ML20199G686
| ML20199G686 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/16/1998 |
| From: | Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199G643 | List: |
| References | |
| 50-302-97-20, NUDOCS 9802040326 | |
| Download: ML20199G686 (70) | |
See also: IR 05000302/1997020
Text
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U.
S.
NUCLEAR REGULATORY COMMISSION
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. REGION 11
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Docket Nos :
50 302
License Nos.:
DPR 72
Report Nos.-:
50 302/97 20
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Licensee:
Florida Power Corporation
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Facility:
Crystal River 3 Nuclear Station
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Location:.
15760 West Power Line Street
Crystal River, FL
34428 6708
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Dates:
December 1 - 16, 1997
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Team Leader:
C. Julian Technical Assistant Division of Reactor
Safety-
Inspectors:
_ B. Crowley, Senior Reactor Inspector, Maintenance -
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Branch, RI!
- Ron Gibbs, Senior Reactor Inspector, Maintenance
Branch, Ril
Russell Gibbs, Resident inspector,. North Anna-Site
E Girard; Senior Reactor Inspector, Special Projects-
Branch, RII
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K. 0'Donohue, Resident inspector, Vogtle Site
L, Wert. Senior Resident inspector Browns Ferry Site
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F.
Wright. Senior Radiation Specialist, Plant Support
Branch Ril
Approved By:
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C. Julian Technical Assi(tyt
D/te Sig'ned
- Division-of Reactor Safety
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Enclosure 2
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EXECUTIVE SUMMARY
C.wstal River 3 Nuclear Station
NRC Inspection Report No. 50 302/97 20
This inspection included an assessment of the current status of the licensee
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programs for Operations. Radiological Protection, Maintenance, and
Surveillance.
Overall, the inspection team concluded that the licensee Operations.
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Radiological Protection. Maintenance, and Surveillance programs were
adequate to support plant operation.
Operations
Overall, the team concluded that the conduct of operations was adequate
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to support plant restart. The team noted there have been numerous
recent changes and that some aspects of the programs were not yet fully
implemented.
Control room operators were consistently professional and demonstrated a
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positive attitude.
Communications, procedural compliance, turnovers,
and response to off-normal conditions were strong.
The widespread
utilization of radios for communications was effective.
The operators
demonstrated a sense of ownership of the plant.
Attention to detail
during some control board walkdowns was weak,
Control room access
control during backshift hours and level of detail in the logs were
areas needing improvement. (Section 01.1)
Several areas were identified in which procedural controls over
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annunciators and alarms should i>e improved.
There was no formal
mechanism to address compensatory measures for disabled annunciators.
Annunciator windows expected to be lit due to plant conditions were not
designated as such.
Procedural guidance did not address actions to be
taken for invalid annunciators / alarms.
Computer alarm points removed
from scan were not periodically verified. (Section 01.2)
Deficiencies were noted in the questioning attitude and attention to
detail on the part of some plant equipment operators.
The licensee
effectively used temporary enclosures, referred to as "Hiltons" in the
operating spaces.
The use of personnel safety equipment was excellent.
(Section 01.3)
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The new work control process had not yet fully implemented. Operations
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personnel were well informed regarding all significant maintenance and
testing activities in progress. Operations actively participated in
briefings for maintenance activities.
(Section 01.4)
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A weakness was identified regarding a lack of strict compliance with
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clearance tags.
The team noted that information tags were
inconsistently utilized. (Section 01.5)
The Equipment Out of Serv Ma log was accurate but was not being
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rigorously maintained. i ct.m 01.6)
The lack of a separate program w control temporary modifications could
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lead to temporary modifications being performed without proper
assessment.
No safety significant examples of this were identified.
There was no designated log for jumpers and lifted leads, but they were
adequately controlled by various mechanisms. (Section 02.2)
The procedural controls and emphasis on the work around program needed
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to be improved.
Monitoring of control board deficiencies was not being
performed accurately. (Section 02.3)
Numerous examples of poor housekeeping were noted.
Lighting was not
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effectively maintained and some areas of the plant were not well lit.
Numerous inconsistencies and deficiencies were identified in equipment
labeling.
The licensee's labeling upgrade program should be continued.
(Section 02.4)
The availability of computerized programs such as NUPOST and View / Print
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was considered a strength.
Procedure adherence and usage was good.
Several uncontrolled operator aids were identified.
There was no
procedural guidance for time to core uncovery/ boil curves for extended
shutdowns.
Two deficiencies were noted associated with outdated
revisions of controlled procedures. (Section 03.1)
Operator knowledge of significant Probabilistic Safety Assessment
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information needed to be improved.
Overall knowledge of Technical
Specification requirements and system operations was good. (Section 04)
Personnel in Operations worked significant amounts of overtime during
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the last several months of the extended shutdown.
The team did not
Enclosure 2
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observe any indications of significant fatigue on the part of the
operators.
The licensee had decided to piace personnel experienced in
operations into other working groups and will need to continue efforts
to obtain more licensed operators to decrease the required working
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hours. (Section 06)
Chemistry sampling required by Technical Specifications and the Offsite
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Dose Calculation Manual was properly implemented. (Section 08)
The licensee had plans for strengthening of the current Operations self
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assessment program. (Section 07)
Maintenance
Overall, the Maintenance Program was adequate to support restart of the
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unit.
Maintenance was being performed in accordance with procedures in
a quality manner by trained and qualified craftsmen.
In general,
maintenance procedures provided adequate detail for the control of
maintenance. (Sect 4on M1.1)
The strong maintenance supervision presence and involvement on the job
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site was considered a strength. (Section M1.1)
Maintenance personnel had a positive attitude about performing and
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documenting maintenance correctly, and procedure use was good.
(Section M1.1)
The maintenance training and certification program, which was
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comprehensive with detailed multiple task performance training
requirements specified for each discipline, was considered a strength.
(Section M1.1)
Corrective and preventive maintenance backlogs were low, and the strong
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emphasis on control of maintenance backlogs was considered a strength.
(Section M1.1)
Activities relative to foreign material exclusion (FME) controls,
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quality contro' (OC) hold points, pre-job briefings. interface with
operations and engineering post maintenance testing, and control of
measuring and test equipment M&TE were performed in accordance with
program requirements and were found to be satisfactory. (Section M1.1)
Enclosure 2
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The following programmatic weaknesses were identified: (Section M1.1)
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There was a possibility that, for " troubleshooting" work requests (WRs),
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the added post maintenance test (PMT) requirements would not receive
Operations review and approval as required by procedure.
The process for evaluation of the effectiveness of the preventive
maintenance (PM) program, including evaluation of the effect of repeated
maintenance on the program, was not formalized.
Repetitive maintenante was being documented and tracked, but was not
being used to monitor and improve maintenance of equipment.
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The responsibilities for the ' Gator Team" (quick response maintenance
team) were not proceduralized.
Licensee implementation of the Maintenance Rule program was evaluated as
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satisfactory, with the following observations. (Sect <on M1.2)
Strengths:
The licensee had developed and implemented an on-line risk monitor
as e tool for assessing risk when removing equipment from service
during power operations,
inspection of structures under the Rule were comprehensive, and
documentation of inspection deficiencies including the location
and extent of condition was excellent.
Weakness:
Deficiencies identified by the structural inspections had not yet
been evaluated to determine if any structures should have been
classified as (a)(1) under the Rule with goals and monitoring
established.
This weakness was corrected during the inspection.
No structures were classified as (a)(1).
The licensee's surveillance program was acceptable for plant operation.
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Surveillances were satisfactorily scheduled, proceduralized, performed
-and documented, (Section M1.3)
Enclosure 2
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Pre job briefings for the surveillances were thorough and well-
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presented. (Section M1.2)
Licensee nondestructive inspection examiners were thoroughly aware of
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recent industry experience involving high pressure injection piping and
thermal sleeve cracking at other sites and had performed appropriate
examinations to assure the condition did not exist at Crystal River. A
weakness that could impact future examinations was noted in the
licensee's written examination criteria.
The licensee prepared a
precursor card to address this weakness. (Section M1.3)
Plant Sucoor.t
Overall, the radiation protection program was adequate to support
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restart of the unit.
A violation (50-302/97-20 01), was identified for failure to provide
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adequate written instructions for documenting personnel contaminations.
(Section R1.1)
A violation (VIO 50 302/97 20-02) was identified for failure to follow
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radiation protection program procedures for documenting personnel
contamination events. (Section R1.1)
A violation (50-302/97 20 04) was identified for failure of radiation
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workers to follow contamination control procedures.
(Section R1.1)
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An Inspector followup Item (50 302/97-20 03) was identified to review
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the licensee's technical basis for dose conversion factors during a
future NRC inspection. (Section RI.1)
The Radiation Monitoring System Readiness Review was thorough.
The
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corrections made to the system and others proposed should improve the
equipment operability, ensure equipment is capable of performing
intended functions, and impi ve quality of supporting and administrative
documentation for the equipment.
(Section R2.1)
The inspectors verified thi:. the Mhole Body Counter was properly
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calibrated, monitored, and maintained.
(Section R2.2)
Enclosure 2
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The inspectors verified that the licensee's whole body contamination
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monitors were being properly calibrated, monitored, and maintained.
(Section R2.3)
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Enclosure 2
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Reoort Details
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rv of Plant Status
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Crystal River 3 was in an extended shutdown during the inspection period.
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Introduction
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- The primary focus of Phase One of this Operatiomi Safety Team inspection was
to verify that the licensee had achieved readiness to' resume plant operations,
inspection areas focused on operations, maintenance, and surveillance.
The
inspection was performed by a team of inspectors that included a Team Leader,
four region based inspectors _and three resident. inspectors.
I. OPERATIONS
01
Conduct of Operations
-01.1- Control Room Observations (93802)
a.
Insoection Scone
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The team _ observed the conduct of Operations in the control room for
significant periods, including approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of continuous
shift coverage. The team observed operator. professionalism,
attentiveness, awareness of plant status, communications, conduct of
evolutions, response to alarms, and control of plant activities.
Observations _1rcluded response to a malfunctioning transformer which
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resulted in-a_ loss-of the control . room annunciator system. - The team
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also performed inspection of routine Operations shift activities
including shift turnovers, control-board walkdowns, and control room
environment. -Shift operating logs, night orders, and short term
instructions were reviewed.
b.
Observations and Findinos
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Throughout the inspection, the team noted that numerous changes had
recently been made affecting the Operations department.
In recent
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-weeks._ revisions to operating practices including reissuance of the
Operating Instructions.and changes to major'watchstation titles had been
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completed. During the inspection, other_ significant Operations
procedures were changed.
The team'noted that some aspects of the
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programs had not yet been fully incorporated into the plant operating
routine.
Major revisions were planned in the near future for the
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Operations self assessment program and work around control program.
The
team observed a consistently positive attitude on tne part of Operations
personnel.
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Several members of the team observed tne operators' response to a loss
of control room annunciators on December 10, 1997.
In response to
indications of degraded oscillating voltage with the annunciator system,
the operators verified that the control room computer was unaffected and
deenergized the annunciators to prevent equipment damage.
The
appropriate abnormal procedure was immediately entered. The problem was
traced to a malfunction of an alternate transformer supplying power to
several vital loads.
The operators utilized procedures and returned the
loads to their normal source. The team observed that the actions for
the loss of annunciators were completed. The control room operators
contacted watchstanders in the plant and increased monitoring of
indications and equipment.
The team noted that emphasis was placed on
monitoring of the decay heat removal sy; tem. The Nuclear Shift
Supervisor effectively directed the overall activities.
Operations
management and the annunciator system engineer promptly responded to the
control room.
The emergency plan was reviewed for entry requirements,
and it was determined that entry into the emergency plan was not
required because the plant computer remained operable during the event.
Access control and traffic in the control room wat evaluated.
Generally, the team found that the control room environment was
conducive
safe plant operation.
During backshift hours there was
more trr
the control room than expected.
The team observed on
numerous
.casions that maintenance personnel entered the control room
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to obtain permission to perform work.
The team asked selected workers
if they had tried to get permission from the Work Control Center (WCC),
and they had not.
The workers explained that the WCC was sometimes not
manned with a Senior Resident Operator (SRO). especially during
backshifts.
The team observed that controlled key issuance was
performed from the control room. This oractice caused more control room
traffic than necessary.
On several occasions, the team observed that
individuals entered the control room without permission from the SRO.
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Enclosure 2
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Throughout the inspection period, the inspectors observed good
communications practices by Operations personnel.
Three part
communications were consistently utilized.
The phonetic alphabet was
used in almost all communicat Mns, The team observed one incident
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involving a loss of annunciators and several days later, a loss of the
plant computer.
Communications did not degrade during response to the
incidents. Although use of the phoretic alphabet was not as consistent
throughout the plant staff, management emphasis was placed on correcting
errors in this area.
During offnormal conditions, shift management
provided briefings to the Operating crew which were concise, accurate,
and timely,
The extensive use of radios by plant personnel reduced the noise level
in the control room by decreasing incoming phone calls.
The use of
radios also significantly decreased reliance on the plant paging system.
The team noted that although operations personnel used three way
communications on the radios, some of the other depart.vnts were not
consiscent in this area.
The team observed good procedural compliance by Operations personnel.
In response to off-normal conditions, procedures were actively
referenced and followed in step sequence.
The team observed tnat
operating and testing procedures were followed correctly. Alarm
response procedures were utilized as required in response to alarms.
During the performance of pr vedural steps, the team noted that Stop-
Think-Act-Review (STAR) principles were usually e*aployed.
The team observed that the operators were very professional and
demonstrated a positive attitude.
The background noise levels in the
control room were low.
The general control room atr ;phere was
maintained as business oriented with non plant conversation and outside
distractions limited.
When one board operator left the control board
area, there was appropriate comaunications to ensure the remMning board
operator was fully aware of the absence.
During discussions and pre-job
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briefs, the operators were attentive and actively participated.
The
team conducted multiple operator interviews and found that the operators
vare open about issues. The operators were willing to discuss areas of
needed improvement.
Shift turnovers were thorough and informative.
The team obst.rved
numerous watch stations conduct turnovers.
Overall. the team concluded
Enclosure 2
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that sufficient time was allocated to ensure plant and equipment status
were known.
The team noted that shift relief checklists were used by
the various operator watch stations. In addition to equipment status and
log reviews..the checklists included reviews of degraded equipment.
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evolutions in progress, temporary plant configuration changes, and
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equipment / controls in manual. The team observed active participation by
plant equipment operators-in the shift turnover briefings. The team
verified the effectiveness of shift turnovers through discussions with
operators. The team concluded that the turnovers were effect.1ve and that
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operators were well informed of plant conditions.
One of the inspectors noted that several control board indicating lights
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were not lit after turnover board walkdowns were completed.
Control
room personnel explained that the indicating lights were not lit because
equipment was isolated in the field. The equipment was not tagged on
the control board.
Investigation identified that about half of the
approximately a dozen dark indications checked were caused by burned out
light bulbs, not isolated equipment. One broken light socket was aleo
identified during light bulb replacement.
The team noted that the
practice of not indicating active clearances on the affected control
board equipment placed a burden on control room personnel and could mask
control room equipment failures.
