IR 05000443/1998011

Insp Rept 50-443/98-11 on 981228-990207.No Violations Noted.Major Areas Inspected:Licensee Operations,Engineering, Maint & Plant Support

ML20207C307
Person / Time
Site:	Seabrook
Issue date:	02/26/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207C304	List: IR 05000443/1998011 ML20207C299
References
50-443-98-11, NUDOCS 9903080442
Download: ML20207C307 (21)

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U. S. NUCLEAR REGULATORY COMMISSION i REGION I

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Docket No.: 50-443 l License No.: NPF-86 Report No.: 50-443/98-11 l Licensee: North Atlantic Energy Service Corporation l

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t 4 Facility: Seabrook Generating Station, Unit 1

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Location: Post Office Box 300 1 Seabrook, New Hampshire 03874

Dates

December 28,1998 - February 7,1999

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4 Inspectors: Ray K. Lorson, Senior Resident inspector

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Javier Brand, Resident inspector Paul Frechette, Security Specialist

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1 Approved by: Clifford Anderson, Chief

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Projects Branch 5

Division of Reactor Projects i

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l EXECUTIVE SUMMARY Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/98-11 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six week period of resident and specialist inspectio Operations:

• The licensee implemented adequate actions to address a boron storage deficiency, and to ensure timely access to the start-up feed pump condensate storage tank lower suction valve during cold weather conditions. A weakness was noted involving the effectiveness of previous actions to correct these problems (Section 02),

e The emergency feedwater (EFW) turbine driven pump surveillance test activities were performed well. The inspector noted a minor problem identification weakness in that several personnel from multiple disciplines did not identify a small steam leak from a EFW steam cupply valve. The licensee promptly evaluated the leak, and determined that it did not affect the system operability (Section 04.1).

Maintenance:

• The licensee performed a containment building spray pump test and pipe inspection wel Several minor corrective action and oil sampling program weaknesses were noted following the test. The licensee is developing corrective actions to address the identified concerns (Section M1.1).

• Work control process deficiencies allowed a potentially degraded condition to exist on a safety-related fan for approximately six months without investigation. The equipment issue did not affect plant safety since the fan operated properly when tested (Section M2.1). l Enaineerina:

• The licensee properly evaluated a potential failure mechanism that would have precluded the proper operation of multiple safety-related solenoid valves (Section E1.1).

• The licensee's evaluation of a bulletin discussing the potential to perform a non-conservative calibration of the nuclear instruments was not completed in a timely manne The licensee's subsequent response to this issue was appropriato. The inspector reviewed the operating experience backlog and did not identW any operability concerns (Section E2.1).

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Executive Summary (cont'd)

• The licensee evaluated an EFW pressurization condition that resulted from a degraded component condition. This piping is norrnally maintained depressurized. Pressurization of the emergency feedwater system discharge piping did not affect operation of the system, since the pressure source (check valve leakage) wouH be rapidly depleted during a postulated pipe break event. The licensee had an appropriate plan to ensure that the system operating condition matched the Updated Final Safety Analysis Report (Section E2.2).

Plant Sucoort:

• The licensee was conducting security and safeguards activities in a manner that protected public health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel and packages. This portion of the program, as implemented, met the licensee's commitments and NRC requirements. (Section S1)

• The licensee's security facilities and equipment in the areas of protected area assessment aids, protected area detection aids, and personnel search equipment were determined to be well maintained and reliable and were able to meet the licensee's commitments and NRC requirements. (Section S2)

• Security and safeguards procedures and documentation were properly implemente Event logs were being properly maintained and effectively used to analy s, track, and resolve safeguards events. (Section S3)

• The security force members (SFMs) adequately demonstrated that they had the requisite knowledge i.ecessary to effectively implement the duties and responsibilities associated

with their position. (Section S4)

) * Training was conducted in accordance with the Training and Qualification (T&O) plan, and based upon interviews and inspector observations was considered effective. (Section

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• The level of management support was adequate to ensure effective implementation of the

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security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic needs. (Section S6)

' * The review of the licensee's audit program indicated that the audit was comorehensive in scope and depth, that the audit findings were reported to the appropriate level of management, and that the program was being properly administered, in addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weaknesse (Section P7)

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i TABLE OF CONTENTS Paae

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EX EC UTIV E S U M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TAB L E O F CO NTE NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Op e ratio ns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Ope rations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 G e n e ral Com m e nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 04.1 Emergency Feedwater Pump Operation and Testing ............. 2 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.1 (Closed) LER 50-443/98010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

