ML20149H665
| ML20149H665 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/17/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20149H644 | List: |
| References | |
| 50-321-97-06, 50-321-97-6, 50-366-97-06, 50-366-97-6, NUDOCS 9707250106 | |
| Download: ML20149H665 (18) | |
See also: IR 05000321/1997006
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U.S. NUCLEAR REGULATORY COMMISSION (NRC)
REGION II
Docket Nos: 50-321 and 50-366
Report No: 50-321/97-06. 50-366/97-06
Licensee: Southern Nuclear Operating Company. Inc. (SNC)
Facility: E. I. Hatch Units 1 and 2
Location: P. O. Box 439
Baxley. Georgia 31513
Dates: June 9 through June 13. 1997
Inspectors: C. Ogle. Senior Resident Inspector (Vogtle)
M. Ernstes. Project Engineer
J. Canady. Resident Inspector (Hatch)
J. York. Reactor Inspector
Approved by: P. Skinner. Chief. Projects Branch 2
Division of Reactor Projects
Enclosure 2
9707250106 970717
PDR ADOCK 05000321
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[ EXECUTIVE SUMMARY.
Plant Hatch. Units 1 and 2'
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NRC Inspection Report 50-321/97-06. 50 366/97-06 :
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This routine announced inspection examined the lic^ensee's corrective
- action 3rogram including problem resolution, operating experience ;
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- feedbacc programs, self-assessment activities, and commitment -
identification and tracking. Conclusions included the-following:
- e All deficiency cards (DCs) reviewed by the inspectors for. a two-
week period were appropriately categorized for resolution (Section
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-07.1). ,
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i. e Event Review Teams (ERTs) effectively determined the root causes
of events. Team members were adequately trained in root cause
- analysis techniques and effectively..imalemented them' The
corrective actions recommended by the ERT were appropriate for the ,
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identified root causes. Actions were generally' completed in a <
timely manner to prevent recurrence (Section 07.2)-.
- e The licensee's disposition of NRC Information Notices was j
. generally in accordance with procedural requirements (Section
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07.3).
j e The licensee.had an informal process to evaluate events that occur
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at other of the licensee's facilities. However, some events were
not captured for review at Hatch'(Section 07.3).
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[ e The inspectors identified no discrepancies between the licensee's
- ) implementation of the corrective action program and the 4
i requirements of the Updated Final Safety Analysis Report (UFSAR) l
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b e The failure to properly implement site management's disposition of
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a Service Information Letter (SIL) was identified as a weakness
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(Section 07.4). l
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- e The failure to follow procedure for dispositioning minor findings
found in NRC inspection reports was identified as a weakness
4. (Section 07.5).
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, e Formal audits of NRC promulgated items, such as non-cited
violations, weaknesses., and negative observations, did not reflect
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historical trends (Section 07.6). ,
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l e The Safety Audit and Engineering Review (SAER) audits reviewed by
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the inspectors were appropriate and met licensee program
requirements. A negative observation regarding SAER auditor
performance was made for two readily a) parent shortcomings
identified by the inspectors, but not )y the auditor (Section
07.6).
e A violation was identified for inadequate corrective actions which
failed to prevent recurrence of imprc?erly stored material in the
control room. This issue was the ub]t a.t of a closed Audit
Finding Report Item (Section 07.6).
e The inspectors identified two examples of shortcomings in the
licensee's tracking of commitments made in response to NRC
violations (Section 07.7).
e Three self-assessments reviewed by the inspectors were well done
and reflected the willingness of the responsible departments to
identify problems (Section 07.8).
