IR 05000298/1997008

Insp Rept 50-298/97-08 on 970810-0920.No Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20198L475
Person / Time
Site:	Cooper
Issue date:	10/20/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198L474	List: IR 05000298/1997008 ML20198L472
References
50-298-97-08, 50-298-97-8, NUDOCS 9710270051
Download: ML20198L475 (20)

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, ENELQAMf1E i

U.S. NUCLEAR REGULATORY COMMISSION REGION IV - ,

i Docket No.: '50 298

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License No.:- DPRd6  !

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Report No.:: 50 298/97 08 Licensoo: '

Nebraska Public Power District - .

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Facility: - Cooper Nuclear Station

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P.O. Box 08 Brownvillo, Nebraska

- Dates: ' _ August 10 tnrough September 20,1997- i

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Inspectors:: Mary Miller, Senior Resident inspector Chris Skinner, Resident inspector ,

Approved By: Elmo Collins, Chief, Branch C_ 3 Division of Reactor Prr,jects _--

l ATTACHMENT: ' Supplemental Information

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EXECUTIVE SUMMAR Cooper Nuclear Station NRC Inspection Report 50-298/97-08 Operations

• Operations activities observed during this inspectial period were generally good (Section 01.1).

• Inspectors identified that the core power / flow graph posted on the main control board, used as an operator aid, was taken from the prior (superseded) revision of a procedure. A quality assurance audit of operations, including operator aids, also found poor control of operator aids. The audit did not review the operator aids used in the control room and, thus, was a missed opportunity for quality assurance to identify the out of date power-to-flow graph (Section 03.1).

• The inspectors identified a weak operability evaluation in which the licensee did not address all of the functions of a f ailed valve (Section O3.2).

• Initiatives resulted in an improvement in control room command anri control during the turnover process. The effort was initiated by a control room superviso (Section 04.1).

• Inspector attempts to review 26 open items in a 2-week period, found that 1 nem had been prepared satisfactorily for closure. The remaining items had not been assigned to staff for resolution or had not been completed. Quality assurance had noted the untimely resolution of NRC open items and Quality Assurance items in an earlier audit and in a Significant Condition Adverse to Quality (Section 08.1).

Maintenance

• The licensee's evaluation of a problem identification report was weak in that it did not establish the basis for the significance of a pressure spike before the pressure switch was returned to service. Also, no action was taken to determine the cause of the pressure spike (Section M2.1).

• Inspectors identified a weakness in that replacement of a fuse was not documented (Section M2.2).

Enoineerina

• Inspectors identified that licensee's controls f ailed to require an engineering evaluation of use of Teflon tape in applications where essential service or high radiation exposure equipment qualification was required. The interim actions to evaluate use of the tape during upcoming scheduled work were informal

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Evaluation of the concern did not include assessing past use of the tape, assessing

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how use of an unqualified material was authorized by procedure without an engineerin0 evaluation, or determining the extent of unevaluated consumable i materials in plant systems (Section E2,1).

_Pjant Synnpit j

• During an unannounced emergency response drill, the technical support conter director did not respond to the site within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period. Despite this concern, the technical support center resporise appeared to have been adequate based on performance of an interim qualified individual actin 0 as the technical support center director (Section P4.1),

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{Leport D_etails Summarv of Plant Slatus The plant operated at full power until August 18,1997, when reactor power was reduced to 99.6 percent due to feedwater pump oscillations. On September 6, power was reduced to 70 percent for monthly turbine valve testing and restored to 99.6 percent on September 7. Full power operation was restored on September 8, when a loose connection on the feedwater pump controller was identified as the cause of the feedwater pump oscillations. The plant remained at full power through the end of the inspection perio . Operations 01 Conduct of Operations 01.1 Ctenerally Aoorooriate Conduct Of Operations Inspection Scope (717071 Inspectors performed routine inspections of operations activities, including turnovers, control of clearances, control room actions to establish and .nonitor plant conditions, and operator tours. inspectors discussed observations with control room crew members and plant management, Observations and Findinas During the inspection period, inspectors conducted routine and backshift observations of control room crew activities. Inspectors observed that turnovers included appropriate information and crews focused on maintaining alert and questioning observation of plant conditions and plant activities. Alarm response procedures were referenced and followed. Logkeeping was thorough and addressed relevant plant conditions and indications. Briefings by the shift test engineers and operations management directed crews to be alert to broader safety issue Operations management evidenced strong presence and involvement in control room and plant activities. Operations managament raised concerns to the plant and engineering organization to resolve equipment problems in a more timely manner, Conclusions Operations activities during this inspection period were generally goo ._

