ML17228B354
| ML17228B354 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie |
| Issue date: | 11/27/1995 |
| From: | Landis K, Lia E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17228B352 | List: |
| References | |
| 50-335-95-18, 50-389-95-18, NUDOCS 9512120054 | |
| Download: ML17228B354 (55) | |
See also: IR 05000335/1995018
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 303234199
Licensee:
Florida Power
& Light Co
9250 West Flagler Street
Hiami,
FL
33102
~g RfCy
Wp*y+
Report Nos.:
50-335/95-18
and 50-389/95-18
Docket Nos.:
50-335
and 50-389
Facility Name:
St.
Lucie
1 and
2
License Ncs.:
and
Inspection
Conducted:
September
17 through October 28,
1995
Lead Inspector:
R. Prevatte,
eni
Resident
Inspector
H. Hiller, Resident
Inspector
S.
San i
,
enior Operations Officer,
Approved by:
e
gned
K.
dis, Chief
Reactor Projects
Branch
3
Division of Reactor Projects
SUMMARY
Dat
Si
ned
Scope:
Results:
This routine resident
inspection
was conducted
onsite in the areas
of plant operations
review, maintenance
observations,
surveillance
observations,
engineering
support,
plant support,
followup of
previous inspection findings,
and other areas.
Inspections
were performed during normal
and backshift hours
and
on
weekends
and holidays.
Plant operations
area:
Two violations involving; inadequate
log keeping
and status
control
of the valve/switch duration log (2 exampl.es),
paragraph
3.A.,
and
performing hazardous
work on
a system without implementing
a
required clearance
were identified, paragraph
3.A.
A weakness
involving a log keeping deficiency that was not entered
into the
licensee corrective action program when identified.
An additional
weakness
involving the failure to properly back out of an incorrect
procedure
resulted
in discharging
blowdown water to
the roof of the reactor auxiliary building.
A problem involving
leaking pressurizer
safety valves
and misaligned tailpiping resulted
in extensive
engineering
analysis,
valve rework and detailed piping
alignment to permit Unit
1 restart.
" The startup of Unit
1 after the
.95i2i20054 95ii27
ADQCK 05000335
8
'I
0
0
intended
short notice outage
was slow, cautious
and methodical.
The
shutdown of Unit 2 for a refueling outage
was slowed
by the large
number of needed
procedural
changes,
but proceeded
slowly and
methodically without incident.
Maintenance
and Surveillance
area:
A violation involving design
inadequacies
in the
Emergency Diesel
Generator
governor control logic was discovered
during
Integrated
Safeguards
Testing,
paragraph
4.b.
Two non-cited
violations involving missed surveillances
on control element
assembly position indication
shutdown
boron chemistry
samples
were identified and corrected
by the
licensee,
paragraph
4.b.
An additional non-cited violation
involving incore instrument wiring discrepancies
that occurred
during the previous refueling outage
was identified and corrected
by
the licensee,
paragraph
4.a.
Problems
involving load oscillations during surveillance testing
on
the
Emergency
Diesel
Generators
resulted
in extensive
troubleshooting
and repairs to the governor controls.
Assistance
was obtained
from equipment
vendors to analyze,
repair the problems,
and assist
in developing
equipment
maintenance
program upgrades,
paragraph
4.a.
Engineering
area:
Licensee
performance
in this area
was satisfactory.
Plant Support area:
Performance
in the fire protection,
and
radiological protection
areas
continued to be satisfactory.
Within the areas
inspected,
the following violations were identified:
VIO 335/95-18-01,
"Failure to Follow Procedures
and Maintain Current
and Valid Log Entries in the
Rack Key Log and Valve Switch Deviation
Log," paragraph
3.a.
VIO 335/95-18-02,
"Failure to Follow Clearance
Procedures,"
paragraph
3.c.
VIO 389/95-18-03,
"Failure to Adequately
Design
and Test the
Emergency
Diesel
Generator
2 A/8 Engineered
Safety Feature
Control
Logic," paragraph
4.b.
Within the areas
inspected,
the following non-cited violations were
identified associated
with events
reported
by the licensee:
NCV 389/95-18-04,
"Inadequate Verification of ICI Wiring Connections
After Reassembly,"
paragraph
4.a.
NCV 335/95-18-05,
on
CEA Position Indication,"
paragraph
4.b.
NCV 389/95-18-06,
"Missed
Surveillance
During Mode 6," paragraph
4.b.
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- R. Ball, Mechanical
Maintenance
Supervisor
- W. Bladow, Site guality Manager
- L. Bossinger,
Electrical Maintenance
Supervisor
- H. Buchanan,
Health Physics Supervisor
- C. Burton, Site Services
Manager
R. Dawson,
Licensing Hanager
- D. Denver, Site Engineering
Manager
J. Dyer, Maintenance guality Control Supervisor
- H. Fagley,
Construction
Services
Manager
- P. Fincher,
Training Manager
R. Frechette,
Chemistry Supervisor
- P. Fulford, Operations
Support
and Testing Supervisor
- J. Geiger,
Vice President,
Nuclear Assurance
- J. Goldberg,
President,
Nuclear Division
K. Heffelfinger, Protection
Services
Supervisor
- J. Harchese,
Maintenance
Manager
- R. Olson,
Instrument
and Control Maintenance
Supervisor
W. Parks,
Reactor
Engineering
Supervisor
- C. Pell,
Outage
Manager
- L. Rogers,
System
and
Component
Engineering
Manager
- D. Sager,
St. 'Lucie Plant Vice President
- J. Scarola,
St.
Lucie Plant General
Manager
- J.
West, Operations
Manager
C.
Wood, Operations
Supervisor
- W. White, Security Supervisor
Other licensee
employees
contacted
included engineers,
technicians,
operators,
mechanics,
security force members,
and office personnel.
NRC Personnel
- S. Ebneter,
Regional Administrator,
Region II
- K. Landis, Chief, Reactor Projects
Branch
3
E.
Lea, Project Engineer,
Region II
- G. Heyer, Acting Region II Coordinator,
EDO Office
- H. Miller, Resident
Inspector
- J. Norris, Senior Project Manager,
- R. Prevatte,
Senior Resident
Inspector
- S. Sandin,
Senior Operations Officer,
- Attended exit interview
and initialisms used throughout this report are listed in the
last paragraph,
2.
Plant Status
and Activities
a.
Unit
1 restarted
from a
73 day unplanned
outage
on October
12 and
operated
at essentially full power for the report period.
b.
Unit 2 shut
down for a planned
49 day refueling outage
on October
9
and remained
in that outage for the remainder of the report period.
c.
NRC Activity
R. Carrion,
a health physics inspector
from Region II, visited the
site during the week of October
16.
His inspection efforts are
documented
in IR 95-19.
S. Ebneter,
Region II Regional Administrator,
K. Landis,
Region II
Branch Chief, St,
Lucie Plant,
G. Meyer, Acting Region II
Coordinator,
EDO Staff,
and J. Norris, St.
Lucie Project Manager,
NRR, visited the site
on November
1 for a St.
Lucie Plant
Improvement
Program Status
meeting.
3.
Plant Operations
a.
Plant Operations
Review (71707)
The inspectors periodically reviewed shift logs
and operations
records,
including data sheets,
instrument traces,
and records of
equipment malfunctions.
This review included control
room logs
and
auxiliary logs, operating orders,
standing orders,
jumper logs,
and
equipment tagout records.
The inspectors routinely observed
operator alertness
and demeanor
during plant tours.
They observed
and evaluated
control
room staffing, control
room access,
and
operator
performance
during routine operations.
The inspectors
conducted
random off-hours inspections
to ensure that operations
and
security performance
remained
at acceptable
levels.
Shift turnovers
were observed to verify that they were conducted
in accordance
with
approved
licensee
procedures.
Control
room annunciator
status
was
verified.
Except
as noted
below,
no deficiencies
were observed.
1)
On October 4,
1995, during
a routine review of Unit
1 Control
Room Logs, the inspector
noted that the
SWITCH
(Key //21) was listed in the Appendix
C Valve Switch Deviation
Log as being in BYPASS for SG Draining conducted
on September
30.
The
RCO stated that this switch was placed in the
BYPASS
position when the electrical
leads for the
AFW PP
1A and
AFW PP
1B were lifted per step 8.3. 1 of Operating
Procedure
No.
1-
0120027,
Rev 21,
Cooling and
Wet Lay-Up."
The
BYPASS position
was designed
to block the
AFAS signal for
actuation of the
1C
AFW PP.
The
1C
AFW PP was out-of-service
at the time due to plant conditions.
A review of the control
board
showed the switch position to be in the
NORMAL position.
Discussion with the
RCO determined that the log entry should
have
been closed out when the switch was restored
to the
NORMAL
position.
The
RCO verified the location of Key 821
and closed
out the Deviation
Log entry.
The inspector
reviewed the archived Appendix
B Rack Key Log for
September
30 and found
no entry for Key 0'21 check out.
AP 1-0010123,
Rev 99, "Administrative Controls of Valves,
Locks,
and Switches," required:
a)
that "All valve or switch position deviations or lock
openings shall
be documented
in Appendix
C Valve Switch
Deviation Log...". [step 8. 1.6]
b)
c)
that
"The NPS/ANPS/NWE shall
ensure that the verification
of the status of all valves,
locks
and switches
under
Administrative Control is performed at 'the required
intervals specified in AP 1-0010125...[step
8.3. 1] which
"Verifies that log entries
are current
and valid". [step
8.3.2.3]
1
C
that
"A log of keys issued shall
be maintained
by the
ANPS
for the Controlled
Key Locker...Appendix
B, Rack Key Log".
[step 8.2.2]
Step 8.1,2.R of AP 1-0010125 required review of the
Valve/Switch Deviation
Log each Midnight shift while in modes
1
through 6.
Check Sheet
82 step
19 required the
ANPS "Review
the Valve/Switch Deviation
Log to ensure that
no valves or
switches
were in an alignment that would cause
a Tech.
Spec.
LCO to be exceeded".
Step 8.3,2 of AP 1-0010123 states
that
"The periodic verification of the status of valves,
locks
and
switches
under Administrative Control serves
the following
purposes:
1.
Confirms that proper tags or locking devices
are in
place."
2.
Ensures that all safety
system
main flow path valves
are
properly aligned
and the valves
are maintained in an
operable condition.
3.
Verifies that log entries
are current
and valid."
The periodic verifications of the Valve/Switch Deviation
Log as
documented
by Check Sheet
P2 step
19 were completed
on October
1 through October 4.
However;
due to the
somewhat
narrow scope
of the verification, i.e.
"Review the Valve/Switch Deviation
Log to ensure that
no valves or switches
are in an alignment
that will cause
a Tech.
Spec.
LCO to be exceeded",
the fact
that the
AFAS BYPASS
SWITCH position was neither current or
valid was overlooked.
The inspector identified this
as
a
procedural
inconsistency.
On October
5, the inspector questioned
the
ANPS regarding the
corrective action taken for this occurrence.
The
ANPS stated
that discrepancies
of this nature
could
be reported to the
operations
supervisor
using Data Sheet
¹7 of AP 0010120,
Rev
75, although,
in this instance,
no such report
was made.
