IR 05000315/1994014
| ML17332A312 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/20/1994 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17332A310 | List: |
| References | |
| 50-315-94-14, 50-316-94-14, NUDOCS 9409290132 | |
| Download: ML17332A312 (31) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos.
50-315/94014(DRP);
50-316/94014(DRP)
Docket Nos. 50-315; 50-316 Licensee:
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 License Nos.
Donald C.
Cook Nuclear Power Plant, Units 1 and
Inspection At:
Donald C.
Cook Site, Bridgman, NI Inspection Conducted:
July 2 through August 12, 1994 Inspectors:
J.
A. Isom D. J. Hartland J.
H. Niesler Approved By:
Wayne J.
Krop,
C ef Reactor Projects Section 2A Date Ins ection Summar Ins ection from Jul
1994 throu h Au ust
1994 Re ort Nos.
50-315 94014 DRP 50-316 94014 DRP Areas Ins ected:
Routine, unannounced safety inspection by the resident inspectors of action on previous inspection findings; operational safety verification; onsite event follow-up; engineering safety feature systems; current material condition; housekeeping and plant cleanliness; auxiliary equipment operator (AEO) tour discrepancies; Licensee Event Reports (LERs);
condition reports; maintenance activities; post maintenance testing; action request tags; surveillance activities; battery grounds; and failure of a canopy seal weld.
Results:
Of the fourteen areas inspected, two violations were identified that pertained to a blocked emergency light (paragraph 2.h.)
and AEO tours (paragraph 3.f).
One non-cited violations was identified that pertained to a
fire door (paragraph 4.a).
Four Unresolved Items were issued that pertained to inadequate closure of a condition report (paragraph 4.b); post maintenance testing (paragraph 5.b); action request tags (paragraph 5.c);
and battery grounds (paragraph 6.a).
Two Inspection Followup Items were identified that pertained to calibration of exhaust hood high temperature switches (paragraph 3.d);
and auxiliary building negative pressure (paragraph 4.a).
The following is a summary of the licensee's performance during this inspection period:
9409290i32 940921 PDR ADOCK 05000315
Safet Assessment ualit.Verification
0 The licensee s performance sn thss area was good.
Review of licensee event reports and condition reports indicated that root cause were gener ally being addressed and corrective actions were appropriate.
However, licensee's investigation to determine =whether a Technical Specification surveillance was performed on hatches between upper and lower containment before Node change was inadequate.
The inspectors also identified a weakness in the review of condition reports for reportability.
Naintenance and Surveillance The licensee's performance in the maintenance and surveillance area was good.
The inspectors found that the surveillances and maintenance activities were performed well.
The inspectors did identify a concern with the failure to remove action request tags for equipment from the control room panels after maintenance was completed or cancelled.
En ineer in and Technical Su ort The licensee's performance in the engineering area was adequate.
The engineering department provided valuable assistance to the operators and electricians in locating a hard ground on the Unit
"CD" battery.
Also, investigation into the weld failure of the Unit 1 core exit temperature nozzle assemblies was thorough and well done.
However, the inspectors identified a
concern with system engineer involvement in post-maintenance test for corrective maintenance which may impact system operabilit DETAILS 1.
Persons Contacted
- A. A. Blind, Site Vice President/Plant Hanager
- K. R. Baker, Assistant Plant Manager/Operations Superintendent L. S. Gibson, Assistant Plant Hanager-Technical J.
E. Rutkowski, Assistant Plant Hanager, Support
- T. P. Beilman, Haintenance Superintendent P.
F. Carteaux, Training Superintendent D. L. Noble, Radiation Protection Superintendent T. K. Postlewait, Site Engineering Support Hanager P.
G. Schoepf, Haterials Management Superintendent
- J. S. Wiebe, guality Assurance 8 Control Superintendent L. H. Vanginhoven, Project Engineering Superintendent G. A. Weber, Plant Engineering Superintendent A. A. Lofti, Site Design Superintendent
- Denotes those attending the exit interview conducted on August 19, 1994.
The inspectors also had discussions with other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and foremen, and electrical, mechanical, and instrument maintenance personnel, and contract security personnel.
2.
Action on Previous Ins ection Findin s (92701)
a ~
Closed Unresolved Item 50-315 90-201-04 DRS 50-316 90-201-04 DRS
The Safety System Functional Inspection (SSFI) questioned whether the calculated 178 Vdc at the motor terminals for the steam-driven auxiliary feedwater (AFW) inlet valve was sufficient for the valve to perform its required design function.
The inspectors reviewed the licensee's motor torque calculations for this valve which was completed subsequent to the SSFI.
The calculation indicated that motor torque developed at 178 Vdc exceeded the torque required to operate the valve.
This unresolved item is closed.
b.
Closed Unresolved Item 50-315 90-201-09 DRS 50-316 90-201-09 DRS:
Essential service water (ESW) check valves ESW-111, ESW-112, ESW-113, ESW-114, ESW-141, ESW-142, ESW-143, ESW-144, ESW-101E, ESW-101W, ESW-102E, and ESW-102W have a reverse flow closure function.
Testing of the reverse flow function was not included in the licensee's inservice test (IST) program.
The inspectors verified that the reverse flow closure function was included in the June 28, 1993 revision to the IST program for check valves ESW-101E, ESW-101W, ESW-102E, and ESW-102W.
