IR 05000341/1999003
| ML20205T395 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/23/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205T387 | List: |
| References | |
| 50-341-99-03, 50-341-99-3, NUDOCS 9904270244 | |
| Download: ML20205T395 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION
i REGION lll Docket No:
'50-341 License No:
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Report No:
50-341/99003(DRP)
Licensee:
Detroit Edison Company Facility:
Enrico Fermi, Unit 2 Location:
6400 N. Dixie Hwy.
Newport, MI 48166 Dates:
February 18 through April 1,1999 Inspectors:
S. Campbell, Senior Resident inspector J. Larizza, Resident inspector Approved by:
Anton Vegel, Chief Reactor Projects Branch 6 Division of Reactor Projects 9904270244 990423 PDR ADOCK 05000341
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EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC Inspection Report 50-341/99003(DRP)
This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6-week period of inspection activities by the resident staff.
Operations
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Two separate instances occurred where operator performance of routine activities was
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not appropriate. First, an operator did not follow an emergency diesel generator test procedure sequence which caused the emergency diesel generator output breaker to trip open due to a reverse power condition. Second, inattention-to-detail, unfamiliarity with the job assignment, the lack of a peer review, and failure to self check by an operator resulted in the improper operation of the centrifuge feed tank agitator and caused an inadvertent transfer of radioactive resins. Two examples of a non-cited violation were identified. (Section O1.3)
Ineffective communication between the control room operators and radiation protection
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personnel following the inadvertent transfer of radioactive resins to the waste clarifier tank resulted in the failure to survey the waste clarifier tank room. Consequently, a maintenance worker and a health physics technician received a small unexpected dose when the room was subsequently entered for maintenance activities. (Section O1.3)
The inspectors concluded that out-of-service main control room annunciator alarm
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windows were properly evaluated, marked and tracked per procedure. Control Room personnel were aware of out-of-service alarms, and as necessary, compensatory measures were in place for the loss of alarm function. (Section O2.2)
Although the out-of-service annunciators were properly tracked in the main control room,
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the licensee was not effective in maintaining the configuration of the annunciators in the training simulator consistent with the main control room. (Section O2.2)
Operator response to the increase in the off-gas radiation levels was prompt and
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appropriate. (Section E1.1)
Maintenance The laspectors concluded that the observed maintenance and surveillance testing
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activities were conducted in a thorough, professional manner. The inspectors observed supervisors and system engineers supporting and monitoring the activities in progress.
The inspectors also noted that appropriate radiation control measures were implemented and all of the maintenance activities were performed with the work package present and in use. (Section M1.1)
. The licensee lacked rigor while determining the initial work scope for a scheduled down
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power. Although the licensee followed their process for the addition of work, the change to the scheduled activities, the day before the power decrease, created a short lead time
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for radiation protection personnel to assess dose goals and perform the necessary surveys. (Section M1.2)
The inspectors concluded that improperly performed maintenance restoration activities
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resulted in the grounding straps on three safety-related motor operated valves not being reconnected. The inspectors also determined that the disconnected grounding straps did not impact the ability of the valves to operate. (Section M1.3)
The licensee failed to implement effective corrective action to preclude the repetition of
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inadvertent repositioning of safety-related equipment due to accidental bumping. A non-cited violation was identified. (Section M7.1)
Enaineerina Engineering personnel provided good support during the plant down power and during
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surveillance testing. (Section M1.2).
Engineering personnel coordinated well with the fuel vendor to determine that no fuel
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failure had occurred following the increase in the off-gas radiation levels. (Section E1.1)
Plant Suooort l
Immediate personnel response to an inadvertent transfer of radioactive resins and
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subsequent elevated radiation level in the radwaste basement was prompt and appropriate. (Section 01.3)
Radiation protection personnel provided effective oversight during the scram solenoid
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pilot valve replacement activities. (Section M1.2)
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Report Details Summary of Plant Status Unit 2 began this inspection penod at 97 percent power. On February 19,1999, the licensee reduced power level to 61 percent in order to perform maintenance and surveillance testing activities on safety-related and balance-of-plant equipment. On F:.'>ruary 21,1999, the licensee retumed power level to 97 percent and operated the unit at or near 97 percent power level throughout the remainder of the inspection period.
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l. Operations
Conduct of Operations 01.1 Failure to Follow Procedure Seouence Causes Emeroency Diesel Generator Outout Breaker to Trio on Reverse Power a.
Insoection Scope (71707)
On February 18,1999, the output breaker for emergency diesel generator (EDG) 13 unexpectedly opened when a reverse power condition occurred on the electrical bus during surveillance testing. The inspectors interviewed individuals involved in the test and reviewed Surveillance Procedure 24.307.16, "EDG 13 - Load Start Test," General Conduct Manual 03, " Procedure Use and Adherence," and Condition Assessment Resolution Document (CARD) 99-11755, which was initiated to document the occurrence and track corrective actions.
