IR 05000219/1990019
| ML20062H022 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/16/1990 |
| From: | Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062H018 | List: |
| References | |
| 50-219-90-19, NUDOCS 9012040032 | |
| Download: ML20062H022 (18) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /90-19 License N DPR-16 Licensee: GPU Nuclear Corporation 1 Upper Pond Road Parsippany, New Jersey 07054 Facility Name: Oyster Creek Nuclear Generating Station Inspection Conducted: September 23, 1990 - October 20, 1990 Inspectors: M. Banerjee, Resident Inspector E. Collins, Senior Resident Inspector Approved By: [A .
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W. Rul~and, Chief, ~
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'Date Reactor Projects Section 4B Inspection Summary:
Inspection Report No. 50-219/90-19 for September 23, 1990 - October 2'J,1990 Areas Inspected: This report documents routine and reactive inspection of station activities including: plant operations, radiological protection, surveillance and maintenance, emergency preparedness, security, engineering and-technical support, and safety assessment / quality verificatio Results: Overall, the facility was operated safely. One violation was identified concerning the lack of appropriate control and review of plant temporary configurations (paragraph 1.4). Another violation was identified concerning an entry into a high radiation area withoJt the monitoring required by the radiological work permit (paragraph 2.1). Licensee activities to replace a relay in the Reactor Manual Control System were conducted safely and according to Technical Specification requirements. Control room operators showed a questioning attitude in identifying recirculation flow discrepancies (paragraph 1.1). A comprehensive plan to evaluate Core Spray system operation '
was formulated and begun by the licensee. Eight previously opened inspection
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-items were closed.(paragraphs 1.4 and 6.0).
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I' TABLE OF CONTENTS
& Page Executive Summary. . . . . . . . . . .............. 1 I Details. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
- 1.0 Operations (IP 71707, IP 93702)* . . . . . . . . . . . . . . . I 1.1 Review of Operational Events. . . . . . . . . . . . . . . . I 1.2 Control Room Tours .................... 2 1.3 Facility Tours ...................... 2 1.4 Configuration Control . . . . . . . . . . . . . . . . . . . 4 2.0 Radiological Controls (IP 71707) . . . . . . . . . . . . . . . . 7 2.1 Entry Into High Radiation Area . . . . . . . . . . . . . . 7 2.2 Licensee Evaluation of Potentially Contaminated Soil. . . . 7 2.3 Contamination in New Radiological Waste Building. . . . . . 8
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3.0 Maintenance / Surveillance (IP 61726, IP 62703) ......... 8 3.1 Monthly Maintenance Observation . . . . . . . . . . . . . . 8 3.2 Emergency Diesel Battery Testing. . . . . . . . . . , . . .
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4.0 Observation of Physical Security (IP 71707) . . . . . . . . . . 9 j 5.0 Safety Assessment / Quality Verification (IP_71707, IP 35502). . . 10 5.1 Review of Written Reports . . . . . . . . . . . . . . . , . 10 5.2 Core-Spray System Evaluation Plan . . . . . . . . . . . . . 10 6.0 ReviewofPreviouslyOpenedItems(IP92701,IP92702)..... 11 7.0. Inspection Hour Summary. . . ._ . . . . . . . . . . . . . . . 14-
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Exit Meeting and Unresolved Items (IP 30702, IP 30703) . . . . . 14 !
