ML20129F112
ML20129F112 | |
Person / Time | |
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Site: | Zion File:ZionSolutions icon.png |
Issue date: | 10/22/1996 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20129F025 | List: |
References | |
50-295-96-10, 50-304-96-10, NUDOCS 9610290030 | |
Download: ML20129F112 (25) | |
See also: IR 05000295/1996010
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket Nos: 50-295, 50-304
Report No: 50-295/96010, 50-314/96010
Licensee: Commonwealth Edison Company
Facility: Zion Nuclear Plant, Units 1 and 2
Location: Opus West III
1400 Opus West III '
Downers Grove, IL 60515
Dates: July 13 - August 29, 1996
Inspectors: R. A. Westberg, Senior Resident Inspector
D. R. Calhoun, Resident Inspector
D. M. Chyu, Resident Inspector
D. E. Jones, Reactor Engineer
S. K. Orth, Health Physics Specialist
J. L. Belanger, Security Specialist '
J. Yesinowski, Illinois Department of
Nuclear Safety (IDNS) Inspector
Approved by: Lewis F. Miller, Jr., Chief 4
Reactor Projects Branch 4
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9610290030 961022
PDR ADOCK 05000295
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PDR 0n
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l EXECUTIVE SupMARY
j Zion Nuclear Plant, Units 1 and 2
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NRC Inspection Reports 50-295/96010; 50-304/96010
l This integrated inspection included aspects of licensee operations,
! engineering, maintenance and plant support as a result of the routine
{ inspections by the resident inspectors, a regional radiation specialist, a
] regional security specialist, and a reactor engineer.
Operations
e The briefing for the Unit I startup was good (Section 01.2).
{ e There were a significant number of rod position indication system
! problems during the Unit 1 startup (Section 01.3).
{ e Licensed operators failed to include a valve in the partial clearing of
j an out-of-service on the auxiliary steam system which resulted in cross-
- tying the auxiliary steam system with the service air system. (Section
j 01.4).
- e A violation was identified for the second occurrence of overfilling the
i OB lake discharge tank due to non-licensed operator error (Section i
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l 01.5).
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j e A non-licensed operator misaligned a 2B diesel generator air regulation
isolation valve while performing a valve lineup verification. (Section
l 02.1).
! e A violation was identified when fuel handling personnel inadvertently !
! dropped two new fuel assemblies during new fuel assembly receipt l
l inspection due to an inadequate procedure (Section 03.1).
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j e Rod position indication problems resulted in numerous individuals l
l clustering around the process computer terminal. ;
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Maintenance
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- e A violation was identified when inadequate corrective actions were
, implemented after scaffold interfering with the Unit I turbine stop
j valves was found on June 17. On August 5, the inspectors identified
i that a scaffold around the IB containment spray pump obstructed
l operation of the IB containment spray discharge valve (Section M1.2).
l e A violation was identified for the failure of maintenance personnel to
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properly document all as-found discrepant conditions of the IB
, centrifugal charging pump (CCP) shaft-driven oil pump during an
i inspection of the pump (Section M1.3).
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e The licensee identified that poor preventive maintenance had been
performed on the main steam isolation valve limit switches (Section
M1.4).
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Enoineerina
e Engineering personnel failed to include the necessary supporting
information in an operability assessment to justify the conclusion that
the IB charging pump was operable with a degraded shaft driven lube oil
pump (Section E2.2).
Plant Support
Radioloaical Protection and Chemistry
>
e The licensee dedicated additional resources to improve as low as
reasonably achievable (ALARA) planning of work activities for the site
l construction staff. ALARA plans for site construction activities were
- well prepared and contained good radiation protection hold points and
information. However, the ALARA plans were not formally incorporated by
, the licensee's procedures to ensure that significant RP requirements
l were reflected in radiation work permits (Section RI.1).
e Weaknesses were observed in the configuration of the portable air
samplers. Sample pump exhaust ports were expelling filtered air into
the sample pump intake (Section R2.1).
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e Radiological posting problems were observed in the Auxiliary Building
- (Section R2.2).
e A violation was identified with ZRP 5820-12 "Out-of-Service
Surveillance for Radiation Monitor," for failure to specify actions to
meet the technical specification action statement requirement when
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containment high radiation monitor 2R-AR03 was inoperable (Section
R3.1).
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e Preparations for unloading new fuel were not well coordinated.
Personnel were cbserved loitering in the Auxiliary Building for l
excessive periods of time (Section R4.1). I
! Security
i e TI 2515/132, " Malevolent Use of Vehicles at Nuclear Power Plants," was
closed, as the licensee had adequately developed and implemented an
adequate Vehicle Barrier System as required (Section S1.1).
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Report Details
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Summary of Plant Status
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Unit I began this inspection report period at 100 percent power. However, the
unit tripped on August 18 due to low low level in the 10 steam generator as a
result of the closure of the ID main steam isolation valve (MSIV). The root
cause of the MSIV closure was determined to be a faulty limit switch on the
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MSIV. The unit reached criticality on August 21; however, the unit was taken
i off-line again on August 26 for an inoperable power operated relief valve.
Unit 2 began this inspection report period at 100 percent power and remained
there throughout the period.
I. Operations
01 Conduct of Operations
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent
review of ongoing plant operations.
