IR 05000498/1997023

Insp Repts 50-498/97-23 & 50-499/97-23 on 970811-15,25-29 & 0903-04.No Violations Noted.Major Areas Inspected: Operations,Maint & Engineering

ML20199E084
Person / Time
Site:	South Texas
Issue date:	11/12/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199E069	List: IR 05000498/1997023 ML20199E063
References
50-498-97-23, 50-499-97-23, NUDOCS 9711210097
Download: ML20199E084 (34)

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ENCLOSURE  ;

U.S. NUCLEAR REGULATORY COMMISSION -

- REGION IV  ;

Docket Nos.: 50-498i 50-499 Ucense Nos.: NPF 76; NPF 80  ;

Report No.: 50 498/97 23; 50 499/97 23 Ucensee:: Houston Lighting & Power Company _'  ;

Facility:-- South Texas Project Electric Generating Station, Units 1 and_2

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Location: FM 521 8 miles west of Wadsworth" Wadsworth, Texas

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Dats.: August 1115 and 25 29, and September 3 4,1997

- Inspectors: M. Runyan, Senior Reactor Inspector, Engineering Branch P. Goldberg, Reactor Inspector, Engineering Branch D.' Pereira, Reactor Inspector, Engineering Branch Approved By: T. Stetka, Acting Chief, Engineering Branch Division of Reactor Safety o

ATTACHMENT Supplemental Information

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9711210097 971112 -

PM ADOCK 05000498

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- E X E C U T I V E S U M M A R Y - . = . . ' . 4 . . . . . . . . . . . . . . . . . . . . .. . . _. . , , . . . . . . . . . . . . iii

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R e por t D e t ail s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -

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' l . O p e r a t io n s . . . . . . . . . . . . . . . . . . - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1  ;

02 Operational Status of Facilities and Equipment -. . . . . . . . . . . . . . . . . . 1 . ,

-02.1 Operator WorkiArounds . . . . . . . . . . . . . . . . . .. . . . . . . - . = . . . ._1

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O2.2 Operations Support of Condition Reports . . . . . . . . . . . . . . . . . . 2 -

-04' Operator Krow! edge and Perf ormance . . . . . . . . . . . . . . . . . . . . . . . . . 3  ;

04.1' interview of Operations Personnel . . .- . . . . . . . . . . . . . . . . . . . 3 04. 2 _ Syst em Walkd owns . -. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 -

07 Quality Assurance in Operations . . . . . . . . , , , . . . . . . . . . . . , . . . . . .' 4 07.1 Safety Review Committee Activities . . . , . . . . . . . . . . . . . . . . . 4

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. I I . M a i n t e n a ryj e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

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M2 . Maintenance and Material Condition of Facilities and Equ;pment . . . . . . .- 5 M2.1 - Maintenance Support of Condition Reports . . . . . . . . . . . . . . . . , , 5 '

M2.2 Corrective Maintenance Condition Records .. . . . . . . . . . . . . .. . . . 7 M2.3 Repeat Maintenance Condition Reports . . . . . . . . . . . . . . . . . . . . 8

.i 111. E n g i n e e r i n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - . . . . . . . . . 8 e E2 Engineering Support of Facilities and Equipment .................. 8 E Engineering Support of Operating Experience . . . . . . . . . . . . . . . .8 E2.2 Engineering Support of Condition Reports . . . . . . . . . . . . . . . . . 10 E2.3 Engineering Support for Condition Report Engineering Evaluation . 11 E2.4 Engineering Support of Operability Determinations . . . . ... . . . . . 12

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E2.5 Minor Design Chang es . , , . . , , . . . . . . . . . . . . . . . . . . . . . . 13 E2.6 Temporary Modifications . . . . . . . . . . . . . . . . . . . . . , , , . . . . . 18 E4 Engineering Staff Knowledge and Performance . . . . . . . . . . . . . . , , . 18 E4.1 Interview of Engineering Personnel . . . . . . . . . . . . . . . . . . . . . . 18 E7- Quality Assurance 'in Engineering Activities . . .:. . . . . . . . . . . . . . . . . . 19 E7.1 Quality Assurance Audits and Self Assessments . . . . . . . . . . . . 19 E7.2 Root-Cause Analysis . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . 20 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 E (Closed) Licensee Event Report 50-499/94 02: Standby Diesel Generator 22 Piston Failure . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 -

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VI. Management Meetings ......................................,...22-X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . 22

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__ EXECUTIVE SUMMARY .l South Texas Project NRC inspection. Report 50-490/97 23; 50-499/97 23 ]

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. This inspection reviev,ed the hcensee's corrective action processes to determine whether - -D problems affecting plant safety were being identified and resolved in a manner that would

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prevent recurrence. The inspection revtaled that the South Texas corrective action -

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processes were functioning satisfactoril DDfrLE1\DDS ,

• - Operator work arounds were being controlled effectively. They wero sow in number and, collectively,- did not represent a significant burden on operator effectiveness ~ l

- (Section O2.1).

e All condition reports assigned to operations, which were reviewed, had -

comprehensive root causes and corrective actions (Section 02.2). ,

• The licensee's trend analysis program was working effectively, despite a large number of event codes. The licensee was in the process of reducing the number of avent codes (Section 02.2).

• -inc inspectors concluded that operators weic knowledgeable of the corrective action prog;am, including the initiation, approval, and implementation of condition reports in addition, the inspectors concluded that a strong teamwork approach was evident (Section 04.1). .

• The inspectors concluded that the material condition and housekeeping of the rooms inspected were excellent. The spaces were being maintained orderly in spite of

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work-in progress for the epcoming outage. The inspectors noted no safety significant concerns (Section 04.2).

• .The Nuclear Safety Review Board and the Plant Operations Review Committee were

- very aggressive in their approach to overseeing nuclear st.foty (Section 07.1).

Maintenan *: - The condition repyte completed by maintenance were, for the most part, good ef forts to resolve the identified deficiencies. However, the inspectors made three obsefiations that may warrant additional management attention: the generallack of detail making the reports unable to be a stand alone document, the tendency to overlook human f actors in conditions adverse to quality, and the lack of a procedural

- prohibition for the personal storage of expendable materials (Section M2.1).

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e Engineering

• Operating experience information was being disseminated appropriately. Evaluat;on reviews and corrective actions for operating experience reports were being satisf actorily controlled. Several problems related to information processing and comrnunications in this area had been identified by licensee personnel. Proposed improvements in the program were being implemented (Section E2.1).

• In general, the engineering department reviews of condition reports were very goo However, in one case an essential technical evaluation of the potential for damage resulting from an unexpectedly high component cooling water flow rate to the reactor coolant pump motor upper bearing oil cooler was not performed (Section E2.2).

• Engineering provided satisf actory support to operations and other plant groups through the disposition of conditior report engineering evaluations, although, in some cases, documentation detail was lacking (Section E2.3).

• Engineering satisf actorily assessed the operability implications of degraded plant conditions (Section E2.4).

• Following discovery of an insulation discrepancy related to a power operated relief valve loop seal, the licensee checked the other power operated valve loop seals for the presence of insulation, but they did not extend the review to include other pLing systems, consistent with their cause determination (Section E2.4).

• The 10 CFR 50.59 review guide appeared to incorrectly define the term " trivial changes," by allowing changes that affected plant drawings in the Final Safety Analysis Report to be classified as trivial and to not constitute a change to the facility and as a result, not require an unreviewed safety question evaluation. This issue was referred to the NRC program office for review and evaluation (Section E2.5).