The team noted that the shift operating logs, while usually meeting the
requirements specified for contents in Operating Instruction 01-5 were
not detailed.
In some cases information was not icgged which could be
useful to management and other reviewers.
The team noted that a Daily Plant Status Report, which was used to
provide an overview of plant conditions and system alignments, contained
some inaccurate information regarding the status of safety equipment.
The licensee reviewed the report and identified that the information,
along with some other data, had been incorrectly carried over from a
previous days reports.
The error was apparently caused by inattention
to detail.
After reviewing shift personnel assignments, control room staffing, and
fire brigade assignments, the team determined that shift manning
practices were adequate nd met Technical Specification 5.5.2. " Unit
Staff" requirements.
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- icting staff assignments were not identified,
although the low-number t
licensed operators resulted in heavy work
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loads for shift personnel.
Back shift work activities were often
controlled by the on shift SRO rather than work control personnel.
The team reviewed the use of Short Term Instructions (STis). operating
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instructions, night orders, and the shift study book.
In general, they
were adequate and used correctly. The ST!s and night orders were few in
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number and addressed appropriate topics.
Most shift members reviewed
each book during shift turnover or soon after.
Several operators stated
that they do not review all of the books every night, although they did
acknowledge that it was part of the turnover process.
The study book
contained several updates on abnormal procedure revisions as well as
other plant information. A few of the active updates were initiated in
October, 1997 and had not yet been read by all personnel,
in response to questioning by the team, the licensee stated that there
were no formal interpretations of Technical Specifications.
One long
term night order contained operability guidance regarding the use of
Once Through Steam Generators for decay heat removal. The team
concluded that the guidance in the night order would be more
appropriately controlled if incorporated into a procedure,
c.
Conclusions
Control room operators were consistently professional and demonstrated a
positive attitude.
Communications, procedural compliance, turnovers,
and response to off normal conditions were strong.
The widespread
utilization of radios for communications was effective. The operators
demonstrated a sense of ownership of the plant. Attention to detail
during some control board walkdowns was weak. Control room access
control during backshift hours and level of detail in the logs were
areas ne2 ding improvement.
01.2 Alarms and Annunciators
a.
Insoection Scone (93802)
The team reviewed the controls associated with the annunciator system
'and computer alarms.
Administrative controls for disabling alarms and
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tracking the status of alarms were reviewed.
Portions of the corrective
actions for a malfunctioning annunciator were observed. The status of
the sliding links associated with the annunciator system were verified
by one of the inspectors.
Enclosure 2
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b.
Observations and Findinas
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Section 5 of Operating Instruction 017, Control of Equipment and System
Status, contains the procedura! requirements for disabling annunciators.
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The inspectors noted that eleven annunciators were listed in the
Annunciator / Event Point Ala_rm Defeat Log,
With the assistance of an
operator trainee; an inspector verified that only the sliding links
associated with the annunciators listed as defeated were opened.
None
of the defeated annunciators were of a nature that would be expected to
be described in the Updated Final Safety Analysis Report (UFSAR). The
licensee was not sure which annunciators, if any, were described in the
UFSAR. The_ annunciator system is not a safety related system.
The
inspector noted that the administrative procedures did not require a
specific safety review or assessment prior to disabling an annunciator.
Green dots were used to mark annunciator windows which were disabled or
have a open work request.
One of the inspectors verified that the dots
and logbook, which contained documentation for the open work requests.
were in agreement.
None of the work requests associated with the
annunciators had been open for an excessive time period.
The number of.
windows with open work requests or that were disabled were not
excessive.
1he team. discussed with-reactor operators the procedural guidance for
removing annunciators from service when annunciators were invalid. The
team noted two invalid annunciators that had not been disabled or marked
with a' green dot.
The team noted that Operating Instruction 01 07
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Control of Equipment'and System Status, did not provide sufficient
guidance to address the issue.
Questioning by one of the inspectors
identified that a reactor operator was not aware that one of the two
annunciators was invalid.
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The team also noted that the licensee had not established a practice to
label or mark the lit annunciator windows which were " expected u,be
lit" due to plant conditions.
Since numerous annunciators were lit due
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to the long term outage conditions. this might facilitate the operators'
awareness of offnormal conditions.
During observation of a recovery
from loss of annunciators. the team noted that such a practice would
have been particularly useful.
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The team noted that the procedural controls for disabling of
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annunciators or alarms do not require or recommend consideration of
compensatory measures.
No formal method for tracking or monitoring
completion of such compensatory measures was identified.
Trough
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discussions with the operators on watch. the team was informed that on-
shift personnel did give consideration to what compensatory actions were
appropriate and how to monitor them. The licensee indicated that
consideration would be given to establishment of procedural guidance in
this area.
The team noted that changes to computer alarms such as removal from scan
by the operators were listed in the computer alarm change log in the
control room. One of the inspectors determined that there was no
requirement or expectation that a computer printout of points removed
from scan be generated periodically. This printout could be reviewed
against the log to ensure the correct status of alarm points is known.
The computer alarm change log is reviewed daily.
In response to the
observation, the licensee obtained a printout and determined that
numerous points not listed on the log maintained in the control room
were in fact removed from scan. At the close of the inspection period,
the licensee was evaluating methods for periodic review of computer
points removed from service.
The team observed some of the corrective actions taken due to a
malfunctioning annunciator.
The electrical worker who performed the job
appeared very familiar with the task.
Configuration control of the
sliding links was maintained through use of the temporary sliding link
log as required,
The work was completed under a generic work request.
A specific request was not generated 'or the job.
The inspectors
questioned how the performance of the work would be tracked for
equipnent reliability considerations. Subsequently, the licensee issued
work request 350630 to document the work and a precursor card was
initiated on the issue,
c,
Conclusions
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Several' areas were identified in which procedural controls over
annunciators and alarms could be improved.
There was no formal
mechanism to address compensatory measures for disabled annunciators.
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Annunciator windows expected to be lit due to plant conditions were not
designated as such.
Procedural guidance did not address actions to be
Enclosure 2
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taken for invalid annunciators or alarms.
Computer alarm points removed
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from scan were not periodically verified.
01.3 Doerations Watchstandina Activities Outside of the Control Room
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a.
Insoection Scone (93802)
The team members accompanied several plant operators during routine
building rounds and other plant activities. These included rounds in
the Auxiliary Building, Control Center Complex, intermediate building,
and the Turbine Building.
Attentiveness to overall conditions and
communications were assessed as well as the quality of the tours,
b.
Observations and Findinas
During the observation of some tours, the team found that attention to
detail and questioning attitude was not strong. The team noted several
items which indicated that some operators were not paying close
attention to building conditions and certain practices. There were
several examples of poor radiological protection practices such as water
on step off pads, personnel conducting conversations on step off pads,
an individual not properly wearing radiation monitoring equipment, and a
container of used anti Cs located outside of a contaminated area.
Numerous building light bulbs were burned out and were not reported to
the maintenance department,
A controlled key was missing from a locked
enclosure. One confined space appeared to have an expired permit or
certificate.
A pipe cap was missing from a boric acid storage tank
sample line.
An individual was not wearing appropriate security
identification.
Precursor cards were initiated to address the
conditions.
The team noted that the operators consistently demonstrated
ownership of the equipment and conditions by prompt followup of any
questioned conditions.
The building operators have field offices which are known as "H11 tons."
Administrative activities such as phone communications, procedure
review, and shift turnover are generally conducted in the Hiltons.
There is also a computer in the Hiltons that allows the operators to
print controlled procedures.
The team discussed the value of the
Hiltons with operators who stated that these field offices allowed them
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to conduct their business more efficiently because less trips to the
control room area were necessary.
This also allowed the operators to
spend more time in their assigned areas.
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The team observed a very high emphasis was placed on the use of
personnel safety protection equipment.
Hardhats, safety glasses, and
earplugs were consistently worn as required.
c.
Conclusions
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Deficiencies were noted in the questioning attitude and attention of
detail by some plant equipment operators.
The licensee effectively used
temporary enclosures referred to as "Hiltons" in the operating spaces.
The use of personnel safety equipment was excellent.
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01.4 Doerations Control of Maintenance. Troubleshootina. and Surveillance
Testina Activities
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a.
Insoection Scone (93802)
The team reviewed the interface between Operations and other groups
during maintenance and testing activities,
b.
Obcarvations and Findinas
The control room staff was well informed of ongoing activities in the
plant, in particular they understood the field work which affected
control room equipment and indications. The inspectors noted that
appropriate questions were asked by the control room staff about the
work during job pre briefs. Additionally, work was postponed if there
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were unanswered concerns or if it was determined to be too disruptive
for the control room.
The team observed that on a few occasions. the
combination of control room activities resulted in a level of noise
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which was potentially distracting to the operators.
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Shift personnel were often responsible for controlling all aspects of
work control in addition to the daily control room activities.
The
shift mandger and nuclear shift supervisor addressed the development,
review and approval of clearances: scheduled manpower; coordinated
support groups and directed shift operators.
The team was informed that
in the future, most of tha work control activities would be addressed by
Enclosure 2
.
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-
-
.- - - .-.-. - - .
_ - __ - - -_ - - . - . - - -
10
additional Senior Reactor Operators (SR0s) who were in license class at
the time of the inspection.
Additionally, the new work control program
was not fully implemented due to insufficient numbers of SR0 personnel,
A review of the new work control program indicated that once fully
.
implemented, the work control activities should be adequately removed
from the control room area.
The team observed a pre brief for the tag out of one train of the decay
heat system to repair a leaking pump seal. A SR0 conducted the brief
using a check off list which addressed multiple considerations for tag
out personnel,
in addition to the technical aspect!.
f the clearance,
which were discussed at length, the brief included discussions of past
experiences from INP0 and lessons learned directly by the licensee, and
the use of STAR for self-checking.
Communications HP support including
expected dose rates and how to accommodate system drainage, expected job
duration, equipment needs, and what could go wrong were also discussed.
Operators actively participated in the brief. The team concluded that
the brief was thorough and appropriately prepared operators for the tag
out,
c,
Conclusions
The new work control process was not yet fully implemented. Operations
personnel were well informed regarding all significant maintenance and
testing activities in progress.
Operations actively participated in
briefings for maintenance activities.
01.5 Clearance and Information Tagaina
a.
Insoection Scoce (93802)
The team reviewed the use of clearance and information tags.
The
inspectors observed clearance development activities, control of
clearances, and tag placement and removal. The inspectors also reviewed
numerous active clearances for accuracy.
b.
Observations and Findinas
Compliance Procedure Cp-115. Nuclear Plant Tags and Tagging Orders, was
recently revised to supply detailed directions on the development,
placement. verification and removal of clearances.
Discussions with
Enclosure 2
. _- ___ _ _ _ _ _ _ _ _
. _ _ .
11
operations personnel indicated that they were familiar with the changes
and procedure requirements. The team found that the clearances were
adequate, tags were placed accurately, and the work performed under the
clearance was appropriate.
However, in a few cases, the inspectors
.
observed that inadequate labeling of plant equipment made tag placement
difficult.
Although no deficiencies were identified, the potential for
error due to inadequate labeling existed.
Attention to detail, self checking and caution were observed during tag
placement.
The plant operators involved with the clearances thoroughly
understood the activities and were prepared for potential problems.
During plant walkdowns, several hundred tags were inspected for accuracy
by the inspectors.
No incorrectly installed tags were identified.
During a discussion with maintenance management, the team was informed
that under the new work control program, each clearance would be walked
down prior to placement. The team noted that although personnel
involved in the tagging process reviewed the piping and instrumentation
diagrams for clearance development, they did not walk each clearance
down prior to placement, This deficiency was forwarded to licensee
management for resolution.
One of the inspectors noted that a 480 volt motor control center breaker
control switch handle was in the "on" position but had a clearance tag
attached indicating that the switch should be in the "off. not locked
position." A primary plant operator was notified.
He indicated that he
considered the situation to be a problem and immediately contacted the
control room.
Subsequently. it was determined that the breaker had been
removed from the interior of the cabinet.
Consequently, the control
switch handle was not connected to the breaker and therefore was not
being physically supported in the tagged position. The breaker cannot
be removed if locked in a certain position.
Some Operations personnel
indicated that they did not regard the situation as a problem since the
breaker was not installed. Several days later, the inspectors observed
an electrical worker manipulate a similar breaker switch handle (with
the door open so the switch was not connected to the component) which
had a clearance tag on it.
The team noted that some personnel did not
regard this as a significant problem since the breaker itself was not
being operated. The team discussed the concern with Operations
management regarding the importance of strict compliance with clearance
tags in that such tagged components are not to be manipulated.
A
precursor card was initiated to address the issue.
The licensee's
Enclosure 2
12
review identified several other breakers in which the tagged switches
were not in the specified position due to the breakers being removed.
The team observed that white or "information* tags were extensively
,,
used.
Section 4.15 of Compliance Procedure CP 115, Nuclear Plant. Tags
- '
and Tagging Orders. contains procedural guidance for these tags.
The
information tags do not receive the same reviews as clearance tags arid
can be placed by any employee as directed by the department supervisor.
The team noted numerous examples in which the tags communicated valuable
information and were appropriate.
These tags were in heavy use on the
control boards and throughout the plant.
The information tags are
audited and are permitted to be installed for a maximum of three months
before reissue if required.
The inspectors notd that there was not a
pcsitive mechanism in place to prevent information on a white tag from
being reissued indefinitely.
Information tags were noted on temporary jumpers and on opened sliding
links. The team noted some instances in which information tags were used
to indicate that a component was not functioning properly due to a
maintenance issue but no work request sticker was present,
A few tags
provided guidance for the operation of balance of plant equipment.
Some
conditions were noted in which it appeared an information tag would be
appropriate but was not used.
For example, unidentified cabling and
other material was present in the back of the control room panels,
in
response to the inspector's question. it was determined that the items
were for future modification work.
The team concluded that close
monitoring of the use of information tags was necessary to prevent the
tags from being used as informal procedures, work around descriptions.
or in place of clearance or blue tags,
c.
Conclusions
A weakness was identified regarding a lack of strict compliance w1".h
clearance tags,
The team noted that information tags were
inconsistently utilized.
Enclosure 2
i
i
!
't
13
'
01.6 Eouinment Out of Service Reoort
a.
Insnection Scone (93802)
.-
The team reviewed the Equipment Out of Service Report and interviewed
operators to determine its usefulness for ensuring action statements are
satisfied.
Plant conditions were also reviewed to determine the
accuracy of the report.
b.
Observations and Findinos
The Equipment Out of Service Report was computer generated, kept in the
control room area, and was updated daily.
Guidance for the report was
in Section 2.0 of 01 07. Control of Equipment and System, Revision 7,
The report primarily includes equipment which was associated with TS.
the Plant Fire Plan, and the Offsite Oose Calculation Manual where an
action statement _was entered or tracked when equipment was removed from
service.
The Nuclear Shift Manager had the authority to add to the
report if desired for other equipment.
In the same section of the
notebook, non action statement equipment was also tracked. The team
reviewed the report and compared it to actual plant equipment or systems
removed from service and no discrepancies ware found.
