ML20244A883

Insp Repts 50-369/89-01 & 50-370/89-01 on 890120-0227. Violations Noted.Major Areas Inspected:Operations Safety Verification,Surveillance Testing,Maint Activities & Review of Plant Procedures

ML20244A883
Person / Time
Site:	McGuire, Mcguire
Issue date:	03/29/1989
From:	Croteau R, Shymlock M, Vandoorn K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20244A875	List: IR 05000369/1989001 ML20244A873 ML20244A880 ML20244A883
References
50-369-89-01, 50-369-89-1, 50-370-89-01, 50-370-89-1, GL-88-17, IEB-85-003, IEB-85-3, NUDOCS 8904180247
Download: ML20244A883 (19)

See also: IR 05000369/1989001

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NUCLEAR REGULATORY COMMISSION

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J: REGION ll

101 MARIETTA ST.. N.W.

. %+, , , , *j ATLANTA, GEORGIA 30323

Report Nos. 50-369/89-01 and 50-370/89-01

Licensee: Duke Power Company

422 South Church. Street

Charlotte, NC 28242

Facility Name: McGuire Nuclear Station 1 and 2

Docket.No(s): 50-369 and 50-370

License No(s): NPF-9 and NPF-17

Inspection Conducted: an ry 20, 1989 - February 27, 1989

Inspectors: .

K. Y I)o n

M  !/t./ at( Signed

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SeniorRf1dentInspector

$/ S/ k?

f.~Crte','esident/spector

R /Date' Signed ,

Approved-by:. .

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M a .'Shymlock, Segfion Chief D6te sign #d i

Division of Reactor Projects

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SUMMARY

Scope: This routine unannounced inspection involved the areas of operations

safety verification, surveillance testing, maintenance activities,

review cf plant procedures, drawing system verification and follow-up

on previous inspection findings.

Results: In the areas inspected, the following issues were identified:

Violation 369,370/89-01-01, Failure to Follow Maintenance

Administrative Procedure. Three examples were identified involving

l perfonning work without a work request and improper acceptance of

j' operational control following maintenance. (Paragraphs 5 and 6)

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! Licensee Identified Violation 369/89-01-02, Missed TS Surveillance on

Snubbers. (Paragraph 6)

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Licensee Identified Violation 369/89-01-03, Breach of Fire Barriers.

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(Paragraph 6)

Violation 369/89-01-04, Inadem> ate Chemistry Procedure Leading to

Inadvertent Dilution. (Paragraph 6) ,

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Violation 369,370/89-01-05, Followup of Improvements in Control Room '

Drawing Control. For reasons described in the report no Notice of i

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Violation is being issued for.this violation. (Paragraph 10)

Inspector Followup Item 369,370/89-01-06, Written Guidance on Use of  !

Procedures. (Paragraph 11)

Violation 369,370/89-01-07, Failure to Follow Procedures With Respect to '

Writing Problem Investigation Reports (PIRs). (Paragraph 12)

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REPORT DETAILS

'1. Persons Contacted-

Licensee Employees

• J.'Boyle, Superintendent of Integratea Scheduling

• G. Gilbert, Acting Superintendent of Technical Services

• T. McConnell, Plant Manager

W. Reeside, Operations-Enginesr

M. Sample, Superintendent ofiiaintenance

• R. Sharp, Compliance Engineer

J. Snyder, Performance Engineer

• B. Travis, Superintendent of Operations

R. White, Instrument and Electrical Engineer

Other licensee employees contacted included construction craftsmen,.

technicians, operators, mechanics, security force members, and office _

personnel.

• Attended exit interview

2. Unresolved Items

An unresolved item (UNR) is a matter about which more information is

required to determine whether it is acceptable or mayl involve a violation

or deviation. There were no unresolved items identified in this report.

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3. Plant Operations (71707, 71710)

The inspection staff reviewed plant operations during the report period to

verify conformance with applicable regulatory requirements. Control room

logs, shift supervisors' logs, shift turnover records .and equipment

removal and restoration records were routinely reviewed. Interviews were

conducted with plant operations, maintenance, chemistry, health physics,

and performance personnel.

Activities within the control room were monitored during shifts and at

shift ~ changes. Actions and/or activities observed were conducted as

prescribed in applicable station administrative directives. The complement

of licensed personnel on each shift met or exceeded the minimum required

by Technical Specifications.

Plant tours taken during the reporting period included, but were not  ;

limited to, the turbine buildings, the auxiliary building, Units 1 and 2 4

electrical equipment rooms, Units 1 and 2 cable spreading rooms, and the i

station yard zone inside the protected area. j

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During the plant tours, ongoing activities, housekeeping, security, l

equipment status and radiation control practices were observed. j

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A detailed walkdown of the accessible portions of the Unit 1 auxiliary  ;

feedwater (CA) system was conducted by the inspectors. A CA Resistance (

Temperature Detector (RTD) was found disconnected and details are  !

contained in paragraph 5. l

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The inspectors reviewed the licensees progress relative to Generic  ;

Letter 88-17, Loss of Decay Heat Removal . The licensee appears to be  ;

thoroughly addressing the issue with appropriate detailed procedures

under development. Further detailed inspections will be conducted at

a later date.

