IR 05000413/1999001

Insp Repts 50-413/99-01 & 50-414/99-01 on 990124-0313. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20205N061
Person / Time
Site:	Catawba
Issue date:	04/06/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205N056	List: IR 05000413/1999001 ML20205N053
References
50-413-99-01, 50-413-99-1, 50-414-99-01, 50-414-99-1, NUDOCS 9904160137
Download: ML20205N061 (31)

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U.S. NUCLEAR REGULATORY COMMISSION REGION ll Docket Nos: 50-413,50-414

- License Nos: NPF-35, NPF-52 Report Nos.: 50-413/99-01,50-414/99-01 Licensee: Duke Energy Corporation Facility: Catawba Nuclear Station, Units 1 and 2 Location: 422 South Church Street Charlotte, NC 28242 Dates: January 24 - March 13,1999 Inspectors: D. Roberts, Senior Resident inspector R. Franovich, Resident inspector M. Giles, Resident inspector J. Coley, Reactor inspector (Sections M8.4 - M8.8)

E. Testa, Senior Radiation Specialist (Sections R1 - R7)

W. Kleinsorge, Senior Reactor inspector (Sections M8.9 - M8.14)

Approved by: C. Ogle, Chief Reactor Projects Branch 1 Division of Reactor Projects

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EXECUTIVE SUMMARY Catawba Nuclear Station, Units 1 and 2 NRC Inspection Report 50-413/99-01,50-414/99-01 This integrated inspection included aspects of facility operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of announced inspections by regional reactor safety inspectors. [ Applicable template codes and the assessment for items inspected are provided below.]

Operations

• The licensee's response to two reportable events was appropriate. The plant was maintained in a safe condition and the NRC was notified in accordance with 10 Code of Federal Regulations (CFR) Part 50.72 requirements. (Section 01.2; [1 A - POS])

Maintenance

• After converting to improved Technical Specifications, the licensee continued to identify surveillance test procedures that do not correctly reference Technical Specification surveillance requirements. This raised concerns about the effectiveness and timeliness of reviews associated with the licensee's earlier improved Technical Specification review project. The most recently identified discrepancies involved engineered safety features response time testing of components in the hydrogen skimmer system and valves associated with the residual heat removal heat exchangers. (Section M1.2; [2B - NEG])

• Eight Unit 1 ice condenser lower inlet doors were inoperable as a result of ice accumulation on, and/or deformation of, glycol piping associated with ice condenser beam cooling. The ice accumulation and one bent glycol pipe would have obstructed the opening paths of the eight lower inlet doors. Pending further review of past inoperability, this issue is identified as an unresolved item (Section M2.1; [2A - URl])

• The licensee recognized that an outstanding residual heat removal system relief valve leakage problem, initially identified on January 25,1999, had not been adequately addressed one month later and took actions to determine the leakage contribution to onsite and offsite dose calculations and the impact of the leakage to the valve and system operability. (Section M2.2; [5A - POS]) i I

• The licensee's initial response to address a leaking residual heat removal system valve i was neither thorough nor timely to prevent the potential spread of contamination, evaluate dose implications, and ensure that valve and system operability were not adversely affected. (Section M2.2; [2A, SC - NEG])

• The licensee requested and was granted a Notice of Enforcement Discretion for non-compliance with Technical Specifications 3.3.7 and 3.3.8 on March 11,1999. An i unresolved item was opened to review testing requirements for lower-tier logic in the control room area ventilation system, as well as previous opportunities for the licensee to ,

identify or preclude the Technical Specification non-compliances. (Section M3.1; [2B - i ED]) l

• The licensee demonstrated a good questioning attitude regarding operation and testing of the control room area ventilation system and auxiliary building filtered ventilation I exhaust system during its Plant Operations Review Committee meeting prior to submitting a Notice of Enforcement Discretion request. (Section M3.1; [5A- POS])

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• A non-cited violation was identified concerning a 1998 non-compliance with Technical Specification 3.3.1 due to a mispositioned thumbwheel that caused Channel 4 of the overtemperature delta temperature and overpower delta temperature reactor trip functions to be inoperable in excess of the Technical Specification allowed outage tim (Section M8.1; [3A - NEG; SA, SC - NCV])

. The licensee did not develop the human performance aspects of technicians performing actions outside of approved plant procedures in its root cause determination for the mis-positioned delta-T/T-average card thumbwheel that rendered Channel 4 of overpower and overtemperature delta temperature trip functions inoperable. (Section M8.1; [5B -

NEG])

• An inspector-identified non-cited violation was issued for a 10 CFR Part 50.59 safety evaluation that failed to adequately address the potential for an unreviewed safety question or Technical Specification implications associated with the end-of-cycle moderator temperature coefficient measurement. (Section M8.2; [4B - NCV])

+ A non-cited violation was identified concerning the failure to comply with Nuclear System Directive 704 during control room ventilation maintenance work. (Section M8.7; [3A-NEG; SA, SC - NCV])

• A non-cited violation was identified concerning a failure to test auxiliary building ventilation per Technical Specification 4.7.7.d.1. (Section M8.13; [2B - NEG; SA, SC -

NCV])

• A non-cited violation was identified concerning the failure to monitor the waste gas system per Technical Specifications. (Section M8.14; [4B - NEG; SA, SC - NCV])

Enaineerina

. The licensee identified three occurrences of a degraded plant condition whereby inoperable refueling water storage tank level instrument channels were in the " tripped" condition instead of the required " bypassed condition for periods exceeding that allowed by Technical Specifications. This occurred during transmitter replacements for the associated channels. (Section E3.1; [28,4C - LER])

Plant Support

. The licensee's implementation of its As Low As Reasonably Achievable (ALARA)

program during the Unit 1 ice condenser lower inlet door beam cooler inspection on March 5,1999, was good. Radiation protection technicians minimized dose by using detailed, comprehensive planning and by providing good information to the licensee's inspection team. (Section R1.1; [1C - POS])

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. The inspectors observed minor problems with housekeeping in posted contaminated I areas. (Sections R1.1; [1C,2A - NEG])

Radiation and process effluent monitors and environmental monitors were being maintained in an operational condition in compliance with TS requirements and Updated Final Safety Ana:ysis Report commitments. (Section R2.1; [1C,2A - POS])]

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. Radiation worker doses were being maintained well below regulatory limits and the licensee was maintaining exposures ALARA. (Section R1.1; [1C - POS])

. Radiation work activities were appropriately planned. (Section R1.1; [1C,3A - POS])

e in response to radiation protection and chemistry audits, the licensee was developing corrective action plans, trending, and completing corrective actions in a timely manne (Section R7; [1C, SC - POS])

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Report Details l

Summarv of Plant Status Unit 1 began the inspection period at approximately 100 percent reactor power. On February 13,1999, reactor power was reduced to 97 percent to support the end-of-cycle moderator temperature coefficielt measurement. Reactor power was further reduced to 88 percent on February 14,1999, for performance of turbine control valve movement testin Reactor power was returned to 100 percent on February 15,1999, and remained at full power untilit was reduced to 18 percent on March 5,1999, to allow inspection of the ice condenser lower inlet door beam coolers. After completing the inspection, the licensee performed minor maintenance on and removed some ice from the glycol piping associated with the ice condenser lower inlet door beam coolers. Reactor power was returned to 100 percent on March 7,1999, and remained at or near full power for the remainder of the inspection perio Unit 2 operated at or near 100 percent power until January 28,1999, when reactor power was reduced to 97 percent to allow stroking of 2SV-1, the D steam generator power operated relief valve. Reactor power was returned to 100 percent the same day and remained at or near full power for the remainder of the inspection perio l. Ooerations 01 Conduct of Operations O1.1 General Comments (71707)

The inspectors conducted frequent control room tours to verify proper staffing, operator attentiveness and effective communications, and adherence to approved procedure The inspectors: (1) attended operations shift turnovers and site direction meetings to maintain awareness of overall plant status and operations; (2) reviewed operator logs to verify operational safety and compliance with Technical Specifications (TS);

(3) periodically reviewed instrumentation, computer indications, and safety system lineups, along with equipment removal and restoration tagouts, to assess system availability; (4) reviewed the TS Action item Log books for both units daily for potential entries into limiting conditions for operation (LCO) action statements; (5) conducted plant tours to observe material condition and housekeeping; and (6) routinely reviewed Problem identification Process (PIP) reports to ensure that potential safety concerns and equipment problems were resolved. The inspectors identified no major problems from the above review O1.2 Prompt Onsite Response to Operational Events - General Comments (93702)

The inspectors responded to two reportable events during the period. The inspectors reviewed the circumstances associated with each event, verified that plant personnel responded to the events in accordance with governing plant programs and procedures, verified that the plant was in a safe condition, and confirmed that the licensee made the appropriate notifications to the NRC as required by 10 CFR Part 50.7 !

One event involved inadequate surveillance testing of the hydrogen skimmer system, which rendered it inoperable and placed Unit 2 in TS LCO 3.0.3. The other involved refueling water storage tank level instrument channels being inappropriately * tripped" while inoperable during a transmitter modification. This placed the plant in an unanalyzed condition. These issues are discussed in Sections M1.2 and E3.1, respectively. The inspectors concluded that the licensee properly addressed and

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reported these issues once they were identified, and that the plant was maintained in a safe conditio . Maintenance M1 Conduct of Maintenance M1.1 General Comments on the Conduct of Maintenance and Surveillance Activities (6270 )

The inspectors observed all or portions of the following maintenance and surveillance activities:

- PT/1/A/4400/0038, Revision 57, Cornponent Cooling (KC) Train 1B Performance Test

- IP/0/A/3162/005, Revision 26, Control Room Ventilation (VC) System Chlorine Detectors, (Channel Operational Test)

- IP/1/A/3240/011, Revision 18, Calibration Procedure NIS Power Range Calibration at Power

- MP/0/A/7650/056C, Revision 08, (Component Cooling Water) Heat Exchanger Corrective Maintenance

- PT/1/A/4600/002A, Revision 162, Mode 1 Periodic Surveillance items

- PT/0/A/4150/128, Revision 9, Moderator Temperature Coefficient of Reactivity Measurement The inspectors identified minor discrepancies during an overtemperature delta temperature channel check, during a chlorine detector test, and following a component cooling water heat exchanger tube cleaning activity. These observations were provided to the licensee for resolution. Other than these observations, maintenance and surveillance activities were conducted with proper adherence to procedures and appropriate adherence to equipment calibration and radiation protection requirement M1.2 Non-Comoliance with TS Surveillance Reauirements - General Comments (61726)

The licensee identified several missed or inadequate TS surveillances during the inspection period and, as required, notified the NRC in accordance with 10 CFR Part 50.7 On February 25,1999, the licensee determined that the surveillance test procedures associated with residual heat removal (RHR) valves 1(2)ND-26 and -60, RHR Heat Exchanger (HX) A and B Outlet Control Valves, and 1(2)ND-27 and -61, RHR HX A and B Bypass Control Valves, referenced incorrect Engineered Safety Feature (ESF)

response time criteria. This discrepancy was identified during a programmatic review of ESF response time test criteria in the Updated Final Safety Analysis Report (UFSAR)

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Table 7-15. The UFSAR table specified that 12 seconds (normal power) and 27 seconds (emergency diesel power) were the response time criteria. However, the ESF test prescedures indicated that response time criteria for these valves were not applicabl .

