IR 05000341/1999011

Insp Rept 50-341/99-11 on 990724-0908.Two NCVs Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20217F609
Person / Time
Site:	Fermi
Issue date:	10/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217F596	List: IR 05000341/1999011 ML20217F593
References
50-341-99-11, NUDOCS 9910210024
Download: ML20217F609 (18)

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, - U.S. NUCLEAR REGULATORY COMMISSION l

REGIONlli Docket No: 50-341 License No: NPF-43

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l Report No: 50-341/99011(DRP) 1

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Licensee: Detroit Edison Company

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Facility: Enrico Fermi, Unit 2

i Location: 6400 N. Dixie Hw Newport, MI 48166 Dates: July 24 through September 8,1999 Inspectors: S. Campbell, Senior Resident inspector

- J. Larizza, Resident inspector Approved by: A. Vegel, Chief

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Reactor Projects Branch 6 Division of Reactor Projects

i 9910210024 991007 PDR 0 ADOCK 05000341 PDR I

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L EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC Inspection Report 50-341/99011(DRP)

l l- This inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspectio Ooerations -

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- The inspectors concluded that in response to several emergent equipment problems the licensee promptly and appropriately took corrective actions. For enmple, the licensee -

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was pro-active in maintaining sufficient fuel oil level for the station blackout combustion turbine generator, an STA identified an inoperable data acquisition system and took

! appropriate steps to verify TS compliance and to restore the system promptly, and

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l . operations personnel responded appropriately to a sudden rise in hydrogen j concentration that occurred after an off-gas system trip. (Section 01.1).

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Inattention to detall, and less than thorough pre-job reviews contributed to the occurrence of several human performance errors. One non-cited violation was identified for an operator who inadvertently diluted the Standby Liquid Control tank sodium pentaborate concentration. (Section 04.1).

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Recent human performance errors were properly documented in the corrective action program. The licensees corrective actions included a site-wide work stand down to support training which focused on improving work practices which were conducive to decreasing human performance errors. (Section 04.1).

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Effective communication of plant status and equipment issues was exchanged during

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shift turnover and management meetings. Plant management asked challenging l- questions during these meetings, in particular, identifying and addressing potential error likely situations that may occur from a sudden change in the brush replacement

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schedule._ (Sections 06.1 and M1.2)

Maintenance e' - The rea'c tor recirculation MG set brush replacement work activity was performed

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! effectively. Workers followed appropriate work procedures and management provided

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. sufficient oversight. (Section M1.2). l

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. . Although industrial safety practices were followed, the inspectors noted inconsistencies in using protective equipment during the motor generator set exciter brush replacemen Maintenance personnel did not meet plant management expectations when the activity 3 was started without changing an evaluator guide caution statement regarding the use of 'i proper protective equipment. (Section M1.2)

i The maintenance activity for the residual heat removal room cooler was coordinated well. Individuals used adequate radiation work practices. Quality Assurance personnel provided effective oversight. (Section M1.3)

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The inspectors identified an inconsistency between the vendor manual and work request for the quantity of lubricant used in the residual heat removal cooler fan bearin Consequently, the component was under-lubricated. The error occurred because the work request was not updated to reflect the proper quantity after a different fan motor l was installed in 1996. One minor violation was identified. (Section M3.1)

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The licensee identified that a technical service request procedure did not provide clear i- guidance on classifying the proper modification process after experiencing difficulty

installing an air dryer on Emergency Diesel Generator 14. Consequently, engineering l personnel. misinterpreted the procedure requirement for the proper modification process and did not develop an engineering design package for installing the drye l (Section E1.1)

Plant Sucoort l

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Several individuals, who were involved in overseeing the motor generator set brush replacement activity, missed that electricians had violated a radiation protection procedure when the electricians removed their dosimeters to work around the rotating equipment. The licensee identified that this was a site-wide practice during similar maintenance activities. The inspectors identified one non-cited violation. (Section M1.2)

. A maintenance individual lacked adequate protection from contamination when the l individual entered a contaminated area with short pants. A lack of a clear understanding for proper protection caused this poor radiological work practice. (Section R1.1)

