IR 05000397/1996006
| ML17292A328 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/20/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A324 | List: |
| References | |
| 50-397-96-06, 50-397-96-6, NUDOCS 9606240221 | |
| Download: ML17292A328 (27) | |
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No:
50-397 License No:
NPF-21 Report No:
50-397/96-06 Licensee:
" Washington Public Power Supply System facility:
Washington Nuclear Project-2 Location:
3000 George Washington Way P.O.
Box 968, MD 1023 Richland, Washington Dates:
March 31 - May ll, 1996 Inspectors:
R.
C. Barr, Senior Resident Inspector G.
D. Replogle, Resident Inspector G.
W. Johnston, Senior Project Inspector T. 0. McKernon, Senior License Inspector Approved by:
H. J.
Wong, Chief, Project Branch E
Division of Reactor Projects ATTACHMENTS:
Partial List of Persons Contacted List of Inspection Procedures Used List of Items Opened, Closed, and Discussed List of Acronyms
/
960624022i 960620 PDR ADOCK 05000397
EXECUTIVE SUMMARY Washington Nuclear Project-2 NRC Inspection Report 50-397/96-06 This routine announced inspection included aspects of licensee operations, engineering, maintenance, and plant support.
The report covers a 6-week period of resident inspection.
~0eretione Control room personnel exhibited effective command, control, and communications during operation and surveillance activities.
Their communications were characterized by repeat-back of directions and clear acknowledgments of observed indications and alarms.
Senior operations management and supervision were frequently present (Section 01.2).
New fuel receipt, reactor vessel disassembly, and defueling were conducted safely with evolutions being well planned and implemented (Section 01.3).
Preparation and testing of cranes and hoists to support new fuel receipt, reactor vessel disassembly, and defueling were insufficient to identify problems with this equipment (Section 01.3).
The licensee identified that all core shroud bolts had not been unlatched as specified in procedures.
It appears that corrective actions for a past similar problem to assure the adequate verification of moisture separator shroud holddown bolt position were not effective.
This was considered a violation of 10 CFR Part 50, Appendix 8, Criterion XVI (Section 01.3).
Maintenance Maintenance tasks and surveillance testing observed during this inspection were generally performed and documented properly (Section M1.1).
The inspectors identified instances which reflected weaknesses in the control of maintenance activities.
In these instances during work on a
diesel generator (OG)
room heating, ventilation, and air conditioning (HVAC) damper, maintenance workers performed work without appropriate procedures.
The inspectors identified another example of a violation described in NRC Inspection Report 50-397/96-02 (Violation 397/9602-01)
regarding inadequate work instructions associated with maintenance on OG room HVAC Damper OMA-AD-21/2 (Section M8.1).
The inspectors identified another example of a violation described in NRC Inspection Report 50-397/96-02 (Violation 397/9602-01)
regarding inadequate instructions for cleaning of the OG room damper (Section MS. 1).
En ineerin The operability determination for the standby gas treatment system (operable, but degraded)
was appropriate.
However, engineering personnel failed to use some pertinent design basis information when performing the operability determination, thereby not realizing that single failure protection was lost (Section E2. 1).
The inspectors identified one minor nonconformance with the FSAR concerning the standby service water (SSW) keep-full system (a nonsafety-related system)
(Section E2.3).
Troubleshooting efforts associated with a failed DG damper actuator were performed in a thorough, well thought out manner and were effective at identifying the cause of the failure (Section ES. 1).
The inspectors identified a violation related to the licensee's ineffective corrective actions in response to fouling of the SSW control room coolers (Licensee Event Report (LER) 93-31, Revision 1).
These actions were not effective at preventing recurrence.
Fouling of the room coolers exceeded design basis limits a second time in August 1995.
Hydrogen peroxide additions have dramatically improved the quality of the water in the SSW system spray ponds (Section E8.2).
Plant Su ort Observed outage activities which required radiological controls were generally well planned, implemented, and controlled (Section Rl. 1).
Plant access controls had improved this outage as compared to previous outages (Section Sl.l).
The licensee was responsive in correcting fire protection equipment deficiencies identified by the inspectors; however, the inspectors noted the deficiencies were obvious problems that tours by either the fire protection staff or plant staff should have identified (Section FP2. 1).
-3-Summar of Plant Status For the duration of the inspection period the plant was shut down in Mode 4 or Mode 5 for Refueling Outage Rll.
I.
0 erations
Conduct of Operations 01.
1 General Comments 71707 Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations.
The conduct of operations was generally professional and safety conscious.
