IR 05000333/1998003
| ML20237C958 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/18/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20237C943 | List: |
| References | |
| 50-333-98-03, 50-333-98-3, NUDOCS 9808240265 | |
| Download: ML20237C958 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
50-333 License No:
DPR-59 Report No:
98-03 Licensee:
New York Power Authority Facility:
' James A. FitzPatrick Nuclear Power Plant Location:
Post Office Box 41 Scriba, New York 13093 Dates:
June 1,1998 - July 12,1998 Inspectors:
G. Hunegs, Senior Resident inspector R. Fernandes, Resident inspector R. Fuhrmeister, Senior Reactor Engineer (7/6-10)
P. Kaufman, Project Engineer (6/15-19)
Approved by:
D. Lew, Chief, Projects Branch 2A l
. Division of Reactor Projects i
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I EXECUTIVE SUMMARY James A. FitzPatrick Nuclear Power Plant NRC Inspection Report 60-333/98-03 l
l This integrated inspection included aspects of licensee operations, engineering,
maintenance, and plant support. The report covered a six week period of resident inspection and the results of an announced fire protection program inspection by a regional inspector.
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Ooerations
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On June 9,1998, with the decay heat removal (DHR) system in service, the spent fuel pool (SFP) water level was lowered to a point at which the DHR pump lost suction. The cause was that the temporary operating procedure referenced incorrect SFP water levels. The licensea's development of a temporary procedure was inadequate in that reference points for controlling spent fuel pool level was based upon assumptions rather than plant drawings. The inadequate procedure development was a licensee identified and corrected violation and is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement
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Poliev. (NCV 50-333/98003-01) (Section 01.1)
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Opera: ors failed to properly implement the decay heat removal (DHR) operating procedure. Due to poor peacekeeping, operators did not complete the DHR j
operating procedure when the DHR system was placed in service. This resulted in
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the remote alarm circuit for the DHR system to not be enabled. The licensee identified and corrected failure to follow procedure was determined to be a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policv.
(NCV 50-333/98003-02) (Section 01.1)
Operator performance regarding the troubleshooting and operation of the
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uninterruptible power supply power source was poor. Operators failed to initially notice the abnormalline-up following the ground isolation procedure. Also,
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operators demonstrated a lack of questioning attitude and weak system knowledge when the dt.alindication was discovered on the alternate feed breaker. As a result the uninterruptible power supply (UPS) was lost. (Section 01.2)
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Two examples were noted where maintenance rule implementation was weak. The
uninterruptible power supply was not appropriately categorized as a maintenance preventible functional failure and the performance criteria for the high pressure
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coolant injection system was not updated following a reduction in the er ected system demands. (Section 01.2 and Section 08.2)
The inspector identified that the high pressure coolant injection (HPCI) system flow controller in the control roorn was indicating less than the required amount. The HPCI system was determined to be operable and the licensee corrective actions to replace the controller were prompt. (Section 08.2)
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Executive Suiomary (cont'd)
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Maintenance e
Two scram discharge instrument volume vent and drain valves experienced degraded performance during testing which resulted in commencement of a normal plant shutdown. Maintenance was conducted, the valves were mada operable and the plant shutdown was secured. The preventive maintenance program for the valves was ansidered to be weak as it contributed to the valve's failure.
The surveillance testing for the control room ventilation system was not properly e
developed in that the testing did not account for single failure design of the system motor operated valves (MOVs). The licensee had a previous opportunity to correct the test in 1995, but did not consider the additional impact on the control room ventilation system when the power supply for the inlet MOV was changed as the licensee did not recognize the requirement to test for single failure. The inadequate control room ventilation system surveillance test was determined to be a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control." This violation was identified and corrected by the licensee and is being treated as a Non-cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Poliev. (NCV 50-3333/98003-04)
The licensee's extent of condition review for a previous violation related to ventilation system testing requirements enabled the licensee to identify a control room ventilation system testing deficiency. The licensee's immediate corrective actions to isolate the control room ventilation system were timely and the extent of condition review was appropriate. (Section M3.1)
Plant Sucoort e
The fire protection program was being effectively administered. Fire fighting equipment, fire pumps, fire barrier penetration seals and fixed fire suppression systems were well maintained. (Section F.2)
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TABLE OF CONTENTS l
L EXEC UTIVE S U M M ARY.............................................. il l
i TA BLE O F CO NTEN TS.............................................. iv l
Summary of Plant Status
............................................1 1. O p e ra tio n s..................................................... 1
Conduct of Operations.................................... 1 01.1 Loss of Spent Fuel Pool Cooling......................... 1 01.2 Loss of Uninterruptible Power Supply..................... 3
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Quality Assurance in Operations (71707)....................... 5 07.1 NRC Review of institute of Nuclear Power Operations (INPO)
Training Accreditation Evaluation Report................... 5
Miscellaneous Operations issues (71707,92700,92901)........... 5 08.1 (Closed) Licensee Event Report (LER) 50-333/97012-00 and 97012-01;(NCV 50-333/98003-02).................. 5 l
08.2 (Closed) LER 50-3 3 3/9 8 005........................... 6 ll. M ainte na n c e................................................... 7 M1 Cond uct of M ainte nance................................... 7 M 1.1 General Comments on Maintenance Activities (62707......... 7 M1.2 General Comments on Surveillance Activities (61726)......... 7 M2 Maintenance and Material Condition of Facilities and Equipment....... 8 M2.1 Scram Discharge Instrument Volume Vent and Drain Valve Failures
...............................................8 M3 Maintenance Procedures and Documentation-.................... 9 M3.1 Control Room Ventilation Single Failure Vulnerability (NCV 50-3 3 3 /9 8 00 3 -0 4..................................... 9 -
M8 Miscellaneous Maintenance issues........................... 11 M8.1 (Closed) Violation 50-33 3/96007-01....................
