IR 05000335/1998003
| ML17229A706 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/27/1998 |
| From: | Schin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229A705 | List: |
| References | |
| 50-335-98-03, 50-335-98-3, 50-389-98-03, 50-389-98-3, NUDOCS 9805050161 | |
| Download: ML17229A706 (59) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION REGION II'ocket Nos: 50-335, 50-389 License Nos:
DPR-67, NPF-16 Report Nos: 50-335/98-03, 50-389/98-03 Licensee:
Florida Power 5 Light Co.
Facility:
St. Lucie Nuclear Plant. Units
8 2 Location:
6351 South Ocean Drive Jensen Beach, FL 34957
.Dates:
February 15 - March 28, 1998 Inspectors:
M. Miller, Senior Resident Inspector J.
Munday, Resident Inspector D. Lanyi, Resident Inspector B. Crowley, Regional Inspector (Sections Ml.1, M1.5, and M1.6)
Approved by:
R.
P. Schin, Acting Chief Reactor Projects Branch
Division of Reactor Projects Enclosure 9805050%61 980427 PDR ADQCK 05000335
~l
EXECUTIVE SUMMARY St. Lucie Nuclear Plant, Units 1 5 2 NRC Inspection Report 50-335/98-03.
50-389/98-03 This integrated inspection included aspects of licensee operations, engineer-ing, maintenance, and plant support.
The report covers a 6-week period of resident inspection; in addition, it includes an inspection in the area of maintenance by a Region based inspector.
~oerations
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Throughout the inspection period, the inspectors noted generally weak control room conduct.
Examples included: control room noise level high during turnover, conversations unrelated to the turnover taking place during turnover, general lack of three-part communication, performance of reactivity manipulations during turnover, operators not understanding the reason for annunciators being in alarm, large number of personnel in the control room during periods other than turnover, and Nuclear Plant Super visor and Assistant Nuclear Plant Super visor involvement in particular activities detracting them away from the overall plant condition.
(Section 01.2)
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The inspectors found the evolution to take Unit 2 off-line and then restore it to service was accomplished according to procedure in a safe and conscientious manner.
Several operational conduct weaknesses and strengths were identified during the observation period.
(Section 01.3)
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The inspector found two safety related clearances hung in the field technically and administratively adequate.
The inspector identified a
-
weakness in the preparation of the clearance requests.
A large percentage of clearance requests did not comply with the licensee's procedure to propose a detailed boundary.
(Section 02.2)
Maintenance The inspectors observed portions of maintenance associated with 15 work orders, most notably the replacement of a Reactor Coolant Pump Seal cartridge.
The inspectors concluded the work was adequately performed and procedures were being appropriately used by qualified personnel.
Applicable Foreign Material Exclusion controls, Measuring and Test Equipment controls, Post Maintenance Test requirements, and Quality Control hold points were being performed in accordance with requirements.
Additionally, the licensee was considering Maintenance Rule requirements in corrective action and disposition of equipment failures.
(Sections M1.1, M1.2, M1.3, Hl.4,)
The licensee has been aggressive in reduction of'he maintenance backlog and the backlog was being well controlled.
(Section Hl.5)
~
The licensee identified an adverse trend when three events involving misoperation of plant equipment by personnel painting occurred in less than two weeks.
The inspector found the corrective actions to be swift and appropriate.
(Section M4. 1)
~
The inspector found the Instrument and Control department's initiatives to improve departmental performance and, particularly, the involvement of bargaining unit personnel in the improvement process, to be a
positive step.
The effort was successful in developing definable, implementable corrective actions.
(Section M4.2)
En ineerin
~
The inspector concluded that the licensee acted responsibly in addressing a pin-hole leak in a fillet weld on a Unit 1 Main Feedwater Isolation Valve bypass line.
The licensee's early involvement of the NRC in the process of addressing the condition under the guidance of Generic Letter 91-18 was noteworthy.
The licensee's engineering organization appropriately considered operability issues associated with the issue.
(Section El. 1)
~P1 tt t
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The 18 Gas Decay Tank area was properly controlled from a radiological standpoint.
The inspector identified a weakness in Pro'cedure OP 1-0530020 in that it did not provide direction to Operations to inform HP prior to placing a Gas Decay Tank in service.
(Section R2. 1)
.l
/'
Summar of Plant Status Re ort Details Unit 1 entered the period at full power.
The unit was shut down on February 16 to repair the 181 Reactor Coolant Pump Seal.
The unit was returned to service on February 24, reaching full power late that evening.
Unit 1 remained essentially at full power for the remainder of the report period.
Unit 2 entered the period at full power.
The unit reduced power several times during the weeks of March 9 and 16 to repair condenser tube leaks.
The unit was removed from service on March 24 to repair a hot spot on the B isophase bus ducting.
The unit remained in Mode 2 for the duration of the repair, returning to service the next day.
The unit reached full power on March 26 and remained there for the rest of the report period.
Conduct of Operations 01.1 General Comments 71707 I. 0 er ations Using Inspection Procedure 71707; the inspectors conducted frequent reviews of ongoing plant operations.
In general, the conduct of opera-tions was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections below.
01.2 Contr ol Room Conduct a.
Ins ection Sco e
71707 Throughout the inspection period, the inspectors observed activities in the control rooms.
The inspectors were focusing on the conduct of operations, control room command and control, and procedural use and compliance.
b.
Observations and Findin s The inspectors noted generally weak control room conduct.
Examples of observations made in covering issues discussed in this report include:
~
On February 17, the inspector attended the Unit 1 Operations day shift turnover meeting.
The unit had been shut down during the previous shift and was in the process of beginning a cooldown, therefore, the amount of activity and number of personnel was higher than normal.
The inspector noted that the control room was extremely noisy due to annunciators coming into alarm, the computer printer operating and the telephone ringing.
On several occasions personnel had to move or ask someone to speak louder due to the excessive noise.
Also, during the meeting, the off going
and oncoming shift were.completing paperwork and conducting separate conversations which detracted from the meeting's effectiveness.
On February 17. the inspector monitored control room activities, and noted a general lack in three-part communication.
On one occasion, a maintenance worker performing a process radiation monitor surveillance in the control room, informed the control room, after receipt of an annunciator, that the annunciator was not caused by his activities.
The control room operator misunderstood the maintenance worker and did not initially respond.
The maintenance worker quickly informed the operator again whereupon the operator took the appropriate action.
The inspector noted that again, three-part communication was not used.
Although the inspector observed no additional miscommunications, the use of three-part communication was sporadic at best.
On February 18, the inspector witnessed portions of a Unit 1 Reactor Coolant System (RCS) inventory reduction.
In discussions with operators, it became clear that the licensee had commenced the drain down at 0740, 5 minutes before the scheduled turnover.
A review of control room logs indicated that, on January 5, Unit 1 operators withdrew control rods for a scheduled control rod drop test through the turnover period from day shift to peak shift.
The inspector noted that, while these activities were not prohibited, Appendix C to AP 0010120.
"Conduct of Operations,"
advised against performing evolutions through shif't turnovers.
The inspector concluded that these were examples of nonconservative operations.
On February 23, while preparations were being made to start up Unit 1, the inspector observed control room activities.
The inspector noted that an annunciator indicating abnormal NaOH tank level was illuminated.
This condition was not expected for the plant condition.
The inspector queried control room operators as to the reason for the indicated condition.
None of the four licensed operators in the control room knew why the annunciator was illuminated.
During the same observation, an 18C technician performing radiation monitor calibrations was observed to announce three times that he was responsible for an annunciator alarming before being acknowledged by operators.
During the Unit 2 return to power following an off-line period f'r isophase ductwork repair. the inspector noted approximately
personnel in the Unit 2 control room envelope (additional personnel were in the control room outside of the envelope).
No turnover was in progress, but one was pending.
There was a high potential for confusion resulting from the number of personnel and the number of tasks being performed (individual operators were preparing for turbine roll, controlling steam generator levels due to steam bypass control system-induced steam generator level swings, and maintaining reactor power at 5-7 percent).
c
01.3
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During the downpower and uppower maneuvers surrounding the Unit 2 isophase ductwork outage, ANPS/NPS invol.vement in individual control problems appeared excessive.
In one case, the ANPS=was observed to have a procedure in-hand directing actions at the control boards during the shift over to the 15 percent feedwater bypass valves.
In another, the NPS was at the control board with procedure in-hand attempting to help an operator troubleshoot a
turbine control problem.
In both cases, other activities involving controlling steam generator and reactor power levels'ere taking place on other portions of the control boards.