a. Unit 1 Operations

Unit 1 operated at approximately 100 percent power for most of the

report period. On February 12, 1989, power was reduced to 90 percent

to repair the number two governor valve position indicator which had

failed. The unit returned to full power approximately twelve hours

later. ,

b. Unit 2 Operations

The unit operated at approximate 100 percent power until January 27,

1989. On January 27, 1989, at 4:30 p.m. the licensee observed

indication of main condenser tube leakage on Unit 2. Turbine

generator load was reduced in accordance with procedures to allow

isolating and repairing the leaks. Load was reduced to approximately

40 percent. Three condenser tubes were found leaking and a total of

fifty two tubes were plugged. The unit returned to full power at

10:05 a.m. January 29, 1989. The licensee believes steam impinging

on the conderser tubes from a leaking turbine steam drain valve may

have caused the tube leakage. The leakage from the drain valve was

not stopped, however, and power was again reduced on February 22,

1989, to approximately 85 percent in order to inspect and plug

additional leaking condenser tubes. The un;t returned to full power

on February 22, 1989.  !

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c. At the licensees request, the inspectors reviewed the licensees

progress relative to Generic Letter 88-17, Loss of Decay Heat

Removal. The licensee appears to be thoroughly addressing the issue

with appropriate detailed procedures under development. Further

detailed inspections will be conducted at a later date.

No violations or deviations were identified.

4. SurveillanceTesting(61726)

Selected surveillance tests were analyzed and/or witnessed by the

inspector to ascertain procedural and performance adequacy and conformance  ;

with applicable Technical Specifications. {

Selected tests were witnessed to ascertain that current written approved 1

procedures were available and in use, that test equipment in use was {

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calibrated,-that test prerequisites were met, that. system restoration was I

completed and test results were adequate. {

Detailed'below are selected tests which were either reviewed or witnessed:

PROCEDURE- EQUIPMENT / TEST

PT/2/A/4208/10B 2B NS HX Heat Balance f '

PT/1/A/4200/09A ESF Test

PT/1/A/4206/09A NI Check Valve Movement Test

No violations or deviations were identified.

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5. Maintenance Observations (62703)

a. Routine maintenance activities were reviewed and/or witnessed by the

resident inspection staff to ascertain procedural and performance

adequacy and conformance 'with applicable Technical Specifications.

The selected activities witnessed were examined to ascertain that,

where applicable, current written approved procedures were available

and'in use, that prerequisites were met, that equipment restoration' ,

was completed and maintenance results were adequate, j

Specific maintenance activities observed included:

Activity Work Request No.

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Control Room Activity Door No. 507 Repair 26740 ADM

Troubleshooting Diesel Generator 137753 OPS

2B Battery Charger

Replacement of Power Range 68487 IAE

Nuclear Instrumentation (N41)

Meter and Potentiometer.

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Replace CA-57 96430 NSM

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Repair CA Turbine Trip Mechanism 500488 MNT :l

(ReviewOnly)

b. The . inspectors discussed painting of the auxiliary building relative

to operability of the Auxiliary Building Ventilation System (VA), i

Technical Specification (TS) 4.7.7.b. The TS requires testing after I

painting in zones communicating with the system. By previous  !

agr eement with the NRC - painting was defined as 1,000 square feet of ,

painted area and retesting was to be done after painting each 1,000 l

square feet. The primary concern being carbon degradation in the i

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charcoal absorber. Two years of data has shown negligible effect'on

the carbon, therefore, the inspectors agreed that 5,000 square feet

could be painted and larger amounts dependent on test results. The ,

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licensee requested this relief due to an afiort to improve

housekeeping which includes repainting of the auxiliary building.

The results after 5,000 square feet also showed no effect on the l

carbon and, therefore, the licensee will paint larger amounts and

retest as appropriate. At a minimum tests will be taken monthly.

The inspectors agreed with this approach.

c. On February 4,1989, during a walkdown of the auxiliary feedwater

system, the Resistance Temperature Detector upstream of ICA-65 was

found disconnected by the inspectors. The licensee inspected the

other CA RTDs and found the RTD upstream of 1CA-57 also disconnected i

and others were found damaged. These RTDs are installed to monitor  !

check valve backleakage from the stecm generators to the CA pumps to l

prevent steam binding of the pumps. The CA RTDs were reinstalled,

however, a work request was not used to reinstall them. The RTDs are

strap on devices that attach perpendicularly to the pipe. The straps

were damaged such that the RTDs had slid under the straps and were

parallel to the pipe and could not be reinstalled properly.

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After reinstallation, the RTD upstream of ICA-57 was reading between  !

200 degrees and 246 degrees F; the operability limit is 250  !

degrees F. Attempts were made to reseat the valve with out success.  !

The licensee then decided to replace the valve while on line.

On February 15, 1989, while checking the job site setup prior to

removal of ICA-57, the inspectors found the RTD upstream of ICA-57

again disconnected. Operations was not aware that the RTD had been

disconnected and no work request had been authorized to remove the

RTD. Work Request 96430NSM indicated that the RTD was removed on ,

February 15, 1989, however the work was not cleared to begin until

February 16, 1989. Operations reconnected the RTD and again no work

request was used.

On February 16, 1989, maintenance personnel recorded on week request i

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96430NSM that the CA RTD was already removed prior to starting work.

