IR 05000424/1998006
| ML20154C519 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Vogtle  |
| Issue date: | 09/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20154C491 | List: |
| References | |
| 50-424-98-06, 50-424-98-6, 50-425-98-06, 50-425-98-6, NUDOCS 9810060299 | |
| Download: ML20154C519 (24) | |
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U. S. NUCLEAR REGULATORY COMMISSION ('
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REGION II
Docket Nos.
50-424 and 50-425 License Nos.
50-424/98-06, 50-425/98-06 Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Location:
7821 River Road Waynesboro. GA 30830 Dates:
June 28, 1998 through August 15, 1998 Inspectors:
J. Zeiler, Senior Resident Inspector M. Widmann, Resident Inspector K. O'Donohue. Resident Inspector E. Girard, Regional Inspector (Section E8.1)
L. Hayes, Regional Inspector (Section S8.1)
G. Wiseman, Regional Inspector (Section F)
Approved by:
P. Skinner, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure 2 9810060299 980910 PDR ADOCK 05000424 G
- EXECUTIVE SUMMAPsY Vogtle Electric Generating Plant Units 1 and 2 NRC Inspection Report 50-424/98-06. 50-425/98-06 This integrated inspection included aspects of licensee operations.
engineering. maintenance, and ]lant support.
The report covers a 7-week period of resident and region-]ased inspection.
Operations e
Violation (VIO) 50-424, 425/98-06-01. Inadequate Corrective Actions for Failure to Properly Document All Applicable Technical Specification (TS)
Limiting Condition for Operations (LCOs), was identified.
Operations personnel did not adequately review procedures and TS prior to entry into the LCO for containment ventilation isolation instrumentation (Section 03.1).
Maintenance e
Maintenance and surveillance activities were satt cily performed and were completed by personnel knowledgeable of t,+
assigned tasks.
Procedures were present at the work location and being followed.
Procedures provided sufficient detail and guidance for the intended activities (Section M1.1).
Enaineerina Engineering design packages reviewed were well prepared. safety e
evaluations were complete. thorough, and appropriate.
Equipment changes as 3 result of engineering documents implemented were achieved without adversely impacting plant operations (Section E3.1).
Plant Sucoort e
Violation 50-425/98-06-02. Failure to Properly Secure a Door to a Locked High Radiation Area. was identified.
This was an isolated incident and not indicative of a programmatic weakness in the control of locked high radiation areas. The licensee identified a weakness in their routine preventive maintenance program for locked high radiation area doors (Section R1.1).
e Violation 50-424. 425/98-06-03. Failure to Properly Escort Individuals In and Around the Electric Boiler Building. was identified.
The inspectors concluded that personnel responsible for escorting the visitors did not fully understand their responsibilities (Section S3.1).
The fire prevention and protection program implementing procedures met e
NRC requirements. The procedural requirements for use and storage of transient combustibles in safety-related areas were properly implemented. The observed housekeeping reflected satisfactory cleanliness practices of plant workers (Section F1.1).
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Enclosure 2
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Appropriate emphasis had been placed on the operability of the fire j
e protection equipment and components.
This was evidenced by a low number i
of degraded fire protection components and overall material condition of
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the fire protection and fire brigade equipment.
The number of fire j
protection surveillance procedures being performed within the allowed
extension grace period in 1998 was improved from 1997 (Section F2.1).
The fire brigade organization and training met procedure requirements.
e Performance by the fire brigade during the observed fire drills met
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established drill objectives.
The fire drill critiques identified areas
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of fire brigade challenges which were being addressed by the training I
staff (Section F5.1).
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The 1998 Safety Audit and Engineering Review assessment of the i
facility's fire protection program was thorough and effective in i
identifying fire protection program performance to management (Section F7.1).
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Reoort Details Summary of Plant Status
. Unit 1 operated at essentially full' power throughout the inspection period.
J Unit 2 operated at full power until July 18. 1998, at which time power was reduced to 65 percent to repair an oil leak on the 2B Main Feedwater Pump.
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Full power was attained on July 19. following this repair activity. The unit operated at essentially full power for the remainder of the inspection period.
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Operations Ol'
Conduct of Operations 01.1 -General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations.
In general, the reviews indicated that the conduct of operations was professional and safety-conscious.
Operational Status of Facilities and Equipment 02.1 Safety-Related Walkdowns (71707)
The inspectors walked down the following engineered safety feature systems to verify availability and overall condition of the systems:
Nuclear Service Cooling Water System. Train A. Unit 1 Nuclear Service Cooling Water System, Train B. Unit 2 Component Cooling Water System. Train A. Unit 1
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Component Cooling Water System. Train B, Unit 1 l
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perform their design function and were properly aligned.
No significant
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items or discrepancies were identified during these inspections.
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Operations Procedures and Documentation 03.1 Missed Technical Soecification (TS) Loo Entry a.
Insoection Scone (71707)
The inspectors reviewed the Unit Shift Supervisors' (USS) logs and Limiting Conditions for Operation (LCO). Status books for Units 1 and 2 to verify required actions were completed.
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Observations and Findinos
,g On July 23, the inspectors identified that the Unit 1 Supervisor failed i
to enter TS LCO 3.3.6 " Containment Ventilation Isolation
Instrumentation," for inoperable radiation monitors during performance
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of surveillance procedure 14420-1. " Solid State Protection System and Reactor Trip Breaker Train A Operability Test." Revision (Rev.) 30 in the control room log.
The licensee revised the Unit 1 log to reflect the proper LCOs entered and generated a condition report.
Although the proper log entry was not made for TS 3.3.6. the licensee did not exceed any applicable LCO action statement completion times.
Performance of procedure 14420-1 required the operations staff to enter TS 3.3.1. " Reactor Trip System Instrumentation." TS 3.3.2. " Engineered Safety Features Actuation System Instrumentation." and TS 3.3.6.
The requirement to enter the applicable TSs were clearly referenced in the procedure.
However, the inspectors review of control room records for 1998 and 1997 indicated that all three TS LCOs were properly entered in control room logs in only 9 of 42 performances of procedures 14420-1/2.
During an interview with the USS onshift July 23. the inspectors determined that the USS failed to review procedure 14420-1 prior to commencement, and failed to review in detail all possible TSs impacted by performance of the surveillance procedure.