• The licensee's temporary modification program was well imp!emented (Section E2.6).

• Engineers were knowledgeable of the corrective action program and confident in its use (Section E4.1).

• The lack of controlled switchyard drawings at the site was considered a weakness in the configuration management system (Section E7.1).

• Engineering performed a satisfactory review of condition reportt to ascertain the root or apparent cause of the condition (Section E7.2),

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i Report Details

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ilnsoection Objectives (40500)

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The objective of this inspection was to evaluate the effectiveness of thei South-

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j-Tcxas Project controls in identifying, resolvinpi and preventing problems that . t degrade plant safety. This review was focused on the following areas:

• Safety review committee activities J

• Root cause analysis -

• Corrective action

• Self assessment

• Operating experience feedback The inspection consisted of an extensive review of plant documents, employee *

interviews, and meetings with licensee personnel to dis. cuss technical or ~

administrative question . Operations ,

02 Operational Status of Facilities and Equipment O 2.1 Ooerator Work-Arounds Insoection Scoce (40500)

The' inspectors reviewed the licensee's controls for ensuring timc!y corrective taction of operator work arounds. The inspectors reviewed Operations Department Procedure OPGPO3 ZA-0090, " Work Process Program," Revision 18, attended several daily communication and teamwork meetings, more commonly termed " plan-of the day," and conducted interviews with several operators.

- Observations and Findinos An operator work around was defined by the licensee as a deficiency other than main control board or inoperable automatic function that had an associated compensatory or contingency action assigned to the operating watchstation. The NRC is concerned that work-arounds are controlled, because they can complicate operator responses to emergencies or transient conditions.

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Procedure OPGPO3 ZA-0090 described the process for controlling total impact assessments. A totalimpact assessment item was defined as a equipment

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- and af fects the crew's ability to monitor and control plant parameters, The . l inspectors noted that totallmpact assessment items normally had an assigned

compensatory or contingency action and were subcategorized as main control board -

' items, inoperable automatic functions, operator work-arounds, and chemical process monitor The inspectors determined that the licer see maintained a high priority on' total impact assessments, as well as, the sub' classification'of operator work-arounds and conducted a weekly and a quarterly review of these items. The inspectors -

determined that the August 26,1997, work around list for Unit 1 had three nonautage items and five outage items listed. Similarly, the inspectors noted that '

for Unit 2, the August 20,1997, work-around list had four nonoutage items and one

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outage item liste During interviewu, all operatcrs stated thet'they had no operational concerns with-the listed operator work-arounds, In addition, the operators stated that plant management was quick to resolve or repair operator work-around Every Wednesday, the total impact assessment items were discussed. These d!scussions included a description of the deficiency end an estimated resolution date. This exhibited good administrative contral of operator work-arounds, ci Conclusions The inspectors determined that the existing operator work arounds were low in number and, collectively, did not represent a burden on operator effectiveness. The inspectors concluded that the operator work arounds were receiving appropriate management attention. The inspectors concluded that resolution and closure of operator work arounds was scheduled in a timely manner consistent with necessary prioritie O2.2 - Ooerations Sucoort of Condition Reoorts Insoection Scone (40500)

The inspectors reviewed nine condition reports that were assigned to operations for resolution and disposition. These reports are listed in the attachment to this inspection report, Observations and Findinas The inspectors determined that the corrective actions assigned to the condition -

reports were comprehensive and correlated well to the root causes of the condition or proble L

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While reviewing cOnd; tion reports, the inspectors noted that a large number of event codes were being used to classify conditions adverse to quality. The inspectors questioned operations management to determine if such a large number of event codes could lead to inefficiencies or mask repetitive problems. The licensee agreed that too many event codes existed and stated that efforts were in progress to significantly reduce the number of codes, in response to the inspectors'

observations, the licensee stated that, even though there was a large number of event codes, all problems were being reported and properly trended, even to the extent that adverse trends were being identified prior to attainment of the assigned threshold value. The inspectors determined that the licensees' trend ana'ysis program was working effectively despite the presence of a large number of event code f,d2ripjttpq[13 The in9pectors concluded that the condition reports assigned to operations had comprehensive ioot causes and corresponding corrective action The inspectors concluded that, while the condition report system had a large number of event codes, the licensee was in the process of reducing the number of event codes and that this did not affect the trend analysis progra Operator Knowledge and Perfonnance 04.1 Interview of Ooerations Personnel Insoection SCd20e (40500)

The inspectors interviewed 10 operations personnel to determine their knowledge of, involvement in, and perceptions of the corrective action process, Observations and Findinas The operators showed complete knowledge of the initiation, approval, and implementation of condition reports and felt that these functions were working satisf actorily. The operators stated that problems were being corrected in an effective manner and that the closure mechar. ism for operations-initiated condition reports was good. Furthermore, the operators stated that the computer-based tracking of the condition reports was an excellent too During the interviews, the inspectors observed that the operators had a strong teamwork attitude. The operators stated they were always looking for better ways to perform activities, and that there was good cooperation with other organization The inspectors noted that the teamwork concept was readily apparent throughout the sit .. ..

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• - , ConclusiODS The inspectors concluded that operators were knowledgeable of the corrective action program, including the initiation, approval, and implementation of condition reoorts. In addition, the inspectors concluded that a strong teamwork approach was eviden .2 System Walkdowns Insanction scooe (40500)

The inspectors performed visualinspections of the Unit 1 essential safety features switchgear Train B and C rooms, the essentia! cooling water system rooms, the Channel lli and IV battery rooms, and the Emergency Diesel Generator 13 roo Observations and Findinos The inspectors noted that housekeeping was being well maintained. The Unit 1 refueling outage was imminent and various scaffolding was in place with appropriate tags indicating the seismic qualifications of the scaffolding. In general, all areas were very well maintained. Furthermore, the inspectors did not identify any examples of poor _ material conditio Conclusions The inspectors concluded that the material condition and housekeeping of the rooms inspected were excellent. The spaces were being maintained orderly in spite of work in progress for the upcom:ng outage. The inspectors noted no safety significant concern ,

07 Quality Assurance in Operations 07.1 Safetv Review Committee Activities insnection Scoce (40500)

The inspectors evaluated the effectiveness of the Plant Operations Review Committee (the onsite review committee) and the Nuclear Safety Review Board (the offsite review committee) by attending meetings and reviewing committee minutes and audit .

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+ 1 Observations and Findinas

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The inspectors' determined that the Plant Operations Review Committee mede recent progress in ensuring that corrective act!ons match the root causes of problems. ' At j the August 13,1997, Plant Operation Review Committee meeting, the inspectors ;

- noted that issues were discussed at some length, and out ot the five issues on the agenda, two were passed, one was disapproved, and two issues were rescheduled for later in the day. The inspectors found these actions to be appropriat During attendance at the Nuclear Safety Review Board meeting held on August 26, 1997, the inspectors determined that this body demonstrated an excellent questioning attitude coricerning the corrective act;ons and root causes of plant problems, Conclusions The inspectors concluded that the Plant Operations Review Committee provided highly effective reviews and recommendations for item approval or disapproval to plant management. The inspectors concluded that the Nuclear Safety Review Board was aggressive in pursuing resolution to plant problems, ll. Maintank?e M2 Maintenance and Material Condition of Fa:llities and Equipment M 2.1 Maintenance Sucoort of Conditior' rieoorts Insoection Scoce (405001 The inspectors reviewed 17 condition reports that were assigned to maintenance for resolution. These reports are listed in the attachment to this inspection report, Qbietyations and Findinas The condition reports complettd by naintenance were, for the most part, good of forts to resolve the identified deficiencies. However, the inspectors made three

. observations that may warrant additional management attention: the general lack of

detail making the reports unable to be a stand-alone document, the tendency to overlook human f actors in conditions adverse to quality, and the lack of a procedural prohibition for the personal storage of expendable materials.