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Observations and Findinas Based on independent inspector and licensee interviews, the inspectors determined that an operator did not sequentially perform the steps contained in Surveillance Procedure 24.307.16, Section 5.1.24, to synchronize and manually load EDG 13.
Specifically, the operator closed the EDG output breaker in accordance with Step 5.1.24.4. Prior to increasing load on the EDG, the operator noted that the kilovolts amperage reactive (KVARs) were too high, deviated from the procedure sequence, and performed Step 5.1.24.6 to reduce KVARs. Consequently, the operator did not perform Step 5.1.24.5 to increase load immediately after closing the breaker. As a result, a reverse power condition occurred and the output breaker tripped open. This sequence
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of events occurred too quicidy for the peer reviewer to intervene and prevent the error.
The licensee subsequently reset the trip relay and inspected the breaker for damage.
No damage was found and the surveillance test was completed successfully. The licensee's corrective actions for this event also included counseling the involved operator and adding the issue to CARD 99-11177, which addressed recent adverse trends in operator performance.
Technical Specification (TS) 6.8.1.a states that written procedures shall be established, implemented, and maintained for procedures recommended in Appendix A, of
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Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies procedure adherence as an example of an administrative procedure. General Conduct Manual 03, " Procedure Use and Adherence," Revision 8, Step 4.1.1.2, requires that continuous use procedures be performed as written in the sequence given. Surveillance Procedure 24.307.16, l
"EDG 13 - Load Start Test," Revision 38, which was a continuous use procedure, required that the steps in Section 5.1.24 be performed in sequence to synchronize and manually load the EDG. The failure to perform Surveillance Procedure 24.307.16, Section 5.1.24, in sequence to synchronize and manually load EDG 13 is a violation of TS 6.8.1.a. This Severity Level IV violation is being treated as an exarnple of a Non-Cited violation (NCV), consistent with Appendix C of the NRC Enforcement Policy (NCV 50-341/99003-01a(DRP)). This violation is in the licensee's corrective action program as CARDS 99-11755 and 99-11177.
01.2 Operator Error Causes Unax=4ad Radioactive Resin Transfer to the Waste Clarifier i
Tank (WCT)
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Inspection Scope (71707)
On February 18,1999, while decanting the centrifuge feed tank per Procedure 23.701.14, " Operation of the Centrifuge Feed Tank," Revision 6, the radwaste operator inappropriately started the agitator (stirring the resin) and later started the
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pump. This caused a radioactive slurry of resins to be sent through piping to the WCT that changed radiological conditions in the radwaste basement. The inspectors interviewed the involved personnel and reviewed the procedure, dose records, radiation surveys and CARD 99-10688, which was initiated to document the occurrence and track corrective actions.
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Observations and Findinos During the event, two individuals exited the radwaste basement hallway after increasing radiation levels caused an area radiaticn monitor, with a 1 millirem per hour setpoint, to aiarm. The readings from the personal dosimeters for these individuals did not indicate exposure from this event. After receiving radiation alarms in the control room, perations personnel notified the radwaste operator of the alarm and the radwaste operator stopped the evolution. Also, in response to the alarms, health physics (HP) technicians surveyed the radwaste basement hallway and found radiation levels of 0.4 millirem per hour and determined the area was acceptable for access. However, since the control room operators were not clear in communicating with radiation protection personnel regarding the decanting evolution, the WCT room was not re-surveyed.
Subsequently, the HP supervisor granted permission for maintenance and HP personnel to enter the WCT room to perform the previously scheduled work activity of replacing
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prefilters and the top gasket on a spent resin tank. After entering the room, the HP j
technician's radiation detector indicated a sudden increase in area radiation levels and i
the maintenance worker's electronic dosimeter alarmed simultaneously. Both individuals exited the room in response to the alarm. The dose received by the worker and the HP technician were 20 and 10 millirem, respectively. The licensee surveyed the WCT and found radiation levels up to 5 rem per hour on contact with the WCT. The licensee
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subsequently posted the area as a locked high radiation area until system and piping flushes were completed to reduce the radiation levels.
During the subsequent investigation into the event, the licensee determined that the radweste operator failed to follow Procedure 23.701.14, when he inappropriately started the agitator and not the pump. After starting the agitator, he did not see the expected changes in parameters (tank level, flow and pressure) following a presumed pump start and did not recheck the steps he had performed. Consequently, he failed to recognize that the agitator was running and then started the pump, which compounded the problem.