1 8.1 Preliminary Inspection Findings . . , . . ......., 14-8.2 Attendance at Management Meetings Conducted by Region Based Inspectors . . . . . . . , , . . . . . . . . 14 i
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The NRC inspection manual inspection procedure (IP) or temporary l
. instruction (TI) .that was used as inspection guidance is listed for each l applicable report section l
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REGION I
EXECUTIVE SUMMARY Report N /90-19 Operations
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I Overall, the plant was operated in a safe manner. Licensee actions and L planning for the_ replacement of a relay in the. reactor manual control system met technical specifications and supported safe plant operation. Control room operators showed a questioning attitude in identifying a discrepancy associated-with the recirculation flow' indication. This allowed identification and resolution of inaccurate average. power range monitor scram and rod block trip setpoints. NRC review of this event was in progress at the end of the in-spection perio On October 15, 1990,-an NRC inspector tour of Oyster Creek facility was observed by a representative from the State of New Jerse One violation was identified in the area of plant configuration control in- j volving several examples of unauthorized temporary variation I Radiological _ Controls An event occurred.where an individual entered an area posted as a high radi-ation area without.the appropriate. dose rate meter. The licensee identified
.. the condition.and promptly began. review and corrective action. This event is a
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repeat of an event which occurred in October 1989 and is an example of a poor radiation work practic The licensee demonstrated an appropriate questianing ,
g and probing attitude in the evaluation of soil which was removed from the sit g Maintenance /Surveillaace Emergency diesel generator battery testing accurately simulated actual battery service and demonstrated adequate cell performance. The licensee adequately.
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controlled the cleaning of containment spray system I heat exchanger Plant Security Licensee review and corrective action associated with main gate activities were i
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Safety Assessment and Quality Verification The licensee implemented an extensive review to identify the cause for core spray system #2 seismic support damage. System operation during this in-spection period did not show excessive pipe movement or unusual condition Licensee implementation of this plan was in progress at the end of the in-spection period,
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DETAILS
1.0 Plant Operational Review
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1.1 Review of Operational Events The inspection period began and ended with the reactor at full powe Reactor power was reduced periodically to perform backwash of the main condenser. Inspectors reviewed key operational events that occurred during the report period as discussed ir the following paragraph On October 7,1990, during weekly cor' ol rod testing, the licensee identified that reactor manual control system (RMCS) insert relay (4K4)
allowed a control rod to continue to insert af ter the notch switch was released. Afterwards, the relay functioned correctly. On October 8, 1990, at 9:23 p.m., the reactor manual control system was deenorgized to allow replacement of this relay. Technical specification 3.2.0.4 spect-fies that control rods which cannot be moved with control rod drive pressure shall be considered inoperable. Since no rods could be moved during the corrective maintenance associated with the insert relay, the licensee declared all control rods inoperable. Technical specifications limit the number of' inoperable control rods to six. The licensee con-sidered the plant to be under the action statement of technical speci-fication 3.0.A which requires cold shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. For this event, a plant shutdown was not begun because of the 6nticipated short !
duration of the maintenance. The relay was replaced, and the reactor manual control system was reenergized at 10:02 p.m. Post maintenance j testing was completed at.10:32 p.m. after successfully moving 12 control rods. The scram function of the control rods remained operable during this evolution, . Inspectors. reviewed licensee-actions and concluded they supported safe operation of the facility and met plant technical speci-fication requirement ,
On October 18, 1990, the. licensee identified.the flow input from the . I reactor recirculation system to the average power range monitoring (APRM)
system was about'six percent high. This error increased the flow biased rod block and scram setpoints by as much as four percent. The licensee-concluded the actual setpoints were above the technical specification requirements of Section 2.3.A and began a plant shutdown at 1:24 Initiation' of a plant shutdown required'by technical specificatiens was reported to the NRC within one hour as required by 10 CFR 50.72(b)(1)
(i)(A). -The licensee recalibrated the flow converters and calculated the-necessary APRM gains to compensate for the flow error. The gain adjust-ment returned the APRM rod block and scram trip setpoints to technical
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specification requirements. The shutdown was terminated at about 7:00 4
'p.m. with the plant at 72% power. The plant was returned to full power at I about 7:00 a.m.- on October 19, 1990, inspector review of this event was in progress at the end of the inspection period.