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- Lack of S'tand Alone QUalitv Condition Report 9710591 identified that the steam generator feedwater preheater

. bypass valve f ailed to close.- The hcensee later discovered that the valve _had ,

actually closed and that the problem was only an indication discrepancy, Th t condition report contained no information to this effect and was not updated to correct the problem statement. The licensee stated that their standard practice was

- to leave problem statements as criginally drafte The irispectors were concerned that inconsistencies of this type could adversely

- affect trending of plant problems. The licensee explained that the work control

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process, which worked alongside the condition report system, contained the missing-

- information and that the trending program was designed to receive information from  ;

- both the condition report and work control processes, in other words, for this -

condition report, the trending program would have an indication rather than a valve problem entered.- The inspectors were satisfied tha: trending was not af fected by

- this discrepanc Although no specific examples were identified, the inspectors observed that the .

presence of inaccurate information in a vaulted condition report could result in a future quality concern whsn this material is accessed on an informational basi The inspectors also noted that most of the condition reports cssigned to maintenance contained detail that was limited and required significant folicwup to

' fully understand the issues and corresponding resolution Tendencv of CAO-D Condition Reoorts to Overlook Human Factors Within Condition Report 97 9004, the quality assurance organization identified that two condition reports assigned to maintenance had been closed without proper attention to human errors that had contributed to the conditions. For example, the licensee determined the condition was caused by human error, but corrective actions

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did not include training or counseling the individuals involved. Quality assurance personnel recognized that this problem was repetitive of findings from an audit in 1995.

2 Tne inspectors note that all of these discrepancies were limited to conditions adverse to quality-department level (CAO-D). This level of conditico report is limited to a single department from generation through closeout. The licensee did not specifically identify a concern, which could be generic to other departments. The inspectors observed there could be a link between the reduced scrutiny and the -

tendency to overlook human f actors issues within condition reports that are categorized as conditions adverse to quality-department level, t

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Personal Storace of Exoendable Materials Within_ Condition Reports 96 4581 and 96-6245, the licenFde identified a repetitive problem with maintenance technicians using expendable rnaterials that had passed their expiration dates. A large part of this problem was caused by technicians storing expendable materials in personal storage areas and using there materials without properly ensuring that the materials had not exceeded their expiration dates, in response, maintenance mansgement communicated to the maintenance technicians the expectation that expendable materials should be returned to the general storage areas af ter each use, so that expired materials could be removed as-a centrally controlled process. However, the inspectors noted that plant procedures had not been revised to prohibit the personal storage of expendable material Considering the repetitive history of the problem, this appeared to be a marginal ,

dispositio Conclusions Although no specific safety concerns were identified as a result of the review of maintenance condition reports, the inspectors observed the following: the lack of a stand alone quality among certain condition reports, the tendency to overlook human f actors in condition adverse to quality for department level condition reports, and the lack of a procedural prohibition of personal storage of expendable material M2.2 C.ntrective Maintenance Condition Records Insoection Scone (40500)

The inspectors reviewed six corrective maintenance condition records to determine if repetitive problems existed and to determine if condition records were being used to improperly modify the plant design. In addition, the inspectors reviewed corrective maintenance condition records to determine if identified problems were being properly documented on condition report forms. The inspectors discussed several of the corrective maintenance condition reports with applicable licensee personne Observations and Findinas The inspectors found that corrective maintenance condition records were used appropriately for repair and replacement of plant equipment. The inspectors found no examples where corrective maintenance condition records were imoroperly used tn modify the plant design. In addition, the inspectors did not find any examples of repeat maintenance had not been identified by the licensee. The inspactors determined that the licensee had performed appropriate corrective actions for the

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c;= Conclusionii The inspectors concluded tisat the corrective maintenance condition records were appropriately used for repair and replacement of plant equipment.--

M2.3 4Recent Maintenance Condition Reoorts-

-- IDipaction Scoce f40!iOO)

The inspectors reviewed 12 repeat maintenance condition reports andTheir '

associated work orders to determine if the corrective actions were adequate to preclude recurrence of the problem.- In addition, the inspectors reviewed the licensee's " Repeat Maintenance Review Committee Guideline," dated December 13, 1994, O

. bservations and Findinas The inspectors noted that the licensee's guideline required planners to examine the -

condition reports foi repeat maintenance and to review the database for repetitive maintenance performed during the previous 18 months. A reliability engineer was responsible for performing a history screening and for trending the repeat maintenance. The inspectors found the corrective actions for repeat maintenance to be adequate to preclude recurrence of problem Conclusions

~ The inspectors concluded that the corrective actions for the repeat maintenance identified by the licensee were adequate to preclude recurrence of the problem Ill. EnainetflD9 E2- Engineering Suppoit of Facilities and Equipment

- E Enoineering Suocort of Ooerating Exoerience insoection Scoce (40500]

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The inspectors reviewed the operational experience feedback program to determine

its etfectiveness in assessing, documenting, and informing appropriate plant pei annel of significant plant events to prevent their occurrence at the South Texas Project. The team reviewed Procedure OP(.PO3-ZX-0013, " Industry Events Analysis,_ Revision 3.

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The inspectors reviewed 31 NRC infortnation notices, fiv6 Institute of Nuclear Power Operation signifi::not event reports, and one institute of Nuclear Power Operation significant opercting experience report, which are identified m the supptr -+ 31 inf ortnation attachment to this inspection repor The inspectors atterided three morning meetings, during which tise operating experience group presented recer.1 operating events at other nuclear plant Dhruv.ationi.and. findings The inspectors found that Procedure OPGP03 ZX 0013 established a uniform method of screening, assessing, and responding to industry operating experienca information, as well as, delineating the ret.ponsibilities for performing evaNations of .

mdustry operating experience events, implementing corrective actions, issuing periodic status oports, and conducting periodic program offectiveness review The inspectors determined that the opvating experience foodback program proc 4 dure provided controls for forwaruing iriformation regr ding events to 'he '

appropriate review personnel. The inspectors also determined that corrective e:Lians resulting from the review of information for operational events were planned, knplemented, and tracked to completion via the candition report proces The operat;ng experience group held morning meetings to evaluate the previous day's condition reports for correlation with operating events. The inspe<: tors observed effective communications between the participants at these meeting Tha licensee commenced an operating experience program effectiveness review in March 1997 and completed the review on July 31,1997. The inspectors found the review to be thorough. The inspectors noted that several problems related to information processing and communications were identified and that corrective actions had been specified, .

