IR 05000315/1998007
| ML17334A735 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/03/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17334A734 | List: |
| References | |
| 50-315-98-07, 50-315-98-7, 50-316-98-07, 50-316-98-7, NUDOCS 9806110065 | |
| Download: ML17334A735 (51) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos:
License Nos:
50-315; 50-316 DPR-58; DPR-74 Report No:
50-315/98007(DRP); 50-316/98007(DRP)
Licensee:
Indiana and Michigan Power 500 Circle Drive Buchanan, Ml 49107-1395 Facility:
Donald C. Cook Nuclear Generating Plant Location:
1 Cook Place Bridgman, Ml 49106 Dates:
February 1 through April27, 1998 Inspectors:
B. L. Bartlett, Senior Resident Inspector B. J. Fuller, Resident Inspector J. D. Maynen, Resident Inspector Approved by:
Bruce L. Burgess, Chief Reactor Projects Branch 6
'80bi i00bS 980b03 PDR 'DQCK 050003iS
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EXECUTIVESUMMARY D. C. Cook Units 1 and 2 NRC Inspection Report 50-315/98007(DRP); 50-316/98007(DRP)
This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 5-week period of resident inspection and includes the followup to issues identified during previous inspection reports.
~oerations
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During routine walkdowns of selected engineered safety features systems, the inspectors
'dentified some equipment in poor material condition. Examples of items identified included bent and dirty motor air inlet screens on the residual heat removal (RHR) pumps, missing bolts on the containment hydrogen mixing system (CEQ) and electrical junctions boxes, with gaps on the CEQ system.
The inspectors concluded that these material condition issues did not render the CEQ system inoperable.
An unresolved item was opened to address the analysis of the open junction box on the operability of the CEQ system (Section 02.1).
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During an assessment of the distributed ignition system (DIS), the inspectors identified an unresolved item on the whether the DIS was required for beyond de'sign basis accidents.
The inspectors also identified inspector followup items on the initiating signals used to manually actuate DIS, possible water impingement on the DIS, and drawing discrepancies from the as-built configuration (Section 02.2).
During a routine plant tour, the inspectors identified loose hold down nuts on some of the divider deck barrier missile blocks. The licensee informed the inspectors that while these particular bolts were not known to be loose, this was a repetitive problem and had been evaluated.
As of the end of the report period, the licensee was unable to find the evaluation.
Pending the review of the evaluation, this issue remained unresolved (Section 02.3).
Maintenance During a review of the Technical Specification (TS) surveillances on the hydrogen recombiner, the inspectors identified:
1) an apparent violation for declaring the recombiner operable with recorded data which exceeded the TS limits, 2) an apparent violation for an inadequate procedure which failed to measure resistance to ground immediately following the heat up test, 3) an apparent violation for a procedure which, caused inconsistent performance of TS surveillances, and 4) an apparent violation for failure to correct a previously identified condition regarding preconditioning of equipment prior to a surveillance test (Section M1.2).
During a review of the surveillance testing program for the DIS the inspectors determined the licensee was performing surveillance test of measuring voltage and current of the igniters. The need to conduct visual verification of igniter energization or to measure
igniter temperature was identified as an inspection followup item (Section M1.3).
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The inspectors identified duct tape as being used as an installation aid that did not appear to be properly controlled by procedure.
In addition, during a review of the installation procedure for the divider deck barrier seals, the inspectors identified a step which appeared to authorize a blanket bypass of the 10 CFR 50.59 process.
Additional information was required to resolve the questions and two unresolved items were issued (Section M1.4).
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As noted in Sections 02.1, 02.2, 02.3, 02.4, and M1.2, the inspectors identified a number of material condition issues.
Most of the issues had not been recognized by licensee personnel and were long-standing (Section M2).
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During followup to a licensee identified blockage of a CEQ line, the licensee identified low flow rates in other lines and trains of both units'EQ systems.
The licensee determined that the low flow rates were attributed to the system design, inadequate pre-operational
.tests, and the failure to maintain a proper distribution of system flows. An apparent violation was identified for the failure to comply with 10 CFR 50.59 (Section E1.1)
During a review of power operated relief valve (PORV) operability, the inspectors identified a 2-year period in which one PORV did not have an operable backup air supply.
Following consultation with the Office of Nuclear Reactor Regulation, it was determined that the operability of the PORVs depends upon the operability of the associated backup air supply. An apparent violation was issued for a failure to comply with TS requirements upon discovery of an inoperable PORV (Section E8.1).
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No discrepancies were note Re ort Details Summa of Plant Status Units 1 and 2 remained in Mode 5, Cold Shutdown, during this inspection period. The unplanned outage was in response to NRC and licensee concerns with the operability of the containment recirculation sump and other engineering issues.
The unplanned outage has continued due to the discovery of other equipment operability issues identified by the NRC and the licensee.
I. 0 erations
Conduct of Operations 01.1 General Comments 71707 Using the referenced inspection procedures, the inspectors conducted frequent reviews of ongoing plant operations.
During observations of control room activities such as shift tumovers, operator response to annunciators, and equipment operation, the inspectors identified that control room personnel monitored and operated equipment in a professional manner.
Specific events and noteworthy observations are detailed in the sections below.
Operational Status of Facilities and Equipment En ineered Safet Feature S stem Walkdowns Both Units Ins ection Sco e 71707 The inspectors walked down selected portions of the containment hydrogen mitigation system, the distributed ignition system, the hydrogen recombiner system, and the residual heat removal (RHR) system.
The material condition issues of the containment hydrogen mitigation system and the RHR system are discussed below. The distributed ignition system and the hydrogen recombiner system are discussed in Sections 02.2 and 02.3, respectively.
b.
Observations and Findin s Containment H dro en Miti ation S stem CEQ During the walkdown of the CEQ system on February 4, 1998, the inspectors identified a number of material condition issues on each of the CEQ fan housings.
The inspectors identified missing bolts, missing nuts, electrical junction boxes with missing screws, one electrical junction box with gaps which could allow water entry, and extensive surface rust and corrosion. These material condition issues were most severe near Unit 2 CEQ Fan Number 2 (2-HV-CEQ-2), but similar issues existed to some extent on all four CEQ fan units.
The licensee had spent considerable efforts testing the CEQ system due to operability questions that had been self-identified (reference Inspection Report 50-315/97025,
N C5
Section E1.1). Significant management oversight and attention was provided during extensive system testing, but it appeared that licensee personnel were not looking for material condition issues.
No action requests, condition reports, or job orders were found to address any of the material condition issues identified during the inspectors'alkdown.
