IR 05000333/1997007

Insp Rept 50-333/97-07 on 970831-1026.Violation Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20199H193
Person / Time
Site:	FitzPatrick
Issue date:	11/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20199H180	List: IR 05000333/1997007 ML20199H177 ML20199H184
References
50-333-97-07, 50-333-97-7, NUDOCS 9711260046
Download: ML20199H193 (29)

Text

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U.S. NUCLEAR REGULATORY COMMISSION i

Region I License No.: DPR 59 l l

Report No.: 97 07 Docket No.: 50 333

Licensee: New York Power Authority Post Office Box 41 Scriba, New York 13093

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Facility Name: James A. FitzPatrick Nuclear Power Plans Dates: August 31,1997 throuch October 26,1997

Inspectors: G. Hunegs, Senior Resident inspector R. Fernandes, Resident inspector L. Eckert, Radiation Specialist '

J. Jang, Senior Radiation Specialist Approve <' by: John F. Rogge, Chief, Projects Branch 2 -

- Division of Reactor Projects

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EXECUTIVE SUMMARY  !

i James A. FitzPatrick Nuclear Power Plant r NRC Inspection Report 50 333/97 07 l

Ooerations f

e Overall, the licensee operated the plant safely and activities were performed in ;

conformance with requirements. Effective controls were implemented to achieve ,

safe operation of the plan e An improperly substituted component (tachometer generator brushes) for the recirculation system by a vendor ultimately resulted in plant single loop operation due to recirculation motor generator set oscillations. Operators demonstrated excellent use of orocedures and control of the evolutio The licensee generated an action commitment tracking system item to plan replacement of the brushes for the other recirculation loop with a due dato of about 1 year past the potential f ailure date of the brushes based on operating experience. The inspector considered that, based on the due date, this planned corrective action was not prudent and could result in an unplanned plant translen o Operator response, including procedure use, to indications of an uncoupled control rod were good. The licensee's analysis of the cause including the operability determination were thorough and corrective actions appeared appropriate. The control rod has had two previous Indications which may have indicted that the uncoupling rod was misaligned. An additional rod may also be susceptible to becoming uncoupled based on previous work history and rod operating characteristic Maintenance o Overall, maintenance and surveillance activities which were observed were well conducted, with good adherence to both administrative requirements and maintenance and surveillance procedures, e The work activities associated with the "B" emergency diesel generator (EDG)

were generally well conducted and had good management as well as supervisory oversight. An error that occurred durlog the installation of a limit switch operating aim in the EDG breaker indicate that continued licensee focus on attention to detailis wmranted. Emergent maintenance issues, including the degraded voltage regulator transformer and contaminated fuel oil were adequately addressed,

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Executive Summary (cont'd)

• The licensee actions to address the potential for residual heat removal service water system degradation due to strainer gasket deterioration, including the operability review were appropriate. The previous modification to address strainer gasket cover leakage was ineffective in that the potential for the flow turbulence to destroy the gasket was not recognize * Generally, plant material condition was considered to be acceptable. However, there were several specific issues that detracted from the overall appearance and condition of the plant. The licensee adequately addressed the specific items which Were note * Incorrect oil was installea in several pumps. The procedure change program was not sufficiently controlled to ensure that work instructions to perform pump iubrication would be accurate. Additionally, review efforts were not through t nough to identify the error. The licensee's operability review and corrective Sctions associated with the pumps were timely and satisf actory. The improper development of a maintenance procedure which caused the error was a violatio '

EDaineerina

• The procedure written to control the evolution of moving spent fuelinto the outer racks met the constraints placed on the task by the safety evaluation. However,it was not clear that the planned task did not involve an unresolved safety question as discussed in 10 CFR 50.59, and the issue will remain unresolved pending further evaluatio Plant Sucoort

• The radioactive liquid and gaseous effluent control programs were well implemented. Good management control and oversight of the radioactive liquid and gaseous effluent control programs was noted. The radiation monitoring system (RMS) calibration program was wellimplemented. RMS reliability has been generally good. The air cleaning system program area was well-implemente Monitoring and trending of air cleaning system performance parameters was a noted strength. The technical depth of quality assurance audits was good and chemi. .ry laboratory quality assurance / quality control was very goo * Initial operator actions to investigate and respond to a fire protection system alarm were appropriate, although it was questionable whether it is necessary to remove an automatic function of a fire water suppression system from service due to the l fe'se alarm. Apparently poor coordination and cornmunication between different l acensee departments resulted in the fire protection system being isolated for a l longer period of time than was necessary.

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e Executive Summary (cont'd)

• Procedures were in place to direct the appropriate response to fires in the control room and control room evacuation in the event of a relay room CO, system discharge. Operators were knowledgeable of equipment operation and f amiliar with the associated procedures, i

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TABLE OF CONTrNTS EX ECUTIV E SU MM ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 T ABLE O F CO NT E NT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V Summ a ry of Plant St at u s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O PE R AT I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Ope r ations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 Operational Saf ety Verification . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Single Loop Operation ...............................2 O2 Operational Status of Facilities and Equipment ................... 4 02.1 Uncoupled Control Rod Drive . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ll . M AIN T EN AN C E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............... 5 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M1.1 General Comments on Maintenance and Surveillance Activities . . . 5 M1.2 Emergency Diesel Generator Maintenance ................. 6 M1.3 Re Wual Heat Removal (RHR) Service Water System Strainer Des t 1ation ......................................9 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . 9 M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . 10 M3.1 incorrect Pump Bearing Oil (Violation 50 333/97007 01) ...... 10 lli . E N G IN E E RI N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 El Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 E1.1 Moving Spent Fuel with the Reactor Building Crane (Unresolved item 50 3 3 3 /9 7 007-0 2 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 E8.1 (Closed) LER 5 0 3 3 3 /9 7 003 . . . . . . . . . . . . . . . . . . . . . . . . . . 14 IV. PL A N T S U PPO RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 14 R2 Status of RP&C Facilities and Equipment ..... ................ 15 R2.1 Calibration of Effluent / Process / Area / Accident Radiation Monitoring Systems (RMS) ...................................15 R2.2 Air Cleaning Systems ..............................16 R7 Quality Assurance (OA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . 16 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 17 S1.1 Operational Safeguards Response Evaluation (OSRE) . . . . . . . . . 17 F1 Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 17 F1.1 Fixed Water Suppression System . . . . . . . . . , . . . . . . . . . . . . . 17 F2 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . 18 F Control Room Fire Suppression System .................. 18 v