1 1 lil. Engine ering................................................. 1 2 E8 Miscellaneous Engineering issues (92903).....................
E8.1 ' (Closed) Unresolved item 50-333/96005-03:............... 12 I V. Pl a nt S u p p o rt................................................. 1 2 F2 Status of Fire Protection Facilities and Equipment................ 12 F2.1 In-plant Fire Protection Equipment...................... 12 F2.2 Fir e Pu m p s.....................................
1 3 F2.3 Fire Barrier Penetration Seals.......................... 13
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I F2.4 Fixed Fire Suppression Systems........................ 14 a
L F3 Fire Protection Procedures and Documentation..................
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F3.1 Program Changes Since Last inspection.................. 15
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F4 Fire Protection Staff Knowledge and Performance................
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F4.1 Fi re D rill........................................
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Table of Contents (cont'd)
F4.2 Fi re Eve n t s...................................... 1 7 F7 Quality Assurance in Fire Protection.......................... 17 F7.1 Program Audits................................... 17 V. Manageme nt Meetings........................................... 18 X1 Exit Meeting Summary................................... 18 ATTACHMENT Attachment 1 - Partial List of Persons Contacted-Inspection Procedures Used-Items Opened, Closed, and Discussed
- List of Acronyms Used I
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I Report Details Summarv of Plant Status i
The unit operated at 100 percent reactor power at the beginning of the inspection period.
On June 4,1998, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown limiting condition for operation (LCO) was entered
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due to a scram discharge volume vent and drain valve test failure. Reactor power was
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l reduced to 45 percent at which time the valves were declared operable. On June 6,1998,
l the plant was returned to 100 percent reactor power. On June 13,1998, the "A" condensate booster pump (CBP) tripped and power was reduced to 65 percent. Following repairs to the CBP, reactor power was returned to 100 percent on June 16,1998. On June 17,1998, reactor power was reduced to 90 percent due to high temperatures on the
"A" recirculation motor generator set. On June 20,1998, reactor power was reduced to 45 percent for condenser water box cleaning. Power was increased to 60 percent on June 24 and returned to 100 percent on June 26,1998. On July 8,1998, reactor power was reduced to 70 percent to address outboard main steam isolation valve surveillance test failure and returned to 100 percent on July 9,1998. Reactor power was reduced to 65 percent on July 10 for as low as reasonably achievable (ALARA) considerations to install visual monitoring equipment for the main steam isolation valve and power was returned to 100 percent on July 11,1998 and remained there through the end of the j
inspection period.
j l. Operations
Conduct of Operations'
01.1 Loss of Spent Fuel Pool Cooling a.
Inspection Scope (71707)
On June 9,1998, while preparing to remove the spent fuel pool (SFP) cooling system from service for scheduled maintenance, the operators determined that the
"A" decay heat removal (DHR) pump was not providing adequate flow and secured cooling to the SFP. The inspectors observed the operators response to the loss of SFP cooling and reviewed the licensee's corrective actions.
b.
Observations and Findinas
it was subsequently determined that the SFP water level had been reduceJ to a l
point at which the DHR pump lost suction and was not providing adequate flow.
l The operators shut down the system and after investigating the reason for the loss of suction, increased the SFP water level and restored the DHR system to an
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operating status. The safety consequences of the event were minimal as the heat-l up rate for the SFP was low (~.25 degrees per hour) and the normal SFP cooling j
system was operable as it had not been disabled for maintenance. The operators
' 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 topics.
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entered the appropriate abnormal operating procedure and responded promptly to the event.
At the time of the event, the operators were lowering the spent fuel pool water level per temporary operating procedure (TOP)-282, Draining of the Fuel Pool Cooling System, Revision 0, in preparation to perform maintenance. When the control room was notified of the local low flow alarm, the evolution was secured.
Subsequent investigation by the licensee determined that the procedure was inadequate in that the water level references, utilized in providing direction on water level control, were incorrect. Loss of suction to the DHR pump was caused by lowering SFP level below the elevation of the DHR suction piping anti-siphon holes.
The TOP allowed pool level to be lowered a maximum of 12 inches in preparation for maintenance on piping at lower elevations in the system. The level band directed in the procedure was based on plant experience, which has been that the poollevel drops approximately 6 inches when the SFP system is secured. The control band was based on the reference mark on a ruler integral with the SFP wall, being 6 inches above the pool scuppers. Therefore the procedure directed that the SFP cooling be secured and lowered an additional 6 inches after the level was stable. The licensee subsequently determined, by additional drawing review, that the reference mark was closer to the bottom of the scuppers and the water level should have been lowered no more than 7.5 inches instead of 12 inches. The licensee concluded that there was ro damage to the DHR pump, and corrected the procedure and the safety evaluation. The inspectors concluded that the procedure preparation was not thorough and resulted in the loss of suction to the DHR pump.
Assumptions were used to develop the reference points for the TOP rather than the use of plant drawings. The inadequate procedure development was a licensee identified and corrected violation and is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Poliev. (NCV 50-333/98003-01)
In addition, the remote alarm circuit for the DHR local control panel was not enabled by the operators when the system was originally put into service. The operating procedure to line-up and start the DHR system, OP-30B, Decay Heat Removal System, was not completed and the low flow alarm condition was not annunciated in the control room, as designed. The licensee determined that the operator did complete the procedure because of poor place keeping. Corrective actions included management re-enforcement to operating shifts the importance of proper place I
keeping and of providing back up to shift members by reviewing completed l
procedures. The inspector concluded that operator performance concerning l
procedure use was poor. The corrective actions to address procedure use were adequate. The licensee identified and corrected failure to follow procedure was determined to be a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policv. (NCV 50-333/98003-02)
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c.