The licensee was informed of the material condition issues, and corrective action documents were initiated. Pending the licensee's assessment of the as found operability of the open electrical junction box, and additional inspector review, this willremain an Unresolved Item (50-316/98007-13(DRP)).
On February 11, 1998, Condition Report (CR) 98-0502 was written when licensee personnel identified that some of the missing bolts identified by the inspectors had previously been identified on January 20, 1998, and an action request (AR) submitted to correct the deficiencies.
However, the AR was rejected by planning department personnel who thought that the AR duplicated the existing job order.
However, when the job order was worked, the problem identified in the AR was not corrected because the work scope of the job order did not address the missing bolts. A new AR was written in order to repair the missing bolts.
RHRS stem During a waikdown of the RHR system on February 4, 1998, the inspectors identified material condition issues with the RHR pump motors. The inspectors identified that the inlet screens on the air cooling paths for the motors were bent, dirty, broken out, and did not fullycover the opening.
These conditions existed to some extent on all four motors (two motors per reactor unit) but were most severe on Unit 1. The inspectors informed the licensee and corrective action documents were initiated.
In addition, operations management reminded the non-licensed operators that it was part of their jobs to look for items such as this during their rounds.
During a walkdown of the RHR heat exchangers on February 23, 1998, the inspectors identified that a support to Safety Valve 1-SV-104E was missing a nut. The nut appeared to have vibrated loose leaving the support hanging from the pipe. The licensee's assessment determined that the inoperable support did not affect the operability of the Unit 1 East RHR train. Licensee personnel initiated a corrective action document.
Conclusions During routine walkdowns of selected engineered safety features systems, the inspectors identified examples of poor material condition. Examples of items identified included bent and dirty motor air inlet screens on the RHR screens, missing bolts on the CEQ system and electrical junctions boxes with gaps on the CEQ system.
The inspectors concluded that these material condition issues did not render the RHR system inoperable.
An
'nresolved item concerning the operability of the CEQ system with an open junction box was identifie @
02.2 0 erational Status of Containment H dro en Recombiners Both Units Ins ection Sco e 71707 Due to the number and type of operability questions identified by the NRC and licensee personnel on safety-related systems, the inspectors performed a detailed walkdown of an engineered safeguards features system.
Previous inspection reports have documented a
significant number of operability questions involving systems related to containment integrity; therefore, the inspectors selected the hydrogen recombiner system, another system related to containment integrity. Documentation reviewed included:
01(02)-Operations Head Procedure (OHP) 4023. Supplement (SUP) 005, Revision 0, "Supplement C5, Placing Hydrogen Recombiners In Service" Pre-operational (PO)-050-524, Electric Hydrogen Recombiner Pre-operational Test, dated January 17, 1975 PMP 1040.SES.001, Revision 1,"Safety Evaluation Screening" Observations and Findin s During a review of the procedure which directed the operation of the hydrogen recombiners, the inspectors questioned the portion of Emergency Operating Procedure (EOP) 01(2)-OHP 4023.SUP.005 which directed the operators to increase the power setting based upon post accident containment pressure.
The inspectors determined that the power settings were significantly higher than those that would be required during post accident conditions based upon the pre-operational test data and correction tables supplied in the vender technical manual
~ Engineering personnel evaluated the recommended power settings and informed the inspectors that the recommended power settings were set conservatively high to ensure that the recombiners would not exceed their full power ratings.
Inspector review of the settings determined that they were not conservative and that the settings reflected a change in the method used to operate the recombiners.
The inspectors noted that the EOP directed the operators to maintain temperature between 1,225'F and 1,400'F.
The operators used the recombiner control panel readout located inside containment to monitor the three thermocouples indicating recombiner heater temperature.
The licensee's response to Updated Final Safety Analysis Report (UFSAR)
Question 14.23.4 stated that the recombiners were to be controlled using only the power settings and that no instrumentation inside of containment was required for the proper operation of the recombiners.
The UFSAR also stated that the thermocoupies were provided for convenience during tests and periodic checkouts but were not necessary to assure proper operation of the recombiner.
While monitoring the thermocouples to ensure proper recombiner operation was a good practice, an extended period at high power could cause the recombiners to over-heat.
Monitoring the thermocouples and reducing power would ensure the recombiners were not damaged; however, this method of operation would require the use of instrumentation inside of containment.
Therefore, the EOP differed from the method of operation as described in the UFSA I'I
The inspectors reviewed the licensee's safety evaluation for the procedure change which modified the method used to operate the recombiners.
Although the safety evaluation did not result in a determination that the revised procedure was an Unreviewed Safety Question (USQ), the UFSAR should have been updated to reflect the change in operating methods.
Procedure PMP 1040.SES.001 required that a safety screening involving a change to a procedure referenced or implicitlyreferenced in the UFSAR required a full safety evaluation.
Even though the method of operation using just the power levels was referenced in the UFSAR, the safety evaluation screening performed on January 9, 1996, stated that a full safety evaluation was not required. The failure to perform a full safety evaluation on the change to the operating procedure for the hydrogen recombiners was a violation of 10 CFR Part 50, Appendix B, Criterion V, "Procedures, Instructions and Drawings" (50-315/98007-01(DRP); 50-316/98007-01(DRP)).
During routine observations of control room instrumentation on February 10, 1998; the inspectors observed that, both Unit 1 recombiners and one of the Unit 2 recombiners had high temperature alarm setpoints that were significantly lower than the alarm setpoint for the second Unit 2 recombiner.
The three recombiners with lower setpoints were around 1,000'F (a low of 960'F to a high of 1,060'F) while Unit 2 Recombiner 2-HR1 was set at approximately 1,380'F.
The licensee was informed and efforts to identify the cause of the discrepancy were begun.
During a surveillance test on 2-HR2 several weeks later, the IKC technicians confirmed that its high temperature alarm setpoint was too low and re-set it in accordance with their procedure and the plant setpoint document to the required 1,375'F.
Subsequently, the licensee determined that when the reactor operators performed
- 01(2)-OHP 4030.STP.013A(B), the 18-month surveillance, some of them would adjust the outer dial in order to better see the required 700'F limit. The operators were unaware that by doing so they were also changing the alarm setpoint.
When the operators were finished with the surveillance test they would leave the outer dial where they had moved it, inadvertently changing the alarm setpoint. This change did not affect the instrument's accuracy.
The inspectors reviewed the annunciator response procedure and determined that the procedure directed the operators to monitor the recombiner's temperature and reduce it ifnecessary.
Thus, the operators would have been confronted with an alarm coming in sooner than required, but the early alarm did not affect hydrogen recombiner operability.
