IR 05000293/1987026
| ML20235T611 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/13/1987 |
| From: | Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235T588 | List: |
| References | |
| 50-293-87-26, NUDOCS 8707220200 | |
| Download: ML20235T611 (26) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
l Docket / Report N /87-26 Licensee: Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station Locatlon: Plymouth, Massachusetts Dates: May 19 - June 22, 1987 Inspectors: M. McBride, Senior Resident Inspector J. Lyash, Resident Inspection T. Kim, Resi' dent Inspector L. Doerflein, Project Engineer R. Fuhrmeister, Reactor Engineer Approved By: Qbb J. AiggiYr's,'thi ef,2 R$)ctorProjects Dh![7 Oate'
is/ction 18, DRP'
Inspection Summary Areas Inspected: Routine resident inspection of plant operations, radiation protection, physical security, plant events, maintenance, surveillance, outage activities, and reports to the NR The inspection consisted of 406 hours0.0047 days <br />0.113 hours <br />6.712963e-4 weeks <br />1.54483e-4 months <br /> of direct inspection by three resident inspectors and two regional inspector ,
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Results: No violations were identified. The following observations were made i by the inspector j Problems with standards for the deportability of licensed operator physical conditions are discussed in section 2.0 (IFI 86-01-04). Control room hardware improvements are described in section 3.a. Concern about outage-related informality in the control room is also described in section . Outage planning concerns and recent outage organizational changes are i described in section I I
i 8707220200 970714 4 ADOCK 05000293
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i Inspection Summary (Continued) 2
. Problems with management control over security post orders is discussed in section . Lack of progress in the review of local leakage rate test (LLRT) failures is discussed in section . The discovery of significant corrosion in the primary containment spray header in the drywell is described in section . Licensee response to HFA relay binding problems has been well focused and .
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directed at resolution of the root cause (see section 2.0). The licensee's program for control of transient equipment in safety-related areas appears to be. weak and is described in section . Discussions in the Operations Review Committee meetings were probing and focused'on safety concerns (see section 7.0).
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TABLE OF CONTENTS Page Summary of Facility Activities ........................ I Followup on Previous Inspection Findings . . . . . . . . . . . . . . 1 Violations, Unresolved Items, Inspector Follow Items Routine Periodic Inspections .......................... 9 Control Room Observations Plant Outage and Maintenance Activities Physical Security Surveillance Testing Radiation Protection and Chemistry Review of Plant Events ................................ 17 Unexpected Secondary Containment Isolation Containment Spray Header Internal Corrosion and Spray Nozzle Blockage Inoperable Technical Specification Fire Hydrant Review of Safety Enhancement Program Safety Evaluations ........................................... 18 Storage of-Transient Equipment in Safety-Related Areas ................. ......................... ..... 20 Onsite Review Committee Meeting Observation ........... 21 Management Meetings ................................... 22 Attachment I - Persons Contacted i
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l DETAILS 1.0 1 Summary of-Facility Activities
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Th'e. plant was shutdown on. April 12, 1986 for unscheduled maintenance. On
. July 25,1986, ' Boston- Edison announced that the outage would be extended
- to-. include refueling and-completion of certain modification .0 Followup on Previous Inspection Findings Violations ,
l - (Closed) Violation . (84-39- 01), failure to initiate a Failure and Malfunc-I tion Report. No Failure and Malfunction (F&M). report was initiated -fol-l 1cwing ' discovery of a defective weld in the reactor vessel head vent lin The F&M reports, as a part of the station nonconforman.ce report processes, are designed to provide prompt notification of important plant conditions,
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l- initial internal review, and safety . assessment of events. In~~ response to the notice- of violation, the licensee committed to revise the applicable
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station. procedures to clarify the need and circumstances where F&M report should - be . ini tiated. The inspector reviewed the revised station procedure-1.3.24 " Failure and Malfunction Reports" Rev.13, dated September 19,-1986
- and the Nuclear Organization Procedure NOP83A14 "Nonconformance Report Process" dated October 18, 1986. The inspector noted however, that similar concerns were identified in the inspection reports IR 85-21 , IR 86-25 and IR 87-03. Follow up on continuing licensee efforts to resolve this problem will be conducted under the outstanding inspection item 87-03-04. Based on the above, this item is administrative 1y close (Closed) Violation (85-03-11), failure to use a current revision of a test procedure. The inspector reviewed procedure no. 1.3.8, " Document Control",
Revision 34. The licensee revised the procedure. to require the work supervisor to verify _that the latest version of the procedure was used in the performance of the activity. If a revision which affects the outcome
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of the activity is made between the start of the activity and the super-visor verification, those portions of the procedure which were changed are required to be reperforme Also, the procedure now requires that all copies of procedures and instructions used to perform and document work be stamped " Working Copy". This is also the copy verified by the superviso Copies issued for information or . training purposes are required to be stamped "For Info Only". The inspector determined that these changes should preclude the end use of out-of-date procedures. The use of current-revisions of procedures is verified by the resident inspectors on a rou--
tine basis.
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(Closed) Violation (85-06-01), failure to calibrate Local Power Range Monitor (LPRM)44-13A prior to placing it in service. In response to the violation, the licensee indicated it was an isolated case of an indivi-dual's failure to follow procedure and issued a memo to control room per-sonnel describing the incident and reminding them of the importance of adhering to procedure The inspector reviewed procedures 9.5, "LPRM Calibration", and 9.12 "LPRM Non-Linearity and Drift", and determined that the licensee's controls for removing and returning to service drifting LPRMs or LPRMs which fail to calibrate, were adequate. The inspector also reviewed procedure 2.1.15, " Daily Surveillance Log", and noted the licen-
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see verifies daily that the Average Power Range Monitors (APRM) have suf-ficient LPRM inputs and that the APRM readings agree within a specified tolerance. The inspector had no further questions on this ite (Closed) Violation (85-21-01), failure to initiate a Failure and Malfunc-tion Report. Failure and Malfunction (F&M) reports were not initiated on July 15 and July 23, 1985 when malfunction of safety related components were identified. In a licensee letter dated October 18, 1985 to the NRC, i the licensee committed to conduct a station-wide instruction on the impor-tance and need for the F&M reports. The inspector reviewed the lesson plan for the training and copies of the attendance sheets. The training covered the following areas: 1) why an F&M report is required to be in-itiated, 2) who is responsible for writing the F&M report, 3) how the form
, is filled out and 4) when an F&M report is required. The groups trained l include operations, maintenance, health ' physics, construction management, l compliance, QA/QC, modification management, and site safety and perform-I ance group. Despite the revised procedures and training on F&M reports, !
