IR 05000313/1998008
| ML20196G407 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/19/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20196G398 | List: |
| References | |
| 50-313-98-08, 50-313-98-8, 50-368-98-08, 50-368-98-8, NUDOCS 9812070330 | |
| Download: ML20196G407 (22) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV l
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Docket Nos.: ~ 50-313; 50-368 l i
License Nos.: DPR-51; NPF-6 Report No.: 50-313/98-08;50-368/98-08 i
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Licensee: Entergy Operations, In j Facility: Arkansas Nuclear One, Units 1 and 2
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Location: 1448 S. R. 333 Russellville, Arkansas 72801 ,
S qh mb e r 13 - Octobe r 24, 849% >
Dates: Mugust 2 through Ospiernber-12r4998-Inspectors: K. Kennedy, Senior Resident inspector S. Burton, Resident inspector ,
K. Weaver, Resident inspector !'
J. Hanna, Resident inspector P. Goldberg, Reactor Inspector :
P. Gage, Senior Reactor inspector !
Approved By: Charles S. Marschall, Chief Project Branch C l Division of Reactor Projects i
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ATTACHMENT: Supplemental Information I
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9812070330 981119 PDR O ADOCK 05000313 PDR
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EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report 50-313/98-08; 50-368/98-08 This routine announced inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6-week period of resident inspectio Operations i
Unit 1 operations personnel were very knowledgeable of the system piping l configuration, containment penetration operability conditions, licensee commitments, and Technical Specification (TS) requirernents for Containment Penetration 40 isolation and firewater reactor building isolations valves (Section O1.2).
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Unit 2 operations took appropriate actions for operability, monitoring, and repair of plant protection system instrumentation that momentarily spiked low on two occasions !
(Section 01.3).
Unit 1 control room operators communicated well with auxiliary operators in the field during a Feedwater Heater E1 A level transient. Additionally, operations personnel i demonstrated conservative decision making when they reduced reactor power during l the transient (Section 01.4). l Maintenance
Calibration and troubleshooting of Unit 2 shutdown cooling and low pressure safety injection flow instrumentation was performed by knowledgeable technicians using appropriate procedures. Technicians demonstrated good system and theoretical knowledge, questioning attitude, peer checking, and housekeeping practices on multiple occasions during surveillance and repair activities (Section M1.3).
Unit 2 maintenance personnel transferred the dry fuel storage cask from the rail car to the independent spent fuel storage installation in accordance with approved procedures and radiation work permits. Licensee personnel observed safety precautions and properly contro!Ied observers during the movement of the cask. Supervisory involvement was observed during the evolution (Section M1.4).
- Due to proceduralinadequacies and a lack of expectations for the use of peer-checking and self-checking for maintenance technicians, Unit 1 instrumeat and control technicians inadvertently actuated emergency feedwater Train B while performing surveillance activities, and a noncited violation was issued (Section M4.1).
Plant Support
- During the performance of radiation surveys on a newly loaded dry fuel storage cask, health physics technicians demonstrated good ALARA practices and were
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knowledgeable of requirements contained in the Certificate of Compliance. Minor discrepancies were identified with the radiation surveys performed and postings !
associated with the loaded cask (Section R1.1). ,
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- The reliability of the Units 1 and 2 postaccident sampling systems has been poor due to problems with system hardware, detectors, and the system computer. The licensee closely monitored the availability and reliability of the systems and has been very .
responsive to correct emergent issues. The licensee's plans to upgrade the system I computer and evaluate long-term system improvements were reasonable (Section R2.1).
- The failure to incorporate appropriate requirements and acceptance limits as specified
, by applicable design documents to demonstrate that Unit 1/ Unit 2 Diesel Engine Fire Pump P-6B would perform satisfactorily while in service was identified as a violation of TS 6.e.1 (Section F1.2).
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Report Details
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f Summary of Plant Status Unit 1 began the inspection period at 100 percent power and remained at 100 percent throughout with the following exceptions. On October 8,1998, power was reduced to 98 percent for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to troubleshoot level control valve problems associated with High Pressure Feedwater Heater E1 A. Power was reduced to 85 percent on October 9 for approximately 10.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to perform turbine valve testing and repair Feedwater Heater E1 A "
level control valve. Power was reduced for 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on October 12 to swap condensate pump Unit 2 began the inspection period at 100 percent power and remained at 100 percent throughout with one exception. On October 3, power was reduced to 99 percent for 40 minutes to perform moderator temperature coefficient testin . Operations 01 Conduct of Operations O General Comments (71707)
The inspectors observed various aspects of plant operations, including compliance with TSs, conformance with plant procedures and the safety analysis report, shift manning, communications, management oversight, proper system configuration and configuration control, housekeeping, and operator performance during routine plant operations and the conduct of surveillance !
