IR 05000333/1989009
| ML19325D228 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/06/1989 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19325D227 | List: |
| References | |
| 50-333-89-09, 50-333-89-9, NUDOCS 8910190216 | |
| Download: ML19325D228 (18) | |
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Ae U.-.S, NUCLEAR REGULATORY COPMISSION-
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Region I (p
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fz-Report No', -
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.89-091 i
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-- Doc ket. No ~. :s 50-333
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" License No.:
DPR-59 N
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'Licenseei t.:New York Power Authority Post-Office Box 41 M
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Lycoming, New York '13093
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Facility::
LJames A. FitzPatrick Nuclear Power Plant
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- Location:.
Scriba, New York
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Ca'tes:
fJuly 30,J1989'through September 6, 1989
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.Inspectorsi"
'W.LSchmidt', Senior. Resident. Inspector
- R. Pluse, Jr., Resident Inspector D L;ta.<ge? Project Manager, NRR
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LApproved'by:
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React'or Projects. Sectior(/No. LIB
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- lenn W. Meyer7 Chfef.. f Date
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Division of-: Reactor Projects-
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- ,I_rjpecticn Summary
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-This 'inOection ' report documents routine inspections--during day and backshift hours. off plant.i activities,11ncluding plant' operations; security, surveillance t
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'::and maintenancep emergency--preparedness,; engineering and technical support,.and
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WN iradiological protectionE This report period encompassed'a total.of 225.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> i
,s y 'of, direct inspection: effort. - Of:that total, 26' were backshift hours while 13 i
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- were deep bacS. shift: hours which.were conducted wrn August 3, 13, 23,.and'27.
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mihe ~ ; inspectors did not.. identify any violations.
There are
.nresolved
'ItemsEidentified.. Additional inspection items that.the inspector will follow.
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!in; a usabsequent report are noted by an F-/* designation. A Table of Contents
.,pN lf611ows and: notes: Unresolved-Items and follow items.
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TABLE OF CONTENTS Page
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Plant Tour by Commissioner Curtiss........................
I 2.
.0perations (MC 71707,93702)..............................
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2.a Both Senior Reactor Operator on a Break at the Same c"
Time, Unresolved Item 89-09-01.....................
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2.b Standby Gas: Treatment System Fan itun Time Indicator
. Environmental Qualification, Unresolved I*'m-
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89-09-02...........................................
- 2. c - Review of'Previously Documented Technical:
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Specification Discrepancies, F-1...................
2.d Review of Differing Technical Specification
. Requirements-for Placing the Plant in the Cold Shutdown Condition, Unresolved Item 89-09-03.......
'4 2.1 Safety Assessment....................................
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Security-(MC'71707)......................................
3.1 Safety Assessment..............................'......
4.
Surveillance-and Maintenance-(MC 61726, 62703, 92702, 92703)..................................................
's.a A:and C Residual Heat Removal Pump) Testing..........
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- 4.b L115 KV Offsite: Power Transformer Maintenance.........
- 4.c ;High Pressure Coolant Injection Turbine Lube Oil
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. Contamination,with Water, F-2......................
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4.d Residual Heat' Removal Service-Water Pump Breaker i
m"4 Maintenance, F-3................e..................
I 4.e':LER 89-13-00, Partial Group :I Isolation.............
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391 4.f- (0 pen) Unresolved Item 88-11-01: Review of Technical Specification-Required Daily Surveillance Procedure..........................................
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..4.g. (0 pen)' Violation 89-08-02.1:
Emergency Diesel i
Generator Fuel Oil-Day Tank Level Instrument
. Concerns during Pipins Pressure Test...............
4.h /Open) Unresolved Item 89-29-10: Testing of Crescent l
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Area Unit Coolers with Emergency Service Water.....
j 4.1'l Safety Assessment..................................
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iTable of Contents-(Continued)
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Emergency Preparedness:(MC 71707,82301)..................
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-5.a: Loss of Emergency Sirens.............................
5.b Review of-Prat. ice Drill Observations................
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5.1 Safety Assessment......................./............
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Engineering / Technical Support (MC 37700, 90712, 92700,-
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92702)...........................................;......
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6.a A and C Residual-Heat Removal Pump Evaluation.....-...
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6.b Review of PORC Approved Safety Evaluations...........
6.c IST Instrument Modifications, Unresolved item 89-09-04...........................................
6.d Review of 10 CFR 50.59, Safety Evaluation Procedures.
6.e LER 89-12-00,. Potential Overcurrent due to a Three Phase Short while Operating Emergency Diesel Generator for Surveillance Test 1ng, Unresolved Item 89-09-05......................................
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6.f (0 pen) Violation 89-80-05:
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LER 89-11-00, Plugged Emergency Diesel Generator Buildi ng Fl oor Drai n s.........................
