05000335/FIN-2009006-02

Finding

Title

Adequacy of Performance Monitoring of the IA Compressor Emergency Cooling System

Description

An unresolved item (URI) was identified related to the performance monitoring of the IA emergency cooling system. The team determined that the performance monitoring did not provide reasonable assurance that the system was capable of fulfilling its intended function. This failure to monitor the performance of the IA emergency cooling system was a performance deficiency. The system was identified to be in the scope of the maintenance rule (MR), 10 CFR 50.65(a)(1), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, because it is included in the St. Lucie emergency operating procedures. Description: The IA emergency cooling system is an alternate source of cooling for IA compressors A and B. The system is a small, closed cooling system with a pump, head tank, fan cooled radiator and connecting piping and valves to the IA compressors. The normal cooling water to the compressors is provided by the turbine cooling water (TCW) system which does not have power available after a loss of offsite power (LOOP) accident. These IA compressors and the emergency cooling system pump are provided with vital power so that the compressors can be manually loaded in accordance with 1[2]-EOP-09, Loss of Offsite Power, Rev. 38. During the inspection, the team requested design, maintenance, or operational documentation that would provide reasonable assurance that the emergency cooling system could perform its intended function of providing adequate cooling for IA compressors A and B during a LOOP event. There were no documented specifications, analysis, or testing available to verify the adequacy of the emergency cooling water system to support continued operation of the IA compressors. The team reviewed the routine testing performed on the emergency cooling system and concluded that this testing did not verify the system adequacy or provide the capability to identify potential degradation of the equipment. For example, Procedure OSP-69.13A, ESF-18 Month Surveillance for SIAS/CIS/CSAS, Rev. 2, aligned the IA emergency cooling system to the 2B IA compressor; however, the test configuration was in parallel with the higher capacity 2C IA compressor and, therefore, it was not possible to determine if the 2B IA compressor was loaded and the emergency cooling system was capable of sustaining loaded compressor operation. Procedure 2-0330020, Appendix H, Instrument Air Emergency Cooling Test, Rev. 56, required the recirculation pump to be run for 30 minutes but stated that starting the IA compressor was an option. The licensee did not provide past test information that demonstrated the IA compressor was run or loaded during this routine test. The inspectors concluded that the routine testing performed verified the flow path to the unloaded compressor but did not verify that the cooling system was capable of supporting sustained operation of the compressor. The licensee documented this issue in CR 2009-22766 and planned to perform a formal test of the system to demonstrate its capabilities. The team noted that the IA system at St. Lucie was a non-safety related system. Station design was that air-operated components fail to a safe position or are provided with an air accumulator. The emergency cooling system for the IA compressors was identified to be in the scope of the MR because it is a non-safety related system that was used in the emergency operating procedures (10 CFR 50.65(b)(2)). This item will remain unresolved pending the completion of the stations testing, and NRC review of the results of the IA emergency cooling systems capability to provide cooling for the IA compressors under conditions comparable to those expected during a LOOP event. The item is identified as URI 05000335,389/2009006-02, Adequacy of Performance Monitoring of the IA Compressor Emergency Cooling System

02
Site:	Saint Lucie
Report	IR 05000335/2009006 Section 1R21
Date counted	Sep 30, 2009 (2009Q3)
Type:	URI:
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.21
Inspectors (proximate)	R Taylor G Kuzo T Hoeg S Sanchez D Rich M Coursey R Patterson A Sengupta W Deschaine C Dykesb Desaij Hamman M Shylamberg N Greca R Moore R Taylor S Rose
INPO aspect
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v • d • e

Finding - Saint Lucie - IR 05000335/2009006

2(5)3(3)4(3)5(1)6(6)7(3)301(0)302(0)402(0)403(0)404(1)16(0)

IR 05000335/2009006: 1 2 3 4 5 6

Finding List (Saint Lucie) @ 2009Q3

CCA Matrix: 2009Q3

	Q	CCA	Title
05000335/FIN-2008005-02	2008Q4		Failure of the Automatice Diesel Fuel Oil Transfer System Could Potentially Result in the 1A EDTG Being Inoperable
05000335/FIN-2008005-01	2008Q4	H.11 H.12	Unit 1 Loss of Shutdown Cooling
05000335/FIN-2009007-03	2009Q1		Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)
05000335/FIN-2009007-01	2009Q1	H.4 H.5	Failure to Correct Conditions Adverse to Quality
05000335/FIN-2009007-02	2009Q1		Passive Fire Protection
05000389/FIN-2009002-04	2009Q1	H.5	Failure to Implement Adequate Process Controls during Maintenance Activities Resulted in a Manual Reactor Trip
05000335/FIN-2009002-03	2009Q1	H.4 H.5	Failure to Perform an Adequate Post Maintenance Test on the 1A-EDG Fuel Oil Day Tank Low Level Switch
05000335/FIN-2009002-02	2009Q1	P.3	Failure to Take Timely and Effective Corrective Actions for EDG Day Tank Level Switch Failure
05000335/FIN-2009002-01	2009Q1	H.7	Failure to Perform a Required TS Surveillance
05000335/FIN-2009003-03	2009Q2		Failure to Have a Fully Qualified and Active Licensed Operator at the Control Boards During Reactivity Manipulations
05000335/FIN-2009003-02	2009Q2	H.12	Failure to Follow Procedure When Placing Shutdown Cooling In-Service
05000335/FIN-2009003-01	2009Q2	H.5	Inadequate Risk Assessment When Performing Weekly Pump Venting
05000335/FIN-2009004-01	2009Q3		Seat leakage of Containment Spray Valves 2MV-07-3/4
05000335/FIN-2009006-06	2009Q3	H.13	Failure to Identify and Correct a Condition Adverse to Quality such that Non-Safety Related system Could Cause a Common Mode Failure of Both Trains of a Safety-Related System
05000335/FIN-2009004-02	2009Q3		2B2Reactor Coolant Pump Failed Seal Injection Line
05000335/FIN-2009006-02	2009Q3		Adequacy of Performance Monitoring of the IA Compressor Emergency Cooling System
05000335/FIN-2009006-04	2009Q3		Inadequate Procedure for Restoration of Non-Essential CCW Flow Following a SIAS
05000335/FIN-2009006-05	2009Q3		Failure to Translate Design Basis Specifications to Prevent Single Failure of CCW
05000335/FIN-2009004-03	2009Q3	P.3	Failure to take timely and effective corrective actions to prevent recurrence of EDG Day Tank level switch failures.
05000335/FIN-2009006-01	2009Q3		Failure to Meet the ASME Boiler and Pressure Vessel Code, Section VIII, Division 1 Requirements for the Overpressure Protection for the CCW Surge Tank
05000335/FIN-2009006-03	2009Q3	H.7	Failure to Maintain the Safety-Related 125V DC System Design Basis Information Consistent with the Plant Configuration

Self-Identified List (Saint Lucie)

	Q	Title
05000335/FIN-2009002-05	2009Q1	Licensee-Identified Violation

[Saint Lucie Findings full list]

05000335/FIN-2009006-02

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