According to the licensee, the Ameri;an Society of Mechanical Engineers (ASME) Code,Section XI, valve stroke (lWV) tests for these valves was used to implement the surveillance requirement, and the IWV procedure incorrectly specified 15 seconds as the response time acceptance criterion. As a result, the licensee failed to recognize that three valves (1ND-27,1ND-60 and 2ND-26) failed to meet the 12-second ESF response time criterion during their most recent IWV tests, and actions to correct the valve stroke times were not taken. The licensee determined that these three valves had, at some point, been in their non-accirient positions since the unrecognized test failures occurred and were, therefore, inope>able during those times. The licensee immediately verified l that all the valves, inclur5ng those that had failed the stroke time tests, were currently in -J their accident position',, and actions were taken to administratively control the valves in their accident positions until (1) procedure changes could be completed to correct the errors and (2) response time testing for the three valves with excessive stroke times could be performed to the correct acceptance criteria. The inspectors independently verified that these actions were performed. The inspectors will review this issue with {

associated Licensee Event Report (LER) 50-413/99-02, Three RHR System Valves Did j Not Meet Their ESF Response Time Requirement Due to a Procedure Deficiency, j

On March 4,1999, the licensee submitted a 10 CFR Part 50.72 report when Unit 2 )

entered TS LCO 3.0.3 for approximately 30 minutes. The licensee identified a j discrepancy between the acceptance criterion specified in a surveillance test procedure and the TS surveillance requirement. This was identified during a programmatic review of improved TS surveillance requirements. The surveillance involved ESF response time testing for the hydrogen skimmer (VX) fan suction isolation valves, which are required to open within 600 seconds of an ESF actuation signal. The acceptance criterion in the surveillance procedure was s664.8 seconds, whereas the acceptance criterion specified in Table 7-15 of the UFSAR was s600 seconds. The licensee reviewed the procedures I associated with the most recent surveillance tests to determine if the performance data were within the acceptance criterion specified in the UFSAR table. They determined that Unit 1 B train valve (1VX-28) and Unit 2 A and B train valves (2VX-1 A and 2VX-28, respectively) did not meet the 600 second acceptance criterion and declared the affected trains of the VX system inoperable. Unit 2 entered LCO 3.0.3 at 12:28 a.m., on March 4, 1999, because both trains of the system were inoperable. The licensee had the 2B train timer relay calibrated to reduce the delay time and, as a result, reduce the valve's response time to within 600 seconds. The 2B train of VX was restored to operable status, and Unit 2 exited LCO 3.0.3 at 12:59 a.m., on March 4. The licensee calibrated i the timer relay associated with valve 1VX-2B and declared the 1B train of VX operable at i 3:54 p.m., on March 4,1999. The licensee subsequently declared the 1 A VX train inoperable at 4:00 p.m, on March 4,1999, because they determined that a calibration of the timer relay associated with the 1 A train VX valve (which was calibrated on February 22,1999, after the previous surveillance test of the valve had been performed) had rendered its stroke time outside the 600 second accer tance criterion. Since no TS action statement associated with ESF TS 3.3.2 applies to the VX system,1 A and 2A trains of VX were in a 30-day action associated with TS 3.6.8. Both of these trains were restored to operable status on March 6,1999. The licensee was evaluating reportability of this issue under 10 CFR 50.73. Pending further review. this issue will be identified as Unresolved Iterr (URI) 50-413,414/99-01-01: ESF Response Time Testing for VX Fan Suction isolation Valve ___

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The inspectors noted that these issues arose after the licensee's conversion to the improved TS on January 16,1999. Prior to the conversion, the licensee had conducted a comprehensive review of procedures that implement TS requirements to ensure that appropriate testing methods and acceptance criteria were specified. The inspectors were concerned that the recent findings, along with others since January, were not resolved before the ITS conversion. The inspectors expressed this concern to licensee management, who indicated that these findings were actually identified before January 16,1999, but they were not resolved until months later for reasons that were unclear. The inspectors willinclude a review of the licensee's delayed resolution of these findings during the subsequent review proces M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Inspection of Unit 1 Ice Condenser Lower Inlet Doors Inspection Scope (62707. 92902)

On March 5,1999, the licensee inspected accessible lower inlet doors in the Unit 1 ice condenser while at 100 percent reactor power to determine if ice had accumulated on the lower inlet door beam coolers and associated glycol piping. This inspection was performed as a planned corrective action documented in LER 50-414/98-05, which involved the past inoperability of Unit 2 ice condenser lower inlet doors as a result of blockage from ice accumulation on the beam cooler glycol piping. The inspectors accompanied the licensee on this inspection. Based on observed ice accumulation on the first bay inspected, the licensee determined that a 100 percent bay inspection was necessary. A Unit 1 power reduction was initiated to reduce radiation dose levels for this inspection. The inspectors reviewed LER 50-414/98-05 and the TS requirements for operability of the ice condenser. The inspectors accompanied the licensee during their 100 percent inspection of the beam coolers and associated glycol piping to independency assess the operability of the inlet doors. The inspectors also reviewed the procedures ased to document the as-found and as-left conditions of the beam coolers and glycol pipin Observations and Findinas After reactor power was reduced to 18 percent, the inspectors accompanied the licensee during their followup inspection of the ice condenser to verify that the inlet doors were not physically restrained (in immediate contact with ice accumulation or any other obstruction that would render them incapable of opening), which would require implementation of TS 3.6.13, Action A, for having one or more ice condenser doors inoperable due to being physically restrained from opening. Technical Specification Action A requires that the door (s) be restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the unit be placed in Mode-3, Hot Standby, The inspectors did not observe any physically restrained doors. The licensee determined that eight lower inlet doors were inoperable because of ice accumulation on beam cooler glycol piping. This accumulation would have obstructed the doors from freely opening to the full open position. One of the doors was obstructed by ice and a bent glycol pipe. The unit entered TS 3.6.13, Action B, for having one or more doors inoperable for reasons other than those specified in Condition i

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5 Six ice condenser bays were affected by the inoperable doors. On March 6,1999, the ice that obstructed the inlet doors was cleared, and the bent glycol pipe was physically reshaped. The licensee declared the lower inlet doors operable, exited TS 3.6.13 LCO and initiated a power increase later that day. The unit resumed full power operations on March 7,1999. The licensee is preparing LER 50-413/99-03 (Violation of TS Due to ;

Inoperable Ice Condenser Lower Inlet Doors Caused by Ice / Frost BuPup Restricting Door Movement) to notify the NRC of the past inoperabikty of the Unit 1 ice condenser lower inlet doors. Pending further review, this issue will be identified as URI 50-413,414/99-01-08: Past inoperability of Unit 1 Ice Condenser Lower inlet Door Conclusions The inspectors concluded that the licensee performed the Unit 1 ice condenser lower inlet door inspection in accordance with the commitment specified in LER 50-414/98-05 and that none cf the lower inlet doors were physically restrained from opening. Ice accumulation and a bent glycol pipe would have obstructed the opening pathway of eight lower inlet doors in six ice condenser bays. Pending further review of past inoperability, this issue is identified as an UR M2.2 RHR System Valve Leakaae Problems Inspection Spope (61726. 71707_)

Valve leaks were idenafied by the licensee and the inspectors during the report pedo To urderstand the impact to safety, the inspector discussed the equipment problems with engineering and operations personnel, and conducted frequent tours of the auxiliary building to monitor the leakage and the licensee's actions to address i Observations and Findinas The inspectors observed an operations shift briefing during the evening of February 22, 1999, when the Knift was informed that valve 2ND-35, RHR Pumps A and B Discharge Relief Valve, was leaking. The licensee had characterized the leak as a flange connection leak. The inspectors visually inspected the valve and observed boric acid accumulation on piping and ventilation duct under and around the valve. The inspector also noted that bori; acid had accumulated in an area above the flange that was reported to be leaking. Earlier that day, during the moming management site direction meeting, the licensee indicated that Work Request 98062546 was written on January 25, 1999, to document leakage from the valve, but that no adions had been taken to stop the leakag The inspectors reviewed the work request and detcrmined that it documented: (1) the presence of boron on the valve, pipes and floor; and (2) the need to have the valve removed and bench tested. Upon further investigation, the inspector determined that the leakage was mis-characterized as a flange leak, since the leak was originating from a relief vent in the valve bonnet. The licensee indicated that neither the valve nor the system had been evaluated for operability and that contamination controls were not installed until February 22,1999. The inspectors determined that a dose Jsses3 ment for the valve teakage was requested by verators and provided by engineers earlier that da _ _ _________________ ___________ _ _ -

