IR 05000498/1998006
| ML20236M325 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236M295 | List: |
| References | |
| 50-498-98-06, 50-498-98-6, 50-499-98-06, 50-499-98-6, NUDOCS 9807140021 | |
| Download: ML20236M325 (32) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-498,50-499 License Nos.: NPF-76, NPF-80 Report No.: 50-498/98-06;50-499/98-06 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483
. Dates: May 3 through June 13,1998 Inspector (s): D. P. Loveless, Senior Resident inspector W. C. Sifre, Resident inspector G. L. Guerra, Resident inspector C. F. O'Keefe, Resident inspector, Fermi Station Approved By: J. l. Tapia, Chief, Projects Branch A Division of Reactor Projects Attachment: Supplemental information l
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9007140021 900708 PDR ADOCK 05000498 G PDR i.
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EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/98-06; 50-499/98-06 Ooerations
. The professional demeanor of licensed operators in the main control room, the use of self-verification techniques, the use of closed-loop communications techniques, and operator knowledge were considered strengths (Section 01.1).
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. In general, equipment availability and material condition were excellent and plant housekeeping was good. However, minor deficiencies were noted. On one occasion, a worker left a safety-related ventilation boundary door open and unattended (Section O2.1).
. The auxiliary feedwater train inspected was in excellent material condition, was properly aligned for standby conditions, and was considered to be operable. However, minor deficiencies were identified (Section O2.2).
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Maintenance
. In general, technician performance during maintenance activities observed was very good. However, on one occasion, technicians attempted to perform work on a solid state protection system component when the work instructions were known to be insufficient to provide adequale guidance (Section M1.1).
. Surveillance testing was well conducted in accordance with approved procedures and properly implemented the Technical Specification surveillance requirements (Section
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. The licensee's request for a notice of enforcement discretion to permit repairs of the Fuel Handling Building Exhaust Booster Fan 11B satisfied the NRC's policy for enforcement discretion. Certain information related to previous booster fan failures was not provided to the NRC. However, after a thorough review, the information was not considered material to the final NRC decision (Section M2.1).
. The licensee's workload has remained significantly below the established goals in the operational readiness plan and the licensee was clearly managing their work in a manner to maintain the workload at acceptable levels. Therefore, further tracking of the maintenance backlog was not deemed necessary (Section M8.3).
Enoineerina
. Engineering evaluations related to the installation of a temporary reverse osmosis skid
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were of very good quality. The engineers' identification of a potentialinteraction between the temporary system and the charging pump suction line was excellent (Section E1.1).
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The licensee's practice of discharging the full core during each refueling outage did not represent a change to the facility or a change to the procedure described in the safety analysis report and thus did not require a review pursuant to 10 CFR 50.59 (Section E8.1).
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Plant Succort
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in general, radiological controls were in place and meeting minimum requirement However, two examples of a minor violation indicated that workers were failing to implement proper contamination frisks (Section R1.1)
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Two examples of a failure to properly implement the fire protection program with respect to fire brigade training drills constituted a violation of 10 CFR Part 50, Appendix ]
Corrective actions identified following an improperly conducted drill were not ,
implemented within a reasonable period of time (Section F1.1).
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The technical support centers and operations support centers in both units, as well as the emergency offsite facility and the primary and backup meteorological towers were
readily available and maintained for emergency operation (Sections P2.1 and P2.2).
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Protected area barriers, security detection and assessment equipment, and temporary security compensatory measures were considered excellent (Section S1.1).
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Table of Contents l l. Operations . .. . . ... . . . .. . .. . . .. . .1 O1 Conduct of Operations . . . .. .... . .. ... .. .... 1 l 01.1 Control Room Observations (Units 1 and 2) . ... . ...... 1 O2 Operational Status of Facilities and Equipment ... . ... . . . . . 2 O2.1 Plant Tours (Units 1 and 2) .. . . ... ... . . .. .2 02.2 Detailed Walkdown of the Auxiliarv Feedwater System . ... . .3 08 Miscellaneous Operations issues . . . . . .. . . . .. .... . . .. 5 08.1 (Closed) Insoection Followuo item 498:499/96012-01: Reliance on prompt l operator actions to control overcooling from auxiliary feedwater during an l
event. .. . .. ... .. . . . . . .. .... .. ...5 i 08.2 (Closed) Insoection Followuo item 50-499/97008-01: Review of the root
! cause determination, the operator error, and the associated corrective j actions related to a loss of main transformer oi .. . .... .5 I
11. Maintenance . . . ... ... .. . ... ... 6 )
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M1 Conduct of Maintenance . . .... . . .... . .6 l M1.1 General Comments on Field Maintenance Activities .. . .6 l M1.2 General Comments on Surveillance Testino . . . . . . .... . ... . 7 M2 Maintenance and Material Condition of Facilities and Equipment . .. 8 M2.1 Notice of Enforcement Discretion . . .. .. .. . .....8 M8 Miscellaneous Maintenance issues . . . .. .. . ... . 10 M8.1 (Closed) Licensee Event Reoort 50-498/93-011: Failure to perform damper position verification during required surveillance testin l M8.2 (Closed) Licensee Event Reoort 50-498/94-004: Voluntary licensee event
- report regarding surveillance testing of the pressurizer power operated l relief valves. . .. .. . . .. . . . . . 11 M8.3 (Closed) Insoection Followuo item 498:499/94025-05: Maintenance backlog reduction goal effectivenes ... . . ....... ... .. 11 M8.4 (Closed) Violation 498:499/96025-01: Failure to take corrective action to j reduce emergency core cooling system (ECCS) leakage for a period of 7
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l Ill. Engineering . .. ... . . . ... . . . ... . .. .15 E1 Conduct of Engineering . .. 15 l . . ... .