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Table of Contents (cont'd)  :;

I V. MAN AGEMENT MEETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 - f X1 Exit Meeting Summary . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19  ;

X2 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 i X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 X4 Licensee Organizational Realignment . . . . . . . . . . . . . . . . . . . . . . . . . 20

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ATTACHMENT i

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Attachment 1 Partial List of Persons Contacted Inspection Procedures Used l

- ltems Opened, Closed, and Discussed Ust of Acronyms Used -  ;

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Reoort Details i i

Summary of Plant Statug  ;

i The unit began this inspection period at 100 percent power. On August 31, reactor ,

operators reduced power to less than 54 percent due to large oscillations on the "A" recirculation (RWR) motor generator (MG) set. On September 1, reactor power was reduced to 43 percent and single loop operations were conducted to complete repairs to the RWli MG set. Reactor power was returned to 100 percent on September 1. The plant continued operation at 100 percent through the end of the inspection perio , OPERATIONS l 01 Conduct of Operations'

0 Operational Safety Verification '! lDRDection Scope

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The inspectors observed plant operation and verified that the f acility was operated safely and in accordance with procedures and regulatory requirements. Rac'.'lar tours were conducted of the plant with focus on safety related stn' tures and '

systems, operations, radiological controls and security. Addit:enally, the operability of engineered safety features, other safety related systems and on site and off site power sources was verified. The inspectors performed a walk down of accessible portions of the following systems'

emergency diesel generator ,

intake structure emergency service water  !

residual heat removal service water high pressure coolant injection ,

reactos core isolation cooling  !

The inspection activities during this report period included spection during normal, backshift and weekend hours. Regular tours were conducted of the following plant areas:

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' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic .

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controf room secondary containment building radiological control point electrical switchgear rooms emergency core cooling system pump rooms security access point protected area fence intake structure diesel generator rooms Control room instruments and plant computer indications were observed for correlation between channels and for conformance with technical specification (TS) requirements. The inspectors observed various alarm conditions and confirmed that operator response was in accordance with plant operating procedures. Compliecce with TS and implementation of appropriate action ,

statements for equipr'4ent out of service was inspected. Plant radiation monitoring system indications and coolant stack traces were reviewed for unexpected changes. Logs ano records were reviewed to determine if entries were accurate and identified equipment status or deficiencies. These records included operating logs, turnover sheets, system safety tags, and temporary modifications. Control room and shif t manning were compared to regulatory requirements and portions of shif t turnovers were observed. Daily supervisor meetings were attended to assess personnel focus on risk significant items and plant priorities, Observations and Findinas Overall, the licencoe operated the plant safely. Plant activities were performed in accordance with procedures and effective controls were implemented for safe plant operation. Overall, equipment operability, material condition and housekeeping conditions were good, Conclusions Overall, the licensee operated the plant safely and activities were performed in conformance with requirements. Effective controls were implemented to achieve safe operation of the plan .2- Single Loop Operation Insgretion Scope The inspector observed operator eations associated with single loop operat*ons, including procedure use and verified that Technical Specification requirements-were me Recirculation flow is varied by a variable v.a pump. Pump speed is varied by controlling the frequency of the AC power source to the motor. The variable AC

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t power is derived from a variable speed generator driven by a motor through a variable speed fluid coupling. The voltage of the pump motor is regulated as a function of speed and the voltage regulator uses a tachometer generator to generate a speed signal to the voltage regulator to control the generator voltage as a function of spee b. Observations and Findinna .

On August 31,large oscillations on the "A" recirculation (RWR) motor generator (MG) amps and voltage were observed. Operators reduced power to less than 54% which was less than 70% required to be outside the unstable region and manually locked up the scoop tube to mitigate the MG set oscillation ,

Troubleshooting efforts were begun and it was determined that the tachomotor generator was f aulty. To affect repairs, the licensee removed the "A" RWR pump from service por operating procedure (OP) 27 Recirculation System Sect G.2, Emergency RWR Loop A shutdown with Reactor in Startup or Run Mode, and entered abnormal operating procedure (AOP) 8, Loss of Reactor Coolant Flo The inspector noted excellent operator focus on plant parameters and appropriate concern for thermal hydraulic instability. Technical Specification 3.5.k, Single Loop Operation, requirements were me The tachometer generator was replaced in accordance with maintenance procedure (MP) 058.01, Recirc MG Set Outage Brush Maintenance. Operators ensured all requirements were met to restore the loop including surveillance test (ST) 20K, Recirc Loop Startup Differential Temperature Check, and returned the plant to normal operatio The licensee performed an equipment failure evaluation and determined that the tachometer generator f ailure was caused by excessive brush wear, which damaged the commutato ,