repetitive violations were identified in the inspection reports IR 86-25 j and IR 87-03 where failure to initiate a F&M report remained unresolve '
Follow up on continuing licensee efforts to resolve this problem will be conducted under the outstanding inspection item 87-03-04. Based on the above, this item is administrative 1y close (Update) Violation (85-26-05), failure to take corrective action to ensure that station personnel overtime was properly authorize This item was last updated in inspection report 50-293/86-3 ,
Instances of excessive j overtime had been identified in the areas of operations, maintenance, I security, and reactor engineering. In response to this, the licensee established a maximum sixty-hour work week in addition to compliance with the published NRC overtime guidance. While this policy appears to ag- l gressively address the overtime issue, its implementation has not been j completely effective, as described in inspection report 50-293/86-3 This item is updated to include evaluation of the effectiveness of the ];
licensee's system for tracking and controlling station wide overtime and l l
specifically in the areas mentioned above.
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(Closed) Violation (86-25-04),. failure to follow surveillance procedure The inspector noted that the licensee subsequently successfully completed both surveillance tests. The licensee reviewed all Instrument' and Control surveillance. procedurer to identify and correct similarl legibility .and reproduction problems. which contributed to, the omission of_ the second verification. In addition, a memo. was issued to operations department personnel concerning the conduct of surveillance testing to ensure that
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specified items are independently ~ verified and signed where required,'even in. cases whereithe surveillance' test is not' completed and the system is returned to the normal lineup. The inspector had n~o further questions on this item. Procedural compliance -is reviewed by the resident inspectors on a routine basi (Closed) Violation (86-25-09), failure to initiate a Failure and' Malfunc-
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' tion Report; . A-- Failure and Malfunction (F&M) report was not promptly initiated on July 2,1986, after an engineering memo outlining the defic-ient fire' barriers was sent to the station. In an attempt to resolve the programmatic : weakness involving the failure to utilize the F&M. process, training of engineering personnel on the use of F&M reports was conducted on August 4, 5, and 21-of 1986. ' Retraining of site personnel who had '
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received the engineering memo was also conducted on October 2,1986. 'An Enforcement Conference was held on August 27, 1985 (IR 85-25) in NRC :
Region I offices where licensee's programmatic weakness involving F&M report process was discussed. . Licensee management stated that the . ex-tended training of personnel on the F&M report process should resolve the problem. However, a similar concern was identified again in the inspec .
tion report IR 87-03. The inspector was informed that . the licensee' is currently- re-evaluating the adequacy and effectiveness of the entire sta-tion nonconformance report process including the F&M report. Followup on
. continuing-licensee efforts to resolve the problem will be conducted under the outstanding' inspection item 87-03-04. Based on the above, this item is administrative 1y close (Closed) Violation (86-38-01), inadvertent isolation of the fire protec-tion system due to incorrect drawing and procedure. On November 11, 1986, it was discovered that the normal station fire water supply sources to the site had been inadvertently isolated for six days due to an inaccuracy of the. controlled drawing M218, Rev 10 and in the system operating procedure 2.2.25, Rev.16. The inspector reviewed licensee corrective actions taken to date. The licensee has revised and issued Piping and Instrumentation Diagram M218 and the system operating procedure 2.2.25, Fire Water Supply System on December 9,1986 to resolve the discrepancies. The inspector also noted that the licensee revised Nuclear Operations Department pro-cedure 2.1.11, System Line-up File, on November 25, 1986 to require inde-pendent verification of fire water system line-up changes. The inspector determined that these corrective actions are in accordance with the licen-see response to the Notice of Violation, as documented in the licensee i
letter to the NRC dated January ' 9, 1987. The licensee review of other system drawings and procedures with similar characteristics to the fire water supply system is discussed in the inspector followup item 86-38-0 , - - . _ .- - _ _ - - - - - - - - - _ _ _ - - __ ___- - - - _ _ . - _ - - - _ _ _ _ - - _ - - _ - - _
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. Unresolved Items i
(Closed) Unresolved ' Item (85-13-03), a licensee special instruction ap-peared to supersede a licensee approved procedure. During a previous inspection period, the inspector _ noted that .a special . instruction dated'
June 7,.1984 appeared to supersede an approved station procedure 7.3.41-1 for' sampling and analysis of service water. The special instruction added isotopic analysis . requirements for the salt service water samples to the existing procedure which only _ required a gross activity analysis. _The licensee has revised procedure 7.3.41-1 " Salt Service Water Discharge Header Activity. Analysis" on July 17, 1985 to provide appropriate steps for the ._ isotopic' analysi_ s. The plant chemistry group leader stated.that the chemistry group discontinued the practice of using special instruc-tions in conjunction with ' approved -procedures in December of 1985, as a long term corrective action to a QA audit finding. The inspector reviewed-the adequacy of 'the revised procedure and the chemistry group's response to the. QA Deficiency Report ~ (No. 85-1453). The inspector had no further question (Closed) Unresolved Item (85-26-01), review .the applicability of overtime restrictions to reactor engineering technicians. Concerns regarding the excessive use of overtime at Pilgrim have been raised in several NRC inspection report The licensee has adopted a nuclear organization policy that no individual will exceed sixty hours per week without prior department manager approva This policy clearly indicates ' licensee management's intent to establish overtime control, and. is applicable to reactor. ' engineers. The licensee's effectiveness in implementing the established station wide overtime controls will be evaluated under exist-ing open item 85-26-05. Based on the above, this item is close (Closed) Unresolved Item (86-14-01), operation with unqualified emergency diesel . generator differential relay This item was last updated in NRC inspection _ report 50-293/86-25. At the licensee's request, General Electric performed a preliminary station blackout assessment. The assess-ment substantiated the licensee's assertion that adequate time existed for operator action to reset ' spurious relay trips and restore emergency AC power during a seismic event. The analysis concludes that. plant stability and adequate core cooling can be maintained .for at least one hour during blackout conditions. This would have been adequate time to diagnose and correct a spurious differential relay trip. The licensee has replaced the unqualified relays with a seismically qualified design, eliminating future concern in this area. The inspector had no further questions. This item is close l l
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i (Closed) Unresolved Item (86-21-05), the High Pressure Coolant Injection l-(HPCI) system flow rate test at .150 psig does not demonstrate the normal flow control system is operable. The inspector reviewed procedure n .5.4.3, "HPCI Flow Rate Test at 150 PSIG", Revision 12, and verified the licensee revised the procedure to include testing the HPCI system flow controller. The inspector noted that the procedure requires HPCI system flow and pressure data be taken with the flow controller in service and that a verification of correct system response to flow controller setpoint changes be made. The inspector determined the procedure was adequate and had no further questions on this.