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Enclosure 2
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ReDort Details -
I. Operations
07 Quality Assurance'in Operations
07.1 Resolution of Problems
a. Insoection Scooe (40500)
The inspectors assessed the licensee's programs for identifying and '
correcting problems. Procedure 10AC-MGR-004-0S " Deficiency Control i
System." Revision 10. described the guidelines for initial disposition of
problems via review of Deficiency Cards (DCs) by the dispatcher. The
inspectors reviewed all DCs submitted during a two-week period to
evaluate the dispatchers' ability to identify and characterize problems.
b. Observations and Findinas
All individuals performing the duties of the dis)atcher had significant
experience. Most of them currently or formerly 1 eld a Senior Reactor
03erator license. DCs submitted during a two-week period and reviewed by.
tie. inspectors indicated that the dispatchers adequately assessed the
potential significance of .the deficiency. Significant DCs were forwarded
to the Shift Supervisor for review and action such as entering a limiting
condition for operation (LCO) or reporting an event. DCs which the
dispatchers had evaluated as not significant were forwarded to a
Performance Team and entered in the Action Item Tracking (AIT) system.
The AIT effectively tracked the status of the deficiencies and their
corrective actions. Most items were closed by immediate corrective
actions or by transferring the item to be tracked as a Maintenance Work
Order (MWO) or Design Change Request (DCR).
c. Conclusions
All DCs reviewed by the inspectors for a two-week period were
appropriately categorized for resolution.
07.2 Corrective Action Proarams
a. Insoection Scooe (40500)
Procedure AG-MGR-27-0687N. " Root Cause Analysis." Revision 3. described
the licensee's methods for determining the root causes of events. The
inspectors selected the following nine recent events to analyze, in
detail, the licensee's disposition of the. event for significance and root
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cause analysis:
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L e Licensee Event Report.(LER) 50-321/96-04: Inadequate Procedure
Results in Reactor Pressure Increase and Auto Reactor Shutdown,
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e Event Review Team Report 97-003: Unit 1 Emergency Core Cooling
System (ECCS) Room Cooler Control Switches Found Mispositioned on
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e LER 50-321/96-015: Failed Control Relay Results in an Automatic
Primary Containment Isolation System Actuation.
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e Two main transformer fan grounds result in trip of feedwater (FW)
- . heater drain pump and subsequent power reduction,
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surveillance testing.
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e Failure to verify Unit 1 plant service water pump discharge valve
position as required by Technical Specifications-(TS),
o Engineered Safety Features (ESF) actuation during surveillance
testing, J
e Reactor feed pump minimum' flow valve failed open and caused a 1A
reactor recirculation pump trip,
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e Notice of Unusual Event (NOUE) declaration for nitrogen release on ,
Unit 2.
The inspectors reviewed the corrective actions associated with events to '
determine their effectiveness in preventing recurrence. Completion of
selected corrective actions was verified by the inspectors.
b. Observations and Findinas 1
Plant events which were categorized as High Level Risk." were evaluated j
by an Event Review Team (ERT). ERT members had appropriate training in
root cause analysis techniques such as Management Oversight and Risk Tree
(MORT) and Kepner Tregoe. Application of these techniques resulted in a
thorough root cause analysis of the selected events. The ERT reports
contained a broad range'of contributing causes. For example, on March
23. 1997. the Unit 1 reactor automatically scrammed due to a pressure
increase following shutdown of the main turbine. Control room operators i
deduced that the Turbine Bypass Valves (TBV)s had improperly o]erated,
causing the pressure transient. Through comparison of strip clarts for
reactor pressure from this event with strip charts from previous main
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turbine shutdowns, the ERT concluded that the TBVs had operated properly ,
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and recommended procedure changes to preclude recurrence of the event.