The inspector noted that the tachometer generator had been replaced during the 1996 refueling outage and the brushes had been replaced during a forced outage in May 1997. The licensee determined that brush life has shortened from 2 years to approximately 7 months beginning in February 1996 and investigated the reason it was determined that the vendor had supplied different brushes than what was specified on the licensee's purchase order. The licensee's purchase order had stated "no substitutions authorized," however, the vendor had substituted brushes but did not indicate such on the documentation. The brushes have different design and consequently operating characteristic The inspector noted that the "B" tachometer generator brushes were replaced on May 27,1997 and may therefore also be susceptible to similar f ailure af ter about 7 months of operation. Also, the uninterruptable power supply (UPS) MG set may be using an equivalent brush. The licensee has a brush monitoring program, however, the tachometer generator brushes are not visible. The licensee has generated an action commitment tracking system (ACTS) item to plan replacement of the "D" tachometer generator brushes. The inspector noted that the ACTS item

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dun date was December 31,1998. Based on the operating experience concerning the brushes and the potential plant impact,it was not clear to the inspector why the brush replacement would not be pursued more aggressivel Og jlusions An improperly substituted component for the RWR system by a vendor resulted in plant single loop operation. Operators demonstrated excellent use of proceduros and control of the evolutio The licensee generated an ACTS item with a duo date of about 1 year past the potential failure dato of a component based on operating experience. The inspector considered that the selection of this date for this planned correctivo action was not prudent and could result in an unplanned plant transient. The licensee acknowledged the inspector's concern and is in the process of developing a plan to replace the brushe Operational Status of Facilities and Equipment 0 Uncoupled Control Rod Drivo Inspection Scoom On September 20,1997 while performing control rod maneuvers for a sequence exchange, control rod drive (CRD) 1819 became uncoupled. The inspector reviewed operator actions, applicable proceduto and Technical Specification requirements and the operability assessment for the CR Observations and Findinns Control rod 1819 was originally at position 06. During the sequence exchange it was required to be withdrawn to position 48. While single notching the control rod from position 40 to 48, the CRD indicated that it was uncoupled and Abnormal Operating Procedure (AOP) 25, Uncoupled Control Rod, was entered. The CRD was inserted to position 44 to attempt to couplo the drive to the blad Subsequently, the CRD was withdrawn to position 48 and a coupling check was performed satisf actorily in accordance with ST 238, Control Rod Coupling Integrity Tes The licensee determined that there were several possible causes for the uncoupled control rod drivo. Those possible causes included interference in the fuel cell, control blado locking me::hanism f ailure, damaged control rod drive spud, damaged or misaligned control rod drivo inner filter, debris in the upper portion of the control rod drive and incorrectly installed control rod drive uncoupling rod. The incorrectly installed control rod drive uncoupling rod was determined to be the most likely cause based on analysis and work history, if an uncoupling rod is placed in one of the flow holes rather than in its intended position, it could come in contact with the top of the inner filter. When this occurs the uncoupling rod will either prevent

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the drive from reaching position 48 or the uncoupling rod will compress the locking mechanism and uncouple the control blade from the drive. The nature of the incorrectly installed uncoupling rod is such that when the drive is moved from position 46 to 48, there is a risk of inadvertently uncoupling the control ro The licensee elected to place the CRD at position 46 to prevent challenging the coupling in'.egrity of the drive. The control rod had successfully passed six coupling checks since it became uncoup'ed which provided reasonable assurance that the control rod drive is coupled to the blade. Additionally, impact on reactivity management was determined to be nominal and scram systems have not been affecteo. The affected CRD has been satisfactorily scram time tested twice during the current operating cycle most recently in July,1997 and the rod had not been at position 48 since the The inspector reviewed the work history of the control rod drive. The control rod drive had been in service since 1980. The inspector noted that the licensee had implemented the recommendations included in General Electric Services Information Letter (SIL) No. 052, Supplement 3, Control Rcrj Uncoupling Rod Replacement, dated March 17,1989. The SIL described additional actions to minimize the probability of control rod uncoupling. However, since the rod had been in service prior to the recommended actions, it was not subject to the additional quality contro The inspector also noted that the rod has had two previous indications in 1983 and again in 1993 which may have indicated that the uncoupling rod was misaligned. The problem was attributed to a reed switch problem when it may have been an indication that the control rod drive was incorrectly assembled. It was also noted that an additional rod,18-07, may be susceptible to becoming uncoupled based on previous work history and rod operating characteristics. I he licensee has scheduled these CRDs for replacement during the next refueling outag Conclusions Operator response, including procedure use, to indications of an uncoupled control rod were good. The licensee's analysis of the cause including the operability determination were thorough and corrective actions appeared appropriato, ll. MAINTENANQ1 M1 Conduct of Maintenance M1.1 General Comments on Maintenance and Surveillance Activities inspection Scopjt The inspectors observed selected maintenance activities to verify that activities were conducted in a manner sufficient to ensure reliable, safe operation cf the

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plant. The inspectors observed selected surveillance tests to determine whether the tests were conducted in accordance with technical specification and other requirement I The inspectors observed all or portions of the following work activities:

evatious High pressure coolant injection system maintenance e97-05166 345 KV line circuit breaker maintenance e97 06341 Hydraulic control unit 18 23 charging water header isolation valve e97 02280 Residual heat removal service water strainer inspection e97 07542 Filter fuel oil in emergency diesel generator +

e97 06549 Replace recirculation system motor generator Set "A" tachometer generator The inspectors observed portions of the following survelitance activities:

eST 8R Emergency Service Water Check Valve and Strainer Test eST 3A Core Spray Pump and Valve Operability Test

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eST 18 Main Steam isolation Valve Fast Closure Test eST 98 Emergency Diesel Generator Full Load Test Observations and Findinas

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The inspectors found the work performed under these activities to be professional and thorough. Technicians were experienced and knowledgeable of their assigned l

task. Activities were conducted appropriately and in accordance with procedural and administntive requirements. Good coordination and communication were observed dur.og performance of the surveillance activitie Conclusions Overall, the thove maintenance and surveillance activities were well conducted, with good adherence to both administrative requirements and maintenance and surveillance procedure M Emergency Diesel Generator Maintenance

