IR 05000483/1998018

Insp Rept 50-483/98-18 on 980914-1002.Violations Noted. Major Areas Inspected:Review of Design & Licensing Basis for Essential Service Water Sys,Associated Electrical Support Sys & Review of Program Implement 10CFR50.59

ML20198A152
Person / Time
Site:	Callaway
Issue date:	12/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198A079	List: IR 05000483/1998018 ML20198A074 ML20198A123
References
50-483-98-18, NUDOCS 9812160165
Download: ML20198A152 (51)

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! ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-483 License No.: NPF 30 Report No.: 50-483/98-18 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Hwy. CC and Hwy. O Fulton, Missouri Dates: September 14 through October 2,1998 Team Leader: Linda Joy Smith Senior Reactor Inspector, Engineering Branch Division of Reactor Safety inspectors: David Loveless Senior Resident inspector Division of Reactor Projects Joe Panchison Consultant Farouk Baxter Consultant Approved By: Thomas F. Stetka, Acting Chief Engineering Branch Division of Reactor Safety Attachment: Supplemental Information i

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9812160165 981204 PDR ADOCK 05000483 G PDR

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EXECUTIVE SUMMARY Callaway Plant NRC Inspection Report 50-483/98-18 During the weeks of September 14 and October 2,1998, the NRC conducted the on-site portion of an engineering team inspection. The team inspection included a review of the design and licensing basis for the essential service water system and associated electrical support

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systems and a review of the program to implement 10 CFR 50.59," Changes, Tests and l

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• The team found that the design and testing of the essential service water system were consistent with applicable licensing, design, and operations documents. While, the licensee had not initially established a clear analytical basis for system operability with a l degraded pump, testing practices were aggressive, and the licensee had proactively scheduled pump replacement as needed. Subsequent analysis confirmed that the i as found design was acceptable over the full range of allowed pump degradation l

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(Sections E1.1 and E2.1).

• One unresolved item was identified concerning design changes made to bypass torque  !

switches, originally installed in safety-related motor-operated valve control circuits to I prevent overtorque during valve closure. The licensee committed to perform additional l review to confirm the adequacy of their current design (Section E1.1.1).

• While the as-found design of the electrical support system was-found to be acceptable, l the team identified several instances where the licensee had either f ailed to follow procedures or failed to establish procedures to assure that the design basis for the electrical system was maintained and that operation in unanalyzed condition was properly evaluated (Section E1.2).

• The load flow voltage drop calculation was not checked properly and included an incorrect assumption. Emergency diesel generator load growth was not properly monitored and evaluated as required by procedure. These failures to follow design control procedures were determined to be a violation of 10 CFR Part 50, Appendix B, Criterion V, " Procedures, Instructions and Drawings," (Section E1.2).

• The failure to provide adequate procedures for operator logging practices and failure to prescribe preventive maintenance instructions for switchyard voltage indicators, which were needed to assure operation in an analyzed condition, resulted in multiple failures to evaluate potentially inoperable offsite power supplies. These failures to provide adequate procedures were determined to be a violation of Technical Specification 6. (Section E1.2).

• Material condition of the essential service water system was good. System walkdowns combined with a review of suggestion / occurrence / solution reports, maintenance rule reports, and system health reports indicated that the essential service water system was in good material condition (Sections E2.2, E2.3 and E2.4).

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Procedural guidance was in place to ensure that changes to the plant were properly evaluated in accordance with the requirements of 10 CFR 50.59, " Changes, Tests and Experiments," and to appropriately update the Final Safety Analysis Report. The safety evaluations reviewed were well documented and properly concluded that no unreviewed safety questions existed (Section E3.1).

The team concluded that adequate procedural controls were in place to ensure that affected calculations were reconciled when new or revised calculations were generated (Section E3.2).

The failure to test the pressurizer safety valve balancing devices in accordance with Technical Specification 4.0.5 is a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll. of the NRC Enforcement Policy (Section E8.11).

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TABLE OF CONTENTS I til. Engineerina . . . . . . . . . . . . . . . . . . . . . . .. .... .... . ........... ........ 1 E1 Conduct of Engineering (93809) . . . . . . . . . . . . . . . .................. 1 E Essential Service Water Mechanical System Design . . . . . . . . . . . . . 1 E1.2 Essential Service Water Electrical System Design . . . . . . . . . . . . . . . . 6 E2 Engineering Support of Facilities and Equipment (93809) . . . . . . . . ...... 15 E Essential Service Water Mechanical System Surveillance Testing .. 15 E2.2 Essential Service Water System Walkdown . . . . . . . .... ....... 18 j E2.3 Essential Service Water Rooms Minimum and Maximum Temperatures

.............................. ........ .. .......... 19 E Essential Service Water System Health . . . . . . . . . . ..... ...... 20 E2.5 Computer System Compliance for the Year 2000. . . . . . ......... 21 E3 Engineering Procedures and Documentation . . ............... . ... 23 E Review of the 10 CFR 50.59 Safety Evaluation Program ......... 23 E3.2 Calculation Modification Program . . . . . . . . . . . ................ 24 E8 Miscellaneous Engineering issues (92903) . . . . . . . . . .......... .,,. 24 E (Closed) Violation 50-483/9705-01: Failure to Report 14/20 Main Steam Safety Valve failures during Refueling Outage 7. ............... 24 l

E8.2 (Closed) Inspection Followup item 50-483/9705-02: Review analysis to I support an increased setpoint tolerance for the pressurizer safety valve to verify that accident analysis assumptions were rnaintained . . . . . . . . 25 E8.3 (Open) Inspection Followup item 50-483/9705-03: Review the licensee's efforts to identify and resolve discrepancies between the Final Safety Analysis Report and the as-built configuration and operation of plant systems. . . . . . . . . ................................ ... . 26 E8.4 (Closed) Violation 50-483/9705-04: Failure to report temporary modifications in accordance with 10 CFR 50.59 requirements. . . . . . 26 E8.5 (Closed) Violation 50-483/9705-1034: Failure to perform a safety evaluation for a modification of the post-accident sampling system. . . 27 E8.6 (Closed) Violation 50-483/9705-1024: Failure to perform a safety i evaluation of a refueling machine setpoint change . . . . . . . . . . . . . . 27 I 3-

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E8.7 (Closed) Violation 50-483/9705-1014: Failure to perform a written safety evaluation for placing the emergency diesel generator supply fans in pull-to lock . . . . . . . . . . . . . . . . . . . ............................ 28 E8.8 (Closed) Licensee Event Report 50-483/97-001: Misinterpretation of Technical Specification 3.9.6 refueling machine trip limits. ........ 28 E8.9 (Closed) Licensee Event Report 50-483/97-007: Main steam safety valve setpoint drif t outside design basis requirements . . . . . . . . . . . . . . . 29 E8.10 (Closed) Licensee Event Report 50-483/98-006: Reactor coolant system pressurizer safety relief valves failed low on as-found set pressure tes .. .... .. ..... .... .... . ..... ... ..... .... ... 30

E8.11 (Closed) Licensee Event Report 50-483/98-007

Failure to verify the integrity of the pressurizer safety valve balancing device . . . 30 V. Management Meetings . .... ... .... . .. ... ... .. . . . . ... . 31 X1 Exit Meeting Summary . . . .. .. .. .. . . . .. . . 31

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Report Details introduction This inspection was performed in accordance with inspection procedure, " Safety System Engineering Inspection," (93809). The team reviewed the essential service water system (ESW), using inspection Procedure 93809. This system was selected because of its relatively high risk significance. In addition, the team reviewed the design basis for associated portions of the electrical distribution syste Ill. Enaineering E1 Conduct of Engineering (93809)

E Essential Service Water Mechanical System Desian E1.1.1 Essential Service Water Mechanical Design Capability Inspection Scoce The team reviewed various ESW system calculations and compared them to the available licensing, design, and operations documents related to the capability of the ESW system. The team verified that the ESW system was designed to supply cooling water to safety-related components that were required to safely shut down the reactor following a loss-of coolant accident or loss of off-site power and to provide an emergency source of water for the auxiliary feedwater system (AFS). Observations and Findinas Essential Service Water System Performance Calculation M-EF 52," Heat Exchanger Performance Based on Reduced ESW Temperature and Flow," Revision 1, was reviewed. This calculation determined the flow rate to the safety-related heat exchangers and room coolers that was needed to dissipate the design basis heat loads, based on a reduction of ESW inlet temperature from 95 to 92.3 degrees. The calculation established the acceptance criteria for the monthly flow verification to the containment coolers required by Technical Specification 4.6.2.3 as well as the acceptance criteria for the flows to all other safety-elated components supplied by ESW during the once per cycle ESW flow balance test. Design inputs such as heat loads were found to be correct and consistent with the design basi Calculation EF-68," Impact on ESW Flows and Pressure When in the LOCA/SI Lineup and Flow Is Then Diverted to AFS," Addenda 1, was reviewed. This calculation was performed to confirm that the ESW was capable of providing sufficient flow to all components while providing 2311 gpm flow to the AFS system. However, the team noted that this calculation did not consider allowed pump degradation. Instead, the calculation used the most recent ESW flow balance as the basis for the pump flow capability. The team determined that this analysis only represented the capability of the

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ESW system at the condition of the pump, piping, and components during the time of the flow balance only. The team did not consider this analysis to be a bounding design basis calculation. The licensee stated that, in lieu of a comprehensive calculation, they assured adequate system performance by testing. See Section E2.1 for additional discussion of the licensee's test progra The team also reviewed the thermal performance of the component cooling water (CCW) heat exchanger based on ESW design basis flow and temperatur Calculation M-EG-20," Maximum CCW Temperature Post LOCA, Addendums 1 and 2, were reviewed. The team confirmed that the methodology for this analysis was correct and that design inputs were properly selecte Available Essential Service Water Pump Net Positive Suction Head The team reviewed Calculation EF-58, " Minimum UHS Level That Will Ensure That NPSH Requirements for the ESW Pumps is Maintained," Revision 0, and the pump manufacturer's manual, associated pump outline drawing and performance curves. The team found that a minimum submergence of 8 feet was necessary for pump operatio Eight feet of submergence corresponded to an elevation of 1978 feet 6 inches, which corresponded to minimum pond level as specified in Table 9.2-4 from the site-specific Supplemental Addendum to the Final Safety Analysis Report," Ultimate Heat Sink Component Data." The team concluded that adequate net positive suction head existed for the ESW pump Motor-Operated Valve Calculations The team reviewed Engineering Department Procedure EDP-ZZ-01114," Motor Operated Valve Predictive Performance Manual," Revision 10. This document, in part, established the methodology in determining the required thrust / torque window for safety-related motor-operated valves. It also established the torque and limit switch setting policy for the motor-operated valves. This program document states, in part, that

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the most appropriate setting (i.e., limit / torque switch setting) would be selected based upon a review of the valve / operator limitations and the required thrusts and torques to overcome differential pressure conditions." Typically the differential pressure dictates the minimum thrust / torque of the window, and the limitations on the valve / operator dictates the maximum thrust / torque of the windo The team found that the majority of safety-related motor-operated valves were seated (i.e., valve travel in the close direction was halted) by using the limit switch, while the torque switch and the motor thermal overloads were bypassed. The team noted that using only a limit switch to halt valve travel in the close direction was an unusual desig The licensee stated that it was their design philosophy for the valve operators to drive the valve to the safety position, even if this involved destruction of the valv The licensee viewed valve destruction as very unlikely because of the care taken during valve setup and the repeatability of limit switch settings. Limit switch setting was routinely pedormed with the torque switch and thermal overloads temporarily in the circuit. In this fashion, the torque switch was used to achieve the proper actuator