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The licensee documented events as required,by 10 CFR 50.73. Licensee
l. Event Report (LER) system. However one minor technical inaccuracy was
identified'to the licensee for resolution. LER 50-321/96-03 reported
that there had been no previous similar events in which failure of a CR
120 relay had caused an ESF actuation in the last two years when there
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b. Observations and Findinos
Disposition of the following ins was reviewed by the inspectors:
e IN 96-24 Preconditioning of Molded - Case Circuit. Breakers
Before Surveillance Testing
e IN 96-27 Potential Clogging of High Pressure Safety Injection
Throttle Valves During Recirculation
e IN 96-67 Vulnerability of EDG to Fuel Oil / Lubricating Oil
Incompatibility
e- IN 96-68 ~ Incorrect Effective Diaphragm Area Values in Vendor
Manual Result in Potential Failure of Pneumatic
Diaphragm Actuators
e IN 97-09 Inadequate Main Steam Safety Valve Setpoints and
Performance Issues Associated with Long MSSV Inlet 1
Piping
e IN 97-12 Potential Armature Binding in General Electric Type
HGA Relays
-The inspectors reviewed the licensee's disposition of the above items.
The review included memorandum to file that documented reviews for those
ins not applicable to Plant Hatch; the tracking of action, items: IN typed
response letters: and response completion time (normally within 60 days). l
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The requirements of Procedure 10AC-MGR-005-0S were met ~for the six ins-
reviewed. The ins)ectors observed, however. that the question "Why this -
is or is not a pro)1em'at' Plant Hatch" was not clearly answered in the
response letter for IN 96-24. Further review by the inspectors indicated +
that the licensee appropriately addressed the issues identified in the IN
but-licensee actions were not' clearly documented in the IN response
letter. ,
The inspectors also observed that two ins had response letters dated
. substantially greater than the normal 60 days s)ecified in Procedure
10AC-MGR-005-0S. One response was dated 4 montas and the other.was dated
6 months after receipt of the IN. The inspectors discussed this i
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observation with the Nuclear Safety and Compliance supervisor responsible
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for the ins. The inspectors were informed that the 60 days speified in :
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the procedure was used as a guideline During refueling outages.
personnel responsible for the-IN response letters were assigned various
tasks in assisting the refueling activities. This contributed to the
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delay in developing response letters. One individual was designated to f
l review and prepare responses to the ins on a part-time basis during the
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refueling outage. However, the supervisor continued-to receive the ins
and screen them for urgency. Those ins deemed urgent were assigned to an
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l- had been a similar event reported in LER 50-366/94-09. In this instance.
l the oversight did not impact problem resolution since the corrective
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actions for the CR 120 relays were ongoing.
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The corrective actions were appropriate for the root causes identified by
the licensee's analysis. Completion of corrective actions was tracked '
using the Commitment Identification and Tracking System. Items were
generally well tracked. In one case, a commitment to analyze all Unit 2
CR 120 relays for replacement by February 28. 1997 was made in LER 50-
321/96-15. The Commitment Identification and Tracking System indicated 1
on March 25. that this had not been completed. The individual assigned
to perform the evaluation had not ]roperly completed it. However. ;
another individual had completed t1e analysis in preparation for the Unit ;
2 cutaga. In effect., the commitment had been met, however. the i
commitment tracking system did not reflect that it had been completed.
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Inspectors verified, through direct inspection, the completion of
corrective actions such as procedure revisions, and posting of warning
signs. Corrective actions were generally completed in a timely manner to
prevent recurrence of events. However age-related failures of the
General Electric (GE) CR 120 relays and spurious actuations of Root Mean
Square RMS-9 trip devices occurred over extended periods. Corrective
actions, now in place, appear to be sufficient to prevent future
problems,
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c. Conclusions
Event Review Teams effectively determined the root causes of events.
Team members were adequately trained in root cause analysis technicues
and effectively implemented them. The corrective actions recommenced by
the ERT were appropriate for the identified root causes. Actions were
generally completed in a timely manner to prevent recurrence.
07.3 Review of Ooeratina Exoerience Feedback. Information Notices and Other
Facility Licensee Events
a. Insoection Scooe (40500)
The inspectors reviewed six NRC Information Notices (ins) and verified
their disposition in accordance with Procedure 10AC-MGR-005-0S.
" Operating Experience Program and Corrective Action Program." Revision
10. Selected events at the licensee's other nuclear facilities (Farley
and Vogtle) were reviewed in accordance with NRC Inspection Manual 40500.