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( The licensee entered a seven day limiting condition for operation (LCO) to conduct

! periodic maintenance on the "B" emergency diesel generator (EDG). The inspectors observed various portions of the activities, reviewed rnaintenance

. procedures and interviewed maintenance personnel to verify that the maintenance l activities resulted in the reliable operation of safety related equipment.- Activities ll observed included replacement of the EDG turbocharger in accordance with maintenance procedure MP 093.16, EDG Turbocharger Replacement, replacement

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of a voltage regulator transformer, replacement of a 4160 KV breaker housing limit switch, post work testing of breaker protective relays and EDG fuel oil replacemen b. Qhservations and Findinas The inspector observed the replacement of the EDG turbocharger and noted good participation by the EDG vendor and good management oversight and involvemen The inspector veafied that quality assurs nce and tool calibration records were satisf actory. The inspector discussed the activities with maintenance technicians and found them knowledgeable of the work and sensitive to the maintenance procedure requirement The inspector observed the post work testing of the EDG output breaker protective relays in accordance with work request (WR) 97 02061-00. The maintenance and operation staff performed the post work testing in accordance with the work request. The inspector noted good self checking and peer checking by the technicians and solid procedure us The inspector observed the replacement of a limit switch in the EDG output breaker. The licensee discovered that the control room annunciator alarm panel was not correct for the restoration position of the breaker. Through further investigation, it was determined that the breaker housing limit switch was not closing, possibly due to dirt accumulation or degradation. When replacing the switch the maintenance crew had mistakenly restored tl:e limit switch operating arm upside down, in tnis configuration the switch would not close upon breaker restoration which was again discovered during the tag removal process. The configuration was subsequently corrected by the maintenance staff and the breaker tested satisf actorily. The inspector considered this a personnel error by the electrical maintenance staff with minor safety significance, but warranting further attention by the licensee with regards to attomion to detail and self checkin While performing preventive maintenance on the EDG control panel, some charring on a transformer in the voltage regulating circuitry was noted. The exciter-regulator controls the generator voltage by controlling the amount of current delivered to the generator field. The transformer is one of three saturable transformers which when provided with the proper amount of current from the voltage regulator, provides the means for precise generMor voltage regulatio The licensee did not have any spare parts at the facility r or could one be obtained as safety related equipment. The licensce was able to procure one from another f acility and perform a commercial grade dedication of the replacement transforme The inspector reviewed the commercial grade dedication plan of the replacement transformer, which was done in accordance with work activity control procedure (WACP) 10.1.25, The Dedication of Commercial Grade items Utilized in Safety Related Applications, The plan included material description, summary of end use, seismic qualification, and selection of critical characteristics. The critical characteristics compared the damaged transformer with the new transformer, l including part number, dimensions, weight, insulation resistance, and coil l

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e resistance. The inspector questioned the licens6e's ability to dedicate the component without any technical design information from the component manuf acturer which was not available. This was of :oncern to the inspector because the licensee's procedure int commercial grade dedication relies, in part, on information from the vendor. Without this information the pre installation testing was of limited scope. The licensee stated that the electrical performance would be verified during the post work testing with the machine running and at that time the component would be considered qualified. The post work testing was completed satisf actorily and proper voltage regulation response was verified by the licensee's operations staf The EDG fuel oil was replaced with fuel oil that was stored in temporary tank Difficulties were encountered during the tank fill process, due to clogging of the in-line filter frorn the temporary storage tanks to the EDG fuel oil storage tanks. The licenseo changed the piping lineup from the bottom of the temporary tanks to the top of the tanks which resolved the fuel transfer problem. The EDGs were run multiple times following preventive maintenance activities. During the final run, fuel oil differential pressure began to trend up. The inservice filter was removed and found to contain a black substance which was later determined to be particulate matter, most likely contaminvion from the temporary fuel oil storage tanks. The licensee determined that at the rate of fouling, the filter would require change out every 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Filters were made available and the operations department was made aware of the concern. The filter that plugged is one of two engine driven fuel pump filters either of which can be placed into service during engine operation. Based on the rate of fouling and the availability of filters, the EDG was considered to be operable. Subsequently, the licensee filtered the fuel and subsequent fuel oil samples were satisf actory. EDG fuel oil samples showed that technical specification requirements were met however, particulate contamination exceeded the industry accepted maximum valu Although the 16mporary tanks were inspected prior to use, the residue was not detected, most likely due to the difficulty of inspecting the tank, which caused the f uel contamination, Conclusions The work activity was generally well conducted and had good management oversight as well as the routine supervisory oversight. An error which occurred during the installation of a limit switch operating arm indicated that continued licensee focus on attention to detailis warranted. Emergent maintenance issues, including the degraded voltage regulator transformer and contaminated fuel oil weru adequately addresse . _ - _ _ - _ -

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M Residual Heat Removal (RHR) Service Water System Strainer Degradation insoection Scoce On October 16,1997, during routine preventive maintenance on the RHR service water system strainer, the strainer basket cover gasket was determined to be significantly degraded. The inspector reviewed the maintenance history, operability review and discussed the event with the licensee, Observations and Findinas When the strainer was opened for preventive maintenance, the licensee identified that numerous pieces of the strainer basket cover gasket were in the strainer basket. The licensee determined dat the gasket had been a full sheet gasket which had been torn up by flow turbulence. The pieces which were found were less than the area missing which implies that portions of the gasket material had degraded to an extent to pass through the strainer. The licensee wrote deficiency and event report (DER) 97-1425 to address the issue. The RHR service water system provides cooling for the RHR heat exchanger. An operability review was performed and surveillance test conducted which determined that there was no effect on the RHR heat exchange The licensee dete. mined that the cover gaskets had been in place since 1992 and had been previously inspected in February 1997. The strainer gasket had been

