ML20236N028
| ML20236N028 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/09/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236N019 | List: |
| References | |
| 50-440-98-10, NUDOCS 9807140367 | |
| Download: ML20236N028 (21) | |
See also: IR 05000440/1998010
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U. S. NUCLEAR REGULATORY COMMISSION
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REGIONlli
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Docket No:
50-440
License No:
Report No.
50-440/98010(DRP)
Licensee:
Centerior Service Company
P.O. Box 97, #200
Perry, Ohio 44081
Facility:
Perry Nuclear Power Plant
Location:
Perry, Ohio
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Dates:
April 21 through June 4,1998
inspectors:
C. Lipa, Senior Resident inspector
J. Clark, Resident inspector
Approved by:
Thomas J. Kozak, Chief
Reactor Projects Branch 4
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9907140367 980709
ADOCK 05000440
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EXECUTIVE SUMMARY
Peny Nuclear Power Plant
NRC Inspection Report 50-440/98010(DRP)
This inspection report included resident inspectors' evaluation of aspects of licensee operations,
engineering, maintenance, and plant support. The report covers a 6-week period of resident
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inspection.
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Operations
Two operator errors occurred, which were primarily due to inadequate attention-to-detail
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during the performance of routine tasks. Both of the errors also represented a failure to
follow a procedure. The inspectors concluded that the failure of operators to
appropriately follow procedures on two occasions led to two personnel errors involving
the removal of an incorrect fuse and installation of an incorrect light bulb. A third operator
enor is discussed in Section M1.2. (Sections 01.2 and 01.3)
The inspectors identified four examples of deficiencies that indicate inconsistent operator
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attentiveness and awareness of control room panels. The inspectors continue to be
concemed about the varying level of attention to detail and questioning attitude exhibited
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Maintenance and Surveillance
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The inspectors identified a procedure adherence concern with the performance of a
surveillance test which resulted in a violation. The inspectors were also concemed that
operations supervision failed to identify an omitted step during review of the data
package. (Section M1.2)
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' The inspectors noted an increase in the number of emergent equipment issues over
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recent inspection periods. Some items resulted in distractions to operators or entry into
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Limiting Conditions for Operation. In each case, the licensee resolved the issue promptly.
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(Section M2.1)
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The inspectors identified a procedure adherence violation involving the improper control
of transient combustibles during maintenance activities. The inspectors were also
concemed that supewisory and fire protection personnel did not display adequate
attention to detail in reviewing the administrative control of the transient combustibles.
(Section M2.2)
The inspectors identified three procedure adherence violations of minor significance
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associated with housekeeping and equipment control activities. (Section M2.3)
Enaineerino
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The licensee demonstrated a good questioning attitude in the identification of inadequate
logic testing of radiation monitors. The relay contacts were promptly satisfactorily tested.
(Section E1.1)
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Plant S!Jpport
The inspectors were concemed that access control procedures were not uniformly
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followed by station and contract personnel. This procedure adherence concem is
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concurrent with procedure adherence concems seen in other departments throughout this
inspection period. (Section S1.1)
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Report Details
Summary of Plant Status
The plant began this inspection period at 100 percent power and remained at that power level for
most of the inspection period except for a short duration power change to support a control rod
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pattem change.
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l. Operations
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01
Conduct of Operations
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01.1 General Comments
a.
Inspection Scope (71707)
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The inspectors followed the guidance of Inspection Procedure 71707 and conducted
frequent reviews of plant operations. This included observing routine control room
activities, reviewing operator logs and system tagouts, attending shift tumovers and crew
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briefings, and performing panel walkdowns.
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b.
Observations and Findinas
The conduct of operations was professional The inspectors observed thorough shift
tumovers and good communications. Overall, emergent equipment issues were promptly
addressed and the conduct of operations was appropriately focussed on safety.
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Concems with operator errors during the performance of routine activities and with
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operator attentiveness to control room panels are discussed in Sections 01.2, O1.3, and
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01.4, respectively.
01.2 Operator Error While Removina a Fuse
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Inspection Scope (71707)
a.
The inspectors reviewed the circumstances surrounding an operator error during a tagout
activity. This review included Condition Report (CR) 98-1057, Work Order 97-3521,
Tagout No. 30442, and Plant Administrative Procedure (PAP) -1401, " Safety Tagging."
b.
Observations and Findinas
On May 6,1998, a licensed operator opened the knife switch for the wrong fuse while
. hanging a tagout on the combustible gas control system. Tagout No. 30442 specified
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which fusa to remove and listed the corresponding wire markings. The operator
incorrectly selected the adjacent fuse, which had a similar wire marking that differed by
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only one character. There was no effect on the plant as a result of this error. The
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condition was corrected and the correct fuse was subsequently removed.
Based on interviews and information provided in the CR, it appeared that the licensed
operator compared the wire markings on the tagout sheet to the markings in the panel
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. while another licensed operator provided dual concurrent verification. Additionally, a Unit
Supervisor (US) provided oversight for this activity. However, this additional review did
not prevent the error.
