IR 05000382/1997016

Insp Rept 50-382/97-16 on 970810-0920.Violations Noted: Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20211Q370
Person / Time
Site:	Waterford
Issue date:	10/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211Q353	List: IR 05000382/1997016 ML20211Q349 ML20211Q364
References
50-382-97-16, NUDOCS 9710220275
Download: ML20211Q370 (20)

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ENCLOSUREJ U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382 License No.: NPF 38 d

Report No.: 50 382/97 16 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: August 10 through September 20,1997 Inspectors: L. A. Kellor, Senior Resident inspector G. A. Pick, Senior Project Engineer L. J. Smith, Senior Reactor Inspector

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J. F. Melfi, Resident inspector, Arkansas Nuclear One Approved By: P. H. Harrell, Chief, Project Branch D

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ATTACHMENT: Supplemental Information

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9710220275 971017

PDR ADOCK 05000392 G POR

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EXECUTIVE SUMMARY Watertord Steam Electric Station, Unit 3 NRC Inspection Report 50 382/97-16 This routine, announced inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6 week period of resident inspectio Operations

• Material condition and housekeeping were generally good (Section 01.1).

• Operator response to a liquid toxic chemical spill at a nearby facility was excellent (Section 01.2)

• A violation with three examples was identified for the f ailure to complete operability assessments as required by administrative procedures (Section 04.1.b).

• The licensee identified similar concerns with the operability assessment program in a corrective action audit completed prior to this inspection (Section 04.1.b).

Maintenance e in general, the conduct of maintenance and surveillance activities was good (Section M1.1).

• From review of records for ten surveillance tests, it was determined that the tests implemented the Technical Specification requirements (Section M3.1).

• The failure to specify appropriate fastener torquing requirements for maintenance activities is identified as a noncited violation (Section M8.1).

Ennineerinn

• Discretion was granted in accordance with Section Vll.B.4 of the Enforcement Policy for a violation of design control related to auxiliary component cooling water flows and ultimate heat sink inventory (EA 97-414) (Section E2.1).

• Engineers demonstrated a very good understanding of the design and licensing bases in the resolution of the ultimate heut sink design deficiencies (Section E2.1).

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• Ouserved radiation protection activities were performed in accordance with procedures and were consistent with ALARA principles (Section R1.1).

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Beport Detaitt Summarv of Plant Status The plant operated at essentially 100 percent power throughout this inspection period, l. Operations 01 Conduct of Operations 01.1 General Comments (71707)

The inspectors performed frequent reviews of ongoing plant operations, control room board walkdowns, and plant tours. Observed activities were generally performed in a manner consistent with safe operation of the facility. Operator response to a nearby liquid chemical spill was excellent. Housekeeping and material condition were generally good. The inspectors observed several shift turnovers in the control room and determined that operators performed thorough discussions of issues affecting plant operations and good control panel walkdowns. Operators were knowledgeable of the reasons for annunciators and control panel deficiencie .2 Operator Resoonse to Nearby Chemical Spill On August 28,1997, while the inspectors were touring the control room, control room personnel overhcard a transmission on the Taft industrial Complex Communication radio related to a sulfur monochloride spill at a nearby chemical facility. The control room staff promptly entered Procedure OP 901-520, " Toxic Chemical Release," and isolated the control room. The shift technical advisor referred to Procedure EP-004-010, " Toxic Chemical Contingency Procedure,"

Revision 6, to assess the hazard to onsite personnel. While determining the hazard to onsite personnel, another transmission on the radio indicated that the spill had been contained, and no release from the facility had actually occurred. The control room staff determined that neither the broad range gas monitors nor the chlorine monitors detected the presence of any toxic chemicals and then returned the control room ventilation system to normal operatio The inspectors concluded that the t ontrol room operators responded promptly and coaservatively to the toxic chemical spill radio transmission. By the time the classification of the chemical hazard was completed, the licensee had received notification that no offsite release from the nearby chemical f acility had occurre The inspectors noted that the emergency plan implementing procedure used by the shift technical advisor and the shift superintendent to assess the significance of thc chemical spill was weak since Procedure EP 004-010 did not have the individuals evaluete the type of chemical hazard and take actions before assessing the weather conditions. The inspectors based this observation on the f act that ;ulfur monochloride ':: con.,idered a "large hazard," and an/ "large hazard" within a 2-mile radius required sheltering without considering the quantity or form of the chemical or the weather conditions, t

