ML20128H090
| ML20128H090 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/02/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128H080 | List: |
| References | |
| 50-456-96-11, 50-457-96-11, NUDOCS 9610090235 | |
| Download: ML20128H090 (22) | |
See also: IR 05000456/1996011
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Docket Nos:
50-456, 50-457
License Nos:
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Report No:
50-456/96011; 50-457/96011
Licensee:
Commonwealth Edison (Comed)
Facility:
Braidwood Nuclear Plant, Units 1 and 2
Location:
RR #1, Box 84
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Braceville, IL 60407
Dates:
June 15 - July 26, 1996
Inspectors:
C. Phillips, Senior Resident Inspector
M. Kunowski, Resident Inspector
Z. Falevits, Reactor Engineer
E. Plettner, Regional Inspector
T. Esper, Illinois Department of Nuclear Safety
Approved by:
Lewis F. Miller, Jr., Chief, Projects Branch 4
Division of Reactor Projects
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9610090235 961002
ADOCK 05000456
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EXECUTIVE SUMMARY
Braidwood Nuclear Plant, Units 1 & 2
NRC Inspection Report 50-456/96011; 50-457/96011
This integrated inspection included aspects of licensee operations,
engineering, maintenance, and plant support. The report covers a 6-week
period of resident inspection.
In addition, it includes the results of
announced inspections by regional inspectors.
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Operations
Defueling practices and procedures were consistent with the licensing
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basis and reflected the current design basis of the Updated Final Safety
Analysis Report.
(Section 01.1)
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The failure to follow procedures and poor communications were
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identified by the licensee as the root causes for a Unit I
containment release made without an operable radiation monitor.
(Section 04.1)
A failure to follow a procedure to rack in a 6.9-kilovolt breaker
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was identified by the inspectors as an example of a violation of
Technical Specification 6.8.1.a.
The licensee identified and the
inspectors agreed that the root cause of the problem was poor
communications between operators.
(Section 08.4)
Maintenance
A failure to follow procedures to control the installation of a jumper
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on a ventilation damper controller was identified by the inspectors as
an example of a violation of Technical Specification 6.8.1.a.
(Section
M2.1)
The licensee removed workload from first line supervisors and
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hired contractors to work off longstanding work requests, in
response to maintenance department self-assessment.
However, some
of the department assessments lacked depth and did not address all
the items identified as weaknesses.
(Section M7.1)
Enaineerina
Operability assessments reviewed by the inspectors were adequate;
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however, the inspectors concluded that the licensee's ability to
determine the status of open assessments was weak.
(Section El.1)
The mispostioning of an instrument air vent valve for a Unit 2
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safety injection pump room ventilation damper was identified by
the inspectors as an example of a previously identified violation
for the failure to correct plant configuration control problems.
(Section E8.2)
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P_lant Suonort
Poor communications and a failure to follow procedures on the part of
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radiation protection department personnel contributed to uncorrected air
inleakage into a reactor coolant leakage detection radiation monitor and
securing a Unit I containment radiation laonitor during a containment
release.
(Sections 02.2 and 04.1)
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Report Details
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Summary of Plant Status
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Unit 1 entered the period at or near 100% power and operated routinely until
June 21, 1996. At approximately 11:30 a.m. on June 21, power was reduced to
about 80% to remove the 1A condensate booster pump from service, due to an
overheating inboard bearing, because no standby pump was available.
The IC
condensate booster pump was not available due to maintenance activities that
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were ongoing for several months. The 1A pump was repaired and the Unit was
restored to 100% power on June 26. Full power operation continued for the
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remainder of the period.
Unit 2 operated at or near 100% power for the entire period.
I.
Doerations
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t.onduct of Operations
01.1 Reactor Defuelina Practices and the Licensina Basis
a.
Inspection Scone
In February and March 1996, the inspectors reviewed Braidwood's current
licensing basis for spent fuel decay heat removal to ensure consistency
with station core offload practices. The review included Section 9.1.3
of the Braidwood Updated Final Safety Analysis Report (UFSAR), Technical
Spec.' fications (TSs) 3.9.3 and 3.9.11, and Braidwood procedures BwAP
370-3, " Administrative Control During Refueling," and 1/2BwGP 100-6,
" Refueling Outage." The review was prompted by an event at Millstone,
Unit 1, during which the spent fuel pool (SFP) cooling system may have
been incapable of maintaining pool temperature below the design limit.
This event was discussed in NRC Information Notice 95-54, " Decay Heat
Management Practices During Fuel Outages," (IN 95-54).
b.
Observations and Findinas
Three cases of refueling modes were discussed in Section 9.1.3 of the
UFSAR:
1) Normal Refueling Discharge (nominal 84-assembly discharge -
1/3 of the core offloaded); 2) Full Core Discharge (193 assemblies); and
3) Abnormal Discharge (Full Core Discharge 17 days after a 1/3 discharge
from the other unit).
Each case assumed that the reactor had been
subcritical for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, as required by TS 3.9.3, before defueling
began.
In case 1, the maximum calculated heat load was 35.91 million
British thermal units / hour with a maximum SFP temperature of 138.5
degrees fahrenheit (*F) assuming a single active failure of one train of
SFP cooling. The maximum SFP temperature for case 3 (the most limiting
case) was determined to be 158 'F.
