ML20151L923

Insp Repts 50-445/97-15 & 50-446/97-15 on 970608-0719. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20151L923
Person / Time
Site:	Comanche Peak
Issue date:	08/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151L905	List: ML20151L900 ML20151L915 ML20151L923
References
50-445-97-15, 50-446-97-15, NUDOCS 9708080020
Download: ML20151L923 (21)

See also: IR 05000445/1997015

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ENCLOSURE 2 '

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-445

50-446

License Nos.: NPF-87

NPF-89

Report No.: 50-445/9,'-15

50-446/97-15

Licensee: TU Electric

Facility: Comanche Peak Steam Electric Station, Units 1 and 2

Location: FM-56

Glen Rose, Texas

Dates: June 8 through July 19,1997 l

Inspectors: G. E. Werner, Acting Senior Resident inspector

H. A. Freeman, Resident inspector j

R. L. Nease, Technical Assistant, Division of Reactor Projects l

Approved By: J. l. Tapia, Chief, Projects Branch A

Division of Reactor Projects ,

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ATTACHMENT: Supplemental Information

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9708000020 970005

PDR ADOCK 05000445

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EXECUTIVE SUMMARY

Comanche Peak Steam Electric Station, Units 1 and 2  ;

NRC Inspection Report 50-445/97-15; 50-446/97-15 '

Operations

I * The conduct of operations was professional and included safe practices

(Section 01.1).

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• The inspectors found that operators handled the loss of Reactor Coolant Pump 2-02 1

breaker indication well and that the licensee's plan to refurbish the breaker during

the upcoming outage was appropriate (Section 01.2).

• The inspectors concluded that operations management used appropriate judgment in

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performing the heater drain tank valve maintenance at 100 percent power. The use

of the simulator prior to the maintenance activity was a good practice

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(Section 05.1).

• A violation was identified as a result of the licensee operating Unit 2 above

102 percent thermal power on February 14,1996, for approximately 30 minutes

(Section 08.1).

Maintenance

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• The inverter troubleshooting plan was detailed and indicated a well prepared I

strategy. The operators and technicians demonstrated excellent skills and carefully

performed each task of the troubleshooting plan (Section M1.2).

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• The technicians performed in an excellent manner during a very detailed l

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refurbishment .f Valve X-PV-3584-MO (Section M1.3).

Enaineerina

• The inspector identified a violation where the licensee failed to update design

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drawings and procedures for a design change which limited the travel of the Unit 2

containment pressure relief containment isolation valves (Section E2.1).

! * The inspectors determined that the surveillance procedures did not adequately

implement Technical Specification (TS) Surveillance 4.7.10, in that, a common

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exhaust duct temperature detector provided temperature measurement for two

different safeguard building areas (main steam and feedwater penetration areas),

(Section E3.1).

Plant Sucoort

• Overall, radiological housekeeping was very good; however, four examples of poor

radiological work practices were identified by the inspector (Section R1.1).

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• The inspector concluded that access control was properly implemented and security

personnel demonstrated a good working knowledge of the requirements for

emergency access control (Section S1.1).

• A computer software problem contributed to two individuals entering the protected

area when their key cards should have been deactivated. The failure to deactivate

the two key cards was identified as a noncited violation (Section S3.1).

• The failure of the central alarm operator to reset the containment personnel airlock ,

alarm prior to releasing the compensatory officer is considered a noncited violation j

(Section S4.1). I

• The inspectors identified three examples where the licensee failed to establish

compensatory measures prior to impairing a fire area assembly. These three

examples are considered to be a violation of TS 6.8.1.h (Section F3.1).

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Report Details

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Summary of Plant Status

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Unit 1 and Unit 2 operated at approximately 100 percent power throughout the inspection

period.

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l. Operations  !

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01 Conduct of Operations

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01.1 Plant Tours (71707) l

a. Inspection Scope

The inspectors conducted frequent plant tours to inspect general plant material and

housekeeping conditions. As part of the tours, the inspectors performed routine

control room observations.

b. Observations and Findinas

Overall, the inspectors determined that plant housekeeping and material condition of  !

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plant equipment was very good. Readily observed equipment discrepancies were

appropriately identified for repair. The inspectors did identify that Emergency Diesel

Generator Room 2-01 contained several areas that needed housekeeping attention. l

A plastic bucket (approximately 1 gallon) used as an oil catch was completely full  !

and overflowing. In addition, the inspectors identified a large pool of oil beneath tne l

generator end of the engine and numerous oil soaked pads. When the licensee was

informed of these observations, the areas were immediately cleaned up. The

inspectors identified other areas that needed minor housekeeping attention and

these areas were immediately addressed by the licensee.  ;

The inspectors observed several shift turnovers and conducted numerous

observations of control room activities and determined that the conduct of

operations was professional and safe. Operators were aware of plant conditions

and ongoing riaintenance. Communications were generally good with consistent

use of three-ivay communication techniques (command, repeat back, and

acknowledgement).