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Report Detalla Summarv of Plant Status Unit 2 began this inspection period at 97 percent power. On August 4,1999, power was reduced to 82 percent to replace degraded exciter brushes on the motor generator set for Recirculation Pumps A and B. Power was retumed to 97 percent the same day after completing the activity, l. Operations 01 Conduct of Operations 01.1 Operator Resoonse to Emeroent Eauipment issues Inspection Scope (71707)

The inspectors followed-up on issues related to maintaining adequate fuel supply for Station Blackout Combustion Turbine Generator (CTG) 11-1, an inoperable data acquisition system, and an unexpected increase in hydrogen concentratio { Observations and Findinas Shutdown of the Station Blackout Combustion Turbine Generator j l

On July 28,1999, during a critical electrical load day due to hot weather conditions, the l operators started the CTGs to supply additional electrical power to the grid. However, )

plant operators noted that the CTG fuel oil supply tank was approaching the minimum level (13 feet) for CTG 11-1 operability. As a result, the turbine generators were shutdown until the tank was refilled, thereby ensuring that CTG 11-1 remained operabl Response to Inocerable Data Acauisition System On July 29,1999, during operator rounds, a shift technical advisor (STA) appropriately identified that the Multi Vendor Data (MVD) acquisition system was not functioning properly. The MVD provides reactor core data to a computer (3DMonicore) for three dimensional reactor core power distribution limit calculations. Reactor engineering personnel and the STA determined that the last valid 3DMonicore report remained within the 24-hour Technical Specification (TS) requirement, and initiated MVD lockup l compensatory instructions until the computer support personnel re-booted the MV The licensee initiated Condition Assessment Resolution Document (CARD) 99-16090, to

! document the failur Response to Hydroaen Soike in Off-Gas On August 20,1999, the center off-gas chiller tripped due to a high Freon pressure causing the ring water buffer pump to trip and as a result gases from the main '

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condenser could not be removed via the off-gas system. In response, the oxygen and hydrogen supply valves for the hydrogen water chemistry system immediately closed which prevented the recombination of oxygen with hydroge t_ _ . . . . _ . . . . - . - . . . . - . - - . - - . - - - - . . . . . . . - - . . . . . . . - . . . . . . .

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Operators,'who began monitoring condenser vacuum, entered System Operating Procedure 23.712," Restoration after Loss of Power," and quickly restored the off-gas system. After system restoration, hydrogen reached concentration levels of 68 percent in the delay piping in the Turbine Building basement. Since the concentration level was pater than TS 3.11.2.6 requirement of 4 percent, operators entered Abnormal Operating Procedure 20.712.01, Hydrogen Concentration in the Off-gas System."

Operators also reviewed Abnormal Operating Procedure 20.712.02, "Off-gas System Explosion," and restricted personnel access to the basemen Chemistry personnel sampled the off-gas system and safety personnel sampled the

!- basement air. The licensee did not find hydrogen in the basement. Within 10 minutes,

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the off-gas system was appropriately vented in accordance with procedures and the hydrogen concentration in the delay piping decreased below TS limits.

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The licensee initiated CARD 99-16461, to document the event. During the investigation, I

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the "wnsee discovered that the oxygen supply valve in the hydrogen water chemistry system should have ramped closed rather than quickly isolating to allow sufficient

oxygen / hydrogen recombination. This was determined to be a potential vendor design erro Conclusions ,

The inspectors concluded that in response to several emergent equipment problems the licensee promptly and appropriately took corrective actions. For example, the licensee was pro-active in maintaining sufficient fuel oil level for the station blackout combustion turbine generator, an STA identified an inoperable data acquisition system and took appropriate steps to verify TS compliance and to restore the system promptly, and

. operations personnel responded appropriately to a sudden rise in hydrogen concentration that occurred after the off-gas system trippe ;

O2 Operational Status of Facilities and Equipment O2.1 Enaineered Safetv Feature System Walkdowns (71707)

i The inspectors used Inspection Procedure 71707 to walk down accessible portions of l the following engineered safety feature systems:

l i . High Pressure Coolant injection System L . Divisions 1 and 2 Emergency Diesel Generators (EDGs)

i . Divisions'1 and 2 Switchgear Rooms l

Equipment operability, material condition, and housekeeping were accel: table in all l

f . cases. Several minor discrepancies were brought to the licensee's attention and were

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corrected. The inspectors identified no substantive concerns as a result of these walkdown .