Tha inspectors coniirmed that the corrective actions described in the review were in the process of being implemented and that they appeared to be appropriate for the identified problerns, Corjclusions Tho inspectors (.oncluded that operating experience information was being appropriately disseminated and that evaluation reviews and corrective actions for

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operating experience reports were being setisf actority controlled. The problems identified by the licensee related to information processing and communications during an effectiveness review were being properly addressed, r

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E2.2 Engineering suonoit of condition nepons a, . insanglion_ Scone f 40500)

The inspectors reviewed 19 condition reports that were assigned to engineering for resolution. Fnese are listed in the attachment to this inspection report. The inspectors reviewed the reports and arranged meetings with engineers to discuss questions that arose during the reviews, Qhervations and Findings The inspectors considered the condition reports processed by design engineering to be very good. Each of these reports included detailed documentation supporting every technical judgement made in the analysis. Root and probable cause determinations were well supported, it was clear that a conscientious effort was made to fully develop the issue and to apply corrective actions that would completely address the problems and reduce the probability of recurrenc The inspectors considered the condition reports performed by system engineers to have similar qualities; however, the level of documentation was not as extensiv Through interviews with system engineers, the inspectors received additional information necessary to conclude, in each case, that a satisf actory disposition had been achieve The inspectors identified one issue related to Condition Report 96 6757 2, dated June 4,1996, which idt.tified that the component cooling water return line for the Unit 1 reactor coolant pump motor (RCP 1 A) upper lube oil cooler had an indicated flow rate that was greater than 300 gpm (off scale high on the local gage). The licensee determined that the throttled position of the outlet valve was four turns open, which was consis'ent with the position determined during startup testing and the position listed for the valve in the beensee's component cooling water system operating procede ., (OPOP02 CC-0003). Af ter determining that the gage was reading high off scale, the licensee verified the flow rate by using another gage and

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ultrasonic flow measurements. The licensee determined that the flow rate was approximately 330 gpm. For corrective actions, the throttle position of the valve was revised to reduce the flow rate to the required 190 gpm, and the component coohng water mstem procedure was revised to incorporate the new throtile valve positio The inspectors noted that the licensee did not assess the potential for tube erosion and fretting from the increased component cooling water flow (330 versus 190 gpm) in the reactor coolarit pump motor lube oil cooler. This was of concern because the licenseo could not bound the period of time that this condition existe In response to the inspectors' concern, the licensee investigated the effect the high flow had on the lube oil cooler. The licensee determined that the maximum flow for the lobe oil cooler was listed as 200 gpm in the vendor manual. The licenseo contacted the vendor and found that the limiting flow for the lube oil cooler was

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based on a norzle flow velocity of 10 feet per second, which correlated to a flow rate of approximately 220 gpm. This limiting velocity was chosen to ensure long term integrity by avoiding erosion of the inlet and outlet nozzles and the divider

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plate. The licensee also determined, based on the vendor information, that the flow rate threshold for heat exchanger tubing erosion and vibration concerns was greater than 300 gp s ihe licensee contacted an Electric Power Research institute representative, who

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then performed an evaluation of the effects of operation with a flow rate of 330 gpm in this system. The Electric Power Research Institute representative ,

determined tnat this flow rate was not high enuugh to produce erosion corrosion and vibration damage of carbon steel piping. The licensee concluded that no appreciable damage had occurred to the upper bearing oil coole The inspectors determined that the licensee's original corrective actions for this condition were weak, COnclu112DS

In general, the licensee's engineering department personnel performed very good condition report evaluations. However, in one case personnel did not evaluate the potential for damage resulting from an unexpectedly high component cooling water flow rate to the reactor coolant pump motor upper bearing oil coole E2.3 Engineerina Suoport for Condition Reoort Enaingering Evaluallon insac.ctionScone (405001 The inspectors reviewed nine condition report engineering evaluations and discussed these issues with licensee personnel, Obsenations and Findings The licensee issued a condition report engineering evaluation as a means to identify potential problems and improvements requiring engineering evaluation. The inspectors were able to resolve all questions resulting from the review of the listed condition report engineerk.g evaluations, in some cases, particularly with system engineers, the inspectors required additional information through interviews with the responsible engineer. The only detrimental aspect of the reports, noted by the inspectors, was a lack of detail provided in the documentation, Conclusions Engineering provided satisfactory support to operations and other plant groups through the disposition of condition report engineering evaluations, though in some cases, documentation detail was lackin . .- .- . .. -_ . - - , - , .

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E2.4 Engineerina Swpa" of Operabihty Determinations laspection Scongl4D5QQ)

The inspectors reviewed eight operability determinations performed by engineering to support plant operations. The inspectors interviewed licensee engineers for clarification on some item .Qhigtymions and Findinas in each case, the inspectors determined that engineering had satisf actorily assessed the operability implications of the identified discrepant conditio During review of the operability determination associated with Condition Report 97 2173, the inspectors identified a problem with the manner in which the licensee had handled the discovery of a nonconforming condition. The operability question centered on the Unit 1 Pressurizer Power Operated Relief Valvo 2RCPCV0655A that had a stroke time that was in excess of the specified stroke time during a surveillance test. During the investigation, the licensee discovered that the loop seal to the power-operated relief valve was insulated, which was thought to have contributed to the stroke time problem. The placement of insulation on the loop seals was identified by the licensee to be contrary to Westinghouse installation requirements for the pressurizer power operated relief valves. The licensee issued Condition Report 97 2700 to initiate a work order to remove the insulation from the power operated relief valve loop seals. However, neither in this condition report nor Condition Report 97 2173, did the licensee identify the discrepant insulation configuration as a separate condition. As a resu't they did not perform a review for probable causes or a walkdown to determine whether other similar insulation discrepancies existed. While the licensee did check all power operated relief valve loop seals for the presence of insulation, the team determined that the corrective actions were weak because they did not extend the review to include other piping systems. The basis for this concern was that the cause of the insulation discrepancy appeared to be a generic original construction deficiency, which would not be restricted to the power operated relief valvo loop seat Conclusions Engineering performed satisf actory assessments of the operability implications of degraded plant conditions. An operability determination concerning the pressurizer power operated relief valve was satisf actory, but the corrective actions for a related insulation discrepancy were weak because they did not include the evaluation of other systems for similar insulation discrepancie _--- .

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E2.5 fAinor Desian Chn0D ' lainectioDJcroe (405001 The inspectors selected and reviewed a sample of minor design changes that were assigned to engineering, as listed in the attachment to this inspection report. The inspectors arranged meetings with licensee personnel to discuss questions that arose during the reviews. The inspectors also reviewed Procedure OPGP05 ZA 0002, "10 CFR 50.59 Evaluations," Revision Oh?funtions and FindinDS Procedure OPGP05 ZA 0002 provided the method and criteria for determining if the change was a trivial change not requiring a 10 CFR 50.59 safety evaluation, if a change met the definition of " trivial," it did not (according to the procedure)

constitute a change to the f acility, even though it may affect plant drawings or text within the Final Safety Analysis Report. The procedure stated that a change was considered trivial if it met the following criteria:

• Was not safety related

• Was not important to safety

• Did not affect the safety of operations or the safe shutdown of the plant

• Was not the basis for the NRC safety review as documented in the safety evaluation report and was not required by the standard review plan Changes meeting this criteria were processed as minor design changes, which did not require a 10 CFR 50.59 safety evaluatio The licensee believed their position was consistent with the NRC definition of " trivial changes" las discussed, in part, in NRC Inspection Manual Chapter, Part 9900, 10 CFR Guidance, "10 CFR 50.59 Changes to Facilities, Procedures and Test (or Experiments)," Section D.7.d, dated January 1,1984), which includes the following:

"It should be noted that the SARs for a number of older facilities conta!n floor plans of onsite buildings that may include trivial detail such as the locating of dividing walls between various offices. From a rigid reading of 10 CFR 50.59, it is possible to infer that the removal of a dividing wall betwan two offices constitutes a chtnge from the f acility described in the SAR, and therefore reauires a safety evaluation. However, the intent of 10 CFR 50.59 is to limit the requirement for written safety evaluations to f acility changes, tests, and experiments which could impact the safety of operations."