01.2 Loss c,f Reactor Coolant Pumo 2-01 Breaker Closed Indication

a. Insoection Scope (71707)

On June 27, a licensed operator identified that the closed breaker indication for

Reactor Coolant Pump 2-02 was not lit on the control board or on the breaker

cabinet. The licensee entered the action requirement for Technical Specification (TS) 3.8.4, " Containment Penetration Overcurrent Protective Devices." Pushin.~ an

the breaker housing restored the closed indication. The inspectors reviewed the

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effect that the loss of indication had on the operation of the reactor coolant pump

breaker and on reactor safety, and reviewed the licensee's immediate and long-term

corrective actions.

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b. Observations and Findinas

The breaker overcurrent and underfrequency trip functions were part of the same

circuit as the breaker closed indication. As a result, the loss of indication affected

the ability to trip the breaker both manually and automatically on overcurrent or ,

underfrequency. The licensee pushed on the breaker and reestablished the j

secondary stab contacts on the breaker, which, in part, provided the previously

discussed protective functions. The breaker will be refurbished during the upcoming

refueling outage. The undervoltage-based and underfrequency-based reactor

coolant system low flow trip inputs to the reactor protection system were provided

by circuits separate from the breaker and were not affected by the loss of

indication.

Technical Specification 3.8.4 required that all containment penetration overcurrent

protective devices be operable. Final Safety Analysis Report Section 8.3.1.2

stated, in part, that the electric penetration assembly design is capable of

withstanding, without loss of mechanical integrity, the maximum current versus

time conditions permitted by backup protective devices. Since the primary  ;

overcurrent protective device was inoperable, the licensee entered the action

statement and then restored the protective device prior to exceeding the allowed

outage time. t

c. Conclusions

The inspectors found that the licensee handled the loss of Reactor Coolant

Pump 2-02 breaker indication well and that the licensee's plan to refurbish the

breaker during the upcoming outage was appropriate.

04 Operator Knowledge and Performance

04.1 Operations Surveillance Observations (71707,61726)

The inspector used Inspection Procedures 71707 and 61726 to observe:

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• Unit 1 Slave Relay K601 actuation test

The reactor operator performing the slave relay actuation test conducted the

test using excellent self-verification and communication techniques. The

operator meticulously worked his way through the test procedure and

ensured that all equipment responded as required. During the review of the

surveillance work order (WO), the inspector determined that the TS impacted

by the testing, as noted in the WO, did not match the surveillance procedure

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TS listing. The inspector verified that the surveillance test procedure was

correct by ensuring that the Master Surveillance Test List corresponded with

the surveillance test procedure. A TS amendment changed numerous TS

requirements, however, the WO data base had not been revised to reflect the

changes. Operations personnel updated the WO data base for this test with  :

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the correct TS surveillance references.

• Unit 2 boric acid transfer pump operational test.

The inspector found that the test was properly conducted.

05 Operator Training and Qualification

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O.5.1 Observation of Trainina for Abnormal Heater Drain System O_peration

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a. Inspection Scope (71707)

The inspectors observed meetings and training associated with the planned online

maintenance on the Unit 1 combined heater drain tank level control

Valve-HV-2592.

b. Observations and Findinas j

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On June 17, Valve 1-HV-2592 failed to maintain control of the heater drain tank

levels for both tanks. Operators determined that the valve would only cycle I

between 75 to 100 percent open. Subsequently, heater drain tank levels began to i

decrease and operators took actions to throttle the heater drain pump discharge i

manual isolation valves in order to maintain tank levels in the normal band. l

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On June 18, licensee management decided to repair the heater drain tank combined

outlet valve at power. Numerous discussions took place concerning the best plant i

configuration in which to work the valve. The two options discussed were to

remain at 100 percent power or down power to approximately 70 percent and

remove the heater drain pumps from service. Both options involved some risks.

Initially, the operations supervisor decided that the preferred method would be to

reduce power in order to minimize any secondary plant transients. A draft

procedure was written to manually control heater drain tank levels while reducing i

reactor power.