Conclusions While the inspectors found that the evolutions observed were carried out satisfactorily, in accordance with procedures, and with a high degree of competence, the examples above indicate that control room formality, knowledge of plant conditions, annunciator response, and three-part communications could all be improved.
0 erations Observations Ourin Unit 2 Shutdown Ins ection Sco e
71707 The inspectors observed Unit 2 operators remove the unit from service to repair a high temperature condition on a portion of the B isophase duct.
The inspectors also observed subsequent low power operation control and the return to service of the unit.
Observations and Findin s On the morning of Harch 24, the licensee identified by thermography that a hot spot on the B isophase duct they had been monitoring had degraded beyond their preestablished criteria to remove the unit from service.
At approximately 10:00 am, Operations started reducing power at a
controlled three megawatts per minute rate.
The licensee did not consider this an emergency downpower, and the operators were well-briefed to take their time, and ask any questions that might arise.
Generally. the inspectors found the shutdown to be well performed and coordinated.
The inspectors had two comments about the evolution.
First, the Assistant Nuclear Plant Super visor (ANPS) was observed with the procedure in hand, at the control panel during the shift oyer to the 15 percent feedwater bypass valves.
Normally, the ANPS maintains more overall command and control during multiple evolutions.
Second, the crew had several. quiet mini-briefs during the evolution.
They used the opportunity to review the immediately impending evolutions, and answer any questions that may have existed.
This was beneficial to the crew and maintained their focus on the tasks at hand.
The inspectors observed several periods of maintaining reactor power level below 3 percent and above the point of adding heat.
There was
good cooperation noted between Operations and Reactor Engineering (RE).
RE provided an expected Xenon curve for the off-line period.
This curve included rates of Xenon buildup and burnout, and expected time to maximum Xenon concentration.
The inspector observed conversation between RE and Operations in which the rate of adding water or boration was discussed.
The inspector reviewed the reactor power recorder traces for the period and noted that the operators were able to keep power level constant.
The inspectors observed portions of returning the unit to service on Harch 25.
Overall, the process was completed according to approved procedures and met all regulatory requirements.
Operations personnel controlled the plant in a safe and conscientious manner.
The inspectors did observe several notable items.
First, the inspectors observed approximately 24 personnel in the Control'oom envelope, with another half dozen outside the partial wall.
At the time, the oncoming crew was reparing to assume the watch from the off going crew.
Turbine testing ad just been completed, and the Operators were making preparations to begin rolling the turbine.
The inspectors observed a high potential for confusion because of the evolutions in progress (reactor power control, steam generator level control with the steam bypass system not performing as expected, turbine roll preparations, and individual station turnover)
and the large amount of people and side conversations in progress.
, The inspectors also observed multiple Non-licensed Operators (NLOs) in the control room for an extended period waiting for turnover.
Second, the inspectors observed both the ANPS and the Nuclear Plant Supervisor (NPS) concurrently become involved with the steam bypass control system problems.
At this point. the ANPS had decided to delay rolling the turbine due to the high osci llations of steam generator water levels due to this problem.
Later, the inspectors observed the NPS at the turbine control panel with a procedure in hand discussing a
problem with the operator and an I8C technician.
It is not abnormal for the ANPS to get involved in a problem when the plant is otherwise s'table, but it is generally accepted that one of the supervisors would maintain an overall cognizance of the plant.
Before latching the turbine, Procedure NOP-2-0030124, Revision ll,
'Turbine Startup Zero to Full Load." required a local operator to reset relay 20/ET.
The control room operators failed to perform this step twice.
As a result, the NPS stopped all extraneous activities in the control room, pointed out the error to the operators, reminded them that this was not acceptable behavior.
and refocussed the crew on the activity at hand.
The inspector found the NPS's handling of the situation to be appropriate.
Approximately twenty minutes after the incident mentioned above, the inspector observed widespread confusion growing in the control room.
The crew members were performing their tasks independently.
They were not aligned to return the unit to service.
As the inspector entered the area to investigate, the ANPS stopped all work and called a crew brie gl
02.1 02.2 The brief reviewed the crew's immediate and short term goals and refocused all of the members to the task at hand.
The control room became much more organized.
The NLOs in the control room were dispatched to perform their rounds.
The inspector noted a step change in the ability of the team to perform its task.
The inspector also observed a Reactor'Controls Operator (RCO) question the wisdom, of trying to roll the turbine with the steam bypass control system causing large swings in steam generator level.
At that time level was fluctuating between 60 and 70 percent.
The ANPS decided to delay rolling the turbine until the steam generator level osci llations could be dampened.
The RCO exhibited a good questioning attitude and the decision to wait was sound.
Conclusions The inspectors found the evolution to take Unit 2 off-line and then restore it to service was accomplished according to procedure in a safe and conscientious manner.
Several operational conduct weaknesses and strengths were identified during the observation period.
Operational Status of Facilities and Equipment En ineered Safet Feature S stem Walkdown 71707 The inspector walked down accessible portions of both units'mergency Core Cooling System Ventilation systems.
Equipment operability, material condition, and housekeeping were acceptable.
Several minor discrepancies were brought to the licensee's attention and corrected.
The inspector reviewed the data from the last test of the filters.
The inspector verified that the tests were completed in accordance with Technical Specification 4.7.8.1.
The inspector identified no substantive concerns from this walkdown.
E ui ment Clearance Order Review Ins ection Sco e
71707 The inspector'eviewed two Equipment Clearance Orders (ECO), 1-98-03-078 and 2-98-03-085.
during the report period.
The inspector verified that the clearances were properly prepared and authorized.
The inspector also walked down the accessible components.
Observations and Findin s The inspector verified that the two clearances were properly prepared by the Clearance Center and properly authorized by the Work Control Center Assistant Nuclear Plant Supervisor (WCC-ANPS).
The inspector walked down the accessible components and verified that they were properly tagged and in the correct position.
The inspector identified no deficiencies in this are f>
08.1 During the review of the clearance paperwork, the inspector noted that the clearance request forms were inadequately prepared.
Procedure ADM-09.04, Revision 3, "In-Plant Equipment Clearance Orders," Section 6.8.D required that the ECO request suggest a "detailed boundary for the work to be performed under the clearance request."
Neither clearance reviewed had a suggested boundary included with the request.
The inspector reviewed all of the open safety related clearances (six total)
and found four other requests with inadequate recommended boundaries.
Typical request included "isolate system" and "Isolate * Depressurized *
Drained."
The inspector reviewed the clearance request with the WCC - ANPS and he stated that Electrical and I&C Maintenance generally prepared good requests, but the others were generally poor.
The inspector was shown several other clearance requests that did not include deenergization of the component to be worked on or did not include any instructions.
Another was just a copy of the work order.
The inspector spoke with Operations supervision about the problem.
The licensee agreed that the procedure was not being followed, and opted to remove the requirement from the procedure.
Technical Specification 6.8. l.a requi res that the licensee establish, implement, and maintain procedures covered in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 1.a of that Regulatory Guide requi res procedures for the control of equipment clearances.
Procedure ADM-09.04, Section 6.8.D required that the ECO request suggest a "detailed boundary for the work to be performed under the clearance request."
Contrary to the above.
the inspector identified at least six safety related=clearance requests that had no or inadequate recommended boundaries.
This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the Enforcement Policy (NCV 50-335,389/98-03-01,
"Failure to Follow the Equipment Clearance Order Request Procedure" ).
Conclusions The inspector found the safety related clearances hung in the field technically and administratively adequate.
The inspector identified a weakness in the preparation of the clearance requests.
An NCV was identified because a large percentage of clearance requests did not comply with the licensee's procedure to propose a detailed boundary.
Miscellaneous Operations Issues Closed LER 50-389/96-003-00
"Safet In 'ection Tanks Valves Procedurall Isolated In Mode 4 Due to Personnel Error" 92901 During the process of upgrading procedures on June 25, 1996, the licensee identified that the Unit 2 Safety Injection Tanks (SITs) were being rendered inoperable in Mode 4 by closing and deenergizing the discharge valves in accordance with Operations procedure Two procedures were in effect. at that time which directed these actions be taken, Normal Operating Procedures 2-0030127,
"Reactor Plant Cool-down-Hot Standby to Cold Shutdown,"
and 2-0030121,
"Reactor Plant Heatup-Cold Shutdown to Hot Standby."
Those procedures required that the discharge valve of each required SIT be closed and deenergized when in Mode 4 with RCS pressure less than 276 psia.
