IR 05000327/1997012
| ML20212F413 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/24/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20212F403 | List: |
| References | |
| 50-327-97-12, 50-328-97-12, NUDOCS 9711040278 | |
| Download: ML20212F413 (26) | |
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U,S, NUCLEAR REGULATORY ~ COMMISSION
REGION II
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Docket Nos: l50-327, 50 328-
. License Nos: DPR-77 DPR-79 Report No: 50-327/97-12. 50-328/97-12 Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant. Units 1 & 2 Location: Sequoyah Access Road Hamilton County, TN 37379 Dates: August 24 through September 27, 1997 Inspectors: M. Shannon Senior Resident Inspector R Starkey.. Resident Inspector D. Seymour, Resident Inspector B. Bearden Reactor-Inspector, Region II. (Section M8.1)
S. Sparks.._ Project-Engineer, Region II. (Section M2.1)
P. Harmon Operations Inspector, Region II,
.(Section 05)
L. Mellen, Operations' Inspector, Region II.
[ -(Section 05)
Approved by: M. Lesser, Chief - -
Reactor Projects Branch 6-Division of Reactor Projects Enclosure 2 9711040278 971024 PDR ADOCK 05000327'
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EXECUTIVE SUMMARY
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l Sequoyah Nuclear Plarit, Units 1 & 2 NRC Inspection Report 50-327/97-12. 50 328/97-12 ,
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- - This 1ntegra'ted inspection included aspects of licensee operation maintenance. engineering, plant support. and effectiveness of licensee controls in identifying resolving. and preventing problems: in addition, it
- includes the results of an announced inspection by a-Region II aroject
- engineer and an operator requalification program inspection by '.egion :II inspector Ooerations o' A non-cited violation was identified for failure to follow procedures-
'during an essential raw cooling water (ERCW) valve realignment (Section 0 1.2),
e Operations did not appro)riately apply technical specifications (TS)
with regard to residual leat removal system operability (Section 01.3)
e Assistant unit operators did not properly position the stator cooling water pump discharge valve which resulted in a momentary loss of stator cooling-(Section 01.4).
e The Requalification Program -is effective in maintaining licensed =
operator proficiency and knowledge. The Requalification examination was adequately discriminating and comprehensive (Section 05).
- e- One Weakness was identified regarding a lack of discrimination in the i _In-plant Job Performance Measures (JPMs) used as examination tool 'Four of the six-In-plant JPMs observed were considered too simplistic to-provide meaningful feedback to the Requalification Program (Section 05).
Maintenance e' Various maintenance and surveillance activities were adequately performed (Section M1.1).
e The licensee did not effectively review the impact of the longstanding
- poor material condition of the control air system on activities such as-clearance boundaries, which contributed to the dual unit run back and Unit I reactor trip on August 1,1997 (Section M2.1),
e- Replacement of the control air compressors is contributing to improved material condition of the plant (Section M2.1).
e The licensee had appropriately considered the August 1, 1997, transients and reactor trip in their maintenance rule program (Section M2.1).
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e The licensee conducted a thorough review of root and contributing causes, and corrective actions, for the control air system initiated
. _. transients on August 1. 1997 (Section M2.1).
Enaineerina o Back leakage from the reactor coolant system, due to leaking check valves, caused a pressure transient in the Safety Injection system. The leakage was within allowable limits and the system had previously been analyzed for the higher pressure. However, the licensee did not anticipate the problem. although the check valves were known to lea The licensee plans to repair the check valves at upcoming outage (Section E2.1).
e The relief valve setpoints for the safety injection system drifted high and appears to be a recurring problem. The licensee is in the process of determining the cause (Section E2.1).
Plant Sucogrt e The licensee's upgrade of the ERCW chlorination system should improve the overall efficiency of the system and reduce down-time due to leakage (Section R1.2).
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ReDort Details Summary of Plant Status Unit-1 began the inspection period in power operation. The unit operated at full power for the remainder of the inspection perio Unit 2 began the inspection period in power operation at 94%. The unit continued coast down during the inspection period and at the end of the insoection period power output was at 74%.
Review of Uodated Final Safety Analysis Reoort (UFSAR) Commitments While performing inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that were related to the areas inspecte The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameter I. Doerations 01 Conduct of Operations
'p 01.1 General Comments (71707)
Using Inspection Procedure 71707 the inspectors conducted frequent reviews of ongoing plant o In general, the conduct of operations was acceptable.peration .2 Personnel Errors Result in Essential Raw Coolina Water (ERCW) Valve
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Misalionment Insoection Scooe (71707)
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The inspector reviewed the circumstances related to errors made by operations personnel during the restoration of a hold order which returned to service the ERCW side of a component cooling water system (CCS) heat exchange Q servations and Findinas On August 17. 1997, following preventive maintenance which cleaned the ERCW-side of the 1A1 CCS heat exchanger, operations personnel lifted the hold order clearance. 1-H0-97-3085. on the heat exchanger and aligned the system for normal operation using system operating instruction (50)
1-S0-70-1. Component Cooling Water System 'A' Train. Revision 1 Step 8.6.2[2] of the 50 directed operators to open valve 1-67-1506. CC3 HX 1A1 ERCW Return Isolation, to its required position per surveillance instruction (SI) 0-SI-0PS-067-682.M. ERCW Flow Balance Valve Position Verification. Revision 10. Operators subsequently throttled valve 1-67-l
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L1506 ~an incorrect number.of turns when valve )osition data for; valve 0 - ,
67-1506. CCS'HX 081 ERCW Discharge, was mistacenly used. The mistake j resulted in-an error of 1/12th of a turn which the licensee determined m- _ , _ . _ did not represent an operability concern. The _ licensee's review and -
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! corrective actions were good. The: licensee determined that operations !
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communications and attention to detail errors during this evolution ;
which subsequently led to the valve being mispositioned These personnel errors are listed below.
e The-Unit 2 Control Room Operator (CRO) did not request a specific
appendix and page from the SI and assumed that the TIC clerk would ,
, provide the correct ora for valve 1-67-1506,
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o After follow-up clarincation from the CRO the TIC clerk incorrectly assumed that the. valve sheet being requested was
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associated with another component. The TIC clerk did not ask for further clarification from the CR0 and subsequently provided the
, control room with Apaendix C of 0-SI-0PS-067-682.M. containing valve 0-67-1506, ratier than Appendix A. which contained valve
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1-67-1506.
