IR 05000213/1989002
| ML20247D269 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/03/1989 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247D268 | List: |
| References | |
| 50-213-89-02, 50-213-89-2, NUDOCS 8905250304 | |
| Download: ML20247D269 (39) | |
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.l U.S. NUCLEAR REGULATORY COMMISSION 1 REGION I -)
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Report No'._ 50-213/89-02 1
. Docket N .I '
License No.- DPR-61-
Licen'see: -Connecticut Yankee Atomic Power Company -
i P. O. Box 270 Hartford, CT 06101 ;
I-Facility: Haddam Neck Plant, Haddam. Neck, Connecticut j
' Inspection at: Haddam Neck P' ant Inspection Dates: February'22 through March 28, 1989 l
, Inspectors: .A'ndra A. Asars, Resident . Inspector-John T. Shediosky, Senior Resident Inspector '
Approved by: $ O k O,lr S/3 l F9 E. C.-McCabe, Chief, Reactor Projects Section IB Date -;
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Summary: Inspection 50-213/89-02 (2/22/89 - 3/28/89) '
Areas Inspected: Routine safety inspection of plant operations, radiation pro-
.tection, fire protection, security, maintenance, surveillance testing, events i occurring during the inspection, open items, emergency preparedness drills,. f cleaning of the Containment Air Recirculation Heat Exchangers, and compensatory i measures.for Service Water System performance degradation and Auxiliary Feed-water System susceptibility to single failure Results: No violations were identified. Two new Unresolved Items were opened
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relating to the identification of an uncontrolled containment penetration boundary valve (89-02-01) and potentiel deficiencies in the design change
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process for the Appendix R Switchgear Building (89-02-02).
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8905250304 890517 PDR ADOCK 05000213 Q- PDC .,
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TABLE OF C2NTENTS
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PAGE Summary of Facility Activities....................................... I Plant Operations..................................................... 1 Plant Operations Review Committee... ............. .................. 2
' Maintenance and Surve111ance......................................... 2'
4.1 Containment Air Recirculation Heat Exchanger Cleaning. . . . . . . . . . . 3 b 5 '. Delay in Rescue Team Formation During Emergency Preparedness Drill (88-20-01)......................................................... 4 Events Occurring During.the Inspection............................... 5 6.1 Identification of Unmonitored Release Path....................... 5 l
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. Segaence of Events.................................... 5 L 6. Areas Contaminated.................................... 6 i' 6. Corrective Actions......................,.............. 6 L- 6.1.4- Dose Calculations..................................... 7-6.2 Inoperabl e Auxilia ry Feedwater Pump. . . . . . . . . . . . . . . . . . ... . . . . . . . . . 8-6.3 Relaxation of Containment Integrity During Heat Exchanger-Cleaning........................................................ 9 i 6.4 Rod Control System Failures.......... ..........................- 10
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6.5 Uncontrolled Containment Penetration Boundary Valve. . . . . . . . . . . . . 11 7. . Review of Periodic and Specia Reports............................... -12 l'
H Cable Separation Discrepancies Identified in the New Switchgear Building........................................................... 12 Observation of Emergency Preparedness Dri11s......................... 13 10. Justification for Continued Operation Concerning Degraded Service Water System Performance........................................... 13 10.1 Modifications to Service Water System........................... 14 10.2 Analysi; of Service Water System Design......................... 14 10.3 Revision to Justification for Continued Operation............... 15 1 Identification of Auxiliary Feedwater Susceptibility to Single Failure............................................................ 15 12. Management Meetings.................................................. 16 i
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DETAILS Summary of Facility Activities (71707)
The plant operated at full power until March 6 when power was reduced to 30% for cleaning of the Containment Air Recirculation Heat Exchanger Cleaning evolutions were completed on March 18 and an increase to full power. commenced on March 21 at the rate of 5% per day. The reduced rate was selected.for fuel management considerations. At the close of the inspection period, the plant had reached 70% power. The licensee's Jus-tification for Continued Operations which limits power operations to the condition that the Connecticut River temperature is below 50 degrees F (Fahrenheit) was revised on March 28; the new maximum allowable Service Water inlet temperature is 75 degrees . Plant Operations (71707)
The inspector observed plant operation during regular tours of the follow-ing plant areas:
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Control Room --
Primary Access Point
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Primary Auxiliary Building --
Fence Line (Protected Area)
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Vital Switchgear koom --
Yard Areas
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Diesel Generator Rooms --
Turbine Building
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Radiation Control Point --
Intake Structure
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Appendix R Switchgear Building --