01.2 Control Room Observations 71707 71715 a.
Ins ection Sco e
During the inspection period, observations of control room outage activities were made.
The inspectors observed control room activities associated with control room modification work, balancing flow in service water system Train A, and testing Valve SW-V-12A with degraded voltage.
The inspector also performed plant tours with equipment operators during backshift periods.
b. Observations and Findin s
The inspectors observed that confusion and noise in the control room had been reduced.
Operators were focused on plant conditions and maintaining spent fuel pool cooling using residual heat removal (RHR) system Train B
despite the ongoing control room panel modification work.
Shift turnovers were well organized and conducted.
The individuals involved were well informed and contributed to a well-balanced shift briefing.
The inspector noted the frequent presence of senior operations management and supervision.
The control room supervisor regulated entry by persons other than operations personnel by querying their need to be in the control room and indicating terms of their access.
The areas close to the control room panels were free of extraneous material and housekeeping was good, despite much work involving installation of the control room panel modifications.
Equipment operators were informed and provided detailed information related to their plan't areas of responsibility.
Licensee personnel conducted testing activities associated with restoring systems to an operable status in an orderly fashion.
Data collection,
test coordination, requisite signoffs, and coordination with the operating crew were accomplished satisfactorily.
The inspectors'ackshift observations of equipment operator activities indicated the operators were knowledgeable of their plant assignments and possessed a questioning attitude.
When discrepant conditions were identified, the operators were responsive in reporting the condition to the operating crew and contacting the appropriate system engineer.
Additionally, the inspectors observed training department preparations for instructing licensed operators on the digital feedwater control system's modification.
The training department instructors were knowledgeable of the subject matter and developed a well-organized course of instruction.
The planned instruction integrated classroom, simulator, and in-plant walkthroughs.
Conclusions Control room command, control, communications, and prebriefing of activities were good.
The inspectors noted the frequent presence of senior operations management and supervision.
New Fuel Recei t Reactor Disassembl and Defuelin 60705 60710 Ins ection Sco e
60705 60710 The inspectors observed selected portions of new fuel receipt, reactor vessel disassembly, and reactor defueling.
This inspection also included review of procedures and documents related to these activities.
In addition, the inspectors observed the licensee's followup of a number of events associated with these activities.
Observations and Findin s
The inspectors found that new fuel receipt, reactor vessel disassembly, and defueling were conducted safely with evolutions being well'lanned and implemented.
When problems were encountered with an activity, work was stopped and the problems resolved.
Resolution of the problems was generally effective.
Preparations of Cranes and Hoists for Refueling Activities:
The inspectors noted that the licensee's preparation of cranes and hoists to support new fuel receipt, reactor vessel disassembly, and defueling did not identify problems with this equipment.
As a result, personnel were sometimes challenged during evolutions to place fuel and components in safe configurations prior to resolving the equipment malfunction.
For example, during new fuel receipt, the jib crane experienced a problem that resulted in a
new fuel assembly being suspended approximately halfway in the new fuel vault.
The licensee adequately secured the fuel
assembly during the repair of the jib crane.
The licensee initiated a
number of problem evaluation requests (PERs)
to address each crane/hoist issue.
Based on the number of problems, the licensee initiated a
trending PER to address the broader problems associated with cranes and preparation for refueling activities.
moisture Separator Unlatching:
The inspectors conducted a followup inspection of a licensee-identified event that occurred during the disassembly of the reactor vessel.
Following the unlatching and the independent verification of unlatching of the 36 moisture separator holddown bolts, a craftsman installing reactor main steam line plugs identified that one of the moisture separator holddown bolts had not been unlatched.
The licensee stopped vessel disassembly activities and developed a recovery plan.
Licensee personnel subsequently disengaged the holddown bolt and the moisture separator was successfully removed.
The licensee initiated PER 296-0264 to document and resolve this issue The licensee concluded that four items contributed to the inadequate unlatching of the holddown bolts:
lack of communication during crew turnover, turbulence in the reactor water caused by the operating RHR pump, lack of adequate signoffs (a signoff for completion of the unlatching of all 36 holddown bolts, rather than a signoff for the unlatching of each holddown bolt),
and lack of use of required support personnel during verification.
As corrective actions, the licensee plans to revise procedures to include an attachment for latching and unlatching and a step to secure shutdown cooling before latching and unlatching evolutions.
The inspectors noted that adequate unlatching and verification of the moisture separator bolts had been previously identified as a problem.