The inspectors were concemed' that this tagout error was similar to errors in
February 1998 and August 1997 (documented in Inspection Reports 50-440/98007 and
50-440/97012, respectively). The use of dual concurrent verification and US oversight
was an improvement from the' processes in place when the tagout errors occurred in
1997. However, the additional verification as implerrented failed to prevent this error.
The failure to remove the correct fuse while hanging Tagout No. 30442 was a violation for
failure to follow PAP-1401 as required by Technical SpecificaSon (TS) 5.4.1. Although
licensee-identified, this was not a non-repetitive violation and is, therefore, being cited as
a violation of TS 5.4.1.a. (VIO 50 440/fr8010-01(DRP))
01.3 Operator Error While Replacina a Control Panel Liaht Bulb
a.
Inspection Scope (71707)
On April 25,1998, a licensed operator replaced a control panel light bulb with a different
type than the prescribed light bulb. This caused a fuse to blow and loss of power to
residual heat removal (RHR) system trains "B" and "C." The inspectors reviewed the
circumstances of the event and the licensee's corrective actions.
b.
Observations and Findinas
A licensed operator inadvertently replaced a light bulb with the wrong type. This caused
- a blown fuse in the RHR "B" and "C" control logic. The licensee's investigation
determined that the operator failed to follow the requirements of PAP-0201 and verify that
the replacement bu!b was the same size and type as the one removed. The following
corrective actions were performed:-(1) the correct bulb was installed, the fuse was
replaced, and the circuitry was checked for any potential damage, (2) a Category 3
investigation of Potential Issue Form (PlF) 98-0802 was completed, and (3) a lessons
leamed review was prepared and shared with other operations department personnel.
This non-repetitive, licensee-identified and corrected violation is being treated as a Non-
Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Pclicy.
. 01.4 - Conclusions on Conduct of Operations
Two operator errors occurred, which were primarily due to inadequate attention-to-detail
during the performance of routine tasks. - Both of the errors also represented a failure to
follow a procedure. The inspectors concluded that the failure of operators to
appropriately follow procedures on two occasions led to two personnel errors involving
the removal of an incorrect fuse and installation of an incorrect light bulb.
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02
Operational Status of Facilities and Equipment
O2.1 General Plant Tours and System Walkdowns (71707)
The inspectors followed the guidance of Inspection Procedure 71707 in walking down
accessible portions of several systems and plant areas, including:
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Control complex ventilation systems
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Emergency batteries
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Emergency service water pump house
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Auxiliary building
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Intermediate building
Equipment operability was acceptable in all cases. Concems with materials being
improperly stored or staged to support maintenance activities are discussed in
Sections M2.2 and M2.3. Several minor discrepancies, such as loose or missing labels
on safety-related circuit breakers, were brought to the licensee's attention and were
corrected.
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Operator Knowledge and Performance
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04.1 Concems With Operator Attentiveness and Awareness of Control Room Panels
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a.
Inspection Scope (71707)
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The inspectors conducted panel walkdowns in the control room and discussed minor
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deficiencies with operations personnel.
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b.
Observations and Findinas
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On May 6,1998, the inspectors noted, in the horseshoe area of the control room,
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that the green indicating lights for two main turbine bearing oil lift pumps were not
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illuminated. All of the adjoining pumps had clearly illuminated green indicatinD
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lights. The inspectors questioned the supervising operator at the controls
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(SO-ATC) about the status of these indicators. The SO-ATC stated that the
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indicators were in fact illuminated, but dim. The SO-ATC cupped a hand around
the lens to demonstrate. After the inspectors continued their walkdown, the
SO-ATC brought the inspectors' question to the US. The US performed the same
hand-cupping technique to observe the lights. The US also stated that the
indicators were illuminated, but dim and instructed the SO-ATC to change the two
light bulbs. Afterthe bulbs were changed, there was no apparent change in the
indication. Operations personnel contacted the responsible system engineer and
discovered that the lights should not beve buen illuminated under the plant
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conditions. The lights were subsecamly verified to be de-energized.
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On April 24,1998, and on several other occasions throughout the inspection
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period, inspectors noted that the drywell equipment drain sump level / rate recorder
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(E31-R619) paper drive was sticking. The inspectors discussed this with several
shift and USs. However, it was not until it was discussed again with a US.on
May 29,1998, that a deficiency tag was initiated,
On May 8,1998, chemistry department personnel identified that the reactor water
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cleanup conductivity chart recorder was not advancing. Upon further review, the
licensee uetermined that the paper had not moved in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> since the paper had
been replaced. The inspectors were concemed that operators had not identified
the condition because markings on the recorder paper should have alerted the
SO-ATC that the paper was not advancing. The recorder was subsequently
repaired.
On May 16,1998, the inspectors identified that the " manual" push button for the
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"B" reactor recirculation flow control hand station (B33-K603B) was not lit. The
corresponding push button on the "A" hand station was lit. Without the light,
operators could not tell whether the controller was in " manual" or " auto" control.
