IR 05000219/1985029
| ML20137D953 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/12/1985 |
| From: | Baunack W, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20137D861 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.2.1, TASK-2.K.3.27, TASK-TM 50-219-85-29, IEB-79-02, IEB-79-15, IEB-79-2, IEB-80-08, IEB-80-8, NUDOCS 8511270171 | |
| Download: ML20137D953 (25) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/85-29
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Docket No.
50-219 License No.
OPR-16 Priority Category C
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Licensee:
GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name: Oyster Creek Nuclear Generating Station Inspection At: Forked River, New Jersey Inspection Condccted:
September 23 - October 20, 1985 Participating Inspectors:
W. H. Bateman. Senior Resident Inspector W. H. Baunack, Project Engineer J. F. Wechselberger, Resident Inspector Reviewed by:
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W. H. Baunack, Project Engineer Da'te Approved by:
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H. B. Kist'e Acting Chief, Reactor Projects
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Section IA Inspection Summary:
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Routine onsite inspections were conducted by the resident inspectors and one region based inspector (316 hours0.00366 days <br />0.0878 hours <br />5.224868e-4 weeks <br />1.20238e-4 months <br />) of activities in progress including plant operations, physical security, radiation control, housekeeping, equipment surveillances, and preparations for the upcoming one month outage. The inspectors also reviewed action on previous inspection findings and IE Bulletins, observed special testing of the Emergency Service Water pumps, met with managers of Plant Material and Tech Functions System Analysis, observed preparations for hurricane Gloria, and toured the Basic Principles Simulator.
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Results:
No violations were identified during this report period. The licensee's preparations for hurricane Gloria were adequate to support plant safety.
Outage planning activities were observed to be well under way and should
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result in a successful outage.
Reviews of two older IE Bulletins identified problems with inadequate licensee responses. Seventeen open items were closed and four were opened.
ESW pump runs in response to an older IE Bulletin were satisfactorily performed. As a result of an unforeseen problem, the licensee had to request an emergency change to their Technical Specifications in order to support their planned outage activities.
The proposed emergency changes underwent close scrutiny by the resident inspectors to support NRC Licensing's j
evaluation of the request. Several iterations of the proposed change were required before the request was sufficiently described and justified.
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DETAILS 1.
Licensee Action on previous Inspection Findings (0 pen) Inspector Followup Item (219/85-09-02): 10 CFR 21 Report Involving Seismic Qualificati.on of Installed GNB Batteries This item was updated in NRC Inspection Report 85-26. During this report period, the licensee completed the modification to the battery racks.
During NRC inspection of the completed work, the inspector noted a missing spacer between adjacent cells 31 and 32 in the
'C' battery room.
This item will remain open pending installation of the required spacer.
[ Closed) Unresolved Item (219/85-26-01): Anomaly in Standby Liquid Control Poison Tank Sequential Chemistry Samples The licensee plotted poison tank chemistry data for the past three years to determine if there was any historical data that would t-dicate the difference between the sequential chemistry samples was not &n anomaly, a review of this data indicated that this particular set of samples had unique differences. A second backup sample was taken during this report period which had identical results to the previous sample.
Licensee personnel performed an analysis to determine the maximum discrepancy that could result based on instrument error and found the answer to be.7%.
This is less than the actual difference of 1.1%.
To ensure an adequate amount of sodium pentaborate is maintained in solution, plant chemistry
personnel have decided to read the tank level ordinate on the Tech Spec concentration curve 10% lower than the actual tank volume and to use this value when determining if concentration is on or above the operating In addition, for the next few months, when performing sodium curve.
pentaborate concentration analyses, chemistry personnel will spike a portion of the sample and analyze this spiked ssmple to ensure their analysis procedure detects the change.
The inspector concluded the difference between the two sequential samples was an anomaly. No explanation for the anomaly was offered by the licensee. Based on the actions taken, the fact that sample results have been consistent since the problem, and the fact that none of samples indicated a violation of Tech Spec requirements, this item is closed.
2.
Review of IE Bulletins Licensee action taken to address closure of the following Bulletins was reviewed during this report period.
The results of this review are described below:
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IE Bulletin 79-02, Pipe Support Base Plate Designs using Concrete Expansion Anchor Bolts.
A portion of the licensee's response, dated 12/7/79, stated an inspection of Emergency Service Water piping supports in the Turbine Rutiding for conformance to requirements of this Bulletin would be completed by early January 1980 and that corrective action, if required, would be scheduled for completion prior to the end of the refueling outage scheduled to start January 1980. The NRC inspector requested the results of the inspection, but the licensee was not able tc supply this information prior to the end of this report period.
It is expected this information will be supplied for review during the next report period.
This Bulletin remains open.
IE Bulletin 79-15, Deep Draft Pump Deficiencies.
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Licensee action to address this Bulletin was reviewed and documented in NRC Inspection Report 85-19.
The Bulletin was left open pending
the evaluation of ESW pump performance during extended pump operational runs. These runs were completed during this report period. The data gathered during the runs indicated the pumps operated satisfactorily. This Bulletin is, therefore, closed.
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IE Bulletin 80-08, Examination of Containment Liner Penetration Welds.
In licensee letter dated 7/7/80, a commitment was made to respond in writing to the NRC within 45 days of 7/7/80 with information to complete their response.
In a letter dated 9/6/85, over five years later, the licensee completed their response. The inspector i
reviewed both responses in an attempt to close this Bulletin. The 9/6/85 letter stated that the licensee could not locate radiographs of the three containment liner welds that were identified in the 7/7/80 letter and that they did not consider the specific concerns of the Bulletin applicable to Oyster Creek. This position was in conflict with the 7/7/80 letter wherein it was stated if the missing weld records could not be located, the welds would be radiographed if physically possible.