The inspectors have previously documented occurrences of operations personnel failure to log all apalicable TS LCOs.
Previous issues dealt with turbine generator trip lin(s being left open during a mode change (NRC Inspection Report (IR) 50-424.425/98-04); control room emergency filtration system heaters inoperable due to kilowatt output below TS limits (IR 50-424.425/98-02): unit operation above 375 degrees Fahrenheit with the safety injection system inoperable due to mispositioned discharge valves to the hot leg (IR 50-424.425/97-10);
and. failure to enter the post-accident monitoring system TS with containment sump level transmitters inoperable (IR 50-424.425/97-05).
The failure of the corrective actions for these previous violations to preclude this occurrence is a violation of 10 CFR 50. Appendix B.
Criterion XVI. This was identified as Violation (VIO) 50-424, 425/98-06-01. Inadequate Corrective Actions for Failure to Properly Document All Applicable TS LCOs.
As a result of this recent issue, the licensee developed and implemented several corrective actions to address the repeated failures to document TS LCO entries.
These actions included: specific TS training during licensed operator requalification will be emphasized in 1998 and 1999 through tests and classroom exercises; a management expectation was reemphasized for performing peer checks by other USS and Shift Superintendents (SS) prior to entry into TS LCOs: the USS will be required to discuss entry into each LCO with the SS prior to planned or l
unplanned work or surveillance activities to verify all applicable TS i
LCO's are identified; and the Manager of Operations will discuss management expectations for the control, documentation, and identification of LCO applicability with each SS.
In addition, the
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licensee plans to review existing procedures to ensure that plant
conditions cannot exist that would inadvertently violate TS: and Enclosure 2
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proceduralize actions that are taken in operating modes with procedural triggers for equipment' restoration prior to mode changes.
The inspectors reviewed the licensee's planned corrective actions and concluded that they were satisfactory to prevent recurrence of the
violation.
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Conclusions VIO 50-424, 425/98-06-01. Inadequate Corrective Actions for Failure to Properly Document All Applicable TS LCOs. was identified.
Operations L
personnel did not adequately review procedures and TS prior to entry
into the LCO for containment ventilation isolation instrumentation.
Miscellaneous Operations Issues (92901)
-08.1 (Closed) Deviation 50-424. 425/97-08-02: Failure to Fulfill All Safety Review Board (SRB) Review Commitments The licensee responded to this deviation in correspondence dated September 10, 1997.
The licensee's corrective actions included a review of.past event. reports missed: a revision to SRB Procedure VSRB-05.
" Safety Review Board." Rev. 2. to provide additional guidance as to the
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specific items required to be reviewed by the board: and a review and revision of plant specific-procedures that would promulgate the. SRB's
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involvement -in plant events or significant issues.
Two such procedures were revised, procedures 80014-C. " Handling of Deficiency Cards." Rev.
12. and 81020-C. " Licensing Document Coordination." Rev. 7.
The inspectors concluded that the licensee's: corrective actions were satisfactory.
08.2 (Closed) VIO 50-424/97-10-01: Mis-Positioned Unit Heaters Breakers on 480-volt MCC 1NBG The licensee responded to this violation in correspondence dated December-22. 1997. The inspectors verified the corrective actions described in the licensee's response letter to be reasonable and complete.
08.3 (Closed) VIO 50-425/98-02-01: Failure to Follow Procedure for
.Documentina LC0 Entry on Unit 2 CREFS
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' The licensee responded to this violation in correspondence dated April 29. 1998.
The inspectors verified the corrective actions described in the l
licensee's response letter to be reasonable and complete for the
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specific circumstances surrounding this violation.
However, similar l'
instances have occurred, therefore, a separate violation 50-424/98-06-01 (-
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i was identified in Section 03.1 of this inspection report and documented the repetitive failure to properly document TS LC0 entries.
Based on this review and the issuance of an inadequate corrective action violation. this item is closed.
II. Maintenance M1 Conduct of Maintenance M1.1 Maintenance Work Order and Surveillance Observations (61726) (62707)
The inspectors observed all or portions of various selected maintenance and surveillance activities.
The observed maintenance and surveillance activities were generally completed by personnel knowledgeable of their assigned tasks.
Procedures were present at the work location and being followed.
Procedures provided sufficient detail and guidance for the intended activities.
The inspectors concluded that routine maintenance and surveillance activities were satisfactorily performed.
M8 Miscellaneous Maintenance Issues (92700) (92902)
M8.1 (Closed) VIO 50-425/97-09-01: Failure to Obtain a Work Order Prior to Conductina Maintenance on a Diesel Generator The licensee responded to this violation in correspondence dated November 14, 1997.
The inspectors verified that a preventive maintenance checklist that was developed for periodic inspection and tightening of engine jacket water system piping was being mplemented at the prescribed frequencies.
The inspectors reviewed the icensee's corrective actions and determined that all of the actions had been satisfactorily completed.
M8.2 (Closed) DEV 50-424.425/97-11-03: Failure to Perform Containment Penetration Circuit Breaker Surveillances
The inspectors concluded that the information provided as to the reason for the deviation, the corrective actions. taken and planned to correct the. deviation and prevent recurrence were adequately addressed in other
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correspondence and did not require a licensee response.
This issue was previously reviewed and documented in IR 50-424. 425/97-11.
In addition the licensee issued Licensee Event Report (LER)
50-424. 425/97-007-00. Containment Penetration Electrical Overcurrent Protection Not Tested, dated October 10. 1997, as a result of this event.
A Request for Engineering Assistance (REA) to evaluate the possible deletion of the dual overcurrent protection requirement was completed. The results of this REA determined that it was not feasible to delete the requirement. - As a result, the licensee replaced the Enclosure 2
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breakers and revised procedure 28908-C. " Molded Case Circuit Breaker Testing " Rev. 25. to include the missed breakers in the surveillance and were satisfactorily tested. The inspectors concluded that the
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licensee's actions were satisfactory.
M8.3 (Closed) LER 50-424/97-02-01 and LER 50-424/97-02-02. P-4/ Turbine Trio and Other Circuits not Surveillance Tested The inspectors verified that surveillance procedures were revised for appropriately testing the logic circuitry.
