ML20234E883
| ML20234E883 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/04/1987 |
| From: | Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20234E851 | List: |
| References | |
| 50-412-87-56, NUDOCS 8709220553 | |
| Download: ML20234E883 (19) | |
See also: IR 05000412/1987056
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V. S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No.
50-412/87-56
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Docket No.
50-412
License No.
Licensee:
Duquesne Light Company
Post Office Box 4
Shippingport, Pennsylvania 15077
Facility Name: Beaver Valley Unit 2
Inspection At: Shippingport, Pennsylvania
Inspection Conducted: July 31 - August 7, 1987
Inspectors:
L. Tripp, Section Chief, PB3, Region I (Team Leader)
J. Beall, Senior Resident Inspector, BVPS-2
P. Wen, Startup Specialist, Region I
F. Young, Senior Resident Inspector, BVPS-1
S. Pindale, Resident Inspector, BVPS-1
L. Prividy, Resident Inspector, BVPS-2
A. Asars, Resident Inspector, Haddam Neck
P. Tam, Project Manager, NRR (Part Time)
Approved by:
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LV. Trfph, Section Chief, RPS 3A, Region I
Diate'
Inspection Summary:
Inspection on July 31 - August 7,1987 (Report No.
50-412/87-56).
Areas Inspected: This special safety inspection (404 hours0.00468 days <br />0.112 hours <br />6.679894e-4 weeks <br />1.53722e-4 months <br />) reviewed on shift
activities through 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC inspector coverage of preparation for startup,
initial criticality and low power physics testing activities in preparation for
operation at full power.
Specific items reviewed included control room
activities, post-trip reviews and licensee's response to abnormal events,
operational control of maintenance / surveillance activities, independent
verification of key valves in the plant, testing and surveillance, licensee's
compliance with technical specifications, QA/QC involvement and upper
management's day-to-day involvement in plant activities.
Results:
The licensee's startup of the plant including activities to allow
achie,ement of higher operational modes, initial criticality and low power
operations were found to be systematic and well controlled.
The necessary
management structure, controls and procedures to support further power
8709220553 870916
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escalation were in place and functioning well.
Twenty-four hour coverage by
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resident and startup specialists during these evolutions identified no signi-
ficant regulatory concerns. All prerequisites and technical specification
requirements for entering higher modes were properly completed.
Inspectors
noted that all personnel assigned functions related to initial criticality
testing performed their duties in a well-controlled, professional manner.
Personnel had been properly trained and briefed and were familiar with the
procedures for testing performed during this time.
Approved procedures were
used and properly implemented throughout the approach to criticality. One
event occurred during this inspection period that was considered operationally
significant by the inspection team.
This event was manual trip of the reactor
on August 7, due to dropped control rods.
This operational event was reviewed
in Section 2.3.1 of this report.
Programmatic controls for maintenance and
surveillance testing activities for Unit 2 are the same as those for Unit 1 as
implemented through the Station Administrative and Operating Manual chapters.
This in place system was found to be well understood and well implemented by
all station personnel.
The licensee has instituted a program to reduce the
number of annunciated control room alarms.
Some problems were noted in
operational personnel making the transition to an operational plant, that is,
the inspectors noted that some operator; still had not fully discarded the
construction oriented view of the plant.
In general, continued strong licensee performance during this phase was evident
as was similarly observed during the preoperational testing program.
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TABLE OF CONTENTS
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1.0 Introduction
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1.1 Background . . . . . .
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1.2 Major Milestones During Startup & Low Power Operation. . . . ..
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1.3 Summary of NRC Inspection Activities . . . . . . . . . . . . . .
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2.0 Plant Operations
2.1 Control Room Activities
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2.2 Control Boarcs and Annunciators. ................
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2.3 Post-Trip Review & Incident Response .
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2.3.1
Manual Reactor Trip Due to Dropped Control Rods
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2.3.2
Inoffice Review of Licensee Event Reports (LERs) . . .
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2.4 Operations Control of Maintenance & Surveillance Activities. . .
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2.5 Independent Verification . . . .
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2.6 Compliance with Technical Specifications .
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3.0 Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . .
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4.0 Low Power Physics Testing (LPPT)
4.1 Program Summary. . . . . . . . . . . . . . . . . . . . . . . . .
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4.2 Test Observation . .
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4.3 Test Results Reviewed. . . . . . . . . . . . . . . . . . . . . .
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4.3.1
Initial Criticality.
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4.3.2
Reactivity Computer Checkout . . . . . . . . . . . . .
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4.3.3
Critical Boron Concentration
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4.3.4
Isothermal Temperature Coefficient (ITC) . . . . . . .
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4.3.5
Control Rod Worth Measurement.
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4.3.6
Zero Power Flux Mao. . . . . . . . . . . . . . . . . .
