IR 05000443/1999003
| ML20207B238 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/20/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207B226 | List: |
| References | |
| 50-443-99-03, 50-443-99-3, NUDOCS 9905280161 | |
| Download: ML20207B238 (39) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
DOCKET NO:
50-443 i
LICENSE NO.
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REPORT NO.
50-443/99-03
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l LICENSEE:
North Atlantic Energy Service Corporation J
FACILITY:
Seabrook Generating Station, Unit 1 i
LOCATION:
Post Office Box 300
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l Seabrook, New Hampshire 03874
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I DATES:
March 8 - 26,1999 in Region 1 Office March 27 - April 8,1999 I
INSPECTORS:
L. Prividy, Senior Reactor Engineer, DRS W. Reymond, Senior Reactor Engineer, DRS C. Welch, Reactor Engineer, DRS i
K. Young, Reactor Engineer, DRS APPROVED BY:
Lawrence T. Doerflein, Chief Engineering Programs Branch Division of Reactor Safety
99052801'61'990520
PDR ADOCK 05000443 G
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TABLE OF CONTENTS PAGE EX E C UTIVE S U M M ARY...................................................... iv
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M8 Miscellaneous Maintenance issues........................................ 1 M8.1 (Closed) Violation (VIO) 50-44 3/97-09-01............................ 1 M8.2 (Closed) Violation (VIO) 50-443/97-09-02............................. 1
M8.3 (Closed) Unresolved item (URI) 50-443/97-09-03...................... 2
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M8.4 (Closed) Inspector Follow Item (IFI) 50-443/97-07-02................... 2 j
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E nginee ring.......................................................... 3 E1 Cond uct of Engineering................................................ 3
E1.1 Primary Component Cooling Water System........................... 3 E1.1.1 System Design.................................................. 3 E1.1.2 Mechanical Review.......................................... 4
E1.1.3 Electrical Review............................................ 7 E1.1.4 Problem Identification and Resolution............................... 10 i
E1.2 Technical Resolution of Plant Problems........................... 11 E1.3 Plant M odifications.............................................. 15 E1.4 Engineering Workload......................................... 18 E1.5 Generic Letter 96-01............................................ 1 9 E1.6 Walkdown Observations........................................ 20 E8 Miscellaneous Engineering issues....................................... 21 E8.1 LER 50-44 3/98-1 1.............................................. 21 IV.
Plant Support....................................................... 22 F1 Control of Fire Protection Activities...................................... 22 F1.1 Fire Risk Evolutions...........................................
F2 Status of Fire Protection Facilities and Equipment........................... 23 F2.1 Fa cility To u r..................................................~ 2 3 F2.2 ' Fire Barrier Penetration Seals.................................... 24 F2.3 Fire Main Loop Flow Testing..................................... 25 F2.4 Fire Pum p Testing.............................................. 26 F3 Fire Protection Procedures and Documentation............................. 26 F3.1 Fire Protection Procedure Review................................. 26 F4 Fire Protection Staff Knowledge and Performance................... 27 F4.1 Fire Brigade Drills.............................................. 27 F5 Fire Protection Staff Training and Qualification.............................. 28 il
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TABLE OF CONTENTS (CONT'D)
PAGE F5.1 Fire Brigade Training.................................................. 28 F7 Quality Assurance in Fire Protection Activities.............................. 29 F7.1 Audits and Surveillances......................................... 29 V.
M anagement Meetings............................................... 30 X1 Exit Meeting Summary............................................... 30
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EXECUTIVE SUMMARY Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/09-03 During the weeks of March 8 and March 22,1999, a team of inspectors conducted an onsite inspection of the licensee's engineering activities which included an in-depth review of the primary component cooling water (PCCW) system. The team also reviewed the adequacy of the fire protection program and several open items regarding measuring and test equipment.
Enaineerina:
The lack of a plan to resolve the PCCW system flow balance issue in the long term
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detracted from the otherwise good engineering support noted regarding the flow model development. (Section E1.1)
i Auxiliary supply fan surveillance procedures, PAH-OS001 and PAH-OS002, were not comprehensive in that they did not verify the position of tornado damper, PAH-DP-356.
J The procedures were being revised to correct this weakness. (Section E1.1)
The PCCW temperature control valves were found to have an adequate backup nitrogen
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supply capable of fulfilling the system design requirements. (Section E1.1)
The licensee's corrective actions in response to PCCW system check valve testing
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problems as identified in LER 98-013 were found to be acceptable. (Section E1.1)
The team concluded that the PCCW system was installed consistent with the design
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requirements as described in the UFSAR and the design basis document. (Section E1.1)
The licensee failed to periodically calibrate the PCCW pump high temperature trip
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circuits. Appropriate actions were taken to calibrate this instrumentation, including
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an extensive extent-of-condition evaluation to ensure that no generic implications existed with other equipment designated with special-as-requested maintenance frequencies. Therefore, this Severity Level IV violation of test requirements was being treated as a Non-Cited Violation, consistent with Appendix C of the MB,Q
Enforcement Poliev. (NCV 50-443/99-03-01) (Section E1,1)
Some PCCW equipment deficiencies had not being entered into the licensee's corrective
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action program. ' An administrative procedure was being developed to provide improved guidance to system engineers to correct this problem. (Section E1.1)
Engineering supported plant operations with evaluations to address adverse conditions.
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The evaluations were sound, generally thorough and well documented. Evaluations were not always timely relative to when the issue was originally identified, but were appropriate relative to the safety significance of the issues addressed. (Section E1.2)
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Past reviews of EDG equipment to support the Preventive Maintenance Optimization
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program were not always thorough, and there were missed opportunities to address degraded performance of EDG air start valves. (Section E1.2)
Good monitoring of the emergency feedwater piping temperatures has adequately
assured system operability for several years while engineering has been unsuccessful in achieving a long term resolution of check valve backleakage problems. The licensee plans to implement a design modification to correct this longstanding and high priority operationalimpact issue. (Section E1.2)
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l Engineering support for all modifications reviewed was good. Technical evaluations, j
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installation instructions, post-modification test plans, and the 10 CFR 50.59 screening
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and safety evaluations were thorough and well supported. (Section E1.3)
The timeliness in completing initiatives and achieving resolution of long standing
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problems concerning the emergency diesel generator (EDG) skid and service water vacuum breaker modifications detracted from the otherwise good quality of the i
engineering support. (Section E1.3)
Several initiatives in 1998 (12-week work schedule, focus on operational impact issues,
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engineering fix-it-now group) were successfulin reducing engineering workloads to achieve realistic goals. (Section E1.4)
The risk ranking effort of engineering work requests and the decision to retain, train and
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improve on this effort were noteworthy. (Section E1.4)
Engineering support was good to complete the reviews required by Generic Letter 96-01.
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Technical reviews were thorough, design basis documentation was complete and of good quality, and test discrepancies were properly resolved. (Section E1.5)
Engineering support was good in monitoring the status of EDGs and potential
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deficiencies, and appropriately prioritizing corrective actions to resolve them. (Section E1.6)
A weakness was noted regarding the lack of refresher training for system engineers.
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(Section E1.6)
Plant Suocort:
Fire protection equipment conditions and housekeeping were good. Roving fire
watches were knowledgeable of station procedures for reporting firec, fire watch duties, and responding to fires. Eight hour emergency light operation and illumination patterns were good. (Section F2.1)
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Sampled fire barrier penetration seals were in good condition and the installed
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l configuration of these seals was comparable to that described in Brand Industrial Services, Inc., Construction Group fire test report Nos. 748-134 and 748-170. (Section F2.2)
The fire main loop was in good r3 pair, and capable of providing the necessary water
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i supply for fire fighting needs at the facility. The fire pumps were well-maintained and ready for service. (Sections F2.3 and F2.4)
Fire protection procedures met the requirements for fire protection program
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implementation, contained sufficient detail, and were technically sound. (Section F3.1)
Performance by the fire brigade team during a fire drill was very good. All
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expectations of the fire drill were met. Based on discussions with the local fire department, coordination activities to ensure proper understanding of fire fighting strategies at the site were good. (Section F4.1)
Fire brigade members were current on all required training and annual physical
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examinations. (Section FS.1)
The fire protection quality assurance audits appropriately reviewed fire protection
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program attributes and compliance with program requirements. The fire protection audit findings were appropriately addressed and timely corrective actions were taken for identified deficiencies. (Section F7.1)
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Report Details ll. Maintenance M8 Miscellaneous Maintenance lasues M8.1 (Closed) Violation NIO) 50-443/97-09-01: Failure to perform a 10 CFR 50.59 evaluation.
