IR 05000334/1989013
| ML20248G021 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/28/1989 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248G007 | List: |
| References | |
| 50-334-89-13, 50-412-89-14, NUDOCS 8910100023 | |
| Download: ML20248G021 (15) | |
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LU.S. NUCLEAR REGULATORY-COMMISSION
REGION I
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Report Nos.
L50-334/89-13.
License: :DPR-66 50-412/89-14 NPF-73 Licensee:
Duquesne Light Company One Oxford Center 301' Grant Street-
-Pittsburgh, PA 15279 Facility Name: Beaver Valley Power Station, Units 1 and 2 Location:
lSt.1ppingport, Pennsylvania
' Dates:
July 8 - August 31, 1989-
-Inspectors:
J. E. Beall, Senior Resident Inspector
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P. R.-Wilson, Resident Inspector-Approved by:
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C. J. Cowgill, Ch
,gactorProjectsSection4B Date Inspection Summary: Combined Inspection Report Nos. 50-334/89-13; 50-412/89-14 for July 8 - August 31, 1989 Areas' Inspected:'.. Routine inspections by the resident inspectors of licensee actions on previous ' inspection findings, plant. operations, security, radio-logical controls, plant housekeeping and fire protection, surveillance testing,
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maintenance, measuring and test equipment, fitness for duty, inoperable fire dampers,~and licensee event reports.
Results: Overall, the facility was operated safely. Operator response to an inadvertent letdown isolation was good (Section 4.3.1).
One violation was-c identified regarding the failure to adequately control measuring and test equipment (Section 7). The licensee's fitness for duty-program was reviewed; progress toward meeting new Regulatory requirements is good (Section 8).
Licensee activities ~ associated with Unit 1 inoperable fire dampers were also j
reviewed; no deficiencies were identified (Section 9).
Five previous open NRC items were closed during this inspection.
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8910100023 8909'9
PDR ADOCK 05000334 O
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TABLE OF CONTENTS PAGE 1.
< Persons Contacted................
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'2.
Summary of Facility Activities.......................................
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Status of: Previous Inspection Findings (IP 71707,92702,92701)......
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' Ope'ational Safety (IP 71707,71710,40500)..........................
"4.
r 4.1 Genera 1.........................................................
- 4. 2 E S F. Wa 1 kd own....................................................
'3 4.3-Operations......................................................
4.4 Plant Security / Physical Protection..............................
4.5 Radiological Controls...........................................
l 4.6 Plant Housekeeping..............................
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4.7 Fire' Protection.................................................
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L 15-Surve111ance Testing (61726).........................................
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.. Maintenance (62703)..................................................
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Measuring and' Test Equipment (35750).................................
1 7.1 Genera1....................................................
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-7.2 Findings.........................................................
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Conclusions.....................................................
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L Fitnes s for Duty Program Review (71707)...............................
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Unit I. Inoperable Fi re Dampers (92702, 71707)........................
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10. :Inoffice Review of Licensee Event Reports (90712, 40500)............
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11.
Unresolved Items.....................................................
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12. Mee t i n g s ( 3 070 3 ).....................................................
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t DETAILS
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1.
Persons Contacted During the report period, interviews and discussions were conducted with members of licensee management and staff as necessary to support inspec-
. tion activities.
2.
Summary of Facility Activities
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i At the beginning of the inspection period, Unit I was at-100% power and Unit 2 was in. Cold Shutdown (Mode 5) completing tube repairs to the "2C" Steam Generator.
Unit 2 was returned to power July 14, 1989. On Atgust 14, 1989, Unit 1 began an end of fuel cycle coast down.
Unit 1 was at 80%
power and Unit 2 was a 100% power at the end of the inspection period.
3.
Status of Previous-Inspection Findings The NRC Outstanding Items (01) List was reviewed with cognizant licensee
. personnel.
Items selected by the inspector were subsequently reviewed through discussions with licensee personnel, documentation reviews and i
field inspection to determine whetherzlicensee actions specified in the OIs had been satisfactorily completed. The overall status of previously I
identified inspection findings was reviewed, and planned / completed licen-
.see actions were discussed for the items reported below.