Through interviews, t' he inspectors and licensee identified the causal factors that lead to the improper operation of the centrifuge feed tank agitator. The radwaste operator was unfamiliar with the evolution because he had not been assigned to the radwaste control room in 3 years. Also, an additional radwaste operator had been assigned previously to serve, among other things, as a peer reviewer for radwaste evolutions, but this position
was abolished in November 1998. However, the radwaste operator contacted the tagout center to obtain a peer reviewer, but an operator was unavailable due to resources
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needed to perform the EDG 13 surveillance. Further, the equipment nomenclature in the
procedure was not identical to the equipment label plates on the radwaste control panel.
I Finally, during the evolution, he was distracted with other radwaste operator duties.
The licensee's corrective actions for this event included:
counseling the individual,
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tagging all keys to high radiation aream in the radwaste basement to notify the
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radwaste control roam before issuing the keys, discussing the event during HP turnover,
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assessing other areas of the plant or planned evolutions where unexpected e
radiological conditions could occur and determine if radiological controls were
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adequate, and reviewing jobs where human error or mechanical failure could create substantial
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changes in radiological conditions.
Technical Specification (TS) 6.8.1.a states that written procedures shall be established, implemented, and maintained for procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies procedure adherence as an example of an administrative procedure. General Conduct Manual 03, " Procedure Use and Adherence," Revision 8, Step 5.1, establishes a policy of following procedures and self checking each step. The radwaste operator's failure to implement Procedure 23.701.14,
" Operation of the Centrifuge Feed Tank," Revision 6, Section 4.2.4, by starting the centnfuge feed tank agitator rather than the pump, which resulted in a radioactive resin slurry being sent through piping in the radwaste building that caused changes in radiological conditions and unexpected exposure to individuals, is a violation of TS 6.8.1.a. This Severity Level IV violation is being treated as an example of an NCV, consistent with Appendix C of the NRC Enforcement Policy (NCV 50-341/99003-01b(DRP)). This violation is in the licensee's corrective action program as CARDS 99-10688 and 99-11177.
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O1.3 Conclusions for Conduct of Operations Two separate instances occurred where operator performance of routine activities was not appropriate. First, an operator did not follow an emergency diesel generator test procedure sequence which caused the emergency diesel generator output breaker to trip open due to a reverse power condition. Second, inattention-to-detail, unfamiliarity with the job assignment, the lack of a peer review, and failure to self check by an operator resulted in the improper operation of the centrifuge feed tank agitator and caused an
- inadvertent transfer of radioactive resins. Two examples of a non-cited violation were identified.
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immediate personnel response to an inadvertent transfer of radioactive resins and subsequent elevated radiation level in the radwaste basement was prompt and appropriate.
Ineffective communication between the control room operators and radiation protection personnel following the inadvertent transfer of radioactive resins to the waste clarifier tank resulted in the failure to survey the waste clarifier tank room. Consequently, a maintenance worker and a health physics technician received a small unexpected dose when the room was subsequently entered for maintenance activities.
Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature System Walkdowns (71707)
The inspectors used Inspection Procedure 71707 to walk down accessible portions of thy following engineered safety feature systems.
High Pressure Coolant injection (HPCI) System
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Low Pressure Coolant injection System
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EDGs 11,12,13 and 14
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Divisions 1 and 2 Motor Control Centers (MCCs)
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Radwaste Control Room
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Control Room
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The inspectors noted that equipment operability, material condition, and housekeeping were acceptable in all cases. The inspectors and licensee identified several minor discrepancies which the licensee properly documented in the corrective action system.
j The inspectors identified no substantive concerns as a result of these walkdowns.
02.2 Review of Defeated Main Control Room (MCR) Annunciator Alarm Windows
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Insoection Scope (71707)
On March 17,1999, the inspectors reviewed the following documents to verify that affected MCR annunciator alarm windows were properly placed out-of-service:
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Procedure 23.621, "MCR Annunciator and Sequence Recorder,"
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Alarm Defeat Log index,
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Report of Defeated Alarms for Ten Currently Out-of-Service MCR Annunciators,
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Control Room Information System Dot Report,
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Jumper Control Log,
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Associated Work Requests (WRs),
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Associated CARDS, and
Nuclear Training Conduct Manual, Chapter 9, " Control Room Simulator Controls."