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4.4 Summary of LPPT Program . . . . . . . . . . . . . . . . . . . .
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5.0 QA/QC Involvement . . . . . . . . . . . . . . . . . . . . . . . . . .
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6.0 Management Involvement
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7.0 Exit Interview. . . . . . . . . . . . . . . . . . . . . . . . . . . .
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DETAILS
1.0 Introduction
1.1 Background
On the issuance of Facility Operating License NPF-64 dated May 28,
1987, Duquesne Light Company was authorized to perform low power
testing and tests requiring power operations at/or up to, but not to
exceed, 5% of the reactor core power.
Authorization to operate
beyond 5% power was still under consideration by the NRC. As a
result of the July 8,1987 Commission meeting to consider a full
power license for Beaver Valley, Unit 2, the Commission requested the
staff provide a written summary of the licensee low power operating
experience at Unit 2 before commencing actions authorizing the staff
to issue a full power operating license.
To form the basis for the
written summary required by the Commission, a team inspection of
activities at Unit 2 was performed starting approximately two days
before riticality running through power operations up to 5% power.
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This inspection consisted of round-the-clock coverage of the
licensee's final preparations for entering Mode 2, initiai
criticality, pcter operations testing and completion of prerequisites
for entering Mode 1 (more than 5% power).
Special emphasis was
placed on the areas of management involvement and their attention to
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daily plant operations, plant operations staff knowledge and their
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ability to handle off-normal events, and activities that were
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required to support the unit during this time such as surveillance,
maintenance a:.d testing.
The purpose of this inspection report is to
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document the findings of the team inspection during this period.
1.2 Major Milestones During Startup and Low Power Operation
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During the period of July 31 - August 7,1987, the significant Beaver
Valley Unit 2 Startup milestones included:
(1) completing pre-requisites for entering Mode 2;
(2) taking the reactor critical; and
(3) low power physics testing.
A chronological summary of plant preparations during this period and
significant milestones prior to this time are listed below:
Date
Time
Operational Highlight or
Milestone
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5/28/87
5:00 pm
Received a low power
license.
6/1/87
3:30 am
Completed fuel loading.
6/6/87
6:05 am
Entered Mode 5.
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7/8/87
10:00 am
Commission briefing concerning
full power license.
7/15/87
9:50 am
Plant entered Mode 4.
7/17/87
5:00 am
Plant entered Mode 3.
7/21/87
12:10 am
Pressurizer safety valves
were noted to be weeping
slightly.
7/31/87
4:00 pm
Team inspection commenced 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
shift coverage.
8/3/87
10:07 pm-
Begin deboration for criticality.
8/,4/87
6:25 am
Reactor declared critical (Mode
2).
8/4/87
10:30 am
Increase power to a point of
adding sensible heat, initiated
reactor physics testing.
8/6/87
9:50 am
Completed zero power physics
testing.
8/7/87
9:35 am
Initiated manual reactor trip
due to dropped rods in Group 2
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Bank D.
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1.3 Summary of NRC Inspection Activities
This inspection included completion of pre requisites for entering
Mode 2, initial criticality and zero power physics testing. The team
remained sensitive to adverse impact on shift supervisor safety
duties due to NRC shift inspectors questions and discussions on
matters of a programmatic nature. Accordingly, shift inspectors
referred implementation matters or status questions to the nuclear
shift supervisors and other on-shift operations personnel, and
referred programmatic questions to off-shift licensee personnel.
Non-shift team inspectors interfaced primarily with licensee support
groups and performed followup inspection for on-shift NRC inspector
concerns.
The team's observations and findings regarding initial
plant startup, criticality and low power operation testing and the
licensee's response to operational events are discussed in the report
sections that follow.
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2.0 Plant Operations
2.1 Control Room Activities
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The inspectors extensively reviewed control room activities during
the inspection period.
Particular attention was given to shift
turnovers and briefings, operator conduct, licensed and non-licensed
operator performance and knowledge of plant conditions, logs and
night orders, materials available to operators, and ongoing plant
evolutions, surveillance, and startup testing.
The inspectors noted
the following:
Shift turnovers and briefings were thorough and descriptive,
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allowing the shift change to be smooth with minimal disruption
of on going testing and plant evolutions.
In particular, the
shift change during the final approach to criticality was
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observed by the inspectors to be exceptionally informative.
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Both licensed and non-licensed operators had a good under-
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standing of plant system status and evolutions.
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The inspectors observed ongoing Operational Surveillance Tests
(OSTs) and other plant evolutions.
Control room operators were-
familiar with the procedures and steps necessary to execute
them; this included operation of various computers such as those
associated with the radiation monitors and safety parameter
display system as well as the plant computer.