E Enoineerino Evaluation Reviews . . . 15 E8 Miscellaneous Engineering Issues . . . . . . . ..... . . . . 16 E (Closed) Unresolved item 498:499/96003-03: Spent fuel pool refueling capacity and cooling capability. . . . . . . . . . .. . . 16 L E (. Closed) Licensee Event Reoort 50-499/96-002: Fuel handling building
! exhaust air damper inoperable caused by inappropriate design l
implementation. .. . . . . .. .... . 19
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! IV. Plant Support . . . . . .20 1 R1 Radiological Protection and Chemistry Controls . . . . .. 20 l R1.1 Tours of Radiological Controlled Areas . .. . . . . 20 l R1.2 Secondarv Chemistry Controls . .. . . 21 F1 Control of Fire Protection Activities . . . . . . 21 F Fire Briaade Training Adequacy . . . 21 l P2 Status of EP Facilities, Equipment, and Resources .. . 23 i
P Emergency Resoonse Facilities (71750) . . . 23 P Meteorological Towers (71750) . . . .. . 23 S1 Conduct of Security and Safeguards Activities . . ... 23 S Daily Physical Security Activity Observations . 23 S1.2 Activation of a Protected Area Kevcar . . . . 24
i V. Management Meetings . . . . . . . . .24 l X1 Exit Meeting Summary . . . . . . . 24 l l
l ATTACHMEN . . . . . . . . .. . .. . 26 j PARTIAL LIST OF PERSONS CONTACTED . . . . .. .. 26 l l
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lNSPECTION PROCEDURES USED . 26 )
ITEMS OPENED, CLOSED, AND DISCUSSED . . . ... . 26 l l
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Report Details l
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Summarv of Plant Status l
Units 1 and 2 operated at essentially 100 percent power throughout this inspection perio I
1. Operations
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01 Conduct of Operations 0 Control Room Observations (Units 1 and 2) Insoection Scoce (71707)
Using Inspection Procedure 71707, the inspectors routinely observed the conduct of operations in the Units 1 and 2 control rooms. Frequent revie..vs of control board status, )
routine attendance at shift turnover and turnover meetings, observations of operator l performance, and reviews of control room logs and documentation were performed. A l
selection of plant Technical Specifications were reviewed to ensure that required equipment was operable or the associated action statement requirements were being implemented. The adequacy of control room communications and coordination of l operational activities were evaluated. The implementation of the following plant )
, operating procedures was observed or reviewed:
. Procedure OPOP03-ZG-0008, Revision 15, " Power Operations"
. Procedure OPOP03-ZG-0005, Revision 19, " Plant Startup to 100%"
. Procedure OPOP09-AN-08M3, Revision 3, " Annunciator Lampbox 1-08M-3 i Response Instructions" Observations and Findinos Overall licensed operator performance in the control room was found to be excellen Operators were knowledgeable of their responsibilities during each evolution. They were aware of existing plant conditions and knew the reason for each lit annunciato Operators continued to take action to reduce noise levels and traffic in the control roo The use of closed-loop communications techniques continued to be a strength in crew performance. This was particularly important in those instances when communication I with personnelin the field was difficult because of background noise.
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' The ability and willingness of licensed operators to document problems with plant equipment was noted throughout this inspection period. Operators were routinely j observed documenting minor control board deficiencies and control abnormalities on l'
i condition report Reactor operators maintained a professional demeanor and kept nonwork-related discussions to a minimum. The inspectors observed reactor operators perform routine i control board manipulations. Reactor operators were routinely observed implementing l
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-2-the licensee's self-verification program. The operators were cognizant and knowledgeable of the plant conditions and demonstrated a sense of professionalism t while performing their dutie Throughout this inspection period, operators responded appropriately to control room annunciators. Annunciators in alarm were announced to the crew and alarm response procedures were used to address the condition indicated by the annunciator. The unit supervisors were informed of annunciator status and acknowledged their alarming via
. good communications technique On June 5, the inspectors observed licensed operators respond to an inadvertent trip of l the Moisture Separator Reheater Drip Tank Pump 11B in accordance with Procedure OPOP09-AN-08M3. High level dump valves were operated to protect turbine 1 auxiliaries. Drip tank levels were restored and the pump restarted upon demand. Proper supervisory oversight was observed. In addition, this event occurred during shift turnover. The oncoming crew stepped out of the at-the-controls area, allowing on shift operators to properly respond before returning to turnover activities. Condition Report 98-8678 was written to investigate the cause of the pump tri Conclusi.9ns Licensed operator performance in the main control room was found to be excellent throughout the inspection period. The ability and willingness of licensed operators to document problems with plant equipment was noted. The professional demeanor of licensed operators, the use of self-verification techniques, the use of closed-loop communications techniques, and operator knowledge were considered strengths.
l Performance following a secondary plant pump trip was considered excellent.
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O2 Operational Status of Facilities and Equipment )l
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O2.1 Plant Tours (Units 1 and 2) )
l Insoection Scoce (71707)
The inspectors routinely toured the accessible portions of the plant areas in Units 1 and 2. Areas of special attention during this inspection period included:
- Units 1 and 2 mechanical and electrical auxiliary buildings
- Units 1 and 2 fuel handling buildings
- Standby Diesel Generators 12,13,21 and 2 .
Units 1 and 2 isolation valve cubicles l
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-3- Findinas and Observations The inspectors found that plant equipment was maintained in excellent material condition. However, the inspectors identified an oilleak on High Head Safety injection Pump 28. Condition Report 98-8931 was written to evaluate and monitor this conditio Plant housekeeping was good. Minor deficiencies including leakage from ventilation system drip pans, an uncovered conduit, and missing fasteners were noted by the ;
, inspectors and addressed by licensee personnel. All deficiencies were reported to l l
operations' shift supervision and were properly addressed. In addition, licensee j
- management was routinely observed monitoring ongoing activities in the plan On June 13, during the performance of Procedure OPSP09-TD-0001 documented in Section M1.2 of this inspection report, the inspectors observed a worker leave the door between the mechanical auxiliary building and the tendon gallery open and unattende This door was a required ventilation area boundary. Upon completing the required ]
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whole-body frisk, the inspector entered the area and closed the dooi. This observation l l was discussed with a design engineer responsible for the surveillance testing activit j The engineer ensured that the door was locked upon est. In addition, the engineer
- stated that he would discuss the need to maintain the door closed with the craft prior to their reentr The inspector discussed the incident with the shift supentisor. The supervisor wrote
- Condition Report 98-9025 to document the event and informed the mechanical auxiliary
! building reactor plant operator to ensure that the doors were closed during operator rounds. Although the worker left the door open, the inspector was always within sight of i-
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the door and capable of closing the door upon a safety system actuation. Therefore, this mistake was not considered a violation of operating procedures. Appropriate corrective actions were taken by control room personnel.
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In general, equipment availability and material condition were excellent and plant housekeeping was good. However, minor deficiencies were noted. On one occasion, a worker left a safety-related ventilation boundary door open and unattended. The inspector observed the occurrence and remained cognizant of the oversight until he could access the area and close the door, preventing a violation of operating procedure O2.2 Detailed Walkdown of the Auxiliarv Feedwater System insoection Scoce (71707)
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i On May 12, in accordance with inspection Procedure 71707, " Plant Operations," the l inspectors performed a detailed walkdown of the Unit 2 Auxiliary Feedwater System, l Train A. This inspection was conducted to verify the system operability, specifically that ,
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Plant Operating Procedure OPOP02-AF-0001, Revision 9, "Auxiliery Feedwater"
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Piping and instrumentation Drawing SS149F00024, " Auxiliary Feedwater"
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Technical Specification 3.7.1.2, " Auxiliary Feedwater System"
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Technical Specification 3.7.1.3, " Auxiliary Feedwater Storage Tank"
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Updated Final Safety Analysis Report Section 10.4.9.2, " Auxiliary Feedwater System Description" b. Observations and Findinas The inspectors observed that system components were properly aligned and that the train was in an operable condition. The as-built plant configuration matched that described in Procedure OPOP02-AF-0001 and shown on Drawing SS149F00024. Those valves required to be locked for containment integrity were sealed in the correct positions. Valves did not exhibit excessive packing leakage. Hand-wheels or manual operators were installed and in good condition. Power was available to system components and circuit breakers were properly aligned for standby operations. Process instrumentation was properly installed, aligned, and indications were within expected bounds for plant conditions. System components were labeled. The physical area was appropriately cooled and ventilated. Pump oil levels were within normal bounds and no leakage was observe The inspectors reviewed Section 10.4.9.2 of the Updated Final Safety Analysis Report and found that the as-built system components were as described. The auxiliary feedwater storage tank contained more water than the minimum required volume in Technical Specification 3.7.1.3. Equipment hangers and supports were installed and aligned properly. Spring cans were within range and fasteners and cotter pins were installed. No ignition sources or flammable materials were observed in the vicinity of the syste The inspectors found minor deficiencies during the inspection. Flexible conduit was cracked and open on the housing of a pressure transmitter. This transmitter was not qualified for harsh environment, therefore, there was only minimal safety significance to ,
the deficiency. Additionally, one of the pump test lines was improperly labele i However, the overall material condition of the system was considered to be excellen l The deficiencies were reported to and addressed by the shift supervisor,
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1 e a-S- Conclusions The auxiliary feedwater train inspected was in excellent material condition, was properly aligned for standby conditions, and was considered to be operable. The system was found to be installed and aligned as described in the Updated Final Safety Analysis Report, and Technical Specification operability requirements were being met. However, minor deficiencies were identifie Miscellaneous Operations issues 08.1 LCJkmed) Insoection Followuo item 498:499/96012-01: Reliance on prompt operator actions to control overcooling from auxiliary feedwater during an event.
