IR 05000443/1999001

Insp Rept 50-443/99-01 on 990207-0321.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support

ML20206B353
Person / Time
Site:	Seabrook
Issue date:	04/20/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206B349	List: IR 05000443/1999001 ML20206B345
References
50-443-99-01, 50-443-99-1, NUDOCS 9904290217
Download: ML20206B353 (14)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-443 l License No.: NPF-86 l Report No.: 50-443/99-01 l

North Atlantic Energy Service Corporation

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Licensee:

Facility: Seabrook Generating Station, Unit 1 Location: Post Office Box 300 I Seabrook, New Hampshire 03874 i Dates: February 7,1999 - March 21,1999 Inspectors: Ray K. Lorson, Senior Resident inspector ;

Javier Brand, Resident inspector !

Approved by: Clifford Anderson, Chief ,

Projects Branch 5 l Division of Reactor Projects

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9904290217 990420 PDR ADOCK 05000443 o PM

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EXECUTIVE SUMMARY Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/99-01 This integrated inspection included aspects of licensee operations, engineering, !

maintenance, and plant support. The report covers a 6 week period of resident inspectio Ooerations:

e Routine operations were performed well. The licensee responded well to minor equipment deficiencies identified during the period (Section 01). I e Multiple station personnel failed to recognize and question an improper pre-conditioning activity performed on the primary auxiliary building fan dampers during

- routine testing. The licensee initiated an adverse condition report to review this event. The failure to properly test the safety-related fans is considered a non-cited violation (NCV 99-01-01) (Section 04.1),

e The licensee properly initiated several non emergency event reports during the period (Section 08).

Maintenance:

e The licensee properly identified and evaluated a small leak on the "A" containment building spray pump casing drain line. The leak was determined not to be pressure boundary leakage, end the licensee planned to repair this leak during the next refueling outage (Section M1.1).

e The risk management review for the scheduled refueling outage (ORO6) activities was thorough, and indicated that the planned outage activities presented minimal plant risk. The outage review board properly reviewed the scope of the planned outage activities (Section M1.2).

e Surveillance testing was performed well during the period (Section M1.3).

Enaineerina:

e Component engineering adequately identified and evaluated several abnormal lubricating oil samples on safety-related components. Although none of the deficiencies challenged the operability of the affected components, the licensee developed adequate plans to address the identified anomalies (Section E2.1).

e The licensee failed to implement adequate corrective actions to prevent recurrence of repeated primary auxiliary building fan test failures. This is considered a non-cited violation (NCV 99-01-02). The licensee determined that a postulated failure of both fans failures would not have cha!!enged the operation of the primary ii

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component cooling water pumps. The initial review of an improperly installed identification tag did not evaluate the potential for this problem to exist on other safety-related components (Section E4.2).

Plant Sunoort:

e- Radiation worker performance was observed to be good during the period. Health physics technicians provided good support to plant workers (Section R1.1)

e Security personnel properly evaluated two cases of potential tempering in the alternate health physics checkpoint trailer. The inspector identified weaknesses '

regarding the timeliness to notify operations, and security personnel of the first event, and in securing the area to support the subsequent investigation (Section S1.1 ).

i e The licensee responded well to several fitness for duty test failures during the period (Section 1.2)

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TABLE OF CONTENTS EiL92 EX EC UTIVE S UM M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TABLE O F CO NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operations ....................................................1 01 Conduct of Operations . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operatioaal Status of Facilities and Equipment ................... 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . , . . . . . . 1 04.1 Failure Of Primary Auxiliary Building (PAB) Fan PAH-FN-428 . . . . . 1 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.1 Eve nt Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 11. Maintenance . . . . . . . . . . ........................................3 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 ;

M1.1 " A" CBS Pump Casing Drain Leak . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.2 Refueling Outage Planning Activities .....................4 l M1.3 Surveillance Test Observations . . . . . . . . . . . . . . . . . . . . . . . . . 4 111. Enginee ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E2 Engineering Support of Facilities and Equipment .................. 5 E Safety Related Pump Lubricating Oil Analysis Results . . . . . . . . . . 5 E2.2 Primary Auxiliary Building (PAB) Fan Reliability . . . . . . . . . . . . . . 6 i

l IV. Plant Support .................................................7 R1 Radiological Protection and Chemistry Controls . . . . . . . . . . . . . . . . . . . 7 R Ge aral Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . 7 l S Damaged Cables in Alternate Health Physics Checkpoint Trailer .. 7 S1.2 Fitness for Duty Test Failures . . . . . . . . . . . . . . . . . . . . . . . . . . 8 V. Management Meetings ........... ...............................8 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ATTACHMENTS Attachment 1- Partial List of Persons Contacted-Inspection Procedures Used