Control room documentation was reviewed for adequacy of descrip-
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tions and details of events.
Control room staff logs were
accurate and contained sufficient detail of plant operations to
clearly represent plant activities.
Generally, the shift super-
visor logs contained detailed descriptions of events and ongoing
investigations, such as the troubleshooting and maintenance
efforts on the Gaseous Waste System diaphragms and leakage.
Operational Surveillance Tests (OSTs) which identified equipment
requiring maintenance work adequately described the deficiency
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encountered during test performance and the corrective actions
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taken.
Night orders were used as reminders and notification of
unusual station circumstances.
The current orders were reviewed
and found to be informative and relevant to special plant
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conditions.
Control room system status boards and prints were updated by the
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operations personnel posting equipment clearances. Generally,
these boards / prints were current.
During one shift turnover, an
operator identified that the status print incorrectly
represented the position of a pressurizer PORV block valve.
The
board was corrected immediately and it was re-emphasized to the
personnel posting clearances that the boards must be updated
promptly and accurately.
Generally, the matet !als provided to the control room operators
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were adequate.
The inspectors noted that the operators'
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materials are arranged differently than the IJnit 1 materials.
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For example, the Operating Manual Chapters have been separated
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so that the Annunciator Response Procedures (ARPs) and the OSTs
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are in individual binders rather than together in a rack as' they
are at Unit 1.
The information is stored in two small book
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cases facing the_ control boards rather than on top of the status
board cabinet as at Unit 1.
The operators explained that this
arrangement was used at the simulator and they felt it allowed
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quicker and easier access to the ARPs,. Emergency Response
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Procedures, and other information.
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The inspector reviewed the contents of selected binders and
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found that several ARPs were missing.
The licensee stated that
the missing ARPs would be provided in the future and that these
were.less important annunciators.
Further reviews of materials
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revealed that the tank curves were not marked as controlled
copies and curves were not available for the Accumulators, Steam
Generator Blowdown Tank, the' Primary Component Cooling Water
Surge. Tank and several building sumps.in safety-related
buildings such as the containment and the auxiliary building.
The licensee has elected not to provide sump curves but will
provide' curves for the other tanks mentioned.
The inspector
also noted that the laminated copies of curves, such as rod
insertion' limits and other safety system parameters, used by
operators on the main control board were not marked as
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controlled. The inspector determined that the curves in use are
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the current revision and the licensee has agreed to mark the
copies as controlled.
The resident inspectors will verify the
proper implementation of the tank curves and control of the
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various parameter curves.
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The licensee conducted a practice Emergency Preparedness and
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Planning drill on August 5, while startup testing continued.
The inspectors noted that the drill was conducted without
adverse effects on the plant.
Drill players in the control room
kept the drill activities quiet and separate from the control
room activities and did not cause any undue distractions.
Inspectors also accompanied several auxiliary operators on
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assigned building tours throughout the plant.
It was noted
through identification of inconsistencies on these tours that
personnel had not completed the transition from the construction
site to an operating plant. Operators were found to be diligent
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and knowledgeable of their assigned duties but they still
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possessed a construction-oriented view of the plant.
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operators wera very experienced having worked at Unit 1, but
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their Unit 2 experience had been as a construction site.
For a
plant under construction, ladders, unrestrained pr,.surized gas
bottles, unsecured equipment carts, open junction boxes, and
various other symptoms of work in progress are normal and
acceptabla.
The question of equipment operability with
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consideration given to unsecured material and open wiring was
discussed with operators.and plant management; they were
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responsive.to the concerns identified.
Licensee corrective
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-actions including counseling all operators and conducting area
walkdowns as well as correcting the specific deficiencies
identified by the inspectors.
2,2 Control Boards and Annunciators
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The inspectors reviewed the control boards and annunciators to assess
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system availability. Operators were questioned to determine their
knowledge of system status, abnormal plant conditions, and
annunciator. meaning.
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Operators were found to be generally aware of the reasons for each
lit annunciator and responded appropriately to alarmed conditions.
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Many annunciators appear misleading in that they alarm for a variety
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of conditions and the operator must refer to the computer status
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screens (CRTs) located adjacent to the annunciator panels to deter-
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utne which plant condition is abnormal.
Operators rely heavily on
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the CRTs for. important-plant status information.
This could lead to
difficulties should the CRTs be inoperable, which occasionally
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occurred- during control room observations. Operator performance and
dependence on the.CRTs, which are powered from a non-1E source, will
continue to be assessed as part of routine resident inspection
followup.
The inspectors noted that there were a large number of nuisance
alarms. Many were due to narrow alarm setpoint ranges or would
normally be M t during operation such as for high or low tank levels.