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04' Operator Knowledge and Performance 1 0 Increased Occurrence of Problems Due to Human Performance Errors

- Insoection Scooe (71707)

During the inspection period, several human performance errors occurred that resulted in plant management instituting a plant stand down. The Inspectors reviewed the ;

circumstances and assessed the adequacy of the licensee's corrective actions in i response to the increased occurrence of human performance error Observations and Findinas

. Qgtrator inadvertently Dilutes Standbv Liould Control (SLC) Tank:

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On August 20,1999, an operator was dispatched to sparge the SLC tank per Section 6.2 of Procedure 23.139,"SLC System," for a chemistry sample. Since the operator realized that he had left the procedure in the CR, he contacted the CR and received instructions from the CR Nuclear Shift Operator on the sequence of operating

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applicable valves. During the conduct of this evolution, the operator opened Demineralized Water Valve C4100F010 instead of opening Air Valve C4100F012 to sparge the tank. Both valves were near each other and had identical valve handle The valve remained open for approximately 22 minute Approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later, another operator noticed that SLC tank level was 5.5 inches higher than the night before. The licensee determined that the added demineralized water diluted the sodium pentaborate concentration from 9.1 to 8.6 percent. The TS 3.1.5 concentration requirement was 8.5 percent. The licensee initiated CARD 99-16210 to document the inadvertent SLC tank dilution. The inspectors verified that the calculation for concentration was correct and within TS limit Technical Specification Surveillance Requirement 4.1.5.b.1, requires that the SLC boron concentration be verified every 31 days. . System Operating Procedure 23.139, Revision 30, " Standby Liquid Control System," is a procedure used to perform SLC tank

. sampling to fulfill TS Surveillance Requirement 4.1.5.b.1 _ Step 6.2.2.1 required opening SLC Storage Tank Mixing Air Supply Valve ~ C4100F012 to sparge and mix the tank for boron sampling.- Contrary to the above, the operator opened SLC Storage Tank-Demineralized Water Supply Valve C4100F010 which diluted the SLC tank boron concentration. This _ Severity Level IV violation is being treated as a non-cited violation,

_ (NCV 50-341/99011-01) consistent with Appendix C of the NRC Enforcement Polic . This violation is in the licensee's corrective action program as CARD 99-1621 Failure to Recoanize Imoact of Performina Breaker Preventative Maintenance (PM):

On August 23,1999, while performing work activities in accordance work procedure PM Z837970722 to clean and lubricate Motor Control Center Position 72M-2AR, an

operator opened the breaker per the PM and Pressure Control Valve N11F400A ,

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- opened. As a result, steam jet air ejector header pressure increased above the relief valve pressure set point and opened the relief valve. The operators responded quickly and retumed the system back to normal. The licensee initiated CARD 99-16606 to

document the unexpected opening of Valve N11F400A. The licensee determined that

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the cause of this event was inattention to detail and inadequate reviews of the PM procedure and associated drawings by the electrical planner, Work Control Nuclear Shift Supervisor and the. Work Control Nuclear Senior Reactor Operato Manaaement Resoonse to Errors:

' in response to the increased occurrence of problems due to human performance errors,

- licensee management initiated a site-wide human performance stand down on August 31,1999. The stand down required that all non-critical work be stopped and that each organization review these errors, as well as other. errors that had recently occurred, and the lessons learned from these events. In addition, reviews were conducted of evolutions where good work practices were demonstrate ~ Conclusions Inattention to detail, and less than thorough pre-job reviews contributed to the occurrence of several human performance errors. One non-cited violation was identified for an operator who inadvertently diluted the SLC tank sodium pentaborate concentration. These errors were properly documented in the corrective action program. The licensees corrective actions included a site-wide work stand down to support training which focused on improving work practices which were conducive to decreasing human performance error Operations Organization and Administration-0 Observation of Shift Turnovers. Manaaement Meetinas. and Shift Supervisor Meetinas The inspectors routinely attended shift turnover, management, and shift supervisors'