The operators explained that this condition had existed for several months. In
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addition, the operators indicated that the push button is always rer;uired to be in
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manual by procedural controls and that it would be a high risk evolution to change
out the bulb with the plant operating. The inspectors reviewed the open work
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orders on June 3,1998, and identified that no deficiency tag had been written for
this condition. The inspectors were concemed that operations personnel knew of
the deficiency, but had not initiated a deficiency tag.
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During an Operations Assessment Team inspection (Inspection Report 50-440/98007)
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earlier this year, similar occurrences of indication anomalies were observed. During that
inspection, the inspectors raised concems that operations personnel exhibited varying
levels of attention to detail on panel walkdowns and that a questioning attitude toward
equipment status was not always evident. The observations with the oil lift pump
indication, recorder paper drives, and unlit manual push button bulb are additional
examples of these concerrsa,
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c.
Conclusions
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Four examples of unidentified or undocumented deficiencies were identified by the
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inspectors that indicated inconsistent operator attentiveness and awareness of control
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room panels. The inspectors concluded that the level of attention-to-detail and
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questioning attitude used by operators in their routine panel observations varied from
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operator to operator. The inconsistency led to the failure of operators to identify or report
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four control panel deficiencies that were identified by the inspectors.
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06. . Operations Organization and Administration
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06.1 Chance in Operations Manaaer
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On May 11,1998, Mr. T. Rausch was named as the Operations Manager. He was
formerly Director of Quality and Personnel Development. Mr. F. Keamey remains as the
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Operations Superintendent. The inspectors verified that the Operations ManacGr and
. Operations Superintendent met the qualifications of ANSI /ANS-3.1-1993 as required by
.TS 5.2.2.f and 5.3.1.
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Quality Assurance in Operations
07.1; Licensee Self-Assessment Activities (71707)
During the inspection period, the inspectors reviewed multiple licensee self-assessment
activities, including:
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Audit Report 98-01, " Conduct of Operations,"
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Company Nuclear Review Board, April 23,1998
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Daily Management Review of New Condition Reports
The meetings were attended by appropriate personnel and there was sufficient
discussion of items. The inspectors concluded that the self-assessment activities
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observed were thorough, self-critical, and effective in identifying problems and developing
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corrective actions.
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Miscellaneous Operations issues (92901)
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08.1
(Closed)' Unresolved item 50-440/95002-01(DRP): Locked Valves Not Properly Locked.
On February 18,1995, the licensee identified that two safety-related valves in the nuclear
closed cooling system required to be locked closed were closed, but not locked. The
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valves were "T" handle valves and the locking device'apparently slipped off the handle.
The licensee placed instructions in the operations standing instructions to ensure proper
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locking by the use of a tight " figure 8"Icop around the handle. Plant Administrative
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Procedure PAP-0205, " Operability of Plant Systems" was subsequently revised to
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incorporate the instructions. The inspectors conducted a search of other PlFs related to
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unlocked valves since 1995. There were no other s!milar problems after the corrective
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actions were in place. The failure to property lock the valves in this case constitutes a
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violation of minor significance and is not subject to formal enforcement action. This item
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is closed.
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' 08.2 '(Closed) Violation 50-440/95008-01(DRP): Automatic Reactor Scram Due to Personnel
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Errors and Failure to Follow Procedure. On September 2,1995, operators failed to verify -
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the Reactor Feed Pump Turbine Flow Control was in manual as required by the System
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Operating Instruction. The details of the event are described in Inspection
. Report 50-440/95008.- The licensee's Human Performance Enhancement System
evaluation concluded that this event was caused by operator error. The two operators
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involved were temporarily removed from licensed duties, were rounseled on their -
improper actions, and received remedial training. A lessons leamed videotape was
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presented to all operating crews which emphasized management's expectations for using
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. self-checking practices. The inspectors determined that corrective actions were
sufficient. This item is closed.
08.3 (Closed) Violation 50-440/95009-01(DRP): Three Examples of inadequate Corrective
~ Actions. Specific corrective actions to address this violation were reviewed by the
inspectors and considered acceptable, improvements in the Corrective Action Program
were documented in Inspection Report 50-440/98002(DRS). This item is closed.
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II, Maintenance
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Conduct of Maintenance
Mi.1 ' General Comments
The inspectors observed or reviewed all or portions of the following work activities:
SVI-R45-T2002, " Division 2 Diesel Generator (DG) Fuel Oil Transfer Pump and
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Valve Operability Test"
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Technical Specification Rounds
SVI-R45-T1320, " Standby Diesel Fuel Oil Receipt Analysis"
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SVI-C11-T0044A, * Scram Discharge Volume Water Level High Channel A
Functional"
SVI-E31-T0374, " Reactor Coolant System Unidentified Leakage Determination"
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The inspectors identified several concems with procedural adherence during the
performance of routine activities, as discussed in the following sections.
- Mt.2 Procedure Comoliance Concems Durina Diesel Fuel Oil Transfer Pumo Surveillance Test
a.
Inspection Scope (61726 and 71707)
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The inspectors observed operations personnel perform a regularly scheduled TS required
sumeillance test (SVI). This included field observation of the test, review of results, and
comparison to TS requirements,
b.