Valve ICA-57 was replaced on February 16 and 17, 1989.

After replacing 1CA-57 and restoring the system to operation,

operations personnel noted that the RTD was still indicating high

piping temperatures. Upon investigation it was discovered that the

RTD had been incorrectly placed on the valve ICA-57 rather than

further upstream. The RTD was moved, apparently without using a work

request. The RTD continued to read high, though improved, and a fan

was left on the piping to cool the line between the check valve i

and the RTD. McGuire Maintenance Management Procedure (MMP) 1.0,

" Definition of the Work Request Form," describes the use of a work

request form to control work. Paritgraph B under the scope section

specifies that corrective maintenance (replacement and/or repair of

defective parts) shall require a work request. On several occasions,

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as described previously, maintenance was performed in reinstalling

and removing the CA RTDs without an authorized work request. This is

considered a failure to follow administrative procedures and is

identified as a violation of T.S. 6.8.1: 369,370/89-01-01, Failure

to Follow Maintenance Administrative Procedure. {

In reviewing the completed 1CA-57 work request 96430NSM it was noted

that the Operation Control Accepted block was signed by the shift

engineer (shift technical advisor) and not by a member of the

operations department. MMP 1.0 section 2.20 states that the ,

Operation Control Accepted block shall be signed by a responsible

representative of the group that gave clearance to begin work.

Operations gave clearance to begin work and the shift engineer is in

the Integrated Scheduling department. Apparently past practice has

been to allow shift engineers to sign for operators in some

circumstances (primarily for modifications), however, this is not in

accordance with station procedures. The licensee indicated that it '

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is their intent to have shift engineers sign for clearing

modifications in some cases. This is a second example of failure to i

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follow administrative procedures, violation 269,370/89-01-01.

d. The inspector accompanied NRC/NRR personnel to review the licensee's

raw water fouling monitoring program. Heat exhanager and other raw

water fouling is a general industry problem and the NRC is gathering

information in order to develop a generic communication to the

industry. The licensee has developed various methods to maintain

heat exchangers included differential pressure (DP) and heat transfer

testing, periodic cleaning and flushing and continuous DP monitoring

of Component Cooling System heat exchangers. Visual and ultrasonic  !

testing is also being utilized. These programs have been and will

continue to be monitered by the NRC.

One violation was identified in this area. (Also see paragraph 6).

6. Licensee Event Report (LER) Followup (90712,92700)

The following LERs were reviewed to determine whether reporting

requirements have been met, the cause appears accurate, the corrective

actions appear appropriate, generic applicability has been considered, and

whether the event is related to previous events. Selected LERs were

chosen for more detailed followup in verifying the nature, impact, and

cause of the event as well as corrective actions taken. The following

LERs are considered closed:

(Closed) LER 369/88-23, Required Surveillance was not Performed on Two

Snubbers. These snubbers were omitted since a formal snubber inspection

list was not maintained. The snubbers omitted were subsequently inspected

and found to be operable. The licensee is developing a computerized data s

base program to track all safety related snubber inspection requirements.

This event constitutes a violation of T.S. 3.7.8. This violation meets

the criteria specified in Section V of the NRC Enforcement Policy for not

issuing a Notice of Violation and is not cited. LIV 369/89-01-02, Missed

TS Surveillance on Snubbers.

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(Closed)' LER -369/88-29, Fire Barriers Breached Due to Management

Deficiency and Unknown Reasons. A management deficiency existed because

vendor personnel involved had not received the appropriate training.

Cause of the other breaches could not be determined.. Corrective actions

are being taken to prevent recurrence of this event, however, there_have

been several instances of breached fire barriers in the past several

-years. 1his event constitutes a violation of TS 3.7.11. .This violation

meets the criteria specified in_ Section V of the NRC Enforcement Policy ~

for not issuing a Notice of Violation and is not cited. LIV 369/89-01-03,

Breach of Fire Barriers. The licensee is performing an evaluation of past

fire barrier violations due to the large number of previous breaches. The ,

licensee stated that these occurrences have decreased in number over the

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past several years.

(Closed) LER 369/88-42, ESF Actuation Occurred Due to Personnel Error.

An operator ' caused the motor driven auxiliary feedwater pump to auto start

while in Mode 3 by resetting the ATWS Mitigation System and Actuation

Circuitry (AMSAC). The operator had received training on_ the recently

installed AMSAC system but reset the circuit when the operator mistakenly

believed that the system was generating a signal to shut a blowdown valve

which the operator was attempting to open. The valve was actually

receiving an isolation signal from a high level in the blowdown tank. The l

inspector reviewed the training package for the AMSAC modification and j

found it to be adequate with the following exception. The training i

package stated that the AMSAC indicating light on the control board was '

lit when the system was bypassed. The indicating light is actually lit

when the system is in the reset mode (not bypassed). The light itself is  :

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not labeled and located between the " Bypass" and " Reset" push buttons. In

spite of the erroneous training operations personnel questioned by' the' i

inspector were aware that the indication was lit when the system was

reset. The nomenclature of the AMSAC system and no label on the  ;

indicating light are poor from a human factors perspective. Reseting '

other plant equipment serves to remove a signal restoring control to the

operator but in this case reset caused an actuation signal to be generated

in the plant conditions that existed at the time. The licensee is

considering' relabeling the control switch and light.