I e When the incorrect SI appendix was later identified by the Unit 1 Unit-Supervisor (US), t1e Floor US attempted to replace the ( incorrect- a>pendix using the main control room copy of the SI l procedure. Jut he.also selected Appendix C. rather than Appendix A and stapled that incorrect page into the work packag *
e During the restoration of the 1A1 CCS'HX two assistant unit operators (AU0). failed to read the entire valve number and .
subsequently mispositioned valve 1-67-1506 using the throttling
!~ instructions for valve 0-67-1506. Both AU0s-initialed Appendix for-initial verification and concurrent- verification, believing E that they had correctly positioned valve 1-67-1506.
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During the final-SI package review, the Unit 1 US discovered that the sign off documentation was for valve 0-67-1506 rather than for valve 1-67-1506. The US notified the shift manager who notified the system engineer.- The system engineer verified that operability of the system was not. affected. . Subsequently, the involved operations personnel were coached and counseled on paying proper attention-to detail A " lessons o learned" required reading letter was initiated and distributed to
! an11 cable personnel concerning the event. Problem Evaluation Report ( MR) No. SO971926PER was initiated to document this event and the
- . licensee's corrective action The inspectors determined that, although this event had minimal safety
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significance, there were several significant communication and attention to detail errors which subsequently resulted in a failure of personnel i -to follow a procedure. The failure to follow procedure 0-SI-0PS-067-682.M during the restoration of valve 1-67-1506 is considered a
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violation. This non-repetitive. licensee-identified and corrected
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violation is being treated as a non-cited violation-consistent with:
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Section .VII.B.1 of the NRC Enforcement Policy (NCV 50-327.' 328/97-12-
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, c._Gonclusion One non-cited violation (NCV) was identified for failure to= follow-
. ' procedure during an ERCW valve alignmen The licensee's corrective action was goo ~01.3 T_ll
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ocut of Residual Heat Removal (RHR) Heat Exchanaer Valve Without Entry
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Into Limitina Condition for Ooeration (LCO) Action Statement
l soection Scoce-(71707)
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.The inspector reviewed the licensee's decision not to enter an LC0 t action statement for inoperability of an emergency core cooling. system
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(ECCS) subsystem when the CCS outlet isolation valve to an RHR Heat exchanger was tagged out for testing on the valve breaker, f -b. 10bservations and Findinas
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At 5:04 a.m... on September 10. 1997; Operations tagged out (2-H0-97-3097)-the electrical breaker to valve 2-FCV-70-156, the CCS outlet isolation valve to the 2A RHR Heat exchanger The valve, which is normally-throttled open for CCS flow balance purposes, was placed in the closed position' for the tagout. however, the valve handwheel was not -
tagged. The the breaker. purpose At 5:27 of the the a.m;. tagout shiftwas to perform manager madeoverload testing a log book entryon which stated that'it was o]eration's position that RHR/ECCS operability was not im) acted because t1e emergency. procedure for containment sump
. swapover. ES-1.3. Transfer to RHR Containment . Sump, Revision 7. had a step-to open the valve locally if it would not open from the contro . roo Since the handwheel was not tagged, the valve could-be. opened-locally'by hand cranking:the valve. which: operations believed would'
fulfill the intent of the step in the emergency procedure and therefore-into the action statement. Based on this decision by
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-operations not requirethe entry'C0 L action statement for inoperability of an ECCS subsystem (an RHR Heat exchanger) was not entere During shift turnover, en the morning of. September 10, the inspector
. . reviewed- the. control room logs and questioned the entry regarding the
CCS valve and the decision not to enter the LCO action statemen A Later in that day the inspectors discussed their concern with the N
_ operations manager. The o)erations manager subsequently discussed the inspector's concern with tiose licensed personnel involved in evolutio 'It should be noted that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed by the action statement was never exceeded and that operations subsequently made a late log book entry which entered the TS action statement until the post maintenance test (PMT) was completed on the valve breaker and the valve was re-positione __ _ _ __ _ _ . __ _ _ _ _ - _ _ _ _ _ _ _ _ _
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tli Conclusions The inspectors concluded that operations did not appropriately apply TS
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_ . with regard to heat exchanger operabilit .4 Unit 1 Momentary loss of Stator Coolina Insoection Scoce (71707)
The inspector reviewed the circumstances which lead to a momentary loss (approximately six seconds) of the Unit 1 main generator stator water cocling system, Observations and Findinas On September 18, 1997, stator cooling water pump 1A. which had been tagged out for maintenance activities. was started for a post maintenance test (PMT). After operators determined that the pump was operating correctly, they stopped the 1B pump, which had been running in parallel with the 1A pump. Control room operators immediately received a Generator Stator Cooling System Failure annunciator. An AUO stationed at the pump control switches restarted the 1B pump ar>d restored the stator cooling water system. The licensee determined that Unit I had experienced a momentary loss of stator cooling water (approximately si seconds) when the manual discharge valve to the 1A stator cooling water pump closed unexpectedl Subsecuent licensee investigation of the event determined that the 1A pump cischarge valve had been improperly positioned by AU0s prior to starting the pump. The discharge valve is a manually operated butterfly valve.. The valve is mani)ulated by a squeeze type lever handle with indentations which lock t1e valve in the selected position. Operators failed to ensure that the handle was positioned in one of the indentations. When operators stop)ed the IB pum), a perturbation was experienced across the pumps' disclarge piping w1ich caused the 1A oump discharge valve to clos During the licensee's investigation of the event, the AU0s stated they had difficulty Jositioning the valve lever handle into the
. indentations. T1ey had discussed the positioning of the lever handle, but concluded that as-long as the valve was open, use of the locking indentations was not necessary. They then ) laced the valve in the open position without using the indentations. T1e licensee initiated PER N SO972130PER-to document the even Conclusions The inspectors concluded that AU0s, by not exhibiting a good questioning attitude, did not properly position a stator cooling water pump discharge valve which resulted in the momentary loss of stator coolin _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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'05 Operator Training and Requalification (71001)
The inspectors assessed the licensee's Requalification Program using NRC
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Inspection Procedure 71001. - Licensed Operator Requalification Progra The inspectors v: sited the facility during the week of August 25-29, 1997. The inspectors conducted an Exit Interview with members of licensee management on August 29, 199 .1 Review of Facility Doeratina History Insoection Scoce The inspectors reviewed the facility's operating history using Licensee Event Re) orts (LERs). NRC inspection reports, and the Plant Integration Matrix ()IM). The inspectors also reviewed the licensee's Human Performance Evaluation (HPE) program for evidence of training-related operator performance deficiency trends, Observations and Findinas The facility's operating history did not indicate that operator training was a factor in identified deficiencies. Operator errors identified in the licensee's Corrective Action Program as skills-related errors are trended at a threshold below the levels which would result in LERs or significant events. Results of the most recent (April 1997) HPE trends were forwarded to tne Site Training Manager to be evaluated for inclusion into the 0)erator Training Program. Scheduled completion of this evaluation is tie week of September 2.199 The inspectors reviewed new lesson plans developed during the Requalification cycle to address operator performance deficiencies. The new lesson plans included a lesson plan developed as a response to an operator error involving improper use of Hot / Cold calibrated Pressurizer Level channels. Tha error occurred during the previous Unit 1 refueling outage, an:l resulted in a Violation in Inspection Report 50-327.328/97-95. The lesson plan was developed as a sirnulator demonstration to illustrate dynamic response differences between the hot and cold calibrated level instruments during shutdown conditions. The lesson
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plan / demonstration adequately addressed this training deficienc Conclusions The inspector did not identify adverse trends in operator performanc Individual or specific training deficiencies were identified, and appropriate changes were incorporated into the training progra !