Observations and Findinas
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On May 4,1998, inspectors observed portions of the performance of SVI-R45-T2002,
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" Division 2 DG Fuel Oil Transfer Pump and Valve Operability Test," Revision 2
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(June 1994). During the performance of Step 5.1.2.23, operations personnel experienced
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difficulty in reading the discharge pressure gauge due to pulsations. An in-service testing
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. group representative recommended a technique to the operators to obtain a stable
reading. Based upon this recommendation, the operators closed and then cracked open
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valve 1R45-F501B to obtain a stable reading. Valve 1R45-F501B was directed to be
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opened in Step 5.1.2.19. No other procedure reference was made for operating or
throttling the valve. The operators did not inform their supervision of the valve
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manipulation, nor was this documented in the data package. The inspectors discussed
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this issue with the Shift Supervisor and the Operations Superintendent. While
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manipulation ~of the gauge isolation valve could have been considered a practice within
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the skill-of-the-trade, operations supervision stated that this practice did not meet their
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expectations since the operators appeared unaware of this technique, and because the
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operators did not stop and request supervisor guidance when unable to complete the SVi
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step as written.
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On May 5,' 1998, the inspectors reviewed the completed data package for
SVI-R45-T2002. A comment in the data package indicated that Section 5.1.4 of the SVI,
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which tested air compressor 1R44-C002B, was not performed due to a tagout. The
inspectors noted that the control switch for fuel oil transfer Pump No. 2 (1R45-C002B)
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was incorrectly marked as "N/A" on the system restoration checklist. The inspectors also
noted that the SVI was fully reviewed by operations supervision without noticing the
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discrepancy. This was brought to the attention of the shift and unit supervisors. The
licensee determined that this step was erroneously marked "N/A" due to confusion
between R44 and R45 designations. The control switch was in the correct position.
Technical Specification 5.4.1.a requires, in part, that procedures be implemented
covering applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2.
One of the recommendations in RG 1.33 is for written procedures to be implemented to
conduct surveillance tests. Section 5.2.1 of SVI R45-T2002 required the completion of
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the system restoration checklist. On May 4,1998, operators failed to verify all of the
restoration items specified in the SVI checklist. The NRC identified error in implementing
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the SVI is a violation of TS 5.4.1.a. (VIO 50-440/98010-03(DRP))
c.
Conclusions
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The inspectors identified a procedure adherence concem with the performance of a
surveillance test which resulted in a violation. The operators failed to properly verify the
status of an item in the system restoration checklist. The inspectors were also concemed
that operations supervision failed to identify an omitted step during review of the data
package.
M2
Maintenance and Material Condition of Facilities and Equipment .
M2.1
Plant Material Condition
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Inspection Scoce (62707)
The inspectors reviewed several emergent work items to ensure appropriate operability
evaluations were performed, TS requirements were met, repairs were made, and root
causes were determined where appropriate.
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b.
Observations and Findinas
The inspectors noted that there were several emergent equipment issues during the
inspection period. Although overall plant material condition remained good, the
inspectors noted an increase in sme gent issues over recent inspection periods. The
issues resulted in distractions to operators or entry into Limiting Conditions for Operation
(LCO) in several cases. In each case, the inspectors observed appropriate and timely
resolution. There was effective involvement by engineering personnel and other
departments as necessary. For example,
On April 27,1998, the "B" reacto! water cleanup pump tripped. A replacement
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pump was installed and retumed to service on April 28,1998.
On May 17,1998, a scram discharge volume level transmitter failure resulted in a
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half scram. The component was replaced on the same day.
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On May 18,1998, an annunciator panellost power. This resulted in a loss of
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generator hydrogen and stator water cooling annunciators and would prevent
generator runback circuitry on a loss of stator water cooling. The item was -
successfully repaired the next day.
On May 22,1998, while operators were attempting to transfer the
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Division 2125 Vdc battery from the reserve to the normal battery charger, several
alarms were received. The operators transferred the battery back to the reserve
charger and several more alarms came in.. The alarms were caused by a failure
in the alarm circuit. The circuit was successfully repaired the next day,
On May 23,1998, a Division 2 DG high Jacket water temperature alarm was
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received. The heater was not cycling off at the high temperature set point due to
a problem with the temperature switch, which was subsequently repaired.
On May 26,1998, a Division 1 DG lowJacket water temperature alarm was
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received. The heater was not cycling on at its low set point. The cause was a
problem with the temperature switch, which was subsequently repaired. The
licensee initiated CR 98-1183 as a result of experiencing problems on both
divisions of Jacket water temperature indication within a few days of each other,
On May 26,1998, the recorder for drywell unidentified leakage failed. In order to
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meet TS required surveillance requirements, a special surveillance test was
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completed each shift for approximately one week until the recorde. was repaired
and retumed to service.
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c.
Conclusions
The inspectors noted an increase in the number of emergent equipment issues over
recent inspection periods. Some of the items resulted in distractions to operators or entry
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into Limiting Conditions for Operation. In each case, the licensee resolved the issue
promptly.
M2.2 Imoroper Control of Transient Combustibles
a.