Braidwood had been pract:cing full
core discharges (case 2) during refueling outages.
The licensee also conducted an independent review of SFP cooling
following receipt of IN 95-54 and concluded that the licensing basis had
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been adequately incorporated into the procedures. Based on this review,
the licensee planned two changes intended to remove ambiguities in the
UFSAR and clarify procedures to insure adherence to the UFSAR during
refueling activities.
The 'iicensee's first change was to revise the UFSAR to explicitly state
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that the current full core offload practice was the " routine" or normal
practice.
The second change was to add the UFSAR defueling rate basis
of three assembiies per hour as a caution statement to procedure BwAP
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370-3, " Administrative Control During Refueling," Revision 15.
This
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procedure improvement was to assure that fuel offloads would not be
completed in less than 128 hours0.00148 days <br />0.0356 hours <br />2.116402e-4 weeks <br />4.8704e-5 months <br /> for the 1/3 core discharge and 164
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hours for the full core discharge without a prior engineering
evaluation.
In addition, the licensee proposed to update the generic
outage schedule to reflect the assumptions in the SFP design basis
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analysis for core offloading. The licensee informed the inspectors that
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the UFSAR change regarding the current full core offload practice and
other minor clarifications to the UFSAR would be incorporated during the
next UFSAR update to be submitted on December 16, 1996.
c.
Conclusion
The inspectors concluded that the licensee's refueling practice and
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procedures were consistent with the licensing basis and adequately
incorporated the current design-basis of the UFSAR.
In addition, the
inspectors verified that procedures had been revised as planned by the
licensee.
UFSAR revision verification is an outstanding item and will
be followed up in a future inspection (Inspection Followup Item (IFI)
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50-456/96011-01).
02
Operational Status of Facilities and Equipment
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02.1 Walkdown of Plant Safety Systems
a.
Inspection Scope (71707)
On July 10-18, the inspectors conducted a detailed walkdown using
appropriate procedures and drawings of the Unit I auxiliary feedwater
(AFW) system, the Unit I safety injection (SI) system, and the Unit 2
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fuel pool cooling and clean-up system to verify operability of the
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systems and to ensure that the lineup procedures, plant drawings, and
the as-built configuration were current.
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b. Observations and Findinas
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The inspectors performed a walkdown of the Unit 1 AFW system using
Braidwood operating procedures Bw0P AF-M1, " Operating Mechanical
Lineup," Revision 4, along with Piping and Instrumentation Diagram
(P&ID) drawing M-37. During the system walkdown the inspectors found one
valve that was not labeled, nor identified on the Bw0P AF-M1 lineup
procedure and P&ID drawing. The valve was an instrument isolation valve
for pressura indicator, IPI-AF150.
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The walkdown of the Unit 1 SI system was performed using Bw0P SI-M1,
Revision 6, along with P&ID drawing M-61, sheets 1 through 6.
The
inspectors found no discrepancies.
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The walkdown of the Unit 2 fuel pool cooling and clean-up system was
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performed using Bw0P FC-M1," Operating Mechanical Lineup," Revision 3,
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along with P&ID drawing M-63, sheets la through Ic. The inspectors
identified that 0FC003, the refueling water purification pump OB suction
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valve, was drawn as closed on the P&ID, but listed as open on Bw0P FC-
M1.
Licensee personnel stated that an action request to make a valve label
had been written and the need to change the plant drawings would be
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evaluated by September 30, 1996.
c.
Conclusions
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.The inspectors concluded that the current valve lineup status of the
Unit 1 AFW, Unit 1 SI, and Unit 2 fuel pool cooling system was good.
02.2 Dearaded Unit 2 Reactor Coolant System Leakaae Detection Eauioment
a.
Inspection Scope (71707)
At 5:45 p.m. on July 16, 2PR011J, the Unit 2 containment
atmosphere radiation monitor was declared inoperable after health
physics (HP) personnel informed the shift engineer that, as of
July 6, results of analyses of non-radioactive hydrogen samples
and particulate and gaseous radioactivity samples taken daily from
the monitor by HP personnel were lower than those taken before
July 6.
The inspectors observed that the gaseous radioactivity
samples were lower by a' factor of one hundred. The licensee
assembled a team of personnel from the operations, instrument
maintenance, system engineering, and HP departmein.s to investigate
the cause of the problem. The inspectors, who had been reviewing
the status of the monitor following the computer malfunction,
observed several team meetings and some troubleshooting
activities, interviewed the health physicist and the Unit
operating engineer, and reviewed sample results.
b.
Observations and Findinas
The licensee calibrated the monitor, identified no as found
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discrepancies, and determined that the radiation detectors, the
associated electronics, and the sample pump were operating
properly. Monitor fittings were then checked to ensure there was
no air inleakage.
Finally, operations personnel compared the mechanical lineup of
the monitor as listed in Bw0P AR/PR-M2, the operating mechanical
lineup for area and process radiation monitors, with the actual
configuration. Whereas the configuration for the Unit 2 monitor
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agreed with the lineup, and the configuration for the Unit 1
monitor (IPR 011J) agreed with its lineup; the configuration of
2PR011J was different from that of IPR 011J.