05.2 Examination Develooment and Quality Insoection Scooe The inspectors reviewed the written examinations, adi.inistered November 4-8, 1996. The licensee administers the written exarination at the end
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of the first year of the 2-year Requalification cycle, along with the-operating examinatio Only the o)erating examination is administered at the end of the second year of t1e training cycl '
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The inspectors witnessed the dynamic simulator portion of the o)erating examination presented to two operating crews consisting of two R0s and three SR0s each. The dynamic simulator examination consisted of two separate scenarios designed to challenge both crew and individual competencie The inspectors accompanied the licensee's evaluators during the Job Performance Measure (JPM) portion of the operating examination administered to one R0 and one SRO. The JPM set consisted of five individual tasks. Two JPMs were simulator tasks, and three were in-plant, walk-through task The inspectors evaluated the licensee's examination development process, and compared the examination plan to the final, as-given exa Observations and Findinas The written examinations were appropriately discriminating and covered the training material presented during the Requalification Cycle. The written exams cor.sisted of 50 multiple choice questions. The inspectors reviewed one written examination in detail and determined that six questions had little or no discrimination value due to being overly simplistic. Further evaluation of these six questions determined that except for a single instance, every candidate correctly answered each of the The dynamic simulator scenarios were adequately discriminating and challenged the operators. The inspector questioned the ca) ability of the evaluators to adequately evaluate the Shift Manager (Si) positio This was due to the fact that the SM did not rotate into a more active shift position during the second scenario. Additionally, the licensee's operating philosophy is for the SM to maintain oversight of the crew without becoming too involved in the specific actions. This results in limited opportunities for the SM to temonstrate all competencies. The evaluator assigned to the SM thoroughly documented his observation This demonstrated that an adequate evaluation of the SM position without rotation is possible, but requires extra care and exhaustive documentation by the evaluato The inspector determined the In-Plant JPMs were too simplistic to be an effective examination tool. Two of the three JPMs in each set were not sufficiently complex or challenging to provide an adequate level of discrimination. A less than competent operator could perform the four simple JPMs. For instance. JPM 78-2 requires the candidate to locally trip the reactor by opening the A and B trip breakers by pushing the tri a push button for each breaker. This JPM is successfully com)leted by aeing able to locate the breakers and push labeled ' trip" pus, buttons. JPM 66 AP (Alternate Path) requires local (Auxiliary Control
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Room) operation of the Steam Generator Power Operated Relief (PORV)
valves. The alternate path involves manual controller manipulation when the automatic feature fail Locating the proper panel in the Auxiliary
. Control Room and selecting and using a simple manual controller was not sufficiently discriminatin The two simulate. JPMs were adequately discriminating and comple Additionally, each of the five JPMs in each set had approariately high safety significance. However, the ins)ector determined tlat the low discrimination level of the In-plant J)Ms constitutes a weakness in the licensee's Requalification progra The examination development process is principally a manually accessed matrix. The exam developer uses the matrix or checklist to select questions, JPMs, and simulator scenarios pertinent to the two-year Requalification cycle. The integration of one written exam and two operating exams every two years to provide full subject coverage provided a comprehensive examinatio The process provided excellent traceability to recreate exams. The procet incorporated all applicable requirements. The examination closely folk ad the examination pla Conclusions e The written examination was of good quality with an appropriate level of discrimination. Six of fifty questions were not sufficiently discriminatin e The simulator scenarios were adequately discriminating, and provided a good examination tool e The JPMS were adequate, but a program weakness due to low discrimination level was identifie Four of six In-plant JPMS observed were too simplistic to provide meaningful feedback to the Requalification Progra e The examination development process provided excellent integration of the entire two-year training cycle subject matte .3 Recualification Proaram Administrative Practices Insoection Scooe The Inspectors observed examination activities to assess the effectiveness of Requalification Program administrative practices during the conduct of written examinations and operating tests. The inspectors reviewed examination security measures to ensure compliance with 10 CFR 55.49 which prohibits applicants, licensees, and facility licensees from engaging in any activity that compromises the integrity of any application, test, or examination required by 10 CFR Part 5 . . __- _ - - - - - _ _ _ _ _ -
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8 Observations' and Findinas The inspectors observed .that the examinations'were conducted as planned
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action verb Verify. The intent- of the verb Verify is to observe that an
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expected action has taken place, but if it has not, take no actions. It was used in place of the action verb Ensure which requires an action to take place if the expected action has not occurre The inspectors reviewed the sequestration process and determined that the examination practices gave proper consideration to minimizing undue operator stress (e.g.. schedulina timing of segments security-measures) and minimized the potential for negative training (e. testing crew configuration different from operations). The inspectors reviewed additional examination security measures to ensure compliance with 10 CFR 55.49. and noted no deficiencie The-inspectors assessed the facility evaluators' use of performance standards by grading selected written examination questions and operating tests in parallel and assessing discussions-regarding crew and operator performance following the administration of the operating tests. Based on review observation of the evaluators' the inspectors determined that the performance standards are applied consistently and objectively, crew and operator performance errors made during' simulator evaluations are detected and adequately addressed by the facility's evaluators. Additionally, any significant errors made by individual operators during the walk throuah examinations were aetected and adequately addressed by the facility's evaluators. Post-examination critiques of operators and crews were effective in pointing out-strengths and weaknesses and accurately appraise the observed performanc The inspectors noted one administrative )rocedural problem. TPI-10 Section 3.4.A. states that "All TPIs SHAL_ be approved by all site training managers (or_their designees) whose signature will appear on the a)propriate section of the TPI cover sheet." This was not the case