InsDection Scope (62707)
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The inspectors conducted walkdowns in areas of the plant to assess ongoing
safety-related maintenance activities.
b.
Observations and Findinas
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On May 8,1998, the inspectors toured the 679-foot elevation of the controls complex.
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The inspectors noted approximately 30 cardboard barrels of charcoal media staged near
safety-related control room heating, ventilating, and air conditioning (HVAC) equipment.
The inspectors noted that a transient combustible permit (TCP) was posted for this rnedia
with ongoing control room HVAC work. However, the inspectors noted that the TCP had
expired on March 10,1998. The inspectors notified operations personne! about the
expired TCP, and a new TCP was issued.
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Licensee personnel subsequently determined that the maintenance covered by the TCP
was originally scheduled for February, but had been rescheduled. On March 9,1998, the
TCP was administratively closed. However, the existing TCP was not removed from the
maintenance work package. When the work recommenced in May, workers posted the
TCP from the work package without verifying its status. Maintenance supervision and fire
protection personnel subsequently toured the area and noted a TCP was posted.
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However, they too did not notice that the TCP had expired.
Perry Nuclear Power Plant TS 5.4.1.a. requires that written procedures shall be
implemented covering the applicable procedures recommended in RG 1.33, Revision 2,
Appendix A. Appendix A of RG 1.33 specifies that activities such as fire protection
should be controlled by written procedures.
Part of the plant fire protection program is implemented by Plant Administrative
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Procedure, PAP-1913, " Control of Combustibles," Revision 4. Section 6.4.1 of PAP-1913
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specifies that a Transient Combustible Permit is required to authorize, track, and
document the use of transient combustible materials when the quantity of the
flammable / combustible material exceeds 100 pounds of normal combustibles within
20 feet of safety-related equipment. On May 8,1998, the inspectors identified more than
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4000 pounds of combustible material, with an expired Transient Combustible Permit, in
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an area within 20 feet of safety-related equipment in the control complex. This NRC
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identified failure to follow PAP-1913 is a violation of TS 5.4.1.a.
c.
Conclusions
The inspectors identified a procedure adherence violation involving the improper control
of transient combustibles during maintenance activities. The inspectors were also
concemed that supervisory and fire protection personnel did not display adequate
attention to detailin reviewing the administrative control of the transient combustibles.
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M2.3 Improper Housekeeping md Eauioment Control
a.
Inspection Scope (62707)
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The inspectors conducted walkdowns to assess housekeeping and equipment control
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b.
Observations and Findinas
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The inspectors toured the auxiliary building and the controls complex. Several
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' housekeeping and material controls issues were identified.
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On May 8,1998, the inspectors identified a large cart in the controls complex
without its wheels locked, blocked, or removed. The cart was near safety-related
control room HVAC equipment on the 679-foot elevation of the controls complex.
Plant Administrative Procedure, PAP-204, " Housekeeping / Cleanliness Control
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Program," requires, in part, minimizing seismic falldown/ interaction concems
related to equipment temporarily stored / staged in safety-related buildings by
adhering to specific requirements. One of these requirements is that cart wheels
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be locked, blocked, or removed. This failure to follow PAP-204 as required by
10 CFR Part 50, Appendix B, Criterion V, constitutes a violation of minor
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significance and is not subject to formal enforcement action.
On May 8,'1998, the inspectors identified a compressed gas bottle tied to a
safety-related 1" conduit (1R33T218C) on the 620-foot elevation of the auxiliary
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building. Plant Administrative Procedure -204 also requires that for stored items,
a clearance of at least 1.5 times the height of the item be maintained from
safety-related items. This failure to follow PAP-204 as required by
10 CFR Part 50, Appendix B, Criterion V, constitutes a violation of minor
significance and is not subject to formal enforcement action.
On May 8,1998, the inspectors identified a safety-related instrument cable tray
(No.1660) with the radio frequency cover off and tied-back to an adjacent tray in
the 620-foot elevation of the controls complex. Drawing D-214-001, " Cable Tray
Layout," Note 15, specifies that the affected instrument trays have solid covers
throughout the run for radio frequency protection. This failure to follow PAP-204
as required by 10 CFR Part 50, Appendix B, Criterion V, constitutes a violation of
minor significance and is not subject to formal enforcement action.
,
These three examples of procedure violations were quickly corrected after identifying the
!
problems to the licensee. Condition reports were also initiated by the licensee to
investigate the causes and for trending purposes. Additional examples of procedure
violations in other departments are documented in Sections 01.2, O1.3, M1.2, M2.2, and
,
S1.1 of this report.
c.
Conclusions
The inspectors identified three procedure adherence violations associated with
housekeeping and equipment control activities. This involved equipment that was
improperly staged or stored for maintenance activities.
M8
Miscellaneous Maintenance issues (92903)
M8.1 (Closed) Violation 50-440/95008-02(DRP): Improper Verification of Equipment Prior to
1
!