- Items Opened, Cloud, and Discussed iv

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Report Details Summarv of Plant Statug

The facility operated at approximately 100% of rated power throughout most of this inspection period. The licensee performed a minor power reduction on February 23, to troubleshoot a failed hot leg temperature circui . Operations

' 01 Conduct of Operations 01.1 General Comments (717071 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 communications and effective oversight by shift S upervision. Control room logs accurately reflected plant activities and observed shift turnovers were comprehensive and thoroughly addressed questions posed by the oncoming crew. Control room operators displayed good questioning perspectives prior to releasing work activities for field implementation. The inspectors found that operators were knowledgeable of plant and system statu Operational Status of Facilities and Equipment Inspection Scone (71707. 62707)

The inspectors routinely conducted independent plant tours and walk downs of selected portions of safety-related systems during the inspection report perio These activities consisted of the verification that system configurations, power supplies, process parameters, support system availability, and current system operational status were consistent with Technical Specification (TS) requirements and UFSAR descriptions. Additionally, system, component, and general area material conditions and housekeeping status were noted. The inspectors found that the plant conditions were acceptable, but identified some minor material deficiencies that were appropriately addressed by the license j 04 Operator Knowledge and Performance

. 04.1 Failure Of Primarv Auxiliary Buildina IPAB) Fan PAH-FN-42B Insoection Scope The inspectors evaluated the licensee's response to two PAH-FN-42B primary auxiliary building (PAB) fan failures during routine testing on February 11, and on March 11. Additionally, the inspectors reviewed the test practices associated with these fan I

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c. Observations and Findinas Fans PAH-FN-42A and 42B are safety-related fans designed to maintain the ambient temperature conditions adjacent to the primary component cooling water (PCCW)

pumps, and other safety-related components within acceptable limits following a !

design basis accident. The fans provide a support function for the PCCW pumps, i and the operators declare the PCCW loop inoperable when the associated PAH fan l is out of servic The air supply to the fans is provided through isolation dampers that must open to allow the fan motors to start. Additionally, the dampers provide a tornado protection function for the PAB. The PAH fans and isolation dampers are routinely tested to ensure proper operation. Periodically, over the past several years, (since early 1994) the operators have been required to mechanically agitate the dampers in order to complete this testing. In October 1998, an operator questioned whether assisting the dampers affected the validity of the test results, and initiated engineering work request (EWR 98-0594) to review this practic On December 30, the licensee completed its engineering evaluation, and concluded that it was not acceptable to manually assist a damper in order to complete the fan testing. The evaluation also indicated that if the damper required mechanical agitation to fully operate, then it should be considered degraded and non-functiona ;

The inspectors agreed with this response, but were concerned that personnel in !

multiple disciplines (i.e. engineering, operations, and maintenance) allowed this practice to continue for an extended period of time. The inspectors were also concerned that this practice had been incorporated into the fan and damper test instructions. The licensee's actions to address the fan damper performance problems are discussed in Section E The licensee initiated an adverse condition report (ACR) to review this issue. The management review team (MRT) initially reviewed and classified this ACR as " trend only". The inspectors were concerned that the MRT review was narrowly focused, and didn't consider the potential need to improve operator knowledge and focus to prevent similar pre-conditioning activities. Subsequently, the licensee drafted a

" white paper" on pre-conditioning, and initiated ACR 99-0474 to review the station practices regarding the pre-conditioning of equipmen The inspectors noted an additional potential fan pre-conditioning activity that demonstrated the need to maintain focus on this issue. Specifically, on January 3, 1999, the control room operator had to operate the 42A PAH control switch three times before the fan successfully started. The operator, however, did not ,

apparently consider this 6 potential test failure, or initiate a work request to review whether the fan operated properl Appendix B, Criterion XI, " Test Control," to 10CFR50, requires, in part, that "a test program be established to assure that structures, systems and components (SSC)

will perform satisfactorily in service". Contrary to the above, on multiple occasions