The conduct of operations was professional and safety conscious. Included in these observations was a tour with an outside auxiliary operator on October 7, which was well performed. The operator demonstrated a good working knowledge of the equipment ant' procedures. Audited safety-related tagouts were properly prepared, authorized, hung, and cleared properly. A general walkdown of the low pressure safety injection (LPSI) system indicated that it was properly aligned both mechanically and electrically. A portion of the containment isolation system line-up was verified in accordance with the licensee's Procedure 1015.034, Revision 4, " Containment
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Penetration Administrative Control," and no discrepancies were observed. Specific events and other noteworthy observations are detailed in the following report section O1.2 t; nit 1 - Inoperable Firewater to Reactor Buildina Isolation Vaive Inspection Scope (71707)
The inspectors reviewed the TS requirements and licensee commitments, interviewed operators, and reviewed requirements for inboard firewater to Reactor Building isolation i
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Valve CV-561 l l
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b, Observations and Findinos
! On October 6,1998, while performing Procedure 1305.007. Revision 27, " Reactor l Building Iso'ation and Miscellaneous Valve Stroke Test," inboard tirewater to Reactor i Building isolation Valve CV-5612 was declared inoperable when the associated power l supply breaker thermal overloads tripped as the valve was cycled. Subsequent to the failure of Valve CV-5612, Outboard Firewater to Reactor Building Isolation Valve CV-5611 was tested and left in the closed position. This satisfied TS 3.6.6, which essentially states that, while the . reactor is critical, if a reactor building isolation valve is j determined to be inoperable in a position other than the closed position, the other reactor building isolation valve in the line shall be tested to ensure operability and, if the inoperable valve is not restored, the reactor shall be shut down or the operable valve closed.
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Subsequently, the inspectors noted that an operator information placard for Valve CV-5612 and the associated penetration stated that Reactor Building Penetration 40 was required to be drained when not in use (above cold shutdown) to preclude potential overstressing of piping after a loss of coolant accident. The inspectors discussed the impact of the inoperable valve on this requirement with operations personnel and reviewed Procedures 1305.007 and 1104.032, Revision 51,
Fire Protection Systems," and system isomeric drawings. The inspectors validated the operations personnel assessment which, indicated that the piping configuration in the penetration and procedural restrictions ensured that this requirement would not be ,
compromised while configured in this manner or during performance of stroke testing of '
the operable isolation valv Conclusions Unit 1 operations personnel were very knowledgeable of the system piping configuration, containment penetration operability conditions, licensee commitments, and TS requirements for Containment Penetration 40 isolation and firewater reactor building isolations valve .3 Unit 2 - Plant Protection System (PPS) Channel B Failure Inspection Scope (71707)
'nspectors reviewed the operability and corrective actions asso ciated with two momentary failures of PPS Channel B, Steam Generator 2, pressure indicatio Observations and Findinos On September 24 and October 7,1998, PPS Channel B experienced intermittent low pressure indication associated with Pressure Transmitter 2PT-1041-2. On both occasions, operators declared PPS Channel B inoperable and instrument j and control (l&C) technicians were dispatched to investigate the momentary low l pressure spike. The inspectors did not ioentify any safety concems associated with the !
j licensee's operability determination and the channers return to service for the
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i September 24 event. Continued operability for the first occurrence was based upon the l l fact that the failure was a momentary isolated occurrence and that no malfunctioning ;
i - components could be attributed as the source of the spike. When the condition j i repeated on October 7, the inspectors observed l&C technicians troubleshoot and j
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perform corrective actions for the affected instrumentation. Although maintenance l
} inspections on both occasions could not attribute the low pressure spike to any j
- malfunctioning components, after the second occurrence technicians replaced or ;
l exchanged multiple components to eliminate the most probable causes of the spike !
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1 Conclusions ;
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< c i Unit 2 operations took appropriate actions for operability, monitoring, and repair of PPS i i instrumentation that momentarily spiked low on two occasion l
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01.4 Unit 1 - Feedwater Heater E1 A Level Transient ;
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[ Inspection Scope (93702) !
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Feedwater Heater E1 A and monitored associated activities in the control roo Observations and Findinas i 1 l I
On October 8 at 5:55 a.m., control room operators received a high level alarm on Feedwater Heater E1 A, which was determined to be the result of the Normal Level Control Valve CV-3026 sticking. During the initial occurrence, the valve broke free and heater level stabilized. Subsequently, the valve malfunctioned a second time and operators took manual control at the local controller of Valve CV-3026. Auxiliary operators were dispatched to take local control of the valve; one was stationed at the valve in the field and the second operator was dispis hed to the valve controller which was located remotely from the valve. The inspectors noted that control room operators made the conservative decision to reduce power to 98 percent until the Feedwater Heater E1 A level could be stabilized, Control room operators communicated well with auxiliary operators in the field. Operations subsequently stabilized feedwater heater level and power was restored to 100 percent at approximately 12:38 Conclusions l Unit 1 control room operators communicated well with auxiliary operators in the field during a Feedwater Heater E1 A level transient. Additionally, operations personnel demonstrated conservative decision making when they reduced reactor power during the transien I
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08 Miscellaneous Operations issues (92700 and 92901)
08.1 (Closed) Violation 50-313/9806-01: 50-368/9806-01: Failure to Meet Technical Specification Minimum Shift Mannina Reauirements. Administrative controls allowed for crediting non-TS watch stations for maintaining watch standing proficiency. This resulted in utilizing inactive license holders for shift manning. The inspectors verified the immediate and long-term corrective actions described in Licensee Event Report (LER) 50-313/98-003 dated August 17,1998, and found them to be adequate and complet .2 (Closed) LER 50-313/98-003: Active Status of Licensed Operators Not Maintained Due
,tg a Misinterpretation of Reaulations. The inspectors verified the immediate and long-term corrective actions described in the licensee's letter dated August 17,1998, and found them to be adequate and complete (Violation 50-313/9806-01; 50-368/9806-01).