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01.2 Briefina for the Unit 1 Startuo
a. Inspection Scope (71707)
On August 20, the shift engineer and two nuclear engineers (NEs)
conducted an infrequent evolution briefing in preparation for a Unit I
startup. The inspectors attended the briefing and reviewed the
Reactivity Management Oversight (RMO) memorandum which was issued by the
operations manager.
b. Observations and Findjnqi
The shift engineer and the NEs demonstrated leadership and provided good
direction during the briefing. The briefing was thorough and
appropriate emphasis was given to maintaining the proper safety focus
during the startup activities. Clear communications and expectations
were provided to the Unit I nuclear station operators (NS0s) regarding
their roles and rMponsioilities for assuring safe reactor startup
operations. Operations management also attended the briefing and
reiterated many of the safe practices, consistent with the RM0's
memorandum.
c. Conclusion
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The inspectors considered that the briefing was well conducted and
appropriately focused of safety. In addition, proper management
oversight was provided as indicated by the plant manager's, the
operations manager's, and the Unit 1 operating engineer's attendance at
the briefing. j
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l 01.3 linit " Reactor Startuo Observation
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! a. Inspection Scone (71715)
On August 21, the inspectors observed the Unit 1 startup from pulling of ,
j the shutdown rods through criticality. l
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! b. Observations and Findinas l
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a Due to longstanding problems with the rod position indication (RPI) !
j system, two Nuclear Engineers (NEs) were available to support the Unit 1
- crew. One NE was dedicated solely to monitor rod position indication
j problems and the other was to provide technical support to the operators ;
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as the qualified nuclear engineer (QNE). 1
The startup was well controlled and the operators closely monitored the I
panels; however, frequent RPI out-of-tolerance alarms were received. It
l appeared that there were more than the usual number of RPI alarms during
- this startup. There were 35 alarms. In addition, the crew and the NEs
! were also hampered by the process computer failing during the startup,
! without any indication of failure. The process computer was being used
to provide another indicator of individual rod positions. The frequent
! RPI problems also strained command and control during the startup, since
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the crew, NEs, and observers tended to cluster around the computer
terminal when the RPI alarms were received.
c. Conclusion
) Control rcci: decorum was good. The operators were concentrating on the
i- control boards and calling out the annunciators.
j The control room was congested at times. When there were problems with
j the RPIs, everyone tended to cluster around the NE at the computer
- - terminal.
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l The frequent RPI out-of-tolerances and failure of the process computer
- were a significant distraction to the crew during the startup.
l 01.4 Auxiliary Steam Inadvertent 1v Cross-Tied to Service Air ;
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l a, Inspection Scope (71707) '
I On August 15, the auxiliary steam system was inadvertently cross-tied to
i the service air (SA) system when a valve was overlooked during a partial
l removal of an out-of-service (005) on the auxiliary steam system. The 1
i inspectors interviewed operations and maintenance personnel reviewed the '
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00S and work request (WR) package, and parformed an inspection of the ;
l 00S error. "
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b. Observations and Findinas
When the 00S was placed for the auxiliary boiler, the WR package
directed the mechanics to connect a hose from service air to valve,
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0AX321, " Auxiliary Steam Main Header Drain Valve," to facilitate cooling I
, down the system's piping. However, the WR failed to direct the removal
of the hose after the work was completed. l
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On August 15, operations personnel partially cleared the 00S of the l
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auxiliary boiler system to facilitate generation of boric acid for the I
upcoming Unit 1 outage. In preparation, operations personnel failed to
include valve OAX321. The inspectors noted that a contributing factor l
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for this error was that the valve was not identified on the print. ;
However, the valve was listed on the original 00S as an open valve with i
, its end cap removed, and this valve did not require an 00S card i
according to the 00S. Subsequent to partially clearing the DOS and i
- valving in the steam supply to the header, the control room was informed
that there was water in the SA system. An equipment operator (E0) was
dispatched and he identified that the hose was still connected be9een
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the two systems which allowed steam into the SA system. The E0 l
immediately removed the hose and the control room notified plant l
, personnel, via the paging system, not to use SA due to the cross-tie
error.
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The SA system low point drains were opened to remove any moisture;
approximately 55 gallons of water was drained from the SA system. >
Instrument air (IA) lines were checked for water; no water was found in
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any of the IA lines. However, it was later identified that radiation
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protection technicians while performing a filter changeout on radiation
i monitor 1RIA-PR49, the Unit 1 vent stack monitor, saturated the
radiation monitor with service water while purging the radiation monitor
with SA. The technicians believed that the SA system had been purged of
service water when it had not been purged. This error was due to
miscommunication. The radiation monitor was appropriately declared
inoperable by operations.
Additionally, corrective actions included:
1. Providing station direction to comply with the temporary
alteration program.
2. Adding valve, 0AX321, to the piping and instrumentation drawing
and station operating procedures.
3. Verifying labelling on 0AX321 is accurate.
4. Providing direction to the work analysts to obtain engineering's
input for the installation of a cross-tie between systems and
assuring that work instructions (including signatures for the
cross-tie installation and removal steps) or a temporary j
alteration is used for the installation of the cross-tie.
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c. Conclusion
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The inspectors concluded that the following items contributed to this
event: 1) operator error when partially clearing the 00S; 2) failure of
the work package to specify the hose's removal as required by station
procedures; and 3) miscommunications among radiation protection
personnel.
01-5 Overflow of the OB Lake Discharae Tank (LDT)
a. Inspection Scone (93702)
On August 16, an operator failed to close 0WD-0018, the "0B LDT Inlet
Isolation Valve," which resulted in another operator overflowing the OB
LDT. Approximately 7000 gallons of slightly contaminated water was
pumped onto the floor at the 542' level of the auxiliary building (AB).
The inspectors interviewed personnel involved in this event; walked down
the rad waste panel, the waste gas and boron recovery panel, and the
542' level of the AB; and inspected the LDT inlet isolation valve.
b. Observations and Findinas
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On the day of the event, both the OA and OB LDTs were already full. The
LDTs have a total capacity of 30,000 gallons with overflow alarms set at
the level corresponding to 27200 gallons. Because the LDTs were already
full, the overflow annunciators were in the alarm position for both
tanks. Therefore, adding additional water would not cause an alarm.
The radwaste department, knowing the tanks were full, had planned to
release the LDTs to the lake on Saturday morning, August 17.
In preparation for the release, the day shift operator had performed
S01-67F1, Section 5.2, " Recirculating for Sampling, " Step 1, which was
to verify that 0WD-0118, " Lake Discharge Tank Inlet Isolation Valve,"
was closed and locked. Procedure 501-67F1 is a mandatory, in-hand
procedure; however, the operator did section 5.2 from memory. When
interviewed the operator stated that he was sure he closed the valve
because the valve stem was down. Therefore, assuming the valve was
closed, the operator locked the valve.