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for T)I-20.5 which provides the administrative guidelines for evaluating the training program. This TPI was also not followed for the current revisions of TPI-100.1. TPI-202.2. TPI-203.1. and TPI-206.1. There was no safety significance to these error Conclusions The Ins)ectors concluded that with the exception of the minor instances
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noted tie-Requalification program administrative practices were effective. The ins)ectors concluded examination security measures complied with 10 CFR 55.4 _
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- 05.4-_- Review the Facility Licensee's Feedback System a.- Insoection-Scooe
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-The-inspectors reviewed the faciiity licensee's training feedback system-
-to assess:the effectiveness of the facility licensee's-process for-revising and maintaining its licensed operator continuing training program currer Observations and Findinas The inspectors evaluated the licensee's use of an employee (e.g.,
operators. instructors, supervisors) feedback system by reviewing the content of the comments for the past year, attending an Operations Training Curriculum Review Committee meeting, interviewing operators who-use the system.- reviewing administrative controls for the program and discussions with the training personnel associated with the progra The inspectors reviawed and evaluated a representative sample.of the employee comments and determined that the program's consideration of the comments.-- recommendations, and their- implementation was appropriat There was a small backlog _of- Requalification program changes and simulator fidelity changes. There was reasonable justification for the-few changes that were more than two years ol The program changes were
>; prioritized based;on safet The inspectors. attended an Operations Training Curriculum Review Committee meeting to compare , i= findincs of the training departmen with management ex)ectations. nanagement was aware of the items. They were presented wit 1 a verbatim listing of each comment and the proposed resolution-of some comments. Theblance of the comments was-presented at the.0perations Tiaining Curriculum _ Review Committee meeting to determine the resolution. Due to the volume of comments, this committee tabled several comments und assigned a sut' committee to review the comments and propose resolution during the next committee meeting; The inspectors interviewed operators who use the feedback syste These interviews included all levels of operation.. personnel, including Shift ;
rianagement. The operators _ interviewed were satisfied with the process and stated they had seen significant improvements -in : comment resolution -
in the past two years. They felt the program was-an effective' tool for providing their observations and comments. Additionally if requested, the comment feedback goes to the individual. If it is not, it is '
_ presented to the crew that made the-comment and is available in tabular for.n for review,- ,
The inspectors ieviewed administrative controls for the feedback-arogram, lnis review included a review of SSP-12.1. Conduct of Operations, which stated that feedback is essential and that it may be-oral or written, but it gave no specific instructions. TPI-20 Evaluating Training Programs, described the feedback program in genera .but did not describe the system that was current.: in place. There was
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Lalso mention of: feedback and the' feedback program in several other
- administrative documents, however, none described the program that-was in place. During interviews operators stated that-there were many--
. - L avenues of feedback communication available, i..e. .--voice mails. - E-mail, comment: forms, memos. None of:these were described in procedure d However. while not governed by procedures, the systems in place were .
- effective and useful' tools that provided rapid and traceable feedback resolution that was used extensively. There were more than 500 comments in the last quarte Finally, the inspector discussed the program with training managemen The management agreed that the current program was not described by (
procedures and was an informal 3rocess. The inspector was informed that this program was evolving and t1at it was scheduled to have procedures written that would formalize the program and govern its activities when the evolution was complete Conclusions The feedback program is effective, with uany avenues of comunication (i.e.. standard forms, memos. E-mail, voice mail) available. If
- requested the feedback goes to the individual and resolution or all comments is available for review. Operations and training management are aware of the verbatim comments and the program is used extensivel Miscellaneous Operations Issues (92901)
08.1 -(Closed) VIO 50-327. 328/97-03-01. Failure to Follow Procedure S01-7 in Alianina the SFPCS. The inspector verified the corrective actions described.in the licensee's res)onse letter. dated June 11, 1997.-to-be reasonable, and verified that t1ere were no open licensee commitments related to this violation. The corrective actions stated in the letter are complete. with the following exception. The licensee's letter stated that the malfunctioning flow indicator would be-repaired by JJne 30. 1997. Following the issuance of the June 11- letter, the licensee
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informed the inspector that the repairs could not be made by June 30, 1997. However, replacement parti to repair the flow instrument have been ordered from a vendor with an expected delivery in the Spring of 1998.- Meanwhile, an engineerirg evaluation is ongoing to determine whether to repair or abandon tie-flow instrument. As an interim measure, ultra-sonic flow instrumentation has been installed unier a temporary alteration change form (TACF). Th inspector concluded that the installation of the-TACF was an appropriate interim action pending determination of a -long term solutio '
08.2 (Closed)'IFI 50-327. 328/96-11-02. Review Corrective Action of PER N SO96251LPER Related to ABI Function of Radiation Monitor 0-RM-90-101 The PER recommended a design change notice (DCN) (scheduied issue date of April 18, 1998 and implementation date of Seatember 30,1998) to delete the on-line monitors associated with 0-RE-90-101A and 101C
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(auxiliary building ventilation system particulate and radiciodine monitors);and also to delete their input to the auxiliary builjing
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isolation (ABI). The Offsite Dose Calculation Manual (0DCM) and Regulatcry Guloe ! ".1, Measuring, Evaluating. and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in