3.1 (Closed) Violation (50-334/88-28-01): Inadequate Corrective Action l
For Previous NRC Finding Regarding Inaccurate Information Shown On
Control Room Status Prints To' Prevent Repetition.
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The licensee issued a standing night order delineating responsibili-
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ties to update control room status boards and prints.
Licensee also incorporated guidance requirements to update status boards and prints into Operating Manual Chapter 42.48.3.
The inspector examined-
selected status boards and prints and found all to reflect actual
,l plant conditions.
This item is closed.
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3.2 (Closed) Violation (50-334/87-10-01):
Implement Appropriate Testing Requirements For Both Unit I and Unit 2 Chlorine Detection (CD) Sys-tems.
The inspector reviewed licensee testing procedures and recent test
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results. Unit 1 performs the detector probe test and calibration
biweekly; weekly for Unit 2.
Failure rates have improved due to re-vised testing methods and test frequencies.
Further procedure revi-
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sions have been incorporated to provide test consistency between both
Units. The inspector determined that Technical Specification testing l
requirements were properly implemented and both CD systems were oper-l able. Further, both systems are redundant for the Unit 1/2 common
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control room. Th'e licensee is continuing to trend test results to identify additional actions as appropriate to further enhance test-ing. This' item is closed.
3.3 (Closed) Unresolved Item (50-412/88-22-01):
Implement Permanent Re-pair For PORV Block Valve 2RCS-MOV537.
The valve was disassembled and successfully repaired during the re-cent Unit 2 refueling outage on March 29, 1989. This item is closed.
3.4 (Closed) Violation 50-334/88-08-01: Two Examples Of Failure To Fol-
' low Established Administrative Procedures.
The licensee ~ responded.to the violation required by letter dated June 13, 1988. The inspector reviewed the licensee's response and veri-fied that the corrective actions and actions to prevent recurrence had been properly implemented.
No further concerns were' identified.
This item is closed.
3.5 (Closed) Unresolved Item (50-334/88-20-01; 50-412/88-12-01):
Fire Protection (FP) System Reliability and Testing.
The licensee conducted a review of the FP system and identified those problems which could adversely affect system operation and reliabil-ity. Several recommendations were provided and implemented, includ-ing procedural and hardware changes. Additionally, a flow measuring device that was past its calibration due date was satisfactorily calibrated. Subsequent changes eliminated the need to use that flow device-(FI-FP-1) to satisfy-test acceptance criteria. The inspector verified that an alternative means to measure system flow had been implemented. The inspector reviewed the licensee's evaluation and corrective actions, and no deficiencies were identified.
This item is closed.
4.
Operational Safety 4.1 General Inspection tours of the following accessible plant areas were con-ducted during both day and night shifts with respect to Technical Specification (TS) compliance, housekeeping and cleanliness, fire protection, radiation control, physical security / plant protection and operational / maintenance administrative controls.
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-- Control Room
-- Safeguard Areas
-- Auxiliary Building
-- Service Building
-- Switchgear Area
-- Diesel Generator Buildings
-- Access Control Points
-- Containment Penetration Areas
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-- Protected Area Fence Line -- Yard Area
-- Turbine Building
-- Intake Structure-
-- Reactor Containment
-- Spent Fuel Building l
4.2 ESF Walkdown The operability of selected engineered safety features systems were verified by performing detailed walkdowns of the accessible portions of the systems. The inspectors confirmed that system components were in the required alignments, instrumentation was valved-in with appro-priate calibration dates, as-built prints reflected the as-installed systems and the overall conditions observed were satisfactory. The systems inspected during this period include the Emergency Diesel Generator, Safety Injection and Recirculation Spray systems.
4.3 Operations During the course of the inspection, ' discussions were conducted with operators concerning knowledge of recent changes to procedures, faci-lity configuration and plant conditions. During plant tours, logs and
- records were reviewed to determine if entries were properly made, and that equipment status / deficiencies were identified and communicated.