- meetings. The inspectors noted an effective exchange of information regarding plant status and equipment and prog 7m issues. Requisite support organizations routinely attended and participated in the meetings. Plant management asked challenging questions in particular during the plant power reduction to replace motor generator (MG)

set exciter brushes (see Section M1.2) and for recently issued CARD ' Miscellaneous Operations issues (92700)

08.1 Closure of Severity Level IV Violation The Severity Level IV violation listed below was issued in a Notice 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 this violation ,

would have been treated as non-cited in accordance with Appendix C, it is being closed

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out in this report.'

Violation 50-341/96017-01c: This violation is in the licensee's corrective action program as Deviation Event Report (DER)96-128 !

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11. Maintenance l M1 Conduct of Maintenance M1.1 General Conduct of Maintenance-

The inspectors observed the following maintenance activities:

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Work Request (WR) 000Z992773 - Troubleshoot EDG 13 Trip on field failure, a WR 000Z992776 - Repair of Supervisory Control System B for CTG 11,

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WR 945970819 - PM on Residual Heat Removal (RHR) Room Cooler, and a WRs AD27990806 and AD28990806 - Replace Brushes on MG Sets A and The activities were conducted by trained and knowledgeable individuals using approved

- procedures._ Noteworthy observations during these activities are listed belo M1.2 ~ Replacement of Reactor Recirculation Pumo MG Set Exciter Brushes

' ' Inspection Scope (62707)

. On August 4,1999, the inspectors observed the exciter brush replacement on Reactor Recirculation Pumps A and Observations and Findinas Due to increased brush degradation of the Reactor Recirculation Pump MG set brushes, the licensee initiated an accelerated schedule for brush replacement, which resulted in

..the work activity being moved up from August 6 to August 4. The plant manager became concerned that the sudden schedule change could cause error likely situations that included working overtime, performing the task during off-normal hours, and inadequate time to develop contingencies and to train the mechanics. The licensee staff addressed these concems and the activity was performed on August The inspectors o'bserved a portion of the brush replacement activity and noted Linconsistencies regarding industrial safety practices between the four electricians. For example, the electricians used different methods to secure electrical safety gloves, and only two electricians stood on a rubber mat. _ The inspectors reviewed Evaluator Guide OE-EM-031-0009, Revision 0, " Reactor Recirculation Brush Maintenance," and noted that a caution statement in the procedure required both the use of a rubber mat and rubber gloves for electrical hazard protection. The inspectors were informed by the electrical supervisor that the rubber mat was not required for work on 120V circuits. The supervisor also stated that not using the mat was discussed during the pre-job brie However, the inspectors noted that the licensee continued the brush replacement

activity without changing the evaluator guide to be consistent with the actual

- performance of this activity. Subsequently, the evaluator guide was revised to eliminate the rubber mat requiremen The evaluator guide also required that persons performing maintenance and inspection on rotating equipment must not have any loose items. The inspectore noted that the

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i electricians had removed their neck lanyards used to hold the thermoluminescent (TLD)

and direct reading dosimeters. One lanyard with a dosimeter was on the work platform and another was in an individual's back pocke Radiation Protection Manual MRP 04, Revision 7, " Accessing and Working in Radiologically Restricted Areas," Step 4.1.2 required, in part, that individuals wear the TLD on the upper torso, unless directed by radiation protection (RP) personne Contrary to the above, two electricians failed to wear the TLD on the upper torso and did not receive the required approval to relocate the dosimetry.

, The licensee issued CARD 99-15111 to document the improper location of the

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dosimetry and denied the involved individuals access to the Radiologically Restricted l

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Areas. .This Severity Level IV violation is being treated as a non-cited violation,

(NCV 50-341/99011-02) consistent with Appendix C of the NRC Enforcement Polic j This violation is in the licensee's corrective action program as CARD 99-1511 j i

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j removed during activities where loose items may cause impact during specific j maintenance activities (rotating equipment and/or energized equipment). Therefore, the

! corrective actions were focused for correcting the issue from a generic standpoint.