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1.2 Control Room Tours The inspectors conducted routine tours of the control roo The inspectors reviewed:
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Control Room and Group Shift Superviser's Logs;
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Technical Specification Log;
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Control Room and Shif t Supervisor'6 Turnover Chect Lists;
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Reactor Building and Turbine Building Tour Sheets;
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Equipment Control Logs;
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Standing Orders; an Operational Memos and Directive Inspectors reviewed the status and line up of the core spray, containment spray, isolation condenser, and emergency electrical systems as indicated by control room indication No significant observations were identifie .3 Facility Tours The inspectors conducted routine plant tours to assess equipment con-ditions, personnel safety hazards, procedural adherence and compliance with regulatory requirements. The following areas were inspected:
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Turbine Building
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Vital Switchgear Rooms
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Cable Spreading Room
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Diesel Generator Building
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Reactor Building
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New Radwaste Building
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Old Radwaste Building
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The'following additional items were observed or verified:
, Fire Protection:
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Randomly selected fire extinguishers were accessible and inspected on schedul Fire doors were unobstructed and in their proper positio Ignition sources and combustible materials were controlled according to procedure Appropriate fire watches or fire patrols were stationed when L fire protection / detection equipment was out of servico, Vita 1' Instrumentation: )
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Selected instruments appeared functional and demonstrated parameters within Technical Specification Limiting Conditions for Operatio ,
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Plant housekeeping and cleanliness were according to licensee program l Inspectors questioned the mounting of the station startup transformer No anchor bolts could be seen. .The Facility Design Safety Analysis Repor '
(FDSAR), Section 3.1, indicates that startup transformers are seismi . category 1' equipment, This information is also-reflected in the FSAR Update, Section 3.1. Licensee review concluded that startup transformers !
are-not seismic category I equipment and are'not designed to be seismic _ -
category 1; Inspectors . reviewed Station Drawing 4036-5 (WO2299), Rev. 5, '
and concluded that no anchor bolts were specified. The licensee plans to Lcorrect the FSAR update. Inspectors had no other question t
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The following observations were made:
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The physical appearance of the emergency diesel generator building is
..significantly improved. .The walls, floors and components have been <
cleaned and painte ~ Decontamination efforts were in progress in the torus room, j~
Inspectors were able to enter a portion of the torus room without protective clothin .
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On October 15, 1990, an NRC inspector tour of Oyster Creek facility was observed by a representative from the State of New Jerse .4 Configuration Cottr_ol
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Inspection report 50-219/90-15 opened an unresolved item (90-16-02)
addressing 12 plant configurations. Inspectors reviewed the licensee evaluation and corrective action associated with each ite Item one addressed isolation condenser valve packing gland leak off line Licensee review concluded the installation was controlled. The leak off lines are shown on process and instrumentation drawings (P&ID GE-148F262, Rev. 25). No action is required on this ite !
Item-two addressed standby liquid control pump leak of f drain line Licensee review concluded the drain lines are part of the original plant installation. The span of the support poirts is small and does not exceed ,
dead weight spacing criteria for one inch tipe. The installation is shown
.on p&ID 148F723. The licensee is continuitg to review the seismic ade-
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quacy of the installation, inspectors con:luded this piping does not adversely affect the. operation of the stanjby liquid control pump Item three questioned the clamping of plastic piping to a torus pressure sensing line. Licensee review concluded the clamp was a controlled:
installation. Licensee preliminary evaluation indicates no significant load is placed.on the. torus pressure sensing line. The clamp is installed only to prevent lateral movement of the plastic piping. Since the instal-lation was controlled, inspectors concluded the item had no safety signi-ficanc Item four questioned a two inch penetration located on the north vall of the reactor building. Initial licensee review could not locate doccmenta-
-tion on the valve and the penetration. Licensee planned corrective actions include:- ,
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Incorporation of the valve.and penetration on plant drawings;
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Plant Operations is to control the configuration as a temporary variation in the interim; and,
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Technical Functions is trying to locate the documentation associated ,
with the penetration and the pipe, If no' documentation is found, the-licensee will document the technical adequacy of the installatio Based on the valve being closed, the pipe end: capped, and the licensee
. actions to-control the_ position of the valve, inspectors concluded this condition did not adversely affect the secondary containment boundary.