On the next shift, a different operator (night shift) performed S01-36M,
" Discharge Blowdown Monitor Tanks to Holdup Tanks," Section 5.1, Step
10, which was " verify locked 0WD-0018." The night shift operator noted
that the inlet valve appeared closed by observing the stem position and
that there was a lock on the valve. The procedure did not require the
operator to physically verify the valve position.
The night shift operator started the OA radwaste pump to pump from the
blowdown monitor tanks to the hold up tanks (HUTS). However, valve 0WD-
18 was partially open, so two flow paths were created instead of one:
one flow path was from the BDT to the HUT, while the other flow path was
from the BDT to the LDT. The operator went to verify level on the HUT
level gauge, ILVS-190, located on the waste gas and boron recovery panel
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in Unit 2. When the operator returned to the rad waste panel, he j
received a call from another operator reporting water on the floor of '
the AB 542' level. The operator then secured pumping to the HUT.
The addition of water from the blowdown monitor tanks directly to the OB
LDT invalidated previous sampling of the 08 LDT by the chemistry
department, which had been required prior to the scheduled release.
Therefore, the operator re-performed S01-36M and found that the inlet
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isolation valve to the OB LDT was partially open. The operator
repositioned the valve End locked it closed. !
c. Conclusion ,
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The inspectors concluded that this event was caused by inattention to
detail by non-licensed operators.
This event was of concern for two reasons. First, it was a repeat of a
previous event. On January 20, a non-licensed operator overflowed the
OB lake discharge tank and caused approximately 560 gallons of slightly
contaminated water to backup into various engineered safeguards pump
rooms and other auxiliary building spaces. That event was included as
an example of an apparent violation in inspection report 295/304-96007.
Therefore, corrective actions taken for the January 20 event appeared to
be ineffective. Secondly, an inappropriate practice was identified by
the licensee of operating with the LDT tank overflow annunciators in the
alarm position, which resulted in the second operator having no warning
that the tank was being overfilled.
Failure to verify OWD-0118, " Lake Discharge Tank Inlet Isolation Valve,"
was closed and locked in accordance with S01-67F1, Step 1, is a
violation of 10 CFR Part 50, Appendix B, Criterion V
(50-295/304-96010-01(DRP)).
An identical event was previously the subject of enforcement action, on
August 23, 1996; therefore, this event will be included as an additional
example of that violation. The inspectors observed that the response to
that violation discussed and adequately addressed the August 16
occurrence. Therefore, no separate response is required for this
violation.
02 Operational Status of Facilities and Equipment
02.1 2B Emeraency Diesel Generator (DG) Imoroner Independent Verification
a. Insoection ScoDe (93702)
On July 26, a maintenance engineer identified that the 2B DG air
regulator isolation valve to temperature control valve OTCV-SW186 was
taken out-of-service in the wrong position. The inspectors reviewed
applicable procedures; inspected the valve in the field; and interviewed
the assistant operations manager, shift engineer, equipment operators,
and the shift engineer responsible for preparing the 00S.
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A maintenance engineer, performing a pre-job walkdown on the 2B DG,
identified that the air isolation valve to OTCV-SW186 was open instead
i of closed. The 00S, No. 960009314, had designated the isolation valve j
! as a closed valve that did not require an 005 card. The inspector's
review of the event revealed that the second operator performing !
independent verification responsibilities did not follow the
- requirements of procedure ZAP 300-06B, " Equipment Verification," 1
i Revision 9. The second operator opened the valve instead of checking it
closed as required. The second operator signed the independent
verification (IV) that the valve was 00S closed, even though he had not
actually performed the IV task.
The inspectors were informed by the second operator that he considered
that there was no difference whether he observed or signed the
independent verification as the first or second operator as long as he
observed the valve position. The inspectors also questioned additional
plant personnel on their understanding of ZAP 300-068. In particular,
the inspectors questioned if the operators understood the concept of
independent verification. The answers given indicated the concept of
independent verification was understood.
Corrective actions taken by the licensee included: 1) the operators were !
instructed by optrations management personnel that independent
verification of 00Ss was to be done by the verifying operator after the
operator hanging the 00S had left the area; 2) shift management reviewed '
the independent verification procedure requirements (ZAP 300-06B,
" Equipment Verification") with operations personnel during the shift
briefing; and 3) a standing order was issued that stated that 00Ss
would normally be done with the original 00S copy in the field and
independent verification would be done with the original 00S copy after
the first person had returned to the control room after completing the
initial task for the 00S.
c. Conclusion
The inspectors concluded that the second operator did not understand ZAP
300-06B requirements for independent verification. The failure to
properly independently verify the air regulator isolation valve to valve
OTCV-SW186, as required by ZAP 300-06B is a violation of 10 CFR 50,
Appendix B, Criterion V. However, this violation was identified by the
licensee and could not have been reasonably prevented by the licensee's
corrective action for a previous violation or a previous licensee
finding that occurred within the past two years. Therefore, this
licensee-identified and corrected violation is being treated as a Non-
cited Violation, consistent with Section VII.B.1 of the NRC Enforcement
Policy (50-304-96010-02(DRP)).
The inspectors also concluded '. hat the maintenance engineer did a good
job in identifying the mispositioned valte when he performed a routine
walkdown of the 00S prior to the perforaance of scheduled work.
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03 Operations Procedures and Documentation
03.1 New Fuel Assembly Shinoina Container Drooped !
a. Inspection Scope (93702)
While performing fuel assembly receipt inspection on July 30, the end of
a shipping container containing two new fuel assemblies was
inadvertently dropped approximately two inches. The inspectors
discussed the incident with the fuel handling supervisor, the nuclear .
material custodian (NMC), a RP technician, and Westinghouse's i
representative. The inspectors also observed use of a new procedure !
step to lift the fuel assemblies after the incident and discussed the !
process with various fuel handlers (FHs). .
b. Observations and Findina
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On July 30, FHs were using Fuel Handling Instruction, FHI-02, " Handling
of Shipping Containers and Site Removal of New Fuel Assemblies From
Shipping Containers and Inspection of New Fuel," Revision 2, to prepare
new fuel assemblies for receipt inspection. One end of a shipping ,
container, which held two new fuel assemblies, was being raised using a :
nylon sling to allow the lateral lock tubes, at the one end of the shock
mounted frame, to be telescoped into their support housings to i
facilitate the raising of the shipping container to a vertical position.