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thrust / torque during the setup process. The licensee also provided test data to support {

their view that limit switch settings did not vary significantly over time. The team agreed that under normal conditions limit switch settings were highly repeatabl l Licensees typically perform weak link analyses to examine probable failure modes at l stall conditions. The team requested the licensee to provide their weak link analysi The team found that this analysis had been performed using nominal voltages, rather than maximum expected voltages. Use of the maximum achievable voltage would '

increase the stall torque, At the team's request, the licensee performed a stall torque check at maximum achievable voltage for the service water to ESW, Train B, Downstream Hand Valve EFHV0026. The stall torque was approximately 12,000 ft-lb The weak link was the disk to shaf t key, whose maximum permitted torque limit was 6,000 f t-lbs. In this case, the key was not a pressure boundary part, the safety function for the valve was to close one time, and the licensee judged that the valve would continue to perform its safety function even if the key failed. The team agreed with this conclusio However, the team noted that, in general, the licensee's design philosophy did not account for potential failure mechanisms that involved pressure boundary parts or for valves that were required to both open and close, especially those valves that were called upon to cycle during an accident. In addition, this philosophy may not adequately assure that the structural integrity of the valve will be maintained sufficient to assure the safety function. Without the torque switch or the motor thermal overload in the valve operating circuit, any obstruction to seating the valve, or any slight deviation from the timit switch setpoint could yield excessive thrusts / torque During discussions of possible credible failure mechanisms, the team questioned the licensee regarding the equipment qualification testing for the valve actuators. The licensee stated that the valve operators had been qualified using a torque switch to stop valve travel in the close direction and using a limit switch to stop valve travel in the open direction. The licensee noted that a valve was not used in the actuator qualification testing; therefore, the licensee did not have test data regarding the effects of temperature change during an accident on valve limit switch settings in relation to valve seating. The team noted that differing coefficients of thermal expansion for various valve and limit switch parts could result in excessive thrusts / torques during accident conditions.

i At the end of the inspection, the licensee stated that they planned to reconsider their design philosophy and initiated Suggestion / Occurrence / Solution Report 98-3532 to evaluate the setup of motor-operated valves at the highest expected voltage under accident conditions. They planned to determine what effect stall thrust / torque at the maximum expected voltage has on the weak link of the valve / actuator to determine the consequences of any failure and to evaluate whether the current valve setup was correc Subsequent to the completion of the inspection, the licensee irovided their rationale for not performing a safety evaluation, pursuant to 10 CFR 50.59, when they bypassed the torque switch for 35 butterfly valves. In Request for Resolution 16987C, the licensee determined that this modification did not constitute a change in performance

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characteristics that could impact safety functions. In their view, bypassing the close torque switch increased the reliability of these valves and increased the design margin required for the valves to be able to perform their intended functio This item is unresolved pending the completion of the licensee's review of the effects of stall thrust / torque on the weak link of the valve / actuator and the consequences of any failure (50-483/9818-01).

Ultimate Heat Sink Compliance to Regulatory Guide 1.27 The team reviewed the capability of the retention pond to provide a 30-day cooling water supply to safety-related equipment consistent with requirements delineated in Regulatory Guide 1.27. The team reviewed Calculation M-EF-53," UHS Pond Thermal Performance - Maximum Heat Transfer Case and Final Report," Revision 1. Based on the analysis, the pond volume was adequate to provide cooling water during the 30-day period following a loss-of-coolant accident with a 38.7 percent margin of the initial pond water volume remaining during the maximum evaporation period and with a 51.8 percent margin remaining during the minimum heat transfer period. These margins were based on an ir'itial pond water level at the minimum level allowed by Technical Specification 3/4.7.5.a. For normal pond water levels, these margins would be highe The team also reviewed the loss of pond inventory during ESW flow to the AFS syste For this case, ESW provides water to AFS if a low AFS pump suction pressure exists concurrent with a loss of the condensate storage tank (CST). During this scenario, the valves that direct the ESW back to the retention pond do not automatically open and ESW water is dumped to the main cooling tower basin, which in affect constitutes a direct pump down of the retention pond. The team confirmed that a low water level alarm (Technical Specification 3/4.7.5.a) would alert the operators to take appropriate action to open the return valves. At the minimum Technical Specification pond level, a 30-day inventory still remain Based on this review, the team concluded that requirements of Regulatory Guide 1.27 were me Effects of Water Hammer The team reviewed the ESW system with regard to susceptibility to water hammer. It was concluded that conditions were present that would promote water column separation, a precursor to water hammer. On a safety injection signal, motor-operated valves that isolate ESW from the nonsafety-related service water system begin to clos These valves have a 30-second stroke time and both trains of ESW pumps sequence on at 30 seconds and 35 seconds respectively from the safety injection initiation. The licensee confirmed that because of this start sequence, column separation had occurred in the past at the containment cooler As a result of these occurrences, the licensee performed design modifications that reinforced existing piping supports and added new supports. Calculation GN-17,

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" Containment Cooler Water Hammer Analysis," Revision 0, was reviewed to confirm the

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capability of the final piping configuration to withstand expected water hammer. This I analysis developed the expected loadings in the ESW system piping and was based in part on pressure trace data recorded at the Wolf Creek plant. The results were then modified to account for the differences between the Wolf Creek and Callaway plant The team verified that design inputs and assumptions for this analysis were appropriat Conclusions l

Based on review of design documents coupled with test, trending, and extrapolated data, the team was able to conclude that the ESW was capable of providing the required flow to the safety-related components during accident conditions, as well as, when providing emergency flow to the AFS. Thermal analysis of the heat exchangers I and area room coolers was also found to meet design basis requirements. The ESW l system design was consistent with the applicable licensing, design, and operations documents. One unresolved item was identified related to determining whether the licensee's design control measures have adequately bounded the effect that stall thrust / torque has on the weak link of valve / actuators and the consequences of an)

failur E1.1.2 Essential Service Water Design Modifications Insoection Scope The team reviewed two significant design modifications to the mechanical portions of the ESW system. Modification MP 97-1002," Replace DEF01B With A Pump That Has A Slightly Larger Impeller," Revision A, replaced the ESW "B" train Pump DPEF01 Additionally Modification CMP 91-1014," Modify Return Spectacle Flanges to UHS Pond," Revision A, enlarged the ESW flow orifice located in the return line to the ultimate heat sink retention pon Observations and Findinas Pump Replacement The licensee replaced the ESW "B" train Pump DPEF01B because of degrading performance, which was identified during a quarterly pump surveillance test. Results of this test indicated that the pump had degraded to the alert range. The licensee replaced the original pump with one of identical design except that a slightly larger impeller was specified, since the original pump, as initially supplied, had never met the full capacity that was called for by the original design specification. The original pump motor was replaced with an available spare. Shop testing and generation of the certified pump curve was performed for the replacement pump / motor combination. After pump installation, the licensee established a new baseline pump curve for the purpose of American Society of Mechanical Engineers (ASME)Section XI testing. The team confirmed that affected ESW motor-operated valves were reviewed by the licensee for increased differential pressure due to the larger impeller. It was verified that the current motor-operated valves were capable of operating against the increased differential pressure ..

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The team concluded that be reason for change, the design description, impact on operations, and functional testing of affected components had been adequately addressed. The safety evaluation was-found to be adequat Ultimate Heat Sink Return Line Orifice Replacement The licensee enlarged the existing orifices located upstream of Manual Valves EFV-108 and 117 in the ESW "A" and "B" loop respectively. The purpose of these orifice plates was to maintain a backpressure at the containment coolers above saturation pressure at design basis loss of-coolant accident temperatures so as to avoid flashing. The original sizing of the orifices was based on clean pipe and pump design performance. Since then, the piping had become somewhat fouled and pump performance had degraded, increasing flow resistance. The team reviewed the modification package and confirmed that the reason for change, the design description, impact on operations, and functional testing was adequately addressed. Calculation M-EF-31,"ESW Orifice Sizing,"

Revision 1, Addendum 1, was reviewed. Design inputs and assumptions were found to be accurat The team noted that the afore mentioned calculation as well as the modification package and the safety evaluation all made reference to the requirement that the downstream isolation valves would be throttled and locked in the throttled position in combination with the enlargement of the orifice. It was stated that these actions would be necessary to maintain the required 42.4 psia backpressure in the loss-of-coolant accident alignment. In discussions with the licensee, it was determined that as system resistance continued to increase, the licensee used their routine flow balance test to confirm the required backpressure was available for the as-left throttle valve position The team determined that this was acceptabl Conclusions The team concluded that the modification packages reviewed were consistent with the plant licensing and design basis and that the licensee had developed adequate test procedures to address long-term system fouling concern E Essential Service Water Electrical System Design E1.2.1 Adequacy of Voltages at Safety Buses Inspection Scoce The team reviewed Calculatior. ZZ-62, " Load Ficw Voltage Drop Calculation,"

Revision 4, to evaleste the design basis for assuririg satisfactory voltage to all ESW pumps, fans, valves, ar.d auxiliarie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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. Observations and Findinas Preferred Offsite Power Circuit Capacity Calculation Final Safety Analysis Report Section 8.1.4 lists the safety design bases for the off-site power system. Safety Design Basis Two states that the first preferred circuit, which is connected to the startup trant: crner, has the capacity to supply the startup and all the auxiliary loads (both Group 1 and Group 2 simultaneously) of the unit. Safety Design Basis Three states that the second preferred power circuit, which supplies power to the engineered safety feature transformer, has the capacity to supply all the safety-related loads of the uni Calculation ZZ-62, " Load Flow Voltage Drop Calculation," Revision 4, was used by the licensee to demonstrate the capability of the two preferred power circuits to meet these safety design bases requirements. The team found that the assumptions in Calculation ZZ-62 were not adequately chec i as required by Procedure EDP-ZZ-04023, " Calculations," Revision 13, Mction 5.3.3. The calculation assumed one control room heating, ventilation, and air conditioning unit would be shut down for loss-of-coolant accident Cases 2 thru 13. Whereas, plant drawings indicated that both control room heating, ventilation, and air conditioning units would auto-start in the postulated circumstances, and plant operating instructions did not instruct the operators to secure either uni The team determined that with this error the existing calculation did not adequately demonstrate the capability of the independent off-site power circuit to meet the Safety Design Bases Two and Three listed in Final Safety Analysis Report, Section 8.1.4. The failure to adequately check the assumptions in Calculation ZZ-62 was one example of a violation of 10 CFR Part 50, Appendix B, Criterion V, " Procedures, instructions and Drawings," (50-483/9818-02).

The licensee agreed, issued Suggestion / Occurrence / Solution Report 98-3450 to address the incorrect assumption, and provided a preliminary calculation showing that the two preferred power circuits had sufficient capacity and capability without the need for load shedding the control room heating and ventilation units. The licensee planned to prepare a formal revision to Calculation ZZ-62 by February 15,1999. The licensee also planned to review all other load-shedding assumptions to confirm they were consistent with expected plant respons The team determined that this inspection report adequately described the reasons for this example of the violation and the actions taken to correct and prevent recurrence of the violation. Therefore, no response is required for this example of this violatio Minimum Switchyard Voltage As stated above, Calculation ZZ-62 was used by the licensee to demonstrate the capability of the two preferred power circuits to meet the safety design bases requirements listed in the Final Safety Analysis Report. In this analysis, the licensee determined that the preferred power circuits were not capable of meeting their safety

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des,gn bases, if they assumed a nominal switchyard voltage of 345 kV. In order to assure adequate voltage to safety-related equipment from the off-site power supply, the licensee raised the allowed minimum switchyard voltage assumed in Calculation ZZ-62, to 1.028 times nominal or 354.7 kV. The calculation demonstrated that operation with the switchyard voltage below 354.7 kV, could result in inadequate voltage to safety-re'ated components from the off-site supply during accident condition Therefore operation below 354.7 kV, i.e., in an unanalyzed condition, would call into question the operability of the offsite power suppl ,

The team noted that the analysis was based on worst-case loading assumptions; therefore, operation with switchyard voltages below 354.7 kV would not automatically l indicate that the off-site power supply was inoperable. However, operation outside of '

the analyzed configuration should immediately be evaluated to determine the operability of the off-site power suppl The calculation indicated that Procedure OSP-NB-00001, " Operations Surveillance Procedure for Class 1E Electrical Source Verification," Revision 8, required that the switchyard voltage be maintained at a minimum of 354.7 kV. Because of Calculation ZZ-62's reliance on Procedure OSP-NB-00001 to assure compliance with the safety i design bases for the off-site power supplies, the team reviewed the procedur The team found that Procedu.e OSP-NB-00001 was performed once per 7 days,in part, to complete the surveillance requirement specified in Technical Specification 4.8.1. The team confirmed that Attachment 3 of Procedure OSP-NB-00001," Switchyard

