ML20056D249
| ML20056D249 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/27/1993 |
| From: | Christensen H, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056D246 | List: |
| References | |
| 50-324-93-27, 50-325-93-27, NUDOCS 9308050141 | |
| Download: ML20056D249 (21) | |
See also: IR 05000324/1993027
Text
UNITED STATES
. [ p nt$ h o NUCLEAR REGULATORY COMMISSION
y- 'S REGION 11 i
- E 101 MARIETTA STREET, N.W.. SUITE 2900
5 :: E
ATLANTA GEORGIA 303234199
o.
%...../
Report Nos.: 50-325/93-27 and 50-324/93-27
Licensee: Carolina Power and Light Company
P. O. Box 1551
Raleigh, NC 760
Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62
Facility Name: Brunswick 1 and 2
Inspection Conducted: June 5 - July 2,1993
Lead Inspector: O. N 6 ?!E7 3 .
R. L. Prevatte, Senior TEstdent Idspector Date S'igned
Other Inspectors: G. A. Harris, Project Engineer
P. M. Byron, Resident Inspector
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R. H. Bernhard, Sr. Resident Inspector, Grand Gulf
Approved By: lu 7 7!f3-
H.O.Christensen, Chief Da'te Signed
Reactor Projects Section IA *
Division of Reactor Projects
SUMMARY
Scope:
This routine safety inspection by the resident inspectors involved the areas
of maintenance observation, surveillance observation, operational safety
verification, onsite review committee, an Engineered Safety Feature system
walkdown, and action on previous inspection findings.
Results:
In the areas inspected two violations were identified. One involved the
failure to follow procedures controlling access to the transformer yard,
paragraph 3. The other violation involved the failure to follow procedures
for controlling overtime, paragraph 4.
Two unresolved Items were identified. One was related to inadequacy of post-
modification and surveillance testing, paragraph 4. The other involved the
falsification of auxiliary operator round sheets, paragraph 4.
Also identified was a weakness involving the lack of refresher training in the !
use of infrequently used equipment, Paragraph 3. A strength was identified in
the planning and teamwork that resulted in a well executed DG No. 2
maintenance outage, Paragraph 4.
9308050141 930729
PDR ADOCK 05000324
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REPORT DETAILS
1. Persons Contacted !
Licensee Employees
- K. Ahern, Manager - Operations Support and Work Control
R. Anderson - Vice-President, Brunswick Nuclear Project
G. Barnes, Manager - Operations, Unit 1
E. Blackmon, Manager - Radwaste/ Fire Protection
- M. Brad ay, Manager - Brunswick Project Assessment
- H. Brown Plant Manager, Unit 1 (Acting)
- S. Callis - On-Site Licensing Engineer
R. Godley, Supervisor - Regulatory Compliance
- J. Heffley, Manager - Maintenance, Unit 2
- G. Hicks, Manager - Training
- C. Hinnant - Director of Site Operations
- P. Leslie, Manager - Security
- W. Levis, Manager - Regulatory Affairs (Acting) ,
R. Lopriore, Manager - Maintenance, Unit 1 '
- G. Miller, Manager - Technical Support i
- E. Northeim, Manager - Nuclear Engineering Department (Acting)
R. Poulk, Manager - License Training (Acting) :
- C. Robertson, Manager - Environmental & Radiological Control
- J. Titrington, Manager - Operations, Unit 2 l
- C. Warren, Plant Manager - Unit 2 l
G. Warriner, Manager - Control and Administration i
E. Willett, Manager - Project Management
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, office personnel and security force :
members. 3
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- Attended the exit interview.
Acronyms and initialisms used in the report are listed in the last
paragraph.
2. Maintenance Observation (62703) J
The inspectors observed maintenance activities, interviewed personnel, I
and reviewed records to verify that work was conducted in accordance
with approved procedures, Technical Specifications, and applicable
industry codes and standards. The inspectors also verified that:
redundant components were operable; administrative controls were
followed; tagouts were adequate; personnel were qualified; correct
replacements parts were used; radiological controls were proper; fire- !
protection was adequate; quality control hold points were adequate and
observed; adequate post-maintenance testing was performed; and
independent verification requirements were implemented. The inspectors .;
independently verified that selected equipment was properly returned to '
service.
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Outstanding work requests were reviewed to ensure that the licensee gave
priority to safety-related maintenance. The inspectors observed or
reviewed portions of the following maintenance activities:
PM 92-090 DG Rodofoam Removal and Upgrade of 011
Collection System
PM 92-070 Unit 1 Instrument Rack Upgrade / Replacement
WR/JO 93AISM1 1A CSW Pump Repair
WR/JO 93ASLU2 1A CSW Pump Motor Determination and
Retermination i
PM 91-047 Unit 1 Nuclear Header Inspection and
Repair ;
PM 92-091 RHR SW Booster Pumps IA and 1C Replacement
PM 91-070 DG SW Piping Replacement
PM 91-001 . Unit 1 Hardened Wet Well Vent Installation
PM 82-221L 1B CSW Pump Replacement
WR/JO 93-ATII 1-3 Replacement of Valve 2-SW-V482 j
WR/JO 93-ALWF 1&2 DG No. 2 Flex Drive Inspection
WR/JO 9-ATFR l-3 Freeze Seal Installation
DG No. 2 Flex Drive inspection
On June 26, 1993, at 12:40 a.m., the licensee started a DG No. 2 outaga
to inspect the flex drive and perform other maintenance. Taking DG
No. 2 out of service placed both units in a seven-day LCO.
Considerable effort was placed in planning and scheduling of the outage ,
to ensure the work was completed within the LC0 time. The inspector
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attended several briefings conducted prior to the DG No. 2 outage. The
inspector reviewed the schedule and discussed with the maintenance '
foreman the schedule and availability of parts. The foreman stated that
he had physically located the potentially needed parts several days '
before the outage. He said that in several cases the parts were not
stored in their designated location. It was his opinion that the pre-
positioning of parts saved several hours of schedule time. All major-
tools were also pre-staged.