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This item addressed the licensee's reliance on prompt operator action during implementation of the emergency procedures to reduce auxiliary feedwater flow to control overcoolin The inspectors reviewed licensee guidance and operator performance during subsequent reactor transients and determined that no further staff action was appropriate. Therefore, this item is close .2 (Closed) Insoection Followuo item 50-499/97008-01: Review of the root cause determination, the operator error, and the associated corrective actions related to a loss of main transformer oi On December 29,1997, a large oil leak was discovered issuing from a sudden pressure relief valve on top of the Main Transformer 2B housing. The operator response to the event and immediate corrective actions had been reviewed by the inspectors at that tim Licensee engineers determined that the probable failure mode was air ingestion through a leak in Oil Cooler 1. The air, once heated, would have displaced oil causing the indications and results observed. Two contributing causes were also identified:
improper installation of the gas detector, and the malfunctioning of the hot spot indicato Both of these indicators could have alerted the operators to impending failures and would have automatically started additional coolers when neede I I
The inspectors reviewed Condition Report 97-20369 written to document the peer l'
checking that took place while preparing to secure Steam Generator Feedwater Pump 22. Although no final conclusion was drawn regarding the actual events at that time, the condition was treated as a near-miss by licensee management. Interviews of operators and personnel observing the evolution were conducted. Discussions were held with all crews regarding the threshold for generating condition reports and the value
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added by documenting near-miss situation !
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! Licensee personnel took extensive corrective actions to return the main transformer to service and to ensure continued functionality. Corrective actions included:
leaks in Oil Cooler 1 were repaired; t
a the bladders in both conservator tanks were replaced;
the relief valve was replaced, properly set, and tested;
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problems with the gas detector were corrected; l
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, an insulation test of the transformer windings was performe j Licensee personnel identified the most probable failure cause as well as diligently ;
searched for contributing causes. Corrective actions were sufficient to correct the j problems, safely return the main transformer to service, and to prevent recurrenc J Finally, the potential operator error was evaluated and corrective actions taken as 1 appropriate. Therefore, this inspection followup item is close . Maintenance- >
M1 Conduct of Maintenance M1.1 General Comments on Field Maintenance Activities 1 Insoection Scoce (62707)
The inspector observed portions of the following ongoing maintenance activities identified by their Work Authorization Number
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139236 Power Supply Failed to ERFDADS Computer Point SPOR 3722,
" Function Generator for Overpower Delta-temperature"(Unit 1)
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- 130334 Spring Pack Replacement, Lubrication, inspection, and Testing on ,
High Head Safety injection Miniflow Isolation Valve I
- . Actuator 2-SI-MOV-11 A (Unit 2)
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130337 Spring Pack Replacement, Lubrication, inspection, and Testing on ;
High Head Safety injection Miniflow Isolation Valve l Actuator 2-SI-MOV-12A (Unit 2)
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7- Observations and Findings
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in general, performance of observed maintenance activities was very good. Equipment was properly removed from service and postmaintenance testing indicated that the :
equipment had been properly repaired. Work was performed under appropriate supervision. Work packages and instructions provided appropriate detail, and vendor )
information was properly incorporated into work instructions. Prejob briefings were thorough and provided a sound basis for work start authorit On June 8, during the performance of Work Authorization Number 139236, the inspectors observed technician practices that were inconsistent with management expectations. Following replacement of a failed solid state protection system circuit ,
board, the card would not calibrate as expected. The technicians and the crew l supervisor discussed potential causes. All three individuals expressed concern that the l work instructions were insufficient to perform an adequate calibration. Additionally, the l technicians stated that they were not aware of the configuration of the card that was '
necessary for proper calibration. However, one of the technicians proceeded to attempt further calibration efforts on the card. The inspector questioned the appropriateness of
.this action, and the work was suspended. The crew contacted engineering personnel, j developed a plan of action, including work instructions, and completed the repairs and calibration of the circui Conclusions In general, technician performance during maintenance activities observed was very good. Work packages and instructions provided appropriate detail and vendor information was properly incorporated. However, on one occasion, technicians attempted to perform work on a solid state protection system component when the work instructions were known to be insufficient to provide adequate guidanc M1.2 General Comments on Surveillance Testing Insoection Scoce (61726)
The inspectors observed portions of the following surveillance activities and/or reviewed the surveillance procedures for Technical Specification compliance:
Unit 1 activities:
- Plant Surveillance Procedure OPSP05-RC-0410, Revision 8, " Delta T and T Average Loop 1 Set 1 Calibration (T-0410)"
- Plant Surveillance Procedure OPSP09-TD-0001, Revision 3, " Containment Tendon Test /End Anchorage and Adjacent Concrete inspection" U . J
- Procedure No. STP-10, 'VSL Corporation, inservice Tendon Surveillance l Procedure for Units 1 & 2 Containment Post-Tensioning System" Unit 2 activities:
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Plant Surveillance Procedure OPSP03-HF-0001, Revision 9, " Train A FHB Emergency Exhaust System Operability"
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Plant Surveillance Procedure GPSP03-SP-0009C, Revision 9, "SSPS Actuation Train C Slave Relay Test" Observations and Findinos The observed surveillance tests were well performed utiliang approved procedures. The test procedures properly implemented Technical Specification surveillance requirements as documented and performed. Plant operators were observed performing detailed walkdowns of equipment during testing activities. System engineers provided good support during the collection of data for equipment performance trendin Communication between control room operators and personnel in the field was goo Conclusions Surveillance testing observed was well conducted in accordance with approved procedures and properly implemented the Technical Specification surveillance requirement M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Notice of Enforcement Discretion Insoection Scoce (62707)
On April 30, Fuel Handling Building Exhaust Booster Fan 11B tripped during surveillance testing. Maintenance personnel identified a motor ground indicating that the motor required replacement. Condition Report 98-6902 was prepared to perform the wor During preparation for the motor replacement, licensee personnel determined that the physical work would require a temporary modification to isolate the fan from the duct work associated with the remaining two trains. However, this evaluation required breaching the common exhaust and supply plena serving all three exhaust booster fan This evolution was prohibited by plant Technical Specifications. On May 1,1998, STP l Nuclear Operating Company requested enforcement discretion from the shutdown requirements of Technical Specification 3.0.3 while the temporary modification was installed and subsequently remove '
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c Q-9-The inspectors reviewed the circumstances surrounding this occurrence. A walkdown of the system configuration was performed, and the following documents were reviewed:
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Condition Report 98-6902," Fuel Handling Building Exhaust Booster Fan 11B Tripped - Investigate and Correct."