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Observations and Findinos The inspectors verified that an " Alarm Defeated" marker had been installed on each affected MCR annunciator alarm window, and that a control room information system dot had been installed properly. Out-of-service alarms were appropriately evaluated for impact and their status was tracked in the alarm defeat log index. However, the inspectors identified inconsistencies with the status of out-of-service alarms between the
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MCR and the training simulator. Specifically, three alarms were treated as being out-of-service on the training simulator, two of which were different than the ten alarms that were out-of-service in the MCR. The inspectors discussed these discrepancies with training and operations personnel. After these discussions, training personnel promptly updated the simulator to reflect the status of the MCR annunciator panels. In addition, operations staff personnel stated that simulator fidelity is an ongoing effort and discussions will be conducted on improving tienely updates to the simulator annunciator panels.
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Conclusions The inspectors concluded that the out-of-service MCR annunciator alarm windows were properly evaluated, marked and tracked per procedure. Control Room personnel were aware of the out-of-service alarms, and as necessary, compensatory measures were in place for the loss of alarm function. Although the out-of-service annunciators were properly tracked in the main control room, the licensee was not effective in maintaining the con 5guration of the annunciators in the training simulator consistent with the main control room.
Miscellaneous Operations issues (92901)
08.1 (Closed) Unresolved item (URl) 50-341/97003-08 Operational Safety Review Organization (OSRO) effectiveness in performing special reviews. The inspectors observed that the OSRO quorum did not actively probe the issue involving grease hardening on the MCC disconnect switches and associated corrective actions. In response to this observation, the OSRO members indicated that these reviews were premature and an in-line review instead of an oversight function was conducted.
Nevertheless, the associated corrective action for this observation included a lessons learned meeting with OSRO members that was completed on October 2,1997. The inspectors concluded that no violations of regulatory requirements occurred. This unresolved item is closed
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11. Maintenance J
M1 Conduct of Maintenance M1.1 General Comments (62707)
The inspectors observed all or portions of the following work and surveillance testing activities:
Replace Scram Solenoid Pilot Valves (SSPVs),
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Procedure 54.000 03, " Control Rod Scram insert Time Test,"
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Procedure 24.109.02, " Turbine Bypass Valve Operability Test,"
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Procedure TUO8, " Low Pressure incept Valve and Stop Valve Performance
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Monitoring," and WR 000Z990232, " Leak Repair on Reheater Seal Tank Level Transmitters."
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The inspectors concluded that the observed maintenance and surveillance testing activities were conducted in a thorough, professional manner. The inspectors observed supervisors and system engineers supporting and monitoring the activitiec in progress.
The inspectors also noted that appropriate radiation control measures were implemented and all of the maintenance activities were performed with the work package present and in use.
M1.2 Surveillance Observation of SSPVs Seouence Outaae
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Inspection Scope (62707)
On February 19,1999, reactor power level was reduced from 97 to 61 percent to perform the following:
SSPV replacement on 30 control rod drives,
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scram timing on 19 control rods,
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turbine bypass valve surveillance testing,
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high pressure turbine contral and stop valve functional test,
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Iow pressure turbine int <rcept and stop valve performance test, i
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troubleshooting of alarms associated with the No. 2 high pressure turbine control
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valve, maintenance WRs involving tim condenser pump motor bearing oil sample, o
leak repairs on various reheater valves, and e
control rod pattern adjustment.
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The inspectors observed the pre-job brief and selected portions of the maintenance and surveillance testing activities. The inspectors also discussed pertinent observations with plant management.
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Observations and Findinos Before the down power, the licensee changed the scheduled maintenance activities to include an inspection of the balance of plant systems for mega-watt losses. This
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included eliminating and/or prohibiting other work activities. Although the licensee knew of this inspection weeks in advance, the licensee used the work addition process to add this inspection the day before the plant down power. As a result, concems were raised in the management meeting regarding the short lead time for the radiation protection department to prepare for this inspection (i.e., assessing dose goals and performing surveys). The inspectors noted that radiation personnel subsequently adjusted the dose goals and performed the necessary surveys.
Operators decreased power to prepare for the turbine bypass valve test. The pre-job brief for the turbine bypass valve test was thorough and included the applicable precautions and limitations associated with the test. The crew discussed the experience with prior surveillance tests and the contingency actions associated with potential abnormal conditions. The inspectors also noted that reactor engineers participated in the pre-job brief.
During the turbine bypass valve and control rod scram time testing, the inspectors noted effective self checking and three-way communication. No significant problems were encountered during the testing.
The inspectors observed mechanics replace the SSPVs. Overall, coordination of the activity was acceptable. Operations and radiation protection personnel provided effective support during the maintenance activity.
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Conclusions The licensee lacked rigor while determining the initial work scope for the scheduled down power. Although the licensee followed their process for the addition of work, the change to the scheduled activities, the day before the power decrease, created a short lead time for radiation protection personnel to assess dose goals and perform the necessary surveys. The inspectors also noted that engineering personnel provided good support during the plant down power and during surveillance testing. In addition, radiation protection personnel provided effective oversight during the scram solenoid pilot valve replacement activities.
