IR 05000213/1993019

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Insp Rept 50-213/93-19 on 931003-1106.No Violations Noted. Major Areas Inspected:Plant Operations,Maintenance, Engineering & Technical Support & Plant Support Activities
ML20058F917
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 11/23/1993
From: Rogge J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058F878 List:
References
50-213-93-19, NUDOCS 9312090043
Download: ML20058F917 (33)


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U.S. NUCLEAR REGULATORY COMMISSION REGION 1 i

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Docket /.

50-213/93-19

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Report No.

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License No.

DPR-61 l

l Licensee:

Connecticut Yankee Atomic Power Company (CYAPCo)

P. O. Box 270 l

Hartford, CT 06141-0270

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i Facility:

Haddam Neck Plant j

Location:

Haddam Neck, Connecticut j

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Dates:

' October 3,1993 to November 6,1993

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_ illiam J. Raymond, Senior Resident Inspector

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W Inspectors:

- Peter J. Habighorst, Resident Inspector l

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Approved by:

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,/ John F. Rogge,'Chiejf V Dafe

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Reactor Projects Section No. 4A l

l Areas Inspected: NRC resident inspection of plant operations, maintenance, engineering and j

technical support and plant support activities. As an initiative, the inspector reviewed the design

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and license commitments for the onsite storage of diesel fuel oil.

Results: see Executive Summary i

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ADOCK 05000213 i

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EXECUTIVE SUMMARY f

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IIADDAM NECK PLANT INSPECTION 50-213/93-19

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Plant Operations

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Safe facility operation was noted throughout the period as the plant continued routine power

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operations. Operators performed very well in response to a failure of the 'D' service water

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pump and to cleaning service water strainers when the header was in a degraded condition.

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Licensec actions to revise the technical specifications (TS) to facilitate strainer cleaning i

operations without entry into TS 3.0.3 will be followed (Section 2.2). The plant staff also

performed very well in response to an inoperable diesel fire water pump, establishing a j

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temporary fire water supply in a timely manner.

i NRC review of the licensed operator requalification training program noted very good e

performance by the operators, and good oversight by the Operations Manager, who

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contributed to the quality of the evaluation process. Overall training performance was j

mixed, however, due to some significant failures (Section 2.3). Licensec actions to address a l

e negative trend in the operator requalification program will be reviewed during future routine

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inspections.

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Maintenante j

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i The inspector noted very good control of routine maintenance during this period. Plant staff

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performed very well to troubleshoot and repair degraded equipment conditions, and in

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particular, to the repair of the 'D' service water pump and the diesel driven fire water pump.

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Maintenance provided good oversight of vendor personnel for the overhaul of the diesel t

i driven fire pump. The maintenance staff performed very well to complete the li e pump

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diesel overhaul in a timely manner so as to minimize the out-of-service time for equipment j

important to plant safety.

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Good performance was observed for surveillance activities during this period, and in l

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particular, for the test of the diesel generator heat addition to the diesel room, and the test of

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j the alternate supply of the fire water system. For these activities, plant maintenance, test l

l and engineering personnel were very knowledgeable of the plant systems, as well as the l

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performance requirements of the equipment under test. The satisfactory completion of the

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emergency diesel heat rate and ventilation flow rests allowed the resolution of a long standing

compensatory measure for the generators.

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Jinginee.rjng and Technical Supap_rt l

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Site and corporate engineering provided timely oversight and evaluation of the status of the j

leak-in main steam safety valve MS-SV-14. Engineering provided a very thorough review of

the valve operating characteristics in support of a proposed temporary repair of the leak..

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The associated technical and safety evaluations were of high quality. Plant management chose a permanent repair plan instead. Site engineering also provided good support to j

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operations for the inspection and repair of the non-safety related fuel oil storage tank. The thorough safety and technical evaluations, and timely actions to minimize the out-of-service j

time for the oil tank and the tire pump, showed an excellent regard for equipment important j

to plant safety.

I The NU Nuclear Safety Engineering (NSE) group reviewed the site in response to NRC Information Notice 93-12 and the lessons learned from Hurricane Andrew. The NSE review noted site access vulnerabilities and limitations in the onsite storage capabilities for diesel f

fuel oil, and made recommendations to augment existing plans and procedures. Plant i

management showed a good sensitivity for the issues by acting on the draft recommendations I

to assign actions to develop additional contingency plans that would assure the timely l

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delivery of fuel during natural disasters. Licensee practices exceed existing license l

requirements for the onsite storage of diesel fuel. An inspection item was opened to further

l review the actual capabilities of the above ground storage tank to withstand the effects of natural disasters. This item, and the CYAPCo actions to address the NSE recommendations,

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will be reviewed in a subsequent inspection (Section 4.2).

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l-Plant Support

i Radiological controls for routine operating test and maintenance activities were good.

l Health physics personnel at both Millstone and Haddam Neck were very knowledgeable of the system for storing radworker exposure information. and readily retrieved information

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dating back to 1976. The plant operations review committee (PORC) performed well during i

the period to monitor and evaluate plant performance. The PORC review of the engineering recommendations and the proposed temporary repair plan for the leak in main steam safety valve MS-SV-14 were particularly effective and critical to assure reactor safety. The PORC review of the modification and plans to drain, inspect and repair the onsite fuel oil storage tank was also effective to assure an adequate supply of fuel remained available to the emergency diesel generators.

Good performance was demonstrated during this period to address a historical condition regarding the potential diversion of water from the demineralized water storage tank.

Engineering evaluations in 1993 discovered a potential single fr.ilure vulnerability that was -

not recognized when this area was first reviewed in 1989. Further, the condition was reported late because of a weakness in the internal reportability guidelines. The reportability weakness was discovered as the result of a 1993 initiative to improve the process for evaluating deficiencies. Enforcement discretion was exercised regarding tank operability and LER timeliness in recognition of the corrective actions taken and the initiatives to improve engineering reviews of potential design deficiencies a'nd to improve the reportability process.

Licensee actions to address the reportability process will be reviewed further. Two non-cited violations and one unresolved item associated with these issues are discussed in Section 5.3.

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TABLE OF CONTENTS

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1.0 SUMM ARY OF FACILITY ACTIVITIES........................ I

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. PLANT OPERATIONS (71707 and 93702)........................ I

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2.1 Operational Safety Verification..........

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2.2 Temporary Entrance into. Technical Specification (TS) 3.0.3.........

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2.3 Licensed Operator Requalification Training (LORT).............. 4

2.4 Inoperable Diesel Driven Fire Pump........................ 5 l

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3.0 MAINTENANCE (61726,62703 and 71707)...

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3.1 Maintenance Observation......

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3.2 Surveillance Observation...

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I 4.0 ENGINEERING AND TECHNICAL SUPPORT (37828 and 71707)

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4.1 Evaluation of MS-V-14 Status and Repair Options 15 ~

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4.2 Onsite Storage of Diesel Fuel Oil

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4.3 Fuel Oil Storage Tanks Inspection

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5.0 P' ANT SUPPORT (40500,71707. 90712 and 92701).

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Radiological Controls 21-i

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5.2 Plant Operations Review Committee..

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5.3 Review of Written Reports.....

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5.4 Fitness For Duty Event............................. -..

6.0 EXIT MEETINGS (30702).........

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Note: The NRC inspection manual procedure or temporary instruction (TI) that was used as inspection guidance is listed for each applicable report section.

Figure 1 - Potential DWST Inventory Aversion r

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I DETAILS'

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1.0 SUMMARY OF FACILITY ACTIVITIES I

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l The unit operated at full power throughout the inspection period. The fourth quarter

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emergency plan training drill was conducted on November 4, and included participation by l

the station emergency organization, with limited involvement by the corporate organization.

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l 2.0 PLANT OPERATIONS (71707 and 93702)

i In addition to normal utility working hours, the review of plant operations was routinely j

conducted during portions of backshifts (evening shifts) and deep backshifts (weekend and j

night shifts). Inspection coverage was provided for twenty-two hours during backshifts and j

ten hours during deep backshifts.

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2.1 Operational Safety Verification This inspection consisted of selective examinations of control room activities, operability reviews of engineered safety feature systems, plant tours, review of the problem l

identincation systems, and attendance at periodic planning meetings. Control room reviews j

consisted of veri 6 cation of staffing, operator procedural adherence, operator cognizance of

control room alarms, control of technical specification limiting conditions of operation, and

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electrical distribution verifications. Administrative control procedure (ACP) - 1.0-23,

" Operations Department Shift Staffing Requirements," identifies the. minimum staf6ng requirements. During the inspection period, these requirements were met.

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The inspector reviewed the onsite electrical distribution system to verify proper electrical

line-up of the emergency core cooling pumps and valves, the emergency diesel generators,

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radiation monitors, and various engineered safety feature equipment. The inspector also i

verified valve lineups, position of locked manual valves, power supplies, and flow paths for the high pressure safety injection system, the low pressure safety injection system, the

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containment air recirculation system, the service water system, and the emergency diesel generators. No de6ciencies were noted.

Bypass jumpers 93-0039 and 93-0040 were reviewed against the requirements of ACP 1.2-l 14.1, " Jumper, Lifted Lead, and Bypass Control," with emphasis on proper installation and l

the content of the safety evaluations. The inspector reviewed all jumpers for age, and l

l veri 6ed that Plant Operations Review Committee (PORC) evaluations were completed to j

disposition longstanding evaluations. The jumpers reviewed were found to be in accordance l

with administrative requirements.