For Unit 2, the valve
lineup had the containment sample directed through a dryer.
For
Unit 1, the dryer was bypassed. The inspectors noted that
although the dryer was valved-in on Unit 2, the dryer was not
operating.
In addition, an operator-aid label by the local
control switch for valving the dryer in or out directed that the
dryer be left in bypass and would normally be used only if there
was high moisture in the containment atmosphere.
On July 17, Bw0P AR/PR-M2 for Unit 2 was subsequently revised to
bypass the dryer during normal operations (consistent with Unit I
and with Byron). The local control switch was then moved to the
bypass position and a sample was taken from the monitor. The
results were comparable to those obtained before July 6,
indicating the problem had been air in leakage through the dryer
to dilute the sample. The licensee followed ep by writing a work
request to repair the leak in the dryer and a formal evaluation of
the monitor's operability from July 6-17.
The health physicist stated to the inspectors that the lower sample
readings were considered normal at first because the Unit had dropped
power to shift feed pumps. However, the readings should have returned
to normal the next day and did not. The health physicist stated that
this concern was passed on to the unit operating engineer by leaving a
note on his desk. The operating engineer stated to the inspectors that
he did not remember receiving this note.
c.
Conclusions
The inspectors concluded that there was poor communication between
HP and operations. The HP technician's cor.cern about the proper
functioning of the monitor was not passed on to the Shift Engineer
(SE) until ten days after the problem arose.
In addition, the
configuration control discrepancy was another example of an
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ongoing problem. The inspectors concluded that the licensee's
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team that investigated the problem was well coordinated and
thorough. The results of the evaluation of the monitor's
operability will be reviewed at a later date (Unresolved Item
(URI) 50-457/96011-02).
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04
Operator howledge and Performance
04.1 Containment Purae Radiation Monitors Inocerable Durina Unit 1
Containment Release
a.
Inspection Scone (71707)
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On June 20, the Unit 2 reactor operator (RO) placed the Unit I and Unit
2 containment purge particulate radioactivity samplers, IPR 0lJ and
2PR0lJ, in the purge mode, which rendered them inoperable, at the same
time a Unit I containment release was in progress. The Unit 2 R0
performed this action at the request of a radiation protection
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technician (RPT). The inspectors interviewed the SE and the PRT and
also reviewed BwRP 5820-7, " Process Radiation Monitor Particulate Filter
and Iodine Cartridge Replacement," and BwRP 6110-13, " Containment Vent
and Mini-Purge Gaseous Effluent." The inspectors also reviewed Offsite
Dose Calculation Manual (0DCN), Section 12.2.2, and a statement of what
happened written on June 21 by the SE.
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b.
Observations and Findinas
On June 20, at 5:08 a.m., the Unit 1 R0 started a Unit I containment
release. At 5:09 a.m., the Unit 2 R0 placed the Unit I and Unit 2
containment purge particulate activity samplers IPR 0lJ and the 2PR01J in
the purge mode, which rendered them inoperable, at the request of an
RPT. At about 5:20 a.m., the Unit 2 R0 informed his supervisor that the
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IPR 01J was in p rge mode. The SE stated to the inspectors that when he
overheard that the IPR 01J was in purge he recognized it as a potential
problem and at 5:26 a.m., directed that the release be secured. The
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IPR 01J was then restored to service and the release was restarted at
about 5:29 a.m.
The SE stated that after the release was restarted he reviewed the
containment release procedure, BwRP 6110-13. A note in the procedure
stated, in part, that only one release could be performed with each
noble gas and tritium aaalysis. After reading the note, the SE
concluded that the restart of the release at 5:29 a.m. constituted
another release for wt .h a new analysis was not performed, contrary to
the procedure note. The SE then had the second release terminated,
about 5:32 a.m.
According to the SE, the Unit 2 R0 told him that he (the RO) was not
aware of the Unit I release nor of the requirement to secure the release
if IPR 0lJ became inoperable.
The RPT that requested the IPR 01J and 2PR01J be placed in purge was
changing filters per BwRP 5820-7. A note under step 2 of the procedure
required the RPT to ensure that there were no containment releases in
progress prior to proceeding. The RPT stated that she was aware that a
release was phnned for that shift, but did not know that it was in
progress when she called the control room.
She also stated that she did
not have the procedure with her when changing the filters. The SE
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stated to the inspectors that the RPT was not required to have the
procedure in hand when changing the filters and that she stated to him
that she was not aware of the note. The inspectors verified that it was
not a procedural requirement to have this procedure in hand when
changing filters.
IPR 0lJ monitored noble gas, iodine, and pcrticulate. ODCM, Section
12.2.2, Table 12.2-3, Action 37, stated, in part, that with the IPR 01J
noble gas channel inoperable effluent releases must be immediately
suspenJad.
The inspectors verified the flow pathway for the release was
through the Unit I ventilation stack which was monitored for noble gas,
particulate, and iodine by IPR 028J. The inspectors verified that the
IPR 028J was operable between 5:00 a.m. and 6:00 a.m. on June 20.