Auxiliary Feedwater Pump Room L Control room instruments were observed for correlation between channels and for conformance with Technical Specification requirements. The in-l spector observed various alarm conditions which had been received and acknowledged. Operator awareness and response to these conditions were reviewed. Control room and shift manning were compared to regulatory requirements. Posting and control of radiation and high radiation areas were inspected. Compliance with Radiation Work Permits and use of appro-i priate personnel monitoring devices were checked. Plant housekeeping controls were observed, including control and storage of flammable materi-al and other potential safety hazards. The inspector also examined the condition of various fire prote.: tion system During pl6nt tours, logs and records were reviewed to determine if entries were properly made and l- communicated equipment status / deficiencies. These records included opera-
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ting logs, turnover sheets, tag out and jumper logs, process computer printouts, and Plant Information. Reports. The inspector observed selected aspects of plant security including access control, physical barriers, and personnel monitorin In addition to normal utility working hours (7:00 a.m. to 3:30 p.w.), the review of plant operations was routinely conducted during portions of holiday, weekend, midnight and evening shift Extended coverage was provided on the following days:
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l February 27, 1989 from 5:00 February 28, 1989 from 5:00 March 1, 1989 from 5:00 '
March 2, 1989 5:00 a.m. through 7:00 March 3, 1989 from 5:00 March 5, 1989 4:30 p.m. through 8:00 March 8, 1989 from 5:00 March 12, 1989 5:45 p.m. through 8:45 March 15, 1989 until 8:15 March 18, 1989 1:30 p.m. through 3:00 March 24, 1989 9:30 a.m. through 1:30 No unacceptable conditions were identifie Operators were alert and displayed no signs of inattention to duty or fatigu . Plant Operations Review Committee (40500)
The inspector attended several PORC (Plant Operations Review Committee)
meetings. Technical specification 6.5 requirements for required member attendance were verified. The meeting agendas included procedural chang-es, proposed changes to the Technical Specifications and Plant Design Change Records. The meetings were characterized by frank discussions and questioning of the proposed changes. In particular, consideration was given to assure clarity and consistency in procedures. Items for which adequate review time was not available were postponed to allow committee members time to review and commen Dissenting opinions were encouraged and resolved to the satisfaction of the committe The inspector had no further comment .
4, Maintenance and Surveillance (61726, 62703)
The inspector observed various maintenance and problem investigation ac-tivities for compliance with requirements, applicable codes and standards, QSD (Quality Services Department) involvement, safety tags, equipment alignment and use of jumpers, personnel qualifications, radiological con-trols, fire protection, retest, and deportability. Also, the inspector witnessed selected surveillance tests to determine whether properly ap-proved procedures were in use, test instrumentation was properly cali-brated and used, technical specifications were satisfied, testing was performed by qualified personnel, procedure details were adequate, and test results satisfied acceptance criteria or were properly dispositione Portions of the following activities were reviewed:
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ST 11.7-2, Hotwell Level Control Valve Locking Collar Size Flow Test
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SUR 5.2-24, Safeguards Equipment Timer Test
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CMP 8.2-70, Rod Position Indication System Adjustment At Power i
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ST 11.7-5, Preoperational Testing of SW-MOV-3 and 4 Emergency Manual-Closure Circuitry i
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ST 11.7-3, Operating Test of Automatic Vent aad Closure of SW-TV-l 2365A and B Upon High Containment Pressure Signal l
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CMP 8.5-96, Maintenance of Containment Air Recirculation Fan Coolers L
.-- SPL 10.7-353, Containment Cable Vault CO2 Suppression System Pre-operational Test for PDCR 946
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CMP 8.2-66, NIS Overpower Mid Range Trip Setpoint No unacceptable conditions were identifie .1 Containment- Air Recirculation Heat Exchanger Cleaning During this insp ction period, the licensee received permission to relax containment integrity to clean the CAR (Containment Air Recir-culation) heat exchangers while at power. The operational evolutions associated with this cleaning are discussed in Detail 6.3 of this repor On March 7, the first CAR fan (No. 3) was removed from service for cleaning. Cleaning activities were detailed in CMP 8.5-96, Mainte-nance of the Containment Air Recirculation Fan Coolers. Installation of compensatory measures was incorporated into this procedure,~in-cluding: temporary seismic supports for the SW (Service Water) piping inside containment, blank flanges on the upstream side of the SW re-turn line isolation valve, and leak testing of the blank flange Upon opening of the heat exchangers, the licensee observed fouling cifferent than the localized tube plugging which was expected. The heat exchanger tubes were uniformly coated with an unidentified ma-terial which has been characterized as cold water corrosion product This fouling process apparently choked SW flow through the heat ex-changer tubes. Samples were taken and are currently being analyze !