In the~beginning of August, 1987, the licensee initiated a program to
identify, evaluate and resolve all continuously annunciated control
room alarms. The alarms are logged on each shift, and the program is
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currently in the data collection phase.
Data collection is expected
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to be completed by approximately October 31, 1987.
Both Operations
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and Engineering personnel will be involved in the evaluation and
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resolution phases. The licensee has been requested to provide Region
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program.
The inspector also noted that many vertical board chart recorders
contained paper with incorrect scales..
All of these were adequately
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marked to indicate the correct scale.
fhe licensee has placed orders
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for paper with correct scales and will install it when it becomes
available.
2.3 Post-Trip Reviews and Incident Response
The inipector reviewed the licensee's program to evaluate and docu-
ment operational events, including post-trip reviews.
Operational
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events requiring NRC notification (per 10 CFR 50.73) are described in
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Section 2.3.2.
The licensee implements Station Administrative
Proceoure (SAP) No. 13, Preparation of Draft Incident Reports (DIRs),
Critiques and Unit Off Normal Reports (UONRs).
SAP 13 provides
programmatic guidance to resolve and document station abnormal
occurrences and is common for both Units 1 and 2.
The DIR is the
draft report of an abnorc.a1 occurrence or other reportable event as
described in plant Technical Specifications or 10 CFR.
UONRs docu-
mant abnormal conditions / events which do not meet the criteria for
submitting an incident report, yet are of such a nature that they may
be used for data collection and evaluation purposes.
DIRs are filed
for such events as reactor trips and engineered safety feature
actuations.
Post-trip reviews are documented and included as part of
the DIR.
The DIR addressing the operational event during the inspec-
tion is discussed in Section 2.3.1.
During the inspection, one DIR
and three UONRs were necessitated due to operational events and were
completed by the licensee.
The reports were reviewed by the inspec-
tor, and found to be acceptable with one exception as described
below.
On August 6,1987, as a result of improper operator switching, a 4 KV
bus was locked out or overcurrent.
The loss of the 4 KV bus caused
an auto-bus transfer (AST) of an associated 480 volt bus.
During the
trar,sient, a number of radiation monitor power failures occurred.
The radiation monitors are supplied power from the 480 volt bus. One
of the radiation monitors that was affected initiated a realignment
of the supplementary leak collection and release (SLCR) system such
that the normally unfiltered ventilation flow was redirected and sent
through the main filter banks to the elevated release path on top of
the containment building.
Operators responded in accordance with
plant procedures, and the off-normal conditions were restored within
40 minutes of the initiating event.
Inspector review of design basis
documentation found that the SLCR system is an engineered safety
feature.
During review of the associated UONR (No. 2-87-20), the
inspector determined that the August 6 ESF actuation was not reported
as required per 10 CFR 50.72.
This discrepancy was brought to
licensee management attention.
Through discussions with the plant
manager, it was subsequently determined that this event should have
been reported. Therefore, the licensee made the required ENS report
to the NRC on August 12, 1987, and the associated licensee event
report will b submitted by the licensee.
2.3.1
Manual Reactor Trip Due to Dropped Control Rods
On August 7, 1987, with the plant in Mode 2 and at approxi-
mately 2% power, a manual reactor trip was initiated when
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four control rods fell into the reactor core.
At 9:30
a.m., the r9 actor operator attempted to manually position
Bank D control rods from 39 steps when all four control
rods in Group 2 of the bank dropped into the core. At 9:35
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a.m., a manual reactor trip was initiated in accordance
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with plant procedures to realign the control rods.
The NRC
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was notified.'of the reactor trip via ENS per 10 CFR 50.72
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reporting requirements. This event was. documented by the
licensee in DIR No. 2-87-21.
Based upon similar past experience at Unit I and at other
. Westinghouse PWR plants, the licensee-suspected that the-
circuit card-associated with the firing circuit for the
. moveable gripper coils for the affected rods was the likely
source of the problem.
Since they did not have equipment
on site to. test the card, they elected to replace it. This
corrective action initially appeared to have resolved the
problem in that the licensee was able to move the affected
control rods. At the end of this inspection period, August
7, 1987, the reactor remained in Mode 3 (Hot Standby).
Although not covered by this. inspection report, the reactor
was taken critical at 4:38 a.m,, on August 10 to resume
initial.startup testing, At 4:43 a.m. on August 10, the
same four control rods fell into the core and another
manual reactor trip resulted. -The problem was subsequently
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resolved and is. detailed _in NRC Inspection report
50-412/87-54. The trip' recovery and post-trip review for
.the August 7 incident were found to be. acceptable.
Adequate management attention and licensee investigation
was evident.
2.3.2
Inoffice Review of Licensee Event Reports (LERs)
The inspector reviewed LERs submitted to the NRC to verify
that the details of the event were clearly reported,
including the accuracy of the description 'of the cause and
the adequacy of the corrective action.