The Bulletin clearly states it is applicable to all licensees and specifically requested that all licensees describe how they met code volumetric inspection requirements for containment liner welds. The i
specific concern of the Bulletin was that some licensees were performing UT inspection in lieu of RT when RT was practical and that UT results were questionable if backing bars were used for these welds. Oyster Creek's code commitment specified that all containment penetration welds be radiographed. The codes do permit volumetric inspection by UT if RT is not practical.
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The letter dated 7/7/80 contained a table of double and triple flued head drywell penetrations that were the subject of the Bulletin. A review of this table and various plant drawings indicated that the table was incomplete and inaccurate.
In particular, field weld FW5567A for isolation condenser penetration X-58 was not identified, two of the three welds stated in the letter as missing records of required radiography did r.ot require radiography because they were not pressure boundary welds, and the lack of RT data for field weld FW5575A was not specifically addressed as a problem in the cover letter with the other three welds.
The inspecter discussed these concerns with the licensee and it was agreed that volumetric inspection of welds FW5567A (Isolation Condenser penetration X-5B), FW5575A (Isolation Condenser penetration X-5A), and SW NP 2-B (Liquid Poison penetration X-6) is not documented and that code required NDE should be performed.
Based on RT being impractical and the fact that backing bars were not used on these welds, it was agreed UT inspection of these welds would be pursued to meet the volumetric NDE requirements.
This Bulletin will remain open pending satisfactory licensee action to meet code and Bulletin requirements.
3.
Pipe Hanger Inspections During this report period, pipe and pipe support inspections continued as did efforts to repair deficiencies that were determined by Technical Functions not to be acceptable as is. - The overall scope of the inspection stood at 515 hangers outside the drywell and 268 inside the drywell at the end of this report period.
The NRC inspectors reviewed MNCR's on a sample basis to ensure that preliminary engineering dispositions were reasonable and that deficiencies did not affect safe plant operation. No points of disagreement were identified. The NRC inspectors did, however, identify that base plate bearing is not an inspection attribute of the Bulletin 79-14 reinspection program.
In discussions with engineering personnel after identification of this fact, it was determined that base plate bearing discrepancies required identification.
(The subject of base plate flexibility and bearing is discussed in IE Bulletin 79-02.) It was subsequently agreed that base plate bearing would be inspected during expansion anchor bolt pull testing scheduled to start in December 1985 to address IE Bulletin 79-02.
4.
Observation of Physical Security During daily entry and egress from the protected area, the inspector ver-ified that access controls were in accordance with the security plan and that security posts were properly manned. During facility tours, the
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inspector verified that protected area gates were locked or guarded and that isolation zones were free of obstructions. The inspector examined
vital area access points to verify that they were properly locked or guarded and that access control was in accordance with the security plan.
No concerns were identified.
5.
Radiation Protection
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During entry to and exit from the radiologically controlled area (RCA),
The inspector verified that proper warning signs were posted, personnel entering were wearing proper dosimetry, personnel and materials leaving were properly monitored for radioactive contamination, and that monitoring instruments were functional and in cr.libretion.
Posted extended Radiation Work Permits (RWP's) and survey status boards were reviewed to verify that they were current and accurate. The inspector observed activities in the RCA to verify that personnel complied with the requirements of applicable RWP's and that workers were aware of the radiological conditions in the area.
In NRC Inspection Report 85-26, an issue involving processing of radioactively contaminated material as clean waste was discussed.
Additional corrective action taken during this report period to prevent recurrence included changes in program requirements.
These include sorting all clean trash collected in the RCA prior to it leaving the RCA and removing all yellow material from clean waste whether contaminated or clean. Clean yellow material is then to be shredded in the RCA after the shredder has been relocated into the RCA. Additionally, sorted clean material is to be rebagged, surveyed and released at the RCA exit.
Plant personnel will then dispose of it in a dumpster without it being shredded.
Another incident involving contaminated material appearing outside the RCA was identified by the licensee and reported to the resident inspectors. This incident involved, during routine daily surveys by radcon personnel of dumpsters outside the RCA, the identification of a small piece of contcminated pipe.
Surveys determined there was fixed
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contamination on the pipe in the amount of 15 mrad beta and that no other material in the dumpster was contaminated. Subsequent investigation into the loss of control of this contaminated pipe determined the cause to be an error in transcribing part identification numbers.
The inspectors reviewed the onsite process to decontaminate material and control its subsequent release out of the RCA and found the process to be controlled.
No specific corrective action appeared necessary.
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A problem involving transportation of a control rod blade cutter from Oyster Creek to a repair facility in Tennessee was reported by the licensee to the NRC. The particulars of this incident are discussed in NRC Inspection Report 85-33.
6.
Surveillance Testing and Preventive Maintenance
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The inspectors reviewed the following surveillance and preventive maintenance tests involving the Emergency Diesel Generators to determine if the tests were included on the master surveillance schedule, were technically adequate, were performed at the required frequency, and satisfied Technical Specification requirements:
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Technical Specification Supporting Installed Instrumentation, 112.1, Rev. 19 Quarterly Inspection of Diesel Generators, 636.2.002, Rev. 7
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Diesel Generator Battery Discharge (Load Test) and Low Voltage Annunciator, 636.2.004, Rev. 12
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Diesel Generator Weekly Battery Surveillance, 636.2.005, Rev. 9
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Diesel Generator Monthly Battery Surveillance, 636.2.006, Rev. 7
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4160 Volt Breaker Preventive Maintenance, 732.2.001, Rev. 4
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Diesel Generator Inspection (Annual), 736.1.006, Rev. 7
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Diesel Generator Automatic Actuation Test, 636.2.001, Rev. 11
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Diesel Generator Load Test, 636.4.003, Rev. 22 No concerns were identified.
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7.
Inservice Testing During this report period routine inservice testing was performed on the Emergency Service Water (ESW) pumps.