The inspectors observed operations personnel in the simulator performing the draft

procedure with various training and management personnel observing plant and

personnel recponse. The inspectors observed good discussions concerning the

proposed impact of power changes to the heater drain systems and actions to be

taken in case of unexpected loss of heater drain tank levels. The shift manager and

the operations supervisor stressed to the simulator crew that the downpower should

proceed slowly with good coordination between the reactor operator and the

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operator maintaining heater drain tank levels. Operators were able to easily control

heater drain tank level using the draft procedure. ,

Work on Valve 1-HV-2592 was scheduled for later that evening based on the arrival

of parts. - Prior to commencing the work, the inspectors were informed that the

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decision was made to work on the valve at 100 percent power. The operations

supervisor stated that this decision was reached after determining that the heater

drain tank level could be controlled at 100 percent power. The operations

supervisor indicated that performing the evolution at 100 percent could cause a

more severe secondary transient if one were to occur, however, he did not want to

unduly challenge the operators by intentionally varying mass flow inputs to the

heater drain tanks and possibly inducing a secondary transient.

, The valve work was completed at approximately 11 p.m. without any operational

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problems. The inspectors reviewed the temporary modification used to gag open

, Valve 1-HV-2592 and the procedure used to control heater drain tank levels. Tank

levels were maintained by throttling the manual discharge valves and controlling

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tank recirculation flow. The inspectors determined that the modification and

procedure change were appropriate.

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c. Conclusions

, The inspectors concluded that operations management used appropriate judgment in

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performing the heater drain tank valve maintenance at 100 percent power. The use

of the simulator prior to the maintenance activity was a good practice.

08 Miscellaneous Operations issues (92901)

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08.1 (Closed) Unresolved item 50-446/9601-01: operation of Unit 2 at greater than

100 percent power. After further review, the staff concluded that operating Unit 2

at greater than 102 percent was a violation of TSs. TS 6.8.1 requires the licensee

to establish, implement, and maintain procedures covering the activities referenced

in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A

requires general plant operating procedures for power operation, startup and

shutdown of safety-related systems, and conducting maintenance. Integrated Plant

Operating Procedure Number IPO-0038, " Power Operations," Revision 2,

Section 5.5, stated, in part, that thermal power shall not exceed 102 percent.

Contrary to this requirement, the licensee operated Unit 2 above 102 percent

thermal power on February 14,1996, from approximately 10:10 a.m. to 10:40 a.m.

(50-446/9715-01).

The inspectors also concluded that Instrument and Control Manual Instruction

ICl-4126B, " Calibration Condensate Pumps Discharge Header Pressure

Channel 2240 [ sic)," was inadequately written in that the procedure allowed

calibration of Channel 2240 while in Mode 1 and did not take provisions to prevent

or mitigate the effects of a loss of feedwater heaters. Performing the instruction in

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Mode 1 caused a loss of feedwater heaters and contribugt -' to operating Unit 2

above 102 percent. W

The inspectors reviewed the corrective actions listed in NRC Inspection Report

Numbers 50-445(446)/9601 and 50-445(446)/9604, and in TU Electric Letter

TXX-96075 dated March 25,1996. The inspectors found the corrective actions

reasonable and complete.

II. Maintenance

M1 Conduct of Maintenance

M 1.1 General Comments

a. Inspection Scope (62707)

The inspectors observed all or portions of the following work activities:

• Unit 1 inverters IV1C2 and IV1C3 troubleshooting

• Unit 2 Floor Drain Tank 2 cleaning

• Unit 2 containment preoutage modifications

• Unit 2 Train B emergency diesel generator governor design modification

installation

• Unit 2 N16/Tave (Protection Sat IV) analog channel operational test

• Control room air conditioning condenser component cooling water return

valve motor operator rebuild

• Laundry holdup and monitor tank cleaning

b. Observations and Findinas

The inspectors found the work performed under these activities professional and

thorough. Specific details are listed below.

M1.2 Troubleshootina on Inverters IV1C2 and IV1C3

a. Inspection Scope (62707)

The inspectors reviewed the troubleshooting plan and observed portions of the

troubleshooting activities performed on the two inverters.

b. Observations and Findinas

Troubleshooting was conducted in an attempt to determine the cause of the

inadvertent transfer of the inverters to their bypass power source during battery

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charger swapping. On several occasions, the inverters transferred to bypass power

without any indication of abnormal conditions.

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The inspectors reviewed the troubleshooting plan and found that the plan was very

l detailed and gave detailed instructions regarding actual troubleshooting. The plan

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also specified precise equipment lineups and configuration changes.

Prior to performing the troubleshooting, the shift manager briefed operations and

maintenance personnel on the overall scope of the work activity. Precautions and

limitations were discussed and an emphasis was placed on ensuring a safe and

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controlled evolution.