Conclusions During a review of the hydrogen recombiner system, the inspectors identified a failure to followa procedure which resulted in a required update to the UFSAR not being initiated.
Additionally, the inspectors identified that alarm setpoints were inoperable due to operators not understanding the proper functioning of the controls to the recombiners.
0 erationalStatusof Distributed l nitionS stem DIS Both Units Ins ection Sco e
1707 As a result of the findings discussed in Sections 02.2 and M1.2 of this report, and earlier inspection reports, the inspectors performed an additional walkdown of an engineered
safeguards features system, and selected the distributed ignition system (DIS). As part of that walkdown, the inspectors reviewed the following documents:
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10 CFR 50.36, Technical Specifications
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10 CFR 50.44, Standards for Combustible Gas Control System in Light-water-cooled Power Reactors
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AEP:NRC 0500 Series letters on Hydrogen Control Program between the licensee and the NRC
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NRC Letter N81187 dated December 17, 1981, Safety Evaluation Report (SER)
on the Use of the DIS
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Design Change DC-12-2522, Distributed Ignition System
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UFSAR 14.3.6.4, Distributed Ignition System Observations and Findin s Ins ector ldentiflied Discre ancies Between the As-Built Confi uration and Desi n Drawin s of the Distributed I nition S stem On February 12, 1998, the inspectors performed a walkdown of the Unit 2 DIS. The system, as installed, was compared to the system described in the UFSAR. Several discrepancies were noted during the walkdown. The licensee was informed and condition reports were initiated.
The DIS igniter boxes are located in both upper and lower containment, arranged to give complete coverage of the containment volume where hydrogen may accumulate.
After a loss of coolant accident (LOCA), the containment atmosphere willbe a harsh environment, with high humidity and the possible presence of containment spray. The UFSAR described the boxes as watertight enclosures to protect the electrical components (transformer and wire splices) located within the box. The UFSAR drawing specified that silicone sealant be placed around bolt holes through the box to help maintain a water seal on the box. The inspectors requested the licensee to open a sampling of boxes for inspection of the interior. The inspectors identified that the boxes that were inspected did not have silicone sealant around bolt holes. Additionally, a DIS box in lower containment was identified where the electrical conduit leading into the box bottom did not make a watertight connection to the box. The opening would allow the harsh environment of containment to enter the box and possibly affect the electrical components inside.
The DIS relies on a thermal igniter for initiating hydrogen burning. The thermal igniter (a diesel engine glow plug) protrudes from the side of the igniter box. When the igniter is energized, the temperature of the igniter reaches approximately 1,550 to 1,700'F.
When a hydrogen-air mixture reaches the hot igniter, the mixture willbum and the flame will propagate away from the igniter and consume the available free hydrogen.
The UFSAR describes the igniter boxes as having a drip shield installed on the top of the box to prevent water from impinging on the igniter. Impingement of water on the igniter could
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quench the flame and prevent the igniter from causing the combustion of free hydrogen in the vicinity. The installation drawing showed a 30 degree canted lip on the end of the drip shield which extended over the igniter. The purpose of the lip was to prevent water which landed on top of the igniter shield from running over the edge and running down onto the igniter. The inspectors identified that on the boxes inspected, the drip shield had not been fabricated in accordance with the drawing, as no canted lip was present on the edge of the drip shield.
Pending inspector review of the design basis for the DIS and how the raised lip supported the design basis this willremain an Inspector Followup Item (50-315/98007-08(DR P)) ~
The inspectors identified that some DIS igniter boxes in upper containment were installed in the immediate vicinityof containment spray system (CTS) nozzles.
The CTS would be used in the post LOCA environment to remove heat from the containment, mitigating the temperature and pressure rise in containment.
The CTS nozzle emits a spray of water in a 60110 degree cone.
Placement of DIS boxes near CTS spray nozzles could cause the impingement of water on the igniter and possible flame quenching.
The inspectors identified that. one DIS box in Unit 1 upper containment was located within the spray cone, and numerous other boxes were located such that the spray may have impeded flame propagation from the igniter. The licensee declared the DIS inoperable, pending resolution of the spray impingement concern.
Pending inspector review of the design basis for the DIS and how the spray impingement may have affected the design basis, this will remain an Inspector Followup Item (50-315/98007-09(DRP)).
The inspectors reviewed the licensee's equipment qualification program status for DIS.
In response to the inspectors'uestions licensee personnel stated that the DIS was only required for beyond design basis accidents (DBA) and that, as such, 10 CFR 50.49 did not require that the DIS be environmentally qualified. Pending inspector review of the design basis for the DIS and whether the DIS is required to be environmentally qualified, this willremain an Inspector Followup Item (50-315/98007-10(DRP);
(50-316/98007-10(DRP)).
DIS Technical S eciflication Issues The inspectors discussed the lack of DIS TS requirements with the NRR Project Manager and the licensee staff. A letter from the NRC to the licensee dated April 10, 1989, informed the licensee that further review of hydrogen control for ice condenser plants would be completed as a generic issue.
10 CFR 50.44, Standards for Combustible Gas Control System in Light-water-cooled Power Reactors, required that ice condenser PWRs have systems and components necessary to establish and maintain safe shutdown and to maintain containment integrity.
10 CFR 50.36, TS requires that limiting conditions for operation be established for equipment required for safe operation of the facility.
The inspectors evaluated whether the DIS was a system that is required for the safe operation of the plant, but was not contained in the TS for the plant due to a failure to followup on the amendment submitted to the NRC for approval.
In response to the inspectors'uestions on the DIS, the licensee stated that the DIS is only required for beyond DBA. The inspectors'eview of th'e DIS did not identify any information which clearly supported the licensee's position. The question as to whether DIS was required
l'I Ir II CS
for DBA or beyond DBAsequences was important as to the resultant quality requirements on the DIS equipment.
The inspectors forwarded this question to the Office of Nuclear Reactor Regulation (NRR) for clarification. Pending the results of NRR's review of whether the DIS is required for design basis accidents, this willremain an Unresolved Item (50-315/98007-14(DRP);
(50-316/98007-14(DRP)).
0 erational Issues D. C. Cook Emergency Operating Procedures (EOPs) direct the operation of the DIS after a LOCAwhen a Phase B containment isolation occurred or when there were indications of inadequate core cooling. The NRC Safety SER issued on December 17, 1981, for interim operation of the DIS, listed the NRC requirement that DIS be actuated on receipt of a safety injection signal. The NRC position was that hydrogen generation in the reactor might commence prior to an accident progressing to the point of generating an automatic Phase B isolation signal.