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08.2 (Closed) LER 50-443/9801 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.3 (Closed) LER 50-443/98012 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.4 (Closed) LER 50-443/98014: ................................3 08.5 World Association Of Nuclear Operators (WANO) Report Review . . . . 4 08.6 (Closed) Violation (VIO) EA 9 8-073 . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l l . M ain t e n a n co . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M1.1 Containment Building Spray Pump Maintenance and Testing . . . . . . . 4 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . . . 5 M2.1 Service Water Fan Deficiency Tag . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Ill. Engineering . . . . . ....... .... .......... ..... .............. ......... 6 E1 Conduct of Engineering . . . . . . . . . ...................................6 E Solenoid Valve Differential Operating Pressure Review . . . . . . . . . . . . 6 E2 Engineering Support of Facilities and Equipment . . .................... 7 E High Flux Trip At Reduced Reactor Power . . . . . . . . . . . . . . . . . . . . . . 7 E Emercency Feedwater (EFW) System Piping Review . . . . . . . . . . . . . 8 I V. Pla n t S u p po rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 R1 Radiological Protection and Chemistry Controls . . . . . . . . . . . . . . . . . . . . . . . 9 R1.1 G e n e ral Com m e nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . . . . . . . 9 S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 10 S3 Security and Safeguards Procedures and Documentation . . . . . . . . . . . . . . . 11 S4 Security and Safeguards Staff Knowledge and Performance . . . . . . . . . . . . . 11 SS Security and Safeguards Staff Training and Qualification . . . . . . . . . . . . . . . 12 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 P7 Quality Assurance (QA) in Security and Safeguards Activities . . . . . . . . . . . . 13 iv i

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Table of Contents (cont'd)

P8 Miscellaneous Security and Safeguards issues . . . . . . . . . . . . . . . . . . . . . . . 14 -

P (Closed) LER 50-443/98S01 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 .

ATTACHMENTS Attachment 1 - Partial List of Persons Contacted

- Inspection Procedures Used

- Items Opened, Closed, and Discussed

- List of Acronyms Used

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i Report Details

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i Summarv of Plant Status

The facility operated at approximately 100% of rated thermal power throughout the inspection period.

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1. Operations

I O1 Conduct of Operatior.s

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O1.1 General Comments (71707)

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Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing

! plant operations. In general, routine operations were performed in accordance with station procedures and plant evolutions were completed in a deliberate manner with clear i communications and effective oversight by shift supervision. Control room logs accurately-I reflected plant activities and observed shift turnovers were comprehensive and thoroughly

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addressed questions posed by the oncoming crew. Control room operators displayed good questioning perspectives prior to releasing work activities for field implementation.

4 The inspectors found that operators were knowledgeable of plant and system status.

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02 Operational Status of Facilities and Equipment

' Insoection Scope (71707. 62707)

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The inspectors routinely conducted independent plant tours and walkdowns of selected

' portions of safety-related systems during the inspection report period. These activities consisted of the verification that system configurations, power supplies, process parameters, support system availability, and current system operational status were

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consistent with Technical Specification (TS) requirements and UFSAR descriptions.

Additionally, system, component, and general area material conditions and housekeeping l status were noted.

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Observations and Findinas

[ During a plant walkdown, the inspector identified that several boric acid barrels were not -

stored in accordance with the posted requirements. The licensee conservatively

, developed the storage requirements to ensure that the floor loading limits would not be exceeded. The licensee initiated an adverse condition report (ACR), and indicated that

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j this problem had been previously identified. Subsequently the licensee revised the posted j instructions to ensure that the barrels would be properly stored. The inspector noted that

! the improper barrel storage did not exceed the floor design limits, and determined that the licensee's corrective act ons were adequat ,

A nuclear systems operator (NSO) identified that the access door (CS 100) to the start-up

feed pump (SUFP) condensate storage tank (CST) lower suction valve (CO-V142) was frozen shut. Potentially, an operator could be required to open valve CO-V142 to ensure

an adequate CST inventory to the SUFP during a loss of the secondary heat sink even i i

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The licensee initiated an ACR, and subsequently installed a temporary heated enclosure to prevent the door from freezing. The inspector concluded that the interim actions were

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adequate, and noted that the licensee planned to develop a permanent solution for this problem.

