IR 05000348/1999001

Insp Repts 50-348/99-01 & 50-364/99-01 on 990110-0220. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20196K494
Person / Time
Site:	Farley
Issue date:	03/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20196K492	List: IR 05000348/1999001 ML20196K488
References
50-348-99-01, 50-348-99-1, 50-364-99-01, 50-364-99-1, NUDOCS 9903300089
Download: ML20196K494 (10)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 l

Report Nos.: 50-348/09-01 and 50-364/99-01 Licensee: Southem Nuclear Operating Company, In Faci!ity: Farley Nuclear Plant, Uni 5 4 and 2 Location: 7388 N. State Highway 95 Cclumbia, AL 36319 Dates: January 10 - February 20,1999 Inspectors: T. P. Johnson, Senior Resident inspector J. H. Bartley, Resident Inspector R. K. Caldwell, Resident inspector Approved by: Pierce H. Skinner, Chief Reactor Projects Branch 2 Division of Reactor Projects

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9903300089 990319 ADOCK 050003 8 Enclosure gDR

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EXECUTIVE SUMMARY FARLEY NUCLEAR POWER PLANT UNITS 1 and 2 Nuclear Regulatory Commission Inspection Report 50-348,364/99-01 This integrated inspection to assure public health and safety included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of inspection by Resident inspectors from January 10 to February 20,199 Qggrations e The inspectors observed that control room operator attentiveness to annunciator alarms and unit issues was prompt and demonstrated a high level of awareness of existing plant conditions and ongoing plant activities. Examples included response to Unit 1 decreasing instrument air pressure on January 18, and Unit 2 high instrument air pressure on January 27 and 28, in which operators responded promptly to avert any unit detrimental effects (Section 01.1).

e Improvement in operations department personnel implementation of the risk-based equipment out of service monitor was warranted (Section 01.2).

e The licensee appropriately responded to the Uni t 1 increased Dose Equivalent lodine and that Chemistry and Engineering support provided accurate and timely analysis and recommendations (Section 01.4).

Maintenance l e' The licensee implemented a new 13-week rolling maintenance schedule ( designed to better utilize maintenance resources, to perform the required i corrective and preventive maintenance, and to reduce the current maintenance backlog. The inspectors monitored the first few weeks of the program, and

. noted that the initial results were positive. The inspectors concluded that the 13-week rolling maintenance schedule was a positive initiative (Section M1.1).

e A Non-cited Violation was identified for a failure to identify and correct inadequate l

l guidance in procedure GMP-60, " General Guidelines and Precautions for

. Erecting Scaffolding," Revision 22.

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L REPORT DETAILS i Summary of Plant Status

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l _ At the beginning of this reporting period, Unit 1 was operating at full power and had been on line since December 29,1998. The unit operated at o near full power during the i

inspection period.

L At the beginning of this reporting period, Unit 2 was operating near full power and had been on line since May 17,1998. The unit operated at or near full power during the inspection period.

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l. Operations ( 01 Conduct of Operations 4 Routine Observations of Control Room Operations (71707 and 40500)

The inspectors observed that control room operator attentiveness to annunciator alarms i and unit issues was prompt and demonstrated a high level of awareness of existing plant conditions and ongoing plant activities. Examples included response to Unit 1 decreasing instrument air (IA) pressure on January 18, and Un2 2 high IA pressure on January 27 )

and 28, in which operators responded promptly to avert any unit detrimental effect l l

The inspectors routinely reviewed the Technical Specification (TS) Limiting Conditions 3 for Operation (LCO) tracking sheets. All tracking sheets for Units 1 and 2 reviewed by j the inspectors were consistent with plant conditions and TS requirement '

01.2 ' Eauioment Control By Operations Durina Maintenance Activities (71707 and 62703)

The inspectors reviewed the operators' control of safety and risk related equipment during maintenance activities. The licensee used a Risk Achievement Worth (RAW) of ;

l relative risk for combination < .J risk-significant equipment that were out-of-service. The '

RAW was calculated by the computer-based Equipment Out of Service (EOOS) monitor.

l The guidance was_ provided in procedure FNP-0-ACP-52.1, Guidelines For Scheduling of On Line Maintenance, Revision 8. The shift supervisor (SS) was responsible for

, updating the EOOS monitor with the risk significance of out-of-service equipmen However, the inspectors noted that the SS did not always include all out-of-service risk-significant equipment when updating the EOOS monitor to obtain a new RAW valu These omissions resulted in the EOOS monitor underestimating the increase in relative risk. These omissions were recognized by management during the morning status meetings and the EOOS monitor was corrected. The inspectors concluded thr improvement in the operators' implementation of the risk-based EOOS monitor was warranted.

