IR 05000498/1997005
| ML20216H188 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/12/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20216H183 | List: |
| References | |
| 50-498-97-05, 50-498-97-5, 50-499-97-05, 50-499-97-5, NUDOCS 9709160163 | |
| Download: ML20216H188 (9) | |
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EXECUTIVE SUMMARY South Texas Project. Units 1 and 2 NRC Inspection Report 50-498/97-05;50 499/97-05 This resident inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 0 week period of resident inspection.
Querations
Control roorn operators performed their duties in a professional manner, were attentive to control board indications, and maintained a good focus on safety (Section 01.1).
The f ailure to track the Technical Specification action statements associated with
the inoperability of the hydrogen analyzer was in violation of administrative requirements. This condition continued for 7 days without identification by on shif t operators. This nonrepetitive licensee identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (Section 01.2).
- Incomplete corrective action for a previous event resulted in an inadvertent partial drain down of the Unit 1 spent fuel pool (Section 01.3).
Plant systems were maintained in good material condition. The instrument air
system and selected containment isolation valves were properly aligned (Sections 02.1, O2.2 and 02.4).
- A reactor plant operator exhibited good attention to detail and safety system knowledge by identifying low hydraulic fluid levelin a power-operated relief valve (Section O2.3).
- One example of an inadequate equipment clearance order resulted in an inadvertent start of a Unit 2 essential cooling water screen wash booster pump while the system was drained (Section 04.1).
Maintenanta
Planners f ailed to identify that painting of the air start solenoids could adversely af fect Standby Diesel Generator 11 operability (Section O2.1).
- In general, maintenance activities were performed in accordance with management's expectations. However, several examples of the f ailure to properly implement maintenance related programs were discussed (Section M1.1).
- Surveillance test procedures were well performed and properly implemented Technical Specification surveillance requirements (Section M1.2).
9709160163 970915 PDH ADOCK 05000490
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Craf tsmen did not initially remove plastic bags from containment as required by the containment inspection procedure. Previous corrective actions were inadequate to ensure that plant workers fully understood the requirements of Technical Specifications regarding loose debris in containment (Section M4.1).
- A second example of the f ailure to establish an effective equipment clearance order boundary was identified when craf tsmen breached an unisolated portion of the component cooling water system. In addition, craf tsmen riad prior opportunity to identify this condition (Section M4.2).
LOMIML!DD The actions of the engineers in stopping the attempted removal of the essential
cooling water structure gantry crane was notabic. The recalculation of the crane weight and potential impact on operability of the essential cooling water systems were considered to be conservative (Section E1.1).
The f ailure to perform adequate surveillance testing of the Pressurizer Pressure
interlock P 11 was a violation of Technical Specification surveillance requirements.
This nonrepetitive licensee identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.D.1 of the NRC Enforcement Policy (Section E2.1).
- The identification of surveillance testing inadequacios associated with Permissive P 11 during an operational experierne review was considered to be excellent (Section E2.1).
Maintenance and engineering personnel properly evaluated the causes of a fire that
initiated during a leak sealing evolution on main steam isolation Valve 2D. The associated temporary modification package was properly developed and reviewed.
The use of an injection clamp during this evolution was considered conservative (Section E2.2).
- The licensee's failure to assure that all of the requirements of IEEE 338 1997, Regulatory Guide 1.22, and Regulatory Guide 1.118, related to removing the AFW and containment spray systems from service, were correctly translated into the applicable procedure for testing of the AFW cystem was a violation. This nonrepetitive, licensee identified and corrected violation is being treated as a noncited violation, consistent with Section Vll B.1 of the NRC Enforcement Policy (Section E2.3).
EaDLSUDDDL1
Routino observations of radiological work practices indicated that controls were in place and effective with one minor exception. Several contaminated area signs were not properly secured and had f allen down (Section R1.1).
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- Routine observations of daily security force activities, secondary chemistry controls, emergency response f acility readiness, and meteorological tower operability indicated appropriate management attention to these functional areas (Sections R1.2, P2.1, P2.2, and SI.1).
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10-perfortned on the pump or screen wash sy!, tern during the inadvertent start. This ovent was the result of an inadequato equipment cicarance order boundary.
1ho inspectors reviewed Plant General Proceduto OPGP03 ZO EC01, Revision 0,
" Equipment Clearance Orders." Proceduto OPGP03 20 EC01 required that equipment clearanco orders provide adequato boundaries to ensure personnel safety and equipment integrity. The execution of Equipment Clearance Order 97 70518 did not properly implement this safoty related proceduro. The f ailure to properly implement this safety related proceduto was the first examplo of a violation of Technical Specification 0.8.1 (498:499/97005 03).