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LER 89-10-00, Safety Related Switchgear Environmental Enclosure Air Conditioning Units Not Designed for High Energy Line Break.......
6.1 Safety Assessment....................................
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? Radiological Protection (MC 71707).............
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7.a (0 pen) Unresolved Item 89-08-01:
PASS Operability...
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7.b Weaknesses in Radioactive Contamination Control......
-7.c Weaknesses in ALARA-Area Use during Surveillance Testing, F-4.......................................
'7.d~' Weaknesses in Housekeeping following Maintenance.....
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7.e Typographical Error in Inspection Report 89-08.......
7.1. Safety Assessment.........
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Exit Inter'.',ew (MC 30703).................................
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~ 'i DETAILS
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1.
Plant Tour by Commissioner Curtiss
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On August 28, 1989, Commissioner James R. Curtiss met with the Resident
Manager _ and his staff, and toured the facility.
Commissioner Curtis was accompanied by Kevin Connaughton, his technical assistant, William F. Kane, DL actor, Division of Reactor Projects for - Region I, ~ and the resident
inspectors.
A 2.
Operatius
The - plant operated at ' 100% power during the repert period except for August 26 and-27, when power was reduced due to a ground on a circulating water pump.
- a.
The inspector observed an example of inappropriate conduct and lack
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of pt ofessionalism by the on shift senior reactor operators (5R0s).
Specifically, during the early morning hours on August 3, the inspec-
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tor observed. that the shift supervisor (SS) and the assistant shift supervisor (ASS), both licensed SR0s, were in the lunch room taking a
. break from licensed duties concurrently. The nuclear control oper-
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ator-(NCO), a licensed reactor operator (RO), was observed to be in the controls area of the control room as required.
However, the
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inspector judged it. to be inappropriate for both SR0s to be on a break-concurrently with neither person reviewing the operation of the reactor.
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L The lunch -. room is adjacent to.he controls area and. inside of the security boundary. NYPA considers the lunch room to be an acceptable
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-area for the SS and ASS to perform some auties, such es turnovers and
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briefing of equipment operators, because in this location the SS and -
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ASS can respond to alarms in the controls area, but any disruption L
of the controls area is minimized. Nevertheless,.the inspector con-L cluded that it.was inappropriate for both SR0s to be in the lunch room on a break.
The inspector addressed this concern with the Resident Manager, who agreed that this type of activity was inappropriate and would be cor-rected.
As corrective action, the Operations Superintendent held l
M discussions with each SR0 in which he stated that it was inappropri-
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ate for both SR0s to - take a break together and reemphasized the
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importance of direct supervision by the SS and ASS and the high g
standards of professionalism expected. The inspector concluded that these discussions were ecceptable as initial corrective actions.
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The inspector revie.ed Operations Department Standing Order (0DS0.)-1,
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Operating. Staff Responsibilities and Authorities.
Section 5.4.8
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requires that 'an SRO be within the control room at all times when-the
. plant is not in cold shutdown. Section 5.7 requires;that the NCO be in the control room as defined by a diagram in the back of: the pro-cedure.
The diagram defines the confines of the control room for the
NCO as.the area bounded by the main control panels and the SS's
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office.
The inspector noted that there is no definition as to what
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"within_ the control room" means for the - SRO.
Further, there_ is no E
' provision = as.to when the SR0 may take-a break or under what condi-
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tions. The Resident' Manager agreed that the procedure needed clar-ification.
He committed to reviewing this and making the necessary procedure corrections.
This item remains unresolved pending inspec-tor review of NYPA's corrective actions.
UNR 89-09-01 b.
Tne inspector _ found an instance when the SR0s did not formally enter-the applicable Technical Specification (TS) Limiting Condition for Operation ~ (LCO) despite. being aware of the potential inoperability of
!the system and taking action to correct it.
Specifically, on August 9 the Maintenance Department tried to obtain a run time indi-cator'for the B standby gas treatment (SBGT) fan to replace a failed indicator.
An. environmentally-qualified (EQ) replacement was not available, and Technical Services was contacted to resolve the re-placement part issue.
On August 10, Technical Services completed a review tnat verified the' function of the indicator was 'not r.ecessary
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for ' system operability.
However, this indicator was installed in parallel with the control circuit for the fan motor breaker and was not separately fused. Therefore, if the indicator was to short, it could result in the blowing of the breaker control power fuses, potentially_ causir.g -the breaker and the fan te be inoperable.
i The Maintenance Department 1nitiated a temporary modification (TM) to lift the leads on the B SE.GT fan - run time indicator.
The B SBGT train was already inoperable for electrical maintenance on system
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breakers. The applicable T2chnical Specification (TS)- Limiting. Con-
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dition-for Operation (LCO), Section 3.7.B.2.a, for one trein of SBGT inoperable was in effect.