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Both operations and maintenance personnel used excellent self-checking and peer-

checking techniques prior to component manipulation. Operations and mairitenance

supervisors were present and provided appropriate oversight.

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As a result of information obtained during the troubleshooting, the licensee planned

to change battery charger operating procedures and to replace the battery charger

capacitors.

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c. Conclusions

The inverter troubleshooting plan was detailed and was indicative of a well prepared

strategy. The operators and technicians demonstrated excellent skills and carefully

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performed each task of the troubleshooting plan.

j M1.3 Rebuild of Control Room Air Conditioner Motor Operated Valve

a. Inspection Scope (62707)

The inspector observed partial performance of the refurbishment of

Valve X-PV 3584-MO, control room air conditioning Unit X-02 refrigerant condenser

component cooling water return pressure control valve.

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b. Observations and Findinas

On June 8, the inspector observed two technicians overhaul the motor operator j

ectuator and gearhead assembly for Valve X-PV-3584-MO. The technicians

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performed a detailed inspection of allinternal components and either replaced or  !

! repaired damaged components. Slightly damaged components (burrs, scratches, l

J etc.) were reworked using excellent work practices.

. A quality control inspector inspected new and reused components associated with

the motor operator actuator. The inspection was cursory and not as meticulous as

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the inspection performed by the technicians, however, the inspector determined

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that the quality control inspector did an adequate inspection of the parts.

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The inspector reviewed Technical Manual 661-76268-003, "Limitorque Operation

and Maintenance Manual and Bulletins," and determined that appropriate

maintenance guidance had been incorporated into Procedure MSE-CO-8805.

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c. Conclusions

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The technicians performed in an excellent manner during a very detailed

refurbishment of Valve X-PV-3584-MO.

i M4 Maintenance * Staff Knowledge and Performance

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M4.1 Containment Entry (71707 and 92902)

On June 25, the inspector observed ongoing preoutage modification work inside the

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Unit 2 Containment. This included observing the logging of materialin and out of

containment using Form STA-625-1, " Material / Accountability Log," and the

!' containment closeout process per Procedure STA-620, " Containment Entry,"

Revision 11. The inspector also observed radiation protection personnel monitoring

radiation levels in the work areas, and logging stay times for recording neutron

doses as required per Procedure RPI 515, " Neutron Dose Measurement and

Recording," Revision 8. In interviewing several workers, the inspector found all

workers were aware of the recent revision to STA-620 and knowledgeable of the

changes made in response to a violation of containment entry procedures identified

in NRC Inspection Report 50-445(446)/97-14.

Ill. Enaineerina

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E2 Engineering Support of Facilities and Equipment

E2.1 Containment Pressure Relief System

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l a. Inspection Scone (37551)

The inspector reviewed the TS and design basis for the containment pressure relief

system. In addition, the inspector interviewed various licensee personnel

concerning the operation and maintenance of the system.  ;

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b. Observations ano Findinas

While reviewing operating logs, the inspector determined that both Units 1 and 2

containments were being vented every 3 to 4 days for periods lasting approximately

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6 to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. On average, this would equate to approximately 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per year.

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The inspector reviewed TS 3.6.1.7 and determined that the licensee appropriately

implemented the TS. NUREG-0797, " Safety Evaluation Report related to the

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operation of Comanche Peak Steam Electric Station, Units 1 and 2," Section 6.2.3,

determined that the use of the containment pressure relief system was limited to 90  !

hours of operation per year. Followup conversations with engineering personnel

identified that this was changed during licensing as a result of standard TS 3.6.1.8

which allowed containment purge valves with diameters of 3 inches or less to be .

open continuously. The licensee installed an orifice plate that effectively limited the :

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pipe diameter to 3 inches. Based on this change, the approved TS allows the

containment pressure relief valves to be open continuously.

NUREG 0797, Supplement 23, Section ll.E.4.2, ensured that the valves could shut j

against containment design pressure without damaging the pressure relief ,

containment isolation valves by limiting travel to 65 degrees open. Design Basis '

Document DBD-ME-301, " Containment Air Cleanup Systems," Revision 7, also

stated that the valves were limited in travel to 65 degrees open.  !

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Maintenance personnel reviewed Procedures MSM-CO-6500, " Matrix Actuator

Maintenance with Master Operator", Rev.1 and MSM-CO-8600, "Posi-Seal

Trunnion Valve Maintenance", Rev.1, both associated with the maintenance for

these valves, and could not find any reference to a mechanical stop which limited

disc travel. The inspector reviewed the technical manual and Valve Drawings

14758-2 (1-HV- 5548 and 5549) and 14759-2 (2-HV-5548 and 5549) and did not i

identify any reference to the mechanical stop. On June 16, the system engineer

identified that DCN 906 was implemented for Unit 1 to limit valve travel to 65

degrees open, however, the modification was not referenced on Unit 2 Valve

Drawing 14759-2.  !