During a previous inspection, the NRC found that the licensee had changed procedure MA2.3, " Control and Calibration of Measuring a, :1 Test Equipment," Revision 15, and failed to perform a written safety evaluation to determine that no unreviewed safety questions existed. This failure was inconsistent with the requirements of 10 CFR 50.59.
The team reviewed the corrective actions described in the licensee's response letter, dated March 23,1998, and found them to be reasonable. The licensee determined that the personnel involved in developing and reviewing the change to procedure MA2.3 did not recognize that they had changed a procedure as described in the Updated Final Safety Evaluation Report (UFSAR), and as a result, did not perform a safety evaluation.
The licensee took corrective actions to counsel the involved individuals on the safety review process. The licensee subsequently performed a safety evaluation for MA2.3, Revision 15, and found that the changes to the procedure did not create an unreviewed safety question. The licensee also submitted an UFSAR change request to revise section 17.2.12 to clarify the guidance in accounting for calibration ratios which fall below the 4:1 ratio. Additionally, the licensee implemented an annual requalification program i
for personnel performing 10 CFR 50.59 evaluations. The team reviewed the safety evaluation for procedure MA2.3 and verified the change request for the UFSAR revision was in place. The team found the licensee's corrective actions appropriate and
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acceptable.
The team concluded that acceptable corrective actions had been implemented by the i
licensee. The team also concluded that the licensee performed an acceptable safety e' valuation to determine that no unreviewed safety questions existed.
M8.2 (Closed) Violation NIO) 50-443/97-09-02: Measuring and Test Equipment (M&TE) was not properly controlled. During a previous inspection, the NRC found the licensee's controls allowed revisions to M&TE without formal review which was not consistent with the requirements of 10 CFR 50, Appendix B, Criterion XII, " Control of Measurement and i
Test Equipment." Such practices also were inconsistent with UFSAR Section 17.2.12.3,
" Calibration," which stated, "Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and
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The team reviewed the corrective actions described in the licensee's response letter, dated March 23,1998, and found them to be reasonable. The licensee determined that the personnel involved in the preparation and review of procedure MA2.3, Revision 15, did not adequately review the UFSAR and incorporate the UFSAR requirements into the procedure. The licensee took corrective actions to counsel the involved individuals on the safety review process. The licensee subsequently revised procedure MA2.3, Revision 15, to provide formal procedure requirements for evaluating changes to M&TE accuracy. The team reviewed procedure MA2.3, Revision 15, Change 1, and verified
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that it had been revised to formalize the review process used to evaluate changes to M&TE accuracy. The team also reviewed the M&TE used to calibrate the primary component cooling water system loop A and loop B supply header temperature control instrumentation (See report section Ill.E1.1.3). The team verified that the measuring devices used in this calibtation process met the accuracy requirement in UFSAR Section 17.2.12.3 of at least four-times the accuracy of the equipment being calibrated. The team found the licensee's corrective actions acceptable.
The team concluded that acceptable corrective actions had been implemented by the licensee. The team also concluded that the licensee performed an acceptable evaluation to determine what controls should be implemented to assure formal review of revisions to M&TE.
M8.3 (Closed) Unresolved Item (URI) 50-443/97-09-03: Assessment of instruments to determine safety significance. During a previous inspection the NRC found that the licensee had not completed an overall review of the impact of revised M&TE accuracies on plant safety. The NRC reviewed documents relating to the completion of this activity.
The team found that the licensee had completed a detailed review to determine the impact of revised M&TE accuracies on plant safety. The licensee reviewed all safety-related instrumentation and determined that no instrumentation was affected by revised M&TE accuracies. The team reviewed samples of instruments reviewed by the licensee
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and determined that no safety concerns existed. Through discussion with licensee
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personnel, the team determined that review of allidentified safety significant instruments was completed in an acceptable manner.
The team concluded that the licensee performed an acceptable review of the impact of revised M&TE accuracies on plant safety. No violations of regulatory requirements were identified during review of this issue.
M8.4 (Closed) Insoector Follow item (IFI) 50-443/97-07-02: Update Measuring and Test Equipment specification sheets. During a previous inspection, the NRC found that the licensee had not completed a review and update of M&TE at the site. The team found that the licensee had reviewed and updated M&TE specification sheets to reflect accuracy changes or calibration restrictions of the M&TE equipment under the corrective actions program. The team reviewed samples of completed specification sheets and held discussions with licensee personnel to determine completion of this effort. The team found that the licensee had completed review and update of approximately 1800
M&TE specification sheets with plans in place for future equipment updates as necessary. The team concluded that the licensee's approach of reviewing and updating M&TE equipment was reasonable, completed, and acceptabl *
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Ill. Enaineerina E1 Conduct of Engineering inspection Oblectives and Methods The first inspection objective was to assess engineering performance by evaluating the design of the primary component coolant water (PCCW) system. The team reviewed calculations and engineering documents used to support system performance during normal and accident conditions. As a second objective, the team reviewed other engineering activities, such as the development of plant modifications, the technical resolution of several recent plant problems, and the engineering work backlog.
The inspection consisted of mechanical and electrical reviews of the PCCW system as described in various sections of the Seabrook Updated Final Safety Analysis Report
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E1.1 Primary Component Coolina Water System
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E1.1.1 System Desion The PCCW system provides cooling to safeguard components required for safe shutdown. It also provides cooling for the reactor coolant pumps and an array of nonessential components. The system is highly risk significant in that the Seabrook Station Probabilistic Safety Assessment shows the reactor coolant pump seal loss-of-
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coolant-accident to be the dominant contributor (about 70%) to core melt frequency. The heat removed from the various cooled components is dissipated to the Atlantic ocean (normal) or cooling tower (backup) via the PCCW heat exchanger (s) and service water system.
Two independent and redundant flow loops are provided to assure accomplishment of the system's safety function while accommodating a single failure of any component coincident with the loss of offsite power. Two 100% pumps are provided in each flow loop. For normal plant operation, both loops are required. A separate flow loop, which is supplied cooling from both PCCW loops, provides cooling for the reactor coolant pump thennal barrier (RCPTB) heat exchangers.
Automatic isolation of the non-safety class portion (s) of the system is provided to assure that the system remains capable of performing its safety function. In the event of a loss of system integrity, as determined by PCCW expansion tank level, the non-safety grade sections of the system are isolated. A low expansion tank level initiates isolation of the areas outside containment and a low-low expansion tank level initiates isolation of the j
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non-safety class portions of the system inside containment, excluding the RCPTB
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cooling loop which requires manualisolation. An automatic trip of the operating pump (s),
based on a high PCCW heat exchanger outlet temperature (135*F), is provided to protect system piping and supports from excessive thermally induced stresses should a loss of service water cooling or malfunction in the system temperature control circuitry occur.
E1.1.2 Mechanical Review a.
Inspection Scooe UP 93809 and 37550)
The team reviewed calculations, engineering and work control documents, and test procedures associated with the various equipment included in the PCCW system. This review encompassed system flow balance activities and included equipment in supporting systems, such as emergency ventilation for the auxiliary building pump area and the temperature control valves' nitrogen accumulators.
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Observations and Findinas PCCW System Flow Balance Design calculation C-S-1-83704, " Hydraulic Modeling of the PCCW Flow Distribution,"
was developed to predict the flow distribution in each PCCW loop. The original models were partially benchmarked against the pre-operational flow balance tests. The licensee did not attempt to totally benchmark the hydraulic models since only limited test data was available. Flow deficiencies found in the original models were not attributed to system problems but to conservatisms and uncertainties in the hydraulic modeling and equipment data as well as small margins provided in system balancing.
The flow models were updated in Revisions 1 and 2 of Calculation C-S-83704 to account for ASME Section XI IST instrument uncertainties, a 10% pump degradation, and replacement of the PCCW heat exchangers. Recommended throttle valve settings were provided for each loop. Flow to all safety-related components in both loops was predicted to satisfy the design flow requirements per UFSAR Table 9.2-6. During post modification test ES 97-1-9, "PCCW "A" Train Flow Rebalancing," all A train safety-related component flow rates were verified for the post-LOCA recirculation lineup to be greater than the design flow rates specified in Table 9.2-6.
The team observed that the licensee's assumptions used in the flow model calculations were appropriate. The completion of Revisions 1 and 2 of Calculation C-S-1-83704 provided improved flow predictions to reflect the new system configuration with conse,rvative pump performance and instrument accuracy values. Notwithstanding these ooservations, the team noted a number of system problems that indicated the need to perform a new system flow balance. Several problems had been identified for some time without a long term resolution in place, such as unexpected system and component low
' flow alarms. Lay-up of components in the waste process building was another factor indicating the need for a'new flow balanc T
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Pumo Area Ventilation The team reviewed the design, maintenance, and testing aspects of the emergency ventilation system which is provided to support the proper operation of the PCCW system, primarily in the pump area of the the primary auxiliary building (PAB).