The two inch wide nylon sling being used for the lift slipped off a
three inch wide edge on the shipping container which caused it to fall i
approximately two inches. The nuclear material custodian (NMC) >
immediately stopped the evolution. Accelerometers affixed to the new ,
fuel assemblies during transportation showed no excessive motion. :
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Westinghouse personnel documented in Field Anomaly Report 0-8G-02 that
the two new fuel assemblies were not damaged. The licensee subsequently ;
revised FHI-02 to require the use of two eyelets, located on the end of r
the shipping container, to attach the slings to the crane hook. Another :
option given in the revised procedure was to use a hydraulic jack for
the lift.
Although there was no prior history of the occurrence of this type of
incident, the inspectors observed that the rigging method did not use ,
the readily available techniques that the revised procedure subsequently
included.
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Using the revised procedural rigging method, the shipping container was l
lifted by the attachment of slings to the two eyelets with shackles. '
Following the placement of the lateral lock tubes, the cradle was tilted ,
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upright from the other end, and the new fuel removed and placed over the
new fuel storage area for visual inspection. l
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c. Conclusion
The licensee concluded that the cause of the event was an inadequate
rigging step in the procedure. The licensee took immediate corrective
action by revising the procedure. The inspectors considered that these
actions were appropriate.
Fuel Handling Instruction, FHI-02, " Handling of Shipping Containers and
Site Removal of New Fuel Assemblies From Shipping Containers and
Inspection of New Fuel," Revision 2, Step 9, required that the fuel
handling crew lift the one end of the shock mounted frame slowly with
the overhead crane and a minimum rated two ton nylon sling, until the
lateral lock tubes slide into their support housing. Failure to have an
adequate rigging step in FHI-02, Step 9, that was not appropriate to the
circumstances, which resulted in fuel handling personnel inadvertently
dropping two new fuel assemblies is a violation of 10 CFR 50, Appendix
B, Criterion V (50-295/304-96010-03(DRP)).
The inspectors concluded that the NMC showed conservative decision
making when he stopped the evolution.
08 Miscellaneous Operations Issues
08.1 (00en) NUREG-0737. Item III.D.3.4. Control Room Habitability: This item
was discussed in inspection reports: 90013/90015, 91027, and 92004.
The licensee performed leakage testing in 1991 following modifications
to the ventilation system in response to a 1986 event. The testing
resulted in unacceptable inleakage (LER 91007-01) which prompted further
repairs and another leakage test in 1992. The licensee submitted a re-
analysis of control room habitability to the NRC in September 1993 using
these latest test results.
As of August 22, 1996, this analysis remains under NRR review. Pending
NRR's final review and approval of the latest 1992 reanalysis including
the control room inleakage testing frequency, this issue will be an
inspection follow-up item (50-295/304-96010-04(DRP)).
11. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
a. Inspection ScoDe (62703)
The inspectors observed portions of the work associated with WR 960063817, "DG IB Jacket Water Cooler Cleaning and Inspection;" WR 960063813, "DG 1B-1 Intake Air Intercooler Inspection;" and WR 960012091, "DG 18 Jacket Water M/U Isolation Valve Replacement."
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b. Observations and Findinas
The inspectors determined that the work request packages provided proper
instructions to perform the work and that craft personnel were knowl-
, edgeable of their assigned tasks.
c. Conclusion
i The inspectors observed that the above maintenance activities were
i properly performed.
2 M1.2 Scaffold Obstructina Operation of IB Containment Sorav (CS) Pumo
Discharae Valve ,
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a. Insoection Scope (62703)
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On August 5, the inspectors identified that a scaffold around the IB CS
pump was obstructing operation of valve CS0004, "1B CS discharge valve."
The inspectors interviewed the site construction superintendent and
reviewed the scaffold inspection procedure, ZAP 900-20, "Use of Scaf-
folding and Ladders" and form.
- b. Observations and Findinas
On April 24, contractors erected a scaffold around the 18 CS pump in
preparation for valve testing. On August 5, the inspectors identified
that the scaffold was in the path of the handwheel of valve, CS0004.
The valve could not be manually operated due to the close proximity of
the scaffold.
The inspectors informed on-shift operations personnel of the scaffold
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deficiency; the licensee initiated timely and effective corrective
actions to remove the deficient condition by modifying the scaffold. In
addition, on August 6, the licensee and contractors stopped all scaffold
i erection and walked down all existing scaffolds in the plant. The
licensee identified five additional scaffolds which could interfere with
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the operation of non-safety related equipment.
On June 17, the licensee identified a scaffold deficiency around the
- Unit I high pressure turbine stop valves. At that time, the licensee
informed the contractors of the scaffold interference issue and initiat-
ed a procedural revision to require an operations' review after the
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erection of scaffold. In addition, the licensee performed a cursory
j review of all the scaffold forms and identified no problems.
c. Conclusion !
The inspectors concluded that the corrective actions for the June 17
event were inadequate which resulted in the identification of another
deficient scaffold on August 5. Failure to take effective corrective
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actions to prevent recurrence of a previous condition adverse to quality I
is a violation of 10 CFR 50, Appendix B, Criterion XVI (50-295-96010- .
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05(DRP)).