Conclusions
On June 9,1998, with the decay heat removal (DHR) system in service, the spent fuel pool (SFP) water level was lowered to a point at which the DHR pump lost suction. The cause was that the temporary operating procedure referenced incorrect SFP water levels. The licensee's development of a temporary procedure was inadequate in that reference points for controlling spent fuel pool level was based upon assumptions rather than plant drawings. The inadequate procedure development was a licensee identified and corrected violation and is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRO Enforcement Policy. (NCV 50-333/98003-01)
Operators failed to properly implement the decay heat removal (DHR) operating procedure. Due to poor peacekeeping, operators did not complete the DHR
. operating procedure when the DHR system was placed in service. This resulted in i
the remote alarm circuit for the DHR system to not be enabled. The licensee y
identified and corrected failure to follow procedure was determined to be a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policv.
(NCV 50-333/98003-02)
01.2 Loss of Uninterruptible Power Supply l
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Insoection Scope (71707)
On May 8, with the plant in a cold condition, the power to the uninterruptible power supply (UPS) was lost while transferring the bus from its normal power supply to the alternate feeder. The inspectors reviewed the operators response to the event and observed portions of the post event troubleshooting activities. The inspectors also reviewed the licensee's critique of the event.
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Observations and Findinos On May 8,1998, the UPS was lost while transferring the UPS to the alternate t
feeder. Following the loss of the UPS, the reactor water clean-up (RWCU) system
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isolated, by design, and the operators established alternate means of reactor vessel water level control. While the plant is shut down, the excess reactor coolant system (RCS) water introduced through the control rod drive system, is let down to the main condenser via the RWCU system to control reactor vessel water level.
The UPS was restarted in approximately 12 minutes and the let down path to the main condenser was established approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> later. Based on interviews with the operators and review of Abnormal Operating Procedure (AOP) 21, Loss of UPS, the inspector concluded that appropriate actions were taken following the loss of the UPS.
During the previous shift, while attempting to locate a ground on the direct current l
(DC) power system in accordance with AOP-22, DC Power System Ground Isolation, the DC power supply breaker to the UPS was opened and closed.
Unknown to the operators, this action de-energized a relay which would i
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subsequently allow the UPS to automatically shift to the DC power source following a loss of the AC power source. The following day an operator on rounds noted that l
the red " Ready for Auto Operation" light was not illuminated at the UPS control panel. It was determined by the operators that the UPS had to be put on the alternate power source to reset the swapover logic. When operators were preparing to manually transfer the UPS they noted that the position indication window for the alternate feeder breaker was in an abnormal position (green / red). In spite of this observation, the operators were directed to contir.ue with the transfer. The subsequent attempt to switch the UPS to DC power failed and the UPS bus was de-energized. The licensee's critique of the event determined that the evolution to shutdown and restart the UPS should have been stopped when the operators were faced with multiple system irregularities and when they discovered the alternate feeder breaker in the abnormal position.
The inspector reviewed previous plant operating history concerning the UPS.
During a plant trip on September 16,1996, the UPS was on the alternate feed for preventive maintenance. Following the transient, the alternate feeder breaker tripped open on under voltage. The restoration of power to the UPS was delayed as a result of the operators lack of knowledge on the operation of the unique breaker mechanism. Corrective action for the previous event included training on the resetting of the alternate feeder breaker it does not appear that this training was fully effective in that operators failed to recognize that the breaker, during this recent event, was in the tripped position.
The inspector reviewed the maintenance rule aspects of the current event and noted that the UPS is part of the 120 volt distribution system for performance monitoring.
The inspector noted that the functional failure review performed by the licensee stated that a review was not required because the plant was not operating.
However, this confi; cts with the system basis document in that the UPS is considered an operating system in all modes of plant operation. The current basis document, Revision 3, dated September 25,1997, list the maintenance rule unavailability criteria for the UPS as "under review." In review of the event the inspector concluded that the UPS was in a condition that if called upon to transfer to an alternate source, it would not have because of the previous weakness in the ground isolation procedure. Therefore the failure should be documented as a maintenance preventable functional failure (MPFF). The inspector concluded that the basis document was weak in that it was not being updated in a timely manner and that the failure should have been considered a MPFF. The licensee concurred with the inspectors observations.
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Conclusions Operator performance regarding the troubleshooting and operation of the aninterruptible power supply power source was poor. Operators failed to initially notice the abnormalline-up following the ground isolation procedure. Also, operators demonstrated a lack of questioning attitude and weak system knowledge when the dualindication was discovered on the alternate feed breaker. As a result the uninterruptible power supply (UPS) was lost.
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Two examples were noted where maintenance rule implementation was weak. The uninterruptible power supply was not appropriately categorized as a maintenance preventible functional failure and the performance criteria for the high pressure coolant injection system was nat updated following a reduction in the expected system demands. (also see Section 08.2)
Quality Assurance in Operations (71707)
07.1 NRC Review of Institute of Nuclear Power Operations (INPO) Training Accreditation Evaluation Report The NRC reviewed the June 1998 INPO Training Accreditation Evaluation Report which was based on an INPO review conducted from March 23 to 27,1998. The report covered non-licensed operator, reactor operator, senior reactor operator, shift manager, and shift technical advisor training. The report was generally consistent
.vith the most recent NRC assessment of the licensed operator requalification training program which was performed in April 1998.