The inspector
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determined whether further information was required from
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the licensee, whether generic implications were indicated
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and whether the event warranted onsite followup.
The
following LERs were reviewed:
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LER 87-01:
Reactor Trip Due to Loss of Vital Bus No. 1
LER 87-02:
Inadvertent Preoperational Safety Injection
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Actuation
LER 87-03:
Reactor Trip Due to Simulated Loss of Steam
Generator Level Signal
LER 87-04:
Operation and Violation of Technical
Specifications
LER 87-04-01:
Revision to LER 87-04.
No significant deficiencies were identified.
These LERs
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were also reviewed as discussed in Inspection Report
50-412/87-54.
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2.4 Operations Control of Maintenance and Surveillance Activities
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Programmatic controls for maintenance and surveillance testing
activities for Unit 2 are the same as those for Unit 1, as imple-
mented through the. Station's Administrative and Operating Manual
The Nuclear Shift Supervisor (NSS) is
responsible,to ensure that shift operations are conducted in
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accordance with plant procedures, Technical Specifications, SAPS., and
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Nuclear Group directives.
The NSS is also required to be
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continuously aware of the unit status of systems, equipment and
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intended operations which may affect the reactor or result in the
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release of radioactivity. The Nuclear Shift Operating Foreman
directs the operating forces in accordance with testing, maintenance
and operational requirements.
He also assures that equipment
clearances are properly executed.
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Day-to-day work activities were observed by the inspector and
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determined to have received adequate preplanning and supervisory
oversight.
Daily planning meetings provide coordination for control
of the scheduled activities and for the necessary support from the
various station groups.
The daily work activities were performed in
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accordance with station requirements with respect to taking systems
or components out of service and restoration processes. Throughout
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the inspection plant operators demonstrated a thorough knowledge of
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plant conditions, including off-normal configurations in effect as a
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result of maintenance or surveillance testing. The operators were
also found to be knowledgeable of the reason why specific plant
equipment was out of service.
In the area of control of the contral room station status prints, the
need for closer attention was apparent.
Station status prints are
plastic covered, controlled valve operating drawings provided for
operator use on plant systems.
They are to reflect correct tystem
status conditions at all times per OM Chapter 48.3.D, Administrative
Control of Valves and Equipment.
During a tour of the main steam
valve area, the inspector found that manual isolation valve No.
2SVS-23 (for the "A" steam generator atmospheric dump valve) was open
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as required per the normal system arrangement for the system.
However, the associated station status print in the control room
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showed that the valve was shut.
This discrepancy was brought to the
licensee's attention, who immediately recognized that the system
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status print was incorrect for 2SVS-23.
Operations shift personnel
knew that the valve was open per NSA requirements.
The licensee
subsequently determined that the operator who signed off the
equipment clearance, which required restoration of 2SVS-23 following
maintenance, failed to update the system status board. A second
example of the inadequate control of status prints was noted during
an inspector welkdown of selected auxiliary feedwater system valves.
The inspector found that the casing vent valve for the "B" motor
driven auxiliary feedwater pump was shut per NSA requirements.
However, the system status print showed the valve to be opened.
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licensee stated that this case also represented the failure of an
operator to adequately control / update the associated system status
print.
For the above cases of inadequate control of the system status
prints, the onshift plant operators were aware of actual valve
positions.
However, these two examples were cause for concern in
that inaccurate information could be translated from the system
status prints.
In response to the above events, the licensee
stressed the importance of maintaining accurate system status prints
to onshift personnel.
No further discrepancies were noted.
In summary, for the area of control over maintenan;e and surveillance
testing activities, the licensee demonstrated that the programmatic
controls were generally being implemented properly. NRC concerns in
this area were immediately resolved by the licensee.
No additional
discrepancies were identified in this area.
2.5 Independent Verification
As part of the validation of Unit 2 readiness for full power license,
the inspection team independently verified the position of key safety
related ECCS and AFW valves with the aid of a non licensed operator.
In addition, the in place procedures to address valve positioning and
independent verification were reviewed.
Sampling of these selected
valves found that all valves were in the correct position as required
by plant conditions.
Discussions with plant operators indicated that
operations personnel were knowledgeable of the in place system to
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assure proper alignment of these valves and the system used to inde-
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pendently varify positions of the valves.
2.6 Compliance with Technical Specifications
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Technical Specifications were used extensively by plant operators
concerning operability requirements for specific plant systems.
Through onshift observations and discussions with plant operators,
the inspectors concluded that the operators demonstrated an adequate
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working level knowledge of plant technical specifications.
The
!
licensee developed and maintained checklists to ensure that all
required prerequisites were met prior to mode changes.