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(Closed) LER 370/88-06, ESF Actuation Due to Personnel Error and

Procedure Deficiency. Violation 369,370/88-20-01 was issued with this

event as one example. Corrective actions will be tracked in followup to

the violation.

(Closed) LER 370/88-13, Water Level ESF Actuation Instrumentation for a

Main Feedwater Isolation Valve Inoperable for Indeterminate Period of

Time. Although an ESF instrument was inoperable for an extended period of

time an NRC Notice of Violation is not considered appropriate since the

problem was discovered by licensee self initiated corrective actions and

previous escalated enforcement was issued for problems with the same root

cause (open sliding links and failure of the test program to discover the

deficiency), see NRC Report No. 369,370/88-29.

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(Closed)-LER 369/89-01, Failure to Take Compensatory Measures When.Both-

Trains of Control Room Area Ventilation Were Inoperable. This event was

identified as a violation in paragraph 7 and corrective actions will be

evaluated in. followup to the violation. ->

The following LERs are also considered closed: -i

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LER 369/88-24 LER 370/88-08.

L LER 369/88-35 LER 369/88-43  !

LER 369/88-41' LER 369/88-46 l

LER.369/88-44,'Rev.1 LER 369/88-47  !

Two licensee identified violations were identified as described above.

7. Follow-up on Previous Inspect' ion Findings (92701,92702)

The following previously identified items were reviewed to ascertain that

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the licensee's responses, where applicable, and licensee actions were.in

compliance with regulatory requirements and corrective. actions have been l

completed. Selective verification included record review, observations,

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and discussions with licensee personnel, i

(Closed) Inspector Followup Item 370/87-41-02, Both Trains of Control

Room Ventilation and Chilled Water Fail Control Room Pressurization Test.

The event was reviewed and corrective actions have been taken. A program l

for checking control room door seals has been established.

(Closed) Violation 369/88-09-03, Inoperable Nuclear Service Water Train

Due to Inadequate ' Post Maintenance Test. Planners have reviewed this

event to prevent recurrence. Failure to perform post maintenance tests I

has occurred since this event. A racent example is documented in Report

369,370/88-33, where CA-44 was not retested to set the travel stops after

maintenance.

(Closed). Violation 370/88-14-02, Failure to Follow Procedure and Failure

to Use a Procedure to Perform Safety Related Work. The licensee

attributed 'this event to personnel error on the part of the individual

performing the work. The individual was counseled and station management

has been stressing procedural compliance. This general area continues to

be evaluated by the inspectors.

(Closed) Violation 370/88-20-01 Failure to Follow Procedures / Inadequate l

Procedures With Three Examples. The licensees corrective actions for i

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these three examples have been verified complete by the inspectors. The

second example involved a loss of offsite power due to improper

implementation of a general procedure OP/2/A/6350/05, "AC Electrical

Operation Other Than Normal Lineup." The licensee decided not to change

the procedure since the number of possible variations of alignment would

make a change to a more detailed procedure impractical. The licensee has

chosen to control this type of evolution through the use of the Removal

and Restoration (R&R) process. The inspectors will continue to observe

licensee performance in the use of R&Rs.

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(Closed) Inspector Followup Item 369,370/88-04-01, Long Term Corrective

Action Associated With Nuclear Service Water Expansion Joint Liner. The

liner and bellows were replaced using a stainless steel flanged joint

rather than a welded joint via a Nuclear Station Modification (NSM). The

NSM was installed on Unit i during the last outage and will be installed

on Unit 2 during the next refueling outage.

(Closed) Temporary Instruction 369,370/T2515/77, Survey Of Licensee's

Response to Selected Safety Issues. The completion of this instruction

was due in 1986. Formal documentation in an inspection report indicating

the instruction was completed could not be founu. The inspector verified

that the information requested by this instruction had been transmitted to

the proper NRC group in 1986 indicating that the instruction had been

completed.

(Closed) Inspector Followup Item 370/87-36-04, Review Electrical Breaker

Coordination Resulting in 9/6/87 Trip. This event involved a ground on an

instrument air (VI) compressor motor which tripped both the motor breaker .

and the motor control center (MCC) feeder breaker. The McGuire NRC  !

Diagnostic Evaluation Team (DET) report paragraph 3.5.6.2, also discussed

this event and concluded that no NRC followup was considered necessary. A ,

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breaker coordination problem did, however, exist and the licensees Design

division has an on-going review underway of breaker coordination as a part

of an analytical model review. The essential power supply portion of the ,

review has been completed and the non-essential power supply is currently  !

under review. This review includes normal and standby power supplies 4

under normal and faulted conditions. The DET was also concerned that the j

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responsible design personnel were unaware at the time of any concern with

breaker coordination problems at McGuire due to a communication concern. I

Since the DET inspection, Design representatives have been stationed at

the site and Design has been reorganized such that the design personnel

involved deal only with McGuire. The inspector discussed the

communications concern with the General Office Design person involved who l

stated that information input and communication from the site are not a  ;

Design personnel also indicated that breaker

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problem at this time.

coordination is not assured in all cases since many of the breakers at

McGuire have instantaneous and long time current trips and no short time

trip. In some cases a ground may cause breaker coordination problems due

to high instantaneous current trips. Design indicated that breakers are

being replaced when needed with those having short time over current trips

to provide breaker coordination.