The
inspector discussed
this situation with the operations
supervisor.
The operations
supervisor
agreed with the
inspector that Data Sheet
¹7 was
NOT meant to replace or
circumvent
any other required reporting or corrective process
as stated
in Appendix
B Shift Operations
Policies of the
procedure.
The operations
supervisor pointed out that when
valves,
locks or switches
under administrative control are
repositioned
by a procedure,
no Valve/Switch Deviation
Log
entry is required.
In this case,
the operations
supervisor
stated that operators
should
have initiated
a
TC to
OP 1-
0120027,
Rev 21, to reposition the
The safety significance of this occurrence
was minimal.
However,
the inspector
considered
the failure of the licensee
to document this problem,
and followup with corrective actions,
a program weakness.
On October
17,
a
Rev
99, "Administrative Controls of Valves,
Locks,
and Switches"
was incorporated
which required that the
STA periodically
review Appendix
C entries,
report
any discrepancies
to the
ANPS
and document
the review in
a new Appendix to the
same
procedure.
The inspector questioned this corrective action
since "periodically" could mean
once
a shift, or
a month, or
year,
and did not provide verifiable corrective action.
The failure to document
when
Key ¹21
was issued/returned
and
maintain current
and valid log entries is one example of a
violation, VIO 335/95-18-01,
"Failure to Follow Procedures
and
Maintain Current
and Valid Log Entries in the Rack Key Log and
Valve Switch Deviation Log".
A similar occurrence
was
documented
in IR 95-15.
On October
11,
1995, during
a routine review of Unit 2 Control
Rooy Logs, the inspector
found that the
AFAS CABINET DOOR
D
(Key ¹202)
was listed in the Appendix
C Valve Switch Deviation
Log as being
OPEN for I8C Troubleshooting
conducted
on October
7.
A discussion
with the
RCO determined that the log entry
should
have
been closed out indicating the
LOCKED CLOSED
restored position.'he
RCO verified the location of Key ¹202
and closed out the Deviation
Log entry.
The inspector
reviewed the archived Appendix
B Rack Key Log
between
October
7 and
11
and noted the following:
a)
On October 7, there were
2 Log entries that
showed the
AFAS CABINET DOOR
D was
open
from 5:10
PM to 5:27
PM and
5:30
PM to 5:35
PM for I8C Troubleshooting.
The Appendix
C Valve/Switch Deviation
Log showed only that
the
AFAS CABINET DOOR
D was
opened
at 5:10
PH.
b)
On October
10, there were
2 Log entries that
showed
the
AFAS CABINET DOORS were
open from 8:20
AM to 2:00
PH and
2:35
PH to 4: 10
PH for AFAS Testing.
No Appendix
C Valve/Switch Deviation
Log entries
were
made
since the
AFAS CABINET DOORS were
opened
IAW OP 2-0400050,
Rev 16, "Periodic Test of the Engineered
Safety Features".
However, this
same
OP required that
"The following logs
will be reviewed prior to the performance of applicable
test sections...The
Valve Switch Deviation Log."
[step
5.3. 1].
The inspector
noted that this
AFAS testing should
have identified the open Appendix
C Valve/Switch Deviation
Log entry.
AP 2-0010123,
Rev 68, "Administrative Controls of Valves,
Locks,
and Switches," required:
a)
that "All valve or switch position deviations or lock
openings shall
be documented
in Appendix
C Valve Switch
Deviation Log...". [step 8. 1.6]
b)
that
"The NPS/ANPS/NWE shall
ensure that the verification
of the status of all valves,
locks
and switches
under
Administrative Control is performed at the required
intervals specified
in AP 2-0010125...[step
8.3. 1] which
"Verifies that log entries
are current
and valid". [step
8.3.2.3]
The periodic verifications of the Valve/Switch Deviation
Log as
documented
by Check Sheet
P2 step
25 were completed
on October
8 and 9, however,
due to the
somewhat
narrow scope of the
verification, i.e.
"Review the Valve/Switch Deviation Log to
ensure that
no valves or switches
are in an alignment that will
cause
a Tech.
Spec.
LCO to be exceeded",
the fact that the
CABINET DOOR
D log entry was neither current nor valid was
overlooked.
The inspector identified this as
a procedural
inconsistency.
The safety significance of this occurrence
is minimal.
However, the repeated
missed opportunities to identify and
correct this problem appears
to be
a significant weakness.
On
October
17,
a
Rev 68, "Administrative
Controls of Valves,
Locks,
and Switches"
was incorporated
which
required that the
STA periodically review Appendix
C entries,
report
any discrepancies
to the
ANPS and document
the review in
a new Appendix to the
same procedure.
The failure to maintain current
and valid log entries is the
second
example of violation,
VIO 389/95-18-01,
"Failure to
Follow Procedures
and Maintain Current
and Valid Log Entries in
the
Rack Key Log and Valve Switch Deviation Log."
b.
Plant Tours
(71707)
The inspectors periodically conducted
plant tours to verify that
monitoring equipment
was recording
as required,
equipment
was
properly tagged,
operations
personnel
were
aware of plant
conditions,
and plant housekeeping
efforts were adequate.
The
inspectors
also determined that appropriate
radiation controls were
properly established,
critical clean
areas
were being controlled in
accordance
with procedures,
excess
equipment or material
was stored
properly,
and combustible materials
and debris were disposed of
expeditiously,
During tours,
the inspectors
looked for the
existence of unusual fluid leaks,
piping vibrations,
pipe hanger
and
seismic restraint settings,
various valve and breaker positions,
equipment caution
and danger tags,
component positions,
adequacy of
fire fighting equipment,
and instrument calibration dates.
Some
tours were conducted
on backshifts.
During plant tours,
the
inspector also verified that the posting of required notices to
workers were in place at the required locations.
The frequency of
plant tours
and control
room visits by site management
was noted.
The inspectors routinely conducted
main flow path walkdowns of ESF,
ECCS,
and support
systems.
Valve, breaker,
and switch lineups
as
well as equipment conditions
were randomly verified both locally and
in the control
~~~m.
The following accessible-area
ESF system
and
area
walkdowns were
made to verify that system lineups were in
accordance
with licensee
requirements
for operability and equipment
material
conditions
were satisfactory:
~
Unit
1 Shutdown Cooling Trains
A and
B
On October
4 and 5, the inspector
conducted
a walkdown of the
Unit
(SDC) System.
Both trains were in
service,
however, train "B" was considered
pending
completion of administrative
requirements
following repairs to
V-3651,
All valves
were found to be in the correct alignment
for current plant conditions.
Several
discrepancies
were
noted:
a)
A
PWO Tag with an attached
Contamination
Control
Catch
Device Tag was adrift underneath
V-3935 in the
Pump
Room "1B".
b)
A puddle of clear fluid had collected
under the
Pump casing
near
V-3671 in the
Pump
Room "lA".
The inspector notified
HP of the
above discrepancies.
An HP
tech
accompanied
the inspector to both LPSI
Pump
Rooms
and also
to provide access
to both
SDC Heat Exchanger
Rooms
as part of
the
SDC System walkdown.
A swipe of the fluid taken
by the
7
tech
appeared
to be oil which was contaminated
(18,000
dpm/100
cm').
The
HP tech could not identify the proper location for
the tags adrift inside the roped-off HRA.
~
Unit
2 Shutdown Cooling Trains
A and
B
On October
26, the inspector
conducted
a walkdown of the Unit 2
Shutdown Cooling System.
A core offload was in progress
at the
time with train A isolated for outage
work and train
B in
service.
All train
8 valves were found to be in the correct
alignment for current plant conditions.
The inspector
reviewed both
OP 2-041002,
Rev 20,
"Shutdown
Cooling" and
ONOP 2-0440030,
Rev 26,
"Shutdown Cooling Off-
Normal," verifying correct valve/control
switch nomenclature.
OP 2-041002,
Rev 20,
"Shutdown Cooling," had several
inserted
as part of the licensee's
procedural
upgrade
program.
The inspector,
however, identified to the
RCO an inconsistency
between
OP 2-041002,
Rev 20,
"Shutdown Cooling," and
ONOP 2-
0440030,
Rev 26,
"Shutdown Cooling Off-Normal."
Section 7.2 of
the
OP placed
SDC system in service.
Within the section,
step
7.2.4
had
a
NOTE saying
"V-3545 (Hot-Leg Suction Cross-tie)
is
normally closed."
This valve can
be used to provide flow
during off-normal conditions
and must
be
OPEN if both
trains
are in service".
Other sections of the
OP control the
position of V3545 to ensure that it is closed for single train
SDC.
Step 7.2. 10 of ONOP 2-0440030,
Rev 26,
Off-Normal," stated
in Subsequent
Operator Actions,
"Ensure
proper
Shutdown Cooling Systems
alignment per Appendix C, 'SDC
System Alignment."
Appendix
C of the
ONOP identified V3545 as
OPEN.
This did not recognize single train
SDC operation for
existing plant conditions.
The
RCO said this inconsistency
would be addressed
in
a
TC to the
ONOP.
Operational
Events
Circulating Water
Box Clearance
On September
15, during condenser
waterbox cleaning
on Unit 2,
the
2B2 waterbox
manway was observed
to be leaking following
the start of 2B2 circulating water
pump after waterbox
cleaning.
A decision
was
made to replace
the manway gasket.
The mechanical
maintenance
foreman working this job informed
the
ANPS that parts
were in hand
and the gasket
replacement
would take about
20 minutes.
The
ANPS and maintenance
foreman
decided that
a clearance
would not be required
as long as
operators
were stationed
at both the local circulating water
pump pushbutton station
and at the control switch on
RTGB 202,
to prevent inadvertent
pump start.
.0
At 11:41 p,m., the
2B2
CWP was stopped.
OP 2-0620020,
Rev 26,
"Circulating Water Normal Operating
Procedure,"
Step
4. 14,
stated that, if CW pumps
were being shutdown
one at
a time for
waterbox cleaning,
section 8.8 of the
above procedure
was to be
used.
Step 8.8.4 stated that
a green flag on the
CW pump
control switch in the control
room indicated that the waterbox
vacuum breaker
would open
and the
steam supply valve to the
waterbox primary would close.
Based
on the above guidance,
the
CWP control switch was green
flagged
and permission
was granted
by operations
to mechanical
maintenance
to begin
manway gasket
replacement.
The manway cover bolts were
removed
and the mechanical
maintenance
foreman
and
a mechanic
attempted
to remove the
manway cover.
When the pressure
seal
was broken,
the mechanic
allowed his right index finger to come
between
the cover
and
the waterbox.
A negative
pressure
developed
and sucked the
cover back onto the waterbox
and severed
part of the mechanics
finger.
The mechanic
and his severed
part of the finger were
then
removed
from the scene
and transported
to
a local
hospital.
Attempts to reatta'ch
the severed
part of the finger
were unsuccessful.
A subsequent
review of the control wiring diagrams for the
vacuum breaker
found that the
CWP breaker control fuses
had to
be removed to open the vacuum breakers.