Recent removal of the internal pipe lining from a portion of the ESW piping, required establishment of new base line data for these pumps. The inservice testing performed on these pumps during this report period resulted in questionable operability of pumps 'A'
and 'D' due to high differential pressure and flow on 'A'
and low flow on 'D'.
Because the pumps were determined to be delivering in excess of Tech Spec required flow, they were re-baselined and declared fully operable.
Investigation into the need for re-baselining determined the following:
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When the 'A' pump was baselined, a portion of the flow was being
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diverted through a leaky check valve into the Service Water system.
This resulted in inaccurate base line data.
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When the 'D' pump was baselined, the sonic flow measuring device was
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not properly attached to the piping. This resulted in inaccurate base line data.
Both of the problems that resulted in inaccurate base line data have been problems in the past. The inspectors expressed their concern to the licensee that more care should be taken when establishing inservice testing base line data so that subsequent testing will be meaningful as regards determination of equipment degradation.
8.
ASME Code Cases Licensee letter dated 9/13/85 from R. F. Wilson (GPUN) to T. E. Murley (NRC) stated GPUN was proposing to use ASME Code Cases N-397 and N-411.
The NRC inspectors reviewed Regulatory Guide 1.84, Design and Fabrication Code Case Acceptability, Rev. 23, to ensure these Code Cases had received NRC endorsement. This review disclosed that Code Case N-397 was conditionally approved but that N-411 was not listed as approved.
The inspectors discussed this situation with the licensee and clarified the regulatory position regards the use of ASME Code Cases as stated in 10 CFR 50 paragraph 50.55a(c)(3): "ASME Code cases must have been determined suitable for use by the NRC." A footnote states: "ASME Code cases which have been determined suitable for use by the Commission staff are listed in NRC Regulatory Guide 1.84.
The use of other Code cases may be authorized by the Director of the Office of Nuclear Reactor Regulation upon request...."
Subsequent to this clarification, the licensee contacted the appropriate NRC personnel and determined that Code Case N-411 was nearing conditional approval.
The NRC inspectors confirmed with licensee design personnel that they will comply with the conditions set forth for use of this Code case.
In the future, the license should ensure they comply with the regulations when electing to use an ASME Code case.
9.
Potentially Defective GE Undervoltage Trip Devices NRC headquarters received written notification dated 9/13/85 from General Electric that a defect may exist on undervoltage (UV) trip devices supplied for use on AK and AKR type low voltage power circuit breakers.
A limited number of UV trip devices have recently failed to trip the circuit breakers when power was removed from the devices. Two types of defects were noted.
First, devices made between mid-1973 and May 1985 may have mating surfaces of armatures and pole pieces improperly painted.
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This paint may soften and stick to the pole piece causing failure to trip when power is removed.
In the second defect, UV trip devices were manu-factured with insufficient clearance between the arr.atures and the device mounting studs. GPUN was identified as a user of these trip devices.
UV devices having these potential defects were sold by GE only as replacement components in safety-related applications. GE expe:ts to notify each potential user by 9/23/85 via service advice. Corrective action is to replace the UV trip devices showing either defect. The inspectors will follow licensee action to address this potential concern. (219/85-29-01)
10.
Preparation for the October-November Outage The inspectors attended various planning meetings, met with key personnel to discuss their plans, and toured various areas of the site to observe prefchrication and material staging activities.
The inspectors noted that all activities required in support of the outage were well underway.
In particular, supporting procedures were, for the most part, approved with OC holdpoints established, material to support many of the outage jobs was staged in the warehouse by job number, experienced licensee personnel were assigned to each job to help ensure satisfactory work progression and to identify problems promptly, and prefabrication of the critical path instrumentation was near completion. Discussions with li-censee personnel to determine their feelings about preparations for this one month outage versus previous outages were positive, i.e., they felt all jobs were better planned and supported by engineering and should be better managed and controlled because of additional training and utiliza-tion of experienced personnel.
The inspectors will continue to observe outage activities during the next report period.
11. Completed TMI Action Plan Items An evaluation was conducted of completed TMI Action Plan Items which are considered closed at this time.
This evaluation was based primarily on routine inspection activities and discussions with facility personnel.
Many TMI Action Plan Items which are related to procedure changes and training have been completed and closecut inspections have been performed. A significant number of hardware changes have been made, however, final completion and implementation of the tota! modification has yet to be accomplished. Many of these are scheduled to be completed during the next refueling outage.
Inspection findings and discussions with personnel indicate no significant problems with those items which
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have been completed.
Favorable comments were received with regard to the improved training.
Some personnel expressed a concern that implementing a large number of hardware changes during one outage places an additional burden on the operators. Overall changes which have been made appear not to have experienced unusual problems.
However, a large number of hardware changes remain to be implemented.
12. Licensee Actions Taken as a Result of TMI Action Plan Requirements Specified in NUREG 0737 The licensee's action relative to the following TMI Action Plan requirements were reviewed.
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Item I. A.1.1.3.B, Shift Technical Advisor (STA) Training By letter dated January 15, 1982, D. M. Crutchfield (NRR) to I. R.
Finfrock (JCP&L) the licensee was informed that their submitted STA training program meets the intent of the TMI Action Plan requirements.
During NRC Region I Inspection 84-06, the licensee's STA training program was inspected and found to be acceptable. At the time of the inspection, the licensee's STA Requalification Program had not yet been implemented.
During this inspection, the implementation of the STA Requalification Program was inspected.
The licensee has in place a Training Program Procedure No. 1550.00, STA Requalification Program, dated June 12, 1984.
This procedure describes the program scope, administration, requirements, evaluations and special retraining. The STA requalification training consists of a minimum of 60 classroom lecture hours, simulator, control room mockup or basic principles trainer training, and an annual requalification oral examination.
The licensee currently has six active STA's. Three of these are licensed SRO's, and two save just recently (July 1985) completed the STA training program.