On June 25, 1994, the licensee was not able to remove the moisture separator because one of the holddown bolts had not been unlatched, even though all the holddown bolts had been verified as unlatched.
A violation was issued at that time against Technical Specification (TS) 6.8.1 for inadequate verification (50-397/9419-02).
The licensee concluded that impaired visual conditions caused by water movement in the reactor vessel caused the event.
As corrective action, the licensee revised Plant Procedure Manual (PPN) 10.3.6,
"Reactor Vessel Steam Dryer and Moisture Separator Removal and Replacement."
to state,
".
.
.
independent verification should be provided by underwater camera inspection" and trained the craftsmen on the practice of unlatching the holddown bolts.
In the most recent instance of an unlatched holddown bolt, the individual who performed the unlatching had difficulty in performing the evolution due to flow turbulence deflecting the unlatching tool.
When the flow was secured, he inadvertently failed to unlatch the holddown bolt that he had
been working on.
The independent verifier had used an underwater camera to determine if the bolts were unlatched, but did not keep track of the number of holddown bolts.
Each individual signed that he had unlatched all 36 holddown bolts.
The individual who identified the unlatched bolt was aware of the past problems with unlatching the nolddown bolts and had participated in training on the subject.
The cause of the unlatched bolt appears to be that the licensee did not take effective corrective action to assure adequate verification of moisture separator holddown bolts, a significant condition adverse to quality.
CFR Part 50, Appendix 8, Criterion XVI, states, that for significant conditions adverse to quality that actions shall be taken to preclude repetition.
The failure to take adequate corrective actions was an example of a violation of Criterion XVI (Violation 50-397/9606-01).
(A response to the above violation is not required see Notice of Violation.)
01.4 E ui ment Ta in 71707 The inspectors observed selected equipment for which tagging requests had been initiated and verified that tags were in place and the equipment was in the condition specified.
Operational Status of Facilities and Equipment 02.1 En ineered Safet Feature S stem Walkdowns 71707 The inspectors used Inspection Procedure 71707 to walk down accessible portions of the following engineered safety feature systems:
RHR Trains A and
Standby Gas Treatment Trains A and
High Pressure Core Spray System DG (Division 3)
Division 1 of the Electric Distribution System Reactor Core Isolation Cooling System Low Pressure Core Spray (LPCS)
System Remote Shutdown Panel High Pressure Core Spray System Equipment operability, material condition, and housekeeping were acceptable in all cases.
The inspectors identified no substantive concerns as a result of these walkdowns.
miscellaneous Operations Issues (92901)
08. I Closed Violation 50-397 9424-02:
failure to recognize suppression pool level was in excess of e1.75 inches, contrary to the TS Limiting Condition for Operation; failure to make a timely log entry; and failure
to enter the Emergency Operating Procedures, as required.
The inspector verified that the corrective actions had been implemented'I.
Maintenance Ml Conduct of Maintenance Ml. 1 General Comments a.
Ins ection Sco e
61726 62703 The inspectors observed all or portions of 'the following work order tasks and surveillance activities:
PPM 7.4.8.1.1.2.5B:
PPH 7. 4. 7. 1. 1. 1:
PPM 8.3.374:
WOT ZV09-01:
WOT MY01-01:
WOT HG70-01:
WOT XN49-02:
WOT TG04-01:
DG I Loss of Power Test SSW Loop A Valve Position Verification MOV Differential Pressure Testing of SW-V-12A RCIC-V-19 stem and disc replacement Digital RFW control system installation RRC, ASD installation RRC-V-19 control switch replacement MSIV 28C work b. Observations and Findin s
The inspectors found that the work performed under these activities was professional and thorough.
All work observed was performed with the work package present and in use.
In general, technician'nd operations personnel were technically knowledgeable and worked in a systematic and controlled manner.
No safety significant problems were identified.
PPH 7.4.8. 1. 1.2.5B, DG1 Loss of Power Test (61726):
On May 7-10, 1996, the inspector observed the portion of the DG Loss of Power Test which tests the relay logic for the SM-7 safety-related bus.
The inspector observed good control of the evolution by the test director.
The control was evidenced by clear communications, direct:instructions, and a concise briefing prior to the test.
No significant problems were noted.
The inspector observed one problem that occurred during this testing.
During the pretest alignment, turbine service water Pump A inadvertently started when a lead was lifted in accordance with the procedure.
The lifted lead would have provided for the pump to shed, then start following a loss of voltage on the bus without a shift to the standby pump.
The test director immediately stopped the test activity to evaluate the cause.