The licensee was granted Code relief to use an alternate method to assure valve operability by NRC letter dated April 20, 1994, for
c ~
check valves ESW-ill, ESW-112, ESW-113, ESW-114, ESW-141, ESW-142, 9ESW-143, and ESW-144.
This unresolved item is closed.
Closed Ins ection Follow-U Item 50-315 93011-04'5->>
>>-N:
5 ht,lg, h
- d h
Limiting Condition for Operation (LCO) on Unit 1 for containment integrity after an unisolable weld leak developed on a Containment Spray system (CTS) instrument line during routine surveillance testing.
Upon further review and just prior to initiating a Technical Specification required plant shutdown, the licensee exited the LCO after closing some manual valves outside containment and backseating isolation check valves CTS-127E and 131E with a standing head of water.
The licensee then entered a
72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO for an inoperable CTS pump to repair the leak.
The licensee's design basis provided for two barriers as containment integrity for the CTS system.
The first barrier was the piping system which was a closed system outside containment.
The second barrier was a single check valve, located inside containment, for each header.
The design basis required that these check valves provide containment isolation only in a post-LOCA scenario after containment spray initiation.
The analysis assumed that under these conditions that the check valves would be seated with a column of water.
The inspectors reviewed the design requirements as discussed in the "Containment Isolation System Design Basis" section of paragraph 5.4.1 of the Updated Final Safety Analysis. Report (UFSAR).
Subparagraph 6 in this section states that the two barriers consist of "... (3)
an automatic isolation valve and a
closed piping system or vessel inside or outside the containment..."
Also, subparagraph 7 defines
"a check valve on an incoming line or a locked or sealed closed valve is considered equivalent to an automatic valve."
Based on the review of the UFSAR, the inspectors determined that containment design aspects
'f the CTS system were acceptable.
This inspection item is closed.
d.
Closed Ins ection Follow-U Item 50-315 93011-07'5-
ll->>:
Ilhf1 1 11 I
g
h g
d t th operation of component cooling water (CCW) valves, the inspectors found that not all operators were familiar with this new operational requirement.
The inspectors asked the Operations Superintendent how such information was communicated to the shift and what methods existed to assure such information was received by the operators.
The inspectors discussed this issue with the Operations Department Production Supervisor and determined that a revision to OHI-2070,
"Training," Revision 9, Section 4.9.3, now requires that required
reading material, such as plant modifications, special reports, audits, surveillances, and procedure changes will be in one of three following formats:
~
required reviews
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informational review packages
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E-mail summaries to affected personnel A review of procedure OHI-2070 requires reviews/informational reviews to be routed with a return date.
Also, all required reading e-mail will be sent as "certified" e-mail for tracking purposes.
Additionally, the inspectors review of the recent condition reports and discussion with the Operations Department Production Supervisor indicated that there have been no performance related problems identified in this area.
This item is closed.
e.
Closed Violation 50-316 93020-03 DRP
In LER 50-316/92004, the licensee attributed a Unit 2 "AB" emergency diesel generator (EDG) failure to a modification that had been performed on the air start system.
This modification replaced the older pilot-operated valve (POV) with a valve of another design.
Because the newly installed POV was infrequently operated, the valve operated slower than required to ensure that the EDG started in 10 seconds as required by Technical Specification.
The licensee completed corrective actions.in a timely manner to ensure that the slow EDG start time was addressed.
Part of the corrective actions included replacing the POVs on all EDGs with the original designed valves.
This item is closed.
Closed Unresolved item 50-315 94002-01 DRP 50-316 94002-
~01 DRP:
Licensee identified numerous instances of log falsifications by the AEOs during 1993.
This item is closed based on the issuance of a violation described in paragraph 3.f of this report.
g.
Closed Unresolved Item 50-315 94002-08 DRP
During the 1994 Unit 1 refueling outage, the operators'ack of awareness of ongoing evolutions contributed to a condition where one of the safety-related centrifugal charging pumps was operated with zero percent level in the volume control tank (VCT) for a short period of time.
The inspectors were concerned with what appeared to be a
lack of adequate turnover between operators and the operators'ailure to be cognizant of significant plant operations.
The inspectors found that the licensee's review of this event was thorough.
The investigation results were documented in condition report (CR) 94-0337 that attributed the causes of this event to the following:
~
The turnover given to the balance of plant operator by the reactor operator was not adequate, given the degree of change in the various aspects of plant operations.
~
The Unit Supervisor was not fully cognizant of the status of the ongoing evolutions in the control room.
~
The operational crew did not recognize available staffing limitations and the various demands being placed upon them.
~
Nanagement expectations were not clear regarding authority and responsibility of operations personnel seeking temporary relief from a job assignment.
~
Neans were not provided for ensuring adequate equipment quality/reliability/operability; specifically, the operability of the VCT level alarm.
As a result, the licensee made a change to procedure OHI-4013, Revision 7, "Operators: Authorities and Responsibilities,"
which now requires the unit supervisors to evaluate the plant conditions and current responsibilities prior to an operator being relieved temporarily.'he procedure requires the Unit Supervisor to ensure that appropriate turnovers are conducted with the oncoming operators.
Additionally, both the reactor operators and the non-licensed operators are required to inform and receive permission from the Unit Supervisor before being temporarily relieved.
The operations management also issued standing order "Operations Standards,"
OS0.113, to clarify management expectations for standards of performance in the Operations Department.
This event had minimal safety significance because the unit was in a condition where the centrifugal charging pumps were not needed to satisfy a safety function.