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4 However, based on preliminary conversations with the NRC program office staff and more recent guidance, the inspectors believed a trivial change was intended to include editorial, organizational, typographical and physical changes totally divorced from the plant, but was not intended to extend to changes involving physical changes to the plant configuration that resulted in a revision to plant drawings or text included in the Final Safety Analysis Repor During a review of a sample of minor design changes and trivial change 10 CFR 50.59 screenings, the inspectors identified 19 examples where the licensee had made a trivial change. Each of the 19 minor changes involved a revision to

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drawings in the Final Safety Analysis Report, but did not include an unreviewed safety question evaluation. This evaluation is required by 10 CER 50.59 when a ch6nge is inade that results in a change to the f acility as descriad in the Final Safety Analysis Report. The inspectors considered the drawing changes to constitute changes to the f acilit The 19 examples identified by the inspectors are listed belo * Minor Design Change Package 95 8913 18, Revision 0, removed the internals of the fuel oil collection tank vent return check valve of Emergency Dicam Nnerator 12. The licensee's justification for the change was that it was ex' ey to eliminate the redundant check valve and reduce the nur@ r' a nponents that were tested as part of the ASME Section XI inservice testing program. This change involved a revision to Drawing SO159F00045#1, which was included in the Final Safety Analysis Report. In addition, this change was made to a safety re;6ted system which was not consistent with the licensee's 10 CFR 50.59 safety evaluation procedure. As noted above, this procedure states that a trivial change cannot be safety related, in this case, the licensee determined that, although the chang 9 affected a safety-related system, the change itself was not safety related. However, the licensee representatives stated that it was their expectation that any change affecting a safety-related system should not be handled as a trivial change. As such, the use of the trivial change in this instance did not meet the licensee's expectations. Consequently, the licensee issued a condition report for this matte * Minor Design Change Package 95 110661 2, Revision 0, installed a drain valve to the closed loop auxiliary cooling water line upstream of instrument Air Compressor 11. This change involved a revision to a drawing which was included in the Final Safety Analysis Repor * Minor Design Change Package 95-9125 1, Revision 0, involved adding a new valve to the seal water flush line on Spent Resin Transfer Pump 2A. This change involved a revision to a figure which was included in the Final Safety Analysis Repor . - -- . _

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• Minor Design Change Package 95 753 10, Revision 0, involved relocating the sensing line to the inlet line of a discharge valve on the main turbine lif t oil pump where it would be exposed to lif t oil pump discharge pressure. This change involved a revision to a drawing included within the Final Safety Ana!ysis Repor * Minor Design Change Package 95 2757 2, Revision 0, involved replacing two obsolete chart recorders with one which monitored parameters associated with the condensate polishing system mixed bed regeneration process. lt also included installing a voltage divider resistor network. This change involved a revision to Drawing 9S219F20014#2, which was included in the Final Safety Analysis Repor * Minor Design Change Package 96 917 1, Revision 0, replaced the reverse osmosis product tank level transmitter with a level transmitter that had a built in display. The change also abandoned in place the reverse osmosis product tank indicctor. This change involved a change to Drawing 60210F00008, which was included in the Final Safety Analysis Repor * Minor Design Change Package 96 5288 15, Revision 0, revised airflows in Rooms 313/314 and 316 to t.atisfy noise concerns and assure air flow into Room 316 was maintained in accordance with system design flow rate. This change involved a change to Drawing 9V25002, which documented individual room airflows and was included in the Final Safety Analysis Repor * Minor Design Change Package 96 3733 3, Supplement 0, changed the connection of the degasifier transfer header dissolved oxygen analyzer so that the sample was taken from the bottom of the piping instead of the top of the piping, lhe modification also replaced the flow indicator control valve af ter the analyzer element. This change resulted in a revision to Figure 9.2.3-4, which was included in the Final Safety Analysis Repor * Minor Design Change Package 96 8766 1, Revision 0, installed a 1-inch drain valve for the moisture separator drip tank pumps. This change revised Drawing 8S171MPA006 9, which was included in the Final Safety Analysis Repor * Minor Design Change Package 96 2460 3, Supplement 0, revised the chemical and volume control drawing to reflect that Valve CV0197 was normally closed. This change revised Drawing 9F5007#1/2, which was included in the Final Safety Analysis Repor .

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• Minor Design Change Package 95 7420 2, Revision 0, relocated a number of lube oil cooler outlet localindications and the associated test wells since the exisfng lobe oil cooler outlet temperature indicators did not provide an accurate indication of temperatures. This change revised the temperature indicator locations in Figure 0.5.71, which was included in the Final Safety Analysis Repor * Minor Design Change Package 95 479 13, Revision 0, added a sodium analyzer, associated tubing, and isolation valves to the condensate polishing demineralizer regeneration system. This change revised Drawings 9Z329200042#2 and 95Z219F20014#2, which were included in the Final Safety Analysis Repor * Minor Design Change Package 96-7923-2 Supplement 0,, modified the reactor head vent manifold to remove the interference with tha reactor stud tensioners and allow the reactor stud installation and removal while the vent manifold was in place. The change was listed as quality related, a classification defined by the licensee as not safety related, but of a nature that is considered important to safety. The preliminary screening indicated that this change was identical to and addressed by an existing approved 10 CFR 50.59 screening and unreviewed safety question evaluation. The licensee supplied Plant Change Form 178696A, dated March 3,1993, which added a manifold to the flange connection of Valve 1-RC 132 to f acilitate vessel venting. The screening for this modification stated that this was a trivial change since only the nonsafety related portion of the reactor coolant piping was affected. These changes revised Drawing SR149F05001#1, which was included in the Final Safety Analysis Report. In addition, the changes were made to a quality related part of the syste * Minor Design Change Package 95 478 3, Revision 0, replaced a number of instruments in the secondary samphng sustom and authorized rerouting process tubing and reworking panels. This change affected Figures 9.3.21 through 9.3.2 8, which were included in the Final Safety Analysis Repor * Minor Design Change Package 95 5647 6, Supplement 0, installed an isolation valve in the instrument air system to allow maintenance to secure instrument air to the operator for nonreturn Valve ES0031 without securing a major part of the instrument air system. This change revised Drawings 6S139F20009#2 and 7T089F10001#2, which were included in the Final Safety Analysis Repor * Minor Design Change Package 95 14448 6, Supplement 0, installed an instrument air isolation valve. This change revised Drawings 6S139F20009#1 and 7T089F10001#2, which were

' included in the Final Safety Analysis Repor .