TM 89-66 was prepared and authorizect Tur installation.
Subsequently, on that day,. the ASS was requested by
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Maintenance to preparc aed install a TM to lift the leads from the A SBGT fan run time indicator.
This was requested because Technical
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Services was questioning the EQ of the installed instruments and felt that lifting the leads was conservative, until the EQ determination was completed.
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The inspecto. concluded.that due to concerns on the SBGT run timersi J
A SBGT-should have. been declared inoperable' at this time. While NYPA
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took action-to correct the problem, i.e., the TM was' authorized to-l
remove the timers from the circuitry by lifting leads on A SBGT, it
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was not. declared inoperable-until three hours later when Technical
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Services concluded that the indicator did not meet EQ requirements.
Even then, the inoperable B SBGT train-was not properly ~1ogged. Under
the.LCO action statement NYPA had 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to-reach a cold shutdown condition...The leads were lifted within ten minutes of the~EQ deter-mination, returning A SBGT to operability.
In di4cussions 'with the inspector the Operations Superintendent-
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stated that-in the absence of a final determination of EQ acceptabil--
'ity, the declaration of inoperability was premature and that lifting of leads on A-SBGT was a conservative action. The inspector stated that-these actions were inconsistent and that the conservative step of declariq A SBOT inoperable should have been taken.
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The Operations. Superintendent made a 10 CFR 50.72 notification at
'2:46'p.m., based. on a condition that was outside the plants design
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' bases (1.~ hour; call) and a condition that could prevent the fulfill-
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ment of-a sefety function needed to control a release of radioactive meterial and to mitigate the' consequences of an accident.
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NYPA subsequently qualified the timers based on material composition
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and their' ability to withstand the radiation field that would. follow a loss of coolant accident (LOCA).
In. summary, the inspector concluded thr.t the SRCs had not been con-F servative :regarding the declaration.of the second train of SBGT as L
inoperable and that logging of the inoperablility had been neglected.
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NYPA will 'be asked to respond in writing to these issues. This item is unresolved pending review of the actions taken by NYPA. to resolve these issues.. UNR 89-09-02 l
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The inspector discussed several outstanding Technical Specification l
(TS) issues with the Resident Manager.
In Inspection Report 88-01 two deficiencies were noted:
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1)
The instruments that provide the-primary containment isolation
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a (PCI) functions for the high pressure core injection (HPCI) and
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the reactor core isolation cooling (RCIC) systems are included
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with the instrumentation' that control and initiates the ECCS
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system (TS table 3.2-2).
These. instruments should be listed
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. ith instruments that cause primary containment isolations (TS w
table 3.2-1), because PCI instruments may be required to be operable at times when ECCS instruments are not.
NYPA has com-mitted to review this and determine the need for a TS amendment, but no decision has been reached yet.
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TS 3.5.F.2 for FCCS systems needed during cold shutdown does'not
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specify. what! systems are required when maintenance that could
arain the vessel is being performed. NYPA is in the process of j.
- developing a proposed submitta' to address this issue. NYPA has committed.to submitting' this amendment to have it in - place by the 1990 refueling outage.
NYPA committed to maintaining one l
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ECCS system available for. injection to the core during shutdewns-
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when work is occurring that could drain-thr-reacto_r vessel.
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.The inspector will follow these items in a' subsequent inspection report F-1 The inspector found the NYPA resolution acceptable regarding a con-
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cern in Inspection Report 88-17 on deinerting of the containment (TS l
3.7.A.7).
Specifically, is it acceptable if within -24 -hours of a planned shutdown, the containment is deinerted as 'allrwed by h.
3.7.A 7(1), and then the shutdown is not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
NYPA stated that TS 3.7. A.7(3) applies, which allows six hours to restore the differential pressure or be in hot shutdown within the
- next 6 he':rs-and cold shutdown within the next - 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
Based on; this, NYPA;does not plan or, submitting a TS amendment. The inspector-found this acceptable.
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d.
The inspector has noted that TS contain several different LCOs which
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that-various terminology is used.
Some examples are:
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i On April 19, as documented. in Inspection Report 88-07, both
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standby liquid control systems were declared inoperable.
In this case TS 3.4.0 requires that the plant shall be in cold
shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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On-April 27, as documented in Inspection -Report 88-07, TS -- 3.7,D.3 was entered because the primary containment was declared
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This TS requires that a shutdown be initiated and the plant be-placed in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
On August 15 (see Section 2.b) both trains of SBGT were declared
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The applicable TS 3.7.B.3 requires that the plant be placed in the cold condition.
NYPA treated all these instances the same, i.e.,
as requiring the
plant to be'in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Because a normal. shut-
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down can be achieved within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, no actians were taken until 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> end point.