Technical Specification (TS) 3.5. 1 allows the SITs to be isolated under these conditions; however, it did not allow the discharge valves to be deenergized.
The licensee concluded that the cause of the event was personnel error made when the plant procedures were initiallywritten.
The TS term
"isolated" was mis-interpreted as allowing the valves to be deenergized.
This condition existed since the aforementioned procedures were initiallywritten in May, 1982.
The licensee performed an assessment to determine the significance of this condition and concluded that it was of minor safety significance.
The licensee determined that the High Pressure Safety Injection System (HPSI). which is also required to be operable under those plant conditions, would provide sufficient flow to exceed the boi 1-off rate from the core.
Upon discovery, the licensee issued a night order to the licensed operators informing them of the condition to ensure immediate compliance.
The affected procedures were revised to ensure the SITs remain operable until the unit is in Mode 5.
The procedure revision and review process was revised to ensure'he UFSAR and TS are reviewed when procedures are revised. or reviewed.
The LER was discussed in licensed operator requalification.
In addition, the licensee performed a
UFSAR/Procedure Consistency Review in response to a separate event.
During this review the operating procedures were compared to the UFSAR to determine if the plant was being operated consistent with the UFSAR.
The licensee concluded this project in December 1996 and incorporated the necessary procedural or UFSAR changes into thei r tracking system.
The inspector reviewed Normal Operating Procedures 2-0030127, Revision 11,
"Reactor Plant Cooldown-Hot Standby to Cold Shutdown" and 2-0030121, Revision 7,
"Reactor Plant Heatup-Cold Shutdown to Hot Standby,"
and verified they had been appropriately revised.
In addition, the inspector verified that the event had been discussed with the licensed operators.
This procedural error resulted in the plant being allowed to operate in a condition prohibited by TS.
This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy (NCV 50-389/98-03-02,
"SIT Discharge Valves Procedurally Isolated In Mode 4 Due to Personnel Error During Procedural Development" ).
I
08.2 Closed VIOs 50-335/EA-96-040 Issues Relatin to Unit 1 Overdilution Event Januar
1996 92901 The subject escalated enforcement action resulted from an overdi lution event which occurred when a licensed operator turned over the reactivity controls responsibility to another operator without adequately informing him that a dilution was in progress.
The event was inspected and the results detailed in NRC IR 96-03.
Enforcement issues resulting from that event included three violations:
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VIO 01013,
"Operators Failed to Follow Procedures for Boron Dilution. Match Turnover, Procedure Adherence.
and Event Reporting"
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VIO 01023,
"Inadequate'esign Control of Reactor Coolant System Boron Dilution Procedure"
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VIO 01033,
"Inadequate
CFR 50.59 Safety Evaluation of Change to Boron Dilution Procedure The inspector reviewed the licensee's corrective actions, committed to in their response to the Notice of Violation, and found that all corrective actions had been completed satisfactorily.
The inspector noted that corrective action 4.C (as specified in FPL letter L-96-93, dated April 23, 1996) to violation 01023, which involved a review of both units'FSAR to ensure that procedures described in the UFSAR were appropriately translated into plant procedures, was being tracked as NRC URI 50-335,389/96-008-05.
The adequacy of the licensee's actions in this area will be evaluated in resolving the subject Unresolved Item.
These violations are closed.
Closed LER 50-335/97-001-00
"0 eration Prohibited B
Technical S ecifications Due To Deficiencies In The Pro ram For Post Accident Sam lin "
71707 92901 92904 Closed VIO 50-335 389/97-01-02
"Pro rammatic Breakdown of Post-Accident Sam lin Ca abilit "
92904 This LER and violation documented that deficiencies associated with the post-accident sampling system (PASS) were identified which in the aggregate represented a failure to satisfy the requirements of Technical Specification (TS) 6.8.4.e.
The inspector had identified examples of inadequate post-maintenance testing, fai lures to take timely and appropriate cor rective actions when the system was inoperable, failures to perform requi red instrument calibrations, inconsistencies between the installed plant equipment, UFSAR and vendor documents, discrepancies between drawings and control panel mimics, inoperable indicating lights, and incor rect operator aids.
These deficiencies relating to design control and maintenance of the system collectively resulted in a programmatic breakdown and failure to satisfy the requi rements of TS.
In one example, the licensee's fai lure
to perform an adequate post-maintenance test resulted in the Unit 2 PASS being inoperable from November 26, 1996 to February 22 '997.
The licensee subsequently concluded that this condition constituted a
condition prohibited by TS and subsequently submitted an LER documenting the event.
The licensee concluded that equipment problems were not expeditiously identified and repaired because there was a general lack of system accountability.
Work controls were not adequately prioritized to ensure system availability.
Post maintenance testing requi rements for the PASS instrumentation were not adequate to ensure proper system operation following maintenance.
In addition, preventive maintenance and procedural deficiencies existed as a result of inadequate vendor manual and UFSAR technical reviews.
The licensee also identified that inconsi stencies between control panel mimics and flow diagr ams existed as a result of fai lure to update drawings following plant modifications.
The licensee's corrective action included the following:
1.
The system was added to the list of Haintenance Rule systems with a system engineer assigned the accountability to monitor PASS performance and assist in improving overall system reliability.
2.
Work Control Guideline WCG-003, Revision 1.
"Work Scheduling And Coordination,"
added the PASS to Appendix C,
"Systems Requiring Increased Controls During Online Maintenance."
This appendix included requi rements to expedite maintenance associated with the system.
The inspector reviewed work orders associated with the system and noted that they were being worked in a timely fashion in accordance with WCG-003.
A detailed walkdown of each unit's PASS was performed to identify the design configuration discrepancies.
Those discrepancies included drawing and vendor manual errors and errors on the control panel mimic.
Those discrepancies were subsequently resolved.
The inspector compared the control panel mimic with the applicable drawing, ENG-97047-108, and noted minor discrepancies.
One flowpath depicted on the drawing indicated it led to containment while the mimic on the panel indicated it led to gaseous effluent.
Additionally, there were several labels on the control panel that were not depicted on the drawing.
Labels were placed on the panel which identified that portion of the system which was used for gas sample and liquid sample, however they were not identified on the drawing as such.
However, with those exceptions, the mimic and the drawing were in agreement.
The inspector noted that the drawing was difficult to read and in some cases was completely illegibl I
The inspector reviewed portions of the vendor manual, 8770-9751.
and verified that the manual had been updated based on previous modifications.
. The UFSAR and Chemistry procedures were reviewed.
Discrepancies were identified and corrected.
The inspector reviewed portions of the proposed UFSAR changes and verified that the changes would be implemented during the next scheduled update.
In addition, the inspector reviewed two chemistry procedures, 1-COP-06.09, Revision 0, "Performing an Operability Test On The Unit 1 Post Accident Sampling System (PASS)
and CG-61, Revision 4, "Verification Of Chemistry Sample Valve Position And= Indications."
The inspector noted no def'iciencies in the procedure.
However, it was noted that components were not identified with the same name in both procedures.
Listed below are several examples:
Valve Number V55001 V55003 V55023 V55027
',
CG-61'olenoid Valve for Sample Selection Mod Solenoid Valve for Upstream of Sample Select Solenoid Valve for PASS Smpl Cab Low Pr Sol Vlv for Liquid Sample Outlet Dwnstr 1-COP-06.09 Sample Selection Mod Inlet from 1A Hot Leg Solenoid Sample Selection Mod Strainer Upstrm Solenoid PASS Sample Cab Lp Sat Liquid Sample Line Solenoid Liquid Smpl Outlet Dwnstrm of D02
pH Electrodes Solenoid The inspectors have noted this problem on previous inspections.
It is the licensee's intention to refine component names as they are identified.
In addition, the inspector noted that the switches were not all aligned on the control panel in the same fashion.
The
"CLOSE" position for some switches was at the top, 12 o'lock position, while others had the
"CLOSE" position at the left, 9 o'lock position or the right 3 o'lock position.
The following are examples; 2-V5743, Liquid Sample Isolation -
CLOSE position:
9 o'lock 2-V5780, Gas Sample Vessel Isolation - CLOSE position 12 o'lock 2-V5735, Surge Vessel Pump Discharge
-
CLOSE position 3 o'lock
r
The inspector could find no procedural requirement dictating how the switches were to be placed on the panel but noted this as a
poor human engineering practice.
The UFSAR and vendor manuals were reviewed to determine the necessary preventive maintenance requi rements.
Additional preventive maintenance requirements were subsequently developed which perform loop calibrations on the various instrument loops, vent the systems and perform an operability check.