Tacouts

l Inspection was performed of equipment tagouts according to applicable sections of ACP 1.2-14.2, " Equipment Tagging." Tagouts were reviewed to verify that the proper equipment was j

tagged, equipment identified within technical speciGeations was appropriately controlled, and

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I equipment isolation was proper based on work observations, controlled drawings, and procedural guidance. Tagouts reviewed were: 931229 and 931285. Other tagging operations l

were reviewed by comparing the tags installed within the plant with the tagout sheets maintained in the control room. Equipment reviewed was appropriately isolated and the tagouts met the technical specification requirements and administrative controls.

i leg-Keeping and Turnovers The inspectors reviewed contrcl room logs, night order logs, plant incident report logs, and j

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crew turnover sheets. No discrepancies or unsatisfactory conditions were noted. The inspectors observed crew shift turnovers and determined they were satisfactory, with the shift

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supervisor controlling the turnover. Plant conditions and evolutions in progress were discussed with all members of the crew. The information exchanged was accurate. Control room trouble reports were reviewed for age, planned action, and operator awareness of the i

reason for the trouble report. The majority of trouble reports reviewed were recent, with few longstanding items.

During attendance at daily planning meetings the inspector noted discussions on maintenance and surveillance activities in progress, and planned work authorizations. The inspector conducted periodic plant tours in the primary auxiliary building, turbine building, and intake structures. Plant housekeeping was satisfactory.

2.2 Temporary Entrance into Technical Specification (TS) 3.0.3 The licensee monitored river conditions throughout this inspection period and noted an increase in river debris caused by the seasonal changes. The river conditions were trended on the plant " Plan of the Day" starting on October 4. Activities to mitigate the affects of the -

river debris were discussed in the daily plant status meetings. The operators increased their-survcillance of plant systems potentially affected by the river conditions. No impact was seen except at the intake structure. Fouling of intake travelling screens and the service water (SW) strainers required close monitoring and increased cleaning to preclude excessive fouling and degraded system conditions. Additional maintenrnce personnel were placed on the backshifts to assure adequate resources were available and vendor personnel (divers) were brought onsite to clean trash racks as conditions warranted. The necessity to clean the SW strainers increased to as high as several times a shift, depending on the changing conditions in the river.

The plant was in the TS 3.7.3 action statement on November 1, due to the inoperable 'D'

service water (SW) pump. This pump was removed from service on October 31, as discussed in Section 3.1.4 of this report. The licensee trended the conditions of the alternate SW header using procedure PMP 9.1-36, " Service Water Pump Strainer Operation."

Operators noted that the 'A' and 'B' pump strainers were fooling and had to be cleaned prior to reaching an inoperable condition in which loss of function would occur. The licensee must tmbolt the strainer lids and replace baskets within the strainer housing to complete the i

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cleaning operation. The associated pump corarol switches are placed in pull-to-lock (PTL)

on the main control board to assure the pump does not inadvertently operate during the-cleaning operation. This action assures personnel safety. However, with the control switch j

of any one SW pump in PTL,' the licensee considers that the associated SW header to be l

inoperable per the technical specifications.

.I Thus, with the 'D' SW pump inoperable, the licensee entered the TS 3.0.3 action statement at 5:50 a.m. on November 1 as the 'A' and 'B' SW pumps were removed from service to clean the associated strainers. The licensee staged the personnel and material needed to l

perform the work and completed the operation in 10 minutes. The strainers were cleaned

sequentially, and the header was returned to an operable status to exit the action statement at 6:00 a.m. Recurring fouling conditions required the above sequence to be repeated again j

prior to the return of the 'D' SW pump to service on November 3.

l The inspector reviewed the service water system licensing and design basis and noted that the system has redundancy and operating margins for normal plant operation. For the existing river water conditions, with a temperature of 49 degrees Fahrenheit (F), two operating SW

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pumps are adequate to meet the plant heat loads. By design, three pumps are sufficient to i

remove power generation heat loads with river temperature at the assumed maximum.

Further, for assumed design basis accident conditions, a single service water pump is sufficient to adequately cool the core during the injection phase following a postulated loss of coolant accident. However, the accident analysis assumes that a second SW pump is placed into service after initiating the recirculation phase for long term post-accident core cooling.

This would allow re-establishing cooling to other plant loads, such as to the spent fuel pool heat exchangers. Thus, both SW pumps in each loop must be operable for the header to be operable.

The inspector concluded that, during the November 1-3 period as strainers were cleaned, the alternate SW header remained fully functional since the affected pump remained available to the operators upon demand, and the strainer cleaning operation was completed in a well controlled and deliberate manner. Based on the above, plant safety was not compromised during the brief period that the alternate SW header was " technically" inoperable. The l

inspector noted that the operators and maintenance personnel performed very well to prepare I

for and to clean the strainers in an expeditious manner. The inspector noted further the licensee actions were proper to address strainer fouling before a loss of function occurred.

Licensee management recognized the need to address a technical specification issue on the use of TS 3.0.3 under these conditions. The licensee stated that a proposed change to

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technical specification 3.7.3 would be submitted to NRC:NRR, that would preclude the need to use TS 3.0.3 to cican SW strainers. The inspector considers this matter unresolved pending the completion of the above action by the licensee, and subsequent review by the NRC (UNR 50-213/93-19-01).

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l 2.3 Licensed Operator Requalification Training (LORT)

The inspector witnessed a simulator training session for plant operators on October 14, 1993.

i The session was attended by an operations crew and was held in week 5 of LORT Cycle 4.

Representatives from the licensed operator training staff and the CYAPCo Operations

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Manager evaluated the conduct of training and the crew's performance. The inspector

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witnessed the conduct of two scenarios: CY-OP-LORT-S008, which included a loss of one i

feeder to the semi-vital power supply, a steam generator tube leak, a complete loss of semi-

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vital power supply, and steam generator tube rupture; and, CY-OP-LORT-S010, which included hurricane conditions at the site, a partial loss of the 115KV supply, a total loss of

service water, and a station blackout. The licensee evaluated individual and crew

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performance, as well as the use of the emergency and abnormal operating procedures.

l The session observed by the inspector went very well. The operations crew demonstrated very good performance for both scenarios, with strengths demonstrated in command and j

control, procedure knowledge and use, individual knowledge and skills, and good

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communications. The operations and training staff provided a detailed and thorough critique

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of crew performance following each scenario, and identined improvement items for both

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individuals and the crew. The Operations Manager, in particular, demonstrated a superior knowledge level of the EOP network, and provided a very positive impact on the overall quality of the evaluation and training process.

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One issue requiring additional licensee attention was observed during the session on October

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14. Several simulator problems occurred during the scenarios, including: blinking lights on f

the circulating water pumps, excessive nuisance alarms on the safety system lockout panel,

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faulty indications during operation of the primary water pumps, anomalous indication lights

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on radiation monitor RM-18, and an inoperable computer (plazma) display on the main j

control panel. None of the problems was so severe so as to stop the drills, but they did l

detract from the quality of the training session. The problems were noted by the Operations

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Manager, who indicated that some of them were recurrent or uncorrected conditions.

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Actions were taken to correct each deficiency identified on October 14. Further, actions

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were taken to address the need for improved performance by the training staff to formally j

document discrepant conditions as they occur, and for the simulator maintenance staff to

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improve the timeliness of correcting these types of problems. Another longstanding

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simulator problem reported to the inspector was the backup host computer used to drive the simulator. The computer has been inoperable for 8 months and actions to repair it have been

deferred since it is to be replaced by a new computer. The NRC will review licensee

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performance in this area as part of rc.: tine reviews of the LORT during subsequent

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inspections.

In addition to the session on October 14, the NRC also inspected the LORT during the

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period of October 4-8,1993. T'c results are documented in NRC Report 50-213/93-20 and l

good performance was noted by the operations and training staffs during that inspection.

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However, during the complete LORT cycle, the licensee noted mixed performance, with l

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three individual failures and one crew failure.- The individuals and crews were removed

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from shift to complete remedial training as required. The licensee concluded that a declining i

trend in the training program was indicated by these results, and initiated actions to review

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the reasons for the decline and to implement corrective measures. This matter will also be i

reviewed as part of subsequent routine inspections of the initial and licensed operator requalification program.

2.4 Inoperable Diesel Driven Fire Pump i

The licensee removed the diesel driven Gre pump (P-5-1 A) from service for routine preventive maintenance at 5:58 a.m. on October 18. This placed the plant in the action i

statement for Technical SpeciGcation 3.7.6.1, which allows for continued plant operation for j

7 days. The electric fire water pump and the supply header were otherwise fully operable.

problems were experienced in returning the diesel Dre pump to service _ (see Section 3.1.5 of this report for further details) and the licensee initiated actions on October 21 to provide an~

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alternate supply of fire water in accordance with Action Statement (a) of Technical

Specification 3.7.6.1. This specification allows for indennite plant operation with an alternate supply if the normal pump cannot be returned to service within 7 days, provided the

remainder of the fire water supply and distribution system is otherwise operable.

The inspector reviewed the actions to install, test and operate an alternate supply to the Ere l

water distribution system. The alternate supply was established per SPL 10.1-37,

Installation, Testing and Use of a Tt morary Fire Pump." The licensee also prepared an j

associated technical evaluation and a ety evaluation for the use of the temporary system.

The system consisted of a skid moumai pump driven by a diesel engine. The pump skid assembly was installed outside of the protected area and took a suction from the plant

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discharge canal. The pump was a Godwin Model HL8, fully automatic, single stage -

centrifugal pump. The pump was driven by a Caterpiller 3406B water cooled diesel engme.

Irrigation piping delivered river water from the diesel pump skid to the intake building and connected into the Dre distribution system at the test header isolation valves, FP-V-111 and FP-V-112.