Several operators were interviewed to assess the usefulness of the
report. All those interviewed stated that the report was reviewed prior
to assuming the shift and was one of several sources for_ tracking
equipment status and associated Sction statements.
Several operators
stated that the report was recently placed on computer, and there was-
some frustration associated with its use.
Some operators stated that
-the computerized report was slow and frustrating to use.
The. team performed a line by line review of portions of the report with
a senior reactor operator. There were several entries-that were
incomplete or were marked as *N/A' inappropriately.
'
c.
Conclusim s
The_ team concluded that the Equipment Out of Service Report was accurate
but was not being rigorously maintained.
Enclosure 2
14
02
Operational Status of Facilities and Equipment
02.1 Safety System Walkdowns
'
a.
Insoection Scoce-(93802)
The team performed walkdowns of portions of several safety systems.
The
inspections focused on valve alignment and overall conditions of the
systems.
b.
Observations and Findinos
A walkdown of the Decay Heat (DH) Removal system was performed.
The
team limited the walkdown to the B Train which was in operation as the
protected tnin during an A Train outage.
Accessible valves in the main
system flow p0th were in their correct positions and were generally
found to be in good condition.
The DHV-111 valve mechanical drive
position indicator (MDPI) was found not indicating properly. Work request 341871 hatt been previously generated to replace the MDPI chain
which would correct. the indication problem.
The team noted that a tag
had not been placed on the DHV-lll valve to alert operators that the
problem had already been identified.
No valves exhibited excessive
packing or boron leakage, missing handwheels or bent stems.
All
components were labeled; however, the laceling was not complete.
The
team found that component descriptions were not included on the labels.
As discussed in Section 02.4. the team was informed that a plant
labeling project was planned to correct overall plant labeling
deficiencies.
Power supplies for system valves and the pump were
verified to be in their correct positions with edequate labeling.
Piping supports were found to be in good condition.
Lighting in the DH
pit was adequate.
Control ocard switches and instrumentation were
properly labeled and were operating properly.
The team reviewed the
operating procedure in effect and compared it to the existing plant
parameters and no problems were found.
The team found that appropriate
measures were taken to protect against a loss of deca / heat removal.
Protected train signs were placed at the access area to the DH pit and
throughout the plant to ensure plant personnel received proper approval
prior to entering protected arets. The team concluded that the B Train
of the DH system was properly aligned and in good condition.
Enclosure 2
.
. - -
-
_ - _ _ _ _ _ _
_ _ _ _ _ _ _ _ _
____--
15
The team also performed a partial walkdown of the Nuclear Services and
Decay Heat Sea Water Systems.
There was a leak at the "A" decay heat
exchanger vent which was not contained or directed to a drain.
Additionally, a few missing labels and housekeeping deficiencies were
,
found.
c,
Conclusior ;
No safety significant deficiencies were identified during walkdowns of
portions of several safety systems,
Minor housekeeping and labeling
problems were noted.
02.2 Control of Temocrarv Modifications. Jumners. and Lifted Leads
a,
Insoection Stone (93802)
The team reviewed the effectiveness of the licensee's controls over
temporary modifications, jumper.c. and lifted leads,
b.
Observations and Findinas
In accordance with Operating Instruction 01-7. Control of Equipment and
J
System Status, the licensee maintains a Temporary Modification or
Temporary Modifi:ation Approval Record (T MAR) log.
The log indi:ated
that only five T-MARS were presently installed,
The team questioned why
several specific conditions noted during tours of the facility were not
classified as T MARS. One involved a temporary power supply to an
electrical distribution panel,
Another was a temporary chiller
connected to the control complex ventilation system. The licensee had
installed the temporary power supply under the Temporary Power Supply
control prograin which appears to have the required aspects of a
temporary modification program.
The temporary chiller was installed
under a work request as a maintenance support issue.
The chiller did
not appear to have any potential to affect control complex ventilation
under accident conditions.
The team reviewed Nuclear Engineering
Procedure NEP-210, Modification Approval Records (MARS).
Section V.C cf
NEP-210 addressed T-MARS and primarily descric.d T-MARS as being
prepared in the same manner as permanent MARS,
Procedure NEP-210 did
_ _ _ _
_
_
Enclosure 2
__
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
___-_
16
not define what activities should be considered as MARS. The team
concluded that requiring the same elaborate processes for T MARS as for
permanent MARS would discourage classification of activities as
.
Thelicenseecontrolledtemporaryjumpersthroughseveraladministrative
processes.
Processes such as operating procedures, clearances, and
modification procedures were used to install jumpers. A separate jumper
log is not maintained.
During the inspection, the team examined
numerous circuits and the interior of many cabinets. The team did not
identify any uncontrolled jumpers.
Three jumpers were noted in a back
control room panel.
The inspector verified that the jumpers were
installed in accordance with the operating procedure referenced on the
attached information tags.
The inspectors noted that the licensee did
nat utilize wiring with any distinguishable characteristics such that
installed jumpers would be easily observed.
While the jumpers did
'
contain an information tag, they were not easily discerned from other
wiring.
During inspection of the cong ol room panels, one of the inspectors
noted a lifted lead which was not tagged or marked as intentionally
lifted. Subsequently, the licensee identified that the lead had been
intentionally lifted for modification work, and it was re landed. The
licensee informed the inspector that the lead was controlled within the
MAR process. The inspector noted that a modification or information tag
would have been beneficial to an operator questioning the lifted lead.
c.
Conclusions
The lack of a separate program from the normal MAR process to control
temporary MARS could lead to temporary modifications being performed
without proper assessment.
No safety significant examples of this were
identified.
Jumpers and lifted leads were adequately controlled by
various mechanisms.
02.3 Control of Goerator Work Arounds and Control Board Deficiencies
-a.
Insoection Scone (93802)
The_ team _ examined the programs for the identification and monitoring of
Operations Work Arounds and Control Board deficiencies.
Enclosure 2
._ _ _._ _.__ _. __ _ __._._ __ _ _ _
. _ - -
-
1
r
,
'
17
b.
Observations and Findinas
,
.The licensee maintained a list of operator work arounds on a computer
bulletin board which could be accessed by Operations. personnel.
There'
.
were six work arounds listed as active. The team verified through
,
discussions with Operations management that most of the listed _ work-
arounds will be corrected prior to startup.
Although a formal procedure
was being developed to set forth requirements for classifying conditions
as work arounds, no procedure currently provided such guidance._
.
'
Operations personnel indicated that the procedure was expected to be
issued in January 1998.
The inspectors noted several equipment issues
which would most likely be classified as low priority work arounds under
a formal program. One example consisted of a series of equipment
problems-associated with the raw water system traveling screens. While
no single problem was significant in itself, discussions with operators
indicated that the combination of issues resulted in delays in
correcting increasing screen differential pressures. The taam concluded
that development of a formal work around process wwld i . beneficial.
The licensee monitors control board deficiencies as well as operations
equipment deficiencies as performance indicators, Operations equipment
deficiencies. include all identified problems in the field that have
associated controls on the main control board. Control board
deficiencies are associated with. control--board indication problems, The
licensee has established a goal of less than ten open control board
deficiencies. The team was informed that there currently were no control
board deficiencies. One of the inspectors walked down the control panel
'
and_noted several-problems-which appeared to be control board-
,
deficiencies.
After additional review the licensee revised the list of-
control board deficiencies to include at least six deficiencies.
c..
Conclusions.
The procedural. controls and emphasis on the work around program needed
'
to be improved.
Monitoring of control board deficiencies was not being
performed accurately.
'
L
Enclosure 2
i
i
f.
r ,1
,,,c~.,,
.,o_
r,'~
, _,
y._
-...y..,._,
,,...,,,m._-__.,,.r,.4.
, - . , . . . _ ,
~ , . . , . , . - - , . , , , _ , , .
,
, _ _ _ _ , . , _ _
-x
,. ,:
_ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _
____
_-
_ _ - _ _ _
18
02.4 Overall Plant and Ecuioment Material Conditions
a.
Insoection Scone (938.02.).
.
The team assessed overall plant housekeeping and material conditions.
b.
Obsevations and Findinas
During the first few days of the inspection, the team noted that
excessive condensation from the Nuclear Services cooling syste.ns piping
in the auxiliary building had the potential to cause problems.
The
condensation caused puddles to develop on the floor, some of which ran
across barriers posted as contamination areas and the stepoff pads for
those areas.
The wet floors could also result in personnel injury due
to slipping.
Some condensation was observed to be dripping on plant
equipment.
The situation was not conducive to good housekeeping.
Apparently, rc:ent weather conditions had resulted in heavier than
normal condensation.
The team noted that insulation had been successful
in correcting this problem in some specific areas. The licensee stated
that although intentions had been to use a generic Modification Approval
Record (MAR) to install insulation, outage workforce demands had
resulted in that MAR not being implemented.
Under the proper plant
conditions, the licensee can also utilize a valve alignment which heats
up the raw water supplied to the system.
This reduced the condensation
problem, but that alignment would not be successful due to current plant
conditions.
The licensee focused efforts on mopping up the condensation
and shielding equipment. As the weather changed, the condensation was
reduced.
The team also observed leakaa of rainwater through the
auxiliary building roof.
The licensee inspected for leakage and
concluded that earlier attempts to correct this problem through a MAR
were unsuccessful.
The licensee indicated that additional work will be
performed to seal around the ventilation exhaust stacks.
The team also noted that auxiliary building floor drain screens were
very dirty.
Bilge areas adjacent to the reactor building tendons
between intermediate building and the seawater room were dirty and
contained trash. A few items of trash were identified in the cable
spreading room. The interior of the control room cabinets were found to
be in good overall condition.
__
Enclosure 2
.
- - _ ~
.
_-
____-______-_ _ _
19
During numerous plant tours in multiple areas the team observed that
plant lighting was poor.
In particular, the team noted that the
!
secondary plant was dimly lit.
On one occasion in the turbine building.
L
two of the team members noted that five lights were either totally not-
.
working or partially-lit. The team discussed with an operator-during
rourids if. operators were notifying the Maintenance Department of the
lighting deficiencies. The operator stated that Maintenance had
,
informed operators to not document the deficiencies because a preventive -
!
maintenance program was in place to routinely replace faulty lights
-
throughout the plant.
The team cencluded that the licensee was not
effective in ensuring plant-lighting deficiencies were corrected as
'
needed.
The team noted that control of ladders in the plant appeared to be poor.
Some areas posted as ladder storage contained no ladders while-ladders
were locked or stored in areas not marked as such. The licensee
indicated that deficiencies were noted with th.' emergency operating
procedure (E0P) equipment and ladders during tne E0P inspection and-
corrective actions were i_n progress.
By the end of the same day that
the team asked about the ladders, although permanent installation
arrangements had not yet been--finalized, E0P_ ladders and equipment boxes
were prominently labeled and located in the plant.
The team noted that-in the areas where the restoration painting efforts
had been completed such as the 119 foot elevation of the intermediate
building. -overall housekeeping and material conditions were good. . Good
-
conditions were also-noted in the- room containing the control center
chillers and ventilation. systems.
Throughout_ the observations of field activities, the team observed
'
numerous inconsistencies in equipment labeling. " Magic marker" informal
labels were rioted throughout the plant, including inside some safety
system control cabinets in the auxiliary building. = Some gages were not=
labeled.
The inspectors noted that the recently issued labels were a
significent improvement over older tags which did not include functional
descriptions. The licensee provided the team a summary and status of
the' Plant labeling Upgrade Project.
The project-summary indicated that
-improvement such as bar codes and color coded borders for safety
components are planned.
The project has been divided into different
phases and priorities with completion dates in excess of a year.
,
Enclosure 2
_ . _ _ _ _ _ ...
. . _ _ _ _ _ . . _ . _
. _ _ _ _ ___ _ _ _ _ _
4
J
20
The team also noted that the control room urveillance log nomenclature
,
'did not always match the control board labeling. Althouv (he equipment
numerical designations did match those in the control r o ogs, a
4
potential for error remained.
,
.
c.
Conclusions
Numerous examples of poor housekeeping were noted.
Lighting was not
-
. effectively maintained and some areas of the plant were not well lit.
Numerous inconsistencies and deficiencies were identified in equipment
'
labeling.
The licensee's labeling upgrade program should be continued.
03
Doerations Procedures and Documentation
.
.
03.1 Doerations Procedures and Documentation
.
i
a.
Insoection Scoce (93802)
The team evaluated the availability and currency of normal.-abnormal.
and emergency operating procedures in the control room, including alarm
4
response procedures. The process fcc procedure revisions and the
backlog of procedure comment status was reviewed. Operators were
7
.
interviewed to determine if the process encouraged identification and
'
correction of procedure deficiencies. The controls over operator Aids
'
'
were also reviewed.
b.
Observations and Findinas
,
The licensee maintained all operating procedures on a computerized
- system known as " View / Print" which ensured controlled copies of
procedures were : sed. Sufficient computer terminals were available to
operators to access working copies of procedures as they were needed.
Controlled, hard copies were in the control room for certain procedures
such as alarm response and emergency operating procedures.
Other
controlled hard copies were maintained, depending on the frequency the
,
procedures were used: these procedures were for reference only. The
team observed the operators were able to access procedures easily from
-the computer system.
-
Enclosure 2
- .-
-
. _ _ _ _ _
_ _ _ _ _ _ - .
-_--
21
i
The team found that the current copy of the emergency operating
procedures (EOPS) in the control room were approved for use but not the
procedures that the operators had been trained on over the past several
training cycles.
The E0Ps were going through an extensive rewrite:
therefore, the operators had been trained on draft procedures.
The team
.
discussed with operators if they thought having the older, approved
procedures in the control room was a problem for accident mitigation and
the answer was 'no."
One of the SR0s stated that the changes that had
been made did not have a significant impact on the plant during Mode 5.
The operators indicated that they considered the new procedures to be a
notable improvement over the currently approved procedures.
The primary
feedback from the operators was that the new procedures flowed better.
The team discussed with both the procedures supervisor and operators how
a controlled procedure user was made aware that the procedure in use was
no longer the correct revision when a change was made to a procedure and
a copy was already in use.
Once procedures were requested for use as
working copies. a specific number were issued.
When the procedure
changes. Document Control informed the associated department, and the
user was to be immediately informed to determine '.f the new revision had
any effect on the evolution in progress.
The team questioned this
practice because it might not place appropriate responsibility on the
procedure user to ensure the procedure in use is the correct revision.
During a review with an SRO of completed shift turnover check lists, one
of the inspectors identified that the wrong revision of Al-500. Conduct
of Operations. had been used by the shift clerk.
The licensee later
determined that Document Control had properly notified Operations of the
procedure change to AI-500. but appropriate action to notify the
procedure user was not performed by Operations personnel.
It was
subsequently determined by the licensee that use of the wrong revision
of Al-500 had no detrimental impact on the procedure use.
-A precursor
card was initiated to address this issue.
On December 12, 1997, the team observed control room operators
responding to a loss of the plant computer.
The loss was recognized
quickly and the operators immediately began the actions required by
Abnormal Procedure AP-470. Loss of Plant Computer.
After most of the
as_ ions had been completed, the operators noted that the revision being
used was not the latest.
