ML20133F173
| ML20133F173 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/07/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133F149 | List: |
| References | |
| 50-458-96-16, NUDOCS 9701140093 | |
| Download: ML20133F173 (21) | |
See also: IR 05000458/1996016
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Docket No.:
50-458
License No.:
Report No.:
50-458/96-016
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
P.O. Cox 220
St. Francisville, Louisiana 70775
Dates:
November 3 through December 14,1996
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Inspectors:
W. F. Smith, Senior Resident inspector
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D. L. Proulx, Resident inspector
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W. M. McNeill, Reactor inspector, Division of Reactor
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Safety
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Approved By:
P. H. Harrell, Chief, Project Branch D
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Division of Reactor Projects
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Attachment:
Supplemental information
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9701140093 970107
ADOCK 05000458
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EXECUTIVE SUMMARY
River Bend Station
NRC Inspection Report 50-458/96-16
This inspection included aspects of licensee operations, maintenance, engineering, and
plant support. The report covers a 6 week period of resident inspection.
Operations
In general, the conduct of plant operations was professional and reflected a focus
on safety. Operators responded appropriately to the isophase duct cooling fan
failure. The control room was operated in a formal manner (Section 01.1).
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A detailed walkdowr. inspection verified that the hydrogen mixing, purge,
recombiners, and igniters were capable of performing their intended safety function;
however, the inspectors identified a violation for failure to maintain adequate valve,
switch, and breaker lineup attachments for the system operating procedure
(Section O2.1).
The inspectors identified a violation because an operator failed to implement the
requirements of Technical Specifications (TS) 3.0.6 and 5.5.10, " Safety Function
Determination Program." The licensee determined that operators demonstrated
inadequate knowledge of the design bases and TSs by not identifying that
concurrently removing the high pressure core spray (HPCS) and low pressure core
spray (LPCS) systems from service could have constituted a loss of safety function
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and required entry into TS 3.0.3 for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (Section 04.1).
Maintenance
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Maintenance planners did not have adequate knowledge of the effect on plant
safety of the retest for work on a standby service water (SSW) pump.
Consequently, the licensee did not adequately assess the effects of delays in the
maintenance schedule that caused work to be performed concurrently
(Section 04.1).
During the Division til Emergency Diesel Generator (EDG) maintenance, the
electricians and mechanics properly performed the activities (Section M1.1).
A spent fuel pool cooling pump was inoperable for an excessive amount of time (10
months) because of low system flow. When the cause of the low flow was
determined to be heat exchanger fouling, the licensee did not perform the required
inservice testing (IST) prior to returning the pump to service. The inspectors
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identified a violation for failure to obtain a new set of reference values prior to
placing a safety-related pump in service after performing analyses (Section M1.2).
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The IST of the Division i standby liquid control (SLC) pump was performed
satisfactorily and in accordance with procedures. The operator performing the IST
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of the Division I SLC pump exhibited a questioning attitude by ensuring that the
procedure was technically correct prior to performance (Section M1.3).
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An operator performed the IST of the Division ll SSW system well and obtained
satisf actory results. The inspectors noted that a continuing procedure problem with
meeting ASME Code Section XI vibration measurements existed. This was the
subject of a violation in NRC Inspection Report 50-458/96-15 and corrective actians
had not yet been completed (Section M1.4).
Enaineerino
The licensee responded properly to the inappropriate use of chemicals in the plant
by correcting the specific problem and strengthening the chemical control program.
A noncited violation (NCV) was identified for failure to comply with the chemical
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control procedure (Section E2.1).
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The initial operability assessment of the control room air conditioning system upon
discovery of a mispositioned test switch was weak in that it did not properly
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consider the response of the system actuation logic during a design basis accident.
Following questioning by the inspector, the licensee determined that a violation of
TS 3.0.4 occurred; however, the inspectors identified this deficiency as an example
of a configuration control violation in NRC Inspection Report 50 458/96-15
(Section E8.1).
Plant Succort
Housekeeping and plant material condition continued to be excellent throughout the
inspection period (Section 01.1).
The November 14,1996, failure to lock the door to a locked high rat.iation area was
an isolated incident that the licensee appropriately dispostioned. Ar. NCV was
identified for f ailure to comply with TS 5.7.2 (Section R1.1).
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Report Details
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Summary of Plant Status
The plant operated at essentially 100 percent power for the duration of this inspection
period, except on November 16,1996, when it was necessary to lower power to
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approximately 60 percent because of an isophase duct cooling fan failure. By
November 19, af ter repairs, power was restored to 100 percent.
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1. Operations
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Conduct of Operations
01.1 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations including
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control room observations, attendance at plan-of-the-day meetings, and plant tours.
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In general, the conduct of plant operators was professional and reflected a focus on
safety. During plant tours, the inspectors noted that housekeeping continued to be
excellent. Any minor discrepancies identified by the inspectors were promptly
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corrected.