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Temporary Modification TI-98-6902-3, " Install Blank Plates in Inlet and Outlet Ducts to Iso! ate Booster Fan 118 from the Rest of the HF Exhaust System."
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Unreviewed Safety Question Evaluation 98-0038, " Review of Temporary Modification to Address Maintenance / Replacement of Fuel Handling Building Exhaust Booster Fans."
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" Request for Enforcement Discretion for Technical Specification 3.0.3 as it Applies to Operability Requirements for the Fuel Handling Building HVAC, " letter dated May 1,199 .
" Response to NRC Request for Additional Information RE: Fuel Handling Exhaust Booster Fan Replacements," letter dated May 4,199 *
Service Request HF-178128, " Remove Manway Cover to Gain Access to inside of Exhaust Booster Fan Plenum."
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NRC letter dated August 19,1992, granting a temporary waiver of compliance for repairs to Exhaust Booster Fan 21 Maintenance Work Request HF-87021130, " Investigate Ground on Fuel Handling Building Exhaust Booster Fan 1C."
b. Observations and Findinas The inspectors reviewed the work documents and walked down the system components related to the Booster Fan 11B replacement and determined that a notice of enforcement discretion was required for the licensee to perform repairs with the plant in mode on On May 1, following telephonic discussions with appropriate licensee management, the regional administrator provided the requested discretion stating that:
"On the basis of the staff's evaluation of your request, including the compensatory measures described above, the staff has concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse radiological impact on public health and safety. Additionally, we determined that your request satisfied the NRC's policy for enforcement discretion. Therefore, it is our intention to exercise discretion not to enforce compliance with Technical Specification 3.0.3 as it related to Technical I
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-10-Specification 3.7.8(b) and 3.3.2 for a maximum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to install and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to remove the temporary modification described above. This discretion is allowed to be used once during the seven day allowed outage time for the applicable Technical Specification discussed above."
It is the NRC's policy to not exercise discretion involving recurring problems, such as requests for the same reasons or some similarly avoidable situation. Because a similar failure of a Unit 2 fuel handling building exhaust booster fan motor that occurred in 1992 required the staff to exercise a temporary waiver of compliance, a significant number of l questions were raised by the staff during the May 1 telephone conference. These !
questions were necessary in order for the staff to determine if circumstances warranted I
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enforcement discretion considering our existing polic However, on May 7,1998, the inspectors were informed that a failure of Fuel Handling Building Exhaust Booster Fan 1C had occurred in August 1987 before Unit 1 licensin Although certain licensee individuals in attendance at the May 1 meeting knew of this i occurrence, the information was not provided to the NRC staff even when questions I regarding previous failures were discussed. In August 1987, Technical Specifications were not applicable. As a result, concerns with the inability to repair the fan in accordance with Technical Specification requirements would not have been at issu l Therefore, the information regarding the August 1987 failure was determined not to be j material to the NRC decisio On May 1, at 10:34 p.m., licensed operators secured the fuel handling building exhaust system to install the temporary modification, and restored two trains to service after completing the installation at 2:22 a.m. on May 2. After completing the fan motor replacement, at 10:37 p.m. on May 2, licensed operators again secured the fuel handling building exhaust system to remove the temporary modification, and restored two trains to service after completing the removal at 2:24 a.m. on May 3. At 4:31 a.m. on May 4, all testing was complete on the new fan motor and all three fuel handling building exhaust b 7ste fans were restored to an operable statu c. Concluslom The licensee's request for a notice of enforcement discretion satisfied the NRC's policy for enforcement discretion. The repair efforts for the Fuel Handling Building Exhaust Booster Fan 11B were conducted within the allowances of the notice of enforcement discretion and in accordance with previously established requirements. Certain information related to previous booster fan failures was not provided to the NR However, after a thorough review, the information was not considered material to the final NRC decisio . _ _ _ _ _ __________________D
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-11-M8 Miscellaneous Maintenance issues M8.1 (Closed) Licensee Event Reoort 50-498/93-011: Failure to perform damper position verification during required surveillance testin This report documented the failure to verify that fuel handling building ventilation supply dampers were opening while testing the exhaust system every 30 days as required by Technical Specifications. Although the positions of the subject dampers were not verified during monthly testing, the positions of the dampers upon actuation were being tested quarterly in Modes 1 - 4 in accordance with another surveillance requirement. Therefore, there was a high level of assurance that these dampers would have performed their
. required safety function in the event of an acciden The report also documented multiple examples of previous events involving incomplete Technical Specifications' required surveillance testing because of inadequate procedures. At that time, the licensee committed to implement a surveillance procedure enhancement program to ensure that procedures accurately reflected design basis functions and Technical Specifications requirements. This program was thoroughly reviewed as documented in NRC Inspection Report 50-498/97-002; 50-499/97-002. The inspectors had found that the program had met its initial goals, and concluded that no further tracking or review of the surveillance procedure enhancement program was necessar i The failure to test the fuel handling building ventilation supply dampers every 30 days as required by Technical Specification 4.3.2.1 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 (498;499/98006-01).
M8.2 (Closed) Licensee Event Reoort 50-498/94-004: Voluntary licensee event report regarding surveillance testing of the pressurizer power operated relief valve As documented in NRC Inspection Report 50-498/93-202; 50-499/93-202, the operational readiness assessment team had questioned the validity of pressurizer pilot-operated relief valve testing because the valves were routinely stroked from the auxiliary shutdown panel. This electrically bypassed the main control panel manual actuation circuitry. This had been documented as Observation 93-202-0 ,
During a review of this issue, the licensee had determined that the failure to test the valves from the main control room was in compliance with the Technical Specification However, it was determined to be prudent to properly and completely test the valve Therefore, licensee personnel took corrective actions, and the subject report was issued l- in accordance with 10 CFR 50.73.