- installed as a modification in an attempt to address basket cover leakage. As an identical gasket was installed in the other train of RHR ser/ ice water, the licensee intends to inspect the other train for similar problems at the next opportunity, Conclusions The licensee actions to address the potential for residual heat removal service water system degradation including the operability review were appropriate. The previous modification to address strainer gasket cover leakage was ineffective in that the potential for the flow turbulence to destroy the gasket was not recopize M2 Maintenance and Material Condition of Facilities and Equipmem Jaspection Scope On Geptember 3,1997, a routine plant tour was conducted with NRC management to assess general material condition and equipment status. Specific observations and the licensee's resolution to these observations are detailed belo _ _ - - _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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10 Observations and Findir'os A plexiglass cover was installed on the "B" control rod drive (CRD) pump gear box which was a diferent configuration to the "A" CRD pump. The licensee determined that this cover was m?st likely installed to allow observation of gear box operation and did not aff a ne CRD pump. However, the installation of the cover was not documented bt w lesign drawing and a problem identification (PlD) number 76652 was writtm to address the cove Tape was noted on the "A" CRD pump suction flange. The licensee determined there was no apparent reason for the tape and a PID was generated to remove the tap Debris including a yellow rubber boot and gloves was noted in the east and west crescent areas in the reactor building. The licensee cleaned up the area Emergent.y service water pumn packing leakoff water is directed to the floor. The licensee had previously developed a modification, D195108, to correct the pump packing bleed off lines and determined that there has not been any degradation of the pump support. The modification has not been schedule A high radiation area boundary rope in the reactor coro isolation cooling room was detached from the wall. The licensee reattached the rope and, during an extent of condition review, determined that there were four other radiation area boundary ropes which were not sufficiently attached. The radiation area boundaries were degra 'ed but acceptable. .The RES department response to this concern was considered to be aggressiv A different colored oil was nend in the "A" residual heat removal (RHR) keep fill system pump. The licensee documented the condition on DER 97-1191 to evaluate the condition. This issue is discussed in section M3.1 below, Conclusions Generally, plant material condition was considered to be acceptable. However, there were several specific issues which detracted from the overall appearance and condition of the plant. The licensee adequately addressed the specific items wh..n were note M3 Maintenance Procedures and Documentation M 3.1 Incorrect Pump Bearing Oil (Violation 50 333/97007-01) inspection Score The inspectors noted that a different colored oil was in the "A" residual heat removal (RHR) keep fill system pump oil reservoir. The licensee documented the

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condition on DER 97-1191 to evaluate the condition and determined that the incorrect pump bearing oil had been installed. The inspectors reviewed the DER, operability review and applicable procedures and discussed the error with licensee maintenance, planning and engineering personne b. Observations and Findinas Through discussions with the oil manufacturer, the licensee determined that the '

incorrect oil which was installed had parameters which were similar to the proper oil except that the viscosity was slightly higher. Additionally, the licensee discussed use of the incorrect oil with the pump vendor and noted that bearing temperatures were satisfactory and the relatively short duration of running with the wrong oil (DTE-26) would not be harmful to the pump. Based on these discussions, the licensee's operability review determined that the oil was compatible with the correct oil and acceptable for the pump and therefore pump operation was not adversely affected in the near term. Additionally, two other pumps, both associated with the radioactive waste sump system, had also had the incorrect oilinstalled. The licensee elected to drain and refill the bearing tube oil for the affected pumps as recommended by the vendor and completed this activity on September 9,199 The incorrect oil was installed in the "A" RHR keep fill system pump on August 22,1997 under routine preventive maintenance which was completed using work instructions under WR 96-03759. Previously, pump oil changes were accomplished using a maintencnce I ibrication procedure which was used for multiple pumps. Due to an ongoing effort to reduce the number of maintenance procedures, the original maintenance procedure governing pump oil changes was converted to a work instruction. A sw of work instructions was generated and was to be the basis for all pump lubrication. The work instructions were stored in a pre-plan that was copied to a preventive maintenance file which was used to generate individual work request work instructions. The pre-plan file was incorrectly created with an oil specification for DTE-26 instead of the correct oil, DTE-797. The error was " copied" to additional pump lubrication work instructions and was missed during work planning revie Maintenance procedure, MP-101.06, Lubrication of Pumps, Rev.12 has been withdrawn. However, the technical information in the procedure was incorrectly translated into work instructions which resulted in the incorrect oil being installed in several pumps. The improper development of a maintenance instruction is a violation (50-333/97007 01).

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i 12 Conclusions The procedure change was not sufficit.ntly controlled to ensure that work instructions to perform pump lubricetion would be accurt.te. Additionally, review efforts were not through enough to identify the error. The licensee's operability review and corrective actions associated witn the affected pumps were timely and satisfactory. The improper development of a maintenance procedure was a violatio . ENGINEERING E1 Conduct of Engineering E1.1 Moving Spent Fuel with the Reactor Building Crane (Unresolved item 50-333/97007-02) Insoection Scope Currently, the spent fuel pool does not contain a sufficient number of empty cells to allow the core to be completely off loaded daring the next refueling outage. To remedy this problem, the licensee has planned to install an additional spent fuel rack and to utilize cells that are currently inaccessible with the normal fuel servicing equipment. There are 113 spent fuel rack cells on the north, south, and east sides of the spent fuel pool that are inaccessible by the main hoist on the refuel bridge. The licensee prepared a 10 CFR 50.59 Nuclear Safety Evaluation to demonstrate that irradiated fuel assemblies can be moved within the spent fuel pool to the inaccessible locations using the 1000 lb. hoist on the reactor building crane. The inspector reviewed safety evaluation [[::JAF-SE-97|JAF-SE-97]] 003, Rev.1, "Use of the Reactor Building Crane to Move Irradiated Fuel Assemblies in the Spent Fuel Pool" and irradiated fuel handling procedure, RAP 7.1.05E, Rev 1, Transfer of Fuel to Peripheral Spent Fuel Storage Locations in the Spent Fuel Pool, to verify that the proposed activity by the licensee does not involve an unreviewed safety question, Qbservations and Findinos The proposed activity is the movement of spent fuel assemblies, within the spent fuel pool, using the reactor building crane, to rack locations inaccessible by the main hoist of the refuel bridge. The effective limits of travel of the refuel bridge (trolley), plus the main hoist mast, render 113 locations inaccessible using the refueling bridge. The licensee detennt.ed that modifications to the bridge to make cells accessible were not practical. The main hoist on the refuel bridge is the normal means of moving irradiated fuel within the pool and between the pool and the reactor vessel. The 1000 lb. hoist on the reactor building crane is routinely used to move new fuel from the storage pit to fuel preparation machine and to the fuel pool. The safety evaluation stated that the reactor building crane would be fitted with protective equipment and instrumentation similar to that available on