These records included operating' logs, turnover sheets, tagout and jumper logs, process computer printouts, unit off-normal and draft incident reports. The inspector verified adherence to approved pro-cedures for ongoing activities observed.
Shift turnovers were wit-nessed and staffing requirements confirmed.
Inspector comments or questions resulting from these reviews were resolved by licensee per-sonnel. Onsite Safety Review Committee meetings were attend to -
evaluate the licensee's self-assessment capability.
In addition, inspections were conducted during backshifts and weekends on 7/9, 7/11,.7/18, 7/20,_7/26, 7/31, 8/1, 8/20, 8/26, and 8/27.
4.3.1 Unit 2 Inadvertent Letdown Isolation On July 13, 1989, while Unit 2 was in Hot Standby (Mode 3)
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Chemical and Volume Control (CVCS) system letdown auto-matica11y isolated twice due to low pressurizer level.
Following indications of excessive Reactor Coolant System (RCS) leakage (8 gallons per minute) into the Primary Drains Transfer Tank, operators entered the containment to attempt to reseat the primary Drains Header Isolation ' valve (2 DGS-300) by slightly opening then reclosing the valve.
During the attempt to reseat the valve, the valve fully opened and could not be closed.
Following indications of increased RCS leakage (decreasing pressurizer level, in-creased containment sump pump out rate and Primary Drains Tank level) control room operators increased charging flow, however, normal letdown isolated due to low pressurizer i
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level. Normal letdown was restored four minutes later but re-isolated seven minutes later. Normal letdown was subse-
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quently restored.
Plant operators took several actions to decrease RCS leak-age. The drain valves upstream of 2DGS-300 were tightened and excess letdown was lined up to the CVCS seal water heat exchanger to reduce the pressure upstream of 2DGS-300.
After approximately 40 minutes, plant operators success-fully reseated DGS-300 and RCS leakage to the Primary Drains Transfer Tank stopped. The licensee made all re-quired NRC notifications. Operator response during this event was thorough and timely, helping to minimize the potential consequences of the event.
DG5-300 is a two inch Kerotest valve. The licensee is presently developing a design change to prevent recurrence.
The licensee expects the design change to be made during the next refueling outage. The inspector had no further questions on this issue.
4.3.2 Unit 2 Automatic Isolation of Steam Generator Blowdown On August 15, 1989, an automatic isolation of the steam generator (SG) blowdown line occurred (ESF Autuation) due to high radiation. A plant chemist making adjustments to
"A" SG blowdown sample line pressure apparer.tly caused a crud burst in the blowdown sample system resulting in a high radiation alarm on the sample system radiation moni-tor, closing the blowdown containment isolation valves.
The licensee determined that the crud was from a previous SG tube leak. The operators restored the SG blowdown sys-tem to its normal alignment and flushed the radiation moni-tor. The licensee made the required NRC notifications.
The inspector had no further questions regarding this issue.
4.4 Plant Security / Physical Protection Implementation of the Physical Security Plan was observed in various plant areas with regard to the following:
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Protected Area and Vital Area barriers were well maintained and not compromised; Isolation zones were clear;
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Personnel and vehicles entering and packages being delivered to i
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the Protected Area were properly searched and access control was
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in accordance with approved licensee procedures; Persons granted access to the site were badged to indicate
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whether they have unescorted access or escorted authorization;
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Security-access controisito Vital Areas were being maintained
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Land that persons in Vital Areas were properly authorized.
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. Security posts were' adequately staffed and equipped, security
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personnel.were alert and knowledgeable regarding position re-
.quirements,land that written procedures were available; and AdequateLillumination was maintained.
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No deficiencies'were identified.
4.5 Radiological Controls Posting and control of radiation and high radiation areas were in-spected.
Radiation Work Permit, compliance and use of personnel moni-toring devices were checked.. Conditions of step-off pads, disposal of protective clothing, radiation control job coverage, area monitor operability and calibration (portable and permanent) and personnel frisking were observed on a sampling-basis.