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The inspectors reviewed the operator actions to reduce power subsequent to the
failure of the nonsafety-related isophase duct cooling fan. Power was reduced to
approximately 60 percent to reduce the heat load on the isophase duct to a level
that would not cause overheating without the fan. The operators followed the
appropriate operating procedures to reduce power and then subsequently restored
power in a well-controlled manner.
02
Operational Status of Facilities and Equipment
O2.1 Enaineered Safety Feature System Walkdown (71707)
a.
Insocction Scooe
The inspectors performed walkdowns of the systems that constitute the hydrogen
control system including the hydrogen mixing, hydrogen recombiner, hydrogen
igniter, and hydrogen purge systems. In addition, the inspectors reviewed
completed surveillance procedures and closed out condition reports (CR) to
determine the overall condition of these systems,
b.
Observations and Findinos
The inspectors noted that the systems were lined up pmoerly and that the operating
procedures adequately translated the design bases into operating practices. The
inspectors reviewed the applicable portions of the Updated Final Safety Analysis
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Report (UFSAR) and found no discrepancies. The inspectors reviewed completed
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surveillance test procedures and noted that the tests were satisfactorily completed
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and documented. On a sampling basis, the inspectors reviewed closed condition
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reports and found that the appropriate corrective actions had been implemented.
The inspectors walked down Procedure SOP-0040, " Hydrogen Mixing, Purge,
Recombiners, and Igniters," Revision 9. Procedure SOP-0040 was well written and
provided clear and correct instructions on system operation. However, the
following deficiencies were identified with the valve, switch, and breaker lineup
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enclosures to the procedure:
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Each of the four igniter panels had a master breaker that was not identified
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on the Procedure SOP-0040 breaker lineup. Failu.e to verify these breakers
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closed could have resulted in no less than 5, and possibly all 20, igniter
circuits being unable to perform their intended safaty function.
Procedure SOP-0040, Attachment 3C, " Electrical Lineup for the Hydrogen
Recombiners," conflicted with Attachment 4C, " Control Board Lineup -
Hydrogen Recombiners," in that Attachment 3C required the breakers to be
open while Attachment 4C required the breakers to be closed.
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Procedure SOP-0040, Attachment 1, " Valve Lineup for Hydrogen Purge,"
failed to specify the required status for Valves CPP-V3, -V4, and -V5.
Valve CPP-V3 was specified open in lieu of locked open, Valve CPP-V4 was
specified locked / capped instead of locked closed and capped, and
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Valve CPP-V5 was specified capped in lieu of closed and capped.
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The inspectors found the above breakers and valves in the proper position for
operability. Except for failure to address master brsaker positions in the igniter
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panels, the other examples occurred during the procedure upgrade process since
personnel had correctly aligned the systems using Procedure SOP-0040, Revision 8.
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The above procedure inadequacies constitute a violation of TS 5.4.1.a
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(50-458/9616-01).
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c.
Conclusions
The inspectors concluded that the hydrogen mixing, purge, recombiner, and igniter
systems were capable of performing their intended safety function; however, a
violation was identified for failure of the licensee to maintain adequate valve,
switch, and breaker lineup attachments for the system operating procedure. This
violation resulted, in part, because of errors introduced during the procedure
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upgrade process,
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Operator Knowledge and Performance
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04.1 Potential Entrv Into TS 3.0.3 Dudna On-Line Maintenance
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a.
Insoection Scoce (71707)
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lhe inspectors reviewed control of on-line maintenance from November 11-15 to
ensure that the work was adequately sequenced such that a loss of safety function
did not exist. The inspectors reviewed the control room operator logs, the limiting
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condition for operation (LCO) logs, administrative procedures, and monitored work
in progress.
b.
Observations and Findinas
On November 12 the licensee removed Unit Cooler HVR-UC5 (HPCS pump room
cooler) from service for planned inspection and maintenance. This activity rendered
the HPCS system inoperable, which was a 14-day shutdown LCO. The work
management center had scheduled this work to be complete on November 13 but
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extended the maintenance because mechanics found a baffle plate missing in Unit
Cooler HVR-UC5. Further, the licensee had scheduled maintenance and testing of
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Pump SWP-P2C (SSW Pump C), after personnel completed the work on the unit
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cooler. Because of the delays in restoring Unit Cooler HVR-UC5 to operable,
personnel allowed these two work activities to be performed simultaneously.
The inspectors reviewed the work sequence and noted that on November 14, the
operators declared Division i SSW inoperable because both Pump SWP-P2A (SSW
Pump A) and Pump SWP-P2C were locked out to perform a retest. Therefore, at
the same time, both the HPCS pump and Division l SSW were inoperable. The
inspector noted that TS 3.5.1.H requires that operators enter TS 3.0.3 if HPCS and
LPCS are both inoperable because this situation would entail a loss of spray cooling,
which is an unanalyzed condition. This condition existed approximately from 3:30
to 4:30 p.m.