A review of the event
by the licensee
found that:
~
Neither the maintenance
workers or the operator
anticipated that
a vacuum would exist after the
manway
cover was removed.
~
The steps
in the procedure for CWP operation
led the
ANPS
to believe that when the
CWP control switch was green
flagged,
no other precautions
were required.
~
The maintenance
workers took no added precautions
related
to work with vacuum conditions.
~
The work activity should not have
been
attempted without a
clearance.
A review of this event
and requirements
by the inspector
found
that
OP 0010122,
Rev 58, "In-Plant Equipment Clearance
Orders,"
Step 4. 1, stated that
a clearance
would be required
when
operation of equipment
could create
a hazard to personnel
or
equipment.
This failure to obtain
a clearance
is
a violation,
VIO 335/95-18-02,
"Failure to follow clearance
procedures."
SG Blowdown System Misalignment.
On September
9, while in the process of heating
up in
preparation for entry into Node 3, the chemistry department
requested
that operations
place the
SGBD system in service to
improve secondary
chemistry.
The
ANPS directed the
RCO to
perform this task.
At that time, several
other evolutions
were
in progress.
Approximately two hours later,
the
ANPS
questioned
the
RCO on the progress of placing the
SGBD in
service.
The
RCO showed the
ANPS the page of the procedure
he
was using to place the system in operation.
The
ANPS
discovered that the
RCO was using the
SG Cooling and
Wet Lay-Up
Procedure,
OP 1-0120027,
which was the incorrect procedure for
aligning the
SGBD system.
The
ANPS informed the
RCO that
he
was using the incorrect procedure
and directed
him to use the
Blowdown System Operation
Procedure
OP,
1-00830020.
The
RCO was relieved approximately
30 minutes later.
He
notified the oncoming
RCO that the
SGBD system
was ready to be
placed in service.
The
new
RCO on shift, with the assistance
of another
RCO and
a
SNPO continued with the task of placing
the
SGBD system in service.
The
RCOs were in the control
room
and the
SNPO was located at the closed cycle blowdown heat
exchangers.
In the control
room,
one
RCO was controlling AFW
to the
SGs while the second
RCO was adjusting
SGBD flow.
They
were in radio contact with the
SNPO at the
SGBD heat
exchanger
who would adjust flow through the heat
exchanger
as needed.
The control
room experienced
problems in balancing
AFW flow,
SGBD flow, and
SG water level.
The
SNPO called the control
room and informed them that
steam
was blowing out of a line in
the vicinity of the closed cycle blowdown heat exchanger.'he
RCO isolated the
SGBD and
SG water level returned to normal.
An investigation
by the licensee
revealed that the initial
system lineup using the incorrect procedure,
OP 1-0120027,
had
opened
a valve to the
SGBD tank.
When the
RCO was found to be
using the incorrect procedure,
he did not correctly back out of
the incorrect procedure.
This left valves in the open
position.
These valves
should
have
been closed prior to
implementing the
blowdown procedure
OP 1-00830020.
A review of licensee's
procedure
by the inspector
found that
they did not provide explicit guidance to direct operators
on
how to back out of an incorrect procedure
or
a procedure that
does
not work and/or produce
acceptable
results.
This topic is
covered in general
terms in operator training programs
and it
has
been
a general
expectation that operators
would take this
action.
The licensee
is currently reviewing this item to
determine if additional
guidance
is needed.
This item is
considered
a weakness.
10
Unit
1 Pressurizer
Safety Valves
At the
end of IR 95-15, Unit
1 was in Mode 5, replacing the
on the pressurizer
safety valves
and performing
other various maintenance activities.
After the gaskets
were
replaced,
the
RCS was filled and vented but unit startup
was
delayed while repairs
were accomplished
on
fDG lA/1B.
The unit
achieved
Mode
4 on September
24
and
Mode
3 on September
25.
On
September
26,
simmering
was identified on the pressurizer
safety valves.
The plant has
a history of simmering/leaking
safety valves
and
had modified their
RCS pressurization
procedure
to require slow pressurization
to permit the valves
to soak,
equalize
valve component
temperatures,
and achieve
better valve disc to seat contact.
As
RCS pressure
was
increased,
the leakage
also increased.
After reaching
NOP/NOT,
the leakage
on V1201 increased
to about
1
gpm on September
27.
RCS pressure
was decreased
to 2000 psi
and the leakage
decreased.
The licensee
evaluated this problem
and decided to
simultaneously
pursue
three parallel options:
a)
Cool down, depressurize
RCS, perform repairs/adjustments
on SRVs,
and adjust
pi'pe hangers
to reduce tailpipe
loading
on the
SRVs.
b)
Develop
a design
and obtain necessary
parts to eliminate
SRV tailpipes.
c)
Perform engineering
analysis
and obtain
NRC approval
to
operate with RCS at
a reduced
pressure.
The licensee
started
engineering
work on options
A and
B while
the unit was being cooled
down
and depressuri'zed.
During the
plant cooldown
an engineering
evaluation
and measurements
were
performed
on the existing
SRV tailpipe loading.
It was found
that
one rigid hanger
was exerting
a significant amount of
force
on the tailpipe.
After taking hot and cold strain
gage
measurements,
engineering
concluded that adjustments
could
be
made to reduce
the tailpipe stress.
A decision
was then
made
to place the other option
on hold and proceed with this
approach.
All installed safety valves were removed
and sent to Wylie for
repairs,
adjustments
and testing.
The valves were returned
from Wylie and installed
on the pressurizer
during the week of
October 2.
The Unit was then slowly brought
up in temperature
and pressure
with specific hold and,soak
points to allow for
temperatures
of the valves
and piping to reach equilibrium.
This process
was allowed to continue over several
days until
the system
reached
2230 psia.
This condition was achieved
without any valve leakage.
An engineering
analyses,
JPN-PSL-
SENP-95-025,
was then approved
by the
FRG to permit unit
startup
and operation at 2230 psia.
This analyses
concluded
1'1
that operating at
RCS down to 2225 psia
was acceptable
and did
not require
changes
to Technical Specifications,
the
FSAR or
plant procedures
and also did not require
a
evaluation for NRC approval.
The inspector followed the plant
pressurization,
reviewed the licensee's
analyses
and agreed
with their conclusions
and corrective actions
taken
on this
item.
The Unit was restarted
on October
12 and went on-line on
October
13, concluding
a 73 day outage.
No safety valve
leakage
was observed
during the plant restart
and
none
has
been
detected
since restart.
The licensee
had ordered
new forged safety valves of a more
rigid and sturdier design.
The safety valves replacements
for
each unit is currently planned for the
1997
RFO on Unit 2 and
the next
RFO on Unit 1.
The licensee
believes that this will
provide
a permanent fix for this long term problem.
1B
EDG Failure
During
a weekly surveillance
run, the
1B
12 cylinder engine
developed
a fuel oil leak at
a piping connection
in the
return line to the diesel
fuel oil day tank.
The operator
.
rapidly shut
down the
EDG to reduce fuel oil spray.
The engine
was declared
out of service
and
a section of the piping was
replaced.
The
EDG was satisfactorily retested
and returned to
service
on October 8.
Engineering laboratory analysis of the
failed piping by the licensee
determined that the failure was
the result of high cycle fatigue.
This crack evolved over
a
long period of time.
The licensee
also found that the piping
configuration
on the remaining engines
was of a different
design configuration
and that the failure that occurred
on
1B
EDG was not applicable to the other
EDGs.
The inspector did
a walkdown inspection of the failure when it
occurred.
He also did
a walkdown of the repairs after they
were completed
and verified that
a
PHT was conducted
by
a
CR
log review.
He inspected
the
FO piping system
on the remaining
EDGs, discussed
the failure and repairs
in detail with the
system engineer,
and observed
the engine in operation during
a
succeeding
week's surveillance.
Overall, this repair was
handled
in
a timely and effective manner.
Unit
1 Restart.
The Unit
1 reactor
was restarted
on October
12 after
a 73 day
outage.
The inspector
reviewed the control
room logs including
the
OOS, J/LL, Deficiency Log,
and the
OWA log prior to Unit
restart.
No deficiencies that would affect .the unit's safe
return to power were identified.
The inspector
conducted
a
plant walkdown and verified safety
system alignments
and
0
~e
'
12
availability.
Discussions
were also held with plant management
and on-shift operations
personnel
to verify that
no
deficiencies
existed
which could impact
a safe unit restart.
The inspector
observed restart activities over
a period of
several
hours
from the control
room.
Several
delays,
due to
CEA problems,
resulted
in delaying reactor startup.
Two CEA
timing modules
were replaced
and reactor startup
proceeded
in
an orderly and controlled fashion.
The reactor entered
Mode
2
at 12:03
and achieved criticality at 12:55.
Maintenance
work
on
a hydrogen
seal oil pump
and secondary
chemistry cleanup
delayed restart of the secondary
plant until October
13.
The
turbine was placed
on line at 3:00 p.m.
on October
13,
1995.
The overall startup
went well. It was well controlled
and
methodical with adequate
management
and supervisory oversight.
Some Refueling outage activities were delayed
on Unit 2 since
priority was placed
on Unit
1 restart.
6)
Unit 2
a)
Unit Shutdown/Cooldown
Unit 2 was
shutdown
on October 9,
and entered
a planned
refueling outage of 49 days.
ESF Safeguards
Testing
(paragraph 4.b.)
was conducted
during initial plant
shutdown.
A reactor containment building and system
walkdown by the
licensee
at operating
temperature
and pressure
found boric
acid buildup around
a third of the circumference of a
B hotleg nozzle for a Steam Generator differential
pressure
detector.
No active leakage
was observed
but the
boron buildup indicated past leakage.
Isotopic analysis
of the nozzle
boron residue
revealed
and
an
absence
of Cobalt-58.
This indicated that
no recent
leakage
had occurred.
Since the unit was already shut
down and preparing to enter
a refueling outage,
the
TS
required
shutdown
was not applicable.
Engineering
analyses
of this item determined that the
leakage resulted
from
PWSCC of the Alloy 600 material
used
in these
nozzles.
This'is
a well known industry problem.
Units
1 and
2 have several
nozzles that are susceptible
to
this problem.
These include:
pressurizer
nozzles,
hot and cold leg instrument nozzles,
pressurizer
heater
SG leakoff and
The pressurizer
steam
space
nozzles
were replaced
on Unit
2 during the last refueling outage
and the
3 pressurizer
water space
nozzles
are scheduled
for replacement
during
the current outage.
Based
on the identification of this
13
problem,
the licensee
procured
the services
and materials
needed
to also replace
the
9
RCS Hot Leg Nozzles during
the current Unit 2 outage.
This work after integration
into the outage
schedule
appeared
to have minimal impact
on the planned
outage duration.
After discovery of the above,
ESF Safeguards
testing
continued until
a design
problem (paragraph
4.b.) resulted
in delaying test completion until later in the outage.
The unit was then cooled
down without any significant
'roblem
hnd entered
mode
6 on October
18.
Overall, the
unit shutdown
and cooldown
was handled well.