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between 1994, and December 1998, the licensee did not always properly test the PAB fans to ensure that they were capable of performing their design function. This is a violation of 10CFR50, Appendix B, Criterion XI. The licensee initiated ACR 99- i 0474 to review this issue. This non-repetitive, non-willful violation is being treated l as a non-cited violation (NCV 99-01-01) consistent with Appendix C of the NRC i Enforcement Polic j Conclusion Multiple station personnel failed to recognize and question an improper pre-

. conditioning activity performed on the primary auxiliary building fan dampers during routine testing. The licensee initiated an adverse condition report to review this i event. The failure to properly test the safety-related fans is considered a non-cited l violatio '

08 Miscellaneous Operations issues 08.1 Event Reoorts The licensee properly issued several non-emergency event reports per 10 CFR 50.72 during the period to report issues involving dead seals and ducks in the plant intake structure, the improper release of sewage to a storm drain system, and a fitness for ;

duty test failur '

II. Maintenance M1 Conduct of Maintenance l M1.1 "A" CBS Pumo Casina Drain Leak Insoection Scooe The inspector reviewed the response on February 11, to a licensee identified boric i acid deposit on the "A" containment building spray pump (CBS) casing drain line, Observations and Findinas l The licensee promptly removed the boron, and performed non-destructive testing on the seal weld which identified three small but acceptable indications. The boron deposit subsequently re-appeared which confirmed the presence of a smalllea The licensee determined that this seal weld had been installed in December 1984 to stop leakage past the threaded connection and was not part of the pressure boundary. The leakage was then considered not significant, and acceptable in accordance with ASME Code requirements. The licensee indicated that the leak would be repaired during the refueling outage.

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.. Conclusion The licensee properly identified and evaluated a small leak on the "A" containment i building spray pump casing drain line. The leak was determired not to be presture l boundary leakage, and the licensee planned to repair this lea 6 during the next l refueling outag M1.2 Refuelino Outaae Plannina Activities l The inspectors re9iewed the risk management evaluation of 1he scheduled refueling outage (ORO6) activities. The inspectors noted that the licensee's review was properly focused on assessing the overall risk associated with each of the expected plant configurations. Additionally, the review highlighted concerns associated with '

several potential, but unplanned plant configurations. The tsview indicated that the outage risk was relatively low due to the proper scheduling of activities to maximize the redundancy of the key safety functions. The inspectorn concluded that the scheduled outage risk was low.

l The licensee formed an outage review board (ORB) to review the scope of the I

planned outage activities. The inspectors attended an ORD meeting, and noted that the planned outage activities were evaluated against pre-established criteria to determine whether the planned outage activities should re nain within the ORO6 scope. Additionally, the inspectors reviewed selected act vities that the ORB removed from the outage scope and did not identify any c onterns. The inspectors concluded that the ORB properly reviewed the outage work activitie M1.3 Surveillance Test Observations The inspectors observed several surveillance tests durin(1 the period including:

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- B" emergency diesel generator testing per procedu:e OX1426.05;

- motor driven emergency feedwater pump testing per trocedure OX1436.03;

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- C" spent fuel pump testing per procedure, OX1414.0 The inspectors observed that all tests were controlled 'Nell, and in accordance with the applicable procedures. Communications were clear, and pre-test briefings were thorough. The testing demonstrated that the safety-related equipment met the technical specification requirement ,

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til. Engineering E2 Engineering Support of Facilities and Equipment E Safety Related Pumn Lubricatina Oil Analysis Results

- Inspection Scone The inspector reviewed component engineering's response to anomalous lubricating oil analysis results on the "A" residual heat removal (RHR) pump motor, the turbine driven emergency feedwater (EFW) pump, and the "A" cooling tower pump moto Observations and Findmos The "A" RHR pump motor oil was sampled on February 23, and visually appeared to be an abnormal color (grayish-green). The oil analysis vendor analyzed the oil using ferrography and spectral analysis, and identified high levels of iron, silicon, and zin The licensee evaluated the RHR pump motor operating history and determined that all parameters (1.E.; vibration data, bearing temperatures, pressure and flow) were acceptsble and that no operability concern existed. Additionally, the licensee determined that the discoloration was not related to any rotating component wear products. The licensee indicated that the motor oil would be replaced during the up-coming refueling outag The EFW pump lubricating oil sample indicated a high concentration of non-metallic particles.' The licensee discussed this problem with the oil vendor and determined that the particles were typical for this brand of oil. The licensee noted that the particle size was small enough so that the particles would not be expected to -

interfere with proper operation of the turbine. Additionally the turbine operating parameters were acceptable. The licensee concluded that the EFW turbine remained ,