TS 3.0.6 provides general principles that cascading of TSs is not required even
though supported systems are inoperable unless directed to enter another TS action.
TS 3.0.6 also implements TS 5.5.10, " Safety Function Determination Program,"
which is intended to ensure a loss of safety function does not occur as a result of
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entry into multiple TSs. TS 5.5.10 states, in part, "...a loss of safety function may
exist when a support system is inoperable, and: a. A required system redundant to
system (s) supported by the inoperable support system is also inoperable; or..."
Procedure OSP-0040,"LCO Tracking and Safety Function Determination Program,"
Revision 1, Step 3.4.1 specified that a cross-divisional check must be performed to
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ensure that no loss of safety function goes undetected and Step 4.2.5, specified
when TS 3.0.6 is entered to prevent entering additional LCOs for supported
systems, perform an evaluation in accordance with TS 5.5.10 to ensure no loss of
safety function exists. Further, Procedure OSP-0040, Enclosure 1,
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" Support-Supported LCO Matrix," requires upon entry into support system LCO
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TS 3.7.1 (SSW), a review of supported system LCO 3.5.1 (ECCS-Operating).
The inspectors determined that the Division l SSW supported LPCS and that HPCS
was redundant to LPCS as defined in the UFSAR accident analyses and TS 3.5.1.H.
The inspectors determined that the failure to invoke TS 5.5.10 as required by
TS 3.0.6 and Procedure OSP-0040is a violation (50-458/9616-02).
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The inspectors questioned the control room supervisor (CRS) on the appropriateness
of this operating condition. The CRS did not consider HPCS and LPCS to be
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redundant systems because one provides high pressure spray and the other
provides low pressure spray to the core. The CRS did not consider the spray
cooling function to be a credited safety function. Further, the CRS noted that
TS 3.7.1.G required that operators enter TS 3.8.1.8 and that TS 3.8.1.B allows
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to perform an evaluation to determine if a loss of safety function existed;
also, the CRS knew that the work scheduled would take less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The
inspectors noted that the words in the bases for TS 3.8.1.B specify upon discovery;
whereas, this was an intentional entry by facility personnel.
The inspectors discussed the above issue with the operations and licensing
managers, who agreed that rendering the Division i SSW system inoperable with the
HPCS system inoperable was inappropriate and would potentially place the plant in
TS 3.0.3. The licensee initiated CR 96-1976 to enter this issue into the corrective
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action program. The initiallicensee investigation revealed that most of the licensed
operators at River Bend were unaware that HPCS and LPCS were considered to
have a redundant required safety function. In addition, the licensee noted that most
operators were unaware that the Basis for TS 3.8.1.B stated that the Divisions I, ll,
and lll emergency core cooling systems were considered to be redundant to each
other. The licensee determined from interviews that, although Division i SSW was
inoperable as documented in the LCO 10g, work was not actually in progress while
Unit Cooler HVR-UCS was removed from service.
During a subsequent interview with the CRS, the inspectors noted that the CRS
thought it was appropriate to allow HPCS and Division i SSW to be inoperable at
the same time because he considered Unit Cooler HVR-UC5 available at a moment's
notice. in addition, the CRS could have stopped testing on SSW and returned one
pump to full operability from the control room well within the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> permitted by
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Maintenance planners did not recognize that the retest for the work on
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Pump SWP-P2C required rendering Division i SSW inoperable. The licensee did not
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reanalyze the effect of delays in work on Unit Cooler HVR-UC5 to ensure that other
scheduled work did not inappropriately overlap. The inspectors determined that
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aspects of the maintenance rule were not effectively implemented.
10 CFR 50.65(a)(3) requires that an assessment of total plant equipment out of
service should be taken into account to determine the overall effect on performance
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of safety functions. NUMARC 93-01, " Industry Guideline for Monitoring the
Effectiveness of Mainter'ance at Nuclear Power Plants," Section 11.2.3 specifies, in
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part, that prior to actually removing a system from service to begin maintenance,
the condition of the plant should be reviewed to verify that conditions are
acceptable to take the system out of service.
The inspectors determined that the licensee implemented the Maintenance Rule
using Procedure PEP-0219, " Reliability Monitoring Program," Revision 4.
Specifically, Procedure PEP-0219, Step 6.12 implemented the requirements for
taking equipment out of service, which included evaluating the effect of removing
safety-related equipment from service prior to removal for preventive maintenance,
surveillance, et cetera. Also, Step 6.12 specified that detailed guidance can be
found in Guideline EDG-AN-0002, " Guideline for On-line Maintenance at RBS."