The licensee performed the following corrective actions:
The R0 and the RPT were counselled about the importance of knowing
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and understanding procedural requirements.
The licensee determined that this operating crew had previously
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made several errors. Licensee management replaced the SE on this
crew with a more experienced SE. The less experienced SE was
placed with a more experienced crew.
The RP shearvisor stated that RPTs used a check off list when
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performing daily radiation monitor surveillances. The requirement
to verify a containment release was not in progress was added to
the check off list.
Procedure BwRP 5820-7 was changed to incorporate in
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the body of the procedure the required verification
that a containment release was not in progress.
c.
Conclusions
The inspectors concluded that the safety consequence of this event was
small because the release was monitored by IPR 028J and that the amount
of activity released was within the limits of BwRP 6110-13.
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The inspectors concluded that the communications between the Unit 2 and
Unit 1 R0, and between the RPT and the Unit 2 R0 were poor.
The inspectors concluded that the procedure used to change the T'1ters
on IPR 0lJ (BwRP 5820-7) was weak because it had an action statement in a
note instead of in either the prerequisites section or a procedure step.
The note under step 2 of the procedure stated, in part, to ensure that
there were no containment releases in progress prior to proceeding.
The inspectors concluded that the failure to verify that a containment
release was in progress prior to placing the IPR 01J in purge as required
by procedure BwRP 5820-7, " Pro:ess Radiation Monitor Particulate Filter
and Iodine Cartridge Replacement," and the restart of the release
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without obtaining another containment release form as required by BwRP
6110-13, " Containment Vent and Mini Purge Gaseous Effluent" were
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examples of a violation of TS 6.8.1.a.
This licensee identified and
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corrected violation is being treated as a Non-Cited Violation,
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consistent with Section VII.B.1.of the NRC Enforcement Policy (50-
456/96011-03).
07
Quality Assurance in Operations
07.1 Reaular Plant Operations Review Committee (PORC) Meetina
a.
Inspection Scope (40500)
The inspectors reviewed site quality verification (SQV) written
observations from a PORC meeting SQV observed on May 14, 1996. The
inspectors reviewed the station administrative procedure on PORC
meetings, BwAP 1205-13, " Plant Operation Review Committee." The
inspectors also attended a PORC meeting on July 12.
b.
Observations and Findinas
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The SQV written observations of the PORC meeting on May 14 stated that
there were several problems with the meeting.
1.
The meeting started short of a quorum of regular members.
2.
Only two of the seven individuals listed as material presenters
actually attended the meeting.
3.
The attendees had not reviewed the material before the meeting
started.
4.
Material was presented that was still in draft form and was not
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ready for PORC review.
5.
The focus of the reviews conducted was on the number of action
items and not on the correctness and timeliness of the items.
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On July 12, the inspectors observed that a quorum of regular members
were present when the meeting started, all of the presenters were at the
meeting, and the material distributed was in a finalized form and ready
for presentation.
However, the inspectors noted that the presented material was not
distributed until about 8:00 a.m. on July 12. The PORC meeting started
at 11:00 a.m.
Most PORC members were in regularly scheduled meetings
between 8:00 and 10:00 a.m.
This allowed a limited time for premeeting
review.
The inspectors observed that one of the committee members
pointed out an inappropriate action that occurred during one event that
was not listed in the material. This indicated to the inspectors that
at least one member of the committee had reviewed the material even
though limited time was available.
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One agenda item was not discussed during the meeting because the station
manager included an unscheduled discussion on the station's preparedness
for implementation of a new out-of-service procedure the following week.
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The agenda item was moved to the next scheduled PORC meeting.
The
corrective actions for the other two agenda items were rejected based on
the adequacy of the investigations and the corrective actions presented.
This demonstrated to the inspectors that the PORC had the proper focus
on the material presented. The agenda items met the requirements for
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items to be reviewed as described in BwAP 1205-13.
c.
Conclusions
The inspectors made the following conclusions: 1) SQV was effective in
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communicating and the station was effective in correcting the weaknesses
previously observed; 2) there was inadequate time for a premeeting
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review of material by all PORC members; 3) the material reviewed was
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appropriate for the PORC, including the unscheduled discussion on the
out-of-service procedure; and 4) the rejection of the two agenda items
because of the adequacy of the investigations and corrective actions was
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appropriate.
08
Miscellaneous Operations Issues (92700)
08.1
(Closed) URI 50-456/457/95010-03: Waste Gas Valve Mispositioning.
Waste gas oxygen detector instrument sample chamber isolation valve,
0GWO70, was found mispositioned on five separate occasions between May
31 and August 18, 1995. The licensee's review of this situation could
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not establish that any of the mispositionings were deliberate. The
inspectors concluded that the licensee's corrective action (locking the
door to the room where the valve was located) in this specific case was
adequate based on no further occurrences of the valve being found
mispositioned. On May 16, 1996, a violation was issued for the failure
to take corrective actions regarding plant configuration control
problems (50-456/457/96005-05). Tne inspectors verified the corrective
actions for that violation as described in the licensee's response
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letter, dated June 14, 1996, to be reasonable and complete.
Based on
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the corrective action taken in this specific case and the broader based
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corrective actions described in the letter, this item is closed.