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Item five addressed a two inch condensate line near the south wall of the reactor t,uildirg on the 23 f t elevation. Licensee review concluded this condition was an incomplete installation of a condensate station. The unattached pipilg on the reactor building wall was to be used to complete the station and has been removed by job order No. 25799. The valve was determined to be condensate valve V-11-5. Field change notification C084442 was prepared to incorporate the valve onto plant drawing ER2004 The licensee plans to label the valve and to evaluate the existing pipe support Inspectors concluded this condition did not present a safety concern and that lices.see corrective actions are appropriat Item six addressed a one inch penetration in the reactor building south !
wall. Licensee review concluded the reactor building penetration is !
permanent. The valves are labeled and this configuration 1., included in the configu/ation control database. (he valves are included on plant l
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drawings. Since the valves inside a.id outside the containment are on i plant draoings and are controlled 4 the closed position, inspectors !
concluded there was no safety sig'.ificance to this present configuratio !
Licensee corrective actions are appropriat i Item seven addressed a drain pipe which was directed to a reactor building floor drain on reactor building 23 ft elevatio Licensee review con- !
cluded the line was installed before 1980 as an alternate equipment drain )
path to support construction activitie It was. abandoned in place, i The licensee prepared job order No. 25800 to remove the drain lin Inspectors concluded the licensee actions to remove the drain line are appropriat Item eight addressed the installation of stainless steel tubing to the domineralized water system. This tubing was installed to support tech-nicians during scram discharge volume testing. Licensee evaluation concluded the line was not part of the plant and not shown on plant drawings. The licensee plans to remove the lin The date has not yet -!
been determine Inspectors concluded that item eighc was an unauthorized temporary variatio The installation was not reviewed, not shown on plant draw-ings, and_not_ controlled as directed by licensee procedure 108, " Equipment Control." Inspectors.further concluded there was no technical safety significance to this configuration because the line was not connected to a
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j safety related system, i Item nine addressed the installation of valves in the demineralized water '
system. Licensee review concluded there was no record of this change. A
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portion of the configuration had been shown on plant drawing BR2004 on July 31,199^. The licensee plans to replace one valve under job order 26081 and to remove the unauthorized valve Inspectors concluded that item nine was an unauthorized temporary vari-ation. The installation was not reviewed, not shown on plant drawings, and not controlled ~as directed by licensee procedure 108,
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" Equipment Control." Inspectors further concluded this item had no L technical safety significance because it did not af fect safety related equipment. Item ten addressed a rubber hose in a reactor building penetration. On each end of the hose a valve was installed. Licensee review concluded this was an unauthorized temporary variation. Licensee review concluded the installation was acceptable because the cross sectional area is less than that which affects the operability of the secondary containment. On September 27, 1990, Plant Operations issued a temporary variation review-J ing and documenting the installation. The licensee is reviewing the need for a permanent installation.
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Inspectors concluded that item ten was an unauthorized temporary varia-tio The installation was not reviewed, not shown on plant drawings, and not controlled as directed by licensee procedure 108, " Equipment Control."
This item has potential safety significance because it is a modification to the secondary containment boundary.