Work. No response was requested for this violation. The inspection report documented
i
the inspectors' determination that corrective actions were prompt and effective. This item
'
is closed.
l
M8.2 (Closed) Unresolved item 50-440/96006-01(DRP): Past Operability of Division 3 DG with
Degraded Air Start Subsystem. The inspectors were concemed that degradation in one
,
l
DG air start subsystem could render the DG inoperable due to the description in the TS
bases. The TS bases states that two air start subsystems are required for operability.
Actual test results indicated that the TS start time limit of 10 seconds was met with the
degraded subsystem. The subsystem was promptly repaired in August 1996. Upon
further review and discussion with the Office of Nuclear Reactor Regulation, the
inspectors concluded that the DG was operable, although degraded. This item is closed.
M8.3 (Closed) Violation 50-44-/97009-04(DRP): Failure to Follow Procedure During
Safety-Related Valve Packing Maintenance. The inspectors had identified that
13
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_-_-____
.
.
maintenance personnel did not follow work order instructions as required. The inspectors
reviewed the licensee's letter dated December 23,1997, in response to the violation.
Corrective actions included a revision to General Maintenance Instruction, GMI-0061,
l
" Valve Packing Instruction," and counseling of the maintenance supentisor and
I
maintenance technician involved with the event. No further concems were identified.
This item is closed.
M8.4 (Closed) Unresolved item 50-440/98009-02(DRP): Jacket Water Level Indicator
l
l
Concems. The inspectors questioned the ability of operators to verify Jacket water level
and DG operability due to repetitive problems with the Jacket water level indicator. In
response to the inspectors' concems, the licensee performed a calculation (as part of
PlF 98-700) that verified DG operability. The DG Jacket water level would be maintained
at an operable level as long as the water level was above the low level alarm setpoint.
Since the alarm setpoint actuated at more than 3 feet above the minimum net positive
suction head requirements for the system, operability is maintained using the alarm as a
minimum levelindication. The licensee's calculation also verified operability considering
evaporation losses. The licensee also initiated other corrective actions as a result of
PlF 90-700. The level indicator was scheduled to be replaced with an indicator of
improved design, the system operating instruction was revised to provide additional
controls on water level in the standpipe, and the operator logs were revised. This item is
closed.
lil Enaineerina
E1-
Conduct of Engineering (37551)
The inspectors evaluated engineering staff involvement in resolution of emergent material
condition problems and other routine activities. The inspectors reviewed areas such as
operability evaluations, root cause analyses, safety committees, and self-assessments.
The effectiveness of the licensee's contrels for the identification, resolution, and
prevention of problems was also examined. No concems were identified.
E1.1
Failure to Meet TS Surveillance Requirement Due to inadeouste Loaic Testina
a.
Inspection Scope (37551)
On May 6,1998, the licensee identified that four high radiation alarm relay contacts had
not been tested and that TS Surveillance Requirement (SR) 3.3.6.1.5 had not been met
]
since February 8,1994. The licensee reported the condition in a Licensee Event Report
(LER) 50-440/1998-01 as required by 10 CFR 50.73. The inspectors reviewed the
associated condition report, CR 98-1052, the LER, and the results of testing performed
on May 6,1998, to meet TS SR 3.0.3.
14
.
[
.
,
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1
b.
Observations and FindinSLs
On May 5,1998, questions were raised by a Licensed Operator Class regarding
containment vent exhaust radiation monitor trip logic. While reviewing the system
drawings on May 6, the procedure writers identified that icsting required by
TS SR 3.3.6.1.5 had not been satisfied. Four high radiation alarm relay contacts had not
'
been tested since 1994. A test document was promptly initiated and the relay contacts
were satisfactorily tested later the same day.
Based on an investigation, the licensee determined that an error was made while
j
incorporating TS Amendment 77. Corrective actions included: (1)reviewof testing and
drawings for other similar radiation monitors, (2) review of other procedure changes
related to TS Amendment 77, and (3) revision of surveillance test procedures and related
~ drawings. Also, LER 50-440/1998-01 was issued (See Section E8.7 for LER closure).
This non-repetitive, licensee-identified and corrected violation is being treated as a Non-
Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
.
c.
Conclusions -
~
The licensee demonstrated a good questioning attitude in the identification of inadequate
j
logic testing of radiation monitors. The relay contacts were promptly satisfactorily tested.
E8
Miscellaneous Engineering issues (92700,92902)
l
E8.1
(Closed) Violation 50-440/95004-01(DRP): Slow Corrective Actions Related to On-Site
Vehicle Movements Interfering With Overhead Power Lines. No response was requested
for this violation due to the documentation of sufficient corrective actions in the Inspection
Report. This item is closed.
E8.2
(Closed) Unresolved item 50-440/96002-03: Past Review of Loss of Offsite Power / Loss
of Coolant Accident Test Data Due to Clipping of Data Observed in 1996. During
surveillance testing on February 21,1996, the licensee identified that limitations in
discharge pressure instrumentation prevented the determination of actual time to
discharge pressure stabilization. The licensee reviewed data for the A RHR pump motor
electrical current and determined that response time requirements were met.