The inspector asked for justification for this interpretation. Further., there is no guidance available to operators on how to interpret these different requirements.
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timing of Unusual: Event (UE) declaration and 10 CFR 50.72inotifica-
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tion. of a shutdown required by 1S.
The emergency ' plan procedure.
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' states that a UE should be declared when a shutdown is commenced as'
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required ' by a TS LCO.
Therefore, NYPA interprets a UE would be.
i declared and a r.otification made when the shutdown was actually begun
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(as little -as 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the action statement's expiration).
I Also, NYPA has stated verbally that power-reductions using recircula -
tion flow do not constitute commencing a shutdown, but that once a
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control rod needs to be driven into the core a shutdown has com.
- menced. The inspector requested a justification for this position.
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NYPA committad to review the requirements for commencing a shutdown required by TS and the above issues. This item is unresolved pending i
review of NYPA's actions. UNR 89-09-03
o 2.I' Safety Assessment
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The actions taken to resolve the issue of both SR0s taking a break at the same. time were adequate.
NYPA management should continue to review day-to-day-operations for adequacy with expectations.
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The findings' cited while-reviewing the SBGT issu? discussed above indicated that site management nust take steps to ensure that system operability concerns are addressed by '3Ss and ASSs in a conservative l
manner.. Further action should be taken to improve log keeping to
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ensure thati LCO L entry and exit conditions are fully documented.
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3.
Security a.
On August 27, the inspector walked down the prctected area and ob-served: security personnel performing routine surveillance checks of the perimeter intrusion detection system. The sarveillance was com-pleted properly.
The status of a loose manway cover to the storm drain system was questioned. Security responded that the lake dis-charge line, downstream of the manway cover, is welded with boiler grating, making the manway cover inaccessible from outside the pro-tected. area.
The' inspector determined this to be adequate.
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b.
The inspectors observed various vehicle and personnel searches d'Jring
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the period.
No discrepancies were noted.
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Guard responses to vita; area door alarms were observed to be adequate.
- 3.1 Safety Assessment The security department continued to perform their duties properly.
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Surveillance and Maintenance-e
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k-a-The inspector reviewed NYPA _ actions regarding the inoperability of.
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the -' A and C ' residual heat removal- (RHR) pumps based on inservice-
-testing' (IST) problems.
(The engineering aspects are discussed in Section 6.a).
During quarterly surveillance and inservice testing, the pumps were in the required action range due to low pump differ-
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ential pressures.
The required action range was as defined by ASME
Code,Section XI and the baseline data at that, time.
Although the i
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differential pressures were above the TS required vaiues, the pumps were declared inoperable as required by the Code.
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The inspector monitored the performance of the subsequent it. service testing on - these. pumps.
This testing was conducted in accordance
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with ST-2A, Quarterly RHR Pump and Valve Testing (IST).
Testing was
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observed to'be well-conducted frcm the control room. Data collection.
was proper. a; the pumps.
During this testing, NYPA recalibrated instrumentation and closed :.-anual blocking valves to ensure that the indicated flow was the actual pump flow.
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' The inspectors. noted the following while observing this testing:
NYPA:found that the gages used to measure pump suction pressures.
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were of a large scale (30" Hg vacuum to 150 psig), but the nor-
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mal testbg values are 2-4 psig. This did not meet the criteria
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-imposed by ASME Code section XI. The Code states that the gages shall be of a range.not greater than four times the expected value to be read. _The Technical Services Department implemented a modification which installed higher accuracy gages to be used during testing. This was acceptable to correct this ceficiency.
The. inspector also noted that the flow indicators (annubar type)
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for drywell spray showed approximately 500 gpm going to the dry-well with the spray blocking and throttle valve verified shat.
When this was noted, the control room operators verified that-there was no difference in the measured drywell leak rates before and after the test and wrote a work request to trouble-shoot the deficiency.
The panel indication for RHR flow was not as accurate as the
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digital process computer point.
Both 'of these indications receive input from the same transmitter and are calibrated when the detector _i s calib ated.
The Operations Department has changed the test procedure to utilize the computer point vice the panel indication to allow for better establishment of initial conditions.
The inspector observed the surveillance testing performed on to determine that the pumps met the newly determined baseline.
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testing was completed satisfactorily.
Both pumps were returned to service on August 17.
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b.-
On? August 17, the in., ?ctor observed preventive maintenance being.
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performed-on one ~of the 115 KV offsite emergency transformers.
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-ir.spector verified that NYPA performed the required surveillances i
prior ~ to deenergizing-the line and daily while it was deenergized.
The protective tagging-was performed satisfactorily. Niagara Mohawk i
.was infor:ned, and the required guarantee was received from them prior to deenergizing. the transformer.
The maintenance was handled properly..
c.