08.3 (Closed) Unresolved Item (URI) 50-313/9718-01: 50-368/9718-01: Conseauences for Failina to Write Condition Reports for Emeraency Liahtina Deficiencies. Emergency lighting system deficiencies identified during surveillance and preventive maintenance activities were being corrected by means of job orders (JOs) and were not documented by condition reports (CRs). The licensee issued CR C-1997-0313 to document the failure to write CRs on emergency lighting deficiencies. The inspectors determined that CRs were wntten for the deficiencies, as a result of CR C-1997-0313, and necessary operability evaluations and compensatory actions were performe Licensee personnel added the emergency lighting system to the scope of their maintenance rule program on April 15,1997. The inspectors found that the emergency lighting system did not represent a programmatic concern in that the licensee implemented adequate corrective actions to include this system within the scope of the maintenance rum. The failure to include the emergency lighting system was a violation of the requirements of 10 CFR 50.65(b). This licensee-identified and corrected violation (50-313/9801-02; 50-368/9801-02) was treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic . .
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5-11. Maintenance M1 Conduct of Maintenance M1.1 General Comments Inspection Scope (62707) l
l The inspectors observed all or portions of the following maintenance activities:
. Unit 1 - JO 00967511 and Procedure 1416.404," Unit 1 Cubicle A404 ,
Switchgear," pedormed on September 3 !
. Unit 2 - Procedure 2104.029, Revision 47, " Service Water System Operations,"
perfonned on October 15,199 Observations and Findinas The inspectors found the work performed in these activities to be professional and ,
thorough. Work was performed according to procedures and the workers were l knowledgeable of their assigned tasks. Maintenance supervisory involvement was observed on these activitie M1.2 General Comments on Surveillance Activities Inspection Scoce (61726)
The inspectors observed all or portions of the following surveillance activities:
. Unit 1 - Procedure 1107.001, Revision 54, * Electrical System Operations,"
performed on September 2 . Unit 2 - Procedure 2304.257, Revision 4, " Unit 2 Personnel Airlock Leak Rate Test," performed on October 1 j Observations and Findinas
The inspectors ic, nd these surveillance activities to be professonal and thoroug j Operators performed according to procedures and were knowledgeable of their !
assigned tasks. As applicable, briefs prior to the surveillances were held and operations !
supervisory involvement was observed on these activitie i l
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6-M1.3 Unit 2 - Shutdown Coolina and LPSI System 18-Month Calibration Inspection Scope (61726)
The inspectors observed portions of the 18-month shutdown cooling and LPSI flow calibration conducted per JO 0098263 Observations and Findinas
On September 22, the licensee calibrated instrumentation per Procedure 2304.010, Revision 9," Shutdown Cooling and LPSI Flow," and Procedure 2404.027, Revision 2,
"Fischer and Porter Microprocessor Controller Setup."