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Status," specified that 345 kV (nominal) switchyard Buses E1 A and E1-B should be maintained between 354.7 kV to 372.6 kV. The team reviewed several months worth of data sheets taken in accordance with Procedure OSP-NB-00001 and did not identify any instances where the logged voltage was below the required minimum valu The team also reviewed computer print-out logs of switchyard bus voltages from November 1995 to present, which were collected per Procedure ODP-ZZ-00016,

" Reactor Operator Watch Station Practices and Log," Revision 38. The team found that,in every month since December 1995, switchyard voltages at Bus E1-B were recorded that were below the minimum acceptable value of 354.7 kV, and no action was taken to determine the operability of the off-site power supply. The licensee initiated Suggestion / Occurrence / Solution Report 98-3526 to address this issu The team found that Procedures OSP-NB-00001 and ODP-ZZ-00016 did not provide for adequate operator response to indicated low switchyard voltages in that neither of the i procedures required operator action to determine operability of the off-site power supply dunng operation in an unanalyzed condition,. i.e., below 354.7 kV. In addition, Procedure ODP ZZ-00016 did not include the acceptable voltage rang The licensee issued TCN 98-0655 to require operators to contact engineering for input into an operability determination when voltage readings were below the minimum analyzed value during performance of Procedure OSP-NB-00001. To address the possibility of shorter-term voltage fluctuation (conditions lasting less than seven days),

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i During this inspection, the licensee evaluated the past operability implications of the j

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voltage readings for Bus E1 B and determined that the readings were suspect. Bus B

voltages were erratic as compared to Bus A. Bus A and B voltages should have indicated near the same value because the buses were tied together in the switchyar The licensee suspected a malfunctioning sensor and issued Work Request W19149 to

troubleshoot the cause for the low-voltage printout. As a result of this troubleshooting, l the licensee replaced the switchyard voltage transducer (sensor) and subsequent voltage readings correlated with Bus The team learned that the same sensor provided voltage readings for the main control board voltmeter; therefore, there was reason to believe that the readings from December 1995 onward may have been in error also, and this error may have remained undetected. The licensee noted that Procedure OSP-NB-00001 specified that the l j

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voltage readings be taken f om the main control board analog voltmeters, which did not i have a very precise scale. In addition, they noted that the loop readings were averaged )

by the equipment in the control board analog voltmeter and voltage recorder loops.

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They further noted that the voltage readings that were logged in accordance with j Procedure ODP-ZZ-00016 were collected from the plant computer, which had a digital

output that reflected the sensor output at a specific instant in time (i.e., it was not time averaged). The licensee determined that the averaging effect had resulted in Bus B ;

readings that were within the required minimum and maximum values and; therefore, the sensor failure was not detected. They planned to develop a preventive maintenance instruction to verify and calibrate the indication for Bus A and B voltage Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33," Quality Assurance Program Requirements (Opeartion)," dated February 1978. Appendix A, Sections 3 and 8.a. recommend that procedures of a type appropriate to the circumstances be provided to ensure that readout instruments are properly calibrated and adjusted at specified periods to maintain accuracy and that procedures be developed for operation of the access circuits to the off-site electrical

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system. The failure to establish preventive maintenance instructions to assure reliable indication of switchyard voltages and the failure to establish procedures that assured ;

evaluation of potentially inoperable off-site power supplies is a violation of Technical

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Specification 6.8.1 (50-483/9818-03).

The team determined that this inspection report adequately described the reasons for l this example of the violation, and the actions taken to correct and prevent recurrence of the violation. Therefore, no iesponse to this violation is required for this example

Conclusions Af ter the licensee corrected an inaccurate calculation assumption identified during the inspection, they were able to demonstrate that the preferred off-site power supply circuits had adequate capacity to meet the safety design bases listed in the Final Safety Analysis Report. The failure to adequately check the calculation assumptions was one example of a violation of 10 CFR Part 50, Appendix B, Criterion V," Procedures, d

Instructions, and Drawings." No response was required for this example of this violatio _- ---

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For almost 3 years the licensee routinely logged switchyard voltages that were below minimum analyzed values without recognizing that an operability determination should have been performed. The below minimum readings were determined to have been caused by a failed voltage sensor. The failure to establish preventive maintenance instructions to assure reliable indication of switchyard voltages and the failure to establish procedures appropriate to the circumstances, which assured evaluation of potentially inoperable off-site power supplies, was a violation of Technical Specification 6.8.1. No response was required for this violatio E1.2.2 Emergency Diesel Generator Loading and Voltage Recovery Inspection Scope The team performed a review of Design Guide EE-003, " Electrical Load Growth,"

Revision 0, iscued January 22,1993, and Revision 1, issued December 27,1995, and Drawing E-21005, " List of Loads Supplied by Emergency Diesel Generator,"

Revision 21, to determine if the design guide had been followed for changes to the electrical configuration that affected the emergency diesel generator. The team noted that Drawing E-21005 was actually a calculation that documented the totalloading on the emergency diesel generato The team performed a review of Drawings E-21005 and M-018-0389, " Analysis of Load Table and Predictions of Voltage and Frequency Excursions at the Various Load Step Conditions," Revision 1, with the objective of determining whether the emergency diesel generators had been appropriately sized to start and power their connected loads, including all ESW oumps, fans, valves, and auxiliaries. Drawing M-018-0389 was actually a calculation that documented the results of the emergency diesel generator transient analysi Observations and Findinos Load Growth The team noted that Design Guide EE-003 required load growth Form CA-2218 to be completed and evaluated for modifications that added or subtracted electrical load. The team questioned the fact that Drawing E-21005 did not include load values for spare Battery Chargers NK-25 and NK-26, since these chargers were always energized by design. The team asked the licensee for a copy of the design modification package used to install spare Battery Chargers NK-25 and NK-26, including the appropriate load growth for The licensee produced Form CA-2218 (issued on July 12,1994, which had been completed for Modification CMP 92-1014, " Addition of Swing Battery Chargers for the Class 1E DC Battery System," Revision A, FCN 1 to 14. The form identified the need to revise Calculations ZZ-62 and ZZ-179, "AC Bus Load Lists," but not Drawing E-2100 Based on the team's observation, the licensee initiated Suggestion / Occurrence / Solution Report 98-3477 and Request for Resolution (RFR) 19304 to update Drawing E-21005 to reflect Modification 92-1014. The licensee also initiated a review of the current loads

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listed on Drawing E-21005. This failure is identified in the next section as a nortion of an example of a violatien of 10 CFR Part 50, Appendix B, Criterion Voltage Recovery Drawing M-018-0389 was the applicable calculation for determining emergency diesel generator voltage recovery. The calculation was a generic Vendor calculation that was last issued on March 14,1980; it referenced Drawing E-21005, Revision 2, as a source document. The current issue of Drawing E-21005 was Revision 21. Because of this time difference and the fact that Drawing M-018-0389 was not a site-specific document, the team noted a number of inconsistencies in loads and load ratings between the two documents. In addition, the notes relating to the starting / stopping of various loads differed significantly between the two document Based on the team's observations, the licensee acknowledged that there were minor changes but assured the team that the calculation remained a bounding document with unchanged conclusions. Nonetheless, the licensee marked up a table from Drawing M-018-0389 and superimposed the latest load values from Drawing E-21005, Revision 21. Though the team concurred with the licensee's reassessment that the changes were not significant enough to affect the conclusions, the team noted that loads in Steps 1,3, and 3A had increased and; therefore, Drawing M 018-0389 no longer provided a bounding calculatio Based on the team's observations, the licensee issued Suggestion / Occurrence / Solution Report 98-3508 to evaluate or document the changes to Drawing M-018-0389. The Suggestion / Occurrence / Solution Report noted that, though the load may have been evaluated, it was not documented on the load addition Form CA-2218 or not documented in the design input report or safety evaluatio Procedure EDP-ZZ-04005," Design Development," Revision 30, Section 4.6.1, stated that if existing calculations were impacted by modificata ns, then the calculations were revised as needed. Procedure EDP-ZZ-04023,"Calcuutions," Revision 14, Section 4.3, required that if a new or revised calculation aflects the conservatism of an existing calculation, either increasing or decreasing the conservatism, the preparer must either revise the affected calculation or prepare and addenda that referenced the latest calculation. As of October 2,1998, Drawing M-018-0389 had not been revised nor had an addendum been prepared to address load changes documented since March 19, 1985, in Revisions 3 through 21 of Drawing E-2100 In addition, the licensee failed to identify the need to revise Drawing M-018 0389 as required by Design Guide EE-003, " Electrical Load Growth," Revision 0, dated

, January 22,1993, and Revision 1 dated December 27,1995, for load additions affecting emergency diesel generators voltage recovery. Design Guide EE-003 stated under Section 6.1, "For all modifications that add or subtract electric load, form CA-2218 must be completed and routed to the electrical design control supervisor." Section 6. further stated, "The possible calculations that may be affected were listed in Section 3."

Section 3.15.22 listed Drawing M-018-0389. Procedure APA-ZZ-00600," Design

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Change Control," Revision 19, Section 3.8.7.2, repeated the above requirement relating to Form CA-221 CFR Part 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings,"

states, in part, that activities affecting quality shall be prescribed by procedures appropriate to the circumstances and shall be accomplished in accordance with these procedures. Procedures shallincfoda app opriate acceptance criteria for determining that important activities have been satisfactorily accomplished. The failure to update Drawing E-21005 to include the spare battery chargers and the failure to update Drawing M-018-0389 9 reflect electricalload growth is an example of a violation of 10 CFR Part 50, Appendix B, Criterion V (50-483/9818-02).

The licensee initiated Request for Resolution (RFR) 19342A to perform an evaluation /

assessment of the current emergency diesa generator load table and available marpin The licensee also planned to make any necessary revisions to Drawing M-018-0038 .

l TPn team determined that this inspection report adequately described the reasons for l

this example of the violation, and the actions taken to correct and prevent recurrence of the violation. Therefore, no response to this violation is required for this example Random Loads The team also noted that Drawing M-018-0389 failed to include the random loads with each starting step. Random loads were those loads that were controlled by process signals such as temperature, level, pressure, etc. and could be assumed to start anytime. The licensee responded that most of the random loads were so small that they would have no meaningful effect on the emergency diesel generator's capability. Larger !

random loads, such as the ESW cooling tower fans, were blocked from starting during the emergency diesel generator load sequencing. The team concurred with the i licensee's respons c. Conclusions Emergency diesel generator load growth was not being tracked and evaluated in accordance with applicable design control procedures. Specifically, Drawing E-21005, which listed all connected loads on the emergency diesel generators, was not updated to reflect the loads added in Modification 92-1014. In addition, Drawing M-018-0389, the analysis of load table and predictions of voltage dip and frequency excursions at the various load step conditions for the emergency diesel generators, had not been updated since March 19,1985 to evaluate the impact of load changes documented in Drawing E-21005, Revisions 3 through 21 As a result, the licensee had not recognized that the calculation for determining emergency diesel generator voltage recovery was no longer bounding. The failure to update or reassess load additions affecting emergency diesel generator voltage recovery, as required by design control procedures, was one example of a violation of 10 CFR Part 50, Appendix B, Criterion V, " Procedures, Instructions, and Drawings." No response was required for this example of this violatio . . - - . - - . - - . - - - - - . - - - . - - - - - - . - _ . _ -

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E1.2.3 Short Circuit Withstand Capability Inspection Scoce

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The team reviewed Calculation ZZ-145, "Short Circuit Calculation," Revision 1, and Addendum 1 and 2, to determine if all ESW switchgear and circuit breakers could

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withstand and interrupt the fault currents that would be presen Observations and Findinas

, The team noted that though Calculation ZZ-145 was a site-specific hand calculation, it utilized many generic inputs rather than site-specific inputs. The team questioned the basis for Assumption 4 relating to the maximum fault contribution of 1730 amperes to

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the 13.8 kV buses from site loads. The source reference for this value was an architect-engineer letter stating that 1730 amperes was the value for another plant of similar design (Rochester Gas & Electric's Sterling Plant).