The licensee took appropriate corrective actions to minimize future occurrence.
No further examples of this type of problem occurred during the remainder of Unit 1 outage.
The inspectors have no further concerns in this area and this item is closed.
Closed Unresolved Item 50-315 94002-09 DRP
On February 4, 1994, with Unit 1 in NODE 1, the inspectors observed construction personnel erecting a green canvas tent around the Unit 1 control room emergency exit to the 633 level of the auxiliary building.
The inspectors determined that the green canvas sheets enclosed an Appendix R emergency lighting pack that was installed to provide lighting to motor control center(NCC),
1-AN-A.
This MCC provides power to various residual heat removal and component cooling water valves.
The inspectors informed the shift supervisor of this potential problem and Condition Report (CR) 94-0186 was issue The inspectors reviewed the licensee's CR investigation which determined that a lack of communication and coordination between the construction crew and the project engineers was the main cause for this problem.
As short term corrective action, the licensee briefed the site nuclear services personnel involved in scaffolding construction on the need to contact the Appendix R administrator prior to erecting scaffolding in the vicinity of any emergency lights.
For long term corrective action, the licensee made Change 2 to procedure, CHI 5080.CCD.002, Revision 0, "Contractor Scaffold Erection Guidelines," to have the scaffolding coordinator obtain the Appendix R administrator 's review and approval for any scaffolding that is determined to potentially interfere with normal plant emergency lights.
The inspectors identified no further problems with scaffolding blocking any emergency lighting packs during the rest of the Unit 1 outage period.
The failure of the licensee to properly coordinate the outage work activities 'to ensure that the emergency lighting units are available for operation of safe shutdown equipment is considered a
violation of 10 CFR 50 Appendix R and paragraph 8. 1 of plant "Fire Protection" procedure, PMI-2270, Revision
(50-315/94014-01(DRP).
This procedure prohibits blocking of light beams from emergency lighting units for any reason.
However, because the licensee has adequately completed all corrective actions for this event, no response to this violation is required and the inspectors have no further concerns regarding this matter.
This violation is closed.
Closed Unresolved Item 50-315 94002-11:
The inspectors reviewed the licensee's investigation into an event were valve's bonnet became a projectile because a section of hot piping was still pressurized.
The licensee issued Condition Report (CR) 94-0070 to document the review of this event.
The inspectors agreed with the conclusions of the CR investigation that identified the following causes for this event:
There were leaking isolation valves.
The sequence used in establishing isolation boundary for the work activity prevented all the piping within the work boundary from becoming depressurized.
The maintenance supervisor's failure to implement the requirements of the procedure, PMI-2110, Revision 18,
"Clearance Permit System,"
which required that the supervisor receive permission from both Operations and Maintenance department head or designee prior to working on a system with potentially hazardous condition The inspectors concluded through personnel interviews and review of the event that the maintenance supervisors believed that although there was evidence of leakby, that the leakby was not sufficiently excessive to be of concern.
The supervisor was also aware that some leakby through the isolation valve was possible, and that attachment 12 of procedure PHI-2110, used to document permission received to work under hazardous condition, was not attached to the job order.
The licensee's program did not allow the maintenance supervisors the latitude to perform work under potentially hazardous conditions without first obtaining concurrence from proper levels of operations and maintenance management.
The licensee discussed the event with the responsible maintenance supervisor and was planning to provide training for the other supervisors on the lessons learned.
The inspectors concluded that this was an isolated event and no similar problems have been identified to date.
This unresolved item is closed.
Plant 0 erations The licensee operated both units up to full power during the inspection period, with no significant operational problems.
Unit 2 started
"coastdown" for the cycle 9-10 refueling outage which is scheduled to begin on September 6,
1994.
At the end of the inspection period, Unit
was operating at 100 percent and Unit 2 at 61 percent power.
a 0 0 erational Safet Verification (71707)
The inspectors verified that the facility was being operated in conformance with the licenses and regulatory requirements, and that the licensee's management control system was effective in ensuring safe operation of the plant.
On a sampling basis the inspectors verified proper control room staffing and coordination of plant activities; verified operator adherence to procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was available; and observed the frequency of plant and control room visits by station management.
The inspectors reviewed applicable logs and conducted discussions with control room operators throughout the inspection period.
The inspectors observed a number of control room shift turnovers.
The turnovers were conducted in a professional manner and included log reviews, panel walkdowns, discussions of maintenance and surveillance activities in progress or planned, and associated LCO time restraints, as applicabl Onsite Event Follow-u
(93702)
On June 23, 1994, the licensee made a one hour report to the NRC regarding the falsification of background information by a contract worker who was no longer at the plant.
The licensee determined through subsequent evaluation that this event need not have been reported within one hour.
Instead, the event should have been recorded in a quarterly log that is submitted to the NRC.
The licensee came to this conclusion based on the individual in question having already left the site three months'ago.
Therefore, the licensee determined that this event did not specifically meet the one hour reporting criteria which was to address current events.
En ineered Safet Feature ESF S stems (71710)
During the inspection, the inspectors selected accessible portions of several ESF systems to verify status.
Consideration was given to the plant mode, applicable Technical Specifications, Limiting Conditions for Operation requirements, and other applicable requirements.