Based on previous enforcement action taken to address licensee identified surveillance test procedure discrepancies associated with their Generic Letter 96-01 reviews, this LER is closed.
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Enaineerina l
E3 Engineering Procedures and Documentation l
E3.1 Enoineerina Modification Document Reviews (37551)
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During the inspection period the inspectors reviewed all or portions of
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seven selected documents prepared by engineering department personnel in the form of Temporary Modifications (TM) Minor Design Changes (MDC).10
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CFR 50.59 safety evaluations, and Design Change Packages (DCP).
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The' inspectors identified no deficiencies during their review of the engineering documents.
Design packages were well prepared, safety evaluations were complete, thorough, and appropriate.
Equipment changes as a result of engineering documents imalemented were achieved without an adverse impact on the operation of t1e plant.
E8 Miscellaneous Engineering Issues (92903)
E8.1 (Closed) Insoector Followuo Item (IFI) 50-424. 425/97-04-06:
Actions to Address Generic Letter (GL) 89-10 Insoection Issues.
This followup item was opened pending the licensee's completion of actions described in a May 5,1997. letter from the licensee to the NRC.
These actions were developed to resolve issues raised during an NRC inspection of the licensee's implementation of GL 89-10. " Safety-Related e
Motor-Operated Valve Testing and Surveillance."
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inspection, the ins]ectors reviewed the status of the actions and verified that they lad been adequately completed to permit closure of the IFI. The issues, resolution actions, and the results of the n
inspectors' review are discussed below:
Issue 1: The licensee validated the methodology which it used to l
predict torque requirements for butterfly valves by comparing predicted l
values to torque values determined in differential pressure tests performed on 8-inch butterfly valves.
The predicted values were l
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generally greater than the torques obtained in the tests.
However, in some cases the test torques marginally exceeded the predicted torques.
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- As there had only been a small number of tests, the inspectors were concerned that this might indicate non-conservatism in the methodology.
Resolution Actions:
The licensee's May 5. 1997 response letter
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indicated that the Vogtle thrust / torque calculation (X4C1000UO2) would be revised to provide a discussion of the test results that would ensure that the torque prediction methodology would be used in a conservative manner in the future.
Review Results: The inspectors reviewed Calculation X4C1000U02. " Valve Required Thrust / Torque and Operator Ca GL 89-10 Scope Motor Operated Valves."pabilities and Limitations for the Rev. 13. and found that the licensee had not provided a discussion of the original methodology.
Instead, the licensee had revised the methodology. The torques predicted by the new methodology were compared to differential pressure l
test measurement results in Calculation X4C1000U13. " Evaluation of
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Fisher Butterfly Valve DP Tests for Generic Letter 89-10 Torque / Thrust Methodology." Rev. 1.
The inspectors verified that the new methodology adequately bounded all of the torque measurement results obtained in the differential pressure tests.
Issue 1 was resolved.
Issue 2: As mentioned in the discussion of Issue 1. the licensee had used the results of differential pressure tests performed on 8-inch butterfly valves to validate the methodology for predicting butterfly valve torque requirements. ~The inspectors were concerned that the licensee had not similarly tested any larger size (18-and 24-inch)
butterfly valves to confirm that the methodology was valid for those sizes.
Resolution Actions:
The licensee's May 5. 1997 response letter stated that instrumented dynamic (i.e.. differential pressure) torque testing would be performed on two of the larger (18-inch) butterfly valves to
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validate the prediction methodology.
l Review Results:
The inspectors found that the licensee had tested two 18-inch butterfly valves as stated in the May 5.1997 letter.
The results of the tests were documented and evaluated in calculation X4C1000U13. Rev. 1.
The inspectors reviewed this calculation and confirmed that the testing satisfactorily validated the methodology for application to the larger butterfly valves.
Issue 2 was resolved.
Issue-3: The licensee had used the Electric Power Research Institute Performance Prediction Methodology (EPRI PPM) to calculate thrust l
requirements for several valve groups (AD-1. AD-2. AD-4. V-1. V-2, and l
V-3).
However, the licensee had not established that the conditions and limitations under which the NRC considered this methodology acceptable
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were met. The NRC described these conditions and limitations in a
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7 safety evaluation transmitted to the Nuclear Energy Institute in a letter dated March 15, 1996.
Resolution Actions: The licensee's May 5. 1997 response letter stated that the NRC safety evaluation would be reviewed in detail for a3plicability to the calculations it performed using the EPRI PPM and tlat a summary of the review would be included in Calculation X4C1000U02.
Review Results:
The inspectors examined Calculation X4C1000U02. Rev.
13. and verified that the summary referred to in the licensee's letter
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had been added.
The inspectors found that the review satisfactorily addressed the conditions and limitations described in the NRC safety evaluation. The review identified the need to include cracking loads in the thrust requirements and the inspectors verified that the licensee had addressed this need for current and future valve set-ups.
Calculation REA 97-VAA050. " Evaluation of Cracking Load for Anchor Darling and Westinghouse Gate Valves." Rev. O. evaluated the current set-ups and demonstrated that they were satisfactory.
Procedure 26871.
" Static Testing of Motor 03erated Gate / Globe Valves Using VOTES Analysis and Test System." Rev. 7. lad been revised to include cracking loads in future set-ups.
Issue 3 was resolved.
Issue 4:
The licensee did not have data to justify the 0.5 valve factor which had been assumed in calculating the minimum required thrusts for gate valve group AD-3.
Resolution Actions:
In its May 5,1997 letter, the licensee indicated that the valves would be re-evaluated using a more conservative 0.7 valve factor and that the valves would be modified to increase their opening capabilities.
Industry test results support 0.7 as a conservative valve factor assumption for most gate valves.
Review Results: The inspectors verified that the re-evaluation had been completed.
The re-evaluation was included in Calculation X4C1000U02.
Rev. 13.
Additionally, the inspectors verified that Design Change Packages 97-V1N0035-003 and 97-V2N0035-003 had been issued to modify the AD-3 valves to increase their thrust capabilities.