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The outage work was relatively trouble free. The flex gear was removed, ,
rebuilt, balanced, and reinstalled within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of the outage start. '
The inspector observed the reinstallation of the flex drive and found
the maintenance crews to be thorough, knowledgesble, and well prepared.
Adequate engineering, QC, and maintenance staff support and management
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overview was provided. The inspector concluded that good planning,
scheduling, preparation, and team work significantly contributed to the i
smooth execution of the DG No. 2 outage. It was one of the licei ae's ;
better maintenance efforts observed to date. The inspector cone ers
the crew's dedication, preparation, and the interorganizational .eam ,
work to be a strength. I
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Temporary Storaae ,
The inspector continued to find discrepancies in the area of temporary
storage. However, these weaknesses appear to be confined to the Project
Management Section (PMS). This concern was discussed with PMS
management who said that they had made similar observations. They are l
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reemphasizing the need for proper storage. The inspector has observed
that maintenance has made significant improvement in their temporary
storage control. Overall, temporary storage is acceptable. The
licensee is developing a procedure, AI-18, for temporary storage that is
planned to incorporate ANSI N-45.2.2-1978.
Service Water Pumps
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The licensee had previously experienced problems in meeting ASME ,
Section XI requirements for service water pump bearing temperatures. A !
code exemption was requested and granted January 4, 1990, with the i
requirement that the licensee take monthly OM-6 vibration data. As of
June 29, 1993, all five of the Unit 2 service water pumps were in the
" alert" range. Nuclear Service Water Pump 2A was in the worst condition ,
and, if the current trend data continues, it may become inoperable when 1
the August data is taken.
All of the SW pumps are planned for future replacement with CSW Pump 2A
being the next pump on the schedule. The licensee is reassessing their
schedule based on the results of NSW pump 2A vibration data. They are
attempting to expedite the receipt of the next pump and the installation
modification package from NED. The inspector determined that the
licensee's actions were acceptable.
Service Water leak
On June 13, a leak developed in the service water lube water (SWLW) i
system. The Unit 2 cross-tie valve (2-SW-V48) to Unit I had developed a l
through-wall leak in its body. This is a wafer style carbon steel
butterfly valve held in compression between flanged sections of the
three inch SWLW cross connect line. The licensee's initial evaluation
was that the through-wall leak was caused by erosion / corrosion. The
leak war approximately 30 to 40 gpm and could not be isolated without-
securing the Unit 2 lube water pumps. This would result in a loss of
lube water to the Unit 2 nuclear and conventional service water pumps.
Water from this leak sprayed into the electrical cable trays and onto
the main SW pump and header isolation valves which were in the area.
The licensee rigged a portable ventilation elephant trunk to direct the i
leakage from the valve to the floor drain. Herculite was used to !
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protect nearby electrical equipment from spray. The leakage was
contained and directed to drains while the licensee investigated a
repair and availability of replacement parts.
The inspector observed the above temporary repairs. The licensee's
EER 89-0334, dated Dec. ember 12, 1989, indicated that the service water
pumps could be run for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> without SWLW being supplied to
their motor cooler or bearings. Each running SW pump could provide its
own lubrication and cooling for the motor and bearings. However, on
June 13, NED determined that this EER had been invalidated due to
modifications that had been performed on the nuclear service water pumps
and the IB conventional service water pump. The modification had capped
off the SWLW supply to the motors and removed the check valve in the
supply line between the cyclone separator and the pump bearings. On
June 14, after further review and discussion with the pump vendor, it
was determined that the pump and motor could operate for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />
without SWLW flow. NED revised EER 89-0334 to reflect this information.
The licensee developed a repair plan, which included installing a "C"
clamp seal, to stop the leakage until the valve could be replaced. The
repair also provided for freeze sealing the cross connect lines in two
places and replacing both the Unit I and Unit 2 cross tie valves.
While attempting the freeze seal, the Unit I cross connect valve would
not stop flow through the cross connect line. The crossflow and leakage
was caused by the differential pressure between the Unit I and Unit 2
SWLW systems and the lack of integrity of both cross connect valves.
The inspector observed that the leak had increased with time. Several
unsuccessful attempts were made to balance the discharge pressure of
each SWLW system and thereby stop or reduce the cross connect flow.
Since the freeze seal could not be established while there was flow in '
the line, a decision was made to shut down the SWLW system on both
units. To stop the flow, on June 16, the licensee install a blind ,
flange in the line adjacent to cross connect valve 25W-V483. Two freeze
seals were established outboard of each cross connect valve and both
valves were replaced. After successful hydrostatic testing, the SWLW
system was returned to normal operation.
The inspector reviewed EERs 93-0441, Revisions 0 and 1, and 89-0334 and
the 10 CFR 50.59 evaluations associated with this activity and found
them to be acceptable. Additionally, the inspector reviewed the WR/J0s ;
for the freeze seal and replacement of valves SW-V48 and V483. He also
observed the installation and work activities associated with the above
WR/J0s. A significant amount of difficulty was encountered over three ,
days in establishing the freeze seal due to the inability to stop SWLW
cross connect flow. It was noted that no person or group appeared to be
"in charge" of directing and coordinating the overall activity.
Supervision and guidance appeared.to vacillate between Technical Support ,
and the Project Management Section. The inspector noted that the end
product of this activity was acceptable.
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Vendor Manual Review
The licensee currently uses vendor manuals and drawings when procuring
and conducting engineering evaluations for spare parts used in safety-
related and non safety-related components. According to NRC Generic
Letter 83-28, Technical Manuals, both hard copies and microfilm are
considered to be controlled documents.