The licensee stated that it believed the generic value was bounding but would run a site-specific calculation to confirm this understanding. The licensee produced a

preliminary calculation showing that the fault contribution was in fact 1760 ampere Based on the knowledge that the generic value may not be bounding, the licensee issued Suggestion / Occurrence / Solution Report 98-3468 to update Calculation ZZ-145.

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The licensee concluded that this increase in fault contribution was insignificant because of other over-conservatisims in the calculation. The team agreed. The failure to adequately check the assumptions in this caicalation constitutes a violation of minor significance and is not subject to formal enforcement actio Conclusions Calculation ZZ-145, "Short Circuit Calculation," Revision 1, and Addendum 1 and 2 demonstrated that all ESW switchgear and circuit breakers could withstand and interrupt the fault currents that would be presen E1.2.4 Compliance with Regulatory Guide 1.106 Insoection Scoce The team performed a review of ESW motor-operated valves to verify compliance with Final Safety Analysis Report statements relating to the licensee's stated position on Regulatory Guide 1.106, " Thermal Overload Protection for Motor Operated Valves,"

Revision 1, March 197 l Observations and Findinos i The thermal overload relays of all ESW motor-operated valves were bypassed during  !

normal power operation. The discussion in Appendix 3A referring to Regulatory Guide 1.106 stated,"The Recommendations of this regulatory guide are met. Refer to l Section 8.3.1.1.2." l

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Regulatory Guide 1.106 contained very specific implementation requirements for dealing with the situation where thermal overload protection devices were continuously bypasse The team's review focused on determining whether the Regulatory Guide had been l followed, particularly with respect to the concern expressed in both the " Discussion" section and the " Regulatory Position" section. When thermal overload protection devices were bypassed, these sections emphasized that it was important to ensure that the bypassing did not result in Popardizing the completion of the safety function or in degrading other safety system It was the team's determination that there were certain failure modes that could both l jeopardize the completion of the safety function and degrade other safety systems. The l team identified four devices in the motor-operated valve circuitry whose failure could degrade other safety systems: the motor, the circuit breaker, the contactor, and the thermal overload devic Upon experiencing a rnotor-operated valve malfunction that would result in a locked rotor condition, neither the motor, the thermal overload device, the contactor, nor the breaker was designed to carry locked rotor current for more that brief periods of tim Failure of one or more of the four was imminent because they were being operated beyond their design parameter Failure would result in either an open circuit or a short circuit. If a short circuit, whether three phase or phase to ground, the breaker associated with the motor-operated valve could not be relied upon to trip successfully because it could be prestressed from carrying a current in excess of its design rating, therefore, the upstream motor control i l center incoming breaker could trip and deenergize the entire motor control center. As a !

l consequence, other safety-related systems connected to the motor control center may l

be without power and, therefore, would be degrade In bypassing the thermal overload relays, completion of the safety function could also be jeopardized. In this mode with torque switches bypassed during opening and closing

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strokes, no protection would be provided for the motor-operated valve As a result, if the I motor-operated valve motor or valve was damaged, such that it was rendered incapable

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of further movement, the completion of the initial safety function or subsequent safety functions both automatic and operator initiated would be jeopardized.

l l By Letter DC 93-368, " Evaluation to Remove MOV Core Load Jumpers," dated July 29, 1993, the licensee reevaluated the need to bypass the thermal overload relays. The licensee acknowledged that a number of motor and contactor failures were experienced but concluded that no significant increase of overall plant safety would result from removing the jumpers, and the thermal overload relays would, therefore, remain bypassed as designed. The issue of compliance to the Regulatory Guide 1,106 requirements applicable to bypassing was not part of this lette Based on the team's questions, the licensee provided an analysis to show that the requirements of Regulatory Guide 1.106 were met. The analysis was provided as Letter NED 98-162, " Bypassing Thermal Overload Protection of Motor Operated Valves,"

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dated September 29,1998. The analysis demonstrated that through coordination of the l thermal capabilitie', of components, proper sizing, and improved maintenance practices motor-operated valve failures had been minimized. The licensee believed that these l good practices were indicative that the requirements of Regulatory Guide 1.106 had been considered when deciding to bypass the thermal overload relay Conclusions

The team concluded that based on information provided by the licensee, the design for l bypassing thermal overload relays met the intent of Regulatory Guide 1.10 I E2 Engineering Support of Facilities and Equipment (93809)

E2.1 Essential Service Water Mechanical System Surveillance Testino Inspection Scope

The team reviewed the licensing and design basis documents related to surveillance I testing of ESW mechanical components. This review included the applicable Technical Specifications and surveillance test procedures and focused on the capability of the

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ESW system to provide adequate cooling water supply to the CCW heat exchangers, l containment coolers, emergency diesel generator heat exchangers, and area room coolers. Thermal performance data for the CCW heat exchanger and selected room coolers was also reviewe Observations and Findinos Essential Service Water Pump Testing l

Surveillance Procedures OSP EF-P001 A & B," Essential Service Water Pump Test,"

Revision 27, documented the ESW Pump A & B quarterly inservice performance test performed on July 8 and July 22,1998, respectively. It was noted that the normal and alert range acceptance criteria documented in the procedure were consistent with the licensee's inservice test (IST) program commitments. The required action differential pressure limit (low) established in the procedure for the "A" pump was <129.86 psid and

<136.5 psid for the "B" pum As discussed in Section E1.1.1, the licensee had not developed a calculation to confirm the system design would support adequate flow for all allowed pump degradations. The licensee stated that reliance was placed on frequent flow monitoring to detect degradation, which would compromise required flows to safety-related equipment. This monitoring consisted of monthly flow verification to the containment coolers, the CCW heat exchangers, the emergency diesel generator heat exchangers, and a once per operating cycle ESW flow balance that verified flows to all component The team noted that the monthly flow verification did not include verification of flows to any of the room coolers, nor was a dummy load added to model the flow that may be required by the AFS system, although the test did cover approximately 90 percent of the

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required flows. It was the team's concern that degradation may not be detected in the interim period between the monthly flow verification and the once per operating cycle total flow balance since the monthly test did not cover all the flow demand While the monthly test did not include acceptance criteria that specifically accounted for flow that may be diverted to the AFS system or to the room coolers, the licensee stated that they informally monitored these test results to assure adequate flow was available for all design basis requirements. As discussed in Section E1.1.2, the team found that the licensee had proactively replaced an ESW pump, prior to reaching the action limit, based on an adverse pump performance trend. The licensee stated that analysis of these monthly tests contributed to the timing of the decision to replace the pum The team requested the licensee's response to NRC Information Notice 97-90, "Use of Nonconservative Acceptance Criteria in Safety Related Pump Surveillance Tests." The information notice addressed inadequacies in surveillance test acceptance criteria and cautioned that if only the ASME cou acceptance range was used, more restrictive design basis requiremtnts may be violated. The licensee response stated that an evaluation of the IST pump acceptance criteria was fully consistent with Technical Specification requirements. However, the team identified that more restrictive requirements may appear in design basis analyses and documents other than the Technical Specifications. A further review by the team revealed that design basis calculations existed for all safety related pumps at their degraded condition except for the ESW and CCW pumps. As a result of the team's question, the licensee issued Suggestion / Occurrence / Solution Report 98-3530 to perform a followup review of the response to the information notice and to evaluate the CCW and ESW systems to determine if a formal hydraulic or analytical analysis needs to be perfom ed for these system Subsequent to the inspection, the licensee performed Calculation EF-68, Revision 0, Addenda 2, to more comprehensively demonstrate system capability. They determined that with the system in the Post-refueling Outage 9 flow balanced condition, assuming a 2311 gpm AFS demand and assuming the ESW pump was degraded to the action limit, the ESW system would still perform its design function. Based on this additional information, the team determined that, while all design bases calculations had not been developed, the licensee's testing practices were aggressive and had adequately assured system performanc Essential Service Water Flow Verification to The Containment Coolers The team reviewed the containment cooling system, Technical Specification 4.6.2. surveillance requirements, and the associated surveillance, Procedure OSP-EF-P001 A/B, which was also used for the quarterly pump IST test, in addition to measuring flow to the containment cooling system, the licensee optionally chose to verify flows to the CCW heat exchanger and total system flow. The team verified that acceptance limits from the Technical Specifications were based on design Calculation M-EF-52 and were properly included in the surveillance procedure. The team noted that

! during the monthly test, no simulated load was included that would represent f!ow to the

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l l AFS system. However, the licensee monitored total system flow to assess system l degradation.

l Essential Service Water Flow Balance Verification Surveillance Procedures ETP-EF-0002A & B," Essential Service Water Train A(B) Flow ,

Verification," Revision 1, were reviewed. These procedures were used to perform the )

ESW flow balance verification that was performed once per refueling cycle. Data

! reviewed was collected during the Refuel 9, Operating Cycle 10, flow balance; completed procedures were signed off by the licensee on April 27 and April 18,1998, for the ESW "A" and "B" trains respectively. All collected flow balancing data met or exceeded the design acceptance criteria established in Design Calculation M-EF-5 The team confirmed that the referenced flow balancing procedures mimicked the flow to

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the AFS system by opening ESW isolation Valve HV-59, which was located downstream l of the CCW heat exchange Essential Service Water Thermal Performance Testing The team reviewed Procedure ETP-EG-00001," Component Cooling Water Heat Exchanger Test," Revision 2, and completed data dated April 4,1998. The heat exchanger calculation methodology was reviewed and found to be acceptable. Based j on the data collected, the licensee determined by analysis that total heat exchanger I fouling was at an acceptable value of .0001, which was less than the design basis fouling of .0025, documented on the heat exchanger specification data shee l l The team reviewed Procedure ETP-GL-00001," Area Room Cooler Coil Test,"

Revision 3. It was noted by the licensee that only the Auxiliary Building Penetration Area Room Coolers SGL15A & B were tested. The team reviewed test data collected for the last five tests on SGL15A & B and determined that minimum effectiveness values for all tests exceeded the acceptance criteria documented in the test procedure and; i therefore, the coolers met the design basis performance requirements. Acceptance l criteria design inputs were acceptably derived from Design Calculation M-EF-52. The i licensee stated that the remaining room coolers were not tested, since their respective heat loads were not large and that a test would not be meaningful. In order to assure operability of the untested coolers, the licensee performed similar preventive maintenance on both the tested and untested coolers. They periodically flushed coolers and also routinely cleaned the tube Conclusions The team was able to co clude based on review of surveillance procedures and data gathered during the performance of the surveillance tests that the ESW system was capable of providing sufficient flow to meet design basis flow requirement Surveillance test data also substantiated that the CCW heat exchanger thermal performance met design basis requirements. Room cooler thermal performance met design basis requirements based on review of data gathered from Room Cooler

! SGL15A & B test results. With the ex ntion of the lack of a design calculation that established ESW pump differento '

e and tiow acceptance criteria for the pump

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IST test, all procedures contained acceptance criteria derived from design basis :

analysis. In all cases reviewed, acceptance criteria were selected with significant positive margin. System operability was assured because of the licensee's good work l practices, which included frequent surveillance testing and degradation trending and ,

frequent preventive maintenanc I E2.2 Essential Service Water System Walkdown l l Inspection Scone '

The team performed a walkdown of the accessible portions of the ESW system to verify that the system configuration was consistent with the design basis. The walkdown included portions of the auxiliary building, control building, and the ESW pump hous The team a!so conducted a walkdown of ac and de electrical systems and equipment l that supported the ESW Syste Observations and Findinas The team noted that the control building basement, Room 3101, appeared to be vulnerable to flooding. The team's concern was that the ESW/SW cross connect redundant motor-operated isolation valves were located in this area for both trains. The licensee provided Calculation XX-49, " Control Building Flooding - Maximum Flood Level Due to a Pipe Break of Crack," Revision 0, for review. The analysis postulated that the worst case break / crack would be a moderate energy crack in one of the four 30-inch l nonsafety-related service water lines. The assumption for this calculation was that a crack, instead of a guillotine break, would occur since the 30-inch service water line was seismically supported. The analysis showed that these valves would not be compromised by flooding in this are The team noted that the system configuration was consistent with the piping and instrument diagrams. It was noted that the equipment and piping layout for most areas l walked down permitted abundant and easy access to areas around equipment.

l Housekeeping was goo The team made note of the tap settings on the main transformers, the unit auxiliary transformer, and the safeguard transformers. These tap settings were later compared l to the tap settings used for the same transformers in Calculation ZZ-62 and were found l to be identica In the control building, the team noted that de switchboards were connected to dc switching cabinets with short lengths of rigid conduit. Switchboard NK01 was connected to Cabinet NK71, Switchboard NK02 was connected to Cabinet NK72, Switchboard NK03 was connected to Cabinet NK73, and Switchboard NK04 was connected to Cabinet NK74. The team questioned whether this configuration had been analyzed seismically for acceptabilit The licensee responded that the installation o' :ne conduits was in accordance with architect-engineer standards and did not invai,date the seismic analysis and testing of the individual switchboards and cabinets. The architect-engineer's standard Drawing

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E-2R8900," Raceway Notes, Symbols and Details," Revision 64, stated that, "Only flexible conduits shall be fastened to any equipment, which requires seismic qualification except when the installation is such that the equipment and the last support for the conduit are attached to the same surface (plane), in this case either flexible or rigid conduit may be used." Since both the switchboard and the cabinets were on the same plane, the latter requirement was applicable to the installation, and rigid conduit was acceptabl In addition, the licensee stated that, " Flexing of the outer cabinet skins of the respective cabinets would absorb any differential movement between the cabinets."