M1.3 Inadeauste Maintenance Restoration of Motor Ooerated Valves (MOVs)
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Insmx: tion Scope (71707)
On February 22,1999, the inspectors identified a disconnected grounding strap on the MOV for the division 2 core spray pump minimum flow valve, E2150F031B. After the inspector notified the licensee, the licensee identified loose and disconnected grounding straps on the MOVs for the reactor core isolation cooling system vacuum pump discharge isolation valve, E5150F002, and the HPCI condensate storage tank (CST)
suction isolation valve, E4150F004, respectively. These deficiencies were documented in CARD 99-11813. The inspectors reviewed the Institute of Electrical and Electronics Engineers' Standard 1980, " Guide for Safety in Substation Grounding," recent WRs associated with these valves, and interviewed electrical maintenance -supervision to determine impact on valve operability and the cause of the condition.
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Observations and Findinas Grounding straps were installed per the guidelines of the institute of Electrical and Electronics Engineers' star.dard for personnel protection. The disconnected and/or loose straps did not impact the function of the valves. The inspectors interviewed electrical personnel and determined that the grounding straps were disconnected to facilitate the removal of the motor operator and that the electricians knew to document the disconnection and the subsequent reconnection of the grounding straps during maintenance activities. The inspectors reviewed the WRs that provided instructions to remove the motor operators and determined that the WRs provided the proper guidance for these actions. The inspectors also determined that the grounding straps had not been reconnected during previous maintenance activities associated with these valves.
This failure constitutes a violation of minor significance and is not subject to formal enforcement action.
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Conclusions The inspectors concluded that improperly performed maintenance restoration activities resulted in the grounding straps on three safety-related motor operated valves not being reconnected. The inspectors also determined that the disconnected grounding straps did not impact the ability of the valves to operate.
M7 Quality Assurance in Maintenance Activities M7.1 Corrective Actions for Lockina MCC Switches not Implemented a.
Insoection Scooe (71707)
On February 16,1999, during security guard tours, a guard's rifle accidentally bumped (without his knowledge) the MCC rotary switch to the fan motor for the division 1 standby gas treatment system (SGTS) room cooler, which shutoff the fan motor. As a result, the licensee initiated CARD 99-11725 to document the occurrence and track corrective actions. The inspectors reviewed the following documents to assess the licensee's implementation of corrective actions regarding this issue:
CARD 99-11725, "MCC Switch 72C-2A-1CR for the Division 1 SGTS Found in
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Open Position,"
CARD 99-11578, " Review of Effectiveness of Corrective Actions to Prevent
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Accidental Opening of Rotary MCC Switches,"
CARD 97-05147, "MCC Switch 72C-2A-1CR for the Division 1 SGTS Found in
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Mid-Position,"
CARD 97-11980, " Officer inadvertently Opens MCC Switch for the Torus Makeup
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Valve," and Procedure 23.300.00, * Breaker Operations."
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Observations and Findinas During their investigation into this event, the licensee identified similar events that occurred on October 1,1997 and November 21,1997, which were documented in
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CARDS 97-05147 and 97-11980, respectively. The corrective action for CARD 97-05147 was to modify the affected switch so a metal tab could be slid into a notch to latch and lock the switch in the "on" position. However, the scope of this modification was expanded to include all switches on MCCs after the MCC switch for the torus makeup valve was accidentally bumped (CARD 97-11980).
During Refueling Outage (RFO) 6, conducted in October 1998, the licensee's implementation of these corrective actions was suspended and delayed after an electrician was bumed. Nevertheless, several MCC switches were modified prior to the end of RFO 6. However, the licensee did not revise Procedure 23.300,'" Breaker Operations," to provide instructions to lock the modified switches until December 1998.
Also, maintenance procedures did not include instructions to lock the modified switches.
Consequently, some of the modified switches were never locked. As a result, the licensee inspected and locked all of the modified MCC switches.
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The failure to implement timely and effective corrective action to preclude the repetition of inadvertent repositioning of safety-related equipment due to accdental bumping, a significant condition adverse to quality due to the potential to inadvertently render safety-related equipment inoperable, is a violation of 10 CFR Part 50, Appendix B, Criteria XVI. This Severity Level IV violation is being treated as an NCV, consistent with Appendix C of the NRC Enforcement Policy (50-341/99003-02(DRP)). This violation is in the licensee's corrective action program as CARD 99-11725.
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Conclusions The licensee failed to implement effective corrective action to preclude the repetition of inadvertent repositioning of safety-related equipment due to accidental bumping. A non-cited violation was identified.