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Item eleven addressed an air manifold near the reactor building north wall at 23 ft elevatio Licensee review concluded the installation was
controlled and captured on plant drawings. The installation has not been turned over to plant operation Plant Operations plans to initiate a temporary variation to control the configuration until the turnover
= process can be completed. The projected date of turnover is December 31, 199 __ Inspectors concluded that this configuration installation was controlled and technically accep.abl item twelve addressed a two inch temporary air hose extending from the manifold (addressed in item eleven) to the reactor building 119 ft elevation. The licensee concluded this was a temporary variation and completed the review and documentation required by Station Procedure 10 Inspectors concluded that item twelve was an unauthorized temporary variation. The installation was not reviewed, not shown on plant draw-ings, and not controlled as directed by licensee procedure 108, " Equipment Control." Inspectors further concluded this item has potential safety significance because of the length of run of hose and its proximity to safety related equipment. Licensee evaluation and documentation of this configuration was completed on September 27, 199 Items 8, 9, 10, and 12 were modifications to the plant that were uncon-trolled and undocumente Items No. 10 and 12 have potential safety significance. These modifications were installed without the review and approval required by Station Procedure 103. These examples show weakness
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in the work control process in that these items were not identified as modifications to the plant. This is a violation (NV4 90-19-01). This
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2.0 Radiological Controls 2.1 Entry Into High Radiation Area On October 16, 1990, a worker entered an area posted as a high radiation area without the required monitoring and survey meter. The licensee '
identified, documented and reviewed the conditio '
The worker entered an equipment cage under Radiation Work Permit (RWP)90-990 for observation, inspection and minor maintenance. The cage is- '
posted as a high radiation area due to the possible high dose rates '
when source containers are. moved. The RWp required a 0-500 mrem self
. reading dosimeter (SRD), and an alarming dosimeter or a dose rate mete The worker did not have eithe A radiological control technician (RCT) identified the condition. The worker was sent to the group radiological controls supervisor-(GRCS) for
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the needed meters and was-briefed by the GRCS. The 0-200 range SRD worn by the worker sh7wed no exposure. Radiation levels were about 6 mrem /hr general area. Tie RCT prepared a-deviation report and a radiological ,
incidence report (RIR). Licensee review concluded the cause of the
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occurrence was human erro Although the licensee was prompt in identifying, . correcting, and informing'
the NRC about this event, it is similar to a previous event (inspection report 50-219/90-09) when a worker entered an area posted as a high radiation area without a dose rate meter as specified by the RWP. The current event is an example of a poor radiation protection practic Continued licensee attention to this area is warranted. Entering an area posted as a high radiation area without the monitoring / survey meters as specified by the RWP is a violation. Although identified and corrected by !
the licensee, it is being cited because it is a repeat of a previous violation (NC5 50-219/90-19-02).
2.2 Licensee Evaluation -of Potentially Contaminated Soil On October.2, 1990,.the licensee informed the resident inspectors of an evaluation for environmental disposal of soil which had been removed from the plant. Although this soil was outside.the. radiological controls area, it was located near the radiological controls boundary. The licensee sampled the soil. One sample was delivered to the environmental labora- ,
. tories for evaluation. Another sample was counted on site and was deter- '
mined to have a gross activity'of 1E-6 uci/g Inspectors estimated the total amount of activity (assuming I cm3 per gram and 40 cubic yards total) at about 40 uci. Inspectors concluded the safety significance was minima ,
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At the end of the inspection period the licensee was still evaluating the suitability for uncontrolled environmental disposal of the soil. The licensee demonstrated an appropriate questioning attitude in pursuing possible radiological consequences for removing the soil from the sit The inspectors had no other question .3 Contamination in New Radiological Waste Building On October 13, 1990, a technician working at an instrument rack, outside the evaporator cubicles, in the 23 ft elevation of the new radiological waste (NRW) building received 4000 counts / min contamination on one shoe and 12000 counts / min contamination on one pant leg. Several days before, two people received clothing contaminations during a walkdown in the same general area. At that time the licensee determined that contaminated water from the evaporator cubicle had leaked through the wall. This water evaporated, leaving a-residue which then migrated to neighboring areas, spreading contaminatio The licensee' performed a more detailed review. Air currents introduced