The inspector leamed, based on discussions with engineering management, that the door had been frozen shut in the past, and that previous efforts to resolve the issue had not been effective. Additionally, the inspector noted that protecting the door was not included l on the cold weather preparations list. The licensee planned to add this item to the cold weather preparations list, and to review the previous corrective action j Conclusions

i The licensee implemented adequate actions to address a boron storage deficiency, and to ensure access to the start-up feed pump condensate storage tank lower suction valve during cold weather conditions. A weakness was noted involving the effectiveness of previous actions to correct these problem Operator Knowledge and Performance I

0 Emeraency Feedwater Pumo Operation and Testina (71707/61726)

, Inspection Scope l

i On February 2, the inspectors observed the turbine driven emergency feedwater pump (EFW) quarterly surveillance test. The inspector reviewed the surveillance procedure, Technical Specifications (TS), and the EFW design basis document (DBD). Observations and Findinas i

The surveillance procedure was performed satisfactorily and the TS acceptance criteria

were met. Control room operators and field personnel communicated and coordinated the test activities well. The required system test parameters such as flow, turbine speed,

pump suction and discharge pressure were satisfie During the test, the inspector identified a small steam leak on the "A" train steam supply l check valve (MS-V94). The licensee promptly removed the insulation and inspected the

! leak. The valve component engineer determined that the leak was at a telltale port and

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not in the pressure boundary portion of the valve. The licensee drafted an adverse condition report (ACR) to document this condition, and to initiate a work request to repair this valve during _the up-coming refueling nutage. The inspector noted a minor problem identification weakness in that several licensee personnel from multiple disciplines were in the room for the test, but did not identify the lea ,

The inspector also identified and questioned an apparent discrepancy between the Technical Requirements Manual (TRM) and the EFW system DBD regarding the required system response time. Specifically, the TRM specifies that the EFW system response time for some actuation signals such as low pressurizer pressure at s 77 seconds, while

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the DBD specifies the response time at s 60 seconds for any automatic EFW actuation signal . Further licensee review concluded that the required EFW system response time is s 77 seconds. The licensee is in the process of revising the DBD accordingly. The inspector noted that the surveillance test requirements were appropriately consistent with the TRM specification Conclusions The emergency feedwater (EFW) turbine driven pump surveillance test activities were performed well. The inspector noted a minor problem identification weakness in that several personnel from multiple disciplines did not identify a minor steam leak from a EFW steam supply va've. The licensee promptly evaluated the leak, and determined that it did not affect the system operability (Section 04.1).

08 Miscellaneous Operations issues 08.1 (Closed) LER 50-443/98010: plant shutdown caused by a degraded generator step-up (GSU) transformer condition. The inspector performed an onsite review of this event, and documented the results in inspection Report 50-443/98-09. The LER adequately described the event, and corrective actions to prevent recurrenc .2 (Closed) LER 50-443/98011: inoperable containment penetration overcurrent protective devices. The LER discussed a licensee identified design deficiency involving a cable ,

connected to a containment electrical penetration that was energized during power l operation without an opuable electrical protective device as required by TS 3.8. The licensee attributed the cause of the event to an inadequate design change review of a fuel handling transfer control system modification. The licensee's planned and completed l corrective actions included: opening the affected circuit breaker, installation of a qualified electrical protective device, and briefing of design engineering personne The inspector performed an in-office review of this event report and noted that the affected circuit had only been energized at power on two occasions, and for less than the allowed TS action statement time. Additionally, the inspector noted that the circuit had been protected by non-1E devices to isolate an electrical fault. The inspector concluded that this event was of minimal significance. The failure to perform an adequate design review is considered a violation of minimal significance, and not subject to formal enforcement actio .3 (Closed) LER 50 443/98012: inadvertent engineered safety feature actuation due to l personnel error. The inspector performed an onsite review of this event, and documented I

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the results in inspection Report 50-443/98-10. No new issues were identified in the LE l 08.4 (Closed) LER 50-443/98014: reactor trip due to pole disagreement on a 345kV breake l The inspector performed an onsite review of this event, and documented the results in ;

Inspection Report 50-443/98-10. No new issues were identified by the LE !