" Effectiveness of Licensee Controls in Identifying. Resolving, and
Preventing Problems." Additionally, the inspectors reviewed the Updated
Final Safety Analysis Reports (UFSARs) for Units 1 and 2 associated with
the licensee's corrective action program.
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individual for' a timely review. ins that were not urgent-are deferred
- until after the outage. The inspectors were informed that this was the
case for these'two ins.
NRC Inspection Procedure.40500 states that~ an effective corrective action !
program will ensure that corrective actions applicable at more than one
>of the licensee's facilities'is considered at all of the licensee's >
facilities. (This is not a regulatory requirement.) Vogtle and Farley
fall within the purview of this guideline. The inspectors provided the '
licensee. prior to the start of the corrective action ins)ection, three ;
events that occurred at Vogtle. .The following are the LER number and
title associated with the Vogtle events: ;
e 50-424/96-10-00 . Safety Injection _ Pump Rendered Inoperable Due to
lack of Motor Cooling
e 50-424/97-01-00 Thermal Overload Byp n Jumper Connection
Renders ECCS Valve inoperable
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e 50-424/97-03-00 Unlatched Doors on Motor Control Centers Changes
Seismic Qualifications l
The licensee was aware of these events and provided information that I
indicated that at Hatch training had been conducted; procedural
enhancements had been made: and a policy letter from management had been
issued as a result of~these events.
Seven events / issues that occurred at Farley were prov_ided to the licensee
subsequent to the start of the inspection. The licensee did not have any
information associated with these events. -The licensee informed the
inspectors that there was no formal program to address events that
occurred'at Plants Vogtle and Farley. Through an informal process, the i
licensee stated that some of.the events at Vogtle and Farley were >
captured and addressed but not all events.
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The inspectors requested the licensee provide documentation for other
events / issues that occurred at Farley for which Plant Hatch had taken
some action. The licensee provided the-inspectors with information
regarding four event:. Three of them were addressed in a response to an 1
IN and one was a response to a third party document promulgated to the
. industry. The inspectors reviewed the documentation associated with
these events. The licme's responses appropriately addressed the ;
issues for Hatch.
The inspectors
and section reviewed
17.2.16 of th A!pendix D, section
Unit 2 UFSAR. D.5.5.11
These sections of ofthethe Unit 1 UFSAR
addressed the licensee's corrective action program. The inspectors i
identified no discr 2pancies between the licensee's implementation of 'he
corrective action program and the information contained in the applicable
sections of the UFSARs.
Enclosure 2
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c. Conclusions
The licensee's disposition of ins was generally in accordance with the
procedural requirements of Procedure 10AC-MGR-005-0S. The licensee had
an informal process to evaluate events that occurred at other of the
licensee's facilities. However, some events were not captured for review
at Hatch. The inspectors identified no discrepancies between the
licensee's implementation of the corrective action program and the
requirements of the FSAR.
07.4 Doeratina Exoerience Feedback. Discosition of GE Service Information
Letters (SIls)
a. Insoection Scone (40500)
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General Electric (GE) Services Information Letters (SILs) are issued as a l
service to GE Boiling Water Reactors (BWR) owners. The inspectors )
reviewed the licensee's resolution and disposition of four SIls to i
determine if the corrective actions appeared to be proper and to l
determine if the disposition had been accomplished. !
b. Observations and Findinas
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The purpote of the SILs is to promote plant performance improvements and i
alert owners to actual or potential occurrences which can degrade plant
performance. The inspectors reviewed the following SILs:
- SIL No.196. Supplement 17- This letter involved two potential
problems with Target Rock Safety Relief Valves (SRV). one was main
disc spring relaxation and another was tip breakage on the spring:
- SIL No. 590- This letter involved two potential problems, one with
fasteners coming loose and potentially releasing the top cover on
a NUMAC instrument and fabrication dimension problems with square
receptors; and
e SIL No. 601- This letter involved the potential for loose
connections at some of the Reactor Protection System (RPS)
terminals if the wrong size wiring was used. The correct wiring
was used at Hatch and this SIL was dispositioned with a memorandum
to file.
