ML17312B021
| ML17312B021 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/25/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17312B019 | List: |
| References | |
| 50-528-96-13, 50-529-96-13, 50-530-96-13, NUDOCS 9611010230 | |
| Download: ML17312B021 (46) | |
See also: IR 05000528/1996013
Text
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-528
50-529
50-530
NPF-51
50-528/96-1 3
50-529/96-1 3
50-530/96-1 3
Arizona Public Service Company
Palo Verde Nuclear Generating Station, Units 1, 2, and 3
5951 S. Wintersburg Road
Tonopah, Arizona
August 25 through October 5, 1996
'. Johnston,
Senior Resident Inspector
J. Kramer, Resident Inspector
D. Garcia, Resident Inspector
D. Carter, Resident Inspector
V. Gaddy, Resident Inspector, Fort Calhoun
Dennis F. Kirsch, Chief, Reactor Projects Branch F
ATTACHMENTS:
Attachment 1:
Partial List of Persons Contacted
List of Inspection Procedures
Used
List of Items Opened,
Closed, and Discussed
List of Acronyms
96iiOi0230 96i025
ADCICK 05000528
8
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h
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EXECUTfVE SUMMARY
Palo Verde Nuclear Generating Station, Units 1, 2, and 3
NRC inspection Report 50-528/96-13; 50-529/96-13; 50-530/96-13
~Oerarinne
Although operator performance, shift supervision command and control, and overall
communications
were not effective in preventing an SG overfill event, the licensee's
initial corrective actions were prompt, cautious, and thorough,
and the subsequent
investigation was self-critical and demonstrated
the licensee's commitment to
operations
excellence
(Section 01.1).
~
Operators displayed
a high degree of professionalism
and demonstrated
the
implementation of effective corrective actions when performing the high rate steam
generator blowdowns (Section 01.2).
~
An example of weak attention to detail was identified by the inspectors regarding
the degraded
Class
1E Motor Control Center panel doors (Section 02.2).
~
The licensee did not implement fully effective corrective actions following a May,
1996, event involving the control of ventilation boundary doors, when they
recognized weaknesses
in worker understanding
of door control procedures
and in
the labeling of doors.
Three similar events subsequently
occurred which could have
been prevented
had corrective actions been implemented.
Following the third
event, the licensee implemented more comprehensive
interim corrective actions and
planned longer term corrective actions to prevent recurrence
(Section 02.3).
Maintenance
~
The licensee responded
effectively to problems experienced
while lifting the Unit
1
upper guide structure (UGS) by stopping the evolution, involving plant management,
and developing
an appropriate
plan (Section M1.3).
~
Management's
expectations
and procedural requirements for performing procedure
steps out-of-sequence
were not clearly understood
by certain maintenance
personnel
performing a surveillance (Section M4.1).
~En ineerin
~
Civil and system engineering organizations demonstrated
poor communications
on
the status of unsealed ventilation boundary penetrations.
Additionally, although
civil engineering
had made progress
in the resolution of penetration design
deficiencies, they had not ensured that the interim condition had been adequately
reviewed for system impact (Section E2.1).
li
h
-3-
Engineering's
recently established testing of the auxiliary building essential
ventilation design basis requirement to develop
a measurable
negative pressure
in
emergency mode was seen as improvement to the testing program, although the
acceptance
criteria and the initial conditions for the test had not been welf
established
to assure that the test results were both accurate and could provide
meaningful trend information (Section E3.1).
Radiological protection (RP) personnel demonstrated
weak health physics practices
when entering infrequently accessed
areas that have not recently been surveyed
and in the fabrication of an inadequate
drip catch.
However, RP management
responded
appropriately to the inspectors'oncerns
(Section R1.1).
In an effort to improve on material condition and housekeeping
issues, the licensee
initiated a housekeeping
improvement and area ownership program.
However, the
inspectors continued to identify material condition and housekeeping
issues which
had not been previously identified by the licensee (Section R2.1).
1
I
i
Re ort Details
Summar
of Plant Status
Unit
1 began this inspection period at essentially 100 percent power.
On September
3, the
unit began an end-of-core life power coastdown.
On September 21, the unit began
Refueling Outage
1R6 and at the end of the inspection period was defueled.
Units 2 and 3 operated at essentially 100 percent power for the duration of the inspection
period.
I. 0 erations
01
Conduct of Operations
01.1
S ill While Fillin
Unit
1
a.
Ins ection Sco
e 71707
On September
22, while in Mode 5, operators overfilled a Unit 1 steam generator
and spilled approximately 4000 gallons of uncontaminated
condensate
water
through an open atmospheric dump valve to the main steam support structure.
They had been in the process of implementing
a procedure to cool the steam
generator metal mass to facilitate outage work. The inspectors reviewed the
licensee's
response
to the event.
b.
Observations
and Findin s
The licensee investigated the cause of the spill and identified several weaknesses
in
engineering performance.
The temporary level instrument used to measure the
SG level was not connected
at a location which supported
the intended use.
The
level instrument was connected to the top of the SG, which was not vented, so the
instrument provided an incorrect level reading once the line to the vented
atmospheric dump valve was covered with water.