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l The inspectors determined that the reactor recirculation MG set brush replacement work )

activity was performed effectively. Workers followed appropriate work procedures and

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management provided sufficient oversight.

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Although industrial safety practices were followed, the inspectors noted inconsistencies

.in using protective equipment during the MG set exciter brush replacemen Maintenance personnel did not meet plant management expectations when the activity was started without changing an evaluator guide caution statement regarding the use of proper protective equipmen Several electricians involved in the MG brush replacement rtivity had violated an RP l procedure regarding the proper wearing of personal dosimetry when working around l rotating equipment. The licensee identified that this was a site-wide practice during l similar maintenance activities. The inspectors identified one non-cited violatio Plant management asked challenging questions regarding the sudden change in the ,

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M1.3 Maintenance Observations Durina RHR Room Cooler Work

! Insoection Scooe (62707)

On August 10,1999, the inspectors observed preventive maintenance on the Division 2 RHR Pump Room Coole .

4 . Qbservations and Findinos The work activity, which the licensee performed every 24 months, was well coordinate Generally, radiological work practices were effective. The maintenance crew followed the radiation work permit requirements and RP coverage was adequate. Mechanics us9d proper skill-of-the-craft techniques to complete the jo Quality Assurance personnel were present to monitor the activity that included verifying proper belt tensioning and proper use of equipment. The inspectors noted that methods forimproving belt tensioning were not implemented following the failure of the Division 2 Control Center Heating Ventilation and Air Conditioning inboard fan bearing that occurred on April 19,1999, and is documented in CARD 99-11926 (Inspection Report 50-341/99007). However, a corrective action item for improved belt tensioning was not addressed in CARD 99-11926 because incorrect tensioning did not cause this failur Consequently, the inspectors discovered that no formal tracking method existed for implementing improved belt tensioning techniques. Maintenance personnelinitiated CARD 99-17019 to document that the improvement methods were not being tracked and to ensure that improved belt tensioning would be incorporated in maintenance procedure Conclusions Overall the maintenance activity for the RHR room cooler was coordinated wel Individuals used adequate radiation work practices. Quality Assurance personnel provided adequate oversight of the activit M3 Maintenance Procedures and Documentation l M3.1 Failure to Uodate Preventative Maintenance Instructions Inspection Scooe (62707)

The inspectors reviewed the RHR system room cooler maintenance history and vendor manuals to determine whether the site procedures incorporated vendor recommendations, Observations and Findinas Work Request 945970819 required that 0.2 ounces of lubricant be added to the motor bearing. The inspectors reviewed the motor work history and discovered that the motor was replaced with a different brand in 1996 under Engineering Design Package (EDP) 26881. Per Vendor Manual VMS25-9.2, " Reliance Electric Duty Master Integral Horsepower Induction Motors 180T-5000 Frames," for the replacement motor, the bearings required 0.6 ounces of lubrican The vendor manual for the old motor required 0.2 ounces of lubricant. An incorrect ( quantity of lubricant was listed in the WR because the procedure / program revision notice, used to update the WR after EDP 26881 was issued, incorrectly indicated that no PM procedure revisions were require .

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In response to this issue, the licensee initiated CARD 99-16266 to document this finding. The inspectors also identified that an insufficient quantity of lubricant was added in 1997. However, the licensee considered the pump. operable because of a history of satisfactory bearing vibration readings. The licensee initiated WR 000Z993255 to add sufficient quantity of lubricant. The failure to adesately update the RHR room cooler motor preventative maintenance WR after the EDP was issued, constitutes a violation of minor significance and is not subject to formal enforcement action, Conclusions The inspectors identified that the quantity of lubricant listed in the WR for the RHR room cooler fan bearing was inconsistent with vendor recommendations and caused an

. insufficient quantity of lubricant to be added. The WR was not updated to reflect the