On August 17, the high. pressure coolant injection system -(HPCI) was declared inoperable due to water being found in the turbine lube oil.
This was reported to the NRC via ENS. The lube oil sample was taken based on the known--leakage of the steam supply valve-(MOV-14) and the turbine seals. The oil sump was drained, cleaned and refilled.'After replacing the oil, HPCI was run satisfactorily.. An oil sample was then taken' to verify no presence of water' in the oil and HPCI was-
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f declared-operable. Thi; evolution was handled properly, i
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Excessive seal leakage has been observed by tne inspector when the system was started for surveillance testing.
The leakage slows as the-gland exhauster takes a suction. When the machine is idle, steam can leak - from MOV-14 and can. enter the lube oil snp through the
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shaft seals.
NYPA's short term corrective action has been to sample the oil weekly -and after every HPCI operation to verify no presence
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of water in the oil. The long term corrective actions were to per-form repairs on MOV-14 and the turbine seals to correct leakage-dur-ing the fall maintenance outage. These actions were determined to be adequate by the insputor.
The repairs will be reviewed during a subsequent-inspection report. F-2 d.. : pump.,but the punp would not. start..T work request was issued to On Agust 16, an attempt was made to start the B RHR service.weter
' troubleshoot.
The pump breaker was fouad to.have a broken ' prop
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spring..
This spring holds the breaker closed.
This' Magne-Blast B
AMH-4.76 circuit breaker had been through 1,625 cycles. The Peach
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Bottom Atomic Power Plant had repo-ted such spring failures at higher cycles and recommended changing out the springs at 2,000 cycles. The Maintenance Department plans on reviewing the number ' of cycles on
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'other safety related breakers cnd to complete inspections as nects-sary during the upcoming fall outage. The inspector will follow this in a subsequent report. F-3
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On August 3, NYPA reported via ENS the actuation of a partial Group
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IL isolation due to a grounded jumper during an instrument surveil-
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lance.
The ground caused a blown fuse in the B train of the Group II isolation logic. This resulted in one recirculation pump saal purge
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-valve. and the transversing incore probe nitrogen purge valve failing closed' The fuse was replaced and-the valves reopened within fifteen j
y rH+2s. - The inspector observed the operators -in the control room
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iespond to the actuation and concluded that their actions were proper-ana timely. This event was documented in LER 89-13-00. The inspec-tor found the corrective actions to be adequate.
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f.
(0 pen)~ Unresolved Item (88-11-01):
Acceptance criteria during sur-
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veillance tests..The inspector reviewed surveillance test (ST) 400,
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Daily Surve111ar.ce'and Instrument Check, Rev. 36, dated June 7, F B9.
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This procedure encompasses the daily checkr of instruments, contain-ment leakage, reactor coAnt system leakage and other c'aily checks.
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This item was initially.:.ened because the Operatio Department did not specify any acceptance criteria for leakage from the primary containment, This acceptance criteria has not yet been incorporated.
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During the review of the proceoure the inspector determined. that specific criteria for acceptability of TS required instrument. checks was not provided.
The only acceptance criteria applied to these
,
. instrument checks was " instruments should be in the normal expected
range' as determined by plant conditions, and then should agree with their separate, but redundant, comparison -instruments (if there is one) with ~ a reasonable degree of accuracy." While this meets the definition of an instrument check in section 1.F.4 of TS, NYPA should specify the required accuracies and,. where possible, the required rangesifor power operatSn.
Further, there are numerous TS instru-
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ments.that. require instrument checks.
The instruments are not
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-grouped-in the ST-to give a clear understanding which instruments are
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required for which TS.
NYPA has committed to reviewing ST-40D for
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incorporation of appropriate acceptance criteria. This item has been expanded to encompass this and will remain open 'pendf np inspector
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review of NYPA's actions.
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(0 pen) Violation (89-80-02.1): This violation was issued during the Safety Syste.n Functional Inspection (SSFI) due to the lack of an
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accurate standard during the calibration of fuel oil tank gauges.
During the period this problem resulted in an incorrect calibration.
Specifically, on August 23, the Operations Department performed sur-veillance test (ST)-9G, Emergency Diesel Generator (EDG) Fuel Oil and
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Combustion Air Class III Piping Pressure Test (ISI). Portions of the
testing were observed by the inspector. The intent of the surveil-lance is to drain the fuel oil day tank (F0DT) to permit operation of the fuel oil transfer pumps (FOTP) for 10 minutes to verify class III piping integrity. The D1 F0TP, while selected as lead pump, and the
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02 FOTP, selected as the backup pump, did not start at the required
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low.(7.5%)- and slow-low (5%) FOOT level, respectively.
These F0DT
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slet 's were:being monitored asing the ' installed level indicator on
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'theiDG local' panel.