The three STA's not yet licensed expect to be licensed early next year. All STA's currently participate in the licensed operator retraining program.
This program essentially satisfies the STA requalification program lecture requirements.
During this inspection, documentation associated with the STA Retraining Program was marginally in compliance with procedural requirements, particularly in the area of on-the-job training records. Attendance records, which in some instances were reconstructed from various sources and discussions with personnel, did verify that the required retraining is being conducted.
Presently, the STA requalification program procedure is being modified to more clearly define administrative responsibilities and requirements. Also, within the last month the vacant position of STA Training Supervisor has been filled.
These changes snould ensure an effective requalification program.
This item is considered close.
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Item I.A.2.1.4.B, Upgrading of R0 and SR0 Training TMI Action Plan requirements specified that training programs shall be modified to provide training in heat transfer, fluid flow and thermodynamics; training in the use of installed plant systems to control or mitigate an accident in which the core is severely damaged; and increased emphasis on reactor and plant transients. By letter dated November 30, 1982, D. M. Crutchfield (NRR) to P. B.
Fiedler (GPUN), the licensee was informed that their submitted program satisfied the requirements of TMI Action Plan Item I.A.2.1.4.
During NRC Region I Inspection 84-06, the licensee's operator qualification training program was reviewed and found to be acceptable. During this inspection the content of the operator qualification training program was verified to meet the Action Plan requirements.
Training guide contents, course outlines and class lecture lists were reviewed.
In addition to system traceouts, on shift time and simulator training, the following were among the lecture series included in the 1984-1985 fifteen month operator qualification training program: Math, Physics, Basic Electric Theory, Abnormal Procedures, Modifications, Technical Specification Amendments, Nuclear Instrumentation, Reactor Protection Systems, Core Limits, Reactor Theory, Control Manipulations, Core Spray and ADS, Heat Transfer / Fluid Flow, Containment Spray /ESW, Pumps and Fluid Flow, Vessel Instrumentation, Reactor Theory-Source Neutrons and Poisons, Reactor Theory Review, Emergency and Operating Procedure Review, Technical Specification Review, and Heat Transfer Fluid Flow Review.
The mitigating core damage courses included Core Cooling Mechanics, Critical Parameter Peak Values, Critical Parameter Instrumentation, Damage Verification, Hydrogen Hazards, Gas Accumulation Effects on Core Cooling, and Radiation Hazards.
Also, the Trainee Guide included instructions on recognizing and mitigating the consequences of severe core damage, hazardous conditions resulting from severe core damage, and monitoring critical parameters during accident conditions.
Based on the findings of this inspection, the Action Plan requirements for the licensed operator qualification program have been met. This item is considered closed.
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Item II.K.3.27, Common Reference Level for Vessel Level Instrumentation
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The licensee committed to modify all reactor vessel water level instrumentation so that they have a common reference level. The
reference level was chosen to be the top of active fuel (TAF). This modification was conducted in two phases.
The first phase was to
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include the reference to vessel level above the TAF along with original indicator scales. This was to provide a transition period for the operators to hecome accustomed to the new scales. This was done in 1980. NRC Region I Inspection 82-09 verified this phase of the change over. During the last refueling outage, all vessel instrumentation (Barton, Yarway, and GEMAC reactor vessel leve~.
indicators and recorders) scales were repl. ed having a common reference (TAF).
This change was verified uring routine resident inspections.
During this inspection, documentation verifying completion of training for all shift licensed operators on this modification was reviewed and also procedure changes resulting from this modification were verified to have been completed.
The licensee identified 19 procedures in addition to Alarm Response Procedures, Abnormal Operating Event Procedures, Emergency Operating Procedures and the Control Room Turnover Log which were required to be changed. A sampling of procedures were reviewed (Procedures 201.3, 305, 106, Emergency Operating Procedures, 610.3.005, and Standing Order No.1)
to verify necessary procedure changes had been made. No unacceptable conditions were identified.
This item is considered closed.
13.
Followup of Operational Events 13.1 The "A" Isolation Condenser was declared inoperable on October 8, as a result of V-14-31, steam inlet valve, failing an operability test.
The licensee determined the valve failure was caused by an inadequate motor brush spring tension and a loose torque swit:h affecting its setpoint. This condition apparently generated enough heat to result in the solder melting. The licensee replaced the valve motor and performed a successful operability test on October 10.
In addition, the licensee inspected the other isolation condenser valves for similar problems.
13.2 The licensee detected an increase in drywell identified leak rate and
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drywell equipment tank (DWEDT) temperature.
Suspecting leakage past
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the recirculation valves' stem packing, the "C" and "D" recirculation discharge valves were backseated in accordance with a plant
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engineering memorandum. This did not appreciably affect the increase in leak rate or DWEDT temperature and the licensee proceeded to place the remaining recirculation valves on their backseat.
Subsequently, the licensee determined the "B" DWEDT pump and the recycle circulation valve to be contributors to the problem. The licensee is planning to make a 500 psig inspection for leaks during the October outage shutdown.
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13.3 During the inspection period, the plant experienced unexplained steam flow oscillations. On October 15, there was an unexplained increase in "B" steam flow as indicated on the "B" steam flow indicator. This resulted in a perturbation in reactor level, reactor pressure, and a 20-30% opening of a turbine control bypass valve. Previously the licensee had experienced similar oscillations with "B" main steam flow.
To troubleshoot the channel, the licensee instrumented the steam flow channel to record any future oscillation.
14. Dresser Valves Dresser Industries reported to the licensee a potential problem with Dresser Figure 3050 Y-Pattern diaphragm valves. The concern addressed a potential for the valve disc cap to stick in any position, rendering the valve inoperable. The licensee determined main steam line drain valves V-1-106, V-1-107, V-1-110, and V-1-111 are Figure 3050 Y-Pattern diaphragm valves. The licensee had already tagged the valves closed-due to previous valve operability problems. Technical Functions Division has been tasked to determine if any other valves at Oyster Creek may be the subject of the Dresser letter dated September 23, 1985. Another utility has submitted a 10 CFR Part 21 Report.