Guideline recommendations included reminding personnel that multiple cross
divisional outages should not be scheduled concurrently and that TS 3.0.6 and
TS 5.5.10 need to be considered. Also, Guideline EDG-AN-0002, Step 5.2.4
identified that emergent work resulting from equipment failures and schedule
changes caused by changing plant conditions should be evaluated by the work
management center or an onshift senior reactor operator.
c.
Conclusions
The inspectors identified a violation because operators failed to recognize the need
to implement the safety function determination program. The licensee determined
that operators had inadequate knowledge of the design bases and TS since they did
not know that concurrently removing the HPCS and LPCS systems from service
might have constituted a loss of safety function and required entry into TS 3.0.3.
Maintenance planners did not have adequate knowledge of the effect on plant
safety of the retest for work on a SSW pump. The licensee did not adequately
review the consequences of delays that resulted in work to be performed
concurrently, as required by the Maintenance Rule and administrative procedures.
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Miscellaneous Operations issues (92901)
08.1 LQlosed) Violation 50-458/9511-02: four examples of operator errors that
contributed to loss of control of service water. This violation identified four
examples of violations that resulted in the inadvertent transfer of control of the
service water system to the remote shutdown panel. These examples included: (1)
the work control supervisor released a preventive maintenance (PM) work order
without an adequate review, (2) the control room supervisor assigned review of a
PM work order without specific directions, (3) operators communicated informally,
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and (4) operators manipulated a remote shutdown system transfer switch outside
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the bounds of the procedure.
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For corrective actions, the licensee: (1) briefed the shift superintendents on
operations communication policy, (2) revised the system operating procedure for the
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remote shutdown system, (3) monitored gaitronics communications to ensure that
the communications policy was followed, (4) briefed operators on the event during
human performance workshops, (5) issued an all-employee letter from the Vice
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President-Operations to reinforce human performance expectations, (6) provided
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training to enhance sen:or reactor operator decision-making skills, and (7) performed
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a review of control room workload to evaluate the impact of maintenance on
operators. The inspectors determined that the licensee satisfactorily completed the
corrective actions.
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11. Maintenance
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Conduct of Maintenance
M 1.1 Maintenance Activities on the Division ill EDG
a.
Inspection Scope (62707)
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On December 11 the inspectors observed portions of the work and retesting
activities covered by the following maintenance action items (MAI):
MAI P590845:
Clean fuel oil Strainer 1EGF-STR1C.
mal P588202:
Surge test on Circuit Breaker 1E22-EGS001.
MAI 308695:
Replace alternating current lubricating oil circulating
pump to lower vibrations.
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b,
Observations and Findinas
The inspectors noted that the operators entered the appropriate TS LCO for placing
the Division ill EDG out of service. The craft personnel performed the work in
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accordance with the MAI instructions and in a professional manner. The
maintenance technicians worked to minimize the outage time on the EDG and kept
the work areas clean.
During the replacement of the alternating current lubricating oil circulating pump and
motor, problems were encountered with the motor replacement. The new motor
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would not fit without a significant modification to the skid. The parts list stated the
Frame 184 motors were no longer available and recommended using Frame 145T
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motors. This discrepency and a number of other discrepancies on the parts list
were not identified until personnel performed the work with the EDG out of service.
The system engineer directed that the MAI to be revised to replace the pump only
and that a separate MAI be initiated to replace the motor. An inspection of the
existing motor found that the motor bearings were only slightly worn and not
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indicating imminent f ailure. The system engineer initiated a CR to identify the above
discrepancies and to identify that the delay in replacing the motor could have been
avoided by a better prejob walkdown.
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c.
Conclusions
Based on the inspectors' observations during the Division ill EDG maintenance
activities, the electricians and mechanics demonstrated continued improvement.
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However, had there been a better prejob wa!kdown performed for the replacement
of the alternating current lubricating oil circulation pump and motor, the delay in
installing a new motor might havra been avoided.
M1.2 inocerability of Soent Fuel Pool Coolina Pumo
a.
Insoection Scooe (62707)
The inspectors evaluated the response to CR 96-1774, which identified that the
I:censee deferred IST of Pump SFC-P1 A for approximately 10 months because of
low system flow.
b.
Observations and Findinas
On December 11,1995, during performance of Procedure STP-602-6311,
" Division i Fuel Pool Cooling Quarterly Pump and Valve Operability Test,"
Revision 4, the performers could not obtain the 2500 gpm reference pump flow rate
with the throttle valve fully open. The maximum achievable flow rata was 2480
gpm. The licensee initiated CR 95-1156 to enter this item into the corrective action
program. An operability assessment indicated that 2480 gpm ensured
Pump SFC-P1 A could maintain the spent fuel pool temperature within limas
specified in the UFSAR and the design analysis; therefore, the pump remained
operable. The licensee performed no additional investigation at this time.