The technicians showed good knowledge of the system and related calibration procedures. Based upon their knowledge of a relevant, previously issued CR, the technicians issued a procedure change request to improve the procedure to delete procedure steps that unnecessarily downloaded software into the controller, which currently contained the same revision of the program. The deletion of the procedural steps did not result in the installation of outdated softwar The technicians demonstrated a good questioning attitude when determining the proper terminals for attaching test equipment. Conscientious housekeeping practices were observed when technicians restored the work location after maintenanc Technicians calibrated individual components and noted no deficiencies. However, when performing the final string check which ensures that all of the channel components interact correctly, an out-of-tolerance condition was noted. Technicians discussed the condition with maintenance and operations supervision and initiated a troubleshooting plan. The inspectors reviewed Form 1025.0098, Revision 12. " List of Equipment Fount Out of Tolerance," and discussed system operability with operations and maintenance j supervision. Due to the small deviation from the allowed tolerance, the licensee determined that the instrumentation remained operable and that the impact on flow indication was minor. Although the operability determination was reasonable, the inspectors noted that maintenance supervision did not document the basis for the operability assessment on Form 1025.009 Technicians demonstrated good theoret; cal knowledge and a strong questioning attitude wLen developing the troubleshooting plan for the out-of-tolerarce condition. During the troubleshooting planning, the technicians concluded that some values in the procedure were too restrictive. Engineers reviewed and concurred with the technicians conclusions and a procedure change form was initiated. Technicians identified and repaired faulty connections associated with a resistor in the instrumentation, wtdch was the cause of the out-of-tolerance conditions, completed required string checks, and returned the instrumentation to servic . -
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l L-7-l Conclusions Calibration and troubleshooting of Unit 2 shutdown coolincj and LPSI flow instrumentation was performed by knowledgeable technicians using appropriate procedures. Technicians demonstrated good system and theoretical knowledge, questioning attitude, peer checking, and housekeeping practices on multiple occasions during surveillance and repair activitie M1.4 Unit 2 - Movement of Drv Fuel Storaae Cask to the indeoendent Soent Fuel Storaae Installation Inspection Scope (62707)
The inspectors observed the transfer of the dry fuel storage cask from the rail car to the independent spent fuel storage installation on September 2 Observations and Findinas l Maintenance technicians transferred the storage cask from the rail car to the independent spent fuel storage instal.ation using Procedure 1302.025, Revision 9,
"Spei t Fuel Removal and Dry Storage Operations," and Procedure 1402.230, Revision 6,"VCC Hydraulic Jacking and Rail Car Operations." All tasks were accomplished according to procedure. The inspectors noted that licensee personnel observed proper safety precautions for the movement of heavy loads. Personnel were logged on to the appropriate radiation work permit and radiation protection technicians were present monitoring activities. Maintenance and radiation protection technicians l
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ensured that observers not logged on to the radiation work permit or directly involved with activities stayed clear of the area. Supervision was present during the movement of the cas Conclusions Unit 2 maintenance personnel transferred the dry fuel storage cask from the rail car to the independent spent fuel storage installation in accordance with approved procedures and radiation work permits. Licensee personnel observed safety precautions and properly controlled observers during the movement of the cask. Supervisory involvement was observed during the evolutio . _ - . - . . . - . - . - - - - - - . - . - - . . - . _ . - - -
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8-M4 Maintenance Staff Knowledge and Performance M4.1 Unit 1 - Emeroency Feedwater (EFW) Initiation Durina Emeraency Feedwater Initiation and Control (EFIC) Monthly Testina
! Inspection Scoce (92700)
On September 23,1998, the licensee inadvertently actuated EFW Train B during monthly surveillance testing of the EFIC system. The inspectors reviewed the details i associated with the event, historical similarities with previous occurrences, and the licensee's report Observations and Findinas On September 23,1998, EFW Train B inadvertently actuated while l&C technicians were performing Procedure 1304.206, Revisien 3,"EFIC Channel B Monthly Test." At the time of the actuation, Step 8.3.6.K of Procedure 1304.206 stated " Reset the EFW Trip Modules in Channels A & B." The technician performing the steps repeated back the instruction to the lead technician and then moved his hand to the Channel B EFW trip module and depressed the Trip 1 button before the lead technician could stop hi The intended action was for the technician to push the toggle switch on the trip modul Depressing the Trip 1 button satisfied the trip module actuation logic, actuating EFW i Train B. Because the steam generators were at normallevels and pressure, no EFW was injected. The EFW pump was immediately secured, the trip modules were reset, and EFIC and EFW were returned to their normal configuration. The licensee reported this event in accordance with 10 CFR 50.72(b)(2)(ii). The inspectors examined this report and concluded that it was complete and accurat The licensee determined that the root cause of the event was that the l&C technician failed to perform self-checking and peer-checking prior to perfonning the inappropriate action. The licensee identified two contributing causes involving a lack of specific instructions in the procedure on how to reset the trip modules and a lack of clear expectations for the use of three-part communications and peer-checking by l&C technicians. Following the event, the licensee performed the following immediate corrective actions: the procedure was stopped and the EFW system returned to normal, the l&C superintendent met with involved technicians to determine if additional co rective actions were necessary, the event and expectations concerning three-part coinmunications and peer-checking were disc ssed with the Unit 1 I&C shop, and prejob briefings on performance of EFIC procedures were held. Long-term corrective actions included: developing a summary of lessons learned, evaluating the requirements for reseting the trip logic at the operator control panel, developing a maintenance directive for the expected use of three-part communications and peer-checking, and reviewing other safety-related procedures for vulnerabilities. The inspectors noted that the corrective action to develop a maintenance directive for the expected use of peer-checking had already been identified as an action resulting from a 1996 CR but had not yet been complete !