M8 Miscellaneous Maintenance issues (92700 and 92902)
M8.1 Closure of Severity Level IV Violations The Severity Level IV violations listed below were issued in Notices of Violation prior to the March 11,1999, implementation of the NRC's new policy for treatment of Severity Level IV violations (Appendix C of the Enforcement Policy). Because these violations would have been treated as NCVs in accordance with Appendix C, they are being closed out in this report.
Violation 50-341/96016-05 This violation is in the licensee's corrective action
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program as Deviation Event Report 96-1875.
Violation 50-341/96016-08 This violation is in the licensee's corrective action
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program as Deviation Event Report 96-1886.
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i M8.2 (Closed) Licensee Event Report (LER) 50-341/96023-00: " Technical Specification Required Shutdown - Drywell to Suppression Chamber Vacuum Breaker Failed to Indicate Closed." The licensee conducted a plant shutdown because the suppression chamber vacuum breaker failed to indicate closed after several attempts to close the breaker. The licensee subsequently concluded that a maintenance procedure contained insufficient detail to address the particular design characteristics of the vacuum breaker magnet asmmbly. Thh issue was discussed in NRC Inspection Report 50-341/96016 and viok-tiv" 50-341/96016-05 was cited. This LER is closed.
M8.3 (Closed) LER 50-341/97002-00: " Failure of High Pressure Coolant inje~ction Systam Pump Discharge Valve to Open." A worn setscrew caused the HPCI pump discharge volve, E4150-F006, to not open on demand during surveillance testing conducted on Fobru wy 16,1997. Prior to this event, the manufacturer had identified similar failures in 1989 and issued Maintenance Letter 89-01 recommending that the motor shaft be spot drilled to ensure adequate set of the setscrew. When the licensee received the letter, no formal evaluation of the letter was conducted. However, the licensee decided to implement the maintenance letter recommendations on an "as available basis," which delayed the necessary colective actions to prevent this occurrence. This issue was discussed in NRC Inspection Reports 50-341/97002 and 50-341/97003 and a corrective action violation, EA 97-201, was cited. This LER is closed.
M8.4 (Ooen) URI 50-341/97013-04: Use of a pipe sealant compound in pneumatic systems.
The solenoid operated valves (SOV) for divisions 1 and 2 primary containment pneumatics nitrogen supply isolation valves, T4901F466 and T4901F468, had a slight deposit of the pipe sealant on the end of the solenoid core. The presence of the compound caused valve sticking and stroke times above the allowed acceptance criteria.
The licensee initiated Deviation Event Reports 97-1200 and 97-1202 to address the slow stoke times and the potential SOV deficiencies.
' The licensee reviewed previous stroke time data of similar valves and found three additicnal failures caused by the presence of the pipe sealant. The excessive use of the compound, while performing maintenance on pipe threaded connections, caused this condition. The licensee identified that a lack of clear guidance on the use of lubricants and sealants in maintenance procedures contributed to the deficiency. Corrective actions included using graph c4 tape in lieu of pipe seelant compotnd. Fudher, 52 SOVs covered under the maintenance rule were replaced in ;ystems and ihe solenoids were sent to a laboratory for analysis. To date, approximately 30 SOVs have bsea tested and did not indicate the presence of the ei npound. This unresolved item will remain open pending the licensee's completion of ksting and analysis of the solenoid operated valves.
M8.6 (Closed) Insoection Followuo item (IFI) 50-341/96016-04: Protecting equipment inside containment from damage. Safety Relief Valve D failed to open during testing because
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of a bent solenoid plunger, which had been stepped on during work in the drywell. The inspectors and the licensee noted several similar occurrences where drywell equipment had beers stepped on and damaged, in response, the licensee initiated Deviation Event Report 97-0809 to address this issue. The licensee's corrective Actions for this issue included
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incorporating recent experience of damaged drywell equipment and plant impact
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into SH-GN-502-0300-001, " Plant Access Training Requalification Update,"
revising Maintenance Department Instruction 002, ' Pre-job Briefing," to include a
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precaution statement regarding stepping on equipment in the drywell, creating waming signs, posted throughout the plant, to avoid stepping on e
equipment, and emphasizing during shop meetings to avoid stepping on drywell equipment.
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The inspectors verified the corrective actions have been completed. This inspection follow-un item is closed.
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M8.7 (Closed) URI 50-341/96016-06: Condensate Storage Tank instrument cabinet not locked per Updated Final Safety Analysis Report (UFSAR) requirement. The UFSAR, Section 7.4.1.13.8, required that the CST instrument cabinet remain locked when not attended. In response to this finding, the licensee revised the UFSAR to remove the locking requirement. The inspectors verified that these corrective actions were completed.