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l The "A" cooling tower pump motor lower bearing oil sample showed evidence of j paint chips, possibly from the reservoir coating. Oil samples taken from the "B" '

pump also revealed the presence of paint chips, The licensee confirmed that the i chips were not attributed to metal wear products, and that all pump performance parameters including vibration levels were satisfactory. Additionally, the licensee l

. planned to drain, flush and visually inspect the lubricating oil reservoirs for both R pumps during the up-coming refueling outag Conclusion j

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Component engineering ~ adequately identified and evaluated abnormal lubricating oil samples on several safety-related components. Although none of the deficiencies challenged the operability of the affected components, the licensee developed adequate plans to address the identified anomalie n

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E2.2 Primarv Auxiliarv Buildina (PAB) Fan Reliability Inspection Scone The inspectors reviewed the licensee's response to repeat operating problems during routine testing of the primary auxiliary building (PAH-FN-42A and 42B) fans Observations and Findmas The PAH fan system description and functions are described in Section 04.1. The PAH fans have experienced a large number of documented test failures dating back to 1994. In March 1998, based on the fan operating history, the licensee placed the system into category (a)(1) per the maintenance rule. This required the licensee to develop a system perfr,rmance goals, and a plan to improve the system

. performance. The plan to improve the PAH fan system performance was issued in February 1999. The plan provided for increased preventive maintenance and inspection of the PAH fan dampers. The inspector reviewed the plan and concluded that it was adequate, but noted that it took a relatively long time to develop. The licensee agreed with this assessment and initiated ACR 99-1176 to review this concern along with other licensee identified maintenance rule program issue The licensee evaluated the impact of the PAH fan performance history, and concluded that it would not have significantly challenged the PCCW pumps. This evaluation was based on the large open area surrounding the pumps for heat dissipation combined with a relatively high PCCW pump motor tempereture limi The inspectors agreed with this conclusion, and noted that the projected ambient temperature following an accident (assuming no area ventilation) would not cause the continuous motor winding temperature limit to be exceede . Appendix B, Criterion XVI, " Corrective Actions", of 10CFR50 requires, in part,- that corrective actions be promptly implemented for conditions adverse to qualit Contrary to the above, the PAH fan system failed to operate properly during testing on numerous occasions since 1994, and without implementing adequate corrective actions to improve the system performance. This is a violation of 10CFR50, Appendix B, Criterion XVI. The licensee initiated a ACR 99-1176 to review and improve the maintenance rule program to provide for better response to equipment deficiencies. This non-repetitive, non-willful violation is not being cited (NCV), in accordance with Appendix C, of the NRC Enforcement Polic A licensee technician identified that an improperly located component identification tag interfered with the proper operation of a PAH 42 fan damper assembly limit switch. The licensee was unable to determine how the tag initially became installed in that location, and initiated an ACR to document this finding. The MRT classified i this ACR as " trend only". The inspectors were concerned that this evaluation was narrowly focused and questioned whether other identification tags could have been similarly mis-installed. - The licensee subsequently reviewed some other safety-related dampers, and found several examples where the component identification l

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tags were not properly installed. The licensee developed a plan to inspect all safety-related fan damper assemblies to ensure that the identification tag would not ;

interfere with the limit switch operatio Conclusions The licensee failed to implement adequate corrective actions to prevent recurrence of repeated primary auxiliary building fan system test failures. This is a non-cited violation. These failures would not have challenged the operation of the primary component cooling water pumps. The initial review of an improperly installed ;

identification tag did not evaluate the potential for this problem to exist on other safety related component IV. Plant Suonort i

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R1 Radiological Protection and Chemistry Controls j R1.1 General Comments  ;