The procedure had been revised and issued the
previous day.
Another book of procedures in the control room contained
Enclosure 2
- _ _ .
_-___
. _ _ - - -
-
-
-
_
.
.-.
.. -
22
the latest revision,
The operators went-through all steps of the
procedure again and ensured that necessary actions were completed. A
precursor card was issued to address the issue.
.
The comment status backlog was reviewed with the procedures supervisor.
The general trend indicated that the backlog was decreasing. As of
'
December 7. 1997 there were 451 outstanding comments for procedures that
affected operators.
The team noted that most of these comments were
associated with surveillance and oMrating procedure changes that were
needed as the result of recently completed modifications.
The
supervisor stated that the backlog was aggressively being pursued, but
the operators continued to suggest procedure enhancements actively which
has slowed progress of backlog reduction.
The team discussed with operators if the process for submitting
procedure comments encouraged operator involvement.
In general, the
team found that operators were familiar with the process and were not
hesitant to suggest changer.
During these discussions the operators
informed the team about the computer system used to document comments.
The system, known as Nuclear Procedure Observations / Suggestions Tracking
(NUPOST), was demonstrated by the operators. The NUPOST system appeared
to be an effective means for operators to suggest recommended procedure
changes.
On numerous occasions the team observed operators performing evolutions.
These evolutions included operation of an emergency diesel generator
both in the field and in the control room, testing activities, inverter
alignment, and equipment alignment checklists
The procedures were
followed step by step with good communications between the operators.
In general, the team found that operator adherence to procedures was
good. Other sections in this report also describe positive observations
regarding procedural adherence.
During discussions with cperators concerning decay heat removal. Loe
team found that several operators did not know how long it would take to
uncover the core and boil the core if decay heat removal was lost. The
operators pointed out that time to uncover and time to boil curves were
available in their operating procedure, but the curves did not address
the current operating condition because the plant had been shutdown past
the evaluated time.
Later, a SRO trainee presented a calculation that
had 'oen previously performed that showed the worst case time was 27
Enclo ure 2
_ _______ - _ _
23
l
l
hours:for_ time to boil. The team found that adequate procedural
L
guidance _for the time to uncover / boil curves was not available. The
'
team considered this as an-area for improvement.
.
Operating Instruction 01-17. Operator Aidi, provides guidance fo' the
control of operator aids. A list of acts /e operator aids was' included
in the Control Center Notebook.
The tean questioned what appeared to be
i
two operator aids which were_not on the list. One was associated-with
the radiation monitoring console on a_ control room front panel. The
other was on a bbck panel-in the control room
Subsequently, the
licensee reviewed the aids and determined that they were inaccurate.
The aids were removed,
c.
Conclusions
The availability of computerized programs such as NUPOST and View / Print
was considered a strength.
Procedure adherence and usage was good.
1
Several uncontrolled operator aids were identified. There was no
_ procedural guidance for. time to uncover / boil curves during extended
shutdown conditions. Two deficiencies were noted associated with
revisions of controlled procedures.
04
10perator Knowledge and Performance
a.
Insoection Scone (938021
The team assessed operator knowledge of principle technical
specification requirements. ProDabilistic Safety Assessment (PSA)
-results, and major plant systems.
b.
Observations and Findinas
The inspectors observed an adequate level of technical specification-
awareness. The TS were considered when appropriate.
Low Ten.perature
Overpressure Protection and safety system operability requirements were
discussed. Although the SRO was responsible for the entering and
exiting limiting condu. cs of operation, all licensed personnel were
su Ficiently knowledgeable of the requirements.
Enclosure 2
-_
__ _ _ - _ _ _
24
The team interviewed several operators regarding the probabilistic
safety assessment (PSA) results.
The team considered that operator
awareness of PSA results was important for understanding the risks
associated with removing equipment from service during power operation.
Generally, the operators were not aware that the small break loss of
.
coolant accident was the dominant accident type,
Furthermore, the most
important plant systems from a PSA perspective were not generally known.
The operators typically thought that the loss of offsite power was the
most important accident and the emergency diesel generators were the
most important plant components.
The team noted that PSA posters were
subsequently placed in the control room office and work control center
l
areas to better inform operators of PSA results. The team concluded
that the PSA posters were a positive initial action, but further
training in this area was needed.
The team interviewed numerous operators at all watch stations to
determine their overall knowledge of plant systems and activities.
The
team found that operators :.nderstood system operation, location of
important equipment, and interaction of plant systems to ensure safe
plant operations. . Operators were aware of major plant activities
including the circumstances surrounding the loss of annunciators
discussed in Section 01.1 emergency diesel generator testing and
maintenance activities to repair seal leakage on the DH system Train A
pump.
In particular, all those interviewed knew the backup method of
providing diay heat removal if the operating DH train was lost,
c.
Conclusions
Operator knowledge of significant PSA information needed to be improved.
Overall knowledge of Technical Specification requirements and system
operations was good.
06
Operations Organization and Administration
a,
Insoection Scooe (93802)
The team reviewed the Operations Department's use of overtime since
January 1997. Administrative Instruction Al-100. Facility
Administrative Policies, and records of authorizations to exceed
overtime limitations were reviewed.
Enclosure 2
J
__
._____________-__
_
.
. . . .
..
..
.
..
25
b.
Observations and Findinas
The team found that the Operations Department had routinely scheduled
significant overtime for both licensed and nonlicensed operators.
Since
,
about pay period number 17. the team found that the average number of
overtime hours worked for each operator on-shift was about 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> or
more per pay period or about 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> per work week. The team noted that
,
there were 5 cases in which Operations personnel were approved to exceed
l
l
the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limitation and 29 cases when the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />
l
'
period limitation was approved.
The team discussed the use of overtime with the licensee who stated that
the Operatiens Department was under staffed but actions had been taken
to increase the staff size in 1998.
The team was informed that several
,
more licensed operators would be available to provide shift manning
l
relief.
During the inspection, including numerous observations during
'
backshift hours the team did ot observe any indications of significant
operatc* #atigue.
c,
. Conclusions
Operations personnel worked significant amounts of overtime during the
last several months of the extended shutdown. The team did not observe
any indications of significant fatigue on the part of the operators.
The licensee had decided to place personnel experienced in operations
into other working groups and will need to continue efforts to obtain
more licensed operators to decrease-the required working hours.
07
Quality Assurance in Operations
07.1 Doerations Self Assessments
a.
Insoection Scoce (93802)
The team reviewed the Operations self assessment prc3 ram described in
Administrative Instruction Al-501. Conduct of Nuclear Plant Operations
Assessments.
One of the inspectors discussed the program with an
Operations supervisor extensively involved with the program.
Late in
the inspection period, the te6:.i reviewed selected completed self
Enclosure 2
,
-
-.
. - -
.
- . _
. -.
--
26
assessment forms and a recently completed Operations Readiness for
Restart self assessment.
The team also reviewed a recently completed
self assessment modeled on the Operational Safety Team inspection
procedure.
,
b.
Observations and Findinas
The Al-5'
self assessment fc ms were highly detailed and lengthy.
For
example, one watchstander proficiency assessment form was seven pages
long and sked for ratings in about sixty specific observation areas.
With the assistance of an Operations supervisor, one of the inspectors
selected a sampling of completed assessment forms from over the last
year. The forms were completed as required. with the majority of
ratings assigned as a "three" (all expectations met at all times).
The
inspector noted that some of the assessments contained comments and
indicated that the observer attempted to perform a quality assessment.
Some of the forms contained critical comments and ratings of 1
-
(Immediate corrective actions needed), and 2 (Deficiencies noted).
The
assessments completed by peer level individuals were typically not as
critical as those performed by supervisory personnel.
The reports were
reviewed by the Nuclear Shift Supervisor as required by 41-501. The
inspector concluded that the highly detailed specific cature of the
assessment forms invites a " checklist" approach to the assessments.
Most of the assessments did not contain discussion of perceived causes
or underlying issues.
The inspector noted that Al-501 does not require periodic reviews of the
completed assessments for trends r overall performance evaluation.
Additionally, the involvement of
e. Nuclear Shift Supervisors seems
limited to reviewing completed assessments for their shifts. The
inspector was informed that these characteristics had been identified in
the Operations Organizational Readiness for Restart self assessment
completed in September 1997. The inspector reviewed the report of that
assessment and noted that these issues were discussed,
The supervisor
described corrective actions already in progress which indicated that
the self assessment program was being significantly strengthened.
Al-
501 is being revised.
The intention is that Operations management will
periodically perform reviews which will incorporate results of completed
assessments along with other performance indicators.
Additionally.
~
Enclosure 2
l
27
" focus" areas wil1 ~be developed based on 1he performance trends. The
- 1icensee-also plans to strengthen the rob of the iluclear Shift. Managers
in the assessment program.
.
The team noted that the Operations'0rganizational Readiness for Restart
self assessment, completed in September 1997, was highly detailed and
self critical. Many issues that the team noted as vulnerabilities or
I
deficiencies were addressed in that assessment.
Operations management routinely monitored a series of performance
indicators. The inspector was provided a copy of the indicators _ dated
November 14. 1997.
Operator / tagging errors per opportunity, number of
Operations Precursor cards generated, self assessment results, and
overtime hours were included in the indicators tracked. The inspector
noted that the percentage of Operations deficiencies documented by
Operations was about 65 percent for the most recent month in the report.
The-inspector was informed by Operations supervision that this value is
typically about 80 percent and was lower that particular month as the
'
result of a series of quality assurance audits of Operations'
The team
.
noted that 80 percent indicates that, for the most part. Operations is
-
identifying and-documenting its own problems.
Throughout the inspection, the-team noted that Operations promptly
initiated precursor- cards to address identified deficiencies.
The
Operations department threshold for initiation of precursor cards seemed
appropriate,
c.
' Conclusions-
.The team concluded that the licensee had plans for strengthening of the
current Operations self assessment program.
OS
-Miscellaneous Operations Issues
-08.1 Chemistry Succort of Plant Ooerations
a.
Insoection Scoce (93802)
The team reviewed the control of chemistry sampling required by
Technical Specifications (TS)
and the Offsite Dose Calculation Manuai
(00CM).
.
Enclosum 2
.
.. ~ _
.
.
_ _ _ . __
_
_ . _ _
_
_ . ~ _ _ _ . _ _ . _ _ - _ .
t
.
- 28
- .
-
- b.
Observations and Findinos
'
0perations personnel were responsible for. identifying plant conditions-
,
.
that required sampling. : The identification of such conditions was aided
>
by appropriate steps in the applicable operating procedures and-
annunciator response procedures-
$
- Once notified by operations, chemistry personnel were held responsible
.
for the sampling, analysis.-frequency and timeliness.
Chemistry
personnel used. STIs. shift turnover sheets and the. chemistry
-laboratory's " white board" to_ track the required sampling. Although
L, ,
these methods of sample coordination seemed infsrmal, they also appeared
effective.
No missed sampling requirements were identified.
<
c.
Conclusions
.
'
'
Chemistry sampling required by _ Technical Specifications and _the-Offsite
~0ose Calculation Manual was properly implemented.
-
- 08.2 (Ocen) Insoection Followuo Item 50-302/97-14-01) review of-operational-
procedures prior to restart. This item was: identified as a result of
'
inspection of the pending changes (NUPOST items)'to Procedures _0P-402
for the makeup and purification system and OP-404 for the decay-heat
,
_
removal system.
The inspection determined:that these procedures had a
number of pending changes, and the number of changes had recently risen
_
dramatically.
As a result, the Inspector Followup Item was opened to
[
review the! status of_ pending: changes for all operations procedures prior
F
_to restart of the unit. The team conducted a review'of current pending
changes to OP-402 and OP-404.and noted the pending changes had-been
reduced to six and five, respectively, as opposed to twenty' two and
,
fourteen.: respectively.- during the earlier initial inspection. The
inspection team also revieud the status of_ pending changes to all other
4
operations procedures pruided by the licensee. -The team determined
-
that most of the procedures had very few pending changes: however,
,
approximately fourteen of the procedures hao over ten NUPOST items,
,
t
which indicated a fairly significant need to' revise those procedures.
From this review the team concluded that the licensee had made some
progress toward correcting the backlog of pending NUPOST changes to
'
Enclosure 2
i.
4
9
.. .-
4
. . - .
.
. . . _ ,
.
__
. ,
. , .
,
,
_ . .
. _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _
29
I
operations procedures but,some weakness still existed in *.his area.
This item will require additional followup prior to restart and will
-
' remain open.
'
II. MAINTENANCE
-This inspection included an assessment of the current status of the licensee
programs for Maintenance and Surveillance.
M1
Conduct of Maintenance
l
r
M1.1 Maintenance Observations
- a.
Insoection Stone (93802)
'
The team reviewed maintenance program procedures. observed maintenance
in process and examined records of completed maintenance to evaluate the
effectiveness of.the licensee *s. maintenance program,
b.
Observation and Findinas
-
-b.1
-Review of Procedures
The team reviewed the following procedures and other licensee-
'
documents during .the observation of maintenance in process and
-
review of maintenance records:
'
AI-400C Revision 22. New Procedures and Procedure Change
.
Process
Al-500. Revision 96. Conduct of Operations. Operations
.
Department Organization and Administrative
Al-600. Revision 57. Conduct of Nuclear Plant Maintenance
-
AI-605. Revision 6. Preventive Maintenance Program
.
Al-607. Revision-2. Pre-Job and Post-Job Briefings
.
CP-113A. Revision 22. Work Request Initiation and Work
-
Package Control
Enclosure 2
'II
-
.
- . . .
. .. .
.
...
.
_ _
_
_
_ _
_
--
- _ _ _ - _ _ _ _ _
. ..
.
.
'
30
-CP-113B.- Revision 23, Work Request Evaluation / Planning
.
)
CP-113C, Revision 5 Inspection Planning-
.
!
!
'
CP-1130. Revision 0. Post Maintenance Testing
-
CP-116A, Revision 5. Foreign-Material Exclusion (FME)
-
Control program
CP-143. Revision 2 Repeat Maintenance Program
.
Identification, Evaluation, and Tracking
u
!
i
CP-146, Revision 2 Measuring and Test Equipment Calibration
.
-and Control
Nuclear Maintenance _ Manual Revision'13,
-.
Crystal River Maintenance Improvement Plan, dated October
.
27,-1997
Task-Performance Manual - Nuclear Electrician, Revision 8
.
Task Performance Manual - Nuclear Mechanic, Revision 13
-
Task Performance Manual - Nuclear Technical Support
.
Technician. Revision:10
- Current TPM Performance Matrix- for the Maintenance Shops
.-
In general, the procedures _provided adequate detai~ N the
control of maintenance. Although Procedure AI-500 covered the
operation of_the Work Control Center for Operations review and
approval of maintenance activities, the concept of having work
control outside the control room was relatively new, and _the
Center--was-not fully staffed (see Sections 01.1-and 01.4). 'The
licensee planned to staff the Work-Control center fully as
sufficient new Senior Reactor Operators (SR0s) are certified.
Enclosure 2
m
. . _ . .