Cleaning and testing activities were conducted successfully. Two minor incidents occurred during the restoration and testing portions of maintenanc On March 10, a two inch, threaded pipe nipple was broken off of the No. 3 heat exchanger while the flanged connection bolts were being tightened. The flange blank was replaced and containment integrity was reestablished while the broken connection was repaire _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ - _ _ _ _ _ _ _ _ _ _ _ -
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Inservice Inspection personnel examined the broken pipe to ascertain its condition. Based on the measurements taken, there did not appear to be significant wall thinning. All of the flanges on the heat ex- l changers were subsequently examined; no significant reduction in pipe l wall thickness was identified. The licensee concluded that the threaded connection had been overstressed when the flange bolts were tightened. An evaluation of the system restoration procedures was conducted and the restoration method changed to require an initial lineup and connection of the pipe flanges prior to final tightening of the bolts. This method was used for the remaining three CAR units without inciden On March 11, while leak testing the blank flange installed upstream of the SW return isolation valve, a leak was identified from a root valve fitting upstream of the SW discharge pressure indicator. Be-cause the containment boundary was extended to the blank flange, the leak was repaired prior to resumption of maintenance activitie Throughout this maintenance evolution the inspectors monitored acti-vities including testing of compensatory measures for containment integrity. Maintenance activities were conducted with two shifts as well as continuous Engineering and Quality Services Department sup-port. Communications and coordination between departments was ef-fective as evidenced by the short durations of relaxed containment integrity (see Report Detail 6.3) and responsiveness to the broken flange connection and leaky valve fittin The inspectors also monitored the licensee's attention to minimizing personnel radiation exposure to as low as possible. Plant power was reduced to 30% for the duration of the maintenance. In addition, boron impregnated sheeting was placed on the charging floor grating to reduce radiation field . Delay in Rescue Team Formation During Emergency Preparedness Drill (88-20-01) (71707)
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During the 1988 Annual Emergency Preparedness Exercise, a weakness was identified: the Emergency Operations Facility staff did not aggressively i follow up on reported personnel injuries / fatalities. The formation and subsequent dispatch of a Search and Rescue Team was not timely, nor was it balanced against personnel availability and accident priorities. This was discussed in NRC Inspection Report 50-213/88-2 On March 28, 1989 the licensee conducted an Emergency Preparedness train- ,
ing exercise. The inspectors observed the portion of this exercise which !
related to this open item. The injured persons received prompt attention from both the onsite and Emergency Operations Facility personnel. No un-acceptable conditions were identifie Further review of this item will occur during the inspection of the upcoming Annual Drill on April 22, 198 I
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6. Events Occurring During the Inspection (71707, 92700, 93702)
6.1 Identification of Unmonitored Release Path On February 24, a Health Physics technician identified radioactive contamination in the station switchyar Investigation into the source of the contamination revealed an unmonitored release path from the Spent Fuel Building in the RCA (Radiologically Controlled Area) '
through a system of drains outside of the RCA to the discharge cana The licensee declared an Unusual Event in accordance with the Emer-
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gency Plan and made the required notifications to the NRC and State of Connecticu . Sequence of Events During the 1987 Refueling Outage, the licensee removed three 55 gallon drums of sludge from the containment sum These barrels were stored until the excess water could be removed before final shipment to a waste burial sit During the end of January 1989, dewatering of these drums was initiate ,
The drums were moved from their shielded storage location to the first floor of the Spent Fuel Building in the area of the Spent Fuel Pool Heat Exchangers where they were to be prepared for shipment. The drum contents were recircu-lated with a utility pump to allow excess water to be re-moved through a fifty micron filter. The waste water was routed to an unmarked floor drain under the "A" heat ex-changer. The personnel performing this evolution assumed that these drains were directed to the radioactive waste system. After several attempts, the evolution was discon-tinued because of continual plugging of the discharge fil-ter Conservative estimates of the amount of waste water discharged are about 50 gallon Approximately four weeks later, on February 24, a Health Physics Technician performing a weekly RCA boundary survey identified a slight increase in radiation level at a peint adjacent to the switchyard fence. She then investigated and found that source appeared to be outside the RCA bound- ,
ar Radioactive material was found to have contaminated '
the switchyard drainage trench immediately outside the fence. Further investigation efforts were initiated im-mediately to identify the source and extent of the con-taminatio I l