- when the main entrance door and the door leading to the 23' elevation are simultaneously opened was determined to be the cause of contamination
$pread, sThe licensee plans to install plexiglass walls to contain the contaminatio In addition, the licensee is reviewing the feasibility of installing double doors at the main entrance. Rous'ne surveys are per-formed several times a week. . Inspectors concluded . hat the licensee's attention to this problem was appropriat ,0 Maintenance / Surveillance 3.1 Containment Spray Heat Exchanger Cleaning Inspectors observed performance of the following plant maintenance activities:
-Job Order 26055 - Preventive maintenance, emergency service water pump motor 1-1 and 1-2-Job Order 25678 - Replacement of. containment spray system 1 flow transmitter Job Order 23076 - Containment spray heat exchanger 1-1 open, inspection and clean d Job Order 23109 - Containment spray heat exchanger 1-2 open, inspection and clean
.The inspector verified the system was properly tagged, the technical srecification limiting condition of operation was met, and the redundant system was operable. The technicians had the necessary approval to proceed with the maintenance work and were using calibrated tools and instruments, t
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t Inspectors observed Quality Control coverage for the containment spray flow transmitte No deficiencies were identifie The inspector reviewed the switching and tagging request for the heat exchanger cleaning and questioned the absence of a temporary variation on a drain hose. Station Procedure 108, Rev. 47, " Equipment Control,"
requires a mechanical variation tag on the drain hose if it is expected to be installed more than ene day. Since the one day limit was approaching, the licensee prepared the required tag. The inspector did not have any other question The inspector observed calibration of the containment spray flow trans-mitters. Inspectors verified the technicians were using calibrated instruments and were following the requirements of the work package.-
3.2 Emergency Diesel Generator Battery Testing On September 26, 1990, ;nspectors observed the post maintenance testing for No.=2 emergency diesel generator (EDG) after battery cells Nos. 11 and
.29 were replaced. The mairtenance and testing were performed under 4 immediate maintenance short form No. 61340 Rev. 1. The inspectors reviewed the work pachge ano "orified the following:
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The activity did not violate technical specification limiting conditions for operations and No. 1 (EDG) was operable; ,
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The, required work approvals and releases had been obtained before starting work; and, ;
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the equipment was properly tested and ret.*.'~,d to servic For this~ testing,.each cell voltage was monitored by a Dranetz Battery Capacity tester (DCT-1000), The testing consisted of.two.15 second <
cranking periods separated by 10 minutes. All battery cells performed satisfactoril Inspectors also verified appropriate control of test equipment and temporary modification *
4.0 Observation of Physical Security On September 28, 1990, inspectors questioned the stationing of security guards at the main guardhouse. The licensee reviewed the existing con-dition'and identified weaknesses in the coordination of guard positionin The licensee enhanced their administrative controls fo positioning and relieving guard ;
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Inspectors reviewed the condition and licensee corrective actions and concluded the existing condition did not degrade plant security. Station security plan requirements were satisfied. Licensee corrective actions :
were acceptabl ;
The inspectors had no other question .0 Safety Assessment / Quality Verification 5.1 Review of Written Reports Inspectors reviewed written reports submitted by the licensee to the NR Inspectors verified the details of the events were clearly reported, ,
including accuracy of the description, cause and adequacy of corrective actions. The inspector determined whether further information was re-quired from the licensee, whether generic implications were indicated and whether the event warranted onsite followup. The following reports were reviewed:
Special Report #90-04. dated October 16, 1990 Monthly Operating Report for September 1990 The two reports were well written and contained'the required informatio ,
5.2 Core Spray System Evaluation Plan L In response to core spray system #2 seismic support damage (in',pection report 50-219/90-16), the licensee formulated a plan to evaluate-the performance of the system. Inspectors reviewed the licensec plans and-observed system operation performed as part of the evaluatio The plan consists of the following actions:
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Require inspection / monitoring of core spray supports during and af ter '
1 pump testing;