,- proper quantity after a different fan motor was installed in 1996. One minor violation was identifie M8 Miscellaneous Maintenance issues (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 d the Enforcement Policy). Because these violations would have been treated as non-cited in accordance with Appendix C, they are being closed out in this repor . Violation 50-341/97003-02 This violation is in the licensee's corrective action program as DER 97-0600 and was closed in Section M8.1 of Inspection Report 50-341/9800 . Violation 50-341/97007-05 This violation is in the licensee's corrective action program as DER 97-091 M8.2 (Closed) Inspection Followuo item (IFI) 50-341/97007-04: Reactor Coolant isolation Cooling (RCIC) System Flow Controller Set Point. The RCIC system outage was

~ delayed because operators questioned the validity of the steps in the RCIC Surveillance Test Procedure 24.206.01,"RCIC System Pump and Valve Operability Test."

Specifically, the set point for RCIC Flow Controller E51R614 was raised above the standby set point of 640 gallons per minute (gpm) to 645 gpm to satisfy a TS criteria of 600 gpm. The operators were concerned that returning the controller back to the 640 gpm set point would have negated RCIC operability as justified by the test. The licensee initiated DER 97-0950 to document the operators' concern. The inspectors reviewed the methodology and calculations used to justify the new set point and confirmed that the proper tolerances for the flow controller and the indicator were incorporated into the procedure.

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M8.3 - (Closed) Licensee Event Reports (LERs) 50-341/96017-00. 96017-01. 96017-0 )

l 96017-03: Failure of Safety Relief Valves to Open Within TS Required Tolerance. This item is closed to the NCV issued in Inspection Report 50-341/98019 for LER 50-341/96017-03. This report incorrectly listed LER 50-341/96017-03 as 50-341/96017-0 M8.4 (Closed) LER 50-341/97009-00: Operation in a Condition Prohibited by TS. This LER involved the failure to inspect the control rod drive (CRD) housing support structure following maintenance. Technical Specification 4.1.3.8, provided the surveillance requirement for ensuring gaps between the grid plates and bottom contact surface of the CRD flange and structuralintegrity of the housing support were maintained following maintenance activities, it was determined that past surveillance tests may not have been performed literally per the TS requiremen After a review, the inspectors determined that no violations occurred since the maintenance activities did not affect the housing support or the gap between the grid and CRD flange contact. The drywell close-out procedure was revised to clarify that an inspection of the CRD housing support was required following any maintenance under the reactor vessel area and above the service platform. The inspectors determined that the corrective actions would prevent recurrence. This LER is close '

M8.5 (Closed) IFl 50-341/97003-01: Review of Foreign Material Exclusion (FME) Practice The inspectors had concluded that station FME program weaknesses existed and were concerned that the weak FME practices could potentially impact safety-related equipment. As a result, the licensee reviewed the FME controls against industry 4 standards and initiated DERs 97-0707,97-0603 and 97-0536 to address this issue. The

- licensee's corrective actions included:

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.- incorporating FME requirements in maintenance training,

. providing clear guidance in governing procedures on w'nen FME controls are required, and

. including instructions of FME control sign off in work package )

The inspectors verified the corrective actions had been completed. This IFl is close Ill. Enaineerina E1 Conduct of Engineering E1.1 - Discreoancy in EDG 14 Air Drver Replacement Insoection Scooe (37551)

On July 20,1999, the licensee attempted to install a non-seismic and non-Q, air dryer on EDG 14 during the EDG outage. The mechanics discovered that the associated piping would not fit-up.' The inspectors followed-up on the apparent cause of the ,

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. Observation and Findinas The air dryers on all EDGs required replacement because of obsolescence. The replacement activity began with EDG 14. To perform this replacement, engineers developed an equivalent part Technical Service Request (TSR) 29539 instead of an EDP. The engineers did not develop an EDP because the engineers misinterpreted Engineering Support Conduct Manual MES11, Revision 10, " Technical Service

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The procedure provided guidance for developing a TSR or an EDP with an exception that seismic Category ll/l, such as the air dryer, required an EDP. However, an

- exception to this requirement allowed miscellaneous items such as work benches, ladders, signs, etc and permitted a TSR to be used. ' The system engineer considered

. the air dryer under this criterio . .