The inspectors will follow the licensee actions to resolve the Dresser valve concerns.
(50-219/85-29-2)
15. Management Meetings During the inspection period, the inspectors attended two meetings with the licensee to better understand the particular groups' function and responsibilities. These meetings were with Plant Materiel of the Oyster Creek Division and System Engineering of the Technical Functions Division.
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j During the meeting with the Manager of Plant Materiel, the following topics were discussed: major functions and responsibilities of Plant Material, interface and communications with other divisions, long range planning, and Plant Materiel manning level versus workload requirements. The meeting was informative and beneficial. The inspectors attended another meeting held by the Director of System Engineering. A general description of the various groups within System Engineering and their functions and respon-
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sibilities were discussed.
16.
Readiness Assessment Team Inspection Followup During the period March 26-30 and April 2-3, 1984, a Readiness Assessment Team inspection was conducted at both the facility site and at the Stone and Webster Cherry Hill office. The inspection was conducted for the purpose of determining the readiness of the facility to resume operation following a major modification outage.
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During the inspection exit meeting and during a subsequent April 6, 1984 telephone call from R. Keimig, Region I, to P. Clark, GPUN, certain licensee commitments were made.
By letter dated May 11, 1984, R. Wilson, GPUN, to T. Murley, NRC, the licensee updated Region I regarding the status of these commitments. Specific actions taken involved a Stone and Webster review of all field change requests associated with the Scram Discharge Volume System and an internal audit of modifications performed at Oyster Creek.
Reports of these activities were made available to the resident inspectors' office.
By letter dated May 15, 1984, R. Starostecki, Region I, to P. Fiedler, GPUN, the readiness Assessment Team Inspection Report was forwarded to the licensee. The inspection identified four violations with several examples to each violation and three items for further followup.
By letter dated June 15, 1984, P. Fiedler, GPUN, to R. Starostecki, Region I, the licensee provided responses to each of the violations identified.
In addition, the licensee provided a followup response to the inspection report by letter dated August 9, 1984, R. Wilson, GPUN, to R. Starostecki, Region I.
This more detailed response resulted from discussions which were held between Region I and GPUNC staff members on June 22, 1984.
During NRC Inspection 84-10, the licensee's quality control inspections of all hangers associated with the scram discharge volume modification were reviewed and no unacceptable conditions were identified.
During this inspection, the licensee's corrective actions to each violation as described in their June 15, 1984 letter were reviewed, as well as the corrective actions described in their followup response dated August 9, 1984.
The following actions were taken by the licensee in response to each violation described in Inspection Report 84-09.
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(Closed) Violation (219/84-09-1A):
Numerous outstanding changes (i.e., drawings) to specifications when Project Procedure PI-19 limited the changes against a specification to two.
Technical Function (TF) Procedure 5000-ADM-7350.02, Installation Specifications, Step 4.3.3 was changed to define drawings applicable to an installation specification which appear in CARIRS (Computer Access Records Information and Retrieval System). Also, TF Procedure 5000-ADM-7350.03, Field Questionnaires, Change Notices and Change Requests, Step 4.1.7, requires mandatory update of engineering docu-ments should at any time more than five outstanding FCN's or FCR's appear against it.
Stone and Webster has agreed to comply with this
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(Closed) Violation (84-09-18): A mechanical installation
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specification originated by Stone and Webster was revised and issued by GPUN without further review by Stone and Webster.
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The corrective actions taken to prevent recurrence for this item are the same as those verified for the closecut of Violation 84-09-2A.
Additionally, the licensee had design A/E's perform additional re-certification review of two modifications (Containment Leak Rate Testing Modification and In-Containment Instrumentation Modifications) to verify no significant deficiencies in the modifications have been installed.
Details of these audits are discussed in the supplemental response dated August 9, 1984.
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(Closed) Violation (84-09-1C): Contrary to procedural requirements a Mechanical Installation Specification revision was issued without the approval of QA which had approved the original issue.
Procedural changes have been made to clarify the required QA reviews. Procedure 5000-ADM-7550.02, Installation Specifications, Step 4.4.3 states, " Revision approvals shall be recorded on the
' Summary of Change' page (see Exhibit 3).
The approval circuit shall be the same as the original document, i.e., if QA signed l
Rev. O as concurring, they must sign off on revisions." Also, Pro-cedure 5000-ADM-7313.01, Modification and System Design Descriptions has had Exhibit 5 added. This exhibit provides guidance concerning when to obtain QA review of changes to previously released documents that contain QA concurrence.
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(Closed) Violation (219/84-09-2A): Appropriate measures had not been applied to control the design interface between GPUN and Stone and Webster in that GPUN approved and released revised design document.
without obtaining the approval of the original design organization (Stone and Webster).
Technical Functions (TF) Procedure 5000-ADM-7350.03, Field Question-naires, Change Notices, and Change Requests, Step 4.1.4 has been changed to include, "...any changes (FCN/FCR's) to documents origi-nating outside GPUN shall be forwarded for an after-the-fact review to the organization originally responsible for preparing thst dor:ument."
Also, TF Procedure 5000-ADM-7313.01, Modification and W cm Design Descriptions, Step 4.8.4 has been changed to state, " Modification Design descriptions and System Design descriptions prepared by an AE shall identify the AE organization and be signed by the AE in the preparer and concurrence blocks...."
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(0 pen) Violation (84-09-28): Design requirements not correctly trans-lated into drawings, procedures, and instructions.
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The licensee expected to develop additional design standards to prevent a recurrence by March 1, 1985. However, as discussed in the cover letter forwarding Inspection Report 50-219/85-13, and in your supplemental response to Inspection Report 84-09, dated August 9, 1984, the development of this program to establish engineering standards could take up to two years to complete.