Miscellaneous Operations issues (71797,92700,92901)
08.1 (Closed) Licensee Event Report (LER) 50-333/97012-00and 97012-01;(NCV 50-333/98003-02):drywell personnel airlock outer door seals local leak rate test not properly performed. An incorrectly labeled local leak rate test valve (16LLRT-930)
resulted in improper performance of 10CFR50, Appendix J, Type B local leak rate test (LLRT) on the outer primary containment building personnel access door (i.e.,
the outer seals were not tested properly). Technical Specification 6.20 requires primary containment leakage rate testing to be accomplished in accordance with the primary containment leakage rate testing program. Section 6.4.2 of the program requires that the airlock door seals be tested prior to re-establishing containment integrity and within seven days after airlocks are opened when containment integrity is required.
On December 14,1997, while performing a reactor startup with power at 25 percent, a non-licensed operator discovered valve 16LLRT-930 was incorrect!y labeled. The licensee determined that the valve had been mislabeled, due to personnel error, during valve replacement on November 15,1996. Based on a historical review, the licensee determined that the mislabeled valve resulted in invalid performance of the Type B local leak rate test on the personnel airlock outer door seats since November 24,1996. This particular LLRT test was performed six times since the labeling error. There were no actual consequences of the loss of configuration control as the airlock door seals were satisfactorily tested using the correct LLRT test connection on December 15,1997.
The inspector conducted an onsite inspection including a review of the deficiency and event report (DER) 97-1753 root cause analysis evaluation, a review of updated drawing DSK-16G, Revision 2, a review of the LLRT test results on the inner door seals and airlock volume and verified that corrective actions documented in the LER were implemented. The inspector found that the licensee's corrective actions were
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being properly tracked in their Action Commitment Tracking System (ACTS) and
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appeared to be appropriate to preclude a repeat occurrence. This licensee-identified
. and corrected violation of Technical Specification 6.20 is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policv.
f (NCV 50-333/98003-03)
08.2 (Closed) LER 50-333/98005: High Pressure Coolant injection System Inoperable Due to Lower Than Normal Flow Controller Output a.
Insoection Scope (71707)
i On May 29,1998, the inspector identified that the high pressure coolant injection (HPCI) flow controller, 23FIC-108, was reading less than the required 100 percent j
output. The inspector discussed his finding with operations management personnel, i
reviewed the equipment failure evaluation (EFE) performed on the failed controller and reviewed operator practices concerning panel walkdowns.
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Observations and Findinas I
In accordance with Operations Department Standing Order (ODSO)-4, Shift Turnover And Log Keeping, the reading should have been greater than or equal to 100 percent. The shift manager subsequently declared the system inoperable after instrument and con.trols (l&C) technicians determined that the controller output voltage was low and made a four hour non-emergency report in accordance with
The faulty controller was replaced and post work testing included running of the HPCI system. The EFE determined that the controller's output had decreased from a normal output of 51 milliamps (ma) to an output of 48 ma. The EFE also determined that the controller was capable of performing its function of controlling the speed of the turbine, such that flow was at least 4250 gallons per minute (gpm). The cause of low output voltage was determined to be a random failure of a
capacitor. The controller had been in service since 1995. The licensee's review of similar events at the plant and in the industry did not identify other similar events.
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In addition to the recent replacement of the flow controller, it had been replaced twice since 1994. The inspector reviewed the documentation associated with the previous replacements and concluded that the f ailures were not similar. The inspector reviewed the procurement documentation for the replacement controller and similar controllers. The controllers were refurbished by a vendor utilizing appropriate quality controls.
The HPCI system is currently being monitored under (a)(2) of the maintenance rule.
The inspector reviewed the performance criteria (PC) established for the HPCI
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system and noted the system functional failure PC was established at three. This l
criteria was based on severalitems including expected system demands of 33
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during the cycle. The inspector noted however that following the implementation of technical specification amendment 241,in December,1997, the monthly l
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surveillance testing which initiates the HPCI system, is no longer required. As such,
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the demands on the system would be reduced by approximately 20 to 22 demands
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Operations department standing order, ODSO-4, provides instructions for shift l
turnover and log keeping. The HPQ flow controller output is verified per attachment 4, control and relay room checklist, by the off-going shift personnel and
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by the on-coming shift personnel. The inspector discussed the procedure with l
licensed operators and concluded that the procedure was being conducted properly.
c.
Conclusions
l The inspector identified that the high pressure coolant injection (HPCI) system flow controller in the control room was indicating less than the required amount. The HPCI system was determined to be operable and the licensee corrective actions to replace the controller were prompt. There were no violations of NRC requirements:
LER 50-333/98005is closed.
11. Maintenance I
M1 Conduct of Maintenance M 1.1 General Comments on Maintenance Activities (62707)
The inspectors observed all or portions of the following work activities:
- Reactor Analyst Procedure (RAP)-7.1.05E, fuel moves a various WR, tighten control room pressure boundary
- WR 98-02357, scram discharge volume vent and drain valves stem lubrication
- WR 98-02290, high pressure coolant injection (HPCI) flow controller troubleshoot and repair The inspectors observed that the work performed to the above work requests (WRs)
and procedures was conducted satisfactorily.
M1.2 General Comments on Surveillance Activities (61726)
The inspectore observed all or portions of the following surveillance activities:
e ST-98, Emergency Diesel Generator Full Load Test and Emergency Service Water Pump Operability Test I
- ST-20M, Scram Discharge Volume Vent and Drain Valves Full Stroke and Timing
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The licensee conducted the above surveillance activities appropriately and in accordance with procedural and administrative requirements. As applicable, good
. coordination and communication with the control room were observed during performance of the surveillance.