Various observations, where applicable, were made of hangers and supports; housekeeping; whether freeze protection, if required, was installed and operational; valve position and conditions; potential ignition sources; major component labeling, lubrication, cooling, etc.; whether instrumentation was properly installed and functioning and significant process parameter values were consistent with expected values; whether instrumentation was calibrated; whether necessary support systems were operational; and whether locally and remotely indicated breaker and valve positions agreed.-
During the inspection, the inspectors walked down the accessible portions of the Unit 1 and 2 residual heat removal systems.
No discrepancies were identified.
Current Material Condition (71707)
The inspectors performed general plant as well as selected system and component walkdowns to assess the general and specific material condition of the plant, to verify that work requests had been initiated for identified equipment problems, and to evaluate housekeeping.
Walkdowns included an assessment of the buildings, components, and systems for proper identification and tagging, accessibility, fire and security door integrity, scaffolding, radiological controls, and any unusual conditions.
,Unusual conditions included but were not limited to water, oil, or other liquids on the floor or equipment; indications of leakage through
~
~
ceiling, walls or floors; loose insulation; corrosion; excessive noise; unusual temper'atures; and abnormal ventilation and lighting. The following concerns were identified by the inspectors:
On July 7, 1994, during a routine tour of the auxiliary feedwater pump room area, the inspectors found that the double doors to the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump room were closed.
These doors are required to be open to prevent from over-pressurizing the room in the event of a high energy line break (HELB) of the steam supply line to the pump.
The door was verified open during a daily walkdown of HELB doors earlier in the day.
Based on the presence of a cart with scaffolding equipment outside the room, the inspectors concluded that the doors were probably shut during this work activity.
The inspectors informed a fire watch who was on tour nearby.
The fire watch opened the doors after notifying the appropriate supervisor.
On the following day, the inspectors discovered that the operations shift management were not informed of the deviation, nor was a condition report generated, due to apparent'iscommunication among fire watch personnel.
In response, the licensee initiated CR¹ 94-1352 to document and investigate the issue.
The inspectors do not have any further concerns regarding this event, since this event appears to be an isolated incident of minimal safety significance.
During a tour of the auxiliary building, the inspectors found the door from the Unit 1 quadrant 2 room to the non-essential service water (NESW) valve gallery open.
The inspectors were concerned that having this door opened would prevent the ventilation system from developing a negative pressure in the quadrant 2 room.
With this door opened, the quadrant 2 room communicates directly with the area outside the auxiliary building.
After discussion with the system engineers, the inspectors found that the licensee was maintaining this door open because there was a potential overpressurization concern from steam piping in the Unit 1 quadrant 2 room.
The system engineers stated that the ability to maintain negative pressure in all parts of the auxiliary building, as required by the plant's Updated Final Safety Analysis Report, was a
concern presently being reviewed.
A similar condition exists for the Unit 2 quadrant 2 room.
The licensee's resolution to this issue is considered an Inspection Follow-up Item pending further NRC review (50-315/94014-02; 50-316/94014-02).
Housekee in and Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matter.
Housekeeping was considered very good during this inspection period.
Auxiliar E ui ment 0 erator AEO Tours Discre ancies The inspectors conducted a review of circumstances which resulted in generation of an Operations Department memorandum entitled,
"Inappropriate Tour Signoffs."
The December 28, 1993, memorandum discussed the results of an Operations Department internal audit, covering the period of September through November 1993, in which the licensee had identified AEO tour discrepancies.
The September through November 1993 audit identified five AEOs who apparently had not toured rooms as verified through the plant security computer which record individual's entries into these areas.
The rooms were in both the auxiliary and turbine buildings and contained both safety and non-safety related equipment.
Based on the results of the September through November 1993 audit, the inspectors'eviewed all operational internal audits from years 1992.and 1993 and found the following:
~
July through September of 1992:
8 of 30 tours discrepancies
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October through December of 1992:
3 tour discrepancies and weak tours identified.
~
January through March of 1993:
No tour discrepancies found but weak tours identified.
~
April through August of 1993:
No audit report issued; auditor reviewed these months informally and identified no tour discrepancies.
~
September through November of 1993:
5 tour discrepancies identified The inspectors found that the licensee had initiated the routine audits of the AEO tours in response to NRC Information Notice (IN) 92-30, "Falsification of Plant Records,"
dated April 23, 1992.
The NRC issued IN 92-30 to alert licensees to the NRC's concern regarding several examples of falsified plant logs that had been identified in the industry.
In addition, the NRC issued Generic Letter (GL) 93-03, "Verification of Plant Records,"
dated October 20, 1993, to inform licensees of the results of inspections conducted to assess the potential for incomplete or inaccurate records at licensed facilities.
The GL also documented actions
taken by licensees to ensure that management expectations regarding the conduct of rounds and log keeping were clearly articulated to plant personnel and were being implemented in the plant.
'ecause of the apparent widespread problems as indicated by the audits conducted in 1992 and 1993, the inspectors conducted their own audit for the months of September through November of 1993 and identified five additional tour discrepancies which were not identified by the licensee.
These discrepancies involved either tours which were signed as having been completed but could not be verified through the computer access record or tour conducted by individuals other than the ones indicated on the tour sheet.
Additionally', the inspectors audited some available 1992 tours and identified 13 more tour discrepancies, including six individuals not previously identified by the licensee in the September through November of 1993 audit.
In January 1994, the licensee initiated a 100 percent audit of AEO tours conducted during 1993 which was completed in early March 1994.
The licensee concluded that tour falsification was widespread among the non-licensed operators.
The licensee discovered 214 discrepancies.