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o-2-03 Operations Procedures and Documentation 03.1 Incorrect Revtqion of Core Power / Flow Granh Posted on Main Control Board

-- Inspection S. Lone (717071 Inspectors conducted a routine walkdown of control room control board Qblervations and Findinas On August 12,1997, during a routine control Loard walkdown, the inspector identified that the core power / flow graph posted on the main control board was the

, prior (superseded) revision to Procedure 2.1.10, " Station Power Changes," When this was pointed out, the control room crew promptly initiated Problem identification Report 2-23150. The superseded core pov.er/ flow graph was replaced with the correct revision and the affected procedure was properly annotated as an operator aid reference to alert operators during future revitions. The operators identified that Step 8.1.8.4.b of Procedure 2,0.9, " Control of Panel Labeling and Operator Aids,"

required this annotation, which had not been performed and which would have precluded this proble The safety significance of this finding is low since no changes were made to the core power / flow graph by the latest revision. However, failure to properly control operator aids was inappropriat In a recent quality assurance audit, findings were identified associated with poor

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control of operator aids. The findings identified uncontrolled operator aids such as instructions and labels marked by felt pen on structures and components in the field. A walkdown of the control room operator aids was not included in the audit scope, inspectors considered that this was a missed opportunity for quality assurance to identify the out of date power to flow grap The failure to properly implement the operator aids requirement in Procedure 2. is a violation of 10 CFR Part 50, Appendix B, Criterion V, which requires that procedures appropriate to the circumstances be implemented. This f ailure constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (50-298/97008-01). Conclusions inspe'ctors identified that the core power / flow graph posted on the main control board, used as an operator aid, was taken from the prior (superseded) revision of a procedure. A quality assurance audit of operations, including operator aids, also r

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-3-found poor control of operator aids. This audit did not review the operator aids used in the control room and, thus, was a missed opportunity for quality assurance to identify the out of-date power to flow grap .2 incomplete Operability Evaluation Inspection Scope (71707)

Inspectors performed routine reviews of operator logs and operability assessments, Qocrations and Findinns On August 29,19e nspectors reviewed the operability determination for Valve RR-AOV 741, one of two primary containment isolation valves on the reactor coolant sample piping associated with the reactor recirculation line. Inspectors identified that the operability determination had not addressed the postaccident sampling system function of that particular valve. Since the compensatory measure for a valve that does not perform its containment isolation function is to close its redundant valve, and the licensee had also closed the degraded valve, the inspectors questiened the availability of postaccident samples in this configuratio The shif t supervisor acknowledged that the postaccident sampling system function of that line had not been addressed and identified that procedures specified two additional sources of samples for postaccident reactor coolant sampling. Although this subject sample line was unavailable, two alternative methods of sampling remained. The operator then documented this information in the logs. This finding was minor. No violation of NRC requirements was noted. However, it was considered a weakness to have failed to document and address all the safety functions of that system in the operability evaluation, Conclusions The inspectors identified a weak operability evaluation in which the ,censee did not address all of the functions of the failed valv Operator Knowledge and Performance 04.1 Imorovement in Control Room Shift Crew Turnover Process Inspection Scope (71707)

The inspectors observed several crew turnovers after implementation of a revised control room turnover process.