The licensee determined that a step in the procedure had been left out for the selector handswitch to be left in the off or B
select position.
The procedure was then corrected with a deviation.,
The reason the discrepancy had not been 'caught earlier was due to the switch
normally being left selected to the opposite pump during conduct of this test.
The inspector considered this a minor proc'edural discrepancy.
WOT ZV09-01, RCIC-V-19 Haintenance (62703):
The licensee identified that a
new stem and disc assembly for Valve RCIC-V-19 had not been installed during the previous outage as intended.
The new assembly was found in the engineering building.
During this inspection period, the licensee disassembled Valve RCIC-V-19 and verified that the old parts were installed.
At the end of the inspection period, the licensee was evaluating this issue to determine why the new stem and disc assembly had not been not installed (PER 296-0130).
This is an unresolved item pending the licensee's investigation and corrective actions and NRC review (URI 50-397/9606-02).
Conclusions HS. 1 Haintenance activities were generally completed thoroughly and professionally.
One unresolved item was opened regarding an instance in which new parts were not installed in Valve RCIC-V-19.
Hiscellaneous Haintenance Issues (92902)
Closed Unresolved Item 50-397 9602-05:
numerous examples of questionable maintenance practices'his item referred to ten NRC-identified examples of questionable maintenance practices.
Through subsequent review, the inspectors determined that two of the practices were violations of NRC requirements.
The other examples were found to be acceptable or minor in nature and the licensee had taken effective corrective actions.
Emergency Haintenance:
The inspectors identified that on January 18, 1996, the licensee performed maintenance on DG Damper DHA-AD-21/2 (a safety-related component)
without an approved work order or a procedure.
The initial work scope included troubleshooting, reconnecting, and testing of the damper linkage assembly that had been found disconnected.
Following the second failure of the damper actuator to function properly, craftsmen disconnected and tested the damper motor.
Both these activities were performed without procedures or work instructions.
Licensee procedures permitted the shift manager'o characterize some maintenance activities as
"emergency" maintenance, which allowed maintenance to be performed without procedures or instructions'he shift manager considered the maintenance on DHA-AD-21/2 emergency maintenance (a work procedure was not necessary)
because of management's concern to shorten the time to complete the maintenance and thereby minimize surveillance testing of the operable DGs.
The inspectors considered the shift manager's decision and concluded that the maintenance should have been considered "priority 1" maintenance
-9-rather than
"emergency" maintenance and, therefore, required a work procedure with written instructions.
The bases for the inspectors'onclusions were as follows:
The licensee's work process does not preclude preparing and approving a troubleshooting plan and work instructions in a
reasonably short time.
The vendor manual, which was readily available but not used to'erform the initial work, contained detailed instructions for performing the work.
~
A well-developed, thoughtful plan may actually minimize the overall time to perform maintenance.
~
The maintenance was not a simple task.
The licensee had previously performed maintenance incorrectly assembling the DG damper actuators, as documented in PER 292-279.
Therefore, the inspectors concluded that the preparation of work instructions were necessary and appropriate to the situation.
~
The failed damper actuator was a part of a support system to the DG and was an independently testable component and therefore, testing of the other DG was not required by TS.
In interviews with the involved, maintenance personnel, the inspectors noted that the personnel conducting the initial maintenance did not recognize that the maintenance was being conducted as emergency maintenance, but thought the maintenance was being conducted as minor maintenance.
furthermore, the inspectors noted that the lack of documenting the troubleshooting and the work that had been performed complicated the problem resolution and lengthened the time to correct the problem.
On January 19, 1996, substantially after the start of the job, a work order and procedure were issued.
This occurred after the damper had been reconnected and had failed the initial testing.
The failure to have work instructions during the initial and followup troubleshooting appropriate to the circumstances is considered another example of the violation described in NRC Inspection Report 50-397/96-02.
That violation (Violation 397/9602-01)
also dealt with control of work (investigation and troubleshooting)
The licensee's corrective actions include plans to revise Procedure PPM 1.3.7B to further define management's expectations for the use of emergency maintenance (PER 296-0125).
We note that there may be allowances for shift management discretion under certain conditions (abnormal or emergency conditions).
We will monitor the implementation of the expectations.
This issue will be tracked as Violation (VIO) 397/9602-0 The inspectors recognize the potential need to perform maintenance activities without work instructions or procedures when there are plant emergencies or conditions which are immediate plant or personnel hazards.
These conditions should occur rarely.