. _ . _ _ _ _ . _ _ _ _ . . _ _ . _ _ _ _ _ . _ _ _ _ _
d
>
f.
31
' :--
b.2
Observation of In-orocess Maintenance
Selected portions of the following in-process maintenance
activities were observed to verify the maintenance was planned.
-
. .-
controlled, and performed in a manner to. enhance safe operation of
>
the plant:
4
Work Request (WR)'NU 0350053. EqLipment -Tag DHP-1A, Decay-
-.
-Heat Pump 1A - Repair Leaking Mechanical Seal, Replace
.
Rotating Assembly with Spare Unit
,
i
WR NU 0348477, Equipment Tag AH-359A-DPS, Air to EGDG-1A
.-
>
Room Fan AHF-22A Switch - Replace and Calibrate Switches
WR NU 0343807. Equipment Tag EFGV-1. Emergency Feedwater
.
Turbine Driven Pump Governor Valve - Perform PM on EFGV-1
-
Governor Valve
,
WR NU 0345426. Fire Protection Sprinkler System Piping -
.
. Replace Leaking Piping
.
WR NU'0350C90. Equipment Tag DF-2-LS. Emergency Diesel
.
~
Generator EGDG-1A. Day Tank'3A Level Switch --Determine cause
-for DF-2-LS Switch Failure to Control' Level-
i
.
WR NU 0350405. Equipment Tag EGDG-1A, Emergency Diesel
.
i-
Generator
Perform Engine inspections on EGDG-1A After MAR
Functional Testing.
WR NU 0350608.. Equipment Tag, 'BXS-3C.? Static Switch for
-
i:
Inverter VBIT-1C Auto-Transfer - Troubleshoot / Repair VBXS-3C
Problems
-
WR NU 0350651. Equipment Tag SP-23-LSI. EFIC RCSG-1B
.
Overfill Trip Bistable.-Cabinet C - Troubleshoot and Repair
EFIC Channel C Overfill Circuit
p
WR NU 0348706. Equipment Tag NI-5-A13. Uncompensated Ion-
Chamber Assembly. Perform Performance Test PT-180
.
1
I
Enclosure 2
,
4. x -
4
-,
. , - - ,
.
--
.
c
.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
-
l
L
32
WR NU 03E4760. EGDG 1A Air: Compressor'- Investigate and
.-
Repair. Diaphragm'in Unloader.has Ruptured
b.3
The team reviewed the-following completed WK pCCkages to assess
,
.the adequacy of documentation of completed work:
WR NU 0341867 Equipment Tag-SWV .200 - Replace Valve Packing-
-.
WR NU 0347857 F.quipment Tag EFV-13 --Install / Tighten loose.
-
or Missing Fasteners Found on Valve During Testing
WR NU 0349491. Equipment Tag.EF-400-JNO - Resolder Lug for-
.
Power SLpply
WR NU 0349435. Equipment Tag MTMC-22-1EG. MCC Feed for MUV-
.
58 - Adjust .Swi_tch Linkage to Prevent Breaker from Tripping
WR NU 0349426. Equipment Tag MTSW 3G-1B-52. 480V ES Bus 3A
-
Main Feed Breaker-3310 - Troubleshoot the Cause of the Green
4
Light not-Operating Properly
WR NU 0347624 Equipment Tag ESCC-3A AT. ES Actuation "A"
-
Channel Cabinet Fan BM-03A - Troubleshoot Reason for' Fan
Blowing Fuse
. -
WR NU 0338613. Equipment- Tag BSP-1A . Reactor Building Spray
Pump 1A --Remove and Reinstall (after vendor work) Pump
-Impeller
WR NU 0349421. Equipment Tag RWP-3B DH Service Seawater
.
Pump 3B - Coat Inside of. Pump-Discharge with Belzona
WR NU_0349867. Equipment Tag RP A29. RCPM Contact Monitor -
-
Determine Problem with Optical Isolator for #3 Light on RP-
A29(Al-3-4)
WR NU 0349933. Equipment Tag ARV-51. CDHE-4B (West) Vacuum
-
Breaker - Troubleshoot ARV-51 Not Stroking From the MCB
Enclosure 2
.
_.
33
WR NU 0349985. Equipment Tag RC-1-IB1-1. Pressurizer Level
.
from XMTR 1 NNI Input - Replace the Existing Module with a
New Module
WR NU 0350074. Equipment Tag RV-14A-EB1, Reactor Coolant
.
'
Flow (Temp Uncomp) - Calibrate / Repair RC-14A-EB1
NU 0349871. Equipment Tag EFIC-A. Emergency Feedwater
.
Initiation & Control Cabinet A
Determine Problem with EFIC
"A" Based on Event Point 2012 Alarm
During the above in-process observations of maintenance activities and
reviews of completed WRs. the team evaluated the following maintenance
program attributes:
use of current written and approved instructions detailed enough
.
to perform the intended maintenance and adequately document the
maintenance performed.
appropriate prioritization and timely disposition of maintenance
.
jobs that could affect technical specification limiting conditions
for operation of safetv related equipment performance or influence
safe operation of the plant.
appropriate coordination of maintenance activities with control
.
room operations, including appropriate briefings and turnovers
with control room operators and appropriate equipment isolation
and tagging.
appropriate training and qualification, including documentation,
.
of craftsmen for level of work being performed.
control of preventive and corrective maintenance backlogs,
.
including controls of deferrals and efforts to integrate
preventive and corrective maintenance to minimized unavailability.
performance in conducting PM activities on schedule and contr(1
.
over deferred preventive maintenance.
Enclosure 2
I
J1
__
_ - _ _ _ .
34
trending ')f corrective maintenance history to deal with high
.
maintenance components, including identification and trending
repetitive maintenance.
appropriate level of engineering input into maintenance
'
.
activities.
conduct of OC inspections during the performance of maintenance.
.
including the adequacy and appropriateness of OC hold points.
performnce of appropriate PMT. including engineering involvement
.
in specifying PMT.
control of M&TE. including calibrations at required frequencies,
.
tracking equipment, evaluation of past work where M&TE is found
out of calibration. control of contaminated M&TE.
controls for the team for performing immediate or minor
.
maintenance, and
appropriate foreign material exclusion practices.
-
For the in-process activities observed and the records reviewed, the
team found that maintenance was being performed in accordance with
procedures in a quality manner by trained and qualified craftsmen.
A_
strong maintenance supervision presence and involvement was evident and
all maintenance personnel had a positive attitude about performing
maintenance correctly.
The team found the training and certification
program for maintenance personnel to be comprehensive with detailed
multiple task performance training requirements specified for each
discipline.
The team considered training to be a strength. Activities
relative to FME controls. OC hold points, pre-job briefings interface
with operations and engineering, post maintenace testing, and control
of M&TE were performed in accordance with program requirements and were
found to be satisfactory.
During review of completed WRs. the team found that, for
" troubleshooting" work in accordance with Procedure MP-531. PMT
requirements were not added to the WR until after the corrective actions
had been determined. There was a possibility that the added PMT
requirements would not receive Operations review and approval as
Enclosure 2
35
required by Procedure CP-1130.
The team considered this to be a
weakness. The licensee immediately issued Precursor Card (PC) 3-C97-
8456 to evaluate this weakness and take corrective actions.
During review of WR NU 0349421, which covered coating the discharge
'
nozzle of the 3B DH Service Water Seawater Pump with bel. ZONA because of
co,'rosion, the team noted that the WR package did nnt provide any
,
documentation to show that the nozzle minimum wall thickness was still
acceptable. After investigatino, the licensee found that the depth of
the corrosion had been measured ar.o the minimum wall thickness verified
by ultrasonic inspection.
The documentation for these measurements was
in OC inspection records but was not included or referenced in the work
,
package.
PC C-397-8357 was issued to evaluate this problem. The
'
inspection records were added to the work package.
!
During the day shift pre-job briefing for WR NU 0350053 (change out of
the DH-1A Pump Rotating Assembly), the team noted that Operations was
not represented in the briefing.
Procedure AI-607 required that
Operations be involved in pre-job briefings if the activity could render
Emergency Core Cooling System (ECCS) equipment inoperable.
This
appeared to be an isolated case, since Operations was represented for
all other briefings observed where their presence was required,
including the night shift for the DH Pump 1A work.
PC 3-C97-8370 was
t
issued immediately to evaluate this problem.
The team noted a strong emphasis on control of maintenance backlogs.
The corrective maintenance backlog had been reduced from 433 in August
1997 to 171 at the time of the inspection. The number of overdue (more
than 25% past due date) PMs had been reduced from approximately 90 in
August 1997 to approximately 10 at the time of the inspection.
At the
time of the inspection, overdue PMs required completion of extension
requests and approval with detailed justification.
In addition, overdue
PMs were high-lighted for management attention in the " Plan of the Day"
on Thursdays, and the total number of overdue PMs was tracked for
management review in the Weekly Performance Indicators.
For scheduling.
PMs were included in the new Work Week management Process which
implemented a rolling 12-week master schedule, planned to be implemented
the first week of January 1998.
This process should help assure that
PMs are performed on schedule.
The team considered the control of
maintenance backlogs to be a strength.
<
Enclosure 2
l
_ . . . . - _
36
The team found that evaluation of the effectiveness of the PM program-
was not a proceduralized process. Although, on a periodic basis, the PM-
Coordinator reviews all new corrective maintenance.WRs for impact on the
PM program, this was not proceduralized.
In addition, it was only
accomplished for equipment tags that had established PMs. Also, there
. was no: evaluation _for repeat maintenance to determine if the PM program
' needed to be changed because of repeated equipment failures.
The-team-
-
considered the lack of a formal evaluation of the effectiveness of the -
PM program -including evaluation of t_he effect of repeated maintenance
-
on the program, to be a weakness. The licensee issued PC 3 C97-8560 to
evaluate this weakness.
Relative to repetitive maintenance, the team found that corrective
maintenance WRs were being reviewed to determine if equipment _ problems
- were repetitive and the information was being documented and tracked in
the equipment history.
However, the data were not being used to monitor
D
and improve maintenance.
The team considered this to be a weakness.
The licensee pointed out._that a previously issued PC-(3-97-6927) had
identified problems with.the repeated maintenance program and that the
corrective actions for-this PC would-address the weakness identified by
the team.
Corrective actions for the PC were not scheduled to be
completed until' January _15, 1998.
The team no'ted that the Minor Maintenance Program was well defined with
detailed limitations on-what can be worked under minor maintenance
rules. However, the responsibilities of the quick response maintenance -
team-(Gator Team at Crystal' River), the organization responsible for
minor maintenance were not formally-proceduralized. The team-
considered this-to be a weakness,
Further discussions with-maintenance
management'. revealed that their Maintenance Improvement Plan, dated
October 27, 1997, had identified actions to evaluate and _ define the
responsibilities for the Gator Team,
c.
Conclusions
Overall the Maintenance Frogram was adequate-to support restart of the
unit. Maintenance was being performed in accordance with procedures in
a quality manner by trained and qualified craftsmen.
In general,
maintenance procedures provided adequate detail for the control of
maintenance. The strong maintenance supervision presence and
involvement at the job site was considered a strength.
Maintenance
Enclosure 2
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..
J
. _ _ - - _ _ - _ _ - _ _ _
..
.
-
'37
personnel had a positive attitude about performing and documenting
maintenance correctly.-and procedure use was good.- The maintenance
training and certification program, which was comprehensive with
detailed multiple task performance training requirements specified for
each. discipline, was considered a strength.
Corrective and preventive
t
'
maintenance backlogs w' .'e hv. and the strong emphasis on control of-
maintenance backlogs wo
4sidered a strength. Activities relative to-
,
FME controls. QC hold points, pre-job briefings, interface with
- operations and engineering post maintenance' testing, and control of
_
_M&TE were performed in accordance with program requirements and were
found to be satisfactory.
The following programatic weaknesses were 1&ntified:
There was a possibility that. for "troublehooting" WRs. the added PMT
requirements would not receive Operations review and approval as
required by procedure.
'
,
.The process for evaluation of the effectiveness of the. PM program,
including evaluation of the effect of repeated maintenance-on the
program, was not formalized.
Repetitive maintenance was being documented 'and tracked but was not
.being used.to monitor and improve maintenance of equipment.
E
The responsibilities for tne " Gator Team" (quick response maintenance
-team) were not proceduralized.
.M1.2 Maintenance Rule Imolementation
a.
Insoection Scone (62706)
This portion of the inspection was conducted to review the licensee's
Maintenance Rule program. The inspection was not intended to establish
a baseline for the program but rather was conducted to determine if the
licensee's program was adequate to support the restart of Unit 3.
The
Maintenance Rule Baseline Inspection at Crystal River is currently
scheduled for the first half for June 1998.
Enclosure 2
______
._ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _
38
During this inspection effort. the Team examined the following licensee -
procedures and documents.
CP-153A. Revision 0 Maintenance Rule Implementation
.
.
CP-1538.- Revision 1 Monitoring the Performance of Systems
.
Structures and Components Under the Maintenance Rule
AI-255. Revision 6 On-line System Outage Preparation and
-.
Implementation
l
PM-156. Revision 0 Visual Inspection of Plant Structures -
.
Report R020-97-002. Revision 0 Maintenance Rule Structural
.
l
Baseline Inspections
b.
_ Observations and Findinas
The inspection in'cluded a review of the following Maintenance Rule
areas: Scoping.. goal setting and monitoring, performance criteria.
Maintenance Rule structural inspections, expert panel activities.
Probabilistic Risk Assessment (PRA) basis for the Rule, balancing
reliability and unavailability, periodic assessment, risk assessment for
on-line removal of-equipment from service, and self assessments of Rule
-
implementation. The review of these areas was cnnducted as follows:
The team requested the licensee to provide a listing of all structures,
systems. 'and' components not included in the Rule. This listing was
reviewed to determine _if- there were any obvious omissions.
The team.
reviewed the' goals and monitoring established when the control room air-
handling system was put into-(a)(1) as a result of repetitive
maintenance preventable functional-failures. The team also reviewed the-
expert panels approval for return of this system to (a)(2) status. A
_j
sample of performance criteria for both risk and not risk significant
__
systems under the Rule was reviewed. The team reviewed the program
procedure; the structural-inspection checklist examples of _ inspection
deficiencies identified, and the finai Maintenance Rule Structural
Inspection Report. Meeting minutes from expert panel meetings held
October 24 1997 and November 25. 1997 were also reviewed.
dCtiVities associated With implementation of the Rule were reviewed to
determine if an adequate technical basis for Rule implementation b;d
been established.
This review included risk ranking, and the P'A basis
Enclosure 2
..
. . . .
..
..
. __ _ _u
_ _ _ _
39
for establishment of performance criteria.
The licensee had not
accomplished a periodic assessment or any balancing of reliability and
unavailability, so the licensee's ;. ocedure was reviewed for compliance
with NUMARC guidance in these areas.
The team reviewed the licensee's
on-line risk _ monitor which-is to be used by the licensee to assess risk
,
when removing equipment from service during on-line operations. The
team also reviewed the Sargent and Lundy Assessment of the FPC
Maintenance Rule dated March 18, 1997, and the Nuclear Quality
Assessment's Audit 97-09 dated October 30, 1997, as well as, the status-
of corrective actions for these assessments.