M1.3 Inadeauate Documentation of As-Found Condition of the IB Centrifuaal :
Charaina Pu=a (CCP) Shaft Driven Oil Pumn -
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a. Inspection Scone (62703)
On August 16, the inspectors identified that the as-found condition of !
the IB CCP shaft driven oil pump was not documented in the work package !
as required by the work package. The inspector reviewed ZAP 400-02,
" Initiating and Processing Work Requests," Revision 8, WR 960036505 02,
which had been prepared to inspect and repair the IB CCP shaft driven
oil pump, and interviewed the involved maintenance engineer (ME). !
b. Observations and Findinas
After reviewing the work pac.kage for WR 960036505 02, the inspectors
interviewed the ME who was present when the pump was inspected and ,
removed. The ME informed the inspectors that the shaft driven lube oil
pump had a missing bottom plate. The ME also commented that the !
combination of the missing plate, which had orifices that provided a ;
back pressure for the lube oil in the pump internals, and pump wear i
could have caused degraded performance of the IB CCP shaft driven pump.
However, the missing plate was not documented by maintenance personnel ;
as part of the as-found condition of the work package. The documented i
as-found condition stated that "no problems were found during the
inspection." In addition, another undocumented as-found condition noted
during the inspection was that a flexible hose, which was connected to ,
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the lube oil reservoir, was only hand-tight instead of being properly
secured.
c. Conclusions l
Failure to adequately document the as-found condition of the IB CCP l+
shaft driven lube oil pump to furnish evidence of activities affecting
quality is a violation of 10 CFR 50, Appendix B, Criterion XVII, ,
" Quality Assurance Records." !
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M1.4 1D Main Steam Isolation Valve (MSIV) Limit Switch Material Condition .,
a. Inspection Scope f62703)
On August 18, Unit I tripped on low low steam generator level when l
testing the ID MSIV. The ID MSIV intermediate limit switch failed to i
operate properly to prevent more than 10 percent valve closure from >
fully open. The inspectors responded to the trip and observed the trip
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. recovery and subsequent post trip review, reviewed the Problem Identifi-
- cation Form (PIF) documenting the limit switch failure, reviewed a list ;
i of all valves with similar limit switches in both units, and interviewed ;
the responsible system and maintenance engineers. ;
I
i b. Observations and Findinas I
. During performance of PT-3D, "lD MSIV Partial Stroke surveillance," the l
l 10 MSIV closed approximately 50-75 percent instead of the required 10 )
!
percent closed. As a result, steam generator level decreased to less
than its low-low steam generator water level setpoint of 10 percent,
which caused a reactor trip and a subsequent turbine trip. The cause of
the trip was determined by the licensee to be failure of the intermedi-
ate limit switch on the ID MSIV. The MSIV limit switches were not in
the Zion Preventative Maintenance (PM) program and subsequent inspection
indicated that the grease in the limit switch had hardened and that the
contact resistance was excessive. All four Unit 1 MSIV limit switches
were replaced with upgraded Namco switches, prior to Unit I startup.
The Unit I partial stroke surveillance was then successfully performed
on all 4 MSIVs.
The MSIV intermediate limit switches are non-safety related switches
that perform no safety function. However, the recently installed limit
switches have a different alloy material for the cover and 0-rings on -
the screws which should protect the switches in their hostile environ-
ment. Additional corrective actions included periodic switch replace-
r ent as part of the PM program. Further, a maintenance engineering
action plan activity identified a population of switches that have
critical control and/or safety functions in the plant; these switches
will then be replaced as part of the PM program. Per the action plan,
during the Z2R14 outage, Unit 2 MSIV limit switches and other applicable
Unit 2 switches will be inspected and or replaced. ;
c. Conclusion
The inspectors concluded that the root cause of the limit switch failure
was insufficient preventive maintenance. The inspectors concluded that l
the licensee's corrective action plans'were adequate. i
M8 Miscellaneous Maintenance Activities
M8.1 (Closed) Unresolved Item (50-295/94017-01 (DRS)): Effect of corrective
actions from the April 1994 fire on the July 1994 fire. The inspectors
reviewed the corrective actions following the turbine building generator
bus duct fire in April and the effect of these actions on the July fire.
The April fire was caused by a cracked generator phase "C" bushing,
causing the escape of hydrogen and fire. The July fire was caused by
the improper installation and an insufficient number of bus duct ground
strap cables following the April fire. The inspectors reviewed the
.
'
14
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.
corrective actions taken as a result of the April fire and determined
that they constituted examples of inadequate corrective action as
addressed in the December 1994 violation in inspection report 94021.
This item is closed.
l l
'
III. Enaineerina
El Conduct of Engineering
'
During this inspection report period an engineering and technical
support inspection was also conducted (See inspection report
1 50-295/304-960ll(DRS)).
E2 Eng'neering Support of Facility end Equipment
-
E2.1 Inadeauate Operability Assessment Performed for Dearaded 18 Centrifuaal
'
Charaina (CCP) Shaft Driven Lube Oil Pumo
a. Inspection Scope (37551)
On April 5, an operability assessment, engineering request (ER) No.
9601784, was prepared to determine operability of the IB CCP Pump with a
degraded shaft driven lube oil pump. The inspectors reviewed the
operability assessment, and interviewed system and site quality verifi-
cation engineers.
b. Observations and Findinas
On April 5, the system engineer prepared an operability assessment to
determine the operability of the IB CCP because of a degraded shaft
driven lube oil pump. The shaft driven lube oil pump could not provide
its design lube oil pressure of 10-12 psig.
The operability assessment addressed this deficient condition by stating
that the IB CCP pump was operable provided its associated auxiliary lube
oil pump remained operable. The operability assessment action plan ad-
dressed the condition by specifying that a caution card be placed on the
IB CCP main control board control switch, to run the auxiliary lube oil
pump when running the IB CCP. On August 7, a site quality verification
(SQV) engineer identified a concern with the operability assessment.
The operability assessment failed to address that upon the occurrence of
a safety injection (SI) signal, that the auxiliary lube oil pump would '
start and remain running after the SI signal was reset. Upon resetting
the SI, the auxiliary lube oil pump would then continuously cycle on and
off depending on lube oil pressure. When the pump was off, the IB CCP
would not have adequate oil pressure. Therefore, the SQV engineer
considered the IB CCP inoperable.