The licensee replied to the SER requirement in a letter dated January 27, 1982. The licensee position was that it was neither practical nor necessary to require CTS and DIS actuation following receipt of a safety injection signal. The licensee concluded that the existing DIS actuation criteria was preferable to actuation of DIS following a safety injection signal. The inspectors were unable to identify any NRC correspondence that specifically approved the licensee position. Pending additional discussions with the licensee and NRR, the actuation criteria of DIS willremain an Inspector Followup Item (50-315/98007-11(DRP); 50-316/98007-11(DRP)).
Conclusions During an assessment of the DIS the inspectors identified an Unresolved Item on the whether the DIS was required for beyond design basis accidents.
The inspectors also identified Inspector Followup Items on the initiating signals used to manually actuate DIS, possible. water impingement on the DIS, and drawing discrepancies from the as-built configuration.
Reactor Missile Shield Cavi Cover Blocks Unit 2 Ins ection Sco e 71707 On February 12, 1998, the inspectors toured Unit 2 upper containment in order to identify possible ice condenser bypass flowpaths.
During the tour the inspectors identified loose bolts on the reactor missile shield cavity cov'er blocks and performed routine followup of the findings.
Observation and Findin s During a walkdown of containment, the inspectors found reactor missile shield block fasteners that were less than hand tight. Licensee craft personnel informed the inspectors that this problem was a result of compression of the seal material which resulted in relaxation of the applied fastener torque. The craft personnel also informed the inspectors that while these specific bolts were not known to be loose, that the
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problem was known to be recurring and that an evaluation had been performed to document acceptability of the condition.
The procedure which installed the missile blocks, 12-OHP 4050 Fuel Handling Procedure (FHP) 041, "Reactor Cavity Missile Block Removal and Re-installation," did not provide torque specifications and did not contain any requirement to check and re-tighten the fasteners after the blocks have been in place and settling occurred.
The inspectors contacted the containment system engineer to obtain the evaluation for further review.
As of the end of this inspection period, the evaluation had not been located.
The inspectors evaluated the possibility that loose missile block fasteners could allow upward movement of the blocks due to post accident differential pressure.
Sufficient surface area existed on the underside of the blocks that, ifexposed to the maximum expected 12 psi differential pressure between upper and lower containment stated in the UFSAR, the weight of the blocks could be overcome.
Upward movement of the blocks could create a gap in the divider barrier and could result in the creation of a bypass flow of steam around the ice condenser.
Licensee engineering personnel stated that loosening of the fasteners was a recurring problem due to delayed compression of seal material that relaxes nut torque. The licensee engineer's opinion was that as the blocks would lift, the seal should rebound upward, maintaining the sealing function. Upward travel of the blocks would be limited by contact with the loose nuts. The residents willreview a licensee evaluation of this condition. Pending inspector followup this willremain an Unresolved Item (50-316/98007-15(DRP)).
Conclusions During a'routine plant tour the inspectors identified loose hold down nuts on some of the divider deck barrier missile blocks. The licensee informed the inspectors that this was a repetitive problem and had been evaluated.
As of the end of the report period, the licensee was unable to find the evaluation.
Pending the review of the evaluation, this issue remained unresolved.
Miscellaneous Operations Issues 92700 08.1 Closed Licensee Event Re ort LER 316/96007 "Control Room Without Re uired Senior Reactor 0 erator for One and One Half Minutes Due to Personnel Error" On May 23, 1996, the Unit 2 Unit Supervisor received relief from an extra Senior Reactor Operator (SRO). The extra SRO had been overseeing screen house activities. Shortly after taking the watch, the extra SRO was paged and his assistance was requested in the screen house.
He then left the control room, failing to realize that the control room was left with no SRO. Approximately 90 seconds elapsed with the Unit 2 control room having no SRO present.
The licensee took aggressive corrective actions that went beyond the factors leading to this event.
Licensee management determined that the errors were limited to a single operating crew. Management had beguri to address performance concerns within the shift prior to this event, and subsequently took further action.
Licensee management
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believed that shift teamwork and communications were insufficient to accomplish tasks at an acceptable level. Therefore, the shift was relieved of operating responsibility and given an opportunity to identify, correct, and practice the needed skills in a training environment.,There was no concern identified pertaining to individual operator knowledge or performance.
This event was discussed and addressed in Inspection Report 50-315/96005 and a Non-Cited Violation was issued, this LER is closed.
II. Maintenance M1 Conduct of Maintenance M1.1 General Comments a.
Ins ection Sco e 62707and61726 Portions of the following maintenance job orders, action requests, and surveillance activities were observed or reviewed by the inspectors:
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- 12THP 6030.
Instrument Maintenance Procedure (IMP).140, Revision 1,
"Electric Hydrogen Recombiner Instrumentation Calibration"
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12 Instrument Head Procedure (IHP) 4030.STP.604, Revision 1, "Hydrogen Recombiner Surveillance"
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- 12 Maintenance Head Procedure (MHP) 4030.STP.039, Revision 1, "Upper and Lower Containment Compartments Seal Material Inspection"
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12 IHP 4030.STP.604, Revision 1, "Hydrogen Recombiner Surveillance" b.
Observations and Findin s The inspectors concluded that the observed work activities were performed in a quality manner with procedures present and in use.
During the calibration of the Unit 2, Number 2 hydrogen recombiner (2-HR2) the inspectors observed the l8C technicians use three-way communications and question each other to ensure the procedure was properly followed. During the observations of electrical maintenance workers performing STP.604 on the hydrogen recombiners, the inspectors noted the electricians carefully reviewed the procedure and attempted to followthe guidance given within the procedure.
M1.2 H dro en Recombiner Maintenance and Surveillance Activities Both Units Ins ection Sco e 61726 and 62707 As part of the assessment of the hydrogen recombiners discussed in Section 01.2, the inspectors reviewed the maintenance work history and surveillance procedures, and observed selected surveillance activities. Procedures reviewed and observed included:
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Vendor Technical Document (VTD)- Westinghouse (West) - 0561,
"Westinghouse Technical Manual For The Electric Hydrogen Recombiner" r
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'* 12 Engineering Head Procedure (EHP) 4030 Surveillance Technical Procedure (STP) 206.2, Revision 1, "Electric Hydrogen Recombiner¹2 Surveillance"
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Reoccurring Job Order R0056782, Completed June 17, 1997, Perform Unit 1
'*12 EHP 4030 STP.206.2
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12 IHP 4030.STP.604, Revision 1, "Hydrogen Recombiner Surveillance" Observations and Findin s The inspectors identified a number of problems with the maintenance and surveillances on the hydrogen recombiner system.