1 Insoection Scooe (71750)

I During the period the inspectors frequently toured the radiologically controlled area (RCA) and observed radiological controls practices. The radiological controls l technicians were observed to be attentive, and provided high quality assistance to !

plant workers. Plant workers were observed to be following proper radiological work practices including the use of dosimetry and protective equipment. Personal briefings conducted prior to containment entries *"ere thorough and informativ S1 Conduct of Security and Safeguards Activities S1.1 Damaaed Cables in Afternate Health Physics Checkooint Trailer i Insoection Scone i The inspector reviewed the licensee's response to the identification of damaged cables a the health physics (HP) alternate check point trailer. Two separate issues were identified. The first was identified on March 3, and involved damaged fiber ;

optic cables associated with the outage connection to the LAN. The second item

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was identified on March 12, and involved damaged to cables for one of the four electronic dosimeter reader Observations and Findings The alternate HP check point trailer is not safety-related, and is only used during refueling outages as the main access to the radiation controlled area. Not all of the supporting components in the trailer are normally use .

The inspector performed field walk downs of the subject trailer and interviewed applicable personnel. The inspector found that security and operations personnel promptly and adequately evaluate the conditions for potential tampering as require Also prompt notifications to plant management and the NRC residents office were initiated. However, the inspector identified two minor weaknesses relating to the first incident including:

The technician who found the damaged fiber optic cables (at 1500 on March 3) did not promptly inform his supervisor or the control room as required. He waited until the next morning (about 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> later) to make the required notification e The affected area was not promptly secured to preserve evidence to support the investigatio The security department promptly initiated two adverse condition reports to address the concerns identified by the inspector. The inspector reviewed these documents !

and found that adequate corrective actions had been identified. Additionally, laboratory analysis of the damaged fiber optic cables confirmed that the first event ,

was not tampering, but was caused by rodent damage. The second event remains under revie l Conclusion Security and operations personnel properly evaluated two cases of identified damages to non-safety related cables in the alternate HP check point trailer for potential tampering. The inspector identified two minor weaknesses involving the timeliness to notify Ops and Security, and in securing the affected area to preserve evidence to support the investigation as required by procedure. The licensee took adequate corrective actions to address these concerns S1.2 Fitness for Dutv Test Failures The licensee responded properly to multiple pre-employment fitness for duty (FFD)

test failures during the period. Additionally, the licensee responded well after a contract laborer failed a random FFD tes 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 April 1. 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. Grillo, Technical Support Manager G. StPierre, Operations Manager B. Seymour, Security Manager M. Toole, I&C Manager R. White, Design Engineering Manager INSPECTION PROCEDURES USED i

IP 37551: Onsite Engineering j IP 61726: Surveillance Observation j IP 62707: Maintenance Observation l IP 71707: Plant Operations j iP 71750: Plant Support Activities '

ITEMS OPENED, CLOSED, AND DISCUSSED Opened: NCV 99-01-01, Failure to Properly Test Primary Auxiliary Building Fans NCV 99-01-02, Failure to implement Adequate Corrective Actions for Repeat Primary Auxiliary Building Fan Test Failures Closed: NCV 99-01-01, Failure to Properly Test Primary Auxiliary Building Fans NCV 99-01-02, Failure to implement Adequate Corrective Actions for Repeat Primary Auxiliary Building Fan Test Failures l

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. Attachment 1 (cont'd) 2 LIST OF ACRONYMS USED ACR Adverse Condition Report ASME American Society cf Mechanical Engineers ASTM American Society for Testing and Materials CAS Central Alarm Station CBS Containment Building Spray EDG Emergency Diesel Generator EFW Emergency Feedwater EML Environmental Measurements Laboratory EPA U.S. En'<ironmental Protection Agency FME Foreign Material Exclusion gpd gallons per day gpm gallons per minute -

LCO Limiting Condition for Operation )

MOV motor operated valve NSARC Nuclear Safety and Audit Review Committee QA Quality Assurance QC- Quality Control SORC Station Operations Review Committee SUFP Startup Feedwater Pump SW Service Water

.TDEF Turbine Driven Emergency Feedwater Pump TLD Thermoluminescent Dosimeter TS Technical Specifications UFSAR- 4 Updated Final Safety Analysis Report WR work request

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