In addition, the licensee
considered that the temporary installation did not receive an adequate
independent
design review and could have been improved by an additional diverse level
monitoring method.
The licensee also identified several weaknesses
with operations performance.
Crew
supervision did not maintain command and control of the evolution.
The shift
supervisor and control room supervisor allowed mechanical engineering
to lead the
evolution and did not direct or concur with all manipulations.
Verbal
communications
were weak, in that the reactor operator failed to notify supervision
of difficulty in raising the SG level.
The licensee performed the following actions as a result of the spill:
~
Place the evolution on hold.
Contacted
appropriate levels of management
and the inspectors.
!
)
)
jl
-2-
Initiated investigations to review the impact of the spill on main steam piping
and supports
and, subsequently,
determined that no impact had occurred.
~
Initiated investigations to determine the cause of the event from both
instrumentation
and human performance perspectives.
Before restarting the evolution, the licensee improved the level instrumentation to
include a tygon tube tor an alternate level indication, revised the procedure to
provide additional guidance for the operators,
and conducted
a detailed prejob
briefing.
The revised procedure was implemented without further incident
approximately
1 day after the spill.
c.
Conclusions
Although operator performance, shift supervision command and control, and overall
communications were not effective in preventing the SG overfill event, the
licensee's
initial corrective actions were prompt, cautious, and thorough, and the
subsequent
investigation was self-critical and demonstrated
the licensee's
commitment to operations excellence.
01.2
0 cretin
the Steam Generator Blowdown S stem
Unit 3
a.
Ins ection Sco
e 71707
The inspectors observed the control room staff perform high rate steam generator
blowdowns to the main condenser
using Procedure 40OP-9SG03,
"Operating the
Steam Generator Blowdown System."
b.
Observations
and Findin s
On October 2, the inspectors observed the control room staff perform high rate
steam generator blowdowns.
In the past year, operators
have made errors while
performing this routine evolution that have resulted in unplanned
increases
in
reactor power.
The inspectors observed that in this instance the shift supervisor
(SS) ensured that there were no distractions to the operators and he strictly
controlled control room access.
The reactor operator followed the procedure when
performing the board manipulations
and the control room supervisor displayed
positive command and control of the activity. Operator communication included
verbatim repeatbacks,
and procedural performance
included independent
verification.
e
-3-
02
Operational Status of Facilities and Equipment
02.1
De raded Batter
Powered Emer enc
Li htin
Unit 3
a.
Ins ection Sco
e 71707
The inspectors performed
a routine tour of the Train A emergency diesel generator
and verified valve lineups, material condition, and housekeeping.
b.
Observation
and Findin
s
On August 29, the inspectors noted the electrolyte levels in some of the cells of
Emergency Light 3E-ZGL-DSO-05-100-04 were below the minimum level.
The
inspectors informed the Unit 3 SS, who contacted the system engineer.
The
system engineer verified the levels and requested
electrical maintenance
to adjust
the levels.
The inspectors reviewed the design requirements of the emergency
lights in the
Updated Final Safety Analysis Report (UFSAR).
Section 9.5.3.2.2.3 stated that the
emergency lights should be capable of providing a minimum of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
illumination. The lights in question were nonquality related and were designed to
provide emergency lighting to support personnel
egress upon the loss of power.
The inspectors discussed
whether the emergency lights would have met design
requirements with the system engineer.
The system engineer indicated that the
emergency lights were equipped with cells which had an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> illumination rating
and concluded that the lights would have met the design requirements
even with
the low electrolight level observed.
The licensee inspected other emergency lights in all three units and identified
another light that had low electrolyte levels.
The system engineer subsequently
determined that the preventive maintenance
task frequency for this type battery
would be increased from once every six months to once every quarter.
c.
Conclusions
Operations
and engineering
personnel
responded
appropriately to the inspectors
identified battery electrolyte level discrepancy.
02.2
Motor Control Center
MCC Doors Found 0 en
Unit
1
a.
Ins ection Sco
e 71707
The inspectors toured the Unit 1 electrical penetration rooms and held discussions
with operations personnel.
-4-
b.
Observations
and Findin s
On September
14, the inspectors identified two Panel Doors, PHA-M3325 and
PHA-M3514, on the Class
1E 480 volt MCCs that were open and other panel doors
that were improperly secured.
The MCCs were located on the 120 foot elevation
west electrical penetration room and the 100 foot elevation east electrical
penetration room.
The inspectors notified the control room and an auxiliary operator (AO) responded
to the area.
The AO identified that the door handle to PHA-M3514 was broken, the
door latch to PHA-M3325 was bowed preventing the door from closing.
The AO
initiated Work Request 915103 to have the doors repaired.
The inspectors discussed
the discrepancies
with the site shift manager
(SSM).
The
SSM indicated that a previous work request was generated
to correct discrepancies
with MCC PHM34.
The inspectors informed the SSM that the doors identified on
September
14, were from MCCs PHM35, PHM33, and PHM37.
The SSM
determined that a walkdown of all safety-related
MCCs for each unit would be
performed.