With the D2 FGTP selected as the-lead pump,
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both pumps operated satisfactcrily. Based on this,- NYPA declared the
- D1 FOTP inoperable:and placed a special condition tag on the selecaor switch' to maintain the D2 FOTP as the - lead pump, This placed the
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plant.in aL60 day 'f0.
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I&C perfo.med troubleshooting-per Fuel Oil Day Tank Level Functional
~)
Test,. IMP 93.6.
It was. determined that the 01 (lead) and D2 (backup)-
- pumps istarted as required on actual FOOT level as measured using a dip stich.
The level transmitter and_ indicator were - found to be
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erratic at less than 15% day tank level.
This level transmitter had i
been used to calibrate the other separate tank level switches-that
.contro11ed ' the pump start functions on low and low-low F00T level, t
The pump was declared inoperable because an incorrectly calibrated-
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. installed level instrument was used as the standard to determine pump
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operability. This item remains op1.
h.-
(0 pen). Unresolved Item A3-29-10: Acceptability of crescent area unit
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-cooler testing.. The uqit coolers can be supplied with cooling flow from 'either the service water (SW) system (nonsafety-related) or
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' emergency; service water (ESW) (safety-related).
During this period NYPA performed testing using a temporary surveillance test (TST)-4 to
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determine the heat removal capacities of the crescent t.rea coolers while Ssing ESW as the cooling water source._ TST-4 testing demon-
-strated acceptable heat exchanger capabilities with ESW.
Surveil-
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1ance test ST-BA had previously been.used. to determine acceptable
= unit cooler operability-while using SW as.the cooling source.
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0nei concern remained open regarding system flow effects and their acceptability.
During testing under both SW and ESW, the unit
= coolers were. tested individually, but the system flow effects, i.e.,
-all ccolers being supplied, were -not measured. The primary consid-eration is that the flow from each of the five heat exchangers on the Y -
two headers are throttled to provide acceptable cooling when supplied by ESW. However, no testing has confirmed.the acceptability of these
. throttled valve positions, and the basis for tne throttle positions was not clear..
4.1 Safety Assessment
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The surveillance testing observed was prop: c;y conducted and con-trolled.
NYPA must continue their efforts ta e,sure that each sur-
veillance requirement is met with an applicaale acceptance criteria.
~The planned and correcti"e maintenance activities observed were k
conducted properly.
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5.
Emergency Preparedness-
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H a.
On August 4,.NYPA made an ENS call reporting a major loss of offsite
.; n notification capabilityL Thirteen sircns were lost during a severe
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c thunderstorm,.which had caused two ' power supply breakers to trip.
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.The-siren loss was identified by the Oswego County Warning-Point,
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- which promptly notified the FitzPatrick and Nine Mile ~ Point control '
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rooms via the R6diological Emergency Communication System (REOS). An additional ENS call was made on August 6, reporting-five sirens still out of service.. The-inspector determined ~that the transfer of ir'or-mation -' from the county to NYPA and NYPA's. 50.72 r< orting were adequate.
,
b.
. On.- August 21, the inspector discussed the observations-that NYPA had rMe with respect to the two practice drills that were-run in April and July.
' The' areas of difficulty were -personnel accountability,
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dose assessment and protective-action recommer.dations.
The actions taken by NYPA-to correct these areas were followed by the NRC team during the September 6,1989 drill, The results of this review are documented in Inspection Report 89-19.
5.1: Safety Assessment The internal NYPA reviews of the last two practice drill; were proper
and extremely self-critical.
The deficiencies noted and actions
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taken were well documented.
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'6.
Ergineerin'a and Technical Support I
Technical: Services personnel pm formed evaluations of the data
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t received during tha inservice tesi.1ng (IST) of the A and C residual heat removal: (RHR) pumps (see section: 4.a).1 This analysis concluded
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that the reason for the differential pressures being in the required
'
action range stemmed from -a - por 'ly defined baseline.
In April 1989 the flow transmitter used to determine the total pump flow was cali-
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brated and found to be reading the required 10,000 gpm when fiow was actually 9,500 gpm.
It appears, from review of the applicable pump differential pressure versus flow curves, that this 500 gpm discrep-
'
ancy was the cause of the baseline being approximately 10 psid higher than it should have been. This would cause the differential pressure at' which the ciert and raauired action ranges are entered to be higher than actu:11y requirc.
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The 'only -baseline. data-that had been iken on the pumps up until the April 1989 calibration included this-500 gpm error _. A review of nump o
idifferenH al pressure since the calibration', shows an initial drop in differential! pressure, followed byL a ' repeatable scatter of data.
= When the - 10 psid,. correction for the - 500 gpm error, was subtracted from the data points prior _ to the calibration, the scatter of data was within the.same ranges as after the calibration.