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On February 25,1999, the licensee determined that the valve itself was inoperable, but the system was operable because two other relief valves (2ND-31 and 2ND-64) provided overpressure protection for the RHR pump discharge piping. The inspectors verified that these relief valves were normally available to both trains of RHR and concluded that the licensee's determination was reasonable. The licensee also quantified valve leakage during an ASME Code,Section XI, pump performance (lWP) test of the 2A RHR pump on February 24,1999, to confirm that the system was operable under pressurized conditions and to bound their assumptions for worst-case dose analysis. The inspectors inspected the valve for leakage during the IWP and did not identify any leakag Conclusions i The licensee recognized that an outstanding RHR relief valve leakage problem, initially ,

identified on January 25,1999, had not been adequately addressed one month later and '

took actions to determine the leakage contribution to onsite and offsite dose calculations and the impact of the leakage to valve and system operability. However, the licensee's initial response to address the leaking valve was neither thorough nor timely to prevent the potential spread of contamination, evaluate dose implications, and ensure that valve and system operability were not adversely affected. These observations and conclusions were shared with station management, who acknowledged the concerns expressed by the inspector M3 Maintenance Pracedures and Documentation M3.1 Notice of Enforcement Discretion (NOED) for TS 3.3.7 and 3. Inspection Scope (61726. 71707. and 40500)

The inspectors reviewed the circumstances associated with the licensee's discovery of missed TS Surveillance Requirements (SR) 3.3.7.1, 3.3.7.2,3.3.7.3,3.3.8.1, 3.3.8.2, and 3.3.8.3. These items required that the licensee perform actuation logic, master relay, and slave relay testing for the control room area ventilation system (CRAVS) and i auxiliary building filtered ventilation exhaust system (ABFVES) actuation instrumentatio The licensee determined on March 10,1999, that the TS testing requirements were not applicable to these systems and requested enforcement discretion from tha NRC until a TS amendment request could be submitted and approved to eliminate the 'equirement The inspectors reviewed test documentation, attended a Plant Operations Review Committee (PORC) meeting, and conducted discussions with plant personne Observations and Findinas in December 1998, the licensee questioned the adequacy of current station procedures intended to perform solid state protection system (SSPS) testing (i.e., actuation logic, master and slave relay testing) for actuation instrumentation specific to the CRAVS and ABFVES. On March 10,1999, at 6:05 p.m., the licensee concluded that station procedures did not perform testing as specified by the TS for both trains in each system and applied SR 3.0.3. This allowed the licensee 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of discovery to perform the surveillance or declare the LCO not met for the two systems. For the CRAVS equipment, the TS LCO Required Actions for having two trains inoperable is to verify one train is in operation and enter the applicable Conditions and Required Actions for one CRAVS train inoperable. The latter action would have given the licensee seven f

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days to place the one (other) CRAVS train with inoperable actuation in operation. For the ABFVES, the TS did not specify conditions for having two trains inoperable; therefore, the licensee would have had to apply LCO 3.0.3, which requires both units be i in Mode 3 within seven hours and Mode 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> from the time the licensee I determined the LCO was not me )

The licensee determined that the two systems are designed such that they are not directly actuated by SSPS actuation logic and relays, but by the emergency diesel generator load sequencer. The sequencer, in tum, is actuated by either the SSPS system via safety injection (SI) actuation logic and relays, or by emergency bus undervoltage relays (independent of SSPS) designed to detect a loss of offsite power or station blackout. Solid State Protection System logic and relays associated with load ,

sequencer actuation on SI were periodically tested under function 1b of TS Table 3.3.2- j 1. Load sequencer actuation itself is verified on an 18-month frequency during ESF testing. The inspectors reviewed the most recently completed copies of PT/1(2)/A/4200/009, Engineered Safety Features Actuation Periodic Test, Revision 153 '

(131), and verified that ESF testing had successfully demonstrated load sequencer actuation on station blackout, loss-of-coolant accident (LOCA), and the two events concurrently. The licensee informed the inspectors that they independently conducted a similar revie The licensee concluded that the TS-required testing of actuation instrumentation specified in TS 3.3.7 and TS 3.3.8 was not appropriate for these two systems, and that current testing of safety injection logic and relays, as well as the 18-month sequence testing described in tiie previous paragraph, was sufficient to demonstrate actuation instrumentation operability. To avoid an unnecessary dual-unit sLddown at the end of the 24-hour LCO period, the licensee requested a NOED from the NRC to allow non ..

compliance with SR 3.3.7.1 through 3.3.7.3, and SR 3.3.8.1 through 3.3.8.3, until the TS could be amended to delete these requirements. The NRC staff approved the NOED via a telephone conference on March 11,1999, and formally notified the licensee of the j approval in a letter dated March 15,1999. The licensee also submitted a TS amendment request on March 15,1999.

The inspectors attended the licensee's PORC meeting that was conducted to review the NOED request prior to its submission to the NRC. The PORC members demonstrated a good questioning attitude with respect to the systems' designs and the other tests for which credit was being taken for verifying system actuation instrumentation operability.

The inspectors were informed at the meeting that additional system logic intemal to the CRAVS determined which train would start first in the event both were idle. This intemal system logic was not being periodically tested. The inspectors noted that the TS contained no exrlicit requirements for testing this lower-tier logic; however, further research was .equired to determine if its failure could impact the system's ability to perform its intended safety functions.

The inspectors were also aware that there may have been previous opportunities to identify or pr vent the non-compliance with TS 3.3.7 and 3.3.8, including: (1) the lengthy period bety .n December 1,1998, when questions were initially raised, and March 10, 1999, whec the licensee concluded that a non-compliance existed: (2) the licensee's review of the logic testing program in response to NRC Generic Letter 96-01, " Testing of Safety-Related Logic Circuits"; and (3) a modification to the ABFVES trains during the early 1990s which deleted an SSPS input to system dampers, prior to which the testing

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specified by TS SR 3.3.8.1 through 3.3.8.3 would have been applicable. The inspectors concluded that these prior opportunities, as well as testing of the lower-tier system logic in the CRAVS, required further NRC review and will be documented as Unresolved item (URI) 50-413,414/W-01-02: Notice of Enforcement Discretion for TS 3.3.7 and TS 3. Surveillance Requirement Gonclusions The licensee requested and was granted a NOED for non-compliance with TS 3.3.7 and 3.3.8 on March 11,1999. An unresolved item was opened to review testing requirements for lower-tier logic in the CRAVS, as well as previous opportunities to identify or preclude the TS non-compliances. The licensee demonstrated a good questioning attitude regarding operation and testing of the CRAVS and ABFVES during its PORC review of the NOED reques M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) LER 50-414/98-07: Mispositioned Thumbwheel on Process Contml Circuit Card Causes Inoperability of Overtemperature and Overpower Temperature Functions On December 11,1998, Unit 2 Channel 4 of the 7300 process control system delta Tri-average (T-evg) circuitry failed 1.igh. Group 1 NLL lead lag card C4-246 failed and was replaced in accordance with IP/2/A/3222/076D, Revision 61, Calibration Procedure for Delta T/T-average Protection Channel IV. A calibration of the card was performed by maintenance technicians. To expedite the calibration procedure, technicians placed the T1 coarse thumbwheel setting to zero to nullify the lead / lag time constants and eliminate the dynamic compensation for the delta T circuitry; thus allowing a steady state output to be achieved more quickly during the calibration process. Upon completion of the calibration, the thumbwheel was not returned to the correct setting of three, but was left at zer A routine quarterly analog channel operational test (ACOT) performed by maintenance technicians on January 7,1999, revealed that Channel 4 of the delta T/T-avg circuitry was inoperable because it failed to meet the test acceptance criteria as specified in IP/2/A/3222/00D, Revision 54, Analog Channel Operation Test Channel IV 7300. A work order was generated, and maintenance technicians discovered that the Group 1 NLL lead lag card C4-246 coarse thumbwheel was set at zero. Procedure IP/2/A/3222/076D, Enclosure 11.2.4, required the coarse thumbwheel to be set at three for cor ect dynamic compensation to occur in the delta T/T-avg circuitry. Upon discovery, technicians returned the thumbwheel to the correct setting and satisfactorily performed an ACOT verifying operability. The licensee generated PIP 2-C99-0079 to document the even '

' Technical Specification 3.3.1, Table 3.3-1, Functional Units 6 and 7, require that four channels of overtemperature delta temperature (OTDT) and overpower deha temperature (OPDT) be operable during Modes land 2. With the number of operable channels one less than the total number of channels, startup and/or power operation may proceed provided the inoperable channel is placed in the tripped condition within six hours. Otherwise, TS 3.3.1 requires a unit shutdown to Mode 3 be commenced within the following six hours. Due to the incorrect thumbwheel satting, Channel 4 was inoperable for the OTDT and OPDT reactor trip functions for more than three weeks between Decembe' 11,1998, and January 7,1999, without the channel being placed in

the tripped condition or a unit shutdown being performed. The safety significar.ce of this issue was mitigated by the fact that the other three channels of OTDT and OPDT circuitry remained operable or capable of performing their protective functions. On December 29,1998, an ACOT was performed on Channel 1, in which the channel was placed in the tripped condition. This conservatively reduced the reactor trip logic from two-out-of-four to one-out-of-three for the OTDT and OPDT f unction The inspectors quest;oned the technical adequacy of the calibration procedure and whether the informal maintenance practice of setting the lead / lag card coarse thumbwheel to zero was necessary for the calibration to be performed successfull Engineering personnel confirmed that setting the thumbwheel to zero was merely a shortcut as described above. This action was not required to ensure successful calibration, and was not included in the approved calibration procedur The inspectors, in reviewing the associated LER and the licensees' completed root cause failure analysis report, concluded that the licensee did not develop the human performance aspects of this event in its root cause statement. Specifically, the licensee attributed the root cause to an inadequate program design, in that the p.vcedure should have ensured that the coarse thumbwheel was restored to the correct setting after it was informally set to zero. The inspectors questioned this logic in that approved procedures were written for compliance and not designed to capture and correct any and all informal practices. The inspectors concluded that the root cause of this event was human error because maintenance technicians performed actions outside of an approved procedure, which changed the configuration of safety-related equipmen Because of the differences in the root cause determinations, and comments in other NRC inspection Reports (IR) regarding human performance issues that were not developed in previous LERs (i.e., IR 50-413,414/98-15; IR 50-413,414/98-08; and IR 50- I 413.414 98-03), the irnpectors reviewed the root cause process with licensee personne Discussions revealed that the primary reason the licensee's root cause was " inadequate program design" was that the licensee considered the inappropriate action to be failure to reset the card thumbwheel to the correct position (a step the procedure did not address), not that the shortcut was evoked in the first place. The inspectors concluded that the inappropriate action was taking the shortcut to set the card thumbwheel to zero, which deviated from the procedure's instructions. The inspectors referenced a human error root cause block in the licensee's " Human Errors or inappropriate Actions" chart, l entitled " Shortcuts Evoked," which described the inappropriate actions taken by the maintenance technicians. The licensee again reiterated its position on the inappropriate action being failure to restore the position once the shortcut was evoked. Licensee management did indicate that it generally does not condone informal practices such as this performed outside of approved plant procedure Immediate corrective actions for this event consisted of restoring the delta T/T-avg lead / lag card thumbwheel to the correct setting followed by successful completion of the