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08.5 World Association Of Nuclear Operators (WANO) Reoort Review (71707)

in October 1998, a WANO team conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and -

to identify areas for improvement. The licensee received the evaluation report in December 1998. The inspector reviewed the report, and determined that the WANO assessment was generally consistent with the most recent NRC assessment of the licensee's performanc .6 (Closed) Violation (VIO) EA 98-073. Failure to Promotiv Correct Degaded Material Conditions: Inspection Report 97-08 Identified three examples where the licensee did not implement prompt, effective corrective actions for degraded plant conditions. These examples included: residual heat removal system pressure boundary leakage (01013),

multiple control building air conditioning compressor failures (02013), and a degraded condition on the positive displacement charging system pump (03013). These issues were discussed at a Predecisional Enforcement Conference on March 24,1998, and a Severity Level (SL) 111 violation, no civil penalty was issued for the multiple failures to properly implement timely corrective action The licensee corrected the individual material deficiencies, and implemented extensive corrective actions to improve the station's operational focus. These actions included:

implementation of a ninety-day plan to improve operational focus, revision of the morning (. management meeting, enhanced engineering support to operations, a comprehensive 4 safety system walkdown program, and implementation of a 12 week work planning

! process to reduce the maintenance backlog. The inspector concluded that the licensee's

actions were reasonable and complete. This violation is closed.

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11. Maintenance M1 Ccnduct of Maintenance M1.1 Containment Buildina Sorav Pumo Maintenance snd Testina (62707)

i Insoection Scope i On January 13, the inspector observed a portion of a "B" containment building spray l' (CBS) pump test, and associated pipe inspection.

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' Observations and Findinas The test was designed to verify the mechanical integrity of the "B" CBS piping, and to verify the CBS pump operability. The test was performed by aligning the CBS pump

, suction to the refueling water storage tank (RWST) while operating the pump in the recirculating mode of operation. The inspector reviewed the online maintenance (OLM)

assessment for this evolution and found it to be acceptable. The inspector performed an

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independent visual inspection of the suction and discharge piping and pump component No problems or leaks were identified.

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The CBS pump and motor oil were sampled following the pump run per the oil analysis program. Several oil analysis, and corrective action program weaknesses were noted l

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during the sampling activities including:

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• The oil samples were obtained approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pump was shutdown, contrary to the procedural recommendation to obtain the sample within l

30 minutes of the pump shutdown. Extracting the sample late could result in a non representative sampl ! * An adverse condition report was not initiated to document the !6te oil sample '

approximately 8 day '

• The oil sampling procedure directed that the sample be extracted from the midpoint of the bearing oil reservoir. The inspector noted, based on discussions

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with the mechanic, and program engineers that it is difficult to ensure that the oil

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samples are consistently drawn from this location. The difficulty in extracting the .

sample from a consistent location could result in a non-representative sample.

' * A potential industrial safety concern was identified when a mechanic climbed over the pump motor due to accessibility limitations caused by a temporary scaffold, and because he did not want to reach across the air space above the marked off contaminated area on the pump base. The Health Physics department developed a training mock-up to enhance employees knowledge of contaminated area

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requirement The lubrication program manager stated that several program enhancements including: addition of a mechanic to the oil analysis group, group meetings, and a procedure revision were being developed to ensure that the oil samples would be consistently drawn. Additionally, he stated that the CBS pump operation was acceptable since the other pump parameters (i.e, vibration, bearings temperature, and discharge pressure and flow) were normal.

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The licensee performed a containment building spray pump test and piping inspection i well. Several minor corrective action and oil sampling program weaknesses were note The licensee is developing corrective actions to address the identified concern '

M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Service Water Fan Deficiency Tao

- Inspection Scope

- The inspector reviewed the disposition of a deficiency tag hung in August 1998 on a service water cooling tower switchgear supply fan (SWA-FN-63).

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6 Observations and Findinos Fan SWA-FN-63 is a safety-related fan that provides ventilation to electricM switchgear within the service water cooling tower. The deficiency tag indicated that the fan motor inboard bearing was noisy and also that the motor housing was ho The inspector discussed the tag information with the system engineer (SE), and learned that work request (WR) 98 WOO 2816 was initially generated to resolve these potential deficiencies. Subsequently, WR 98 WOO 2816 was voided, and the work activities were to be incorporated into WR 98 WOO 1163. However, no activities were actually performed since WR 98 WOO 1163 was in a " hold" status. Additionally, the original WR activities were not added to the "new" WR due to an administrative error. The inspector noted that these work process control deficiencies allowed a potentially degraded condition to exist for approximately six months without investigation. Additionally the inspector noted that no WR existed to address the issues listed on the deficiency ta The licensee initiated an ACR to review this event, and satisfactorily tested the fan. The inspector concluded, based on the acceptable fan performance, that this issue reflected a work control process weaknes Conclusions Work control process deficiencies allowed a potentially degraded condition to exist on a safety-related fan for approximately six months without investigation. This issue did not affect plant safety since the fan operated properly when teste Ill. Enaineerina E1 Conduct of Engineering E Solenoid Valve Differential Operatino Pressure Review (37551) Inspection Scope The inspector eviewed the evaluation of a potential failure mechanism for safety-related solenoid valve Observations and Findinos l l