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The failure to nilow this procedure is a violation of TS 6.8.1. The inspectors reviewed the licensee's co rective actions identified in the LER and found them to be appropriate and adequate. T1is licensee-identified and corrected, nonrepetitive violation is being treated as a noncited violation, consistent with Section Vll. B.1 of the NRC Enforcement Policy (50-313/9808-01).
c. Conclusions Due to proceduralinadequacies and a lack of expectations for the use of peer-checking and self-checking for maintenance technicians, Unit 1 l&C technicians inadvertently actuated EFW Train B while performing surveillance activities, and a noncited violation was issue Ill. Enaineerina l E8.1 (Closed) URI 50-313/9424-02: Unit 1 Pressurizer Safetv Valves Outside of Technical Specification Bases Tolerance. In 1994, two Unit 1 pressurizer safety valves failed their I as-found set pressure tests, with the as-found setpoints of +4.5 and +3.1 percent out of l tolerance. The applicable Unit 1 TS, item 3 on Table 4.1-2 did not have a setpoint tolerance for these valves, but the TS bases stated that the as-found setpoint may be 2500 psig +1/-3 percent. The licensee did not submit an LER when both of the Unit 1 pressurizer safety valves had out-of-tolerance setpoints, since their Techr.ical Specifications required the safety valves to be operable without any setpoint tolerance 1 value specified. The reportability of both Unit 1 pressurizer safety valve setpoints being out of tolerance was referred to NRR for revie The NRC concluded that the out-of-tolerance safety valves were not required to be reported since the tolerances were not specified in the TS. The inspectors noted that the NRC considered it inappropriate to cite the licensee based on the lack of safety significance and the inconsistencies between the TS and the TS base ,
To resolve this problem in the future, the licensee modified their reportablility manua The inspectors reviewed Reportability Manual TREDS," Interpretations of Event-Driven Reporting Requirements," Revision 11, distributed December 9,1997. The Reportability Manual Section, "Reportability Event SAF 1.15," described operations prohibited by TS and the requirement to provide a followup written report to the NRC within 30 days of discovery. This document stated that the Unit 1 pressurizer safety valves should be considered inoperable and reportable if the as-found setpoint was not within
+/-3 percent of the nominal setpoint. The inspectors noted that the guidance was in effect until implementation of the improved standard TS or an amendment to Unit 1 TS to clarify operability requirement The licensee concluded that the cause for the safety valves lifting high was the previous testing and maintenance on the valves. Previously, these valves were sent offsite for set-pressure testing, and after the setpoint was attained, lapped the valve seats to assure a leak tight fit. The licensee has discontinued this practice and this item is close . - - - - . - - . _ - - _ . _ _ _ . . - -
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E (Closed) URI 50-313/97201-04: Inadeouate Pioina Pressure and Temoerature !
l Specifications. During the Architect-Engineering inspection, the NRC and the licensee !
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raised questions about the design adequacy of the EFW piping to withstand the !
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maximum postulated discharge pressures. The applicable calculation (88-E-0100-16)
neither used the pump suction alignment with the highest discharge pressure, nor l
entirely accounted for manual control of the turbine-driven pump. The use of the service j water system as a source would result in a higher system discharge pressure than if ;
suction were taken from the condensate storage tank. Further, if the turbine-driven i speed control was out of tolerance or the pump was operated manually, the maximum l
discharge pressure could exceed the EFW piping design pressur !
The licensee reviewed their records and determined that the EFW pump was never l operated with service water lined up as the primary water and the piping was never !
overpressurize !
I An analysis of the pump discharge pressure versus turbine speed revealed that, in a l worst case scenario, discharge pressure could approach 1941 psig with the pump (
suction aligned to the condensate storage tank and 2029 psig with the pump suction !
aligned to the service water system. In their operability assessment, the licensee ;
determined that the 2029 psig discharge pressure was the bounding maximum pressure for the discharge piping. The ASME Code, Section lil, allows components to exceed }
their design pressure by 10 percent (i.e.,2035 psig). The licensee determined that the i
. EFW system was operable at a pressure of 2029 psig, since this pressure was within I
the code allowance. The licensee stated that the pump was hydrostatically tested to i 2400 psig, and the design was considered to be fully capable of withstanding the !
potential pressure excursio !
To reduce the possibility of a future overpressurization due to manual control of turbine f speed or controller failure, the licensee implemented a modification to reduce the EFW i pump overspeed trip setpoint and normal operating speed. The inspectors reviewed Limited Change Package 980191P101,"ANO-1 EFW Turbine Normal Operating Speed i and Overspeed Trip setpoint Reduction," Revision 3. The licensee lowered the !
overspeed trip setpoint to 4255 rpm and the normal operating speed to 3650 rpm. In j addition, the licensee revised Procedure 1106.006, " Emergency Feedwater Pump ,
Operation," Revision 58, to ensure that when operators took manual control of the EFW f pump, they controlled the pump discharge pressure between 1300 and 1600 psig and l l the turbine speed control to 3650 rpm. The licensee also included a caution in the I procedure which stated that exceeding the turbine speed of 3773 rpm could result in
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excessive discharge pressure with the EFW pump aligned to service wate f
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i The inspectors determined that there was no safety significance associated with l exceeding the design pressure. The f ailure to have adequate design controls in place to !
ensure that the design pressure of the pump casing and discharge piping were not
exceeded constituted a violation of minor significance and is not subject to formal !