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I The inspector reviewed the alternate supply against the design and technical specification requirements for the normally installed pump to assure the alternate was an acceptable substitute. The temporary pump had an adjustable capacity of 3000 ppm at 138 psi and 1800 rpm. This was greater than the 100% capacity rating of the permanent pump, which was 2500 gpm at 115 psi and 1800 rpm. The temporary installation was demonstrated adequate by a system flow test on October 24, 1993. The inspector reviewed the test results, plotted in a curve of system Cow versus pressure, and verified that the temporary system Dow characteristics exceeded the flow requirements required by the technical specifications.

Although the alternate supply could be set up to provide for automatic start on low fire header pressure, the licensee elected to leave the pump in standby with the supply piping drained as a precaution against freezing. Also, the supply piping was disconnected at

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speci6ed locations to drain the header. Additional maintenance personnel were assigned to f

the back shifts to assure adequate resources would be available to put the alternate supply i

l-into service on demand within 15 minutes. The inspector walked down the diesel skid and j

supply piping to assure that the licensee's assumption for bringing the system on line were

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realistic. No inadequacies were identified, t

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The inspector also reviewed the services established to support operation of the skid, l

including electrical power, cooling water, fuel and lubrication. The vendor's preventive maintenance activities for the skid were reviewed and found to be current. The temporary

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diesel had a frame mounted fuel storage tank of 138 gallons, which was greater than the

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minimum volume of 130 gallons required by the technical specifications for the permanent pump. This quantity of fuel was sufficient to provide for pump operation for a period of time that exceeded the assumed duration for the design basis Orc. In addition, the licensee l

had a portable 500 gallon tank of fuel oil in standby that could be used to re-supply the

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alternate supply skid.

The alternate supply was installed, tested and declared available by 6:00 p.m. on October 24 This was prior to the expiration of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement at 5:58 a.m. on October 25.

The inspector identi6ed no inadequacies in the licensee actions to meet Technical

Speci6 cation 3.7.6.1. The alternate supply remained available and well controlled by the

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I licensee for the duration _of the outage on the permanent fire pump. Diesel fire pump P-5-1 A was successfully repaired and returned to service at 5:06 p.m. on October 27.

3.0 MAINTENANCE (61726,62703 and 71707)

3.1 Maintenance Observation The inspector observed various corrective and preventive maintenance activities for compliance with procedures and the plant technical speci6 cations. The inspector also s cri6ed appropriate quality services division (QSD) involvement, appropriate use of safety tags, proper equipment alignment and use of jumpers, adequate radiological and Dre prevention controls, appropriate personnel qualifications, and adequate post-maintenance testing. Portions of activities that were reviewed included:

AWO 93-11897, MS-SV-14 Flange Leakage

AWO 93-12998, Replace MS-SV-14 AWO 93-12678, SS-SOV-151D Dual Indication

AWO 93-13129. Wide Range Channel 3 Erratic Operation

AWO 93-13146, Wide Range Channel 3 Bargraph Display AWO 93-13165, 'D' Service Water Pump Noise / Repair

CMP 8.5-105, P-37-1 A, IB, IC, ID SW Pump Maintenance

AWO 93-12811, 'B' RHR Pump Seal Cooling Line Leak i

AWO 93-12205, 'A' PHR Pump Oil Leak

PMP 9.1-36, Ser ice Water Strainer Operation

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AWO 93-13487, Diesel Driven Fire Pump Overhaul CMP 8.5-189, P-5-1 A, Fire Pump Diesel Engine Head Installation

PMP 9.5-87, P-5-1 A, Diesel Driven Fire Pump Preventive Maintenance

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3.1.1 AWO 93-13129, Wide Range Channel 3 Erratic Operation The inspector reviewed activities under AWO 93-13146 and 93-13129 to repair and retest

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I wide range nuclear instrumentation channel #3. The channel was removed from service on l

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l October 12 to address an erratic display. The licensee determined that the 250 Vdc power supply in the drawer required replacement, along with the driver card for the display. The

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faulty components affected the non-safety related display portion of the channel, but not the trip functions. The components were replaced and the channel was returned to service on i

October 18.

The inspector reviewed Technical Speci6 cation 3.3.1 and noted that the wide range nuclear

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instrumentation system consists of four channels, and that the specifications require that at least 3 channels be operable for operation in Mode 2 through 5. Thus, no action statement l

was in effect for the time that channel #3 was not in service. No inadequacies were

identified.

I 3.1.2 AWO 93-12678, SS-SOV-151D Dual Indication i

The inspector reviewed activities under AWO 93-12678 to complete repairs to post accident

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sample system (PASS) valve SS-SOV-151D. This issue was also discussed in NRC Report

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50-213/93-17. The licensee determined that the valve closed upon demand, but that a j

problem with the reed switch in the solenoid operated valve caused a dual indication to

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occur. The faulty valve components were replaced with a spare. After the completion of repairs and a successful retest, the licensee exited the action statement for Technical Speci0 cation 3.6.3 on October 6,1993, since the valve was fully operable as a containment isolation valve. However, the redundant PASS sample path remained unavailable until October 12, when the inboard manual isolation valve was opened during a planned entry into the containment for routine surveillance activities at power. The PASS was operable during the interim period via the redundant sample supply and return paths. Valve SS-SOV-151D operated satisfactorily during a PASS sample taken on October 12. No inadequacies were identified.

3.1.3 AWO 93-11897, MS-SV-14 Flange leakage The licensee continued to monitor a minor body to bonnet steam leak from the flange area of main steam safety valve MS-SV-14 This was a new valve installed during the Cycle 17 refueling outage. Licensee evaluations determined that the main gasket in the body to bonnet flange was leak tight, and the leak was most likely due to a failure of a grafoil gasket in a

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port on the valve head that provides steam to the " unloader," which is part of the control

circuit in the pilot operated relief valve. NRC inspection of the previous CYAPCo activity regarding MS-SV-14 were discussed in Report 50-213/93-17

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Licensee engineering continued to assess the leak and its significance, and concluded that the f

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present leakage was small enough to not impact safe plant operation. See section 4.1 of this-l

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report for further discussion of the engineering evaluations. Plant management instructed operations to monitor valve conditions continually, as plans were made to bring the plant to

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hot shutdown. The shutdown was scheduled for November 18 as preparations to replace the l

present valve with a spare proceeded. The operators were instructed to begin a plant

shutdown immediately if any significant increase in leakage developed.

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The licensee sent the spare valve to a vendor test facility in Westfield, Massachusetts to test the valve for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> under simulated plant conditions. On October 28, the spare valve was

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damaged when the boiler test stand exploded. Initial inspections at the test facility determined that the valve sustained only minor damage. The licensee shipped the valve to

the vendor's (Andersen Greenwood) facilities in Texas for furtiier evaluation and repair.

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Licensee engineering personnel went to the vendor's facilities to evaluate the valve status and j

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rebuild activities. A report of the valve conditions will be presented to the plant operations review committee, which will evaluate de valve and its suitability for use. The licensec's i

activities in this area will be reviewed as part of the NRC review of routine plant operations j

and maintenance.

The inspector reviewed the condition of MS-SV-14 periodically during this inspection period.

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The inspector determined that the leak gradually increased, but otherwise remained minor and had no impact on any other component of the main steam system or adjacent plant equipment. The inspector concluded that continued operation with the minor leak did not impact plant or worker safety. The leakage remained stable through the end of the period.

Licensee actions to address MS-SV-14 will be followed as part of the routine NRC review of plant operations.

3.1.4 AWO 93-13165, 'D' Service Water Pump Repair During routine rounds on October 12, plant operators noted an unusual noise in the 'D'

service water (SW) pump. The pump continued in service with no abnormal changes in operating characteristics, such as flow rate and differential pressure. Maintenance and engineering personnel reviewed the status of the pump and participated in an operability determination. ISI engineering personnel monitored the pump vibrations and assisted in the review of pump operating characteristics. No abnormal vibration levels were noted and the operating characteristics remained within normal values. The noise produced a vibration that g

was not related to the rotational frequency. The pump vendor (Worthington) assisted in a

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review of the pump internals and assessment of the possible causes for the observed conditions.

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The engineering assessment and conclusions were summarized in a memorandum (ODM 93-159) dated October 13. The licensee concluded that the pump was operable, and remained available for unrestricted use. A possible cause of the noise was the inner shaft guide tube, which was postulated to have come loose from its point of attachment to the casing at the discharge end of the pump. Continued operation in this condition was deemed acceptable.

However, the licensee began an action plan to schedule a voluntary entry into the action statement for Technical Specification 3.7.3 to repair or replace the pump.

The noise was intermittent and appeared as a " thumping" sound that emanated from the discharge end in the upper pump column. The location of the noise shifted vertically along the column and its occurrence began to coincide with changes in river level caused by tidal effects. The noise gradually became more intermittent, and eventually ceased altogether by October 22. The licensee postulated that river debris had become trapped in the pump casing, and then finally passed through the pump.

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On October 31 at 10:30 p.m., operators noted an oily water mixture leaking from the pump shaft near the motor coupling. The pump was removed from service, and after further evaluation and in light of *'.c past history, the shift supervisor declared the pump inoperable at 10:45 p.m. With a single SW pump inoperable the associated SW header was declared inoperable (even though the 'C' SW pump was operating satisfactorily). The operators entered the action statement for TS 3.7.3 which allows for continued plant operation with one inoperable header for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Actions were initiated to replace the pump with a spare unit from plant stores.