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The inspectors found that the Health Physics Technician who discovered the-radioactive contamination had been especially observant: she initially acted on and investigated a change in radiation level of only 0.2 millirem per hour. The in-tent of the survey was to measure radiation levels at the RCA boundary; there are surveys other than this one to check uncontrolled areas for loose. surface contaminatio .1.2 Areas Contaminated The floor drain from the Spent Fuel Building empties'1nto a trench outside of the RCA around the switchyard. This trench then drains to the south yard drain system which empties into a marshy area immediately south of the Pro-tected Area. Water runoff from this marshy area eventually drains to the discharge canal. During normal winter opera-tion with four Circulating Water and so Service Water pumps running, approximately 384,000 gallons per minute flow through the discharge cana Contamination outside of the RCA was identified in the switchyard trench, south yard drain system, and in the marshy area. The contamination in the marshy area extended about 50 yards from the discharge piping of the south yard drain system. No contamination was identified in the area of the piping to the discharge cana Initial surveys of the affected areas indicated 70 mr/hr at the Spent Fuel Building drain piping discharge.to the trench and less than 1 mr/hr where the trench enters the south yard drain system. Smears of these areas indicated maximum levels of 350,000 dpm/100 sq.cm and 2,000 dpm/100 sq.cm, respectively. In the marshy area surveys indicated a maximum of 600 cpm at the discharge of the drain system which decreased to 20 cpm about_50 yards awa .1.3 Corrective Actions Promptly after the confirmation of the contamination, the affected areas were roped off and identified as radiation areas. Samples were taken for analysis where possible in these area Short term corrective actions included removal of contami-nated soil from the marshy area and decontamination of the affected drains and trench. The contaminated soil was re-moved and put into storage in LSA (Low Specific Activity)
boxes. The Spent Fuel Building drains were plugged and the drain pipe discharge point into the trench was bagged to
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limit further spread of contamination. Also, all station floor drains were labelled as controlled or uncontrolled with instructions to notify Chemistry prior to discharging any colutions. A flier was posted around the site which explains the marking of these drains and actions to take prior to discharging any solution The station drawings indicate that the floor drains in the area of the spent fuel pool cooling heat exchangers were plugged shut. This was not the case. Additionally, none of the personnel contacted by the inspectors recalled the drains ever being plugge The licensee has initiated periodic sampling of the soil in the marshy area to identify any increase in contamination levels and provide for material removal. Additionally, an instruction for the use of plant drains is being prepared and training will be conducted on drain us Concurrent with the cleanup activities, plant personnel recalled the removai of sludge from the switchyard trench to the peninsula several weeks prior to the identification of the contamination. The licensee surveyed the sludge which had been removed and verified that it was also con-taminated. This material was removed from the area and also stored in an LSA box. At the inspector's request, the licensee surveyed the lockers and cars of the employees who participated in this sludge removal. No contamination was identifie .1.4 Radiation Dose Calculations Isotopic analysis was performed on samples taken from the I drums containing the remaining sludge from the containment sump. The samples contained primarily Cobalt 60 and Cesium 134 and 137. The total activity discharged was 1,085 micro-curie The conservative assumption was made that all radioactive material entering the drain was released to the environ-ment. No credit was taken for holdup within the drain pipes, for the material removed from the drainage ditch, or for the contaminated soil removed. The calculated dose from this release in unrestricted areas was 3.03E-03 mrem (millirem) whole body and 4.0E-03 mrem to the liver, the most significant organ. This was included with the other liquid releases made in February to calculate quarterly and annual whole body and maximum organ dose per Technical Specification 7.1. At the end of February, the annual total whole body dose was 1.60E-02 mrem; the r..aximum organ
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dose 2.22E-02 mrem. This was a small fraction of the whole i body (1.5 mrem / quarter) and maximum organ (5 mrem / quarter).
dose limits. The total whole body and maximum organ dose over a twelve consecutive month period ending in February was 3.43 mrem and 0.91 mrem, respectively. This also was a small fraction of the 25 mrem limit of Technical Specifi-cation 7.1.3 for either whole body or organ dos .2 Inoperable Auxiliary Feedwater Pump On March 2, during a routine plant tour, an operator identified that the overspeed trip mechanism had been activated on the "A" Turbine Driven AFW (Auxiliary Feedwater) Pump. In this condition the pump is inoperable. The trip mechanism was immediately reset and SUR 5.1-13, Auxiliary Feed Pump Monthly Functional Test, was performed to verify pump operabilit AFW pump operability requirements are specified in TS (Technical Specification) 3.8. A.2. Two steam-driven AFW pumps are required to be operable when the reactor is critical. With one pump inoperable, it must be returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant must be placed in. hot standby within the following six hours. This time. limit was not exceeded because pump operability had been verified the pre-vious day with the performance of the routine monthly-surveillance test, SUR 5.1-1 Security computer records were reviewed and personnel who had ac-cessed the' room were interviewed. No unexpected occurrences were identified. There was no evidence of tampering. The licensee con-cluded that the overspeed trip mechanism was inadvertently actuate Personnel access to the rear section of the AFW pump Room is diffi-cult due to the congestion of piping and associated seismic support The intended pathway to the left of the "A" AFW pump is blocked by pipe supports. Passing this way requires an individual to crouch down and move sideways through the opening. The licensee has stated that, as an alternative, personnel have been observed crossing to the right of the AFW pump. This requires traversing the pump turbine discharge piping and the turbine overspeed trip mechanis The position of the AFW pump turbine trip lever is visually verified by the Plant Equipment Operator during each shift (Reference: SUR 5.1-000, Steady State Operational Surveillance).