Further the inspectors selected the following three examples of the AD-3 valves and
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verified that Maintenance Work Orders (MW0s) had been issued to
implement the stated modifications (gear changes):
29701967 com31eted last outage for valve 2HV-9380A 19801587 to 3e completed (next outage) for valve 1HV-9380A 19801588 to be completed (next outage) for valve 1HV-9380B Issue 4 was resolved.
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Issue 5:
The licensee's two 0.5-inch Fisher globe valves (1-and 2-HV3548) had calculated closing thrust capability margins of less than 5%
at design basis conditions.
This small margin was of particular concern because there was no test data to su] port the calculation methodology which had been used to predict the t1 rust requirements for these valves.
Resolut:on Actions:
In its May 5. 1997 letter. the licensee indicated that the as-left capability margins of these valves would be substantially increased by repacking the valves to reduce their design packing loads from 1000 to 500 lbs.
Review Results:
The inspectors reviewed Calculation X4C1000U02. Rev.
13. and verified that the design packing load had been reduced to 500 lbs.
In addition the inspectors reviewed MW0s 19602369 and 29602465.
which repacked these valves, and verified that tests performed following repacking resulted in packing loads below 500 lbs.
By applying the new packing loads, the licensee's spreadsheet calculation showed that the margins for these valves were substantially increased.
The new opening margins exceeded 200% and the closing margins exceeded 55%.
Issue 5 was resolved.
Issue 6:
Three Velan globe valves had calculated closing thrust capability margins of less than 5% at design basis conditions.
The inspectors expressed concern that maintaining such small margins was not a good long-term practice.
Resolution Actions:
In its May 5, 1997 letter, the licensee indicated that this concern would be addressed by including an additional 5% bias uncertainty in the target thrust settings of all torque switch controlled rising stem valves.
The 5% would be included as a " good practice." but would not be used in determining operability.
Review Results: The inspectors verified that Procedure 26871-C. " Static Testing of Motor 0)erated Gate / Globe Valves Using VOTES Analysis and
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l Test System.~ had )een revised (Revision 7) to specify the additional margin.
Further, the inspectors reviewed the following MWO examples and verified that they documented implementation of the required margin:
29702941 Velan Valve 2HV-8508B (6% margin)
29800055 Velan Valve 2HV-8103C (11% margin)
Issue 6 was resolved.
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Issue 7:
The results of dynamic tests performed on Westinghouse gate j
valve grou)s W-2A. W-28. and W-8 did not fully support the methodology which had Jeen used to calculate the minimum thrust requirements for
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these valves.
The required operating thrusts measured in the tests sometimes exceeded the calculated requirements by a smell amount.
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Resolution Actions:
In its May 5, 1997 letter. the licensee indicated that it would re-review the dynamic test results for the valves in these groups and would revise the methodology to bound all credible test data.
Review Results: The ins)ectors verified that the licensee had revised the design methodology tlat was used to calculate thrust requirements for valve groups W-2A W-28 and W-8.
This revision increased the l
design valve factors specified by Calculation X4C1000UO2. resulting in higher predicted thrust requirements.
The inspectors confirmed that the
thrust requirements determined with the new valve factors satisfactorily bounded all of the licensee's dynamic test data.
In addition. the inspectors verified that the licensee had evaluated the existing valve settings and assured that all of the valves in the three groups were operable when the new design valve factors were applied.
The evaluation was documented in Calculation REA 97-VAA050 " Evaluation of GL 89-10 As-Left Torque Switch Settings Outside of Set-Up Window." Rev. O.
l Issue 7 was resolved Issue 8: The licensee had no dynamic test results to support the methodology employed in calculating the minimum thrust requirements for Westinghouse gate valve groups W-9. W-11. and W-12.
Resolution Actions:
In its May 5, 1997 letter, the licensee indicated that it would either identify industry test data to justify the existing methodology or replace the methodology with the EPRI PPM methodology.
Review Results: The inspectors verified that the licensee now used the t
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EPRI PPM methodology to calculate the minimum thrust requirements for i
Westinghouse gate valve groups W-9. W-11. and W-12.
The thrust l
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l X4C1000U02. Rev. 13.
In Calculation REA 97-VAA050. Rev. O, the licensee
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using the PPM and determined that all settings were satisfactory. The inspectors confirmed that the current settings resulted in positive margins for all the valves in the groups.
Issue 8 was resolved.
Issue 9: The licensee did not have adequate justification for the 0.15 stem friction coefficient value which it had used to evaluate the capabilities of Fisher. Velan, and Westinghouse rising stem valves
operating under limit switch control.
A statistical analysis of the
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licensee's test results found that a value of 0.18 was appropriate.
Resolution Actions:
In its May 5. 1997 letter to the NRC. the licensee l
indicated that it would use a stem friction coefficient of 0.18 in place l
of 0.15 to evaluate the capabilities of these rising stem valves when l
they operated under limit switch control.
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Review Results:
The inspectors reviewed Calculation X4C1000U02.
Revision 13. and verified that it now used a 0.18 stem friction
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coefficient to calculate the capabilities of these valves.
The current valve set-ups were evaluated with this stem friction coefficient and all but three were found to be acceptable.
The torque switch settings of l
three of the valves exceeded their operator ca3 abilities.
The set-ups of these valves were evaluated in Calculation REA 97-VAA050 " Evaluation of GL 89-10 MOV As-Left Torque Switch Settings Outside of Set-up l
Windows." Rev. O.
The inspectors reviewed this calculation and verified l
that it demonstrated that the set-ups of the three valves were acceptable, as their measured stem friction coefficients were significantly less than the 0.18 design value.
Issue 9 was resolved.
E8.2 (Closed) VIO 50-424/97-10-04: Failure to Take Adeauate Corrective Actions to Revise the APEX Users Manual The licensee responded to this violation in correspondence dated December 12. 1997.
The inspectors reviewed the licensee *s corrective actions and determined that all of the actions had been completed satisfactorily.
E8.3 (Closed) IFI 50-424. 425/97-12-02: Comolete Review of EDG Missile Enclosure Dearadation In January 1998, the licensee identified significant degradation of the inside walls of each emergency diesel generator (EDG) exhaust enclosure located on the roof of the EDG buildings.
Concrete had spalled from the inside walls of enclosures in several locations, exposing the reinforcing steel (rebar) in some areas.