l l This issue was fully reviewed prior to plant restart as documented in Section 6 of NRC Inspection Report 50-498/93-055; 50-499/93-055. The inspector had determined that Technical Specification requirements were being met, and that licensee corrective
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-12-actions had been acceptable. As a result of this inspection effort, Observation 93-202-03 was closed in NRC Inspection Report 50-498/96-022; 50-499/96-022. Therefore, this licensee event report is administratively close j l
M8.3 (Closed) Insoection Followuo item 498:499/94025-05: Maintenance backlog reduction goal effectivenes On February 5,1993, the NRC issued a Confirmatory Action Letter to Houston Lighting and Power regarding the South Texas Project and supplemented that letter on May 7,1993 and October 15,1993. Issue 3 identified in these letters documented I problems with management control of an excessively large and increasing service request backlog. In responding to this issue, the operational readiness plan, dated August 28,1993, set goals of less than 1000 and 850 service requests for the restarts of Units 1 and 2, respectivel The restart issue was considered resolved for Unit 1 restart as documented in NRC l
Inspection Report 50-498/94-008; 50-499/94-008. At that time the backlog had been reduced to 950 open service requests. NRC Inspection Report 50-498/94-020; 50-499/94-020 documented resolution of this issue for Unit 2. Although the backlog was ,
approximately 1000 open service requests, the backlog appeared to be under control I and decreasin The subject inspection followup item was documented by an integrated assessment team inspection conducted in August 1994. The team had noted that the licensee had l made substantial progress in reducing the backlog of maintenance work. In l August 1994, the backlog consisted of approximately 1300 service requests. In addition, the number of incomplete outage service requests was documented as approximately 400. Based on the licensee's history and their findings, the team recommended that the NRC continue to track and monitor the licensee's effort to reduce and manage the maintenance backlo Since that time, resident inspectors have reviewed the maintenance backlog on a routine basis via the licensee's Daily Communication and Teamwork Meeting. Following the restart of Unit 2, the service request backlog continued to decrease for some time and has remained significantly below the established goals for restart of the units. On May 20,1998, the total site workload consisted of 703 non-outage work orders and 411 outage work orders. It should be noted in comparing numbers that the workload tracked in 1998 was more comprehensive, including more categories of work, than the service request backlog discussed in 199 The inspectors concluded that the licensee's workload has remained significantly below ( the established goals in the operational readiness plan and the licensee was clearly managing their work to a manner to maintain the workload at acceptable level Therefore, further tracking of this item was not deemed necessary.
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-13-M 8.4 (Closed) Violation 498:499/96025-01:- Failure to take corrective action to reduce emergency core cooling system (ECCS) leakage for a period of 7 month On February 22,1996, operators had identified that an ECCS component was leaking into the fuel handling building pump room sump. Although a condition report had been written, the significance of the leakage was not evaluated until the condition was observed by the inspectors on September 11,199 The circumstances surrounding this condition were previously reviewed as documented
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in NRC Inspection Report 50-498/96-025; 50-499/96-025. The inspectors had concluded that the leakage was excessive, had existed for 7 months, and represented a significant degradation of a safety system. At least 6 individuals, including licensed operators and the system engineer, had reviewed the condition report and failed to recognize the l potentialimpact of system leakage on doses to control room personnelin the event of a loss of coolant accident. In addition, the licensee had utilized nonconservative containment leak rate assumptions in the no significant hazards determination.
l The licensee stated in their February 6,1997, letter that the reason for the violation was the unfamiliarity of station personnel with the relative contributions of all potential source terms and release pathways assumed in the analysis of the design-basis loss of coolant accident control room doses. The letter stated that:
"if the relationship between safety injection system leakage and control room dose had been recognized, two courses of action would have been available:
the safety injection train could have been immediately declared inoperable and the leakage repaired, or,
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an operability review could have been requested. If the leakage had been such that the train remained operable,
- procedural requirements dictated performance of a formal l evaluation pursuant to 10 CFR 50.59."
l l However, in a letter dated July 24,1997, the licensee stated that expectations for performing an unreviewed safety question evaluation for degraded equipment left in service were not sufficiently clear. A self-assessment had indicated a lack of knowledge of the procedural requirement to perform a 10 CFR 50.59 evaluation for operability
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reviews. As a result, the following corrective actions were performed:
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A Training Bulletin was issued to engineering department personnel reiterating the requirement that a 10 CFR 50.59 evaluation is required for operability reviews j where degraded equipment will be left in servic The Manager, Design Engineering Department conducted a management i expectation discussion with all design engineering department personne l
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The maintenance backlog was reviewed for open conditions that require a I 10 CFR 50.59 evaluation. All identified evaluations from this review have been completed. South Texas Project has implemented an ongoiilg process to require 10 CFR 50.59 evaluations on identified degraded material conditions not repaired in an appropriate time fram l l
The inspectors reviewed the recommendations of the material deficiency evaluation task l group, a comprehensive listing of the results of the maintenance backlog review, and the revision of the systems engineering department guidelines document. These reviews indicated that the licensee had taken substantial corrective actions to address concerns l with the performance of unreviewed safety question evaluations for all operability review i As documented in the NRC letter, dated March 27,1997, forwarding the notice of -
violation, the NRC staff determined that corrective actions by the licensee were sufficient to support the exercise of discretion. Therefore, no civil penalty was proposed. The corrective actions, taken as a result of the subject emergency core cooling system leakage, included: The leaking flush valve was repaire . All other trains in both units were tested to confirm that no additional leakage sources were unidentified. No additional leakage in excess of design limits was foun . A discussion of this situation was included in operator requalification trainin . Training was provided to the engineering staff to ensure that the relationship between safety injection system leakage and control room dose was understoo In addition, the training focused on careful assessment of any plant conditions that may impact design basis margin . System engineers reviewed open material deficiency condition reports on their systems to identify if any other material deficiencies impacted compliance with the licensing basis. No other such deficiencies were determined to exis . This situation was added to the initial operator training progra __ __________--------------__;
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! -15-l The engineering staff conducted review meetings to identify other areas where sensitivity to the margin of design limits should be included in operator training. A
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list of identified areas was considered for inclusion in the above training.
l Tho inspectors toured the emergency core cooling system pump room in Unit 1 on l June 3 and in Unit 2 on June 10. No significant leakage was observed out of system l components or at the discharge of the system equipment drain into the room sumps.
l Additionally, an engineered safety features walkdown of the ECCS was conducted as documented in NRC Inspection Report 50-498/98-04; 50-499/98-04. The inspectors reviewed lesson plans developed for licensed operator initial and requalification training l
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programs. The issue was thoroughly addressed in these training document Attendance records indicated that system engineers had been trained regarding the sensitivity of control room accident doses to ECCS leakage.
i-Ill. Engineering E1 Conduct of Engineering
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E Engineering Evaluation Reviews
' insoection Scooe (37551)
Using Inspection Procedure 37551, the inspectors reviewed the design documents associated with the temporary installation of a reverse osmosis system in the Unit 2
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I l refueling water st'orage tank purification loop of the spent fuel pool cooling and cleanup system. The following specific engineering evaluations were selected for review:
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- Temporary Modification T2-95-12322-7, install a Temporary Reverse Osmosis unit in Unit 2 to help reduce the level of silica contamination in the Refueling Water Storage Tank l
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- Condition Report Engineering Evaluation 95-12322-15, Rigging Plan for Reverse Osmosis Skid
! - Condition Report Engineering Evaluation 95-12322-16, Evaluation for a Missile Barrier to Protect the Charging System Suction Line from a potential Secondary i j 1mpact from a Heavy Load Dro ]
- Unreviewed Safety Question Evaluation 98-0014, Reverse Osmosis System for the Refueling Water Storage Tank I L
- Unreviewed Safety Question Evaluation.98-0023, Engineering Evaluation of Rigging Plan for Installation of Reverse Osmosis Skid
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0-16- Observations and Findinos Temporary Modification T2-95-12322-7 was developed to install a temporary reverse osmosis skid in the Unit 2 mechanical auxiliary building. The skid was connected to the refueling water purification loop to reduce silica contamination in the refueling water storage tank. The reason for reducing silica in the refueling water storage tank was to improve water clarity during the next refueling outage. The skid consisted of two pumps in series, a filter, and reverse osmosis modules with a design flow of 50 gpm. The
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system was connected via reinforced hoses to the suction and discharge piping of Refueling Water Purification Pump 2A in the non-safety related portion of the spent fuel pool cooling and cleanup system. Two safety-related valves in series provided the isolation boundary between the skid connections and the refueling water storage tan Unreviewed Safety Question Evaluation 98-0014 was developed to evaluate the use of '
the reverse osmosis system in accordance with 10 CFR 50.59. The evaluation was thorough in that it provided detailed evaluations of the temporary modification with respect to the current licensing basis. Specific issues addressed in the evaluation included refueling water storage tank or spent fuel pool dilution or draindown. The evaluation also specified the limits of operation to maintain design bases. The limits were incorporated into Temporary Operating Procedure OTOP02-FC-0003, " Boric Acid Recovery System Operation."