Ventilation is normally supplied for PCCW equipment by the main PAB ventilation system. However, if the PAB fans are not available, auxiliary supply fans, PAH-42A&B, which are powered from separate emergency buses and controlled by thermostats in the pump area, are provided.
During walkdowns and discussions with the ventilation system engineeer. the team determined that the auxiliary supply fan surveillance procedures, PAH-OS001 and PAH-OS002, did not include verification of the position of the associated torrado damper, PAH-DP-356, located in the supply air plenum common to both fans. !f this damper were closed during the surveillance, air flow would not be established sinca air flow verification was not a current requirement in the surveillance procedures. The licensee issued ACR 99-0803 to address this concern. Corrective actions were established to revise the above surveillance procedures and review other ventilation systems associated with
- safety related equipment, such as emergency feedwater and service water, for generic implications. The team considered that these actions were appropriate.
Backuo Nitrocen Supolv for Temperature Control Valves The PCCW heat exchanger outlet and bypass valves are provided for temperature
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control. These valves are normally positioned by instrument air, and backup nitrogen supplies are provided in case of a loss of the instrument air supply.
The design basis for the backup nitrogen supplies, as documented in the Updated Final Safety Analysis Report (UFSAR), requires that the system contain sufficient volume to
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fully cycle each temperature control valve ten times for up to six hours following the loss of instrument air. Design calculation 9763-5-SP-00-4F provided the bases for the i
original design of four nitrogen bottles per valve pair. However, pre-operational test procedure 1-PT-47, " Backup Gas Supply Verification Test," identified that the design was inadequate due to greater nitrogen consumption than predicted. Four additional bottles were added to each valve group per Engineering Change Authorization (ECA)-
98118030. Testing per PT-47 demonstrated the new design was more than adcquate to meet the system design requirements.
The licensee had issued ACR 97-2194 to evaluate the need to perform periodic leakage testing of the backup air supply systems for various safety related valves. The team noted that the corrective actions for this ACR failed to address the backup systems for the PCCW temperature control valves. ACR 99-0822 was issued to address this error and provide corrective action by performing a periodic leak test based on maintenance activities.- The team concluded that these actions were adequate.
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Inservice Testina Proaram Licensee Event Report (LER)98-013 reported the omission of thirty-three valves from the scope of the Inseivice Testing (IST) Program. Eight valves (four per loop) were from the PCCW system. The inspector reviewed the piping and instrumentation drawings (P&lDs) for the "A" PCCW loop and did not identify any additional "A" loop components which should have been included in the IST program.
Four of the omitted valves (CC-V944,V945,V946,& V947) comprise two sets of series check valves located in each loop's radiation monitor (RM) retum line. The check valves are normally open and have a safety function to close to isolate the non-safety class piping (RM side) in the event that the piping fails. Only one check valve in each pair is credited in the safety analysis.
J Full closure testing of the individual check valves, as required by Section XI of the 1983
ASME code, is not possible due to system configuration. Therefore, relief request RR-1 was instituted by the licensee to partially disassemble, examine, and manually exercise the check valves on a staggered sampling basis each refueling outage. The relief request was not submitted to the NRC for approval based on guidance provided in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," and NUREG 1482, " Guidance for Inservice Testing at Nuclear Power Plants."
The NRC Chace of General Counsel (OGC) has determined that generic relief afforded by Position 2 of GL 89-04, as stated in NUREG 1482 is not entirely correct, and that a relief request is still required for disassembly and inspection on a sampling basis. This determination will be discussed when the NUREG is updated.
As licensees have updated their IST programs, this item has typically been covered in a refueling outage justification. On a case-by-case basis, the NRC has simply approved the practice in these cases as an altemative under 10 CFR 50.55a (f)(4)(iv). The NRC i
has not been requiring licensees to change their programs or submit relief requests ahead of their next scheduled IST program updates. Therefore, it will be acceptable to document the disassembly and inspection on a sampling basis of the PCCW RM check valves in : re!!cf renuest to be submitted with the new 10 Year interval program in 2000.
(Relief request should also uc provided for similar situations in other systems.)
The team also noted that seat leakage testing of isolation valves CC-V-426/427/447/448, which isolate the non-safety class section of the system, is currently not required. The licensee addressed this concem in ACR 99-0550, which had been issued after reviewing NRC IN 98-25, " Loss of Inventory from Safety Related Closed-Loop Cooling Water Systems," for applicability to Seabrook Station. The licensee's corrective action is to perform periodic surveillance leakage rate testing of the isolation valves. The surveillance procedure is scheduled for completion in June 1999. Assurance exists that the isolation valves currently provide adequate isolation based on satisfactory leakage rate testing of similar valves in the syste.,
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Conclusion The lack of a plan to resolve the flow balance issue in the long term detracted from the otherwise good engineering support noted regarding the PCCW flow model development. Auxiliary supply fan surveillance procedures, PAH-OS001 and PAH-OS002, were not comprehensive in that they did not verify the position of tomado damper, PAH-DP-356. The procedures were being revised to correct this weakness.
The PCCW temperature control valves were found to have an adequate backup nitrogen supply capable of fulfilling the system design requirements. The licensee's corrective actions in response to check valve testing problems as identified in LER 98-013 were found to be acceptable.
E1.1.3 Electrical Review a.
Inspection Scope (IP 93809)
i The team reviewed the PCCW system electrical instrumentation and controls (l&C)
included in the design basis documentation (DBD), design drawings, calculations, analyses, and other engineering documents that are used to support system performance during normal and accident conditions.
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Observations and Findinas Desian Basis Documentation Review The team found that the DBD described the electrical and ISC design of the PCCW system and other supporting and interfacing equipment. The team also found that bistables, sensors, relays, wiring, and controls needed to operate the system were consistent with the Updated Final Safety Analysis Report (UFSAR) requirements. The team verified that the motor driven PCCW pumps were appropriately powered from the safety-related 4160 volt buses (E5 and E6) and were provided backup power by the Emergency Diesel Generators (EDGs). The power supply requirements for the control devices of the PCCW system and its supporting equipment were adequately designed and powered from the applicable power supplies required to support system operation during normal and accident operation.
During plant walkdowns the team verified that the manual controls for the PCCW system j
pumps, control valves, and associated instrumentation were appropriately provided in the main control room, at the remote safe shutdown (RSS) panel or locally to support the proper operation of the system on demand. The team found no deficiencies between the
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DBD and the plant installed equipmen _
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Calculation Review The team reviewed the following design calculations:
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9763-3-ED-00-83-F, Revision 5, " Emergency Diesel Generator (EDG) Loading Calculation" (2)
9763-3-ED-00-66-F, Revision 3, " Control Circuit Voltage Drop Calculation" (3)
9763-3-ED-00-14F, Revision 9, "125 V de System Battery, Charger, Motor Feeder Calculation" (4)
9763-3-ED-00-03F, Revision 6, " Power Cable Application Criteria and Sizing" (5)
9763-3-ED-00-23F, Revision 4, " Medium Volt. Prot. Relay Co-ord. & Misc. Relay Settings" The team found that the EDG loading calculation included the maximum brake horse
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power rating for the motor driven PCCW pumps. In addition to this conservatism, the licensee had included the starting loads of all applicable process related motor-operated valves (MOVs)in the starting sequence of the EDG loading. The review of the worst-case voltage dip during the starting load sequences indicated an approximate 14% dip of rated bus voltage which was within the 20% voltage dip requirement limit shown in the UFSAR (Sections 8.3.1.1.e.5 and 8.3.1.2.b.2). The team concluded that this calculation was acceptable.
The team reviewed the de system calculations associated with the PCCW system components and found that the licensee had appropriately assumed the minimum battery system voltage of 105 V de in the calculations and applied appropriate field cable voltage losses in evaluating voltage drops. The inspectors concluded that the de system components and control circuits had sufficient voltage and were appropriately powered from the respective de buses to perform the intended design function.
The team reviewed the power cable application criteria and sizing calculation and the medium voltage protective relay coordination calculation associated with the PCCW pumps. The team found the licensee appropriately used PCCW pump ratings of 700 HP, full load current, and derating factors to determine cable size of conductors supplying electric power to the pumps. The licensee also appropriately used these attributes to determine protective relay trip settings for the PCCW pumps. The team found no discrepancies in these calculations and concluded that the licensee had appropriately determined the protective relay trip settings for the pumps and sized the conductors i
supplying electric power.
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= Instrument Calibration and Setooint Data The team reviewed the calibration data and calculations associated with a number of PCCW instrument setpoints. The review included the head tank level and system temperature alarms and controls plus the low pressure and low flow alarms. With one exception, no discrepancies were identified between the reviewed documents and the setpoints included in the design basis documents. The team identified one deficiency during the review of the calibration data for the PCCW pump high temperature trip
circuits.