, ACOT. Additional corrective actions consisted of: (1) inspecting all lead / lag card thumbwheel settings on both Unit 1 and Unit 2 to ensure they were in the correct positions (this inspection revealed one non-safety related circuit associated with the turbine load inhibit control, C-16, improperly set at zero; the thumbwheel was restored to its correct position); (2) conducting a maintenance department meeting on February 4, 1999, which addressed this event and stressed the importance of maintaining appropriate configuration control; (3) communicating to technicians to discontinue setting l

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the thumbwheels to zero while performing card calibrations; and (4) revising the calibration procedures to incorporate a new testing philosophy in which evoking the shortcut will not be necessary. Corrective action number 4 had not been completed at the end of the inspection perio The licensee's failure to placc Unit 2 Channel 4 of the OPDT and OTDT circuitry in the tripped condition within six hours or ba in hot standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of its inoperability constituted a violation of TS 3.3.1. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Polic This violatbn is in the licensee's corrective action program as PIP 2-C99-0079. It is identified as NCV 50-414/99-01-03: TS 3.3.1 Non-Compliance Due To OTDT And OPDT Reactor Trip Functions Inoperable in Excess Of Action Statement Limits. This LER is close M8.2 (Closed) URI 50-413.41 t/98-07-03: Nuclear Instrumentation Deviation from Calorimetric During Moderator Temperature Coefficient Test This URI resulted from the inspectors' observations during the Unit 2 end-of-cycle 9 moderator temperature coefficient (MTC) determination on June 9,1998. The licensee's procedure for this TS-required measurement, PT/0/A/4150/128, Revision 7, Moderator Temperature Coefficient of Reactivity Measurement, allowed a six-degree Fahrenheit reduction in average reactor coolant (NC) system temperature (T-avg) with reactor power held constant. The procedure accomplished this with a boration of the NC system and subsequent dilution to return T-avg to its reference temperature (T-ref). Reactivity balances were conducted prior to the boration, following the boration, and following the dilution to measure the MTC and determine whether it met the TS acceptance criterio The inspectors noted on June 9,1998, as a result of the T-avg reduction by six degrees, that all four channels of the power range nuclear instruments (PRNis) were deviating by more than two percent from the indicated secondary heat balance (calorimetric) value of approximately 93 percent power. The PRNis were indicating as low as 88 percent power, or five percent below actual (calorimetric) reactor power. The PRNis deviated by more than two percent in this non-conservative direction from the calcrimetric value for approximately four to five nours. The attenuating affect of the T-avg reductic n on the nuclear instruments was described in more detail in IR 50-413,414/98-07 The inspectors were concerned that the PRNis were indicating so much lower than actual power and questioned: (1) whether the power range neutron flux high trip set point (109 percent) and allowable value (110.9) specified in TS 2.2.1 were effectively increased for the four channels simultaneous!y, placing Unit 2 in a condition outside its design basis or not covered by TS; and (2) whether the licensee should have adjusted the PRNis to within two percent of the calorimetric value, as specified by the TS 4. surveillance requirement for instrument calibratio To address these concems, the licensee performed a study of those UFSAR Chapter 15 accidents for which the power range high flux trip was assumed, and revisited its previous position on not requiring an adjustment of the PRN!s when they deviate by more than two percent from calorimetric during this test. The licensee also provided the inspectors with the 10 CCR 50.59 safety evaluation from 1990 that accompanied the change to Procedure PT/0/A/4150/12B increasing the T-avg reduction to six degree .

The licensee documented its accident study in PIP 0-C98-2045. It considered reactivity and power distribution anomalies, as well as control rod ejection events covered in Section 15.4 of the UFSAR. The licensee concluded that, although the power range hi-flux trips were credited, other trip functions (over temperature delta T, pressurizer hi pressure) were also credited for events such as an uncontrolled bank withdrawal at ,

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power. The licensee concluded that, for slow withdrawals of Bank D (the only control bank not fully withdrun during the MTC test) a subsequent NC system temperature increase or more neutron leakage would offset the attenuating effect of the reduced T-avg. For rapid reactivity insertions, the power range high positive rate trip (although uncredited for this event) would also be available. The licensee concluded that, if needed, the power range hi flux trip would have occurred before the 113.2 percent assumed in the accident anaF,* sis, based on the relatively large MTC at the end of cycle combined with the initial position of Bank D. The inspectors verified that UFSAR Section 15.4.2.2, Uncontrolled Rod Cluster Control Assembly Bank Withdrawal at Power, indicates that a reactor trip on high neutron flux is assumed to be actuated at the conservative value of 113.2 percent of nominal full power. This implied that the TS ~

allowable value was selected conservatively to maintain the plant within its design basi However, the licensee's evaluation did not address whether any necessary power range high neutron flux trips would have occurred before the TS allowable value was exceeded. For rod ejection events, in which UFSAR Chapter 15 credits both the power range hi-flux and high positive flux rate trips, the licensee provided a similar discussion to that r oted above for rod control and reactivity anomalie To address the inspectors' concern regarding compliance with TS 4.3-1 (now TS SR 3.3.1.2 under the improved TS (ITS)), the licensee changed Procedure PT/0/A/4150/128. The change (Revision 9) required technicians to adjust the PRNis to within two percent of the steady state calorimetric value whenever the rolling 15-minute average power indication for an affected channel deviated by more than that amoun The new TS Bases for SR 3.3.1.2 states that if the calorimetric exceeds the Nuclear Instrumentation System (NIS) channel output by greater than two percent rated thermal

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power, the NIS is not declared inoperable, but must be adjusted. If the NIS channel output cannot be properly adjusted, the channelis declared inoperable. The licensee employed this approach during the recent Unit 1 end-of-cycle 11 MTC measurement on February 14,1999. The inspectors observed the February test and considered the licensee's corrective actions reasonable to ensure compliance with TS SR 3.3. The licensee further reviewed its basis for choosing a six-degree T-avg reduction instead of a lesser value that would minimize the attenuating effect on the PRNis. The licensee concluded that a cooldown of six degrees provided a balance between reducing the potential impact of errors from the boron sampling (the error impact goes up witl: smaller reductions in T-avg), and having too large of a cooldown that extends the plant transient for no appreciable gain in MTC measurement. The licensee stated that it considered this

. test to be a Condition 1 event, as described in UFSAR 15.0, in that it should be categorized under the heading of Operation with Permissible Deviation as " Testing as allowed by Technical Specifications." Tt 3 licensee arrived at this conclusion because this test was required by the TS and NC / stem temperature was maintained well within TS allowable limit The inspectors reviewed the 199010 CFR 50.59 safety evaluation. All questions evaluating the possibility of an unreviewed safety question (USQ) with regard to the

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T-avg reduction were answered "no." These included: (1) may the probability of a malfunction of equipment important to safety previously evaluated in the FSAR be increased and (2) will the margin of safety as defined in the bases to any TS be reduce The evaluation only addressed the fact that the proposed six-degree temperature reduction exceeded the four-degree T-avg /T-ref deviation assumed in normat accident analyses (then Section 15.0.3.2), and that such deviations were generally allowed by the FSAR (then Section 15.0.1.1). The licensee did not consider the possible effects of the T-avg reduction on the function of the PRNis and the potential for reduction of margin of safety associated with those accidents for which the power range high flux reactor trip was credited. No consideration was given for the possibility of requiring a TS change to allow conducting the test without performing adjustments when the PRNis deviated by more than two percent from calorimetric value The licensee's 1990 safety evaluation allowed procedural inadequacies to exist for over eight years that potentially involved a USO or necessitated a TS change. The inspectors concluded that the failure to provide an adequate safety evaluation to address the potential USQ or TS requirements as it related to Procedure PT/0/A/4150/12B constituted a violation of 10 CFR 50.59. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PIP O C98-2045. It is identified as NCV 50-413,414/99-01-04: Failure to Conduct An Adequate 10 CFR 50.59 Safety Evaluation for the End-of-Cycle Moderator Temperature Coefficient Test Proce. dure. The URIis close M8.3 (Closed) LER 413/96-011: Two Channels of Over Power Differential Temperature Inoperable This issue was previously discussed in IR 50213A14/9611. The inspectors conducted an additional review of the October 1996 Channel A and B delta-TIT-avg loop calibrations to determine the availability and adequacy of proceduralinstruction Work Orders 96083140-01 and 96083131-01 were used to calibrate the A and B channels, respectively. The work order instructions were to calibrate each channel using Procedure IP/1/A/3222/76A (768), Cahbration Procedure for 4TTT-avg Protection Channel 1 (Channel 2), and perform a functional test per procedure. The functional tests were described in Section 10.11, " Restoration,"in each channel's procedure. In 1996, the functional test requirement was to perform a " channel check," or compare each individual channel indication for delta-T, T-avg, OPDT, and OTDT with the same indications for the other three channels. The acceptance criteria was satisfied if the difference between the highest and lowest indications for each parameter was less than or equal to four percent and the associated trip status light indicators in the control room were extinguishe The completed work orders reviewed by the inspectors for Channels A and B indicated that the two delta-T loops were indicating three percent lower than Channels C and D, which still satisfied channel check requirements. Loops C and D were calibrated or 3 checked later that day, but with different (non-faulty) test leads and by a second 1 maintenance crew. Documentation in the work orders indicated that operations personnel had informed maintenance technicians that the three percent difference did not render the channels inoperable. A later investigation by engineering concluded that I the Channel A and B OPDT functions actually were inoperable simultaneously I

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(constituting an NRC reportable entry into TS LCO 3.0.3) and intermittently during a five and one-half hour period. This was becaJs0 the tWo channels' margins to their trip set points had increased by more than three percent (Unit 1 TS Limit) for intermittent periods following their mis-calibrations with. faulty test leads (discussed in IR 50-413,414/98-11).