The licensee identified a concern that certain solenoid valves would not be capable of performing their design safety function following a failure of their associated non safety upstream pressure regulating valve. The postulated regulating valve failure would result in supplying instrument air header pressure to the solenoid valve, resulting in an excessive solenoid valve differential pressure. The excessive differential pressure could prevent the solenoid valve from operating to its required safety positio l l

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The licensee analyzed the pressure regulating valves, and determined that these valves would remain functional following design basis seismic and environmental conditions. The

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licensee concluded that the solenoid valve failure discussed above was not credible. The inspector reviewed the licensee's analysis, and determined that it was adequat Additionally, the inspector noted that the licensee planned to replace the affected solenoid valves with a higher differential pressure rated valv c. Conclusions The licensee properly evaluated a potential failure mechanism tl'at would have precluded the proper operation of multiple safety-related solenoid valve E2 Engineering Support of Facilities and Equipment E2.1 Hiah Flux Trio At Reduced Reactor Power Inspection Scope The inspector reviewed the licensee's response to a Westinghouse Technical Bulletin (92-14R1) regarding calorimetric inaccuracies at low power level Observations and Findinas Technical Specification Surveillance Requirement 4.3.1.1, Table 4.3-1, requires a daily nuclear instrument (NI) channel calibration be performed above 15% of rated thermal power (RTP). The channel calibration is performed by comparing the secondary I

calorimetric power to the indicated NI power. The Nls are required to be adjusted to maintain the absolute difference between the Nls and secondary power to < 2%.  !

Westinghouse issued a bulletin in 1996 identifying the potential for a non-conservative N1 l calibration resulting from an Ni adjustment to the secondary power calorimetric at low i power levels. This calibration error could result in a non-conservative NI power indication l greater than assumed in existing design analysi l i

The licensee's preliminary evaluation, concluded that due to the very small uncertainty in ;

the power calorimetric (< 2% reactor power) no immediate operability concern existed, l while the Unit remained at 100 % power. The licensee determined, however, that a l

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potential non conservatism existed if the Ni were adjusted down (i.e. NI power greater

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than calorimetric power) at a lower power level since the gain reduction would effectively delay the high power trip. The licensee promptly issued an standing operating order :

instructing the operators to reduce the Power Range Neutron Flux High Trip setpoint by l 14% when operating below 80% reactor power. Additionally, the licensee evaluated the last shutdown of December 97, and verified that no Ni downward adjustments had been )

performe j The oversight group identified that the review of this bulletin had not been evaluated in a timely manner, at the time, the operating experience program did not require an initial screening review of issues. The licensee indicated that the operating oxperience program )

was revised last year to reqt, ire a prompt preliminary screening of isst es. The inspector l l

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reviewed selected open items from the operating experience list and did not identify any operability concerns. Similarly, a review of the operating experience backlog by the oversight group did not identify any operability concern Conclusion The licensee's evaluation of a bulletin discussing the potential to perform a non-conservative nuclear instrument calibration was not completed in a timely manner. The licensee's subsequent response to this issue was appropriate. The inspector reviewed the operating experience backlog and did not identify any operability concern E2.2 Emeraency Feedwater (EFW) System Pioina Review Insoection Scope The inspectors reviewed a licensee identified condition involving pressurization of the emergency feedwater system (EFW) discharge header piping, Observations and Findinas I

The system engineer initiated work request (WR) 99000002 to install a gage to record the !