The team concurred with the licensee's responses, Conclusions Based on the areas walked down, the ESW system configuration was consistent with the design basis. Housekeeping was good. The team concluded that the transformer tap settings recorded were appropriately included in calculations and that there was no seismic concerns with the rigid conduits that connected the identified switchboards and cabinet E2.3 Essential Service Water Rooms Minimum and Maximum Temperatures Inspection Scope The team evaluated the minimum and maximum temperatures in the ESW pumphouse and the ultimate heat sink cooling tower electrical rooms to determine the vulnerability of electrical equipment to low and high ambient temperature Observations and Findinas The team evaluated the licensee's compliance with Final Safety Analysis Report Section 9.4.8.2.3, which stated that the minimum design temperature for the ESW pumphouse was 50* F. The licensee indicated that the referenced 50' F minimum temperature in Final Safety Analysis Report, Section 9.4.8.2.3, was stated as a power generation design basis in Final Safety Analysis Report, Section 9.4.1.8.2, and not as a safety design basis. As such, the temperature limit was dictated by personnel comfort and not by any equipment minimum temperature requirements. The heating in the pumphouse consisted of nonsafety-related unit heaters powered by Safety Class 1E motor control centers. These unit heaters were tripped during accident conditions (when a safety injection signal was present); however, the licensee stated that pump motor ambient heat losses exceeded the capacity of unit heaters and would provide adequate room heating during accident condition The team observed very hot and humid conditions in the ESW pumphouse and the ultimate heat sink cooling tower electrical rooms, and questioned whether the electrical equipment had been analyzed for the maximum temperatures that would be experience .. . ..

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The team noted that ventilation was provided by room ventilation fans; however, these fans did not start automatica'ly unless the room temperatures were above 65* F and the associated pumps or cooling tower fans had started. Alternatively, the ventilation fans could be started manually prodied the room temperature was above 65* F. The team noted that room temperatures were remotely monitored by wall mounted temperature detectors, but questioned the licensee whether the detectors were reading temperatures that were representative of the temperatures in the vicinity of the electrical equipmen The team was concerned that without the pumps or fans running and without manual start of the ventilation fans, the electrical equipment in the rooms would experience prolonged high temperature conditions that could cause premature degradation. This concern would be heightened in the event that the remote temperature readouts were not representative of temperatures in the vicinity of the electrical equipmen The tearn, together with the licensee, conducted a walkdown of the areas of concer Using a calibrated portable temperature detector, readings were taken adjacent to the wall mounted detectors and at various points around the electrical equipment. The results revealed that, for the most part, the temperatures in the vicinity of the electrical equipment in each room were within 2* F of the temperature recorded at the wall mounted detectors. As an exception, the highest temperature observed around the electrical equipment in the ultimate heat sink Cooling Tower "A" electrical room was

+5* F above that of the wall mounted detecto The licensee indicated that the wall mounted detectors alarmed at 7 to 8' F below the 122* F maximum ambient temperature rating of electrical equipment and, therefore sufficient margin existed to accommodate these temperature differences. The tear,i noted that the worst case 2 F margin may not allow much time for operator rest 7nse before equipment temperature limits were exceede Conclusions The team concurred that the design for assuring minimum and maximum temperatures in the ESW pumphouse and the ultimate heat sink cooling tower electrical rooms did not present a hazard for the electrical equipment contained in these room E2.4 Essential Service Water System Health Inspection Scoce The team performed a walkdown of the major system components including electrical power supplies. Reviews of the system health reports, Suggestion / Occurrence / Solution Reports, and outstanding system maintenance activities were conducted. Additionally, the maintenance rule program was evaluated as it related to the syste Observations and Findinas The team toured applicable plant areas observing system components and surrounding structures. During the walkdown, ESW System Train A was running. The team noted

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some vibration of system piping and components, particularly, in the vicinity of smaller heat exchanger The team also noted a number of vibration-induced failures of system valves while reviewing the maintenance history of the system. These included: l l

Valve vibrated closed breaking lock wire

Frangible lock broken and throttle valve mispositioned

Cracked yoke on Valve EFV0058 l

l Although each specific failure was repaired or corrected, a broader evaluation of system vibration induced problems had not been conducted. The team noted that these failures had not been evaluated by engineering to determine whether broader corrective actions were needed. Further inspection is planned to review future system maintenance and availability for evidence of system vibrations negatively affecting system health. This item will be tracked as Inspection Followup ltem 50-483/9818-0 The team found that most of the open Suggestion / Occurrence / Solution reports that related to the ESW system and system components were minor material condition problems. However, four reports related to maintenance preventable functional failures, and an additional four related to the failure of both trains to meet unavailability and functional failure goals. The failure to meet these goals caused the licensee to monitor both trains in accordance with 10 CFR 50.65 a(1), " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The team reviewed the licensee's actions and monitoring of the system train Corrective actions were taken to improve outage times, repair failed components, and better assess unavailability during system outages. Monthly reports indicated that system unavailability remained well under prorated goals for the cycle. No maintenance preventable functional failures had been identified during the current cycle. The team found that the licensee's corrective actions had been appropriate and that rnonitoring efforts met the Maintenance Rule requirement Conclusions System walkdowns combined with a review of Suggestion / Occurrence / Solution reports, Maintenance Rule reports, and system health reports indicated that the ESW system was in good material condition. However, observed system vibration in the vicinity of smaller heat exchangers and several vibration induced failures need to be evaluated generically for the affect on other system component E2.5 Computer System Comoliance for the Year 2000 Inspection Scop _e The team reviewed the license 9's program to evaluate computer systems and microprocessors for continued tanctionality beyond the year 2000. The scope, problems identified, and status were reviev.9d. Four computer systems were selected for further

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assessment: the security system, response time test equipment processors, the plant computer, and the digital radiation monitoring syste l Observations and Findinas The team reviewed the monthly status report," Year 2000 Project." The identification of all components / applications with the potential to be affected by the change of millennium had been completed. This review resulted in 1295 items to be verified. The project verifications were approximately 62 percent complete with the verifications of all remaining components / applications in process. The implementation of remediation items was scheduled for completion on December 31,1998, with final testing to be completed by July 1,199 Significant line items in the licensee's plan were reviewed. The main plant computer was determined to have a noncompliant operating system. Licensee engineers have developed a test laboratory module and were in the process of testing the compliance of the new operating system. An evaluation of the computer system routines has determined that no coding problems existed. Some of the extraneous routines may have compliance problems. However, the licensee has determined that these routines would not affect plant operation The team assessed information provided regarding the RM 11 digital radiation monitoring system. The supporting computer hardware main frame was not complian Licensee engineers stated that system sampling, monitoring, and alarming functions were not affected and were year 2000 compliant. The affected equipment involved the operator interface and the safety parameter display system portions of the syste Plans to replace the main frame with dual 586 microprocessor chips were in plac The plant security system and access controls were determined to be noncomplian The access system software and many hardware components were affected. The licensee planned to replace the main computer, system card readers, multiplexers, and software. Additionally, plans to replace the protected area access controls and badges to include retina scanning equipment were in place. These changes and upgrades were being monitored and reviewed by NRC security specialist Finally, the team assessed remedial actions planned for the solid state prctection system response time test equipment. The equipment utilized noncompliant single-board processors. At the time of this inspection, licensee personnel were evaluating whether to replace the processors or establish administrative controls to resolve this proble Conclusions The team determined that the licensee had established a reasonable program to identify and address computer compenents/ applications that would not operate properly beyond j the millennium Corrective actions for the specific items reviewed were appropriate and

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being implemented in a timely manner. The schedule and schedule adherence supported completion of the project prior to December 31,199 l I

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E3 Engineering Procedures and Documentation E Review of the 10 CFR 50.59 Safetv Evaluation Procram insoection Scoce (37001)

The team reviewed components of the licensee's unreviewed safety question determination program. Several formal safety evaluations and screening evaluations were reviewed. Procedural guidance for implementing safety evaluations, updating the Final Safety Analysis Report, and maintaining related records were reviewed. The following administrative procedures were reviewed:

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Procedure APA-ZZ-00140," Safety, Environmental, and other Licensing Evaluations," Revision 25,

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Procedure APA-ZZ-00108," Primary Licensing Documents: Change / Revision Process," Revision Observations and Findinas The team reviewed the programmatic procedures to ensure that the formal guidance provided in Procedure APA-ZZ-00140 properly implemented the requirements of 10 CFR 50.59. The guidance included assessing and documenting whether 10 CFR 50.59 applied and whether a change to the plant Technical Specifications was involved. Maintenance of records and reporting requirements were also include Procedure APA-ZZ 00108 was reviewed to ensure that procedural guidance required that the Final Safety Analysis Report be updated for all changes made in the facility or procedures as described in the Final Safety Analysis Report. Review and approval of these changes included the responsibilities to ensure that the Final Safety Analysis Report and other licensing documents were properly update The team reviewed safety evaluations' and evaluation screenings for changes to the ESW and other systems. The evaluations properly implemented the requirements of 10 CFR 50.59 and no unreviewed safety questions were identified. Records requested were readily retrievable and supported the subject changes. Additional evaluations and programmatic changes were reviewed and evaluated as documented in Sections E8.4, E8.5, E8.6, and E8.7 of this inspection repor Conclusions Procedural guidance was in place to ensure that changes to the plant were properly evaluated in accordance with the requirements of 10 CFR 50.59 and to appropriately update the Final Safety Analysis Report. The safety evaluations reviewed were well documented and properly concluded that no unreviewed safety questions existe _ - - _ _ _

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E3.2 Calculation Modification Proaram Insoection Scoce (37550)

The team reviewed the licensee's control and use of design calculations related to design modification Observations and Findinas The team discussed the calculation process with the licensee to determine if affected calculations were reconciled when a design input or calculation was revised. The

, licensee stated that two engineering department procedures govern calculation control.

j The team reviewed the first of these procedures, Procedure EDP-ZZ-04005," Design Development, Revision 30. Section 4.6.1 of this procedure stated that if existing calculations were impacted by a modification, then existing calculations were revised, as needed. Additionally, this procedure stated in Section 4.6.2 that, if needed, new or revised calculations were performed to document / verify compliance or deviations from existing design inputs. The team also reviewed engineering department Procedure EDP-ZZ-04023," Calculations," Revision 14. Section 4.3 of this procedure stated that the preparer was responsible for performing the calculation in accordance with this

procedure. If the new or revised calculation affected the conservatism of an existing calculation, either increasing or decreasing the conservatism, the preparer must revise or addend the affected calculation referencing the latest calculatio Conclusions The team concluded that adequate procedural controls were in place to ensure that affected calculations would be reconciled when new or revised calculations were

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E (Closed) Violation 50-483/9705-01: Failure to Report 14/20 Main Steam Safety Valve failures during Refueling Outage Backaround Following the failure of multiple main steam safety valves during Refueling Outage 7, licensee personnel had failed to issue a licensee event report in accordance with 10 CFR 50.73. The licensee stated that the cause of this violation was the failure to adequately consider all reporting requirements and their applicability to the surveillance testing of main steam safety valve Insoection Followuo As corrective action, the licensee submitted Licensee Event Report 50-483/97-007 to report the subject conditions. Additionally, the event was reviewed with the personnel responsible for making and approving reportability determinations. As described in