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-11-E8.3 LClosed) LER 50-368/97-005-00: Unit 2 Main Steam Safety Valve As-Found Setooint Values Did Not Meet Technical Soecification Reauirements. The inspectors reviewed LER 50-368/97-005-00 and found that the as-found setpoints for eight of the ten Unit 2 main steam safety valves exceeded the maximum of +1 percent tolerance above the setpoint allowed by TS. The inspectors noted that four of the eight out-of-tolerance valves had setpoints exceeding +3 percent above the nominal setpoin The inspectors reviewed the licensee's root cause evaluation, dated June 23,1997, for the failure of the Unit 2 main steam safety valves. The inspectors found that nine of the ten valves had been replaced with valves that had been inspected and tested at an independent laboratory. During final certification testing, the ve!ves were left with setpoints of 0 to -1 percent, a!!owing some margin from the TS as-found tolerance on the high sid As part of the licensee's corrective action, the licensee submitted TS amendment (June 29,1998) tc increase the setpoint tolerance from +1/-3 percent to +/-3 percent for the main steam safety valves. Other long-term corrective actions included evaluating whether to incorporate a flexi-disk designed by the valve vendor. The purpose of the flexi-disk was to enhance seat leakage performance rather than improve the accuracy of the set pressur The licensee concluded that the reason for the higher setpoints was that they lapped the seats after the setpoint was set to improve the leak tightness of the valves. The licensee discontinued this procedur The inspectors determined that the licensee's corrective actions were adequate to prevent recurrenc E (Closed) Violation 50 368/9801-06: Unit 2 Safety Valve Performance Monitored Aaainst Goals Hiaher than Threshold for Reliability. The inspectors determined that the licensee established goals for the Unit 2 main steam safety vd.as which were not commensurate with safety. Safety valve performance was monitored against goals of +/- 5 percent of the nominal setpoint, which is greater than TS 3.7.1.1 limits of +1/-3 percent of the nominal setpoin The inspectors reviewed the licensee's violation response letter, dated June 22,1998, which provided the corrective actions for the violation. The inspectors found that one of the corrective action items included a proposed TS amendment (June 29,1998) to change the setpoint tolerance from +1/-3 percent of nominal setpoint to +/-3 percen The inspectors reviewed CR 2-1996-0081, dated June 5,1998. In this report, the licensee established new goals to limit functional failures to less than two of the main steam safety valves tested failing to lift within ASME Code and TS requirements per operating cycle. Until the TS amendment is approved, the current TS setpoint tolerance of +1/-3 percent of setpoint will be maintained. In addition, the licensee revised the corrective action due date so that goals and corrective actions would be monitored by CR 2-1996-0081 with e due date of December 1,200 . .
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-12-The inspectors determined that the licensee had completed all of the corrective actions committed to in their response letter to the violation. The inspectors determined that the licensee's corrective actions were adequate to prevent recurrenc E8.5 LClosed) URI 50-313/97201-10: Lack of Cathodic Protection Testina. The inspectors reviewed the periodic maintenance requirements for the cathodic protection syste The inspectors noted that voltage and current readings were taken every 24 weeks and sent to system engineering, but the licensee did not have a procedure describing *.he review and trending of the readings, acceptance criteria, anode or rectifier maintenance recommendations, and methods for cleanin The licensee stated that they would contact other nuclear station organizations and review industry standards for information on maintenance, inspection, and periodic testing of grounding and cathodic protection system The licensee stated that a procedure was not prepared for describing the review and trending of the readings taken every 24 weeks for the cathodic protection system. The inspectors reviewed Preventive Maintenance Task JO 00967943, dated September 5, 1997, which the I;cer'see revised to add a signoff for the system engineer. The inspectors noted that the system engineer reviewed the data and compared it to previous data. If the data indicated a problem, the system engineer would generate a replacement reques The licensee found that, for the most part, other facilities did not test or inspect their grounding system. Based on this survey and the absence of such criteria in the licensing basis, the licensee concluded that no actions were needed to address ground system maintenance and testing. The inspectors verified that cathodic protection was not a part of the facility's licensing basis and consider this item close IV. Plant Support R1 Radiological Protection and Chemistry Controls R Unit 2 - Drv Fuel Storace Radiation Practices
! Inspection Scope (71750)
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On September 13-25,1998, the inspectors periodically observed health physics control j and oversight of dry fuel storage activities in accordance with the licensee's Certificate of Compliance and 10 CFR Part 72. Activities observed included radiological postings, radiation surveys, personnel controls, and radiation work permit complianc Observations and Findinas On September 13,1998, the inspectors observed health physics technicians perform j surveys and postings of the dry fuel storage cask while located in the vicinity of the spent fuel pool. Radiation zones and procedural requirements were properly j j
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- 13-implemented and posted. On September 23, the inspectors observed surveys performed on the exterior surfaces of the dry fuel storage cask. The surveys were performed and documented in accordance with the licensee's Certificate of Compliance and Procedure 1601.303, Revision 4, " Radiation Monitoring Requirements for Loading and Storage of the VSC (Ventilated Dry Fuel Storage Cask)."