'
,
i
The team did not identify any problems with regard to scoping of
'
'
l
structures, systems, and components under the Rule. The goals and
monitoring for the control room air handling system were adequate, and
?
the expert panel decision to place the system in (a)(2) status following
completion of monitoring was appropriate. The performance criteria
reviewed were in accordance with NUMARC guidelines, and there appeared
to be an adequate basis for these criteria in PRA.
The licensee's self
assessments of implementation of the Rule were comprehensive; however.
corrective actionsifor several of the findings were not completed.
The
licensee had developed and implemented an on-line risk monitor as a tool
for assessing risk when removing equipment from service during power
operations. The team considered this a strength.
The inspections of'
-structures under the Rule were comprehensive and documentation of
-deficiencies was excellent. The team did note that the licensee had not
evaluated the deficiencies to determine if any structures needed to be
placed under (a)(1) of the Rule with goals and monitoring established.
1
This was considered a weakness. The licensee-reviewed the structural
deficiencies during the inspection and determined that no structures
needed to be classified as (a)(1).
c.
Conclusions
The Maintenance Rule Program was adequate to support restart of the
Unit. As a result of the self assessment process, the licensee had
initiated several program enhancements, which were ongoing during the
-
inspection
Efforts on these enhancements needs to continue. Two
strengths and one weakness were observed:
Enclosure 2
40
Strengths:
The licensee had developed and implemented an on-line risk monitor
.
as a tool for assessing risk, when removing equipment from service
during power operations.
'
Inspection of structures under the Rule were comprehensive, and
.
documentation of inspection deficiencies including the location
and ntent of condition was excellent.
Weakness:
Lneficiencies identified by the structural inspections had not been
.
evaluated to determine if any structures should have been
classified as (a)(1) under the Rule with goals and monitoring
established.
This weakness was corrected during the inspection.
No structures were classified as (a)(1).
l
M1.3 Surveillances
a.
Insoection Scoce (93802)
The team reviewed surveillance scheduling procedures and computer
schedule output, reviewed surveillance performance procedures. observed
surveillances in process, examined records of completed surveillances,
and interviewed involved plant personnel to evaluate the effectiveness
of the licensee's surveillance program.
The inspec'.:on concentrated on
the surveillances required by the Improved Technical Specifications
(ITS) but also included several examples of surveill . ices not required
by the ITS.
b.
Observation and Findinas
b.1 St,rveillance Schedulina Process
The team reviewed the following scheduling-related procedures and
interviewed surveillance scheduling personnel to determine the
scheduling process:
SP-443. Rev. 109 Master Surveillance Plan
SP-440. Rev. 69 Unit Startup Surveillance Plan
Enclosure 2
,,
..
..
..
_ _ _ -
-
41
SP-441. Rev. 43 Unit Shutdown Surveillance Plan
e
SP-442. Rev. 69 Special Conditions Surveillance Plan
e
CH-400. Rev. 10 Nuclear Chemistry Master Scheduling Program
The licensee's actions to assure proper scheduling of surveillances
involved both manual and computer actions.
The SCATS computer program
specified the schedules and performance procedures for surveillances
required at specific time intervals (e.g., 92 days) on a calendar basis,
with SP-443 as a backup reference.
Procedures SP-440 through -442
provided the schedules and the procedures for surveillances required to
be performed when shutting down, for startup, or in response to specific
plant conditions.
Procedure CH-400 specified the schedule for routine
chemistry surveillances.
The history of performance of each
surveillance procedure was maintained in the SCATS database.
Surveillance schedulers reviewed completed surveillance procedures upon
receipt and updated the SCATS history.
Periodically, the surveillance
schedulers obtained output listings from SCATS identifying dates
specified for upcoming surveillances. These dates were manually input
,
to the licensee work schedule.
The work schedule was also manually
updated to include surveillances required by SP-440 through -442 in
response applicable plant conditions. Tolerances on the performance
dates for surveillances were determined based on the ITS limits and the
dates of last performance given in SCATS.
The inspectors were informed that a new computer program for scheduling
surveillances would be instituted about February 1998. This program
would reportedly require fewer manual entries and less monitoring by
scheduling personnel than the current program.
Both programs would be
maintained in parallel initially, until confidence was obtained that the
new program operated satisfactorily.
b.2 Procedures for Imoroved Technical Soecification Surveillances
The team conducted a review to verify that procedures had been prepared
for performing the surveillance requirements specified in the ITS. A
sample of 17 surveillance requirements was selected by the team, the
performance procedures were identified by licensee personnel, and the
team then verified that the procedures contained the appropriate
surveillance requirements and acceptance criteria.
In addition. the
team verified that the correct surveillance frequency was specified in
the procedure dictating the schedule for each surveillance,
in some
Enclosure 2
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
42
instances the same surveillance requirement was contained in more than
one procedure (e.g.. to cover A and B : rains).
In most cases the team
only reviewed the requirement in one o' the procedures. The
surveillance requirements (SRs) selected and implementing procedures
reviewed were as follows:
,
SR
Procedure
I
3.1.4.2
SP-333. " Control Rod Exercises". Rev. 26
3.1.9.1
SP-424 ' Physics Testing Hourly Surveillance Log". Rev. 7
3.2.1.2
SP-300. " Operating Daily Surveillance Log". Rev. 139
3.3.1.6
SP-112. ' Calibration of tte Reactor Protection System",
Rev. 57
3.3.8.1
SP-907A. " Monthly Functional Test of 4160V ES Bus A
Undervoltage and Degraded Grid Relaying ' Rev. 19
3.4.10.1
SP-370. 'Ouarterly Cycling of Valves". Rev. 69
3.5.1.1
SP-300. " Operating Daily Surveillance Log'. Rev. 139
3.5.1.3
SP-347. "ECCS and Boration Flow Paths". Rev. 45
3.5.2.5
SP-347. "ECCS and Boration Flow Paths'. Rev 45
3.5.2.7-
Containment Sump Level and Flood Mnnitoring System
Calibration". Rev. 26
3.8.1.9
-SP-137, " Engineered Safeguards Actuation System Time Delay
Relay Calibration'. Rev. 12
3.8.3.4
SP-3548. " Monthly Functional Test of Emergency Diesel
Generctor EDGB-1B". Rev. 45
3.8.4.5
SP-522. " Station Batteries Inspection and Battery Charger
Load Test". Rev. 19
3.8.4.7
SP-523. ' Station Batteries Service Test'. Rev. 30
3.9.3.2
SP-335C. " Radiation Monitoring Instrumentation Functional
Test'. Rev. 18
5.6.2.11a
CH-400. " Nuclear Chemistry Master Scheduling Program".
Rev. 10: and CH-450 " Secondary Water _ Chemistry Startup and
Shutdown Guidance." Rev. 16
5.6.2.14c
SP-746A. ~ Diesel Fuel Oil Testing Surveillance Program:
Emergency Diesel Generator fuel Storage Tank DFT-1A" Rev. 0
While selecting surveillance requirements from the ITS. the team
questioned that the ITS contained no " Low Pressure Overpressure
Protection" (LTOP) requirements.
In response, the licensee provided a
copy of a letter to the NRC dated October 23. 1997, which submitted
Technical Specification Change Request Notice 213. Rev.1. to add LTOP
Enclosure 2
__
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_ - -
___ _ _ - - _____ _______
43
requirements.
In addition, the licensee-provided another letter to the
NRC dated November 21, 1997. which described commitments for LTOP that
would be implemented until the ITS change was approved. The team was-
shown a draft surveillance procedure being prepared to implement LTOP
surveillance requirements.
'
b.3 Records of Imoroved Technical Soecification Surveillances
The team selected a sample of ITS surveillance requirements and reviewed
l:
the last completed procedure records. These records were reviewed to
l
- verify that the surveillances were current (based on plant condition and-
l~
required frequency) and that they had been satisfactorily performed and
l
documented. The requirements and procedures, including performance
dates were as follows:
SR
Procedure
3.5.2.7_
SP-175. " Containment Sump Level and Flood Monitoring System-
Calibration". Rev.- 25 W4 month frequency) - last performed
.
4/24/96
-
-3.8.1.9
SP-137. " Engine.ered Safeguards Actuation System Time Delay
'
-
Relay Calibration". Rev.12 (24 month frequency for modes
1-4) - last_ performed 10/21/97
3.8.3.4
SP-301. " Shutdown Daily Surveillance Log".. Rev. 103 (monthly -
4
frequency) --last performed 12/6/97
3.8.4 5
SP-522. " Station Batteries Inspection and Battery Charger
Load Test". Rev. 19 (18 month frequency for modes 1-4)--last-
performed 10/7/97 (for "A" battery)
_
_
'
3.8.4.'7_
SP-523. " Station Batteries LService Test". Rev. 30 (24 month
frequency for modes 1-4)'- last performed 8/18/97
3.9.3.2
SP-335C. " Radiation Monitoring Instrumentation Functional
Test". Kev. 15 (24 month frequency) - last performed 2/20/96
5.6.2.11a
CH-450. " Secondary Water Chemistry Startup and Shutdown
Guidance." Rev. 16: and Short-Term Instruction 97-067 -
currently being performed at frequencies specified in the
_
Short-Term Instruction
5.6.2.14c
SP-746A. " Diesel Fuel Oil Testing Surveillance Program:
Emergency Diesel Generator Fuel Storage Tank DFT-1A". Rev. 0
(quarterly frequency - last performed 11/12/97
Enclosure 2
44
5.6.2.14c
" Diesel Fuel Oil Testing Surveillance Program: New
,
Diesel Fuel-Receipt, Rev. 0 (performed on receipt) - last
_
performed 9/30/97
The team also selected a sample of surveillance procedures which the
'!
SCATS program indicated would require performance within the next two
months and verified that the dates scheduled were consistent with the
specified frequency and last performance for each entered in SCATS. The-
sample was as follows:
SP-108, SP-110, SP-150, SP-157. SP-187. SP-296.
SP-320, SP-335C. SP-340, SP 349, SP-408. SP-421, SP-521, and SP-672,
b.4 Observation of Surveillances
The team observed all or portions of the performance of the following
surveillance procedures and verified that required approvals were
- obtained, personnel-were properly qualified, currently approved
procedures and calibrated equipment were used, procedures were adequate
to satisfy the surveillance requirements, test discrepancies were
properly resolved.-and that the surveillances were performed
satisfactorily within the specified frequencies:
('
SP-169F, Rev.- 4:
observed calibration of decay heat closed cycle
cooling water surge tank 3A level instrumentation (ITS 3.7-8)
.
-SP-340A, Rev. 37:- observed beginning of raw water pump 3A test
-(ITS.S 6.2.9)
e
SP-907A. Rev. 19:
oMerved first level undervoltage relay test
(ITS 3.3.8)
e
SP 502. Rev. 18:
observed all fire pump diesel batterie'. weekly
checks (Fire Protection Plan table 6.2b.8a)
SP-520. Rev. 21: _ observed all weekly checks on A and B batteries
(ITS 3.8.4.1, 3.8.5.1 and 3.8.6.1)
PT-542, observed _ weekly _ checks performed on batteries up to entry
e
of electrical cabinet, the surveillance was delayed at that point
due to unavailability of safety gloves (Non-1E batteries, no ITS
cr other nuclear. safety requirement applicable)
During their observations, the team noted that pre-job briefings for the
surveillances were thorough and well-presented.
They also observed that
procedures were adhered to stringently, except in one instance.
In that
case (SP-907A) the responsible individual inadvertently skipped a page.
After quickly completing two steps on the wrong page. he recognized his
Enclosure 2
- -.
- . . - - -
- - - - - -
_. -
- _ ..
-... - .- - _
i
45
error.- appropriately stopped the test and informed supenision,
p
Operations was notified of the error as soon as it was recognized.
Upon
j-
completion of a review of the error, appropriate test' conditions were
re-established and the test was satisfactorily completed. The error did
-not adversely affect equipment or personneh
'
,
(b,5 Review of Records for Non-Technical Soecification Surveillances
The team selected and reviewed the related records for the last
j-
performances of two non-technical specification surveillances and
~
- verified that they were appropriately completed and_ documented. The
d
surveillances and the team's findings are described below:
-(1)
Reactor Vessel Material Surveillances
'
-
These surveillances were required by 10 CFR 50. Appendix H, and involved
tests on irradiated coupons to monitor changes in the fracture toughness
'
j_
of reactor vessel materials.
Report BAW-2049. " Analysis..of Capsule CR3-
]
F'
dated September 1988. documented the results of the final tct for
Crystal River. The team verified that the licensevs February 25, 1993,
[
letter to the NRC: documented submittal of this report,
Surveillance
,
coupons for othor.' licensees continued to be irradiated in the Crystal
l
River reactor, based on a program developed by the industry and_ approved
"
by the NRC.
NRC approval of the current program (including schedule)
i
was provided in a letter from the NRC to the Babcock and Wilcox (B&W)
Owners Group dated-July 11, 1997 1The program showed that all tests
,
were complete for. Crystal River.
_
l
(2):
Examinations of Hich Pressure Iniection Thermal Sleeves and Pinina
i
The-industry identified cracking in the high pressure injection thermal
sleeves and piping at Crystal River and other B&W nuclear plants in-
E
1982. This cracking was documented in NRC Information Notice-82-09.
Generic Letter 85-20 specified use of industry-developed examinations
E
-and repairs to address the cracking. The. examinations consisted of
l-
loosening (considered a precursor to cracking) and ultrasonic tests (UT)
to detect cracks.
In 1997,-additional examples of this cracking
.
occurred at the Oconee nuclear plant' and resulted in an unisolable
reactor coolant leak. This was documented in Information Notice 97-46.
3
Oconee had performed the examinations approved by Generic Letter 85-20
i
Enclosure 2
i
L
.
_
. .
-
_,
.
46
but, due to inadequate examination criteria, failed to detect prior
evidence of potential cracking until the leak occurred.
Both Oconee's
RT and UT criteria had been inadequate.
In the current inspection, the team reviewed the records (UT reports and
'
RT film) of the last examinations performed to detect cracking in high
pressure injection piping and thermal sleeves at Crystal River.
These
examinations were performed and documented during the current outage
through Work Requests 346054, 346056, 346424. and 346426.
Based on
their review of the records and discussions with the enminers, the team
found that the examiners were thoroughly aware of the recent industry
experience at Oconee and had performed appropriate examinations to
assure the condition did not exist at Crystal River. However, the team
identified a weakness in the licensee's written examination criteria
l
which could impact future examinations. Specifically, the criteria for
l
identification of gap associated with sleeve loosening were unclear.
'-
The licensee initiated a precursor card (PC 3-C97-8482) to address the
weakness,
c.
Conclusions
The licensee's surveillance program was acceptable for plant operation.
Surveillances were satisfactorily scheduled, proceduralized, performed
and documented.
IV. Plant Succort
R1
Radiological Protection and Chemistry Controls
The inspection included reviews of records and procedures, interviews
- with licensee personnel and observations of work activities in progress.
The inspectors made observations in the Reactor Building. Auxiliary
Building and yard areas within the Radiation Control Area (RCA).