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Section E8.9 of this inspection report, the report adequately documented the evaluation ,

and corrective actions related to the main steam safety valve failure l l

E (Closed) Inspection Followuo item 50-483/9705-02: Review analysis to support an increased setpoint tolerance for the pressurizer safety valve to verify that accident analysis assumptions were maintaine I Backaround l

Suggestion / Occurrence / Solution Report 96-1273 documented that a pressurizer safety l valve opened 2.31 percent below setpoint. This exceeded the Technical Specification allowable tolerance of +/- 1 percent. A vendor supplied analysis stated that the l out-of-tolerance condition was enveloped by the accident analysis. However, the letter I stated that a change in the setpoint tolerance to +/- 3 percent would require changes in accident analysis calculations. This followup item was opened to review the calculations when availabl Inspection Followup Licensee personnel stated that they were currently pursuing a change in the setpoint tolerance to +/ 2 percent. A sensitivity analysis was in process to determine if the tolerance could be adjusted. The team noted that any change to the pressurizer safety l valve setpoint tolerance would require a change to the Technical Specifications. As such, NRC staff review and approval of the analysis would be required prior to implementatio The team reviewed the performance testing data available for each valve. Early i performance of the valves indicated that the valves had routinely been within a 2 percent tolerance of the desired setpoint. Two of the valves had been installed for approximately 15 effective full power years before removalin Refueling Outage 9. All three valves exhibited pitted seats and discs, inaccurate ring settings, and intermittent l seat leakage. The valves were tested by an off-site vendor and the setpoints were out-of-tolerance by -3.14 percent, -2.94 percent, and -1.53 percent respectivel Licensee engineers surmised that replacing the valves with refurbished valves each cycle would increase reliability and decrease setpoint drift. The replacement valves installed in Refueling Outage 9 had operated for a cycle at Wolf Creek Generating Station, a sister plant. The valves had been tested and the as-found lif t was well within the 2 percent tolerance. The team determined that replacement of the pressurizer safety valves was a reasonable corrective actio The team reviewed letters from the vendor dated February 26,1997, and July 16,1998, documenting the analysis of the as found test data from Refueling Outages 8 and 9 respectively. The letters stated that the as-found lift test data met the Chapter 15 safety analysis. However, the team noted that during Operating Cycle 9, the analysis took credit for the pressurizer power-operated relief valves. Therefore, the team verified that the block valves had remained open, when required during the entire operating cycl ..

s Considering the valve specific data and operating cycle characteristics, the lif t point of the pressurizer safety valves supported the accident analysis of the plant. Corrective actions included a routine replacement and refurbishment preventive maintenance program and an analysis designed to support a relaxation of the Technical Specification required setpoint tolerances. Although this analysis was not complete at the time of this inspection, NRC staff review of the analysis would be conducted prior to implementatio Therefore, this item does not need to be tracked and is hereby administratively close E8.3 (Open) insoection Followuo item 50-483/9705-03: Review the licensee's efforts to identify and resolve discrepancies between the Final Safety Analysis Report and the as built configuration and operation of plant system Backaround The licensee committed to review seven safety system functional assessments previously conducted to evaluate the impact of these assessments on all areas of the l Final Safety Analysis Report. A task team was initiated to identify and prioritize sections of the report for further compliance review against plant hardware and operating procedures. By a letter to the NRC dated February 5,1997, the licensee documented this effort as a commitment. This inspection followup item was opened to review the licensee's efforts to determine the extent of Final Safety Analysis Report discrepancies similar to those identified during the previous inspectio Insoection Followuo The team reviewed the action plan developed by the task team. Work on the action items was ongoing with final actions scheduled for completion on April 30,1999. This itam will remain open for final review of the quality and product of these review E (Closed) Violation 50-483/9705-04: Failure to report temporary modifications in accordance with 10 CFR 50.59 requirement Backaround During a review of Procedure APA ZZ-00140, the team determined that a description of changes to the facility involving short-term modifications was not included in the licensee's report issued in accordance with 10 CFR 50.59(b)(2). Temporary modifications had been excluded from the report because they were typically installed for a limited duration. Licensee personnel stated that the decision to not report these safety evaluations was in error, Insoection Followuo The team reviewec the licensee's report dated May 9,1997, covering a reporting period of May 11,1995, through December 31,1996. This report included safety evaluation summaries for temporary modifications developed during the reporting period. Further, licensee personnel evaluated the temporary modifications developed between May 1, 1987 through May 10,1995. Temporary modifications implemented during that period had either been removed from the plant or were incorporated in permanent design

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changes that were subsequently reported. The team reviewed Procedure APA-ZZ-00140. Sections 5.2.3.1 and 5.7.1 provided sufficient guidance to ensure that temporary modification summaries were included in the required periodic repor E8.5 (Closed) Violation 50-483/9705-1034: Failure to perform a safety evaluation for a modification of the post-accident sampling syste Backaround The team had reviewed Modification CMP 95-1027A that upgraded the source of power for instrument cabinet fans from nonsafety-related to safety-related. The modification was documented as an improvement. Therefore, in accordance with the licensee's program, a safety evaluation was not performed. The team also reviewed Modification RMP 94-005A. This modification was implemented to redesign the post-ccident sampiing system by replacing the computer control of the sample panel with manual control. Licensee personnel stated that the description of system computer control was documented in a letter to the NRC. While this letter was referenced in the Final Safety Analysis Report, the computer control was not directly described. Therefore, the modification had not been considered a change to the facility as described by the Final Safety Analysis Repor Inspection Followuo The team reviewed the licensee's response to the Notice of Violation. The licensee stated that design engineers had erroneously determined that previous Final Safety Analysis Report change notices had adequately addressed the removal of computer control from the post-accident sampling system. The Final Safety Analysis Report was modified by Change Notice 97-20 to properly describe manual system control. At that time, a formal safety evaluation was performed. The evaluation concluded that no unreviewed safety question existed. The team reviewed the change notice and associated safety evaluation and determined that they were adequat Procedure APA-ZZ-00140, " Safety, Environmental and Other Licensing Evaluations,"

Revision 20, was revised to enhance the guidance regarding when a safety evaluation must be performed. Section 3.6 specifically stated that the Final Safety Analysis Report included documents that were referenced as part of the description. This required a safety evaluation to be performed when a change was made to the facility, as described in a document referenced in the Final Safety Analysis Report. This new revision deleted references to regarding whether a modification improved a system, structure, or component (and, therefore, did not need a safety evaluation).

E (Closed) Violation 50-483/9705-1024: Failure to perform a safety evaluation of a refueling machine setpoint chang A review of the condition resulting in this violation was documented in Section E8.8 of this inspection report. The licensee's response to this violation was bounded by the documented review and corrective actions related to Licensee Event Report 50-483/97-001. Based on that review, this item is close __ _ _ _______-

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E8.7 (Closed) Violation 50-483/97051014: Failure to perform a written safety evaluation for placing the emergency diesel generator supply fans in pull to-loc Backaround Until February 27,1997, Technical Specification Interpretation 18 and Procedure OTN-NE 00002 permitted manual operation of the emergency diesel generator building ventilation supply fans. This was contrary to the Final Safety Analysis Report description that committed to automatic operation of the system. The licensee stated that in 1985 utility engineers had pedormed a general engineering evaluation of the basis for Technical Specification Interpretation 18, but had failed to perform a formal safety evaluation in accordance with 10 CFR 50.5 Inspection Followuo On February 27,1997, the portions of Technical Specification Interpretation 18 and Procedure OTN-NE-00002 that were inconsistent with the Final Safety Analysis Report were deleted. The team confirmed that the revised documents were consistent with the i

Final Safety Analysis Report. In addition, a design modification was completed to limit the need to place the system in manual. On May 15,1997, the licensee submitted an application for site-specific implementation of the improved standard Technical Specifications. The licensee stated that implementation of these specifications will substantially reduce the need for Technical Specification interpretation The team verified that all Technical Specification Interpretation documents not related to the improved specifications had been deleted. The interpretations themselves had been incorporated into the Technical Specifications or appropriate plant procedures. The team also reviewed four of the Technical Specification Interpretation documents that were stillin effect. Technical Specification Interpretations 32,50,56, and 70 were all reviewed. No misinterpretations nor conflicts with the existing Technical Specifications were identifie E8.8 (Closed) Licensee Event Report 50-483/97-001: Misinterpretation of Technical Specification 3.9.6 refueling machine trip limit Backaround This report documented that the refueling machine overload and load reduction setpoints had been set in a nonconservative manner. The licensee stated that the cause was a misinterpretation of the method for setting the interlocks. The Technical Specification did not provide for weight differences among fuel assembly type Therefore, the licensee had written a Technical Specification Interpretation document that promulgated an incorrect method of setting the interlocks. This resulted in a violation of Technical Specification 3.9.6 during refueling outages from the spring of 1986 through the spring of 1995,

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. Inspection Followuo In 1995, the Technical Specification was deleted, and the associated requirements were relocated to Chapter 16 of the Final Safety Analysis Report. Although a violation existed, the team noted that the failure to perform a safety evaluation of the nonconservative setpoints when the Final Safety Analysis Report was updated was cited l

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as Violation 583/97005-1024. Therefore, an additional Notice of Violation will not be issued for the past noncompliance with Technical Specification The licensee deleted Technical Specification Interpretation 25 containing the incorrect interpretation and the Final Safety Analysis Report was revised to provide appropriate guidance for setting the interlocks. The team reviewed Section 16.9.2 and determined that an appropriate description of the overload and load reduction setpoint was provide No damage to the fuel elements resulted from the improperly set interlock l l

E8.9 (Closed) Licensee Event Report 50-483/97-007: Main steam safety valve setpoint drift l outside design basis requirements '

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l In March of 1995, main steam safety valve testing demon.strated that the lift setpoints of 14 valves were outside of the +/- 1 percent tolerance allowed by Technical Specification 3.7,1,1. In addition, four of these valves were outside of previously analyzed limits. The cause of the condition was identified as setpoint drif t or variance attributable to disc to seat surface adhesion. The licensee also reported that in 1993, seven of the valves'setpoints were found to be less than the analyzed -1 percent setpoint limit. This was attributed to intentionally setting the valves low in the tolerance band to compensate for apparent seat surface adhesion identified previousl Inspection Followuo

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As corrective action, the valves were reset and tested satisfactorily. The licensee has submitted an operating license amendment to change the as-found setpoint tolerance to

+3 percent, -1 percent. This amendment request included a full safety evaluation and analysis for setpoints found within these tolerance The team reviewed a letter from Westinghouse dated June 18,1998, documenting an evaluation of the condition. The analysis documented that the tolerance range of

! +3.5 percent /1.5 percent of setpoint was conservatively bounded by the licensee's accident analysis for loss-of-coolant accident events and was either insignificant or could be addressed with the margin found in the plant-specific analyses for other design basis accidents and operational transients, i The team reviewed the entire test history for the main steam isolation valves. Historical l as-found test data indicated that on six occasions, valves were outside of this tolerance range. The team reviewed a letter from Westinghouse dated July 14,1997. This letter indicated that the as-found condition and setpoints of the main steam safety valves in

Operating Cycle 7 supported the accident analysis. In addition, although one valve each l cycle was-found out of the Technical Specification +1 percent tolerance, no valves were

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found to be outside of the analyzed tolerances during testing at the end of Operating Cycles 8 and E8.10 (Closed) Licensee Event Report 50 483/98-006: Reactor coolant system pressurizer safety relief valves failed low on as found set pressure tes As documented in Section E8.2 of this inspection report following Refueling Outage 9, all three pressurizer safety valves were found to have setpoints out-of-tolerance. The valves were replaced with refurbished valves that had been properly adjusted. The licensee committed to continue the removal of the valves each outage for testing and refurbishment. Replacement of the valves and a continuing preventive maintenance program should substantially improve the performance of the pressurizer safety valve E8.11 (Closed) Licensee Event Report 50-483/98-007: Failure to verify the integrity of the pressurizer safety valve balancing devices, Backaround During Refueling Outage 9, all three pressurizer safety valves were removed and transported to an off-site facility for testing in accordance with Technical Specification 4.0.5. During a review of the off-site test results, licensee engineers

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determined that the pressurizer safety valve balancing devices, which are internal

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components of the valves, had not been properly tested during previous in-situ testing to ensure their integrit Inspection Followuo The team reviewed the licensee event report and evaluated the licensee's actions. The test data indicated that the off-site balancing device integrity testing was satisfactory, and no degradation was identified. The cause of the event was determined to be a i

personnel error in updating the IST program to comply with a newer addition of the ASME code. Personnel failed to recognize that the pressurizer safety valves utilized i balancing devices. As documented in Section 8.2 of this inspection report, the licensee intended to continue removal of the pressurizer safety valves for off-site testing and refurbishment. This should ensure that the balancing device integrity testing is performed. Given that the devices tested satisfactorily, the team concluded that the failure to test these devices in the past had no safety significanc The failure to test the pressurizer safety valve balancing devices in accordance with Technical Specification 4.0.5 is a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 l of the NRC Enforcement Policy (50-483/9818-05).