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-4-F Observations and Findinng On September 13,1997, operations initiated a change in the control room turnover process. The former process consisted of each operator turning over information for_10 to-15 minutes with his relief in the control room and then leaving. This was followed by a 20 to 25-minute briefing of the entire oncoming crew on watch, by the shif t supervisor, also in the control room. The inspector observed the revised -

process on September 14. The offgoing shift supervisor briefed the oncoming crew in a meeting in a conference room outside the control room. After that meeting the oncoming crew performed a board walkdown in the control room led by the offgoing balance of-plant operator. The offgoing crew then conducted 5-minute individual turnovers with their reliefs while offgoing control room crew membert alternately maintained "at the controls" watch duties. Then the offgoing crew exited the control room, and a 5-minute summary briefing was conducted by the on oming shift supervisor to disseminate any new crew turnover informatio As a result of the revised process, the turnover within the control room was reduced from approximately 40 minutes to less than 20 minutes. Further, command and control was improved because more offgoing crew members remained at their positions during oncoming crew boari waQdowns. Another result was that the oncoming crew members took the watch at the same time, limiting the length of tin e that a mixed crew was in contro Interviews with control room operators indicated that a control room supervisor had facilitated this change with the endorsement of plant management ard that operators generally concluded that the new turnover process was an improvament in plant safety, Conclusigns initiatives resulted in an improvement in control room command and control during the turnover process. The effort was initiated by a control room superviso Miscellaneous Operations issues 08.1 Inspector Closure of NRC Open items Inspection Scoce (92901. 92902,92903. 92904)

Inspectors initiated ef forts to review several NRC open items, Observations and Findinns ,

From September 1-11,1997, inspectors attempted to review 26 NRC open items in L various areas, inspectors found that individuals assigned ownership of items were

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unaware of their responsibilities for these items, or had not pursued resolution on

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-5-those items for several months. Af ter several days of inquiry, docu:nontation of resolution and corrective action was provided to the inspectors for 15 of the 26 item An earlier quality assurance audit and significant concition adverse to quality had noted poor timeliness on several quality assurance issues and NRC open item During subsequent weeks licensee performence improvea in ownership and resolution of NRC open items, incomplete resolution of NRC open items was still evident. Some examples are documented in this inspection report, Conclusions inspector attempts to review 26 NRC open items in a 2 week period found that 1 item had been prepared satisfactorily for closure. The remaining items had not been assigned for resolution or had not been completed. Quality assurance had noted the untimely resolution of NRC open items and quality assurance items in an earlier audit and significant condition adverse to qualit .2 (Open) Violation 50-298/96026-01: No documentation for Technical Specification

- surveillance requirement. The violation involved two events in which Diesel Generator 2 was declared inoperable and completion of Technical Specification Surveillance Requirement 4.5.F.1, common cause failure evaluation of diesel gor.erators, was not documented. The inspectors concluded that the corrective actions described in the licensee's response letter dated May 2,1997, wem reasonabl The violation was issued because the licensee did not perform a common mode f ailure evaluation, and interviews with operations staff indicated conflicting basis for the conclusions of the evaluations. The licensee's response to the notice of violation stated that two common failure evaluations have since been performe The inspectors reviewed the evaluations. The second common mode failure evaluation stated that the operable diesel generator was run within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to e

the second f ailure and a visual examination of the f ailed component (motor operated potentiometer) on the operable diesel was performed. The evaluation stated that the f ailure was a random / age dependent failure. Inspectors considered that running the operable diesel generator and performing a visual inspection would not have identified whethcr the component was about to f ail or f ail the next time the diesel generator was run. Therefore, this evaluation did not substantiate that a common cause f ailure did not exis After inspector questioning on September 20,1997, the licensee stated but did not document that the component of concern on the operable diesel generator was newer and had less probability of a random / age dependent failure than the redundant component which had f aile . -- - _ _

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-6-This item remains open to evaluate the licensee's actions to adequately perform the second common modo failure evaluation and to review the licensee's procedures to implement this Technical Specification requiremen .3 (Closed) Licensee Event Report 50-298/97 003-00 and -01: Primary containment