It was noted
that since operations
had gone to verbatim procedural
compliance,
a large
number of the procedures
used during
plant shutdown
and cooldown required temporary procedure
changes.
RPV Disassembly
and Defueling
Unit 2 was cooled
down to 200'
on October ll and work
was started
on removal of support
components
to permit
reactor disassembly.
The reactor vessel
head
was
detensioned
on October
19.
CEA's were unlatched
on
October
20, the
UGS was lifted on October
21
and core
offload commenced
on October 22.
All of the
above
evolutions went well without any significant problems.
During flooding of the lower refueling cavity on October
17, routine job distractions
and inattention to this
activity resulted
in overfilling the lower cavity into the
upper refueling cavity.
This resulted
in leaking
approximately
100 gallons of water into the containment
sump.
A TC/PCR to
OP 2-1600024
was developed
and
implemented to require that
an operator
be stationed
in
containment to follow this evolution in the future.
The
inspector followed all the above evolutions
and conducted
inspections
as
a part of routine daily plant tours.
Core offload initially incurred problems with the
adjustment
and calibration .of the refueling machine load
cell.
The load cell
was replaced
October
23 and offload
continued without any significant equipment
problems
and
was completed
on October 24.
The inspector
observed
the
offload activities from the control
room, containment
and
the refueling machine.
The activity met the
TS required
staffing.
Overall the offload went exceptionally well.
The inspector
was
impressed
with the strict procedural
compliance
and good repeat
back communications
used during
this evolution.
The licensee
practice of having contract
equipment specialists
available to provide for assistance
on equipment repairs
appeared
to assist
on rapid
0
0
(y
14
resolution of the minor equipment
problems encountered.
No deficiencies
were identified.
c.
Plant Housekeeping
(71707)
Storage of material
and components,
and cleanliness
conditions of
various
areas
throughout the facility were observed
to determine
whether safety and/or fire hazards
existed.
Overall plant
cleanliness
and equipment
storage
was
deemed satisfactory.
No violations or deviations
were identified.
d.
Clearances
(71707)
During this inspection period,
the inspectors
reviewed the following
tagouts
(clearances):
~
1-95-10-047
- This tagout isolated
FCV-25-2 isolation valve
P-11) for HSV Containment
Purge Supply.
The
inspector verified that the
4 tags associated
with this
clearance
were
on the correct
components,
in the specified
position/condition
and that applicable
00S
Log entry was
made.
~
2-95-10-228
- This tagout isolated
SB14530/SB14528.
The
inspector
reviewed the Clearance
Order only and noted that the
2
CCW drain valves,
V14173
and V14455,
on lines
58 and
59 were
positioned
Open at 0550 hours0.00637 days <br />0.153 hours <br />9.093915e-4 weeks <br />2.09275e-4 months <br />
on October
23 and not initialed
by the posltioner.
However,
an Independent Verification was
completed
on these
2 valves.
This discrepancy
was brought to
the attention of the work clearance
center
SRO For correction.
e.
2-95-10-245
- This tagout
was issued for configuration control.
The inspector verified that both valves
were in the closed
position
and properly tagged
and that the applicable
Log
entry was made.
~
2-95-10-246
- This tagout
secured
HVA/ACC-3A Air Handling Unit
for the Unit 2 Control
Room Air Supply due to the
The
inspector verified that the breaker
was off and properly tagged
and that the applicable
Log entry was made.
No other deficiencies
were identified.
Technical Specification
Compliance
(71707)
Licensee
compliance with selected
TS
LCOs was verified; This
included the review of selected
surveillance test results.
These
verifications were accomplished
by direct observation of monitoring
instrumentation,
valve positions,
and switch positions,
and
by
review of completed
logs
and records.
Instrumentation
and recorder
traces
were observed for abnormalities.
The licensee's
compliance
with LCO action statements
was reviewed
on selected
occurrences
as
0
~
15
they happened.
The inspectors verified that related plant
procedures
in use were adequate,
complete,
and included the most
recent revisions.
f.
Effectiveness
of Licensee
Controls in Identifying, Resolving,
and
Preventing
Problems
(40500)
Facility Review Group Meetings
The inspector
attended
the
FRG meeting
on October
10 where
a
proposed
license
amendment
to permit operation with a
pressurizer
pressure
minimum limit of 2115
PSI if needed
due to
leaking safety valves
was reviewed.
This amendment
was
supported
by engineering
evaluation
JPN-PSL-SEFJ-95-039,
Rev 1,
After a presentation
by engineering
on this item, several
questions
were raised
by operations.
All questions
were
satisfactorily answered.
The licensee
intends to submit this
request for NRR review if equipment fixes do not resolve the
leaking pressurizer
safety valves.
This
FRG meeting
was the first meeting the inspector
had
attended
since the licensee
revised the
FRG Procedure
ADM-
0010520,
Rev 29, in September
and the Preparation,
Revision,
Revision/Approval of Procedure
gI 5-PR/PSL-1
Rev 64 in October
to use
a subcommittee
review of minor procedural
changes.
In
conjunction with the
above
changes,
the
PGM has delegated
the
Chairmanship of the
FRG to the Manager of Licensing or other
designated
managers
as
needed.
The above meeting
was chaired
by the Manager of Licensing.
The meeting
had the required
quorum and business
was conducted
in accordance
with the above
procedures,
and the meeting
issues
were covered well.
The inspector discussed
the changes
that have occurred in
FRG
Chairmanship with the
PGM.
The
PGM has indicated that
he will
approve all
FRG actions
and will periodically chair these
meetings
and will actually participate
in
FRG issues
with major
safety significance.
This appears
to be appropriate.
2)
Licensee Self Assessment
a)
The inspector
reviewed
gA Audit Report gSL-OPS-95-19,
Training and gualification Functional
Area Audit and gSL-
OPS-95-17
gA Performance
Monitoring Audit reports for the
months of August
and September
1995.
The Training and
gualification Audit appeared
to be adequately
detailed
and
contained
one finding involving the retention of training
records
in the
gA vault.
Action is being taken to address
this item.
gA Performance
Monitoring was conducted
on the following
items:
RCP lAl and
1A2 seal
replacements,
HVE-21A fan
motor replacement,
Local
Leak Rate Testing
on the
RCB
0
16
Maintenance
and
Equipment
and Personnel
Air Locks, Unit
1
PORV repairs
and testing,
Health Physics activities during
the
PSL-1 Short Notice Outage,
Operation of the
new
vehicle barrier gates,
freeze
seal activities
and the
closure
and statusing of STARs required for a mode change.
Two findings were identified in this report;
one
identified problems
associated
with the status of STARs
prior to mode change
and the second
item found that
a work
activity was started
by Construction Services prior to
obtaining formal approval of the Nuclear Plant Supervisor.
It was noted that
STARs were written on each identified
deficiency.
Overall the monitoring activities appeared
to
be adequately
detailed
and focused
on safety significant
activities.
The result of the inspections
were well
documented
and provided good recommendations
for
improvement.
b)
The inspector
met with guality Assurance
on October
19,
for a quarterly update.
Items covered
in this meeting
included:
~
Planned organizational
staffing and responsibility
changes
~
Summary of recent audits
and inspections
~
Planned
4th quarter
and plant outage
inspection
plans
~
Increased
operations
oversight
~ 'ew controls for contractor work
~
Recent
independent
technical
reviews
~
NPWO reviews
~
Engineering
and vendor audit results
~
Nuclear fuels
gA
l
Presentations
were provided
by group supervisors
for each
of the above items/area.
The meeting provided the
inspector with a good understanding
of current
gA and
gC
issues
from the licensee's
perspective.
The inspector
found the presentations
were beneficial
and the
discussions
open
and frank.
The licensee
appears
to be
aware
and taking appropriate corrective actions of
deficiencies that were discu'ssed.
(
17
4.
Maintenance
and Survei1
1 ance
a.
Maintenance
Observations
(62703)
Station maintenance activities involving selected
safety-related
systems
and components
were observed/reviewed
to ascertain
that they
were conducted
in accordance
with requirements.
The following items
were considered
during this review:
LCOs were met; activities were
accomplished
using approved
procedures;
functional tests
and/or
calibrations
were performed prior to returning components
or systems
to service; quality control records
were maintained; activities were
accomplished
by qualified personnel;
parts
and materials
used
were
properly certified;
and radiological controls were
implemented
as
required.
Work requests
were reviewed to determine
the status of
outstanding
jobs
and to ensure that priority was assigned
to safety-
related
equipment.
Portions of the following maintenance
activities
were observed:
1)
Maintenance
Rework during Short Notice Outage.
In IR 95-15, the inspector identified that several
of the
components
that required work during the
SNO had also
been
worked
on during the previous Unit
1 refueling outage that
ended
in December
1994.
The inspector questioned
the licensee
on this item and they agreed
to review the issue.
The
licensee's
review found that 1,029 total
components
were worked
in the Unit
1
1994
RFO.
Sixty-four of these
same
items were
also worked on during this
SNO.
The licensee classified
32 of
these
as definite rework.
The other items were classified
as
long standing
known problems that frequently require
maintenance
and the remainder
were considered
as possible
rework.
Maintenance
issued
a
STAR on each
rework item to
identify root cause
and
needed corrective action.
The
inspector
noted that the number of items worked
on in this
refueling
and
SNO was 6.2 percent,
It was also noted that
several
of the items
had
a history of repetitive maintenance
and that
some of these
maintenance
items were major
contributors to this extension of the
SNO.
2)
Unit
1
EDG Load Oscillations.
In late August, the inspector questioned
an entry in the Unit
1
control
room log which identified
a load oscillation during the
monthly surveillance,
1-22000508,
on
EDG 1B.
Since there
was
no additional entries
involving this item and
any effect on
component operability, the inspector discussed
i,t with the
system engineer.
The
SE stated that the oscillation resulted
from MVAR swings
on the grid.
On September
5, during the post maintenance
and surveillance
run on
EDG 1B,
some load oscillations
were again observed
and
logged.
Some adjustments
were
made in the governor control
0
0
('
18
circuitry and the swings were again credited to grid
oscillations.
On September
6, during
a surveillance
run of EDG
lA, the governor response
was identified as being slow and
non
linear when load adjustments
were
made
by the operator.
Electrical maintenance,
under the direction of the
SE again
made
adjustments
in the governor control circuitry.
During
a
followup test,
500 to 1000
KW load swings occurred
and
a ground
was found in the wiring harness
between
the
DG control cubicle
and the governor
on
EDG 1A2.
PWO 95026057-02
and 95024478-01
were issued
and repairs
were
made to the control wiring.
As
a result of the
above
problems
and to place
more experience
on the
EDGs, the licensee
assigned
a new system engineer with
extensive
past
EDG experience
on the Unit
1 and Unit 2
EDGs.
On September
8, during surveillance testing,
KW oscillation was
again
noted
on
EDG A and additional
adjustments
and tuning took
place
on the governor control circuits.
On September
20,
1B experienced
400
KW load spikes during
a
surveillance
run.
During the troubleshooting effort a ground
alarm started
coming in each
time the governor
speed controls
were manipulated.