4.6 ' Plant Housekeeping and Fire Protection Plant-housekeeping conditions, including general cleanliness condi-
'tions and control and htorage of flammable material'and other poten-tial safety hazards, were observed in.various areas during plant tours.
The inspectors' observed a decline in general housekeeping at both units.
Paper trash, tape, cotton glove liners, dirt, etc. were found-in radiologically controlled areas.
In addition, in Unit'I the in-spector found several standing ladders and carts unsecured in the vicinity.of safety related equipment.
The licensee took.immediate action to relocate.or secure these items. The inspectors noted'an improvement in general housekeeping in Unit 2 before the end of the inspection period and in Unit I shortly after the inspection period.
4.7 Fire Protection Maintenance of fire barriers, fire barrier penetrations flammable material storage and the verification of posted fire watches were observed in various areas during plant tours.
l On August 15, 1989, Underwriter's Laboratory (UL) notified the 11cen-L see that all 6 licensee vertical Unit 1 prototype fire dampers failed the endurance and hose stream tests and therefore, were not in com-p11ance with the associated UL standard. The licensee subsequently declared 26 vertical fire dampers inoperable and posted a continuous L
fire watch in the affected areas.
For more information, see Section 9.0.
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5.
Surveillance Testing The. inspectors witnessed / reviewed selected surveillance tests to determine whether properly approved procedures were'in use, details were adequate, test instrumentation wa; properly calibrated and used, Technical Specifi-
. cations were satisfied, testing-was performed by qualified persunnel and test results satisfied acceptance criteria or were properly dispositioned.
.The following surveillance testing activities were reviewed:
OST 1.36.20, Diesel Generator No. 2 Start-Up, July 19, 1989
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OST 1.36.2, Diesel Generator NO. 2 Monthly Test, July 19, 1989
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OST 1.36.1, Diesel Generator No. I Monthly Test, August 16, 1989
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OST 2.36.2, Emergency Diesel Generator (2EGS*EG2-2) Monthly Test,
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August 16, 1989
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OST 2.24.2, Motor Drive Auxiliary Feed Pump (2FWE*P23A) Test.
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No deficiencies were identified.
6.
Maintenance The inspector reviewed selected mait.tenance activities to assure that:
the activity did not violate Technical Specification Limiting Condi-
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tions for Operation and that redundant components were operable; required approvals and releases had been obtained prior to commending
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work; procedures.used for the task were adequate and work was within the
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skills of the trade; activities were accomplished by qualified personnel;
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where necessary, radiological and fire preventive controls were ade-
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quate and implemented; QC hold points were established where required, and observed;
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equipment was properly tested and returned to service.
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Maintenance activities reviewed included:
MWR 892173-River Water 1B Discharge Isolation Valve MOV-RW-102B1
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No deficiencies were identified.
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Measuring and Test Equipment
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7.1 General i
10 CFR 50 Appendix B, Part XII, " Control of Measuring and Test Equip-ment [M&TE]", requires licensees to establish measures to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, cali-brated, and adjusted at specified periods to maintain accuracy within necessary limits. The licensee uses Section 2, " Control and Calibra-tions of Measuring and Test Equipment", of the Instrument and Control Administrative Manual to control activities associated with measuring and test equipment (M&TE). An inspection of the licensee's M&TE pro-gram was conducted following indications that M&TE was being impro-perly controlled (see Inspection Report 50-335/89-12; 50-412/89-13)
Areas inspected included the licensee's calibration procedures, cali-brations, and c)ntrol of M&TE.
The majority of M&TE used by the licensee is calibrated onsite by
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technicians assigned to the Instrument and Control Department. All other M&TE is puiodically sent to qualified vendors for calibration.
M&TE is issued to the various users from two locations in Unit I and a single location in Unit 2.
For Unit 1, M&TE used by mechanical maintenance (torque wenches, micrometers, calipers etc) is issued from the Unit 1 Tool Room. Ali other Unit 1 M&TE is issued by the Unit 1 Instrument and Control (I&C) M&TE issued point.