Oni August 17., the inspector._ attended the PORC meeting at which the
- analysis of-the-pump data was discussed. NYPA approved plans to use J
the digital flow-indicators ~on the process computer during testino to allow = more accurate setting of initial conditions. Also,.the estab-
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lishment of a new baseline per Technical -Services Performance Memor-
-andum PN 89-16 was approved.
The PORC - also approved -increasing the frequency of cesting of the pumps to once every two weeks. This would allow a substantial amount of' data To verify t5einew baseline prior to the scheduled fall main-
-.tenance ou tage.
i The. PORC also recommended that a mod *fication be implemented to increase tra accuracy of the pump discharge and suction _ pressure
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gages _ (see Section 4.a-and 6.c).
b.
On. August 24, the 1.. cpecto r attended the Plant Operations Review Committee : (PORC) meetir.g. Among other PORC business were two safety
'evalua+.iens; JAF-SE-89-908, detailed control room design review to
' resolve human engineerins deficiencies on main control room bench-
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-boards.and vertical panels and, JAF-5E-89-079, addition ~of RHR pump E.
test pressure gages.
v The - PORC1 discussion on these items war odequate.
Inspector review, y
after PORC. approval, showed the' evaluations to be proper and to meet
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the requirements of.10 CFR 50.59, for determining that no unresolved safety questior.s existed.
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.NYPA has known of the IST instrumentation range and accuracy defici-
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encies since Technical-Services completed a study in August.
The modification that was installed on the RHR pumps is only part of a total plant wide modification to enhance IST data usability.
The
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Resident' Manager has committed to reviewing this study and preparing
. modifications, where necessary, to enhance the instrumentation. This will be done on a case by case basis vhere the installed instrumenta-tion is not adequate to give acceptable IST da';a.
The extent to which other IST gages do act meet the Code requirements has not been i
completely addressed and is an Unresolved Item. 89-09-00
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. Safety Analysis-Procedures (10 CFR' 50.59). Audit. The purpose of the W
inspection was to audit the procedures-and processes used by NYPA to
- evaluate proposed changes to equipment, procedures, tests and experi--
'
ments _ to ensure compliance with:10 CFR 50.59 criteria. The inspector concluoed that the procedures were acceptable; Lowever, the adequacy of.the resulting. safety analyses was not assessed.
The following procedures were reviewei:
s WACP 10.1.6, Control of Modifications and Component Changes-
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'WACP 10.1.3, Jumpers, Li f ted I.eads, Temporary Modificatiuns
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_MCM 5 Minor Modifications
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MCM 4,:Nuc1 car Safety and Environmental Evaluations
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LERl89-12-00. This event report was-submitted to document the revien of: the three phased bolted short condition when emergency - diesel
.generaturs are.-paralleled with the 345 KV generator bus during test-
.ing..This.is discussed in the SSFI report, 89-80. section 4.5.1.3
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a
- and in' Resident Inspector Repe., 89-08, section 5.a.
A subsequent
. report was committed to be submitted by June 30, 1990, which will
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- document the long term corrective actions that could involve system modificatioi.s. The acceptability of emergency diesel generator oper-ation in parallel with the main generator was uncler review by the NRC staff and represents an Unresolved Item. 89-09-05 f.
- (0 pen) Viciation (89-80-05)
1..
On-June 30, LER 89-11-00 was-submitted to document the plugging of the errergency diesel generator (EDG) room floor drains. This item is discussed in S$FI - report-89-80, section 4.4.2.3.
The plugging was completed 'in 1979. without a 10 CFR 50.59 safet/
evaluation to pr_ event the toxic corrosion inhibitor used in the EDG coolant from entering the lake. This inhibitor was replaced with a non-toxic substance in 1986. The plugs were removed on May 31.
2; On. June 19, LER 89-10-00 was sebmitted documenting conditions s
outside the design basis or safety related environment enclos-ures housing safety related switchgear. This item is discussed in SSFI report 89-80, cection 4.4.2.2 and in resident Inspection Report 89-07, sectice 5.c.
On' May 19, these deficiencies,
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_ hich would have made the air conditioning units for these w
enclosures ' inoperable in the event of a high energy line break were corrected.
NYPA's actions to resolve these issues was adequate. The violation
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will remain open pending che review of NYPA's response to the violation, l
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~6.1" Safety Assessment l
F Technica1L Services-involvement in the EQ issue dealing with the SBGT
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fan run timers was proper and in accordance with WACP 10.1.11.
The
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. technical resolution of the pump differential pressure baseline issue
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forLthe A and C RHR pumps was well founded. Actions taken to resolve
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issues reised by the SSFI were timely and adequate to resolve safety Concerns.
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7.
-Radiological Protection a.
(Open) Unresolved Item (89-08-01):
NYPA spent quite a lot of time fixing the post' accident samp'ing system (PASS) and ensuring that all
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- samples could be taken during this period. On August 31, PASS was
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- declared operable.