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4 During subsequent diwussions with emergency preparedness personnel, the inspectors determined that the licensee had established a Quality Action Team, on March 17,1997, to evaluate whether Procedure EP-004-010 established an appropriate level of response to chemical hazards by plant personne'. From review of the meeting minutes, the inspectors found that the licensee was n the process of addressing the order of actions and method used by operators to assess toxic chemical hazards offsite. The inspectors determined that the actions taken by the licensee to revise the procedure would address the identified concer Operator Knowledge and Performance 04.1 Operability Assessments Scope (40500, 71707)

The inspectors assessed the implementation of the operability assessment process to verify that Fcensee personnel properly performed immediate operability assessments. The inspectors reviewed and assessed selected condition reports, evaluated design documentation, and interviewed personnel, Obse.vations and Findinas The inspectors limited the population of condition reports reviewed to those initiated in 1997. The inspectors sampled approximately 520 condition reports and selected 29 for detailed evaluation. The condition reports were selected from both full power operations and shutdown conditions. Genersily, condition reports not selected for evaluation identified a process! Program problem, did not affect Technical Specification equipment, or resulted in the equipment being declared .

inoperable. The inspectors determined 22 of the immediate operability assessments to be satisfactory. The details of the other seven operability assessments are discussed below:

• In Condition Repart 97 0128, the licensee identified inadequate lubrication instructions for Emergency Diesel Generator Exhaust Fan HVRMFAN0025 '

. because the instrut tions riid not specify the amount of grease to be use The exhaust f an was hstalled in an inaccessible enclosure, and maintenance personnel greased the fan using 6 foot long copper tube with a remote grease fittin Operations personnel determined that tha fan remained operable. However,

' the condition report did not provide an adequate basis for the operability assessment. In the basis section, the operator discussed the problems associated with too little and too much grease and then stated that there was no short term operability concerns; however, the operator did not document why a short term operability concern did not exist. The inspectorn concluded this condition report had an inappropriately documented

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-3-operability assessment; however, no concerns regarding operability of the f an were identifie * Condition Report 97-0238 documented an apparent waterhammer in the containment spray riser on January 30,1997; however, the licensee did not initiate a condtion report until February 2,1997. The inspectors identified that the immediate operability assessment, combined with the condition description documented in the condition report, appropriately assessed the past inoperability of the piping. Since the containment spray system was already out of service, the licensee could have indicated the system would be evaluated prior to declaring it operable. Similarly, the licensee could have identified the immediate actions taken that allowed them to conclude the system remaine.d operable. The inspectors concluded this Condition Report had an inappropriately documented operability assessment but did not identify any violation of procedure requirement * In Condition Report 97-0258, the licensee identified, on February 3,1997, '

that the installed seismic restraints for the spent fuel handling machine did not agree with Machine Arrangement Drawing 5817-111317. In the operability assessment, the licensee stated that the spent fuel handling machine met the requirements of Technical Specification 3.9.7 without the seismic constraints; however, a description of why the spent fuel handling machine remained qualified without the restraint was not provided. The licensee stated that this was a documentation issue because, at the time the condition report was initiated, an engineer qualified to make seismic determinations had evaluated the field condition and concluded the spent fuel handling machine was acceptably restrained. The inspectors concluded that the licensee had not adequately documented the basis for the conclusion that the spent fuel handling machine remained operable, but agreed that no operability concern existed. The failure to document the basis for the operability determination is the first example of a violation of Technical Specification 6.8.1.a (50 382/9716-01).

Although the immediate operability evaluation by the engineer identified that the spent fuel handling machine remained seismically qualified, the inspectors determined that a formal esaluation would be required to demonstrate that the spent fuel handling machine met the design requirements for seismic loading, as specified in Section 9.1.4.1.2.b of the Updated Final Safety Analysis Report. The inspectors noted that Condition Report 97-0258 identified performance of a detailed evaluation as a corrective action and this action would confirm the engineer's evaluatio * In Condition Reports 97-0887 and -0888, the licensee identified that two temperature switches for the Core Protection Calculator Cabinet A high temperature alarm were found out of calibration. The licensee corrected the conditions and initiated a condition report for each temperature switch. The

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i i-4 I operator subsequently assessed the past operability of Core Protecticn Calculstor A. In both condition reports, the licensee stated that there was no evidence that the temperature in the cabinet exceeded the setpoint. The inspectors noted that the licensee did not positively describe the basis for why the high temperatures had not occurred. The inspectors concluded these condition reports contained an inappropriately documented operability assessment but did not identify any violation of procedure requirements.