On February 22,1996, during performance of Procedure STP-601-6311,
Pump SFC-P1 A again f ailed to achieve 2500 gpm. This time the flow rate
measured 2471 gpm, and the performers initiated CR 96-0573. The operability
assessment concluded that the pump remained operable because it could maintain
spent fuel pool temperature. The operators disagreed with this operability
assessment because the pump failed to meet the IST acceptance criterion and was
degrading. Subsequently, IST personnel added Pump SFC-P1 A to the " exception
report" that tracked equipment for which surveillance testing was not necessary
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because the equipment was inoperable. Although Pump SFC-P1 A has no
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associated TS, UFSAR Section 9.1.3 specifies that the spent fuel pool cooling
pumps are safety-related and requires testing in accordance with the ASME Code
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Section XI IST program.
After Pump SFC-P1 A f ailed to again meet the reference flow rate on April 1, the
licensee commenced a "Kepner-Tregoe" root cause analysis. During this
investigation, the licensee cross-connected Pump SFC-P1 A with the Division 11
spent fuel pool cooling system and determined the flow rate exceeded 2500 gpm.
On April 17, the licensee concluded that no problem existed with Pump SFC-P1 A
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but the Division I heat exchanger had tube leaks. The licensee tagged out Heat
Exchanger SFC-E1 A at this time, ordered parts to plug the assumed leaking tubes,
and waited until the parts arrived on August 5 to inspect the heat exchanger in
accordance with MAI 306345. On August 18, the licensee inspected Heat
Exchanger SFC-E1 A and found the heat exchanger tubes fouled. The licensee
cleaned Heat Exchanger SFC-E1 A and returned it to service on August 18.
Af ter returning Pump SFC-P1 A to service on August 18, the licensee deferred the
IST of Pump SFC-P1 A until the next scheduled IST due date and kept the pump
listed on the " exception report." The licensee satisfactorily performed the quarterly
IST for Pump SFC-P1 A on November 11. From August 18 until November 11,
operators ran Pump SFC-P1 A on several occasions because SFC-P1B was removed
from service for maintenance.
ASME Code Section XI, Subsection IWP-3230(c), " Corrective Action," specifies
that correction shall be either replacement or repair per IWP-3111, or shall be an
analysis to demonstrate that the condition does not impair pump operability and that
the pump will still fulfillits function. A new set of reference values shall be
established after such analysis. The inspectors determined that the f ailure of the
licensee to establish a new set of reference values prior to placing Pump SFC-P1 A
in service is a violation of 10 CFR 50.55a(f)(50-458/9616-03).
Because the licensee attributed the root cause to a lack of oversight by departments
other than the IST engineers, for immediate corrective actions the licensee (1)
revised procedures such that if a safety-related non-TS item was inoperable, it
would be entered into the tracking LCO list and (2) revised work management policy
such that items on the exception list would be tracked to completion.
c.
Conclusions
The inspectors identified a violation of 10 CFR 55a because personnel f ailed to
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obtain a new set of reference values after performing analyses as specified in ASME
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Code Section XI. A spent fuel pool cooling pump was inoperable for an excessive
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amount of time (1'O months) because of system low flow. When the cause of the
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low flow was determined to be heat exchanger fouling, the licensee did not
promptly perform the required IST and return the pump to service.
M1.3 Inservice Testina of SLC Pumo
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a.
inspection Scope (61726)
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On December 3,1996, the inspectors witnessed the performance of
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Procedure STP-201-6311," Division i SLC Quarterly Pump and Valve Operability
Test," Revision 6A. In addition, the inspectors reviewed the procedure for technical
adequacy in accordance with ASME Code Section XI.
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b.
Observations and Findinos
Prior to commencing the test, the performer noted a number of discrepancies with
the procedure. The performer identified that Procedure STP-201-6311 specified
that the vibration data be taken on the SLC pump motor rather than the crankshaft
bearing housing as required by the ASME code and the IST plan and ensured that
the procedure was revised. In addition, the performer identified that a number of
safety-related components that were directed to be manipulated during test
performance were not listed for independent verification. These discrepancies were
revised prior to the surveillance test. The test was performed in accordance with
the revised procedure with no problems. The inspectors reviewed the completed
test data and determined that data was satisfactory.
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c.
Conclusions
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The IST of the SLC pump was performed satisfactorily and in accordance with
procedures. The operator performing the IST of the Division I SLC pump exhibited a
questioning attitude by ensuring that the procedure was technically correct prior to
performance.
M 1.4 IST of the Division 11 SSW System
a.
Inspection Scooe (61726)
On December 12 the inspectors observed performance of Procedure STP-256-6304,
" Standby Service Water B Loop Quarterly Pump and Valve Operability Test,"
Revision 8.
b.
Observations and Findinas
The test was performed with satisfactory results and the operators followed the
procedure in a step by step manner. However, the vibration technician failed to
obtain vibration data from the locations specified in Attachment 4 of
Procedure STP 256-6304. The drawing required taking measurements directly on
the motor bearing housing; however, the test performer took the measurements at a
lifting lug that was accessible since the motor bearing housing was not accessible.