II,_Maintenanto M1 Conduct of Maintenanco M 1.1 GenuBiLCntnrnents o.nficid_Mainitonnlo_Attivition a,
jnspglip1LSqpat1027.01)
The inspectors observed portions of the following on going work activities identified by their work authorization numbers:
Unit 1:
95013550 Bench Test Charging Pump Cooler Air Handling Unit 11 A/
Component Cooling Water Return Pressuro Relief Valvo (Juno 30)
114733 Rod Cluster Control Assembly Tool Repairs (July 17,21)
347083 Residual Heat Removal Pump 1B Flange Look Ropair and Impeller inspection (July 21)
Unit 2:
114701 Steam Generator 2A Main Steam Pressure Low Alarm Lead / Lag Card and Comparator Card Replacement and Calibration (July 10)
347818 Steam Generator 2D Main Steam isolation Valve has a Small Hissing Steam Leak at the Body to Bonnet Flange b.
Qbietnligfutamtfindtnas in general, the inspectors found the work performed during these activities thorough ar d conducted in a professional manner. The work was performed by
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The work package did not identify triu 'eed to estabbsh a component coohng water boundary,
The job scope was not fully understood by either the equipment clearance order preparer nor reviewer, The equipment clearance order acceptor did not adequately walk down the
boundary.
The inspectors reviewed Plant General Procedure OPGPO3 ZO EC01, Revision 6,
" Equipment Clearance Orders Procedure OPGP03 ZO EC01 required that equipment clearance orders provide adequate boundaries to ensure personnel safety and equipment integrity. The execution of Equipment Clearance Order 97 1 71009 did not properly implement this safety related procedure. The f ailure to properly implement this safety related procedure was the second e - nple of a violation of Technical Specification 6.8.1 (498:499/97005 03),
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Conclusions This event and the event discussed in Section 04.1 of this inspection report have regulatory significance because equipment clearance orders establish necessary boundaries to protect critical equipment and to ensure personnel safety. Both of these events were of low safety significance because the consequences were relatively inconsequential. However, the fact that neither personnel safety nor equipment integrity were jeopardized cannot be attributed to the equipment clearance order quahty. This event-disclosed, non-repetitive, licensee corrected violation is being cited because the licensee had rior opportunity to identify the inadequate equipment clearance order when the mechanics discussed the need to walk down the component cooling water boundary.
M8 Miscellaneous Maintenance items (92902)
M B.1 Use of Lif tina Device Without Proper Inspection (93001)
On July 17, during an observation of activities being performed under Work Authorization Number 114733. The inspectors observed a problem associated with the use of a temporary lif ting device. Workers in the fuel handling building determined that an additional hoist was desirable while removing a refueling tool from the spent fuel pool. An electric hoist attached to a rail mounted trolley on the refueling machine was utikred. The inspector asked the craf tsmen and operators present and was informed that no one had performed a daily inspection of the trolley, as required by the licensee's hiting program. fvianagement was informed of the problem, and Condition Report 97 12532 was written to docurnent the occurrence and evaluate appropriate corrective actions.
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- 18-deficienclos in the previous testing methods. Permissive P 11 had been declared inoperable and Technical Specification 3.3.2 Acton 21 was imptomonted to ensure that the it'terlock was in its required state. Tho technicians were knowledgeable of the systern and the appropriato testing methods. The permissive was properly test.ed and returned to service. Observed indications verified that the permissive had been properly returned to service. The inspectors determined that the identification of this condition resulted from a quality operational experience review process.
As documented in Section M8.1 of this inspection report, the licensco properly reported this problern in Licenseo Event Report 50 498/97 007. However, the f ailuro to properly test Permissive P.11, prior to June 19,1997, in accordance with Technical Specification Surveillance Requirement 4.3.2.1. Table 4.3.2 was a violation. This licenseo identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the MlC Enforcement Policy (498:499/97005 04).
E2.2 llrLD1HE1.liHDLlf!Ent!MutLLenk._Snalion Ap.nylling a.
[Ilmn@rtkontLQ3702. 325ftij On July 15, a small fire was discovered on the insulation surrounding Main Steam Isolation Valve 2D during steam leak sealing activities. The crew performing the leak sealing activities lef t the area following a series of leak sealant injections.
Shortly thereaf ter, a security officer making a routino patrol of the area observed the flames and contacted a nearby mechanic. The mechanic extinguished the flame with a fire extinguisher. The fire brigado was notified, the insulation removed, and the ernbors extinguished. The inspectors reviewed the licensco's response to and evaluation of the event; the event review team's report; and the temporary modification package associated with the leak sealing activity, b.
QbigfyndpD1 and findtrlitti An event review team noted that the material safety data sheet indicated that the leak scalant material should not have caught fire in the specific application nor at the piping temperatures encountered. The team determined that mineral oilin the leak sealant material had leached out from under the injection clamp and collected in the fiberglass insulation. The conditions were then sulficient to cause the oil to autoignite. Licenseo engineers stated that the spontaneous ignition of oil soaked insulation can occur under the following conditions:
The liquid is insufficiently volatile to evaporato rapidly.