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vent and purge system; simultaneous opening of inlet purge and outlet exhaust lines. On April 23,1997, the licensee identified that Procedure 2.2.60, Revision 55, " Primary Containment Cooling and Nitrogen inerting System," was not followed, which resulted in licensed operators opening both drywell and torus 24-inch inlet purge lines and outlet exhaust lines simultaneously. Technical Specification 3.7.A.2.b states that, when coolant temperature is above 212 F, the drywell and suppression chamber purge ar'd vent system may be in operation for up to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per calendar year with the supply and exhaust 24 inch isolation valves in one supply line and one exhaust line open for containment inerting, deinerting, or pressure control. Procedure 2.2.60, Step 8.3.2, required operations to ensure Technical Specification 3.7.A.2.b will be satisfieri before opening drywell and or

torus inlet and exhaust valves. All four lines (two inlet lines and two outlet lines)

were open from 4:41 p.m. to 9:04 p.m. on March 28,1997, and from 4:36 a.m. to 3:28 p.m. on March 29. From March 28 at 4:41 p.m. to March 29 at 6:28 p.m.,

the two inlet lines remained ope The inspectors verified that the licensee: (1) revised Procedure 2.2.60 for clarification that only one inlet and outlet line could be opened; (2) issued a night order clarifying Technical Specification 3.7 A.2.b; and (3) initiated a training work request to provide additional training on this subject for initial and requalification training for licensed operators. During the inspectors' review of he licensee's completed corrective actions, the inspectors identified that the training work request was implemented for requalification training only (not for initial training) and the night order initial sheet provided to the NRC for open item closure did not include all of the shift licensed operators initials to indicate that they had been informed of the concern. Based on the inspectors findings, the licensee issued a separate training request specifically for initial operating training and provided a completed night order verification initial sheet from a later date. The operators opening all four lines simultaneously from 4:41 p.m. to 9:04 p.m. on March 28, and from 4:36 a.m. to 3:28 p.m. on March 29, and having opened two inlet lines from 4:41 p.m. on March 28 to 6:28 p.m. on March 29,1997, is a violation of Technical Specification 3.7.A.2.b. This nonrepetitive licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50 298/97008-05).

08.4 (Onen) Violation 50-298/96031-01: Lack of appropriate procedures to assist

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mitigation of river surf ace slush buildup in circulating water bays. The control room did not have guidance in procedures to properly mitigate this slush buildup. The actions taken by operations were based on likely expectations of success by agitating the slush surface buildup with fire hose streams and other actions. Later information determined that this situation had occurred several years ago, but

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7-mitigating actions were not recorded in procedures to direct operators and that other infrequent situations had occurred which had not been recorded in procedure The inspectors verified that the specific procedure had been changed to include past guidance. The violation response dated March 31,1997, stated other actions to enhance procedures would be taken. In particular, information would be collected and made available to operators concerning other infrequent occurrences which were not currently documented in procedures, Although the licensee characterized '

collection of information as an enhancement, this addressed the root cause of the inadequate procedure,

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During this inspection period, inspectors followed up on actions to collect information from historical occurrences not documented in procedures. The computer database for collection of this information had been established during this inspection period; however, no data had been collected on the database since it was not yet accessible to plant employees. Information which had been collected in advance of the database installation by cognizant operators had been disseminaced only partially and informally to operators, This item remains open to follow the licensee's corrective actions on this violatio . Maintenance M1 Conduct of Maintenance M 1.1 General Comments Inspection Scone (62707)

The inspectors observed the following maintenance activities:

Minor maintenance concerning Problem Identification Report 2-17653, verify correct size fuses are installed in RMP-RM-452B, -C, and - Maintenance Work Request 97-0862 Replace Pressure Switch RHR PS 120B Maintenance Work Request 97-0864 Replace Pressure Switch RHR-PS-120D Maintenance Work Requent 97-0350 Replace Flange on Valve SW-V 660 In general, appropriate practices were implemented to set clearances, follow procedures, comply with radiation protection requirements, and perform postmaintenance testing and surveillance testing, Specific examples of inappropriate practices are documented in other sections of this repor _ . .