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A similar problem with Division i SSW was identified by the inspectors in NRC
Inspection Report 50-458/96-15 and was the subject of a violation. The corrective
actions were still in process; therefore, the procedure was not revised, the pump
motor was not modified, nor a relief request submitted to alleviate the physical
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inability to meet ASME requirements. The inspectors expressed concern that
placing the vibration technicians in the position of noncompliance with the
procedure could undermine efforts to ensure procedure compliance at River Bend.
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The licensee responded that they would resolve the concern.
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c.
Conclusions
Operators performed the IST of the Division 11 SSW system well and obtained
satisfactory results. The licensee had not yet corrected the procedures to reflect
the actual points for obtaining the ASME Code Section XI vibration measurements.
This was the subject of a violation in NRC Inspection Report 50-458/96-15 and
corrective actions had not yet been completed. The licensee indicated that they
would include this example in their violation response.
M8
Miscellaneous Maintenance issues (92902,92700)
M8.1 (Closed) Violation 50-458/9511-01: preventive maintenance (PM) work order not
properly preplanned. This violation addressed an event in which control of the
service water system was inadvertently transferred from the control room to the
remote shutdown panel during a PM task because of inadequate work instructions.
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For corrective actions, the licensee: (1) required maintenance supervision to screen
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PM tasks prior to implementation, (2) developed a PM reviewers checklist to ensure
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that all expectations for the work document were met, (3) issued a PM work
instruction writer's guide, and (4) trained maintenance craft on the implementation
of PM tasks. The inspectors determined that the licensee satisfactorily implemented
the corrective actions.
M8.2 (Closed) Violation 50-458/9523-01: failure to comply with Operations Policy 19,
" Restoration / Maintenance of System / Component Operability Through use of Manual
Action in Place of Automatic Action." While painting the Division 11 EDG, plant
construction personnel installed plastic sheeting over the EDG cooling vents to
prevent damage from paint overspray. However, control room operators were
unaware of the extent of this activity and that manual action would be necessary
for the EDG to perform its intended safety function.
At the time of the incident, the inspectors noted that appropriate immediate
corrective actions were taken. To prevent a recurrence, a painting impact
walkdown checklist was developed and implemented by revising
Procedure PMC-22-002, " Modification Installation," to require walkdowns by
painters and operators to ensure that safety related equipment was not impacted
without the knowledge of the operators. The inspectors noted over the past year
that the painters and paint supervision exercised caution not to impact operating
equipment during extensive painting activities in the power block.
M8.3 LClosed) Violation 50-458/9523-02: two examples of f ailure to comply with
written procedures. In the first example, a mechanic disconnected the wrong
solenoid pilot operated air start valve from the Division I EDG for troubleshooting
and/or replacement. This inattention to detail resulted because the mechanic
perceived that the job was to be expedited. The inspectors verified that an
accountability and counseling session was held with the mechanic. In addition,
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training sessions were held with mechanics to stress the importance of following
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procedures and not expediting work at the expense of quality.
In the second example, a CR was not initiated to document the error and properly
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disposition the valve until 2 days later when prompted by the inspectors. This was
contrary to Procedure RBNP-030, " Initiation and Processing of Condition Reports,"
Revision 7. The maintenance supervisor had misinterpreted the
Procedure RBNP-030 requirements. The inspectors verified that
Procedure RBNP-030, Revision 9 contained clear instructions requiring a CR to be
initiated whenever activities are performed on the wrong equipment.
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M8.4 (Closed) Insoection Followur; Item 50-458/9523-0_3: during the observation of the
replacement of an air start solenoid operated valve the inspectors identified a
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question on the generic implications of the failed component being replaced.
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The licensee experienced several failures of this component in service and during
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bench testing. The EDG vendor issued a 10 CFR Part 21 report on these
components which were purchased from Calcon Corporation. The 10 CFR Part 21
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report identified a generic impact from the failures and, thus, the generic impact
was appropriately reported to the industry.
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M8.5 (Ocen) Licensee Event Report 50-458/95-02: deficient IST surveillance of EDG air
receiver check valves because of an inadequate procedure. On March 21,1995,
the EDG system engineer identified that the surveillance procedures for verifying the
operability of the Division I and II EDG air receiser tank inlet check valves were
deficient. The test incorrectly included nonsafety-related check valves in the test
boundary.
The corrective action for this problem was to train system engineers and other
selected personnel who review and verify IST surveillance procedures. Training was
to be given by October 26,1995. The inspectors reviewed the training records and
found that the reactor core isolation cooling system engineer, who reviewed and
verified IST surveillance procedures, had not been trained in this regard. After being
informed of this observation by the inspectors, the licensee discovered an additional
three engineers who were not trained. The licensee documented this discrepancy in
CR 96-2069. This licensee event report will remain open until all system engineers
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who review IST procedures have been trained.