The inspectors noted that there is no remote indication of overspeed
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trip mechanism position. The advantage of this indication and the unacceptability of personnel traversing safety-related equipment was discussed with the Operations Supervisor. The licensee is evaluating the feasibility of installing remote annunciation of the overspeed l trip mechanism position. To prevent further inadvertent actuations l of the turbine overspeed trip mechanism, the licensee placed a large l *
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sign over the pump turbine. The sign states that the pump is safety-
-related and that personnel should use an.alternata route through the area. These actions conformed with the recommendations of IE In-formation Notice No. 84-66, Undetected Unavailability of the Turbine Driven Auxiliary Feedwater Train, dated August 17, 1984. Addition-ally, Security personnel were advised through the " Read and Sign" process of the hazards in this are .3 Relaxation of Containment Integrity During Heat Exchanger Cleaning On March 7, the licensee received TS (Technical Specification) Amend-ment No. 112 permitting a one-time relaxation of containment.integ-rity for cleaning of the SW (Service Water) side of the four CAR (Containment Air Recirculation) fan heat exchangers during power operations. The heat exchangers had been determined to be partly blocked. Cleaning was necessary for relief from the restrictions of the JCO.(Justification for Continued Operation) involving SW. flow and heat loading. This JC0 was discussed in NRC Inspection Report 50-213/88-23 and is also discussed in Detail 10 of this repor Cleaning activities are described in Detail 4.1 of this report.
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The amen 6ent added a footnote to TS 3.11.B, Containment, which states that the SW piping (containment boundary) may be opened for u to eight hours at a time for installation or removal of blank flan-ges. During the time in which integrity is relaxed, compensatory measures are to be taken: a blank on the SW outlet valve; and water pressure in the SW piping greater than containment accident pressur If' integrity is not restored within eight hours, the plant must be placed in hot standby within six hours and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Additionally, the cumulative time for the re-laxed integrity is not to exceed 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. Operability of the CAR fans is controlled: TS 3.11.0 requires that three of the four CAR fans be operable whenever the reactor is critical. Administrative controls are in place which limit the time that a CAR unit is in-operable to seven day On March 6, power was reduced to approximately 30% in preparation for the cleaning evolutions. The No. 3 CAR fan was removed from service on March Cleaning activities for all four CAR fans continued un-til March 18. On March 21, power escalation began at the rate of five percent per day. The reduced increase rate was for fuel manage-ment considerations. The plant reached 70% power at the end of the inspection perio The licensee elected to perform volumetric leak testing of each CAR heat exchanger in order to assign a leakage rate to each of these containment penetrations. This leakage is added to the total current containment leakage, 146.873 lbm/ day. Containment leakage is limited to 650 lbm/ da _ _ _ _ _ _ _ _ - _ - ___ _ - _ _ - ______ - _ - - __ - _ -
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The following table itemizes for each CAR fan the' total time of re-11 axed containment, the measured increase in SW. flow through the heat
' exchanger tubes following cleaning, and the total air leakage across the dry heat exchanger tubes following cleanin CAR TOTAL TIME INCREASED TOTAL FAN N CTMT RELAXED SW FLOW LEAKAGE 1 5 hrs. 36 mi gpm 0.903 lbm/ day 2 4 hrs. 43 mi gpm 1.124 lbm/ day 3 5 hrs. 27 mi gpm 2.478 lbm/ day 4 4 hrs. 20 mi gpm 1.875 lbm/ day For each CAR fan, containment integrity and operability were restore well within the TS and Administrative limits. The longest period during which a CAR fan was inoperable was about 3.5 days for the
'first heat exchanger cleaned (No. 3).