. Liquid and Gaseour Effluents From Light-Water-Cooled Nuclear Power i Plants Revision 1 only require a ;3mpler, not an on-line monitor, for measuring iodi .; and particulates. An engineering evaluation will be required when the DCN is issued to determine which on-line monitors and ABI functions can be deleted. The DCN may also evaluate whether to delete the ABI function from 0-RE-90-1013. noble gas activity monito The UFSAR would subsequently be updated to reflect changes in the ABI function of 0-Rh 90-101. The inspector concluded that the PEP recommended corrective actions were appropriate 'nd reasonabl .3 (Closed) LER 50-327/96010. Manual Reactor Trio. as a Result of an Unexper.ced feedwater Heater Isolation and Loss of Feedwater. This event was ai! 'issed in Ins)ection Report (IR) 50-327.328/96-14. No new issues were b.tified by t7e LE The inspector reviewed the corrective actions listed in the LER and in ompleted PER No. SO962918PER, which also doc nented this event. The corrective actions were reasonable and complet .4 (Closed) LER 50-328/96001. Inadvertent Enaineered Safety Feature (ESF)
Actuation. Loss of Power Sianal and Load Seauencina. Durina Perform gj;g of Maintenance Instruction. On April 18, 1996, during performance of a maintenance instruction on the 6.9 kilovolt shutdown board 2B-B blackout load shed relay, an inadvertent ESF actuation occurred. The AU0 performing the maintenance was removing a control power fuse. The AVO was using the wrong size fuse holder, and was having difficulty removing the fuse. In the process, the AU0 momentarily broke electrical contil.uity, reestablished electrical continuity, and broke electrical continuity. This electrical sequence resulted in a loss of power signal and the inadvertent ESF actuatio The licensee determined that the root cause of the event was personnel error. The AU0 made an incorrect decision to use a smaller fuse pulle The licensee's corrective actions included counseling the AU0, and providing operations with a " lessons learned." which stressed correct tool usage and thorough pre-job briefings. The licensee also reviewed training for fuse pulling and determined it was acceptable. The maintenance instruction was also augmented by adding a caution statement to depress and hold the undervoltage blackout reset push-button for the removal of fuses. The corrective actions described in the LER were reasonable and complete.
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II.: Maintenance )
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M1.1 General Comment ;
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- Instsection' Scooe (61726 & 62707)
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The ir.spectors observed and/or reviewed-all or portions of the following work activities-and/or surveillances:
-e -WO 96-037758- Replace Arrowhart Breaker for 1-FCV-067-067.B- i e- 1-SI-0PS-063-12 B-B SI Pump Casing and Discharge Piping Vent e WO 97-010813 Replace Broken Handswitch Actuator Lever '
On 1-HS-62-53C e' 0-PI-SXP-087-20 Spent Fuel Pit Cooling Pump 18-B
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Performance Test e WO 97-008483 Replacement of Radiation Monitor SON-1-RM-090-e 0-PI-NUC-092-00 Incore Excore Detector Single Point Alignment e -0-PI-NUC-092-03 Incore-Excore Detector Calibration e WO 96-039552-000 Replacement of C805 Capacitor Bank-
- PI-EBT-250-73 Vac Vital Inverter Function Test o- 2-H0-97-2901 -120 Volt Vite. -Inverter 2-II T e- 2-SI-0PS-082-00 Electric Power-System Diesel Generator 2A-A-o 0-S0-27-1 Condenser Circulatory Water System
. S0-250-9 Technical Support Center Power System e 0-MI-MRR-070-611-1 Component Cooling System He6t Exchanger Maintenance e- WO 97-009479 Component Cooling Heat Exchanger Inspection i
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. Observations and'Findinos The inspectors noted that the wek activities and the performance of the
- . . surveillance activities were adequately performed. The inspectors were still reviewing the activities associated with the modification work on a control room radiation monitor that caused an ABI signal actuation. A discussion of the 2A-A emergenc) diesel generator (EDG) testing follows in Section M :
M1.2 Emeroency Diesel Generator (EES) Testing Insocction Scope b The ins)ectors reviewed the results of the routine surveillance of the 2A-A ED3 test performed on September 24, 199 ,0bservations and Findinas On September 24, 1997. The 2 A-A EDG was operated for a routine surveillance using 2-SI-0PS-082-007.A. Electrical Power System Diesel Ganerator 2A-A. The EDG was started and loaded per the )rocedure with voltage and frequency requirements met. However, once tie EDG was fully loaded, the system engineer, who was in the diesel room, noted an oscillation of the engine fLel racks which was equivalent to an approximate 100 kilowatt gerterator output (+/- 100 kW). This effect was not observable in the control room. Although the diesel met the acceptance criteria listed in the SI, the licensee secured the diesel and made the conservative decision to declare the diesel inoperabl Subsequently, the licensee initiated WO 97010851-000, and adjusted the actuator compensation, gain, and reset. The actuators had been replaced in February 1997, and no adjustments have been made since that tim 'However, the licensee indicated that differences in temperature, etc.,
can effect engine dynaaics, and that aeriodic minor adjustments were not unex)ected. After the adjustments, tie licensee performed a PMT run on the EDG to check voltage drops, frequency and recover No problems were noted. Next, the licensee performed the routine surveillance (2-SI-0PS-082-007.A). The diesel met the acce)tance criteria listed in the routine surveillance and was declared operaale on September 25, 199 c. Conclusions The licensee identified minor problems with the governor actuator on the 2A-A EDG during a routine surveillance, and made adjustments to the actuator. The surveillance was repeated and the acceptance criteria for the surveillance were met, l
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14 H2 Maintenance and Material Condition of Facilities and Equipment M2.1 Additional Review of loss of Control Air issue
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a. Insoection Stone (62707 and 40500)
The inspectors conducted a review of preventive maintenance on the control air system, as well as root cause and corrective actions from a run back of both units and a Unit 1 manual trip on August 1. 199 Thest transients were caused by a loss of control air due to the failure to establish a proper clearance boundary during a modification to replace a control air system com)ressor. The clearance boundary was not properly established in part. 3ecause of debris buildup in the portion of the control air system between the compressors and the air receiver tanks. An initial review of this event was documented in IR 50-327.328/97-0 The inspectors also conducted a review to determine
if the licensee had properly ircorporated this issue into the maintenance rule program in accordance with 10 CFR 50.65 requirement a b. Observations and Findinas The licensee's review of the root and contributing causes of this event and corrective actions were documented in PER No. SQ971825PE The licensee identified the causes to be establishment of an inadequate clearance boundary due to poor material condition of that portion of the ,