Upon disassembly, the licensee found very little damage in any of the pump internals. Only one bearing on the bottom of the suction bowl was noticeably worn and stuck on the shaft (suction case bearing - part no. 41 on Worthington Drawing RW 11765). No damage was found in the shaft guide tube, the remaining bearings, or in the upper pump column. There was no debris either in the pump or in the strainer immediately downstream of the pump.

Four pressure equalizing ports located in the pump bowljust above the second stage were plugged with river debris (silt). The plugged ports caused a colunta of water to rise up the shaft guide tube and leak past the bearing housing in the upper section of the shaft. The pump was still adequately lubricated in the as-found condition. Based on a review of the mechanical condition of the pump, the licensee noted that the 'D' SW pump had many service hours left in the as-found condition.

Action was completed on November 3 to install and successfully retest the spare SW pump.

The pump was returned to service at 7:02 a.m. and the licensee exited the action statement for TS 3.7.3. The inspector determined that maintenance and engineering personnel performed very well during this period to assess the operability of the 'D' SW pump, and to

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assess the as-found conditions and causes for anomaleus operation. Maintenance personnel also performed well to return the pump and the associated SW header to an operable condition in a timely manner. No inadequacies were identified.

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3.1.5 A W O 93-13487, Diesel Driven Fire Pump Overhaul The licensee removed the diesel drive fire pump from service for routine preventive maintenance in accordance with AWO 93-13487 on October 18. The preventive maintenance work and replacement of a solenoid valve was completed on October 20. During the post maintenance test at 5:00 p.m. on October 20, the engine started acceptably and came up to operating speed, but engine coolant temperature rose to 200 degrees F in about 2 minutes.

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Maintenance and operations personnel quickly identified the abnormal temperature and immediately shut the engine down.

After further evaluation and with the assistance oflocal representatives of the Atlantic Detroit Diesel Allison Co., the licensee concluded on October 21 that the outboard piston had blown.

Actions were initiated to rebuild the engine on an expedited schedule. A replacement engine power pack assembly (consisting of the head, valves and valve lifters) was available in site stores. Vendor personnel assisted plant maintenance to replace the damaged piston and rebuild the power pack. The inspector reviewed the completed work and rebuilt engine on October 24. When the engine retest was attempted on October 25, the engine would crank but not turn over.

Licensee diagnostic review determined that the probable cause was a part internal to the power pack. The head assembly was disassembled again on October 25. The licensee found that the cam roller guide (6 pieces, one for each valve set) had been installed backwards.

The improperly installed guides allowed the valves to operate, but did not allow enough fuel to reach the cylinder to support combustion. The guides were improperly installed at the factory by the engine vendor prior to shipment of the power pack assembly to the site. The guides were reversed and the licensee included an instruction in the preventive maintenance procedure for the plant mechanics to check this part when assembling the head.

The licensee concluded that the manner in which the engine is tested contributed to the-engine failure. The test method provides for a fast start of the diesel and operation at rated load. The fast start is performed to meet fire protection code requirements. The licensee intends to review the requirements with the designated fire protection authority to determine whether the test method can be changed.

The diesel fire pump was successfully reassembled, retested and returned to service on October 27. The inspector determined that plant maintenance personnel performed very well to provide oversight of vendor representatives, to diagnose engine trouble and identify the cause for engine problems, and to complete the engine overhaul work in an expeditious The prompt action by the licensee allowed the timely return to service of plant manner.

equipment important to plant safety.

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3.2 Surveillance Observation

The inspector witnessed selected surveillance tests to determine whether: frequency and

action statement requirements were satisfied; necessary equipment tagging was performed;

test instrumentation was in calibration and properly used; testing was performed by qualified

personnel; and, test results satisGed acceptance criteria or were properly dispositioned.

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Portions of activities associated with the following procedures were reviewed-ST 11.7-128, PDCR 1339 Preoperational Testing

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ST 11.7-129, EDG 2A Heat Generation Test

ST 11.7-132, Underground Fuel Oil Supply and Return Leak Test

SUR 5.1-155B, Diesel Fire Pump (P-5-1 A) Monthly Test

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SUR 5.1-4, Emergency Core Cooling System Test

SUR 5.1-13A, Auxiliary Feed Pump (P-32-1 A) Functional Test l

SUR 5.1-23, Routine Control Rod Motion Check i

SUR 5.2-9, NI Analog Channel Operational Test

SUR 5.7-148B, Substantial Flow Test of A, B, C and D Service Water Pumps

SPL 10.1-37, installation, Testing and Use of a Temporary Fire Pump

3.2.1 SUR 5.1-13A, Auxiliary Feed Pump (P-32-1 A) Functional Test The inspector observed the performance of surveillance procedure SUR 5.1-13A on November 2. The surveillance objective was to operate the "A* Auxiliary Feedwater pump on recirculation to the demineralized water storage tank (DWST) for a length of time, and to verify that selected non-automatic valves in the flow path were in the correct position. The

inspector veri 6ed that installed instruments were properly calibrated, and the acceptance criteria were met to prove pump operability. The inspector observed the operator perform l

the post-surveillance valve line-up. No deficiencies were identified. The inspector noted that communications between the control room and the auxiliary feedwater pump room were concise and clear.

3.2.2 SUR 5.1-155B, Diesel Fire Pump (P-5-1 A) Monthly Test The inspector observed auxiliary operators test the diesel fire pump on October 27. The test was performed to prove operability of the pump following a major overhaul of the diesel engine. The system piping was filled and vented prior to the test. During the filling and venting, the inspector noted that a larger than normal section of discharge pipe was installed due to the installation of a temporary line from a temporary diesel fire pump. At procedure step 6.2.4, the operators reduced fire header pressure by opening valve FP-V-445, l

"Hypochloride Fire Protection System Test Connection Isolation." By design, the diesel fire pump should start prior to header pressure decreasing below 75 psig (Technical Specification 4.7.6.1.1.d.3). The diesel fire pump started at 70 psig. The operators called the control

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room to notify the shift supervisor that the diesel did not meet the acceptance criteria. The shift supervisor instructed the operators to realign the 6re system, and re-perform the

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surveillance. The shift supervisor concluded that the temporary line was not completely j

vented, and resulted in a larger than normal header pressure decrease when valve FP-V-445 l

was opened. The inspector noted that full consideration of the effect of the larger temporary l

Grc system piping on the surveillance were not taken into account for the first pump start.

j The operators vented the temporary pipe again and re-performed the start sequence of the l

diesel fire pump. The surveillance was successfully completed at 4:20 p.m. on October 27.

3.2.3 SUR 5.1-23, Routine Control Rod Motion Check l

l The inspector observed the performance of SUR 5.1-23 on November 3. The objective of the procedure is to satisfy technical speci6 cation surveillance requirement 4.1.3.1.2. The.

t surveillance requirement is to verify on a monthly basis that each control rod not fully

inserted into the core is demonstrated operable by movement of at least ten (10) steps. The i

inspector observed good adherence to the procedure by control room operators and good

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knowledge level of the assigned task. The control rods met the acceptance criteria and were j

demonstrated operable.

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3.2.4 SUR 5.7-148B, Substantial Flow Test of A, B, C and D Service Water Pumps j

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On November 2, the licensee performed SUR 5.7-148I1 to test the 'D' service water (SW)

pump. The test was performed following the replacement of the pump due to a failure of the

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seal between the inner shaft seal and the water column (see Section 3.1.4). CYAPCo successfully completed the surveillance at 1:40 a.m. on November 3, and declared the pump l

operable at 7:02 a.m.

The inspector verified that the licensee made the appropriate procedure and inservice test (IST) program changes based on the new pump hydraulic and vibration spectrum baseline

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readings. The changes involvea an increase in pump shutoff head from 238 feet to 254 feet, l

and a reduction in the " alert" and " required action" ranges for the upper motor bearing in the

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'Y' direction. The inspector reviewed temporary procedure change (TPC)93-780 to SUR j

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5.7-148B and IST program revision 93-027, and found them acceptable. The post main:enance retest for the 'D' SW pump was completed satisfactorily.

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i On November 8, at 3:25 p.m. the licensee declared the 'D' service water pump inoperable

during the scheduled quarterly IST (SUR 5.7-148A). The 'D' service water pump was _

l declared inoperable because the shutoff head reading was on the high end of the required action range. CYAPCo con 6rmed the reliability of the installed discharge pressure gauge, verified agreement in the motor amperes from the test on November 3, and re-veri 6ed the system line-up. No dc6ciencies were noted. CYAPCo considered the most probable cause for the high shutoff head was leak-by the pump discharge valve (SW-V-101D) during the

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baseline measurement on November 3. CYAPCo processed a TPC to revise the shutoff head to the increased valve and returned the pump to an operable status at 5:11 p.m. on November 8.1993. CYAPCo concluded that the baseline hydraulic and vibration measurements

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assure pump operability and to process the TPC were acceptable. The inspector concluded

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that the engineering justification to demonstrate pump operability was acceptable.

3.2.5 ST 11.7-128, PDCR 1339 Preoperational Testing ST 11.7-129, EDG 2A IIcal Generation Test

The inspector reviewed the results of the licensee tests completed under ST 11.7-128 to measure the ventilation flow rate in the diesel generator rooms. These tests were performed l

to address concerns previously identified (reference NRC Report 50-213/92-80) regarding the l

adequacy of the room ventilation flo v. The licensee had previously determined that the ~

i minimum flow rate needed from the room ventilation system was 36,000 cfm, which would j

supply 11,000 cfm needed for engine operation, and 25,000 cfm for room cooling. The i

recent testing with the modified damper showed the following room ventilation flow rates-f

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EDG-2A - 33,109 cfm; and, EDG-2B - 33,858 cfm. Based on the above, the licensee maintained the established administrative controis in effect to assure diesel operability. The

matter was referred to engineering for further review.