Although it was also r lfected, the OTDT function was not inoperable for more than one instrument channel simultaneously, nor were the OPDT or OTDT functions inoperable for any individual channelin excess of the TS LCO tim Problem Investigation Progress (PIP) Report 1-96-2789 indicated that technicians initially resolved the indicated difference between Channel A and the other three channels (found during a channel check before the latter three were adjusted) as being " correct" since they knew the other channels still needed to be calibrated. When a cross-channel check was performed between Channels A and B after both were calibrated, the results agreed. It was not until all four channels had been calibrated or adjusted and a channel check performed, that technicians from the second crew scrutinized the discrepancy between the two sets (A,B vs. C,D). From a review of all available data, the inspectors concluded that, even with the indicated differences, the instrument loops all satisfied the four-percent channel check acceptance criterion. No TS violations occurred since the channels were not inoperable for time periods exceeding that allowed by LCO 3.0.3 or TS 3.3.1. No other regulatory violations were identified. This LER is close M8.4 (Closed) Violation (VIO) 98-208-01023: Failure to Take Corrective Action for a Low Flow Condition Associated with the Unit 2 A-Train Ventilation System This vio!ation concerned the licensee's identificat!on of a low flow condition associated with Unit 2 A-train auxiliary building ventilation (VA) system. After identification, prompt corrective action was not taken which resulted in the system failing to meet an 18-month surveillance test required by TS 4.7.7. The licensee documented this violation in PIP 0-C9.8-2414, Sequence Numbers 3 and 6. By letter dated July 12,1998, the licensee acknowledged the violation, attributing it to personnel errors. The licensee's immediate corrective 'ctions consisted of removing the flow straighteners in the VA ductwork, retesting the system, and training all operations, engineering, and safety assurance person. el to reinforce management's expectations regarding TS requirements as thuy relate to operability. A root cause evaluation was performed and the results were documented in PlP 2-C98-1077. Corrective actions taken to avoid further violations included: training for groups in engineering to refresh knowledge of operability and to communicate lessont : earned from recent NRC inspections and self-assessments; a surveillance test working group was established to review the surveillance program requirements for the ITS; and Self-Assessment Number MSE 01-9S " Operability Evaluation Assessment," was conducted and the assessment findings were documented in PIP 0-C98-1485. A followup self- assessment of the implementation of the inspection findings identified in the first self- assessment was scheduled to be completed by April 30,1999. To evaluate the licensee's corrective actions, the inspectors interviewed licensee personnel; reviewed the results of the self-assessment delineated in PIP 0-C98-1485; reviewed the root cause analysis; and reviewed the training plan and attendance records. Although the followup self-assessment had not been performed, it had been assigned and scheduled. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance and prevent the recurrence of similar circumstances. This item is close _

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M8.5 (Closed) VIO EA 98-208-01043: Failure to Verify Ful! Modification implementation in Accordance with tne Modification Manual This violation concemed the licensee's failure to verify that all activities described by Minor Modification CNCE-7901 (Resolution of System VA Filtered Exhaust Low Air Flow Concerns) had been implemented in the field before closing the modification on December 23,1996. As a result, three flow straighteners in the Unit 2 A-train auxiliary building filtered exhaust system that should have been removed by CNCE-7901 were left installed until removed on March 25,1998. The licensee documented this violation in PIP 0-C98-2414, Sequence Number 5. By letter dated July 12,1998, the licensee acknowledged the violation, attributing it to personnel errors. The licensee's immediate corrective actions for this discrepancy consisted of: removing the flow straighteners in the VA ductwork, retesting the system, and returning it operable status; reinforcing modification manual requirements with engineering; and reviewing other heating, ventilation, and air conditioning (HVAC) modifications for closeout issues. Corrective actions taken to avoid future violations consisted of performing Assessment 98-09 of the modification process. This assessment expanded the review beyond the scope of ventilation modification closecut issues. The results of the assessment were documented in PIP 0-C98-2442. The assessment reviewed a list of modifications selected at random, which included 20 elective and 22 corrective modifications; conducted intelviews with personnel involved in the process; and reviewed PIPS, violations, and LERs that occurred from January 1,1997, through May 31,1998. The assessment did not discover any problems concerning modifications being closed out or the modification not being properly implemented. To evaluate the licensee's corrective actio.is, the inspectors reviewed the results of the self-assessment; interviewed licensee personnelinvolved in the process; and reviewed training records. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance ,

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and prevent the recurrence of similar circumstances. This item is close M8.6 (Closed) VIO EA 98-208-02014: Failure to Revise f UFSAR Description of Normal VA System Operation This violation dealt with the licensee's failure to ensure that changes made during 1996 Modifications CE-61117 and CE-61118 to the auxiliary building filtered exhaust system to routinely operate the VA system in the filtered mode were reflected in revisions to the applicable sections (7.6.12.1 and 7.3.1.1.1) of the UFSAR. The licensee documented this violation in PIP 0-C98-2414 Sequence Number 7. By letter dated July 12,1998, the licensee acknowledged the violation attributing it to personnel errors and the fact that in 1996, the Update process was not as effective for tracking and monitoring changes to the UFSAR. A tracking tool to document pending changes was implemented in early 1997 and UFSAR and 10 CFR 50.59 reports presently receive more thorough engineering oversight. The licensee's immediate corrective actions included: changes to the UFSAR resulting from Modifications CE-61117 and CE-61118 were immediately incorporated into i the UFSAR Program Tracking Tool for pending changes; a review of other HVAC modifications was performed to ensure UFSAR changes were included; and a single individual was assigned responsibility for maintaining records for both the UFSAR and 10 CFR 50.59 data bases. Corrective actions taken to avoid further violations will be to t incorporate the changes for CE-61117 and CE-61118 into the next UFSAR update. To I evaluate the licensee's corrective actions, the inspectors interviewed licensee personnel and reviewed marked up copies of the present UFSAR which incorporated changes to paragraphs 9.4.3.2.3,9.4.3.2.5,7.3.1.1.1, and 7.6.12.1. The revision to the UFSAR was j i

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presently in printing and the update to the UFSAR was scheduled to be effective on April 1,1999. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance and prevent the recurrence of similar circumstances. This item is close M8.7 (Closed) LER 50-413/98-0901 Both Trains of Control Room Area Ventilation inadvertently Disabled During Restorat:)n Caused by inadequate Maintenance Procedures On February 4,1998, one train of the control room ventilation system was removed from service to allow implementation of a minor modification. The purpose of the minor modification was to install two new access panels to the filter housing of Air Handling Unit 2 CR-AHU-1. The two old access panels were removed; however, difficulties were encountered in installing the new access panels. Although not within the work scope of the minor modification, a third access panel on the back side of the air handing unit was opened. This allowed the maintenance workers to look for obstructions on the inside of the housing and to equalize pressure across the filter housing. The workers later concluded that the new access panels had incorrect dimensions, reinstalled the old panels and notified operations that the control room ventilation system could be restored to service. However, since the work scope changed without restoration controls in place to ensure the third access panel was closed following the maintenance work, the panel was subsequently left slightly open. On February 5,1998, during restoration of this train to service, both trains of the system were inadvertently disabled. With an access panel open, air from the operating ventilation train could flow back through the opening, which effectively prevented maintaining a positive pressure in the shared control room. As a result, the shared control room depressurized and both units entered Technical Specification 3.0.3. The depressurization was subsequently realized and the panel shu This LER attributed the cause of this event to inadequate procedures in that the procedures governing the work activity did not provide instructions for opening and restoring the third access panel. The LER also stated that a human performance error for inadequate self-checking was the contributing cause. Corrective actions for this LER were documented in PIP 0-C98-0476 and were verified by the inspectors. The inspectors determined that adequate corrective actions were taken to address ventilation system expectations, as well ar 6 human performance aspects of the event, although these corrective actions werc ..vt specifically documented in the LE Failure to properly address the broader issue of weak expectations for controlling work associated with ventilation systems was also discussed as a corrective action concern in NRC IR 50-413,414/98-15. In that report, the inspectors noted that the licensee's corporate office conducted an investigation of ventilation system reportable events in July 1998 and reached similar conclusions regarding the adequacy of the root cause determination and corrective actions documented in LER 50-413/98-001. The licensee's investigation findings were documented in Event Investigation Team Report SA-98-6 The inspectors also concluded that the root cause and corrective action to address events documented in the referenced LER were not well documented; however, the licensee was effective in identifying this problem with the LER quality through their internal audit proces Duke Power Nuclear System Directive 704 " Technical Procedure Use and Adherence" states that,"If at any time during the performance of a procedure, the anticipated results are not, or will not be obtained, the performer should immediately STOP." This failure to follow procedure is a violation. This Severity Level IV violation is being treated as a NCV