Troubleshooting
located
and repaired
frayed
wiring in the wiring harness
between
the local control
panel
and the governor.
This was the
same wiring where
a problem had
been identified and repaired
on
1A on September
6.
The
repairs
were performed
under
PWO 95026002-1A.
The above repair
on both engines
was accomplished
on back
shiFt.
The inspector retrieved
and reviewed the
PWO
documentation
and found that the repair was
made using
Raychem
under
an approved
engineering repair method for damaged
cable
insulation
600 volt and below.
The details for this repair
were contained
on drawing 8770-8-328,
Sheet
19H for PCH 336-
192.
The inspector
reviewed the
PWOs
and discussed
the repairs
with maintenance,
engineering,
and the system engineer.
Based
on this information and
a successful
the
repairs
were
deemed
to be acceptable.
An engineering
assessment
of the
above
DC ground
was that the
plant
DC System is designed
as
a floating, ungrounded
system
and
a single ground
on either the positive or negative
bus
would not affect operability of the
bus or the
EDG governor
system.
The inspector
reviewed this issue
and the governor
control wiring circuit with the frayed wires with the system
engineer
and agreed with that conclusions
On September
21,
18 again experienced
load oscillations
during
a surveillance test.
This occurred
when the operator
attempted
to make load adjustments.
On September
22,
VAR and
KW swings again occurred
on
EDG 1A.
1A was declared
OOS by
operations
and
a meeting
was held with Operations,
Engineering,
19
System Engineering,
and Plant Management
to discuss this issue
and overall
EOG performance
and reliability.
As
a result of
this meeting
an
EOG maintenance
vendor
and governor
manufacturer
services
were obtained to analyze
and propose
short term and long term corrective actions
on these units.
The short term corrective action resulted
in initiation of PWOs
65-1328
on
EOG IB and 65-1326
on
EDG 1A.
These
PWOs led to the
replacement
of the motor operated
the speed
load
sensor,
and amplifier modules
on
EOG
1A and the motor operated
and
speed
sensor
module
on
EDG 1B.
The
electronic control units were readjusted
and tuned in
accordance
with the vendor technical
manual
and with direct
assistance
provided
by the governor
and engine vendor
representatives.
The
DGs were taken out of service
one at
a
time and worked under
LCO controls.
Repairs
were complete
on
September
24.
Post maintenance
testing
on both units
demonstrated
considerably
improved operator control during load
changes.
It was also noted that the frequency
and magnitude of
previously identified oscillations
had decreased.
The inspector
observed
several
of the
above
EOG runs
and
attended
the meeting held
on these
issues.
He also
had
frequent interface with the system engineer,
maintenance
and
vendor personnel
who worked
on the
EDGs,
The licensee
decided to place the Unit
1
on
an increased
surveillance of every seven
days until they gained confidence
that the above repairs
had addressed
the previous problems.
The system engineer
and maintenance
management
have stated that
they are reviewing the overall maintenance
program
on the
EOG.
They have
asked for inputs from the engine
and governor vendors
and intend to upgrade
the overall maintenance
of these vital
components.
They have also stated that they are considering
upgrading
the governor control
system to
a newer model that has
improved reliability and more readily available
spare parts.
The licensee's
efforts
on the
EDGs have resulted
in improved
performances
However, it was noted that this did not occur
until after several
failures
and significant questioning
by the
NRC.
This item is identified as
a weakness
in diesel
generator
maintenance
and the lack of adequate
equipment
performance
standards
by operations.
(Closed)
URI 389/95-05-03,
" Incore Instrument Wiring Errors"
IR 95-05 documented
apparent wiring discrepancies
in Unit 2
ICIs.
The discrepancies
were associated
with ICI flange
8 and
resulted
in erroneous
ICI spatial
input to the plant computer.
During the current Unit 2 outage,
the licensee
performed
an
inspection of ICI flange
8 wiring prior to de-terminating
the
wiring for vessel
head
removal.
20
The subject inspection
was performed
under
PWO 64/4529
and
included checks of wiring from the refueling disconnect
panel
to the top of the reactor
head.
The licensee
found that
4 of 6
ICI strings
were improperly wired.
The results
were recorded
for inclusion in detector
burnup calculations.
As stated
in IR 95-05,
18C Procedure
1400023,
"Incore
Instrumentation
(ICI) Outage Tasks,"
Appendix K, "ICI Flange
Assembly," required
two separate
reverifications of proper
wiring once flange connections
were
made.
The failure of the
licensee
to perform adequate
verifications of the wiring of ICI
8 following reconnection
during the
1994 Unit 2
refueling outage constitutes
a violation,
This licensee-
identified and corrected violation is being treated
as
a Non-
Cited Violation, consistent
with Section VII of the
NRC
and will be identified as
NCV 389/95-18-04,
"Inadequate Verification of ICI Wiring Connections After
Reassembly."
b.
Surveillance Observations
(61726)
Various plant operations
were verified to comply with selected
TS
requirements.
Typical of these
were confirmation of TS compliance
for reactor coolant chemistry,
RWT conditions,
containment
pressure,
control
room ventilation,
and
AC and
DC electrical
sources.
The
inspectors verified that testing
was performed in accordance
with
adequate
procedures,
test instrumentation
was calibrated,
LCOs were
met,
removal
and restoration of the affected
components
were
accomplished
properly, test results
met requirements
and were
reviewed
by personnel
other than the individual directing the test,
and that
any deficiencies identified during the testing were
properly reviewed
and resolved
by appropriate
management
personnel.
The following surveillance test(s)
were observed:
1)
OP 1-2200050A,
1A
EDG Periodic Test
On October 5, the inspector
observed
the licensee
perform the
monthly surveillance
on the "1A" EDG using
OP No.
1-2200050A,
Rev 22.
A local start
was performed
per step 8. 1. 18 of the
procedure.
After performing the normal
engine
checks at 375 to
475
RPM (idle), the operator placed the Idle Start
Mode
Selector
Switch in AUTO and verified that the diesel
increased
speed
to 900
RPM.
At this time, the Local
and
STOP/AUTO/START Switch were to have both the green
and red
lights illuminated per the
NOTE in the procedure.
The operator
at the local station notified the control
room that the red
light was not illuminated.
The System Engineer,
who was
present for the test,
issued
a
PWO identifier tag
872844 for a
faulty lamp socket.
Several
indicator lamps
on this local
panel
had
been
worked
and closed out on September
25 under
a
minor
PWO (Work Request 895015426 identified intermittent
amber
lights).
The inspector's
followup with the Electrical
Planning
21
Department
showed that the bulbs
had
been replaced).
The
System Engineer released
the diesel for test
and initiated Work Request 895016229 to correct the faulty lamp socket.
The
diesel
was loaded to approximately
3500
KW for its
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> run.
The inspector
reviewed the strip chart for load
and
saw no
fluctuations or spiking.
Following successful
completion of
the surveillance
the
EDG was returned to it's standby status.
OP 2-0400050 Periodic Test of the Engineered
Safety Features
Background
Engineered
Safety Features
(ESF)
are designed
to mitigate the
consequences
of postulated
DBA.
The
ESF function is to limit,
contain,
control
and terminate
an accidental
release
of
radioactive fission products, particularly as
a result of
accidents
that could release
large
amounts of energy within the
containment structure.
ESF systems
keep exposure levels to the
public and plant personnel
below applicable limits.
St.
Lucie Unit 2 utilizes the following ESF systems:
1.
2.
3.
4.
5.
6.
7.
Containment Structure
Containment
Spray
System
Containment
Cooling System
Shield Building Ventilation System
Containment Isolation System
Combustible
Gas Control
System
Safety Injection System
Unit 2 Technical Specifications identify the
LCOs and
associated
surveillance
requirements.
The surveillance
requirements
specify tests
and the frequency requirements
to
demonstrate
operability of systems
important to safety.
Operating
Procedure
No. 2-0400050,
Rev 16, "Periodic Test of
the Engineered
Safety Features,"
satisfies
a large
number of
ESF surveillance
requirements.
This
OP verifies
ESF system
actuations
with plant systems
configured
as closely
as possible
to those
found in the normal operating
procedures.
The
OP is organized
into
12 blocks of test instructions
and
15
Appendices.
Hultiple TS requirements
are verified by this test
procedure.
The
NRC inspector selected this
OP for observation
due to the
first use
on Unit 2 following procedural
revision.
Past
surveillance
problems
included:
~
IR 92-14 identified
a procedural
violation for the Failure
to Adequately Test the
C Intake Cooling Water
Pump.
This
was
based
on
a failure to test the trip and restart of the
22
C
ICW Pump
on the energized
emergency
bus following a
LOOP.
~
IR 94-12 identified
a violation for inadequate
corrective
actions involving the surveillance testing of the
C
ICW
Pump,
This involved
a failure to verify C train
ICW and
CCW pump load shed
and sequencing
functions
when powered
from their alternate
power supply busses.
~
IR 94-22 identified
a violation involving inadequate
corrective action to
a
NRC violation regarding
operability.
This violation identified an electrical
alignment of the
1C
ICW pump to the
IA3 bus while relying
Load shed testing of the
1C
ICW Pump,
when aligned to this bus,
had not been
performed
as required
by TS for
EDG operability.
Test Observation
On October
12, the inspector
attended
the pretest briefing
conducted
by the operations
manager
and found it to be thorough
and detailed.
All test personnel
were verified in attendance.
Items covered
included;
Precautions
and Limitations
Past
experiences
and lessons
learned
Pro<"" iral control
Use of effective communications
Contingencies
and test termination criteria/
It was also stressed
that the operating
crew retained
responsibility for safe plant operation.
On October
12, the inspector
observed
the performance of the
following test procedure
steps:
Step 8.4
~
Verifies initial system alignments
~
Secures
a'nd realigns
SDC system,
ESFAS logic and
ICW
system for test
~
Initiates
a
LOOP by simultaneously
opening the Startup
Transformer
feeds to the 4. 16
KV buses
2A2 and
2B2
~
Simultaneously initiates
a SIAS,
CIAS, NSIS and
CSAS using
the trip test pushbuttons
~
Verifies proper system
response
~
Resets
and restores
systems
to pretest
alignments
During the realignment of the
ICW system for test,
the manually
operated
ICW pump discharge
valves were throttled to 10 turns
open
from their normally full open position. 'his
was done to
minimize potential
equipment
damage
due to water
hammer
when
'
23
starting the
ICW pumps
under
no flow conditions.
The
ANPO
assigned
to this test
area
looked
ahead
in the procedure
and
requested
permission to throttle the
2C
ICW Pump discharge
valve before
SDC was secured.
This was proposed
to minimize
the time required to realign the
ICW system after
SDC was
secured.
The Test Director agreed
since the
2C
ICW would be in
a P-T-L position for the test.
The
ANPO reported that the
valve locking device
(a padlocked
chain) could not be removed
and that
he was unable to insert the key into the padlock due
to corrosion.
After removing the chain with boltcutters,
the
ANPO was unable to reposition the valve without excessive
force, i.e. the operator
appeared
to be frozen.
The Test
Director determined that leaving this valve in the full open
position would not impact the test or create
a potential for
equipment
damage.