Enclosure 2
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The inspectors evaluated the licensee's initial screening
-(applicable /non-applicable): validated the non-applicable SILs: verified
the response times, and evaluated corrective action items for the three
-previous SILs listed above. No problems were identified. A problem was
identified for the following SIL:
e SIL No. 602- This -letter involved Traversing Incore Probe (TIP)
ballsvalve roll-pin cracking. Roll-pin cracking was noted in 50
percent of the valves at another site including some of the valves
in stock. The cracking was longitudinal i.e., parallel to the
axis of the pin. The alloy 420 martensitic stainless steel pin
was installed into the valve stem using an interference fit
thereby creating residual stresses in the pin. These stresses-
were considered the likely cause for the intergranular stress
corrosion cracking (IGSCC). Also, contributing was the fact that
an improper heat treatment for the pin made the pin susceptible to
the IGSCC. The inspectors independently verified that this was a
feasible root cause by reviewing appropriate technical information
(Metals Handbook. Volume 4. Heat Treating. Section on Heat
Treating of Stainless-Steel and Heat Resisting Alloys: and Volume
4. Corrosion. Section on Corrosion of Stainless Steels). No
failure to function had been reported for these valves at the time
of the SIL.
-The licensee's decision was to replace all of the pins (only four.
containment isolation valves involved) with new pins supplied by the ;
vendor. These replacement pins were in the properly heat treated
condition, which would not make the pins susceptible to 10 SCC. The SIL q
only recommended that the pins be inspected and if any were found to be !
cracked then to replace only those pins. During a review of the work i
done on maintenance work order (MWO) No. 29602291-01 during the most
recent-Unit 2 outage (mid March through April 1997) the inspectors and
the licensee noted that the work performed on the four valves was a
partial disassembly, visual inspection of the pins, and then reassembly.
The pins.were not replaced because they were not cracked. This failure
to properly carry out the SIL disposition recommended by site management !
(replace all pins whether cracked or not) is identified as a weakness.
c. Conclusions
tiost of the SIls were properly dispositioned, but one SIL (No. 602) had a
disposition that was not properly implemented during a recent outage on
Unit 2. This failure to properly carry out the site's management
disposition for the SIL is identified as a weakness.
Enclosure 2
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07.5 Doeratina Exoerience Feedback. Review of Disoosition of Minor NRC
Findinas
a. Insoection Scooe (40500)
The inspectors reviewed the licensee's disposition of five minor,
unnumbered NRC findings noted in Inspection Reports. These findings were
not violations, deviations, unresolved items, or inspector follow up
items, i.e. did not have an NRC report number designation.
b. Observations and Findinas
The inspectors reviewed the licensee's disposition of the following items
from recent NRC Inspection Reports (irs):
e Negative observation IR 97-01 (Pl.1) - Emergency Preparedness (EP)
drill performance where Health Physics (HP) and other support
personnel were not notified to respond, the staff was short 3 HP
personnel. This item was still being resolved through the use of
the Deficiency Card (DC) system.
e Negative observation IR 96-11 (02.1) - Special Report required by
TS. Some required sections of the report were not clear. This
item was dispositioned through a Significance Occurrence Report
(SOR).
e Negative observation IR 96-11 (R4.1) - Poor sampling techniques
demonstrated by chemistry technicians. This item was
dispositioned through the use of a DC.
e Weaknesses IR 97-02 (M1.7) - Inspection personnel climbing on
]iping and poor MT inspection techniques. These items had not
Jeen addressed in any manner. The licensee stated that they did
not agree with the inspection findings. The licensee agreed that
these items should have been addressed in the manner discussed in
the following paragraph.