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Measurements were made under ST 11.7-129, "EDG 2 A Heat Generation Test," to verify

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the actual heat input into the room, and the temperature difference between outside air and

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combustion air with the diesel operating at full load. It was confirmed that the heat generation rate by the engine was less than design data, and that the actual values would

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support lower flow rates from the room ventilation system. Past calculation used a design i

value for the diesel heat rate of 6 BTU / min-BHP. The present testing and new calculations l

showed that the actual heat loads were approximately 3.5 to 3.8 BTU / min-BHP.

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For the actual heat input rate, the ventilation flow rate with the back draft dampers installed

was sufficient to support engine operation at full load, and with the south access door closed.

i Specifically, the licensee demonstrated that room temperatures would be acceptable (i.e., less j

the temperature used to qualify equipment in the room) for an outdoor ambient temperature i

as high as 82.5 degrees F. An interim limit on outside air temperature of 81 degrees F was

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established for emergency diesel operation with the doors closed. The licensee expects that -

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for the outdoor temperature limit will be restored to the design temperature limit for the site i

of 101 degrees F upon completion of additional QA calculations using the data from the i

September 20 test.

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Thus, a limit 81 degrees F was established on outside ambient temperature. With ambient temperature below 81 degrees F, the diesel room doors could be closed. If ambient

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temperature rose above 81 degrees F, the doors would be opened. The licensee revised j

procedure SUR 5.1-0, " Steady State Operational Surveillance," to reflect these limits, and to

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assure outside ambient temperatures were monitored at least once per shift basis (and more c,-

frequently as warranted).

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The inspector had no further questions at this time regarding licensee testing and control of the diesel room ventilation system. Good controls were observed for the heat addition test, i

and engineering personnel performed well to provide oversight of the activity. The

satisfactory completion of the emergency diesel heat rate and ventilation flow tests allowed

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the resolution of a long standing compensatory measure for the generators. Additional licensee actions regarding the temperature limits for diesel operation will be followed on

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subsequent routine inspections of plant operations.

'l 3.2.6 ST 11.7-132, Underground Fuel Oil Supply and Return Leak Test This test was performed on October 31 to verify the leak tightness of new piping that was installed as part of the modification of the 42,000 gallon diesel fuel oil storage tank. The inspector reviewed the hydrostatic test plan and verified that the test boundary was appropriate. The established acceptance criteria was that leakage would be limited to 0.05

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l gallons per hour at a pressure of 90 psi, which was 1.5 times the working pressure. The actual measured leakage was less that I cubic centimeter during the first half hour of the test.

This corresponded to a leak rate of 0.0005 gallons per hour. A small packing leak was

identified on fuel oil valve FO-V-lli, and fixed during the hydrostatic test. Thus, the actual l

system leakage was reduced to zero. The hydrostatic test was well controlled and executed, with good oversight by the system engineer. No inadequacies were identified.

3.2.7 SPL 10.137, installation, Testing and Use of a Temporary Fire Pump

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This test was performed on October 24 to verify the proper operation of the alternate system used to supply water to the fire water header during repair of the diesel driven fire water

pump. The inspector reviewed the test plan and the setup of the alternate fire water system.

  • The test method was satisfactory to verify that the alternate system was an acceptable substitute for the normal pump. The flow rate measures for the alternate system exceeded

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the minimum requirements. Additional details regarding the NRC review of this issue is provided in Section 2.5 of this report. The inspector determined that the operational test was well controlled, with good oversight by the fire protection engineer. No inadequacie; were.

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identified.

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4.0 ENGINEERING AND TECIINICAL SUPPORT (37828 and 71707)

i The inspector reviewed selected engineering activities. Particular attention was given to

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safety evaluations, plant operations review committee approval of modifications, procedural controls, post-modification testing, procedcres, operator training, and UFSAR and drawing revisions.

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4.1 Evaluation of MS-V-14 Status and Repair Options

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Site and project services engineering assisted site personnel in the ongoing monitoring of a l

minor body to bonnet steam leak in the flange area of main steam safety valve MS-SV-14.

j Plant management requested that engineering evaluate the feasibility of using furmanite as a j

repair option, and to assess the significance of the ongoing leakage.

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Licensee engineering assessed the leak and its significance, and provided the results of the f

evaluation in a memorandum to Operations dated October 25,1993. The leak created the

potential for the inadvertent actuation of the valve. The valve is held closed by maintaining j

a pressure balance across the pilot unloader. Steam pressure from the valve dome is

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balanced by pressure from the inlet sensing line, keeping the unloader in a closed position.

When main steam pressure reaches the set point pressure, the pilot valve actuates to vent pressure from the inlet sensing port of the unloader, causing the dome pressure to force the l

unloader open and the main valve to actuate. Excessive leakage could cause the valve to

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operate in the same way, if the pressure in the sensing line dropped :o 415 psig. Licenset engineering assessed the present valve conditions and determined that substantial leakage l

would be required to cause the pressure in the sensing line to decrease, and that the present l

leakage was small enough to keep the valve from inadvertently actuating. Engineering i

recommended that operations monitor the valve condition each shift. The inspector also

.j reviewed the engineering evaluation and the valve operating characteristics, and identified no

inadequacies in the licensee's conclusions.

l Site and Project Services engineering completed technical and safety evaluations during this period for the proposed leak sealing of main steam safety valve MS-SV-14. The inspector l

reviewed the evaluations and observed the meetings between site and engineering personnel l

to discuss th'.s topic. The inspector also reviewed the operating and design details of the -

l Andersen Greenwood power operated relief valve. Engineering concluded that the procedure

developed to leak seal the valve could be implemented safely and without creating an l

unreviewed safety question. The licensee decided against using the leak seal option in this

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case due to a concern that the risk of inadvertently causing the valve to operate was l

unacceptable. The licensee continued plans to shut the plant down for repair or replacement j

of the valve. No inadequacies were identi6cd in the engineering analyses.

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4.2 Onsite Storage of Diesel Fuel Oil

i The inspector reviewed the adequacy of the onsite storage capacity for fuel oil. The

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inspector selected this topic for review as part of an NRC initiative to assess site vulnerabili-ties to adverse weather and natural disasters. This area was first covered in NRC Report 50-

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213/93-12, and it was noted at that time that the Nuclear Safety Engineering (NSE) Group j

was evaluating site vulnerabilities in view of the lessons learned from Hurricane Andrew l

(reference NRC Information Notice 93-53). The results of the NSE evaluation and the

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associated recommendations were available during this inspection. This topic was a'so

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selected for review in light of the licensee plans and actions during this period to drain the i

non-QA fuel oil storage tank., as described in Section 4.3 below.

The onsite fuel oil storage and delivery system is described in Sections 8.3.1.1.5 and 9.5.4 of the Haddam Neck Updated Final Safety Analysis Report. Technical Specification 3.8.1.1 l

provides the associated limiting conditions for plant operation. The safety related portion of the fuel oil. storage and transfer system includes, for each emergency diesel generator, an (

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independent base mounted 550 gallon storage tank with sufficient capacity for two hours of operation, and an independent 5,000 gallon underground storage tank. Technical specification 3.8.1.1 requires that a minimum of 400 and 3,250 gallons of fuel oil be

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maintained in each tank, respectively. Separate and redundant fuel oil transfer pumps supply the engine mounted day tank from the underground storage tanks. The pumps are powered from the 480 volt emergency buses. The underground storage tanks are tornado and earthquake protected.

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Another design feature of the safety related fuel oil transfer system is that each fuel oil transfer pump normally takes suction from a specific diesel storage tank, but can supply I

either EDG day tank via a cross connect header containing a normally locked-closed isolation l

valve. Another design feature is that the 'B' EDG can supply electrical power to the ' A'

and 'B' fuel oil transfer pump (P-109 'A' and 'B'), while the 'A' EDG can supply power to i

only the 'A' pump. This allows the 'B' EDG to use fuel in either of the 5,000 gallon underground storage tanks, while the 'A' EDG can only use fuel in the 'A' underground tank. There is a non-QA oil storage tank on the site, but this was not credited in the CY l

design and licensing basis. Instead, the licensing basis assumes that the onsite tanks can be resupplied from offsite within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The plant non-QA storage tank (Tk33-1 A) has a capacity of 42,000 gallons and is located above ground on the South end of the site. This tank is normally used to supply oil to the

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EDG underground tanks, as well as to the plant heating boilers. The NRC reviewed the fuel j

oil storage system, including the use of Tk33-1 A during the Electrical Distribution System -

Functional inspection (EDSF1 Report 50-213/91-80). As documented in that report, CYAPCo is not committed to the requirements of Regulatory Guide 1.137, which states that a minimum of 7 days supply of fuel oil should be maintained on site. Licensee controls per l

SUR 5.1-0. " Steady State Operational Surveillance " maintains the tank at a level between 10.5 feet and 13.0 feet. A 7 day supply is assured with the tank level at 13.0 feet. The tank level is allowed to drop to 10.5 or 11 feet to accommodate the 7,500 gallon contents of a full oil truck Tank Tk33-1 A is neither tornado nor earthquake protected.

The licensee has instituted measures in its Abnormal Operating Procedures (AOP) to assure l-the continued availability of oil supply from the non-QA tank for the design basis flood conditions, in which the river elevation is assumed to reach +30 feet above.mean sea level.