15
3
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,
. l
l
After this concern was raised, operations personnel initiated a new
caution card that stated to continuously run the IB CCP's auxiliary lube l
oil pump. On August 10, the IB CCP's shaft driven lube oil pump was j
replaced. The shaft driven oil pump is being evaluated to determine the i
root cause of the pump's inability to develop design oil pressure. l
,
Subsequently, after the inspector questioned the system engineer about
the actual capability of the degraded shaft driven lube oil pump, the I
system engineer contacted the vendor and was informed that a lube oil l
pressure of six psig would be sufficient to maintain the IB CCP's
operation. Also, the system engineer researched the auxiliary lube oil
pump breaker and determined that repeated cycling would not have tripped
off the oil pump breaker unless the cycling was more than three times in I
one minute. I
{
c. Conclusions
The inspectors agreed that the operability assessment was inadequate;
the assessment failed to address the impact of resetting the SI signal
on the IB CCP's auxiliary lube oil pump operation. The inspectors also
concluded that operating safety related equipment with degraded support
systems over a long period of time (April 5 to August 10) did not
demonstrate conservative operation of safety related equipment. Pending
further review of the licensee's level 3 root cause analysis, this is an
unresolved item (50-295/304-96010-07(DRP)).
E3 Review of UFSAR Commitments
A recent discovery of a licensee operating their facility in a manner
contrary to the Updated Final Safety Analysis Report (UFSAR) description
highlighted the need for a special focused review that compares plant
practices, procedures and/or parameters to the UFSAR descriptions.
While performing the inspections discussed in this report, the inspec-
tors reviewed the applicable portions of the UFSAR that relatad to the
areas inspected. The inspectors verified that the UFSAR woroing was
consistent with the observed plant practices, procedures and/or parame-
ters.
E8 Miscellaneous Engineering Activities
E8.1 (Onen) Violation 50-295/304-93009-02(DRP): Failure to use appropriate
acceptance criteria to ensure that: 1) the ECCS cubicles would be !
maintained at a negative quarter-inch water pressure with respect to the i
main auxiliary building; and 2) the main building would be maintained at :
a negative quarter-inch water pressure with respect to the outside. l
Previously, the licensee stated that these concerns would be addressed
in their improved technical specifications (TS). A review of their ;
proposed TS indicated that the licensee addressed tho ECCS cubicles but
did not address the auxiliary building. Further review by the inspector
indicated that the licensee updated section 9.4.3 of the UFSAR and
deleted the ECCS cubicle and auxiliary building acceptance criteria
which provided for a negative quarter-inch water pressure. This was
16
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i
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!. accomplished by a safety evaluation that concluded the change would not j
{ constitute an unreviewed safety question. The evaluation did not +
- provide the bases for determining that this change did not involve an ;
- unreviewed safety question. Failure to perform an adequate safety ;
,
'
evaluation on this issue was the basis for a previous civil penalty
(Report Nos. 93009 and 93014). The current issue remains open pending ,
,
NRR review of the acceptability of the relaxed acceptance criteria. l
! .
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IV. Plant Suonort
'
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i !
- R1 Radiological Protection and Chemistry (RP&C) Controls i
1
'
Rl.1 Unit 2 Refuelina Outaae Plannina ,
!
a. J.nspection Scone (83750)
t
i The inspectors reviewed the licensee's planning for the Unit 2 refueling l
- outage (Z2R14, September 14 - November 4, 11#96). The inspectors i
,
reviewed radiation work permits (RWPs), As Low As Reasonably Achievable ;
j- (ALARA) plans, and dose estimates for several planned outage activities. l
- In addition, the inspectors reviewed the licensee's progress in reducing
j the number of cobalt containing valves. !
1 1
i b. Observations and Findinas
The licensee dedicated additional ALARA planners to the site construc- l
tion staff to prepare ALARA plans and to provide additional ALARA l
oversight. The ALARA planners were assembling job histories for the 35 ',
l construction jobs with the highest estimated dose and were preparing
.
ALARA plans fcr these tasks. The ALARA plans contained information from ,
1 industry experience and the station's historical performance informa- !
] tion. The ALARA planners also stressed the use of training mockups and l
simulations to reduce worker exposures. In addition, the licensee had !
! assured that the 12 cobalt containing valves which were planned to be ;
'
worked on during the outage were rebuilt using non-cobalt containing
! components. ,
The inspectors reviewed the ALARA plan and RWPs for the construction of
i scaffolding in the auxiliary building (AB) and reactor containment. The !
( ALARA plan was comprehensive, documenting good historic information, i
j good radiation protection (RP) practices, and RP hold points. However,
i '
the inspectors observed that the licensee's procedures and program did
not recognize the ALARA plan. The licensee did not have a formal
process to assure that information and RP requirements contained in the ;
ALARA plan were included in RWPs. The health physics supervisor j
indicated that the ALARA plan was a program enhancement and that the !
licensee planned to revise RWPs, as applicable, to contain significant
instructions developed in the ALARA plans.
The ALARA planners indicated that job history files had a number of
weaknesses. For example, lessons learned from previous outages (i.e.
17
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.
1995 Unit I refueling and 1996 Unit 1 maintenance outage) were not well ,
documented. The RP evaluations of the outage were informal. The ALARA
staff planned to improve the job history files via a computer based ap-
proach. The licensee expected ;his system to provide better accessi-
bility and more comprehensive job files. The licensee also planned to
use separate RWPs for emergent and re-work dose to better account for
the dose expended.
c. Conclusion
The licensee dedicated additional resources to improve RP ALARA planning
of work activities for the site construction staff. ALARA plans for
site construction activities were well prepared and contained good
radiation protection hold points and information. However, the ALARA
plans had not been _ incorporated in the licensee's procedures to ensure
that significant RP requirements were reflected in RWPs.