The inspector selected approximately 25 instruments from the M&TE issue and use record logs at each M&TE issue point. The location of each instrument was then verified and a determination was made as to whether the M&TE was within its required calibration frequency. The calibration history data sheets for each instrument were reviewed to determine if any out of specification conditions had been identified and how any unacceptable conditions were resolved. The inspector reviewed a sample of the licensee's calibration procedures to deter-mine if the calibration methodology prescribed by the vendor tech-nical manuals was incorporated into the procedures. The inspector also observed the calibration technician performing calibrations and reviewed the most current Quality Assurance audit of the licensee's M&TE program.
7.2 Findings 7.2.1 Calibration of M&TE
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The inspector identified no instances where the various M&TE vendor's calibration methodologies were not fully im-plemented in the licensee's M&TE calibration procedures.
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L All recommended calibration points and tolerances were in-L corporated. The required calibration frequencies either
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met, or were more conservative than, the vendor's recommen-
'dations.
Technicians performing M&TE calibrations were observed to strictly follow the calibration procedures. The techni-i
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cians were very knowledgeable as to the history and cali-l bration methodology of assigned M&TE.
The I&C Administrative Manual Section 2 " Control and Cali-bration _of Measuring and Test Equipment" requires that when l:
the "As Found" a;ta for a piece of M&TE calibrated offsite
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or onsite is found out of specification, a " Lost or.0ut of l
Calibration Report'_' will be completed to determine the l
l safety impact of the out of specification M&TE.
Section 2
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also requires that the report be completed within 60 days.
Reviewing the M&TE instrument history records, the inspec-tor found no instances where an "as found" out of specifi-cation condition was not identified.
For M&TE which were
identified to be out of specification, the required report
was promptly prepared and was generally resolved within
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four or five days.
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L 7.2.2 Control of M&TE The I&C Administrative Manual Section 2, " Control and Cali-bration of Measuring and Test Equipment", delineates the requirements to control M&TE. When M&TE is checked out of an issue point, the user or an issue point attendant is required to complete a " Daily Issue and Use Record". Here, the user's name and work activity are recorded. The manual requires that M&TE which were checked out'be returned to the issue point at the end of each workday.
Exceptions are
permitted provided the user secures and protects the M&TE.
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The manual also requires that a reject sticker be placed on
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I any M&TE that is out of calibration or past'due for a cali-bration and then be segregated from calibrated M&TE in a separate " Hold" area. When M&TE is used for safety related (Category I) work, the user is required to enter the M&TE serial number, and calibration due date into the surveil-lance or maintenance procedure.
If only simple maintenance is to be performed, the user is required to enter the above information on the controlling maintenance work request.
The inspector was concerned with the apparent inadequate control of M&TE from the Unit 1 Tool Room. The inspector l
identified three instances where M&TE past due for calibra-
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l tion was issued for Category I work. The tool room attend-ant and the users failed to identify the above unacceptable i
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use of M&TE. The licensees quality control inspectors F
' identified the M&TE before it was used on safety related
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n equipment. There were also several other pieces of M&TE that were issued and used with a.past-due calibration date but.were used for Category II work. The inspector also
- found in the Unit 1 Tool Room, 9 pieces of M&TE that were past-due for calibration but did not have the required re-ject sticker nor were the instruments segregated as re-quired.
The inspector also identified several instances where M&TE
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were checked out to individuals which had not been returned to the Unit 1 Tool Room even through the.M&TE had subse-quently exceeded the calibration due date.
In addition, the Unit 1 Tool Room Daily Issue and Use Record log con-tained record sheets for M&TE that had been previously re-tired and removed from use or did not accurately state the location of some of the instruments.
In the Unit 1 I&C hot shop, the inspector identified.72 potentially contaminated test pressure gauges with all but-one.past due for calibration. The past due gauges did not have reject stickers and were not segregated from cali-brated M&TE as required.
Some gauges were obviously dam-aged as evidenced by cracked gauge glasses or broken indi-
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cating needles.