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• Minor Design Change Package 96 9001 1 Supplement 0, added interconnecting piping and an isolation valve to allow pumping of fuel oil from the diesel generator fuel oil storage tank back to the auxilisry fuel oil storage tank in me yard to allow 10 year surveillance inspections of the standby diesel generator fuel oil storage tank. This change was listed as quality related. This change revised Drawings SQ159F00045 #2 and 60170F00011, which were included in the Final Safety Analysis Repor * Plant Change Form 179400A, dated July 7,1994, deleted the electric hoist from the monoraillocated in the Chemical and Volume Control Charging Pump 10 room, disabled and abandoned power to the hoist, and modified a support. This change affected Figure 1.2.26, which was included in the Final Safety Analysis Repor * Minor Design Change Package 94 2665 4, Supplement 0, dated August 6, 1996, removed the electric hoist and two wheel trolley from the Chemical and Volume Contu. System Charging Pump 1 A room. A 10 CFR 50.59 scieening was not performed because the licensee identified that a 10 CFR 50.59 screening for an identical change had addressed this change in its entirety. The original change was Plant Change Form 179400A The change af fect2d Figure 1.2.26, which was included in the Final Safety Analysis Repor The licensco considered each of the 19 examples to meet the definition of a "tnvial change" (i.e., minor changes which had no potential safety impact). The licensee subsequently determined that one of the changes did not meet the licensee's expectations, in each case, the 10 CFR 50.59 screening question asking whether the change resulted in a change to the f acility as described in the Final Safety Analysis Report was marked "No." The inspectors concluded that the 19 examples did not repr69ent trivial plant configuration changes because they involved revisions to plant drawings in the Final Safety Analysis Report. Because the modifications had changed the f acility as described in the Final Safety Analysis Report, an evaluation wes required by 10 CFR 50.59 to determine whether an unreviewed safety question existe The need to perform and document a safety evaluation for 19 design change notices was identified as an unresolved item (50-498;-499/9723-02). This issue was forwarded to the NRC program office for further review to determine if the changes required 10 CFR 50.59 safety evaluations, c. Conclusions The inspectors found that the licensee's 10 CFR 50.59 Review Guide appeared to define * trivial changes" more broadly than intended. The inspectors identified 19 examples wherein safety evaluations potentially required by 10 CFR 50.59 were not performe ___.m_ _ ____.__ _ _ _ _ _ _ - -.-.

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E2.6 ' , Temoorarv Modifications  !

- Insoection Scong Th6 inspectors reviewed five temporary modifications to determine if the j

- modifications were being used as long term solutions _n i lieu of component repairs or ll'

,- permanent modifications. The inspectors reviewed the age and number of

- temporary modifications for each unit. The inspet. tors conducted walkdowns of two f of the five temporary modifications and interviewed licensee personnel to obtain j

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additional information. _  ;

, Observations and Findinas Four temporary modifications were installed on Unit 2 and nine temporary i t

modifications were installed on Unit 1. The inspectors noted that the oldest I

temporary modification on Unit 2 was installed on March 26,1997, and the oldest -

on Unit 1 was installed on May 23,1996. None of the temporary modifications on ,

either unit were safety related. However, some of the modifications were installed on nonsafety related aspects of safety related systems, Conclusions .

i The inspectors concluded that the modifications had been installed in accordance with the modification package. Overall, the inspectors concluded that the licensee's -

temporary modification program was well implemente :

. - E4 Engineering Staff Knowledge and Performance E Interview of Enoineerina Personnel C a, lasagetion Scoce 140500) ,

The inspectors interviewed two system engineers and two design engineers to determine their knowledge of and interaction with the corrective action progra Qbiervations and Findinas The individuals interviewed all had satisf actory knowledge of the corrective action program and all expressed confidence in the capability of the program to meet its

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objective , Conclusions

- - The sample of engineers interviewed were knowledgeable of, and confident in, the

- corrective action program.

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E7 Quality Assurance in Engineering Activities E7.1 Quality Assurance Audits and Self Assessments Insoection Scops To evaluate the effectiveness of the controls for identifying and resolving plant probicms, the inspectors selected and reviewed the corrective actions for three observations from the quarterly monitoring reports, in addition, the inspectors reviewed the procedures for quality assurance monitoring of engineering to determine the frequency of audits, reporting requirements, and followup of findings, Qhany,ations and Findmg3 The inspectors determined that the licensee provided good oversight of engineering activities. The licensee had an oversight planning and scheduling review team that met quarterly to review the current and next two quarters of the oversight pla The team reviewed areas that might need assessment prior to the scheduled activity and issued a quarterly report. The inspectors reviewed the review team's third quarter 1997 oversight planning and scheduling meeting minutes and updated oversight plan. The inspectors determined that the quarterly report thoroughly evaluated the assessment areas and revised the schedule accordingl The inspectors reviewed three quarterly monitoring reports of engineering activities and found that, for two of the reports, the corrective actions resulting from the reports were appropriat However, the inspectors identified that corrective actions associated with Quarterly Monitoring Report MN 96-0-0892, dried November 13,1996 were not effectiv The purpose of this monitoring activity was to assess the switchyard to determine if the drawings in the Final Safety Analysis Report were current with the switchyard drawings, verify that the switchyard drawings were in the records management system, and verify that the switchyard drawings in the switchyard and the records management system were current. The licensee determined from this monitoring activity that the switchyard drawings in the Final Safety Analysis Report, including one line drawings, were current, but that the drawings located in the records management system were out of date by up tu seven revisions. The licensee also found that, out of a sample of six drawings found in use in the switchyard, there was a conthet in the revision level of one of the six drawings, whereas the other five drawings could not be lccated in the records management syste The licensee initiated Condition Report 96-14319, dated November 18,1996, to identify this problem. However, as of the date of the inspection, the one line drawings were still out of-date. The licensee stated that the switchyard draw.ngs, which were not saf ety related, were archived early in the plant's life and were not updated because the switchyard design was not owned, operated, or maintained by onsite groups. The licensee's corporate office was responsible for all of these

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activities. The licensee stated that controlled switchyard drawings were maintained at the corporate headquarters in Houston. The inspectors interviewed a system eligineer who had used the out of date drawings during switchyard walkdowns and found out that the engineer did not realize that they were not current. The inspectors considered that effective corrective action for Condition Report 9614319 should have resulted in copies of the controlled drawings maintained in the Houston office being distributed to the site records management system. As a minimum, current one line drawings should be available to operations and engineering staf Although no specific regulatory requirement existed, the inspectors concluded that not having controlled switchyard drawings on site was a weakness in the licensee's configuration control program and corrective actions for Condition Report 961431 , Conclusions The inspectors concluded that, in general, the licensee provided good oversight of engineering activities. However, in one case, corrective action for an identifieJ finding was not effective. The lack of controlled switchyard drawings at the site was considered a weakness in the licensee's configuration control progra E7.2 Root Cause Analvsis Inspection Scone f40500)

As part of the review of condition reports, the inspectors evaluated licensee personnel performance in assessing the root cause or probable cause of the identified conditio Observations and Findinas The inspectors did not identify any instances where the root or apparent ceuse of a condition appeared to be unsupported or superficial. In all cases, the root causes were appropriate for the identified conditio Conclusions The licensee performed credible reviews of condition reports to ascertain the root or apparent cause of the condition _ __ _ _ . .