The inspector
reviewed the checklists for conformance to t'-hnical specifications
and for completeness.
No deficiencies wers. [entified.
During
onshift observations, the inspectors routinely selected plant control
room components / systems to verify that limiting conditions for opera-
tion (LCO) compliance were met.
No LCO requirements were found to
have been exceeded or unrecognized by plant operations personnel. No
concerns were identified in this area.
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3.0 Maintenance
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Scheduling, controlling and performance of maintenance activities were
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reviewed to determine the effect this area had on overall operations of
the unit. A sampling of work in progress and interviews with key
maintenance personnel were performed as the basis for the assessment in
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this area.
Specific inspection points covered by the inspector and adaitional
observations are as follows:
The maintenance personnel are basically well experienced from
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previous Unit 1 activities.
The primary mechanism to authorize maintenance activities is the
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Maintenance Work Request (MWR) which is common to both Unit 1 and 2.
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Many of the implementing procedures for maintenance work (corrective
and preventive) and maintenance surveillance procedures (MSPs) are
similar for both units.
The inspector reviewed MWRs 877871 and 877884 which had been issued
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on 7/21/87 and 7/26/87, respectively, to determine set pressure for
the "A" and "B" pressurizer safety valves.
The maintenance personnel
responsible for this task were knowledgeable, organized and aware of
the overall maintenance requirements.
The inspector noted that QC
inspection reports were completed covering this work.
The inspector
was advised that a similar process will occur in the upcoming mainte-
nance outage when the "B" and "C" safety valves will be changed to
correct a safety valve leakage problem.
The inspector met with an operations coordinator concerning the
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disposition of damaged aluminum conduit containing heat trace cable
for the sodium hydroxide chemical addition tank (CAT).
The conduit
is located outside, at ground level near the CAT.
The operations
coordinator demonstrated that operations had properly assessed this
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problem and assigned proper priority in dispositioning it, although
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the damaged conduit was not resolved at the end of the inspection.
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The problem had been identified initially on June 24, 1987, and
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Nonconformance and Disposition Report 52133 had been issued to
resolve it.
Engineerbg had issued a resolution and operations was
coordinating a fix such that the conduit would be replaced and a
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nearby sample line which was the root cause of the problem would be
relocated well in advance of the onset of cold weather. Based on
discussions with maintenance and QC personnel, attendance at daily
plan-of-the-day meetings led by outage management personnel, and
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review of several maintenance work requests (MWR) and associated
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inspect. ion reports, the inspector concluded that the maintenance
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activity is being properly planned, autnorized, controlled and QC
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inspected, Also, the inspector noted that operations had a syste-
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matic approach to assign correct priorities to a maintenance task so
that both schedule and safety considerations were properly addressed.
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In summary, the inspector concluded that the maintenance activity is being
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performed satisfactorily.
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4.0 Low Power Physics Testing (LPPT)
4.1
Program Summary
The licensee's approach to criticality and low power physics testing
were performed in accordance with approved station procedures. These
procedures were reviewed previously by NRC Regional specialists and
found acceptable (see NRC Inspection Report 50-412/87-27).
The scope
of this review was to. witness and monitor the iicensee's implementa-
tion of the applicable procedure.
Specific emphasis was placed in
the following areas:
Low power physics tests conduct with respect to compliance with
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approved test procedures;
Briefings with the test crew and operations personnel prior to
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performing each test;
Test pre-requisites and initial conditions;
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Operation actions; and
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Summary analyses.
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The licensee conducted the initial approach to criticality test in
accordance with test procedure IST 2.02.02, " Initial Approach to
Criticality," Issue 2, Revision 0.
The reactor trip breakers were
closed on 7:13 pm, August 3, 1987; the licensee then commenced
control rod bank withdrawal. When the Control Bank D (CBD) reached
the position of 160 steps, RCS boron dilution was initiated.
Initial
criticality was achieved on 6:25 am, August 4, 1987.
concentration at criticality was 1351.5 ppm, with CoM..ol Bank D
(CBD) position at 157 steps; the measured boron concentration was
within the predicted range (1340 +/- 50 ppm).
After the unit reached criticality, the licensee conducted the low
power physics testing in accordance with test procedure IST 2.02.03,
" Low Power Physics Test," Issue 1, Revision 0.
NRC inspection
findings of the initial approach to criticality and LPPT evolution
are documented in the following paragraphs.
4.2 Test Observation
At various times during the inspection period, the inspectors
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witnessed portions of the LPPT in progress.
The tests witnessed
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included.
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' . initial criticality;
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reactivity computer checkout;.
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critical boron concentration measurement;
isothermal; temperature coefficient measurement;
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. control rod worth measurement; and,
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flux mapping.
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Test witnessSg, included observations of the attributes listed in
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Section 3.2 cr Inspection Report.50-412/86-20.