. In the Unit 2 I&C Hot Shop, the inspector identified 27 potentially contaminated test pressure gauges of which seven were past due for calibration. None of the seven gauges had a reject sticker nor were any segregated from calibrated M&TE.
At all M&TE issue points, many (approximately 100) pieces of M&TE were being checked out for long periods of time.
While some items were checked out to specific organizations such as Operations or Testing and Plant Performance, many items were checked out to individua-1 technicians. There were several instances where individuals who had checked out of M&TE did not have the instrument in their control.
Not all the work performed with the M&TE was recorded as required on the Daily Issue and Use Record log nor was there any assurance that the checked out M&TE was being stored in an acceptable environment. Groups which had M&TE checked out for long periods had separate Daily Issue and Use Record Logs and were storing the M&TE in suitable
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i All M&TE issue points have assigned attendants during day.
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. shift but only the Unit 1 Tool Room was locked when the i
attendant was not present~. 'Some.M&TE that, according to i
the Daily. Issue and Use Record Logs, were supposed to be
~-located.at the issue point were found being used in the i
. field..During this inspection.the licensee's Quality Con--
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trol Department performed an audit and found seven in-Estances where M&TE was being used during: work activities at both Units and were not logged in.the Daily issue and Use J
Record Log as required.
The inspector.also reviewed the licensee's most~recent-(March 89) Quality Assurance audit to determine what find-ings were: identified in the area.of control of M&TE. Al-
'though the audit covered control of M&TE, it did not iden -
p tify any concerns.
7.3 Conclusions Both the proper calibration and the' proper control of M&TE are essential to'give high assurance that plant instrumentation and'
equipment are properly calibrated and installed. The licensee has a strong M&TE. calibration program as evidence by high quality proce-dures, accurate' calibrations and, skilled technicians.
However, as described above, significant problems were found with control of M&TE.
Of particular concern was the issuance of beyond calibration M&TE for use on safety related equipment. Also of concern, were the' numerous examples of the failure to control equipment as required by Section 2 of the I&C Manual. These included the failure to properly mark and segregate past-due M&TE, to return M&TE to the issue points'at the completion of the recorded work activity, to record all work per-formed using a piece of M&TE in the Daily Issue and Use Record Log, and to use the Daily Issue and Use Record Log when checking out M&TE.
Failure to follow the procedures for the control of M&TE is contrary to 10 CFR Appendix B Criterion XII and Section 2 of the Instrument and Control Manual and is a violation (5D-334/89-13-01, 50-412/89-14-01).
Also, the lack of requirements to lock up the M&TE issue point when i
unattended was considered to be a weak practice.
8.
Fitness for Duty Program Review L
The inspector conducted a review of the licensee's fitness for duty pro-gram. The program is presented in Nuclear Group Directive No. 29, "Use or Possession of Alcohol or Drugs and Fitness for Duty." Currently, two ver-sions of Nuclear Group Directive No. 29 are in force on-site.
Issue 1 of the Directive, dated November 20, 1985, states that supervisors are re-sponsible for assuring that those under their supervision are fit for l
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duty. Observation training for upervisors is provided to assist in recognizing potential instances of substance abuse.
Chemical testing is used in pre-employment screening and "for cause."
Issue 2 of the Directive, dated May 10, 1988, added two additional appli-cations of chemical tests. A successful chemical test is required before granting unescorted access to the Protected Area. Also, those personnel granted unescorted access must successfully complete chemical testing as part of their routine, periodic physical examination.
Both versions con-tain provisions with respect to employee assistance and/or rehabilitation.
Neither Issue 1 nor Issue 2 centain provisions for random, unannounced chemical testing.
Licensee review of the Proposed Rule on fitness for duty (10 CFR 26) with its requirement for random testing has led to the drafting of a new Directive, still under review, to address the antici-pated new legal requirements.
Most personnel on-site are currently covered by Issue 2 of the directive.