(as compared to the site grade of 21 feet,6 inches). AOP 3.2-5, " Natural Disasters,"

Revision 12 dated March 4,1993, and AOP 3.2-24, " Flooding of the Connecticut River,"

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Revision 13 dated November 3,1993, contain several provisions regarding the onsite fuel oil capacities. The provisions include assuring onsite supplies are maximized by topping off the tanks well in advance of hurricane and floods; load testing the EDGs to assure standby readiness; and, early assessment of the access road and the prompt dispatch of crews to clear the road as necessary to assure the timely delivery of fuel oil and other emergency assis-t:mce.

The EDGs operate at a nominal full load of 2850 KW, and consume fuel oil at a rate varying from 205 gph to 209.3 gph, depending on the ambient temperature. NUSCO calculation 90-BOP-709-GM provides an analysis of the maximum running time for the EDGs for various initial levels in the storage tanks. The calculation results for an assumed 90 degrees F temperature are summarized below:

EDG ' A'

EDG'B'

Volume in Tk33-1 A for 7 days 31,300 gallons 27,650 gallons operation at full load Max run time, QA tank at level 22.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 42.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per Dood procedures Max run time QA tank at min 17.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> 33.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> TS level As can be seen from the above, if no credit is taken for the non-QA tank, and if the QA tanks are at the minimum level required by the technical specifications, and assuming a single active failure of the *B' EDG, the assured run time for EDG 'A' could be as low as

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17.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> under some postulated casualty scenarios. This observation formed the basis for i

the NSE concern in the draft NU Significant Operating Event Report (NUSOER), along with NSE recommendations that CYAPCo develop contingency plans to augment existing plans and procedures to assure the expedited delivery of fuel oil during natural disasters.

The results of the eealuation by NSE were provided in a draft NUSOER dated October 12, 1993 and forwarded to the site by memorandum NSE-93-137. The NUSOER made recom-mendations for actions to take to resupply the onsite diesel fuel on an expedited basis under emergency conditions. The NUSOER recommendations were reviewed by the Operations Manager and the Unit Director and accepted for implementation at Haddam Neck. The Unit Director used the controlled routing system to assign actions to the plant department heads to implement the actions. This was a good response to the draft NUSOER, since actions in response to NUSOERs is not required until after the NUSOER is issued under the signature of the Executive Vice President-Nuclear, which is not scheduled to occur before the end of 1993.

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The NSE recommended that the following actions be taken to assure that the site could be

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resupplied with fuel oil within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as intended by the plant design basis:

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Inspect the fuel oil delivery route immediately after a natural disaster and initiate

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immediate repair and cleaning of any debris to make the route passable to fuel trucks.

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The Director assigned this action to the Security department.

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(b)

Make pre-arrangements to assure a supply of diesel fuel to the CY site within a few l

hours of a loss of normal power and continuing for several days. The Director

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assigned this action item to the Operations department.

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Estabtish a contingency plan for resupplying the CY site should the access road (Injun

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Hollow Road) be impassable to truck trafEc. The Director assigned this action item to the Emergency Planning department.

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Establish a method to qualify a batch of diesel fuel at the supply source, so as to j

eliminate the repetitive and time consuming process of analyzing each delivery to the

CY site. The Director assigned this action item to the Chemistry department.

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The inspector also noted, based on discussions with engineering and operations personnel, j

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that two other factors might provide timely site assistance in the event of a natural disaster.

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A seldom used, but highly passable road approaching the site from the South might be used.

j as an alternate route if Injun Hollow Road is impassable. The inspector verified that fuel oil l

trucks, including those with capacities up to 7,500 gallons, could access the site from that

route. Secondly, the licensee has preferred access to equipment and fuel oil trucks from the Connecticut Light & Power Company, the affiliated electrical distribution company. The

inspector requested information from engineering to assess the capabilities of Tk-33-1 A to

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withstand the effects of natural disasters. This review was in progress at the end of the J

inspection.

In summary, the licensec took good initiatives in response to NRC Information Notice 93-53

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to evaluate potential site vulnerabilities in view of the lessons learned from Hurricane Andrew. Further, site personnel demonstrated a good regard for plant safety by initiating actions on an expedited basis to augment existing plans and procedures for assuring the prompt delivery of fuel oil, Licensee actions on these items were still in progress at the conclusion of the inspection.

This item is unresolved pending the completion of actions by the CY to address the NUSOER concerns and acceptance by NSE, and subsequent review by the NRC. Additional-ly, this item is open pending further inspector review of what evaluations (if any) that the licensee has completed regarding the onsite fuel oil storage and transfer system, such as in the study of site vulnerabilities due to flooding, tornados, wind loadings, etc., as part of the Haddam Neck Plant Probablistic Safety Study and the integrated Safety Assessment Program.

(UNR 50-213/93-19-02).

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4.3 Fuel Oil Storage Tanks Inspection The licensee planned and completed an outage of the above ground fuel oil storage tank (Tk33-1 A) during this period. The tank was taken out of service to drain the contents and inspect the tank bottom and internals. The tank outage also facilitated the completion of modincations to the berm that surrounded the tank., as well as the piping between the tank and the plant. The existing piping penetrated the berm. This configuration was modified to route the piping over the berm. The modifications were completed in accordance with plant design change record (PDCR) 1443. The inspections and modifications were performed to satisfy federal and state requirements for environmental protection. The inspections revealed -

some wall loss that required repairs to the tank bottom, as discussed below.

Tx33-1 A is a non-safety related tank with a capacity of 42,000 gallons, and is used to supply the safety related underground storage tanks for the onsite emergency diesel generators, and the plant heating boilers. Oil in the tank was drained to fuel oil trucks, and sold to offsite distributors. New oil was purchased to refill the tank. In recognition of the importance of this tank for long term operation of the EDGs (see Section 4.2 above), site engineering provided extensive support to plant operations and maintenance staffs to plan for the tank outage, and to develop contingency plans during the period the tank was out of service for repair. The contingency planning included consideration of the following:

Tk33-1 A is not credited in the technical specifications. The original plant design

basis concluded that the diesel underground tanks are sufficient to provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of diesel operation, and that an offsite source can be procured within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Existing contractual arrangements with the fuel oil supplier and delivery companies (per Purchase Order 010405 dated 2/8/93) were confirmed to be current, and that the supplier would provide priority coverage to CY as requested. The supplier re-conGrmed his contractual commitment to deliver oil upon request in less than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

Bypass jumper 93-0039 was prepared and implemented to provide a 7,500 gallon

tanker truck in standby to supply the emergency diesel generators. The tanker truck was parked next to the diesel generator building at the North end of the site. Supply lines were set up from the truck to the connection point to the normal supply piping for the underground tanks, just downstream of flow control valves FO-1700A and 1700B. Quick disconnect fittings were provided to connect the temporary lines to the j

permanent piping.

The plant heating boilers are a backup soerce of heat to maintain elevated temperature

in the boric acid mix tank and the supply lines to the chemical and volume control system. Bypass jumper 93-0040 was prepared to provide an exigent method to supply oil to the plant heating boilers while tank Tk33-1 A was empty. The bypass would be imp!cmented in the event the plant tripped during the tank outage. This jumper would use an additional 7,500 gallon tanker truck to provide fuel oil via temporary lines and

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quick disconnects to the fuel oil transfer pumps at line 2"-OFH-151-48. The licensee determined that actions would have to be taken within two days to restore plant heating steam before the temperature control of the boric acid system would be compromised. In addition to the alternate method of providing fuel to the boilers, the

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plant could be placed in cold shutdown within that time period.

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Prior to draining Tk33-1 A, the diesel tanks and portable tanks at the site were topped f

off. Tk33-1 A was drained over several days, as one tanker truck full at a time was removed. The second from the last truck full was used as the temporary supply for the EDGs. This provided a minimum of 7,500 gallons in Tk33-1 A with the tank still supplying the diesel header through the normal lineup, as the bypass jumper truck and temporary piping was set-up.

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Instructions to operate the temporary supply were provided to the operators, and one-

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time temporary procedure changes were made to several plant procedures to reflect

the interim configuration. Plant operators were briefed regarding the repair activities q

and the procedure changes.

In recognition of the importance to plant safety of the tank as a bulk supply, the plans

also included contingency actions to take in the event of adverse weather conditions.

Specifically, the operators were instructed to initiate contingency plans for resupply of

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oil in the event the abnormal operating procedures for natural disasters (AOP 3.2-5)

or flooding (AOP 3.2-24) were entered. The operators would order a minimum of four additional fuel oil trucks. Plant maintenance would be directed to restore the tank to operation. The objective of these actions would be to restore the Tk33-1 A inventory at least one day before the onset of river levels corresponding to the maximum probable flood, so as to assure EDG operation for the 166 hours0.00192 days <br />0.0461 hours <br />2.744709e-4 weeks <br />6.3163e-5 months <br /> that flood waters could be above grade level.

Plant maintenance prefabricated the piping sections needed to complete the piping

modifications, so as to minimize the number of field welds, and to expedite the field installations. Upon notification, maintenance would begin round-the-ck>ck installation activities. The licensee estimated that the tank could be made ready to receive oil within two work shifts of starting actions to expedite tank recovery.

The inspector reviewed the technical and safety evaluations prepared for the PDCR and bypass jumpers, and wimessed the licensee's discussions of the issues during the plant daily meetings and a meeting of the PORC on October 13. The Tk33-1 A outage started on October 18 when draining began. Bypass jumper 93-0039 was in effect on October 24. The inspector interviewed shift personnel and noted operators were aware of the tank status and the contingency actions. The shift supervisors stated that an order for fuel oil would be initiated immediately if the EDGs were started as a result of a loss of normal power. The

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inspector completed a walkdown of Bypass Jumper 93-0039 prior to implementation and l

periodically thereafter while it was in effect..No inadequacies were identified in the plans,-

procedures changes or contingency actions.