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Investigate the history of core spray support damage;
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Review core spray- system modifications; ,
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Identify similarities and differences between core spray system #1-and #2;
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Review system #2 check valve performance;
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Evaluate core spray system #2 potential for having air entrapped in the system; and,
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Develop a thermal hydraulic model of the core spray syste ,
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The inspectors did not have any questions about the core spray evaluation pla On October 3,1990, inspectors observed the operation of core spray system
- 2. The system was operated per Surveillance Test 610.4.002. System operation was monitored for pipe movement by the licensee. System piping was observed during pump starts and pump shifts at the 51 and 75 ft elevations of the reactor buildin No excessive pipe movement or abnormal conditions were observe .0_ Review of previously Opened items '
.(Closed) Violation 88-02-02. This violation addressed inadequate main-tenance of. station procedures. On January 29, 1988, an NRC inspector-noted Station Procedure.329, " Reactor Building Heating, Cooling and :
Ventilating System," contained a description of a reactor building tem- l perature-indicator in control room panel 11R which was never installe The procedure was in use for a long time, but periodic reviews of this procedure did not identify this discrepanc '
Inspection report 50-219/89-29 reviewed the GPUN response and corrective actions to-identify and correct similar deficiencies. The licensee provided additional guidance to procedure reviewers to reinforce the need to obtain user feedback during biennial review of procedures. This item ,
was left open pending further review of the " user feedback" proces Biennial review of procedures.is performed by the responsible departmen Plant Jperations (usually the Group Shift or Group Operating supervisor)
reviews the system operating procedures and operations surveillance test '
Plant, Engineering (PE) also maintains instrumentation and electrical '
system surveillance procedures, 151 procedures, operating procedures for 3-instrumentation and radiation monitoring systens, abnormal operating and t
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alarm response procedures, and procedures for diagnostic and restoratio Although PE is not a= direct user of these procedures, designated system engineers in PE perform the periodic revie p a
Station Procedure 107, Rev. 36, " Procedure Control," indicates the . o reviewer should contact a " user" of the procedure (operator, technician, '
etc.) for feedback on the adequacy of the procedure and should document 1 this effor The inspector interviewed several reviewers to determine how
" user feedback" is obtained by the reviewer. The inspector determined in most cases this is done informally, The Operations Department recently started using-a procedure review checklist which addresses user feedbac ~
Other reviewers accomplish this by their own knowledge and close associ-ation with-the' users. This kind of user feedback is not separately documented.-
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The inspector concluded " user feedback" is being incorporated into the biennial review of procedures, although formal documentatior, of this feedback is not always provided. This item is close { Closed) Violation 88-04-02. The licensee did not declare snubbers i inoperable when removing them for repair. This involved four hydraulic '
snubbers on the torus ring heade In the response, the licensee developed a data sheet and incorporated it into the snubber surveillance and maintenance procedures. This data sheet requires formal documentation of control room notification for snubber status change The inspector revietted the following procedures and discussed the-requirements with-licensee personnel:
675.1.001, Rev. 17, " Inspection of Bergen-Paterson Hydraulic Snubbers" 675.1.507, Rev. 2, " Functional Testing of Bergen-Paterson Hydraulic Snubbers" A100-GMM-3921.53, Rev. O " Removal, Installation and Rebuilding of Hydraulic Snubbers" The snubber inspection procedure requires control room notification before '
snubber repair or replacement.- A data sheet is used to document control room notification of snubber status. When a snubber needs replacement, the control room is notif. icd of the snubber out-of-service condition and
- GSS permission is obtained to initiate wor ,
Additionally, the snubber inspection procedures require generation of a '
deviation report and declaring the snubber-inoperable when the acceptance criteria are not met. The functional test procedure is used for snubber testing in the shop following removal from the syste ~The current procedures appropriately address control room notification-involving changes of snubber operability status. Inspectors reviewed recently completed work requests. involving snubbers and verified the required control room notifications for deficient conditions and snubber removals were performed and documented. This item is close ,