Additionally, the licensee reviewed all past performances of surveillance test
SVI-R43-T5366, "LPCS/LPCI A initiation and Loss of EH11 Response Time Test,"
Revision 6 and determined that the discharge pressure stabilization method was
incorrectly used. The licensee did; however, determine that Technical Specification
requirements were met by evaluating recorded electrical current data from past
surveillance tests. The inspectors independently reviewed the electrical current data from
past surveillance tests and agreed TS requirements were met. The licensee's review
was documented in PlF 96-893. This item is closed.
E8.3 (Closed) Inspection Followuo item 50-440/96002-05(DRP): Review of Spent Fuel Pool
Licensing Basis Information. The Project Manager from the Office of Nuclear Reactor
Regulation reviewed procedures, the Updated Safety Analysis Report (USAR), and TS.
No concems were identified. This item is closed.
15
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_ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
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.
E8.4
(Closed) Inspection Followuo item 50-440/96003-07(DRP): NUKON Piping insulation in
the Drywell. The inspectors had identified that the insulation on main steam isolation
valves had been pierced by large bolts. The condition was corrected prior to startup from
the refuel outage. This item is closed.
E8.5
(Closed) Inspection Followuo item 50-440/96003-12(DRP): Main Condenser Evacuation
System. The inspectors reviewed this item and applicable USAR sections and
determined that there were no discrepancies or concems. This item is closed.
E8.6
(Closed) Violation 50-440/%005-02(DRP): Slow identification of Condition Adverse to
Quality. A containment vacuum breaker valve was discovered to have a bent linkage arm
for position indication, which could have affected the local leak rate testing of the valve.
l
The condition was not promptly brought to the attention of control room personnel. The
.
licensee's corrective actions for this violation appropriately focused on the importance of
timely reporting of conditions adverse to quality. This item is closed.
'
E8.7
(Closed) LER 50-440/1998-01-00: Instruction Revision Results in inadequate Testing and
Missed TS SR. This item is discussed in Section E1.1 and is closed based on on-site
review of corrective actions.
E8.8
(Closed) inspection Follow-up Item 50-440/%003-08(DRP): Electrical Penetrations
Conformance to USAR. The inspectors had identified an apparent discrepancy between
the USAR description of the electrical penetrations and known degraded c,onditions.
1
There were three separate penetrations that were degraded. Compensatory measures
were established to test and pressurize the degraded penetrations once per week to
ensure that design parameters continued to be met. Repairs were planned for refueling
Outage 7 (Spring 1999). The inspectors determined that there was no USAR discrepancy
as written and that short-term corrective actions were appropriate with long-term actions
scheduled for the next refueling outage. This item is closed.
IV Plant Support
S1
Conduct of Security and Safeguards Activities
31.1
Access Control Procedure Adherence
a.
Inspection Scope (71750)
The inspectors reviewed access control facilities and procedures with the licensee's
security supervision. The inspectors also made periodic observations of personnel
entering the plant protected area through the plant access control point (PACP).
b.
Observations
The inspectors noted that specific procedures were in place for controlling personnel
access to the protected area through the PACP. These procedures were detailed in the
site security plan and PAP-219, " Personnel and Material Access," Revision 3 (July 28,
1997).
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.
During the week of May 25,1998, several observations were made of single-guard
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. access control monitoring at the access lanes of the PACP. Single-guard monitoring is
l
permitted by procedure. However, these procedures call for more restrictive control with
L
one guard present than when multiple guards are monitoring access. Items of access
1
(explosive monitor, metal detector, and x-ray) are to be performed one step at a time
during single guard monitoring. The inspectors noted varying levels of performance of
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these steps by single guards. Some officers made very apparent steps in controlling the
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individual steps of the access lane. However, other guards displayed little difference from
l
multiple guard monitoring.
On May 26,1998, the inspectors observed an individual approach the access badge
1
window. The individual gave a badge number and a fictitious name. The individual was
j
. given the correct badge without stating the correct name because the guard recognized
1
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' the individual. Plant Administrative Procedure PAP-219 required individuals to give their
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badge number and state their name prior to receiving their badaa The next day, other
i
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observations were made by the inspectors of personnel ree N v badge without stating
a badge number and/or name. None of the cases observed by ine inspectors resulted in
i
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unauthorized access or issuance of wrong badges to an individual. This failure to follow
PAP-219 constitutes a violation of minor significance and is not subject to formal
'
enforcement action.
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The inspectors' observations were discussed with security supervision. Immediate steps
i
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were taken by the licensee to reinforce access control requirements. On June 4,1998,
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the inspectors observed another instance of an individual giving a fictitious name at the
,
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badge issue window. The guard issuing badges immediately counseled the individual on
l
the procedure and required a name to be given.
c.
Conclusions
i
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The inspectors were concemed that access control procedures were not uniformly
l
followed by station and contract personnel. This procedure adherence concem is
[
concurrent with procedure adherence concems seen in other areas throughout this
,
inspection period.
(
S8
Miscellaneous Security and Safeguards issues (92904)
S8.1
(Closed) Inspection Follow-up item 50-440/96003-03(DRP): Aberrant Behavior Not
- Reported to Security Department in a Timely Manner. This issue was reviewed by Rlli
security inspectors and determined to be a Non-Cited Violation. This is documented in
Inspection Report 50-440/96004. This item is closed.