These discrepancies were attributed to one senior reactor operator, three reactor operators, and 39 of 44 AEOs.
As a result of this extensive audit for all tours in 1993, the licensee management terminated employment of two AEOs, and issued 7 warnings and 16 letters of instruction to various AEOs.
The severity of the licensee's actions were 'based on the nature, frequency, or pattern of the discrepancies.
Based on these criteria, there were no actions taken against licensed individuals.
The warnings, unlike the letters of instruction, are retained in the individual's personnel folder and can be used by the management to take future disciplinary actions against an individual based on future performance-related problems.
The inspectors interviewed a number of AEOs and shift managers to obtain perceptions and views on the causes for the AEO tour discrepancies.
Generally,- most AEOs and shift managers shared the opinion that a major contributor to the missed room tours was the many tour interruptions that occurred during the shift.
The interruptions were attributed to the increased workload for the AEOs during the non-outage period.
At the beginning of 1993, the licensee made an effort to increase the amount of maintenance work performed during the non-outage period to reduce some of the work traditionally performed during the outages.
Although this reduced the corrective maintenance job order backlog, the result was an increase in demand on the AEOs'ime.
The second major contributor identified by many individuals involved the practice of not carrying the toursheet during the
I W
tour.
The past practice was to complete the toursheet after the tour was accomplished.
Other contributors, not necessarily in order of significance, mentioned by the operators included:
difficulty in remembering which rooms were entered on a
particular day after several days on shift.
The operators work a 12-hour shift.
a single signoff for completing tours of multiple rooms perceptions on the part of the AEOs of the expectation to perform plant tours while fully supporting production work perceptions that missing a room tour on occasion would not be dealt with harshly by the management with the exception of one shift, shift management's lack of emphasis on performing good tours The inspectors also concluded, based on interviews with the AEOs and the Operations'epartment management, that although the Operations management did not openly approve of these discrepancies, by taking relatively minor disciplinary actions against individuals for these tour discrepancies in the past, the management allowed these tour discrepancies to continue.
The past disciplinary actions typically involved counseling sessions in which the AEOs were told to be more conscientious during their tour.
The number of tour discrepancies in which the AEOs'nd other operators'ailed to make room tours as documented on tour sheets is a violation of 10 CFR 50.9, which requires that information required by the statute or by the Commission's regulations, order or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects (Viol ati on 50-315/94014-03(DRP);
50-316/94014-03(DRP)
).
In addition to the disciplinary actions, the licensee has taken other corrective actions that include extensively revising the
"Operation Plant Tour" procedure in an effort to improve the quality of the tours.
This new tour procedure, which went into effect in mid-June 1994, addresses many programmatic deficiencies which existed under the old system.
Under the new tour procedure, the AEOs monitor and record selected equipment parameters during the tour.
The shift management was also sensitive to the tour interruptions caused by additional work for the AEOs.
The licensee was planning to review and revise, if necessary, the contents of this new tour procedure after gaining more experience under this new tour program.
Also, the licensee was continuing to perform audits in this area to ensure tour discrepancy problems have been solved.
One violation and no deviations were identified.
Safet Assessment ualit Verification (40500 and 92700)
Licensee Event Re ort LER Follow-u (92700)
Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, that immediate corrective action was accomplished, and that corrective action to prevent recurrence had been or would be accomplished in accordance with Technical Specifications (TS):
Closed LER 316 93007-LL:
On August 2, 1993, the Unit 2 reactor tripped due to a turbine trip, caused by a spurious actuation of the exhaust hood high temperature trip switches.
The licensee discovered that eight of the nine switch setpoints were significantly below the normal trip setpoint.
The licensee concluded that the method used to calibrate the switches may have caused the setpoints to be misadjusted.
In addition, the licensee believes that a slight increase in hood temperature and vibration level, which resulted from the removal of a portion of the main condenser from service, may have contributed to the trip.
After completing a satisfactory safety evaluation, the licensee disabled the exhaust hood high temperature trip switches under temporary modification 2-93-016.
However, these switches still provide high boot temperature annunciation in the control room.
The inspectors found that the Instrument and Controls (I8C)
department had not written a calibration procedure to properly calibrate the switches.
The inspectors determined through discussions with the 18C engineers and technicians that the orientation of the temperature probe during the calibration has an effect on the results of the calibration.
Although the licensee has a generic calibration procedure, some of the more detailed
- calibration methods to properly calibrate these temperature probes were not found in procedure,
- 12IHP6030. IMP.066, "Generic Calibration," Revision 2.
Currently, the I8C department is determining whether a procedure is required to calibrate this instrument or whether the skill of the craft using the more generic procedure is sufficient.
The licensee's evaluation of whether a procedure is required to calibrate these switches will be an Inspection Follow-up Item (50-316/94014-04).
Closed ER 316 93008-L:
Reactor Trip due to a steam flow/feed flow mismatch coincident with a low level in the No.
The inspectors'eviewed this event with the results discussed in Inspection Report 50-315/93012(DRS);
50-316/93012(DRS).
Closed LER 316 93009-LL:
On September 28, 1993, the licensee discovered that the fire door which separates the Unit 2 non-
essential service water (NESW) valve area from the quadrant
penetration cable tunnel was blocked open with a stanchion in the doorway.
With the stanchion in the way, the normally-open door could not have automatically closed upon release of the C02 pop-off device or the melting of the thermal link.
The licensee determined that the door could have been inoperable for up to six hours with no compensatory actions in place.