Resistance Measurements During a review of the past work history on the recombiners, the inspectors identified that on June 17, 1997, licensee personnel had tested the resistance to ground on the Unit 1 Number 2 recombiner (1-HR2) immediately following an operational test as required by TS Surveillance Requirement 4.6.4.2.b.4.
The TS required that resistance be greater than 10,000 ohms; however, licensee personnel had measured only 6,000 ohms.
Approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the surveillance test, maintenance technicians measured the resistance to be greater than 12,000 ohms. The TS surveillance required that the resistance to ground be measured immediately following the heat up test. The hydrogen recombiner was declared operable based upon the resistance to ground being greater
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than the TS requirement after the recombiner had cooled. The failure to comply with TS Surveillance 4.6.4.2.b.4 which required the resistance to ground be greater than or equal to 10,000 ohms immediately following the required functional test was an apparent violation (EEI 50-315/98007-02).
Licensee personnel stated that due to the high temperature effect on the ceramic insulators, resistance values measured while the heaters were still hot would be low.
Licensee personnel also pointed out that the TS surveillance requirement for Unit 2 did not include the requirement for measuring the resistance to ground immediately following the heat up test and the standard TS did not include the "immediately following" requirement.
The test performed on June 17, 1997, was the only test performed immediately following the heatup within a 4-year review of similar tests.
A review performed by the licensee did not identify why this test had data taken so quickly following the heat up test.
A review of other surveillances on the hydrogen recombiners showed that due to delays in placing the clearance order, the data had been taken when the heaters had cooled
t
sufficiently that the resistance was greater than the TS minimum. The failure of the surveillance procedure to followthe TS surveillance requirement of "immediately following"was an apparent violation of 10 CFR Part 50, Appendix B, Criterion V,
"Procedures, Instructions and Drawings" (EEI 50-315/98007-03).
Structural Connections Technical Specification Surveillance 4.6.4.2.b.1, required a visual examination of the hydrogen recombiner and verification of no loose structural connections.
The inspectors reviewed the licensee's surveillance procedures, observed one electrical crew perform TS Surveillance Procedure 12 IHP 4030.STP.604 (which implemented Surveillance
'Requirement 4.6.4.2.b.1) on one recombiner. (1-HR2), and interviewed the electrical crew
'hich had recently performed the same surveillance on Unit 2 recombiner Number 2 (2-HR2). The crews performed visual checks as required by the TSs but did not physically check the structural connections.
Coincidentally, plant personnel were performing material condition walkdowns of various plant systems several days following the performance of Surveillance 12 IHP 4030.STP.604 and found that on Unit 1 hydrogen recombiner Number 1 (1-HR1), two of four recombiner enclosure to skid mounting bolts on the east side were loose. A condition report was written to document the finding, and an action request (AR) was written to check the condition of the mounting bolts of the other hydrogen recombiners.
Prior to the performance of the AR, the inspectors performed a walkdown of the Unit 2 recombiners and identified a loose recombiner enclosure to skid mounting bolt on the Unit 2 Number 1 recombiner (2-HR1). Licensee personnel were informed and a condition report was written. The loose bolts were not visually identifiable and as such would not have been identified during a visual inspection.
In addition to checking for loose structural connections, TS 'Surveillance 4.6.4.2.b.1 required the visual verification of no loose electrical connections within the recombiners.
The inspectors determined that the electrical crew which performed the Unit 1 surveillance checked the electrical connections within the recombiner enclosure and within the electrical junction boxes attached to the recombiner, but the electrical crew which performed the Unit 2 surveillance only checked the connections within the enclosure.
The cause of the different crew performance was a lack of guidance contained within the Surveillance Procedure 12 IHP 4030.STP.604.
The inspectors concluded that the surveillance procedure was not appropriate to the circumstances in that it did not provide adequate guidance to the electrical crews to ensure that all appropriate electrical connections were checked.
The failure to have a procedure appropriate to the circumstances is an apparent violation of 10 CFR Part 50, Appendix B, Criterion V, "Procedures, Instructions and Drawings" (EEI 50-316/98007-04)..
Potential Preconditionin D. C. Cook TSs required two separate recombiner heat up tests every 18 months.
Technical Specification Surveillance 4.6.4.2.a required a recombiner heat up,test to z 700'
every 18 months and TS 4.6.4.2.b.3 required a recombiner heat up test to
~1,200'F every 18 months.
Both surveillances have a ramp rate requirement and a hold time requirement.
The 4.6.4.2.a surveillance requirement was being implemented by licensee procedure **01(2)-OHP 4030.STP.013A(B) and was being performed shortly
after (a little over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) the 4.6 4.2.b.3 surveillance test. The licensee procedure which implemented the 4.6.4.2.b.3 surveillance requirement was
- 12 EHP 4030 STP.206.1(2).
The inspectors analyzed the data taken for each of the tests and determined that the apparent heat up rate for the second test was significantly quicker than the heat up rate for the first test. The inspectors concluded that the recombiners had not been allowed to cool to ambient temperatures between the tests and that the first test invalidated the second test.
However, a review of the data from the first test performed indicated that the hydrogen recombiners were functioning correctly.
Following the inspectors'uestioning of the pre-conditioning of the second test, the licensee combined the two tests into one procedure and ensured that the data recorded in subsequent tests could meet both TS surveillance requirements.
In NRC Inspection Report 50-315/95013, dated February 8, 1996, the NRC identified previous examples of TS surveillance tests being pre-conditioned.
As part of the corrective action to that violation the licensee performed a review of TS surveillance tests in order to identify and correct pre-conditioning issues.
The failure of test procedure
- 01(2)-OHP 4030.STP.013A(B) to have instructions necessary to ensure that an activity affecting quality (TS surveillance testing) was properly accomplished is an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI,"Corrective Action" (EEI 50-315/98007-05); (EEI 50-316/98007-05).
During the observation of the work being performed on recombiner 1-HR2 during surveillance 12 IHP 4030.STP.604, the inspectors observed the electricians perform a general walkdown of the exterior of the recombiner.
Following the electricians walkdown, the inspectors performed a separate walkdown. The inspectors identified an unsealed opening on the thermocouple junction box (J-box). The electricians were informed and prior to the surveillance being completed the J-box opening was sealed.
The inspectors'etermined that the J-box contained thermocouple extension wire. As the thermocouple wire was open to the post accident atmosphere inside of the recombiner, the open J-box did not affect the operability of the thermocouples.
Conclusions During a review of the TS surveillances on the hydrogen recombiner, the inspectors identified:
1) an apparent violation for declaring the recombiner operable with recorded data which exceeded the TS limits, 2) an apparent violation for an inadequate procedure which failed to measure resistance to ground immediately following the heat up test, 3) an apparent violation for a procedure which caused inconsistent performance of TS surveillances, and 4) an apparent violation for failure to correct a previously identified condition regarding preconditioning of equipment prior to a surveillance test.