i (Update) Unresolved Item (86-40-01), review Raychem splices installed by ^
GE on ECCS equipment. Following completion of maintenance in August of 1986 on the B and D residual heat removal (RHR) pumps and the B core spray (CS) pump, General Electric (GE) reterminated the pump motor leads. Dur-ing January, 1987 the motor lead Raychem splices for these three pumps were removed to facilitate ongoing 10 CFR 50, Appendix R, modification At that time it was discovered that the B and D RHR splices had been improperly installed in that adhesive was absent or improperly applied, cable insulation was damaged and some conductor strands were severed. No problems were identified with the B CS pump splices. The improper splices were applied by General Electric and reviewed by GE quality control (QC).
No licensee QC surveillance of this activity was conducted. The improper splices were removed, the cable damage evaluated and the splices were reperformed under the observation of licensee QC inspectors. Motor lead splices were also performed by GE on the A and C RHR and A core spray pumps, however different personnel were involved. In addition, licensee QC representatives were present for all splices performed on these pump Licensee management stated that based on the additional inspection applied during the activities on the A and C RHR and A CS pumps, no further inspection would be performed. The licensee indicated that the root cause for this problem had been identified and suitable corrective actions taken. However, documentation of this evaluation was not provided to the inspector by the end of the inspection period. This i am will remain open pending review of the licensee's root cause evaluatio (Update) Unresolved Item (86-40-03), evaluate the ne cause and signifi-cance of HFA relay failure This item was last sted in inspection report 50-293/87-18. Boston Edison has determir ut a significant percentage of General Electric (GE) type HFA auxilia ry raays installed in safety related applications at Pilgrim are susceptible to mechanical bind-ing of the armatur GE Service Advice Letter (SAL) 188.1 issued on November 14, 1986 indicates that HFA relays manufactured between January 1983 and October 1986 may experience mechanical binding caused by incor-rect location of a stop tab welded to the relay armature. The incorrect positioning of the stop tab combined with minor movement of the magnetic assembly when energized with AC power, can cause interference between the i tab and the relay core. This interference results in the failure of the i
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normally closed relay contacts to: close. upon relay deenergization. The test' recommended by GE in SAL 188.1 includes adjusting the relay coil and core assembly to place it .in the most mechanically disadvantageous. posi-
'. tion. The 1.icensee is testing installed relays in the as-found condition, and in accordance with the method. prescribed in the SAL. L AC relays 'manu-factured within, prior. to,- and ' after the dates referenced in SAL 188.1-have exhibited varying degrees of binding when tested. in accordance with the SAL. No relay to date has shown evidence of binding -in.the a's-found condition, i.e. , prior _to placing the armature in the test position. ' Test-
- in] of DC relays has identified similar. instances of binding with the -
-amatures in the test position. Boston Edison currently plans to . replace -
the armatures on all safety-related HFA relays which utilize the normally closed contacts during the current outage. Subsequently, the.' armatures of
'all remaining relays. installed' and in the warehouse will be. replace Representatives of the. General Electric Company are onsite and involved in testing, data ' collection. and -armature replacement. The licensee's ap-proach in addressing this issue has been cautious, thorough and appears.to'
be focused on -root cause and significance. The resident . inspectors will continue'to monitor these activitie Inspector Follow Items (Closed) Licensee Event Report (LER) Follow Item (82-LO-06), HPCI stop valve main disc flange broken capscrews. This item was last updated in '
inspection report 50-293/86-3 General Electric SIL' number 352, Steam Balance Chamber Adjustment, was issued to advise licensee of the need for careful adjustment of stop valve balance chamber pressure. Insufficient balance chamber pressure could result in failure of valve internals due to severe transients during opening. Excess pressure could result in failure of the valve to open on demand. The licensee has performed the adjustment several times using temporary procedures, however no permanent corrective or. preventive maintenance procedure was established. The licensee re-cently issued permanent station procedure 3.M.4.81, HPCI Stop Valve Balance Chamber Adjustment. This procedure will be performed after stop valve maintenance and has been added to the preventive maintenance schedule for implementation once per cycle. This item is close (Closed) Inspector Follow Item (84-18-01), two snubbers which appeared inoperable as a result of the visual inspections required functional test-ing to determine operabilit Discussions with the licensee indicated there were no functional test failures during the 1984 outage. The in-spector noted that the. adequacy of the licensee's snubber testing program was reviewed . during inspection no. 87-10. The licensee also plans to reperform the snubber surveillance requirements prior to restart. The L inspector had no further questions on the implementation of the snubber test program and considers this item closed.
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.(Closed) Inspector l Follow- Item (84-42-01), revise reactor physics test-procedures to better define a . constant. reactor. power.' level
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During NRC j
. inspection 50-293/84-42 the licensee ' committed to revise applicable reac-- 1 tor physics . test procedures to better define steady state power. level.~ -l
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r The inspector reviewed the station reactor engineering procedures .and~
verified that .the. necessary ' prerequisites ; and precautions had been adde j
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training appear to ensure. adequate control. This item:is close (Closed). Inspector Follow Item (85-11-02), review reso.lution of contractor?-
QA' problems. During 1985 inadequate contractor quality assurance measures-resulted in- several , instances of piping _ support installations not in ac-cordance with : design requirements. An audit of:the: contractor's~ quality assurance (QA) program was performed by the -licensee- QA staff' in conjunc-tion with representatives of other licensee technical: groups. This report was issued as QA Audit Report 85-33, on October 28, 1985. - The audit con- 1
clusion was that the co' ntractor QA program; implementation was generally- !