The PCCW outlet header temperature is monitored by dual sensors TE-2171 and 2197 for Loop A and TE-2271 and 2297 for Loop B. To protect the system piping and pumps during postulated high temperature conditions, this instrumentation will trip the running
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pump if the temperature exceeds 135'F as sensed by both detectors and the high temperature persists for 60 seconds. Based on the team's questions regarding the last
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calibration of the PCCW pump high temperature trip circuitry, the licensee recognized that this circuitry had not been calibrated since 1991. Specifically, the original calibration frequency for the pump high temperature trip circuit was changed in 1993 from 96 weeks to special-as-requested (SPAR) and no special request had been made to calibrate this instrumentation. The failure to calibrate this circuitry since 1991 is a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control," which requires licensees to test systems and components to assure that they will perform satisfactorily in service.
While the team was onsite, the licensee recalibrated the pump high temperature trip instrumentation and changed the calibration frequency of these instruments from SPAR to 96 weeks. Additionally, ACR 99-0857 was issued to evaluate the basis for changing the calibration frequency of these components from 96 weeks to SPAR. During the recalibration efforts the "As Found" data for the A loop circuit indicated an out-of-tolerance reading of 8*F high for one temperature input and the B loop circuit indicated an out-of-tolerance reading of 1.5*F high, also for one temperature input. The remaining temperature input circuits were within their tolerances and would have provided a valid i
pump trip signal. l&C personnel corrected the out-of-tolerance conditions. The licensee identified these out-of-tolerance conditions and reviewed them for operability in ACR 99-1020. The licensee determined that the pump high temperature trip remained operable i
because the device requires both temperature input circuits to be satisfied to initiate a pump trip The remaining temperature input circuits were found to be in the acceptable
ranges and would have provided a valid pump high temperature trip signal. The inspectors found this review acceptable.
The team held several telephone conversations with the licensee following the March 26,1999 onsite exit meeting to better understand the evaluations and corrective i
actions that had been implemented for dispositioning the pump high temperature trip circuit calibration issue. The final telephone conversation occurred on April 8,1999. In responding to ACR 99-0857, the team found that the licensee promptly performed an extensive extent of condition evaluation to determine if other equipment in the SPAR category at the plant was affected. The licensee determined that the PCCW pump high temperature trip calibration issue was an isolated case. The team agreed with this i
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. assessment. The team concluded that the licensee had performed appropriate evaluations and corrective actions were in place to resolve this issue on a long term basis. Therefore, this Severity Level IV violatic.11s being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as ACR 99-0857 and 99-1020. (Non-Cited Violation (NCV) 50-443/99-03-01)
During the above review the team noted a discrepancy in the DBD in that it referred incorretly to the PCCW pump high temperature trip setpoint as 140*F. The licensee issued ACR 99-0815 to correct this value to 135'F when the DBD is next revised.
Surveillance Testa
The team reviewed the results of recent surveillance tests (OX1412.11, Revision 4 and OX1412.01, Revision 8, Change 1), associated with the PCCW valve and pump 18 month operability testing. The surveillance test data indicated that (1) the reviewed system components functioned properly; (2) the acceptance criteria were well defined; and (3) the licensee had adequately demonstrated the functionality of the system and other supporting equipment. The team concluded that the PCCW system was installed and being operated in a manner consistent with the design bases.
c.
Conclusions '
The team concluded that the PCCW system was installed and operated consistent with the design requirements as described in the UFSAR and the DBD. The licensee failed to periodically calibrate the pump high temperature trip circuits. Appropriate actions were taken to calibrate this instrumentation, including an extensive extent of condition
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evaluation to ensure that no generic implications existed with other equipment designated with SPAR maintenance frequencies. Therefore, this Severity Level IV violation of test requirements was being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Poliev. (NCV 50-443/99-03-01)
E1.1.4 Problem Identification and Resolution a.
Insoection Scope (IP 37550)
The team reviewed the outstanding items in the work control system to determine how the licensee was using its corrective action process for identification, trending, and correction of deficiencies in the PCCW system.
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b.
Observations and Findinas The team concluded that ACRs had not been issued but should have been issued for a number of deficiencies, such as solenoid valve and regulator diaphragm failures. In addition, the team noted that a number of ACRs were identified during this inspection.
99-0815 This ACR was issued to resolve a discrepancy of the setpoint value for the PCCW pump high temperature trip included in the design basis document.
99-0857 This ACR was issued to determine the technical basis for the frequency change for the calibration of the PCCW pump high temperature trip device.
99-0816 This ACR was needed to correct the FSAR regarding locked open breakers for the RCPTB MOVs.
The Technical Support Manager acknowledged the need for clear expectations so that the system engineers would consistently apply the correct threshold for issuing ACRs. A Technical Support Department instruction was being developed to provide guidance for these expectations.
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Conclusions Some PCCW equipment deficiencies had not being entered into the licensee's corrective action program. An administrative procedure was being developed to provide improved guidance to system engineers and correct this problem.
E.1.2 Technical Resolution of Plant Problems a.
Inspection Scope (IP 37550)
The team reviewed the list of 146 ACRs that required evaluation by engineering in 1998.
ACRs96-169,96-1067,97-097 and 97-366 were associated with the EDGs and concerned actual or potential deficiencies. The actions taken by engineering to disposition these ACRs were reviewed. The team also reviewed the licensee's actions to resolve emergency feedwater (EFW) system backleakage concems.
b.
Observations and Findinas ACR 97-0366. Potential EDG Buildina Leak Path This item involved concems with the EDG building floor drain system (ACR 96-544),
which were expanded during a fire protection evaluation (ACR 97-366). The issue involved a postulated failure of the day tank in conjunction with an actuation of the fire water system and could result in the discharge of water and fuel oil into the storm drain system. Engineering responded to ACR 97-366 on September 8,1998, to provide an i
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evaluation of the building floor system design, and make recommendations for a plant modification that would preclude the postulated event. Engineering proposed a design change to extend the fuel building sump vent line from the 23 ft elevation to the 52 ft elevation, and thereby preclude an inadvertent discharge of fuel oil. The EWR was scheduled to be completed by October 31,1998. The ACR action was still open as of March 24,1999.
ACR 96-169. Temperature Switch Calibration This ACR concerned the discovery in 1996 of an adverse trend in the calibration data for F
the temperature switch 1-DG-TSH-9529A. The device monitors the temperature on the outlet of the DG-1A Air compressor, and provides an alarm when discharge temperature reaches 490 degrees F. In response to a high temperature alarm, the operator is directed by the alarm response procedure to remove the air compressor from service, which would render the diesel inoperable. ACR 96-169 was written in recognition that the as-found switch setting was found out-of-tolerance (as high as 9 degrees, as low as 5 degrees) during periodic calibrations since 1986.
Engineering provided an apparent cause evaluation in April 1998. The faulty temperature switch was replaced on April 24,1998 and no subsequent calibration problems were noted. The apparent cause for the poor calibration history was a faulty switch. No similar problems were noted for DG-1B. A backup air compressor was installed in April 1998 (DCR 94-44), which assures an adequate supply of starting air with the main compressor unavailable.
The evaluation highlighted a failure by the Preventive Maintenance Optimization (PMO)
program to identify the consistent out-of-tolerance in the switch test data. The PMO evaluation completed on January 31,1996 did not adequately evaluate the test data, and failed to note two other calibration failures. The frequency of the repetitive task sheet (RTS) was extended from 96 weeks to 240 weeks without an adequate technical basis.
A basis for the extended calibration frequency was provided in the 1998 engineering evaluation for ACR 96-169. The licensee initiated a review during this period to assure the calibration intervals of other items in the PM program were appropriate.
The engineering review for ACR 96-169 was well documented, indicating the evaluation was thorough, comprehensive and well researched. Conclusions regarding the operability impact on the air compressor and DG-1 A were sound and well justified. The engineering evaluation provided a good self-assessment regarding the failure to adequately address the repetitive out-of-tolerance data when lengthening the calibration period, and in the failure to provide a timely response to the original ACR in 1996. The untimely response was attributed to the recognition that the switch problem was not significant, and due to the increased workload resulting from the ACR process.
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ACR 96-1067. Enoine Oil Leakaoe An engineering evaluation was written to support ACR 96-1067, and addressed the impact of oil dripping on DG barring devices. The engineering review was well documented to address DG operability, the potential impact on limit switches, and to provide appropriate recommendations to address the problem.