control air system. weak management oversight with respect to repair of known degraded conditions, and weak decision making practices allowing the activity (establishing a clearance boundary) to proceed with the existence of uncertainties. The inspector discussed the evaluation with several licensee personnel, and concluded that the review of root and contributing causes and corrective actions was thoroug The inspectors reviewed and discussed preventive maintenance activities that were being conducted on the control air system. These included inspection of the control air after coolers (24-week frequency), control air dryer inspections (48-week frequency), control air receiver tank inspections (5-year frequency), control air compressor moisture trap maintenance (12-week frequency), as well as other inspections of the control air system. The inspector noted that the licensee did not
)erform preventive maintenance on the maintenance valves or piping Jetween the compressors and air receiver tanks. The licensee stated that, although the comaressor after coolers were known to be a source of debris (since 1989). t1ey assumed that the debris was accumulating in the air receiver tanks, moisture traps and drain valves, and not in and around the ma.ntenance valves. In addition, because the maintenance valves (manually operated) located between the compressor and air receiver tanks were seldom operated. the licensee stated that there was not a history of problems with the accumulation of debris in these areas. However, the licensee's PER identified that an open work order for valve 0-VLV-32-534 (a maintenance valve), which was used in an attemat to establish the clearance boundary, had been canceled in Decem)er 1996. The licensee stated that the work order was initially
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opened in 1993 due to leakage, but was canceled because it would be .
rolled into the 5 year FA of the air receiver tanks, currently scheduled for 199 ~ ~ '
The inspector noted that a dual unit transient occurred in October 1992, due to water intrusion into a control air receiver tank. The licensee-identified the accumulation of debris from ineffective blowdown technicues to be the root cause. The licensee's corrective actions were
.focusec on that portion of the control-air system downstream of and includir.g the air receiver tanks. In addition the compressor after cooler moisture traps and drain valves have exhibited a history of clogging due to debris buildup. Based on the,above history of problems, the inspectors considered a commonality of the most recent transients of August.1997, and arevious transients, is the poor material condition of that portion of t1e control' air system. The inspectors concluded that the licensee did not effectively review the impact of longstanding poor material condition of the control air system. The ins)ectors also consider the licensee's activities to remedy the relia)ility and ~
material condition problems, in part by replacement of the control air compressors, to be a positive contribution toward material condition improvemen ,
The inspectors also discussed this issue with licensee personnel responsible for maintenance rule implementation. The licensee monitors
the control air system with plant level criteria, which includes unplanned capacity loss on a system basis and on an accumulated basis (with other systems monitored with plant level data) plant trips, and engineered safety features actuations. Based on these discussions, the inspector concluded that the licensee had appropriately residered this issue in their maintenance rule progra Conclusions The licensee did not effectively review the impact of longstanding poor material condition of the control air-system on activities such as-clearance boundaries, which contributed to the dual unit run back and Unit 1 manual-reactor trip of August 1, 199 The licensee's activities to remedy the reliability and material .
condition problems of the control air system, in part by replacement of
- the control air compressors, is contributing to material condition improvemen <
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The licensee had appropriately considered the August 1, 1997, transients and Unit I reactor trio in-their maintenance rule pmgra :The' licensee conducted a thorough review of root and contributing causes, and corrective actions, for the control air system initiated transients of August l', 199 i
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- M2.2 Inaoorooriate Clearance Leadina To An ABI Actuation Spection Scooe (62707)
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The inspecters reviewed the personnel actions and work documerits associated with the ABI actuation which occurred on September 17, 199 Observations and Findinas On September 17. during modifi:ation work in a main control room radiation monitoring control panel, an instrument and controls
+ echo c W inadvertently grounded a power supply lead. The grounded lead caused the power supply breaker to trip and resulted in a merous control room alarms, the loss of approximately 20 control board -
radiation monitoring instruments and approximately 10 control board radiation monitoring recorders. In addition, multiple relays picked up and actuated the ABI circuitr Initial discussions with the licensee indicated that the technician did not recognize that a lead was energized during voltage verificatio This led to not taking precautions for handling an energized lead and subsequently grounding the lead on another cabl The inspector noted that the work order orocess required maintenance to obtain a clearance or that operations pe'rform an impact evaluatio Guidance for approvals in the work control process is provided by Site Standard Practice (SSP)-7.53. Work Approval And Closure. SSP-7.5 Section 3.4. Documentation For Approval To Begin Work, noted that the
"WCC SR0/ Operations Shift Manager / Designee" will " perform an impact evaluation per Appendix B." SSP 7.53. Appendix B. Section 2.0. requires that "both operations and craftsmen understand the impact on the plant" and "if problems arise, what actions should be taken by both groups."
The inspectors noted that a detailed impact evaluation had not been completed prior to the approval to start the work activities. This observation was based on the fact that the licensee had not reviewed the wiring schematics to determine whether or not various leads were energized and had not evaluated the consequences of grounding the energized leads. The inspector concluded that because the licensee had not conducted an adequate impact evaluation prior to the start of the work activity, an adequate pre-job briefirg was not performed and a sensitive activity was not identified prior to the start of the wor Based on the inspector's review, it appeared that the licensee had not performed the work approval activities in accordance with the site standard practice procedure. However, further clarification of the facts by tb? licensee was needed to resolve this issue. Therefore, the potential inadequate impact evaluation is being identified as an unresolved item pending further NRC review (URI 50-327, 328/97-12-02).