adequate. Two' deficiency reports were issued and both_. have been resolved 1 and closed. Piping supports installed on safety related systems'are per-
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.iodically evaluated under_ the licensee's -inservice inspection : progra ;
Any identified discrepancies are tracked through issuance of a licenses QC nonconformance report. A number _ of piping support discrepancies have been identified by the ISI program ~during the present outage. Resolution of these discrepancies is the subject of existing ' NRC open -item 50-293/-
86-34-06. Based on the results of. the referenced QA audit; ongoing ISI
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inspections, and existing NRC open item 50-293/86-34-06, this item is 1 close ;
(Closed) Inspector Follow Item (85-36-03),- review licensee corrective ,
actions on diesel generator governor settings, station batteries, and HPC '
steam l ea k .' During a NRC management tour on December 24, 1985, three items were identified- for resident followup. Tissue-like material was observed floating in certain cells in safety related station batterie This was determined to be . loose. plate spacer material. .NRC special_ist l inspection 87-09 also identified this condition ~ and will track evaluation of its effect on battery performance under existing open item 50-293/ l q
87-09-02. A steam leak was noted on the high pressure coolant injection '
(HPCI) system steam line drain impulse trap. Erosion of the HPCI steam -
drain piping.and frequently required steam trap maintenance have been con-
. tinuing problems. The . licensee has approved piant design change (PDC) J 86-98 ' for replacement of the HPCI and RCIC steam' traps and stcam drain piping with an improved design. This PDC is scheduled for implementation during the current outage and appears to address this issue. During the tour the settings for the emergency diesel generator Woodward governor were questione The licensee has issued procedure 3.M.4-36, Diesel Generator Maintenance - General and Preventive, for use during significant diesel maintenance. This procedure includes instructions to perform a l five minute engine run with the governor linkage disconnected after gover i nor maintenance. This should assist in venting the governor hydraulic i
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1The . procedure ~ however, does not contain the specific instructions needed to' properly fill and : vent the hydraulics and adjust the governor setting .
The licensee has recently overhauled both, diesels and performed extensive governor maintenance.. . Involved test and maintenance personnel indicated that the vendor manual and discussions ' with an experienced consultant provided the basis for set up of ' the ' govern ~or. These personnel seemed .
knowledgeable,.and the method. used; appeared consistent 'with vendor instructions The l inspector discussed with maintenance management the-observed procedure weaknes Licensee maintenance management stated that the procedure would be reviewed and necessary clarification added prior. to startup. This item is close (Closed) Inspector . Follow Item (86-01-04), review final licensee medica evaluation of an SRO. The medical condition of the subject senior reactor operator (SRO) 'was evaluated and determined to be ' less significant than
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' originally- thought. The individual was conservatively restricted from
' performance of licensed duties until completion .of this evaluation. The inspector had no further questions concerning this case. Subsequently a different SR0 developed a significant physical condition which was pro-perly reported, and an appropriate license condition issued. During the review the inspector questioned the deportability of the physical condi-tion of . a third operato This individual had been restricted f rom licensed duty due to a physically limiting disabilit The licensee Operations Manager and medical department stated that it was the licen-see's position that only conditions with the potential to affect an indi-viduals ability to make operational judgements were reportable. The inspector pointed out that 10 CFR 55.11(a)(1) also requires reporting of physical conditions which might cause impaired motor' coordination. Fur-ther American Nuclear Society (ANS) 3.4, Medical Certification and Moni-toring of Personnel Requiring Operator Licenses for Nuclear Power Plants, requires thai, an individual's physical . condition be such that he can per-form expected duties under normal and emergency situations. The inspector stressed in discussions with the plant manager and ' at the exit meeting that any condition adversely affecting this ability must be evaluate Licensee management concurred with'this position and subsequently issued a memorandum to all licensed personnel explaining the deportability require-ments. Licensee management also stated that appropriate guidance would be
' included in procedure 1.3.34, Conduct of Operations. The inspector had no
.further question (Closed) Inspector Follow Item (86-06-05), evaluate the licensee's inde-
. , pendent verification program. As documented in inspection reports No.
86-25 and 86-37, the inspector previously reviewed the licensee's program for independent verificatio Based on these reviews, the inspector determined that the licensee's program met the requirements of NUREG 0737, Item I.C.6, " Verifying Correct Performance of Operating Activities". The inspector had no further questions concerning this ite i
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(Closed) Inspector Follow Item (86-16-01), notification system for SCBA qualification expiratio During a previous inspection period, it was noted that a majority of nuclear watch operations personnel were found unable to obtain self-contained breathing apparatus (SCBA) because their SCBA qualification period had expired. On October 20, 1986 the licensee implemented an improved computerized tracking and notification system informing plant personnel of the need for a physical, respirator fit, respirator training and expiration of SCBA qualifications. The licensee provided samples of the notification letters to the inspector for revie The inspector determined that the new system appears to be an effective mechanism to notify personnel of upcoming expiration of respiratory pro-tection equipment use qualification. This item is close (Closed) Inspector Follow Item (86-38-02), review licensee evaluations on accuracy of system drawings. In response to the violation 86-38-01, the l licensee initiated an Engineering Service Request 86-531 to review the adequacy of fire protection system drawings. The licensee had extended the system drawing reviews and walkdowns to include other select systems where similar undetected discrepancies could exist. The licensee com-pleted walkdowns of the diesel fuel oil system and the salt service water system on January 12, 1987 with no noted discrepancies. This item is close .0 Routine periodic Inspections The inspectors routinely toured the facility during normal and backshift hours to assess general plant and equipment conditions, housekeeping, and adherence to fire protection, security and radiological control measure Inspections were conducted between midnight and six a.m. on May 19, May 24 and June 19 for one hour and May 20, June 2, June 4 and June 22 for two hours. In addition inspections were conducted on weekends on May 24 for one hour, May 25 for two hours, May 31 for four hours and June 21 for two hours. Ongoing work activities were monitored to verify that they were being conducted in accordance with approved administrative and technical procedures, and that proper communications with the control room staff had been established. The inspector observed valve, instrument and electrical equipment lineups in the field to ensure that they were consistent with system operability requirements and operating procedure During tours of the control room the inspectors verified proper staffing, access control and operator attentivenes Adherence to procedures and limiting conditions for operations were evaluate The inspectors exam-ined equipment lineup and operability, instrument traces and status of control room annunciators. Various control room logs and other available licensee documentation were reviewe _ _ _ . _ _ _
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The inspector observed and reviewed outage, maintenance and problem inves-tigation activities to verify compliance. uith regulations, procedures, codes and standard Involvement of QA/ AC, safety tag use, personnel qualifications, fire protection precautions, retest requirements, and deportability were assesse The inspector observed tests to verify performance in accordance with approved procedures and LC0's, collection of valid test results, removal and restoration of equipment, and deficiency review and resolutio Radiological controls were observed on a routine basis during the report-ing period. Standard industry radiological work practices, conformance to radiological control procedures and 10 CFR Part 20 requirements were ob-serve Independent surveys of radiological bounderies and random surveys of notradiological points throughout the facility were taken by the inspecto Checks' were made to determine whether security conditions met regulatory requiremer,ts, the physical security plan, and approved procedures. Those 1 checks included security staffing, protected and vital area barriers, personnel ^ identification, access control, badging, and compensatory measures when require I
' Contr,oLRoomObservations During the parlod, the inspector performed NRC Region I Temporary Instruction RI-87-01, Control Room Environmen The objective of I this instruction is to assess the work environment in the control room and its effect on conduct of duties by licensee personnel. The inspector observed control room activities on regular and backshifts, and on weekend Several previous changes and ongoing modifications )
have impacted the control room atmosphere positively. The licensee 1 established a control room annex and staffed it with several admini- f strative assistants (AA). The annex ,is used to process paperwork such as maintenance and tagout requests, minimizing administrative activities in the control roo A recently installed partition forces personnel to pass through the watch engineer's office prior to accessing the control room proper. A new elevated control room super-visnr's console has been added. This console positions the super-visor slightly above and back from the main control panels, resulting in a broader view of activities. Installation of a new process com-puter with monitors on both the unit eperator and supervisor consoles will also enhance the control room staff's ability to monitor the
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hardware, enhancing the atmospher .