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V. Management Meetings X1 Exit Meeting Summary The teani met with licensee representatives on July 31,1998, to conduct an exit intervie Duiing this meeting, the team leader noted that team personnel had not reviewed proprietary documentation during the course of this inspection. The licensee acknowledged the team's

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ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee M. Ahaag, Electrical Design Engineer S. Fond, Mechanical Design Engineer M. Brenner, Motor Operated Valve (MOV) Engineer T. DeVincentis, Mechanical Design Engineer J. Hogg, MOV Engineer K. Kuechenmeister, Superintendent, Design Engineering J. Lauxx, Manager, Quality Assurance B. Norton, MOV Engineer M. Reidmeyer, Licensing Engineer P. Shannon, Operatiens M. Taylor, Manager, Nuclear Engineering J. Welsh, HVAC Design Engineer R. Wink, ESW System Engineer NRC D. Passehl, Senior Resident inspector INSPECTION PROCEDURES USED 37550 Engineering 92903 Followup - Engineering 93809 Safety System Engineering Inspection (SSEI)

37001 10 CFR 50 59 Evaluations d

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I IIEMS OPENED. CLOSED. AND DISCUSSED l l

l Ooened l 50-483/9818 01 URI Determine whether the licensee's design control measures have adequately bounded the effect that stall thrust / torque

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has on the weak link of valve / actuators and the consequences of any failure (Section E1.1.1).

50-483/9818-02 VIO Failure to follow or establish procedures to assure that the safety design basis for the electrical system was maintained as required by 10 CFR Part 50, Appendix B, Criterion V l (Section E1.2).

50-483/9818-03 VIO Failure to prescribe procedures to assure operation outside of design basis assumptions for switchyard voltage was recognized and evaluated as required by Technical Specification 6.8.1 (Section E1.2).

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50-483/9818-04 (Fl Svaluate need for long-term corrective actions to address affect of system vibrations on system health (Section E2.4).

50 483/9818-05 NCV Failure to test the pressurizer safety valve balancing devices in accordance with Technical Specification 4. (Section E8.11).

Closed 50-483/9705-01 VIO Failure to Report 14/20 MSSV failures during refueling seven 4 (Section E8.1).

50-483/9705-02 IFl Review analysis to support an increased setpoint tolerance for the pressurizer safety valve to verify that accident analysis assumptions were maintained (Section E8.2).

50-483/9705-04 VIO Failure to report temporary modifications in accordance with 10 CFR 50.59 requirements (Section E8.4).

50-483/9705-1034 VIO Failure to perform a safety evaluation for a modification of the post-accident sampling system (Section E8.5).

50-483/9705 1024 VIO Failure to perform a safety evaluation of a refueling machine setpoint change (Section E8.6).

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50 483/9705-1014 VIO Failure to perform a written safety evaluation for placing the emergency diesel generator supply fans in pull-to-lock (Section E8.7).

50-493/97-001 LER Misinterpretation of Technical Specification 3.9.6 refueling machine trip limits (Section E8.8).

50-483/97-007 LER Main steam safety valve setpoint drift outside design basis requirements (Section E8.9).

50-483/98-006 LER Reactor coolant system pressurizer safety relief valves failed low on as found set pressure test (Section E8.10).

50-483/98-007 LER Failure to verify the integrity of the balancing devices on the pressurizer safety valves (Section E8.11).

50-483/9818-02 VIO Failure to follow or establish procedures to assure that the

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design basis for the electrical system was maintained as required by 10 CFR Part 50, Appendix B, Criterion V (Section E1.2).

50-483/9818-03 VIO Failure to prescribe procedures to assure operation outside of design basis assumptions for switchyard voltage was recognized and evaluated as required by Technical Specification 6.8.1 (Section E1.2).

50-483/9818-05 NCV Failure to test the pressurizer safety valve balancing devices in accordance with Technical Specification 4. (Section E8.11).

Discussed 50-483/9705-03 IFl Reviewed the licensee's efforts to identify and resolve discrepancies between the Final Safety Analysis Report and the as-built configuration and operation of plant systems (Section E8.1).

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LIST OF ACRONYMS USED AFS auxiliary feedwater system APV apparent violation ASME American Society of Mechanical Engineers CCW component cooling water CFR Code of Federal Regulations ESW essential service water system FSAR Final Safety '.nalysis Report gpm gallons per minute IFl inspection followup item kV kilovolt LER licensee event report LOCA loss-of-coolant accident MOV motor operated valve MVA megavolt ampere NPSH net positive suction head PDR public document room psid pounds per square inch differential RFR request for resoiution SSEl safety system engineering inspection TS Technical Specification UHS Ultimate Heat Sink URI unresolved item VIO violation

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DOCUMENTS REVIEWED SAFETY EVALUATIONS NUMBER DESCRIPTION REVISION 97-1028 Increase the stroke time of the turbine-driven A auxiliary feedwater pump trip and throttle valve MP 97-1002, Install new essential service water pump with a A FCN-01 slightly larger impeller NUREG-0830 Callaway SSER 3, (Section 8.3.3.1.2)

Temporary Modification Reconfigure turbine-driven auxiliary feedwater pump 96-M010 steam traps for troubleshooting condensate problem SUGGESTION / OCCURRENCE / SOLUTION REPORTS NUMBER DESCRIPTION DATE PRINTED 89-0249 Main steam safety valve test results were September 15,1998 indeterminate

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94-0960 Valve EFV0058 drifted from its required throttled October 1,1998 position 95-0508 As found set pressure for 14 of 22 main steam September 15,1998 safety valves failed to meet acceptance criteria during Trevi testing 96-1953 "B" ESW Pump Inadvertent Trip 96-1273 During Trevi testing Valve BB8010A was found September 15,1998 outside the Technical Specification tolerance 96-1894 Through wall crack of yoke on Valve EFV0090 September 29,1998 96 1933 Valve EFHV0032 failed to open during performance September 29,1998 test 97-0355 "A" ESW Pump Failure to Start 97-1317 "B" ESW Pump Inadvertent Start 97-0865 "B" UHS Cooling Tower Fan Tripped when Started 97-0234 Valve ETP-EF0002A out of position and lock tab October 1,1998 broken 97-0265 TSI 18 permitted EDG supply fans to be in PTL September 15,1998 contrary to the FSAR

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SUGGESTION / OCCURRENCE / SOLUTION REPORTS NUMBER DESCRIPTION DATE PRINTED 97 0272 Refueling machine primary overload cutoff is June 27,1998 improperly set 97 0784 Respond to Notice of Violation 97005-01 August 31,1998 4 97-0785 Respond to Notice of Violation 97005-04 December 29,1997 97-1236 Respond to Notice of Violation 97005-01014 August 31,1998 97 1237 Respond to Notice of Violation 97005-01024 June 9,1998 97-1238 Respond to Notice of Violat i on 97005-01034 June 9,1998

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98-3468 Update Calculation ZZ-145 98-3477 Electrical Load Growth, Mod. 92-1014 98 3508 Electrical Load Growth 98-3526 345 KV Switchyard Voltage 98-3450 Calculation ZZ-62 Assumption 98-0081 Valve EFV0344 operator was not turning the valve September 29,1998 stem 98-0230 Train A essential service water exceeded September 29,1998 maintenance rule availability criteria

98-0304 Train B essential service water system exceeded September 29,1998 maintenance rule availability criteria for Cycle 9 98-1666 EFV0058 was found with a cracked yoke September 29,1998 38-2946 Train B essential service water exceeded September 29,1998 maintenance rule reliability criteria with 2 MPFFs j 98-2983 The locking handle "T" for Valve EFV0058 was October 1,1998 discovered lying on the floor

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98-3022 Train A essential service water exceeded September 29,1998 maintenance rule reliability criteria with 2 MPFFs l l

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REQUESTS FOR RESOLUTION REPORTS NUMBER DESCRIPTION REVISION 17231 Evaluate Frazil ice Concerns at the Ultimate Heat A Sink Pond 18112 Evaluate MOVATS Data for New ESW Pump A thru D 1930 Update Drawing E-21005 to reflect Modification 92-1014 1934 Perform an evaluation / assessment of the current emergency diesel generator load table 7809 Room Cooler Operability Envelope E PROCEDURES NUMBER DESCRIPTION ' REVISION APA-ZZ-00600 Design Change Control 19 APA-ZZ-00108 Primary Licensing Documents: Change / Revision Process 9 APA-ZZ-00140 Safety, Environmental and Other Licensing Evaluations 25 APA-ZZ-00140 Safety, Environmental and Other Licensing Evaluations 21 APA-ZZ-00140 Safety, Environmental and Other Licensing Evaluations 20 Design Guide Electrical Load Growth 0 EE-003-01 Design Guide Electrical Load Growth 1 EE-003-01 EDP-ZZ-0423 Calculations 8 EDP-ZZ-04005 Design Developmen': 30 EDP-ZZ-0423 Calculations 14 EDP-ZZ-0423 Calculations 13 EDP ZZ-01112 Heat Exchanger Predictive Performance Manual 5 EDP-ZZ-01112 Heat Exchanger Predictive Performance Manual 5 EDP-ZZ-01114 Motor Operated VcNo Predictive Performance Manual 10 EDP-ZZ-01121 Raw Water Systems Predictive Performance Manual 3

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PROCEDURES NUMBER DESCRIPTION REVISION

EDP ZZ-04005 Design Development EDP-ZZ-04023 Calculations Revision ETP EF-0002A Essential Service Water Train A Flow Verification 1 ETP-EF-00028 Essential Service Water Train 8 Flow Verification 1 i

ETP-EG-00001 Component Cooling Water Heat Exchanger Test 2 ETP-GL-00001 Area Room Cooler Coil Test 3 ETP-GN-0001 A Containment Cooler Performance Test Train A 1 ETP-GN-0001 B Containment Cooler Performance Test Train B 1 ETP-KJ-00003 Diesel Generator Heat Exchanger Test 3 OSP-NB-00001 Class 1 E Electrical Source Verification 8 OSP-AP-00001 AFW Source Verification with CST Inoperable 2 OSP-EF-P001 A Essential Service Water Pump A Test 27 OSP-EF-P001B Essential Service Water Pump A Test 27 CALCULATIONS l NUMBER DESCRIPTION REVISION AL-17 Maximum Auxiliary Feedwater Flow With Essential 0 I Service Water Boost Using SOS 941354 and RFR-18244 )

EF-31 ESW Orifice Sizing Revision 1, Addendum 1 EF-31 ESW Orifice Sizing 0 l EF-38 Heat Rejected to the UHS Post LOCA 0 EF-45 Minimum Required ESW Flow and Pressure 0 ,

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[ EF-58 . Minimum UHS Level That Will Ensure That the O NPSH Requirements for The ESW Pumps is Maintained

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EF-67 Computer Model of the Cycle 9 ESW System Using 0 j KYPIPE3 8 ,

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NUMBER DESCRIPTION REVISION l EF-68 Determine the impact on ESW Flows and Pressures Revision 0, Addendum 1 when in the LOCA/S! Lineup, and Flow is then Diverted to Auxiliary Feedwate ,