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When the mechanics attempted to install the dryer, dimensional differences between the previous and replacement units prevented the piping fit-up, thus requiring a field modification. Consequently, maintenance personnel stopped work and questioned whether the replacement dryer was non-like-for-like and whether an EDP was required instead of a TS Maintenance personnel documented the concern on CARD 99-15529. Subsequently, the licensee decided not to install the dryer and completed the EDG outage. As corrective action, the licensee was developing an EDP to install the remaining dryers, Conclusions A TSR procedure did not provide clear guidance on classifying the proper modification process after experiencing difficulty installing an air dryer on EDG 14. Consequently, engineering personnel misinterpreted the procedure requirement and developed a TSR instead of an EDP for installing an air drye . E8 Miscellaneous Engineering lasues (92903)

-E Closure of Severity Level lV Violation

- The Severity Level IV violation listed below was issued in a Notice of Violation prior to the March 11,' 1999, implementation of the NRC's new policy for treatment of Severity

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- Level IV violations (Appendix C of the Enforcement Policy). Because this violation would have been treated as a non-cited violation in accordance with Appendix C, it is being closed out in this repor :. Violation 50-341/97011-02013 This violation is in the licensee's corrective action program as DER 97-0244 and CARDS 98-12071 and 98-1826 E8.2 (Closed) Unresolved item 50-341/97016-03: Inspection and Testing of 480V Breaker The inspectors were concemed that the licensee did not initially determine the scope of the 10 CFR Part 50, Part 21 evaluation related to inappropriate wiring of 480V K-Line breakers. ' As a result, the licensee ~ developed procedures to test the breakers, however, I

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I the inspectors were concerned that new and refurbished breakers may not receive this test to confirm adequate wiring. Subsequently, the licensee identified two breakers that needed testing and inspectio The licensee initiated DER 97-1143 and CARD 98-12449 and revised Procedure 35.318.023, " Power Shield - 480 Volt Circuit Breaker Solid State Trip

. Testing," to include the proper instructions for testing. Electrical personnel tested and inspected four new breakers per the revised procedure on February 17,1998, under WR 000Z970142. No problems were identified during these test l I

The licensee reviewed purchase orders to determine whether 480V K-Line breakers (not l I

tested to the new requirements) purchased after plant startup were used in safety-related applications. No breakers were identified.

l E8.3 (Closed) IFl 50-341/96201-07: Verify Relay Contact Separation Requirement. During

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the NRC Safety System Functional inspection, the inspectors questioned the l Justification for satisfying the single failure criteria between the RCIC and the High

, Pressure Core Injection system. Wires from both systems were landed on adjacent l terminals of the same relay, and the inspectors assumed that both systems were ,

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vulnerable to a single failure. In response, the licensee initiated DER 96-1147 to l l address this issue. The licensee provided analysis that supported the single failure criteria was maintained with the wiring in this configuration as stated in the Updated i Final Safety Analysis Report (Section 3.12.3). This IFl is closed.

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R1 Radiological Protection and Chemistry Controls R Radiation Protection Practice While in a Contaminated Area Inspection Scooe (71750)

On August 4,1999, during tours of the plant, the inspectors identified an individual entering a contaminated area with short pant Observations and Findinas

- Two individuals walked down penetrations for an 18-month surveillance per Task J236970819. The task required that the individuals sign-in on Radiation Work l' Permit 99-1010, which allowed substitution of a yellow coverall and a cloth hood for a lab coat, provided that approvals were obtained from RP personne ,

The inspectors noted that one individual wore the lab coat and had short pants under

. the coat. The inspectors were concemed that with exposed skin the individual would be more susceptible to skin contamination. This observation was discussed with the RP manager and the manager addressed this poor radiation work practice in CARD 99-17065 and counseled the responsible individua l

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- Conclusions A maintenance individual lacked adequate protection from contamination when the individual entered a contaminated area with short pants. A lack of a clear understanding for proper protection contributed to the occurrence of this poor radiological work practic V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 8,1999. 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 identifie :

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PARTIAL LIST OF PERSONS CONTACTED l

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Licensee

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D. Cobb, Superintendent, Maintenance J. Davis, Superintendent, Outage Managemen R, Delong, Preventative Maintenance )

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-: D. Gipson, Senior Vice-President, Nuclear Operations

- C. Heitzenrater, Operations .