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- 01.3 System Operator (SO) Tours (71707)

During the period, the inspectors ' observed SO tours and assessed non-licensed operator performance during the conduct of periodic rounds and log keeping. Abnormal items were either addressed on the spot or reported to supervision in the control roo Overall, the tours were well performed with good attention to detail, and effectively monitored equipment statu .4 Unit 1 Rsactor Coolant System Activity increase (37551. 71707. and 71750)

On February 12, chemistry personnel noted that the Unit 1 Dose Equivalent lodine (DEI)

. value increased from 2E-3 microcuries per milliliter (uCi/ml) to a peak of 2E-1 uCi/mi indicating that a fuel rod mey have developed a leak . By the end of the inspection period, the value had decreased to 6E-3 uCi/ml. At the close of the inspection period, the licensee was still evaluating the possibility of a fuel leak. The inspectors concluded that the licensee appropriately responded to the increased Unit 1 DEI and that Chemistry and Engineering provided accurate and timely analysis and recommendation Operational Status of Facilities and Equipment 02.1 - General Tours and insoections of Safety Systems (71707)

General tours of safety-related areas were performed by the inspectors to observe the physical condition of plant equipment and structures. To verify that safety systems were properly maintained and aligned, the inspectors conducted detailed system reviews of the lA systems for both units, the common offsite and onsite electrical distribution systems, and the emergency diesel generators (EDGs). The inspectors determined that the systems were properly maintained and aligne Quality Assurance in Operations

. 0 Self-assessments and Audits (40500 and 71707)

The inspectors reviewed several audits performed by the Safety Audit and Engineering Review (SAER) group. Two of the audits (SAER 98-OA/41-2 and SAER 99-CAR /19-1)

were evaluated in detail. These audits covered the Unit 1 cycle 15 refueling outage and the corrective action program. The inspectors also attended the exit meetings where SAER findings were presented to management. SAER findings were well developed

and communicated to management. Corrective actions were currently being addressed by the licensee. The inspectors concluded that the licensee demonstrated effective self-assessment capability,

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l1. Maintenance M1 Conduct of Maintenance

' M1.1 General Comments (61726 and 62707)

The inspectors observed or reviewed portions of selected maintenance and surveillance test activities in progress. For those activities observed or reviewed, the inspectors determined that the activities were effectively conducted and that the work was properly performed in accordance with approved maintenance work orders. The inspectors also determined that the observed activities were performed in a satisfactory manne l l

During the period, the licensee implemented a new 13-week rolling maintenance l schedule designed to better utilize maintenance resources, to perform the required corrective and preventive maintenance, and to reduce the current maintenance backlo The inspectors monitored the first few weeks of the program and noted that the initial results were positive. The inspectors concluded that the 13-week rolling maintenance schedule was a positive initiativ M1.2 Unit 2 Turbine Moisture Seoarator Reheater Stoo Valve (RSV) Failure (62707)

On January 13, Unit 2 load was reduced to 87% power because an off-site power line was out-of-service. While at this power level, the licensee performed the periodic main turbine valve test and noted a failure of the Unit 2A RSV. The licensee reduced power to 52% as a precautionary measure while corrective maintenance was performed. The Unit 2A RSV was retested satisfactorily and the unit retumed to full powe The inspectors observed testing and maintenance activities from the control room and locally in the turbine building. Overall, testing control was very good and the SS maintained excellent oversight. Test communications were formal and procedure ,

compliance was good. In addition the maintenance activities were also well controlle .

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M1.3 - Control of Scaffoldina (62707)

On January 22, the inspector identified ths.t scaffolding built in ther 2B Containment Spray (CS) pump room was not tied-off per the requirements of procedure FNP-0-GMP-60,

" General Guidelines and Precautions for Erecting Scaffolding," Revision 22. During previous tours in October and November of 1998, the inspector noted scaffolding issues in two Emergency Diesel Generator rooms and the Unit _1 Residual Heat Removal heat exchanger room. These observations were characterized as minor violations at that time to the licensee. This scaffolding was also not tied off per the requirements of GMP-6 The licensee initiated ors 1-98-371 and 1-98-415 to track and correct the deficiencies identified in October and November. These ors were closed on December 21 with all corrective actions complete. The corrective actions addressed inspecting existing scaffolding and coaching the contractor personnel who erect and inspect scaffoldin l