The licensee's root cause evaluation of the degraded exhaust enclosures was documented in REA 98-V1A601, dated March 4. 1998.
The licensee determined that the depth of the concrete over the rebar was insufficient to protect the rebar from overheating.
This caused the rebar to ex)and and spall the concrete around it.
The licensee concluded tlat inadequate design consideration was given to the protection of the rebar from the sustained exposure to high EDG exhaust temperatures.
There was no immediate impact on EDG operability.
The inspectors reviewed DCPs 98-V1N0011. Rev. O and 98-V1N0012. Rev. O.
for correcting the degraded exhaust enclosures.
The planned changes to l
the structures involved removal of the concrete to ap3roximately four
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feet above the EDG building roof and replacing it wit1 a steel guard 3ipe configuration. The steel pipe was to serve as the tornado missile i
Jarrier for the EDG exhaust pipe. The licensee planned to begin the l
modification implementation on each EDG, one at a time, beginning the week of August 16, 1998, completing all work by October 15. 1998.
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The inspectors concluded that the licensee had adequately addressed the root cause of the degraded EDG exhaust enclosure condition and had developed adequate plans to address long term corrective actions to restore the structures to their original design basis missile protection capability.
E8.4 (Closed) Unresolved Item (URI) 50-424. 425/97-12-03: Reoortability oer 10 CFR 50.72 and 10 CFR 50.73 of Emeroency Diesel Generator (EDG)
Exhaust System Dearadation On February 5 and March 25, 1998, the licensee submitted voluntary 10 CFR 50.73 LERs 50-424/98-01-00 and 50-424/98-01-01 (Rev.1), to inform the NRC of the discovery of the EDG Exhaust System Degradation.
The licensee determined that the degraded condition did not represent a condition that was outside the design basis of the plant since the function goal of the Emergency Diesel Generator system was not affected.
The inspectors reviewed NUREG-1022. Rev. 1, which was recently issued to provide new guidance and several examples of reporting criterion, such as, "outside design basis." Based on review of NUREG-1022 the inspectors concluded that the licensee's actions were satisfactory.
E8.5 (Closed) LER 50-424/98-01-00. and LER 50-424/98-01-01: Concrete Dearadation Found in Diesel Generator Exhaust Barriers Details pertaining to these LERs were previously reviewed and discussed in Section E8.3 of this report and in NRC Inspection Report 50-424, 425/97-12.
No new issues were revealed by the LERs.
IV.
Plant Sucoort R1 Radiological Protection and Chemistry Controls R1.1 Unsecured Door to Locked Hioh Radiation Area a.
Insoection Scope (71750)
The inspectors periodically toured the Radiological Control Area (RCA)
and observed radiological protection activities including control of radioactive material, radiological surveys, postings, and radiation area /high radiation area controls.
b.
Observations and Findinos On July 27. during a tour of the Unit 2 Auxiliary Building. the inspectors discovered the cage door to room 2-AB-A-70. the Chemical and l
Volume Control System (CVCS) cation demineralizer valve gallery, was not fully closed.
When the door was released, it closed and properly locked.
Room 2-AB-A-70 was posted as a Locked High Radiation Area (LHRA), which required the area to be locked or continuously guarded to f
Enclosure 2 l
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prevent inadvertent entry.
The inspectors notified Health Physics
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personnel of the discrepancy and the licensee initiated a Root Cause and Corrective Action (RCCA) investigation.
Upon investigation, the licensee identified two problems that contributed to the failure of positive controls associated with the LHRA door.
First, the latch was found to stick in the retracted position.
The latch mechanism was repaired and other locked high radiation area doors were inspected for degradation.
No other doors were found unlocked: however. several other doors needed maintenance to address minor problems, including one other latch that was sticking.
The second problem was a personnel error in that the last person that exited the room did not verify that the door closed and properly locked.
The inspectors were informed that the locked doors for high radiation areas were not included in any routine preventive maintenance (PM)
program.
The licensee's corrective actions for this incident involved adding a six month PM task item to inspect and repair as necessary. all LHRA doors.
In addition, a shift briefing was performed with all Health Physics and operations personnel emphasizing the importance of self-verification, high radiation door closure, and the impact of having a door unsecured.
The inspectors noted that there had not been any recent incidents of an unsecured LHRA door, therefore, this incident was considered to be an isolated occurrence.
The inspectors considered the licensee's corrective action reasonable to prevent recurrence of this incident.
TS 5.7.2. High Radiation Area, and licensee administrative 3rocedure 00930-C. " Radiation and Contamination Control." require eac1 LHRA with radiation levels greater than or equal to 1000 mrem / hour to be locked in such a manner as to prevent unauthorized entry.
The failure to properly secure the door to room 2-AB-A-70 was a violation of TS 5.7.2 and licensee procedures and was identified as VIO 50-425/98-06-02. Failure to Properly Secure Door to Locked High Radiation Area.
c.
Conclusions VIO 50-425/98-06-02: Failure to Properly Secure Door to Locked High Radiation Area, was identified.
This was an isolated incident and not
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indicative of a programmatic weakness in the control of locked high l
radiation areas.
The licensee identified a weakness in their routine preventive maintenance program for LHRA doors.
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l S3 Security and Safeguards Procedures and Documentation S3.1 Escort Duties and Control of Visitors a.
Insoection Scooe (71750)
During the ins)ection period the inspectors observed the performance of escort duties )y licensee personnel inside the protected area.
b.
Observations and Findinas On July 16. the inspectors observed a maintenance individual escorting three visitors.
These visitors were being escorted to permit work activities in the Electric Boiler building.
During the time of observation the inspectors noted two instances that the escort did not maintain control and visual contact with the visitors.
The inspectors observed that the escort lost visual contact with one escorted individual when that individual walked outside the building and the escort remained sitting inside the building. The escorted visitor walked away from the escort to his vehicle parked on the north side of the Electric Boiler building.
Due to the wall of the building between the escort and the escorted visitor and the physical position of the escort inside the building, visual contact was not maintained.
A second instance occurred when visitors closed a roll-up door isolating the escort from all three escorted individuals.