The inspector reviewed the work order and verified the appropriate maintenance activities were included.
The maintenance work order which implemented this procedure for unit 1 was 91000401 and unit 2 was 91000692.
6.
Post maintenance test requirements were reviewed to ensure that adequate functional testing was performed following maintenance.
System components were reviewed to ensure that necessary components were added to the Total Equipment Data Base (TEDB) and to properly label those components.
8.
A new procedure was developed to perform a periodic check of the PASS system alignment.
The inspector reviewed this procedure as noted in item.4 above.
Operator aids associated with chemistry systems were reviewed and updated.
The inspector reviewed the operator aids in place and noted no discrepancies with the controlling document, Chemistry Guideline CG-62, Revision 0, "Control of Chemistry Aids."
10.
The process associated with updating and controlling vendor technical manuals for safety related and TS required equipment was reviewed.
Recommendations for improvement were proposed with an implementation due date of March 31, 1998.
This item was being tracked by Plant Manage s Action Item PMAI 98-02-026.
On March 26, the inspector witnessed the licensee obtain a reactor coolant sample using the PASS.
The sample was obtained in accordance with 1-COP-06.09, Revision 0, "Performing An Operability Test On The Unit 1 Post Accident Sampling System (PASS)."
The technicians drawing the sample appeared knowledgeable about the system, executed the procedure without error and successfully obtained the sample.
However, during the performance of the procedure the following items were identified:
1.
The power switch for the Whittaker hydrogen analyzer was installed upside down.
This did not present a problem but was recognized as operating backwards when compared to other breakers'.
2.
The procedure did not state what action should be taken upon receipt of a high strainer d/p alarm.
It simply described where the switch used to silence the alarm was located.
It was
recognized that an alarm would be received when initially placing the system in service, however, it also alarmed later in the process.
The technicians stated that a work request would be written.
The inspector noted a bypass valve around the strainer
.and questioned if the licensee had considered using the bypass in the event that the strainer was clogged and a sample was needed.
The licensee stated that they had not considered that possibility but would address the issue of what action should be taken when the alarm is received.
3.
Two sample flow temperature indicators located on the PASS control panel were not labeled.
4.
The Whittaker hydrogen analyzer did not respond properly.
A work request was written.
While isolating the system, the sample line pressure increased after the V55001, Sample Selection Mod Inlet from 1A Hot Leg valve, was closed.
This valve is one of three that isolates the reactor coolant system from the PASS.
The licensee stated that they would investigate the condition and generate a work request if needed.
The inspector noted that the operability test only verified the capability to obtain a sample from the reactor coolant, pump hot leg.
It did not verify the capability to obtain a sample from the Low Pressure Safety Injection (LPSI) pump discharge.
The inspector discussed this with Chemistry personnel who stated that although this flow path had been tested in the past it was not routinely tested.
The inspector considered this to be a weakness in the program.
Condition Report 98-0543 was initiated to address the items identified above.
The inspector compared the operability test to the procedure used to obtain a sample during accident conditions, 1-COP-06.01.
Revision 0,
"Operation Of The Unit 1 Post Accident Sampling System During Accident Conditions,"
and noted that they were generally alike.
However, the inspector noted that 1-COP-06.01 did not contain a step to return the control switch to OFF for the V55024, Liquid Sample In1et To Grab Solenoid.
The inspector informed the licensee of this omission.
The inspector concluded that the PASS would perform the function for which it was designed.
Licensee attention has been focussed in returning the system to an acceptable level of performance.
However, the inspector noted numerous deficiencies associated with the system which warranted additional attention.
This LER and violation are closed 08.4 Closed LER 50-335/97-004-00
"0 eration of a Refuelin Machine in a Manner Prohibited b
Technical S ecifications" 92901 The subject LER discussed a deficiency in the control circuitry for both units'efueling machine such that Technical Specification requirements were not met.
During a review of industry operating experience, the
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licensee identified that the original design of the refueling machine circuitry bypassed the overload cutoff during the six inches of the lift after clearing the top of the fuel area.
This feature, which the licensee identified as common on this type of machine, was included to avoid an erroneous overload condition during the transition from lifting a fuel assembly only to lifting a fuel assembly and the hoist box.
The licensee removed the bypass function from each unit's refueling machine prior to the next outage for each unit.
The inspector verified the corrective actions by reviewing the applicable work order to accomplish the tasks.
The i,nspector determined that for every refueling prior to the discovery of the existence of this bypass.
the licensee was in violation of'echnical Specification 3.9.6.
This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy (NCV 50-335.389/98-03-03,
"Failure to Operate the Refueling Machines in Accordance With Technical Specifications" ).
This item is closed.
08.5 Closed LER 50-335/97-005-00
"Reactor Shutdown Re uired b
Technical S ecifications Due to Reactor Coolant Pressure Boundar Leaka e" 92901 The events discussed in this LER were discussed in Inspection Report 97-04.
The inspector reviewed the LER and found that it correctly characterized the event.
This LER is closed.
Ml Conduct of Maintenance Ml. 1 General Comments II. Maintenance a.
Ins ection Sco e
61726 62702 62707 The inspectors observed maintenance activities for portions of the following work orders (WOs) and reviewed associated documentation:
WO 98002406 01, Perform Mid Cycle Cleaning of component cooling water (CCW) heat exchanger (HX) 2B Strainer SS-21-1B WO 98000083 01, Clean and Inspect CCW HX 2B WO 98002404 01, Perform Mid Cycle Cleaning of CCW HX 2A Strainer SS-21-1A WO 98000093 01, Clean and Inspect CCW HX 2A WO 98027586 01, Load Test 2B Battery Charger
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WO 98003883 01, Furmanite Repair Casing Flange Leak on Feedwater Pump 1A
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WO 98002626 01, Perform Monthly PM on Unit 2 Radiation Monitors
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WO 98002205 01, Troubleshoot and Repair SIGMA Flow Indicating Alarm for Reactor Coolant Pump 2B1 Controlled Bleed-off
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WO 97028353 01, Perform Quarterly Inspection of'nit 2 Air Handling Unit HVA/ACC-3C For Control Room Area Supply
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WO 98001765 01.
Replace Fan Motor Bearings for Unit 2 Air Handling Unit HVA/ACC-3C WO 98002711 1A, Replace Fan Bearings for Unit 2 Air Handling Unit HVA/ACC-.3C
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WO 98002711 01, Install Belts and Align Fan Motor for Unit 2 Air Handling Unit HVA/ACC-3C
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WO 98005825 01, Repair of Damaged Isophase Bus Duct In addition, the inspectors observed the following survei llances and post maintenance tests:
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1-1400059 Unit 1 Reactor Protection System
- Periodic Logic Matrix Test
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2-2200050B 28 Emergency Diesel Generator Periodic Test and General Operating Instructions b.
Observations and Findin s During observation of the above in-process maintenance work, the inspectors evaluated procedure use, assignment and performance of QC hold points, foreign material exclusion (FME) controls, measuring and test equipment (METE) controls, post-maintenance testing (PMT) and qualification of maintenance personnel.
The applicable revisions of procedures were in place and were being conscientiously followed by qualified maintenance personnel.
Personnel had a questioning attitude, and on more than one occasion, had procedure or WO requirements clarified before proceeding with an activity.
Maintenance supervision was closely involved with monitoring in-process maintenance work.
Good interface between maintenance and operations personnel was observed.
Applicable FME controls, M&TE controls, PMT requi rements.
and QC hold points were being accomplished in accordance with requi rements.
The inspectors also observed that work activities were properly documented and problems encountered during the performance of the work activities were appropriately resolve To further verify that QC hold points were being properly observed and documented, the inspectors reviewed the following completed WOs:
Ml.2 For these WOs, all required QC hold points were appropriately signed.
Conclusions
, Maintenance activities reviewed were adequately performed and documentation was good.
Procedures were in place and were being conscientiously followed by qualified maintenance personnel.
Interface between maintenance and operations personnel was good.
Applicable FME controls, M&TE controls, PMT requirements, and QC hold points were being accomplished in accordance with requirements.
Reactor Coolant Pum Seal Re lacement Ins ection Sco e
62707 71750 The inspector observed portions of the preparations and replacement of the 1B2 Reactor Coolant Pump (RCP) seal package during the Unit 1 Short Notice Outage.
The inspector reviewed procedural compliance, worker knowledge, maintenance support, Foreign Material Exclusion (FME)
controls, and radiological controls during the maintenance.
Observations and Findin s The licensee shut down Unit 1 on February 16 to replace a failing RCP seal package on the 1B2 pump.