10 CFR 50.71(e) states, in part, that the licensee shall update periodically the UFSAR, to assure that the information included contains the latest changes made in the facility or procedures as described in the UFSAR. Contrary to the above, before November 12,1996, the licensee failed to update the UFSAR to eliminate the requirement of locking the CST instrument cabinets. This violation is of minor significance and is not subject to formal enforcement action. This unresolved item is closed.
III. Engineerina E1 Conduct of Engineering E1.1 Enaineerina Response to itecent Off-Gas Radiation Monitor increase a.
Insoection Ocooe (37551)
On February 26,1999, the licensee detected an increase in the off-gas radiation monitor readings. The inspectors interviewed personnel involved, reviewed applicable procedures and documentation and, evaluated the licensee's response a this condition.
b.
Observation and Findinos Operators notified chemistry department personnel of the increase in the off-gas
i radiation levels and requested that samples be taken. The subsequent chemistry sang,les revealed a slight increase in Xe-133 nuclides. The operators also contacted reactor engineering who worked with the fuel vendor to evaluate the condition. Based on
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the Xe-133 concentrations and the Xe-138/133 ratio, the licensee determined that no fuel failure had occurred.
In the previous operating cycle, two fuel assemblies had exhibited leakage. The licensee subsequently removed those two bundles during the October 1997 mid-cycle outage.
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While the leaking bundles have been removed, engineering personnel attributed the increase in Xe-133 concentrations to the reactor down power on February 19,1999, which caused the Xe-133 residue from the previous leaHng bundles to plate out from inside the core. The activity level, which has since decreased, was below plant administrative limits. As a result of this occurrence, the licensee initiated CARD 99-11850 to document the occurrence and track corrective actions.
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Conclusions Operator response to the increase in the off-gas radiation levels was prompt and
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appropriate. In addition, engineering personnel coordinated well with the fuel vendor to determine that no fuel failure had occurred following the increase in the off-gas radiation levels.
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E8 Miecollaneous Engineering issues (92903)
E8.1 Closure of Severity Level IV Violations j
The Severity Level IV violations listed below were issued in Notices of Violation prior to the March 11,1999, implementation of the NRC's new policy for treatment of Severity Level IV violations (Appendix C of the Enforcement Policy). Because these violations would have been treated as NCVs in accordance with Appendix C, they are being closed out in this report.
Violation 50-341/96010-14 This violation is in the licensee's corrective action
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program as Deviation Event Report 96-1365.
Violation 50-341/96010-15 This violation is in the licensee's corrective action
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program as Deviation Event Report 96-1139.
E8.2 (Closed) IFl 50-341/96006-04: Residual heat removal reservoir service water valves not in the inservice testing (IST) program. Originally, these valves were considered not to have a safety function and were excluded from the program per Paragraph IWV-1200(a)
of the 1980 edition, Winter Addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI. However, Generic Letter 89-04,
" Guidance on Developing Acceptable IST Programs," and NUREG-1482, " Guidelines for
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IST at Nuclear Power Plants," specified such valves to be in the IST program. During the review of these documents, the licensee again determined that the valves should not be in the IST program. However, due to the inspectors' observation and after another review of the NUREG and the Generic Letter, the licensee decided to include these valves into the IST program as an enhancement. The inspectors reviewed procedures, relief requests and surveillance test data and verified that the valves were appropriately placed in the IST program.
E8.3 (Closed) URI 50-341/97010-06: Discrepancy between licensee's Special Nuclear Material License 1097 for criticality monitoring exemption and the operating license. The licensee's special nuclear material license was exempt from tne criticality monitoring requirement of 10 CFR 70.24, but this exemption was not included in the licensee's operating license.
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Since the operating license did not mention the exemption, the licensee implemented the following corrective actions:
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obtaining the appropriate criticality instrumentation,
modifying fuel handling procedures, and
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submitting a license amendment.
a The exemption request from 10 CFR 70.24 was submitted by the licensee on April 27,1998, and the NRC issued an operating license amendment on June 2,1998.
The inspectors concluded that no violations of regulatory requirements becurred. This unresolved item is closed.
1% Ph.at Support
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R1 Radiological Protection and Chemistry Controls R1.1 Comment on Radioloaical Controls (71750)
During tours of the auxiliary and reactor buildings, the inspectors no;ed effective use of radiological controls. The inspectors observed personnel entering and exiting the radiological controlled areas, the control room, the tagout center and the radwaste control room using proper frisking techniques. The inspectors also noted that rope barriers and step-off pads were properly installed and the licensee used proper radiological work practices during maintenance act;vities.