Documentation of Maintenance and Postmaintenance Testing:
While reviewing damper maintenance records, the inspectors found that craftsmen routinely disconnected the DG damper when inspecting and cleaning the dampers.
Specifically, Work Order Task SA 53, dated Hay 3, 1995, documented that the linkages had been removed during the inspection and cleaning activities.
Review of the work order revealed two concerns:
(1) the work planner had not considered the need to disconnect the damper actuator assembly to perform the inspection and cleaning, and (2) the dampers were not retested after the inspection/cleaning activities even though the actuator was disconnected and reconnected and the work order documented these actions.
The failure to appropriately control the work associated with cleaning the dampers or to provide for postmaintenance testing instructions was considered another example of the violation described in NRC Inspection Report 50-397/96-02 (Violation 397/9602-01)
related to inadequate work instructions for the control of work on the EDG dampers.
The licensee's corrective actions include plans to review a
sample of safety-related PH work orders to assure that work instructions match the work performed and that appropriate postmaintenance testing is provided (PER 296-0125).
We will review the results of the review of work orders, which should assure that work instructions are adequate to control work activities.
This issue will be tracked as Violation (VIO) 397/9602-01.
Periodic Testing of the Damper Actuator:
The inspectors identified that the loop calibration of the damper circuitry did not perform a mid-stroke check of the damper's position to ensure that the damper could perform the modulation function.
Only the "ull-open and full-closed positions were actually verified.
The loop calibration checked the circuit at several points to ensure proper circuit performance, but did not verify that the damper was responding to the mid-position'ignals.
The licensee revised procedures to verify the modulation of DG dampers.
III. En ineerin E2 E2.1 Engineering Support of Facilities and Equipment 0 erabilit Determination of Standb Gas Treatment SGT S stem Ins ection Sco e
37551 The inspectors utilized Inspection Procedure 37551 and guidance from NRC Generic Letter (GL) 91-18 in the evaluation of a licensee operability assessment associated with the SGT syste b. Observations and Findin s
Each train of SGT is equipped with two 100 percent capacity, safety-related fans (lead and lag fans).
The lead fan is normally relied upon to achieve the safety function, but the lag fan is designed to start within 30 seconds if the lead fan fails.
The lead and lag fans are both powered from safety-related buses, but from different electrical dl vlsi ons.
During a surveillance test following maintenance activities, the lag fans were found to not function properly, but the lead fans were fully functional.
The system engineer (SE) concluded that the SGT system was degraded, but operable'he inspectors reviewed design basis documents and found that the lag fans were intended to provide single failure protection for each train of SGT.
Burns and Roe Technical Memorandum 0436,
"System Description Standby Gas Treatment System,"
dated September 18, 1973, states, in part:
"A further requirement of these systems, however, is that air flow be maintained through the filters in the event of a single failure, such as failure of a fan or emergency bus.
Thus, assured air flow is required to prevent the filters from igniting, on loss of air flow, due to the decay heat generated by radioactive materials entrained in the filters dueing [during] unit operation.
It is for this reason that two full capacity fans powered from separate emergency buses are provided for each SGT unit."
Additionally, design basis documents indicate that this mode of operation, captured in the Final Safety Analysis Report (FSAR),
was safety-related.
The lag fans ensured that the mode of operation would be protected, even if the system suffered a single failure:
"In the event that the radiation monitors in the discharge duct indicate unacceptable radiation levels in the system discharge air, the operator starts the second unit and diverts the discharge air of the operating unit back into the reactor building to minimize the offsite release of halogens, and/or for cooling of the charcoal bed."
The inspectors conducted interviews with the SE and the backup SE and found that the engineers did not know the design intent of the safety-related lag fan in each train of SGT.
When questioned about the design intent, the engineers indicated that the lag fans were provided for operational and maintenance convenience only.
The engineers were not aware of design basis documents which indicated that the above-noted mode of operation is safety-related.
The inspectors concluded that the operability determination (operable, but degraded)
was appropriate, but the basis for the determination was
-12-weaK in that the engineers had not completely researched pertinent design basis information in order to ascertain the safety consequences of operating the trains with inoperable lag fans prior to making the operability determination.
Because the SE and backup SE did not consider the appropriate design basis information when making the determination, they had not realize that single failure protection was lost.
This lack of insight precluded implementing compensatory measures to minimize the safety consequences of the deficiencies.
In response to the inspectors'oncerns, licensee management met with the engineering staff and emphasized the need to review appropriate design basis documents when evaluating system operability.
Additionally, the licensee previously had identified a broad-based weakness in the knowledge of the SEs regarding design basis information and was developing training to address the concern.