R2 Status of RP&C Facilities and Equipment
R2.1 Air Samplina Instrumentation
a. Inspection Scope (83750)
The inspectors toured the radiologically restricted area and reviewed
the licensee's use of portable air sampling equipment,
b. Observations and findinas
The inspectors verified that air samplers were calibrated to ensure that
flow measurements were accurate. However, the inspectors noted that the
exhaust port for the air sampler in the fuel handling building (FHB) was
located in close proximity to the sampler inlet. The inspectors
identified that exhausted, filtered air was cycling back into the inlet
and diluting the air sample. Subsequently, the licensee installed a
diffuser on the exhaust port to correct the problem and reviewed other
sampling equipment to ensure a similar situation did not exist.
Although the air samphr was not required by Technical Specifications
(TSs) nor the Offsite Dose Calculation Manual (0DCM), the licensee used
the sampler to monitor the contribution of radioactive particulates and
iodines from the FHB to the AB ventilation system.
c. Conclusion
The potential dilution of air samples indicated a weakness in the
identification of problems by the RP personnel, who are responsible for
establishing the air sampler, and the chemistry personnel, who are
responsible changing the filters.
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l R3 Radiological Protection and Control Prcesjures and Documentation
R3.1 Radiation Procedure Weakness for Assurina Surveillance Reauirements Are
t Mt:1
! a. Inspection Scone (83750)
i ,
} On July 26, a system engineer ginerated a station deficiency report for l
1 not meeting the TS, when a radiat%n monitor was inoperable. The I
l
'
inspectors interviewed system engineering, radiation protection, a.,d
regulatory assurance personnel. The inspectors also reviewed the TSs
l and other appropriate procedures.
! b. Observation and Findings )
i 1
l Radiation monitor, 2R-AR03, "High Containment Radiation," was taken out
of service to efftct repairs to inadequate wiring. The radiation
4 monitor is one of two containment high radiation monitors; the other
! redundant radiatio 7 monitor is 2R-AR02 and it was available. With 2R- l
l AR03 inoperable, T5 Table 3.14, " Radiation Monitoring Instrumentation", !
Action Statement 31, required that an alternate method of monitoring
4- containment be initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Radiation protection proce-
dure, ZRP 5820-12, "Out of Service Surveillance for Radiation Monitors,"
Revision 5, was used to implement the requirements of the TS Table 3.14.
The procedure was inadequate in that it specified that no routine
surveillance was required. However, the redundant radiation monitor,
2R-AR03, was available and provided an alternate method of sampling
containment; therefore, the TS action staiement requirement was met.
During the exit meeting, the new radiation protection supervisor stated
that the raquirements of TS Table 3.14 were met by operability proce-
dure, ZODM-AP, " Area Radiation Monitoring," Revision 5. The inspectors
noted that Procedure ZODM-AR required for an inoperable monitor that an
alternate method of monitoring containment be accomplished within 72
hours; which is the same requirement as the TS. However, the ZODM does
not specify how to implement this action. Procedure, IAP 5820-12,
stated that the use of this procedure was to accomplish any applicable
requirements of the TS and offsite dose calculation manual, but did not
require containment monitoring within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an inoperable
radiation monitor. Therefore, as noted above ZAP 5820-12 and ZODM-AR
were inconsistent. J
c. Conclusion
The inspectors concluded that the TS action statement was met when 2R-
AR03 was inoperable; however, Procedure ZAP 5820-12 was inadequate in
that it incorrectly stated no action was required for the inoperability
of 2R-AR03. This is a violat. ion of 10 CFR 50 Appendix B, Criterion V
(50-295/304-96010-09(DRP)).
,
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7._
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l R4 Staff Knowledge and Performance in RP&C
I R4.1 RP Oversiaht of New Fuel Shioments
f a. Insoectjyp A ne (83750)
The inspectors observed preparation for the receipt of a shipment of new
- fuel in the FHB.
b. Observation and Findinas
i All personnel were wearing the correct dosimetry as required by proce-
. dures. Additionally all personnel, including two radiation protection j
l technicians (RPTs), covering the evolution, were staged in low dose l
!. areas'of less than 1 arem/hr. However, the inspectors noted that )
i personnel were spending an excessive amount of time in the FHB, while
j waiting for support from operations' personnel. About one hour later,
j the individuals left the area and deterMned that operations' personnel
were working on a necessary procedure revision.
l
c. Conclusion
l Although the persons were waiting in a low dose area, the lack of
i coordination indicated poor planning and ccamiunications prior to
i entering the radiologically posted area.
- 3
'
l R8 Miscellaneous RP&C Issues
i :
! R8.1 (Open) Violation 50-295/304-95018-01: failure to adequately don
protective clothing and to prevent the spread of contamination as
- required by RP procedure ZRP 500-7, " Unescorted Access To and Conduct in
j Radiological Posted Areas."' The licensee reviewed the violation with RP !
I and maintenance staff members to assure their understanding of proper l
3
radiation worker (radworker) practices. In addition,' the licensee's 1
e corrective actions included additional training of RP, maintenance, and l
i contractor personnel and revising RP procedure, ZRP 500-7. The inspec- !
! tors reviewed the licensee's progress in completing the remaining j
j corrective actions:
l
0 The licensee had begun training first line RP and maintenance
l supervisors to improve their understanding of management expecta- .
'
tions and oversight skills. The licensee had all applicable
1 personnel scheduled for training through November 1996.
]
j o The inspectors also reviewed the enhanced radworker training
- presented to maintenance personnel. The training was comprehen-
j sive and included both classroom and workshop instructions.