Some union personnel are still under Issue 1 due to certain previous con-tractual arrangements. The licensee expects to issue the draft Directive and have the Fitness for Duty program in compliance with 10 CFR 26 when requi red.
No deficiencies were identified. The inspector found the licensee's pro-gram to be good and the licensee's progress toward meeting 10 CFR 26 re-quirements to be timely and appropriate.
9.
Unit 1 Inoperable Fire Dampers On August 15, 1989, the licensee declared 26 vertical fire dampers inoper-able based upon testing performed by Underwriter's oratory (UL) of six prototype dampers.
On January 14, 1985, the licensee requested exemptions from the provisions of 10 CFR 50, Appendix R for fire dampers.
By letter dated December 4, 1986, the NRC concluded that the existing Unit I fire dampers did not constitute an acceptable exemption and the licensee was requested to provide fire test results demonstrating that fire resistance ratings in the configura-tion installed were equivalent to that required of the barriers in which they were installed.
The licensee's horizontal and vertical fire dampers were to be fabricated I
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in accordance with Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) standards, however, the dampers did not bear UL or SMACNA labels, which are the sole means of identifying whether the dampers were constructed in accordance with the standards.
The licensee de-veloped 12 prototype fire dampers (six vertical, six horizontal) to be tested by UL to verify deviation acceptance. On August 15, 1989, UL noti-fied the licensee that all six vertical dampers failed the fire endurance and hose steam tests, resulting in noncompliance with the associated UL Standard (UL555).
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The licensee declared the dampers inoperable and posted fire watches in accordance with Station Administrative Procedures (SAP) 9D, " Fire Protec-tion Program" requirements.
The areas affected by the inoperable dampers include the East and West Emergency Switchgear Rooms, East and West Cable Vaults, Cable Spreading Mezzanine and the Normal Switchgear Room, 752 ft and 768 ft, elevations of the Primary Auxiliary Building, the Fuel Building, the Steam Generator Blowdown Room, the Main Steam Valve Room, and the Purge Duct Room.
The licensee developed a Justification for Continued Operation (JCO) to document a safety and deportability evaluation. The inspector reviewed.
the JC0 and interviewed licensee personnel. The horizontal dampers (not yet tested) are located in the same fire areas as the vertical dampers and, therefore, are bounded by the existing fire watch areas. The licen-see stated the UL is scheduled to perform horizontal damper testing. An evaluation has also begun to determine whether this is a generic issue (10 CFR Part 21 applicability).
The inspector identified no deficiencies in the JC0 and periodically veri-fied ti,at fire watches were performing required duties. The inspector will continue to monitor licensee performance in the area of fire protection.
10.
Inoffice Review of Licensee Event Reports (LERs)
l The inspector reviewed LERs submitted to the NRC Region I Office to verify that the details of the event were clearly reported, including accuracy of the description of cause and adequacy of corrective action. The inspector determined whether further information was required from the licensee, whether generic implications were indicated and whether the event warranted onsite followup. The following LERs were reviewed:
Unit 1:
NONE Unit 2:
LER: 89-19-00 Auxiliary Feedwater Pump Actuation Due to a Low-Low Steam Generator Level LER: 89-20-00 Inadvertent Start of Motor Driven Feedwater Pumps-ESF Actuation LER: 89-21-00 Steam Genrator Tube Leak LER: 89-22-00 Inadvertent Letdown Isolation-ESF Actuation LER: 89-23-00 Potential Generic Failure of Westinghouse Solid State Protection System (10 CFR 21 Report)
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The above LERS were reviewed with respect to the requirements of 10 CFR 50.73 and the guidance provided in NUREG 1022. Generally, the LERs were found to be'of high quality with good documentation of event analyses,
. root'cause determinations and corrective actions. No significant deft-ciencies were' identified.
11. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable. items,. violations or devi-ations. No'new unresolved items were identified in this inspection re-port.
12. Meetings Periodic meetings were held with senior facility manegement during the course of this inspection to discuss the inspection scope and findings. A
. summary of inspection findings was further discussed with the licensee at the conclusion of. the report period on September 8,1989.
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