EFW discharge header pressure. The gage indicated that the discharge header was l i

pressurized to about 994 psig. This pressure was consistent with the feedwater (FW)

system pressure and indicated that the previously identified backleakage through the EFW l to MFW isolation check valves and past V-70 to the CST, was now being contained by the EFW pump outlet check valves (V-70 and V-64). Inspection Report 98-10 discussed the recent repair of the motor driven EFW pump outlet check valve (FW-V-70), completed I on November 17, to minimize the seat leakage. The inspector noted the EFW piping is normally maintained depressurized and questioned the acceptability of allowing it to

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remain pressurize i

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The inspector discussed this concern with the Mechanical Design Engineering Manager who indicated that the EFW piping had been designed for 250 F, and 1595 psi Additionally the licensee indicated that the piping, although pressurized, remained a moderate energy system since the pressure source (i.e. check valve leakage) would be rapidly depleted during a postulated pipe break event. Based on the above information, the inspector concluded that the pressurization of the EFW system discharge header piping was not a safety proble The inspector noted that the UFSAR indicated that the EFW isolation check valves

" maintain the EFW piping depressurized during normal operation," and questioned whether a 10 CFR 50.59 ovaluation should have been performed to address this apparent inconsistency. The licensee indicated that an evaluation was not required since the EFW pressurization resulted from a degraded component condition, and the piping remained within its design basis. The licensee indicated, however, that they would revise the UFSAR to clarify the EFW system operating condition. Additionally, the inspector noted that this condition will be incorporated into the 10 CFR 50.59 review that the licensee is preparing for the FW-V-70 valve replacement. The inspector concluded that the licensee

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had an adequate plan to ensure that the UFSAR description matched the system 1

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operating conditio Conclusions I

The licensee evaluated an EFW pressurization condition that resulted from a degraded

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component condition. This piping is normally maintained depressurized. The licensee determined that pressurization of the emergency feedwater system discharge piping did not affect operation of the system, since the pressure source (check valve leakage) would

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be rapidly depleted during a postulated pipe break event. The licensee had an i appropriate plan to ensure that the system operating condition matched the Updated Final j Safety Analysis Report (UFSAR).

IV. Plant Support

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R1 Radiological Protection and Chemistry Controls R1.1 General Comments (71750)

I During the period the inspectors frequently toured the radiologically controlled area (RCA)

i and observed radiological controls practices. The radiological controls technicians were

observed to be attentive and provided high quality assistance to plant workers. Plant

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workers were observed to be following proper radiological work practices including the use i of dosimetry and protective equipment. Personal briefings conducted prior to containment

entries were thorough and informative.

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S1 Conduct of Security and Safeguards Activities i Insoection Scope (81700)

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Determine whether the conduct of security and safeguards activities met the licensee's commitments in the NRC-approved security plan (the Plan) and NRC regulatory -

! requirements. The security program was inspected during the period of February 1-5, t 1999. Areas inspected included: access authorization; alarm stations; communications; protected area (PA) access control of personnel and packages.

i Observations and Findinos Access Authorization Proaram The access authorization (AA) program was reviewed to

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verify implementation was in accordance with applicable regulatory requirements and Plan commitments. The review included an evaluation of the effectiveness of the AA procedures, as implemented, and an examination of AA records for 5 individuals. Records review included both persons who had been granted and had been denied access. The AA program, as implemented, provided assurance that persons granted unescorted access did not constitute an unreasonable risk to the health and safety of the publi Additionally, by reviewing access denial records and applicable procedures, it was determined that appropriate actions were taken when individuals were denied access or

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had their access terminated. Those actions included the availabilit';of a formalized process that allowed individuals the right to appeal the licensee's decision.

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Alarm Stations The inspectors made multiple observations of operations in the Central

Alarm Station (CAS), and the Secondary Alarm Station (SAS). These reviews provided

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verification that the alarm stations were equipped with appropriate alarms, surveillance

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and communications capabilities. Interviews with the alarm station operators found them L knowledgeable of their duties and responsibilities. It was also verified, through l observations and interviews, that the alarm stations were continuously manned, i independent and diverse so that no single act could remove the plants capability for

] detecting a threat and calling for assistance and the alarm stations did not contain any ,

! operational activities that could interfere with the execution of the detection, assessment .

and response function !

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Communications The inspectors conducted document reviews and discussions with alarm station operators. These reviews and discussions led the inspector to conclude that the j alarm stations were capable of maintaining continuous intercommunications, communications with each security force member (SFM) on duty, and were exercising

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communication methods with the local law enforcement agencies as committed to in the Pla ;

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PA Access Control of Personnel. Hand-Carried Packaaes and Material. On February 2, i 1999, personnel and package search activities were observed at the personnel access l

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portal it was determined that positive controls were in place to ensure only authorized j

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individuals were granted access to the PA and that all personnel and hand carried items entering the PA were properly searche ;

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! Conclusions

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The licensee was conducting its security and safeguards activities in a manner that  :

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protected public health and safety. This portion of the program, as implemented, met the licensee's commitments and NRC requirements.