The inspectors observed activities during the relaxation of contain -
ment integrity, including installation of the compensatory blind flange, and verified the maintenance of SW piping pressures greate than containment post-accident pressures. The inspectors routinely reviewed the control room logs for accurate record of action state-ment-times and accountability of personnel inside containment. No discrepancies were identifie The licensee has identified the additional need to clean the CAR fan motor cooling coils. These coolers are also supplied by SW. Because of the condition that the Operating License Amendment provides a one-time relaxation of the containment integrity TS, the licensee will process a second amendment reques .4 Rod Control System Failures On March 17, with the plant at 30% power, operators experienced a rod control system failure while attempting to move Bank B control rod When the operator returned the control rod in/out switch to the neu-tral position, the movement direction signal did not clear and the rods continued to move. Concurrently, the slave cycler failure an-nunciator alarmed; this annunciator had also alarmed several times during the previous shift. In accordance with A0P 3.2-23, Control Rod Malfunction, the operator placed the disconnect switch to the disconnect position and rod movement cease Review and comparison of the Digital Rod Position Indication and Rod Position Indication Systems indicated that the maximum rod movement was three steps in
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both the inward and outward directions. The control rods remained-tripable throughout the event and no Technical Specification action statements were entere Electrical Maintenance and Instrumentation & Controls personnel were contacted to investigate the cause oflthe unexpected rod movement and the slave cycler. failure alarms. The backup master cycler was placed in service. However, the slave cycler failure alarms continued.' The master cycler which was removed from service was inverted to re-wet-the mercury contacts. This unit was then put in service and the slave cycler failure alarms ceased. The control rods were moved several steps to verify proper rod control system operatio The inspector questioned whether re-wetting of these contacts should be routinely performed to avoid similar situations. Instrumentation
& Control personnel stated that a quarterly PM (Preventive Mainte-nance) activity previously existed for re-wetting of>the master cycler mercury contacts. However,-this PM had been discontinued i June, 1988. The inspector requested that a re-evaluation be per-formed of the necessity for and operational implications of this P .. The determination was made to reinstitute this PM quarterl ..
The inspector observed control room activities immediately following -
engagement of the disconnect switch and identified no further con-cern .5 Uncontrolled Containment Penetration Boundary Valve On March 27, the licensee identified a containment penetration boundary valve in the PW (Primary Water) System which apparently was not being controlled in'accordance with station procedures. This discrepancy was identified during revision of-SUR 5.7-78, Primary Water to Containment, P-68, as part of the Procedures Upgrade Pro-gram. ' PW-V-600 is required by SUR 5.1-126, Locked Valve Checklist, to be in the locked closed position. However, during normal opera-tions, this valve has been routirely operate PW-V-600 is a manual isolation valve for the PW System flush to the sample sink. This flushing line ties into the containment penetra-tion between the outboard isolation check valve and the containment wall. Position and operational restrictions for this valve are not governed by Technical Specifications. The valve is a one-half inch ball valve located in the Primary Auxiliary Building pipe trenc Chemistry personnel routinely use this portion of piping to supply demineralized flushing water to the sample sink.
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When this discrepancy was identified, the valve was closed and locked and an orange " Containment Boundary" tag hun The circumstances L surrounding this apparent uncontrolled operation of a containment u
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penetration bounda'ry valve will be followed as Unresolved item 89-02-01, pending evaluation of safety significance and the associated NRC enforcement policy consideration As this involves the degradation of a containment penetration, the licensee made a one-hour report in accordance with 10 CFR 50.7 Notifications were made to the NRC and the State of Connecticu At the close of this inspection period, the licensee was investi-gating the cause of this situation. The inspectors will follow this investigation and corrective action . Review of periodic and Special Reports (90712)
Upon receipt, periodic and.special reports submitted pursuarit to Technical Specification 6.9 were reviewed. This review verified that the reported information was valid and included the NRC required data; that test re-sults and supporting information were consistent with design ores ctions and performance specifications; and that planned corrective actions were adequate for resolution of the problem. The inspector also ascertained whether any reported information should be classified as an abnormal occurrence. The following report was reviewed:
Haddam Neck Plant Monthly Operating Report 89-02, for the period February 1, 1989 through February 28, 198 No inadequacies were identifie . Cable Separation Discrepancies Identified in the New Switchgear Building (71707)
During this inspection period, two licensee PIRs (Plant Information Re-ports) were issued concerning construction of the Appendix R Switchgear Building. The first concerned deficiencies in cable separation (PIR 89-38) and the second concerned the potential for electrical noise in instrument channels induced by inadequate cable separation (PIR 89-45).