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The inspector reviewed DCN 906 and preoperational test data and determined that  ;

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the mechanical stops had been installed on both units for the pressure relief

containment isolation Valves 1-HV-5548,1-HV-5549, 2-HV-5548, and 2-HV-5549.

The test data verified that valve travel was limited to 65 degrees open. The

inspector was concerned that the valves may have been reworked or replaced since

initial installation and possibly that the mechanical stop was not installed. Licensee

personnel searched the maintenance history data base and determined that the air i

actuators for the valves had not been replaced or reworked.

Subsequent to this finding, licensee personnel initiated DCN 11370, Revision 0, to

document that Unit 2 Valves 2-HV-5548 and 5549 were limited to 65 degrees open ,

by a mechanical stop. In addition, Procedures MSM-CO-6500 and MSM-CO-8600 ,

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were revised to reflect that valve travel was limited to a meximum of 65 degrees

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open. The corrective actions were determined to be appropriate and complete. l

10 CFR Part 50, Appendix B, Criterion lil, states in part that measures shall be )

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established to assure that the design basis, as defined in Part 50.2 and as specified 1

in the license application, is correctly translated into specifications, drawings, i

procedures, and instructions. Design changes, including field changes, shall be  ;

subject to design-control measures commensurate with those applied to the original

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design and approved by the organization that performed the original design. The

failure to update Valve Drawing 14759-2 or to have procedures in place describing

the mechanical stop is a violation of 10 CFR Part 50, Appendix B, Criterion ill

(50-446/9715-02).

c. Conclusions

The inspector identified a violation wherein the licensee failed to update design

drawings and procedures for a design change which limited the travel of the Unit 2

containment pressere relief containment isolation valves.

E3 Engineering Procedures and Documentation (92903)

E3.1 Main Steam Penetration Area Temoeratures

a. Inspection Scope (37551)

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The inspectors reviewed selected areas of routine shift tog taking for compliance

with TS 3/4.7.10, " Area Temperature Monitors." The inspectors measured selected

component temperatures and air temperatures in the Unit 1 main steam penetration

areas.

b. Observations and Findinas

TS Surveillance Requirement 4.7.10 requires that the temperature in each of the l

areas shown in Table 3.7-3 be determined to be within its limit at least once per 12

hours. Table 3.7-3 lists the maximum temperature limit of normal safeguards

buildings areas under normai conditions to be 104*F. The main steam penetration

areas and the feedwater penetration areas are in normal safeguards buildings areas

and are therefore subject to the 104 *F maximum temperature limitation.

Operations Testing Manual Procedures OPT-102A, Revision 8, (Unit 1) and

OPT-1028, Revision 2, (Unit 2), " Operations Shiftly Routine Tests," implemented i

Surveillance Requirement 4.7.10. Procedure OPT-102 required that Temperature

Indicators 1-TI-5624 (Unit 1) and 2-TI-5624 (Unit 2) be recorded to determine that

the main steam penetration area temperatures were within their limit.

The inspectors found that Temperature Indicators 1-TI-5624 and 2-TI-5624

measured the bulk room air temperatures of the main steam penetration area and

the feedwater penetration areas after the air had been mixed in a common exhaust

duct and were located approximately 20 feet in adjoining rooms. The air

temperature in the Unit 1 adjoining room was measured to be approximately 20 F

cooler than the measured temperature. The inspectors concluded that the location

l of the indicators may not be representative of the actual conditions in each of the

areas.

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The inspectors measured the ambient air temperatures and selected component

temperatures in the Unit 1 main steam penetration areas. While most of the air

temperatures were less than the limit, the air temperatures of equipment associated

with Steam Generator 1-01 were approximately 5 to 6 F above the normal

conditions limit of 104 F. Measured locations were selected to be away from hot

steam piping and out of the direct path of ventilation. An exhaust plenum contact j

temperature of 110 F from this area validated the measurements from the selected l

locations. During this time, Temperature Indicator 1-TI-5624 indicated that the bu!k

air temperature from the main steam penetration areas and feedwater penetration

areas was approximately 102 F.

During meetings with engineering personnel, they stated that the environmental 4

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qualification temperature and component life were based on the conservative

assumption that the components experienced the temperatum 'imit continuously.

They also explained that temperatures of the measured areas and components

fluctuated with environmental conditions and typically approached TS limits only I

during the late af ternoon of the summer months. Based on this conservative

assumption, the licensee concluded that operability was not affected. However, the

licensee did initiate an Operations Notification and Evaluation (ONE) form to review

the environmental qualification program measurement techniques and assumptions.