ACR 99-097. Repetitive Air Start Solenoid Valve Failures Each emergency diesel generator (EDG) has a subsystem that provides starting air through redundant headers and air start motors, each capable of starting the engine in 10 seconds. A solenoid valve (SOV) in each header operates to actuate the air start motors. The licensee tests the SOVs per procedure IX1605.310, which requires that the valves operate in less than 0.5 seconds. Both valves on EDG-1B (DGB-FY-AS1 and DGB-FY-AS2) and one valve on EDG-1 A (DGA-FY-AS1) have performed acceptably.
Since 1989, DGA-FY-AS2 was replaced four times due to slow opening times during testing. The repair sequence was as follows:
89WOOOO982 - abnormal time (0.31 seconds on March 3,1989); SOV S/N H84 was replaced with SOV S/N L99, and sent to the vendor for refurbishment.
93 WOO 1664 - abnormal time (0.2 seconds on June 3,1993); SOV S/N L99 was replaced with new SOV S/N L98 on August 25,1993. There was no further followup.
96 WOO 1753 - abnormal time (0.2 seconds) noted on September 6,1996); SOV S/N L98 was replaced with SOV S/N H84 on June 12,1997. No cause for the L98 problems were noted. Additional reviews focused on causes external to the valve, such as air quality and piping configuration. SOV H84 was obtained from stores and tested. An abnormal response was noted on the first stroke, which improved after subsequent cycling. H84 was installed. Although l&C initiated a request on June 12, 1997, to send SOV L99 offsite for analysis and refurbishment, the SOV was not sent offsite until September 18,1998, due to several delays in processing the request.
97 WOO 3358 - abnormal time was noted on November 13,1997, and the SOV failed the inservice testing program required action limit of 0.5 seconds when retested on December 3,1998; SOV H84 was rebuilt, tested satisfactorily and left in service due i
to the lack of replacement valves in stores, l&C noted that the SOV H84 internals were sucky. ACR 98-3406 was written to document the degraded SOVs noted in November 1997, and the lack of spares in December 1998.
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The SOVs otherwise tested satisfactorily during the quarterly tests since 1989, and the diesel started within 10 seconds during the monthly tests. During additional testing of SOVs S/N L99 and L98 on February 8,1999, SOV L98 opened in 0.625 seconds. Both valves were inspected internally, which showed that a gummy substance affected poppet motion. A vendor laboratory was contracted to analyze the substance. The licensee believes that the lubricant used by the vendor during SOV assembly becomes sticky when the valves are idle. An evaluation per 10 CFR Part 21 will be performed upon completion of the SOV failure analysis.
Procedure IX1605.310 was revised (Change #7 dated February 10,1999) to provide further guidance on monitoring response time, and to place the valves in an alert status when the time response exceeds 0.25 seconds. ACR 99-0097 was issued to address performance issues, and establish why the 1996 failures were not fully investigated. The system engineer plotted SOV test results since 1990, which showed an adverse trend starting in November 1997; the trend was not detected because the SOV results were not included in the trend programs maintained by l&C and system engineering.
In summary, there were missed opportunities to note an adverse trend in the time response for SOV DGA-FY-AS2 prior to its failure. There was a missed opportunity to complete a more timely investigation of degraded performance after the 1996 failure.
There does not appear to have been a program requirement to trend SOV response times. The actions in progress since January 1999 appear appropriate to investigate the cause for the past failures, evaluate generic applicability of the problem, evaluate SOV performance, and to complete self-assessments of performance issues.
Emeroency Feedwater System Backleakaae The emergency feedwater (EFW) stop check valves (FW-V76/82/88/94) and wet lay-up recirculation valves (FW-V152/153/154/155) isolate the normally depressurized EFW piping from the main feed headers. Evidence of backleakage of high temperature feedwater through several valves has been classified as a high priority vperational impact issue at Seabrook station. The intrusion of hot feedwater into the EFW piping presents a significant safety concern due to the potential to vapor bind the EFW pumps and prevent performance of their safety function. Further, steam voiding could subject the piping to significant unanalyzed stress as a result of potential water hammer events.
In inspection report (IR) 97-07, the NRC concluded that the licensee was adequately monitoring the EFW piping temperatures to assure system operability. Subsequently, the licensee inspected and repaired stop check valves FW-V82 and FW-V88, and the four wet lay-up recirculation valves. However, FW-V82 seat leakage has continued.
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The licensee intends to cut and cap the wet lay-up recirculation lines per DCR 96-028 and to replace the EFW pump discharge check valves (FW-V64 and FW-V70) per minor modification 98-682. Replacement of FW-V64 and FW-V70 with a tilted " soft-seat" swing check valve, designed for leak tightness, should eliminate the minor backflow of j
high temperature feedwater through the EFW stop check valves by isolating the flow path to the condensate storage tank.
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Conclusions Engineering supported plant operations with engineering evaluations to address adverse conditions. The evaluations were sound, generally thorough and well documented.
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Evaluations were not always timely relative to when the issue was originally identified,
but were appropriate relative to the safety significance of the issues addressed. Past reviews of EDG equipment to support the Preventive Maintenance Optimization program were not always thorough, and there were missed opportunities to address degraded performance of EDG air start valves.
Good monitoring of the EFW piping temperatures has adequately assured system operability for several years while engineering has been unsuccessful in achieving a long term resolution of check valve backleakage problems. The licensee plans to implement a design modification to correct this longstanding and high priority operational impact issue.
E1.3 Plant Modifications a.
Inspection Scope (IP 37550 and 37001)
The team reviewed three modifications involving the EDG and auxiliaries and two modifications concerning the service water vacuum breakers and the feedwater isolation valve accumulator. The review included items such as safety evaluations, design inputs, calculations and design change notices (DCNs).
b.
Observations and Findinos DCR 98-016. Emeroency Diesel Generator"Not Operational" Alarm Enhancements
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The supervisory alarm "DG NOT OPERATIONAL" was provided to monitor the
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operational capability of the emergency diesel generators (EDGs). To improve the j
monitoring of cold temperatures that could lengthen the engine start time, DCR 98-016 J
was prepared to add the jacket cooling and engine lube oil system temperatures as inputs to the supervisory alarm circuit during OR06. The DCR will also reduce the alarm
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setpoint on starting air pressure to 310 psig, and include loss of control power redundancy in the alarm circui *
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The licensee evaluated the change relative to the failure mode and effects analysis described in UFSAR Table 8.3-3, and concluded that there was no impact on the availability for the emergency power system. The technical evaluation, installation instructions (WR 98WO3981), post-modification test plan, and the 10 CFR 50.59 evaluation for DCR 98-016 were acceptable.
MMOD 99-0502. EDG "B" Skid Hioh Pressure Grout and Foundation Core Bore
, inspection Since OR01, there have been several investigations of potential misalignment causes,
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including the pillow block bearing shims, EDG skid bolting practices and torque values,
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an evaluation of internal components, foundation settling, and lastly, skid beam deduction. The licensee recently determined that the diesel skid was sloping downward from east to west.
'l MMOD 99-0502 was written to install high pressure epoxy grout under the skid beams of
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EDG 8, and to take four core bore samples to investigate the condition of foundation grout and concrete. Past inspections have repeatedly found web deflections out of tolerance. The crankshaft misalignment contributed to higher that normal EDG vibrations, which remained below levels that would impact operability. The grout will fill clearances created when skid anchor and jacking bolts are adjusted to align r crankshaft.
A technical evaluation considered the impact of the modifications, including the impact of the core bores on the EDG foundation and verification that the 10,000 psi compressive strength of the grout met the design requirements for the seismic qualification of the EDG skid. The technical evaluation, installation instructions, post-modification test plan, and the 10 CFR 50.59 evaluation for MMOD 99-0502 were acceptable.
MMOD 97-0530. Replacement Capacitor for Power Supolv in Emeroency Power Seauencer Panels Starting in 1995, the licensee began replacing electrolytic capacitors in power supplies used in the solid state protection system (SSPS) - MMOD 95-579; the nuclear instrumentation /7300 racks - DCR 95-0021; and, the emergency power sequencer (EPS)
panels - MMOD 97-0530. These modifications were prompted by a licensee initiative based on industry experience which indicated electrolytic capacitors should be replaced every 16 years. The licensee elected to use a 10 year replacement interval at Seabrook.
The replacement of the power supply capacitors was a good initiative. As of February 1999, the licensee had refurbished the four SSPS power supplies and about 75% of the estimated 60 power supplies in the 7300 racks. The power supplies in the EPS and 7300 racks still to be replaced have been in service for about 15 to 18 years.
The replacement of EPS capacitors has been delayed. MMOD 97-530 was initially
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scheduled for completion during OROS, but was not done due to the unavailability of the replacement capacitors. The MMOD was not included in the OR06 schedule due to errors in scheduling the refurbishment work. ACR 99-0513 was issued to address this problem.