M2 Maintenance and Material Condition of Facilities and Equipment M 2.1 Scram Discharge Instrument Volume Vent and Drain Valve Failures a.
Inspection Scope (71707)
The inspectors observed the licensee's initial corrective actions and reviewed the testing and maintenance history with respect to degraded performance of scram discharge instrument volume vent and drain valves.
b.
Observations and Findinas
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On June 4, with the plant operating at 100% power, during the performance of surveillance testing, the inboard drain valve for the west scram discharge instrument j
volume (SDIV) exceeded the in-service testing (IST) closing time criteria. During j
subsequent testing, the outboard vent valve for the east SDIV failed to completely re-open when the test switches were returned to normal. The licensee made a one hour report in accordance with 10CFR50.72 and commenced a normal plant shutdown. The valves were tested satisfactorily during the same shift and the plant shutdown was secured.
The two valves are included in the eight valves that comprise the SDIV vent and drain valve population. Both valves were cycled satisfactorily following the initial test and all the valves were lubricated and cycled severat times following the initial failures. The valves are cycled and tested quarterly in accordance with surveillance test ST-20M, Scram Discharge Volume Vent and Drain Valves Full Stroke and Timing Test. Initial corrective actions included daily testing of the valves and following a successful trending of data was changed to weekly testing.
The licensee's equipment failure evaluation (EFE) based on non-intrusive visual inspection concluded that the most likely cause of failure was friction between the valve stem and packing. The EFE inferred that this is an industry phenomenon where graphite packing standing idle over a period of time can cause an increase in the initial break away force required to stroke the valve. Long term corrective actions include reviewing the preventive maintenance schedule and inservice test (IST) requirements for the valves and overhaul of the valves during the next refueling outage. The inspector concluded that the licensee's root cause determination was reasonable and that the initial and planned corrective actions were good.
The inspector reviewed the work history and technical manuals for the valves and
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valve air operators. The valves had a previous history of poor performance and in
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1992 maintenance was performed on the operators. At that time, the valves were
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put on an eight year preventive maintenance period. The licensee's preventive maintenance program was developed by considering equipment operating performance as well as manufacturer's recommendations..Since that time the
- valves have had intermittent failures and were repaired with corrective maintenance.
During the review of the manufacture's information on the valves the inspector determined that there was a difference between the manufacturer's recommendations and the licensee's maintenance plan. The manufacturer recommended monthly cycling of the valve-actuator assembly, annual disassembly j
of the valve, and replacement of the o-rings around the stem every five years. In addition, the graphite packing manufacturer recommended routine replacement of
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the packing after three years of service. Albeit these are recommendations, they l
appear to be more frequent than the planned eight year maintenance period that the licensee uses. In addition, the inspector could not find any evidence, with one exception, that the graphite packing had been replaced on any of the valves since installation. The inspector concluded that the maintenance program for the valves was weak and that it contributed to the most recent failure and plant down power.
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Conclusions
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Two scram discharge instrument volume vent and drain valves experienced degraded performance during testing which resulted in commencement of a normal plant shutdown. Maintenance'was conducted, the valves were made operable and
~the plant shutdown was secured. The preventive maintenance program for the
- valves was considered to be weak as it contributed to the valve's failure.
M3 Maintenance Procedures and Documentation M3.1 Control Room Ventilation Single Failure Vulnerability (NCV 50-333/98003-04)
a.
Insoection Scope 162707. 61'726,71707)
' The licensee determined that the surveillance test (ST) for the control room ventilation system was'not adequate. The inspector reviewed the licensee's corrective actions; deficiency and event report (DER) number 98-01319; modification M1-94-057, Electrical Separation of Control Room Ventilation intake Air isolation' Valve and Damper; and discussed the issue with the system engineer.
' Additionally, a control room ventilation system walkdown was performed.
~ b.
Observations and Findinas The licensee's June 17,1998, reply to the Notice of violation in NRC inspection report 50-333/98001 included a review of other surveillance tests that verify h
building isolation to confirm that leak rates were being measured properly. The results of the review identified a concern associated with testing the single failure design of the control room ventilation system. The licensee documented the condition on DER 98-01319 which identified that the control room ventilation -
system was not being tested for single failure of the ventilation inlet and outlet motor operated valves (MOVs). The licensee determined that the control room inlet
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and outlet MOVs have the same power supply which introduced the potential single failure of both MOVs. The inspector noted that the control room is required to be
. single failure proof. The licensee's immediate corrective actions were to align the control room ventilation system in the isolate mode by closing the appropriate MOVs and to tag open the MOV breakers. ST-18, Main Control Room Emergency Fan and Damper Operability Test, was revised to be performed with the MOVs open (i.e. the failure mode) and reperformed on June 30,1998. ST-18 failed and the control room ventilation system was placad back in the isolate mode.
In 1994, the licensee installed a modification to provide electrical separation for the control room ventilation intake air isolation valve and damper. The modification resulted in both the intake and outlet air isolation valves being supplied by the same power supply. At that time, ST-18 accounted for the failure of one MOV as the licensee had not identified the need to perform the test with both MOVs failed open.
The testing was further degraded in 1995 when ST-18 was revised to test the system with both MOVs shut. The licensee had determined that having the MOVs fail to shut was be overly conservative.
The inspector noted that the control room ventilation system, which includes the relay room ventilation system, was classified as maintenance rule classification (a)(1) system due to the frequency of relay room ventilation system functional failures. The recent control room ventilation system failure was appropriately classified as a functional failure under the maintenance rule. The inspector noted that corrective actions were continuing to address system performance concerns and that the licensee was evaluating the long term impact of operating the control room ventilation system in the recirculation mode.