The inspectors noted that gamma and neutron radiatinn levels surveyed for the dry fuel storage cask exterior surfaces prior to transfer to the storage pad were higher then previous radiation surveys on other casks. Due to the higher then normal radiation readings, health physics personnel performed additional surveys and averaged the levels as required by Procedure 1601.303. The inspectors noted that health physics personnel who performed the radiological surveys demonstrated good ALARA practices and were knowledgeable of Procedure 1601.303 and the radiation level requirements from the Certificate of Compliance. During a subsequent review of Radiological Survey Map DFS-12, the inspectors noted that, with only minor exceptions, all surface area radiation surveys were properly documented The inspectors discussed the observations with health physics supervisio On September 25,1998, the inspectors walked down the dry fuel radiation postings at the ventilated dry fuel storage cask, which had been placed on a rail car. The inspection included a review of the licensee's contact survey of the cask, a walkdown of the perimeter of the posted radiation boundary with a survey meter, and a review of Procedure 1012.017, Revision 5, " Radiological Posting and Entry Requirements," which contains the licensee's posting requirements. The inspectors identified minor i
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discrepancies in the radiation survey of the cask and the posted radiation boundary which were promptly corrected by the license { Conclusions During the performance of radiation surveys on a newly loaded dry fuel storage cask, health physics technicians demonstrated good ALARA practices and were knowledgeable of requirements contained in the Certificate of Compliance. Some discrepancies were identified with the radiation surveys performed and postings associated with the loaded cas R2 Status of Radiological Protection and Chemistry Facilities and Equipment R Postaccident Samplina System (PASS) Inspection Scope (71750)
During this inspection period, both the Units 1 and 2 PASSs were out of service due to equipment problems. The Unit 1 PASS was out of service for approximately 2 days due to blown sample booster pump seals. The licensee has experienced past problems with leaking system isolation valves, causin excessive pressure at the sample booster pump. The Unit 2 PASS was out of service for approximately 27 days due to malfunction of the gamma spectroscopy detector. The licensee had to send the
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1 detector to a vendor for repair. Due to recurring problems with the PASSs, the inspectors reviewed the performance of the systems and the licensee's actions to address system performance problems.
- Observations and Findinas
! 1 The inspectors reviewed the maintenance and surveillance history for the Units 1 ar d 2 l PASSs for 1997 and 1998. The inspectors found that the licensee closely monitored the l availability and r6 ability of the Units 1 and 2 systems. The licensee's data indicated :
that the Unit 1 PASS had an availability of 92 percent in 1997 and 92 percent through August 1998. The Unit 2 PASS had an availability of 90 percent in 1997 and 96 percent ,
through August 1998. The inspectors reviewed the surveillance history for both systems l to determine how often the systems functioned properly (all sample requirements met) I when called upon to do so. The Unit 1 system reliability was 100 percent in 1997 and 75 percent through September 1998. The Unit 2 system reliability was 55 percent in 1997 and 71 percent through September 199 The inspectors found that the low reliability of the Unit 1 PASS in 1998 was due to Mlures of the PASS computer. The Unit 2 PASS reliability for 1997 and 1998 was impacted by a variety of problem The inspectors reviewed the licensee's plans to improve the reliability of the PASS for both units. Short-term plans include replacing the PASS computer to address recurring problems and because the computer is not year 2000 compliant. For the longer term, the licensee plans to evaluate system modifications to simplify the process for obtaining and analyzing sample Conclusions The reliability of the Units 1 and 2 PASSs has been poor due to problems with system hardware, detectors, and the system computer. The licensee closely monitored the availability and reliability of the systems and has been very responsive to emergent issues. The licensee's plans to upgrade the system computer and evaluate long-term system improvements were reasonabl S1.1 Conduct of Security - General (71750)
Tha inspectors periodically reviewed security measure and opecations throughout the inspection period and noted that they were properly implemented. Included were observations of personnel and package access, review of watch station assignment and rotation, applications of temporary and low level security lighting, and perimeter walk downs.