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The inspector conducted an inspection to determine the extent of vendor
manuals used when procuring spare parts used for safety-related ;
components. The licensee stated that the technical manuals, used for
spare parts engineering evaluations, are used as a secondary reference
to verify part specifications. The inspector verified that the licensee
primarily relies upon the original purchase order, field verification of
installed components, drawings and a contracted vendor service,
Information Handling Services, to assist in the writing of purchasing
requirements. This service uses a system called Visual Search Micro
Form (VSMF) to maintain purchasing standards (ASTM, ASME, etc.) and
vendor catalogs. For example, ANSI standards are updated every 30 days
and the other standards are updated every 60 days. The inspector
verified that the microfilm and catalogs in use were current.
The inspector reviewed several material engineering evaluation reports
(MEER 92-0116, 0161, 0266 and 0305), quality class analyses, and parts
verification plans, and found that the procurement engineers generally
use means other than vendor manuals to perform part dedication and
acquisition. Each material engineering evaluation report is also
subjected to an independent technical review. The inspector found that
the procurement engineers generally contact and confer.with the vendors
to verify parts specification requirements and to ensure that no changes
have occurred since the original or last purchase. If changes occur .
they are verified and documented in the manuals and/or drawings. The ;
procurement engineers are not required by procedure to conduct and !
document contacts with the vendor. However, this was a routine practice
conducted to provide additional quality assurance. The MEERs reviewed i
were for the procurement of Nordberg diesel parts. The inspector ,
determined that the licensee conducted an adequate evaluation of the
diesel parts and that the parts met the quality requirements for the
diesel generator.
The inspector reviewed the progress of the NED initiative in progress to
revise and update all plant vendor manuals over the next three years. i
There are 390 of 800 vendor manuals remaining to be reviewed. CP&L's ;
on-site document control group implemented the corporate-wide vendor ;
manual control and revision program. The vendor manual revision, along
with a copy of the specific vendor manual, is sent to NED to be )
prioritized and verified. While this review is taking place, the
remaining master hard copy and micro fiche is placed on " Hold" in a (
vault. Once verified, revisions are sent to the affected groups for
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distribution.
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The licensee has started a project to compile vendor manuals into parent
documents which contain technical information for vendor specific
components (i.e., ASCO valves, etc.). Over 265 manuals have been
completed to date. The inspector verified the content of these manuals
and found them to be adequate. '
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The preventive maintenance basis review program required a review of the
station vendor manuals for equipment model numbers, PM recommendations,
calibration requirements, equipment tag numbers, etc. Deficiencies for
over 500 manuals were documented and forwarded to NED for review and ;
incorporation into the current vendor manual. The inspector reviewed i
several of the completed deficiency forms and verified that they were :
being incorporated into the current versions of the plant vendor
manuals. The licensee's review program appecrs adequate.
Violations and deviations were not identified.
3. Surveillance Observation (61726)
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The inspectors observed surveillance testing required by Technical
Specifications. Through observation, interviews, and record review the l
inspectors verified that: tests conformed to Technical Specification i
requirements; administrative controls were followed; personnel were
qualified; instrumentation was calibrated; and data was accurate and
complete. The inspectors independently verified selected test results
and proper return to service of equipment.
The inspectors witnessed / reviewed portions of the following test
activities:
2MST-HPCI?7M HPCI and RCIC CST Low Water Level Instrument Channel
Calibration
The inspector observed the Unit 2 channel calibration and functional
test of the condensate storage tank low level switches. This test was
performed to determine the operability of the low water level interlock
functions of the HPCI and RCIC systems. The calibration requires the
technician to attach a long tygon reference tube to the manifold
calibration valve and fill the tube with water. Despite a procedural
caution, during one attempt to fill the reference tube the technician
inadvertently overfilled the tube and potentially contaminated water !
spilled on the ground. This and several other delays in conjunction j
with the technician's unfamiliarity with the procedure, resulted in the l
level switches being out of service for three minutes beyond the two i
hour testing limit allowed by Technical Specifications. Prior to !
exceeding the two hour limit, the HPCI suppression pool suction valve
and condensate storage tank valves were realigned to their normal l
configuration and the channel was placed in a tripped condition. The
surveillance test was completed satisfactorily. Subsequently, the ,
inspector observed that rubber hoses were attached to the north and
south vent lines for the condensate storage tank low water level
switches. These hoses had been attached to the vent lines to facilitate
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periodic blowdown of the associated vent line piping; however, blockage
of these hoses could cause the level switches to malfunction. The
inspector discussed his concern with the licensee and the hoses were
removed.
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2MST-RGEllQ RGE A0G Effluent Noble Gas Radiation Monitor functional Test
A0G Effluent Noble Gas Radiation Monitor Functional Test. This test is
performed to determine the operability of the process gas effluent
monitor (2-A0G-RM-103). During the test, the inspector noted that the
I&C technician did not correctly interpret procedure step 7.4.12 of the *
surveillance procedure that required him to calculate the alarm trip
value required to meet the surveillance acceptance criteria. After
discussions with the inspector, the I&C technician correctly performed
the missed step and continued with the test. ;
. The next step, 7.4.13, required the I&C technician to adjust the test
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equipment to the calculated frequency with a square wave pulse. It took ,
about one and one-half hours for the I&C technician to adjust the *
oscilloscope and develop the required square wave pulse. The I&C
technician stated that his limited training coupled with the infrequent
use of the equipment resulted in his difficulty in performing this test.
The lack of adequate refresher training on i' #requently used equipment
is considered a weakness.
The inspector also identified discrepancies between the injection signal
required to test the ALERT alarm lights and the specified test
acceptance signal value in Section 6.3 of the surveillance procedure.
The inspector discussed this item with the licensee. Although the test
results met the Technical Specification acceptance criteria stated in
Section 6.2.1, the MST results were declared unsatisfactory due to the
above discrepancy. Shift supervisory personnel were notified in
accordance with Section 6.1 of the procedure. The licensee is reviewing
this discrepancy.
2MST-CAC27Q CAC Division II Drywell Hydrogen /0xygen Analyzer
Channel Check
OPT-20.8.2 CAC-AT-4410 Leak Test
2MST-RBM-21R RBM Channel Calibration and Functional Test i
RCIC-23M RCIC Turbine Exhaust Diagram High Pressure Instrument
Channel Calibration *
No discrepancies were identified with these four items.