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The inspector also reviewed the repair plans and monitored the work activities to inspect the tank. The inspector observed the tank conditions when drained and noted the internals were l

in very good condition overall. There was no sludge or excessive sediment layer on the tank j

bottom. The licensee completed visual and ultrasonic examinations of the floor plates.

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Areas of pitting corrosion were identified and patch repairs were made in three locations to

assure minimum wall requirements were satisfied. The repairs adequately addressed the

level of degradation found during nondestructive testing. The licensee intends to evaluate i

more permanent repair options that will be implemented at a later date, j

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The tank was released for service on November 1 following the satisfactory completion of a j

hydrostatic test of the piping disturbed by the modifications. The tank was refilled and j

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returned to an operable status as activities to rebuild the berm continued through the end of j

the inspection period.

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In summary, the inspector determined that the licensee completed inspection and repair of the

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non-safety related fuel oil storage tank. in a m. mer that showed a high regard for its-

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importance to safety. Site engineering performed very well to provide detailed contingency l

planning, and to provide quality technical and engineering evaluations. Site engineering i

provided very good support to operations and maintenance to assure planning and j

implementation of work was completed in a timely manner.

5.0 PLANT SUPPORT (40500,71707,90712 and 92701)

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5.1 Radiological Controls l

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During routine inspections of the accessible plant areas, the inspector observed the imple-mentation of selected portions of the licensee's radiological controls program. Use and

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compliance with radiation work permits (RWPs) were reviewed to ensure that detailed l

descriptions of radiological conditions were provided and that personnel adhered to RWP i

requirements. The inspector observed controls of access to various radiologically controlled '

j areas and the use of personnel monitors and frisking methods upon exit from those areas.

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The inspector noted that posting and control of radiation areas, contaminated areas and hot spots, and labelling and control of containers holding radioactive materials were in

'I accordance with licensee procedures. The inspector determined that health physics technician

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control and monitoring of these activities were good.

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5.1.1 Review of Radworker Exposure Records

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The inspector reviewed the Northeast Utilities (NU) system for retaining radworker exposure l

- data. The inspection included discussions with training and health physics personnel at both -

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Millstone and Haddam Neck. The inspector reviewed the operation and use of the l

HELPORE system at Millstone and Haddam Neck sites. HELPORE is a computer based

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exposure tracking system used at both sites to maintain and trend worker exposures, and to

.l generate termination exposure reports. Although the HELPORE was not brought online until

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the 1980's, historical exposure data was included in the database.

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The inspector " tested" the HP record retrieval system at both Millstone and Haddam by

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requesting his own exposure records, along with the records for another radworker.

j Personnel at both Millstone and Haddam readily retrieved an electronic summary from l

HELPORE of the inspector's complete exposure history, going back to 1977 for a visit to

Millstone 2 and 1976 for a visit to Haddam Neck. This information was immediately l

available upon demand, and was also provided in hardcopy upon request. The licensee at j

both sites provided summaries of a radworker exposure and related records for a work detail at Haddam Neck in 1980. This included a hardcopy of the records retrieved from a microfiche file at the Haddam site. The hardcopy records were retrieved within an hour of the request.

j Based on this limited sample, it appears that the HELPORE system has information dating back to at least 1976, and that it works very well to provide historical exposure data upon

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demand. The inspector had no further questions on this matter.

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5.2 Plant Operations Review Committee j

The inspec tor attended several Plant Operations Review Committee (PORC) meetings. The-inspector verified that Technical Specification 6.5 requirements for required member attendance were met. The meeting agendas included procedural changes, proposed changes to the Technical Specifications, Plant Design Change Records, and minutes from previous meetings. PORC meetings were characterized by frank discussions and questioning of the proposed changes. Dissenting opinions were encouraged and resolved to the satisfaction of the committee prior to approval. The committee closely monitored and evaluated plant performance and conducted a thorough self-assessment of plant activities and programs.

PORC meeting 93-205 on October 6,1993 was held to review the technical and safety evaluations for the proposed leak sealing of main steam valve MS-SV-14. The deliberations included presentation by site and project services engineering personnel. Engineering personnel described the operating and design details of the Andersen Greenwood power.

operated relief valve. There was a thorough discussion of the engineering conclusion that the procedure developed to leak seal the valve could be implemented safely and without creating an unreviewed safety question. The PORC did not approve use of the leak sealing procedure i

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in this case due to the conclusion that the risk of inadvertently causing the valve to operate

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was unacceptable. The PORC demonstrated a thorough knowledge of plant design, accident-l analyses and licensing bases, and an excellent regard for plant safety in its deliberations.

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PORC meeting 93-213 on October 28,1993 was heid to review, in part, the temporary procedure changes necessitated by the use of the temporary fire pump during the period that i

the diesel driven pump was inoperable. The PORC also reviewed the test procedure to leak

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test the completed piping welds on the fuel oil storage tank. Finally, the PORC assessed the

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results of inspections of the tank conditions and repair options. The PORC performed well l

in these reviews, and provided a good discussion of the oil tank !eak acceptance criteria, j

showing a very good regard for leakage of oil into the environment.

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On November 2, the inspector observed the PORC discuss and approve revision 3 to l

surveillance procedure SUR 5.7-148B, " Substantial Flow Test of A, B, C and D Service j

Water Pumps." The procedure revision allowed testing in all operational modes without a i

signiGeant impact on service header operability. The PORC identified an improper system I

alignment in the procedure during testing of the 'D' service water pump with the traveling l

screenwash pump in service. The screenwash pump diverts flow from the 'D' service water l

pump, thus allowing incorrect flow measurement. The procedure author processed a _

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temporary procedure change to correct this vulnerability. The inspector noted that PORC l

discussions on the procedure safety evaluation were in-depth and complete.

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5.3 Review of Written Reports i

Periodic and Licensee Event Reports (LERs) were reviewed for clarity, validity, accuracy of the root cause and safety significance description, and adequacy of corrective action. The l

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inspectors determined whether further information was required. The 'nspectors also verified.

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that the reporting requirements of 10 CFR 50.73 and Technical Specification 6.9 had been i

m et. The following reports were reviewed:

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Reactor Containment Building Integrated Leakage Rate Test l

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I Monthly Operating Report for September 1993 l

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LER 93-04-01, Entry into Technical Specification 3.0.3 due to Inoperable Service Water Pumps i

This supplement to LER 93-04 was issued on October 13, 1993, to describe additional

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corrective actions for the event, and to clarify the conditions under which the test of the j

service water system could be performed. Speci0cally, the surveillance procedure SUR 5.7-l 148B was revised to state that the test would be done with the plant shutdown in Mode 5.

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However, the licensee intends to allow performance of the test in Modes 1 through 4, under

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controlled conditions, if necessary to satisfy retest requirements for corrective maintenance i

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activities. i ne inspector reviewed the licensee plans and noted that under suitable controls f

this action would not lessen plant safety, and thus would be acceptable. The inspector had

no further comments on this item.

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LER 93-16-00, Potential Inventory Diversion from the DWST

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This report was submitted on October 13, 1993, and described the results of an engineering j

analysis which identified a potential single failure vulnerability that could have resulted in the

diversion of water from the demineralized water storage tank (DWST) to the condenser i

hotwell at a rate greater than previously assumed. Thus, the function of the auxiliary l

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feedwater system (AFW) as defined in the bases of the technical specifications might have been compromised. The event was historical when identified in 1993, because after the

installation of the new condensate storage tank during the May 1993 refueling outage, the l

potential to divert DWST inventory was eliminated. The inspector reviewed the history for this event in detail, as described below. See Figure 1 (taken from LER 93-16) for a i

simplified description of the plant systems involved in this issue.

Backcround

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i The safety related DWST is used to supply water to the auxiliary feedwater pumps, which assure plant cooldown under certain postulated conditions. For example, the licensee credited the use of the AFW pumps and the DWST inventory to meet Appendix R safe shutdown requirements following a postulated tire. The DWST has a capacity of 100,000 l

gallons, of which 50,000 gallons is required by the design basis to supply the AFW pumps.

-l The technical specifications require that the DWST inventory be maintained above the

volume needed to assure safe shutdown. As part of the original plant design, the DWST was

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also connected to the condenser and was used to make up to the hotwell during normal l

operations. In 1989, the license prepared justification for continued operation OCO) 89-11 l

to address a plant design weakness in the interface between the DWST and the non-safety related condenser hotwell. The issue was reported in LER 89-02.

The DWST was connected to the hotwell via a 4 inch line containing valve AOV-CD-1317B

(or AOV-1317B), which failed closed by design in 1989 on loss of air. This valve operated as the condensate dump line to divert water from the condenser to the DWST on high level in the hotwell. The DWST was also connected to the condenser via an 8 inch line containing valve AOV-CD-1317A (or AOV-1317A). This valve operated automatically in response to a low level in the hotwell to supply water from the DWST to the hotwell. In the 1989 design, l

AOV-1317A failed open on loss of air.