No unacceptable
conditions'were identified.
4.3 Test Results Review
Hot zero_ power physics test results were reviewed and compared with
' Technical Specifications and with acceptance criteria detailed in.the
test procedures. The details and findings ~of the review are
described below:
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4.3.1
Initial Criticality
Initial criticality of Unit 2.was achieved on August 4,
1987, with~ reactor coolant system. boron concentration of
1351.5 ppm and CBD position at 157 steps. This boron
concentration when corrected'to the hot zero power, all rod
out (ARO) configuration, was 1363 ppm.
The. predicted value
')
based on the same ARO configuration was 1350 ppm.
The
measured deviation from prediction was, therefore,
1363_-1350 = 13 ppm.
This result was within'the test
acceptance criteria of +/- 50 ppm.
4.3.2
Reactivity Computer Checkout
The inspector independently verified tnat the reactivity
computer was adjusted with the correct inputs of delayed
neutron fraction and decay constants and noted that the
results of the " cold" calibration checks were satisfactory.
The reactivity computer was further checked using NI-44
input when the reactor reached criticality.
Comparisons of
predicted and measured reactivities, based on doubling time
measurements, were all within test acceptance criteria of
4%.
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4.3.3
Critical Boron Concentration
The inspector reviewed test data and noted the following
results.
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Predicted Value
Measured Value
Configuration
(ppm)
(ppm)
ARO
1350 +/- 50
1367-
CBD Inserted
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1230
Difference between the
critical boron concentration
with ARO and with CBD
inserted
131 +/- 13
137
Test results met acceptance criteria.
4.3.4
Isothermal Temperature Coefficient (ITC)
The inspector reviewed test data and noted the following
ITC results.
Predicted Value
Measured Value
Configuration
(pcm/F)
(pcm/F)
ARD
-0.11 +/- 3.0
-0.03
CBD Inserted
-2.91 +/- 3.0
-2.83
The corresponding moderator temperature coefficients (MTC)
,
were determined to be as follows:
'
Measured Value
TS Limit
Configuration
(pcm/F)
(pcm/F)
ARO
+1.75
<0
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CBD Inserted
-1.05
<0
The measured MTC at ARO condition was a positive value
which exceeded the TS limit.
The licensee took correct
actions, including establishing administrative restrictions
on rod withdrawal
and boron concentration limits.
The
inspector reviewed the related calculations and verified
j
that the administrative restrictions were calculated in
accordance with BVT Procedure 2.1-2.49.3, " Operating Limits
.
to Ensare a h'egative Moderate Temperatur> Coefficient."
The calculations were technically adequate.
Through
control room tours, the inspector noted that these
administrative restrictions were being implemented by
operations personnel.
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4.3.5
Control Rod Worth Measurement
The inspector reviewed test data and noted the following
test results:
Predicted Worth
Measured Worth
Rod Bank Test Method
(pcm)
(pcm)
CBD
Dilution
1342 +/- 134
1413.5
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CBC
Rod Swap
914 +/- 137
947.7
CBB
Rod Swap
1233 +/- 185
1328.2
CBA
Rod Swap
564 +/- 100
567.4
SBB
Rod Swap
1020 +/- 153
1048.0
Rod Swap
1088 +/- 163
1099.7
TOTAL
6161 +/- 616
6404.5
The measured rod worth test results met acceptance
criteria.
The measured boron difference between the ARO and CBD
inserted configuration is 137 ppm (Section 4.3.3).
The metsured differential boron worth therefore is:
1413.5 pcm or 10.32 pcm
137
ppm
ppm
This result is within the acceptance criteria of 10.24 pcm
plus or minus 10%.
ppm
4.3.6
Zero Power Flux Map
The inspector reviewed the zero power flux map and noted
that the predicted power distribution generally agreed with
the predicted values.
The measured quadrant power tilt of
1.0051 was within the test acceptance of <1.02.
No unacceptable items were identified.
4.4 Sunimary of LPPT Program
Low Power Physics Test was accomplished in accordance with approved
procedures, data were acceptable, and test objectives were met.
Licensee performance during coproath to criticality and subsequent
LPPT was deliberate, and carefully controlled.
TS surveillance
requirements associated with the special test exceptions during LPPT
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were correctly addressed in the test procedure IST-2.02.03, " Low
Power Physics Test," and were adequately performed.
Problems
identified during the test, such as positive MTC value at the hot
zero power all-rods-out condition, were disseminated to the appro-
priate groups and corrective actions were implemented.
Overall, the licensee's startup test program continues to be
effective and acceptable.