Condition Report Engineering Evaluation 95-12322-16 was written to evaluate the requirement for a missile barrier to protect the six-inch charging suction line from a potential secondary impact caused by hypothetical heavy load drop during installation i and removal of the reverse osmosis skid. The skid was brought into the Unit 1 l mechanical auxiliary building through the equipment hatch at the 60-foot elevation. The j skid was then lowered through hatches in the 60-foot and 41-foot elevations to the l 10-foot elevation adjacent to the charging suction line. Design engineers determined I that although the line was not directly beneath the equipment hatches, it was possible
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that the line could receive a secondary impact from a dropped hatch cover or skid. As a !
result, licensee design engineers designed a barrier to protect the line from a secondary
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impac The inspector determined that the engineering assumptions were consistent with assumptions for a gravitational missile as described in Section 3.5.3 of the Updated Final Safety Analysis Report. The inspector independently verified the design calculations and i determined that they were conservative, j Conclusions
Engineering and unreviewed safety question evaluations reviewed were thorough and of very good quality. The temporary modification package for the reverse osmosis skid was
! appropriately detailed. The identification of the potentialinteraction with the charging
! suction line was excellent. The resultant protective barrier design was conservative.
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-17-E8 Miscellaneous Engineering issues E8.1 (Closed) Unresolved item 498:499/96003-03: Spent fuel pool refueling capacity and i
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cooling capabilit This item tracked the evaluation of compliance of the licensee's refueling methods and I analyses with the licensing basis for the spent fuel pool cooling and cleanup syste Specifically, five items were considered still under review. These were addressed as
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follows:
1.: The licensee routinely discharged the full reactor core to the spent fuel pool during refueling outages, as opposed to the updated final safety analysis report normal mode of operation, apparently without performing the determinations required by 10 CFR 50.5 The inspectors reviewed licensing documents associated with the spent fuel poolincluding Section 9.1.3 of the Updated Final Safety Analysis Report, the latest fuel pool storage rerack amendment (Amendment 2 to )
the Unit i license) dated November 1,1988, and the application for that amendment dated March 8,1988. Updated Final Safety Analysis Report Section 9.1.3.1.1 states:
Each train (of the spent fuel pool cooling and cleanup system)is capable of removing 100 percent of the normal maximum design heat load and 50 percent of the abnormal maximum design heat load. The system can maintain the spent fuel cooling water temperature at or below the -
maximum allowable temperatures listed in Table 9.1-1...
If it is necessary to remove a complete core from the reactor, the system can maintain the spent fuel cooling water below the maximum allowable temperature specified in Table 9.1- In the updated final safety analysis report, Table 9.1.1, " Spent Fuel Pool Cooling and Cleanup System Design Parameters," that was also included as Table 5.1 in the March 1988 rerack application, the licensee listed the assumptions for different core discharge analyses that had been analyzed relative to heat load and maximum resulting fuel pool temperature. The analyses were segregated into 3 modes of operation: the normal, the normal maximum, and the abnormal maximum modes. The only reference to the discharge of more than % core was made referring to the L abnormal maximum mode. The inspectors reviewed records from past refueling riutages and confirmed that the licensee had discharged the full core during each refueling since initial plant startup.
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l I-18-l The inspectors observed that Section 9.1.3.1, by introducing the terms I normal, normal maximum and abnormal maximum, characterized each of the design basis cases in a way that could imply that the discharge of a full core would occur on a less frequent basis than the discharge of a partial core. The inspectors were unable to conclude, however, that Section 9.1.3.1, represented a specific commitment to limit the frequency with which a full core was discharged or restricted the licensee from discharging the full core for any one outage or for all outages. In addition, none of the assumptions or calculated values in the spent fuel pool design basis were dependent upon assumptions regarding the frequency with which the full core was discharge Therefore, the inspectors concluded that the practice of discharging the full core during e~ach refueling outage did not represent a change to the !
facility or a change to the procedure described in the safety analysis report and thus did not require a review pursuant to 10 CFR 50.5 . The licensee calculated spent fuel pool heat loads for each core discharge case. However, engineers did not formally check to ensure that ;
peak spent fuel pool temperatures would remain below the 150.7' limit described in the updated final safety analysis report based on this calculated heat loa l The inspectors reviewed documents related to peak spent fuel pool temperatures during previous outages. Although engineers did not formally check to ensure that the predictions met the updated final safety analysis report limit, the limit had always been met. In addition, engineers reported having made the comparison informally. The inspectors determined that there was no requirement for the licensee to formally make the subject compariso . The licensee's calculations were performed to predict compliance with the abnormal maximum mode of spent fuel pool operation, as opposed to the normal maximum mode that should be the bounding cas As documented in NRC inspection Report 50-498/97-06; 50-499/97-06, the inspectors reviewed the spent fuel pool heat up analysis performed for Refueling and Equipment Outage 1REO7. The inspectors had determined that the licensing basis spent fuel pool normal maximum temperature limits would be met provided certain assumptions were maintained. Furthermore, the inspectors had verified that the major t
calculational assumptions had been maintained during the refueling evolution . The Refueling and Equipment Outage 2REO4 calculations did not predict the time to boil for the spent fuel pool and compare this with the limit of l m
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-19-2.86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> documented in the Updated Final Safety Analysis Report Amendment 2 safety evaluation repor NRC Inspection Report 50-498/97-06; 50-499/97-06 also documented the review of licensee Calculation 97-FC-004, " Spent Fuel Pool Heat up For 1REO7." This calculation predicted a best estimate time to spent fuel pool boiling following a postulated loss of cooling. The assumptions utilized appeared to be reasonable, and the maximum heat up rate predicted provided for an adequate operator response to restore cooling or take appropriate corrective / compensatory actions. The heat up rate was also determined to be well within the safety evaluation report licensing limit . Because licensee engineers were not using the bounding case, the control room annunciator was set to alarm at 154' F in accordance with the operating procedure. Therefore, the 150.7* F limit could have been exceeded prior to receiving a trouble alar The inspectors reviewed Plant Operating Procedure OPOP09-AN-22M2, Revision 8, " Annunciator Lampbox 22M2 Response Instructions." The Annunciator 22M02-F-6, "SFP T.ouble" response instructions note that the alarm setpoint may be raised to any value less than or equal to 126* F Additionally, Preventive Maintenance Task IC-1-FC-86003920, written to calibrate the annunciator, had established a setpoint of 118' F for the seventh Unit 1 refueling outage. However, the instruction Prerequisite 1.01.04 would permit a setpoint up to 154' F. This was discussed with planning and licensing organizations personnel. The system engineer stated that the failure to update the preventive maintenance instruction was an oversight. The instruction was updated to indicate a hard limit of 126 E (Closed) Licensee Event Reoort 50-499/96-002: Fuel handling building exhaust air damper inoperabia caused by inappropriate design implementatio The event described by this report was fully documented in NRC inspection Report 50-498/96-002; 50-499/96-002, Section 2.2. At that time, the immediate corrective actions had been reviewed and found to be acceptable. The violation of Technical Specifications had not been cited based on the NRC enforcement policy in effect. The inspectors had further questioned compliance with Technical Specifications based on the licensee's implementation of the allowed outage tim The inoperability of the damper was caused by a failure of a flow transmitter that prevented a control damper from operating as required. A review of historical computer data indicated that the flow transmitter had failed and the damper had been inoperable on March 14,1996. The cause of the transmitter failure was a design change that connected the damper fail-safe closure circuit to the station battery. The issues L
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-20 associated with the design change had been the result of less than adequate i consideration of all design input information during the design change process.