M1.3 a.
Technical S ecification Surveillance Questions on the Distributed I nition S stem Both
~Units Ins ection Sco e 61726 As part of the assessment of the DIS discussed in Section 01.3, the inspectors'lso reviewed the maintenance work history, reviewed surveillance procedures, and observed selected surveillance activities. Procedures reviewed and observed included:
~
AEP:NRC 0500 Series Letters on Hydrogen Control Program between the licensee and the NRC
~
NRC Letter N81187 dated December 17, 1981, Safety Evaluation Report on the Use of the DIS
~
12 Instrument Head Procedure (IHP) 5030.
Electrical Maintenance Procedure (EMP).008, Revision 3, Distributed Ignition System Test b.
Observations and Findin s The inspectors reviewed the correspondence between the licensee and NRC during the period that the DIS was designed and installed. AEP:NRC Letter 0500C dated May 29, 1981, provided licensee commitments on periodic testing of the DIS. Specifically, the licensee proposed that the 18-month surveillance would verify energization of the igniter through visual observation of the glow plugs.
The Safety Evaluation Report on the use of the DIS, NRC Letter N81187 dated December 17, 1981, stated that the NRC would require that the pre-operational testing of the DIS include measurement of igniter temperatures and that the surveillance testing of the system should also include temperature measurements.
The licensee surveillance on the DIS, performed in accordance with 12 IHP 5030.EMP.008, Distributed Ignition Test, verified the voltage and current readings for each phase of the igniters. The surveillance did not perform visual verification of igniter energization or measure igniter temperature.
The inspectors questioned the licensee concerning the adequacy of the surveillance testing of DIS.
Distributed ignition system was declared inoperable on March 11, 1998, pending resolution of the surveillance testing questions.
The inspectors willcontinue to evaluate whether the DIS was being properly tested and this willremain an Inspection Followup Item (50-315/98007-12(DRP)).
Conclusions During a review of the surveillance testing program for the distributed ignition system the inspectors determined the licensee was performing surveillance test of measuring voltage and current of the igniters. An Inspection Followup Item concerning the need to perform visual verification of igniter energization or to measure igniter temperature was identified.
@
M1.4 Divider Deck Barrier Seals Procedural Questions Both Units Ins ection Sco e 62707 During a routine walkdown of the Unit 2 containment, the inspectors observed red duct tape located on the bulkhead seals.
The bulkhead seals form a portion of the divider deck barrier seals, and are important for the proper separation of the upper and lower containment.
It appeared to the inspectors that the tape had been used as an aid while re-installing the seals following the refueling outage.
The inspectors performed follow up to identify the purpose of the duct tape and ensure that it was being properly controlled.
b.
Observations and Findin s Interviews with the system engineer confirmed that the tape had been used to hold a portion of the flexible seal in place while its steel backing was bolted together.
Red duct tape was routinely used on both unit's bulkhead seals.
The engineer gave the inspectors a copy of the engineering technical direction memo (ETDM 97-067) that authorized the use of the tape.
The ETDM stated that because the tape ended up being bolted in place and secured by the steel backing, it would not become a source of debris to the recirculation sump.
The inspectors agreed that while secured in that manner, the tape had a small probability of becoming loose, but noted that the procedure had no specific steps directing that the tape be installed in a consistent manner.
The system engineer was informed of the inspectors'omment and stated that the tape usage would be reviewed.
Pending the inspectors review of additional information on the appropriateness of the use of duct tape inside'of containment this willremain an Unresolved Item (50-315/98007-16(DRP);
(50-316/98007-16(DR P)
During further review of the installation procedure, the inspectors noted that Step 6.3, stated, "Seal material configuration may vary with... engineering approval. Approval shall be documented in Job Order Activity." The inspectors discussed Step 6.3 with the system engineer and stated that this step appeared to give a blanket approval to violate 10 CFR 50.59, "Safety Evaluations." The engineer agreed that the step did appear to give blanket approval and stated the step would be reviewed.
The engineer was not sure as to whether the "blanket approval". had been appropriately reviewed when the step had been inserted into the procedure.
Pending the receipt of additional information on Step 6.3, this willremain an Unresolved Item (50-315/98007-17(DRP);
(50-316/98007-17(DR P)).
Conclusions The inspectors identified duct tape as being used as an installation aid that did not appear to be properly controlled by procedure.
In addition, during a review of the installation procedure for the divider deck barrier seals, the inspectors identified a step which appeared to authorize a blanket bypass of the 10 CFR 50.59 process.
Additional information was required to resolve the questions and two Unresolved Items were issued.
~i
M2 Maintenance and Material Condition of Facilities and Equipment
2teisect As noted in Sections 02.1, 02.2, 02.3, 2.4, and M1., h n p ors identified a number of material condition issues.
Most of the issues had not been recognized by licensee personnel and were long standing.
Examples of the material condition issues were an unsealed opening in a J-box to a hydrogen recombiner, loose mounting bolts on hydrogen recombiners, loose hold down nuts on some of the divider deck barrier missile blocks, a DIS box in lower containment was identified where the electrical conduit leading into the box bottom did not make a watertight connection to the box, RHR pump motor air inlet screens that were bent and dirty, missing bolts and electricai J-boxes with gaps on the CEQ system.
M8 Miscellaneous Operations Issues 92700 M8.1 Closed Licensee Event Re ort LER 315/98009
"Interim LER - H dro en Recombiner Surveillance Re uirement Not Bein Met Results in Unanala ed Condition" Following the identification by NRC inspectors that the Unit 1 hydrogen recombiner surveillance test performed on June 17, 1997, had failed its acceptance criteria, the licensee performed a review of the surveillance test data.
This LER reported that the licensee failed to comply with the TS surveillance requirements.
This issued is being tracked by the NRC in resolution of Apparent Violation EEI 50-315/98007-02.
Therefore, this LER is closed.
III. En ineerin E1 Conduct of Engineering I
E1.1 Closed Unresolved Item 50-316/97024-03 DRP Inadvertentl Plu ed H dro en Skimmer Suction Line Unit 2 a.
Ins ection Sco e 62707 Licensee personnel had identified operability questions on a Unit 2 containment hydrogen skimmer suction line (referred to as the CEQ system).
In response to the operability questions licensee personnel performed flowtesting of the CEQ system and additional operability issues were identified. NRC Inspection Reports 50-315/97024, and 50-315/97025 discussed the licensee's identification and followup of the CEQ operability questions.