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j S2 Status of Security Facilities and Equipment Insoection Scope (81700) I

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Areas inspected were

PA assessment aids, PA detection aids, personnel search  !

j equipment and testing, maintenance and compensatory measure i

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). Observations and Findinas

1 PA Assessment Aids The effectiveness of the assessment aids was evaluated, by I

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observing on closed circuit television, an SFM conducting a walkdown of the perimeter of j t

the PA. The assessment aids had good picture quality and excellent zone overlap.

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Additionally, to ensure Plan commitments are satisfied, the licensee has procedures in i 4 . place requiring the implementation of compensatory measures in the event the alarm _j j station operators are unable to properly assess the cause of an alar ,

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Personnel and Packaae Search Eauipment Routine use and performance testing of the licensee's personnel and package search equipment were observed. Observations and procedural reviews indicated that the search equipment performed in accordance with

licensee procedures and Plan commitments.

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PA Detection Aids Multiple observations of an SFM conducting performance testing of the l

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perimeter intrusion detection system (PIDS) were conducted. The testing consisted of 3 intrusion attempts in each of five different zones. The appropriate alarms were generated in each attempt. In addition, during the perimeter walkdown, random intrusions were j attempted with the appropriate alarm being generated in each case. The equipment was functional and effective and met the requirements of the Plan.

j c. Conclusions i

The licensee's security facilities and equipment were determined to be well maintained i

and roliable and were able to meet the licensee's commitments and NRC requirement !

S3 Security and Safeguards Procedures and Documentation

. Insoection Scope (81700)

Areas inspected were: implementing procedures and security event log b. Observations and Findinas

Security Proaram Procedures The inspectors verified that the procedures were consistent ,

, with the Plan commitments, and were properly implemented. This was accomplished by reviewing selected implementing procedures associated with access authorization, PA access control of personnel, packages and materials, testing and maintenance of personnel search equipment and performance testing of PA detection aid Security Event Loas The Security Event Logs for the previous twelve months were reviewed. Based on this review, and discussion with security management, it was determined that the licensee appropriately analyzed, tracked, resolved and documented safeguards events that the licensee determined did not require a report to the NRC within

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1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

j Conclusions Security and safeguards procedures and documentation were being properly implemented. Event Logs were being properly maintained and effectively used to analyze, track, and resolve safeguards event S4 Security and Safeguards Staff Knowledge and Performance [nispection r Scoce (81700)

Area inspected was: security staff requisite knowledge

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12 Observations and Findinas ,

Security Force Reauisite Knowledae Observations of a number of SFMsin the performance of their routine duties were conducted during the inspection period. These observations included alarm station operations, personnel, and package searches, and -

performance t.esting of the PIDS. Additionally, interviews of SFMs were conducte Based on the responses, it was determined that the SFMs were knowledgeable of their responsibilities and duties, and could effectively carry out their assignment Conclusions f

The SFMs adequately demonstrated that they had the requisite knowledge necessary to effective ly implement the duties and responsibilities associated with their positio S5 Security and Safeguards Staff Training and Qualification Inspection Scooe (81700)

i Areas inspected were security training and qualifications, and training records, Observations and Findinas

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Security Trainina and Qualifications. Ten randomly selected T&Q records of SFMs were reviewed. Physical and requalification records were inspected for armed and supervisory '

personnel. The results of the review indicated that the security force was being trained in accordance with the approved T&Q plan.

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Trainina Records Review of training records indicated that the records were properly ,

i maintained, accurate and reflected the current qualifications of the SFMs.

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[ Conclusions '

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! Security force personnel were being trained in accordance with the requirements of the T&Q Plan. Training documentation was properly maintained and accurate and the training provided by the training staff was effective. i S6 Security Organization and Administration inspection Scooe (81700) ,

Areas inspected were: management support, effectiveness and staffing levels.

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. Manaaement Support Various program enhancements made since the last program i inspection which was conducted in July,1998, were reviewed. These enhancements .

l included the allocation of resources for procurement and installation of 25 new CCTV

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cameras and new equipment to enhance tactical training.