The licensee 1s constructing the Appendix R Switchgear Building conduit and cable routings in accordance with Regulatory Guide (RG) 1.75, Physical Independence of Electrical Systems, and IEEE 384-1977, Criteria for Inde-pendence of Class 1E Equipment and Circuit During an instrument cable pull, it was identified that although the 4'
separation criteria of RG 1.75 and IEEE-384 are being met in the conduit banks, the separation is apparently inadequate in the manholes and cable chases. This nonconformance was confirmed by Bechtel Engineers. The licensee was informed that physical separation criteria would not be met i in these cases, however the cable will be adequately protected by alter- )
nate means: cable wraps and tray covers, j
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'While investigating PIR'89-38, the licensee became aware of the potential for induced _ electrical noise in the instrument channels due to the routing of power cables close to the instrument channel cables. It became ap-parent that two DCNs (Design Change Notices) were made to the original PDCRs (Plant Design Change Records): the substitution of PVC for steel-conduit in several conduit banks and the addition of the Containment Air Recirculation Fan Motor power cables into the Service Building Hallway conduit ban These DCNs may not have received complete review by all
. disciplines affected. The licensee is currently conducting a review of the circumstances involved and an audit of interdisciplinary DCNs which also may not have received thorough reviews. Inspector review of the potential deficiencies in the DCN process for the Appendix R Switchgear Building will be tracked as Unresolved Item 89-02-0 At the close of the inspection period, the licensee was commencing root cause analysis of these issues. The inspectors will continue to review Switchgear Building construction and implementation of corrective action . Observation of Emergency Preparedness Drills (71707)
Throughout the inspection period, the inspectors observed portions of several planned and unannounced emergency preparedness drills. These'in-cluded fire drills for operations and security personnel, security exer-cises' for the security guard force,. as well as the training exercise on March 2 The drills were conducted in a professional manner and had minimal icpac on plant operations. The March 28 drill included.a site evacuation and a personnel injury requiring search and rescue. Post drill critiques were thorough and adequately identified any areas requiring improvement. No inadequacies were identifie . Justification for Continued Operation Concerning Degraded Service Water System Performance (71707, 61726, 62703)
On December 16, 1988, the licensee had determined that, under certain cir-cumstances, the CAR (Containment Air Recirculation) fan cooling units would not adequately cool the containment atmosphere and that the contain-ment design pressure could be exceeded in the event of a design basis Loss of Coolant Accident. To address these concerns, a JC0 (Justification for
,
Continued Operation) was developed. This JC0 included several operational limitations including a maximum Connecticut River water temperature of 50 l- degrees F and maximum CAR heat excnanger tube plugging of 55%. This JC0 L was discussed in detail in NRC Inspection Report 50-213/88-23, Detail 11.
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10.1 _ Modifications to S'ervice Water System During this inspection period the licensee has continued efforts to'
lif t _the JC0 and its accompanying restrictions. The CAR heat ex-changer tubes were cleaned (discussed in Detail 4.1 of this report).
Also, the following three PDCRs (Plant- Design Change Records) were made to the SW (Service Water) system:
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PDCR 955, Installation of Emergency Automatic Closure Circuitry for the Turbine Building Service Water. Header Isolation Valves, SW-MOV-1 and SW-MOV-2
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PDCR 957, Installation of Emergency, Manual Closure Circuitry for the Component Closed Cooling Water Header Isolation Valves, SW-MOV-3 and SW-MOV-4-
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.PDCR'958, Automatic Vent and Closure of SW-TV-236A & B Upon a High Containment Pressure Signal Basically, these design changes isolate nonessential:SW loads during desigr, basis accidents. That makes additional water capacity avail-able for the' CAR Seat exchangers, Emergency Diesel Generators, and Residual Heat Recoval Heat Exchanger Associated with implementation of these PDCRs were preoperational tests, procedure changes and operator training. .The inspectors at-tended several of the Plant Operation Review Committee meetings in which these PDCRs were discussed. Portions of installation and testing evolutions were observed and procedure revisions'and operator
,
training were reviewed. No deficiencies were identifie .2 Analysis of Service Water System Design The licensee received notification from Westinghouse that the SW sys-i tem will meet all of its heat removal requirements with the plant l design basis SW inlet temperature of 85 degrees F, with the design ;
l modifications previously discussed, and with the following condi- !