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l E8 Miscelleneous Engineering issues f

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f E8,1 IClosed) Licensee Event Reoort 50 499/94-02: Standbv Diesel Generator 22 Piston Failure Backaround 192903) I

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During a March 2,1994, refueling outage surveillance performed on Standby Diesel f Generator 22, Piston 4R, was discovered to be cracked on the lower piston tkirt and f also between the number 6 and 7 oil rings. An extensive examination of the remaining cylinders of the standby diesel generator and a review of inspection

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videotapes of the other standby diesel generators led the licensee to conclude that i no other portion of Standby Diesel Generator 22 or any of the other five standby diesel generetors was af fected by this problem. The licensee was unable to  ;

definitively determine the cause of this f ailure, but postulated that foreign material  ;

had been introduced into the cylinder, resulting in an eventual loss of lubrication and high stresses. The licensee's corrective actions for this event included the ,

following:

• Piston and cylinder liner for Cylinder 4R were replaced

• All cylinders in Standby Diesel Generator 22 were examined and some other parts were replaced to preclude a possible forced outage

• Alllower oil rings and piston end caps on Standby Diesel Generator 22 were removed based on the manuf acturers' recommendation

• Standby Diesel Generator 22 was tested cxtensively, including a 168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> ,

run  ;

• Additionallower end inspections of Standby Diesel Generator 22 were scheduled to be performed every 6 months during the next fuel cycle .

• Other plants using the same diesel engines i.ere informed by the licensee e' Previous Unit 1 and 2 boroscopic inspection videotanes were reviewed to determine if other engines were similarly affected r

. Insoector Followun The inspectors reviewed documentation covering the corrective actions described 1

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above and discussed the details with licensee engineers. The inspectors determined

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that the licensee completed the corrective actions. However, the inspectors noted

that the licensee had not addressed the issue of foreign materialintroduction into the subject cylinder within the scope of the investigation, such as reviewing foreign

- material exclusion procedures. The inspectors reviewed Station Problem

Report 94 0551, which investigated this issue, and noted that the probable root

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cause.was stated to be the trapping of tin and other metallic grit. The report did not  !

specifically address a foreign materialissue. On further discussion, the inspectors learned that the licensee engineers felt that an intrinsic particle rather than a foreign-particle was responsible for the event. The licensee also stated that oil analyses, [

internalinspections, and a review of maintenance packages were conducted to  !

identify the potential for foreign material, but that no evidence of this condition was {

foun ! Conclusion j The inspectors concluded that the licensee's actions were satisf actory to resolve the piston f ailure occurrenc ML.ManagemenLMeetings  ;

, X1 Exit Meeting Summary-The inspectors presented the inspection results to members of licensee management I by telephone at the conclusion of the inspection on September 4,1997. The licensee representative acknowledged the findings presente :

The inspectors asked the licensee representative whether any materials examined i during the inspection should be considered proprietary. No proprietary information was identified, j

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SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSDNS CONTACTED  ;

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Licanats R. Brown, Senior Reactor Operator, Shif t Supervisor l T. Cloninger, Vice President, Nuclear Engineering i

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J. Cook, NSSS Supervisor W. Cottle, Executive Vice President j

H. Danhardt, Supervisor, Operating Experience Group M. Forsyth, Manager, Operating Experience Group  :

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T. Frawley, Senior Reactor Operator, Shif t Supervisor M. Hill, Plant Operator-  !

" T. Jordan, Manager, Systems Engineering -

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. M. Kanavos, Manager, Mechanical / Civil Engineering  ;

A. Kent, Manager, Electrical and Instrumentation and Control Systems T. Koser, Licensing Engineer - l D. Leazar, Manager, Nuclear Fuel and Analysis L. Martin, General Manager l

R. Masse, Plant Manager, Unit 2 M. McBurnett, Licensing Manager B. Mookhoek, Licensing Engineer

G. Parkey, Plant Manager, Unit 1 R. Pell, Shilt Technical Advisor / Supervisor ,

Si Phillips, Vendor Technical information Program Coordinator j P. Pieknik, Design Engineer  ;

S. Saylors, Plant Operator R. Scarborough, Shif t Technical Advisor i

V. Starks, Design Engineer S. Thomas, Manager, Design Engineering Department D. Valley, Staff Quality Assurance Specialist'

NBC D. Loveless, Senior Resident inspector j

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ITEMS OPENED, CLOSED, AND DISCUSSED Clased  :

'50:499/94 02 LER Standby Diesel Generator 22 Piston Failure i

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I LIST OF DOCUMENTS REVIEWED J

Condition Benotts i

hiaintenance_ Condition Reoorts 90 4400 RHR pump f ailed surveillance test for dif ferential pressure 964581 Expendable materials, shelf life 96 5148 RHR Miniflow valve failed to open 900245 Use of outdated neolube 96 6492 AFW valve f ailed to open 90 7009 Condition report closed without apparent cause or corrective actions 968334 Steam generator PORV failed to stroke closed 908053 Open loop pump motor smoked 968858 Interference betwoon damper and support 90 10771 Essential chiller hot gas bypass valve f ailed to close 9013647 HVAC damper would not open '

97 1193 Steam generator PORV stroke time excessive 97-3150- Repeat instances of f ailing to writo condition reports 97 5818 Repeat material control and traceability problems 97 8384 Missed EDO surveillance 97 9004 Condition reports did not address all corrective actions needed 97 10591 Steam generator feedwater preheater bypass valve failed to close Engiacering Condillon3cnous Qcsign Engineering Condition Reoorts 96-3547 Decrease in motor operated valve stoke time 90 4624 Design change implementation deficiencies 9010432 Design change did not consider all design inputs 90 13058 MOV motor changed without equivalency documentation 90-13101 Lack of procedures for vendor documents 97 1613 EOP value for AFW flow 97-2815 Twn pipe supports not installed SystenLEngineerina Conditicp Reoorts 90-5157 Failure to evaluate pump operability 96 6659 EDG 11 Standby tube Oil Pump High D/P 96 7764 Three repetitive f ailures on steam dump valves 96 8171 Pressurizer safety valve outside tolerance 96-9187 diaphragm valve f ailure trend 9610073 Only a 50.59 screening was provided 96 14615 Pump d/p too high 97 4056 Main steam safety valve set pressure low

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97 8198 Excessive number of mcintenance preventable functional f ailures 96-4024 Loose exhaust expansion joint bolts on EDG #13 96 4861 EDG #22 high thrust bearing clearance 96-4862 High Rate of Oil Consumption on DG #12 96 6757 2 High CCW Flow Rate to RCP Lube Oil Coolers OptMiiDDLCondition Reoorts 97 505 Lube oil cooler 3 way inlet / outlet valve was mispositione Valve for ECO 75059 found out of positio ,

97 1992 Few training /line management observation of OJT/OJE activitie Valve EH 0103 found in incorrect closed positio Radwaste operator hung danger tag on wrong handswitc ECO provided inadequate protection for v,r NRC inspector found valve MS 0214 in i;. correct closed positio Three air volume dampers were found in wrong position Spent Fuel Pool Level dropped 2 inche Condition Report Enaineerir.g_Eyaluations 9511853 Vent line bent 20 degrees from vertical 9513270 Use of uncalibrated strain gages 96 3734 Olister on Unit 1 personnel airlock 96 6102 EDG #12 exhaust valve timing dimensions 97 2173 Pressurizer PORV open time out of specification 97 3286 Unauthorized leed shielding 97 5785 Replace ball throttle valves with globe valves .97-753 Incorrect locked rotor amps 97 2358 Yoke blemishes containment isolation valve QRRabildy and Reoortability Revievg ,

CR 96 5472 Surveillance test discrepancy CR 9613095 Leak rate test discrepancy CR 96-16035 Feedwater isolation wrong valve hydraulic modulator oil used CR 97 0587 Inadequate surveillance testing CR 97 2173 Pressuriter PORV loop seals insulated, contrary to vender recommendations CR 97 4758 No hydrostatic test of weld CR 97 8252 Motor operated valve overthrust CR 9711724 Te. ting of interlock function of FWlV circuit Cnunctive Maintenance Condition Records 97 1317 Remove insulation and furmanite leaks in steam generator 97 1308 Remove iisulation and formanite leaks in steam generator 97 6994 Perform engineering evaluation to deterrnine corrective actions for leakby 90 15990 Unit heater in C train of ECW will not run

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96 14460 EDG has 2 slip sing brushes not making contact with the slip rings  !