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consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PlP 0-C98-2518. It is identified as NCV 50-413/99-01-05: Failure to Comply with Nuclear System Directive 7C4 During Control Room Ventilation Maintenance Work. This LER is close M8.8 (Closed) LER 50-414/98-002: Violation of Auxiliary Building Filtered Exhaust Ventilation System Technical Specification 3.7.7 Due to Low Flow from Filtered Exhaust Fan 2A This LT_R reported that or March 16,1998, a test was performed on auxiliary building filtered ventilation exhaust system (ABFVES) 2A. This test indicated that the minimum flow required by TS 3.7.7 was not met. A determination, based on an engineering evaluation, was made that ABFVES 2A was still operable with less than TS required flo On March 24, a question we i raised during the operability review process concerning the basis of the engineering evaluation and a decision was made to retest ABFVES 2A. On March 25, additional testing was performed and ABFVES 2A did not meet the TS required flow rate. The ABFVES 2A was declared inoperable. Flow blockages were identified and removed. The ABFVES 2A was retested and was declared operable. The period of inoperability was determined to be greater than the TS allowed outage time. T e LER identified the root cause of this event was inadequate menagement monitoring and assessment of the implementation of the operability program with ' contributing cause of inadequate procedures. Corrective actions included communicating expectations on the operability process to appropriate groups and revising ventilation test procedure In NRC IR 50-413,414/98-03 an inspector reviewed the low flow problem for ABFVES 2 After review of applicable requirements, PIP reports that documented Unit 2 A-train ventilation system low flow conditions (identified on February 9,1998, March 16,1998, March 25,1998), and associated surveillance procedures, eight apparent violations were identified. These apparent violations involved noncompliance with the requirements of TS 3.7.7; 10 CFR Part 50, Appendix B, Criteria XI and XVI; 10 CFR Part 50.71e; and TS 6.8.1.a. On May 14,1998, an open predecisional enforcement conference for EA Case Number 98-208, was conducted in the Region II office with Duke Energy Corporation (DEC). Based on information developed during the inspection documented in NRC IR 50-413,414/98-03, and the information provided by DEC during the conference, the NRC determined that violations of regulatory requirements occurred. A Jotice of Violation was issued on June 11,1998. NRC IR 50-413,414/98-07 documented the escalated enforcement action (EA 98-208) and identified six violations. A Severity Level I!! violation, identified 5 problems regarding the actions associated with the VA ano a Level IV violation identified a failure to update the UFSAR to include a modification performed in 1996. Corrective action for each of the six violations were addressed a. i closed in this report. Since the NRC addressed this issue in detail and took appropria') enforcement action, this LER is close M8.9 (Closed) VIO EA 98-208-01013: Failure to Comply with Technical Specification 3.7.7 with One Train of the Unit 2 Auxiliary Building Filtered Exhaust (VA) System inoperable This violation concemed the licensee's identification of a low flow condition associated with Unit 2 A-train VA system. After identification, the licensee failed to take prompt corrective action, which resulted in the system failing to meet an 18-month surveillance test required by TS 4.7.7. The licensee documented this violation in PIP 0-C98-2414, Sequence Numbers 3,4, and 6. By letter dated July 12,1998, the licensee acknowledged the violation, attributing it to personnel errors. The licensee's immediate I

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corrective actions consisted of training all operations, engineering, and safety assurance personnel to reinforce management's expectations regarding TS requirements as they i relate to operability. Corrective actions taken to avoid further violations included: aining for groups in engineering to refresh knowledge of operability end to communicate lessons learned from recent NRC inspections and self-assessments; a surveillance test working group was established to review the surveillance program requirements for the iTS; and a followup self-assessment was scheduled to be completed by April 30,1999. To evaluate the licensee's corrective actions, the inspectors interviewed licensee personnel, reviewed training records and lesson plans; reviewed the results of the self-assessment; and the results of the surveillance test working group's program review. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance and prevent the recurrence of similar circumstances. This item is close M8.10 LClosed) VIO EA 98-208-01033: Failure to Follow Procedures Related to Operability and Surveillance Testing This violation concerned the licensee's failure to implement administn:tive and surveillance procedures which resulted in: the VA system not being declared inoperable when it failed to meet TS acceptance criteria; formal documented operability notification not being provided as required; and three flow straighteners being left in the VA system ducting, contrary to Minor Modification CNCE 7901.4.7.7. The licensee documented this violation in PIP 0-C98-2414, Sequence Numbers 2,3,4, and 6. By letter dated July 12, 1998, the licensee acknowledged the violation, attributing it to personnel errors. The licensee's immediate corrective actions consisted of: training of all operations, engineering, and safety assurance personnel to reinforce management's expectations regarding TS requirements as they relate to operability; performing a self-assessment of operability evaluations; and establishing a surveillance test working group to review the surveillance program requirements. Corrective actions taken to avoid further violations included: conducting training for groups in engineering to refresh knowledge of operability and to communicate lessons learned frcm recent NRC inspections and self-assessments;

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establishing a surveillance test working group to review the surveillance program requirements for the ITS; scheduling of a followup self-assessment to be completed by April 30,1999; and the revising of fourteen periodic test (PT) procedures. To evaluate the licensee's corrective actions, the inspectors interviewed licensee personnel; reviewed 1 training records and lesson plans; reviewed the results of the initial self-assessment; the j results of the surveillance test working group's program review; and reviewed a 1 representative sample of revised PT procedures. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance and prevent the l recurrence of similar circumstances. This item is close M8.11 (Closed) VIO EA 98-208-01053: Failure to Provide Adequate Test Controlin Accordance ,

with 10 CFR Part 50, Appendix B, Criterion XI, and ANSI N510-1980 l i

i This violation concems the licensee's failure to establish a consistent, repeatable test methodology to ensure that VA system performance trends were reliable indicators of flow degradation. The licensee documented this violation in PIP 0-C98-2414 Sequence Number 2. By letter dated July 12,1998, the licensee acknowledged the violation attributing it to personnel errors. The licensee's immediate corrective actions consisted of a complete review of HVAC procedures. Corrective actions taken to avoid further violations were the revision of fourteen PT procedures. To evaluate the licensee's corrective actions, the inspectors interviewed licensee personnel and reviewed a l

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representative sample of revised procedures. The inspectors determined that the licensee had taken appropriate measures to achieve full compliance and prevent the recurrence of similar circumstances. This item is close M8.12 (Closed) insoector Followuo item (IFI) 50-413.414/97-10-2: Review Revision to EDM-101 for Calculation Quality This issue concerns six PIPS that were examples of the poor performance of independent reviewers / checkers in that the errors were not identified during the independent review process. To address this issue, the licensee issued PIP 0-C97-2283 which indicated that EDM-101 should be revised to provide more consistent calculation quality. The licensee revised EDM-101, issuing Revision 9, on June 6,1998. In addition, the licensee conducted training, for all engineers who perform calculations, on the implementation of EDM-101 Revision 9. To evaluate the licensee's actions related to this issue, the inspectors reviewed EDM-101 Revision 9 and the lesson plan and attendance records for j

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the implementation training for EDM-101 Revision 9. The inspectors concluded that the licensee had taken appropriate actions to address errors that were not identified during the independent review process. This item is close ,

M8.13 (Closed) LER 50-413/98-005: Missed Technical Specification Surveillance on Auxiliary Building Ventilation System due to Misinterpretation of Surveillance Requirement 4.7.7. On May 14,1998, it was discovered that the test procedure used for TS Surveillance Requirerent 4.7.7.d.1 (testing of VA system filter pressure drop) did not ensure compliance with the TS. The procedure did not include a measurement of the pressure drop across the moisture separator as specified in Surveillance Requirement 4.7.7. This problem was discovered as a result of a review of HVAC procedures that was prompted by the event described in LER 414/98-002. The root cause was determined to be a misinterpretation of the TS surveillance requirement which resulted in an inadequate procedure. Corrective action was to enter both trains of the VA system of both units in TS I 4.0.3 and test them utilizing a temporary test procedure that included a measurement of the pressure drop across the moisture separator. The normal test procedures for the VA system were to be revised to be compatible with the requirements of TS 3.7.7. The issue ;

was entered into the licensee's corrective action program as PIP 0-C98-1786. The I inspectors verified the completion of corrective actions listed in that PI The failure to measure the pressure drop across the moisture separator is a violation of TS 4.7.7.d.1. This Severity Level IV violation is being treated as a NCV, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PIP 0-C98-1786. It is identified as NCV 50-413/99-01-06: Failure to Test Auxiliary Building Ventilation per Technical Specification 4.7.7.d.1. This LER is ciose !

M8.14 (Closed) LER 50-413/98-008: Noncompliance with TS Requirements for Waste Gas  ;

System Oxygen Analy: er Caused By Errors in Administrative Controls j

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On May 6,1998, during a review of a 10 CFR 50.59 evaluation, a potential l noncompliance, with TS involving the waste gas system was identified. An engineering l review of this issue was performed which identified that the oxygen analyzers at the inlet l l

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of the recombiners had setpoints higher than the TS limit and could nct be used to satisfy the TS requirements. The oxygen analyzers at the outlet of the recombiners had setpoints within the TS limit, but could only be used when the recombiners were not in operation. A third set of oxygen analyzers, the system oxygen analyzers could be used to satisfy the TS requirements at any time. On June 11,1998, a situation was identified in which the system oxygen analyzers were removed from service, and other analyzers were improperly credited for satisfying the TS requirement 3.11.2.1. Consequently the

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applicable action statement was not implemented. This situation occurred November 3-7, 1997. This was a condition prohibited by the TS. Station administrative documents erroneously permitted the unconditional use of the other analyzers. The condition had been in existence since 1989. The root cause of the initial error could not be determine The station administrative documents have been revised to meet TS requirement Setpoints for the recombiner inlet analyzers have been reduced to within the TS limits to permit their use in meeting the TS requirements. The issue was entered into the licensee's corrective action program as PlP 0-C98-1701. The inspectors verified the completion of corrective actions listed in that Pl The failure to perform TS required limiting condition for operation actions is a violatio This Severity Level IV violation is being treated as a NCV, consisted with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PIP 0-C98-1701. It is identified as NCV-50-413/99-01-07: Failure to Monitor the Waste Gas System per Technical Specification 3.11.2.1. This LER is close lil. Enaineerina E3 Engineering Procedures and Docurr.entation E Refuelina Water Storace Tank Level Channel 3 Inadvertentiv Placed in The Tripped Condition Inspection Scope (93702. 37551)

The inspectors reviewed Catawba Elective Minor Modification CNCE-9668, PIP 1-C99-0597, and associated plant procedures and work orders to address a configuration error identified during a modification to replace the Unit 1 Refueling Water Storage Tank (FWST) Channel 3 level transmitter. The configuration error resulted in the unit operating with an inoperable channel placed in the " tripped" condition for a period greater than that allowed by TS 3.3.2. The licensee reported this item to the NRC per 10 CFR 50.72 (b)(1)(ii)(A) as an event resulting in the unit being in an unanalyzed condition that significantly compromised plant safety, b. Observations and Findinos On February 15,1999, at approximately 6:30 p..<.., _ m % ..gnt shift contru room operators questioned the validity of an illuminated bistat onnunciator light for FWST level Channel 3, which indicated the channel was in a tripped condition. Catawba minor modification 98060233-04, which was being implemented to replace the associated transmitter,1FWLT5120, was in progress and had rendered the channelinoperabl Following the operators' observation, maintenance technicians verified that FWST level Channel 3 was indeed in the incorrect, tripped condition. The technicians placed the