• In Condition Report 97-0989, the licensee identified, on April 23,1997. that an incorrect thermal overload relay with different trip characteristics was installed in the control circuit for Valve EFW 2208, emergency feedwater ,

isolation valve. The licensee stated that this normally locked closed and l deenergized valve was used to isolate the emergency feedwater from the i steam generator blowdown system. The operator indicated on the condition l report that the installation of an incorrect overload retcy did not affect I Technical Specification / Technical Requirements Manual applicable equipment, so an operability assessment was not completed. The inspectors noted that Technical Specifications contain requirements for the emergency feedwater system and noted that the valve is Technical Specification applicable equipment. However, considsring the normal operating condition

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of the valve (deenergized closed in its safe position), the inspectors determined that the implicit conclusion that the system remained operable was correct. The failure to document an operability assessment for a Technical Specification / Technical Requirements Manual applicabic component is the second example of a violation of Technical Specification 6.8.1.a (50-382/9716-01).

The inspectors noted that, after Condition Report 97-0989 was provided to operations for an operability assessment, engineers identified as of July 31,1997, that incorrect overload relays were installed in the control circuits for Valves SI 502A(B), safety injection system hot leg injection isolation, and Valve SI 506B, safety injection system hot leg injection control. The inspectors noted that operations personnel did not document an operability assessment for these additional examples. The licensee stated that, as these new examples were identified, the engineer concluded that the difference in overload re'ay trip characteristics remained acceptable. The engineer determined it was not necessary to notify operations about the additional nonconforming condition The inspectors determined that the licensee was required to have a documented operability assessment for nonconforming conditions from the time of discovery until the engineers determined that the replacement component was acceptable and the design change approved. The inspectors agreed that the valves remained operable; however, it was concluded that appropriately qualified personnel had not perforrned an operability assessment for the use of incorrect overload relays for Valves St 502A(B)

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. and Valve SI 506B. The failure to perform this assessment is the third example of a violation of Technical Specification 6.8.1.a (50-382/9716-01).

• In Condition Report 97-0890, a system engineer identified that a potentially unanalyzed, active single failure existed in the battery room exhaust syste The exhaust system was designed to ensure that hydrogen did not accumulate to explosive concentrations. Each battery room contains two

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exhaust fans that discharge to a common exhaust plenum. A gravity damper

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installed at the discharge of each exhaust fan, prior to the plenum, was designed to open or close if the associated fan was operating or secured, respectively. The system engineer noted that if a gravity damper for a

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secured fan sticks open, the operating fan would draw air from the battery room and also from the ventilation ducts associated with the secured fan.

, This could potentially diminish the exhaust flow from the battery room below flow rates needed to maintain hydrogen accumulation less than explosive

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The system engineer visually inspected the gravity dampers and the associated exhaust fans and found deenergized Exhaust Fan SVS-306B rotating backwards and its associated gravity damper stuck open. The licensee restored the damper to its correct position and noted that the fan rotation halted. The licensee found no other secured fans were rotating backwards. The licensee installed caution taas on each fan control switch,

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which required the operators to verify that the idle fan is not rotating, after

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switching running fans. This would confirm that the damper had closed as designed.

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Because of the short time span between identifying the adverse condition,

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instaliing the caution tags, and performing the operability assessment, the inspectors noted that the shift technical advisor appropriately ast,essed operability for the as lef t condition. The inspectors agreed that the fans were operable with the compensatory measures in place and found no problerns with the timeliness or content of the immediate operability assessmen The in-House Events Assessment Group expressed concem that the

immediate operability issessment should have addressed the as-found condition without considering closure of the damper and placement of the

< caution tags. The Group requested that Licensing personnel determine if the

! system remained operable with the failed open damper. In the response to the Group's question and in the reportability determination, Licensing personnel concluded that the batteries remained operable with the damper failed open since no explosion had occurred dat disabled the batteries. The inspectors did not agree with this conclusion since personnel failed to consider the ventilation suppurt equipment, as required in the definition of operabilit .- _

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Table 9.4-11, "RAB Cable and Switchgear Areas Ventilation System Failure j Modes and Effects Analysis," of the Updated Final Safety Analysis Report, 1 i documented the failure of an exhaust fan.- The inspectors noted that the

! design included a redundant operable exhaust fan to prevent Jn unacceptable t

increase in hydrogen concentration. The inspectors noted that, while failure !

j modes and effects analyses usually include bounding active failures, the

{ failure of the gravity dampers had not been analyzed. Since a gravity

! damper f ailure could potentially result in an increase in hydrogen j i concentration to explosive concentrations and since controlling hydrogen

! concentration was a goal of the system, the inspectors concluded the ticensee had not provided an adequate basis to support the conclusion that j the batteries remained operable in the as found condition (damper failed

open) in the reportability evaluation.