08.2 (Closed) URI 50-456/457/95017-01: Configuration Control Problems. The
inspectors identified a trend when three valves were found mispositioned
during the inspection period. On May 16, 1996, a violation was issued
for the failure to take corrective actions regarding plant configuration
control problems (50-456/457/96005-05). The inspectors verified the
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corrective actions for that violation as described in the licensee's
response letter, dated June 14, to be reasonable and complete.
Based on
these actions, this ites is closed.
08.3 (Closed) URI 50-456/457/96008-01: Continued Problems With Out-0f-
Service and Configuration Control. Between March 21 and April 24, the
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licensee identified configuration control problems with 14 separate
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components. On May 16, a violation were issued for the failure to take
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corrective actions regarding plant configuration control problems (50-
456/457/96005-05). The inspectors verified the corrective actions for
those violations as described in the licensee's response letter, dated
June 14, to be reasonable and complete.
Based on these actions, this
item is closed.
08.4 (Closed) URI 50-457/96009-01: Mispositioned 6.9-kilovolt breaker
on May 12 due to miscommunications and a failure to follow
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procedure Bw0P MP-8, " Restoring Unit 2 Main Generator, Main Power
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Transformers 2E and 2W, and Unit Auxiliary Transformers 241-1 and
241-2."
The licensee's investigation determined that the root
cause was poor communications and that corrective actions from
previous events should have prevented this problem. The
inspectors concluded that the failure on May 12, to rack in
breaker 2581, for the Unit Auxiliary Transformer feed to 6.9-
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kilovolt bus 258, when restoring Unit Auxiliary Transformer 241-2,
as required by Bw0P MP-8, was an example of a violation of TS 6.8.1.a. which, in part, required implementation of procedures
recommended in Appendix A, of Regulatory Guide 1.33, " Quality
Assurance Program Requirements (Operations)," Revision 2, February
1978 (Violation 50-457/960ll-04a).
II. Maintenance
M1
Conduct of Haintenance
M2.1 Ju=ner For Controller OPDC-VWOO8
a.
Event (62703)
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On July 10, System Engineering generated Problem Identification Form
(PIF) 456-201-96-1574 to document that a potential unmonitored release
from the radioactive waste (radwaste) building occurred due to a
ventilation supply damper being jumpered cpen. Two aspects of this PIF
were researched by the inspectors: whether an unmonitored release
actually occurred and the administrative controls used to control the
installation of the jumper.
The inspectors reviewed BwAP 400-9, " Maintenance Alterations," BwAP
2321-18, " Temporary Alterations," and work request 960065296. The
inspectors interviewed RP personnel, the system engineer, the instrument
maintenance (IM) first-line supervisor, IM personnel, the system
engineering manager, the IM work planner, and operations shift
personnel. The inspectors also performed a walkdown of the installed
jumper assembly.
b.
Observations and Findinas
Potential Unmonitored Release:
RP and System Engineering personnel
concluded no unmonitored release occurred. This conclusion was based on
air samples taken in the radwaste building, the assumed duration of the
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condition (less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), and the activities that were in progress
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when the condition existed. The inspectors were unable to reach the
same conclusion because the bases for the conclusion, including the air
sample results, were not documented and could not be reviewed. However,
due to increased sensitivity by plant personnel regarding the initiating
event, RP planned to perform an analysis of the event and compile
documentation to substantiate their conclusions. The decision t<:
perform the analysis was made on July 23 and the results of the analysis
were scheduled to be reviewed at a plant operations review committee
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meeting on August 16, 1996.
Jumper For Controller OPDC-VW008: On the midnight shift of July 9, the
radwaste building fans were off in the pull-to-lock position with the
supply dampers closed due to a failure of a pressure transmitter.
Operations personnel determined that it was necessary to operate the
radwaste building ventilation system in order to generate more flow up
the auxiliary building stack during a containment release.
l
As part of the work request 960065296 to repair the damper, a pneumatic
jumper without a pressure regulator was installed on controller OPDC-
VW008 to fail tie damper open and allow operation of the ventilation
systea. After the containment release was complete the radwaste
ventilation system was secured. With the damper failed fully open,
radwaste building negative pressure approached 0.0 inches water gauge,
which led plant personnel to conclude that the potential for an
unmonitored release existed. Section 9.4.3.3.2.c of the UFSAR,
stipulated that the ventilation system control radwaste building
negative pressure be at least 0.125 inches negative water gauge.
The jumper was controlled using BwAP 400-9, " Maintenance Alterations."
Use of BwAP 400-9 allowed the jumper to be controlled by the work
request while the work request was still open and work was-in progress.
When the IM first-line supervisor arrived at work for day shift on
July 9, he reviewed the work package from the midnight shift.
Since the
containment release was complete, operation of the radwaste building
ventilation system was no longer required and the system was off. The
IM supervisor stated, upon review of the documentation, that the jumper
should have been covered by temporary alteration controls (as opposed to
maintenance modification controls) if the jumper was to remain in place.
The IM supervisor instructed his workers to remove the jumper and then
notified IM work planners that a temporary alteration was required for
re-installation of the jumper.