The pumps for both units were Byron Jackson pumps with four seal stages each.
Each of the first three stages was capable of operating with full RCS differential pressure across it.
The licensee had decided to operate with one seal failed approximately one month earlier.
When the licensee noted indications that the second stage was beginning to fail, they made the decision to shut down the unit for repairs.
The inspectors verified that the licensee was prepared to enter a
reduced inventory condition prior to the licensee lowering level.
Besides reviewing the licensee's administrative program to control'id-loop operations'he inspector verified that the licensee had containment closure capability, two independent Reactor Coolant System (RCS) temperature and level indications, and at least two means of adding borated water.
Upon reviewing the seal package replacement procedure, M-008, Revision 26.
"Reactor Coolant Pump Seal Removal," the inspector noticed that the procedure required RCS level to be less than 33 feet. but the licensee Work Control group had only planned on lowering level to 34 feet.
,This would potentially allow the licensee to
not perform Reactor Coolant Pump sweeps to clear air from the steam generators.
When the inspector pointed out the procedure inconsistency, the licensee revised their plan to lower level to 33 feet.
The licensee had been preparing to replace the seal package from the time that the first stage failed.
They assembled a seal package in the shop and had it ready for installation.
The inspector observed portions of the removal of the old seal package and installation of the new seal package.
The mechanics were using procedure M-009, Revision 26 "Reactor Coolant Pump Seal Installation," to replace the seal.
Good procedural compliance was observed by the inspector during the process.
The foreman maintained the working copy up to date and the workers referred to the procedure often.
The inspector questioned the workers about their work practices and procedural knowledge and identified no deficiencies in this area.
The inspector also observed that Engineering support was available to quickly solve any problems that occurred.
The maintenance crews completed the job approximately eight hours ahead of their schedule.
The inspector observed the job to be completed within the bounds of the approved procedures.
The inspector observed that the maintenance crew took appropriate actions to maintain FME control during the replacement.
The inspector verified that guality Control performed a cleanliness inspection of the bowl area before installation of the new seal.
Once the unit reached Mode 4, overall control of the material taken into containment was left up to the workers.
Health Physics (HP) briefed every person entering containment to take only what they required and to bring everything back out when completed.
The inspector verified that the workers in containment were following this guidance.
The inspector found only minor deviations that maintenance personnel corrected.
The inspector observed several aspects of the Radiological Controls for the project.
The original brief of personnel for the job was well coordinated and involved most of the personnel that would participate in the job.
Overall, the workers minimized thei r dose.
HP maintained workers'wareness of'adiation levels in work locations.
Hot particle areas were set up as requi red by HPP-15, Revision 3,
"Hot Particles,"
and personnel access and egress into the area, were appropriate.
Conclusions The inspector concluded that the RCP seal replacement was accomplished as planned by knowledgeable Mechanical Maintenance personnel in accordance with approved plant procedures.
Support for the project was immediately available, and FME and radiological controls were goo ~
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N1.3
Refuelin Water Tank Outlet Valve Ins ection Ins ection Sco e
62707 In January.
the licensee identified that motor oper ated valve (HOV) HV-07-1A, the "A" train Emergency Core Cooling System (ECCS) suction valve from the Refueling Water Storage Tank (RWT), would not cycle.
When the licensee opened the gearbox of the HOV, they found the gears were restrained by corrosion.
The licensee instituted a corrective action to verify the "B" train valve was not similar ly corroded.
The inspector observed the inspection of NV-07-1B.
Observations and Findin s On March 17, the licensee performed an inspection on MV-07-18, the "B" train ECCS suction valve from the RWT.
The inspection included MOV diagnostic testing (VOTES Testing)
and inspection of the MOV gear chamber.
Appropriately, the licensee declared the "B" train of ECCS out of service during the inspection.
Technical Specification 3.5.2 states that if one train of ECCS is out of service it must be returned to service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Because of the short action statement time, the licensee planned'the inspection. with contingencies.
in detai l.
The inspection started with VOTES testing of the valve in the as-found condition.
The data generated by the test was nearly identical to data taken more than two years ago.
The licensee then performed a visual inspection of the gear box.
In contrast to NV-07-1A, inspected in January, NV-07-1B was in a l.ike new condition.
The inspector saw no sign of corrosion of the gears or degradation of the grease.
The licensee restored the valve and turned the retest over to operations.
The post maintenance test (PHT) of the valve was a timed stroke of the valve.
The inspector observed the stroke test and noted no problems with the PMT.
Since no indications of'roblems with the valve existed, the licensee declared the system operable again by early afternoon.
The inspector discussed with Engineering about probable causes for the buildup of corrosion in MV-07-1A.
Engineering believed the seal for the gear casing had leaked due to degradation or possibly improper'nstallation.
Conclusions The inspection of'he motor operated valve HV-07-1B was well planned.
The electricians and engineers working the job were knowledgeable of their task M1.4
. Ventilation Fan HVE-8A Maintenance Ins ection Sco e
62707 The inspector observed portions of the replacement of the main bearing for the ventilation fan 2HVE-BA, containment purge fan.
The inspector also reviewed the work order for the task.
Observations and Findin s On March 3. the inspector observed a portion of the main bearing replacement for the 2HVE-8A fan.
The mechanics were performing the work according to Work Order 97028113 01.
-The inspector reviewed the work package and verified that the work had been properly authorized, and the work was being properly documented.
No problems were noted with the work order.
The inspector questioned the mechanics-about the job.
The lead journeyman was knowledgeable about the task and the history of the component.
He stated that he had verified the equipment was satisfactorily tagged out, and that the paperwork was correct before starting.
The inspector noted that the mechanics were well organized and had all of the tools necessary at the worksite to perform their job.
Conclusions
"
Work on the 2HVE-8A main bearing was performed according to written procedures by knowledgeable mechanics.
Proper approval was received and the Equipment Clearance Order was verified prior to commencing work.
Control of Maintenance Backlo Ins ection Sco e
62702 62707 The inspectors reviewed control of the maintenance backlog to determine if identified corrective maintenance was being accomplished in a timely manner
.
Observations and Findin s Based on discussions with licensee personnel (Plant Manager and Maintenance Manager),
reduction of the maintenance backlog has had a
high priority.
The status of the backlog is highlighted in management meetings on a daily basis.
The non-outage backlog includes all Type
(planned miscellaneous),
Type 3 (projects),
Type 5 (trouble and breakdown)
and minor maintenance WOs.
The goal has been to have the total non-outage backlog of WOs less than 650.
On February 26, 1998, the backlog was 631 with 94 of the 631 being minor maintenance.
The 631 is compared to a backlog of approximately 900 in May 1997.
The backlog of Type 5 WOs had been reduced from approximately 120 in January 1997 to approximately 75 currently. with the average age reduced from 114 days to 61 days over the same period of time.
Also, the number of WOs
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greater than nine months old had been reduced to six with none greater than 12 months old.
Any time a
PH becomes overdue, a Condition Report (CR) is required.
Conclusions Based on the above review, the inspectors concluded that the licensee was aggressive in reduction of the maintenance backlog and the backlog was being well controlled.
Reactor Coolant Pum Failures 62707 On February 20, 1998, reactor coolant pump (RCP)
1B1 tripped on over-current.
The inspectors reviewed the status of corrective actions for this failure to determine if the fai lure was being evaluated in accordance with the Maintenance Rule program.
CR 98-0315 had been issued with an interim disposition.
Based on review of the CR. the failure of the pump trip was a severed phase A motor lead caused by local heating creating an arc and melting of the lead.
For Maintenance Rule purposes, the CR identified the failure as a functional failure.
However, since the root cause analysis had not been completed.
the licensee had not determined if the functional fai lure was maintenance preventable.
Therefore, the CR disposition was interim. awaiting determination of the root cause.
Licensee Maintenance Rule personnel stated that after determination of the root cause, a decision would be made relative to whether the failure was maintenance preventable and appropriate corrective actions would be determined.
In mid January 1998, one stage of the 1B2 RCP seal failed.
On February 17.
1998, a second stage was showing signs of problems and the plant was shut down to repair the seal (see paragraph Hl.2 for additional details).
The failure of one stage of RCP seal was not considered to be a functional failure since the seal has four stages and only one failed leaving the seal still oper able.
Thus the function of the seal was not lost.
At the time of the inspection, the licensee had not performed a root cause determination for the seal failure.
The evaluation was still in process to determine what corrective actions needed to be made and how Maintenance Rule program Figure 4 (goal setting and monitoring criteria) needed to be changed.