Finally, the licensee was in the process of developing requirements that would ensure increased management involvement in operability determinations.
At the time of the inspectors'bservations, the requirements had not been implemented.
The inspectors also observed that the SE did not have a working knowledge of SGT historical problems.
Instead, he relied upon the backup SE for the pertinent information.
Through followup discussions with engineering management, the inspectors learned that the engineering retraining program is being revised to clarify expectations and include training associated with historic system issues.
Conclusions E2.2 The operability determination (operable, but degraded)
was appropriate, but the basis for the conclusion was poorly supported.
The engineers demonstrated poor utilization of design basis information in developing the operability determination.
Plant management was in the process of addressing SE weaknesses associated with utilization of design basis documents and knowledge of system history.
Motor Pinion Ke Failure Valve LPCS-MO-5 a
~
Ins ection Sco e
37551 On April 21, during a maintenance inspection of the motor operator for LPCS injection Valve LPCS-MO-S, the licensee identified that the motor pinion key was sheared in the longitudinal direction along the shear plane.
This key transfers torque between the motor shaft and the pinion gear set and in turn drives the actuator to move the valve.
The inspectors utilized Inspection Procedure 37551 to evaluate the licensee's investigation and corrective actions associated with this issu b. Observations and Findin s
The licensee conducted additional inspections and found that the set screw, which holds the gear to the shaft and limits the axial motion of the pinion gear, had,gouged the shaft approximately 3/8 inch in one direction and 5/16 inch in the other, which indicated some movement of the pinion gear on the motor shaft in the circumferential direction.
8ased on the movement and surveillance results which demonstrated that the valve had recently stroked under static condition on two occasions, the licensee determined that the valve was operable.
The inspectors could not conclusively determine that the valve would have functioned during an accident because the valve was not proven to be able to function under full flow conditions in the as-found condition.
As such, the key failure was a significant challenge to the operability of the valve and operability could not be guaranteed.
As immediate corrective actions, the licensee replaced the key with one made of a stronger, more reliable material and identified other valves that could be susceptible to similar failures.
The inspectors also noted several NRC Information Notices and
CFR Part 21 notifications which documented failures of Limitorque motor pinion keys.
At the end of the inspection period, the licensee had not completed the investigation and corrective actions associated with this issue.
This is considered unresolved, pending licensee actions and NRC review (URI 50-397/9606-03).
Conclusions E2;3 The licensee identified that the motor pinion key for the motor operator for Valve LPCS-HO-5 had failed, but concluded that the valve was operable.
The issue is unresolved pending further NRC review of the investigation and corrective actions.
Review of Faci lit and E ui ment Conformance to FSAR Descri tion A recent discovery of a licensee operating their facility in a manner contrary to the FSAR description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the FSAR description.
While performing the inspection discussed in this report, the inspectors reviewed the applicable portions of the FSAR that related to the areas inspected.
One minor inconsistency was identified associated with the SSW system.
FSAR, Section 9.2.7.2, describes the SSW keep-full system and states that the function of the nonsafety-related system is to keep the piping full of water to minimize maintenance and repair on system components.
However, the licensee had valved the keep-full system out of service in 1993.
A 10 CFR 50.59 evaluation was performed to justify the change, but the FSAR was not appropriately updated in accordance with the requirements of
CFR 50.71(e)(4).
This regulation requires the
-14-licensee to update the FSAR annually and the FSAR revisions are required to be accurate to within 6 months of filing the revisions.
E8 E8.1 E8.2 The inspectors concluded that this instance of failing to update the FSAR was an additional example related to an earlier violation for which the licensee had not had a reasonable opportunity to implement corrective actions.
This item will be reviewed as part of the closeout of the violation identified in NRC Inspection Report 50-397/9602 and is considered an inspection followup item (IFI 50-397/9606-04).
miscellaneous Engineering Issues (92903)
Closed Unresolved Item 50-397 9602-03:
repetitive failures of DG heating, ventilation, and air conditioning (HVAC) air dampers.
This item referred to the failure of DG Air Damper DNA-AD-21/2 in January 1996, which was the fifth failure of this actuator type since 1992.
There are 24 similar actuators equally distributed among the three DG rooms.
The inspectors observed troubleshooting of the failed actuator and noted that the engineer performed the troubleshooting process in a controlled and well thoughtout manner.
The troubleshooting was superior to the previous troubleshooting effort, which was discussed in NRC Inspection Report 50-397/96-02.