R1.1 Personnel Contamination Controls. Occucational Radiation Exoosure and
Occuoational Safety Team Insoection
a.
Insoection Scoce (83750. 93802)
The purpose of this inspection effort was to verify that Radiation
Protection (RP) activities for work in contaminated areas met applicable
regulatory and licensee requirements.
Enclosure 2
l
,
__ ._ _ _ _ _ _ ._ _ . _ _ . _ _ . _ _ _ _ . _ _ _ . . _ . _ .
__
l
47
4
i
Contamination control procedures, contamination monitoring
i
instrumantation, and personnel contamination documer.tation were reviewed
during the-inspection,
b.
Observations and Findinos
l
Personnel Contamination Events (PCEs)
The inspector,, reviewed the numbers of PCEs documented at the site in
re';nt years for trends.
The licensee reported the following
informat' ion concerning numbers of PCEs generated.
lothing
contaminations were included in the annual totais.
1
)
Personnel Contamiaation Events
Year
Number
1992
232
1993
116
4
1994
218
1995
21
^
1996
340
-
The number of PCEs generally increased in years having a Re Fueling
l
Outage.(RF0) as seen in years 1992, 1994, and 1996.
The licensee did
not have any outages in 1995 and the number of PCEs documented were much
lower that year.
The number of PCEs increaseo significantly in 1996 and
the licensee attributed the increased number of PCEs to increased
contamination levels found in the 1996 refueling and the extended
maintenance outage.
-
The licensee had recently conucted a survey of other nuclear power
facilities to determine typical contamination level' thresholds for
documenting PCEs.
l.icensee personnel reported the typical threshold
-found in their survey was greater than 500 counts per minute (cpm)/ area
under probe (aup).
Following the survey the licensee revised Health
Physics Procedure (HPP)-104. Personnel Monitoring and Decontamination.
Revision 13. dated June 2. 1997, to require documentation of PCEs when
'
contamination levels were greater than 500 cpm /aup.
Prior to the change
the licensee had documented PCEs whene e contamination levels were
Enclosure 2
_
_ _ _ - - _
_ _ _
_ . _ .
_ _ _ .. _ _ _ _ ___ _ _ ._- __
45
.
greater than 100 cpm /aup. The inspectors found the procedure change
decreased the number of PCE's generated without improving RP program
performance.
,
~
While reviewing Revision 13 of HPP 104, the inspectors found the
'
procedure had conflicting guidance concerning the criteria for
documenting personnel contaminations. Section 3.4 of the procedure
required the user complete the Personnel Clothing /3'.In Contamination
.
form when personnel contaminations ;ere greater than 100 counts per
minute cpm /aup beta gama as directed by the Health Physics (HP)
Supervisor.
However Section 4.4. of the same procedure provided the
following guidance:
"The HPs will detarmine when the Personnel Contemination Form will
be completed for cortamination <500 cpm /aup beta gamma. The form
must be completed when contamination levels are >500 cpm /aup
beta gamma and when there is a potential for ingestion or
inhalation with contamination levels >100 cpm /aup beta gamma."
The inspectors found the procecural guidance in Section 3.4 and
Section 4.4 were conflicting and failed to provide clear guidance for HP
personnel implementing the procedure. Additionally, the procedure did
not provide clear criteria for documenting PCEs having " potential for
ingestion or inhalation." Failure of the licensee to have adequate
written procedures for the documentation of personnel contaminations was
identified as a violation of the licensee's Technical Specifications
(TS). V10 50-302/97 20-01, failure To Provide Adequate Written
Instructions For Documenting Personnel Contaminations.
The inspectors reviewed PCE documentation completed in 1997. The HPP-
104 procedure required the person completino the Persohnel Clothing / Skin
Contamination form to include the next ennst.cutive " Radiological Survey
Number." The statement implied that each personnel contamination report
would have a unique number.
However, the inspectors found that the
licensee gave a unique number to a contamination event and an event
could involve several personnel contaminations. When reporting a
quantity of PCEs one PCE could be reported that actually resulted in six
personnel becoming contaminated. The inspectors requested access to all
PCEs completed in 1997 for the reviem The inspectors were provided a
binder having an index and copies of PCEs initiated in 1997. The
inspectors counted approximately 73 personnel contaminations for the
Enclosure 2
,.
- - . . - .
..
.- -
.
. _.
-.
-
_
-
- .
_ _ _ _ - _ _ _ - _ _ _
_
i
49
site through December of 1997. The numbers were not excessive
considering the licensee had been in an extended outage all year and all
PCEs the inspectors had reviewed included some having less than 500
cpm /aup.
Each of those reports were assigned a survey number.
That
assessment was discussed with the Radiation Protection Manager.
Later
in the inspection, the inspectors picked up a binder in a lab to review
any additional PCEs that may have been generated since the inspector's
review. The inspectors noted that the index in the binder was not the
I
same index that had been reviewed earlier.
The binder included another
set of PCEs. The inspectors learned that the licensee had started
another index of PCEs when the primary RCA access had beer aved several
months earlier. The second index listed personnui having contamination
greater than 100 cpm /aup but unlike the first. survey numbers had not
been assigned to all personnel contaminations having less than 500
cpm /aup.
Some of the PCEs on the second index were on the first index
but not all. An additional 44 personnel contaminations were identified
from the review of the second index raising the total number of PCEs
documented by the licensee to 117.
The PCEs were logged on a Persor.nel Clothing / Skin Contamina' tion index
form.
Information along the bottom of the index form indicated a survey
number was not applicable for skin contaminations <500 cpm /aup.
However. Section 4.4.1.1 of HPP 104, required the Personnel
Clothing / Skin Contamination form include a " Radiological Survey" number.
The inspectors found some of the personnel contamination farms for
personnel contaminations having <500 cpm /aup included survey numbers and
others did not. The guidance on the bottom of a form and the written
procedure-did not agree.
That procedural discrepancy was also
-
identified by the Quelity Assurance (0A) staff during the inspection and
a Precursor Card (3 C97-8077) was initiated by 0A personnel.
Failure of
the licensee to have adequate written procedures for logging PCEs was
identified as a second example of inadequate procedures and a violation
of the licensee's TS, VIO 50 302/97 20 01. Failure To Provide Adequate
Written Instructions for Documenting Perr-H Contaminations.
The
inspector concluded the licensee's numbering process utilized for
logging personnel contamination records did not help control the PCE
records and could be misleading.
The inspectors found the Personnel Clothing / Skin Contamination forms
were not being completed as described in HPP 104.
Steps 4.4.2.3 and
- - - -
-4.4.3.2 of HPP 104 required the preparer to " Instruct the individual
Enclosure 2
. - _ _ _ _ _ .
..
. .
.
50
involved in the contimination event to complete the Event Descript %n
portion ant. tign the form." The purpose of the process was to capture
the workers perspective on how they may have became contaminated.
in
some circumstances the contaminated worker can provide the best
information concerning actual work conditions and possible contamination
causes. The input can be valuable information when attempting to
l
determine the probable causes and corrective actions to prevent
recurrence. However, in the review of approximately sixty Personnel
Clothing / Skin Contamination forms, the Event Description section of the
form was blank on about ten forms and another three had partial
information in the section.
None of the thirteen forms were signed by
the contaminated worker.
Failure of licensee personnel to follow
written procedures for documenting event descriptions on the Personnel
Clothing / Skin Contamination forms was identified as a vic atir of the
licensee'.1 TS VIO 50 302/97 20 02. Failure To Follow Radiation
'
Protection Program Procedures For Documenting Personnel Contamination
Events.
While reviewing the 1997 personnel contamination records the inspectors
founo the licensee was using three different forms. The three forms
were titled " Personnel Clothing / Skin Contamination:"
" Personnel
Clothing Contamination:" and " Personnel Skin Contamination." The
current revision of HPP-104 (Revision 13) did not addrecs all the forms
being utilized. The inspectors reviewed recent revisicas to HPP-104 end
determined that prior to revision 12 of HPP 104 dated February 20, 1996,
the licensee had utilized two forms to document personnel
contaminations. There was a Personnel Clothing Contamination form and a
Personnel Skin Contamination form.
However, when revision 12 of HPP 104
was issued the two forms had been combined into the Personnel
Clothing /Skir. Contamination form. The individual forms for skin and
clothing contaminations were not addressed by the procedure after
February 20. 1996.
Licensee personnel reported the old contamination
forms should have been removed from the lab.
However, during the review
of the 1997 PCEs the inspectors found technicians had used six of the
l
deleted forms to document one skin and five clothing contaminations.
Failure of licensee personnel to utilize the correct form-for
documenting personnel skin and clothing contaminations in 1997 was
identified as a second example of failure to follow written procedures
for the documentation of personnel contamination events and was
Eulosure 2
'
51
identified as a violation of the licensee's TS VIO 50 302/97-20 02.
,
Failure To Follow Radiation Protr.ction Program Procedures For
Documenting Personnel Contamination Events.
The forms used by the radiation protection staff were not included in
'
the written procedures and the staff could not go to the Health Physics
(HP) implementing procedures to verify a form was current.
The
,
l
inspectors concluded that failure to include the proper personnel
contamination form in the written procedures contributed to the improper
use of discontinued personnel contamination forms and was a program
weakness.
Section 3.3.3 of HPP-104. Personnel Monitoring and Decontamination.
Revision 13. dated June 2.1997. required HP Supervision be responsible
,
f
for reviewing personnel contamination records for applicability wich
'
regards to personnel exposure evaluations and documentation.
The HP
supervisors reviewing the personnel contaminatioqs that were improperly
documented on deleted forms failed to identify and correct the
procedural discrepancies.
Failure of the HP supervisors to follow
written procedures for the review and verification of procedure
compliance was identified as a third example of failure to follow
written procedures for documentation of personnel contaminations and a
violation of tne licensee's TS VIO 50 302/97-20 02. Failure To Follow
Radiation Protection Program Procedures For Documenting Personnel
Contamination Events.
The licensee's procedures and forms did not require the HP staff to
determine a cause or probable cause of the personnel contamination for
tracking, trending, or corrective action purposes. There was a section
on the form for remarks that could be used to identify a possible cause
however, the remarks section was blank on 36 of 60 PCE records reviewed.
The inspectors found that the licensee was not actively tracking and
trending PCE causes and that was identified as a second weakness in the
licensee's contamination control program.
The inspectors discussed causes of personnel contaminations with RP
staff and found that the licensee had identified causes of some
personnel contaminations. For example, the inspectors noted that for an
event in which four personnel were contaminated in a clean area, the HPs
had investigated the event and determined the cause to have resulteo
from an inadequate post decontamination survey. HP management issued a
Enclosure 2
.
--
'
!
4
i
-
,
52
,
i
i
i.
- HP Supervisor Information Notice in October,1997, directing the HP
i
-
staff to be more thorough in post decontamination surveys.
i
!
!
3
The inspectors reviewed personnel exposure records for personnel having
!
exposure to skin contamination to verify the licensee was including the -
'
j
skin dose on the radiation worhrs exposure _ reco_rds.- The inspectors
i
J
found the licensee was properly updating radiation workers occupational
radiation exposure records,
i
- The inspectors found that the licensee's technical basis for conversion-
,
factors for determining shallow dose equivalent to low level
_
4
contamination were not defined in a controlled document. The licensee's
'
Personnel Clothing / Skin Contamination Form included a factor for
converting gross contamination activity to shallow skin dose rates. The
inspectors asked to see the technical basis for the factor being
utilized.
The licensee reported that the basis for the factors had been
documented in a letter that could not be located during the inspection.
The inspectors reported that the issue would be reviewed in a future
inspection as an Inspector Followup Item (IFI) 50-302/97-20-03,
Review
Technical Basis Documentation for Radioactive Contamination Dose
Conversion Factors,-
Contamination Control Observations
Radiation Safety Procedure (RSP)-101, Basic Radiological Safety
Information and Instructions for Radiation Workers, Revision 24, . dated
July, 9 -1997, required Florida Power Corporation (FPC) supervision be
responsible for assuring all individuals under their direction are aware
of and comply with applicable radiological controls and radiological
safety instructions, procedures, guidelines, good .nract1ces, and
.
-policies.
Section:4,9. provided radiation workers guidance on removing
protective clothing.
The procedure required each item of used
protective clothing be carefully deposited in the appropriate receptacle
-(1.e. waste _ items in waste receptacles and reusable items in
receptacles designated as such).
During the inspection the inspectors observed radiation workers in the
Radiation Control Area (RCA). While on a tour in the Auxiliary building-
the~ inspector came upon some radiation workers (Painters) exiting a
contaminated area (Waste Transfer Valve Alley). The Step Off Pad (50P)
~
was set at the door frame into the room. The used protective clothing
Enclosure 2
_ _ . _ . _ . _ _ . _
_. _ _ _ _ _ _ _ ___
_ _ _ _ _ _
_
53
container was. located outside the contaminated area and full.
When the
)
.
workers began removing the protective clothing the container was already
,
overfilled. The inspector observed a worker throw his used pr tective
- clothing'to the container. - Some of the potentially contaminated
protective clothing missed the container landing on the clean floor.
'~
which was a high traffic walkway. . A worker outside the room picked up
the clothing with his bare hands and placed it on top of the alread/
'
overflowing container.
There were several workers in line waiting to
remove their protective clothing. The inspectors called for an HP to
come to the site to regain control of the activity and to conduct a
i
contamination survey of the clean areas around the 50P. The HP stopped
the workers from exiting the area until a empty container was found and
moved to the 50P.
The workers were then permitted to complete their
removal of the used protective clothing.
The work 9r that picked up the
,
contaminated clothing was not contaminated and no' contamination was
found in the clean areas surrounding the 50P.
Failure of the radiatior.
workers and their supervision to ensure the radiation control practices
for contamination control were properly implemented was identified as a
violation of the licensee's contamination control program procedures and
,
a violation of the licensee's TS VIO 50 302/97 20 04.
Failure of
Radiation Workers To follow Contamination Control Procedures.
,
The inspectors also observed water crossing the contamination control
boundaries on posted contami_nated areas throughout the Auxiliary
,
'
-Building. The source of the water appeared to be from condensation
.
dripping off piping above the contam1_nated areas.
Licensee personnel
reported that the contamination levels in most of the posted areas were
.l ow. The licensee reported that the aren where' condensation was a.
problem were surveyed and mopped frequently.
The inspectors did not
identify anj spread of contamination resulting from the condensation
problems.
The inspectors discussed with responsible management the
undesirable conditioning of radiation workers to accept water crossing
contaminated area boundaries. No violations were . identified.
._.
Enclosure 2
r
-
.
- - -
. . .
- .
- - --.. - . - -
-
..- - - -. _ .,.-. -
.-.
. . - - . - . -
.
- - - - -
- - - . - - - - - _ - - - - -
,
54
c.
Conclusions
Personne1' Contamination Events-
,
The inspectors concluded the licensee's overall process for documenting
'
-
and investigating personnel contamination was deficient.