Transformer Yard Access Control
On June 14, the licensee was making' preparations to perform the semi-
annual Environmental and Radiation Surveillance Test, 0-RST-79.0, "GE
Service Water Effluent Radiation Monitor Channel Calibration,"
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Revision 0, on Unit 2. These radiation monitors are located on the
service water discharge piping where it exits the west side of the
turbine building. This area is adjacent to the unit auxiliary
transformers. The preparations included moving a Cs-137 source from the
Unit 1 monitor to the Unit 2 monitor The surveillance is normally
performed every 18 months. At approximately 9:00 a.m. on June 14, the
, fork truck used to transport the source broke through a concrete cover ,
l for a transformer control power cable trench which is located adjacent '
to the Unit 2 monitor. The fork truck came to rest with one of its
wheels in the trench. The source remained on the pallet. The fork
truck was removed about 11:33 a.m. with no damage to the source or the
cables in the trench. The area was barricaded to preclude unauthorized
entry.
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Administrative Instruction, 0-Al-ll8, " Switchyard and Transformer Yard
Vehicle Access", Revision 0, Section 3.2 requires that the shift
supervisor be contacted prior to entry into the transformer yard.
Additionally, Section 3.1 indicates that the shift supervisor is
responsible for granting entry approval. The inspector determined that
the fork truck operator received permission for transformer yard entry
from the Unit 1 SCO with the concurrence of the Unit 2 SCO rather than
the shift supervisor as required. Moreover, the shift n pervisor,
unaware of the transformer yard entry, gave permission to perform the DG
No. 4 Monthly Load Test durir this same time period. Investigation
found that a pre-job briefing was not held as required by Section 5.2.8
of AI-118. Further investigation revealed that the fork truck operator ,
had not previously performed this task. The fork truck normally used '
was not available and a larger unit was used which required that a new
route be established for transporting the source. The assistance of the
system engineer was not used when selecting the new route and the fork
truck operator, accompanied by a HP technician, had to remove a rope
barrier to use the route selected. Investigation revealed that the fork
truck operator had not reviewed the requirements of AI-118 and these
requirements are not included in the training for forklift operators.
The failure to have a pre-job briefing and obtain shift supervisor
permission is a Violation (325,324/93-27-01), Failure to Implement
Procedure AI-118.
One violation was identified.
4. Operational Safety Verification (71707)
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Unit 1, which began a forced outage on April 1,1992, remained defueled
with refueling scheduled for August,1993.
Unit 2 operated at 100% power for the reporting period.
The inspectors verified that Unit I and Unit 2 were operated in
compliance with Technical Specifications and other regulatory
requirements by direct observations of activities, facility tours,
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discussions with personnel, reviewing records and independent 1
verification of safety system status. !
The inspectors verified that control room manning requirements of '
10 CFR 50.54 and the Technical specifications were met. Control
operator, shift supervisor, clearance, STA, daily and standing ,
instructions and jumper /oypass logs were reviewed to obtain information
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concerning operating trends and out of service safety systems to ensure
that there were no conflicts with Technical Specification Limiting
Conditions for Operations. Direct observations of control room panels, ;
as well as instrumentation and recorded traces important to safety, were -
conducted to verify operability and that operating parameters were ;
within Technical Specification limits. The inspectors observed shift ,
turnovers to verify that system status continuity was maintained. The
inspectors also verified the status of selected control room
Operability of a selected Engineered Safety Feature division was
verified weekly by ensuring that: each accessible valve in the flow
path was in its correct position; each power supply and breaker was
closed for components that must activate upon initiation signal; the RHR
subsystem cross-tie valve for each unit was closed with the power
removed from the valve operator; there was not leakage of major
components; there was proper lubrication and cooling water available;
and conditions did not exist which could prevent fulfillment of the i
system's functional requirements. Instrumentation essential to system i
actuation or performance was verified operable by observing on-scale 1
indication and proper instrument valve lineup, if accessible, j
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The inspectors verified that the licensee's HP policies and procedures l
were followed. This included observation of HP practices and a review '
of area surveys, radiation work permits, posting and instrument
calibration.
The inspectors verified by general observations that: the security
organization was properly manned and security personnel were capable of
performing their assigned functions; persons and packages were checked
prior to entry into the PA; vehicles were properly authorized, searched
and escorted within the PA; persons within the PA displayed photo
identification badges; personnel in vital areas were authorized;
effective compensatory measures were employed when required; and
security's response to threats or alarms was adequate.
The inspectors also observed plant housekeeping controls, verified )
position of certain containment isolation valves, checked clearances and i
verified the :perability of onsite and offsite emergency power sources. ;
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Housekeepina
Overall, licensee efforts in housekeeping have significantly improved;
however, some low traffic and low visibility areas need additional
management attention. The licensee has designated certain areas (i.e., l
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RFP rooms) as model rooms that are to be maintained as the site standard
for housekeeping. Prior to Unit 2 restart, the inspector identified oil )
on the floor and pedestals in the RFP 2A and 2B rooms. Upon being i
informed, the licensee cleaned up the oil. Since restart, the inspector i
has repeatedly observed oil on the floor and pedestals of both Unit 2
RFP rooms and informed the licensee each time the observation was made. ;
Additionally, the horizontal I-beams in the Unit 2 turbine building j
structure are being used as storage areas. The inspector observed duct ,
tape, tools, conduit covers, scrap material, and rusted components <
stored in the horizontal I-beams. The inspector discussed these
observations with licensee management who directed that these items be ;
corrected.