The engineer identified that the feedback circuit potentiometer had failed, which impaired the unit's ability to modulate the damper to control air flow to the DG room.
Instead of modulating, the actuator moved continuously in one direction until reaching a
mechanical stop.
Additionally, the direction of rotation was not consistent, as the unit was observed to rotate in different directions on different occasions.
The inspectors considered the engineer's efforts at troubleshooting to be excellent.
From the licensee's investigation, the inspectors concluded that the failure of DNA-AD-21/2 was not directly related to the failures of the previous four units.
However, the cause for the increased failure rate could be age related.
As corrective actions, the licensee planned to replace the older actuators, installed during initial construction, with actuators of a newer model by the end of the 1997 refueling outage (R12).
The planned corrective actions appear acceptable.
Closed LER 397 93-31 Revision 1:
main control room HVAC high temperature condition during a design basis accident.
This LER was initiated when the licensee determined that the main control room HVAC system may not maintain control room temperature below. the design basis limit of 104'F following a design basis event.
Fouling of the SSW side of the HVAC coolers resulted in cooler efficiencies that were below design basis limits.
The inspectors had previously. reviewed the licensee's investigation and corrective actions, as documented in NRC Inspection Reports 50-397/95-26
-15-and 50-397/96-02.
The LER was left open pending resolution of two NRC-identified concerns, as documented below.
Periodic Monitoring:
As documented in NRC Inspection Report 50-397/95-26, licensee corrective actions included a program to monitor fouling in the SSW system.
When fouling approached the design basis limit of 65 percent UA, system cleaning would be performed (100 percent UA means no fouling is present).
However, in July 1995 the NRC inspectors identified that the program was inadvertently discontinued.
When testing was resumed based on the inspectors'uestion~~',
fouling was found to once again be below the design basis limit of 65 percent UA (61 percent on Train A and 59 percent on Train B).
In response to the fouling issue, the licensee determined through additional calculations that fouling could get as low as 50 percent UA without challenging system operability.
However, the failure to appropriately implement corrective actions to ensure that fouling did not exceed the established design basis limits was an example of a violation of 10 CFR Part 50, Appendix B, Criterion XVI.
Criterion XVI requires that measures be established to assure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified and corrected.
Additionally, for significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition (VIO 50-397/9606-01).
As part of the followup to this issue, the inspectors noted that the licensee's subsequent corrective actions, which included counselling pertinent individuals and strengthening the requirements for performance monitoring, were effective.
The licensee has recently changed, chemical treatment of the service water ponds.
Discontinuing the addition of biocides and algicides and adding hydrogen peroxide has dramatically improved the material condition of the service water ponds and has apparently eliminated the problems with biological growth.
Considering this action, a response to the above violation is not required.
monitoring of Service Water Building Coolers:
As noted in NRC Inspection Reports 50-397/95-26 and 50-397/96-02, the licensee monitored the SSW pump room coolers only and had assumed that the UA of control room coolers would be the same.
This practice was inconsistent with the recommendation made in GL 89-13',
"Service Water System Problems Affecting Safety-Related Equipment,"
in that the GL recommended performance monitoring for all safety-related coolers.
This was because fouling cou'ld vary significantly from cooler to cooler.
Test data from one cooler could not be directly applied to another cooler without sound technical justification.
The licensee performed inspections of all of the affected room coolers during the current outage to justify their position.
The licensee confirmed by visual examination that the service water building coolers
-16-were among the worst with regard to fouling.
Although the visual inspection was not as conclusive as performance monitoring, the inspection did provide a measure of validation to the licensee's original position.
The inspectors considered the licensee's position to be acceptable, provided the fouling of the SSW system does not approach design bas'.s limits in the future.
Some margin between the actual performance of the room coolers and the design basis limits appears to be necessary in order to account for the potential differences in cooler performance, which the licensee agrees.
IV. Plant Su ort Rl Radiological Protection and Chemistry Controls Rl.l Refuelin Outa e Radiolo ical Controls a.
Ins ection Sco e
71750 The inspectors observed outage-related activities requiring radiological controls (as low as reasonably achievable planning)
and dose reduction efforts which included the installation of permanent and temporary shielding and the removal of a portion of a contaminated system which was a very high radiation hazard.
b. Observations and Findin s
The inspectors observed the selected portions of activities in the primary containment drywell.
The activity included work on reactor core isolation cooling (RCIC) motor-operated valves, safety relief valves, installation of shielding, and piping removal.