The technical evaluation, installation instructions (WR 96 WOO 1106), post-refurbishment test plan, and the 10 CFR 50.59 screening evaluation for MMOD 97-0530 were acceptable. Examples of good practices were the use of a " hot rack" to bum in electronic equipment for four weeks prior to installation in the plant; and, the use of thermography to evaluate the power supply performance.
Service Water Vacuum Breaker Vacuum breakers (SW-V-174,175,176, & 177) allow air flow into the service water system outlet piping during operation in the normal mode (ocean) when a slight vacuum exists. These valves, including some prior design changes, have historically failed to seat tightly following switchover from the ocean to cooling tower mode of operation when this piping becomes slightly pressurized.
Temporary modification request (TMOD) 99-0006, modified vacuum breaker valve 1-SW-V-177, replacing the ultra-high molecular polyethylene "hard" valve seat with a Viton
" soft" seat to improve valve closure. Also, the valve was rotated 90 degrees downward allowing both gravity and spring force to seat the valve poppet. The TMOD was appropriately installed in the field and the team observed no vacuum breaker leakage while under the cooling tower mode of operation.
(DCR 98-0032) Addition of Accumulators on the Feed Water Isolation Valves (FWlV)
The FWlVs are 18-i_nch flex wedge gate valves positioned by a pneumatic-hydraulic actuator. The actuator was originally designed using a 0.3 valve factor (VF) to determine the required thrust for valve operation. Substantial testing performed in response to Generic Letter 89-10, " Safety Related Motor-Operated Valve Testing and Surveillance;"
has identified that a 0.3 VF may not be appropriate for this application. Using a more i
appropriate valve factor of 0.5 to 0.6 for this application results in a significant increase in i
the predicted thrust requirement for valve operation.
To provide increased assurance that the FWlVs will be capable of performing their
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design basis function using the higher VF, an additional accumulator is being installed at each FWlV during OR06 per DCR 98-0032. The engineering work in support of this
DCR, including the team's observation of work ongoing in the west pipe chase was
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Conclusions Engineering support for all modifications reviewed was good. Technical evaluations, installation instructions, post-modification test plans, and the 10 CFR 50.59 screening and safety evaluations were thorough and well supported. Concerning the EDG skid deflection, EDG capacitor replacement and service water vacuum breaker modifications, the timeliness in completing initiatives and achieving resolution of longstanding problems detracted from the otherwise good quality of the engineering support.
E1.4 Enaineerina Workload a.
Insoection Scooe The team reviewed the licensee's efforts regarding the control of the engineering workload. The review included the activities of the recently established engineering-fix-it-now (EFIN) group.
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Observations and Findinas Engineering management recognized the importance of reducing engineering workload to assure effective support to operations, and established goals to reduce backlogs. The backlog was trended in several categories, as described in the licensee's 1998 Engineering Progress Report, such as for design document trends (DCRs, MMODs, EWRs, TMODs) and ACR activity. Engineering made significant progress to meet goals for backlog reduction in 1998. The reduction was achieved through focus on the performance indicators and renewed emphasis to work off the backlog, and by alignment with the station 12 week work process. The licensee noted that a large percentage of the backlog items were enhancements. Through meetings with plant staff to better prioritize which items needed to be done, the licensee reduced the number of EWRs by 100.
Another initiative to improve control of the engineering workload was through the formation of the engineering fix-it-now (EFIN) group in the fall of 1998. This group was composed of a supervisor plus 7 multi-disciplined engineers to support the station on a daily basis. The EFIN group provided a point of contact for items added to the Operational Impact List, and resolved the item or coordinated and tracked its resolution
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through design engineering. As of January 1999, the group had processed 245 engineering work requests, and had maintained its backlog within established goals.
The inspector verified that the EFIN group actively tracked and/or worked all items on the Operational impact List that required engineering action.
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Through the above initiatives, the licensee reduced the number of outstanding EWRS from 650 to 350, and the number of ACR evaluations from 675 to 275. The licensee has a plan to significantly reduce the number of TMODS coming out of OR06 (there were 25 as of January 1999), with the goal of either removing or converting most TMODS to permanent design changes by the end of 1999. The licensee also completed a recent self asses:; ment (ESAR 99-009) which provided a risk ranking of the 76 highest priority EWRs. The EWRs were ranked and prioritized by maintenance rule and overall risk ranking. The license indicated that the EWR risk ranking effort would be performed periodically c.
Conclusions Several initiatives in 1998 (12-week work schedule, focus on operational impact issues, EFIN group) were successful in reducing engineering workloads to achieve realistic goals. The risk ranking effort of EWRs and the decision to retain, train and improve on this effort were noteworthy.
E1.5 Generic Letter 96-01 a.
Inspection Scope The purpose of this inspection was to conduct a limited scope review per NRC Temporary Instruction 2515/139, " Implementation of Generic Letter 96-01, Testing of Safety Related Logic Circuits."
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Observations and Findinos Generic Letter (GL) 96-01 requested licensees to compare electrical schematic drawings and logic diagrams for the reactor protection system, emergency diesel generator (EDG)
load shedding and sequencing, and actuation logic for the engineered safety feature systems against procedures to ensure that all portions of the logic circuitry are adequately covered in the surveillance tests to fulfill the Technical Specification (TS)
requirements.
The licensee responoed to GL 96-01 by letter dated May 22,1997, to describe the process and results of the review. When GL 96-01 was issued, the licensee had a program in place to review technical specifications and surveillance procedures as a result of commitments made in LER 94-016 regarding discrepancies in testing safety related circuits. The licensee developed a scoping assessment to identify the procedures and modifications that needed to be included in the GL96-01 review. The scope and methods were appropriate to meet the GL96-01 requested actions. The licensee's review included relay contacts, parallel logic, interlocks, and other logic components performing a safety function.- An example of a good practice was the method to assure circuit continuity after test jacks were disturbed during the test
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(reference Section 4.6 of procedure LX0563.04). An example of a strength in the test documentation was the Design Basis Documents for the testing process, which described the licensing and design bases, the detailed testing requirements, and potential testing problems that could be encountered.
Engineering memorandum CEM#97-093 described the procedures reviewed, the results of the review, and status of corrective actions. The licensee revised two procedures used for the EDG load shed and sequence testing. The licensee corrected several discrepancies associated with EDG procedures EX1804.001 and EX1804.015 (reference ACR#97-489), and overlap testing within the analog portions of some channels outside L
the scope of GL96-01. The procedure changes were completed by change request SB-
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SPCR-97-005 dated March 5,1997.
The team selected a safety related logic circuit for detailed review to evaluate the process used to meet the requirements of GL 96-01 and to confirm the adequacy of the surveillance procedures. The circuit selected included the Reactor Protection System (RPS) trip signals detected for 13.8 kV bus undervoltage and underfrequency.
Procedures LX0563.04 and IX1680.921 were adequate to test the RPS circuits per the TS requirements. The licensee proposed changes to procedure LN0563.59, " Trip Check of the Reactor Coolant Pump (RCP) Breakers," that will be implemented during the OR06 to completely test the control circuits for the RCP trip coils. The change will add a check of the RCP trips on 13.8 KV bus underfrequency. Although the reactor is tripped for an underfrequency condition on the RCP buses, the licensee had not tested this part of the circuit because the RCP trip is not safety related and is not credited in the loss of coolant flow accident analyses (UFSAR Section 15.3). The licensing basis is consistent with the design basis established by the NSSS vendor (reference WCAP-8424).
c.
Conclusions Engineering support was good to complete the reviews required by Generic Letter 96-01.
Technical reviews were thorough, design basis documentation was complete and of good quality, and test discrepancies were properly resolved.
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E1.6 Walkdown Observations a.
Inspection Scope
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The team conducted a walkdown with system engineers to review the status of both emergency diesel generators (EDGs) and the PCCW syste e
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Observations and Findinas
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EDG System There were 35 deficiency tagged (DTs) conditions on DG-1A and 25 on DG-1B. Most
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deficiencies were identified in 1998. The number of tagged deficiencies was due in part j
to the present focus to have zero identified leakage in the diesel support systems. The majority of the deficiencies involved minor leakage of fuel, glycol or lubricating oil, and I
other minor mechanical or instrumentation problems. Based on a review of the history and engineering evaluation of each deficiency, the team concluded that the deficiencies, individually and collectively, did not impact EDG operability.
J The licensee's practices for prioritizing and scheduling work were reviewed. Past practices included an engineering assessment to prioritize the deficiencies that should be worked during the outage to address those that could impact EDG operability. Less q
significant deficiencies were left for work during plant operations. The present intention is to work as many deficiencies as possible during the outage, such that the number of j
outstanding deficiencies will be reduced by 46 during OR06. The most significant EDG repair will be to replace the DG-1 A turbocharger, which has had an adverse trend in vibration.