The licensee increased management presence in the plant and instituted
management backshift tours; however, these tours have not resulted in
significant housekeeping improvements. Based on the above observations
management tours do not encompass all plant areas. It also appears that ,
management has not communicated their new housekeeping standards to all
personnel and follow-up is not being accomplished to insure I
implementation. Maintenance and operations personnel also do not appear l
to be identifying many housekeeping issues. Additionally, Unit 1 !
housekeeping is poorer than Unit 2. I
Loss of CBEAF
On June 27, 1993, while performing Periodic Tast, OPT-34.4.1.3, Control
Building Fire Detection Instrumentation Operat'ility Test, Revision 14,
dated May 26, 1993, at 1:21 p.m., the control building intake high
chlorine and control building HVAC isolation alsrms were received. The
detectors were reset and again tripped. The operators determined that
hand held radios used by operators in the vicinity of the detectors ;
caused the actuation and isolation. A modification had recently '
installed new detectors that may be more sensitive to radio signals.
The shift supervisor issued instructions to prohibit the use of hand
held radios in this area. The isolation of the chlorine detectors
rendered both the fire protection and radiation protection of the CBEAF
system inoperable for approximately 29 minutes. The licensee made an
ENS notification at 5:12 p.m. and documented the event in ACR 93-200.
The OPT was restarted about 3:00 p.m. The test was limited to tes'.ing
the four thermal detectors in both CBEAF trains. When thermal deiector
(C15-2) in CBEAF Train 2A was tested, the operator observed that the
inlet and outlet isolation dampers did not close as required. The 2A
CBEAF was declared inoperable. The 2A CBEAF Train was retested and it
was determined that the detector isolated the damper on the opposite
CBEAF Train. Both trains of the CBEAF system were declared inoperable
at 2:32 a.m. on June 28.
The system engineer was contacted and reviewed the design basis document
DBD-37, " Control Building HVAC System," Section 3.1.5.5, which states
that the CBEAF train should automatically shut down and isolate on
detection of excessive heat in that train. Investigation by the
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licensee revealed that the "A" detectors (15-1 and 2) were wired to the
B train and vice versa. The wiring was corrected and OPT 34.4.1.3 was
reperformed satisfactorily and the 2A and 2B CBEAF systems were declared
operable at 5:50 a.m. The licensee made the ENS notifications and
documented the event in ACR 93-0201.
Plant Modification 79-308 installed two thermal detectors in each CBEAF
in 1980. The modification was made to meet an NRC commitment for
10 CFR 50, Appendix A. The CBEAF is provided with two air filters: a
high efficiency particulate air filter and a charcoal absorbing filter.
A heat detector is installed on the inlet and outlet of each CBEAF for
fire detection as the CBEAF does not utilize a deluge system. The inlet )
and outlet dampers close and the recirculation fan shuts down when a
high temperature is detected. The isolation of the CBEAF contains the
fire and allows it to extinguish through oxygen starvation. The above
problem would result in a fire in one CBEAF isolating the non-affected
unit and smoke would be allowed to enter the control room. The wiring ;
error occurred during the installation of the modification in 1980. The ,
inspector reviewed system procedures and surveillance test revisions in
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an attempt to determine why the error had not been discovered earlier ,
since OPT 34.4.1.3 has been performed semiannually for the past 13
years.
The inspector reviewed OPT 34.4.1.3, Revisions 12, 13, and 14 and
Drawings F-03896, Sheet 5, F-04080 and LL 09046. It was noted that the
only requirement in Revision 1 of the OPT to determine detector
operability was to verify that the annunciator alarmed. The annunciator
is activated for either train and would not detect the error.
Revision 13, dated February 16, 1993, added the requirement to verify j
that the appropriate recirculation fan shuts down and both isolation 'j
dampers close. Discussions with the Technical Support Fire Protection -
Engineer revealed that while reviewing procedures as part of the Fire
Protection System review in 1992 and 1993, he had concluded that the
test procedure was inadequate. He did not consider that it demonstrated
system functionability and revised the procedure to better demonstrate
system operability. The inspector also determined from the drawing
review that Drawing F-03896, Sheet 5, showed the detectors to be wired
incorrectly. The other drawings depicted the detectors with the correct
wiring.
The inspector questioned the Unit 2 Operations Manager as to system
operability. The operations manager stated that the system had been
inoperable since the installation of the modification in 1980. This is ;
an Unresolved Item (325,324/93-27-02); Inadequate Testing of CBEAF l
System, pending completion of the licensee's investigation of this i
event and an independent review and evaluation by the inspectors.
Control Room Observation
On June 9, at approximately 9:15 a.m., the inspector observed the one
remaining on-shift Senior Reactor Operator (SRO) leave at the controls
area of the control room. This left only one licensed reactor operator
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for Unit 2 and two licensed reactor operators for Unit I remaining in
the control room at the controls. The normal operating shift staff
consists of two senior reactor operators, one per unit, and four reactor
operators, two per unit. Station procedures state that there shall be
at least one licensed SR0 in the control room at all times. The control
room is defined as the control building 49 foot elevation within the
vital area. In the above case, the licensee met their procedural
requirements. The inspector discussed his observation with Operations
management who stated that their expectations were to insure that at
least one SP0 emained at the controls area at all times. The licensee
stated that the above was an isolated event and that they would take
steps to ensure management expectations are met in the future.
Auxiliary Sample Pumps (CAC 1261 and 1262)
On June 18 at 2:25 a.m., the licensee entered technical specificatico
3.0.3, because two sample pumps used to monitor the containment
atmosphere were inoperable. Two of three sample pumps are required to
be operable per TS 3.3.5.3 and Table 3.3.5.3-1. One pump, CAC-1261, had
been taken out of service to perform a preventive maintenance cleaning
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and inspection task (PM/JO 93PME004).
During the above time, sample pump, CAC-1262, was declared inoperable
when a fuse failed in the pump's control circuitry. The licensee
entered TS 3.0.3 because two pumps, CAC-1261 and CAC-1262, were now
inoperable. The fuse was replaced, the pump was declared operable and
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the licensee exited TS 3.0.3.
l During the follow-up investigation, the inspector found a discrepancy
between the SCO and C0 log entries concerning which pump had actually
failed. The licensee reviewed the matter and has counseled shift
supervisory personnel on the need for timely implementation of LC0
requirements, accurate log entries, and the need to review LC0
supplementary sheets.