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Ill. Enaineering
E2
Engineering Support of Facilities and Equipment
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E2.1
Inacoropriate Use of Chemical Cleaner
a.
Injip_ection Scope (37551)
The inspectors reviewed licensee actions in response to an incident where personnel
used an unapproved commercial cleaner to clean a service water radiation monitor
heat exchanger.
b.
Observations and Findinas
On October 17,1996, mechanics removed the stainiess steel heat exchanger from
Radiation Monitor RMS-RE158, Train B SSW radiation monitor, to inspect it for
fouling. After attempts to flush with water, mechanically clean with brushes, and
ultrasonically clean the heat exchanger, the heat exchanger remained fouled. Upon
discovering that the heat exchanger remained clogged with sludge, the engineer
performing the inspection suggested that the mechanics contact the Chemistry
Department for guidance on an appropriate chemical cleaning agant to remove the
sludge.
.
Subsequently, the mechanics cleaned the heat exchanger with a diluted solution of
"Fantastik" (three ounces of cleaning agent in four gallons of water) on the verbal
suggestion of a chemistry laboratory supervisor. "Fantastik" contained caustics
that could promote stress corrosion cracking of the stainless steel surfaces in the
heat exchanger at elevated temperatures. " Fantastic" was classified by the licensee
under their chemical control program as a Class 111 chemical, which was a chemical
that was not to be used in direct contact with plant systems. Upon recognizing this
action was contrary to Procedure RBNP-040," Control of Chemicals," Revision 7A,
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the mechanics initiated CR 96-1869. The heat exchanger was flushed with water
prior to placing it into service. Based on this and the diluted solution of "Fantastik"
used, the engineer determined that there was no degradation of the heat exchanger.
The root cause analysis associated with CR 96-1869 identified miscommunication
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among departments and a lack of thorough understanding of the chemical control
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program. Additionally, administrative procedures related to evaluating chemicals in
the plant did not agree on who had responsibility for designating the use of
chemicals on safety-related equipment. The inspectors expressed concern that the
chemical control program continued to be ineffective in preventing the unauthorized
use of chemicals in the plant. The licensee revised procedures to ensure clear
guidance provided on user responsibilities when using chemicals in the plant and for
approving chemicals for use in the facility. The inspectors reviewed Revision 8 to
Procedure RBNP-040 and noted that the requirements were clear and concise. The
licensee also scheduled training with maintenance shops, chemists, and engineering
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to heighten awareness levels with the clarified chemical control program
requirements.
Failure to comply with the requirements of Section 6.1.5 of Procedure RBNP-040is
a violation of TS 5.4.1.a. This licensee-identified and corrected violation is being
treated as an NCV consistent with Section Vll.B.1 of the NRC Enforcement Policy.
Specifically, the violation was identified by the licensee, was not willful, actions
taken as a result of a previous violation should not have corrected this problem, and
appropriate corrective actions were completed by the licensee (50-458/9616-04).
c.
Conclusions
The inspectors concluded that the licensee responded appropriately to the improper
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use of chemicals in the plant by correcting the specific problem and strengthening
the chemical control program. An NCV was identified for failure to comply with the
chemical control procedure.
E2.2 Review of Facility Conformance to UFSAR Descriptions
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A recent discovery of a licensee operating a facility in a manner contrary to the
UFSAR description highlighted the need for a special focused review that compares
plant practices, procedures, and/or parameters to the UFSAR descriptions. While
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performing the inspections discussed in this report, the insptctors reviewed the
applicable portions of the UFSAR that related to the areas inspected. The
inspectors verified that the UFSAR wording was consistent with the observed plant
practices, procedures, and/or parameters.
E8
Miscellaneous Engineering issues (92903)
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E8.1
(Closed) Unresolved item 50-458/9615-06: potential violation of TS 3.0.4 because
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of mispositioned test switch. The inspectors questioned the initial operability
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assessment for Switch S1-HVKB03 being mispositioned. Subsequently, the
licensee noted that Division I of control room air conditioning would be inoperable if
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Chiller HVK-CH1B was selected and Switch S1-HVKB03 was in the " TEST"
position. The inspectors left this item unresolved because the licensee was
reviewing whether the plant changed modes with Switch S1-HVKB03 in the " TEST"
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position and Chiller HVK-CH1B selected for postaccident operation.
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The licensee completed their review of this event and determined that they violated
TS 3.0.4 by changing operational modes with the control room air conditioning
system inoperable. An example of a configuration control violation was identified in
NRC Inspection Report 50-458/9615 for Switch 31-HVKB03 being out of position
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that addressed this same deficiency. The inspectors will followup on the corrective
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actions for this issue during review of the licensee event report.
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IV. Plant Support
R1
Radiological Protection and Chemistry Controls
R1.1 - Locked Hiqh Radiation Area Door left Unlocked
a.