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F1 Control of Fire Protection Activities i F1.1 Control of Fire Protection Activities - General (71750)
l The inspectors periodically observed fire protection activities during the perio Intentiews of fire watches indicated that they were knowledgeable of procedural requirements, responsibilities and duties, and the breaches that were covered by their tours. The inspectors also observed proper application of breach and fire watch requirements when fire doors were temporally removed to facilitate battery charger modifications at Unit ;
F1.2 (Closed) Aooarent Violation (EEI) 50-313/9806-02: Failure to incorporate Acorooriate i Acceptance Limits into Surveillance Procedure (92901). Deficiencies associated with Procedure 1104.032, Revision 51, " Fire Protection Systems," Supplement 2,
" Surveillance Test of Diesel Fire Pump (P-6B)," were identified in NRC Inspection Report 50-313/98-06. Specifically, the inspectors iden'Jied that the engine cooling water temperature limits contained in the procedure did not reflect the limit described in the technical manual and the licensee did not have a basis for the procedural limit The inspectors reviewed the licensee's corrective actions described in the root cause analysis for CR C-1998-0171 associated with this issue and found them reasonable and adequate. Corrective actions already taken included revision of the affected procedure, assignment of system engineering (versus fire protection) as responsible for both the
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fire and security diesels, evaluation of diesel fire engine operating limits and incorporation into the affected procedure, and interaction between management and fire protection personnel emphasizing the applicability of the system engineering desk guide for fire system components. Proposed long-term corrective actions included -
engineering review of diesel engine coolant system design, evaluation of diesel fire pump and security diesel preventive maintenance requirements for adequacy, a review of operating procedures for the diesel fire pump engine to determine limits established j in procedures, a review of the root cause with procedures writers, and establishing i management expectations for engineering review of procedures. Interviews with ;
engineering indicated that management expectations in the future would ensure that l
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requirements and limits specified by applicable design documents or written procedures are technically justified when an engineering review is required. The inspectors found this approach for addressing design limits to be reasonable and adequat The failure to incorporate appropriate requirements and acceptanee limits as specified
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by applicable design documents to demonstrate that Diesel Engine Fire Pump P-6B would perform satisfactority while in service was identified as a violation of TS 6.8. l (50-313/9808-02).
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V. Manaaement Meetinas ,
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I l X1- Exit Meeting Summary .!
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i The inspectors presented the inspection results to members of licensee management at : the conclusion of the inspection on October 29 and November 3,1998. The licensee ;
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acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the ;
inspection should be considered proprietary. No proprietary information was identifie ',
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!- ATTACHMENT
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( PARTIAL LIST OF PERSONS CONTACTED l
Licensee
! B. Allen, Unit 2 Maintenance Manager C. Anderson, General Plant Manager G. Ashley, Licensing Supervisor B. Bement, Unit 2 Plant Manager V. Bhardwaj, Unit 1 Electrical Superintendent
- J. Bradford, Unit 2 instrumentation and Control Superintendent
. R. Carter, Maintenance Superintendent l- E. Christian, Unit 1 Instrumentation and Control Superintendent M. Cooper, Licensing Specialist D. Denton, Director Support M. Farmer, CRS Unit 1 Operations R. Fuller, Unit 1 Operations Manager D. James, Acting Director, Nuclear Safety R. Lane, Design Engineering Director T. Morrison, Modifications Supervisor J. Smith, Jr., Radiation Protection Manager t
J. Vandergrift, Nuclear Safety Director D. Wagner, Quality Assurance Supervisor R. Walters, Unit 1 Shift Operations Superintendent H. Williams, Plant Security Superintendent C. Zimmerman, Unit 1 Plant Manager INSPECTION PROCEDURES USED IP 37551: Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: Followup -Operations IP 92902: Followup - Maintenance
,' IP 92903: Followup - Engineering i' IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
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ITEMS OPENED AND CLOSED Opened 50-313/9808-01 NCV inadvertent Actuation of Emergency Feedwater Initiation and Control System During Surveillance Testing (Section M4.1)
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1 -3-50-313/9808-02 VIO Failure to incorporate Appropriate Acceptance Limits into ,
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Surveillance Procedure (Section F1.2)
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50-313/9424-02 URI Unit 1 Pressurizer Safety Valves outside of Technical i Specification Bases Tolerance (Section E8.1)
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50-368/97-005-00- LER Unit 2 Main Steam Safety Valve As-Found Setpoint Values Did Not Meet Technical Specification Requirements (Section E8.3)
50-313:368/9718-01 URI Consequences for Failing to Write Condition Reports for i
Emergency Lighting Deficiencies (Section 08.3)
t 1 50-313/97201-04 URI Inadequate Piping Pressure and Temperature Specifications
(Section E8.2)
50-313/97201-10 URI Lack of Cathodic Protection Testing (Section E8.5)
[ 50-368/9801-06 VIO Unit 2 Safety Valve Performance Monitored Against Goals Higher
, than Threshold for Reliability (Section E8.4)
] 50-313/98-003-00 LER Active Status of Licensed Operators Not Maintained Due to a l Misinterpretation of Regulations (Section 08.2)
- 50-313;368/9806-01 ' VIO Failure to Meet Technical Specification Minimum Shift Manning Requirements (Section 08.1)
50-313/9806-02 eel Failure to incorporate Appropriate Acceptance Limits into
Surveillance Procedure (Section F1.2) l j 50-313/9808-01 NCV inadvertent Actuation of Emergency Feedwater initiation and I l Control System During Surveillance Testing (Section M4.1)
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LIST OF ACRONYMS USED CR condition report eel apparent violation EFIC emergency feedwater initiation and control EFW emergency feedwater l&C instrument and control JO job order LER licensee event report LPSI low pressure safety injection NCV noncited violation PASS postaccident sampling system PPS plant protection system TS Technical Specification URI unresolved item VIO violation j
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