As followup to this problem,
however,
the
Test Director briefed other test personnel
that if a similar
problem was encountered
in repositioning the
2A or 28
ICW
discharge
valves,
SDC would be restored
and the test
temporarily secured.
The inspector
was
impressed
by the ANPO's
initiative in looking ahead
in the procedure
and identifying
this impediment to testing.
This problem recognition
and
resolution minimized the period of time that
SDC was secured
and which could have interrupted the test.
Shutdown cooling was secured
at 2:26 p.m.
and the final 'system
realignments
performed.
RCS temperature
was 120'.
At 2:40
p.m.,
the
LOOP was initiated by simultaneously
opening the
Startup Transformer
feeds to the 4.16
KV buses
2A2 and 282.
One
second later the SIAS,
CIAS, HSIS and
CSAS trip test
pushbuttons
were depressed
inserting the
ESFAS Signals.
All
ESFAS actuations
occurred
as expected.
SDC was restored
at
1505 hours0.0174 days <br />0.418 hours <br />0.00249 weeks <br />5.726525e-4 months <br />.
During the 39 minutes
SDC was secured
the
calculated that the
HUR was approximately 66',
however
temperature
increased
to only 160'
due to partial core
cooling from the operating
ECCS pumps.
An unexpected
EDG 28 Local Alarm (A-26 annunciator)
was
received
when the
LOOP was initiated.
This was caused
by the
failure of the
EDG 28 electrical
fuel
pump.
The attached
fuel
pump allowed for continued operation.
This alarm later cleared
and
a
PWO was written to correct this problem.
Also, test
personnel
reported
problems with the
EDG 2A test recorder.
A
cross-check
with installed instrumentation locally and in the
control
room as well as
a hand held calibrated voltmeter,
isolated
the problem to an apparent drift of the null point
(bias)
on the test recorder
channels
selected.
At 3:42 p.m.,
a loud noise
was heard
from the
H&V toom adjacent
to the control
room.
The operating
HVAC/ACC 3-A was secured
and the noise stopped.
The licensee
suspected
a freon release
caused
by inadequate
ICW flow to the
CCW Heat Exchangers.
24
HVAC/ACC 3-B was placed in service,
however,
a failure alarm
was received
on that train also.
This placed Unit 2 in AS b.
of TS 3.7.7 which with both control
room emergency air cleanup
systems
required the suspension
of all operations
involving core alterations
or positive reactivity changes.
The
access
door from the control
room to the
H&V room was blocked
with explicit instructions given by the Operations
Manager to
the
NPS that entry for safety
and maintenance
personnel
would
be through the access
door inside the
RCA and not the control
room.
This would ensure
continued control
room habitability.
A technician
from the safety department
reported to the control
room,
and
due to poor communications,
entered
the
H&V room
through the blocked access
door.
The technician
entered
the
H&V room alone using
a handheld
oxygen meter sampling at neck
level.
The Operations
Manager ordered
the technician
out the
H&V room and posted
a sign
on the access
door stating,
"No
entrance without prior NPS approval".
A followup survey of the
H&V atmosphere
using
a freon detector
confirmed that freon
levels were within an acceptable
range.
Maintenance
reported
that the 3-C freon safety valve had apparently lifted based
on
low system pressure
and that both the 3-A and 3-B units were
available.
Unit 2 then exited
A followup discussion
by the inspector with the Operations
Manager confirmed that the
safety department
technician's
actions
were inconsistent with
plant procedures
and that the technician
had
been
counseled
on
this item.
The licensee
is evaluating
a procedural
enhancement
~
which will either fully open the
ICW discharge
valves
when flow
is reestablished
during the test or increase
the number of
turns throttled
open to preclude
recurrence
of this problem.
A list of equipment
problems identified during steps
8. 1
through 8.4
and their associated
PWOs,
where applicable,
include:
a.
b.
C.
d.
e.
HCV-09-1A, A MFW isolation valve, valve was slow to open,
PWO 5424/64
MV-09-10,
2C
AFW Pump discharge,
Unable to throttle,
PWO
1451/66
V09136,
2B AFW Pump Supply isolation valve,
Valve leaking
by,
PWO 5072/62
V09158,
2C
AFW Pump Supply isolation valve to
2B
inlet, Valve leaking by,
PWO 5092/66
MV-09-13, Cross-tie
between
AFW pump
2A and
2B discharge,
Valve leaking by,
PWO 5074/62
MV-09-14, Cross-tie
between
AFW pump
2A and
2B discharge,
Valve leaking by,
PWO 5075/62
25
g.
FCV-25-35, Shield building vent
8 purge control to vent
stack,
OL would not reset,
PWO 1458/62
h.
2B2
EDG,
Pump binding,
PWO 5098/62
i'UPS,
SUPS lost in
LOOP test,
PWO 1447/66
j.
'VE-6A, The overload tripped when the
A train Shield
Building Ventilation Fan
was stopped
and then restarted.
This was due to
a high rad signal
being present
when the
radiation monitor lost power during the
LOOP.
This signal
was reset
and the overload for HVE-6A was also reset.
HVE-6A was
OP tested
SAT.
k.
2A2
RCP OIL LIFT PUMP, This
pump restarted
when the
signal
was reset.
The licensee will review the applicable
CWDs and determine if a
PWO is required.
l.
RM-23's, Approximately 1/2 of the
RM-23 monitors were lost
during the
LOOP.
The licensee
generated
a
STAR to address
this problem.
m.
FCV-25-32/33,
HVE-6A/6B inlet control valves,
These
two
valves closed
upon reset of the
CIAS signal.
This was
due
to the high rad signal
being present
when the radiation
monitor lost power during the
LOOP.
When the signal
was
reset,
the valves functioned normally.
Items j. and
m.
above will be incorporated
as
a procedural
enhancement
to recognize
the failed high rad monitor signal
during the
LOOP.
Step 8.5
Aligns the
2AB bus to the
A Electrical Side
Initiates
a load rejection with a concurrent
LOOP/Swing
Pump
SIAS Signal
using
a Group
9A SIAS Signal
Realigns
the
2AB bus to the
B Electrical
Side
Initiates
a load rejection with a concurrent
LOOP/Swing
Pump
SIAS Signal
using
a Group
9B SIAS Signal
Testing of the
A Electrical
Side was satisfactorily completed
prior to shift turnover.
When testing
resumed
on the
B
Electrical Side,
the
2C Charging
Pump failed to start
when the
Group
9B SIAS Signal
was inserted.
This was
due to
a
procedural
deficiency, i.e.,
channel
MB Containment
Pressure
SIAS 127,
BA 101,
301
bypass
key was in the bypass position.
The test
was exited prior to completing step 8.5
and
resumed
at
step 8.6.
Step 8.6
26
Aligns both
full load
Initiates
a
Initiates
a
Initiates
a
Initiates
a
Initiates
a
Initiates
a
2A and
2B
EDGs with offsite power at or near
Channel
A CIAS then resets,
Channel
B CIAS then resets
Channel
A SIAS then resets
Channel
B SIAS then resets
Channel
A CSAS then resets
Channel
B CSAS then resets
After each
ESFAS Channel
is actuated
individual component
actuations
are verified.
This particular step of the procedure
had
been revised.
The
previous
procedure
Revision inserted
a SIAS Signal prior to the
CIAS Signal.
This did not allow for separate
verification of
the
CIAS Signal actuations
since the
SIAS also generated
a CIAS
signal
by design.
The licensee
believed that changing the
order would enhance
the procedure
and provide more detailed
ESFAS Signal verifications.
After the Channel
A CIAS Signal
was inserted
and the component
actuations verified, Channel
A CIAS was reset.
At this time
the
2A
EDG tripped
on reverse
power.
The test
was secured
and
the
2A
EOG declared
An investigation
by the licensee
determined that during the
performance of Section 8.6 of OP 2-0400050,
EDG 2A was running
parallel to the grid and loaded to >3600
KW.
CIAS-A was
manually initiated in accordance
with step
12 of the test
procedure.
Actuation of CIAS caused
the
EDG A governor circuit
to change
from the droop
mode (i.e. follows the grid frequency)
to an isochronous
mode (i.e. reverts to preset
frequency
and
does
not follow the grid frequency).
The
EOG
2A preset
frequency
was lower than that of the grid.
This resulted
in
reducing fuel to slow the
EOG down, leading to reverse
power
flow causing
the generator to act
as
a motor (or synchronous
capacitor).
The reverse
power relay actuated;
however,
due to
the presence
of the CIAS-A signal,
the relay trip function was
blocked.
Upon resetting of the CIAS-A signal,
the reverse
power relay trip block was
removed
and the
EOG tripped,
Total
time of EOG operating
under reverse
power was approximately
45
seconds.
A review of the
ERDADS printout of Bus
2A3 voltage
and current
and
EDG current confirmed
a sudden
change
at the approximate
time CIAS was initiated.
The current
drawn by the
EDG 2A
generator
during the reverse
power incident was approximately
330
amps.
From this the licensee
determined that the
2A EDG
output current of 477.54
amps reversed
to 330.38
amps for a net
change of 807.84
amps which was sufficient to actuate
the
reverse
power relay.
Concurrent with this,
Bus
2A3 voltage
changed
from 4331.7 volts to 4360.2
as
a result of the
27
generator
producing additional
HVARs, i.e., acting
as
a
synchronous
capacitor with a high power factor.
This value is
well within the
660
amp continuous
rated capacity of the
generator
windings.
Based
on the above,
System
and
Component
Engineering
determined that
EOG
2A had not been
damaged
by the
incident.
The
2A
EDG voltage regulator
was visually inspected
with satisfactory results
and the
2A EDG was started
and loaded
successfully
as
an operability check.
Further,
performance of
the regular
18-month preventative
maintenance
(Haintenance
Procedures
2-2200062
and 2-H-00180),
included
a thorough
inspection
on
EDG 2A and did not identify any damage
as
a
result of this event.
An engineering
review of the
EDG control circuits found that
the
EDG starts
on SIAS,
CSAS or CIAS and that these
signals
cause
the
EOG to change
from droop
mode to isochronous
mode
(Ref.
CWDs 957
& 958
and Vendor Hanual
2998-7434).
Opening the
Bus 2A2-2A3 tie breaker will also
change
the
EDG from droop to
isochronous
modes.
In the case of SIAS and
(CSAS will
only occur with SIAS), the
EOG circuit breaker will trip if
closed,
permitting the
EOG to run separate
from the offsite
power source.
However,
CIAS without SIAS does not trip the
breaker,
resulting in the
EDG operating
in isochronous
mode
while still connected
to offsite power. This condition is not
expected
during normal operation or any design basis
event
requiring the
EDGs.
STAR 8951391
was written to identify this design deficiency
on
the Unit 2
EDGs.
EDG 2B has not been tested with a manual
CIAS actuation,
therefore its operability was not affected.
The Unit
1
EDGs governor control design is different from the
Unit 2
EDGs.
The Unit
1
EDGs have
been successfully
tested
using
an essentially identical
ESFAS test procedure.
Therefore,
there is no operability concern
from the Unit
1
EDGs.