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The licensee agreed that they had not developed an adequate basis for their

! past operability determination and their reportability determination.

j in addition, the system engineer stated that they were not able to easily demonstrate that an explosion in one battery room would affect only one i battery room since the battery rooms are adjacent and the walls were not specifically designed to contain a hydrogen explosion, in response to the j- inspectors' concern, the licensee performed an analysis of the effects of the

degraded flow path to determine whether or not explosive concentrations of

hydrogen could accumulate if a gravity damper for a secured fan failed open had been planned. The licensee performed Work Authorization 01160647, i " Evaluation of the Effect of a Single Failure of a Battery Room / Battery Fan Room Gravity Damper," that determined the minimum air flow from a battery-

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room with a damper failed open to be 123 acfm. _ Revised Calculation B13.17, " Battery Room Air Flow Required To Limit Hydrogen

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Concentration," identified that the design air flow required to limit the hydrogen concentration to 2 percent was 28 acfm. Based on this additional information, the inspectors agreed that the batteries remained functional and the as found condition was not reportabl Prior to this inspection, the licensee had completed a corrective action program audit that identified similar concerns for documentation of operability assessments as identified by the inspectors. The licensee had not had time to implement any corrective actions based upon the audit finding Conclusions From review of condition reports, the inspectors concluded that, overall, f acility personnel generally performed well documented operability assessments with good technical basis. Three examples of f ailure to properly perform or document an appropriate operabilhy assessment were identified. Generally, the poorly documented operability assessments resulted from a failure of personnel to identify

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l j the information used to conclude the equipment remained operable. These fellinto two categories: (1) failure to identify what personnel did to ensure the components remained operable and (2) untimely operability assessment i 11. Maintenance

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M1' Conduct of Maintenance (62707,61726)

M 1.1 General Corgments l t

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The inspectors observed all or portions of the following maintenance and

surveillance activities. as specified by the referenced work authorization (WA): l t

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[ -* WA 01163149 Investigate / Repair Erroneous Wet Cooling-Tower Level

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• OP-903-050 Pump and Wlve Operability Test for Component i- Cooling Water Pump B l * WA 01163422 Wet Cooling Toser B Level Transmitter Reading Higher.

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• WA 01163410 Va ve CAP-102 Would Not Stroke Closed -

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i in general, the inspectors found the conduct of these maintenanca and surveillance i activities to be good. All r:tivities observed were performed with the work packag_

ar.d/or test procedures present and in active use. When applicable, appropriate i'

radiation cor. trol measures were implemented. The inspectors observed supervisors

monitoring joc progress and quality control perso'inel present whenever required by proced"re.

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M1.2 Wet Cooling. Tower B Level Transmitter Readinc _Hioher than Actual Level i l

' Insoection Scope (61726)

i The :nspectors' observed portions of the level Transmitter ILT-7079B changeout ,

associated with WA ')1163422 and reviewed the completed paperwork.

, _ Observations and Findinos- _

On September 15,1997, a chemistry technician observed that the actsi level of

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- the Wet Cooling Tower B basin water level was lower than Technical Specification 1~ requirements, although the indicated level was 99 percent. Technical Specifications require that the basin level be maintained greater than 97 percent. Shortly after the i

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discovery of the low basin level, operators ensured that adeauate level would be maintained by overflowing the basin and initiated WA 01163422 to request troubleshooting of the level transmitte The licensee checked the level transmitter and adjusted the iristrument into calibration during the last refueling outage after technicians found the transmitter reading 1.6 percent low. On September 2, technicians found that the basin level transmitter had drifted high by 1.7 percent and, subsequently, calibrated the transmitter. During evaluation of the deficiency identified by the chemistry technician, instrumentation and control technicians found the level transmitter again reading 2.1 percent high. Consequently, the licensee replaced the level transmitter with an equivalent transmitter, which was evaluated under Substitute Part Equivalency Evaluation Report 970181 The inspectors reviewed this evaluation and found it acceptable. The inspectors also noted that the technicians followed the work installation instructions and appropriately verified that the new transmitter functioned properly, Conclusions The engineering evaluation was done properly and the work done according to the work instruction M3 Maintenance Procedures and Documentation M3.1 Review of Surveillance Procedures The inspectors reviewed selected surveillance procedures, with a specified trequency of 18 months or longer, completed during the refueling outage. The review was performed to verify that the surveillance procedure met the intent of the Technical Specification and was technically adequate, recorded data was complete, acceptance criteria were met, and any test discrepancies were properly resolve The inspectors found that the surveillance procedures reviewed (listed in the attachment to this report) were acceptable and had been completed within the sun'eillance interval. The data was complete and the surveillance tests met the acceptance criteri Based on the results of the review, it was concluded that the licensee had j adequately verified the Technical Specification surveillance requirements.