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channel in the correct " bypassed" condition at 9:47 p.m. FWST level Channel 3 was also erroneously listed in the TS Action item Log as of 8:50 a.m. that morning as being in the

" bypassed" condition. Technical Specification 3.3.2, Table 3.3.2-1 requires four channels of FWST levelinstrumentation to be operable during Modes 1-4. With one channel inoperable, that channel is to be placed in the " bypassed" condition within six hours, or the unit is to be placed in hot standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The inspectors verified the following morning that the instruments and associated trip status lights were indicating properly for all four FWST level channel The failure to place the channel in the bypassed condition or be in hot standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was contrary to TS requirements. The licensee generated PlP 1-C99-0597 and initiated a root cause investigation to address this even The inspectors met with operations and engineering personnel to discuss this event and urderstand what procedural guidance or work instructions were in place during the modification. Elective minor modification CNCE-9668 contained a section, " Isolation Requirements For WO # 98060233 -Channel 3 - 1FWLT5120," that provided instructions regarding which component / device was to be isolated and the actions required. The inspectors' review of the isolation instructions indicated that performance of Sections 1 and 10.2 of Procedure IP/1/A/3222/001C, Revision 021, Refueling Water Storage Tank Level Channel 3, were required for adequate isolation. Discussions with plant personnel indicated that maintenance technicians were not clear as to the exact portions of the procedure to be performed. Communications between the maintenance technicians and the system engineer did not adequately clarify the steps within Sections 10.1 and 10.2 to be performed. This resulted in technicians placing Channel 3 in the tripped conditio In making a preliminary safety significance determination, the inspectors determined that the FWST levelindications are referenced in eme gency operating procedures when performing actions required for cold leg recirculation, at which time the containment sump is the suction source for the emergency core cooling system (ECCS) components. When an FWST low level is sersed by two channels during a safety injection event, the two-out-

^f-four coincident logic is satisfied, which causes an automatic swapover of the suction source from the FWST to the containment sump. With an FWST level channelin the tripped condition, the two-out-of- four logic is changed to a one-out-of-three logic. A spurious failure of one of the remaining operable channels, coincident with a safety injection signal, would result in a premature automatic swapover to the containment sump .

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when sufficied inventory may not be available to provide adequate supply to the ECCS

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component The inspectors were informed that a review of work documents revealed two additional channels that had been inappropriately isolated (Unit 1 Channel 2, and Unit 2 Channel 1)

when they were modified in December 1998. These two channels were " tripped" for ,

periods in excess of TS limits as weli. Preliminary corrective actions to preclude  !

! recurrence following the third event included revising the modification instructions to l ensure %chnicians knew which specific steps in Procedure IP/1/A/3222/001C to perform

) in . . inoperable channels. The inspectors noted during subsequent transmitter i rept ent offorts for Unit 2 (Channel 4 and Channel 3) that the associated " tripped" I status lights in the control room were extinguishe _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ - _ _ - - - _ - -

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At the close of the inspection period, the licensee was preparing to submit LER 50-413/99-01 (Inoperable RWST Level Channels Results in Operation Outside of the Design Basis) to document this event, its safety significance, root cause, and any proposed corrective actions. The inspectors wiH review this event for safety and regulatory significance upon issuance of the LE Conclusions The licensee identified three occurrences of a degraded plant condwn where inoperable FWST level channels were in the " tripped" condition instead of the required " bypassed" condition for periods exceeding that allowed by TS. This occurred during transmitter replacements for the associated channels. This item was reported to the NRC as an event placing the unit in an unanalyzed condition significantly compromising plant safet It will be addressed for regulatory and safety significance when the LER has been issue E8 Miscellaneous Engineering issues (92903)

E (Closed) Accarent Violation (eel) 50-413.414/98-12-02: Auxiliary Feedwater System Outside Design Basis due to Potential Adverse ' eraction Between CACST and CA During Swapover During an inspection conducted December 23,1998, through January 13,1999, the NRC examined the circumstances associated with a licensee-identified design deficiency that rendered the auxiliary feedwater system outside its design basis. LER 50-413/97-03 was submitted on June 16,1997, to communicate the licensee's problem determination and corrective action The NRC's inspection findings were documented in NRC IR 50-413,414/98-12 with the issue characterized as an eel. By letter dated February 25,1999, the NRC notified the licensee of an exercise of discretion (EA 99-019)in accordance with Section Vll.B.3 of the Enforcement Policy. The letter documented the closure of the apparent violation and completed the NRC's action on the issue. Accordingly, the apparent violation is administratively closed in this repor IV. Plant Suogo_r1 i R1 Radiological Protection and Chemistry (RP&C) Controls R General Comments (71750)

I The inspectors assessed the implementation of the ALARA program during the Unit 1 ice condenser lower inlet door beam cooler inspection on March 5,1999. The inspectors reviewed radiation protection (RP) survey maps, observed RP pre-job briefings, and partn.ipated in the at-power ice condenser inspection. Inspectors concluded that RP l technicians minimized dose by using detailed and comprehensive planning, and providing l good information to the licensee's inspection tea l During a separate plant tour, the inspectors noted minor housekeeping concerns in the 2A residual heat removal / containment spray heat exchanger room, including trash in the room and a power cord that extended out of the room and past the posted contaminated

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area boundary without being secured. The inspectors were concemed that a portion of the power cord located in the contaminated area could be pulled further outside the boundary and increase the risk of spreading contamination. The inspectors informed licensee personnel who immediately corrected these item R1.2 Conduct of Radioloaical Protection and Controls i Inspection Scope (83750) I The inspectors reviewed personnel monitoring, radiological postings, high radiation area controls, posted radiation dose rates, contamination controls within the radiologically controlled area (RCA), and container labeling. In addition, ALARA work planning, prejob worker briefings, and job execution observations were performed. The inspectors also reviewed licensee secords of personnel radiation exposure and discussed ALARA program details, implementation and goals. Requirements for these areas were specified in 10 CFR 20 and Technical Specifications (TS). Observations and Findinas The inspectors toured the health physics facilities, the auxiliary building, outage storage warehouse, radioactive waste storage areas, turbine building, hot machine shop and waste monitor tank building. Radiologically controlled areas including radioactive material <

storage areas (RMSAs), high radiation areas, and locked high radiation areas were !

appropriately posted and radioactive material was appropriately stored and labele I The inspectors reviewed operational and administrative controls for entering the RCA and performing work. These controls included the use of radiation work permits (RWPs) to be I reviewed and understood by workers prior to entering the RCA. The inspectors reviewed selected RWPs for adequacy of the radiation protection requirements based on work scope, location, and conditions. For the RWPs reviewed, the inspectors noted that appropriate protective clothing, and dosimetry were required. During tours of the plant, )

the inspectors observed personal dosimetry was being worn in the appropriate locatio !

The inspectors discussed ALARA goals and annual exposures with licensee management and determined the organizational structure and responsibilities for the ALARA staff were clearly defined in organizational charts. The site ALARA program was reviewed in detail and found to contain appropriate ALARA outage planning. The inspectors discussed boundary postings and control for the extended burnup fuel that will be discharged during the Unit 1 refueling outage. The licensee had measured radiation levels during fuel transfer (or the first three refuelings and verified shielding and measured minimal radiation levus. The licensee will measure several selected points during the fuel transfer to l reaffirm the previously measured low radiation levels and control points. Dose rates and i radiologic.al controls associated with movement of the extended burn-up fuel will be I reviewed during subsequent inspection Calender Year 1998 site exposure goal was set at 142 person-rem. The site person-rem total for 1998 was measured as 161.818 person-rem. Approximately 127 person-rem was accumulated as a result of Unit 2 refueling activitie !

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rilSTORICAL STATION EXPOSURE YEAR PERSON / REM

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1991 462 1992 394 1993 396-1994 206 1995 462 1996 302 1997 264 1998 162 The inspectors noted that station radiation exposure has continued to trend lower during the last three years. Records reviewed showed that the licensee was tracking and trending personnel contamination events (PCEs). The licensee had tracked -

approximately 139 PCEs for the 1998 calender year. The inspectors reviewed the contaminated square footage data and observed that the licensee was tracking approximately 1387 square feet or about 0.9 of the controllable are Conclusions Radiological conditions in radioactive material storage areas, health physics facilities, turbine building and waste storage building were found appropriate and the areas were properly posted and material appropriately labeled. Personnel dosimetry devices were appropriately wom. Radiation work activities were appropriately planned. Radiation worker doses were being maintained well below regulatory limits and the licensee was maintaining exposures ALARA. The station radiation exposure has continued to trend lower during the last three year R2 Status of Radiation Protection (RP) Facilities and Equipment R Environmental and Process and Effluent Radiation Monitors Inspection Scope (84750. 86750)

The inspectors reviewed selected licensee procedures and records for required surveillances on the radiological environmental and process and effluent radiation monitor b, Observations and Findinas During tours of the auxiliary building, radwaste building, turbine building and waste -

monitor tank building, the inspectors observed the physical operation of process radiation effluent monitors (EMFs) in service. The inspectors took independent smears and verified that areas were appropriately posted. The inspectors reviewed selected radiation and process monitor surveillance procedures and records for performance of channel checks, source checks, channel calibrations, and channel operational tests. The S

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inspectors determined the licensee was performing checks described in TS and selected 3 commitments in Chapter 16.7 of the Updated Final Safety Analysis Report (UFSAR). !

l The inspectors reviewed selected licensee procedures and resords for required surveillance of the radiological environmental monitors and observed the operation of three of five stations in the vicinity of the plant. There were no problems observe Conclusions The inspectors concluded radiation and process effluent neonitors and environmental monitors were being maintained in an operational condition in cor,.pliance with TS requirements and UFSAR commitment R7 Quality Assurance in Radiation Protection and Chemistry R Licensee Quaktv Assurance Activities and Self-Assessment Proarams Inspection Scope (83750. 84750. 86750)