Additional documentation reviewed in this report period included:
~
LER 50-316/97009-00, Blockage of Containment AirRecirculation Inlet Line
~
LER 50-315/98001-00 and Revision 1, Containment AirRecirculation System Flow Testing Results Indicate Condition Outside The Design Basis Observations and Findin s In LER 50-315/98001, dated March 6, 1998, the licensee stated that with regards to both units that, ".. ~ certain flows in the steam generator and pressurizer compartments, fan-
Ji'
accumulator rooms, and instrument room were found to be less than the flows stated in UFSAR Section 5.5.3." The licensee attributed the low flows to errors in initial system design, inadequate pre-operational testing, and to the system not being properly flow balanced.
The licensee's testing and analysis of the as-found condition of the CEQ system identified six flow paths with less than the UFSAR, Chapter 5, flow rates.
The licensee identified the Unit 1 low flow paths as the Train B flowfrom the pressurizer space, the Train A flowfrom the pressurizer space, the flowfrom the instrument room, and the flowfrom the containment dome. The licensee identified the Unit 2 low flows paths as the Train A flowfrom the pressurizer space and the containment dome.
Following the identification of the low flow paths the licensee re-balanced the system.
In order to add extra margin increased the size of the piping from the pressurizer space from 6" to 8". In addition, the damper that was mis-positioned (1-VMO-101) was corrected and other similar dampers were inspected to ensure they were properly installed.
The licensee performed an evaluation of the as found condition to determine the safety significance of the low flows. The licensee determined that all areas except for the instrument room and the fan-accumulator rooms would remain below the 4 volume percent hydrogen required by the design basis.
However, the assumptions used for this evaluation were less conservative than those contained in UFSAR, Chapter 5, or UFSAR, Chapter 14, "Accident Analysis." The analysis for the instrument room and'the fan-accumulator rooms had not been completed as of the issuance of the LER.
The TSs required that the CEQ systems be operable in Modes 1, 2, 3, and 4. While the CEQ systems may have met all stated TS requirements, the licensee identified that the CEQ systems would not meet the design bases.
Operation of both units in Modes 1, 2, 3, and 4 with the CEQ systems outside of their design bases since initial licensing is an apparent violation of 10 CFR 50.59 (EEI 50-315/98007-06; EEI 50-316/98007-06)
Conclusions During followup to a licensee identified blockage of a containment hydrogen mixing (CEQ)
line, the licensee identified low flow rates in other lines and trains of both units'EQ systems.
The licensee determined that the low flow rates were attributed to the system design, inadequate pre-operational tests, and the failure to maintain a proper distribution of system flows. An apparent violation was identified for the failure to comply with 10 CFR 50.59.
ES Miscellaneous Engineering Issues E8.1 Closed Unresolved Item 315/96011-03 0 erabili of Pressurizer Power 0 crated Relief Valves POR Without Backu AirSu lies Both Units Ins ection Sco e 37551 During a review of the licensee's maintenance practices on the pressurizer PORV air line check valves, the inspectors developed questions regarding the operability of the PORVs without backup air (in Modes 1, 2, and 3). From August of 1992 until October of 1994, a Unit 2 PORV (2-NRV-152) did not meet its stroke time requirements due to excessive air line check valve leakage.
During that time, the licensee did not declare the PORV
Cl
Licensee personnel informed the inspectors that operability of the PORVs did not require the emergency backup air system.
The inspectors questioned this position and requested the Office of Nuclear Reactor Regulation (NRR) to perform a review of the licensee's position. Licensee and NRC documents reviewed included:
NRC Generic Letter 90-06, "Resolution of Generic Issue 70, Power-Operated Relief Valve and'Block Valve Reliability, and Generic Issue 94, Additional Low-Temperature Overpressure Protection For Light Water Reactors, Pursuant to 10 CFR 50.54(f)"
AEP:NRC:1131, Letter between the licensee and NRC dated December 21, 1990
~
AEP:NRC:1131A, Letter between the licensee and NRC dated April 16, 1991
~
AEP:NRC:1131B, Letter between the licensee and NRC dated January 6, 1993
~
Technical Specification Amendment Number 176 (Unit 1) and 161 (Unit 2), issued by NRC on March 9, 1994
~
Technical Specification 3.4.11, Reactor Coolant Relief Valves - Operating
~
Action Request A0026389, dated August 3, 1992, PORV 2-NRV-152 failed to stroke properly using emergency backup air
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Job Order C0011060, October 1994, Replaced Check Valve 2-CA-711
~
Job Order C0026749, October 1994, Replaced brass check valve with soft seat check valve for 2-CA-711
~
LER 50-316/98001-00, PORV 2-NRV-152 Inoperable Due to Inoperable Backup AirSupply Observations and Findin s On March 9, 1994, TS Amendment 161 was issued by NRC. The amendment added Surveillance Requirement 4.4.11.1.c and required that at least once per 18 months that the solenoid air control valves and check valves in the PORV control systems be operated through one complete cycle of full travel. On August 3, 1992, PORV 2-NRV-152 was stroked using the backup air supply. The valve failed to stroke within the required 6 seconds.
The cause of the failure was determined to be a leaking normal air header check valve (2-CA-711)..During the test, the leaking check valve allowed the backup air to leak into the normal air header and prevented the PORV from receiving an adequate supply of pressurized air.
At the time of the surveillance test, TS Amendment 161 had not been issued and the job order to repair the check valve was delayed until the next refueling outage.
Subsequently, on March 9, 1994, the amendment was issued and on October 5, 1994, the check valve was repaired, restoring the PORV to an operable status.
The delay to repair the check valve from constituted an apparent violation of TS 3.4.11 which required that with a PORV inoperable due to causes other than excessive seat leakage it should
I iJ S
either be restored to operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The failure to comply with TS Requirements 3.4.11 is an apparent violation (EEI 50-316/98007-07).
Conclusions During a review of power operated relief valve operability the inspectors identified a 2-year period in which one PORV did not have an operable backup air supply.
Following consultation with the Office of Nuclear Reactor Regulation, it was determined that the operability of the PORVs depends upon the operability of the associated backup air supply. An apparent violation was issued for a failure to comply with TS requirements upon discovery of an inoperable PORV.
IV. Plant Su ort P5 Staff Training and Qualification in EP P5.1 Closed Unresolved It'em 50-315/97015-02 DRP '0-316/97015-02 DRP: Emergency Response Organization Respirator Qualifications (Both Units). During a review of an Operating Experience report, the licensee identified that the program for maintaining operator respirator qualifications did not include a provision for ensuring that the operators maintained corrective lenses available when necessary.