After the escort regained visual contact with the visitors, security was contacted. As a result, the maintenance person responsible for escorting the visitors was relieved of duties as an escort and the visitors were transferred to another individual.
Procedure 00652-C. " Personnel Escort-Duties and Responsibilities. "Rev.
5. requires an escort to maintain control and visual contact with assigned individuals.
Upon identification of the issue, the licensee took appropriate immediate compensatory action and transferred escort responsibilities to another individual.
The inspectors concluded that the failure of the escort to maintain control and visual contact of escorted individuals on two occasions did not meet the requirements of procedure 00652-C.
This is identified as VIO 50-424, 425/98-06-03.
Failure to Properly E.scort Individuals In and Around the Electric Boiler Building.
As part of the corrective actions to address this problem, the licensee implemented a security " stand down" and prohibited visitors from entering the protected area for several days.
In the interim, the
licensee revised the escorting program including procedure 00652-C to 3rovide instruction on the new escort process.
Specifically, escort
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Sadges were develo)ed to identify a person responsible as an escort the i
)rocess to enter t1e protected area was enhanced via detailed security 3riefings being implemented prior to being authorized to escort.
Enclosure 2
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controls on transferring of vis'itors inside the protected area were increased by performance of a turnover each time the visitor was transferred to a new escort.
A detailed review of escort responsibilities will be conducted prior to the escort assuming the duties.
In addition, special training was conducted for authorized individuals qualified as escorts. The inspectors reviewed the above corrective actions and concluded they were sufficient to preclude j
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recurrence, i
The inspectors reviewed licensee performance and noted that this violation was similar to a violation identified in IR 50-424, 425/98-03.
However, the inspectors concluded that the corrective actions for that violation would not have reasonably prevented the recent violation.
Conclusions VIO 50-424. 425/98-06-03. Failure to Properly Escort Individuals In and Around the Electric Boiler Building, was identified.
The inspectors concluded that personnel responsible for escorting the visitors did not fully understand their responsibilities.
Hiscellaneous Security and Safeguards Issues (81502)(92904)
S8.1 (Closed) VIO 50-424. 425/97-208-02014 (EEI 97-208): Failure to Maintain Confidentiality of Personnel Information The licensee responded to this violation in correspondence dated April 21. 1998. The corrective actions included revising Fitness for Duty (FFD) procedures to require that written consent be obtained from the employee prior to releasing personal information to persons other than those specified in 10 CFR 26.29.
The inspectors determined that appropriate personnel were counseled and trained on proper policy.
A licensee letter dated A)ril 20, 1998, appropriately notified management and employees of tie meaning of 10 CFR
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26.29 and the use of a consent form.
The inspectors interviewed two I
Labor Relation employees and determined that they understood the recuirements associated with the protection of personal information.
Adcitionally, the inspectors verified that the consent form was currently in use as required by procedure 720-001. " Fitness for Duty."
dated May 14. 1998.
The inspectors verified that, for the one case that occurred since the problem was identified, consent had been given by the individual prior to the release of personal FFD information.
The inspectors concluded that the licensee's corrective actions were appropriate.
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F1 Control of Fire Protection Activities F1.1 Combustible Material Controls / Fire' Hazards Reduction l
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a.
Insoection Scope (6d/04)
The inspectors reviewed administrative procedures 92000-C. " Fire Protection Program." Rev. 13. 92010-C. " Control of Ignition Sources."
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L Rev. 13. and 92015-C. "Ute. Control and Storage of Flammable / Combustible Materials'." Rev.17. to determine if they satisfied the combustible i
control and housekeeping objectives established by the licensee's approved fire protection program.
The inspectors also toured selected areas of the plant and inspected the licensee's implementation of these procedures.
b.
Observations and Findinas The procedures reviewed were the. principle procedures used to implement the fire prevention and protection program. The procedures were satisfactory and met the licensee s commitments to the NRC.
During plant Walkdowns the inspectors observed that controls were being
properly maintained for limiting transient combustibles in safety
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related plant areas.
In areas where transient combustible materials were allowed, permits were properly posted.
No transient combustible materials were stored or used in the cable chase rooms or cable spreading room in the control building that might challenge the fire
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loading limits.
Lubricants and oils for normal maintenance activities
were placed in approved safety containers and properly stored within
approved fire resistive flammable liquid storage cabinets.
Waste
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material trash cans utilized safety covered lids and were emptied
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frequently.
The housekeeping for areas of potential lubrication oil and diesel fuel leaks, such as the diesel generator rooms. was controlled. The licensee made use of oil absorption materials to catch and soak up the oil from
' leaks associated with the diesel generators. The oil absorption materials were being replaced at frequent intervals.
c.
Conclusions
L The fire prevention and protection program implementing procedures met
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NRC requirements. The procedural requirements for use and storage of transient combustibles in safety-reluted areas were properly
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implemented.
The observed housekeeping reflected satisfactory cleanliness practices of plant workers.
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Status of Fire Protection Facilities and Equipment L
F2._1 _QDerability and Maintenance of Fire Protection Facilities and Eouioment a.
Inspection Scooe (64704)
l The inspectors reviewed all closed maintenance work orders on fire protection components for 1998 and operation's list of out-of-service fire protection equipment for the period June 28 through August 12, 1998, in addition. walkdown inspections were made of the plant's fire protection systems. equipment, features, and fire brigade equipment.
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'b.
Observations and Findinas l
During the period June 28 through August 12. 1998, there had been approximately 17 fire protection components declared out-of-service or inoperable for Units 1 and 2.
The inspectors considered this number low.
Most of the 17 items were related to plant work activities which were in process.
As of August 12. all but two of the components had been returned to service. The inspectors verified that appropriate compensatory measures had been impl.emented for the degraded components when required.
The inspectors toured the plant and noted that the operable manual fire fighting equipment.. automatic fire detection and su)pression systems, and fire zone / area walls, floors, and ceilings of t1e fire zones inspected were well maintained.
The material condition of the equipment was satisfactory.
A review of the scheduled and completed maintenance fire protection inspection tests (29000 series) for 1998, indicated that early in 1998 approximately 40- percent of.the quarterly.. six-month. annual, or 18-month frequency fire protection test procedures scheduled had been extended such that they were performed late within the allowed grace period.