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M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Unresolved item 50 382/9702-03: Appropriate torquing requirements not specified during emergency diesel generator maintenance activitie On February 3,1997, during replacement of air start check Valve B, the outlet flange for Valve EGA1618 cracked because mechanics excessively torqued the 3/4-inch bolts. The mechanics inappropriately utilized Procedure MM-001-068,

" General Torquing and Defensioning Practices," checklists rather than the vendor manual requirements. All of the excessively torquod valves were subsequently replaced. The licensee determined the root cause to be unclear and difficult to use procedures / instruction The licensee audited 100 work packages to determine if other instances of excessive torquing had occurred. Six discrepancies were identified and none of the discrepancies were considered to be operability concerns. Corrective actions included enhancements to Procedure MM-001-068, instructions to work package planners to provide specific torque values in the work package rather than referring to procedures / technical manuals, and additional training to planners and mechanics that provided guidance and clarification on use of Procedure MM-001-068 andlis

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The inspectors reviewed the additional examples whero components were excessively torqued and concurred with the licensee's assessment that there were no operability concerns. The inspectors concluded that the corrective actions were adequat Procedure MM-001-068, Section 5.2.1.1, stated, in part, that if no torque values are given in vendor information, then determine torque values by using attachments to the procedure. The feiture to recognize the specific torque values for the air start check valves, as specified in the vendor technical manual, resulted in the f ailure to follow Procedure MM-001-068, a violation of Technical Specification 6.8.1.a. This nonrepetitive, licensee identified and corrected violation is being treated as a noticited violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic Specifically, the violation was identified by the licensee, was not willful, actions taken as a result of a previous violation should not have corrected this problem, and appropriate corrective actions were completed by the licensee (50-382/9716 02).

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EI Conduct of Engineering .

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E Condition Report Corrective Actions

. Scope (40500, 717071-I The inspectors performed this inspection to verify licensee personnel properly 1 performed an effective operability assessment, as required by the corrective action

)- ' program for degraded and nonconforming conditions. In addition, the inspectors reviewed and assessed the corrective actions for Condition Report 961534, which described the failure of reactor trip breakers to clos Observations and Findinas

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, Condition Report 96 1534 identified that reactor trip breakers require multiple I

attempts to close onto the bus after testing. The inspectors identified 17 separate condition reports, from late 1995 through the beginning of Refueling Outage 8, that

documented the failure of the breakers to close on the first attempt after being -

tripped during a surveillance test. In each instance, operators correctly concluded p that the breakers teraained operable since the breakers continued to perform their intended safety function of opening to allow the control element assemblies to drop into the core.

i j Because of the large number of failures to close, the licensee became concerned

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. with the reliability of the breakers and initiated a trend / review condition report each

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time the deficiency occurred. In addition, the licensee procured and installed nine

refurbished rractor trip breakers since they suspected that wear from aging was the

- root cause. '/ollowing installation of the refurbished breakers during Refueling .

Outage 8, the licensee experienced seven failures of the breakers to close following

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' testing. During this inspection,-the licensee indicated a formal root 'cause analysis was initiated.to identify additional actions to take to resolve the reliability concerns with the breakers. The licensee indicated industry information would be reviewed and evaluated to determine if other licensees have experienced similar problems.

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The inspectors concluded that the licensee actions to replace the reactor trip breakers with refurbished breakers was reasonable method to resolve the problein.

' Conclusiong

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The inspectors noted that the licensee had identified the f ailure of reactor trip -

' , breakers to close following testing as a trend / review condition report. The corrective actions implemented in the last refueling outage were not c

:mpletely 4 successful; however, the licensee continued to evaluate actions to resolve this hardware deficienc , - , - . . . . , .- ~ .---- - = - - - - ,

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-11-E2 Engineering Support of Facilities and Equipment i

E Nonconservative Desian Assumptions for Heat Removal From the Plant Scope (92700)

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j The inspectors assessed the safety and regulatory significance related to

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.nonconservative design assumptions of the amount of heat transferred to the j ultimate heat sink.