V. Manacement Meetinas
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X1 Exit Meeting Summary The inspectors presentee the inspection results to members of licensee management at the conclusion of the inspection on April 1,1999. The licensee acknowledged the findings preserited. The inspectors asked the licensee whether any mcterials examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED i
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Licensee i
S. Booker, Superintendent,' Maintenance
. D. Cobb, Superintendent, Maintenance
. J.' Davis, Director, Nuclear Training
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R. DeLong, Superintendent, System Engineering i
R. Eberhardt, Superintendent, Outage Management
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P. Fessler, Assistant Vice-President, Nuclear Production
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R. Gaston, Supervisor, Compliance K. Harsley, Engineer, Licensing.
H. Hi';9 ns, Nuclear Shift Supervisor, Operations i
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K. H!naty, Superintendent, Operations S. Hsieh, Supervisor, Nuclear Fuel
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J. Hughes, Nuclear Quality Assurance E. Kokosky, Radiatior Protection P. Lynch, Nuclear Shift Supervisor, Operations B. O'Connor, Assistant Vice-President, Nuclear Assessment J. Pendergast, Principal Engineer, Licensing N. Peterson, Director, Nuclear Licensing J. Plona, Manager, Engineering / Technical l
S. Stasek, Supervisor, independent Safety Engineering Group J. Tibal, Principal Engineer, Performance Engineering NBC
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S. Campbell, Senior Resident inspector G. Larizza, Resident inspector A. Vegel, Chief, Reactor Projects Branch 6, Region lli l
lNSPECTION PROCEDURES USED j
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IP 37751: Onsite Engineering
- IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities
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IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Raactor Facilities IP 92901: Follow-up Plant Operations l
lP 92902: Follow-up Maintmance l.
IP 92903: Follow-up Engi. 2 Ang
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ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-341/99003-01a NCV Failure to implement Procedure 24.307.16 50-341/99003-01b NCV Failure to implement Procedure 23.701.14
- 50-341/99003-02 NCV Failure to implement Timely and Effective Corrective Action to I
Preclude the Repetition of inadvertent Repositioriing of Safety-Related Equipment due to Accidental Bumping 50-341/99003-01a NCV Failure to implement Procedure 24.307.16 50-341/99003-01b NCV Failure to implement Procedure 23.701.14 50-341/97003-08 URI OSRO Effectiveness in Performing Special Reviews J
50-341/99003-02 NCV Failure to implement Timely and Effective Corrective Action to Preclude the Repetition of inadvertent Repositioning of Safety-Related Equipment due to Accidental Bumping i
50-341/96016-05 VIO Inadequate Procedure Causes Failure of the Vacuum Breaker to i
Reclose During Testing 50-341/96016-08 VIO Performance of inadequate Reference Leg Backfill system Procedure Causes Plant Scram 50-341/96023-00.
LER Technical Specification Required Shutdown - Drywell to Suppression Chamber Vacuum Breaker Failed to Indicate Closed 50-341/97002-00 LER Failure of HPCI System Pump Discharge Valve to Open 50-341/96016-04 IFl Protecting Equipment inside Containment from Damage
. 50-341/96016-06 URI CST Instrument Cabinet not Locked per UFSAR Requirement 50-341/96010-14 VIO Temporary Modification to General Service Water Fails to Provide Ultimate Heat Sink Makeup 50-341/96010-15
- VIO Procedure 42.302.11 Inadequate to Prevent Rendering Residual Heat Removal Service Water System Pumps inoperable 50-341/96006-04 IFl Residual Heat Removal Reservoir Service Water Valves Not in the IST Program
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ITEMS OPENED, CLOSED AND DISCUSSED (cont'd)
i Closed f'
50-341/97013-06 URI ' Discrepancy Between Licensee's Special Nuclear Material i
License 1097 for Criticality Monitoring Exemption and the Operating License Discussed
' 50-341/97013-04 URI Ute of Pipe Sealant Compound in Pneumatic Systems j
LIST OF ACRONYMS USED-CARD Condition Assessment Resolution Document CFR Code of Federal Regulations CST Condensate Storage Tank EDG Emergency Diesel Generator HP Health Physics HPCI High Pressure Coolant injection IFl Inspection Followup item IST Inservice Testing KVAR Kilovolts Amperage Reactive l
,LER Licensee Event Report -
l MCC Motor Control Center MCR Main Control Room l
MOV Motor Operated Valves l
NCV Non-Cited Violation
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NRC Numar Regulatory Commission OSHO On:,ite Review Organization l
RFO Refueling Outage l
SGTS Standby Gas Treatment System l
SOV.
Solenoid Operated Valves
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SSPV Scram Solenoid Pilot Valves UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation WCT Waste Clarifier Tank WR Work Request
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