The inspectors verified that none of the surviellances were completed outside the allowed grace period. Discussions with maintenance management indicated that procedure scheduling and
. maintenance inspection test performance was significantly improved. As a result, as of August 1998, only four test procedures had been completed in the extended grace period, c.
Conclusions Appropriate emphasis had been placed on the operability of the fire protection equipment and components. This was evidenced by a low number
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of degraded-fire protection components and overall material' condition of the fire protection and fire brigade equipment. The number of fire -
l protection surveillance procedures being performed within the allowed l
extension grace period in 1998 was -improved from 1997.
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F3 Fire Protection Procedures and Documentation F3.1 Surveillance Procedures for Fire Protection Water SuDoly System a.
Insoection ScoDe (64704)
The inspectors reviewed the licensee's implementation of commitments to perform 3 year fire protection water supply system flow testing.
b.
Observations and Findinas Updated Final Safety Analysis Report (UFSAR) Table 9.5.1-10. Section 2.4.1.G. states that the fire suppression water system will be o)erable at all times.
The system was demonstrated to be operable througl a series of teste listed in the UFSAR Table 9.5.1-10. Section 2.4.1.
The subject test was a system flow test procedure 14956-C. " Fire Suppression System - 3 Year Flow Verification." Rev. O, which was performed in September 1995.
Prior to the 1995 test, a Request for Engineering Assistance (REA) VG-2720 was initiated to develop pressure drop calculations of various flow paths in the fire protection water system and verification that test procedure 14956-C satisfied the system design basis.
The inspectors reviewed test procedure 14956-C. Rev. 2 which incorporated REA VG-2720 to require water flow through seven different underground piping flow )aths. This revision of the test procedure has not yet been performed.
)ut was scheduled to be conducted in September 1998.
The inspectors discussed with licensee fire protection personnel their performance of the 3 year fire protection system flow and pressure test
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and whether any flow or pressure performance degradation has been noted since the previous tests. The inspectors noted that the acceptance criteria for the test data in the new procedure was not well established.
The acceptance criteria for the test pressure drop data was established on calculated theoretical pressure drop calculations based on new piping.
The inspectors also raised a question regarding the scope of fire protection piping actually tested.
Interior supply piping to fire hose stations and automatic fire suppression systems within the power block were not being flow tested to identify potential degradation.
The licensee was performing flow and pressure drop testing only on overall yard loop piping.
Using this approach. interior water supply piaing degradation may not be readily apparent.
The water supply for t1e fire protection system was well water and historically has not exhibited evidence of significant corrosion in the auxiliary or control buildings.
The licensee acknowledged the ins)ectors' concerns and initiated a review to evaluate the basis of tie procedure acceptance criteria to l
provide baseline information of system degradation.
Enclosure 2
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c.
Conclusions
' The administrative processes for long-term monitoring of the fire protection system for degradation included testing of overall yard loop piping; however, testing to identify indications of system degradation of interior water supply piping was not apparent.
F3.'2. Surveillance Procedures for Aooendix R Emeraency Liahtina a.
Insoection Scoce (64704)
The ins)ectors reviewed the design, operation, and maintenance of the 8-hour 3attery powered emergency lighting system.
b.
Observations and Findi9gs The inspectors' review of procedure 14961-C. " Emergency Lighting Surveillance." Rev.-22, and discussions with the facility fire protection engineer, indicated that the scope and content of the'
maintenance inspection and periodic test procedure was sufficient to perform verification of the emergency battery lighting performance.
The
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procedure was well written and verified that the emergency battery lighting units were operable, correctly aimed to illuminate post-fire alternate shutdown equipment and the batteries were adequately sized.
The inspectors walked down the remote shutdown equipment identified in abnormal procedures and inspected approximately 15 lighting units designated in the surveillance procedure checklist for the equipment.
The inspectors'noted that the available emergency battery lighting. units were operable. properly aimed, and the material condition was satisfactory.
c.
Conclusions
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The maintenance inspection and surveillance test program for the emergency 8-hour battery lighting system was sufficient to ensure that the system design function was met.
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F5 Fire Protection Staff Training and Qualification F5.1 Fire Briaade t
a.
Insoection Scoce-(64704)
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The inspectors reviewed the fire brigade organization and training program for compliance with plant procedures and NRC guidelines and requirements.
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Observations and Findings The organization and training requirements for the plant fire brigade were established by the fire protection program procedure, 92000-C.
" Fire Protection Program". Rev. 12.
A review of the qualification and training status report for the fire brigade members indicated that the training drill, respiratory, and physical examination requirements for each active member were up to date and met the established site training procedural requirements.
On August 10 and 13. the inspectors witnessed fire brigade drills involving a simulated fire in the control building.
Fire drill critiques were conducted following the drills to discuss the participants' performance.
The critiques verified that the drill objectives were met.
During the critiques both challenges and successes were discussed.
Challenges noted by the inspectors were identified and being addressed by the training staff.
c.
Conclusions The fire brigade organization and training met procedure requirements.
Performance by the fire brigade during the observed fire drills met
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established drill objectives.
The fire drill critiques identified areas of fire brigade challenges which were being addressed by the training staff.
F7 Quality Assurance in Fire Protection Activities F7.1 Fire Protection Audit Reoorts a.
Insoection Scooe (64704)
The inspectors reviewed the Safety Audit and Engineering Review (SAER)
Audit Report OP20-98/14. " Annual, Biennial, and Triennial Audit of Fire Protection Program", dated June 12. 1998, and the status of the corrective actions implemented for the Audit Finding Reports (AFRs).
b.
Observations and Findinas The licensee's SAER organization performed an evaluation of the fire protection program during the time period from May 4.1998. through May 15, 1998.
The audit team determined that the fire 3rotection program was adecuate and there were no programmatic pro]lems.
The inspectors notec that the audit team identified three findings associated with the implementation of the fire protection quality assurance program.
These findings were under review for resolution by the licensee.
Enclosure 2
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The inspectors concluded that the SAER. assessment of the facility's fire protection program was thorough and effective in identifying fire protection program performance to management.
c.
Conclusions The licensee's 1998 Safety Audit and Engineering Review assessment of the facility's fire protection program was thorough and effective in identifying fire protection program performance to management.