The inspectors concluded that Procedures OPT-102A and OPT-102B did not I

adequately implement the surveil!ance requirement in that the location of the l

temperature indicators in common exhaust ducts prevented the licensee from j

determining that the temperature of each area was within the limit. Area  !

temperatures in excess of the limit would not be identified if the exhaust air flows I

from other areas were sufficiently greater than or cooler than that from the affecei

area. The failure to adequately implement the requirements of Surveillance

Requirement 4.7.10 in Procedures OPT-102A and OPT-102B is a violation of 10 j

CFR Part 50, Appendix B, Criterion V (50-445(446)/9715-03).

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c. Conclusions

The inspectors determined that the surveillance procedures did not adequately

implement TS Surveillance 4.7.10, in that, a common exhaust duct temperature

detector provided temperature measurement for two different safeguard building

areas (main steam and feedwater penetration areas).

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E6 Engineering Organization and Administration

! E6.1 Operational Review Subcommittee Meetina

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The inspectors attended a presentation on the axial offset anomaly given to

members of the maintenance and engineering Operational Review Subcommittee.

The presentation focused on measures to reduce the anomaly during the current

operating cycle and on redesign of the Unit 2 Cycle 4 core (October 1997 refueling

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outage) to minimize axial offset. The presentation was informational and the

subcommittee members openly participated.

IV. Plant Support

3 R1 Radiological Protection and Chemistry Controls

R 1.1 Tour of Auxiliary Buildina

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a. Inspection Scope (71707 and 71750)

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The inspectors performed a tour of the radiation controlled area (RCA) to verify that

areas were properly posted for given radiological conditions and to observe

, radiological practices.

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I b. Observations and Findinas

The inspectors found that areas were properly posted and that overall radiological

housekeeping was very good, however, during the walkdown of Room X-213, a

radioactive material storage area, the inspector identified a pump hose with a

contact dose rate of 4.5 mrem / hour. The hose did not have a radioactive material

tag attached. Procedure STA-652, " Radioactive Material Control," Revision 7,

Section 6.6 specified that a radioactive material tag should (management

expectation) be attached to equipment with a contact dose rate greater than

2 mrem / hour. In addition, the hose ends were not taped closed or capped which i

was also contrary to a management expectation as stated in Procedure STA-653, l

" Contamination Control Program," Revision 6, Section 6.5. l

A radiation protection technician immediately attached a radioactive material tag l

and tapped the hose ends. ONE Form 97-693 was initiated to document these l

discrepancies.

On July 2, while exiting the RCA, the inspectors observed a small article monitor

(SAM) alarming with low activity indicated. A radiation protection technician

opened the monitor and picked up the flashlight without wearing protective gloves.

Subsequent frisking of the flashlight indicated no contamination. The inspectors

discussed the practice of not using gloves to pick up potentially contaminated items

with the technician and a radiation protection supervisor both of whom indicated

that this was a poor practice.

On July 16, while exiting the RCA, the inspectors observed another poor

radiological work practice associated with the use of the SAM. The SAM alarmed

on low activity and the individual removed his design modification package with a

gloved hand; however, he opened the package and removed severalitems with his

ungioved hand and placed the items back in the SAM. Allitems were determined to

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be clean. The inspectors discussed this poor work practice with the individual and

a radiation protection technician.

c. Conclusions

Overall, radiological housekeeping was very good; however, four examples of poor

radiological work practices were identified by the inspector.

S1 Conduct of Security and Safeguards Activities (71750)

S 1.1 Physical Security

a. Insnection Scope (71750)

Using Inspection Procedure 71750 during routine tours in the protected and vital

areas, the inspector observed various aspects of physical security.

b. Observations and Findinas

On June 16, the inspector observed security officers performing normal access

control to the protected area. Security officers were found to be knowledgeable of

the requirements for access control to the protected area during emergencies for

NRC employees, emergency response personnel, and emergency vehicles. The

inspector independently verified that licensee designated vehicle numbers of several

licensee designated vehicles in the protected area were on the authorized vehicle

access list. No keys were found in unattended vehicles in the protected area,

c. Conclusions

The inspector concluded that access control was properly implemented and security

personnel demonstrated a good working knowledge of the requirements for

emergency access control.

S3 Security and Safeguards Procedures and Documentation

S3.1 Access Authorization

a. Inspection Scope (71707 and 71750)

During a routine review of ONE Forms, the inspector identified a concern with

access authorization.

b. Observations and Findinas

ONE Form 97-650 identified that on June 20, the licensee discovered that a key

card was not deactivated per the request of the fitness for duty coordinator.