Licensee quality assurance activities and self-assessment programs were reviewed to determine the adequacy of identification and corrective action programs for deficiencies in the area of chemistry and health physic Observations and Findinas Reviews by the inspectors determined that quality assurance audits and self-assessment efforts in the areas of chemistry and RP were accomplished by reviewing chemistry and RP procedures, observing work, reviewing industry documentation, and performing plant walkdowns to include surveillance of work areas by supervisors and technicians during normal work coverage. Documentation of problems by licensee representatives were included in quality assurance audits and self-assessment report The inspectors found the nuclear assurance reports and job observations insightful, and detaiied. Identified items were trended and tracked for cloceout. A selected sample of closecut actions were determined to be timel c. Conclusions The inspectors determined the licensee was conducting formal RP and chemistry audits as required by TS and conducting self-assessments. The licensee was developing corrective action plans, trending, and completing corrective actions in a timely manne V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 17,1999. The licensee acknowledged the findings presented. When the inspectors expressed concem that human performance issues were not developed in the root cause determination for LER 50-414/98-007

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(discussed in Section M8.1 of this inspection report), the licensee reiterated its position that the event's root cause was an inadequate program design. No proprietary information was identifie X4 NRC Management Review Meeting of Open Violations The NRC recently revised NUREG-1600, Revision 1, " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy) by the addition of Appendix C. Appendix C, Interim Enforcement Policy for Power Reactor Severity Level IV Violations, effective March 11,1999, revises the NRC's enforcement approach for Severity Level IV violations. Appendix C permits closure of most Severity Level IV violations, based on the violation being entered into the licensee's corrective action program, as well as other considerations as describ sd in the Appendix. The NRC conducted a review of the following Severity Level IV violations, and considers it appropriate to close these violations consistent with Appendix C of the Enforcement Policy:

Corrective Action Procram Violation Number File Number 50-413,414/98-01-02 PIP C96-3285, PIP C98-0496, PIP C98-0447 50-413,414/98-01-05 PIP C97-1579 50-413/98-07-01 PIP C98-1716 50-413/98-07-05 PIP C98-3074 50-413/98-12-03 PIP C98-3427 50-413/98-08-02 PIP C98-0932 PARTIAL LIST OF PERSONS CONTACTED Licensee R. Beagles, Safety Assurance Manager M. Boyle, Radiation Protection Manager S. Bradshaw, Safety Assurance Manager G. Gilbert, Regulatory Compliance Manager R. Glover, Operations Superintendent P. Herran, Engineering Manager R. Jones, Station Manager G. Peterson, Catawba Site Vice-President F. Smith, Chemistry Manager R. Parker, Maintenance Manager INSPECTION PROCEDURES USED IP 37550: Engineering

- IP 37551: Onsite Engineering IP 61726: Surveillance -

IP 62707: Maintenance Observation

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IP 71707: Plant Operations IP 71750: Plant Support Activities IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-413,414/99-01-01 URI ESF Response Time Testing for VX Fan Suction isolation Valves (Section M1.2)

50-413,414/99-01-02 URI Notice of Enforcement Discretion for TS 3.3.7 and -

TS 3.3.8 Surveillance Requirements (Section M3.1)

50-414/99-01-03 NCV TS 3.3.1 Non-Compliance Due To OTDT And OPDT Reactor Trip Functions Inoperable in Excess Of Action Statement Limits (Section M8.1)

50-413,414/99-01-04 NCV Failure to Conduct an Adequate 10 CFR 50.59 Safety Evaluation for the End-of-Cycle Moderator Temperature Coefficient Test Procedure (Section M8.2)

50-413/99-01-05 NCV Failure to Comply with Nuclear Site Directive 704 During Control Room Ventilation Maintenance Work (Section M8.7)

50-413/99-01-06 NCV Failure to Test Auxiliary Building Ventilation per Technical Specification 4.7.7.d.1 (Section M8.13)

50-413/99-01-07 NCV Failure to Monitor the Waste Gas System per Technical Specification 3.11.2.1 (Section M8.14)

50-413/99-01-08 URI Past inoperability of Unit 1 ice Condenser Lower inlet Doors (Section M2.1)

50-413/99-02 LER Three RHR System Valves Did Not Meet Their ESF ,

Response Time Requirement Due to a Procedure Deficiency (Section M1.2)

50-413/99-03 LER Violation of TS Due to inoperable Ice Condenser ;

Lower inlet Doors Caused by Ice / Frost Buildup l Restricting Door Movement (Section M2.1) I i

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50-413/99-01 LER Inoperable RWST Level Channels Results in Operation Outside of the Design Basis (Section E3.1)

Closed 50-414/98-07 LER Mispositioned Thumbwheel on Process Control System Circuit Card Causes inoperability of Overtemperature and Overpower Delta Temperature Functions (Section M8.1)

50-413,414/98-07-03 URI Nuclear instrumentation Deviation from Calorimetric During Moderator Temperature Coefficient Test (Section M8.2)

50-413/96-011 LER Two Channels of Over Power Differential Temperature (OPDT) Inoperable (Section M8.3)

EA 98-208-01023 VIO Failure to Take Corrective Action for a Low Flow Condition Associated with the Unit 2 A-Train VA System (Section M8.4)

EA 98-208-01043 VIO Failure to Verify Full Modification implementation in Accordance with the Modification Manual (Section M8.5)

EA 98-208-02014 VIO Failure to Revise the UFSAR Description of Normal VA System Operation (Section M8.6)

50-413/98-001 LER Both Trains of Control Room Area Ventilation inadvertently Disabled During Restoration Caused by inadequate Maintenance Procedures (Section M8.7)

50-414/98-002 LER Violation of Auxiliary Building Filtered Exhaust Ventilation System Technical Specification 3.7.7 Due to Low Flow from Filtered Exhaust Fan 2A (Section M8.8)

EA 98-208-01013 VIO Failure to Comply with Technical Specification 3. with One Train of the Unit 2 Auxiliary Building Filtered Exhaust (VA) System inoperable (Section M8.9)

EA 98-208-01033 VIO Failure to Follow Procedures Related to Operability and Surveillar.ce Testing (Section M8.10)

EA 98-208-01053 VIO Failure to Provide Adequate Test Controlin Accordance with 10 CFR Part 50, Appendix B, Criterion XI, and ANSI N510-1980 (Section M8.11)

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50-413,414/97-10-02 IFl Review Revision to EDM-101 for Calculation Quality (Section M8.12)

50-413/98-005 LER Missed Technical Specification Surveillance on Auxiliary Building Ventilation System due to Misinterpretation of Surveillance Requirement - 4.7.7.d.1. (Section M8.13)

50-413/98-008 LER Noncompliance with TS requirements for Waste Gas System Oxygen Analyzer Caused By Errors in Administrative Controls (Section M8.14)

50-413,414/98-12-02 eel Auxiliary Feedwater System Outside Design Basis due to Potential Adverse interaction Between CACST and CA During Swapover (Section E8.1)

50-413,414/98-01-02 VIO Failure to Follow Plant Operating and Administrative Procedures- Four Examples (Section X4)

50-413,414/98-01-05 VIO Failure to Conduct 10 CFR 50.59 Safety Evaluation for Operable but Degraded Condition and Related Changes involving the Normal AFW Pump Suction Source (Section X4)

50-413/98-07-01 VlO Failure to Have Adequate Operations Procedures Addressing AFW System Design Temperature Limits and Operation of Valve 1CM-127 (Section X4)

50-413/98-07-05 VIO Failure '.o Take Prompt Corrective Actions to Prevet.t Recurrence of UST Over-Temperature Events and AFW System inoperability (Section X4)

50-413/98-12-03 VIO Failure to Conduct an Adequate 10 CFR 50.59 Safety Evaluation for Changes to Procedures AP-6 and AP-17 Potentially Affecting SSS Operability (Section X4)

50-413/98-08-02 VIO Failure to Declare Two CA System Pumps Inoperable During RN to CA Pipe Flush (Section X4)

Discussed 50-414/98-05 LER TS Violation Due to the Inoperability of the Ice Condenser inlet Doors Caused by Ice / Frost Buildup Restricting Door Movement (Section M2.1)

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LIST OF ACRONYMS USED ABFVES - Auxiliary Building Filtered Ventilation Exhaust System ACOT -

Analog Channel Operational Test ALARA -

As Low As Reasonably Achievable ASME -

American Society of Mechanical Engineers CA -

Auxiliary Feedwater (licensee's system designation)

CACST -

Auxiliary Feedwater Condensate Storage Tank CFR -

Code of Federal Regulations CRAVS -

Control Room Area Ventilation System eel - Escalated Enforcement item (Apparent Violation)

EMF -

Effluent Monitor ESF -

Engineered Safety Featur FWST - Refueling Water Storage Tank HVAC -

Heating Ventilation and Air Conditioning HX -

Heat Exchanger IFl -

Inspector Followup item

' ITS -

Improved Technical Specifications IWP - ASME Section XI Pump Performance Test IWV -

ASME Section XI Valve Stroke Test IR -

Inspection Report

KC - Component Cooling Water (licensee's system designation)

LCO - Limiting Conditions for Operation LER - Licensee Event Report LOCA -

Loss of Coolant Accident MTC - Moderator Temperature Coefficient NC -

Reactor Coolant System (licensee's system designation)

NCV -

Non Cited Violation NIS - Nuclear instrumentation System NOED -

Notice of Enforcement Discretion NRC -

Nuclear Regulatory Commission OPDT -

Overpower Delta Temperature OTDT -

Overtemperature Delta Temperature PCE - Personnel Contamination Event PIP -

Problem investigation Process PORC - Plant Operations Review Committee PRNl -

Power Range Nuclear Instruments PT -

Periodic Test RCA -

Radiologically Controlled Area RHR -

Residual Heal Removal RMSA -

Radioactive Material Storage Area RP . ., Radiation Protection -

RWP - Radiation Work Permits SPA -

Single Point of Access SI -

Safety injection -

SR' -

Surveillance Requirement SSPS - Solid State Protection System

' T-avg -

' Average Temperature (for Reactor Coolant System)

'T-ref -

Reference Temperature (associated with Reactor Coolant System)

TS -

Technical Specification a_= __- _ ---

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UFSAR - Updated Final Safety Analysis Report -

URI -

' Unresolved item USQ . - Unreviewed Safety Question VA_ -

Auxiliary Building Ventilation VC -

Control Room Ventilation System (licensee's system designation)

VIO -

Violation VX -

Hydrogen Skimmer (licensee's system designation)

WO - Work Order

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