The inspectors reviewed the procedure for handling unnumbered findings.
such as weaknesses and negative observations, that appear in NRC reports.
Procedure 10AC-MGR-005-05, Step 8.7.1.12 stated, "For other NRC items NOT
discussed in the preceding steps ...(items discussed previously were
violations, deviations, unresolved items, and inspector followup
items). . the following actions will be taken: Step 8.7.1.12.1 Nuclear
Safety and Compliance (NSC) will forward applicable portions of the NRC
inspection report to the responsible department. . Step 8.7.1.12.2 The
responsible de)artment will take action as necessary to resolve the
concern and su)mit a response to NSC... ." When asked to provide the
correspondence / documentation for accompl'shing this part of the
procedure, the licensee realized that Wey were not implementing this
part of the procedural requirements.
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c. Conclusions
Review of unnumbered inspection findings from several NRC inspection
reports revealed that the licensee was not following their procedural
requirements for addressing these inspection findings. Given that there
is no regulatory basis far requiring licensee's to respond to unnumbered
inspection report item. this will not be cited as a violation. However,
it is identified as a weakness.
07.6 Self-Assessment Activities
a. Insoection Scone (40500)
The inspectors reviewed onsite audits performed by the Safety Assessment
and Engineering Review (SAER) Group in the corrective action area. The
following audits were reviewed:
e 97-CA-1 Corrective Action Program May 23, 1997
e 96-CA-2 Corrective Action Program October 18, 1996
e 96-CA-1 Corrective Action Program April 9, 1996
e 95-CA-3 Corrective Action Program December 27, 1995
Additionally, the inspectors interviewed SAER personnel concerning the
conduct of audits.
b. Observations and Findinas
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The inspectors verified that these four audits met UFSAR requirements.
Further, each audit contained the elements specified in the SAER Audit
Planning Matrix, Schedule, and Status Report provided by the licensee.
The inspectors noted that in accomplishing Audit Item Number 1, NRC
Inspection Reports, for Audits 97-CA-1, 96-CA-2, and 96-CA-1, the SAER
auditor reviewed the licensee's dis]osition of five violations and 1 non-
( cited violation. However, during t1e 1996-1997 time frame which l
encompassed these audits, approximately twenty-eight violations and
l fourteen non-cited violations (NCVs)were identified. The inspectors
l expressed concern to the licensee regarding the small number of NCVs
- audited in these last three audits. The basis of this concern was that l
l NCVs typically receive less formal NRC followup and closeout of the I
i corrective actions than violations. Hence, more review of NCVs by the
j licensee may be warranted. j
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Additionally, the inspector.s noted that in the last four SAER audits, no !
review had been performed of unnumbered NRC inspection report items such j
as weaknesses and negative observations. Procedure 10AC-MGR-005-0S l
contained actions to be taken for such items. This process had not been
reviewed in the audits performed by SAER examined by the inspectors. j
While there is no regulatory recuirement for a SAER review of this i
process, the inspectors did finc problems in the area as outlined in '
Er. closure 2
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L Section 07.5 of this report. Given the nature of these shortcomings, it
was reasonable to assume that these errors would have been detected if
audited. .The failure of SAER to audit the actions required of Procedure 1
10AC-MGR-005-0S for unnumbered NRC inspection report requirements was
identified as a negative observation.
The inspectors reviewed audits 97-CA-1 and-96-CA-2. This-included a
selected verification of licensee corrective actions. identified as having
been. reviewed by the auditor. In general, the inspectors observed that
the~ audits were logical, covered a wide range of issues, and for the most
part appeared to be probing. .Two Audit ~ Finding Reports (AFRs) were
identi fied which indicated that the auditor was willing to identify -
issues. However, several deficiencies were identified by the inspectors. 4
First. Audit 96-CA-2. Item 6. presented the auditor's review of Licensee I
Event Report (LER) 50-321/96-003. Component Failure Results in Unplanned
Engineered Safety Feature System Actuation. The audit item stated that
there were no previous similar events reported in the last two years in
which an unplanned Engineered Safety Feature system actuation occurred
due to a failed relay coil: that this event was considered an isolated i
failure. However, a similar occurrence within the previous two years was
documented in LER 50-366/94-09. Furthermore, similar relay failures were
the subject of licensee event reports for several years. This was
considered a lack of attention to detail on the part of the auditor.