Auxiliary Operators
On June 18, 1993, the licensee notified the inspector that they had
terminated two Auxiliary Operators (A0s) for falsification of records.
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Specifically, the two A0s had documented on their round sheets that they
had spent more time in the Reactor Building than they actually did. The
licensee recently became suspicious of these A0s and performed a
computer verification of the operators' entry and departure times. A
reconciliation of both sets of data revealed discrepancies. The A0
round sheets are not required by Technical Specifications nor do they
contain Technical Specification required data. The licensee considered
the falsification of stay time to reflect on the A0s' trustworthiness.
The inspector determined that no Technical Specifications were
falsified. Falsification of records is an Unresolved Item (325,324/93-
27-04), pending further review by the NRC.
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Overtime
The inspector observed that several operators appeared to have worked a
large amount of overtime during the recent Unit 2 outage. The
operators' time sheets of March 20 to May 21, 1993, were reviewed to
validate this observation. The time records of 54 Unit I and 50 Unit 2
operators were reviewed. Operating Manual Administrative Procedure, j
Volume I, Book I, Section 4.4, delineates the licensee's overtime '
policy. Section 4.4.b states, in part, that an individual will not be
permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period.It also ,
establishes limitations on overtime which may be exceeded in exceptional
situations. The procedure requires that prior authorization from the ;
Section Manager be obtained.
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The time sheet review revealed 33 of the 104 operators exceeded the time
limits specified. The inspector determined that three individuals had j
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worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period without authorization.
The inspector also noted there were 40 occurrences of individuals
working eight to eleven consecutive days and five individuals working
from 15 to 19 consecutive days.
The inspector reviewed 181 excess time authorization forms covering the !
operators, STAS, production assistants and work control center :
personnel. There were five occasions for which double authorizations l
were issued and eight authorizations that listed the incorrect position
for the operator (SCO vs 00). Revision 146, changed the approval level
of the Excess Working Time Authorization Form from the Plant Manager to :
an equivalent position of Section Manager per Plant Manager direction. ,
The inspector determined that only 10 of the 181 authorizations reviewed ;
were authorized by a Section Manager.
The five cases of duplicate authorizations and the listing of incorrect
position titles are examples of inattention to detail. Operators ;
working 15 to 19 consecutive days demonstrates a weakness in the
, management controls. The three individuals working in excess of )
requirements without authorization and the failure to receive the proper i
i approval is contrary to the above procedural requirements and is a l
Violation (325,324/93-27-03) Failure to Implement Procedures to Control '
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Overtime Work.
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ISI/IST i
A contractor under licensee direction completed an inspection of the
, Unit I reactor vessel internals. The inspection revealed two '
indications of cracking in the Core Spray B sparger. On June 24, a
review of the inspection video tape revealed a 2.5 inch crack parallel
to a circumferential weld in the heat affected zone of the sparger :
fusion weld located approximately 18 inches west of the Sparger T-box i
located at 270 degrees. The area was reinspected with a measuring l
template to determine the exact length of the crack. The inspector i
viewed photographs of the crack. On June 29, the licensee cr.nfirmed
that they had found another crack on the Core Spray B sparger. The
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second crack was about 3 inches long and is located in the heat affected
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zone of the 355 degree T-box to the sparger weld. The licensee found no
other cracks on the Core Spray B sparger and no indications on the Core
Spray A sparger. The licensee also reviewed the video tapes for the ;
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similar sparger on Unit 2 and found no indications.
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The cracks are currently being analyzed and the licensee plans to submit
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its evaluation and proposed corrective action to the NRC within 30 days
of the initial telephone report.
Three-Year Plan
The inspector reviewed the May 1993, Three-Year Plan Monthly Report and l
noted that the licensee has completed 99 of 112 initiative action steps ;
and project phases that were scheduled from January I through May 31, :
1993. Twenty-seven initiatives and seventy-six projects were in l
progress as scheduled in May 1993. Twenty-three activities _were i
scheduled and completed in May. Four initiative actions were completed
early and three previously late activities were also completed. Seven
activities scheduled to start were delayed. One of these activities was j
rescheduled to better coordinate with the Unit I revised refueling- ;
schedule. The other changes involved problems encountered with physical j
plant interference during modification installation and delays resulting- ,
from remedial engineering training. The licensee continues to place l
emphasis on completing six previously delayed activities which include i
developing an overall Authorized Personnel Inventory Plan for the site,
Scheduling and Planning Coordination and improvement in the Management l
Review Process. They approved changes to two milestone dates and twelve
projects during May. Overall, these changes appear to have minor impact !
on the initiative, project, and scheduled completion dates. Progress l
was noted on improvements to the work control process by the prioritiza-
tion of each backlog category. Performance expectations were
established for Section Managers and finalized for all other personnel.
A guideline which incorporates self and independent assessment was
completed to address closing out of initiatives. In addition,
administrative controls were developed for Inservice Inspection and
Testing processe.s and procedures. The inspector compared the above
status and progress against the original Three-Year Plan submitted to
the NRC on December 15, 1992, and concluded that the licensee made
satisfactory progress.
Operator Corrective Actions
The licensee, in an attempt to reduce inattention to detail errors, has
instituted the " STAR" self-checking program. STAR is an acronym for
Stop, Think, Act, Review.
STAR has been introduced to replace the "Please Listen" program. The
licensee surveyed one Operations and one I&C/ Electrical crew to
determine what would assist in reducing inattention to detail events.
One of the survey findings was that the respondents wanted shorter and
easier to use acronyms to promote self-checking. The licensee chose
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STAR among several available programs. The inspector reviewed the STAR
training manual which includes the results of the survey. It also
contains a listing of recent hattention to detail and self-checking
issues. The training manual appears to be adequate. One operations -
crew has implemented a practice where an auxiliary operator discusses ,
suggestions or experiences relating to self-checking during the shift t
turnover meeting. The inspector considers the involvement of the
operators to be a strength in the licensee's effort to reduce attention
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to detail errors.