The inspector atched a gaseous drywell sample
' being drawn on August 30. NYPA-alw successfully completed the other
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samples; small and.large volume reactor coolant and_ dryt. ell iodine and particulate. These samples were drawn in accordance with process surveillance-procedure (PSP)-17, PASS operating procedure.
These
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' efforts should'have been completed prior to the issuance of TS amend-
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ment 131 which established the requirements for PASS. The operabil-
-ity'of the system should be tracked and known at all times.
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PASS is included in TS 6.19, which requires that a program be imple-mented to ensure the rapability to obtain and analyze the above samples. This item will remain open until the inspectors review this
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program.
..
b.,
During troubleshooting-to determine the cause of the low RHR pump differential ' pressures (see Section-4.a), the I&C' department cali-
'brated the suction and. discharge pressure gages for the A snd C RHR
. pumps.
The inspector entered the area to monitor the reperformance i
H of the surveillance test and noted water spillage below the test con-nections for the A&C RHrt pump suction gages. These gages are located
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in an area not posted as a contaminated area. The inspector informed the radiological technician responsible for the crescent areas of the spill. The technician determined the spill area to be contaminated.
The water was cleaned up by the technician to prevent any spread of the contamination.
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The I&C' technicians performing the gage calibrations were self-monitors and were not required to have a specific Radiation Work Permit (RWP) to perform the calibration.
All radiological wor kers should be sensitive tc, potential changing radiological conditior.s due i
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to the work they perform.
I t 'l :, every worker's responsibility to ensure an area is left in the same radiological conditions as found.
T.f leakage--is.not contained or other conoitions change, the proper
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radiological protectirn personnel should be informed to perform sur-veys 'to ensure the rauiological conditions of an area are known at all times.
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.During the surveillance testing on the A and C RHR pumps, the inspec -
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tor-observed the enerators-having to utilizei a hear-hear in the vicinity-of. the: RHR pumps.
This:was a high noise area which made it difficult to communicate and.was also in a 25-30 mrem /hr. field.
.
There are other areas in the-room where the. noise is greatly reduced
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and.the background radiation-is minimal. (The.ALARA area between the; t RHR -pumps and core spray pump was noted to be 2-3 mrem /hr by the inspector.). This was discussed -with the Operations Superintendent, and' he 'said he is rware of this situation. He committed to obtaining-additional communications lines to allow the use of ALARA areas.
Th1s will be followed'in a' subsequent. report. F-4 l
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The-inspector' entered the east crescent to monitor the HPCI turbine luba_ oil change-out (see Section 4.c).
On August 17, general clean-
.liness of - this area was poor, with mud and turbine lube oil on the
- floor In. addition, a radiologically contaminated area boundary in the vicinity of the step off pad was not properly posted.
The inspector informed radiation protection of-thase observmons.
The insnector returned ' to: this area after HPCI was declar;J operable.
- Tne sate radiological boundary was not properly posted.
In addition, numerous protective clothing (PCs) and rags were left in the contam-n
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-inated area 'in a pile and some had fallen onto the step off pad K
(clean. area).
The PC laund y bags were overfilled and spilling to
- the floor outside the contaminatea area.
The oil and mud were still
present.
Plant management and * adiological personnel were informed
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of these observations.
The inspector _ was informed tnat personnel were in = the nrocess of cleaning the area. The inspector revisited
- the area.again on = August 21 and cleanliness was adequate at that time. The condition of the llPCI room after completion of corrective actions - and-declaration of system operability were seen by the inspectors-as'an indication-of poor quality wcrk.
~e.
Inspection report 89-08 contained a typographical error in Section H
6.c.
The amount of radioactive material consumet by the person who
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. drank the spiked lemonade was 1.5 uCu rather that 1.5 mCu as docu-
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mented in the' report.
b 7 ~.1 - Safety Assessment
' The 11nspector concluded that conduct of radiological work by the I&C j
technicians, the contaminated area barriers left not properly posted, the. utilization of communicatior, lines in high noise and radiation i
ao fieldLareas, and the condition of areas after corrective maintenance
,
represented radiological prngram weaknesses, which needed
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.W improvement.
These weaknesses were discussed with the appropriate station managers.
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i, 8.
Exit' Interview (30703)
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At periodm intervals ~ during the-course of this inspection, meetings were
- held with senior facility management to discuss inspection scope and find-ings. In addition, at'the end of the period, the inspectors met with NYPA
ln" representatives-and summarized the scope and findings of the inspection as
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they are described in'this report.
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l Based on the NRC Region I-review of this report and discussions' held with
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C NYPA representatives during the-exit meeting, it was determined that this
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repeet' does not contain information subject to 10 CFR 2.790 restrictions.
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