Therefore, this commitment has been extended.
(Closed) Violation (84-09-2C): Regulatory requirements pertaining to
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fire protection, physical security, and protection from missiles were not translated into specifications, drawings, procedures, and instructions for the new cable spreading room modification.
The licensee concurs that there eventually will be additional design consideration and resultant modifications to the new cable spreading rocm. However, at present, current regulatory requirements are met as follows: (1) Physical Security presently the new cable spreading room must not be designated a vital area, (2) Missile
Protection - there is nothing within tne area which currently requires missile protection, and (3) Fire Detection and Protection -
evaluation has shown with only a portion of one safe sbut-down system routed through the new cable spreading room safe shut-down capability would be maintained in the event of a fire. Additional design considerations and resultant modifications, which will be necessary for completion of the modification, will be governed by the requirement of the design standards being developed in response to Violation 84-09-28.
This item is, therefore, considered closed.
(Closed) Violation (84-09-4A): Failure to inspect conduit supports
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due to a failure by Maintenance and Construction to identify to QC the existence of the supports, t
The conduit and supports ident!fied, as well as additional supports on the 23 foot elevation of the reactor building, were torqued, verified, witnessed and accepted by QC. Also, to prevent recurrence, the inspector verified that an attachment has been added to Electrical Installation Procedure A158-30728, which includes for each individual hanger / support, a hanger / support number, drawing number, torque verification, hanger IAW drawings, and sign-offs for Maintenance Construction and Facilities and QC.
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(Closed) Violation (84-09-48): Hanger NC-I*IPS-002 2 not installed in accordance with applicable design drawing and installation procedure.
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MNCR's were written against the hanger to correct the discrepancies.
All discrepancies were either corrected or dispositioned by Engineer-ing as " Accept As Is."
To prevent recurrence, the inspector verified a memo (A100-84-0208) was issued by the Maintenance and Construction (M&C) Director for all M&C and contractor supervisors, foremen, and planners.
The memo reiterates the requirement that Technical Func-tions Engineering approval is a prerequisite to effecting a change on any Field Change Request. The memo was issued as Required Reading Assignment #49 on June 14, 1984 and completed on June 22, 1984.
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(Closed) Violation (84-09-4C): Failure to prescribe steps in the installation procedure for the reactor head cooling modification to remove and reinstall a hanger in the recirculation system, although such work was performed during the installation of this modification.
The subject hanger was inspected as to the correctness of installa-tion, and corrections were made as necessary. The work was verified and signed off by QC. To prevent recurrence, the inspector verified a memo (A100-84-0210) was issued by the M&C Director for all M&C and contractor supervisors, foremen, and planners.
The memo requires,
"If any hanger needs to be temporarily removed (partially or completely), written authorization must be obtained from Engineering to do so.
In addition, the work of removing and reinstalling the hanger (partially or completely), must be controlled via procedure or Job Order." The memo was issued as Required Reading Assignment #50 on June 14, 1984, and completed on June 22, 1984.
(0 pen) Violation (84-09-4D): This violation, though identified in
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the body of the inspection report, was inadvertently omitted as an example of a violation to 10 CFR 50, Appendix B, Criterion V and the Oyster Creek Quality Assurance Plan, Section 3 in the Notice of Violation. The licensee identified this omission and will provide an amended response to address this violation.
(Closed) Violation (84-09-5A): Failure of a hanger to meet design drawing requirements.
The licensee has prepared a checklist No. HA-01-G, Inspection Check-list for Elec/ Mech Hangers / Supports.
Included on the checklist are:
Hanger S/N; Hanger Location; Hanger Location in accordance with applicable drawings; Hanger Hardware (A) Clips, (B) Clevis, (C)
Cotter Pins, (D). Turnbuckles, (E) Nuts / Bolts (check all attachments for double nut requirement), (F) Spring Canisters, (G) Locking Tabs on Nuts, (H) Washers, (I) Swivels; Hanger configuration in accordance with applicable drawings (A) dimensions, (B) angle of support to system and base plate, (C) all hanger attachment, i.e., clips, brackets,
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etc., oriented correctly; Weld Locations (A) proper weld location, (B) proper weld spacing, (C) proper number of welds. Also, Checklist No. WF-001-G-kl, Mechanical and Electrical Generic Walkdown Checklist has been prepared to provide detailed inspection attributes to verify that all mechanical components are installed in accordance with approved drawings and/or drawing change documents and that conduit and/or cable tray installations are proper.
(Closed) Violation (84-09-58): An ASME Class 3 valve was
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inadvertently installed in the Liquid Poison system that was designed ASME Class 2 for the purpose of modification work.
The Class 3 valve installed in a Class 2 system was evaluated and determined to be acceptable.
To prevent recurrence, the Mechanical Electrical Generic Walkdown Checklist No. WF-001-G-R1 has been revised to include verification that " Material classification is in accordance with engineering documents (ASME Class I, II, III)."
(Closed) Violation (84-09-5C): Arc strikes in two locations in the
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Reactor Head Cooling System.
These arc strikes were stated to have been evaluated by a GPUN inspector and were judged to be minor.
This evaluation was not documented. To ensure future documentation, this inspection attribute was added to Visual Inspection Procedure MTNE-001 to examine piping and valves for arc strikes. Also, QA Procedure C-130-QAP-7209.21, Visual Inspection of Welds, was examined by the inspector and it was verified that arc strikes are listed as an unacceptable weld defect.
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(Closed) Violation (84-09-5D): QC inspections failed to identify a hanger within the boundaries of modification work which was not addressed or included in either the installation procedure or design drawings.
As noted in the inspection report, the hanger in question was acceptable to leave in place.
Inspection personnel have been reinstructed to question any installation configuration that appears to deviate from the installation specification.