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the main bridge hoist. Furthermore, rigging will be installed to prevent lifting the fuel assembly more than 24 inches above the storage racks by a backup " limit switch," a primary limit switch will stop the assembly six to twelve inches below the backup switch. The hoist has a mechanicalload brake to control the lowering speed and prevent dropping the load in the event of an electric motor failure, and has an electric scienoid operated motor brake. An electronic crane scale or load cell with digital readout will be used to monitor the load and verify seating. Cells containing fuel assemblies to be move were tested with the refuel bridge prior to moving the assemblies with the reactor building crane hoist on June 9,1997. To minimize movement of fuel, fuel will only be moved from adjacent cells (within two storage cell locations).

The inspector discussed the safety evaluation and the procedure with the licensee and determined that the commitments and restrictions placed on the activity by the safety evaluation were captured in the revised fuel handling procedure. The inspector had a concern that the cells which were to receive the assemblies may have debris in them which coWd cause difficulties in moving the fuel. The licensee stated that most of the cells were previously tested to ensure there would be no binding of the assemblies. The newer racks did not have testing done because they were tested prior to installation. The inspector noted that albeit, the racks v,ere new, there had been two refueling outages since they were installed and therefore some what susceptible to foreign material which could cause problems in the future. The licensee acknowledged the comment and considered it for revie The inspector reviewed the technical specifications and the FSAR and did not find any requirements which prohibited the use of the reactor building crane to move irradiated fuel. However the FSAR, did not discuss the activity. In review of previously issued TS amendment No.175, dated December 31,1991, for increasing the capacity of the spent fuel pool, the NRC staff in approving the installation of the racks, noted that the fuel handling procedures in, and around, the pool will be the same as those procedures that were in effect prior to the proposed modification. The inspector concluded that had it been known at the time of the TS change that the fuel handling procedures were going to be different than those in place, then the staff would have taken that into account during their review. The licensee has placed administrative controls on fuel movement pending resolution of the issue, Conclusions The procedure written to control the evolution of moving the spent fuel into the outer racks met the constraints placed on the task by the safety evaluatio However, it was not clear that the planned task did not involve an unresolved safety question as discussed in 10 CFR 50.59, and the issue will remain unresolved (URI) pending further NRC review (50 333/97007-02).

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E8 Miscellaneous Engineering issues E (Closed) LER 50 333/97003: Potential Overpressurization of Containment Penetrations Due to Thermal Expansion. On February 13,1997 the licensee determined that overpressurization of containment penetrations could potentially be a condition outside of the design basis of the plant. The licensee discovered the condition while responding to NRC Generic Letter 96-06, Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Condition:. The licensee determined that pressurization of these penetrations due to thermal expansion of entrapped fluid between the containment isolation valves was not considered during the design of the plan The licensee reviewed 584 containment penetrations and determined that 8 required further review. The licensee's detailed operability determination, JPN 97-019, Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions, determined that contahment integrity is maintained and safety functions are not compromised for the susceptible containment penetrations. The memorandum provides a summary of the detailed evaluation, and identifies modifications to eliminate the susceptibility of thermal overpressurization. Long term corrective actions by the licensee include modmcation to three containment penetrations X 19 drywell equipment drain sump discharge, X 224 and X 226, reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) torus suction penetrations respectfully. The corrective actions are planned to be completed prior to start-up from the next refueling outag IV PLANT $_UPPORT R1 Radiological Protection and Chemistry (RP&C) Controls Inspection Scope The radiological liquid and gaseous effluent control program inspection was conducted which included: (1) plant tours; (2) review of selected chemistry procedures used to conduct the effluent control programs; (3) the 1996 Annual Radioactive Effluent Release Reports;(4) the Offsite Dose Calculation Manual (ODCM); and (5) the impact of hydrogen water chemistry and the ability to comply with 40 Code of Federal Regulations (CFR) 19 Observations and Findinos No discrepancies pertaining to release permits were found. The Annual Effluent Report was found to be complete. The ODCM contained required and site-specific parameters; no discrepancies were foun No significant discrepancies were noted during plant tours.

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No discrepancies pertaining to 40 CFR 190 were identified. The licensee had maintained a maximum hydrogen injection rate of 18.5 standard cubic feet per minute (SCFM) as noted in the last inspection of this program are Conclusions Good management control and oversight of the radioactive liquid and gaseous effluent control programs was note R2 Status of RP&C Facilities and Equipment R Calibration of Effluent / Process / Area / Accident Radiation Monitoring Systems (RMS) Insoection Scoce .