The program also failed to include an annual respirator fittesting requirement for members of the Emergency Response Organization (ERO) who were required to be respirator qualified.
Corrective lens inserts were distributed to the operators, and all members of the ERO have been qualified to use a respirator.
The licensee planned to implement a tracking program to ensure that supervisors were notified prior to an employee's respirator qualification expiration. These actions appeared adequate to prevent a recurrence of the respirator qualification issue.
The inspectors noted that the licensee's ERO respirator qualification requirements were more comprehensive than the industry standard.
As a result, the inspectors concluded that the safety significance of some of the ERO members riot being respirator qualified was minor. This item is closed.
R1 Radiological Protection and Chemistry Controls (71750)
During the resident inspection activities, routine observations were conducted in the areas of radiological protection and chemistry controls using Inspection Procedure 71750.
No discrepancies were noted.
S1 Conduct of Security and Safeguards Activities (71750)
During normal resident inspection activities, routine observations were conducted in the areas of security and safeguards activities using Inspection Procedure 71750.
No discrepancies were noted.
F1
-
Control of Fire Protection Activities (71750)
During normal resident inspection activities, routine observations were conducted in the area of fire protection activities using Inspection Procedure 71750.
No discrepancies were noted.
V. Mana ement Meetin s X1 Exit Meeting The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on March 12, 1998. The licensee had additional comments on some of the findings presented.
No proprietary information was identified by the licensee.
Ill
PARTIALLIST OF PERSONS CONTACTED
~
Licensee
¹M. Ackerman, Nuclear Licensing
¹K. Baker, Manager, Production Engineering
¹A. Blind, Vice-President Engineering
¹J. Boesch, Maintenance Superintendent
¹S, Brewer, Regulatory Affairs
¹D. Cooper, Plant Manager
¹S. Delong, Management Information
¹L. Demarco, Nuclear-System Engineering
¹MB. Depuydt, Nuclear Licensing
¹M. Eberhardt, Nuclear Licensing
¹S. Farlow, Supervisor I&C Engineering
¹R. Gillespie, Operations Superintendent
¹MB. Greendonner, Fire Protection Supervisor
¹D. Hafer, Manager, Plant Engineering
¹P. Holland, Radiation Protection
¹A. Lofti, Performance Engineering
¹D. Morey, Chemistry Superintendent
¹F. Pisarsky, Supervisor, Mechanical Component Engineering
¹T. Postlewait, Manager, Design Engineering
¹T. Quaka, Project Management 8 Instrument Services
¹P. Schoepf, Supervisor, Safety-Related Mechanical Systems
¹J. Stubblefield, Scheduler
¹J. Tyler, Manager, Plant Protection and Emergency Preparedness
¹L. VanGinhoven, Materials Management
¹J. Wiebe, Performance Engineering
¹W. Zemo, Manager, Preventive Maintenance USNRC
¹B. Burgess, Branch Chief, Region III
¹Denotes those present at the March 12, 1998, exit meeting.
t'
IP 37551 IP 61726 IP 62707 IP 71707 IP 71750 IP 92700 INSPECTION PROCEDURES USED On-site Engineering Surveillance Observations Maintenance Observation Plant Operations Plant Support Activities Onsite Review of LERs ITEMS OPENED, CLOSED, AND UPDATED ITEMS OPENED 50-315/98007-01 50-316/98007-01 50-315/98007-02 50-315/98007-03 50-316/98007-04 50-315/98007-05 50-316/98007-05 50-315/98007-06 50-316/98007-06 50-316/98007-07 50-315/98007-08 50-315/98007-09 50-315/98007-10 50-316/98007-10 50-315/98007-11 50-316/98007-11 50-315/98007-12 VIO Failure to perform a full safety evaluation on the change to the operating procedure for the hydrogen recombiners EEI An apparent violation for declaring the recombiner operable with recorded data which exceeded the TS limits EEI An apparent violation for an inadequate procedure which failed to measure resistance to ground immediately following the heat up test EEI An apparent violation for a procedure which caused inconsistent performance of TS surveillances EEI An apparent violation for failure to correct a previously identified condition regarding preconditioning of equipment prior to a surveillance test EEI An apparent violation for failure to comply with 10 CFR 50.59 EEI An apparent violation for failure to comply with TS requirements upon discovery of an inoperable PORV IFI Review of the design basis for the DIS and how the raised lip supported the design basis IFI Review of the design basis for the DIS and how the spray impingement may have affected the design basis IFI Review of the design basis for the DIS and whether the DIS is required to be environmentally qualified IFI Unable to identify any NRC Correspondence that specifically approved the licensee position IFI DIS was declared inoperable on March 11, 1998, pending resolution of the surveillance testing questions
Clll (ill
50-316/98007-13 50-315/98007-14 50-316/98007-14 50-316/98007-15 50-315/98007-16 50-316/98007-16 50-315/98007-17 ITEMS CLOSED 50-316/96007 50-315/96011-03 50-315/97015-02 50-316/97015-02 50-316/97024-03 50-315/98009-00 ITEMS UPDATED None URI Pending the licensee's assessment of the as found operability of the open electrical junction box, and additional inspector review URI Review of whether the DIS is required for design basis accidents URI Upward travel of the blocks would be limited by contact with the loose nuts URI Review of additional information on the appropriateness of the use of duct tape inside of containment URI Pending the receipt of additional information on Step 6.3 LER Control Room without Required Senior Reactor Operator for One and One Half Minutes Due to Personnel Error URI Operability of PORVs with an Inoperable Backup AirSupply URI Emergency Response Organization Respirator Qualifications URI Inadvertently Plugged Hydrogen Skimmer Suction Line LER Hydrogen Recombiner Surveillance requirement not being met results in Unanalyazed Condition
Cll
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LIST OF ACRONYMS AEP bcc CCW CFR CR DCC DRP DPR EDT ENTDM ESF IHP IR JO LER LOCA Ml NCV NOV NRC NRR PDR SCFM SE SFP SM SP SRO STP S/G ST UFSAR URI American Electric Power blind carbon copy carbon copy Component Cooling Water Code of Federal Regulations Condition Report Donald C. Cook Division of Reactor Projects Demonstration Power Reactor Eastern Daylight Time Engineering Technical Direction Memo Engineered Safety Feature IRC Head Procedure
Inspection Report
Job Order
Licensee Event Report
Loss of Coolant Accident
Non-Cited Violation
Nuclear Regulatory Commission
Nuclear Reactor Regulation
Public Document Room
Standard Cubic Feet per Minute
Safety Evaluation
Spent Fuel Pool
Shift Manager
Special Procedure
Senior Reactor Operator
Surveillance Test Procedure
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item
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