' Oblectives and Findinas The auxiliary component cooling water system operates in conjunction with the 4 component cooling water system and the wet cooling tower basin to serve as the ultimate heat sink. The component cooling water system removes 60 perc6nt of I the accident heat load through the dry cooling tower. The auxiliary component cooling water system removes any additional heat load and transfers.it to the wet i cooling tower basin. The auxiliary component cooling water system was designed

to supply a fixed 850 gpm flow to the essential chillerc, which supply rcom cooling .

for safety-related equipment and supplies at least 4500 gpm flow to the component  !

cooling water heat exchanger to transfer the heat to the ultimate heat sink. The component cooling water system supplies cooling water to loads such as the contaiament fan coolers, safety-relateo pumps, shutdown cooling heat exchangers,

and othei nonessential loads such as the spent fuel post cooling heat exchange The auxiliary component cooling water flow through the component cooling water -

i heat exchanger is controlled by increasing or decreasing the flow dependent upon the component cooling water inlet temperature.

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'In August 1996, the licensee questioned whether a 13'F temperature uncertainty

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was included in the' calculations for the ultimate heat sink related to auxiliary

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component cooling water flow through the component cooling water heat exchanger, in Octobar 1996, during review of Information Notice 96-01, " Potential

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For High Post Accident Closed-Cycle Cooling Water Temperatures to Disable Equipment important to Safety," engineers recognized that heat rejection to the ultimate heat sink had been miscalculated and could be higher since, originally,-

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engineers assumed the containment fan coolers were partially fouled. While .

I developing the Technical Specification change to identify the required amount of

ccomponent cooling water flov' through the containment fan coolers and the number of containment fan coolers available, the licensee evaluated the pressure / temperature conditions of the containment using CONTElv1PT in -

April 1997. The inspectors noted that the Technical Specification change was a

, required corrective action in response to previous escalated enforcement for low component cooling water flow through the containment fan coolers (see NRC i i- Inspection Report 50-382/97-03).

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- 12-As a result of the CONTEMPT computer run, the licensee determined that the original design analysis used nonconservative assumptions. The licensee identified ~

nonconservatisms in the Updated Final Safety Analysis Report value for the amount of heat transferred to the ultimate heat sink from the containment and other safety-related loads during an accident (refer to Licensee Event Report 50-382/97 015).- Specifically, during devele :.it of Calculation AN-LOU 8,

" Ultimate Heat Sink Study," the licensee f ailed to in . ado a i3 F instrument uncertainty in the control point for Valves ACC-126A(B), auxiliary component cooling water system flow control valve; failed to consider clean containment fan cooler tubes; and used too low of an overall heat transfer coefficient for the shutdown cooling heat exchangers frecently, special testing identified a higher heat

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Each of the above items were conservative relative to the pressure increase in the containment, but were nonconservative relative to increased heat transfer to the ultimate heat sink and any required hventory. Cooler water to both clean -

containment fan cooler (heat exchanger) tubes and a more efficient shutdown cooling heat exchanger _ heat transfer coefficient increased t's heat transfer and reduced the available volume margin in the ultimate heat sink basins. The licensee documented this condition in Condition Report 97-0777. As corrective action for Condition Report 97 0777, the licensee: (1) demonstrated that the system remained operable with the previous existing meteorological conditions, (2) conducted a root.cause analysis, (3) initiated Licensing Document Change Request 97 0201 to change the Updated Final Safety Analysis Report, and (4) initiated Technical Specification Change Request NPF 38197 to delete the allowance for more than three dry cooling tower fans to be inoperable at one tim As a result of the increased heat transfer efficiencies, the licensee determined that the maximum possible ultimate heat sink heat load, including nonessential auxiliary heat loads, can be at high as 199.2 E6 BTU /hr, which exceeded the Updated Final Safety Analysis Report specified value of 178.35 E6 BTU /hr. .The licensee concluded that a single ultimate heat sink basin had sufficient inventory to cool all essential, safety-related loads for 30 days; however, the inventory would need to be supplemented with 44,000 gallons of makeup water if the nonessential spant fuel pool cooling heat exchanger continued to be used. The licensee included the nonessential spent fuel pool cooling system (a component cooling water system load) as an ultimate heat sink load in 1996 after completing a design basis revie In responsa to this deficiency, the licensee concluded that supplementing a single train of the ultimate heat sink to compensate for losses resulting from nonessential loads was the most conservative course of actio The inspectors confirmed that the increased efficiencies and lower flows increased'

the heat load for the ultimate heat sink basins sad resulted in insufficient available inventory, without makeup, for the combined essential and nonessential loads. The inspectors reviewed the Updated Final Safety Analysis Report, the safety evaluation report, and other regulatory documents and concluded that the spent fuel pool

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-13 cooling heat exchanger was a nonessential ultimate heat sink load, in addition, preliminary reviews of the Technical Specification change request by NRC personnel did not identity any safety or equipment operabdity concerns existed that would prevent startup of the facility from the refueling outage.