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The control room staff is generally well aware of plant status and ongoing activitie Operators are knowledgeable of plant system characteristics and locations. The experience and confidence level of the operating shif ts is high. The. inspector however noted a de-gree of informality and casual attitude - during conduct of routine busines Discussions were sometimes loud and potentially distrac-ting. Nonoperating staff individuals were observed loitering in the control room adding to the background noise level. Work areas often appeared cluttered. While no evidence of distractions resulting in safety impact were identified, the substantial licensee effort to upgrade the control room material condition may not. be fully effec-tive without a corresponding upgrade in personnel habits and conduc The plant is currently in an extended outage which may contribute to the observed conditions. In the defueled condition, there are few technical specification requirements imposed on the control room staf The inspectors discussed the transition to the technical specification requirements for refueling and ultimately to the requirements for plant operations with plant management during the exit interview. The inspectors will continue to evaluate the control room environment during routine inspection b. Plant Outage and Maintenance Activity
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Outage Planning Effectiveness During the period the inspector observed numerous daily morning meetings, reviewed the status of ongoing maintenance, and held discussions with individuals involved in planning and implemen- ;
tation of maintenance activities. Until recently, development '
and implementation of the outage schedule was the responsibility of the outage management grcup (OMG).. In addition a maintenance planning. group was in place to schedule routine maintenance activitie OMG typically issued a two week rolling schedul This two week schedule provided guida=e on the short term sequencing of activities but did not ensure a long term plan or i effectiveness of a daily work plan. Maintenance planning served primarily as a maintenance request - (MR) package development service. As MR packages were compiled, they were released for work without significant inte gation into the broader outage schedule. This often resulted in uncertain daily schedules and rapidly shifting priorities at lower levels in the organization.
l Various groups within the organization did not always communi-cate effectivel This has resulted in systems being removed j from service multiple times rather than coordinated system or I
component outage These factors contribute to morale and
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productivity problems at the worker and first line supervisor levels. The licensee conducted daily morning meetings which were attended by a large number of people representing several-layers of station management. The focus of these meetings was unclea Specific topics were often reviewed in detail while
. larger outage issues and progress were only briefly discusse While these meetings were successful in promoting a sense of staff involvement they were 'not effer.tive in promoting outage progres The licensee has recently created a new outage support organiza-tion. The purpose of this organization is to develop and track implementation of a realistic outage schedule. Steps have been taken to increase the planning staff, promote communications and to closely monitor performanc The licensee has plans to develop more forward looking working schedules as well as a more stable daily work schedule. The goal of this organization is to increase productivity, morale, and complete maintenance activ-ities and problem resolution in a more timely manne The inspectors will continue to observe licensee progress in this a.rea .
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Salt Service Water Pipe Inspection and Repair Update In October 1986, Salt Service Water (SSW) piping inspection conducted by the licensee revealed delaminated and missing lin-ing and below minimum wall corrosion wastage on portions of the SSW piping in the intake structure and in the Reactor Building Auxiliary Ba The root cause analysis indicated that erosion and delamination of the pipe lining material occurred followed by aggressive galvanic attack from the corrosive salt water environment. The SSW piping corrosion was identified as a start-up issue in.the NRC management meeting report 50-293/86-41 dated December 31, 1986. The licensee has established an inspection program to evaluate the scope of the problem and to develop a repair pla Following is the list of piping inspections performed by the licensee and failures noted to date:
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UT examinations on the accessible portions of above ground piping:
1) 1 spool piece on the A loop in the auxiliary bay I
failed due to visual leakag The spool piece was l
patched, returned to service and UT monitore ) 2 spool pieces on the B loop in the auxiliary bay were UT rejected and replaced due to pipe wall thinnin _-___-______-__m
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i 13 3)' 2 spool pieces on the crosstie in the.screenhouse wer UT- rejected due to pipe wall . thinning. A complete UT.'
examination has not been completed on these - pipe ' '
4) lThe screenhouse. wall penetration spool piece on the B'
loop ~ was UT rejected due to less than minimum pipe wall thicknes Hydrostatic pressure te'sti ng o'f - the underground. piping:
$ undetermined leakage: source'of~approximately 7 gallons
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1) , . per minute was detected on the. B loop ' piping at' the test pressure of 110'psi "
2) 'No leakage detected on the- A loop ' underground piping,
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-- Visual. remote camera inspection -of the underground piping:
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- 1) a rust nodule with missing lining was noted! on .the .
elbow '(B loop) between auxiliary bay' and the screen-hous ). a rust nodule with missing . lining was 'noted on the l screenhouse wall penetration 'spoolpiece flange.-(B loop).