PCCW System The team noted some unfamiliarity by the system engineer with the remote safe shutdown equipment. Discussions with the PCCW system engineer and other system engineers indicated their last systems training was more than 10 years ago. The technical support manager acknowledged that this weakness regarding the lack of refresher systems / simulator training would be addressed in a licensee initiative, the Recognition and Achievement through Technical Engineering Support project, which was in progress. Recommendations from this effort would be coordinated with the curriculum advisory committee to formulate needed training for system engineers.
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Conclusions Engineering support was good in monitoring the status of EDGs and potential
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deficiencies and appropriately prioritizing corrective actions to resolve them. A weakness was noted regarding the lack of refresher training for system engineers.
E8 Miscellaneous Engineering issues E8.1 LER 50-443/98-11: The team reviewed documents regarding engineering's performance in resolving the issue of inoperable containment penetration overcurrent protective devices as discussed in Licensee Event Report (LER) 98-11. LER 98-11 had been closed in inspection report 50-443/98-11.
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On November 20,1998, the licensee identified a cable connected to an electrical penetration that was energized during power operation without operable electrical protective devices. The cable provides an electrical interlock between the reactor side control console (FH-CP-60) and the fuel pool side control console (FH-CP-61) for the fuel transfer system.
The team reviewed ACR 98-3290 and found that the licensee had performed an extensive root cause analysis of this issue and provided acceptable corrective actions (such as training) to prevent recurrence. Additionally, the licensee conducted an evaluation that determined the circuit breakers already included in the circuit, while not class 1E, were sufficient to protect the containment penetration in the event an overcurrent condition were to occur. The licensee also performed an extent of condition evaluation to determine if additional problems of this type existed elsewhere. No other deficiencies were identified. The team found these evaluations to be acceptable.
IV. Plant Support F1 Control of Fire Protection Activities F1.1 Fire Risk Evolutions a.
Inspection Scope (64704)
The team reviewed the licensees administrative processes for controlling and evaluating fire hazards, including limiting the interaction of combustible and flammable materials with ignition sources. This review was conducted to verify that adequate guidance and proper authorization requirements existed for identifying and limiting fire risk.
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Observations and Findinas The team reviewed hot-work activities associated with hot-work permit number 190036,
" Fabricate and install Feedwater Cool Down Line 1-FW-5855-01," hot-work permit 190049, " Cut Grating & Toe Plates for support installation," and implementation procedure FP 2.1, " Control of Ignition Sources," Revision 4, Change 1. The inspectors found that the administrative process for controlling ignition sources included the use of a permit system for authorization to perform hot-work activities. The authorization to perform the task was granted by the work group supervisor overseeing the job task.
Prior to authorizing the hot-work activity, fire protection personnel appropriately inspected the hot-work area to identify potential fire protection problems and to ensure that appropriate fire watches were provided. The inspectors found that the hot-work procedure was properly implemented in the field and that the guidelines in the hot-work permit were being followed. Review of the hot-work log revealed no discrepancies.
The team determined that the administrative process provided a comprehensive review of the above hot-work activity and should have identified any potentialinteraction of combustible and flammable materials with ignition source.
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Conclusions The team concluded that good administrative controls had been established for hot-work accomplished in the associated hot-work permits. Proper controls of combustible materials were in place. Good control of hot-work activities were evident.
F2 Status of Fire Protection Facilities and Equipment F2.1 Facility Tour a.
Inspection Scope (64704)
The team toured the Seabrook Station site and inspected fire suppression and detection systems / components. The team also inspected the material condition of fire fighting equipment, emergency lighting unit operation, fire door latching, and roving fire watch turnover and tour.
b.
Observations and Findinos The team found that the fire protection equipment material condition was good and that combustible fire-loading was properly maintained in those areas inspected. Fire brigade members' protective clothing and gear was found in good condition and well organized in the various site fire brigade lockers. The team found that monthly surveillances were conducted on fire fighting gear at the staged locations. The inspectors determined that housekeeping in areas containing safety-related and nonsafety-related equipment was good. Proper combustible material control was observed.
The team verified that the fire suppression system pressure was adequate.- Fire hoses j
did not exhibit any cracks or fraying and all observed nozzles were properly rated. The team noted that lexan hose nozzles were being replaced by metal nozzles because of cracks developing in the lexan nozzles. The team found that this action was being
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accomplished as a result of corrective actions implemented by ACR 98-3217.
The team found that gauges on fire equipment including some fire extinguishers registered in their appropriate ranges. The team verified that all observed fire extinguishers were current with monthly surveillances. The team noted appropriate smoke detection, fire detection, and alarm panels were installed throughout observed areas at the site and proper surveillances were conducted to ensure operability. The team observed that fire doors latched properly. There were no instances observed where access to fire suppression devices was restricted by any materials or equipment.
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During observation of the fire watch tumover, the team noted that appropriate
~ information was provided to the security guard beginning his roving fire watch activities.
The team found that the roving fire watch toured appropriate areas of the plant in a timely manner, looked for appropriate indications of fires, failed equipment, and obstructions of fire protection equipment during his tour. The roving fire watch was knowledgeable regarding the station policy on reporting fires, the roving fire watch duties, and responding to fires. The team dec; ermined that the roving fire watch was knowledgeable of his duties and responsibilities regarding the fire protection program.
The team found that recent actions by the licensee had been implemented to improve the effectiveness and operation of eight hour emergency lights for access / egress routes of safety-related equipment areas. The licensee demonstrated emergency light operability and illumination patterns on approximately twenty-five selected emergency lights during the plant tour. All emergency lights properly illuminated when the test button was depressed.
The team performed a detailed walkdown of the suppression and detection systems in the cable spreading room because it was identified as a risk significant fire area. The inspectors compared the installed configuration of the suppression and detection systems with their associated drawings and found no discrepancies. Appropriate surveillances were conducted on the suppression system and the smoke detection system to verify operability, c.
Conclusions The team concluded that fire protection equipment conditions and housekeeping in various areas of the plant were good. The team also concluded that the licensee l
maintained good control of combustible materials. Roving fire watch personnel were knowledgeable of station procedures for reporting fires, roving fire watch duties, and responding to fires. Eight hour emergency light operation was good. Observed fire protection systems were capable of providing protection against fire and were consistent with the defense-in-depth principle.
F2.2 Fire Barrier Penetration Seals I
' nsoection Scope (64704)
I a.
The team reviewed selected penetration seals to determine the adequacy of installation and testing.
b.
Observations and Findinos The team found that the licensee performed visual inspections of 10% of the fire barrier penetration seals every 18 months to ensure that required barriers were not degraded and remained operable. Fire barrier penetration seals DG021DG2015009, DG021DGST13003, and DG021DG2021010 located in Seabrook's emergency diesel generator rooms were sampled for review. The team found that the selected penetration
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seals were in good condition and that they were installed comparable to that described in Brand Industrial Services, Inc., Construction Group (BISCO) fire test report Nos. 748-134 and 748-170. The team reviewed these reports, which documented the fire barrier penetration seal acceptance tests. These tests included destructive examinations demonstrating that the fire barrier penetrations had withstood the fire endurance test without the passage of flame for a period of time equivalent to the barrier fire resistance rating.
c.
Conclusions The team concluded that the sampled fire barrier penetration seals were in good condition and that the installed configuration of the seals was comparable to that described in BISCO test report Nos. 748-134 and 748-170.
F2.3 Fire Main Looo Flow Testina a.
Inspection Scope (64704)
The team reviewed test results of the last three yard hydrant loop flow tests for Seabrook Station. The team also performed a walkdown of the yard hydrant loop.
b.
Observations and Findinas The team found no evidence of deterioration or blockage of the fire mains based on loop flow test results. The team noted loop flow tests resulted in flow coefficients well above the acceptable minimum. In addition, the fire protection self-assessments recorded flow coefficients from previous tests to establish the trend / data. The team verified that no
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degradation to loop flow had occurred over the last three years. The team found that the materit mnditior$ c/ the yard hydrant loop components was good.
c.
Conclusions i
Based on the tests results reviewed, test data trends, and observation of the condition of the hydrants and post indicator valves, the team concluded that the fire main loop is in good material condition and capable of providing the necessary water supply for fire fighting needs at the facility.
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F2.4 Fire Pumo Testina a.
Insoection Scoce (64704)
The team reviewed the fire pumps test data for the past three years. The team also inspected the material condition of the installed fire pumps and fresh water storage tank *
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b.
Observations and Findinas The team determined that fire pump operating data recorded during pump tests were within the acceptance criteria. The team also found that test data showed consistent performance for pumps and drivers.