The surveillance testing for the control room ventilation system was not properly developed in that the testing did not account for single failure design of the MOVs. The licensee had a previous opportunity to correct the test in 1995, but did not consider the additional impact on the control room ventilation system when the power supply for the inlet MOV was changed as the licensee did not recognize the requirement to test for single failure. The inadequate control room ventilation system surveillance test was determined to be a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control." This violation was identified and corrected by the licensee and is being treated as a Non-cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Poliev. (NCV 50 3333/98003-04)
The licensee's extent of condition review for a previous violation related to
{
I ventilation system testing requirements enabled the licensee to identify a system testing deficiency. The licensee's immediate corrective actions were timely and the extent of condition review was appropriate.
c.
Conclusions The surveillance testing for the control room ventilation system was not properly developed in that the testing did not account for single failure design of the motor operated valves (MOVs). The licensee had a previous opportunity to correct the i
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test in 1995, but did not consider the additional impact on the control room ventilation system when the power supply for the inlet MOV was changed as the licensee did not recognize the requirement to test for single failure. The inadequate control room ventilation system surveillance test was determined to be a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control." This violation was identified and corrected by the licensee and is being treated as a Non-cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policv. (NCV 50-3333/98003-04)
The licensee's extent of condition review for a previous violation related to ventilation system testing requirements enabled the licensee to identify a control room ventilation system testing deficiency. The licensee's immediate corrective actions to isolate the control room ventilation system were timely and the extent of condition review was appropriate.
M8 Miscellaneous Maintenance issues M8.1 (Closed) Violation 50-333/96007-01: Incorrect Exchange of Tiiree Control Rod Drives a.
Insoection Scone (92702)
NRC inspection report 50-333/96007 documented that control rod drives (CRDs) to be removed were not accurately located prior to their removal on November 11, 1996, which resulted in the incorrect removal of three CRDs. The inspector reviewed the licensee's corrective actions in response to the violation and the following documents:
Corrective actions documented in the licensee reply to notice of violation
letters dated January 17,1997 and revised reply letter dated February 21, 1997.
Maintenance Procedure (MP)-004.03, CRD Rernoval and Replacement,
Revision 18.
Administrative Procedure (AP)-01.08, Control of Contractor and Vendor
Activities, Revision O.
b.
Observations and Findinas MP-004.03, CRD Removal and Replacement, was revised to incorporate a core map with reference points and verification steps were added to ensure that the correct CRD units are initially identified and selected. The inspector found the addition of the core map and verification steps in the revised procedure to be satisfactory.
Management expectation guidelines regarding oversight of contractor personnel were developed and proceduralized in AP-01.08, Control of Contractor and Vendor Activities, Revision 0, dated June 30,1997. The administrative procedure
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adequately addresses management's expectations regarding contractor oversight
- including work oversight, quality, questioning attitude, and open communications.
c.
Conclusions The revised procedures and corrective actions taken appropriately address the cause and factors associated with the incorrect removal of three control rod drives by contractors during the previous refueling outage.
lil. Enaineerina E8 -
Miscellaneous Engineering issues (92'903)
E8.1 (Closed) Unresolved Item 50-333/96005-03: drywell continuous atmosphere monitor control room alarm / indication. ' During a review of the process radiation monitoring system, the inspector determined that the current plant configuration with regards to the drywell continuous atmosphere monitor system (CAMS) did not match the Updated Final Safety Analysis Report (UFSAR). The UFSAR description of the. reactor coolant leakage detection system stated that the drywell CAMS has annunciators and recorders in the control room, which is not the case. The operation of the CAMS in a manner inconsistent with the UFSAR was determined to be an unresolved item. The licensee subsequently completed a safety evaluation and determined that an unreviewed safety question did not exist. The safety
- evaluation determined that there was no credit taken in the existing accident
,
analysis for use of the CAMS in detecting and preventing the occurrence of a primary coolant boundary failure, the CAMS does not perform a safety-related o.
function, and the operation or lack of operation of control room alarms and recorders does not impact other safety related systems. The licensee also determined that the lack of a control room alarm and recorders for the CAMS is not consistent with the design specifications and was an oversight during plant construction. The licensee documented in the UFSAR that a modification will be l
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initiated to provide the drywell CAMS with alarms and recording capability in the control room. The inspectors deterrained that a violation does not exist, this item is closed.
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IV. Plant Support
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F2 Status of Fire Protection Facilities and Equipment l
F2.1 In-plant Fire Protection Equipment i
a.
. Insoection Scope (64704)
The inspector observed the material condition of the installed fire protection equipment (hose stations, portable extinguishers, sprinkler systems, water curtains, CO systems, etc).
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b.
Observations and Findinas
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The fire protection equipment in the plant was in good condition.1 Hose stations and portable extinguishers were not obstructed by scaffolding or temporary equipment.
All fire hoses checked were within the prescribed hydrostatic test periodicity. The automatic water suppression systems were lined up for operation, c.
Conclusions Based on the equipment in the plant being in good repair, with all hoses checked being within hydrostatic test periodicity and no obstructed nozzles found, the inspector determined that the in-plant fire-fighting equipment was well-maintained and ready to serve its intended function.
F2.2 Fire Pumps a.
Insoection Scope (64704)
The annual fire pump performance test results, and the National Fire Protection Association (NFPA) Standard for the Installation of Centrifugal Fire Pumps (NFPA-l 20) were reviewed.
b.
~~ Observations and Findinas
The inspector observed that the fire pumps' material condition was good. The
performance test results reviewed did not show an adverse performance trend for any of the three fire pumps.