The inspectors reviewed the most recent calibration results for the following

. effluent and process RMS to determine the implementation of the Technical Specification (TS) requirements and Updated Final Safety Analysis Report (UFSAR)

commitments:

• Liquid Radwaste Discharge Monitor,

• Liquid Radwaste Flow Rate,

-* Service Water Discharge Monitor,

• Main Steam Line Radiation Monitors,

• Reactor Building Closed Loop Cooling Radiation Monitor,

• Main Stack - Normal and High Range Noble Gas Monitor * Main Stack Flow Rate

• Refuel Floor Exhaust Radiation Monitor,

• Reactor Building Exhaust Radiation Monitor,

• Turbine Building Exhaust - Normal and High Range Monitors, e' Radwaste Building Exhaust - Normal and High Range Monitors, and

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• Offgas Radiation Monitor l Observations and Findinas l No discrepancies in either the radiological or Instrumentation & Controls (l&C)

portians of RMS calibrations were noted. Good use and development of

calibration factors was noted.

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l The inspectors noted that despite the age of RMS, reliability has been good.

l Various parameters were trended. There were few open work orders at the

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The RMS calibration program was well-implemented. RMS reliability has be'en

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d R2.2 L Air Cleaning Systems-

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- T Inanection Scone The inspectors reviewed the licensee's most recent surveillance test results (visual inspection, in-place high efficiency particulate (HEPA) leak tests, in-place charcoal -t Ll eak tests, air capacity tests, pressure drop tests, and laboratory tests for the -

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lodine' collection efficiencies) for:, (1) the standby gas treatment system; (2) t_he- --

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- control room ventilation system; (3) technical support center system; and (4) the -i radwaste building air cleaning syste .-

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tn Observatlons and Findinas-

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All test results were within the licensee's TS acceptance criteria. Two individuals -

_within the Engineering Department had been assigned to manage the station . ,

. ventilation systems. All TS and UFSAR tests were conducted at the prescribed - >

frequencies.: Unsatisfactory test results were analyzed and corrective actions

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.were implemented in a timely manner. The inspectors noted that attention given

'to the air cleaning systems was good. The system engineers monitored and trended the performance of the air cleaning system During discussions with the ventilation systam. engineers, the inspe,rtors were informed that additional survel' lancer sn non-TS raled ventilation systems were -

-'under developmen Conclusient -

. The air cleaning system program area was well-implemented. Monitoring and trending of air cleaning system performance parameters " a= a notou strengt R7: Quality Assurance (QA)in RP&C Activities =

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The inspection consiste' d of: (1) review of the_1997 audits; (2) QA policy of the

> measurement laboratory; and (3) implementation of the measurement laboratory Lquality control (OC) program for radioactive and gaseous effluent samplesi p

Observations and Findinas The inspectors reviewed QA Audit Reports A97-05J and A97-06J. These audits ll -

i included the' implementation of: (1) the ODCM and TS requirements; (2) semi-

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annual radioactive effluent reporting requirements (Regulatory Guide 1.21); and (3) .

laboratory QC program. Audit team members identified several findings and observations including recommendations. The audit team identified several matters for enhancing the radioactive liquid and gaseous effluent control programs, but no items were of regulatory significanc Audit team members were composed of the licensee's technical staff, technical specialists from other utilities, and consultants. The depth of the audit was goo The inspectors considered chemistry laboratory QA/QC to be very goo ' Conclusion The technical depth of the QA audits was good ano .ry laboratory QA/QC was very goo S1 Conduct of Security and Safeguards Activities S Operational Safeguards Response Evaluation (OSRE)

An OSRE team inspection was conducted from September 15-18,1997. The inspection consisted of security _ system observations, staff interviews, observation of weapons familiarity and proficiency, observation of response drills and conduct of table top exercises, inspection results will be documented in separate currespondenc ,

F1 Control of Fire Protection Activities F Fixed Water Suppression System insoection Scoce During a routine control room tour, the inspector noted that the fixed water suppression system isolation valve to the turbine lube oil storage room was shu The inspector discussed the condition with operators, and fire protection personnel and reviewed fire protection procedure requirements, Observations and Findinas

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On October 9, during fire pump testing, a flow alarm occurred on the fire system header to the turbine lube oil fire suppression system. Operators responded

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appropriately by investigating the condition and subsequently isolated the system

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pending investigation of the cause of the' alarm. No other compensatory action

.was taken nor was required by procedures. The fixed water suppression system is described in FSAR 9.8.3.1.4, Fixed Water Suppression System, and is a wet pipe syste .

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The fire protection supervisor felt that a false ale:m had been generated, possibly due to a malfunction in the expansion tank. 6 't was a false alarm, once the initial condition was investigated, there was no apparent reason to keep the system isolated. Approximately two days after the event, the system was returned to service by opening the isolation valv Conclusions initial operator actions to investigate and respond to the fire protection system alarm were appropriate, although it was not clear whether it is necessary to remove an automatic function of a fire water suppression system from service due to a false alarm once conditions are reviewed. Apparently poor coordination and communication between different licensee departments resulted in the fire protection system being isolated for a longer period of time than was necessar F2 Status of Fire Protection Facilities and Equipment F2.1 Control Room Fire Suppression System InsDeetion _S_qnp_2 The inspector reviewed the licensee's fire suppression system in the control room and plant procedures for the use of the fire fighting equipment in the control roo The inspector included in the review procedures for inadvertent actuation of the fire suppression systems and review of the UFSAR basis for the systems, Observations and Findinas The control room does not have an automatic fire suppression system (AFSS).