The team walked down the installed equipment and found that the fire pumps were in a good state of preservation, with the water supply valves open, and the pumps ready for operation. An exception was one of the two fire main jockey pumps was removed to analyze an observed high vibration in the motor. The remaining jocky pump was operable and could assume the full work load of the jocky pump removed for repair. The team verified that the licensee had entered the pump into their corrective action program for evaluation and repair.
c.
Conclusions Based on the observed conditions of the equipment and the review of the test data, the inspectors determined that the Seabrook Station fire pumps are well-maintained and ready for service. Conditions which could adversely affect pump performance were identified and corrected.
F3 Fire Protection Procedures and Documentation F3.1 Fire Protection Procedure Review a.
inspection Scope (64704)
The team reviewed fire protection procedures to determine if they provided sufficient detail and were technically sound. The team also reviewed changes that occurred in these procedures during the past three years, b.
Observations and Findinas The team found that the fire protection procedures govern all facets of the fire protection program. This included the operational fire protection program, fire protection training and qualifications, fire protection maintenance and surveillance testing, fire emergency preparedness, fire protection inspections and audits, control of combustible materials, fire watches and fire patrols, and actions for inoperable fire protection equipment. The team found that the procedures provided sufficient detail and were technically sound for implemer. ting the fire protection program at the site. The team also found that recent changes to the fire protection procedures did not impact the program as it is stated in the UFSAR.
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Conclusions The team concluded that fire protection procedures were acceptable for fire protection program implementation, contained sufficient detail, and were technically sound. The team also concluded that recent changes to fire protection procedures did not impact the licensing basis of the fire protection program.
F4 Fire Protection Staff Knowledge and Performance F4.1 Fire Brioade Drills a.
Inspection Scope (64704)
The team observed a fire drill to evaluate the effectiveness of the fire brigade and their understanding of fire attack strategies. The drill was conducted to demonstrate the following:
(1) effectiveness of fire alarm response, timeliness of department notification; (2) response of fire brigade, time required to initiate fire attack or mitigation; (3) ability to assess the fire properly; (4) an understanding of the fire attack strategy; (5) an awareness of vital equipment in the area; (6) ability of each member to physically perform required tasks; (7) effective communication between fire brigade members; and (8) an awareness of additional hazards in the fire area.
b.
Observations and Findinas l
The team observed a fire drill on March 11,1999. A hydrogen fire was simulated at the northeast comer of the turbine building.
The team determined, based on drill observations and post-drill discussions with responding brigade members, that the performance and knowledge of the drill participants was very good. This determination was based on the following:
(1) The fire brigade dressed quickly and appropriately.
I (2) Fire fighting gear was checked for proper operation.
(3) The fire brigade used en appropriate fire suppressant type.
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(4) Command and control was demonstrated by the fire brigade leader.
(5) Team work was displayed by fire brigade members; (6) Fire brigade members displayed effective communications.
(7) The fire brigade appropriately simulated obtaining assistance from a local fire department.
(8) The fire brigade secured the simulated fire in a timely manne.o
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The team found the quality of the critique following the drill to be effective in that it I
provided constructive feedback to the fire brigade regarding performance. The team noted that each member of the fire brigade team was allowed to provide constructive comments to the team leader and supervision regarding fire brigade performance.
Additionally, the team noted that this fire drill was also used as a training vehicle to increase the effectiveness of the fire brigade.
Through discussions with the Seabrook Fire Department's fire chief, the team found that licensee's fire fighters were well coordinated with local fire department in the event they were needed to support Seabrook Station fire fighting activities. An example of such coordination included annual joint training to ensure fire fighting strategies at the site were understood by the local fire department.
c.
Conclusions The team determined that the fire brigade performance during a drill was very good. All
- expectations of the fire drill were met. Based on discussions with the local fire department, coordination activities to ensure proper understanding of fire fighting strategies at the site were good.
F5 Protection Staff Training and Qualification F5.1 Fire Briaade Trainina a.
Inspection Scooe (64704)
The team reviewed the training program requirements and d e. raining provided for fire brigade members to verify that members had completed all required training for qualification and duty.
b.
Observations and Findinas The team verified that ten fire brigade members randomly selected for review had successfully completed the required training courses, drills, respirator training and passed their annual medical physicals. No deficiencies were identified.
The team found that initial and continuing training programs appropriately emphasized
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potential fire hazards and precautionary measures, supported brigade member readiness, and complied with NRC requirements and the Seabrook Station licensing basis. The team also found that the training department had modified training courses
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Conclusions The team determined that fire brigade members were current on all required training and annual physical examinations. The training program complied with NRC requirements for preparing fire brigade members to combat fires.
F7 Quality Assurance in Fire Protection Activities F7.1 Audits and Surveillances a.
Inspection Scope (64704)
The team reviewed the quality assurance audit reports and surveillances conipleted to satisfy the UFSAR requirements.
b.
Observations and Findinas The team reviewed the most recent quality assurance audit report number 98-A08-02,
" Fire Protection (Annual and Triennial)," conducted from August 10,1998, through August 21,1998, audit report number 97-A07-02, " Fire Protection," conducted from July 21,1997, through August 1,1997, several quality assurance surveillance reports, and several fire protection self-assessments. The team verified that audits adequately
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evaluated the effectiveness of fire protection measures, equipment, program implementation, and problem identification and resolution.
The team determined that these documents demonstrated good problem identification and clearly communicated the findings in the reports. The team noted that the audit scopes, findings, and observations were good and met the requirements of the program.
The team verified that proper revisions and actions were taken to effectively resolve any identified deficiencies. Corrective actions were found to be implemented for resolving these deficiencies in a timely manner, c.
Conclusions The team concluded that the fire protection quality assurance audits appropriately reviewed fire protection program attributes and compliance with program requirements.
The team also concluded that the fire protection audit findings were appropriately addressed and timely corrective actions were taken for identified deficiencie r
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V. Manaaement Meetinas X1 Exit Meeting Summary Licensee representatives were informed of the purpose and scope of the inspection at an
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entrance meeting conducted on March 8,1999. The fire protection inspection results were presented to members of licensee management at an exit meeting on March 12,1999. The team met with the principals listed below on March 26,1999, to summarize all preliminary
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inspection findings.- The licensee acknowledged the preliminary findings and conclusions, with no exceptions taken. The bases for the inspection conclusions did not involve proprietary l
I information, nor was any such information included in this inspection report. Several subsequent telephone conversations were held with licensee staff to further discuss findings of the inspection. The last telephone conversation occurred on April 8,1999.
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PARTIAL LIST OF PERSONS CONTACTED North Atlarytic Enerav Service Corooration J. Grillo, Assistant Station Director R. Faix, Engineering Supervisor T. Nichols, Technical Support Manager M. Ossing, Licensing Engineer H. Carmichael, Nuclear Oversight Manager D. Conti, Fire Fighter Supervisor T. Feigenbaum, Executive Vice President - Nuclear J. Grillo, Assistant Plant Manager J. Peschel, Regulatory Compliance Manager G. St. Pierre, Operations Manager J. Vargas, Director of Engineering B. White, Mechanical Engineering Manager U.S. Nuclear Reaulatory Commission J. Brand, Seabrook Resident inspector J. Yerokun, Chief, Engineerin' Support Branch g
INSPECTION PROCEDURES USED i
i IP 37550 Engineering IP 92903 Engineering Followup IP 37001 Safety Evaluation Program IP 64704 Fire Protection Program IP 92903 Follow up Engineering IP 93809 Safety System Engineering inspection i
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-443/99-03-01 NCV failure to calibrate high temperature PCCW pump trip circuit Closed
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50-443/99-03-01 NCV failure to calibrate high temperature PCCW pump trip circuit 50-443/97-09-01 NOV failure to perform a 10CFR50.59 evaluation 50-443/97 09-02 NOV measuring and test equipment (M&TE) was no properly controlled 50-443/97-09-03 URI assessment of instruments to determine safety significance
50 4 43/97-07-02 IFl update measuring and test equipment specification sheets l
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LIST OF ACRONYMS USED i
l ACR Adverse Condition Report j
BISCO Brand Industrial Services, Inc., Construction Group j
CFR Code of Federal Regulations
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DBD Design Basis Document de direct current l
EDG Emergency Diesel Generator l
HP Horsepower
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l&C Instrumentation & Control IFl Inspector Follow-up Item LER Licensee Event Report M&TE Measuring & Test Equipment MOV Motor Operated Valve NCV Non-Cited Violation i
NOV Notice of Violation n;RC Nuclear Regulatory Commission l
NRR Nuclear Reactor Regulation PCCW Primary Component Cooling Water System i
RSS Remote Safe Shutdown SPAR Special as Requested TS Technical Specification UFSAR Updated Final Safety Analysis Report i
URI Unresolved item Vdc Volts Direct Current l