Based on discussions with system engineering and operations personnel',
the IM work planners decided to revise the work request on July 9, to
install a temporary jumper with a pressure regulator and control the
jumper using BwAP 400-9, " Maintenance Alterations." The regulator used
in the jumper allowed manual control of the damper. Operators checked
radwaste building pressure twice a shift and adjusted the regulator for
the jumper as needed to maintain building negative pressure greater than
or equal to 0.125 inches water gauge. This jumper was installed on July
9, and was still in place on July 25.
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The inspectors questioned plant personnel on the use of BwAP 400-9,
Maintenance Alterations, instead of BwAP 2321-18, " Temporary
Alterations," to control the re-installation of the jumper.
System
engineering and operations personnel stated that, since the work package
for the damper was still open and the system was not safety-related,
BwAP 400-9 could be used.
The inspectors reviewed the applicable procedures and found guidance
that conflicted with the logic used by the operations and system
i
engineering personnel.
Specific items noted by the inspectors included:
BwAP 400-9, " Maintenance Alterations," step C.3 stated:
-
"If the alteration is to be turned back to the Operating
.
Department, and the item is to be declared operable, then
"
any remaining Temporary Alterations will be documented in
accordance with BwAP 2321-18.
For example, if a work
function is interrupted by the lack of replacement parts and
it cannot be restored to its original design condition and
an alteration has been installed to make the item operable,
BwAP 2321-18 will be initiated."
,
Work request 960065296 was started July 9, and, as of July 25, was
-
ongoing due to unavailability of replacement parts for the
controller. The jumper installed as part of the work package was
still installed to allow operations to run the system. This case
exactly duplicated the example presented in step C.3.
BwAP 2321-18T11, " Determination of Temporary Alterations," step
.
C.1 stated:
"A work request with a Maintenance Alteration Form will not
be used to track temporary installation, removal, or
replacement of equipment if the equipment is of different
form, fit or function than the original; requires different
operating procedures; or requires a change to plant design
documents."
The temporary jumper with the regulator was of different form, fit, and
function than the original equipment. Additionally, since control of
radwaste building pressure was manual instead of automatic, the
operating procedure with the jumper for the radwaste system was
different than with the original equipment.
For these reasons, the
inspectors concluded that the jumper installation should have been
controlled by BwAP 2321-18.
c.
Conclusions
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Use of BwAP 400-9 to control the second installation of the jumper for
controller OPDC-VWOO8 on July 9 was contrary to the requirements of
procedures BwAP 400-9 and BwAP 2321-18. The failure to follow
procedures was an example of a violation of TS 6.8.1.a, which required
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that procedures be established, implemented, and maintained for
activities covered in Appendix A of Regulatory Guide 1.33 (50-456/96011-
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04b).
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M7
Quality Assurance in Maintenance Activities
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M7.1 Maintenance Report and Self-Assessment
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a.
Inspection Scope (40500)
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+
The inspectors:
1) interviewed the maintenance superintendent and
members of the maintenance staff, and 2) reviewed maintenance department
!
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self-assessment reports, data, and corrective actions.
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b.
Observations and Findinas
,
Two self-assessment methods were used. The first was a statement by
each sub-department (e.g., mechanical or electrical) head of what were
.
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the strengths and weaknesses of the department.
Each department then
developed a list of strategies / corrective actions to address weaknesses.
The licensee planned to reperform the self-assessment effort every
,
quarter with the next coming due July 31. .The second was a compilation
'
and trending of data from several different sources: maintenance field
monitoring reports, quality control deficiency reports, and station
'
problem identification forms.
The inspectors observed that some sub-departments stated specific
weaknesses, but did not indicate any actions to address the weaknesses.
The inspectors also observed that the compilation of trending data
'
showed that the corrective maintenance backlog was growing. The data
also showed that the average work request age had about doubled, to over
'
200 days, in the past 12 months. The maintenance superintendent stated
that there were several initiatives to make the departments more
efficient in order to bring down the backlog.
For example, senior work'
crew members instead of first line supervisors were making in field
decisions on such things as whether scaffolding should be used and
ordering parts. This took some of the work load off first-line
supervisors. The maintenance superintendent also stated that the reason
the average age of work request had gone up was that many of the work
requests were waiting on unresolved engineering issues. The maintenance
superintendent stated that unbudgeted money had been allotted from Comed
corporate headquarters to accelerate material condition improvements and
some of this money had been allocated to hire contractors to
specifically work off older work requests. The maintenance
superintendent stated that these activities would commence soon, but did
not know exactly when.
c.
Conclusion
The inspectors concluded that the licensee's corrective actions of
removing workload from the first line supervisors and hiring contractors
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to work off longstanding work requests were reasonable corrective
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actions. ; However, some of the departments' assessments lacked depth and
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did not address all the items identified as weaknesses. The maintenance
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department heads did not state in their assessments the severity of the
weaknesses. The inspectors were unclear whether all the weaknesses
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mentioned were major or if some were just areas that could be improved.
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III. Enoineerina
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El
Conduct of Engineering
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El.1 Ooerability Assessments
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a.