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- An unresolved item was identifi'J for a potentially inadequate-impact-a . #- review which contributed to.a maintenance error'and an ABI actuation signa MB- Mismilaneous Maintenance Issues (92902)
M (Closed)-IFI 50-327.328/96-12-02. Followuo on Licensee Actions to
- Provide Performance Criteria for Structures After Industry Resolution of
.this Issu This industry-wide' issue had been identified during the Maintenance Rule
? Team Inspection. The reason for the issue was that there had been no industry guidance in this area. Guidance was subsequently provided in Regulatory Guide 1.160. Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Revision The inspector reviewed Procedures 0-TI-SXX-000-004.0. Maintenance Rule t Performance Indicator Monitoring. Trending, and Reporting - 10 CFR 50.65.. and SON-CI-96.02. Procedure for Walkdown of Structures for Maintenance Rule. The licensee's program required routine inspections
- of all structures under the scope of the rule. Those routine ,
inspections included checkH g for excessive settlement.-degradation or '
cracking.of concrete, corrosion or-changes in condition of structural steel. ground water infiltration -mineral dep'osits, missing or loose components. etc. Evaluation by the licensee s civil engineering group was required for any defects identified during those inspections. The-inspector determined that the licensee had completed greater than 60% of the baseline walkdowns-of structures for the Maintenance Rule and that i all baseline walkdowns were scheduled to be completed by October 199 '
.-The licensee's-performance criteria -for each structure were zero failures:or unacceptable conditions. The licensee's program considered '
as unacceptable any condition which did not meet the design basis of the structure or any condition which might not meet the design basis if left uncorrected until the next normally scheduled assessment. This included j iconsideration of-protection and support of structures, systems or components (SSCs) under the scope of the Maintenance Rule. Additionall l no more than 15 acceptable deficiencies per structure or five acceptable
- deficiencies per sub-structure per structure-in a 24-month period were allowed. -Structures which failed to meet these 3erformance criteria were required to be classified as (a)(1) under t1e rul : The inspector determined that the licensee's established performance criteria documented in 01-SXX-000-004.0. Attachment 34, met the intent of Regulatory Guide 1.160. Rev. 2. The inspector concluded that-the
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licensee had-adequately addressed the original concer .
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E2 iEngineering Support of Facilities-and Equipment i a ~
E2.1J Safety Iniection System Pressure Transient (37551)
a . Insoection Scooe The~ inspectors reviewed the activities associated with an over-pressure condition of the Unit 2 safety injection system. The inspectors also reviewed the back-leakage status of the reactor coolant system / safety
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injection-system check valve bservations and Findinas During safety injection-system-Section XI valve testing for valve 2-FCV--
63-156 on September 9. 1997.-the safety injection system was slightly over pressurized to 1850 pound per square inch gauge (psig). Due to a previous event -in November 1996, the licensee had an evaluation in place to allow system operation up to a maximum of 1850 psig which is above the design pressure of 1750 psig. The pressure transient was- due to back-leat.:ge through the safety injection system / reactor coolant system
--isolation check valve During check. valve testing in-1996, the licensee had noted a proximately 0.5 gallons per minute back-leakage through two different sa ety 6 injection system flow paths with corresponding check valves (2-VLV-63-641 and 543) and-(2-VLV-63-644 and 545). .This leakage was noted to be within the design leakage for the valves, however, the licensee had written a work request to repair the valves during the Fall 1997 Unit 2 outage. The ins)ectors noted, that with:the safety injection-isolation valve closed ~(2 CV-63-156), there was no back-leakage from the RCS to
- the safety injection' system and this problem only surfaced during
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Section XI testing of the isolation valve.-
It was also noted.that. system pressure reached 1850 psig. Tie system has a relief valve (2-VLV-63-534) that should have opened tc relieve-pressure at approximately 1750 psig. In November 1996, the plant experienced an over-pressure condition when three safety injection <
_ relief valves failed to open as required. Relief valve 2-VLV-63-534 was replaced with its relief setpoint at approximately 1750 psig. Based on the September 1997 transient, it appeared that the valve setpoint had drifted high. The cause for the setpoint drift for three valves noted in the November event and one valve noted in the September ever.v has not been determined. The licensee plans to perform an investigation and evaluation of the relief valve setpoint drift problem during the up i coming refueling outage. - An inspector followup item is being identified to follow the licensee's resolution of the safety injection system relief- valve setpoint drift problem and to followup on the repairs and testing of the system check valves (IFI 50-328/97-12-03).
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' Conclusion Back leakage from the RCS due to leaking check '31ves, caused a pressure transient on the Saf6ty injection syste The relief valve setpoints for the safety injection system drifted high and the cause has yet to be determine Hiscellaneous Engineering Issues (92903)
E !. Closed) 1/1 50 328/96 05 03: Follow uo on Licensee's Cause j,nvestination of Ir, advertent Ice Concenser Door Onenina. lhe inspector reviewed completed PER No. 50961600PER. witch addressed this event. The root causes for this event were .dentified as a- failure to adequately correct a known problem through the use of the corrective action program that was in ef fect at the time: and inadequate skills or knowledge, g The licensee performed an extent of condition search, and no events 11milar to this event were identified. However. several operators and 2ngineers recalled similar events (inadvertent opening of ice condenser doors) witho*;t significant ice melts. The licensee believes these events occurred before the corrective actions program was emphasized, The licensee also concluded that a sianificant contributor to the event was the " lack of operator knowledge' concerning the offect that the control roa drive mechanism (CRDM) cooling units can have on the ice condetiser dcot The inspector reviewed and verified the licensee's listed corrective actions. These included adding precautions and pr cedure steps to three procedures varning of the potential for the ice condenser doors coming open under certain conditions, and issuing a required reading memo to o)erations personnel describing this event. The inspector concluded tlat the corrective actions d? scribed in the completed PER were reasonabl dased on this review thi:; item is close E8.2 (Closed) LER 50-327/96005. Inadvertent Enaineered Safety Feature (ESF)
Actuation. Start of the Diesel Generators. From an Un(nown Cause. On