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_ M2 ; Maintenance and Material Condition of Facilities and Equipment

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. M2;11 Potential Over Ranae Conditions of Safetv-Related Pressure Switch .insoection Scone (617261 Tho' inspectors' reviewed the .icensee's actions associated with a pressure spike on a pressure switch and discussed this issue with maintenance technicians and maintenance management.-

- Observations cod Findinas ,

On ' August 7,1997, inspectors noted that,_when the automatic depressurization lo-

- 4 -lo set pressure switch,:NBI PS-51 A, was returned to service, a pressure spike was - 1 induced and tripped the switch. The licensee initiated Problem Identification Report 2-23308.- Inspectors observed that the licensee had not documented it if the switch had been over ranged. When questioned by the inspectors, the licensee noted that this pressure switch was not considered operable for other reasons and -

therefore the operability concern did not need to be addressed; The pressure switch was later returned to an operable status.without

. documentation of resolution of this concern. Later, the licensee did not provide the inspectors with the consequences and cause of the pressure spike despite severa'

requests;' Inspectors noted that, as of September 20, this concern had not been resolved. The licensee stated that weekly surveillances had indicated the pressure switch was operable. On October 2, the licensee informed inspectors that a temporary gage installed for the surveillance had indicated that the pressure switch had not been over ranged during the spike and, although the cause of the spike was not apparent, the licensee did not intend to investigate it's e,aus Co'nclusions The licensee's evaluation of a problem identification report was weak in that it did -

not establish a basis for the significance of a pressure spike before the pressure switch was returned to service. Also, no action was taken to determine theLcause

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M2.2 Failure to Document Fuse Installation ,

Inspection Scope (6270 A =

e l The inspectors observed minor maintenance that was performed to verify the correct size fuses'were installed in Reactor Building Radiation Monitors RMP-RM-

-4528,.-C, and--D.---The inspectors' observations were discussed with maintenance

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9 Observatiqns and Findinas On September 5,:1997, the licensee identified that Radiation Monitor RMP-RM 452A had incorrectly rated fuses installed. On September 8, the shift supervisor identified the need to verify that the correct fuses were installed in Radiation Monitors RMP RM 452B, -C, and -D and questioned the adequacy of an earlier fuso control audi On September'8, the licensee issued a minor maintenance document, Problem Identification Report'2-17653 to verify that the correct size fuses were installed in Radiation Monitors RMP-RM-4528, -C, and -D. While performing the minor

. maintenance, the maintenance technicians identified that one fuse was made by a different manufacturer, although of the correct rating. The maintenance technicians replaced that fuse for consistency. All of the fuses were determined to be the correct size. Later information indicated that the fuse from the different manufacturer was previously evaluated for this application; therefore, the fuse change was not required. The inspectors requested a copy of the evaluation, which has not yet been provide .During the review of the completed work document on September 6, the inspectors identified that the maintenance technicians did not document that the fuse was replaced. When questioned, the maintenance technicians steted that they intended

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to document the fuse replacement but forgot. Procedure 7.0.1.6, Revision 8,

" Maintenance Work Request - Minor Maintenance," Step 8.10.1, required that the performer complete the minor maintenance history index sheet by documenting all work performed. The licensee stated that docunientation of like for-like fuse replacement is a management expectatio On September 18, the inspectors questioned whether a problem identification report

'had boon issued for this failure to follow procedures. The licensee was unable to locate a problem identification report and one was issued on September 1 Procedure 0.5, Revision 11c2, " Problem identification and Resolution,"

4 Attachment 5, Step 1,17, stated that a problem identification report should be initiated when a failure to follow procedure is recognize The licensee's lack of documentation of the fuse replacernent, and the lack of initiation of a condition report, and inspector review of the evaluation that demonstrates that different manuf acturers fuses are interchangeable will be

followed by an inspector followup item 150 298/97008-02). Conclusions inspectors identified a weakness in that replacement of a fuse was not documente .

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-10 Ill. Enaineerino -

E2 Engineering Support of Facilities and Equipment E2.1 - Use of Teflon Tape Without Proper Ennineerina Evaluation inspection Scope (62707)

Inspectors reviewed engineering support of maintenance activitie Observations and Findinas inspectors observed that technicians had used Teflon tape on essential components and environmentally qualified instrument connections. Procedurn 1.8, " Warehouse issun, Return and Shipping," Revision 22c1, described Teflon ta?e as a nonsafety-related consumable. Procedure 14.0.6, " Instrument Tubing, Valve, Fitting and Thread Lubricant Guidelines", Revision 5.1c1, Step 8.13.3.1, states that thread lubricant ". . . Teflon tape may be used on test connections such as calibrating shop

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test gages with dead weight tester. Teflon tape should not be used on connections which come in contact with reactor system water or in connections which see temperatures > 250F."