The licensee has expanded the STAR training to include other onsite
organizations. All of the operators have been trained and training is .
being initiated for the other organizations on site. The inspector
attended a STAR training session for the diesel maintenance crew. The i
crew appeared to be receptive.
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APRM Neutron Monitorina Spikes
The inspector reviewed the licensee's action on the observed power !
spikes on Unit 2 APRM neutron monitoring instrumentation. These spikes
are similar in frequency and magnitude (i.e., 3%-4% of reactor power) to
those observed on Unit I when it was in operation. The Unit I spikes ;
were believed to be caused by a slight fluctuation in Recirculation Pump
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B flow. The spikes have occurred both in the upscale and downscale
direction and appear to be caused by a core-wide phenomena that affects
all APRM channels simultaneously. Although the highest spikes have
caused the actuation of APRM upscale alarms, which occur at
approximately 107% of reactor power, no scram setpoints have been ,
reached. To better understand and analyze the cause of the power
spikes, a standing instruction was issued that requires the collection
of ERFIS data (e.g., core flow, reactor power, recirculation flow, '
control valve position, etc.).
On June 30, the frequency of alarms on APRM C increased sharply due to -
power spikes. The licensee performed a maintenance surveillance test on
the affected channel and found that the alarm setpoint had drifted. The
licensce is continuing its investigation of the power spikes. ;
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Hurricane Preparedness
The inspectors reviewed the licensee's evaluation of the lessons learned
from Hurricane Andrew. The review focussed on the adequacy of l
compensstory measures for equipment and facilities not designed for a i
hurricane and the adequacy of the licensee's examination of the impact i
of non-safety equipment on important equipment during external events.
The inspector found that the licensee's focus and review was very
narrow. They only addressed such items as radio communications, loss of i
sirens, support of recovery personnel's families, and missile
vulnerability of the TSC Diesel Generator.
The licensee concurred that their review had been limited in scope and l
organized a task force to re-review this item. The group was directed i
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to determine areas in which the licensee needed to re-evaluate its
efforts, recommend actions, and designate procedural enhancements.
" Lessons Learned from Hurricane Andrew," issued by Florida Power and
Light and "The Effect of Hurricane Andrew on the Turkey Point Generating ,
Stations from August 20 - 30, 1992," jointly issued by INP0 and the NRC,
were used as the basis for the task force's review.
The task force's initial efforts have been to identify areas which
require additional review. The inspector has reviewed the licensee's
initial effort and it appears to be adequate.
The licensee has revised Administration Instruction 68, "BNP Response to
Severe Weather Warnings," and Emergency Procedure A0P-13, " Operations
During Hurricane, Flood Conditions, Tornado, or Earthquake." The
licensee has also ordered a high frequency radio and is completing plans
to upgrade its site communication equipment.
The licensee has not performed their evaluation to determine the
adequacy of the licensee's compensatory measures for equipment and
facilities not designed for a hurricane or the impact of nonsafety-
related equipment on safety-related equipment. They also have not
determined the validity of their original assumptions relating to
hurricanes. The inspector considers that the licensee's early efforts
were very limited in scope and depth. The recently developed efforts
appear to be adequate. The inspector will review the remaining licensee
efforts which are scheduled for completion in August of 1993. j
One violation was identified. j
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5. Onsite Review Committee (40500)
The inspector attended selected Plant Nuclear Safety Committee (PNSC) :
meetings conducted during the period. The inspector verified that the ;
meetings were conducted in accordance with Technical Specification '
requirements regarding quorum membership, review process, frequency and
personnel qualifications. Meeting minutes were reviewed to confirm that
decisions and recommendations were reflected in the minutes and followup
of corrective actions was completed. The inspector had previously
observed that the PNSC members were not receiving material in sufficient
time to perform an adequate review. This item appears to have been
corrected. When material is not received within sufficient review time,
the item is deferred to the next PNSC meeting.
There were no concerns identified relative to the PNSC meetings
attended. The resolution of safety issues presented during these
meetings was considered to be acceptable.
Violations and deviations were not identified.
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6. Review of Licensee Event Reports (9700)
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(Closed) LER 92-93-07, Outside of TS 3.3.2, Trip System Not Placed in
Trip Condition Within One Hour. This event was addressed in Inspection
Report 325,324/93-23 and was closed by NCV 93-23-01.
(Closed) LER 1-92-016, Fire Seals Around Diesel Generator Pedestals. j
l- The licensee used Rodofoam 300 as a seismic joint filler in the gap
between the diesel pedestal and the DG building floor.. The licensee
re-evaluated this material and determined that it was not an acceptable
fire barrier. Plant Modification 92-090 was developed to remove the i
installed Rodofoam, install an approved fire barrier, and redesign and
install the DG oil collection system. This is described in more detail .
in Inspection Report 325,324/93-19. The inspector observed that the !
installation of the approved fire barrier was completed on April 17,
1993. Additionally, the redesign of the oil collection system has been .
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completed and installation of the redesigned system is scheduled for
mid-July. This item is closed.
(Closed) LER l-93-002, 480 Volt Breaker for Standby Liquid Control Pump
Was Found With Undocumented Breaker Type. On December 7, 1992, the
breaker installed in the 1A standby liquid control pump breaker
compartment was identified as a type that did not meet the design
functional requirement for the application. Research by the licensee
showed the breaker probably was the one installed originally in the
motor control center and not one mistakenly installed through
maintenance. The inspector reviewed the following corrective actions.