' The corrective actions did not address the adequacy of the procedural guidance nor !

training of licensee personnel who erect and inspect scaffoldin I I

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l The inspector discussed the scaffolding with operations and maintenance personne Initially, the licensee felt the scaffolding was tied off per the requirements of GMP-60.

l The procedure stated: " Scaffold shall be tied off at each working level. Spacing of

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intermediate vertical tie-off points between working levels shall not exceed a 12 foot spacing. Horizontal spacing of tie-offs shall be at least one per 8 feet of scaffold length

! and at least one per 8 feet of scaffold width." The operations and maintenance personnel interpreted that the working level was the scaffold platform and did not include the floor level. Because the scaffold was less than 8 feet in length and width, they decided that the requirements of at least one tie-off per 8 feet of length and width did not apply. After inspector questions, Engineering Support provided clarifying guidance on tie-off requirements. . Based on the feedback, maintenance added multiple tie-offs to the j scaffolding. The scaffold was in place approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without being adequately

restrained per GMP-60. The TS allowed outage time for the CS pump was 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to l assure that conditions adverse to quality are promptly identified and corrected. The SNC-Farley Project Operations Quality Assurance Policy Manual (OQAPM), GO-M-7, Revision 31, Section 16.4.1, stated: "The General Manager-Nuclear Plant shall assure that conditions adverse to quality are identified and corrected in accordance with documented procedures." Contrary to Criterion XVI and the OQAPM, the inadequate criteria for scaffolding tie-offs was not promptly identified and corrected. The corrective

! actions for ors 1-98-371 and 1-98-415 focused on the contractors who installed

- scaffolding during the outage and did not revise GMP-60 to ensure the tie-off requirements were clear nor did the actions provide any training to maintenance l personnel. Based on observations and interviews, maintenance and operations staff did not understand the tie-off requirements as listed in GMP-60. Failure to identity and correct the inadequate guidance of GMP-60 is a Severity Level IV violation and is being l treated as a Non-cited Violation, consistent with Appendix C of the NRC Enforcement l Policy. This violation (NCV 50-364/99-01-01, inadequate Corrective Actions Resulting in

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Additional Scaffold Errors) is in the licensee's corrective action program as OR 2-99-56.

l -M2' Maintenance and Material Condition of Facilities and Equipment

. M2.1 - Material Condition (62707)

The inspectors performed detailed walk downs and assessments of the overall plant material condition. Areas inspected included the turbine, auxiliary, and diesel building Some improvements were noted in the ECCS pump rooms including a reduction in the l amount of contaminated floor space. The inspectors noted some leaks and other l

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material condition deficiencies in the turbine building. - The licensee indicated that they were addressing the turbine building conditions. The inspectors also noted oil and water

! leaks in the diesel rooms that were not in the licensee's deficiency tracking system. The l licensee adequately addressed these conditions.

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M2.2 Instrument Air (IA) System Reliability (62707)

Based on risk significa'nce and recent IA initiated plant events, the inspector walked down the lA systems for both units with the licensee's system specialist and operator The lA initiated plant events caused system perturbations, required the operators to respond rapidly, and were possible precursors for significant unit upsets. During this walk down, the inspector noted unit differences, numerous equipment and material deficiencies, and that the 1D IA compressor had been out-of-service since December 1998. _ Since the 1D compressor could be aligned to either Unit 1 or Unit 2, the relative risk for both units was increased. The licensee was aware of this condition and had decided not to repair the compressor because the Unit 1 lA compressors were to be replaced. The inspector also noted that the local IA compressor alarm was disabled which prevented annunciation of abnormal IA conditions in the control room. The licensee was not aware of this condition; however, when informed of this condition by the inspector corrective actions were promptly take .The inspector expressed concem to the licensee about the reliability of the lA syste The licensee had recognized the risk significance of the lA system and planned modifications to increase the reliability. This included replacement of the lA piston-type compressors with more reliable centrifugal compressors. The licensee had completed these modifications to the Unit 2 lA system. Due to the recent Unit 1 IA events, the licensee changed their schedule to modify the Unit 1 lA system sooner. The inspector

' noted strong engineering support in following up on these issues, and for the overall proactive involvement in the IA modifications syste . Ennineerina

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E2 Engineering Staff Knowledge and Performance l i

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E System Fnaineer/Soecialist Performance (37551)