The inspector observed that activities were well-planned and implemented and that workers were signed on and working within the guidance of radiation work permits.
The inspector observed that the health physics technician assigned to monitor and control drywell activities maintained a listing of ongoing drywell activities and closely tracked exposures.
At the conclusion of the inspection period, the inspector noted that the licensee was well below their projected total exposure for the oUtage (195 versus 245 Person-REN).
Also, personnel contaminations had been significantly reduced from the previous outage, and no personnel had entered the radiologically controlled area without digital dosimetry.
c. Conclusions Observed outage activities which required radiological controls were generally well-plan'ned, implemented, and controlled.
The licensee continued to implement their Dose Rate Reduction Program to reduce general area radiation levels.
These efforts appeared to be effective in
-17-Sl S1.1 that projected outage dose is less than projected.
The licensee has reduced the number of contamination events and inappropriate entries into the radiologically controlled area.
Conduct of Security and Safeguards Activities Securit Outa e Controls Ins ection Sco e
71750 The inspectors used Inspection Procedure 71750 to assess outage access controls during day and backshifts.
Observations and Conclusions The inspectors observed access controls had improved this outage as compared to previous outages.
Generally, the access area was not congested during shift changes due to increasing the number of security personnel in the search area and the number of access lanes.
Security personnel conducted thorough searches of personnel and hand-carried items.
The inspector noted that security personnel continuously manned the access control area.
F2 F2.1 Status of Fire Protection Facilities and Equipment Haterial Condition of Fire Protection E ui ment Ins ection Sco e
64704 The inspectors utilized Inspection Procedure 64704 to evaluate the material condition of selected fire protection equipment.
Observations and Findin s
During plant tours, the inspectors identified two deficiencies of fire protection equipment.
The inspectors found Jockey Fire Pump FP-P-3 vibrating excessively and leaking excessively from its pump seal.
This pump is a small electric driven pump that maintains yard main pressure at 170 psig to prevent automatic starts of the fire pumps due to minor system pressure changes.
The inspectors observed that a drain hose had been connected to the seal area to direct the leakage; however, the seal leak rate exceeded the capacity of the hose and water was overflowing to the floor.
No deficiency tags were on FP-P-3 and the inspectors notified the control room.
Subsequently, the licensee took vibration readings on the motor.
Pump vibration had significantly increased from the previous quarterly vibration reading.
The licensee initiated a work request to repair FP-P-3.
The inspectors also identified two fire doors not closed.
One door, which bordered the radiological controlLed area but was not a
primary passageway, was located on the 441 foot level of the Turbine Building.
The other door, which provides a primary entrance to the
'
-18-radiologicl controlled area, was on the 441 foot level of the General Services Building.
The licensee repaired the doors.
c. Conclusions The licensee was responsive in correcting the fire protection equipment deficiencies identified by the inspectors; however, the inspectors noted the deficiencies were obvious problems that tours by either the fire protection staff or plant staff should have identified
.
V. Hang ement Neetin s
Xl Exit meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on Hay 22, 1996.
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 PARTIAL LIST OF PERSONS CONTACTED Licensee P.
Semis, Vice President for Nuclear Operations L. Fernandez, Regulatory Affairs Supervisor G. Smith, Plant General Manager C. Schwarz, Operations Manager J. Swailes, Engineering Director D.
Swank, Regulatory and Industrial Affairs Manager R. Webring, Vice President Operations Support NRC J. Clifford, Senior Project Manager, NRR
INSPECTION PROCEDURES USED IP 37551:
IP 60710:
IP 61726:
IP 62703:
IP 71707:
IP 71715:
IF 71750:
IP 92901:
IP 92902:
IP 92903:
IP 92904:
Onsite Engineering Preparation for Refueling Refueling Activities Surveillance Observations Maintenance Observations Plant Operations Sustained Control Room and Plant Observation Plant Support Activities Followup - Plant Operations Followup - Engineering Followup - Maintenance Followup Plant Support ITEMS OPENED AND CLOSED
~0en ed 50-397/9606-01 50-397/9606-02 50-397/9602-01 50-397/9606-03 50-397/9606-04 Closed 50-397/9424-02 50-397/9602-05 50-397/9602-03 50-397/9331-01 VIO failure of corrective actions to preclude repetition URI stem and disc assembly installation VIO failure to have appropriate work instructions for maintenance and cleaning/testing URI motor pinion key failure IFI FSAR update VIO failure to enter LCO or declare UE URI maintenance procedure deficiencies URI inadequate trending of damper motor failure LER control room high temperature potential