Inspection Scone (37551)
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The inspectors reviewed the operability assessment process and its
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implementation to determine the technical adequacy of selected
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assessments, compliance with 10 CFR 50.59, and conformance to
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UFSAR design requirements, applicable codes &nd standards.
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b.
Observations and Findinas
!
The inspectors determined that a tracking mechanism was not in
place to identify which assessments were still open; which did not
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conform with applicable codes and standards; which did not meet
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UFSAR design requirements; and which involved a condition of a
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structure, system, or component where a compensatory action was
!
needed to ensure functional capability. Also, the existing
tracking process was not proceduralized.
The inspectors requested that the licensee provide a list of open
and completed assessments that identified compensatory and
corrective actions needed to ensure o)erability, including
deviations from UFSAR commitments. T1e licensee could not readily
provide the data requested.
Subsequently, the licensee initiated
a new computer program that would include the status of
assessments and required corrective actions to close any
identified concerns.
The inspectors examined six assessments and found them, in
general, technically adequate. However, the inspectors identified
the following concern regarding operability screening 95-026
(Attachment B).
This assessment was performed to justify
operability of the containment spray additive tank with nitrogen
to the tank isolated for maintenance. The assessment stated that
a nitrogen blanket of approximately 1 pound per square inch gauge
was used to maintain an inert atmosphere in the tank to prevent
degradation of the sodium hydroxide. To enable maintenance on the
pressure control loop, nitrogen would be isolated. The assessment
further stated that this condition was acceptable for up to 30
days, provided the low pressure relief was still operable or the
tank was vented to atmosphere. The assessment concluded that the
30-day isolation of nitrogen would not significantly degrade the
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sodium hydroxide. 'When questioned by the inspectors, the licensee
could not provide documentation of the technical bases or
engineering justification that isolation of the nitrogen for 30
days would not degrade the sodium hydroxide. This is an inspector
followup ites (50-456/96011-05).
c.
Conclusions
The inspectors concluded that, in general, the operability
assessments reviewed were technically adequate; however, the
inability to readily determine the status of open assessments was
a weakness.
E8
Miscellaneous Engineering Issum
E8.1
(Ocen) Violation 93022-Ola:
Inadequate actions to correct auxiliary
building ventilation system construction problems resulting in a fire
door impairment. Due to initial construction scheduling deficiencies
causing the ventilation exhaust ducts to be installed in a tortuous
path, the exhaust systen had more backpressure than it was designed for.
Thus, restricted flow in the ducts caused the fans to operate in or near
the stall region of their operating curve, resulting in the blades being
fatigued by the cyclic backpressure waves in the ducts and subsequently
'
failing when operating with two supply fans and two exhaust fans
running. To prevent this, the auxiliary building ventilation system was
operated in a configuration outside the original design with one supply
fan running and one exhaust fan running, typically resulting 1n a high
differential pressure on the main access door between the auxiliary and
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turbine buildings. A fire door adjacent to the main door was maintained
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open to reduce the pressure on the main door and allow personnel to
safely enter and exit. The Updated Final Safety Analysis Report does
not state how many supply and exhaust fans should have normally been
running. However, the design basis for the auxiliary building exhaust
system, paragraph 6.5.1.1.2.b, states that on a loss of coolant accident
'
concurrent with a loss of offsite power, the auxiliary building supply
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and exhaust fans powered by the unit are tripped and two out of six
charcoal booster fans are started to maintain a negative pressure in the
auxiliary building and route exhaust air through charcoal adsorbers and
high efficiency filters before exhausting to the outdoor atmosphere,
The running of one supply fan and one exhaust fan does not appear to
conflict with their design basis.
The licensee was in the process of replacing the cast aluminum
blades of the exhaust fans with forged aluminum blades. The
replacement blades should offer better fatigue resistance to the
apparent cycle fatigue the existing blades were experiencing.
However, because of the long lead time (approximately one year) to
obtain the blades, exhaust duct modifications were currently in
progress downstream of the exhaust fans. These should reduce the
backpressure and allow the existing fans to operate properly.
In
parallel with the modifications, the licensee was actively
evaluating adding an additional intake plenum to the auxiliary
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building which would further reduce the pressure on the existing
personnel door and allow the fire door to be closed. This
modification would also have the advantage of allowing only
filtered air into the auxiliary building. This item remains open
pending the completion of the licensee's actions to address the
fire door impairment.
E8.2
(Closed) URI 50-456/96009-06: 2B SI Pump Room Not Able To Satisfy
Pressure Requirements. This item was opened pending inspector review of
the licensee's resolution of three issues, as described below:
a.
Reason for apparent movement of the caution card hung on the
instrument air (IA) supply valve to controller OPDC-VA192:
The
caution card was moved inadvertently during troubleshooting (by
system engineering and operations personnel) of the failed open
damper on June 3.
The licensee determined that moving the caution
card was not the root cause of damper OVA 303Y failing open. At
some time between January 23 and June 3, damper OVA 303Y opened due
to a combination of two conditions:
The IA supply valve for controller OPDC-VA192 leaked past
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its seat.
An air vent valve for controller OPDC-VA192 that was opened
.
on January 23 was closed. With the IA supply valve leaking
by and the vent valve closed air pressure built up and
opened the damper. This vent valve did not have a caution
card affixed and no other plant controls were 1n place to
ensure the valve remained open.