The breaker was replaced with a breaker of the proper type. An as-built
verification performed in 1985 failed to identify the discrepancy. The
licensee performed an inspection of a 5% sample of similar breaker
- applications and no other discrepancies were found. The licensee ,
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considered this to be an isolated case. This item is closed. '
(Closed) LER l-91-022, Control Building Emergency Air Filtration Damper
Malfunction. On August 7,1991, the normal air supply damper failed to
I close during periodic testing. The licensee's investigation revealed i
l that the damper was binding due to the mispositioning of a portion of
i the actuator during reassembly. The inspector reviewed the following
I corrective actions. The damper was repaired. A sampling inspection of :
other dampers was made for mispositioning of the arm and no l
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discrepancies were found. The event was reviewed by the Unit Manager,
1&C, electrical, technical support, OM&M projects, and modification
support personnel. This item is closed. l
(Closed) LER 1-9-020, Worst Case Voltage Conditions Were Not Considered
l For Standby Gas Train Heater Surveillance. The SBGT periodic test
l failed to compensate for degraded voltage conditions in its acceptance
l criteria. Mechanical calculations OSBGT-002 addressed concerns of past
l operability by establishing a lower KW limit that would meet system
requirements. In addition, modifications were made to the SBGT units to
increase the power output of the heaters to above the TS minimum. The
inspector reviewed Plant Modification 92-105, approved March 19, 1993,
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and its attached safety reviews for the Unit 1 modification. PM 92-106
was completed for Unit 2. The inspector reviewed the changes to the
SBGT heater operability test. The test was broken into four tests (one
for each train), and an equation correcting for degraded voltage
conditions was added. This item is closed.
(Closed) LER 1-91-004, Invalid First Interval Hydrostatic Test Boundary
on Reactor Pressure Vessel Hydro. The licensee determined in February,
1991, that required components had not been hydrostatically tested on
both Unit I and Unit 2 during their first 10 year interval hydro ;
performed in 1983 and 1984. The inspector reviewed Periodic Test
PT-80.1, Reactor Pressure Vessel Hydrostatic Test, Revision 6,
Attachment 4, RPV Test Alignment For Valves (10 year only). The
attachment verifies the inboard drain line valve open and the outboard
drain line valves closed for those valves identified in EER 91-0059,
Evaluation of Unit 1 Potential Degraded RCPB Integrity and EER 91-0060
(Unit 2). The Unit hydro was performed using this procedure and was -
completed December 11, 1991. Unit I hydro is planned to be performed
using the new revision of PT-80.1 during restart from the current '
refueling outage. Based upon the successful completion of the hydro for
Unit 2 and the procedure modifications performed on PT-80.1, this item
is closed.
(Closed) LER 1-92-004, Residual Heat Removal Room Cooler Found .
Inoperable Due To Outlet Damper Not Passing Sufficient flow. On
January 7,1992, the licensee discovered louvers on one of the two 100%
capacity room coolers to be closed. The failure was caused by broken
damper linkage. The condition had existed for an indeterminate time.
The damper was wired open until replacement parts could be obtained and
repairs effected. The replacement parts included a redesigned drive
bracket. EER 92-0030 performed the engineering evaluation and 50.59
review. EER 92-0021 provided the evaluation for blocking open the
louvers and the associated 50.59 evaluation. The inspector verified
changes were made to include the dampers as part of OPM-LUB500, Plant
Equipment Lubrication Schedule, Revision 12. In addition, OPM-ACU500,
Revision 3, Inspection and Cleaning of the RHR/ Core Spray Room Aerofin
Cooler Air Filters and Coolers, includes steps to operate the dampers
manually and visually inspect them. OPM-DMP500, HVAC Single and Multi-
Blade Damper Inspection, Revision 0, contains lubrication and inspection
instructions for the dampers. These procedures ensure the dampers are
included in a regular inspection program to verify function and identify
degradation. In addition, other dampers with similar functions were
identified, inspected, repaired as needed, and placed on a three year
inspection schedule using 0PM-DMP500. This item is closed.
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7. Exit Interview (30703)
The inspection scope and findings were summarized on July 2, 1993, with !
those persons indicated in paragraph 1. The inspectors described the !
areas inspected and discussed in detail the inspection findings listed !
below and in the summary. Dissenting comments were not received from f
the licensee. Proprietary information is not contained in this report.
Item Number Description / Reference Paracraph
325,324/93-27-01 Violation: Failure to follow Procedures
for Controlling Access to the Transformer
Yard, 9aragraph 3. -
325,324/93-27-02 Unresolved Item: Inadequate Testing of
CBEAF System, paragraph 4.
325,324/93-27-03 Violation: Failure to Follow Precedures
for Controlling Excessive Overtime,
paragraph 4.
325,324/93-27-04 Falsification of A0 round sheets,
paragraph 4.
8. Acronyms and Initialisms
Al Administrative Instruction
ANSI American National Standards Institute
A0 Auxiliary Operator
A0G Augmented Off Gas
APRM Average Power Range Monitor
ASME American Society for Mechanical Engineers
BNP Brunswick Nuclear Project
CBEAF Control Building Emergency Air Filtration
C0 Control Operator
CSW Conventional Service Water
DG Diesel Generator
EER Engineering Evaluation Report
ENS Emergency Notification System
ERFIS Emergency Response Facility Information System
. GE General Electric
HP Health Physics
HPCI High Pressure Coolant Injection
HVAC Heating Ventilation and Air Conditioning
I&C Instrumentation and Control
INPO Institute of Nuclear Power Operations
LCO Limiting Conditions for Operation
LER Licensee Event Report
NED Nuclear Engineering Department
NRC Nuclear Regulatory Commission
NSW Nuclear Service Water
OM&M Outage Management & Modification
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PA Protected Area
PM Preventive Maintenance
PMS Project Management Section
PNSC Plant Nuclear Safety Committee
PT Periodic Test
QC Quality Control
RBM Rod Block Monitor
RCIC Reactor Core Isolation Cooling
-RCPB Reactor Coolant Pressure Boundary
RFP Reactor Feed Pump
RGE Radioactive Gas Effluent
SBGT Stand By Gas Train
SCO Senior Control Operator
SR0 Senior Reactor Operator
STA Shift Technical Advisor
STAR Stop, Think, Act, Review
SWLW Service Water Lube Water
TS Technical Specification
WR/JO Work Request / Job Order
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