In addition, the Mechanical and Electrical Generic Walkdown Checklist utilized for final inspection requires a walkdown of piping installations. The checklist verifies the following: (1) proper valve orientation, including flow direction, class, service and pressure rating, (2)
material classification is in accordance with engineering documents (ASME Class I, II, III), (3) components are identified in accordance with appropriate drawing, (4) component location is within drawing tolerances, (5) hanger and pipe supports are located in accordance with appropriate drawing tolerances and are the correct design, (6)
verify that all welds are completed, (7) piping and supports are free of arc strikes, (8) snubbers and spring hangers are installed in accordance with drawings.
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The following unresolved and inspector follcwup items associated with Region I Inspection 84-09 were also reviewed:
(Closed) Inspector Followup Item (84-09-03): Verify action has been
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taken to protect mechanical snubber NC*IPS-011-2.
Visual inspection by the inspector verified a substantial metal enclosure has been erected to protect this snubber.
(Closed) Inspector Followup Item (84-09-07): Evaluate effectiveness
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of the Incomplete Work List (IWL) particularly with regard to listing specific items as opposed to summaries containing several items.
The Master IWL containing outstanding items as of September 10, 1985, and the RAGEM's Master IWL as of June 18, 1985 were reviewed.
These IWL's appear to list outstanding items in sufficient detail to
d be an effective management tool.
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(Closed) Unresolved Item (84-09-08): Licensee to evaluate considering the scram discharge volume (SDV) vent and drain valves as containment isolation valves.
As a result of a recent Main Steam Isolation Valve closure scram
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event in which SDV drain valves failed to fully close, this item is
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being tracked as Unresolved Item 85-23-06.
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(0 pen) Inspector Followup Item (219/84-09-09): Deletion of Head Seal
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Leakage Detection Alarm.
The Head Seal Leakage Detection Alarm was inappropriately deleted prior to April 1984, and as a result a plant engineering task was initiated to replace this alarm feature.
The licensee has determined that this alarm is not required.
The Vessel Flange Leak Detection System was described in the Facility Description and Safety Analysis Report and has been deleted from the Updated Final Safety Analysis
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Report (FSAR). The actual alarm was bypassed approximately in 1977 as a result of information provided by General Electric. The licensee review of this item in 1977, May 1984, and June 1985 did not ascertain that the alarm was deleted and removed from the FSAR without a safety evaluation. The licensee is continuing to search their records for information to support a safety evaluation. This item will remain open pending the outcome of the licensee record search.
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(Closed) Inspector Followup Item (84-09-11): Two pathways into tunnels that carry redundant safety cables are not presently secured against entry.
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As described in the licensee's response to Violation 84-09-2C, the new cable spreading room and associated tunnels are not currently required to be designated vital areas, therefore, the tunnel pathways do not now have to be addressed as a security concern.
Also, as discussed in the licensee's response, this issue will be addressed in the future, as may be necessary, in conjunction with future modifications.
The following actions, not specifically associated with any individual violation, were part of the overall corrective action taken by the licensee and were described in the followup response dated August 9, 1984.
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The Standard Distribution List for engic.eering documents has been changed so that the original engineering organization, either
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internal or external to GPUN, automatically receives copies of any changes to the engineering packages performed by that organization.
Document distribution is currently controlled by Technical Functions Division Standard No. AS-001, Document Distribution. This standard l
was issued November 1, 1984 and governs the distribution of such documents as Field Questionnaires, Field Change Request, Field Change Notices, System Design Descriptions, and as built prints. The specified distribution is such that the original engineering organization will receive copies of any changes to their engineering package.
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Steps have been taken to ensure that the engineering contractor of a job is not changed part way through the process without very careful
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consideration of the potential consequences.
In particular, making such a change now requires written concurrence of the Director of Engineering Projects and final approval by the Vice President, Technical Functions.
At the time of this inspection, the means by which this was accomplished was not available for review.
This item will be closed during a future inspection.
(219/85-29-03)
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The desirability of having any changes to engineering documents be made by the same organization that originated the document has been re-emphasized to the project engineering staff.
At the time of this inspection, the means by which this was accomplished was not available for reviaw. This item will be closed during a future inspection.
(219/85-29-04)
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Added emphasis has been placed on the importance of walkdowns during
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the design process in order to reduce the subsequent number of field changes.
Procedures have been changed to require that the engineering organization performing the walkdowns log in with site Technical Functions personnel so that a record of the walkdown is available.
Technical Functions Procedure 5000-ADM-6250.01, Professional Services, has been changed to require, "For all design engineering performed by a PSC for GPUN, the PSC engineer shall conduct at least three walkdowns during the performance of a contract.
The first walkdown shall be conducted prior to initiation of work; the second walkdown at about the time of completion of preliminary engineering; and the third at close to completion of detail engineering.
PSC personnel shall notify GPUN Technical Function Site Supervior (TFSS)
at the time of the walkdown so that each walkdown may be logged by the TFSS." M&C involvement is unnecessary on the fir:t wkdown, optional on the second, and mandatory on the third. Also, principle engineering contractors have been notified by letter of this added l
requirement. Site Technical Function was verified to be maintaining a walkdown log.
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The licensee has instituted a requirement that outside engineering organizations performing significant engineering for GPUN must install the necessary computer equipment to access their CARIRS system. This requirement has been communicated to major vendors.
The licensee provided the inspecter with a memo for the Engineering Data and Configuration Control Manager to the Oyster Creek Licensing Engineer which stated that, as of September 12, 1985, four AE's (Burns and Roe, Inc.; Gilbert Commonwealth, Inc.; Impell Corporation; and Stone and Webster Engineering Corporation) have the hardware installed at their locations, have been trained, and are using the GPUNC Configuration Control List.
Technical Functions procedures have been modified to clearly require
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that new engineering or major changes to existing engineering packages will not be released as a field change, but rather as a re-release of the previous engineering document.