Inspectors noted that the second sentence of Step 8.13.3.1 appeared to address test connections in context of the prior sentence, but was interpreted by maintenance and chemistry to allow use of Teflon tape in essential and environmentally qualified system permanent connections. Inspectors noted that later in the Procedure 14.0.6 listing of approved lubricants, use of consumables on essential and environmentally qualified equipment is specifically addressed, as in Step 8.13.3.4, which states "EGS Corpora". ion part number P 1 is an Environmentally Qualified approved Critical Use thread lubricant and may be used in Drywell and on all Environmentally Qualified and Essential instruments."

Inspectors noted over 18 Teflon tape connector installations on each train of reactor coolant levelindicator racks in contact with reactor coolant fluid. Inspectors questioned if the use of Teflon tapt in areas where high radiation exposure could be expected, for example environmentally qualification applications, had been properly evaluated. The licensee issued ' Problem identification Report 2-16137 on September 15, which stated that Teflon tape halogen generation on thread areas should be evaluated. Design engineering staff indicated a need to provide an equipment evaluation before Teflon tape could be used in these applications. Work on a pressure switch was postponed to resolve this issue.

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The operability evaluation associated with the problem identification report concluded that Teflon tape use was acceptable for uses on environmentally qualified and safety-related instrument lines in the residual heat removal system. This was

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11-based on a conclusion'that halogen production did not result in stress corrosion cracking since, although halogens would be generated, high temperatures would be brief. The inspector raised the concern that the evaluation did not address the chemical and structural degradation of the Teflon, which would be expected during high radiation exposure, and could result in connection leakage and foreign material generation of degraded Teflon tape in the post LOCA cooling system and instrumentatio The inspcctor noted that, as of September 26, the evaluation did not include an examination of the failure to require an engineering evaluation for a procedure change which had allowed use of unqualified material on essential and equipment qualified systems. Also, the interim corrective actions to preclude unanalyzed use of Teflon consisted of informal engineering communications with the chemistry and maintenance departments. No actions had been planned to assess the extent of past installation of Teflon tape. Further, no efforts were planned to address the potential need to dedicate or qualify nonsafety-related Teflon tape consumables as defined in Procedure 1.8 for essential use. As of the close of this inspection period, the licensee had not finished assessing this use of Teflon tapo. This issue will be followed by an unresolved item (50 298/97008-03). nclusions inspectors identified that licensee's controls f ailed to require an engineering evaluation of use of Teflon tape in applications where essential service or high radiation exposure equipment qualification was required. The interim actions to evaluate use of the tape during upcoming scheduled work were informa Evaluation of the concern did not assess past use of the tape, assess how use of an unqualified material was authorized by procedure without an engineering evaluation, or determine the extent of unevaluated consumable materials in plant system E8 Miscellaneous Engineering issues E (Open) Licensee Event Reoort 50-298/96-015: Potential for single active f ailure in reactor recirculation system. On October 25,19SS, the licensee identified that, due to an inadequate pressure rating for a common air regulator, the pressure rating for downstream nonsafety-related pressure regulators providing motive force for valves on the reactor coolant sample line could be exceeded. This could cause the two redundant pneumatic containment isolation valves to be exposed to a pressure greater than their rated pressur The cause of the high pressure would be failure of the common pressure regulator providing pneumatic control pressure. The nonsafety related regulators were replaced with safety related regulators, and a safety-related relief valve was removed from the line. The inspector questioned removal of the relief valve. At the close of the inspection period, the licensee had not resolved whether the relief valve was required in the line. This issue will be resolved during future inspector ac .vity.