l The corrective actions related to this failure were inspected as documented in NRC l Inspection Report 50-498/96-008; 50-499/96-008. The previous inspectors had documented that the modification of the damper power supply had been inadequate initially, although it had not caused immediate system failures. However, as documented in Condition Report 96-3056 and the subject licensee event report had comprehensively investigated the problem. The inspector had concluded that the postmodification configuration of the system supported operabilit The previous inspectors had questioned the licensee's compliance with the Technical Specifications based on the implementation of the allowed outage time. This question had been based on the licensee identifying that the damper had become inoperable 2 days prior to discovery. Internal NRC review of the subject resulted in the conclusion that the licensee was correct in starting the allowed outage time from the time of discovery despite later identifying that the system failure had occurred earlier.
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IV. Plant Suoport R1 Radiological Protection and Chemistry Controls
R1.1 Tours of Radiological Controlled Areas l
1 Insoection Scooe (71750) l Routine tours of the radiological controlled areas were conducted throughout the inspection period. Radiological controls were observed and evaluated in accordance l with the guidance in inspection Procedure 7175 l Observations and Findinos Doors and gates required to be locked in accordance with Technical Specifications or the licensee's radiation protection program were verified to be properly secured. Work observed in these areas was performed in accordance with approved radiation work permits, with exceptions noted below. On one occasion, the inspectors observed the temporary storage of radiological area vacuum cleaners. Two of the vacuum hoses were not covered to prevent the spread of contamination. This condition was reported to a health physics technician and was promptly correcte On June 13, during the performance of Procedure OPSP09-TD-0001 documented in Section M1.2 of this inspection report, the inspectors observed two problems associated with radiological control practices. The worker's were performing testing outside the
! radiological control area in the tendon galleries. On one occasion, a worker left the tendon gallery entering the fuel handling building at the 68-foot elevation. The worker l
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-21-then entered the mechanical auxiliary building, performed a contamination frisk of his hands and feet, and entered the tendon gallery at the 60-foot elevation. A magenta and yellow rope barrier was placed at this location with a sign indicating the boundary of the radiological controlled area. The sign clearly indicated that a full-body frisk was required prior to exiting the mechanical auxiliary building. The inspector contacted a health
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physics technician and Condition Report 98-9023 was written to address the proble On the same occasion, when the inspector began to perform a whole body frisk to exit the radiological controlled area, he noted that an audible beep was present, but the analog gauge was not responding to background radiation. The health physics
} technician was consulted and determined that the frisker was improperly set for contamination control. It was determined that workers had used this frisker on several occasions earlier that day. A second report, Condition Report 98-9022, was written to address this concer The inspectors determined that the failure to perform a whole-body frisk in accordance with a radiation protection sign was in noncompliance with Plant General
) Procedure OPGP03-ZR-0051, Revision 8, " Radiological Access and Controls."
l Section 5.6.2 of this procedure required that personnel contamination monitoring be utilized as directed by qualified health physics personnel prior to radiological controlled
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area exit. Likewise, the use of a frisker on an improper setting represented an inadequate frisk and was in noncompliance with the same procedural requiremen Because the workers had just entered the radiological controlled area in a noncontaminated location, the inspectors determined that these noncompliance were of only minor significance. These noncompliance constituted two examples of a violation of minor significance that is not subject to formal enforcement actio Conclusions in general, radiological controls were in place and meeting minimum requirement Radiological housekeeping was generally considered to be good. However, on one occasion contaminated vacuum cleaner hoses were not properly covered. Additionally,
two examples of problems indicating that workers were failing to implement proper contamination frisks were observed. These noncompliance constituted two examples of a violation of minor significance that is not subject to formal enforcement actio R1.2 Secondary Chemistrv Controls The inspectors routinely reviewed secondary water chemistry reports and radiation monitor alarm status. Secondary chemical analysis, the calculated primary to secondary leak rate, and indication from the Nitrogen-16 radiation monitors all confirmed steam generator tube integrity. Review of the chemical analysis resu!ts provided evidence of management attention and commitment to maintaining chemistry parameters within appropriate limit l
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l l-22-I F1 Control of Fire Protection Activities
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F Fire Brigade Training Adeauacy Insoection Scoce (71750) l l
On December 31,1997, the fire protection coordinator identified 23 individuals that had l
not attended a sufficient number of fire drills to maintain fire brigade qualifications. All
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23 individual's qualifications expired on January 1,1998. Condition Report 97-20387 was written to address this deficiency. Two makeup drills were scheduled for January 3 and 6,1998. A quality assurance auditor performing a formal observation of the drill identified that these drills were attended by an excessive number of personnel and that as a resuh, proper training and evaluation were not conducted. These concerns were documented on Condition Reports98-519 and 98-520, and reviewed by the inspector l' Observations and Findina_ s Condition Report 98-519 documented a failure to fully meet the requirements of 10 CFR Part 50, Appendix R, Paragraph Ill.l.3.E, in that, not all fire brigade members fully participated nor were properly evaluated. Appendix R requires that drills include, as a minimum, assessment of the time required to notify and assemble the fire brigade, and an assessment of each fire brigade member's knowledge of his or her role in the fire fighting strategy. However, three individuals arrived at the drill fire scene within two minutes of the drill being terminated. Additionally, several other individuals dressed in bunker gear, but did not actively participate in the fire drill. All these individuals signed the attendance sheet and were given credit for participation in the drill. The failure to include minimum objectives in the January 6,1998 drill constitutes a violation of 10 CFR Part 50, Appendix R (498;499/98006-02).