- During this inspection, the licensee was in the process of expand-
- ing its initial nuclear general employee training (NGET) to
e include the topics of the enhanced training, including contamina-
tion control techniques. The training staff indicated that the
20
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.
revised NGET would assure that contract personnel hired for Z2R14
would receive radworker training at the depth of the enhanced
training.
o The inspectors also reviewed a draft revision of ZRP 500-7, which i
provided instruction to personnel regarding removing items from '
contaminated areas and contamination control techniques. The
inspectors verified that the above training was consistent with
the licensee's RP procedures. Once personnel were trained on the
revision, the licensee planned to approve the procedure. l
This violation will remain open pending the completion of training, the
revision of ZRP 500-7, and the observations of radworker performance 1
during the 1996 Unit 2 re-fueling outage. I
S1. Conduct of Security and Safeguards Activities
S1.1 (CLOSED) Temoorary Instruction 2515/132. " Malevolent Use of Vehicles at
Nuclear Power Plants"
a. Insoection Scope (TI 2525/132)
The inspectors examined the licensee's provisions for land control
measures to protect against the malevolent use of a land vehicle to
determine compliance with regulatory and licensee comitments.
b. Observations and Findinas
(1) Vehicle Barrier System (VBS)
The inspector found that the features and structures that form the
VBS met the design characteristics established by the NRC. The
vehicle barrier components and the location of the barrier were as
described in the revised sumary description of the VBS submitted
by the licensee to the NRC in February 1996.
A visual walkdown performed by the inspector confirmed that the
general type of vehicle barrier described in the VBS sumary
description had been installed and that the barrier was continu-
ous.
(2) Bomb Blast Analysis
Inspector field observations of standoff distances were consistent
with those documented in the sumary description. The licensee
confirmed that calculation of minimum standoff distance was based
on NUREG/CR-6190 or an independent engineering analysis.
21
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(3) Procedural Controls
The licensee appropriately defined criteria for maintenance,
surveillance, and compensating for the VBS system in Corporate
Nuclear Security Guideline No. 4, " Operational Planning and
Maintaining Integrity of Vehicle Barrier Systems (VBS)," Revision
0, dated February 1996.
Discussions with security management confirmed that procedures
necessary to safely shutdown the units after a bomb blast were
reviewed and found adequate.
c. Conclusion
The licensee's provisions for land vehicle control measures met regula-
tory requirements and licensee commitments. The VBS program was
consistent with the summary description submitted to the NRC and
adequate procedures addressing VBS maintenance and compensatory proce-
dures were developed and implemented.
XI Exit Meeting Summary
The inspectors presented the inspection results to members of licensee I
management at the conclusion of the inspection on August 29, 1996. The l
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.
i
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, PARTIAL LIST OF PERSONS CONTACTED
.I
Licensee
. G. Schwartz, Station Manager
i W. Stone, Regulatory Assurance Supervisor
B. Fitzpatrick, Operations Manager
i B. Giffin, Engineering Manager
'
K. Hansing, Site Quality Verification Director '
W. Strodl, Radiation Protection Supervisor
4 D. St. Clair, Work Control Manager
M. Weis, Services Director ,
4
i
. HEL ,
L. Miller, Chief, Reactor Projects Branch 4
j R. Westberg, Senior Resident Inspector
.
!
IDMS
J. Yesinowski
L
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b
23
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List of Insnection Procedures Used
IP 37551 Engineering
IP 62703 Maintenance Observation
IP 71707 Plant Operations
IP 71715 Sustained Control Room Observation
IP 83750 Occupational Radiation Exposure
IP 93702 Prompt Onsite Response to Events at Operating Power Reactors
TI 2515/132 Malevolent Use of Vehicles at Nuclear Power Plants
.
List of Items Opened. Closed. and Discussed
!
4 Opened
50-295/304-96010-01(DRP) VIO failure to follow procedures which
resulted in overflowing the OB LDT. No
<
response required
, 50-304-96010-02(DRP) NCV failure to properly independently
- verify DG air regulator isolation valve
, 50-295/304-96010-03(DRP) VIO failure to have an adequate procedure
for rigging of new fuel containers
50-295/304-96010-04(DRP) IFI testing of the control room ventila-
tion system
50-295-96010-05(DRP) VIO inadequate corrective actions taken
to assure procedures were followed for
scaffold interferences
50-295/304-96010-06(DRP) VIO failure to document all as-found
discrepancies during the inspection of the
IB CCP pump
-
'
50-295-96010-07(DRP) URI inadequate operability assessment for
IB CCP
50-295/304-96010-08(DRP) NCV failure to assure that radiological
postings were conspicuous in accordance
'
with 10 CFR 20.1902
50-295/304-96010-09(DRP) VIO Procedure ZAP 5820-12 was inadequate
in that it incorrectly stated no action
was required for the inoperability of 2R-
<
AR03.
-
Closed
50-295/304-96010-02(DRP) NCV failure to properly independently
verify DG air regulator isolation valve
50-295/304-96010-07(DRP) NCV failure to assure that radiological
postings were conspicuous in accordance ,
'
- with 10 CFR 20.1902
50-295/94017-01(DRS) URI effects of corrective actions from )
April / July 1994 fire i
Discussed
50-295/304/93009(DRP) VIO failure to use appropriate acceptance
criteria
24
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O l
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List of Acronyms
l
AB Auxiliary Building
ALARA As Low As Reasonably Achievable
CCP Centrifugal Charging Pump
CT Chemistry Technician
DG Diesel Generator
E0 Equipment Operator
ER Engineering Request
FH Fuel Handling
FHB Fuel Handling Building i
IFI Inspection Followup Item l
IP Inspection Procedure !
IR Inspection Report ,
IV Independent Verification !
LDT Lake Discharge Tank l
ME Maintenance Engineer i
MSIV Main Steam Isolation Valve
NCV Non-Cited Violation I
NE Nuclear Engineer l
NGET Nuclear General Employee Training l
NMC Nuclear Material Custodian
NRC Nuclear Regulatory Commission
NSO Nuclear Station Operator
ODCM Off-site Dose Calculation Manual l
00S Out of service ;
PDR Public Document Room l
PIF Problem Identification Form !
QNE Qualified Nuclear Engineer
RM0 Reactivity Management Oversight :
RP Radiation Protection l
RP&C Radiological Protection and Chemistry !
RPI Rod Position Indicator i
RPT Radiation Protection Technician i
RWP Radiation Work Permit
SA Service Air
SI Safety Injection
SQV Site Quality Verification
TS Technical Specification
UFSAR Updated Final Safety Analysis Report i
URI Unresolved Item
VBS Vehicle Barrier System
VIO Violation
WR Work Request
!
25
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