The second deficiency involved Item Number 1 in the same audit. This
item presented the auditor's review of the licensee's response to
Violation 50-321/96-06-04 During their independent review of this item.
the inspectors determined that the procedure revision identified in the
licensee's response to the violation had not been. entered into the
licensee's Commitments Identification and Tracking System. However, j
under Audit Technique for this item, the auditor included " Verify that '
commitments are in the Cunmitment Identification and Tracking System."
When questioned on this point, both the auditor and his manager
acknowledged that this had indeed not been verified by the auditor.
Further, they also indicated that the results section for the same item
did not state that this attribute had been verified by the auditor. The ;
inspectors noted that presenting audit techniques which have not been
performed in the final audit plan and checklist was not clear and could
confuse the reader.
Additional followup in the area of commitment tracking was performed by !
the inspectors and is documented in Section 07.7.
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Finally, a control room walkdown of AFR 96-SA-8/28. " Unsecured items were
found in areas where safety related equipment is located. These items
may present a safety or reliability hazard during a seismic event." was
performed. This AFR documented unsr 1 red equipment stored in plant areas
adjacent to safety related, seismic Category I equipment. Six control ,
room areas identified in the AFR as having unsecured stored equipment !
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were examined by the inspectors. The inspectors noted that many of the ;
same item documented in the AFR were still stored immediately adjacent to
control room cabinets.
The licensee informed.the inspectors that many of the items h'ad been <
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previously analyzed in their observed storage locations. Information-to
support this position was provided by the licensee. _However, the
. licensee informed the inspectors that approximately seven 1tems
identified required remedial actions to prevent potential seismic
- interactions with safety related equipment.
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The inspectors noted.from their review that this AFR. including the
planned corrective actions, had been closed by the plant and SAER in
October and November 1996, respectively. However, these corrective
actions failed to preclude repetition of this condition. During a
review of this issue with the licensee, the SAER manager noted that this
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AFR had been closed by SAER aiproximately seven months before the
,
inspector's observation and t1at a control' room walkdown had not been
l performed as part of SAER's closecut of this issue.
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Several SAER personnel were interviewed regarding audits and their . ;
performance. They all described a willingness to identify issues free i
- from undue pressure.
c. Conclusions !
o
The SAER audits reviewed by the inspectors -were appropriate and met
licensee program requirements. A negative observation regarding SAER i
i auditor performance was made.for two readily identified shortcomings
identified by the inspectors, but' not by:the auditor. Additionally the
inspectors concluded that formal audits of NRC promulgated items, such as
non-cited violations, weaknesses'. and negative observations, did not
'
reflect historical trends.
-The failure to prevent recurrene of improperly stored material which had
- the potential to impact the seismic performance of equipment in the
control room was contrary to the requirements of 10 CFR 50. Appendix B.
'~
Criterion XVI. Corrective Actions. This was identified as Violation 50-
321, 366/97-06-01. Failure To Prevent Recurrence Of Improper Equipment ;
Storage In Control Room.
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07;7 Commitment Identification and Trackina System
l a Scooe-(40500)
!
The inspectors verified that licensee commitment control met the
requirements of Procedure 00AC-REG-002-05, " Commitment -Identification and
l Tracking System " Revision 2. The inspectors reviewed the licensee's
- handling of commitments made in licensee responses to violations 50-
321/96-06-04: 50-321, 366/96-04-02 (Example 2): 50-321, 366/97-01-01
(Example 1); and AFR 96-SA-8/28.