P8
Miscellaneous Emergency Preparedness issues (92904)
l
P8.1 '(Closed) Unresolved item 50-440/97021-01(DRP): Timeliness of Initial Unusual Event
Declaration on January 23,1998. The licensee declared an unusual event when
' 275 gallons of trichlorethylene leaked from the offgas brine system into the offgas
building. The inspectors initially questioned the timeliness of the declaration. This issue
!
was reviewed by Region lli emergency preparedness inspectors as docume'ited in
Inspection Report 50-440/98003. After a review of the timeline associated with the event,
17
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the inspectors concluded that the timeliness of the unusual event declaration was
appropriate. This item is closed.
V. Manaaement Meetinas
1
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
i
conclusion of the inspection on June 4,1998. The licensee acknowledged the findings
presented. The site Vice President disagreed with the inspectors' conclusions regarding
throttling of the gage isolation valve as discussed in Section M1.2. The inspectors asked the
licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
1
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
L. Myers, Vice President, Nuclear
H. Bergendahl, Director, Nuclear Services Department
N. Bonner, Director, Nuclear Maintenance Department
]
H. Hegrat, Manager, Regulatory Affairs
T. Henderson, Supervisor, Compliance Unit
W. Kanda, General Manager, Nuclear Power Plant Department
F. Keamey, Superintendent, Plant Operations
T. Rausch, Manager, Plant Operations
R. Schrauder, Director, Nuclear Engineering Department
J. Sears, Radiation Protection Manager
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INSPECTION PROCEDURES USED
IP 37551:
Onsite Engineering
j
IP 61726:
Surveillance Observation
IP 62707:
Maintenance Observation
IP 71707:
Plant Operations
IP 71750:
. Plant Support
IP 92700:
. Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
t
Facilities
'
IP 92901:
Followup - Operations
IP 92902:
Followup - Engineering
IP 92903:
Followup - Maintenance
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ITEMS OPENED AND CLOSED
Opened
50-440/98010-01
Incorrect Fuse Removed
l
50-440/98010-02
NCV Light Bulb Replaced with Wrong Type
i.
50-440/98010-03
Missed Step in Surveillance Restoration Checklist
!
50-440/98010-04
Expired Transient Combustible Permit
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50-440/98010-05
NCV Inadequate Logic Testing of Radiation Monitors
'
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Closed
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50-440/95002-01
Locked Valves Not Properly Locked
j
50-440/95004-01
Slow Corrective Actions Related to On-Site Vehicle Movements
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Interfering With Overhead Power Lines
50-440/95008-01
Automatic Reactor Scram Due to Personnel Errors
'
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50-440/95008-02
Improper Verification of Equipment Prior to Work-
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50-440/95009-01
Three Examples of inadequate Corrective Actions
50-440/96002-03
Past Review of Loss of Offsite Power / Loss of Coolant Accident
Test Data Due to Clipping of Data Observed in 1996
50-440/96002-05
IFl
Review of Spent Fuel Pool Licensing Basis Information
l
50-440/96003-03
IFl
. Aberrant Behavior not Reported to Security
50-440/96003-07
IFl
NUKON Piping insulation in the Drywell
L
50-440/96003-08
IFl
Electrical Penetrations Conformance to USAR
l.
50-440/96003-12
IFl
Potential USAR Discrepancy
50-440/96005-02
Slow identification of Condition Adverse to Quality
50-440/96006-01
Past Operability of Div 3 DG With Degraded Air Start Subsystem
50-440/97009-04
Failure to Follow Procedure During Safety-Related Valve Packing
y
!
Maintenance
50-440/97021-01
Timeliness of Emergency Declaration
50-440/98001-00
LER
Inadequate Testing and Missed TS Surveillance Requirement
'50-440/98009-02
DG Jacket Water Level Concems
,
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50-440/98010-02
NCV Light Bulb Replaced with Wrong Type
L
50-440/98010-08
NCV Inadequate Logic Testing of Radiation Monitors
50-440/98010-09
NCV Security Badge issuance Concems
20
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.
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LIST OF ACRONYMS USED
CFR
. Code of Federal Regulations
CR
Condition Report
'
Control Rod Drive
J
Diesel Generators
Division of Reactor Projects
!
Enforcement Action
I
Heating, Ventilation, and Air Conditioning
IFl
Inspection Followup item
IP
Inspection Procedure
IR
inspection Report
LCO
Limiting Condition for Operation
LER
Licensee Event Report
Non-cited Violation
NRC.
Nuclear Regulatory Commission
PACP
Plant Access Control Point
Plant Administrative Procedure
Public Document Room
Potential Issue Form
Regulatory Guide
SO-ATC
Supervising Operator at the Controls
sol
System Operating Instruction
SR
Surveillance Requirements
SVI
Surveillance Instruction
Transient Combustible Permit
TS
Technical Specification
US
Unit Supervisor
Updated Safety Analysis Report
Unresolved item
Violation
,
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