Insoection Scooe (71750)
The inspectors reviewed licensee actions in response to CR 96-1954 that
documented the failure to maintain a high radiation area door locked.
b.
Observations and Findinas
On November 14,1996, while on a routine tour, a maintenance supervisor
discovered Door RW-136-62 urdocked and unattended. This door provided a locked
barrier for a locked high radiation area as defined in TS 5.7.2 (i.e., areas with
radiation levels greater than or equal to 1000 millirem per hour). The maintenance
supervisor contacted Radiation Protection and stood by the door until a radiation
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protection technician arrived at the scene. The door was one of three in the
radioactive waste building that did not automatically lock when latched. The
radiation protection technician who last used the door failed to check that the door
was locked as well as latched. The door was promptly locked and the CR was
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initiated.
In response to the incident, the licensee checked to determine if someone could
have entered the area through the door while it was unattended and found none. A
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check was made for abnormally high exposures for the day involved and none were
identified. The radiation protection technician who left the door unlocked was
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counseled about self-checking. The licensee initiated an investigation to determine
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if the three doors that did not automatically lock could be modified so that alllocked
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high radiation area doors lock automatically when latched. The inspectors
determined that this was an isolated incident.
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Failure to maintain locked high radiation area Door RW-136-62 tocked or
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continuously guarded is a violation of TS 5.7.2. This licensee-identified and
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corrected violation is being treated as an NCV consistent with Section Vll.B.1 of the
NRC Enforcement Policy. Specifically, the violation was identified by the licensee,
was not willful, actions taken as a result of a previous violation should not have
corrected this problem, and appropriate corrective actions were completed by the
licensee (50-458/9616-05).
c.
Conclusions
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The inspectors concluded that the November 14 f ailure to lock the door to a locked
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high radiation area was an isolated incident that the licensee appropriately
dispositioned. An NCV was identified for failure to comply with TS 5.7.2.
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Conduct of Security and Safeguards Activities
S 1.1
General Comments (71750)
Throughout the inspection period, the inspectors observed security officers as they
performed their duties. The security officers were alert at their posts, security
boundaries were being maintained properly, and entry screening processes were
performed well at the primary access point.
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V. Manaaement Meetinas
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on December 19,1996. A subsequent exit was held on
Janaury 2,1997, to reclassify several inspection findings. The 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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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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J. P. Dimmette, General Manager, Plant Operations
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M. A. Dietrich, Director, Quality Programs
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D. T. Dormady, Manager, System Engineering
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J. R. Douet, Manager, Maintenance
J. Holmes, Superintendent, Chemistry
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H. B. Hutchens, Superintendent, Plant Security
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T. R. Leonard, Director, Engineering
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D. N. Lorfing, Supervisor, Licensing
C. R. Maxson, Senior Lead Licensing Engineer
J. R. McGaha, Vice President-Operations
W. P. O'Malley, Manager, Operations
W. H. Odell, Superintendent, Radiation Control
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lNSPECTION PROCEDURES (IP) USED
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Onsite Engineering
Surveillance Observations
Maintenance Observation
lP 71707
Plant Operations
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Plant Support Activities
Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Facilities
Followup - Operations
Followup - Maintenance
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iP 92903
Followup - Engineering
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Ooened
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50-458/9616 01
Failure to maintain an operating procedure (Section O2.1)
)
50-458/9616-02
Failure to implement the safety function determination
program (Section 04.1)
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50 458/9616-03
Failure to establish reference values prior to placing pump
in servica (Section M1.2)
Closej
50-458/9511-01
Inadequate preventive maintenance instruction
(Section M8.1)
50-458/9511-02
Four examples of operator errors led to loss of control of
SSW (Section 08.1)
50-458/9523-01
Failure to comply with administrative controls over manual
actions (Section M8.2)
50-458/9523-02
Two examples of failure to follow procedures
(Section M8.3).
50-458/9523-03
IFl
Review of generic implications of EDG start valves
(Section M8.4)
50-458/9615-06
Potential violation of TS 3.0.4 because of mispositioned
4
test switch (Section E8.1)
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Opened and Closed
50-458/9616-04
Improper use of chemical cleaner (Section E2.1)
50-458/9616-05
Failure to lock a locked high radiation area door
(Section R1.1)
Discussed
50-458/95 002
LER
Deficient IST of EDG air receiver check valves
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(Section M8.5)
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LIST OF ACRONYMS USED
American Society of Mechanical Engineers
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CR
Condition Report
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Control Room Supervisor
gpm
gallons per minute
!PCS
IP
inspection Procedure
lST
Inservice Testing
LCO
Limiting Condition for Operation
Low Pressure Core Spray
mal
Maintenance Action item
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,,CV
Noncited Violation
Public Document Room
Preventive Maintenance
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Standby Service Water
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TS
Technical Specification
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Updated Final Safety Analysis Report
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