As part of corrective action evaluations, a new seal design (N9000) being used at other Combustion Engineering plants was being considered.
For these RCP problems, the inspectors concluded that the licensee was considering Maintenance Rule requirements in corrective action and disposition of equipment failure 'k J
M4. 1
Maintenance Staff Knowledge and Performance Control of Maintenance Personnel Ins ection Sco e
62707 During the report period. the licensee experienced the misoperation of three components due to maintenance personnel not being careful to avoid contacting equipment in the area they, were working.
The inspector reviewed each occurrence and assessed licensee management's reactions.
Observations and Findin s On March 16. operators received an annunciator indicating a
DC ground on the 2A Start Up Transformer.
The Non-Licensed Operator (NLO) that responded found that painters were using a pressure washer to clean the transformer.
Water had penetrated the rubber door seal causing arcing near the gl main control power supply to the control cabinet.
Electrical Maintenance Supervision and Fire Protection were called to the scene.
Meanwhile, the painters were instructed to stop.
The electrical supply was immediately swapped to the backup control power.
Electrical Maintenance repai red the terminal block, replaced a breaker, and replaced degraded wiring.
Electrical Maintenance Supervision decided that all future washing of transformers would be by hand.
The Plant General Manager, the Electrical Maintenance Supervisor.
the Sub-Station Supervisor and the Foreman met on March 24, to outline the
'lant's expectations on work control and they required Sub-.Station supervision to make procedural and programmatic changes.
On March 23, painters were working on a scaffold in the B Emergency Diesel Generator (EDG) room when one of them accidentally kicked open an air receiver drain valve.
The Control Room was alerted by the low air ressure alarm and the air compressor did start to maintain pressure.
he painter was aware that he had opened the valve and the valve was shut shortly after the NLO arrived.
On March 24.
a painter accidentally kicked open a breaker for the B
EDG fire system inverter.
The control room sent an NLO to investigate and correct the problem.
In this case, the painter was unaware of a problem.
The licensee held a stand down after these three events.
They performed a root cause evaluation that determined that the workers were focused on their tasks and did not pay attention to the equipment surrounding thei r tasks.
The licensee also determined that the workers were not generally knowledgeable of the sensitivity of the equipment surrounding their tasks.
The licensee's corrective action was extensive.
First, supervision discussed the events with the maintenance workers.
Second, supervision and Operations walked down and identified sensitive equipment to the workers.
Third, these workers will be subjected to increased supervisory oversight.
Last, the licensee reviewed other work for potential issues and held meetings with the workers about these tasks
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Conclusions The licensee identified an adverse trend when three events involving misoperation of plant equipment by personnel painting occurred in less than two weeks.
The inspector found the corrective actions to be swift and appropriate.
M4.2 I8C Performance Im rovement Plan a.
Ins ection Sco e
62707 The inspector reviewed efforts by the I8C department to identify areas f'r departmental perf'ormance improvement.
b.
Observations and Findin s As a result of a recent number of events involving I8C personnel performance, the licensee developed a performance improvement plan for the department.
The plan resulted from a cooperative self assessment process between bargaining unit personnel and management.
The self assessment identified a number of causal factors for-I&C performance problems, to include:
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Ineffective communications
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Lack of attention to detail
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Poor teamwork
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Low morale Each area of concern was addressed by the team with individual.
trackable,'orrective actions aimed at bolstering individual areas of weakness.
Corrective actions included:
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Daily briefings and crew meetings and a formalization of the turnover process to improve communications
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Training, to include the use of a simulator, to strengthen attention to detail and communications skills.
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Peer reviews and team building activities aimed at fostering cooperation within the department.
c.
Conclusions The inspector found the I8C department's initiatives to improve departmental performance and, particularly, the involvement of bargaining unit personnel in the improvement process, to be a positive step.
The effort was successful in developing definable, implementable corrective action j
H8
Miscellaneous Haintenance Issues M8.1 E1 El. 1 Closed LER 50-335/96-011-01
"0 eration Prohibited b
Technical S ecifications Due to Failure of Ox en Anal zer
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92902 The subject LER discussed a failure in a waste gas oxygen monitor failed, allowing the 1A Gas Decay Tank oxygen levels to exceed the value allowed in Technical Specification 3. 11.2.5.
On August 17.
1996, the licensee discovered that the Unit 1 in-service waste gas oxygen analyzer had failed.
The cause of the failure was determined to be a failed sensor-membrane in the oxygen detector.
The failure mode was such that when the membrane failed the monitor continued to display a valid reading and inhibited the high oxygen content alarm.
Based on an unchanging indication, the licensee's investigation concluded that the monitor had not provided an accurate oxygen concentration for six days.
Technical Specification 3.3.3. 10 required that oxygen samples be taken and analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the oxygen monitor was out of service.
Contrary to the above, the monitor was inoperable for six days without the requi red compensatory sampling.
This non-repetitive.
licensee identified and corrected violation was treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy and was identified as NCV 50-335/98-03-04.
"Failure to Adequately Sample Gas Decay Tank Oxygen Levels When the Waste Gas Analyzer Failed."
III. En ineerin Conduct of Engineering Unit 1 Feedwater Isol ati on.Va1 ve B
ass Line Leaka e
Ins ection Sco e
93702 37551 On February 27, the licensee identified steam leaking from a socket weld on a Unit 1 main feedwater isolation valve (MFIV) bypass line.
The bypass line was a 1" pipe terminating on either extreme at the body of the MFIV on opposite ends of the valve's seat and included an isolation valve in the pipe run.
The leak was through the fillet weld of a socket connection on the steam generator side of the MFIV.
The inspector followed the licensee's activities relative to this condition.
Observations and Findin s On February 28, the licensee notified the inspector that an oper ability assessment, underway to establish a basis for continued operation, indicated that some manner of regulatory relief may be needed.
The inspector responded to the site.
The subject leak was the result of a in-hole in a socket weld's fillet material.
The inspector observed the eak and noted that concentrated steam was visible approximately 2'rom the weld.
The leak was later measured to be approximately 2..5 gallons per hour.
The licensee's operability assessment was being conducted assuming that the 1" line containing the weld failed as a result of weld
E8 E8.1
failure.
This assumption brought into question the operability of the Auxiliary Feedwater System (AFW), as the postulated pipe fai lure would create a bypass flowpath for AFW (AFW would be required to feed both the steam generators and the 1" pipe break).
The licensee involved NRC early in the evaluative process under the guidance in Generic Letter (GL) 91-18, Revision 1.
The licensee's desire was to implement alternate evaluation criteria for the flaw, as described in paragraphs 6. 13 and 6. 14 of NRC Inspection Manual Chapter 9900,
"Operable/Operability:
Ensuring the Functional Capability of a System or Component." which involved a qualitative assessment of the flaw and sustained observations for any potential increase in leakage.
for the interim period before ASME code relief was obtained for the installation of a mechanical clamp to stop the leak.
It was determined through discussion with NRC that alternate evaluation criteria were inappropriate, as insufficient baseline information was available for the weld in question (the class 2 weld had not been volumetrically evaluated when fabricated).
The licensee's ultimate operability evaluation assumed the inoperability of the subject weld and showed that the structural design of the pipe would maintain the orientation of the piping, thus creating an annular leakage area through the socket connection (as opposed to a full, open-ended, 1" path).
With this assumption, the licensee was able to show adequate AFW capacity.
The inspector found this approach acceptable.
A mechanical clamp was installed on March l.
At the end of the inspection period.
a relief request was pending with the NRC for acceptance of the repair
.
Conclusions The inspector concluded that the licensee acted responsibly in addressing a pin-hole leak in a fillet weld on a Unit 1 Main Feedwater Isolation Valve bypass line.
The licensee's ear ly involvement of the NRC in the process of addressing the condition under the guidance of Generic Letter 91-18 was noteworthy.
The licensee's engineering organization appropriately considered operability issues associated with the issue.
Miscellaneous Engineering Issues Closed LER 50-335/96-010-00
"0 eration Prohibited b
Technical S ecifications Due to Linear Ran e Nuclear Instrumentation Out of
~Si
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92903 The inspector reviewed the subject LER and found that it accurately described the subject event.
Corrective actions were found. to be complete and in effect.
Enforcement actions related to this issue resulted from investigations documented in NRC special inspection report 96-22 and were identified as violations 50-335/EA-96-457/03013 and 50-335/EA-96-457/03023.