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The licensee designed the auxiliary comr'onent cooling waict cystem to throttle the cooling water suppF/ to component coo nng watm heat exchanger to maintain tha temperature at the setpoint (115 F) and to supply 850 gpm component cooling water flow to the essential chiller. The licensee determined that, at flows less than 510 gpm, the essential chillers would trip. With the increased heat load for the component cooling water heat exchanger requiring additional ficw and the flow to the essential chiller required to be greater than 510 gpm to prevent tripping the chiller units, the licensee determi,1ed that the new maximum wet bulb temperature had to remain less than 91 F to prevent flow to the chiller decreasing below 510 gpm. In reviewing past operability, the licensee concluded in Licensee Event

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Report 50-382/97-015 that there were 70 instances in 1993 that could have resulted in both trains of essential chillers tripping because of low flot for only a few hours each day.

The root cause analysis for Condition Report 97-0777, generated to address this issue, specified the followirig corrective actions: (1) reviso calculations to

demonstrate that makeup is available to ensure continuous capability of the wet cooling tower to perform its safety function, (2) demonstrate that makeup can be

provided to the wet cooling tower basins by the nonessential, seismic Category 1

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cross-connect line and the circulating water pipe gravity feed valves, (3) demonstrate by a flow test that the locked throttled position of Valves ACC-127A(B), auxiliary component cooling water flow control manual iso!ation valve, ensured a design flow of 850 gpm to the essential chiller and at least 4500 gpm to the component cooling water heat exchangers, and (4) revise operating procedures to specify the correct throttle position for

Valves ACC-127A(C).

The inspectors verified that Special Test Procedure 01156126, " Wet Cooling Tower Basin Cross-Connect and Circulating Water Makeup to Wet Cooling Tower Basing Flow Verifications (MODES 5-6)," demonstrated the ability to makeup to an ultimate heat sink basin with the other basin through a nonessential, Seismic Category 1 cross-connect line and by gravity feeding through a nonsafety related circulating water line that has accessible isolation valve Tha inspectors confirmed that during Refueling Outage 8, the licenree performed the auxi!iary component cooling water flow test in accordance with Procedure PE-004-024, "ACCW & CCW System Flow Balance." The auxiliary component coolir*g water flow test demonstrated *. hat the licensee could achieve 4 both 4500 gpm to the component cooling water heat exchanger and 850 gpm to i

the essential chillers. The licensee established throttle valve positions for

Valves ACC 127A(B) to ensure sufficient flow through the component cooling water

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-14 heat exchanger without flow to the essential chillers sing below 850 gp The licensee revised Procedure OP-002-001, " Auxiliary t,omponent Cooling Water,"

to specify the correct throttled positions for Valves ACC-127A(B).

Although this deficiency resul:ed from inadequate control of design information that could liave resulted in inoperability of the essential chillers had an accident occurred, NRC concluded that no violation of regulatory requirements would be cited in accordance with Section Vll.B.4 of the Enforcement Policy. Specifically, the licensee: (1) identified this condition while resolving Enforcement Action 97-099 (see NRC Inspection Report 50-382/97-03); (2) the root cause is similar to the previously issued violation, in that the violation resulted from inadequate initial design; and (3) it was promptly corrected by establishing a flow balance and throttling auxihary component cooling water flows to ensure the design basis functions could be accomplished. Also, although the deficiesiey was related to poor understanding of design information, different systems were involved; therefore, this deficiency did not aubstantially change the safety significance or character of the previous escalated action, C_gnglupinna Although e violation of design control occurred related to auxiliary component cooling water flows, the licensee met all the criteria for discretion as identified in Section Vll.B.4 of the Enforcement Policy since the licensee identified this during their corrective actions for a previous enforcement action. The inspectors noted that engineers identified this design denciency as a result of a rigorous evaluation of the ultimate heat sink design bases, which represented a very good understanding of the design and licensing base E3 Miscellaneous Engineering issua

- E (Closed) Licensee Event Reoort 50-382/96-005: Failure to meet Technical Specification action requirement The licensee initiated this licensee event report after determining that on several occasions operators failed to properly enter Technical Specification limiting conditions for operation. Specifically, operators f ailed to enter Technical Specification 3.7.4.f for the outs'de ambient weather condition Violation 50-382/9613 03 documented this same deficiency and this violation was closed in NRC Inspection Report 50 382/97 1 The inspectors verified that the licensee had established controls for engineering inputs, including operator requirements for review of engineering inputs. The inspectors also noted that operators have improved their ability to recognize and enter all applicable limiting conditions for operation.