tions:
--
No credit was taken for PDCR 958;
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No credit is taken for automatic isolation of the SW supply to the spent fuel pool heat exchangers; )
--
Screenwash flow is assumed to run continuously; l --
The SW pumps are assumed to be fully degraded to minimum In-service Inspection allowable limits; and L
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Three sets of manual throttle valves were assumed to be in pre-scribed positions. These valves control the coolir.g of safety:
related components: the SW throttle valves to the CCW (Component Cooling Water), RHR (Residual Heat Removal), and CAR heat ex-changer 'Because this analysi.s did not account for degradation of the CAR fan motor. coolers.due to silt buildup similar to that in the CAR heat exchangers, the licensee has elected to revise instead.of lift the JCO, until the motor coolers can be cleaned or replace Additional modifications to the SW system and system operation are being evaluated to alleviate demands on SW during warm weather. The operational concern is that, with the SW CAR heat exchanger outlet valves in the current pocition, there is-insufficient SW flow'to meet the balance of plant comands with elevated SW inlet temperature .3 Revision to Justification for Continued Operation On March 28, the licensee revised the JC0 in accordance with the re-analysis of the SW design basis. The-limiting conditions for this
. revision are: SW inlet temperature is below 75 degrees F, four SW pumps are operable (one may be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />), and '
the SW throttle valves for the CAR, CCW, and P.HR heat exchangers are throttled to specified position The licensee is pursuing another Technical Specification change to relax containment integrity for cleaning or replacement of the CAR fan motor heat exchanger . Identification of Auxiliary Feedwater Susceptibility to Single Failures 'i (71707, 61726) '
On March 17, the licensee reported to the NRC the identification of sus-ceptibility to single failures in systems associatert with the AFW (Auxili-ary Feedwater) System. Two separate single failures were identified which could result'in an inadequate water supply for AFW. The licensee postu-lated that failure of a level control valve (CD-LCV-1317A) which diverts makeup from the DWST (Demineralized Water Storage Tank) to the condenser hotwell could result in draindown of the DWST. Similarly, failure of the return piping to the DWST from the condensate pump discharge downstream of a second level control valve (CD-LCV-1317B) could also result in DWST draindown. Draindown of the DWST would deprive AFW of sufficient water for steam generator decay heat removal. A JC0 (Justification for Con-tinued Operation) was prepared and the required reports were made to the NRC and the State of Connecticu ._ _ _ - _ _ _ _ _
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Both level control valves are pneumatically operated. CD-LCV-1317A'is an eight inch valve which fails open'on a loss'of air; CD-LCV-13178 is a four inch valve which fails closed on a loss of- air. Both valves are' located on;the. ground floor of the~ Turbine Building and an not seismically quali-fie The JC0 re( red sset of the low DWST level alarm setpoint,-modification to the CD-LL e.t la to limit flow diverted to the. condenser, and changes to several operations procedure Technical Specifications 3.8. A.3.a requires that the DWST have a minimum inventory of 50,000 gallons. The'lcw level alarm setpoint has been 54,000 gallons. Under this JC0 the ' low level alarm setpoint has been raised to 70,000 gallons. An inventory of about 100,000 gallons is normally main-tained in the DWST-.
Additionally, the licensee had performed ST 11.7-2, Hotwell Level Contro Valve Locking Collar Size Flow Test, to determine the necessary collar
. size to limit diverted flow to 460 gpm through CD-LCV-1317A. With this
!
collar in place, the draindown of the DWST is limited and allows for suf-
! ficient time for operator action before the minimum level required by Technical Specifications is reached.
f Operations, procedures were. changed accordingly and a Read and Sign noti-c' fication was; issued to operators to detail this modification and the changes to operating and emergency procedure The. inspectors observed performance of ST 11.7-2 and final installation. of the collar. . Procedure changes and operator training were also reviewed.
No deficiencies were identifie The licensee is evaluating possible long term modifications to this system to correct the single failure susceptibilit . Management Meetings (30703)
.
On February 2i, the inspector attended a presentation the licensee made to :!
!. NRC Region I Management on the proposed 1989. Refueling Outage Test Program f for testing and tie-in of the Appendix R Switchgear Building. Attachment 1 to this report is the handout presented by the licensee during this
'
meetin The inspector also attended a meeting between the licensee and NRC staff in:Rockville, MD on February 28. Topics discussed included Appendix R
- Switchgear Building construction, testing, and compliance with 10 CFR 50 L
Appendix R. The meeting handouts detailing construction status and the 1989 refueling outage test program are Attachments to the meeting minutes, dated March 20, 198 .m_-... _m _--a_ _____m._-.___m - _ - _ _ _ _ _ _ _ _ - - ._
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Meetings were held with' station management as needed to discuss inspection findings during the report period. A summary of the findings was also discussed during the exit meeting. No proprietary information related to this inspection was identified. No written material was given to the licensee during the inspection perio ,
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