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c.
Conclusions Based on the observed condition of the fire pumps, and the surveillance test results
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reviewed, the inspector determined that the fire pumps are in good condition, and l
there is no evidence of pump' performance degradation.
F2.3 Fire Barrier Penetration Seals
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inspection Scoce (64704)
The inspector observed the condition of numerous fire barrier penetration seals during tours of the facility. Two penetration seats were selected at random for comparison of design and test configurations to the ' installed configuration, in addition, the inspector reviewed the installation specification for fire rated
.
penetration seals.
b.
Observations and Findinas The inspector observed a breached silicone foam floor penetration seal with several
. small diameter wires passing through it. The inspector discussed this penetration
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with the fire protection engineer, and reviewed the fire area boundary drawings.
The penetration in question was not in a credited fire area boundary, and therefore was not a required fire rated seal.
The two seals selected in fire area 3-hour rated boundaries were a mechanical pipping penetration, and an electrical cable penetration. Both penetrations appeared to be in good condition > with no obvious separation, cracking, or other damage.
Both seals conformed to their design details, and were representative of seals which had undergone fire testing.
The review of the installation specification for fire rated penetration seals showed that the specification included limits on the foam density for silicone foam fire seals.
The specification also included guidance on replacing urethane foam penetration seals with silicone foam penetration seals.
c.
Conclusions Based on the condition of the penetration seals observed, the detailed review of two seals selected at random, and a review of the fire barrier penetration sealinstallation specification, the inspector determined that appropriate controls have been implemented to ensure the integrity of the fire barrier penetration seals is maintained.
F2.4 Fixed Fire Suppression Systems a.
Inspection Scope (64704)
The inspector observed the condition of fixed fire suppression systems in the plant during facility tours, discussed fixed fire suppression systems with the resident inspectors and fire protection staff, and performed a detailed walkdown of the fixed i
foam system which protects the high pressure coolant injection (HPCI) turbine skid.
b.
Observations and Findinos The water based fixed suppression systems in the plant areas toured were properly lined up for automatic actuation. The inspector also noted that the deluge valves for the East Crescent water curtains were connected to function simultaneously.
At the time of the inspection, the carbon dioxide total flooding suppression system for the emergency switchgear areas was out of service due to a recently discovered design problem regarding the shuttle valve for the sliding fire door between the
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rooms. The problem, which could have led to inoperability of both switchgear areas
!
due to a valve misoperation, was being evaluated by the licensee to determine appropriate corrective actions. The inspector confirmed that the appropriate compensatory measure specified in plant procedures had been implemented. In addition, the inspector verified, by review of the logs, that the hourly patrols had been conducted since the system was removed from service. The inspector also l
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During a tour of the East Crescent area, the inspector performed a detailed walkdown of the fixed foam suppression system which protects the HPCI turbine skid. The inspector verified that the valves from the water supply system were appropriately aligned, that the foam concentrate tank was filled, and that the accessible foam discharge nozzles at the turbine skid were unobstructed. The inspector also noted that the temporary scaffolding erected in the vicinity did not obstruct any of'the nozzles' discharge paths.
c.
Conclusions Based on the observed conditions of the fixed suppression systems, and the I
detailed verification of the HPCI turbine foam system lineup, the fixed suppression
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systems are well-maintained. In those instances where systems were out of I
service, appropriate compensatory actions were implemented.
F3 Fire Protection Procedures and Documentation
- F3.1 Program Changes Since Last inspection
a.
inspection Scooe (64704)
The safety evaluations generated for changes to the fire protection program and procedures made since the last inspection were reviewed.
b.
Observations and Findinas The facility's operating license permits changes to the approved fire protection program without prior NRC approval only if those changes do not adversely affect the ability to achieve and maintain safe shutdown conditions in the event of a fire.
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The changes to the program and procedures implemented since the last inspection included:
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Revising the governing procedure to the new administrative procedure format; e
Reassigning fire protection responsibilities within the operating organization j
to incorporate organizational changes at the facility; Changing the setting of the control relay for the able spreading room high o
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point vent damper to limit pressure rise p.fter a CO discharge;
e Changing the inspection schedule of fire barrier penetration seals, fire doors -
and fire dampers to conform to the 24 month refueling cycle;
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e Changing the inspection interval and inventory for the exterior hose houses, and, e
Deleting the requirement for reporting inoperability of fire protection equipment to bring the governing procedures into conforrnance with the special reports section of technical specifications.
~ Each of the changes was the subject of a safety evaluation, and subjected to review by the plant operations review committee. The inspector determined that none of the changes affected the ability to achieve and maintain safe shutdown conditions in the event of a fire.
c.
Conclusions
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Based on the information contained in the safety evaluations reviewed, the program changes were properly evaluated and controlled.
F4 Fire Protection Staff Knowledge and Performance F4.1 Fire Drill a.
Insocction Scope (64704)
The inspector observed an announced fire drill conducted the evening of July 7,1998.
b.
Observations and Findinos The fire drill was conducted using a scenario staged in the cable spreading room.
The fire brigade leader appropriately established communications with the control room using the dial telephone system due to the radio frequency interference issues with equipment in the cable spreading room. Selection of the appropriate extinguishing agent was made, and a fire hose was kept ready outside the doorway used for access. Search and rescue activities were conducted to determine if any personnel were in the cable spreading room at the time of the fire. The inspector observed good use of "three-point communications" by the fire brigade members.
c.
Conclusions During the fire drill, fire brigade members demonstrated an acceptable understanding of fire-fighting procedures and actions.
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LF4.2 - Fire Events a.'