3)' No indications were detected on the A loop'u'ndergroun , pipin The licensee is currently in the process of excavating portions I, -of underground piping with visual camera inspection indications
- to perform UT examinations. -The data from all of the piping
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examinations will be utilized later to determine repair plans ,
and inspection criteria for further routine inspections. Other .1 corrective actions planned by the licensee include an improved j painting system for exterior surfaces and an evaluation to iden- i tify improved materials for SSW system. The ' inspector will followup on the licensee's continued piping inspections and q
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implementation of the necessary permanent repairs under existing '
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open item 50-293/86-34-01.
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Diesel Generator Control panel Rewiring and Inspection Activities The inspector observed portions of work activities associated with Maintenance Request (MR) 87-61-41, 87-61-42 and 87-61-40, t
post' maintenance testing on the A diesel generator instruments-tion performed during June 8-13, and June 15-20, 1987, to deter-mine that the work was conducted in accordance with approved
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procedure Regulatory . Guides, Technical Specifications, and applicable industry codes and standards. The post maintenance calibration testing of the A diesel generator instrumentations was performed in accordance with procedure No. 8.E.38 - Diesel Fuel Instrumentation Calibration, Revision 12, dated June 1,.
198 No discrepancies were noted.
l-l Physical Security l
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The inspector reviewed the CAS and SAS protected Command History computer printouts for April 5,1987 through June 7,1987. The i inspector noted three occasions on June 2, and June 3, 1987 L where CAS and SAS operators were on continuous duty for eight to l twelve hours. The station security procedure limits the con-tinuous duty hours for the CAS and SAS operators to three hours
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under normal conditions. The inspector discussed this concern with the licensee management and learned that an internal Security Deficiency Report (No.87-185) dated June 14, 1987 had been generated which previously identified the same concer The review of the deficiency report indicated that between May 29, 1987 and June 7,1987, several qualified CAS/SAS operators (Sergeants) have resigned. During this time period, the normal shift changes for the operators could not be carried out due to the shortage of qualified operator The licensee security group leader has informed the inspector that as an immediate corrective action, several security offi-cers were promoted to sergeant. One of these officers has al-ready completed the required CAS/SAS operator training and the others are expected to complete the training by the end of June, 198 The licensee is also rotating on-shift security super-visors (lieutenants) for'CAS/SAS duties until the newly promoted sergeants complete their qualification training. As a long term corrective action, the licensee has hired new security officers and plans to promote and train more individuals as CAS/SAS operator The inspector had no further question !
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On June 17, 1987 during a tour of the security secondary alarm station (SAS) the inspector noted that the SAS operators were not following instructions contained in the post orders. Subse-quent investigation by licensee security management identified that ' direction given to the SAS operators by the Watch Engineer (WE) contradicted the post orders. The SAS operators had imple-mented the WE instructions, however security management was not made aware of the situation. As a result SAS operators did not conduct the activities prescribed by the post orders for a i
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significant length of ~ time and did not amend- the post. order The failure- to properly implement- the orders did not constitute a safety concern because additional compensatory measures were in effec The inspector expresse'd.' concern: that. security per-sonnel were neither obeying the post orders nor. raising the con-flict to security. management ~ for resolution, In response, the licensee revised the post orders in cooperation with the . opera-
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tions department and conducted security. shift briefings stress- ing the need to follow orders or to. notify management'if this is not possible. In addition, the licensee stated that a systema-
. tic review of' all post orders is in progress and 'will be~ com-pleted; in 'early Jul .
Security management also stated that random tours and review of' standing post orders would be ' con-ducte During the. period, the inspector-reviewed the adequacy of secur-ity manning. The number of patrolmen and security supervisors L on shift was reviewed for the period of June 8 through June 19, l- 1987. The status of manning for the shift beginning 6:00 pm on June 18 and ending 6:00 am on June 19, 1987. was examined in detail. The inspector _ also reviewed the licensee's _ security plan and procedures to determine the number of security person-nel- needed for normal and abnormal operations. The 11cen'see shift manning levels were .well .in excess of security plan re-quirements for _the period examine Based on the inspector's observations, the number of security personnel '.per shift ap- ;
peared , consistent with maintaining ' the ability to respond to- '
postulated ~ security events while cc,mpensati ng for possible coincident security system hardware failures. The inspector had i no further question Surveillance Testing' l i
The licensee has experienced, in the past, recurring local leak rate ,
test (LLRT) failures for 'certain station valve NRC inspection L report 50-293/86-41 expressed concern regarding these failures. In response the licensee established a LLRT root cause analysis tea The inspector discussed the activities of the team with involved per-sonnel, and reviewed their findings. The team is composed of six technical individuals from various parts of the organizatio Due to concurrent responsibilities however, these individuals have been unable to devote sufficient time to this effort. Although the team .
was formed in September, 1986, no analysis results or recommendations
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have been issued. The inspector reviewed a draft report dated March 3,1987 which contained corrective action recommendations for four-valves. This draft however, had not been approved for issuance nor supplied to station management for possible implementation. While other methods of addressing LLRT problems are available and accept- ,
able, the LLRT root cause analysis team appears to be only marginally 1 effective due to a lack of resource commitmen _ - - - _ . - - - _ . - _ . - _ - - - - - - -
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e, Radiation Protection and Chemistry During. a routine tour .in the control room, the inspector noted that the A loop Reactor Building Closed Cooling Water (RBCCW) system radi-ation monitor was reading about.3000 counts'per second and the B loop
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RBCCW system. radiation monitor was reading about 5000 counts per ,
second. '
The alarm set points for the monitors were set at 30,000 counts ' per second.' for the first high alarm and 40,000 counts per second for the high-high alarm. The inspector discussed with the licensee. a concern regarding the sensitivity and effectiveness of these' radiation . detection and alarm system with, such high background level . and high alarm set points.; According to the station Updated Final Safety Analysis Report, the detectors are located in the system to continuously monitor radioactivity level and to alarm the control room upon detection of a high radiation level. The inspector'n'oted however, that' the station Technical Specifications does not include alarm set- points, no. surveillance requirements for the RBCCW radia-tion; monitors. The station Technical Specifications and Offsite Dose Calculation Manual do not require a gross activity analysis or an isotopic analysis on the RBCCW samples. Although the-RBCCW system is-not a plant effluent, a possibility of leakage from the system through the Salt Service Water system to the environment does exist since the . operating pressure for the RBCCW is higher than.the Salt Service Water Syste The licensee informed the inspector that the backgrotind readings on these monitors have gradually increased over the years due to a build up .of low level internal contamination in the RBCCW system sample line and a shine exposure -from the- adjacent condensate transfer ~ sys- 1 tem. ' Consequently, the alarm set points were raised to avoid fre- i quent spurious alarms. The inspector reviewed the RBCCW radiation monitor: readings recorded in the station chemistry log book and noted ;
that the monitors were reading as high as 14,000 to 18,000 counts per .