95 7748 BOP auto started at greater than allowed acceptance criteria  ;

i 96 299 Valve will not open automatically or manually  ;

e 97 5761 Outlet temperature indicator of essential chiller is out of calibration low  ;

i 96 11609 CCP has various lube oil piping leaks . [

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96 14224 MSIB will not open due to f ailure of the solenoid to pass air to the operator  ;

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' 96 14475 MSIBs have experienced problems with the actuator pneumatic control system .

t 96 8334 SG PORV failed to stroke closed 95 10256 MS PORV high and low pressure switches f ailed on several occasions 96-4056 Mixed bed caustic supply valve diaphragm leaked i

96 438 CW pump traveling screens run constantly in auto and stop . [

97 1933 Valve f ailed inservice test Beneat Maintenance Work Orden t

97422 Repair EDG slip ring brushes 95018903 Correct BOP auto start problem 73983 Correct valve which would not open ,

. 79992 Inspect, test, calibrate, and rework essential chiller 87499 ~ Repair SG PORV 81568 Repair mixed bed caustic supply valve diaphragm  ;

Mjnor Desian Chanags j 95 12056 Interference with the heat exchanger flange stud  ;

96 5563- Add a threaded connection at the end of vent configuration i 95 13533' Double gasket for installation of Kinney valve on SBDG

' 96 7960 Replacement of PASS liquid control switch -

95 12061 Add spacer between stem adapter and the top of the stem 96 2460 Change P&lD to show valve normally shut

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-95 8552 Remove the essential chille s motor bearing acceleromaters 95 3349 Install a 3 inch pipe in the CP sump discharge line 95 8913 Removal of valve internals from check valve DO 0169 Minor Damian Chanae 50.59 Evaluations 95 11061 Install drain valve to closed loop ACW line -

-95 9125 Add new valve to the seal water flush line 95 753 Correct pressure switch location on the P&lD l

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95 2757- Install voltage divider resistor network 96 917 Replace reverse osmosis product tank level transmitter f i

95 5288E Adjustment of altflow in EAB tooms t

96-3733' Change connection c he degasifier transfer header dissolved oxy 9en j analyzer i

96 8766 Install 1 inch drain valve for moisture separator drip tank pumps 96 2460 Revise P&lD for CVCS in reflect correct position of valve i i

97 7695 Install drain down valve to the water separator - >

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, 96 12682- Rework of valve u joint angle i

95 1284 Evaluation of the capability of 2 breathing air stations ,

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95 13394 Reactor vessel stud hole cover seals modification .

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t 96 14199 Installation of an instrument air isolation valve 96 9790 Replacement of impeller, shaf t and packing to Mechanical Seals 95 6172 Installation of drain lines and valves to the OC strainer 96 9916 Add tubing from valves which will mako instrumentation function properl !

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95 14254 Raise high' alarm setpoint of the fresh water system chlorine analyzer 95 11340 - Remove ORP analyzer from the control circuit of the stroke controllers -

96 8813 - Add isolation valves to the sapling system- -

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96 11980 Remove abar.doned hose connection piping had heat tracing from the fresh water settling basin 95 14448 Add isolation valve to the instrument air system 97 8304 Add auto vent valve to the FWlV filter skid 95 7445 Remove abandoned equipment at the hypochlorite pot skid 95 7420 Relocate thermometer /thermowells in EDG lube oil system 95 479 Add orion !ow level sodium analyzer 94 2665 Remove electric hoist and trolley from the CVCS charging pump room 96 7923 Modify the reactor head vent manifold 95 478 Replace secondary sample system instrumentation 179400A Remove electric hoist 96 5647 Install an instrument air iso!~ in valve 95 14448 Add instrument air valve to isolate valvo 96 0001 Add 3" line with isolation valve to allow drainage of EDG fuel oil storage tanks Temoorary Modifications T2 97-8313 Replace ECW Pump 20 seal water flow indicator T2 97 5710 Replace ECW Pump C seal water flow indicator T2-07 6255 Disable alarm for RCP 28 standpipe fill valve level high annunciator window To 97 8139 Open M.C. breakers to 4 RCP space heaters To 961922 Secure air supply to mast doors of refueling machine mast due to leak Plant Procedures Procedure Numbu Bevision .Ittle OPGP03 ZX-0013 3 " Industry Events Analysis" OPOP01 ZA 0001 1 " Plant Audits" OPOP01 ZA 0002 1 " Site Quality Surveillances" OPOP02 ZA 0003 4 " Quality Monitoring Program" OPOP01 ZA 0006 1 " Independent Plant Assessments"

OPOP01 ZA 0015 4 " Oversight Planning and Scheduling Process" OPGP05 ZA 0002 6 "10 CFR 50.59 Evaluations"

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o Misc.ellantaut Docmucats ,

Opetallog Exoeriencg Review

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Information Notice 9014, " Degradation of Radwaste Facility Equipment at Millstone Nuclear Power Station, Unit 1"

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Infor' otion Notice 9617, " Reactor Operation inconsistent with Updated Final Safety Anal; * Reports"

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Information Notice 95 03, Supplement #1, " Loss of Reactor Coolant inventory and Potential Loss of Emergency Mitigation Functions While in a Shutdown Condition" ;

Information Notice 96 22, " improper Equipment Settings Due to the Use of Non Ternperature Compensated Test Equipment" information Notice 96 23, " Fires in EDGs Excitors Puring Operation Following Undetected Fuse Blowing" Information Notice 97 49, "B&W once through steam generator tube inspection findings" information Notice 97 29, " Containment inspection Rule" Information Notice 97 27, "Effect of incorrect Strainer Pressure Drop on Available Not Positive Suction Head" Information Notice 97 20, " Degradation in Small Radius U Bend Regions of Steam Generator Tubes" Information Notice 97 21. " Availability of Alternate AC Power Source Designed for Station Blackout Event" Information Notice 9615. " Unsxpected Plant Performance" Significant Event Report 9614. " Operation with Reversed NIindicators" Significant Event Report 90-15, " inappropriate Operator Actions During Low Power Operations" Significant Event Report 9616, " Multiple Personnelinjuries caused by High energy Reheater Drain Pipe Failure"

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o Significant Event Report 97 01, "Nonconservative operations during isolation of a Reactor Recirculation pump seal leak" Significant Event Report 97 04, " incorrect use of EOPs during a potential ATWS" Significant Operating Experience Report 96-01, " Control Room Supervision, Operational Decision making, and Teamwork"

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