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May 26, 1996, an ESF actuation occurred during performance of res)onse-time testing of the feedwater isolation relays in Train A of the Jnit 2
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Solid State Protection System (SSPS). The licensee determined that the ri.ost probable cause of the four diesel generators (EDG) starting was the failure of the slave relay test panel during the response time testin The slave relay test panel was tested and no loose connections, grounds or other problems were identified. The licensee's corrective actions included modification of the slave relay test panel to prevent energizing of the EDG start relay except during the performance of a blackout /safetyinjectiontest. The corrective actions described in the 1 LER were reasonable and complet l l
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IV, Plant Suonti R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 General Comments (71750)
The inspectors performed tours of the control building, auxiliary building, turbine building. ERCW pump house and diesel generator buildings and did not identify any noteworthy deficiencies in housekeaping or radiological control RI.2 ERCW Chlorination System Unorade (71750) Insoection Scom-The inspector reviewed the scope of the licensee's ERCW chlorination system upgrade. This review included discussions with the license observations of the work in progress, and walk downs of selected portions of the chlorination svste Observations and Findinos Historically, the licensee has had numerous problems with the ERCW chemical addition system because the chemicals caused numerous leaks in the system. Because of these continuing problems, and the increased unreliability of the chembi addition process, in approximately 1992 the licensee decided to upgrade the program under Project Change Notice (PCN) 2020. ERCW Chlorination Project, PCN 2020 included three design change notices (DCN):
o DCN-M12249-B replaced existing chemical injection piping inside the ERCW building with hastolloy piping up to the injection point downstream of the ERCW Strainers: and provided four spare penetrations into the ERCW pumping station. This DCN was field completed in 1996, o DCN M12677 installed hastolloy piping inside the ERCW aumning station to allow chemical addition into the ERCW pump aays:
rebuilt the ERCW strainers with ceramic coated shafts to eliminate leakage: installed sample valves on the auxiliary feedwater ERCW emergency supply header crosstie to allow sampling of a lcngth of pip ng with low or stagnant flow; and replaced sections of flanged pip ng located outside of the ERCW building, that was susceptible to eaks, with hastolloy piping, o DCN M12678A installed a valve manifold at the ERCW building, replaced the chemical injection isolation plug valves with hastolloy ball valves; and installed permanent power / telecommunications to the pump skid and the ERCW sample traile \
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Much of the upgrade is already in place and working well. The licensee expects to field complete the PCN by October 15. 1997, c. Conclusions The inspector concluded that the licensee's upgrade of the ERtW chlorination system should improve the overall efficiency of the system and reduce system down time due to system leakag I'.8 Miscellaneous RP&C Issues (71750)
R8.1 -(C'osed) IFI 50-327. 328/97-04 05- Review Licensee's Corrective Actions Fo'lowina ar -Inadvertent Snill of Several- Thousand Gallons of-Contaminatec Water. This event, and the licensees's corrective actions for the event, were documented in IR 50 327. 328/97 06. Section R Based on the review documented in IR 97-06.1this item is considered -
close V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspect 1on on October 8.1997. The licensee acknowledged the findings prusente During the inspection period, the inspectors asked the licensee whether any materials would be considered proprietary. No proprietary information was identifie .LUtTIAL LIST OF PERSONS CONTACTED Licensee
- Bajestani M.. Site Vice President
- Burton. C,. Engineering and Support Systems Manager
- Butterworth. H. Operations Manager
- Fecht. M.. Nuclear Assurance Manager
- Flippo. T.. Site Support Manager Freeman.-E. Maintenance and Modifications Manager
~*Herron. J.. Plant Manager Kent._C..-Radcon/ Chemistry Manager
- Koehl..D. Assistant Plant Manager
- 0'Brien.- B. , Maintenance Manager
- Salas. P., Manager of Licensing and Industry Affairs Summy, J., Assistant Plant Manager
- Valente. J., Engineering & Materials Manager
- Attended exit' interview r
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INSPECTION PROCEDURES USED
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IP 37551: -0nsite Engineering !
- ~1P.40500: Effectiveness of Licensee Controls In Identifying. Resolving, &
!.,.. Preventing Problems j IP 61726: Surveillance Observations IP 62707: Maintenance Observations !
i IP 71707: Plant Operations j
, IP 71750: Plant Support !
IP 92901: Followup - Operations
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IP 92902: Followup - Maintenance
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IP-92903: Followup --Engineering ,
ITEMS OPENED. CLOSED. AND DISCUSS 10 ,
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' NCV 50 327, 328/97-12 01 OPEN/ Failure to. Follow Procedura During I CLOSED Restoration of an ERCW Throttle !
,. Valve (Section 01.2) l
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URI- 00-327. 328/97-12-02 OPEN PotentialInadequateImhact Evaluation (Section M2. )
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! IFl 50 328/97 12-03 OPEN Follow Resolution of Safety
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Injection Check Valve Back-leakage :
and Relief Valve Setpoint Drift t (Section E2.1) -
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Iygg item Number Status Descriotion and Reference *
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VIO 50 327,'328/97-03-01 CLOSED Failure to follow Procedure S01-7 in Aligning the SFPCS (Section 08.1)
IF , 328/96-11-02 CLOSED Review corrective Action of PER N ;
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S0962511PER Related to ABI Function i F of Radiation Monitor 0-RM 90-101C (Section 08.2)
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- LER -50-327/96010 CLOSED as a Result of
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ManualReactorTriha,terHeater an Unexpected Feed Isolation and Loss of Feedwater
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(Section 08.3)
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LER 50-328/96001 CLOSED Inadvertent Engineered Safety Feature (ESF) Actuation. Loss of Power Signal and Load Sequencin . During Performance of Maintenance Instruction (Section 08.4)
IFI 50 327, 328/96 12-02 CLOSED Followup on Licensee Actions to Provide Performance Criteria for Structures after Industry Resolution of this Issue (Section M8.1)
IFI 50-328/96 05 03 CLOSED Follow up cn Licensee's Cause Investigation of Inadvertent Ice Condenser Door Opening (Section E8.1) 7 LER 50 327/96005 CLOSED Inadvertent Engineered Safety Feature (ESF) Actuation. Start of the Diesel Generators, from an Unknown Cause (Section E8.2)
IFI 50 327. 328/97-04 05 CLOSED Review Licensee's Corrective Actions Following an inadvertent Spill of Several Thousand Gallotis of Contaminated Water (Section R8.1)
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