second with alarm set points at 30,000/40,000 counts per second in 1 January of 198 In August 1980, the licensee had relocated the monitors in the RBCCW system with lead shielding around the monitor ,
The background readings on the monitors aecreased to about 1000 to l 2000 counts per second. However, the alarm set points were not changed and remained at 30,000/40,000 counts per second. Since August 1980, these radiation monitor readings have gradually in-creased to the current reading of 3000 to 5000 counts per second.
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In response to the inspector's concern, the licensee initiated main-tenance request (MR 87-251) and (MR 87-428) to decontaminate the sample line around the monitors and to lower the alarm set point I The background readings on the monitors decreased to about 600 to l- 1000 counts per second following the' decontamination effort and the alarm setpoints were lowered to 5000/10,000 counts per second.
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l: , The-inspector also reviewed the results of the weekly. RBCCW and salt.
't service water discharge header activity analysis completed on May 26, 1987 and noted the. measured. activity is well below the limits spec '
ified.in the'10.CFR Part 20,' Appendix 8, Table II, Column As required by;the station Technical Specifications, the salt service water discharge. header activity analysis was performed in accordance with the station procedure 7.3.41. The RBCCW activity analysis was
. also . performed weekly as described ~ in the . station Updated- Final:
Safety Analysis Report. The . inspector noted however, the RBCCW activity analysis was being performed without an approved ' procedure and there was no technical basis for the set points. The inspector expressed concern about the lack of control over the. set points. The licensee is . currently writing an appropriate ' procedure for the analysi .0 Review of Plant Events-The inspectors followed up on events occurring during the period to. deter-mine if licensee response was thorough and effective. Independent reviews, of the' events were conducted to verify the accuracy and completeness of -
licensee informatio Unexpected Secondary Containment Isolation On June 7, 1987 at' 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, an unexpected secondary containment isolation signal was' generated during daily surveillance . testing of the refueling. area exhaust vent radiation monitors. Instrument' trip testing of the channel 'B' radiatio'n monitors had just been complete and the ~ 1ogic reset. While testing the upscale - trip on the 'A'
channel, the 'B' channel spuriously tripped ' causing the iLolation signal. All equipment responded as designed. The Standby Gas Treat-ment System fans were tagged out for maintenance and did not star The NRC Operations ' Center was notified of the actuation at 1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br />. The licensee initiated a Failure and Malfunction Report and is investigating the source of the spurious signal, Containment Spray Header Internal Corrosion and Spray Nozzle Blockage On June 10, 1987, during implementation of a planned system modifica-tion, the licensee discovered the presence of corrosion products in the primary containment spray headers and nozzles in the drywell .
Primary containment spray in the drywell consists of two independent eight inch ring headers located at different elevation The upper header spray nozzles are angled downward at approximately sixty degrees, and the lower header nozzles are aimed inward along the header radius. As part of a modification to optimize the system flow rate and spray pattern, the licensee has begun replacement of the
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existing nozzles with an improved design. Removal of all 104 nozzles from the upper header revealed buildup of a significant amount of rust flake in the nozzles, and similar material approximately one-half inch deep distributed throughout the header. Sixty-four nozzles have been removed from the lower header with similar caterial iden-tified in the heade Less significant quantities were found in the lower header spray nozzle Licensee engineering evaluations to determine system operability based on the amount and location of the material, and to identify the problem root cause, are underway. These evaluations include simulation of the containment spray nozzle con - l figuration and performance of flow tests to determine the effect of i the rus No determination of system operability had been made at I the close of this inspection perio The licensee also plans to inspect the condition of the torus spray header. A successful air flow test was last performed on the system in 198 In 1984 the j system was inadvertently pressurized with water during maintenance l activitie The resident inspectors will continue to follow the I licensee's evaluation under inspector follow it.m (87-26-01). l l Inoperable Technical Specification Fire Hydrant !
On June 11, 1987, the licensee informed the NRC via ENS that a fire hydrant required by Technical Specifications was found to be inoper-able during performance of the routine monthly surveillanc The hydrant is located outside the process building but inside the pro-tected area. The hydrant was declared inoperable when it was dis-covered that less than the required length of fire hose was instal-led. The fire protection group leader informed the inspector that all required hoses were present when this hose station was used dur-ing a drill on June 3. Based on his investigation, the fire protec-tion group leader concluded that the hose station was used by either maintenance or construction personne The licensee stated that these workers were instructed not to use hoses from the hose stations for routine jobs. The licensee had not finalized long term correc-tive action by the end of the inspection perio The inspector will follow up on the licensee's action .0 Review of Safety Enhancement Program Safety Evaluations A preliminary review of the Safety Evaluations supporting several of the licensee's Safety Enhancement Program modifications was conducted to verify these evaluations adequately address the impact of the modifica-tions on existing plant systems. A more thorough NRC review is planned prior to startup.