Inspection Scooe (64704)
. The inspector reviewed documentation relating to two fire events which occurred during 1998, a'nd discussed the events with the resident inspectors and site fire protection personnel.
'
b.
Observations and Findinas On May 4,1998, a Halon discharge occurred in the Meteorological Monitoring and Radiological Assessment Systern computer room.. investigation of the cause found no apparent fire damage. The cause of the Halon discharge is believed to have -
been an overheated florescent light ballast. There was no apparent fire damage in the room, and no evidence of smoke when the fire brigade arrived. Review of the
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event by NYPA personnel identified a need for several enhancements to the training.
program, since most of the fire brigade members have never seen a Halon discharge..
On June 29,1998, a report of smoke and a strong burning odor in the vestibule of the Old Administration Building Annex was made to the control room. The building
. was ordered evacuated. ' A contract employee used a pressurized water extinguisher.
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on apparent smoldering material. The fire brigade was dispatched and investigated the condition. A hot spot was found near the floor at the bottom of the metal door
, frame in the exterior wall of the vestibule. Subsequent investigation determined
. that the most likely source of the ignition of the exposed wooden door sill was j
improperly disposed smoking materials from the designated smoking area just
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.outside the door.
. c.
' Conclusions
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Based on the review of documentation of the fire events,' and discussion of the
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events with the resident lnspectors, the fire protection program engineer, and fire
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and safety specialists, the fire brigade responded well to indications of fires in nonsafety-related areas.
F7:
Quality Assurance in Fire Protection
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' F7.1 - Program Audits
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L a..
Insoection Scope (64704)-
L Fire protection program audits which were conducted since the last inspection were reviewed to determine what findings had been identified, and how they were resolved.-
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b.
Observations sad Findinas
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The audits reviewed all aspects of the fire protection program, including design, material condition of equipment, personnel training and performance, and procurement. Audits were conducted as required by the facility technical (
Specifications.
Deficiencies were entered into the corrective action program for tracking and
closure. Recommendations for improvement were documented separately, and tracked to resolution. Each audit reviewed the resolution of findings and recommendations from the previous audits.
l C.
Conclusions
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Based on the issues identified in the audit reports reviewed, and their handling in the corrective action program, the program audits had been effective in identifying deficiencies and areas for improvement in the fire protection program.
V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the inspections results to members of the licensee management at the conclusion of the inspection on July 20,1998. Also, on July 10,1998, Mr. R. Fuhrmeister presented the NRC's inspection findings in the j
area of fire protection. The licensee acknowledged the findings presented.
.The inspectors asked the licensee whether any materials examined during the inspection should be considued proprietary. No proprietary information was j
identified.
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ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Licensee M. Colomb, Site Executive Officer D. Lindsey, General Manager, Operations J. Maurer, General Manager-Support Services D. Ruddy, Director, Design Engineering A. Zaremba, Licensing Manager NRC J. Williams, Project Manager INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 64704: Fire Protection Program J
IP 71707: Plant Operations IP 71750: Plant Support IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities j-IP 92702: Follow-up on Corrective Actions for Violations and Deviations IP 92901: Followup - Plant Operations IP 92903: Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 50-333/98003-01 NCV inadequate temporary operating procedure developed for spent fuel system
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_NCV failure to properly implement decay heat removal procedure
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50-333/98003-02 50-333/98003-03 NCV drywell personnel airlock outer door seals local leak rate test
)
-not properly performed j
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50-333/98003-04 NCV control room ventilation single failure vulnerability l
Closed 50-333/96005-03 URI drywell continuous atmosphere monitor control room alarm / indication 50-333/96007-01 VIO incorrect exchange of three control rod drives I
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' Attachment 1
50-333/97012-00 LER drywell personnel airlock outer door seals local leak rate test not properly performed
.50-333/97012-01 LER drywell personnel airlock outer door seals local leak rate test not properly performed j
50-333/98003-01 NCV inadequate temporary operating procedure developed for spent l
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fuel system 50-333/98003-02 NCV failure to properly implement decay heat removal procedure 50-333/98003-03 NCV drywell personnel airlock outer door seals local leak rate test not properly performed 50-333/98003-04 NCV control room ventilation single failure vulnerability-
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l 50-333/98005 LER high pressure coolant injection system inoperable due to lower than normal flow controller output Discussed None l-i
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~ Attachment 1
LIST OF ACRONYMS USED AOP Abnormal Operating Procedure ALARA-As Low As Reasonably Achievable CBP Condensate Booster Pump CFR Code of Federal Regulations CRD Control Rod Drives CST-Condensate Storage Tank DER-Deficiency and Event Report DHR Decay Heat Removal EFE Equipment Failure Evaluation
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GPM Gallons Per Minute HPCI.
High Pressure Coolant injection INPO
. institute of Nuclear Power Operations I&C -
Instrumentation & Controls LCO Limiting Condition for Operation LER Licensee Event Report LLRT Local Leak Rate Test
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MG Motor Generator MOV Motor Operated Valve
MPFF Maintenance Preventable Functional Failure NFPA National Fire Protection Association NRC
. Nuclear Regulatory Commission
.. ODSO Operations Department Standing Order OP Operating Procedure P-T-Pressure Temperature RAP Reactor Analysis Procedure RCA Radiological Controlled Area RCS Reactor Coolant System RPM Revolutions per Minute RPS Reactor Protection System RWCU-Reactor Water Cleanup SDIV Scram Discharge Instrument Volume
SFP Spent Fuel Pool
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ST Surveillance Test URI Unresolved item UFSAR Updated Final Safety Analysis Report VIO Violation WR-Work Request
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