Efforts by the licensee and
the inspectors to identify the actual date that the vent
valve was closed have been unsuccessful.
b.
Period of time that the refueling water storage tank pipe tunnel
hatch seal was degraded: The exact date that the seal was
degraded has not been determined; however, since the surveillance
test for the 2B SI pump room met its acceptance criteria when it
was performed on January 23, it can be concluded that the seal was
not degraded sufficiently on January 23 to adversely affect SI
pump room pressure. The inspectors concluded the seal degraded
sometime between January 23 and June 3.
A refueling outage
occurred during that period and the hatch was accessed to route
equipment cables for steam generator eddy current testing.
c.
Period of time Unit 2 was unable to meet TS vacuum limit:
The
exact date that damper OVA 303Y failed open was not known; however,
a picture taken in the Unit 2 curved wall area on April 15, showed
that the damper was open. Therefore, from at least April 15 until
June 3, TS 3/4.7.7.d.3 was not satisfied for the 2B SI pump room.
Failure to satisfy pressure requirements for the 2B SI pump room for a
period between at least April 15 and June 3, is a violation of TS
3/4.7.7.d.3.
The root cause of the TS violation was the failure to
,
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maintain proper configuration control over the IA valves that controlled
the damper. On May 16, a violation was issued for the failure to take
t
corrective actions for plant configuration control problems (50-
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456/457/96005-05). The inspectors verified the corrective actions for
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that violation as described in the licensee's response letter, dated
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June 14, to be reasonable and complete.
Based on the corrective action
l
taken in this specific case (the damper was repaired and the hatch was
sealed) and the broader based corrective actions described in the
l
letter, this item is closed.
1
V. Manacement Meetinas
X1
Exit Neeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on July 26, 1996. The
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licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary. No proprietary
information was identified.
.
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<.o
PARTIAL LIST OF PERSONS CONTACTED
Licensee
- H. G. Stanley, Site Vice President
T. Tulon, Station Manager
- H. Pontious, Nuclear Licensing Administrator
W. McCue, Support Services Director
R. Flessner, Site Quality Verification Director
- J. Stone, Maintenance Work Director
R. Byers, Maintenance Superintendent
- D. Miller, Work Control Superintendent
- T. Simpkin, Regulatory Assurance Supervisor
- H. Cybul, System Engineering Supervisor
- A. Haeger, Health Physics and Chemistry Supervisor
- F. LeSage, Site Quality Verification Audit Supervisor
- J. Meister, Engineering Manager
- D. Cooper, Operations Manager
- M. Cassidy, Regulatory Assurance - NRC Coordinator
E.C
L. Miller, Chief, Reactor Projects Branch 4
- C. Phillips, Senior Resident Inspector
- M. Kunowski, Resident Inspector
IDM
T. Esper
Present at the exit meeting
17
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I
INSPECTION PROCEDURES USED
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IP 37551:
Onsite Engineering
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Prob ms
t
IP 71707:
Plant Operations
IP 71750:
Plant Support Activities
IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power
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Reactor Facilities
l
IP 92902:
Followup - Engineering
ITEMS OPENED, CLOSED, AND DISCUSSED
'
Opened
50-456/96011-01; 50-457/96011-01
IFI
review UFSAR revision on defueling
50-457/96011-02
review operability of rad monitor
50-456/96011-03
failure to follow containment
release
procedure
50-457/96011-04a
failure to follow transformer
,
restoration procedure
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50-456/96011-04b; CD 457/96011-04b VIO
failure to control jumper
50-456/96011-05; 50-457/96011-05
IFI
justification of 30-day limit for
isolating nitrogen to spray add tank
GlQ1td
50-456/95010-03; 50-457/95010-03
waste gas valve mispositioning
50-456/95017-01; 50-457/95017-01
configuration control problems
50-456/96008-01; 50-457/96008-01
continued problems with out-of-
service and configuration control
'
50-457/96009-01
mispositioned 6.9-kilovolt breaker
50-456/96009-06; 50-457/96009-06
28 SI pump room unable to satisfy
pressure requirements
50-456/96011-03
failure to follow containment
release
procedure
Discussed
50-456/93022-01a; 457/93022-01a
inadequate actions to correct
auxiliary building ventilation
system construction problems
50-456/96005-05; 50-457/96005-05
failure to take corrective actions
regarding plant configuration
control
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LIST OF ACRONYMS USED
1
CFR
Code of Federal Regulations
Health Physics
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Instrument Air
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IFI
Inspection Followup Item
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IM
Instrument Maintenance
J
IN
Information Notice
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1
Non-Cited Violation
i
NRC
Nuclear Regulatory Commission
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Offsite Dose Calculation Manual
Problem Identification Form
Public Document Room
4
I
Piping and Instrumentation Diagrams
Plant Operations Review Committee
R0
Reactor Operator
Radiation Protection Technician
Shift Engineer
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Spent Fuel Pool
Safety Injection
SQV
Site Quality Verification
,
TS
Technical Specification
9
Updated Final Safety Analysis Report
Unresolved Item
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Violation
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