(Closed) Violation 369/88-09-02, Inoperable Component Cooling Train Due

To Inoperable Nuclear Service Water (RN) Valve. The licensee postulated,

that the travel stops on RN valve IRN-1908, service water flow control

"alve to the component cooling heat exchanger, had come loose and vibrated

out of position. Signs were placed on these valves warning against moving

the travel stops and locking the stops securely after any authorized

positioning. Corrective actions in the licensees response also included

placing Loctite thread sealant on th travel stops for 1RN-190B and

evaluating the need to put Loctite on all four of these valves. After

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Loctite was initially p _d on 1RN-190B the licensee subsequently decided i

to discontinue use of Loctite in this application. Currently none of the  ;

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valves have Loctite on the travel stops.

travel stops have not been found out of position since this event 'i

occurred. In addition, these valves are scheduled to be replaced with

more reliable valves in the early 1990's. All signs have been verified in

place and tightness of the selected travel stops has been verified by the

inspector.

(Closed) Unresolved Item 369,370/88-33-03: Review of Control Room Door

Seal Maintenance Affecting Operability of Control Room Ventilation. On  !

January 17, 1989 Mechanical Maintenance personnel replaced the seals on a ,

control room door rendering Control Room Ventilation (VC) system l

inoperable for approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Instructions on the work request

(WR) stated " Repair or adjust door closure after door seal is replaced". j

Another WR was supposed to be implemented first which would have  ;

implemented adequate controls to maintain VC operable. Although the

statement on the WR could be misleading it did not clearly authorize seal

work to be accomplished. Maintenance Management Procedure (MMP) Scopa ,

Section Bl.0 requires a WR for maintenance activities. Responsibility l

Section Bl.11 requires a description of requested work. This incident is

considered a violation of both sections of MMP 1.0 in that unauthorized

work was accomplished and the description of work was unclear. This is

another example of violation 369,370/89-01-01, Failure to Follow

Maintenance Administrative Procedures.

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(Closed) Unresolved Item 369/88-33-07: Followup of Dilution Event. On  ;

January 10, 1989 a cation bed demineralized was placed in service which  !

led to an unplanned dilution of the reactor coolant system. Operators l

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acted in a timely manner to isolate the demineralized and boron concen-

tration was returned to normal. Excore detectors rose approximately "

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1.2% and the highest indication of excore power was 100.49%. While this

event was not a significant transient, it is important that procedures i

adequately control reactivity without unplanned changes. McGuire

Procedure OP/1/A/6200/01, Chemical and Volume Control System, contains  !

instructions for placing the cation bed demineralized in service. This

procedure specifies boron saturating mixed bed demineralizers prior to ,

placing in service to ensure no change in reactivity, however, the

procedure does not require boron saturating the cation bed demineralized

rior to placing in service. The chemistry procedure in this case

p(CP/0/B/8400/14) allowed filling of the demineralized with unborated water

leading to the event. Therefore, this is a violation of Technical

Specification 6.8.1 which requires that adequate written procedures be

maintained for plant systems. This is violation 369/89-01-04: Inadequate

Chemistry Procedure Leading to Inadvertent Dilution.

(0 pen) Bulletin 85-03: As requested by Action Item e. of Bulletin 85-03,

" Motor-Operated Valve Common Mode Failures During Plant Transients Due to

Improper Switch Settings", the licensee identified the required

safety-related valves, the valves' maximum differential pressures and a

prograni to assure valve operability in their letters dated May 16, 1986,

November 20, 1986, and February 18, 1987. Review of these responses

indicated the need for additional information which was requested in NRC

Region II letter dated March 31, 1988.

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Review of the licensee's May 2, 1988, response to the request for 4

additional information indicates that the licensee's selection of the

applicable safety-related valves to be addressed and the valve's maximum i

differential pressures meets the requirements of the bulletin and that the l

program to assure valve operability requested by Action Item e. of the

bulletin is now acceptable, with the exception of providing justification  ;

in cases where testing with maximum differential pressure cannct ,

practicably be performed. Prior to final acceptance, differential i

pressure testing will be examined more closely by a regional inspector.

The results of the inspections to verify proper implementation of this

program and the ' review of the final response required by Action Item f. of

the bulletin will be addressed in additional inspection reports.

Two violations were identified as described above. '

8. Review of Licensed Operators Medical Records (71707)

10 CFR Part 55 requires that applicants for an operator's license be

certified as medically fit. Documentation of medical examinations is

required to be maintained and made available for review by the NRC. A

random review of medical examination documentation was conducted from

currently licensed reactor operators.

No violations or deviations were identified.