Fire suppression is via portable CO2 cylinders and one fire hose station. The FSAR does not specifically address fire protection in the control room, however section 9.8.3.1.3 addresses interior hose stations and states that all points in safety related areas can be effectively reached by at least one hose stream. Abnormal operating procedure AOP-43, Shutdown From Outside The Control Room, addresses fighting control room fires and attempting to access the control room utilizing standard fire fighting equipmen Recent industry events have called into question procedures for responding to automatic actuation of fire suppression systcms in the control room. This is not applicable for the licensee's control room. However, AOP-63, Relay Room CO 2 Discharge, directs actions to be taken in the event that the relay room CO2 system is required for fire fighting. The relay room is directly underneath the control room and in the past, leakage of CO2 gas from the relay room AFSS activation has called into question the atmosphere of the control room. The system does not auto-initiate, manualinitiation is required. The procedure directs evacuation of personnelin areas that could be effected by the discharge end specifically addresses the control room. The procedure directs essential control room

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personnel to don control room breathing air provided for by the cascade air system or self contained breathing apparatus (SCBA). The remainder of the procedure discusses ventilation lineups and atmospheric sampling to establish habitability in adjacent area The use and monthly surveillance of the control room cascade air system is addressed by radiation protection procedure RP-RESP-2.04,' Revision 0, Cascade Air System. The procedure provides direction on use of the control room and the post accident sampling system (PASS) emergency cascade air systems. The system consists of two or three air cylinders connected in parallel to a regulating valve and supply hoses. Several air line respirators are stored next to the system in the control room for future use. The monthly surveillance verifies adequate cylinder pressure, proper low pressure alarm response and regulator performanc Emergency Plan implementing Procedure SAP-2, Emergency Equipment Inventory, Revision 22, performs a quarterly inventory and inspection of emergency-equipment. Attachment 12 of this surveillance includes the cascade air system equipment and the eight SCBA. The pre-fire plans also identify the fire fighting equipmont and SCBA in the control room. The inspector verified the numbers in the procedure inatched the equipment in the control room and were sufficient in quantity for control room personne Conclusions

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Procedures were in place to direct the appropria% response to fires in the control room and control room evacuation in the event of a relay room CO2 system discharge. Operators were knowledgeable of equipment operation and familiar

.with the associated procedure V. MANAGEMENT MEETINGS X1 Exit Meeting Summary l

The inspectors presented the inspections results to members of the licensee management at the conclusion of the inspection on November 14,1997. The licensee acknowledged the findings presented.

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l The inspectors asked the licensee whether any materials examined during the .

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inspection should be considered prq.ietary. No proprietary information was identifie X2 Review of UFSAR Commitments l

l A recent discovery rst a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or l parameters to the UFSAR description. While performing the inspections discussed

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related to the areas inspected. The inspector verit'ied that the UFSAR wording was consistent with the observed plant practices, procedure and/or parameter X3 Management Meeting Summary On September 4,1997, the NRC Systematic Assessment of Licensee Performance (SALP) management meeting was conducted at the licensee's training center auditoriu X4 Licensee Organizational Realignment On October 6,1997, the licensee announced an organizational change which was effective on October 20. W. Josiger, previously Vice President (VP) - Engineering was assigned as VP - Special Activities, in this role, he will work on NYPA's participation in the New York Nuclear Operating Company (NYNOC). H. Salmon, Previously VP - Operations was assigned as VP Engineering. The VP -

Operations position will be eliminated with the result being that the Site Executive Officer will report directly to J. Knubel, Sr. VP and Chief Nuclear Office . .. -

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ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED

- Licensee P. Brozenich, Operations Managar M. Colomb, Site Executive Offic W. Hamblin, Chemistry Supervisor A. Jarvis, Chemistry General Supervisor -

D. Lindsey, General Manager, Operations A. McKeen, Radiological and Environmental Services Manager E. Mulcahey, Radiological Engineering General Supervisor D. Ruddy, Director, Design Engineering D. Topley, General Manager, Maintenance 'i

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A. Zaremba, Licensir.g Manager

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INSPECTION PROCEDURES USED

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37551 Onsite Engineering 62707: Maintenance Observations 6172 Surveillance Observations 71707 Plant Operations 71750 PI' ant Support 84750-01 Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED

_Ocened-50-333/97007-01 VIO Technical information in a procedure was incorrectly translated into work instructions which resulted in the incorrect oil being installed in several pumps 50 333/97007 02 URI Possible unreviewed safety question concerning moving spent fuelinto the outer racks using the overhead crane vice refueling bridg Closed 50 333/97003 LER Potential Overpressurization of Containment Penetrations Due to Thermal Expansion Discussed

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p LIST OF ACRONYMS USED AFSS - Automatic Fire Suppression System

. ACTS Action Committment Tracking System

- AOP ' Abnormal Operating Procedure BWR Boiling Water Reactor' j CFR= : Code of Federal Regulations: ,

CRD' Control Rod Drive -

DER - Deficiency and Event Report

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EDG .Cmsrgency Diesel Generator-ES Engineered Safety Feature ,

FR . . Federal Register *

HEPA' High Effciency Particulate HPC High Pressure Coolant injection l&C Instrumentation and Controls

. lR Inspection Report  :

LER- Lice'nsee Event Report '

MG - Motor Generato ;

MP " Maintenance Procedure NRC' Nuclear Regulatory Commission .

NYNOC New York Nuclear Operating Company  ;

ODCM Offsite Dose Calculation Manual OP - Operating Procedure .

OSRE-- Operational Safeguards Response Evaluation .

PASS-. Post Accident Sampling System

~ PID Problem identification OA - Quality Assurance QC Ouality Control RCAL Radiological Controlled Area ,

RCIC : Reactor Core isolation Cooling RHR Residual Heat Removal

'RMS - Radiation Monitoring System RP . Radiation Protection i RP&C Radiological Protection and Chemistry f RWR Recirculation SCBA Self Contained Breathing Apparatus SCFM -Standard Cubic Feet Per Minute SIL - Services Information Letter

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T Technical Specification-UPS- Uninterruptible Power Supply

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' URl- Unresolved item

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WACP -Work Activity Control Procedur UFSAR- Updated Final Safety Analysis Report

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-VI Violation =

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