Based
on the above,
the
EDGs were considered
The, inspector
reviewed the above
assessment
and noted that
while actuation of the
CIAS relay without SIAS is not expected
during normal operation,
both Unit 2
EDGs are tested
monthly
and operated
a minimum of
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> paralleled to the offsite
power source.
Actuation of CIAS under these test conditions
could have resulted
in damage to the
EOG.
The inspector
was concerned
by several
aspects
related to the
design deficiency identified during testing:
(4
kj'
28
I.
Integrated
Safeguards
testing over the, past
2 years
had
received
a high level of management
and technical
support
attention
due to the licensee's
misinterpretation of
testing requirements
particularly related to swing bus
components.
The current test procedure revision changed
the test
sequence
for initiating CIAS/SIAS/CSAS Signals in
step 8.6
as
a procedural
enhancement.
Although this
same
test
was successfully
performed earlier
on Unit I and
satisfactorily tested
on the simulator, it was not
reviewed in sufficient detail to assess
the impact
upon
equipment or system operation
on Unit 2.
2.
This condition has existed
since initial construction.
There
was
no licensee identification of this failure mode,
i.e. receiving
a CIAS Signal while paralleled to an
offsite power source.
3.
The
2A
EDG was operated for approximately
45 seconds
with
a reverse
power trip blocked,
A review of the
CWDs
determined that
a local reverse
power alarm occurred
which
the licens'ee
believes
also generated
a control
room alarm.
Since operators
were either
unaware or did not question
these
alarms,
the inspector
concluded that it was doubtful
whether operator actions
would have prevented
damage if
the
CIAS had not been reset
unblocking the reverse
power
trip.
The licensee
has
placed
a temporary hold on 2A/B EDG testing
pending resolution of their STAR.
On October
23, the licensee
issued
JPN-PSL-SEES-95-034,
Rev.
0
Safety Evaluation for the provisions to trip emergency diesel
generator
output breaker
on CIAS in plant modes
5 and 6.
This
short term plant temporary modification (plant mode
5 and
6
only) involves wiring any convenient
"deenergize
to close"
CIAS
spare
contact in the
ESFAS cabinet
(A or B,
as required) to
trip the
EDG output breaker
upon receiving
an actual
or
spurious
CIAS while operating
the diesel
generator paralleled
to an offsite power source.
The inspector
reviewed the Safety
Evaluation
and found the approach
acceptable
and consistent
with existing licensing requirements.
The above short term plant temporary modification was not
implemented.
Rev I to the above Engineering
Report
was issued
on October 27.
The licensee's
long term corrective action
involved deletion of the automatic
EDG start
on CIAS and
~
since it removed the adverse
conditions,
was relatively easy to
implement
and test,
and
can
be installed
under
This modification will also
be impl'emented
on Unit I at the
earliest
convenience
for consistency
between units
and to
ensure
that spurious signals
would not bypass
the non-safety
trips if the
EDG was connected
to offsite power.
The inspector
29
reviewed
and evaluated
the revised
Engineering
Report
and found
it to be acceptable.
10 CFR 50 Appendix
B guality Assurance Criteria for Nuclear
Power Plants
and
Fuel
Processing
Plants requires,
in part:
a.
that
"Measures
shall
be established
to assure
that
applicable regulatory requirements
and the design basis,
as defined in g 50.2
and
as specified in the license
application, for those
systems,
structures
and components
to which this appendix applies
are correctly translated
into specifications,
drawings,
procedures,
and
instructions...
The design control measures
shall provide
for verifying or checking the
adequacy of design,
such
as
by the performance of design reviews,
by the use of
alternate
or simplified calculational
methods,
or by the
performance of a suitable testing program."
[CRITERION
III, DESIGN CONTROL]
b.
that
"A test
program shall
be established
to assure that
all testing required to demonstrate
that structures,
systems,
and
components will perform satisfactorily in
service is identified and performed ..."
[CRITERION XI]
The licensee's
failure to identify this design deficiency
during initial design
and testing
and adequately
review the
revised
Safeguards
Test procedure for performance
on Unit 2 is
considered
a violation,
VIO 389/95-18-03,
"Failure to
Adequately Design
and Test the
Emergency
Diesel
Generator
2 A/B
Engineered
Safety Feature
Control Logic."
This licensee
identified and corrected violation was considered for treatment
as
a Non-Cited Violation, consistent with Section VII of the
This violation is being cited due to
the lack of questioning attitude
and
a weakness
in the depth of
review during the changing,
updating,
and correcting of the
applicable
EDG test procedure.
3)
Hissed
CEA Position Surveillance
On October 20, the licensee identified that operations
had
missed
the Unit
1
TS 4. 1.3.3 surveillance
which verifies
position indication difference
between
reed switch position
transmitters
and pulse counting channels
to be less
than 4.5
inches.
TS requires this surveillance
once every
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
and
the licensee
accomplishes
this surveillance
once
each shift in
accordance
with AP 1-0010125,
Rev 102,
"Schedule of Periodic
Test,
Checks,
and Calibrations,"
Check Sheet
1, step
16.
This
surveillance
was missed
on the day and peak shifts
on
October
19.
An investigation
by the licensee
found that the last
surveillance
was performed
between
Midnight and 2:00
AH on
0
30
October
19.
The readings
were recorded
on the Control
Room Log
sheet for CEA positions.
The operator
also signed off
completion of the surveillance
on AP 1-0010125
Check Sheet
1.
The midshift ANPS reviewed the log and check sheet,
but
inadvertently placed the
CEA position log sheet
in the
licensing review file rather than returning it to the
RCO.
The
oncoming
RCO did not identify that the log sheet
was missing
and therefore
he did not perform the surveillance.
Since the
RCOs were standing
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts during the refueling of a
unit,
he was responsible
for completing the day and peak shift
surveillance.
Prior to turnover to the next
RCO,
he signed off
the
AP 1-0010125
check sheet indicating that the
CEA position
indicator surveillance
had
been
completed.
The next midshift ANPS, during his documentation
review on
October
20, discovered that the surveillance
had
been
missed
for the day and peak shift.
The readings
were then taken at
approximately
1:00
AM on October 20.
The total time between
surveillances
was approximately
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> which exceeded
the
allowable interval including
a 25 percent
extension
period of
15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.
Since the pulse counting channels
and
CEA reed switch positions
were both operable
and alarms
were available to indicate
any
significant
CEA misalignment, this item had minimal safety
significance.
It has
been
noted that the licensee's
current practices
permit
operators
to complete surveillances
such
as this
and later sign
off the check sheet
near the
end of their shift.
Had the check
sheet
been required to be signed off when the surveillance
was
actually done vice the
end of the shift, then this event would
not have occurred.
This licensee identified and corrected violation is being
treated
as
a Non-Cited Violation, consistent
with Section VII
of the
and will be identified as
335/95-18-05,
on
CEA Position Indication."
Hissed Surveillance
on
RCS Born Sample
Unit 2 Technical Specification 3. 1.2.9 requires that boron
'oncentration
shall
be verified consistent with Shutdown Margin
in Mode 6 by sampling the
RCS at
a frequency determined
by the
number of operable
charging
pumps.
The
AS requires that all
operations
involving core alterations
or positive reactivity
changes
be suspended if the
TS requirement
is not met.
At.approximately 6:00
AM on October
20 the Shift Technical
Advisor identified that two charging
pumps were operable
and
that the
RCO was logging the Boronometer readings
hourly to
verify Born concentration.
After review, it was determined
31
that sampling vice using the boronometer
was required
and that
with
2 charging
pumps operable the'ampling
frequency
was
95
minutes.
Further review by the operators
found that this
TS
had
been
met by using the boronometer
since entering
Mode
6 at
4:30
AM on October
18.
During this time span Chemistry
had
been taking
RCS samples
every
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
as required
by TS
4. 1.9.2.
Upon identification of this item the
NPS directed
that
2C Charging
pump
be disabled
and Chemistry to begin taking
samples
every
220 minutes
as required with I Charging
pump
available.
During the
above time span
when samples
were not
taken,
the boronometer
'readings
showed that
concentration
was consistent with the shutdown margin
requirements,
and
or positive reactivity
changes
had occurred.
The inspector verified this action
had
been
taken
and the readings
were current
by log reviews.
The licensee's
above corrective actions
were adequate
to
prevent recurrence
of the event.
However,
the inspector
noted
that the licensee's initial evaluation of the event
found that
the licensee's
method of scheduling
and tracking this
surveillance,
AP 2-0010125,
Rev 55,
"Schedule of Periodic Test,
Checks
and Calibration," check sheet
I item ll was poorly
worded
and possibly misleading to the operator.
The inspector,
on conducting
an evaluation of the licensee
action to correct
this procedural
deficiency, visited the control
room on October
26
and found that
a procedure
TCN had not been
issued to clear
up the procedural
questions
and the operators
on watch did not
understand
this problem
and the correct
TS interpretation or
the operator actions that should
be taken.
Based
on the above,
the inspector
met with the Operations
Supervisor
who stated
that the task of correcting the procedure
had
been
assigned
to
a night shift NPS.
A procedure
change
was
implemented
on
October
26, to address
this issue.
It was noted that since the
boronometer
was in service
and
used during this time span
and
since the correct
boron concentration
was maintained, this item
has little safety significance.
The licensee identified and
corrected violation is being treated
as
a non-cited violation,
consistent with Section VII of the
will be identified as
NCV 389/95-l8-06,
"Hissed
Concentration
surveillance during Mode 6."
5.
Engineering
Support
(37551)
a.
Review of adequacy of Spent
Fuel
Pool Cooling Design
assuming
single
failure.
The inspector
reviewed the both unit's
and
spoke with Reactor
Engineering
regarding
the Spent
Fuel
Pool Cooling Design issue
addressed
in the Region II Director of Reactor Projects
memo to all
Region II SRIs.
This issue
questioned:
32
1)
Is the Spent
Fuel
Pool
heat
removal capability based
on the
assumption
that only 1/3 of the core would be off-loaded,
rather
than the full core
as
has
become
the standard
practice
at
some sites
and,
2)
Is the Spent
Fuel
Pool heat
removal capability adequate
in this
case
assuming
single failure.
a)
Unit
1 was designed
to maintain
a storage
capacity of no
more than
1706 fuel assemblies
(7 2/3 cores of spent fuel
assemblies,
control element
assemblies,
new fuel during
initial core loading
and the spent fuel shipping cask).
Two thermal
loading analyses
have
been performed;
the
Normal. Batch Discharge
and the Full Core Discharge.
In
the case of the Normal
Batch Discharge,
the analysis
assumes
that
18 batches
of 80 assemblies
each
have
been
discharged
from the core in
18 month intervals,'
refueling batch of 80 assemblies
was
added
150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> after
reactor
shutdown.
This analysis
showed
a maximum pool
bulk temperature
of 133.3 degrees
F with the fuel pool
cooling system in service.
For the Full Core Discharge,
assuming that
73 of the assemblies
have
90 days of
irradiation,
72 have
21 months of irradiation
and the
remaining
72 assemblies
have
39 months of irradiation (217
assemblies total), the analysis
showed
a maximum pool bulk
temperature
of 150.8 degrees
with the fuel pool cooling
system in service.