F8 Miscellaneous Fire Protection Issues (64704)(92904)
F8.1 (Closed) VIO 50-424. 425/97-01-02:
Failure To Demonstrate Fire Detectors Were Ooerable At least Once Per 12 Months The licensee responded to this violation in correspondence dated May 9.
1997.
The inspectors reviewed the licensee's response and verified that the corrective action initiated by the licensee on this issue was complete.
appropriate, and adequate to prevent recurrence.
F8.2 (Closed) VIO 50-424. 425/97-01-03:
Failure to Revise UFSAR To Conform to As-Built ADoendix R Plant Confiaurations The licensee responded to this violation in correspondence dated May 9, 1997.
The inspectors reviewed UFSAR Table 9.5.1-1. Rev. 7 and verified that the identified changes had been correctly incorporated into the current UFSAR.' The inspectors also verified that administrative procedure 00402-C. " Licensing Document Change Request (LCDR)." Rev. 17. clearly-
stated the controls for initiating and processing a LDCR.
No similar
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LDCR problems were identified. The inspectors concluded that the licensee's actions were satisfactory.
F8.3 (Closed) URI 50-424. 425/97-12-04:
Determine if Desian. Maintenance.
and Testina Reauirement for the Seismic Fire Protection Dry Standoioe System are Necessary The licensee initiated Request for Engineering Assistance. REA 98-VAA608, and commitment item tracking system Item No. C00038097 to evaluate and implement corrective actions.
The licensee also prepared a
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Minor Design Change to remove standpipe system flow restrictors. The presence of and subsequent removal of the flow restrictors did not adversely affect the system.
The system was originally tested and maintained in accordance with ASME standards and did not violate regulatory requirements.
The licensee was also developing hydrostatic and surveillance test procedures for the seismic standpipe system to enhance the defense in depth of the system.
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The inspectors concluded that the development of additional testing for the interior seismic dry standpipe system provided a suitable defense-in'-depth' functional basis for the seismic dry standpipe fire protection I
system.
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V.
Manaaement Meetinas and Other Areas X1 Exit Meeting Summary The inspectors ) resented the inspection results to members of licensee management at t1e conclusion of the inspection on August 20. 1998.
' Interim exit meetings were conducted on July 2. 28. and August 14.-1998.
The licensee acknowledged the findings presented.
PARTIAL LIST OF PERSONS CONTACTED Licensee S. Chestnut. Plant Operations Assistant General Manager G. Frederick. Manager. Operations J. Gasser. Nuclear Plant General Manager K. Holmes. Manager. Maintenance
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.D. Huyck Manager. Security.
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I. Kochery. Manager. Health Physics
.M. Sheibani. Nuclear Safety and Compliance Supervisor
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INSPECTION PROCEDURES USED-IP 37551:
Onsite Engineering IP 61726:
Surveillance Observation IP 62707:
Maintenance Observation IP.64704:
Fire Protection Program IP 71707:
Plant Operations IP 71750:
-Plant Support Activities.
IP 81502:
Fitness for Duty IP 92700:
Onsite Follow-up of Written Reports of Nonroutine Power Reactor Facilities IP 92901:
Followup 0perations
'IP 92902:
Followup - Maintenance IP 92903:
. Followup - Engineering
'IP 92904:
Followup'- Plant Support
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ITEMS OPENED AND CLOSED Ooened Tvoe Item Number Descriotion and Reference VIO 50-424, 425/98-06-01 Inadequate Corrective Actions for Failure to Properly Document All Applicable TS LCOs (Section 03.1)
VIO 50-425/98-06-02 Failure to Properly Secure Door to Locked High Radiation Area (Section R1.1)
VIO 50-424. 425/98-06-03 Failure to Properly Escort Individuals In and
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Around Electric Boiler Building (Section S3.1)
Closed Tvoe Item Number Description and Reference DEV 50-424. 425/97-08-02 Failure to Fulfill All SRB Review Commitments (Section 08.1)
VIO 50-424/97-10-01 Mis-Positioned Unit Heaters Breakers on 480-volt i
MCC 1NBG (Section 08.2)
VIO 50-425/98-02-01 Failure to Follow Procedure for Documenting LCO Entry on Unit 2 CREFS (Section 08.3)
VIO 50-425/97-09-01 Failure to Obtain a Work Order Prior to Conducting Maintenance on a Diesel Generator (Section M8.1)
DEV 50-424. 425/97-11-03 Failure to Perform Containment Penetration Circuit Breaker Surveillances (Section M8.2)
LER '50-424/97-02-01 P-4/ Turbine Trip and Other Circuits not Surveillance Tested (Section M8.3)
LER 50-424/97-02-02 P-4/ Turbine Trip and Other Circuits not Surveillance Tested (Section M8.3)
IFI 50-424. 425/97-04-06 Actions to address GL 89-10 inspection issues (Section E8.1).
VIO 50-424/97-10-04 Failure to Take Adequate Corrective Actions to Revise the APEX Users Manual (Section E8.2)
IFI 50-424, 425/97-12-02 Complete Review of EDG Missile Enclosure Degradation (Section E8.3)
Enclosure 2
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URI 50-424, 425/97-12-03 Reportability per 10 CFR 50.72 and 10 CFR 50.73 j
of Emergency Diesel Generator Exhaust System Degradation (Section E8.4)
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LER 50-424/98-01-00 Concrete Degradation Found In Diesel Generator j
Exhaust Barriers (Section E8.5)
LER 50-424/98-01-01 Concrete Degradation Found In Diesel Generator Exhaust Barriers (Section E8.5)
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VIO 50-424, 425/97-208-02014 Failu.e to Maintain Confidentiality of Personnel Information (Section S8.1)
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VIO 50-424, 425/97-01-02 Failure to Demonstrate Fire Detectors Were Operable at least Once per 12 Months (Section F8.1)
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VIO 50-424, 425/97-01-03 Failure to Revise UFSAR to Conform to As-Built j
Appendix R Plant Configurations (Section F8.2)
URI 50-424, 425/97-12-04 Determine if Design Maintenance, and Testing Requirements for the Seismic Fire Protection Dry
Standpipe System are Necessary (Section F8.3)
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Enclosure 2