The licensee was unable to determine why the door was blocked open.
The licensee also determined that appropriate measures were already in place to prevent recurrence which included postings in prominent locations.
Although this event involved a violation of TS 3.7.9.3, there was minimal safety significance because the fire protection available in these areas would have been able to mitigate any fire spread between the fire zones.
In addition, the licensee properly reported and investigated the event.
Therefore, we have determined that the violation meets the criteria of 10 CFR 2, Appendix C, Section VII, B(2) for a non-cited violation.
Condition Re orts CRs
In addition to the LERs, the inspectors reviewed the licensee's condition reports generated during the inspection period.
This was done in an effort to monitor the conditions related to plant or personnel performance, potential trends, etc.
CRs were also reviewed to ensure that they were generated appropriately and dispositioned in a manner consistent with the applicable procedures.
The inspectors reviewed the CRs CR 94-70;94-186; 94-283;94-337; 94-471;94-571; 94-1063; and 94-1187.
The inspectors did identify a concern with the closure of CR 94-1063.
On May 24, 1994, while completing datasheet 2 to procedure Ol-OHP-4030.001.002, Revision 12,
"Containment Inspection Tours,"
the
~ operators became concerned about whether all required inspections of hatches and openings between the upper and lower containment were performed.
Datasheet 2 required that the Maintenance department perform an inspection as required by Technical Specification (TS) 4.6.5.5.2 in accordance with procedure,
- 12-NHP 4030.STP.037,
"Inspection of Access Doors Separating Containment Upper and Lower Volumes."
The operators determined that inspections were performed, or were not required because the hatches were not opened, for all but two of the hatches.
The operators then took actions to ensure that the inspection of these two hatches were completed before the unit went to NODE 4.
However, because of the difficulty encountered in verifying whether these TS required inspections took place, the operators questioned whether the inspections were performed on all the
I h
required hatches during a previous Mode 5 to Mode 4 change earlier in the month on May 2, 1994.
The licensee initiated CR 94-1063 to document this concern.
The inspectors reviewed closed CR 94-1063 and determined that the investigation, conducted by a maintenance department evaluator, focused on the May 25 event and concluded that the May 25 event was not reportable.
However, CR 94-1063 did not address whether the TS surveillance requirement was violated during the mode transition on May 2, 1994.
Through discussions with outage management personnel, the inspectors determined that these hatches were observed opened during the Unit 1 outage and as a result, the inspection of hatch sealing surfaces were required in accordance with TS 4.6.5.5.2.a.
The inspectors assessment of the May 2, 1994, Mode change determined that the operators had placed Unit
in MODE 4 without properly inspecting hatches
"1-HATCH-612-3" and
"1-HATCH-612-4" per TS 4.6.5.5.2.a.
The inspectors discussed with the licensee whether the missed TS surveillance for hatches
"1-HATCH-612-3" and
"1-HATCH-612-4" per TS 4.6.5.5.2.a.
during the Unit 1 Mode change on May 2, 1994, should be considered for reportability.
Later, the Plant Nuclear Safety Review Committee (PNSRC)
reviewed the reportability aspects of the missed hatch surveillance on May 2, 1994 and agreed with the investigator that an LER should be submitted.
In addition, the inspectors determined that the CR evaluator failed to obtain the concurrence of the reportability determination for the May 25 event from NS&A, as required by the licensee's corrective action system.
Based on the inspectors'oncerns, the licensee initiated CR 94-1369, dated July 12, 1994, to document the inadequate investigation of CR 94-1063 for the May 2, 1994, Mode change and the problems with the reportability determination.
As follow-up, the licensee identified 10 additional CRs that were originally classified as potentially reportable and were closed without a completed reportability evaluation by NS&A.
The licensee's closeout of CR 94-1063 and the reviews of CRs for potential reportability is considered an Unresolved Item pending further NRC review (50-315/94014-05(DRP).
No violations or deviations were identified.
Maintenance Surveillance (62703
& 61726)
a ~
Maintenance Activities (62703)
Routinely, station maintenance activities were observed and/or reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specifications.
The following'items were also considered during this review:
~limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; and activities
'ere accomplished by qualified personnel.
Portions of the following maintenance activities were observed and reviewed:
JO C0016069 "Repair Oil Leak on CD Emergency Diesel Generator Shaft Driven Fuel Oil Pump" JO C0025118
"Replace Annunciator 116 Drop 22 Socket" JO C0024682
"RFC 2985:
Replace 1/4 amp fuse in SPEC 200 V2H's with 1/2 amp fuses" JO C0023072
"Repair of valve 12-ZRV-402" Post Maintenance Testin PHT The inspectors'identified a concern with the system engineer involvement in PHT.
For non-routine corrective maintenance, the work planners may not always have an adequate background in the system operation to ensure that the appropriate PHT would be performed.
This concern is based on the following:
During observation and review of records associated with the repair of the electric motor driven fire pump (EHDFP) back pressure regulating valve 12-ZRV-402 (JO C0023072),
the inspectors determined that the post maintenance test (PHT)
was not adequate.
The PHT did not adequately verify that the valve would perform as designed.
As follow-up, the inspectors determined that the licensee was evaluating changes to the PHT planning process to address previously identified weaknesses.
The licensee declared the EHDFP pump inoperable on April 10, 1994, after failing to maintain header pressure during performance of procedure, 12-OHP 4030.STP. 120SF, Data Sheet No. 4.,
"Yard Piping Unobstructed Flow Test."