(Closed) Unresolved-Item 88-16-03. This item addressed an event where-containment spray heat exchanger differential-pressure exceeded the surveillance test acceptance criteria. - Special inspection 50-219/88-21 reviewed this event and-the performance of the heat exchangers. The inspection concluded there was sufficient heat. transfer capacity to- satisfy functional requirement Based on the review of. inspection report L 50-219/88-21, this unresolved item is closed, b
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13 i (Closed) Unresolved Item 88-17-01. This item addressed the absence of ,
administrative controls for the Emergency Operating Procedures (EOP) '
flowcharts. This item was left unresolved pending upgrade of the administrative controls for control room flowchart update Station Procedure 107, " Procedure Control," establishes the requirements and responsibilities for the preparation, review,. approval, and revision '
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control for all station procedure Inspectors reviewed revision 35 and verified the existence of administrative controls for the E0P flowchart Section 6.3 of the procedure addresses maintenance of E0Ps, and section 6.3.3 specifies the steps to be taken to update E0P flowcharts when a revision or temporary change has been approved. Based on the incorpora-tion of administrative controls to update E0P flowcharts, this item is close { Closed)UnresolvedItem 88-38-02. This item addressed potential single failures in the Standby Gas Treatment System (SGTS) logic. Follow-up safety inspection 50-219/89-09 reviewed the design of the system logic and concluded the system automatic start logic was not originally designed to meet single failure criteri Loss of power to the reactor building ventilation and filter bank heating coils would not prevent the system from performing within its design basis. The system could be manually started during a design basis accident while remaining well below 10 CFR
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Part 100 exclusion boundary dose limit .
The design of the system was discussed.in an enforcement conference-(February 16,1990). NRC letter dated _ April 8, 1990,-transmitted the results of this conference and indicated the design did not constitute-a condition adverse to quality. Based on the conclusions of inspection report 50-219/89-09 and the enforcement conference of. February 16, 1990, thit item is close (Closed) Unresolved Item 89-06_-01. 'This item addressed GPUN's review of .
closed Preliminary Safety Concerns (PSC). .
Before startup from the 12R refueling outage, the licensee conducted a review of closed PSCs. The results of this review were documented in a letter to the NRC dated March 21, 1989. NRC review of the results is documented in inspection report 50-219/89-07, paragraph 6. This review concluded that the licensee review provided confidence the PSC process had'
not left significant safety questions unresolved. Also, the results of this review were discussed in an enforcement conference conducted or February- 16,.1990. Based on the results of the licensee and NRC review, this unresolved-item is close '
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.(Closed)UnresolvedItem 89-06-04. This report documented instances where GPUN's preliminary safety concern ('SC) process identified conditions adverse to quality, but did not prescribe adequate corrective action This was considered an apparent violation of 10 CFR 50, Appendix B, Criterion XVI. An enforcement conference conducted on I?bruary 16, 1990 addressed this apparent violation. The results were documented in an NRC letter dated April 8, 1990. The letter concluded that f ailure.to co. rect these conditions adverse to quality constituted a violation. A Notice of
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Violation was not proposed for this violation because this and other violations were considered the basis for classifying a previous enforce-ment action at severity level 3 (inspection report 50-219/89-23). Also considered were the comprehensive actions that were taken or planned -
to be taken to. upgrade the licensee's programs for identifying and cor-recting problems. This open item number is changed to non-cited violation (NON) 89-06-04, and is close .0 Inspection Hours Summary Inspection consisted of 129 direct inspection hours; 30 of these direct inspection hours were performed during backshift periods,.and 10 of these hours were deep backshift hour .0: IExit Meeting and Unresolved Items 8.1 Preliminary Inspection Findings A summary of findings was provided to senior licensee management after this inspectiori. During the inspection, licensee management was periodically notified of the findings by the resident inspectors. No written inspection material was provided to the licensee during the inspection. No proprietary information is included in this repor .2 Attendance at Management Meetings Conducted by Region Based >
lnspectors The resident' inspectors attended the exit meeting for Inspection
'50-219/90-18. At this meeting, the lead inspector discussed inspection '
activities and findings'with senior licensee management, n
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