- The insulation is sufficiently porous to allow oxygen to dif fuse to the surf ace of the absorbed liqui [
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- regulatory guidance and that the bypass testing was acceptable. However, the inspector noted that this testing methodology did not specifically meet the description provided in the original FSAR design. UFSAR 7.3.1.2.2.5.4.5 stated
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that automatic actuation circuitry will override testing activities and actuate the system. The licensee identified this discrepancy and had decided to install a field change to install a second slave relay which willinactivate the discharge motor-operated valve in the respective train. The field change had been scheduled to be implemented during the 1998 and 1999 refueling outage time frames. This is a third example of a f ailure to implement the design commitments from applicable regulatory guidance into tha AFW system design.
10 CFR 50, Appendix D, Criterion ill, * Design Control," requires, in part, that measures be established to assure that applicable regulatory requirements be correctly translated into specifications, procedures, and instructions. The three examples of the licensee's failure to assure that all of the requirements of IEEE 338-1997 and Regulatory Guida 1.118 were correctly translated into the applicable procedures for testing of the AFW system represents a violation of Criterion lli of Appendix 0 to 10 CFR 50. However, the inspector determined that: the violation was identified by licensee personnel; corrective actions had been developed; the violation was not a repeat of a previous violation or finding; and the violation was not willful. Therefore, this nonrepetitive, licensee identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 498:499/97005 05).
In light of these findings, the inspector questioned whether these issues required a report to the NRC in accordance with 10 CFR 50.73(a)(2)(ii)(B), which stated that the licensee shall report any condition that was outside the design basis of the plant. The inspector noted that on November 26,1996, the licensee had generated a reportability review for Condition Report 96 14496, wherein they concluded that the AFW system testing deficiencies were not reportable. The licensee stated that the testing of the AFW system was done with the system properly removed from service in accordance with the Technical Specifications, and that the testing adequately tests the system components in accordance with the Technical Specification requirements.
The inspector agreed with the licensee determination that the issues were not reportable because the testing of the AFW system was conducted with the applicable train properly removed from service in accordance with the Technical Specification 3.7.1.2 action statement. Based on the redundancy of having four trains, there was always a sufficient number of trains available, such that the AFW system was not degraded during the testing of one train of the system. In addition, the AFW train was taken out of service for testing with the full knowledge of all operators and monitored by entry in the control room tog of the Technical Specification action statement. There were no ESF actuations involved. The testing conditions did not result in an inability to mitigate an accident or maintain safe shutdown (three remaining AFW systems were operable and only one AFW f
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ATTACHMENI SUPPLEMENTAL INFORMATION P_ARTIAL LIST OF PERSONS _QBNTACTED Unan T. Cloninger, Vice President, Nuclear Engineering W. Cottle, Executive Vice President and General Manager Nuclear B. Dowdy, Manager, Operations, Unit 2 J. Groth, Vice President Nuclear Generation E. Halpin, Manager, Maintenance, Unit 2 S. Head, Licensing Supervisor K. House, Supervising Engineer, Design Engineering Department T. Jordan, Manager, Systems Engineering M. Kanavos, Manager, Mechanical / Civil Design Engineering A. Kent, Manager, Electrical / Instrumentation and Controls Systems B. Logan, Manager, Health Physics R. Lovell, Manager, Operations, Unit 1 B. Masse, Plant Manager, Unit 2 G. Parkey, Plant Manager, Unit 1 T. Waddell, Manager, Maintenance, Unit 1 INSPECTION PROCEDUEES USED IP 37551: Onsite Engineering IP 61720: Surveillance Observations IP 02707: Maintenence Observation IP 71707: Plant Operations IP 71750: Plant Support IP 92700: Onsite Followup of Written Reports at Power Reactor Facilities IP 92902: Followup - Maintenance IP 93001: OSHA interface Activities llEMS OPENED. CLOSED. AND DISCUSSED Onened 499/97005 01 NCV Entry of Incorrect Technical Specification Action Statement into Operability Assessment System 498:499/97005 02 URI Manual Valves in Certain Containment Penetrations not Surveilled in Accordance with Technical Specification 4,0.1.1.a 490:499/97005 03 VIO Two Examples of inadequate Equipment Clearance Order Boundaries
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498:499/97005 04 NCV Failure to Properly Test the Pressurizer Pressure
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Interlock P 11 in Accordance with Technical Specifications 498;499/97005 05 NCV Failure to Translato Design Commitments into AFW and Containment Spray Systems Design i
Claatd 499/97005 01 NCV Entry of incorrect Technical Specification Action Statomont into Operability Assessment System T
498:499/97005 04 NCV Failure to Properly Test the Pressurizer Pressuto interlock P 11 in Accordance with Technical Specifications 490:499/97005 05 NCV Failuto to Translate Design Commitments into AFW and Containment Spray Systems Design 50 498/97 007 LER Engineered Safety Features Actuation System Pressurizer Pressure interlock Not Fully Tested by Surveillanco
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