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1 Security manual records indicated that the badge was deactivated on May 19, i

however, the individual entered the protected area three times after May 19. ONE

j Form 97-676 identified that on June 27, another instance was discovered where a j

key card was not deactivated per the request of the fitness for duty coordinator.

Security logs indicated that the badge was deactivated on June 25, however, the

. individual entered the protected area on June 27. l

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The key cards were deactivated because the individuals were infrequcntly onsite

and not available for their scheduled fitness for duty test. Procedure STA-910,

, " Fitness for Duty Program," Revision 2, Section 6.8.4.7, required that if an

individual is unavailable for random testing because he or she is only onsite

occasionally, their access shall be deactivated until a urine specimen is provided.

The security manager indicated that a computer software problem allowed these

events to occur. If data was entered and not updated within approximately 90

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seconds, then the computer data base was not updated. Followup conversations

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with the security manager identified that the software was modified to prevent this

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from recurring and that positive verifications of data base information was required j

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for all key card deactivations. The inspector reviewed Security instruction 3.13,

" Key Card Control," Revision 7, and determined that the changes, as described by

the security manager, were incorporated into the procedure. The inspector

determined that the corrective actions taken by the licensee were prompt and

should prevent recurrence.

In addition, the manager stated that no other examples were identified where fitness I

for duty testing access authorization were not properly deactivated. When

! questioned about reviewing deactivation of access authorization for other issues, I

j the security manager stated that they had not looked generically at the issue;

however, after reviewing all of the key card deactivations for the prior 12 months,

no other instances were identified.

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Technical Specification 6.8.1 requires that written procedures be established,

implemented, and maintained covering the activities recommended in Regulatory

Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Appendix A, Section

1.a, recommends that procedures be written covering security and visitor control.

This licensee-identified and corrected violation is being treated as a Noncited

Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

(NCV 50-445(446)/9715-04)

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c. Conclusions

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A computer software problem contributed to two individuals entering the protected

area when their key cards should have been deactivated. The failure to deactivate

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the two key cards was identified as a noncited violation.

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S4 Security and Safeguards Staff Knowledge and Performance

S4.1 Failure to Reset Security Alarm (71750 and 92904)

At approximately 5:17 p.m. on June 25, the licensee identified that the security

alarm on the Unit 2 personnel containment hatch had not been reset, as required by

Security instruction 3.10, " Alarm Stations," Rev. 9, prior to releasing the security _

compensatory officer after containment closecut, at 4:25 p.m. Upon discovery, the

central alarm station operator immediately reset the alarm and the licensee reported

a 1-hour Reportable Safeguards Event to_the NRC per 10 CFR 73.31(a)(1). Security j

personnel verified that both the Security and Radiation Protection containment hatch i

padlocks were in place, and walked down the RCA and found no unauthorized

personnel or activity. A review of control room alarms, security access logs, and

sector reports revealed no unauthorized entries. The licensee determined that there

was no opportunity for unauthorized or undetected access, and no such access had,

in fact, occurred because (1) both containment hatch padlocks were verified to be

iocked and in place and (2) no door alarms (independent of the security alarm) were

received in the control room. Based on this the licensee determined that this event

was only required to be logged, and retracted the 1-hour report. Security

management issued immediate instruction to emphasize the requirement for alarm

station operators to reset alarms prior to releasing compensatory officers.

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The failure of the central alarm operator to reset the alarm prior to releasing the l

compensatory officer is considered to be a violation of procedure of minor

significance and is being treated as a Noncited Violation, consistent with Section IV

of the NRC Enforcement Policy (NCV 50-445(446)/9715-05).

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F4 Fire Protection Staff Knowledge and Performance j

F3.1 Inadeauate Imolementation of Fire Protection Proaram Reauirements

a. Insoection Scope (71707. 71750) ,

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The inspectors observed work associated with the cleaning of Unit 2 Floor Drain

Tank 2 conducted in accordance with WO 3-97-318184-01. The inspectors

reviewed the work package for adherence to procedures, and held discussions with

licensee personnel. The inspector reviewed the Fire Protection Report to

independently determine the effect of the work on Unit 2 fire protection barriers.

b. Observations and Findinas i

On June 19, the inspector observed the removal of liquid waste and associated

drain tank cleaning equipment from Room 2-061, elevation 773, to Room 2-070,

elevation 790, in the Unit 2 safeguards building. The work required the removal of

a floor plug on elevation 790. The inspector noted that the STA-738, Form 2, " Fire

Protection System / Equipment impairment Form," in the work package had been.