During the period, the inspectors reviewed system engineer / specialist performance for {

the lA and the EDGs systems.. The inspectors accompanied licensee personnel during i system walkdowns. The inspectors concluded that the systems' engineers / specialists ;

were knowledgeable regarding the status of their systems. The inspectors also reviewed

- engineer involvement in the Unit 1 power uprate testing and during Unit 2 main feedwater regulating valve tuning and adjustments. System engineering / specialist involver.1ent for these activities was good as evidenced by strong interfaces with >

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E8 Miscellaneous Engineering issues E (Closed) LER 50-348/1998-008-00i Reactor Vessel Support Concrete Desian Basis Temperature Exceeded Due To Closed Coolina Damoer (92700 and 90712)

(Ocen) eel 50-348. 364/98-05-02: Failure to identify Defacto 50.59 and Unreviewed Safety Question (USQ)(92903)

The licensee performed flow testing of the Unit 1 Reactor Cavity Cooling system on December 23,1998. This testing was performed because no venfication of the system performance or alignment had been performed since startup testing in 1977. The testing revealed that one of the six reactor vessel supports (RVS) had no cooling flow as a result of its manual damper being shut. The licensee was not able to determine how long the damper has been shut since no previous testing or system verifications had been performed.'

The licensee's evaluation for this condition determined that the RVS concrete temperatures would remain below 300 F with no air cooling flow. They further concluded that temperatures as high as 300*F would not have any detrimental effects on the concrete strength. The licensee's evaluation will be reviewed as part of the NRC's resolution of eel 50-348,364/98-05-0 IV. Plant Support R1 - Radiological Protection and Chemistry (RP&C) Controls R Radioloaically Controlled Area (RCA) Tour (71750)

The inspectors toured the RCA and noted appropriate conditions, and observed that personnel exhibited adequate knowledge and application of radiological control practices. Health physics technicians generally provided positive control and support of work activities in the RCA. This included work associated with a Unit 2 local leak rate test for the containment purge valves,1B charging pump casing drain work, and a high radiation transfer from the auxiliary building to the dnmming roo Conduct of Security and Safeguards Activities S Routine Observations of Plant Security Measures (71750)

The inspectors verified that portions of the site security program were being properly implemente'i. Disabled vital area doors were properly manned and controlled. Security personnel activities observed during the inspection period were well performed. Site security systems were adequate to ensure physical protection of the plan I L- f: .

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l F5 Fire Protection Staff Training and Qualification l

F Site Fire Marshall Qualification Reauirements

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The inspectors reviewed changes to the site Fire Marshall requirements in which the licensee lowered the experience requirement from 2 years to 16 months. A review of the i National Fire Protection Standards, FSAR, Fire Hazzards Safety Analysis Report, and i various licensee commitments to generic communications was conducted. The l

inspectors concluded that the program modification was permitted and would not result in a reduction in the fire protection program effectivenes V. Manaaement Meetin_gs X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on February 26,1999. The licensee acknowledged the findings present. No proprietary information was identifie Partial List cf Persons Contacted Licensee l R. V. Badham, Safety Audit Engineering Review )

R. M. Coleman, Maintenance Manager i K. C. Dyar, Security Manager R. S. Fucich, Engineering Support Manage S. Fulmer, Plant Training and Emergency Preparedness Manager J. S. Gates, Administration Manager l D. E. Grissette, Assistant General Manager - Operations J. R. Johnson, Operations Manager D. H. Jones, SNC - Configuration Management Manager l R. L. Monk, Engineering Support Supervisor C. D. Nesbitt, Assistant General Manager - Plant Support L. M. Stinson, Plant General Manager G. S. Waymire, Technical Manager B. R. Yance, Plant Modification and Maintenance Support Manager Other licensee _ employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, and electricians.

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List of Opened, Closed, and Discussed items >

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Type item Number Sbtus Description end Reference LER 50-348/1998-008-00 Closed Reactor Vessel Support Concrete Design Basis Temperature Exceeded Due To Closed Cooling Damper (Section E8.1).

eel 50-348, 364/98-05-02 Open Failure to identify Defacto 50.59 and Unreviewed Safety Question (USO) ,

(Section E8.1).

NCV 50-364/99-01-01 Closed inadequate Corrective Actions Results in Additional Scaffold Errors (Section M1.3)

l List of Inspection Procedures (IP) Used IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Prevent Problems IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operation IP 71750: Plant Support Activities IP 90712: In office Review of Written Reports IP 92700: Onsite Follow up of Written Reports IP 92903: Follow up - Engineering

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