The licensee recognized in 1989 that the DWST inventory could drain below the minimum l

TS level with a postulated single failure. Specifically, a failure in the station air supply l

would cause AOV-1317A to open and drain the DWST to the condenser at a rate of 3000 l

gallons per minute (gpm). Similarly, assuming a random failure of AOV-1317B to the open l

position, the DWST would drain at a rate of 416 ppm. Although credit could be taken to

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isolate the DWST from the condenser with 30 minutes, the DWST inventory would have I

drained below the 50,000 gallon inventory needed to assure safe shutdown for the assumed j

failure of AOV-1317A. The minimum required inventory would be preserved for the j

assumed failure of AOV-1317B.

j As described in LER 89-02 and JCO 89-11, compensatory actions were implemented at that time to mitigate the consequences of the identified failures. Specifically, a collar was added to AOV-1317A that limited the flow to the hotwell to 460 gpm. The DWST low level alarm

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and the technical specification minimum limits were raised to 70,000 gallons to assure the j

minimum required inventory was maintained as operators isolated the tank. Finally,

procedures were revised to describe the operator actions needed to isolate the DWST under

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conditions when the turbine building might be inaccessible. These changes were adequate to l

maintain the DWST volume needed to assure safe shutdown. The valve and procedure j

j changes completed the short term actions to address JCO 89-11.

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As long term action, CYAPCo initiated a plam design change to install a new condensate storage tank (CST). The non-safety related CST would provide the surge volume and the j

make up supply for the hotwell under normal operations, and thereby eliminate the normal j

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i hotwell interface with the DWST. The DWST is now isolated from the condensate system through locked closed manual valve CD-V-632. The CST was installed during operating l

Cycle 17 and was tied into the plant systems during the Cycle 17 refueling outage. The new l

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CST went into service on May 16, 1993. Also, to meet Appendix R requirements, the design of AOV-1317A was changed to fail closed on loss of air.

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New Single Failure Identified As part of an engineering review in 1993 associated with the original JCO and the CST, NUSCo Balance of Plant Systems Engineering identified a new failure mode for the level

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l control valves. This resulted in the initiation of reportability evaluation form (REF) 93-27 l

l on June 4,1993 to evaluate the consequences of the postulated event in the former plant l

l configuration when the DWST and hotwell interface still existed. The past engineering l

l analyses assumed that either AOV-1317A o_[ AOV-1317B would fail open during a loss of

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main feedwater event. The revised engineering analysis noted that if the controller failed i

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AOV-1317A to the open position, the increase in hotwell level would cause AOV-1317B to

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be open concunently, and if neither the condensate or feedwater pumps were in operation,

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the DWST could drain to the hotwell through the open supply valve (AOV-1317A) and via a

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somewhat circuitous path through the condensate and feedwater system via valves CD-TCV-l

1312 and FW-FCV-1311 A and B. The combined flow rate through both paths would be 886

ppm. The operator would have to isolate the DWST within 17 minutes to preserve the minimum required inventory under these conditions.

l The results of the engineering evaluation were documented in REF 93-27 on July 12, 1993.

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The reportability evaluation was forwarded to the CY site on July 14 with a recommendation j

i from Nuclear Licensing to report the issue under 10 CFR 50.72(b)(2)(iii)(B), as a condition j

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that could have prevented the fulfillment of a safety function to keep the plant in a safe shutdown condition. However, the Unit Director concluded on July 21,1993 that the issue was pat reportable, since the assumed failure mode was not an issue in the present plant configuration. Again, at the time of discovery, the CST modifications had been completed and the potential drain path could not affect the DWST. In support of this conclusion, plant -

management cited the reportability guidelines written by NU and used by the staff at the four operating plants for making reportability determinations. The guideline stipulated that plant -

deficiencies that were strictly historical in nature need not be reported under the cited 10 CFR 50,72 criteria. Thus, although actions were initiated to address the need for thorough engineering evaluations by the staff, no action was taken to report the issue.

Self-Assessment of the REF Process As a separate initiative, NU initiated a self-assessment of the REF process in 1993. The assessment was completed with personnel independent from the REF process and was

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performed at NUSCo on August 10-13, 1993. The assessment covered NU procedures NEO 2.25. the NUSCo reporting Guidance on 10 CFR 50.72 and 10 CFR 50.73, and Emergency Plan Implementing Procedure 4400, " Event Assessment, Classification and Reportability."

The assessment identified several program areas that warranted further evaluation, and noted several positive aspects of the program. A noted strength was the background engineering work performed for operability determinations. The reportability guideline document was noted to be a good initiative. Several recommendations were made to improve the REF process and the guideline document. Notable improvement included the need to complete more timely reportability and operability determinations to meet the intent of Generic Letter 91-18. One recommendation included the need to revise the guideline regarding the reportability of " historical" conditions. Specifically, the assessment identified the need to revise the reportability determination for REF 93-27 (and other REFs) at CY and Millstone.

It was further recommended that the file of completed REFs be reviewed to determine if any additional reports should be made to the NRC. The inspector noted that licensee actions to review and improve the reportability process were a good initiative. This area will be reviewed further on subsequent routine inspections to verify the other actions to address the recommendation from the a.;sessment (UNR 50-213/93-19-03).

The results of the self-assessment were provided by NU licensing in a memorandum to the CY Unit Director dated September 13.1993 (NL-93-490). By separate memorandum dated September 20 (NL-93-517), NU licensing also recommended that the DWST issue be reported. CYAPCo acted on the recommendation by initiating Plant Information Report (PIR)93-202, and by reporting the matter to the NRC Duty Office under 10 CFR 50.72(2)-

(b)(iii)(C) on September 20,1993. The licensee reported this issue to the NRC as licensee event report (LER) 93-16 dated October 13, 199 _ _ _

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NRC Findings Engineering analyses in 1993 identified a vulnerability which could have jeopardized the DWST inventory and the safety function of the auxiliary feedwater system under certain postulated events. While the 1993 evaluation was thorough and successful in identifying a previously unrecognized single failure vulnerabihty, it showed that the work done in 1989 was incomplete. Engineering Drawing 16103-26013 shows the feedwater and condensate systems and the interrelations with other plant systems on thirteen (13) separate sheets. The inspector had to create a composite view of the flow path from at least 5 of the associated sheets to reverify the flow path identified during the 1993 analysis. Thus, discovery of this.

issue was impeded by the complexity of the associated engineering drawings. Past NRC inspections reviewed the installation activities for the new CST. The inspector verified, during this inspection, that the plant was no longer susceptible to the vulnerability based on the present design configuration and the administrative controls for the DWST.

Plant operation prior to May 16,1993, during which time the auxiliary feedwater system and the associated water supply were susceptible to failure from a single component, was contrary to the licensing basis for the plant and the operability requirements for the DWST as stated in Technical Specifications 3.7.1.3. No violation will be issued since, in accordance with the NRC Enforcement Policy in Section Vll.B of 10 CFR 2, Appendix C, the violation was identified by the licensee; it was classi6ed as a Severity !cvel IV; it was not reasonably expected to have been prevented by the corrective actions from a previous violation; and, the licensee corrective actions taken or planned were appropriate (NCV 50-213/93-19-04).

Similarly, the plant vulnerability described above constituted a condition that was reportable to the NRC under 10 CFR 50.73(a)(2)(5)(B). A licensee event report (LER) was due to the NRC on August 14, 1993, or within the 30 days of the date on which a reportability recommendation was made to the Unit Director (July 14). The failure to submit a timely LER is contrary to the requirements of 10 CFR 50.73(d). No violation will be issued since, in accordance with the NRC Enforcement Polity in Section Vll.B of 10 CFR 2, Appendix C, the violation was identified by the licensee; it was classi6ed as a Severity level IV; it was not reasonably expected to have been prevented by the corrective actions from a previous violation; and, the licensee corrective actions taken or planned were appropriate and comprehensive (NCY 50-213/93-19-05).

In summary, the inspector also noted that licensee actions during this period were good to evaluate and report a historical condition regarding the potential diversion of water from the auxiliary feedwater system. Engineering evaluations in 1993 discovered a potential single failure vulnerability that was not discovered when this matter was first reviewed in 1989.

Further, this condition was reported late because of a weakness in the internal reportability guidelines. However, the reportability weakness was discovered as the result of a gcad initiative in 1993 to improve the process for evaluating deficiencies. Licensee action to

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improve the reportability process will be reviewed further. Licensee initiatives to improve

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engineering reviews of potential design deficiencies and to improve the reportability process

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l are encouraged.

5.4 l'itness For Duty Event i

The licensee notified the NRC Duty Officer 912:25 p.m. on October 18, of a significant

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i event that was reportable per 10 CFR 26.73. A random drug and alcohol test taken at 12:00 p.m. found that a CYAPCo non-licensed supervisor employee was not fit for duty. The -

individual's badge for access to the protected area was pulled and he was accompanied home following an interview by plant management. The individual had not worked in any vital

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plant area on that day. The licensee initiated actions in accordance with the Fitness For Duty l

Manual (FFDM) procedure 15, "Significant Events, Determinations, and Notifications," and FFDM 13.4, " Medical Review, Notification of Positive Test Results, Employee Assistance Program Referral," to followup the positive test result and to review the individual's safety-:

l related work activities. No inadequacies in completed work were identified. The inspector

identified..a inadequacies in the licensee actions to meet the requirements of the FFDM or

i 10 CFR Part 26. Licensee performance in this area was also reviewed in inspection 50-

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213/93-23.

6.0 EXIT MEET'AGS (30702)

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During this inspection, periodic meetings were held with station management to discuss inspection observations and findings. At the close of the inspection period, an exit meeting l

was held to summarize the conclusions of the inspection. No written material was given to

the licensee and no proprietary information related to this inspection was identified.

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in addition to the exit meetings for the resident inspection held on November 9 and 12,1993,

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the following meetings were held for inspections conducted by Region 1 based inspectors.

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19spection Reporting Areas

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l eport No Dates inspector Inspectrd l

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93-20 10/4 - 10/8 Bisset Operator Requalification Training Program l

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