Technical Functions Procedure 5000-ADM-7350.03, Field Questionnaires, Change Notices and Change Requests, has had significant changes made to reflect improvements to administrative practices. Specifically, Step 4.1.1 states, " Field Change Notices and Field Change Requests shall n_ot be used as a means of expanding overall engineering scope o
of a project. They are to be used only to correct deficiencies or problems discovered during construction or test.",
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Technical Functions has defined and is undertaking a program to
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develop engineering standards to serve as the basis for achieving uniformity between engineering produced by different contractors.
While this program will take two or more years to complete, it should provide a substantial imorovement in the number of required field changes.
Completion of this item is being tracked as discussed in Violation 84-09-2B above.
Technical Functions procedures now require two design reviews for
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each modification, one at the completion of preliminary engineering and one near the end of detailed engineering.
Licensee experience with modifications which have gone through both of these design reviews indicates that they have a very helpful impact on reducing the number of required field changes.
Technical Functions Procedure 5000-ADM-7313.01, Modification and System Design Descriptions, has been extensively changed to reflect revised administrative practices.
Specifically, Steps 4.8.3 and 4.11.3 require two design reviews be performed for each modification.
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A program has been undertaken to accumulate and categorize the actual field changes which are required for each modification.
A program was initiated in mid 1983 by which computerized records are maintained for each field change associated with a specific budget activity (Modification). This program for each field change categorizes the type of engineering deficiency and identifies the responsible organization.
17. Hurricane Preparations The licensee took appropriate precautions in advance of hurricane Gloria's arrival on September 27, 1985. The licensee implemented Abnormal Opera-ting Procedure 200-ABN-3200.31, "High Winds." Significant preparations were implemented in accordance with the "High Winds" procedure including reducing power to 35%, securing loose material and anchoring trailers, restricting plant access to essential personnel, increased shift manning, and manning the Technical Support Center.
Damage to the site from the hurricane's passage was minimal. A construction trailer associated with the new low-level radwaste storage facility was overturned and some minor damage to metal siding on the main gate occurred.
The licensee conducted
a critique of their response to the hurricane and plan to make minor revisions to the governing procedures. No inspector concerns were identi-fied.
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18. Basic Principle Trainer and General Employee Training The resident inspectors, at the licensee's invitation, toured the Basic Principles Trainer (BPT) and viewed a training tape to be presented to NRC inspectors to facilitate unfettered access. The training tape was done in a professional manner covering all the plant specific information for Oyster Creek. The Basic Principle Trainer (BPT) is presently i
undergoing acceptance testing. The licensee briefed the inspectors on the BPT and demonstrated some of the trainers capabilities.
The BPT is scheduled to be available for training programs in early 1986.
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19. Plant Operation Review l
19.1 Routine tours of the control room were conducted by the inspectors during which time the following documents were reviewed:
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Control Room and Group Supervisor's Logs;
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Technical Specification Log; Control Room and Shift Supervisor's Turnover Check Lists;
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Reactor Building and Turbine Building Tour Sheets; Equipment Control Logs;
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Standing Orders; and,
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Operational Memos and Directives.
The reviews indicated that the logs were generally complete.
Control room housekeeping and behavior were observed to be
acceptable.
19.2 Routine tours of the facility were conducted by the inspectors to
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make an assessment of the equipment conditions, safety, and adherences to operating procedures and regulatory requirements.
The following areas were among those inspected.
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The following items were observed or verified:
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Fire Protection:
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Randomly selected fire extinguishers were accessible and inspected on schedule.
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Fire doors were unobstructed and in their proper position.
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Ignition sources and combustible materials were controlled in accordance with the licensee's approved procedures.
Appropriate fire watches or fire patrols were stationed
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when equipment was out of service.
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Equipment Control:
Jumper and equipment mark-ups did not conflict with
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Technical Specification requirements.
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Conditions requiring the use of jumpers received prompt 1icensee attention.
Administrative controls for the use of jumpers and
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equipment mark-ups were properly implemented, c.
Vital Instrumentation:
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Selected instruments appeared functional and demonstrated
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parameters within Technical Specification Limiting Conditions for Operation.
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Housekeeping:
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Plant housekeeping and cleanliness were in accordance with approved licensee programs.
20.
Emergency Technical Specifications Change Request The licensee submitted Technical Specification Change Request No. 142 to support the fall 1985 outage.
This emergency change request would enable the licensee to complete the outage in a reasonable time to effect environmental qualification of electric equipment as required by 10 CFR 50.49. This change request was necessitated due to the different
configuration the environmentally qualified equipment has in comparison to the present instrumentation associated with the " Low-Low" reactor water level feature. This different configuration requires disabling the reactor " Low-Low" water level feature in order to install the configuration in a reasonable time period. The reactor " Low-Low" water level feature provides initiation signals for the Standby Gas Treatment System (SGTS) and the reactor isolatfor function which are required to be
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operable according to the Technical Specifications when in a shutdown
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mode. The licensee submittal was accepted by Nuclear Reactor Regulation
after several iterattuns to clarify the submittal.
The request for the emergency Technical Specification change was not submitted in a timely fashion.
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In addition, the licensee has taken special precautions to ensure I
operators respond correctly should a condition requiring SGTS actuation or a reactor vessel low water level occur.
These include a temporary modification to install an alarm unit to indicate an alarm condition when water level drops to 146 inches above top of active fuel and a standing order that delineates operator actions in the event of an abnormal condition.
During the process of verifying licensee actions for the change request, the inspectors discussed with Maintenance, Construction and Facilities the planning for the " Low-Lew" reactor water level modification.
The modification planning effort and staging of materials was extensive and seemed to cover all aspects of the modification.
21.
Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss the inspection scope and findings. A summary of findings was presented to the licensee at the end of this inspection.
The licensee stated that, of the subjects discussed at the exit interview, no proprietary information was included.
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