'b. Observation and Findinas
In each case, the inspectors. observed that the appropriate licensee
. procedure had been changed to reflect the commitments made in response to
the items listed above. However, the inspectors noted that for
violations 50-321/96-06-04 and 50-321, 366/97-01-01 (Example 1), the
appropriate commitments had not been entered into the licensee's
Commitment Identification and Tracking System.
Procedure 00AC-REG-002-0S requires that long-term commitments be entered
into the Commitment Identification and Tracking System. The same
procedure identifies a procedure change made in response to a violation
as a long-term commitment. When questioned on these apparent
discrepancies, the licensee indicated that the failure to enter the
procedure change made in response to violation 50-321, 366/97-01-01
(Example'1) into the Commitment Identification and Tracking system was an
oversight. However, the licensee indicated that the procedure change
made in response to violation 50-321/96-06-04 was intentionally not
entered into the system. As described by the licensee, this decision was
based on the licensee's belief that this procedure change represented an
enhancement to the procedure and du)licated an existing procedural-
requirement which was captured by t1e system.
Subsequent to inspector questions, these items were entered into the
Commitment Identification and Tracking System. The licensee indicated
that they were also considering a review of other violation responses to
ensure commitments were appropriately documented. t
c. Conclusions
The inspectors identified two examples of shortcomings in the licensee's
tracking of commitments made in response to NRC violations. These
shortcomings did not' impact implementation of the appropriate
commitments
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Enclosure 2
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Ac the exit. the inspectors acknowledged that there is no regulatory I
ME M for a commitment tracking system. However, the licensee's
procedure, as reviewed by the. inspectors, did not provide the flexibility
l. to not enter procedure changes made in response to violations into their '
I commitment identification and tracking system.
07 8 Deoartmental Self-Assessments
a Insoection Scope (40500)
l
The . inspectors reviewed the following licensee self-assessments.
e Contamination Control and Personal Contamination Reports (PCR).
Self-Assessment (dated July 16, 1996)
e Radioactive Material Control Assessment (dated November 15, 1996)
e Self-Assessment of E.I. Hatch Operations Department (September
l 1996)
!
! b. Observations and Findinas
! .Each of the self-assessments contained a broad range of observations,
included strengths and weakness, and identified potential corrective
actions. The -inspectors noted many of the weaknesses identified
reflected a critical review of licensee performance,
c. Conclusions
- The' three self-assessments listed above were well done and reflected the
l willingness of these departments to ident.ify problems.
l
V. Manaaement Meetinas Other Areas
X.2 Review of UFSAR Commitments
A recent discovery of a licensee o)erating its facility in a manner
, . contrary to the UFSAR description lighlighted the need for a special
focused review that compares plant practices, procedures and/or i
parameters to the UFSAR description. While performing the inspections
discussed in this report, the inspectors 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.
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'X.4 Exit Meeting Summary
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The inspectors presented the inspection results to members of the 'l
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. licensee management at the conclusion of the inspection on June 13. 1997. l
.The license acknowledged the findings presented. Some of the !
departmental-self-assessments discussed in Section 07.8 were 3roprietary '
and returned to the licensee at the end of the inspection. W1en l
questioned.. no other material was identified by the licensee as.
'. proprieta ry.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
!
, Anderson, J.D. . Unit Superintendent
l ' Davis D., Plant Administration Manager
l Fraser, 0.M., Safety Audit and Engineering Review Supervisor
Metzler. E.T. Nuclear Safety and Compliance Supervisor
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Moore, C T.. Assistant General Manager - Plant Support
Roberts, P.A., Outages and Planning Manager
Tipps..S.B., Nuclear Safety and Compliance Manager
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INSPECTION PROCEDURES USED
,
IP 40500: Effectiveness of Licensee Controls in Identifying Resolving, and
,
! Preventing Problems i
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ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
~50-321, 361/97-06-01 VIO Failure to prevent recurrence of improper-
equipment storage in control room
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