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-12-E8,2 (Open) Insoector Followun item 50-298/96007 01: Reactor core isolation cooling suction relief valve leakage and design functions. Inspectors questioned why the-reactor core isolation cooling suction relief valse occasionally leaked and were informed it was expected and acceptable since the keep fill system pressure at that elevation was near the relief valve setpoint and since no design basis for the setpoint was availabl The licensee provided rehef valve sizing and design basis calculations to determine that the relief valve was correctly sized. in March 1997, inspectors asked why some of the system piping was not considered for relief valve sizing calculation The licensee concluded this issue should be addressed and noted that the safety significance was low since significant margin was available in the relief valve capacit The inspector and engineers discusssd post-loss-of-coolant accident leakage, relief valvo lif t potential, and the lack of a design basis for the setpoint. The setpoint was raised from 90 to 100 psig to address the leakage, reduce likelihood of spurious

- relief valve lift under normal or accident conditions, and be consistent with the high pressure coolant injection suction relief valve setpoint. The inspectors observed no leakage from the relief valve after the setpoint was change The inspector identified that the evaluation for the increased setpoint had not addressed the pressure margin above design basis loss of coolant accident conditions, and calculations did not consider the more conservative torus temperature of 160*F expected during station blackout conditions, rather than the design basis loss of coolant accident temperatures of 140 F. The design engineer had not considered these design functions which were less conservative than the calculation assumptions. These were resolved and the setpoint determined to still be within design margi During this inspection period, inspectors noted that a significant fraction of the piping in the room was still not considered for relief valve sizing calculations. The licensee stated that the issue would be addressed. Additionally, inspectors questioned the adequacy ( ~ the design basis for the high pressure coolant injection suction relief valve setpoint, since no design basis calculations could be locate The resolution of these concerns will be addressed in future inspection activitie _

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13-IV. Phodupnott P Staff Knowledge and Performance in EP P4.1 Eniture to Staf f the Yechnical Suonort Center With the Duts Resn.onders Within thq Heauired Time in30ection Scope 171750)

The inspector responded to and evaluated an unannounced emergency planning drill requirin0 the duty emergency response team to respond to the site and activate each of the emergency facilitie Qhaprvations and Findings On September 10,1997, an emergency plannino drill was conducted about 7 requiring response by all essential members of the emergency operations facility, technical support center, and operations support center. The purpose of the drill was to establish essential staffing of the emergency response facilities onsite and activate them in accordance with procedures Both the emergency operations facility and the operations support center were activated within the required one-hour timeframe. However, the technical support center was not activuted because its director was unable to respond within the required time. The emergency planning staf f continued the drill for the technical support center until a qualified alternate director arrived onsite and activated the technical support conter about 90 minutes later/ The licensee initiated a problem identification report to address this concer The failure of the technical support center emergency director to arrive onsite within the time limit is a concern. The licensee emergency procedures would have allowed the emergency director in the emergency operations f acility to have activated the technical support center without it's director. Therefore, by procedures, this issue would not have prevented an activation of the technical support center. In addition, the resident inspector observed technical support center activities. Although the technical support center director did not respond, another emergency responder not qualified in the technical support center director position, but qualified to fill the role as an inteam measure by the emer0ency director, provided appropriate technical support conter leadership and direction until properly relieved by a qualified directo The inspector assessed the technical support center security, radiation protection, engineering, and operations response as directed by the interim emergency director and found the' technical support center activities to have been capable of providing appropriate emergency response under emergency conditions, Failure to staff the technical support center with a qualified technical support center director in a timely mariner will be followed as an inspector followup item (50-298/97008 04).