Unit
1 has
2 fuel pool cooling
pumps supplying flow
through
a single spent fuel pool heat exchanger.
The Unit
1
FSAR requires
2 fuel pool
pumps
and the heat
exchanger
in service for an abnormal,
or full core offload.
section
9. 1.3.4.3 states
" In the event of a complete loss
of cooling capability, there is sufficient time to provide
an alternate
means of cooling".
The inspector
has
requested
a clarification of this section
from the
licensee.
b)
There were currently 973 spent fuel assemblies
and
16
miscellaneous
assemblies
in the Unit
1 Spent
Fuel
Pool.
Existing space
allows for operation until the year 2007.
Unit 2 was designed
to maintain
a storage
capacity of no
more than
1076 fuel assemblies
(approximately
5 full cores
and the fuel handling tools).
Two thermal
loading analyses
have
been
performed;
the
Normal
and the Accident Case
Assumptions.
The Nor'mal
Case
assumes;
1.
11 batches
(each
1/3 core) discharged
33
2.
Host recent
batch cooling for five days after
shutdown
3.
Adiabatic heat
up of the pool
The analysis
showed
a maximum pool bulk temperature
of 131
degrees
F with the fuel pool cooling system in service.
The Accident Case
assumes;
1.
11 batches
plus
one full core discharged
2.
One (1) core cools for 7 days
3.
Host recent
1/3 core batch cools for 90 days
This analysis
shows
a maximum pool bulk temperature
of 148
degrees
F with the fuel pool cooling system in service.
Unit 2 has
redundant trains of spent fuel pool
pumps
and
heat exchangers.
Under accident conditions, i.e. loss of
1 train,
pool temperatures
are expected
to rise to
approximately
155-160
F.
This exceeds
the
SRP Subsection
9.1.3 recommendations,
however,
the licensee
considers
this to be acceptable.
There are currently 544 spent fuel assemblies,
84 new fuel
assemblies
and
5 miscellaneous
assemblies
in the Unit 2
Spent
Fuel
Pool.
Existing space
allows for operation
until the year 2002.
6.
Plant Support
(71750)
a.
Fire Protection
During the course of their normal tours,
the inspectors
routinely
examined
facets of the Fire Protection
Program.
The inspectors
reviewed transient fire loads,
flammable materials
storage,
housekeeping,
control
hazardous
chemicals,
ignition source/fire risk
reduction efforts, fire protection training, fire protection
system
surveillance
program, fire barriers, fire brigade qualifications,
and
gA reviews of the program.
No deficiencies
were identified.
'.
Physical
Protection
During this inspection,
the inspector toured the protected
area
and
noted that the perimeter
fence
was intact
and not compromised
by
erosion or disrepair.
The fence fabric was secured
and barbed wire
was angled
as required
by the licensee's
Physical
Security Plan
(PSP).
Isolation zones
were maintained
on both sides of the barrier
and were free of objects
which could shield or conceal
an
individual.
34
The inspector
observed
personnel
and packages
entering the protected
area
were searched
either
by special
purpose detectors
or by a
physical
patdown for firearms,
explosives
and contraband.
The
processing
and escorting of visitors was observed.
Vehicles were
searched,
escorted,
and secured
as described
in the
PSP.
Lighting
of the perimeter
and of the protected
area
met the 0.2 foot-candle
criteria.
In conclusion,
selected
functions
and equipment of the security
program were inspected
and found to comply with the
requirements.
c.
Radiological Protection
Program
Radiation protection control activities were observed to verify that
these activities were in conformance with the facility policies
and
procedures,
and in compliance with regulatory requirements.
These
observations
included:
Entry to and exit from contaminated
areas,
including step-off
pad conditions
and disposal
of contaminated
clothing;
Area postings
and controls;
Work activity within radiation,
high radiation,
and
contaminated
areas;
Radiation Control Area
(RCA) exiting practices;
and,
Proper wearing of personnel
monitoring equipment,
protective
clothing,
and respiratory equipment.
7.
Other Areas
Susan Clark,
Chairman of the Florida Public Service
Commission visited
the plant
on September
22.
She
was provided
an overview and tour of both
units.
The SRI attended
a working lunch, question
and
answer session,
with the Chairman
and her staff assistant,
Mr,
W. Berg,
and the licensee.
8.
Exit Interview
The inspection
scope
and findings were
summarized
on November
1,
1995,
with those
persons
indicated in paragraph
1 above.
The inspector
described
the areas
inspected
and discussed
in detail the inspection
results listed below.
The licensee
questioned
violations 389/95-18-02,
"Failure to Follow Clearance
Procedures,"
and 389/95-18-03,
"Failure to
adequately
Design
and Test
Emergency Diesel
Generator
2A/B Engineered
Safety Feature
Control Logic."
They stated that since the first item was
identified and corrected
by the licensee it should
be
a non-cited
violation.
The inspector
acknowledged
that the item could have
been
non-
cited but since this item was
one of the
many examples of procedural
noncompliance
identified in the past several
months,
the licensee's
corrective actions for these
previous violations should
have reinforced
the need for procedural
compliance
and prevented this violation.
35
The second
item involved the inadequate
design of EDG
2 A/B ESF control
logic, the licensee
stated that this item was the result of an error in
the initial design which had
been detected
by a recently
improved
integrated
safeguards
test procedure.
Therefore,
they felt that this
item'hould also
be non-cited.
The inspector
noted that even
though it
was
an old design
issue,
the licensee,
in the past
18 months
had done
extensive
research
into these
design features
while upgrading the
test procedure
in response
to two violations in this area.
Since this
afforded the licensee
ample opportunity to identify this error, the
NRC
did not exercise discretion
on this item.
Proprietary material is not
contained
in this report.
~T
e
Item Number
Status
50-335/95-18-01
Open
50-335/95-18-02
Open
50-389/95-18-03
Open
Descri tion
"Failure to Follow Procedures
and
Maintain Current
and Valid Log
Entries in the
Rack Key Log and
Valve Switch Deviation Log,"
paragraph
3.a,
"Failure to follow clearance
procedures,"
paragraph
3.c.
"Failure to Adequately Design
and
Test the
Emergency
Diesel
Generator'
A/B Engineered
Safety
Feature
Control Logic," paragraph
4.b.
50-389/95-18-04
Closed
50-335/95-18-05
Closed
50-389/95-18-06
Closed
50-389/95-05-03
Closed
" Inadequate Verification of ICI
Wiring Connections After
Reassembly,"
paragraph
4.a.
"Hissed Surveillance
on
Position Indication," paragraph
4.b.
"Hissed
surveillance during Mode 6,"
paragraph
4.b.
" Incore Instrument Wiring
Errors," paragraph
4.a
~
9.
Abbreviations,
and Initialisms
ACC
ADM
Auxiliary Building
Heating Ventilation and Air Conditioning
Administrative Procedure
Analysis
and Evaluation of Operational
Data, Office for (NRC)
Actuation System
V
36
ANPO
ANPS
ATTN
CFR
CIAS
CR
CWD
dpm
F
FR
FRG
gpm
HUR
HVA
HVE
ICI
ICW
IR
J/LL
JPN
KW
Auxi1 iary Feedwater
(system)
Auxiliary Nuclear Plant [unlicensed]
Operat
Assistant
Nuclear Plant Supervisor
Administrative Procedure
Attention
Cubic Centimeter
Component
Cooling Water
Control
Element Assembly
Control
Element Drive Mechanism
Cubic Feet per Minute
Code of Federal
Regulations
Containment Isolation Actuation Signal
Control
Room
Containment
Spray Actuation System
Circulating Water
Control Wiring Diagram
Circulating Water
Pump
Design Basis Accident
Diesel
Generator
Disintegration
Per Minute
Demonstration
Power Reactor
(A type of oper
Emergency
Core Cooling System
Emergency
Diesel
Generator
Executive Director for Operations,
Office o
Emergency
Response
Data Acquisition Display
Engineered
Safety Feature
Engineered
Safety Feature Actuation System
Fahrenheit
Flow Control Valve
Fuel Oil
The Florida Power
& Light Company
Federal
Regulation
Facility Review Group
Final Safety Analysis Report
Gallon(s)
Per Minute (flow rate)
Hydraulic Control Valve
High-Efficiency Particulate Air
Health Physics
High Pressure
Safety Injection (system)
Heatup
Rate
Heating Ventilation and Air Conditioning
Heating Ventilation and Air Conditioning
Heating
and Ventilating Exhaust
(fan, syste
In Accordance
With
Incore Instrument
Intake Cooling Water
[NRC] Inspection
Report
Jumper/Lifted
(Juno
Beach)
Nuclear Engineering
KiloWatt(s)
or
ating license)
f the
(NRC)
System
m, etc.)
LCO,
HSIS
MWe
No.
NOT
NPF
NPWO
NRC
NWE
ONOP
OP
PCH
PGM
PHT
psi
psia
PSL
PWO
gA
gC
gSL
RCB
RCO
Rev
RI I
RH
37
TS Limiting Condition for Operation
Low Pressure
Safety Injection (system)
Hain Feed
Water
Hain Steam Isolation Signal
Motorized Valve
Reactive
Load
Megawatt(s),
Electrical
[Energy from the Electrical Generator]
NonCited Violation (of NRC requirements)
Number
Normal Operating
Pressure
Normal Operating
Temperature
Nuclear Production Facility (a type of operating license)
Nuclear Plant Supervisor
Nuclear Plant Work Order
Nuclear Regulatory
Commission
NRC Office of Nuclear Reactor Regulation
Nuclear Watch Engineer
Overload
Off Normal Operating
Procedure,
Out Of Service
Operating
Procedure
Operations
Operator
Work Around
PerCent Milli (0.00001)
Procedure
Change
Request
NRC Public Document
Room
Plant General
Manager
Post Maintenance
Test
Power Operated Relief Valve
Pounds
Per Square
Inch
Pounds
per square
inch (absolute)
Plant St.
Lucie
Physical Security Plan
Plant Work Order
Primary Water Stress
Corrosion Cracking
guality Assurance
guality Control
guality Instruction
guality Surveillance Letter
Recirculation Actuation Signal
Reactor
Containment Building
Reactor Control Operator
Pump
System
Revision
Refueling Outage
Region II - Atlanta, Georgia
(NRC)
Radiation Monitor
Reactor
Pressure
Vessel
Reactor Turbine Generator
Board
Refueling Water Tank
SNPO
St.
TCN
TS
UGS
VAR
WG
38
Shut
Down Cooling
Steam Generator
Blowdown System
Safety Injection Actuation System
Safety Injection Tank
Short Notice Outage
Senior Nuclear Plant [unlicensed]
Senior Resident
Inspector
Senior Reactor [licensed] Operator
Standard
Review Plan
Saint
St.
Lucie Action Request
Temporary
Change
Temporary
Change Notice
Technical Specification(s)
Upper Guide Structure
[NRC] Unresolved
Item
Reactive
Load
Violation (of NRC requirements)
Water
Operator