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crossed out and marked as not applicable. In questioning fire protection personnel, l

the inspectors were informed that Form STA-738-2 was not necessary because i

Rooms 2-061 and 2-070 were in the same fire area. The inspectors independently  ;

reviewed fire area boundaries shown on Figures FPR-25 sheets 1 and 2 of the Fire i

Protection Report and found that Rooms 2-061 and 2-070 were in different fire l

areas and, therefore, the removal of the floor plug breached a fire barrier. Upon

identification by the inspectors, the licensee established the required compensatory I

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measures and initiated a ONE form. The licensee's investigation found that

Form STA-738-2 was incorrectly processed due to human error when a fire

protection technician reviewed fire protection drawings for Unit 1 rather than

Unit 2.

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in reviewing ONE forms, the inspectors noted two ONE forms having recently been

( written on fire impairment issues. The inspectors requested a listing of all ONE

forms written on fire impairrnents in the last 6 months and found similar errors. On

March 15, the licensee failed to initiate the required compensatory measures prior to

impairing a fire assembly when a concrete floor plug was removed from the 810

elevation of the Fuel Building. On' July 16, the licensee again f ailed to establish

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compensatory measures prior to impairing a fire area assembly when a concrete

! floor plug was removed from the 810 elevation of the Unit 1 Safeguards Building.

The inspectors found that the licensee failed to follow procedure on three separate

occasions when fire assemblies were impaired prior to implementing compensatory

measures as required by procedure S. A-738. In addition, the inspectors found that l

corrective actions for a previous failure to be very limited in scope and ineffective to

( prevent recurrence.

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TS 6.8.1.h states, in part, that written procedures covering fire protection program

implementation be established and implemented. Procedure STA-738, " Fire

l Protection Systems / Equipment impairments," Revision 5 required that any fire

l protection systern/ equipment needing to be impaired to support work activities shall

have a Fire Protection impairment Form STA-738-2 initiated and the necessary

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compensatory measures put in place prior to the item being impaired. The failure to

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establish compensatory measures prior to impairing fire area assemblies is a

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violation of TS 6.8.1.h (50-445(446)/9715-06). i

c. Conclusions

The f ailure to establish compensatory measures prior to impairing a fire area

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assemblies as required by procedure on three occasions is a violation of TS 6.8.1.h.

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V. Manaaement Meetinas

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X1 Exit Meeting Summary  ;

The inspector presented the results of the inspection to members of licensee management ,

at the conclusion of the inspection on July 25,1997. The licensee acknowledgad the

findir'gs presented. No proprietary information was identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Curtis, J. R., Radiation Protection Manager

Davis, D. L., Nuclear Overview Manager

Killgore, M. R., Nuclear Enginee ing Manager

Lancaster, B. T., Plant Support Manager l

Moore,.D. R., Operations Manager ,

Terry, C. L Group Vice Presidcot, Nuclear Production I

Walker, R. D., Regulatory Affairs Manager

INSPECTION PROCEDURES USED

37551 Onsite Engineering

61726 Surveillance Observations

62707 Maintenance Observations

71707 Plant Operations

71750 Plant Support Activities l

92901 Followup - Operations j

92902 Followup - Maintenance

92904 Followup - Plant Support

ITEMS OPENED. CLOSED. AND DISCUSSED  !

Opened

50-446/9715-01 VIO Operation in excess of 102 percent thermal power

(Section 08.1)

50-446/9715-02 VIO Failute to update valve drawing or to have procedures

in place describing the mechanical stop (Section E2.1)

50-445(446)/9715-03 VIO Inadequate surveillance procedure (Section E3.1)

50-445(446)/9715-04 NCV Failure to deactivate key cards (Section S3.1)

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50-445(446)/9715-05 NCV Failure of the central alarm operator to reset the

containment personnel airlock alarm prior to releasing

the compensatory officer (Section S4.1)

50-445(446)/9715-06 VIO Failure to establish compensatory measures prior to

impairing a fire protection assembly (Section F3.1)

Closed

50-446/9601-01 URI Operation of Unit 2 at greater than 100 percent power

(Section 08.1)

50-445(446)/9715-04 NCV Failure to deactivate key cards (Section S3.1)

50-445(446)/9715-06 NCV Failure to establish compensatory measures prior to

impairing a fire protection assembly (Section F3.1)

LIST OF ACRONYMS USED

IFl inspection followup item

NCV noncited violation

ONE Operations Notification and Evaluation

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PDR Public Document Room

RCA radiation controlled area

SAM small article monitor

TS Technical Specification

URI unresolved item

VIO violation

WO Work Order