The licensee determined that valve, 12-ZRV-402, located on a
recirculation line back to the fire water storage tanks, had failed open due to deterioration of the valve internals.
This resulted in the diversion of some of the flow from the header to the tanks.
As a result, fire header pressure could not be maintained by the EHDFP and another fire pump autostarted as designed on low header pressure.
After repair of the valve, the licensee performed a
PNT in accordance with 12-OHP 4030.STP. 121HD, "Electric Driven Fire Pump Oper ability Test."
During this test, the relief setpoint of the valve was adjusted to the appropriate value.
The licensee successfully completed the procedure and declared the pump operable on June 4,
1994.
The inspectors reviewed this procedure and determined that the procedure only provided for a flowpath through 12-ZRV-402 and back to the storage tanks.
The inspectors determined that the procedure did not demonstrate the backpressure regulating function of the valve to maintain fire header pressure under load; therefore, the PNT did not verify the repair was successful and that the system was able to perform as designed.
However, the system was able to provide the required flow to the fire header during flow testing performed later that day.
The inspectors determined that PHTs were normally assigned by planners from the department that had the lead for the specific job order activity.
System engineers would normally not review the PMT requirement to verify that it was adequate unless requested by the planner.
The system engineer did not review the PHT for the repair of valve 12-ZRV-402.'n June 28, 1994, the licensee declared the ENDFP inoperable because of a fitting leak on valve 12-ZRV-402.
This time, the system engineer was involved in the planning process to ensure that an adequate PHT was performed.
For the PHT, the system engineer made a one time revision to procedure, 12-OHP 4030.STP. 121HD, to simulate a load on the header by using the alternate recirc test line back to the storage tanks, to verify that valve 12-ZRV-402 was able to maintain header pressure.
~
The inspectors determined that the licensee had identified a
similar discrepancy regarding PHT.
The Unit 2 CD Emergency Diesel Generator (EDG) was out of service (OOS) for planned corrective maintenance on July 19, 1994.
One of the activities performed was the replacement of the engine-driven fuel oil pump.
For PHT, the licensee performed routine surveillance 02-OHP 4030.STP.027CD,
"CD Diesel Generator Operability Test (Train A)," that required loading the EDG to only half the designed capacity (1750 kw).
The operators declared the EDG operable at 0814 on July 20, 1994.
After the EDG was declared operable, the system engineer determined through review of control room logs that an inadequate PHT was performed on the EDG.
The EDG was tested under full load later in the evening of July 20, 1994, and declared operable.
Despite the delay in doing the correct PMT, there were no Limiting Conditions of Operation
exceeded based on the original time the EDG was taken OOS.
The licensee wrote condition report 94-1446 to investigate this problem.
The inspectors'ere concerned that for non-routine corrective maintenance, such as the activities discussed above, the planners may not have an adequate background in the operation of a system to ensure that appropriate PHT would be performed.
The licensee has recently issued procedure PHSO. 154, "Planning of Post Maintenance Testing Activities," that outlines the circumstances when planners should request engineering review of a job order for PHT.
The effectiveness of, implementation of procedure PHSO. 154,
"Planning of Post Maintenance Testing Activities" is considered an Unresolved Item pending further review by the NRC (50-315/94014-06(DRP).
Action Re uest AR Ta s on the Control Room Panels:
In response to a concern identified by the inspectors, an audit conducted by the licensee revealed that several Action request (AR) tags remained attached to components in the control room, despite resolution of the deficiencies documented on the tags.
On July 18, 1994, during a routine walkdown of the control room panels, the inspectors found that some AR tags remained attached to components although the conditions documented on the tags had been corrected.
In response, the inspectors notified operations personnel, who initiated an audit of all tags located on the control room panels.
The licensee's audit resulted in the removal of 15 tags from Unit 2 and 5 tags from Unit 1 due to either corrective action that was completed or ARs that were rejected.
During a subsequent walkdown, the inspectors identified an additional tag which required removal.
The inspectors reviewed results of the licensee's guality
. Assurance (gA) audits/surveillances performed in 1993 identified the following:
gA audit report gA-93-04, dated April 8, 1993, identified that 20 of 90 AR tags reviewed in the auxiliary and turbine buildings were not removed for actions that had been completed.
gA documented the deficiency in CR¹93-528 and, as preventative action, the licensee revised procedure NPM-02CH, "Corrective Maintenance Process Instruction," to require the individual rejecting a AR to remove the tag.
NPH-02CH already contained instructions that required removal of tags upon completion of the primary corrective maintenance activities.
gA surveillance 12-93-58 report, dated November 8, 1993, documented a similar discrepancy.
~
gA surveillance report 12-93-63, dated December 16, 1993, identified that ll out of 91 tags posted in the Unit 2 control room should have been previously removed.
In response, a licensee scheduler sent an e-mail message to all plant personnel requesting that, upon completion of corrective maintenance, the primary planner for the job should verify removal of the tag during the review of the AR for close-out.
This process was apparently never formalized or effectively implemented.
The failure to remove AR tags may inhibit personnel from initiating new ARs when similar equipment problems reoccur.
Also, the failure to remove outdated AR tags could result in an inaccurate assessment by the reactor operators and others in the plant of the condition of plant components.
The failure to remove AR tags which was previously identified by the licensee'A organization is considered an Unresolved Item pending further review by the NRC (50-315/94014-07(DRP);
50-316/94014-07(DRP)
.
d.