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Manaaement Effectiveness The inspector reviewed the management organizational structure and reporting chain and noted that the Security Manager's position in the organizational structure provides a means for making senior management aware of programmatic needs.

e Staffino Levels The inspector verified that the total number of trained SFMs immediately available on shift met the requirements specified in the Pla Conclusions The level of management support was adequate to ensure effective 4 implementation of the security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic need P7 Quality Assurance (QA)in Security and Safeguards Activities

, Inspection Scoce (81700)

Areas inspected were: audits, problem analyses, corrective actions and effectiveness of management control Observations and Findinas

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Audits The 1998 OA audit of the fitness for duty program conducted December 7-14, 1998, (Audit No. 98-A12-01) was reviewed. The audit were found to have been conducted in accordance with the Plan and was enhanced by the use of technical specialists as

' members of the audit team.

! Audit report 98-A12-01 identified no findings, and three recommendations for improvemen i Problem Analyses A review of data derived from the security department's self-assessment program was accomplished. Potential weaknesses were being properly

> identified, tracked, and trende Corrective Actions A review of the corrective actions implemented by the licensee in response to the OA audit and self-assessment program indicated that the corrective actions were technically sound and were performed in a timely manne Effectiveness of Manaaement Controls The licensee had programs in place for identifying, analyzing and resolving problems. They included the performance of annual OA audits, a departmental self-assessment program and the use of industry data such as violations of regulatory requirements identified by the NRC at other facilities, as a criterion

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for self-assessmen Conclusions

The review of the licensee's audit program indicated that the audit was comprehensive in scope and depth, that the audit findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a

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review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weakness.

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P8 Miscellaneous Security and Safeguards issues P8.1 (Closed) LER 50-443/98S01: incomplete pre-employment screening records. This event was discussed in Inspection Report 50-443/98-10. No new issues were identified by the

. LE V. Manaaement Meetinas X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management, following the conclusion of the inspection period, on February 11,1999. The licensee acknowledged the findings presented.

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ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Licensee G. Boissy, Assistant Station Director W. Diprofio, Unit Director J. Ellis, Security Supervisor C. Goodnow, Chief of Security J. Grillo, Technical Support Manager

, M. Harvey, Senior Auditor J. Hill, Operations Supervisor J. Kwasnik, Senior Radiation Scientist J. Linville, Chemistry and Health Physics Manager R. Messina, Security Supervisor J. Peterson, Maintenance Manager

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P. Ryan, Special Project Coordinator G. StPierre, Operations Manager B. Seymour, Security Manager J. Savold, I&C Technician, Meteorological M. Toole, l&C Manager R. Thurlow, Health Physics Supervisor R. White, Design Engineering Manager INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 81700: Physical Security Program for Power Reactors IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities ITEMS OPENED, CLOSED, AND DISCUSSED Closed: LER 98-010: Plant shutdown caused by a degraded generator step-up transformer bus deficienc LER: 98-011: Inoperable containment penetration overcurrent protection devic LER 98-012: Engineered Safeguards Feature Actuation due to Personnel Error LER 98-014: Reactor Trip due to 345 kV breaker proble LER 98-S-01: Incomplete Pre-Employment Screening records EA 97-073: Failure to implement Prompt Corrective Actions for a Degraded Plant Conditio *,.6 Attachment 1 2 LIST OF ACRONYMS USED ACR Adverse Condition Report ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials CAS Central Alarm Station CBS Containment Building Spray CCTV closed circuit television CST Condensate Storage Tank DESEL Duke Engineering and Sciences Environmental Laboratory DOE U.S. Department of Energy EDG Emergency Diesel Generator EFW Emergency Feedwater EML Environmental Measurements Laboratory EPA U.S. Environmental Protection Agency FME Foreign Material Exclusion gpd gallons per day gpm gallons per minute LCO Limiting Condition for Operation MMP Meteorological Monitoring Program MOV motor operated valve MPCS Main Plant Computer System NIST National Institute of Standards and Technology NSARC Nuclear Safety and Audit Review Committee NSARC OS NSARC Operations Subcommittee ODCM Offsite Dose Calculation Manual the Plan NRC-approved physical security plan PA protected area psig pounds per square inch gauge OA Quality Assurance OC Ouality Control REMP Radiological Environmental Monitoring Program RESL Radiochemical and Environmental Sciences Laboratory RHR Residual Heat Removal SAS Secondary Alarm Station SFM security force member SG steam generator SIR Station Information Report SORC Station Operations Review Committee SUFP Startup Feedwater Pump SW Service Water TDEFW Turbine Driven Emergency Feedwater Pump TLD Thermoluminescent Dosimeter T&O training and qualification TS Technical Specifications UFSAR Updated Final Safety Analysis Report WR work request YAEL Yankee Atomic Environmental Laboratory

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