This LER is close ~
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E8.2 E8.3 E8.4 E8.5 E8.6
Closed LER 50-335/96-016-00
"Insufficient Testin and Maintenance on 125 VOC Bus Cross-tie Breakers" 92903 The inspector reviewed the subject LER and found that it accurately described the subject event.
Corrective actions were found to be complete and in effect.
The details surrounding this event are described in NRC IRs96-201 and 97-06 (in which Non-Cited Violation 50-335/97-06-06, resulting from the inspection of the event, was documented).
This LER is closed.
Closed VIO 50-389/EA-96-236/01013
"Unreviewed Safet uestion Involvin EOG ZB" 92903 The inspector reviewed the licensee's corrective actions with respect to the subject violation, which resulted from inspections documented in NRC IR 96-12.
The inspector found that corrective actions were complete.
comprehensive, and appeared adequate to prevent recurrence.
This violation is closed.
Closed VIO 50-335/EA-96-249/03014
"Failure to U date Drawin s Followin Plant Modification" 92903 The inspector reviewed the licensee's corrective actions with respect to this violation, which resulted from inspections documented in NRC IR 96-12.
The inspector found the licensee's corrective actions to be of appropriate scope and complete and that programmatic changes made as a result of the subject violation were still in affect.
This violation is closed.
Closed LER 50-389/97-002-00
"Containment Sum Debris Screen Not in Accordance With Desi n Oue to Ga s in the Screen Enclosure" 92903 The subject event was described in NRC IR 97-09, and enforcement action was issued under violations 50-389/EA-97-329/01014 and 50-389/EA-97-329/02014.
The inspector reviewed the licensee's corrective actions described in the LER and found them appropriate and complete.
This item is closed.
Closed LER 50-335/97-06-00
"0 erations Prohibited b
Technical S ecifications Due to Inade uatel Tested De raded Volta e S stem" Ins ection Sco e
92903 While reviewing safety r elated logic circuits, as requi red by Generic Letter 96-01 "Testing of Safety Related Logic Circuits." the licensee became aware of a deficiency in their testing the Safety Injection Actuation System (SIAS) permissive contact for degraded voltage protection.
The inspector reviewed the subject LER and the associated.
Condition Report, CR 97-087 'h
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b.
Observations and Findin s
On Hay 1.
1997, while perform'ing a review of the Engineered Safeguards Actuation System (ESFAS) test procedure OP 2-040050.
Revision 22.
- "Periodic Test of the Engineered Safety Features,"
the licensee discovered that failure of the SIAS permissive contact for the degraded voltage protection system would not cause
'a load shed and Emergency Diesel Generator (EDG) start upon detection of'
degraded voltage condition as required by Technical Specification Table 3.3-4 item 6.
Sustained operation at lower voltages could cause damage to safety related components.
The degraded voltage protection system consisted of a set of undervoltage relays, set to a higher voltage than the loss of voltage relays, and two time delays.
The first time delay was of a length of time sufficient to establish the existence of a degraded voltage condition.
At the end of the delay.
a control room alarm alerted operators to the degraded condition.
An interlock with the SIAS was included such that a subsequent SIAS immediately separated the Class 1E power distribution from the offsite power system.
The EDGs would then start and align to the 1E buses.
The second time delay was limited in duration, such that the permanently connected Class lE loads would not be damaged.
If the Operators were unable to correct the problem after the second delay, the Class 1E power distribution would separate from offsite power, the EDGs would start and power the Class 1E buses.
Technical Specification 4.8. 1.1.2.e.5 required the licensee to verify the deenergization and load shedding of the emergency buses during a
simulated loss of offsite power in conjunction with an ESFAS signal every refueling outage (18 months).
The problem occurred because the load shed function was tested during ESFAS testing using a complete loss of power to the buses.
This resulted in the first level protection, the loss of voltage relays, initiating the load shed and EDG start.
In general, surveillance procedures provided for the calibration and test of the degraded voltage relays, time delays, and relay logic.
Therefore, the load shed function is verified for a complete loss of power.
However, the SIAS permissive contact that initiates the load shed and EDG start for a sustained degraded voltage condition was not verified by test.
At the time of the discovery, Unit 2 was in Hode 6 with reduced requirements for EDG operability as defined by Technical Specifications 3.8. 1.2 and 3.8.3.2.
Technical Specifications and licensee procedures do not require the 4160 V and 480 V Emergency Bus Undervoltage (Degraded Voltage) system to be functional in Hode 5 or 6.
The licensee completed testing of these contacts on Hay 9.
Unit 1 was in Hode 1 at the time of the discovery.
Full system operability requi rements per Technical Specifications 3.8. 1. 1, 3.8.2. 1, and Table 3.3-3 required both EDGs and the 4160 V and 480 V Emer'gency Bus Undervoltage (Degraded Voltage) system to be functional.
Surveillance requirements per Technical Specification 4.8.1. 1.2. s c
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included functionally verifying oper ation of the undervoltage system, including the degraded voltage protection system, on an 18-month (refueling) basis.
The licensee determined that operability of the B train degraded voltage system had been proven during the incident described in LER 50-335/96-007-00, where a Containment Isolation Actuation System Group 2 test was performed while the undervoltage relay potential transformers were removed.
This resulted in a load shed of the B train Emergency buses and start of the 1B EDG.
Since surveillance testing of the A train had not been performed, the-licensee declared 'the 4160 V and 480 V Emergency Bus Undervoltage (Degraded Voltage) system inoperable at approximately 9:00 am.
The licensee successfully tested the contact and declared the system operable again by approximately 4:30 pm.
The licensee later completed the appropriate procedure changes to ensure adequate testing of the contacts in the future.
The failure to test the Emergency Bus Undervoltage(Degraded Voltage)
systems fully is identified as a violation of Technical Specification 4.8. 1. 1.2.e.5.
This non-repetitive, licensee identified and corrected violation was treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy and was identified as NCV 50-335.389/98-03-05,
"Failure to Fully Test Emergency Bus Undervoltage (Degraded Voltage) Contacts."
Conclusions The subject LER accurately described the issues and resolutions that the licensee identified by the event.
The LER lacked some details that would have enabled the inspector to determine Technical Specification applicability.
The inspector was able to fully evaluate the event with the aid of the Condition Report issued by Engineering.
An NCV was identified with the event.
This LER is closed.
R2.1 IV. Plant Su ort Status of Radiation Protection and Chemistry Facilities and Equipment Radiation Area Controls Ins ection Sco e
71750 While on a walkdown of another system, the inspector found the cage door to the 1B Gas Decay Tank (GDT) unlocked.
Normally. the licensee maintained the GDT doors locked because of the potential for rapid and large changes in radiation levels if a tank is put in service.
The inspector questioned Health Physics and Operations abut the locking requirement ~
o
b.
Observation and Findin s
P1 Pl. 1 On March 25, the inspector found the door to the 1B GDT unlocked.
The inspector also found the door unlocked on March 3.
The room was posted as a radiation area.
Procedure HPP-3, Revision 6,
Section 7.5.9 stated:
There are locations with the potential for rapid. and significant increases in radiation levels, such as the waste gas decay tanks.
These areas should be posted and controlled as locked high radiation areas, even though at any point in time the actual dose rates may be only a few mi 1 li rem.
The inspector notified Health Physics (HP),
and when the super visor arrived they discussed the requirements for the room.
The HP supervisor pointed out that the procedure allowed access controls to be downgraded to High Radiation Area Controls if the general area radiation levels were less than 1000 mi llirem per hour and the radiation levels were not expected to change and the area is properly posted for the radiation levels present.
The supervisor stated that, Operations would inform him if they were going to place the B GDT in service.
The inspector spoke with several Senior Nuclear Plant Operators (SNPO)
about placing a
GDT in service.
All SNPOs interviewed stated that they would inform HP before placing a
GDT in service.
However, the inspector found that Procedure OP 1-0530020, Revision 31,
"Waste Gas System Operation," did not provide any direction to inform HP at any time while placing a
GDT in service or removing one from service.
This was identified as a weakness in the procedure.
The inspector learned that the key to the GDT rooms is controlled by Operations.
If a GDT room were to become a Locked High Radiation (LHR)
Area, HP would secure the door with a LHR lock.
Operations determined that the lock for the 1B GDT room was deficient and a work order was initiated.
The Assistant Nuclear Plant Supervisor stated that he would ensure that the SNPOs knew to check the door after exiting to make sure that it locked.
Conclusions The 1B GDT was properly controlled from a radiological standpoint.
The inspector identified a weakness in Procedure OP 1-0530020 in that it did not provide direction to Operations to inform HP prior to placing a Gas Decay Tank in service.