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Safety Evaluation No. 2133: Repl'acement of the RHR Containment Spray Caps
. The modification replaces the existing drywell' header spray caps with identical caps which have six of the. seven . spray nozzles' blanke This change is. intended to reduce the probability .of sudden depress-
. urization of' the drywell,following the initiation of drywell spra : The analyses indicate that there will be : sufficient flow to ' maintain drywell temperatures' and pressures following a small break LOCA to less.than' the design values (see FSAR, Chapter 5.2). To ensure.that-full heat removal capability is not compromised, the ' procedures will:
be changed to: require opening of the suppression pool bypass valve (2001-36A o'r B) in containment spray mode. The safetyx evaluation further states .that the- System is clean and plugging of the nozzles is not probable. This assertion will be reviewed by NRC after- eval-uation of recent spray header. rust / plugging is complete Safety Evaluation No. 2124; Modifications to' Automatic Pressurization System Logic--
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This modification adds timers to bypass the' high' drywell- press-ure contacts of the ADS logic, and.the low reactor. pressure per-
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missive for starting of Core Spray and RHR pumps. This modifi-
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cation also adds manual keylock switches . for inhibiting ADS
. initiation when called for in ' Emergency Operating Procedure These features will enable ADS actuation and low pressure CSCS initiation upon'a sustained low reactor water level, and relieve the operator of the necessity.to depress the " reset" pushbuttons every 2 minutes during' an ' emergency to inhibit ADS. Maintenance and surveillance of the timers, . as well as the procedural implementation of the inhibit switches will require further NRC review once they are complete Safety Evaluation No. 2131: Enriched Boron Modification to Standby Liquid Control System-This modification replaces the existing sodium pentaborate solu-tion using natural boron, with a sodium pentaborate solution
- utilizing 54.5% of B-10 minimum enrichment to meet the "equiva-lent control capacity" specified in 10 CFR 50.6 It also changes required concentrations, . tank level and temperature requirements, relocates a test switch, and adds a local pressure indicator near the test switches. This modification is in ac-cordance with an agreement worked out between NRR staff and representatives of the BWR Owner's Group at a meeting on April 1, 1987 in Bethesda, Md. The 'new concentration and enrichment in B-10 exceed by a substantial margin, the original system shutdown requiremen However, little or no margin to the regulator / requirements of 10 CFR 50.62 was incorporated. This concern was discussed with NRR for its review and evaluation.
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Safety Evaluation No. 2106; SEP Diesel Generator Facilities This modification provides for excavation, foundation, and grad-ing work associated with the installation of an additional on-site diesel generator and installation of the underground fuel storage tank This installation will ultimately result in the addition of another on-site electrical power source for use during station tGackout, as part of the Safety Enhancement Progra This porticular modification does not affect any systems important-to-safet Safety Evaluation No. 2118; Backup Nitrogen Supply This modification will add piping and a valve to enable connec-tion of trailer-mounted N2 supply to the containment instrument air supply header, as well as a bank of N2 cylinders to maintain system pressure until the trailer connection can be made u l This modification also provides for installation of a check valve in the N2 supply line from the existing cryogenic storage tank to permit use of an existing connection for purging the containment, while preventing backflow to the tank. This modif-ication was found to be in accordance with the guidelines of GE Service Informe. tion Letter 402, IE Bulletin 84-01 and IE Infor-mation Notice 84-1 The inspector had no further questions or observations at this tim I 6.0 Storage of Transient Equipment in Safety-Related Areas The inspector reviewed the licensee's programs for the storage of trans-ient equipment in safety-related area IE Information Notice 80-21,
" Anchorage and Support of Safety-Related Electrical Equipment", was issued on May 16, 1980. This Notice also included non-seismic ancillary items (such as gas bottles, dolleys, scaffolding, tool cribs, etc.) that could potentially dislodge, impact, and damage safety-related equipment during a seismic even The licensee response to the Notice included an October 22, 1980 letter and a February 16, 1981 Office Memorandum. These reviews only addressed seismic qualifications of the installed safety related electrical equip- ,
ment and not the transient storage of equipmen l Current licensee administrative procedures addressing the storage of transient equipment include:
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-1 PNPS 1.4 3, " Storage of Flammable and Combustible Materials"
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NEDWI-239, " Temporary Snielding Blanket Support Criteria" The inspector reviewed these documents and discussed implementation with licensee ' managemen . During routine tour of the . plant, the . inspector.-
1 verified proper implementation of these procedures. The licensee control of f gas bottles, combustible. materials, ~ and temporary lead shielding ap-pears to .txt adequate. However, the inspector noted the following trans-1ent items ' that could possibly. damage safety related equipment during a i seismic event:
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numerous mobile work carts
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temporary cooling fans for motor' winding l
L The inspector discussed this concern with the licensee. . The licensee is reviewing the existing procedures for the-possibility of expanding them to include all transient equipment in the . safety-related areas. The inspec-l
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tor will followup on the licensee's actions in a future inspection period (87-26-02).
7.0 Onsite Review Committee Meeting Observations The ' inspector . observed the conduct of the Operations Review Committee
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(ORC) meeting (Meeting No. 87-53) held on'May 29,'1987, to verify that the ORC meetings are conducted in accordance with the requirements of the station Technical Specifications ~ 6.5.A. A special meeting was convened to review proposed' plant design changes and safety evaluations related to
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the' Safety Enhancement Program (SEP). The following plant design changes (PDC) were reviewed by the committee.
l' PDC 85-43C ' Replacement of PCB-filled service capacitor units on the 23 KV offsite power supply line with a suitable non-PCB typ PDC-86-52B Installation of a piping crosstie between the fire (SEP) protection system and the residual heat removal syste PDC 86-80 A&B Installation of electrochemical potential testing equipment
for sampling and measuring hydrogen concentration in the reactor wate PDC 87-32 Installation of new and replacement fire barrier penetra-
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tion seals using upgraded seal designs.
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The inspector noted that the Committee did not approve the PDC 86-80 A&B as submitted because of concerns including operator action requirements and local leak rate testing of penetratio The~ PDC 87-32 was disapproved as submitted due to unanswered questions including designed integrity of the fire boot seals for high temperature process lines and a potential for leakage through the insulation. In summary, the inspector found the Committee's discussions were probing and focussed on safety issues. No discrepancies were note .0 Management Meetings l
At periodic intervals during the course of the inspection period, meetings ~
l were held with senior facility management to discuss the inspection scope and preliminary findings of the resident inspectors. No written material was given to the licensee that was not previously available to the public.
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l Attachment I to Inspection Report 50-293/87-26 Persons Contacted R. Bird, Senior Vice President - Nuclear K. Roberts, Station Manager D. Swanson, Nuclear Engineering Department Manager N. Brosee, Outage Manager T. Sowdon, Radiological Section Head N. Gannon, Chief Radiological Engineer J. Seery, Technical Section Head P. Mastrangelo, Chief Operating Engineer R. Sherry, Chief Maintenance Engineer C. Higgins, Security Group Leader F. Wozniak, Fire Protection Group Leader
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