Surveillance Activities (61726)
During the inspection period, the inspectors observed technical specification required surveillance testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that results conformed with technical specifications and procedure requirements and were reviewed, and that any deficiencies identified during the testing were properly resolved.
The inspectors witnessed or reviewed portions of the following surveillances:
~
OHP 4030.STP.027CD,
"CD Diesel Generator Operability Test," Revision
~
IHP 4030.STP. 111, "Pressurizer Pressure Protection Set I Functional Test and Calibration," Revision
~
2 IHP 4030.STP. 104,
"Overtemperature E Overpower Protection Set I Surveillance Test," Revision
~
2 IHP 4030 STP. 148,
"Containment Pressure Set III Surveillance Test,"
Revision
~
OHP 4021.082.018,
"Racking In and out Reactor Trip, Reactor Trip Bypass, and HG Set Output Breakers,"
Revision
No violations or deviations were identified.
En ineerin 5 Technical Su ort (37700)
The inspectors monitored engineering and technical support activities at the site including any support from the corporate office.
The purpose was to assess the adequacy of these functions in contributing properly to other functions such as operations, maintenance, testing, training, fire protection, and configuration management.
'a ~
Batter Grounds On July 18, 1994, the operators received a "hard ground" on the Unit
"CD" battery.
The positive polarity read "0" volts
'ndicating that the positive polarity of the 250 battery system was grounded.
The
"CD" battery is one of two 250-volt safety-related batteries which is by design an ungrounded system.
With one of its two polarities grounded, the inspectors were concerned that another ground on the opposite polarity may result in loss of equipment supplied by the
"CD" battery.
The
"CD" battery for Unit 1 supply both safety and non-safety related loads.
The inspectors observed that the reactor operator (RO) was removing fuses from the
"DC" branch circuits in an attempt to locate the ground.
The inspectors questioned whether this was the proper procedure or person to be removing fuses to locate grounds on the system.
The inspectors observed that the plant engineering personnel provided valuable assistance to the operators and the electricians on the proper use of the "ground hound" equipment.
The use of the
"ground hound" instrument eventually lead to the electricians successfully locating the source of the ground.
The inspectors'iscussion with the Maintenance Department Superintendent found that the electricians are improving in their ability to troubleshoot grounds as they get more proficient on the use of the
"ground hound" equipment.
Plant policy for locating and clearing grounds was discussed with operators, system engineers.
Also, the inspectors reviewed the training and equipment available to investigate grounded conditions to the operators and technicians.
After reviewing the plant's procedure 01-0HP-4021.082.012, Revision 3, and 02-0HP-4021.082.012, Revision 2, for unit 1 and 2 respectively, the inspectors made the following observations:
The operational procedures do not provide instruction for the operators relative to reporting intermittent grounds that alarm and clear without operator action.
The ground procedures are not clear as to limits on operator actions or when the electrical maintenance and engineering
departments become involved in locating grounds on
"DC" systems.
~
No instructions or guidance are provided in the operational procedures for electric maintenance activities or the use of portable detectors such as the "ground hound."
The licensee was in the process of revising the
"DC" ground procedures during the inspection period.
This item is unresolved pending completion of the procedure revision and NRC review (50-315/94014-08; 50-316/94014-08).
b.
Failure of a Cano Seal Weld The inspectors reviewed the licensee's engineering evaluation into the failure of the canopy seal weld lack of fusion on Unit 1 core exiting temperature nozzle assemblies (CETNAs).
During the Unit
refueling outage in early 1994, the licensee experienced weld failures on two of the five CETNA units shortly after entering NODE 3.
This condition was determined to be caused by inadequate weld penetration or lack of fusion on the upper flange of the weld joint.
The licensee elected to repair the leak using a multipass weld repair procedure.
The multipass weld procedure was a success and the unit was returned to service.
The licensee, with assistance from Westinghouse representatives, investigated the cause of the weld failures which included duplicating weld conditions experienced at the plant.
Several weld mock ups were proposed to validate a theory that combinations of sulfur mismatch between the upper and lower flanges produced a
weld puddle shift towards the weld member of lower sulfur content.
After performing several welds with flanges of different sulfur contents, the licensee concluded that the root cause of the canopy seal leaks observed on Unit 1 in 1994 could be attributed to the welding process that included procedures which did not
. sufficiently compensate for the sulfur mismatch between the upper and lower flanges.
The licensee plans to incorporate these factors into the welding procedure used to install the CETNAs during the upcoming Unit 2 outage.
No violations or deviations were identified.
Ins ection Followu Item Inspection Followup Items are matters which have been discussed with the licensee, which will be reviewed by the inspectors, and which involve some action on the part of the NRC or licensee or both.
Inspection Followup Items disclosed during the inspection are discussed in paragraphs 3.d and 4.a.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during the inspection are discussed in paragraphs 4.b, 5.b, 5.c, and 6.a.
Meetin s
and Other Activities a ~
b.
Mana ement Meetin s (30702)
On August 1 and 2, 1994, the Regional Administrator, Director of Reactor Safety and Director of Radiation Safety and Safeguards toured the D.
C.
Cook plant and met with licensee management to discuss plant performance and plant material condition.
Ex't Interview (30703)
The inspectors met with the licensee representatives denoted in paragraph 1 during the inspection period and at the conclusion of the inspection on August 19, 1994.
The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report.
The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
23