Conduct of EP Activities Gener a l Comments 82701 On March 2, the NRC issued Inf'ormation Notice 98-08,
"Information Likely To Be Requested If An Emergency Is Declared."
Although not specifically
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applicable to power reactors, the licensee's Operating Experience Feedback personnel concluded that information contained in the Information Notice would be beneficial to the EP organization.
The licensee subsequently provided training in preparation for the emergency exercise conducted on March 18.
The inspector considered this to be an example of being pro-active in the use of industry experience, particularly considering that the Information Notice did not apply to power reactors.
V. Mana ement Heetin s and Other Areas Xl Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 27.
1998.
An interim exit meeting was held on February 27, 1998 to discuss the findings of'egion based inspection.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified.
Licensee PARTIAL LIST OF PERSONS CONTACTED M. Allen, Training Manager C. Bible, Site Engineering Manager W. Bladow, Site Quality Manager D. Fadden, Services Manager R. Heroux, Business Manager H. Johnson.
Operations Manager J.
Marchese, Maintenance Manager C. Harple, Operations Supervisor 3. Scarola, St. Lucie Plant General Manager A. Stall. St. Lucie Plant Vice President E.
Weinkam. Licensing Manager Other licensee employees contacted included office, operations.
engineering, maintenance, chemistry/radiation, and corporate personnel.
IP 37551:
IP 61726:
IP 62702:
IP 62707:
IP 71707:
IP 71750:
INSPECTION PROCEDURES USED Onsite Engineering Surveillance Observations Maintenance Program Maintenance Observations Plant Operations Plant Support Activities
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IP 82701:
IP 92901:
IP 92902:
IP 92903:
IP 92904:
IP 93702:
Operational Status of the Emergency Preparedness Program Followup - Plant Operations Followup - Maintenance Followup - Engineering Followup - Plant Support Prompt Onsite Response to Events at Operating Power Reactors
~0ened ITEMS OPENED CLOSED AND DISCUSSED 50-335,389/98-03-01 50-389/98-03-02 50-335,389/98-03-03 50-335/98-03-04 50-335,389/98-03-05 Closed 50-335,389/98-03-01 50-389/98-03-02 50-335,389/98-03-03 50-335/98-03-04 50-335,389/98-03-05 NCV NCV NCV NCV NCV NCV NCV NCV NCV NCV
"Failure to Follow the Equipment Clearance Order Request Procedure" (Section 02.2).
"SIT Discharge Valves Procedurally Isolated in Mode 4 Due to Personnel Er ror During Procedural Development" (Section 08. 1).
"Failure to Operate'the Refueling Machines in Accordance With Technical Specifications" (Section 08.4).
"Failure to Adequately Sample Gas Decay Tank Oxygen Levels When the Waste Gas Analyzer Failed" (Section M8.1).
"Failure to Fully Test Emergency Bus Undervoltage (Degraded Voltage) Contacts" (Section E8.6).
"Failure to Follow the Equipment Clearance Order Request Procedure" (Section 02.2).
"SIT Discharge Valves Procedurally Isolated in Mode 4 Due to Personnel Error During Procedural Development" (Section 08. 1).
"Failure to Operate the Refueling Machines in Accordance With Technical Specifications" (Section 08.4).
"Failure to Adequately Sample Gas Decay Tank Oxygen Levels When the Waste Gas Analyzer Failed" (Section M8.1).
"Failure to Fully Test Emergency Bus Undervoltage (Degraded Voltage) Contacts" (Section E8.6).
50-389/96-003-00 50-335/EA-96-040/01013 50-335/EA-96-040/01023 50-335/EA-96-040/01033 50-335/97-001-00 50-335,389/97-01-02 50-335/97-004-00 50-335/97-005-00 50-335/96-011-01 50-335/96-010-00 50-335/96-016-00 50-389/EA-96-236/01013 50-335/EA-96-249/03014 50-389/97-002-00 LER VIO VIO VIO LER VIO LER LER LER LER LER VIO VIO LER
"Safety Injection Tanks Valves Procedurally Isolated in Mode 4 Due to Personnel Error" (Section 08.1).
"Operators Failed to Follow Procedures for Boron Dilution, Watch Turnover.
Procedure Adherence, and Event Reporting" (Section 08.2).
"Inadequate Design Control of Reactor Coolant System Boron Dilution Procedure" (Section 08.2)
"Inadequate
CFR 50.59 Safety Evaluation of Change to Boron Dilution Procedure" (Section 08.2).
"Operation Prohibited by Technical Specifications Due to Deficiencies in the Program for Post Accident Sampling" (Section 08.3)
"Programmatic Breakdown oi Post-Accident Sampling Capability" (Section 08.3).
"Operation of a Refueling Machine in a Manner Prohibited by Technical Specifications" (Section 08.4).
"Reactor Shutdown Required by Technical Specifications Due to Reactor Coolant Pressure Boundary Leakage" (Section 08.5).
"Operation Prohibited by Technical Specifications Due to Failure of Oxygen Analyzer" (Section M8. 1).
"Operation Prohibited by Technical Specifications Due to Linear Range Nuclear Instrumentation Out of Service" (Section E8.1).
"Insufficient Testing and Maintenance on 125 VDC Bus Cross-tie Breakers" (Section E8.2).
"Unreviewed Safety Question Involving EDG 2B" (Section E8.3).
"Failure to Update Drawings Following Plant Modification" (Section E8.4).
"Containment Sump Debris Screen Not in Accordance With Design Due to Gaps in the Screen Enclosure" (Section E8.5).
p
~ I ry
I
~ ~l 50-335/97-006-00 Discussed
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LER
"Operations Prohibited by Technical Specifications Due to Inadequately Tested Degraded Voltage System" (Section E8.6).
50-335,389/96-08-05 URI 50-335/EA-96-457/03013 VIO 50-389/EA-97-329/01014 VIO 50-389/EA-97-329/02014, VIO
"Licensee Identified 11 UFSAR Deficiencies" (Section 08.2).
\\
"Failure to Control the Design Process According to 10 CFR 50" (Section E8.1).
"Failure to Properly Construct U2 Containment ECCS Sumps",
(Section E8.5).
"Failure to Promptly Identify and Correct U2 Containment Sump Deficiencies" (Section E8.5).
CCW CFR CR DPR EA ECCS ECO EDG ENG ESFAS FME FPL FR GDT GL HP HPP HPSI HVE HX IEcC IP IR LER LHR LPSI LIST OF ACRONYMS USED Administrati ve Procedure Auxiliary Feedwater (system)
Assistant Nuclear Plant Supervisor Administrative Procedure Attention Component Cooling Water Code of Federal Regulations Condition Report Demonstration Power Reactor (A type of operating license)
Enforcement Action Emergency Core Cooling System Equipment Clearance Order Emergency Diesel Generator Engineering Engineered Safety Feature Actuation System Foreign Material Exclusion The Florida Power 8 Light Company Federal Regulation Gas Decay Tank
[NRC3 Generic Letter Health Physics Health Physics Procedure High Pressure Safety Injection (system)
Heating and Ventilating Exhaust (fan, system, etc.)
Heat Exchanger Instrumentation and Control Inspection Procedure LNRC3 Inspection Report Licensee Event Report Locked High Radiation Low Pressure Safety Injection (system)
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M&TE MFIV HOV NaOH NCV NLO No.
NOP NPF NPS NRC PASS PDR PH PMAI PMT psia PSL QC QI RCO RCP RCS RE RWT.
SIAS SIT SNPO TEDB TS UFSAR URI USNRC VDC VIO WCC WCG WO
Measuring 8 Test Equipment Hain Feed Isolation Valve Motor Operated Valve Sodium Hydroxide NonCited Violation (of NRC requirements)
Non-Licensed Operator Number Normal Operating Pressure Nuclear Production Facility (a type of operating license)
Nuclear Plant Supervisor Nuclear Regulatory Commission Post Accident Sampling System NRC Public Document Room Preventive Maintenance Plant Management Action Item Post Maintenance Test Pounds per square inch (absolute)
Plant St. Lucie Quality Control Quality Instruction Reactor Control Operator Reactor Coolant Pump Reactor Coolant System Reactor Engineering Refueling Water Tank Safety Injection Actuation System Safety Injection Tank Senior Nuclear Plant [unlicensed] Operator Total Equipment Data Base Technical Specification(s)
Updated Final Safety Analysis Report
[NRC] Unresolved Item United States Nuclear Regulatory Commission Volts Direct Current Violation (of NRC requirements)
Work Control Center Work Control Guideline Work Order