9. Escalated Enforcement Issues

On January 19, 1989, two severity level III violations were issued

concerning the operability of the hydrogen. skimmer (VX) system and ,

inadequate post modification testing. Reports 369,370/88-24 and 88-29

identified numerous concerns in these areas which ultimately resulted in

the two severity level III violations. In order to correctly document the

final disposition of these items, previously opened items 88-24-01,

88-24-02, 88-24-03, and 88-24-04 are being combined into one item {

369,370/88-24-03,VX Operability Violation. Also, 88-29-01, 88-29-02 and j

88-29-03 are being combined into one item 369,370/88-29-01, Inadequate '

Post Modification / Maintenance Testing. These two items will remain open ,

pending review of completed corrective actions for the violations. l

10. Drawing System Verification (37701, 39702)

The inspector conducted a special inspection of the drawing control

program and reviewed critical control room and technical support center )

drawings to verify the drawings were adequately controlled, legible and j

usable by the operations staff for decision making during an emergency. l

Licensee Station Directive (SD) 2.1.1 describes the licensee's process for l

drawing control. SD 4.4.1 and 4.4.2 describe the program for modifica-

tions including incorporation of modifications into drawings. Operations  ;

Management Procedure (OMP) 1-11 provides guidance to operations staff in l

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maintaining critical drawings up to date relative to modifications. The

licensee indicated that OMP 1-11 was being reviewed to add more detailed .

control for updating drawings relative to modifications. The licensee  ;

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presently red marks critical drawings for significant plant modifications

to assure current information is available while waiting on an official

drawing change which typically takes several months. Addition of a valve

would be a significant change and addition of a note would typically not

be considered significant. Temporary modifications are not presently red

marked. A note is placed on the drawing and the package is filed in the

control room for reference. While these modifications are usuall- cimple

in nature, the licensee is evaluating the need for red marking 'Se ,

licensee also intends to provide more guidance for complicated red marking

and partially implemented modifications. The inspectors review showed  ;

that drawings were being red marked with appropriate reference to the j

modification and a file was maintained of modification packages #or l

further reference. Drawing stamps and red marking are supposed t be

initialed by the clerk and a second person who is SR0 licensed.

Some discrepancies were identified. An out of date drawing revision was

noted. In addition, some markings were not properly initialed, two added

drain valves were not red marked, some areas of electrical drawings were

illegible and the modification file was in disarray. The inspector

discussed these problems with the licensee. The licensee immediately

initiated a complete audit of critical drawings and found additional

similar discrepancies. The licensee initiated corrective actions. Out of

date drawings and illegible areas were determined to be insignificant to

operations. A number of discrepancies were found on control room drawings i

but were not critical. These drawings are being evaluated for retention.

Some drawings were found with unnecessary stamps or references to

temporary modifications. The fi'le was reorganized and a training package

was developed for shift clerks. Stamps and red marks have been validated

and out of date drawings have been replaced. Additional reviews by an NRC

team inspection (see Report 369,370/89-02) identified one out-of-date  ;

drawing since the licensee audit, identified several situations where the j

control rrom had later drawings than the Master File and also discovered l

that confusion may exist with operators as to whether the drawings are

usable without using the NSM's on file. The licensee indicated that a

Design Engineering master list was available, that operator training would ]

be conducted and that Operations, Projects (lead group for modifications) l

and Document Control personnel would be working together to verify I

drawings which were affected by the modification process are up-to-date in

all station groups. The Master file problems were apparently filing

i errors only. The licensee also indicated that Document Control personnel

had recently deleted distribution / accountability sheets and master file

i audits for drawings. Individual groups were tasked with auditing. The l

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licensee committed to evaluate the need for reinstating these processes or l

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l The licensee relies on -internal audits of individual groups and random

audits / surveillance by quality assurance (QA) personnel. One QA

surveillance of modifications was conducted in late 1988 with no problems

. identified and one audit was conducted in 1987 with one minor finding.

Past operations audits have apparently not been sufficiently broad based.

The licensee was requested to consider an improved audit process. A ,

detailed walkdown of the Unit 1 Auxiliary Feedwater System against

as-built drawings was also conducted (see paragraphs 3 and 5).

The above discrepancies appear to have minor technical significance and

the licensee initiated appropriate corrective action before the inspection

period ended. This violation meets the criteria specified in Section V of

the NRC Enforcement Policy for not issuing a Notice of Violation and is

not cited. However, further followup wiil be conducted of licensee

corrective actions. This is Violation 369,370/89-01-05: Followup of

Improvements in Control Room Drawing Control.

One violation was identified as described above which is not being cited.

11. Review Of Plant Procedures (42700)

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Due to an ongoing concern with failure to follow procedures the

inspector reviewed procedures which define how specific procedures are to

be implemented. Procedures reviewed included " Operations Management

Procedure" (OMP) 1-2, "Use of Procedures"; OMP 2-17, "Tagout/ Removal and

Restoration (R&R) Procedure" and Station Directive 4.2.1, " Handling of

Station Procedures". The following comments are provided:

a. The first statement in the OMP 1-2 section titled " General Statements

of Philosophy" is that " Procedures do not cover all situations".

While this is a true statement it appears inappropriate that this

statement is listed first under philosophy. If procedure compliance

is to be strongly emphasized, and may imply to some that procedures

do not need to be followed. The OMP 1-2 later states that operators

are required to take appropriate action to place the plant in a safe

condition, independent of procedures. This is also an appropriate

statement, however, the OMP should emphasize the use of procedures

for most situations and processing changes when the time taken to

process the change will not impact plant or personnel safety. In

summary, the OMP should reflect the strict procedural compliance, an

attitude that the licensee ihas verbally indicated it intends to

enforce,

b. OMP 1-2, Section 7.1.E under philosophy, states " Prior to using any

procedure the initial conditions...must be verified. If these are

not met, the procedure cannot be used without supervisory review and

approval". This section does not state that a procedure change must

be processed and, therefore, is unclear as to whether a change is ,

needed. A procedure change should be made if initial conditions

cannot be met.

