to provide bases *when the
test, *change or modification was found not to constitute.an
unreviewed environmental-question.* Based on t.his information
the inspector concluded the problem was programmatic.
d.
The inspector observed that a-person or group that does not
directly report to the plant was determining compliance to the.
license as it applied to the Environmental Protection Plan ..
This was discussed with the licensee.
One violation was identified.
No deviations, unresolved or open
items were identified.
a .
Open Items
Open items are matters which have.been discussed with the licensee,
and will be reviewed further by the inspector.
These involve some
action on the part of the NRC or licensee or both.
An open item
identified during the inspection is discussed in Paragrap~ 4.b.
Management Interview
The inspectors met with licensee representatives - denoted in
Paragraph 1- -
on December 18, 1991, to discuss the scope and findings
of the inspection.
In addition, the likely informational content of
the inspection report with regard to documents or processes reviewed
by the inspectors during the inspection was also discussed.
The
licensee did not identify any such documents or processes as
proprietary.
-
Highlights of the exit interview are discussed-below:
a.
Strengths noted:
.
(1)
The licensee demonstrated a conservative operating
philosophy when dealing with the inoperable steam supply
valve to the.turbine driven auxiliary fe$dwater pump
(paragraph 3.b.(1), "Operations -Turbine Driven Auxiliary
Feedwater Pump Inoperable").
(2)
(3)
Open communication_* within the maintenance organization
(paragraph 3.b.(2), "Operations - Turbine Driven Auxiliary
Feedwater Pump Inoperable").
Strong documentation by system engineering when discussing
13
resolution of a problem (paragraph 3.b.(3), "Operations -
Turbine Driven Auxiliary Feedwater Pump Inoperable").
(4)
Control room leadership (paragraph 3.c, "Operations -
Control Room Observations").
(5)
Several examples were identified of well planned
maintenance activities and thorough understanding of
procedures and equipment by the workers (paragraph 5.i,
"Maintenance").
(6)
Scheduling of outages (paragraph 6, "Outages").
b.
- Weaknesses noted: , .
.
.
.
.
c.
d.
e.
f.
g .
(1)
The lack of completeness of a* licensee response to a Notice
of Violation.
The inspector discussed the completeness and
.accuracy requirements of 10 CFR 50. 9 (par*agraph 2, "Actions
on Previously Identified Items").
(2)
(3)
(4)
(5)
The plant reliance on an offsite group to determine the
plant compliance with a Technical Specification (Pa.ragraph
7.d, "Quality Program Activities")..
Component identifiers that do not match the checklist
description (paragraph 3 .. e. ( 2 )_, "Operations - System
Walkdowns")~
Lack of a screening mechanism to*assure that maintenance
activities or modifications do not expand the cold weather
preparations envelope (paragraph 3.f, "Operations - Cold
Weather Preparations").
Poor coordination of the emergency down power (paragraph
4.a, "~eactor Trip - Power Reduction").
The inspector discussed the Notice of. Violation (paragraph 7.c,.
"Quality Program Activities").* *
The inspector discussed the potential of flow blockage of the
emergency f eedwater to the auxiliary f eedwater pumps as the
result qf flow blockage from zebra mussels (paragraph 7.a, *
"Quality Program Activities").
The 50.72 notification was discussed.
The inspector will
perform additional reviews when the associated LER is issued
(paragraph 3.d, "Operations -
50~72 Notifications").
The open.item. pertaining to inplant communication was discussed
(paragraph 4. b, "Reactor Trip - Unusual Event") ..
. A topic that was not documented in the inspection report but was
14
discussed at the exit interview pertained to lessons learned at
another plant.
Apparently there was a return to criticality
event during a plant cooldown.
The event was not documented or
communicated to plant management.
The lesson learned pertained
to the thr~shold for documentation and communication of
problems.
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