K. Hlavaty, Superintendent, Operations E. Kokosky, Superintendent, Radiation Protection A. Kowalczuk, Manager, Plant Support R. Libra, Systems Engineer ' .

A. Lim, Plant Support Engineer l M. Moran, Work Control I

J. Moyers, Director, Nuclear Quality Assurance .

. W. O'Connor, Assistant Vice-President, Nuclear Assessment j

. J. Pendergast, Principal Engineer, Licensing

.'N.' Peterson, Director, Nuclear Licensing .

T J, Plona, Manager, Technical '

P. Smith, Licensing T. Stack, Security S. Stasek, Supervisor, independent Safety Engineering Group NRC-S. Campbell, Senior Resident inspector J. Larizza,- Resident inspector A. Vegel, Chief, Reactor Projects Branch 6

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INSPECTION PROCEDURES USED IP.37551: Onsite Enginee;ing IP 62707: Maintenance Observation .

IP 71707: . Plant Operations

' IP 71750: Plant Support Activities _

j IP 92700:- Onsite Followup of Written Reports of Nonroutine Events at Power 1 Reactor Facilities j

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IP 92902: Followup - Maintenance #

IP 92903: Followup - Engineering ITEMS OPENED AND CLOSED

- Ooened 50-341/99011-01 NCV Operator incorrectly opened SLC valve which diluted the tank boron concentration 50-341/99011-02 NCV Failure of two electricians to wear TLDs on the upper torso as required

. Closed

~ 50-341/99011-01' NCV Operator incorrectly opened valve which diluted the SLC tank

' boron concentration 50-341/96017-01c ' VIO Cross-tie valves to RHR reservoir 50-341/99011-02 NCV Faiiure of two electricians to wear TLDs on the Upper torso as required 50-341/97003-02 VIO Inadequate Procedure to restore RCIC to proper lineup 50-341/97007-05 VIO Failure to perform SR 4.4.1.1.2 within required period 50-341/97007-04 IFl RCIC system flow controller set point i 50-341/96017-00 LER ' Failure of safety relief valves to open within TS required tolerance 50-341/96017-01 LER Failure of safety relief valves to open within TS required tolerance

- 50-341/96017-02' LER. Failure of safety relief vaives to open within TS required tolerance ,

50-341/96017-03 LER ; Failure of safety relief valves to open within TS required tolerance j

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50-341/97009-00 LER Operation in a condition prohibited by TS 50-341/97003-01' :IFl Review of FME practices

. 50-341/97011-02013 VIO HPCI valve not adequate to preclude motor pinion gear malfunction recurrence ,

50-341/97016-03 URI inspection and testing of 480 V breakers 50-341/96201-07 IFl Verify relay contact separation requirement

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LIST OF ACRONYMS USED

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. CARD Condition Assessment Resolution Document !

CR- Control Room l CRD ' Control Rod Drive CTG Combustion Turbine Generator DER Deviation Event Report EDG- Emergency Diesel Generator EDP Engineering Design Package FME Foreign Matorial Exclusion GPM Gallons Per Minute IFl Inspection Followup item LER _ Licensee Event Report MG Motor Generator MVD Multi Vendor Data-NCV Non-Cited Violation NRC ' Nuclear Regulatory Commission NSRG Nuclear Safety Review Group PM Preventative Maintenance RCIC Reactor Coolant isolation Cooling System RHR Residual Heat Removal

. RP Radiation Protection SLC Standby Liquid Control i STA Shift Technical Advisor

- TLD Thermoluminescent Dosimeter i TS Technical Specification TSR Technical Service Request WR Work Request

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