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f -15-r IV. Plant Support R1 Radiological Protection and Chemistry Controls R General Comments (71750)

Routine tours of the ra:^iological controlled area revealed that: (1) posting of areas was in accordance with requirements, (2) controlled access areas wue properly locked, (3) personnel were wearing ;ppropriate dosimetry and protective clothing, and (4) the small number of contaminated areas continued to be a strengt _

The inspectors concluded that observed radiation protection activities were performed in accordance with procedures and were consistent with ALARA principles, F8 Miscellaneous Fire Protection issues

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F (Closed) Violatior_M-382/9517 02: Fire brigade training progra This violation resulted from a f ailure of the licensee to conduct initial ar.d refresher traines for extinguishing cable tray fires as required by 10 CFR Part 50, Appendix R. As corrective action, the licensee indicated that they would provide the requir to ..UC onal fire brigade training on cable tray fire The inspectors reviewed the course description, initial fire brigade training lesson plan, and fire brigade refresher training lesson plan. From this review, the inspectors confirmed that the licensee presented the required training on cable tray

.. f res, in addition, the inspectors determined that the fire brigade members had received the required trainin V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management September 25,1997. The licensee acknowledged the findings presente _

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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i o-ATTACHMENT SUPPLEMENTAL INFORMAllON PARTIAL LIST OF PERSONS CONTACTED Licensee F. J. Drummond, Director Site Support C. M. Dugger, Vice-President, Operations E. C. Ewing, Director Nuclear Safety & Regulatory Affairs T. R. Leonard, General Manager, Plant Operations D. C. Matheny, Manager, Operations G. D. Pierce, Director of Quality D. W. Vinci, Superintendent, System Engineering A. J. Wrape, Director, Design Engineering

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INSPECTION PROCEDURES USED 40500 Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems 61726 Surveillance Observations 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities 92700 Onsite Followup of Written Reports 92902 Followup - Maintenance ITEMS OPENED CLOSED. AND DISCUSSED Opened 50 382/9716-01 VIO Failure to document basis for operability determination (Section 04.1.b)

50-382/9716-02 NCV Appropriate torquing requirements not specified during maintenance activities (Section M8.1)

Closed 50-382/9702-03 URI Appropriate torquing requirements not specified during

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emergency diesel generator maintenance activities (Section M8.1)

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C-2-50-382/9716-02 NCV Appropriate torquing requirements not specified during maintenance activ; ties (Section M8.1)

50-382/96-005 LER Failure to meet Technical Specification action requirements (Section E8.1).

50-382/9517-02 VIO Fire brigade training program (Section F8.1),

LIST OF ACRONYMS USED acfm actual couic feet per minute ALARA as low as is reasonably achievable BTU /hr British thermal units per hour gpm gallons per minute NRC Nuclear Regulatory Commission PDR Public Document Room DOCUMENTS REVIEWED PROCEDURES Ml-03-320 Containment Sump Level Loop Check and Calibration, Revision 3 Ml-03-321 Containment Leak Detection Measurement System Calibration, Revision 3 Mi-03-409 Functional Test of Containment Air Cooler Flow Switches, Revision 4 MM-03-019 Diesel Fuel Oil Storage Tank inspection, Revision 4 MM-07 004 Functional Test of Pressurizer Safety Valve, Revision X NE-02 020 CEA Insertion Time Measurement, Revision 6 OP-903 028 Pressurizer Heater Emergency Power Supply Functional Test, Revision 4 OP-903-033 Cold Shutdown IST Valve Tests, Revision 11 OP-903-097 Pressurizer Heater Capacity Verification, Revision 5 OP 903-098 RCS Vent System Functional Check and Lineup Verification, Revision 13 PE-05-031 Emergency Diesel Dual Start Test, Revision 2 TECHNICAL SPECIFICATION SURVEILLANCE PROCEDURES REVIEWED (SEE SECTION M3,1)

TECHNICAL INTERVAL TOPIC SPECIFICATION 4.1. months Control Element Assembly Reed Switch Transmitter Indicator Channel

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-3-4.4. Refueling Pressurizer Code Safety Test 4.4.3. months Pressurizer Heater Capacity 4.4.3. months Pressurizer Heater Emergency Power Supply Functional Test 4.4.3. months Auxiliary Spray Valve Cycle 4.4.5 '.b 18 months Containment Sump Level Instrument Calibration 4.4.5. months Containment Air Coolers Flow Switch Functional Check 4.4.10 18 months Reactor Coolant System Vent Path 4.8.1.1.2.g 10 years Emergency Diesel Generator Simultaneous Start 4.8.1.1.2.h 10 years Emergency Diesel Generator Fuel Oil Storage Tank inspection

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