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c. OMP 1-2, Section 7.2.E.1 allows signing a valve checklist even if the

valve is mispositioned as long as a Removal and Restoration (R&R)

exists. It seems to be more appropriate to sign the checklist noting

that the valve mis-position is acceptable per R&R,

d. OMP 1-2, Section 7.2.F states " Performance valve checklist may be

performed by Operations to allow performance testing of certain

systems. When the testing is complete, the checklist requires the

valves to be returned to a " normal" position. This " normal" position

may not correspond to the actual valve position required by the

approved (0P) Operations Procedures currently in use. In such cases,

the Performance valve checklist " normal" position should be signed

off as being correctly positioned."

There has been difficulty in the past with conflict between the final j

position of valves in a performance test procedure and the position

desired by Operations (per the OP in use or an R&R). Performance

test procedures use various methods in an attempt to overcome this

problem including recording the as found position in the PT and

specifying returning the valve to the as found condition; specifying

returning the valve to the position desired by operations; and .

specifying final positions but allowing deviation from the final l

position if an R & R is outstanding on the valve. However, the OMP

paragraph allows signing for a valve which is out of position. Other

alternatives exist that would not give the appearance of the ,

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performance procedure.

e. OMP 1-2 Section 10.1.A states that "No deviation from the original

intent of the procedure shall be allowed without an approved

procedure change". The original intent is not defined and this

statement allows the procedure user to interpret original intent

without reviews. Original intent needs to be clearly defined and

narrowly interpreted by procedure users. TS 6.8.3. in part states j

that temporary changes to procedures may be made if the intent of the

original procedure is not altered. Intent in the TS is not defined,

however, the TS requires approval of a temporary change by two

members of the plant management staff, at least one of whom must

holds a senior operator license and review / approval by the plant

manager or a superintendent within 14 days. The intent determination

made by the procedure user per 0MP 1-2 does not receive the reviews

required by the TS.

f. OMP 1-2 outlines the use of procedures for Operations Department

personnel but not for other station personnel. Only minimal guidance

is provided for other personnel via Station Directive (SD) 4.2.1,

" Handling of Station Procedures". Section 1.0 states that the

objective of Station Directive 4.2.1 is to insure adequate prepara-

tion, review and approval for all station procedures, changes and

completed procedures. Ensuring proper use of procedures is not

listed as an objective of SD 4.2.1. Section 4.0.9 of SD 4.2.1 is

titled "Use of Procedures" but the guidelines are very limited. The

licensee committed to revise SD 4.2.1 to be more specific in the

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requirements for use of procedures in response to violation

369/87-41-04 _ The revision of SD 4.2.1 dated' December 18, 1987 was

incomplete in that the only change in~this area was to state'"Where

an approved Station Procedure exists that covers station activities, J

those station activities shall always be conducted in accordance with I

, the provisions of the approved procedures." The revision to SD 4.2.1

was intended to reflect the management policy clarification on the .

use of procedures as stated in the plant managers memorandum dated l

10/27/87. This memorandum stated: =i

(a) "If a station activity is important enough to have a procedure l

written to perform the activity, then the procedure will always

be used, in its entirety... Steps may not be deleted, skipped or

altered without a procedure change being made unless specifi-

cally allowed by the procedure. To perform the activity without

the procedure IS NOT OPTIONAL."

(b) "Do not deviate from the scope of the , procedure unless the

activity is covered by another procedure or administrative

control, such as a troubleshooting procedure. Again, if the

activity .'s important enough to be performed under procedural

control, DO NOT PERFORM ACTIVITIES THAT G0 BEYOND THE PROCEDURE l

without also using a procedure or other administrative

controls".

The actual change to SD 4.2.1 did not state that steps may not be

deleted, skipped, or altered without a procedure change unless

specifically allowed by the procedure. Part 8 of the memorandum .i

likewise was not included in the station directive. Realistically J

there are situations in which procedures cannot be followed or where

alternate rethods are acceptable. Clear guidance needs to be  ;

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provided for these situations to maintain a proper attitude for

following procedures and to assure correction of procedural problems.

In summary, SD 4.2.1 appears weak in the area of providing guidance

on use of procedures.

g. "Tagout/ Removal and Restoration (R&R) Procedure", OMP 2-17 provides

guidance for removal and resto"ation of equipment. However, very

little guidance is provided relative to when an R&R can be used in

lieu of a procedure. The licensee is developing this guidance based

on an NRC violation (369,370/88-31-01).

h. The licetsee hat independently recognized the need to improve

guidance for use of Abnormal and Emergency procedures and is

developing this guidance.

Due to the history of weak procedural compliance and adequacy at

McGuire, management has increned emphasis on following procedures

and correcting inadequacies in procedures. However, the Station

Directive and Operations Management Procedures governing use of

procedures continue to be weak in providing adequate guidance 'to

plant personnel. Again, it is noted that the OMP applies only to

Operations Personnel and the Station Directive applies to all Station

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Personnel-b'ut the SD gives very l'ittle' guidance on use of procedures.: .