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-14 c, Canglgiiong During an unannounced emergency responsu drill, the technical support contor director did not respond to the site within the one hour timo period. Despite this concern, the technical support contor responso appeared to have boon adequato based on performance of an interim qualified individual acting as the technical support contor directo S8 Miscellaneous Security and Safeguards issues S8.1 (ClgiqdLimpstnLfg!1gnup_llem 50 298.")7002-01: ovaluation of control of security plan in the control room. The licenson's security plan was located in the shif t supervisor's desk in the control room and appeared to be restricted from personnel who dK1 not have access to the control room. The intpector questioned if sofoguards material may be accessed by an individual without the nood to kno . The licensee initiated Prcblem identification Report 2 01090 to address the issue and immediately removed the security plan from the control room and placed it in the secondary alarm station in close proximity to the control room, lho licensco datormined the prior condition was in compliance with 10 CFR 73.21(d), because both the shif t supervisor and the control room supervisor were authorized to maintain control of the security plan. NUREG 0794, " Protection of Unclassified Safeguards Information," October 1981, Section 4.1, states, in part, that 10 CFR 73.21(d) requires that safeguards information be stored in a locked storage container when unattended and Section 4.2 states,in part, that Section 73 21(d) requires that safeguards information be under the control of an authorized individual while it is in use in order to limit access to persons who have a need to know. This requirement is satisfied if the materialis attended by bn authorized individual, even if the information is not constantly being use Based on the actions taken by the licenseo and the requirements of NUREG 0794, the inspectors concluded that the licensen was in compliance with 10 CFR 73.21(d).

F8 Miscellaneous Fire Protection issues F {CJgigdl Violation 50 298/97003 Ofl: f ailuto of fire watch to observe area. This violation involved the f ailure of the fire watch to maintain visual centact over the affected area. Inspectors identified this concern two different times for the same activity. Also, flammablo materialidentified by the licenseo during hot work was not removed from that area until af ter tho inspectors questioned why work continued for 30 minutos with the material not removed. The inspectors verified that the specific corrective actions for the fire watch program were completed as described in the licenson's responso letter dated June 11,199 l

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-15-NRC Inspection Report 50 298/97-03 documented that the correct;ve actions performed for the site-wide procedural adherence problerns were determined to be less than fully effective and concluded that licensee attention in the area of procedural use and adequacy was considered warranted. Procedural adherence throughout the licensee's organization has been a recurring problem and will be followed by inspector Followup item 50-298/97003 0 VI. LVlananement MeStions X1 Exit Meeting Summary J

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[ - ATTACHMENT-PARTIAL LIST OF PERSONS CONTACTED Licensee F. Diya, Design Engineering Manager R. Gardner, Operationn Manager M. Hale; Radiation Protection Manager B. Hannaford, issues Management Team Leader

' B. Houston, Licensing Manager S. Minahan, Work Control Manager B. Newell, Assistant to Maintenance Manager L. Newman, Operations Manager O. Olson, Plant Engineerino Manager J. Pelletier, Senior Engineering Manager J. Spencer, Engineering Programs Supervisor INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62703: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: Followup Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 92904: Followup Plant Support ITEMS OPENED, OPENED AND CLOSED, CLOSED, AND DISCUSSED Opened 50 298/97008-02 IFl Weak maintenance documentation and lack of an evaluation on interchangability of different fuse manuf actures (Sections M2.2).

50-298/97008 03 URI Failure to evaluate use of Teflon tape in essential and environmental qualified applications (Section E2.1).

-50-298/97008-04 I Failure to staff the technical support center in a timely manner (Section P4.1).

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s-2-Qpaned and Closed 50 298/97008 01 NCV Failure to properly implement operator aids as required by plant procedures (Section 03.1).

50 298/97008-05 NCV Simultaneous opening of drywell and torus inlet purge and outlet exhaust lines (08.3).

G91El 50 298/97002 05 IFl Evaluation of storage of security plan in the control room (Section S8.1).

50 298/97003 06 VIO Failure of fire watch to observe area (Section F8.1).

50 298/97 003 00 LER Simultaneous opening of drywell and torus inlet 50 298/97 003-01 purge and outlet exhaust lines (Section 08.3).

Discussed 50-298//96-015 LER Single f ailure in reactor recirculation system (Section E8.1).

50 298/96007-01 IFl Reactor core isolation cooling suction relief valve leakage and design functions (Section E8.2).

50 298/96031-01 VIO Inadequate procedures to mitigate slush buildup in circulating water bays (Section 08.4).

50 298/96020 01 VIO No documentation of Technical Specification surveillance performance (Section 08.2).

50 298/97003 04 IFl Procedural adherence problems (Section F8.1). _ _ _ _ _