EF-68 Determine the impact on ESW Flows and Pressures 0  ;

when in the LOCA/SI Lineup, and Flow is then l

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Diverted to Auxiliary Feedwate EG-20 Maximum CCW Temperature During Post LOCA 0 I EG-20 Maximum CCW Temperature During Post LOCA Revision 0, Addendum 1 l EG-20 Maximum CCW Temperature During Post LOCA Revision 0, Addendum 2 GL-390 Auxiliary Building HVAC 0 GN-17 Containment Cooler Water Hammer Analysis O M-018-03 Analysis of Load Table and Predictions of Voltage 1 89 and Frequency Excursions at the Various Load Step Conditions M-EF-10 Essential Service Water System Flow Requirements O M-EF-10 Essential Service Water System Flow Requirements Revision 0, Addendum 1 M-EF-35 ESW Minimum Head Requirement. Added Pressure Revision 0, Addendum 1 Drop Due to Addition of Boundary Valves M-EF-41 Evaluation of Control Room A/C Unit, Class 1E 0 Electrical Equipment A/C Unit, and Diesel Generator Heat Exchangers at 80% of ESW Design Flow Rate and 90'F Inlet Temperature M-EF-51 Evaluation of Containment Air Cooler with Reduced 0 ESW Temperature and Reduced ESW Flow I

M-EF-52 Heat Exchanger Performance Based on Reduced 1 ESW Temperature and Flow M-EF-53 UHS Pond Thermal Performance - Maximum Heat 1 Transfer Case and Final Report M-FL-01 Flooding of the Auxiliary Building 2 M-FL-04 Summary of Flood Levels in all Auxiliary Building 2 Rooms Due to a Pipe Break / Crack

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CALCULATIONS NUMBER DESCRIPTION REVISION N-9 System NG/PG Protective Relay Settings 3

. NG-12 NG MCC Setpoint Calculation 3 XX-49 Control Building Flooding - Determine the Maximum 0 Control Building Basement (Room 3101) Flood Level Due to A Break or Crack ZZ-145 Short Circuit Calculation 1 ZZ-179 AC Bus Load Lists 1 ZZ-62 Load Flow Voltage Drop Calculation 4

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ZZ-224 MOV Sizing Calculation 6 l

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NUMBER DESCRIPTION REVISION CMP 91-1014 Modify Return Spectacle Flanges to UHS Pond A l

CMP 92-1014 Addition of the Swing Battery Charger for the A 1 Class 1E DC System l MP 97-1002 Replace DEF018 with a Pump that has a Slightly A Larger Impeller LICENSING DOCUMENT CHANGE REQUESTS NUMBER DESCRIPTION REVISION 97-020 Change FSAR to indicate that the post- O accident sampling system is no longer computer controlled Amendment 51 Technical Specification change regarding March 1,1990 electrical inoperability of movable control rods

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Amendment 105 Technical Specification change regardingGL December 7,1995 j 93-05 line item improvements '

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l DRAWINGS NUMBER DESCRIPTION REVISION 8600-X 89247 Interconnection Diagram Main Control Board RLO13 12

& 14, Sheet 5, Onsite Comm Sig & Control Sys E-23EF06(O) Schematic Diagram ESW to Ultimate Heat Sink 7 j isolation Valves

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E-23EF06A(O) Schematic Diagram ESW to Ultimate Heat Sink 7 I Isolation Valves E-23EF07(O) Schematic Diagram ESW to Containment Air 9 Coolers isolation Valves E-23EF05(O) Schematic Diagram ESW from Component Cooling 9 Water Heat Exchanger Isolation Valves E-23EF08(O) Schematic Diagram ESW from Containment Air 9 Coolers isolation Valves E-23EF09(O) Schematic Diagram ESW to/from Containment Air 9 Coolers isolation Valves i E-23EF09A(O) Schematic Diagram ESW to/from Containment Air 0 Coolers isolation Valves ( E 23EF10(O) Schematic Diagram ESW from Containment Air 11 Coolers isolation Valves Bypass E-23EF11(O) Schematic Diagram Instrumentation 1 E-U3EF01(O) Schematic Diagram Essential Service Water Pump A 27 E-U3EF01A(O) Schematic Diagram Essential Service Water Pump B 21 E-U3EF02A(O) Schematic Diagram Ultimate Heat Sink Cooling 15 i Tower Fans J E-U3EF02B(Q) Schematic Diagram Ultimate Heat Sink Cooling 4 Tower Fans Speed Selection E-U3EF02C(O) Schematic Diagram Ultimate Heat Sink Cooling 13 Tower Fans Manual Control E-U3EF02D(O) Schematic Diagram Ultimate Heat Sink Cooling 5 '

Tower Fans E-U3EF05(O) Schematic Diagram Cooling Tower inlet Bypass 15 Valves E-U3EF06(O) Schematic Diagram Essential Service Water Pump 5 Interposing Relays

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DRAWINGS NUMBER DESCRIPTION REVISION E-U3EF07(O) Schematic Diagram Essential Service Water Aux 9 Relays Inlet Clg. Twr, Bypass Vivs. & An I l

E-U3EF11(O) Schematic Diagram ESW Pump Discharge Line Air 16  !

Discharge Valves E-21PA02(O) Higher Medium Voltage System 13.8 kV Single Line 5 ,

Meter and Relay Diagram )

' E-21024(O) Relay Setting Tabulation and Coordination Curves Various System NG & PG, Sheet 1 to 17 E-21005(O) List of Loads Supplied by Emergency Diesel 21 Generator E-21NK02(O) Class IE 125V DC System Meter & Relay Diagram 5 E-23EF02B(O) Schematic Diagram ESW to SW System isolation 1 Valve E-3GD03(O) Schematic Diagram ESW Pump Rm & Electrical Rm 5 Unit Heaters

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E-074-0002046K GE Nameplate ( Transformer XNB01) 3 l

l E-U3EF11(O) Schematic Diagram ESW Pump Discharge Line Air 16 Discharge Valves l E-U1NG91(O) Low Voltage System Class IE 480V Single Line 7 Meter and Relay Diagram E-052-00185 Essential Service Water Panel OJ169A-Power Dia E-052-00187 Essential Service Water Panel OJ169B-Power Dia i L E-23EF04(O) Schematic Diagram ESW from Component Cooling 9 Water Heat Exchanger Isolation Valves

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E-U3OB01(O) Schematic Diagram Stand-by Lighting System Power 5 l Feeders l E-052-00182 Essential Service Water - Heat Tracing 7

L E-052-0186 Essential Service Water Panet OJ169A 6 l

l E-052-0188 Essential Service Water Panet OJ169B ' 6 E-21001(O) Main Single Line Diagram 6 E U1001(O) Single Line Essential Service Water System 5

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E-23EF00(O) Essential Service Water System Schematic Index 5 l

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E-21NB01(O) Lower Medium Voltage System Class IE 4,16KV 3 Single Line Meter and Relay Diagram E-21NB02(O) . Lower Medium Voltage System Class IE 4.16K )

Single Line Meter and Relay Diagram '

3 E-21NK01(O) Class IE 125V DC System Meter & Relay Diagram 6

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E-21NK02(O) Class IE 125V DC System Meter & Relay Diagram 5 E-23EF01(O) Schematic Diagram ESW to Air Compressors 4

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Isolation Valves

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E-23EF02(O) Schematic Diagram ESW to SW System isolation 14 l Valves E-23EF02A(0) Schematic Diagram ESW to SW System Isolation 8 Valves

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E-23EF03(O) Schematic Diagram ESW to SW System isolation 14  ;

Valves M-UH0101(O) Heating Ventilating & Air Cond. Essential Service 4 Water Pumphouse

- M U2EF01(O) Piping & Instrumentation Diagram Essential Service 36 Water System M-089-U0012 ESW Pump "B" Outline Drawing 0 M-154-U0018 Self Cleaning Strainer Outline Drawing 6 M-22EA01 Piping & Instrumentation Diagram - Service Water 15 System M-22EF01(O) Piping & Instrumentation Diagram - Essential Service 29 Water System

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M-22EF02(O) Piping & Instrumentation Diagram - Essential Service 36 Water System M-23EF01(O) Piping Isometric - Essential Service Water System - 10 Control Building (A & B) Train

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M-25EA01 Hanger Lccation Drawing - Service Water System - 1 j_ C0mmunication Corridor

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DRAWINGS NUMBER DESCRIPTION REVISION l

M-2G020 Equipment Location - Reactor and Auxi'iary Buildings 22

- Plan - Basemant El.1974'-0" M-2G021 Equipment Location - Auxiliary Building - Partial Plan 7

- El.1988'-0" & El. 2013'-6" M-2G022 Equipment Location - Reactor and Auxiliary Buildings - 34

- Plan - Ground Floor El. 2000'-0" l M-U2EF01(O) Piping & Instrumentation Diagram - Essential Service 36 Water System MISCELLANEOUS DOCUMENTS

NUMBER DESCRIPTION DATED

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!- AP97-002 Quality assurance department audit report regarding June 11,1997 l the accuracy of the licensing basis for the essential l service water system AP97-004 Ouality assurance department audit report regarding June 27,1997 l

the accuracy of the licensing basis for the auxiliary l feewater system l Form CA 2218 Electrical Change Tracking Form 5/23/93 l

FSAR 9.4.7. Diesel Generator Building Ventilation System OL-9 Operation l FSAR 16. Refueling Machine OL-9 l

Letter DC Evaluation to Remove MOV Core Load Jumpers .7/29/93 l 93-368 Letter Bypassing Thermal Overload Protection of Motor 9/29/98 NED-98-162 Operated Valves NET 98-0035 Response to NRC Information Notice 97-90 - March 10,1998 Internal Memorandum No Document Evaluation of Potentid Fazilice Blockage of the August,1996 Number Essential Service Water Pump House at the Callaway Nuclear Power Plant l SCP-97-105 Letter from WLestinghouse: " Increased Pressurizer February 26,1997 Safety Valve Tolerance at Callaway"

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MISCELLANEOUS DOCUMENTS NUMBER DESCRIPTION DATED SCP-97-131 Letter from Westinghouse: Effect of 3.6% increase in July 14,1997 MSSV Tolerance on LOCA for Callaway SCP-98-130 Letter from Westinghouse: " Increased MSSV Tolerance Range for Callaway" SCP-98138 Letter from Westinghouse:" Increased Pressurizer July 16,1998 Safety Valve Tolerance" l l STS No. 622835 Surveillance Task Sheet June 29,1998

. T61.011 Licensed Operator Tmining Module 971205, September 15,1997

" Essential Service W ter (EF)"

TCN 98-0655 Temporary Change Notice Request Form TSI32 Operability of the source range boron dilution flux 4 multiplication function TSI70 Electrical Inoperability of Movable Control Rods 6 TSI56 Operability of control room ventilation system with 7 ,

radiation monitors inoperable TSI52 Operability of ultimate heat sink sump heaters 12

TSI18 Operab;lity of Diesel Generator auxiliary equipment 10 ULNRC - 2324 Response to Generic Letter 8913 November 14,1990 ULNRC -2146 Response to Generic Letter 8913 0 ULNRC-03230 Letter: " Revision to Technical Specifications, Line June 23,1995

, Item Technical Specifications Improvements" ULNRC-03580 Union electric approved written safety evaluations May 9,1997 report ULNRC-205S Letter: " Revision to Technical Specification 3/4.1.3, August 2,1989 Movable Control Assemblies" ULNRC-2129 Letter:" Revision to Technical Specification 3/4.1.3, Demmber 28,1989 Movable Control Assemblies" ULNRC-2146 Response to Generic Letter 89-13 January 29,1990 I

ULNRC-3649 Letter: " Request for Information Pertaining to September 15,1997 l Emergency Diesel Generator Room Temperature l Limits"

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r MISCELLANEOUS DOCUMENTS NUMBER DESCRIPTION DATED ULNRC-3656 Letter:" Request for information Pertaining to Room October 2,1997 Temperature Effects on Emergency Diesel Generator Operation" ULNRC-3670 Letter:" Reply to Notice of Violation inspection Report November 20,1997 50-483/97005" ULNRC 3868 Letter:" Amended Reply to Notice of Violation July 22,1998 Inspection Report 50-483/97005"

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