The- current written guidance for use of procedures is. considered a i

weakness and ~ an Inspector Followup Item IFI- 369,370/89-01-06, l

Written Guidance on Use of Procedures, is being opened to followup in. j

y this area.  ;

No violations or deviations were' identified.

'12. Review of Problem Investigation Process .(71707) ,

The inspectors reviewed various problems and' events to determine if the' j

stations corrective action program was being properly implemented relative l

to these situations. Problem Investigation Reports (PIRs) were also. l

reviewed .to determine adequacy of program implementation. The primary ,

program the licensee uses .for identifying, documenting and correcting j

problems is the PIR program implemented by Station Directive 2.8.1,  ;

" Problem Investigation Process". This procedure requires in paragraph

5.1.1 that " Problems identified that meet the criteria in Attachment 1 j '

shall be documented as soon as practical..." Attachment 1 defines the.

criteria for writing a PIR as follows:

1. Unplanned,. unexpected, unenalyzed events, or conditions involving 1 '

important functions.

2. Degradation, damage, failure, malfunction or 1oss of plant equipment

performing important functions.

3. Deviation from or deficiencies involving code, specifications

(includes Tech Specs) requirements, or administrative controls

involving important functions. o

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Two apparent failures- of the licensee to document problems in accordance

with the above criteria were discovered by the inspectors. The licensee

experienced a loss of Residual Heat Removal on December 1,1988 on Unit 1

in part due to a confusing drawing which had not been properly updated

(see NRC Re 369,370/88-33). A problem was identified by the

inspectors (portsee paragraph 5) involving . damaged Auxiliary Feedwater (CA)

System temperature detectors. Neither of these issues were documented on

a PIR. In addition, two other situations were documented on a PIR

approximately two weeks after the events and after NRC prompting. One  ;

situation involved-a leaking CA check valve which was documented on PIR l

1-M89-0046. Leakage of this valve can affect CA operability. Another ,

issue involved missing fuses causing a Diesel Generator breaker to not 1

function. Local - function (not emergency start) only was affected, i

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however, this was a repeat problem which could indicate a program weakness

or personnel problem. This situation was documented after prompting on  ;

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PIR 1-M89-0050. While the inspector cannot show that the PIRs would not

have been issued, these issues appear to indicate weaknesses in aggressive

program implementation. Another situation involved corrective maintenance 1

on the Unit 1 CA turbine driven pump. This work was documented on Work l

Request (WR) 500488 MNT. The WR indicated that the overspeed trip

mechanism was found inoperable indicating a possible past operability

issue or maintenance problem. Upon questioning of two individuals by the l

inspector each indicated that he thought the other was going to issue a

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PIR. The licensee eventually decided to document the problem on an

existing PIR which had been written previously identifying that the

mechanism was not being periodically tested. This problem may not have

been fully addressed without NRC prompting.

The inspector reviewed PIR 0-M88-0022. This PIR documented problems with

instrument air lines and prompted filter inspections and review for

adequate sizing. Part of the corrective action was to evaluate the need

for a preventive maintenance (PM) program. Given the problems experienced

at McGuire and generally well known industry problems this corrective

action appeared weak and would have allowed no program to be implemented

based on one individuals decision. In addition, Quality Assurance

personnel signed off the PIR indicating a PM program had been implemented.

The air system is designed fail safe and is non-safety-related but this

issue may also indicate weaknesses in program implementation. The first

two examples are considered a Violation 369,370/89-01-07: Failure To

Follow Procedure With Respect To Writing Problem Investigation Reports.

Since this violation is indicative of program implementation weaknesses,

both units are included. A review of licensee statistics did show the

number of PIR's issued had increased through 1988 indicating an improving

documentation trend. The licensee is trending numbers of PIR's on a

monthly basis as a management tool.

One violation was identified.

13. Exit Interview (30703)

The inspection findings identified below were summarized on February 27,

1989, with those persons indicated in paragraph 1 above. The following

items were discussed in detail:

(0 pen) Violation 369,370/89-01-01, Failure to Follow Maintenance

Administrative Procedure. Three examples were identified involving

performing work without a work request and improper acceptance of

operational control following maintenance. (Paragraphs 5 and 6)

(Closed) Licensee Identified Violation 369/89-01-02, Missed TS

Surveillance on Snubbers. (Paragraph 6)

(Closed) Licensee Identified Violation 369/89-01-03, Breach of Fire

Barriers. (Paragraph 6)

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(0 pen) Violation 369/89-01-04, Inadequate Chemistry Procedure Leading to

. Inadvertent Dilution. (Paragraph 7)

(0 pen) Violation- 369,370/89-01-05, Followup of Improvements in Control

Room Drawing Control. For reasons described in the report no Notice of i

Violation is being issued for this violation. (Paragraph 10)

(0 pen) Inspector Followup Item 369,370/89-01-06, Weakness in Written

Guidance on Use of Procedures. (Paragraph 11)

(0 pen) Violation 369,370/89-01-07, Failure to follow Proceduces With

Respect to Writing Problem Investigation Reports (PIRs). (Paragraph 12)

The licensee representatives present offered no dissenting comments, nor

did they identify as proprietary any of the information reviewed by the  ;

inspectors during the course of their inspection. l

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