Condition Report 98-520 documented that Plant General Procedure OPGP03-ZF-0002, Revision 3, " Fire Brigade Drills," allowed some of the required objectives to not be included in a fire drill. The inspectors reviewed the procedure and determined that the evaluation matrix allowed Appendix R minimum requirements to be documented as N/A for a given drill. This was considered a second example of Violation 498;499/98006-0 In response to these concerns, fire protection program management voided any credit given for individual qualifications based on the January 6,1998 drill. However, this "
action was not taken until June 1,1998. Expectations were established for a minimum number of drill controllers and evaluators. The licensee committed to provide measurable expectations in the fire protection program procedures conceming member participation for receiving individual credit. In addition, fire drills have been rescheduled to occur during required requalification training. Therefore, each member will have the required number of drills.
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O O-23-l The inspectors performed an audit of fire brigade members used to meet the minimum j
requirements on shift. Since the determination that the January 6,1998 drill was unacceptable, made on June 1,1998, all serving fire brigade members have been qualified without reliance on the voided drill. Plans to requalify the remaining members were being prepared. However, on June 12,1998, the inspectors requested a listing of all qualified fire brigade members. Such a list was not available. In addition, the shift supervisor of neither unit understood that the qualifications of some individuals were in questio Conclusions Two examples of a failure to properly implement the fire protection program with respect to fire brigade training drills constituted a violation of 10 CFR Part 50, Appendix i Corrective actions identified following an improperly conducted drill were not completed j until 5 months after the drill. Additionally, operations' shift supervision was not aware that the qualifications of some fire brigade members were in questio P2 Status of EP Facilities, Equipment, and Resources P2.1 Emeraency Resoonse Facilities (71750)
The inspectors toured the technical support centers and operations support centers in both units as well as the emergency offsite facility. The technical support centers and the emergency offsite facility were readily available and maintained for emergency operation. The operations support centers were multi-use facilities and being utilized for routine meetings. However, the inspectors observed that documentation and emergency supplies for the facilities were readily available upon an emergency declaratio P2.2 Meteorological Towers (71750)
The inspectors routinely observed indication of meteorological conditions in the main control rooms of both units. The data obtained indicated that both towers remained operable. On June 11, the inspectors toured both the 10-meter and the 60-meter towers including the computer processing equipment, the communications devices, and the backup generators and uninteruptible power supplies. All equipment was found to be in excellent material condition. The overall material condition and housekeeping was considered outstanding considering the remote location and standby nature of the equipment. The ventilation system providing cooling to the instrumentation was in good working order. Liquid petroleum fuel supplies were more than adequate to run the backup generators for an extended period of time.
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-24-S1 Conduct of Security and Safeguards Activities S Daily Physical Security Activity Observa. lions ; Insoection Sgone (71750)
On a daily basis, and in accordance witn Inspection Procedure 71750, the inspectors observed the practices of security force personnel, the implementation of the physical l; security plan, and the condition of security equipmen )
i Observations and Conclusions l
Protected and vital area barriers were in good condition. Temporary compensatory I measures were implemented as appropriate. Personnel access measures and equipment searches for contraband were routinely good. The inspectors concluded that daily security force activities were conducted in an appropriate manne During the inspection period, the inspectors toured both the central and secondary alarm stations. The officers posted in the stations were alert and actively involved in !
responding to alarms and ensuring appropriate field officer response. The stations were ;
in good material condition, camera pictures were clear and easily discernable, video
' screens had good resolution, and the computer alarm system was functioning properl I Conclus!ans in general, daily implementation of the security plan was considered to be goo Protectea area barriers, security detection and assessment equipment, and temporary j compensatory measures were considered excellent. However, one exception was noted as described in Section S1.2 of this inspection report perio S1.2 Activation of a Prot.ected Area Kevcard i
On May 27,1998, while responding to an emergency preparedness drill, an inspector's protected area badge /keycard failed tc unfatch the Unit 1 electrical auxiliary building outer door. Assuming that the card reader was deactivated, the inspector attempted to unlatch the mechanical auxiliary building door with the same resul The inspector contacted the central alarm station operator. The operator informed the inspector that his protected area badge indicated that the inspector was not in the
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protected area. Based on a verbal discussion of the inspector's location, the officer returned the badge to an active status. The inspector questioned the validity of
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activating a protected area badge without visual identification of the individual. Security department personnel wrote Condition Report 98-8394 to document the occurrence.
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l This event will be further reviewed to determine the adequacy of the licensee's computer l system, as well as the validity of activating an inactive badge withou4 visualidentification of the individualin possession of the badge. This issue will be tracked as an unresolved item (498;499/98006-03).
V. Manaaement Meetinas l
l X1 Exit Meeting Summary l The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on June 16,1998. Management personnel acknowledged the findings presented. The inspector asked whether any materials examined during the inspection should be considered proprietary. No proprietary .
information was identifie .
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensam H. Allgeyer, Operations Shift Supervisor W. Atkinson, PMPI Management T. Cloninger, Vice President, Nuclear Engineering W. Cottle, President and Chief Executive Officer J. Drymiller, Supervisor, Security Operations J. Groth, Vice President, Nuclear Generation K. House, Supervising Engineer M. Kanavos, Manager, Mechanical / Civil Engineering J. Labuda, Coordinator, Fire Protection B. Masse, Plant Manager, Unit 2 G. Parkey, Plant Manager, Unit 1 J. Pierce, Shift Supervisor, Unit 1 J. Sheppard, Vice President, Business Systems T. Stroschein, System Engineer F. Timmons, Manager, Nuclear Plant Protection T. Waddell, Manager, Maintenance, Unit 1 INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support IP 92901: Followup - Operations IP 92902: Followup- Maintenance IP 92903: Followup - Engineering
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ITEMS OPENED, CLOSED, AND DISCUSSED Ocened 498;499/98006-01 NCV Failure to test the fuel handling building ventilation supply dampers every 30 days as required by Technical Specification 4.3.2.1 (Section M8.1).
498;499/98006-02 VIO Two examples of failure to include the minimum objectives of Appendix R in the fire protection program and during fire brigade drills (Section F1.1).
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-2 7-498;499/98006-03 URI A central alarm station officer activated an inactive protected area keycard without first visually identifying the j i.ndividualin possession of the card (Section S1.2).
Closed i 498;499/96012-01 IFl Reliance on prompt operator actions to control overcooling j from auxiliary feedwater during an event (Section 08.1). {
499/97008-01 IFl Review of the Root Cause Determination, the Operator '
Error, and the Associated Corrective Actions Related to a Loss of Main Transformer Oil (Section 08.2).
50-498/93-011 LER Failure to Perform Damper Position Verification During Required Surveillance Testing (Section M8.1).
498;499/98006-01 NCV Failure to test the fuel handling building ventilation supply )
dampers every 30 days as required by Technical Specification 4.3.2.1 (Section M8.1). l 50-498/94-004 LER Voluntary Licensee Event Report regarding Surveillance Testing of the Pressurizer Power Operated Relief Valves (Section M8.2). ?
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~ 498;499/94025-05 IFl Maintenance Backlog Reduction Goal Effectiveness (Section M8.3). )
l 498;499/96025-01 VIO Failure to take corrective action to reduce emergency core !
cooling system (ECCS) leakage for a period of 7. months ]
(Section M8.4).
498;499/96003-03 URI Spent Fuel Pool Refueling Capacity and Cooling Capability I (Section E8.1). l 50-499/96-002 LER Fuel Hand ling Building Exhaust Air Damper caused by inappropriate Design Implementation (Section E8.2).
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