The licensee-
'
raised the contamination level threshold for documenting PCEs for the
purposes of reducing the number of PCEs requiring documentation. The
procedure describing the PCE documentation was inadequate in that it
,
contained conflicting-instructions concerning levels requiring
'
,
documentation. HP personnel documenting the PCEs were not following the
procedures and using old and-deleted forms.
In some cases when the
correct form was used it was not completed as required by the procedure.
,
The failure to include the current forms in HP procedures was identified
as a program weakness. The inspectors found that HP supervisors were
'
reviewing the incomplete and inadequate personnel contamination
1-
documentation without verifying procedural compliance and requiring
.
corrective actions.
The licensee was not actively determining
'
contamination causes for corrective actions on most-contamination events-
and was not trending the activity for performance monitoring,
-
The licensee had identified a probable cause of personnel contaminations
-
in a clean area and had emphasized the importance of thorough post
decontamination surveys to the staff.
!
i
Contamination Control Observations
<
,
Inadequate' contamination control practices were identified as a
violation of the . licensee'
contamination control program procedures.
Poor contamination control practices were observed in areas having clean-
-
water traveling through and out of posted contaminated areas. The
conditions were widespread, tolerated, and de sensitizing radiation
,
workers to the. potential consequences of uncontrolled contamination
transport.
.- d
Enclosure 2
_,_
- _ . _ -- _ _-_.,___. _ , _
._
_ _ . ,._, _ _ . _
__.____ _____
_ _ _ _ . _ _ _ _ . _ _ _ . _ . _ _ _
,
!
55
'
R2
Status of Radiation Protection and Chemistry Facilities and Equipment.
- R2.1 Radiation Monitorina System Radioactive Waste Treatment and Effluent
}
and Environmental Monitorina. Doerational Safety Team Insoection
'
a.
Insoection Scone (84750.93802)
This review was made to determine the quality of the licensee's System-
Readiness Review (SRR) of the licensee's Radiation Monitoring System
(PfiS) .
b.
Obser*J3tions and Findinas
i
Inspectors found the licensee had spent considerable resources to
determine and verify that the RMS was meeting commitments and regulatory
requirements.
,
'
The licensee had performed detailed reviews of the plant RMS for
'
compliance with 1pplicable standards and commitments. The review
i
considered, in part, the followir.g requirements, guidance, and
'
references:
.
o
10 CFR Part 20 S+andards for Protection Against Radiation:
o
Final Safety Ana;ysis Report (FSAR):
o
Design Basis Documents: RMS, Safety Parameter Display System, Post
Accident Sampling and Meteorological Monitoring:
o
improved Technical Specifications (ITS):
o
NUREG 0737. Clarification Of Three Mile. Island-(THI) Action Plan
,
Requirements:
_
_
4
o
Regulatory Guides 1.97 Instrumentation For Light Water Cooled
'
Nuclear Power Plants To Assess Plant And Environs Conditions
During And Following An Accident: and 1.45 Reactor Coolant
h
Pressure Boundary Leakage Detection Systems
c-
Off-Site Dose Calculation Manual
o
Operation; Procedures
o
Training Lesson Plans
o
Plant Drawings
_ . -
4
4
Enclosure 2
l
$
J
- -
-'E--
,.-..-.,,.-,,_ewm,
. , . . . _ + . . . , . .
.
-....,,-,_,--e%,,
y--.,.
n..,
.
.%rm._,
,
e,~.'
,,
.
- ._- _
-__. - -
.._- - _
_-
.
. - _
_ - - - . -._
__.
56
The licensee found the RMS was adequately monitoring the parameters and
correctly processed effluent discharge terminations when high setponts
were reached.
The review also reported that a majority of the original
system was in a fair to degraded state of material readiness but still
functioning as required.
A recommendation was made for replacement in
'
the near term.
The system had exhibited a significant number of spurious alarms and
trips beginning before initial plant startup.
These were attributed to
incorrect system grounding in the original system.
'
Several discrepancies were identified in the FSAR, RMS Design Basis
Document (DBD) and affected system DBDs and other system documentation.
A list of items for closure prior to restart was developed in the system
readiness review.
The list also included some issues identified prior
to the system review. The SRR reviewer generated 41 open items that
included 37 Precursor Cards (PC) and 4 Work Request (WR). Documents
written outside the SRR process were also inspected by the SRR reviewer.
The number of issues identified for restart consideration out of that
review included 1 PC 74 WRs. and 12 Requests for Engineering
Assistance.
Following the initial assessment the licensee began working and
monitoring the progress of corrective actions for the identifieu
deficiencies. At the time of the review the licensee was finishing work
on the remaining items designated to be completed prior to restart of
the Unit 3 reactor.
The System Engineer for the RMS began a RMS outage on December 6, 1997,
to work on equipment grounding problems in the RMS cabinets in the
Unit 3 Control Room. The outage lasted several days and the licensee
repaired and replaced instrument cables, performed rignal grounding
upgrades, and improved maintenance access in the cabinet. The decision
'
to have a RMS outage proved to be a good initiative,
During the
maintenance two cables were discovered to be unterminated.
Cables WSE
75 and WSE 80 which carry an output signal from RM A2 (Auxiliary
Building Exhaust Duct) and RM Al (Reactor Building Purge Duct) Low Range
Noble Gas ratemeters to the Low Medium, and High Valve Controllers were
not landed.
Enclosure 2
._,
.--
-
-
-
-
{
'
57
Following the accident at Three Mile Island, NUREG 0737. Three Mile
Island (THI) Action Item II.F.!, required noble gas effluent monitors be
installed with an extended range designed _to function during accident
conditions as well as during normal operating conditions. Multiple
monitors were considered necessary to cover the ranges of interest.
_ System designs were required to accomodate a design basis release and
then be capable of following decreasing concentrations of noble gases.
The licensee's system was capable of routing monitoring air for RM Al-
and RM A2 monitors through three different detectors automatically.
When the low range monitor approached full scale a signal was sent to a
valve controller to route the air to the mid or high range detectors as
needed. However, the unlanded cables would have prevented the noble. gas
monitors from automatically switching to mid and high range monitoring.
The licensee's surveillance, Preventative Maintenance (PM)-292, Checkout
of the PASS Noble Gas Hid and High Range Detector Valves and Valve
Controllers, Rev, 5, dated November 3,1997, for testing the operability
of the controllers did not require the input signal originate from the
low range ratemeter in the control room.
Instead a signal was feed
directly into the controller and the cable from the control room was not
tested. The monitor was set up to permit manual control of the valve
controllers from the control room, therefore, it would have been
possible to make the monitor operable. However, the intended
. operability of the system would not have occurred.- The issue is still
under review by the licensee and resident NRC staff. A PC 97 8333 was
initiated to cause corrective actions. The licensee planned to land the
connectors on the proper terminals, revise PM 292 to test the complete
circuit. and complete the revised PM.
The RMS Engineer also found a gap in the cabinet and cantrol room floor
that had not been seen due to a grounding bar in the cabinet base. A PC
was initiated to seal the penetration.
c,
Conclusions
The RMS review was thorough and numerous discrepancies were identified.
The corrections made should improve the equipment operability, ensure
equipment was capable of performing intended functions, and improve
quality of supporting and administrative documentation for the
equipment. There were no outstanding issues concerning the RMS that=
-
would delay restart of Unit 3.
Enclosure 2
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
L
58
R2.2 Whole Body Counters. Occuoational Radiation Excosure (83750).
a.
Insoection Stone
The inspectors reviewed the licensee's Whole Body Counter (WBC)
'
maintenance to determine if it was being properly calibrated and-
maintained,
i
b.
Observations and Findinas
The inspectors reviewed the licensee's calibration procedures for the
WBC and verified that the monitor was properly calibrated in accordance
_
with the licensee's procedures.. The quality controls for the system
were also reviewed and verified to be in compliance with the procedure
requirements,
c.
Conclusions
The inspectors verified that the Whole Body Counter was properly
calibrated, monitored, and maintained.
_
R2.3 Whole Body Contamination Monitors. Occucational Radiation Exoosures
(83750). Doerational Safety Team Insoection (938021
a.
Insoection Scoce
The inspectors reviewed the licensee's maintenance of.whole body
- personnel contamination monitors to determine if they were being--
properly calibrated and maintained,
b .- Observatics and Findinos
The inspectors revieweC the licensee's calibration procedures for the
whole body personnel conccmination monitors and verified that the
contamination monitors were properly calibrated in accordance with the
licensee's procedures. The quality contro's for the system were also
reviewed and verified to be in compliance with the procedure
requirements.
._
_
_
Enclosure 2
__. .____ __ _ ________-__.___ _ ___ _
59
c.
Conclusions
,
- The inspectors verified that the licensee's whole body contamination
monitors were being properly calibrated, monitored and maintained.
,
R8
Miscellaneous Operational Issues
R8.1
(Closed)
IFI 50-302 97-13-06- Reviaw Accuracy of Gaseous Effluent
itelease start Times and Volumes
a. -Insocction Scone (92904)
The inspectors reviewed this item to determine if Reactor Building Purge
start and stop times and volunes of gaseous releases were accurate.
'
,
b.
Observations and Findinas
In a previous inspection of effluent release activities. the licensee
i
reported a concern had been identified concerning the accuracy of
'
Reactor Building purges when surveillances were performed during a
release.
The concern was that operations might not be accounting for
the total purge time due to their actions in implementing a surveillance
requirement and that the actual volume of the release could be greater
.
than documented.
The concern was raised August 21. 1997 and documented
in Precursor Card 97-6145.
'
The licensee. selected eight previous releases and pulled the purge fan
-
_
strip charts for each to verify the fan operation times matched the
-
release times on the release permits. The licensee found that the
Reactor Building Purge Fans started at the same time as or after the
time recorded on the purge permit. The inspectors reviewed the
licensee's documentation of the review and found that the release times
generally matched the fan operation times. The inspectors determined
that the licensee procedures had been revised to indicate release start
times clearly.
c. . Conclusions
The inspectors concluded the reactor building purge release times and
_
volumes were accurate.--
-
.
Enclosure 2
,
nm,
, .-.
- - - , ,
,
,
. - - , .
_ . -
.-.-.,,c
, - - . , - ,
,,-~,,,,,------,,c,
---m.--.
. , , - - - , , - - - . - - _ _ - - _ , - - -
_ _ _ _ _ _ _ _ _ _ - - _
_
-
60
NANAGEMENT MEETINGS
XI
- Exit Meeting Summary
The Team Leader discussed the progress of the inspection with licensee
representatives on a daily basis, An interim results summary was
presented to license management regarding results of Health Physics
inspections on December 11, 1997. An exit meeting presented the results
_
to members of licensee management and staff at the conclusion of the
inspection on December 16.- 1997.
The licensee acknowledged the findings
presented,
Proprietary information was examined during this inspection but none is
included in this report.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
A. Auner, Instrumentation and Control Shop Manager
J. Baumstark, Director. Quality Programs
D. Brass, Minor Maintenance Manager
J. Cowan, Vice President, Nuclear Production
R. Davis, Assistant Plant Director, Operations and Chemistry
R. Grazio, Director, Nuclear Regulatory Affairs
G. Halnon. Assistant Plant Director, Nuclear Safety
B. Hickle. Director, Restart
J. Holden. Director, Site Nuclear Operations
0, Kunsemiller, Manager, Nuclear Licensing
.C. Pardee Director Nuclear Plant Operations
R, Pepin, Supervisor. Mechanical Maintenance
W. Pike. Manager, Nuclear Regulatory Compliance
M. Rencheck, Director, Nuclear Engineering
M. Schiavoni, Assistant Plant Director, Maintenance
T. Taylor Director, Nuclear Operations Training
D. Wilder, Health Physics Chemistry Manager
-
=
=
__
_
_
Enclosure 2
l
_ . _
. _ _ . _ _ _ _ . _ . _ _ _ . _ . - . . _ . . _ _ - _ _ _ _ _ . . . _ _
_ _ _ . _
-
-
,
!
t
61
'
EC
S. Cahill Senior Resident Inspector
'
T. Cooper. Resident Inspector
J. Jaudon. Division Director. DRS
,
S. Sanchez, Resident Inspector
LIST OF INSPECTION PROCEDURES USED
IP 83750:
Occupational Radiation Exposure
IP 84750:
Radioactive Waste Treatment and Effluent and Environmental
Monitring
--
t
IP 93802:
Operational Safety Team Inspection (OSTI)
IP 62706:
Maintenance Rule
ITEMS OPENED CLDSED. AND DISCUSSED
OPENED'
Iyne
Item Number
Status
Descriotion and Reference
50 302/97-20-01
OPEN
Failure To Provide Adequate Written-
Instructions For Documenting
Personnel Contaminations.
(Section
R1,1)
'
VIO . 50-302/97-20 02
OPEN
Failure To Follow Radiation
Protection Program Procedures For
Documenting Personnel Contamination
Events. (Section R11)
IFIL
50'302/97-20 03
OPEN
Review Licensee Technical Basis
-
Documentation For Radioactive
Contamination Shallow Dose
,
Conversion Factors.
(Section RI.1)
- 50 302/97 20 04
OPEN
Failure Of Radiation Workers To
follow Contamination Control
Procedures.
(Section R1.1)
Enclosure 2
1
P
<-
- = . - - - - ,
,c,
2--.-..-,,,--,-,n,-.---
.,-,--,-e
,,-,.v.,
-
,,rr-,ev.
..,o
-.e,,
, < , , .
,m-,,
---..-n,,
--
_ , - - -
_
t j.
62
Closed
IFI-
50 302/97 13 06
CLOSED
Review Accuracy of Gaseous Effluent
Release Start Times and Volumes.
(Section R8.1)
Discussed
'
IFI_
50 302/97-14 01
OPEN
Review of Operational Procedures
Prior to Restart (Section 08.2)
LIST OF ACRONYMS USED
Al
Administrative Instruction
Abnormal Procedure
AUP
Area Under Probe
CFR-
Code Federal Regulations
Counts Per Minute
DAD
Digital Alarming Dosimeter
Design Basis Document
DH
Decay Heat System,
,
FME-
Florida Power Corporation
Final Safety' Analysis Report
HPJ
Health Physics
HPP-
Health Physies Procedure
-
Instrumentation and Control
IFI
-Inspector Followup Item
.lP-
- Inspection Procedure
-ISI
In-Service Inspection
.lmproved Technical Specifications
MAR ~
Hodification Approval Record
mrem
Hilli-Roentgen Equivalent Man
hRC
Nuclear Regulatory Comission
01
_ Operating Instruction
-
OP-
0perating Procedure-
OSTI
Operational Safety Team Inspection
PC
Precursor Card-
Personnel Contamination Event
PM.
. Preventive Maintenance
Enclosure 2
63
j
Liquid Dye Penetrant Test
Quality Assurance
rad
Radiation Absorbed Dose
Radiation Control Area
REA
Request for Engineering Assistance
'
RF0
Re Fueling Outage
Radiation Monitoring System
Radiation P otection
Radiation Safety Procedure
i
Surveillance Procedure
SR
Surveillance Requirement
SRR
System Readiness Review
S0P
Step Off Pad
THI
Three Mile Island
Violation
Whole Body Counter
WI
Work Instruction
Work Request
Enclosure 2
. - _ . _ .