5.0 QA/QC Involvement
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The inspector had discussions with licensee personnel in the QA surveil-
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lance, QC, testing and operations group to determine the level of QA/QC
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involvement concerning the surveillance of operational activities and to
evaluate the activities of the QA Surveillance Group. Also, the inspector
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reviewed QA documentation which describes the QA surveillance group organ-
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ization, qualification and responsibilities, including instructions on
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what type of correspondence is generated from the group.
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Based on these discussions and reviews, the inspector had the following
comments and observations.
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While the licensee is firmly committed to a QA surveillance effort of
operations / testing activities through the startup test program, it
appears that there is upper management support for this type of
effort into commercial operation. This observation is supported by
the fact that the QA surveillance group has been conducting surveil-
lance of periodic tests at Unit 1 for the past month.
,
QA surveillance group personnel have adequately covered a
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comprehensive sampling of operations / testing activities at Unit 2.
Generally, witness points have been clearly marked in the official
copy of the test procedure to alert the responsible test engineer
that QA desires to witness that particular portion of the test.
The
inspector found what was determined to be an isolated case where
witness points desired by QA were inadvertently omitted from the
official copy of the test procedure.
However, QA surveillance
personnel did witness much of this test procedure so the inadvertent
omission of the QA witness point markings was not significant.
While QA surveillance findings were properly documented in deficiency
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reports and adequately addressed and resolved by the responsible
group, the inspector found that the findings were generally
administrative comments dealing with procedure accuracy and
compliance.
The future course and focus of the QA surveillance group
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efforts appears to be limited to administrative issues and does not
include technical issues that could be potential problems at Unit 2
such as feedwater regulating valve problems, balance of plant
problems that could challenge safety systems, ventilation system
problems, etc.
Unless licensee management provides the proper
direction to attain a focus on such technical issues, use of the QA
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surveillance group or other QA effort as a management tool to
identify potential problems could be considered severely limited.
The current staff of the QA surveillance group consists of 5
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permanent Duquesne Light Company employees and 4 consultants.
Plans
are currently underway to increase the peruanent staff to 7.
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However, outside training opportunities to broaden the group's
perspective on current industry issues are somewhat limited due to
budget restraints.
In summary, the inspector concluded that the QA surveillance group is
adequately covering and witnessing the various testing at Unit 2.
Also,
the insF.etor concluded that QA personnel have primarily focused on
administrative aspects, however, the licensee should consider devoting
more attention to technical issues in its future QA surveillance efforts.
This would enable management to identify potentially serious technical or
safety problems.
6.0 Management Involvement
To assess licensee's management effectiveness in managing and controlling
plant operations, a review was conducted in the following areas:
Observation of management involvement in day-to-day activities.
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Evaluation of adequacy of control room planning and daily activities
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(including daily meetings).
The review of mechanisms used for flow of information between
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different departments into management.
Observation and evaluation activities of onsite committees, offsite
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review committee and independent safety evaluation group.
Observation and evaluation of control of activities such as
--
housekeeping, fire protection, radiation protection and security.
The inspection team found that the licensee's management and various
oversight groups such as the Onsite Safety Committee (OSC) and Joint Test
Group (JTG) maintained a detailed involvement in site activities. Good
management control and planning of daily activities were implemented by
the use of two daily meetings (8:00 am and 4:00 pm).
These meetings were
viewed as an excellent mechanism for dissemination of information to all
groups involved in the startup program.
Specific responsibilities for
each task were identified and well checked. Management's attention in all
areas such as housekeeping, radiation protection and security were
considered to be adequate during the startup program.
Basic startup
activities were slow and methodical which positively attributed to the
almost error free startup program.
There was an excellent balance of
management involvement without undue pressure to naintain schedules and
milestones,
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3
7.0 Exit Interview
The inspectors discussed the inspection scope and findings with the
licensee management at an exit interview conducted on August 7, 1987.
The
following personnel attended the exit meeting:
A. B. Bennett, System Engineer, DLC
J. O. Crockett, Senior Manager, Nuclear Operations, DLC
J. P. Godleski, TCT Engineer, DLC
K. E. Halliday, SOE, Stone and Webster Engineering Corp.
J. D. Johns, Supervisor, QA Surveillance, DLC
E. L. Martin, Compliance Engineer, DLC
,
T. F. McGourty, Principal Engineer, DLC
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T. P. Noonan, Assistant Plant Manager, DLC
M. J. O'Neill, Engineering Manager, DLC
.
D. G. Szucs, Lead Compliance Engineer, DLC
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G. R. Wargo, Assistant Director, QC
R. C. Wittschen, Licensing Engineer, Stone and Webster Engineering Corp.
T. G. Zyra, Director, T&PP, DLC
As discussed at the meeting, the inspection results are summarized in the
cover page of this inspection report.
The licensee's representative
indicated that the subjects discussed contained no proprietors
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information.
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