The inspectors questioned
the SSM about the safety impact of having the doors
open and the requirements for the doors to be shut.
The SSM discussed
the
discrepancies
with equipment qualification, fire protection, and system engineering
personnel,
and determined that the opened doors did not have
a safety impact, nor
were there any requirements for the doors to be shut.
The SSM indicated that
management's
expectations
were that licensee personnel
ensure that the doors
remain properly secured.
The inspectors
inquired whether
a Condition Report/Disposition
Request
(CRDR) had
been initiated for the identified door discrepancies.
The SSM indicated that a CRDR
had not been written and subsequently
generated
a CRDR for followup
documentation.
c.
Conclusions
The MCC panel door discrepancies
demonstrated
a weak attention to detail by both
operations
and maintenance
personnel.
02.3
Closed
Licensee Event Re ort
LER 50-528 96003
a.
Ins ection Sco
e
92901
Between May and August 1996, both the licensee and NRC identified instances
where barriers doors to essential ventilation system boundaries
were open.
These
instances
impacted the ability of ventilation systems to perform during a design
basis event.
One of the events was the subject of LER 50-528/96003.
The
J
-5-
inspectors reviewed these events, the licensee's safety and cause analyses,
and
their proposed corrective actions.
b.
Observations
and Findin
s
S stem Descri tion
The auxiliary building essential ventilation system (licensee system designation
EHA)
was designed to maintain the area containing the essential safety features pumps at
a measurable
negative pressure following a loss of coolant accident to prevent the
unfiltered release of possible airborne radioactivity to the surroundings.
The EHA
envelope includes the volume of the auxiliary building below the plant
100'levation
(essentially ground level).
The EHA boundary includes the auxiliary
feedwater (AFW) vaults, since they are connected
through ventilation ducting.
Additionally, the lower level shares boundaries with the fuel handling building and
the outside yard.
During a safety injection actuation signal (SIAS), the EHA is isolated from the
normal auxiliary building ventilation supply and exhaust.
The lower levels are then
aligned to the fuel handling building essential ventilation exhaust filter train.
The
design basis for EHA is discussed
in UFSAR Section 9.4.2.2.
Technical Specification (TS) 3.7.8 requires that two independent
trains of EHA be
Although the TS did not require testing for a negative pressure,
a
measurement
of system flow was required.
The licensee had established
a test for
negative pressure
in this lineup in 1995 and had completed testing in all units in
August 1996.
On October 4, 1996, the licensee submitted improved TS, which
included testing for a measurable
negative pressure.
Control of Barriers
As discussed
in Inspection Report 50-528, 529, 530/96-07, on May 7, 1996, the
inspector, observing
a leak rate test of a containment purge isolation valve in
Unit 3, noted that technicians had propped open two doors to run a service air
hose.
The inspector determined that the technicians involved in the leak rate test
had not contacted either the control room or the fire department
as required by
instructions printed on the doors and described
in Procedure 40AC-9OP17, "Control
of Security, Fire, and Heating, Ventilation, and Air Conditioning Barrier Doors."
The
inspector identified this as a noncited violation with minor significance.
The licensee determined,
during their evaluation, that the labeling on the doors had
contributed to the technician's confusion.
Dooi number labels were at the top of
doors and room number labels were at the center of the doors.
Both door and room
numbers were typically a letter and three digits with the letter and first digit
referencing the building and elevation of the door.
As a result, the first portion of
most room and door numbers were identical.
Procedure 40AC-9OP17 used the
4
I
-6-
door number as its reference.
Procedure 40AC-9OP17 was subsequently
revised
and renumbered
as Procedure 40DP-9ZZ17 on June 4.
Subsequent
to this event, the licensee identified the following similar events:
~
On June 6, the Unit 3 SS discovered
a door between the auxiliary building
and the fuel handling building had been propped open by carpenters
erecting
The carpenters
had called the fire department
as a sign on the
door required, but had not called the control room as required by Procedure
As corrective action, the carpenters
were provided with
training on the door procedure
and the signs on the doors were modified.
The licensee concluded that the fuel handling building essential ventilation
system had been inoperable for the 45 minutes the door was opened.
However, since there were no operations underway involving the spent fuel
pool, the licensee met TS limiting conditions for operations
~
On June 26, a painter in the access stairwell to the Unit
1 AFW vaults noted
that both water tight doors to the area were open.
The doors had been
opened by a valve service technician who was working on a valve in the
Train B AFW pump room.
The licensee determined that the technician had
not followed Procedure 40DP-9ZZ17.
However, they determined that the
open doors would not have prevented
establishing
a negative pressure
in the
EHA following a SIAS.
As corrective action, the licensee put labels on the AFW vault doors stating
the requirement to keep the doors closed.
~
On August 2, contract maintenance
technicians propped open an EHA
boundary door after they had used the room number, instead of the door
number, when asking the control room for authorization.
The door was open
for approximately 75 minutes when discovered
and questioned
by an AO.
Subsequently,
engineers
calculated that it would not have been possible to
maintain the EHA at a measurable
negative pressure.
The licensee
concluded that both trains of EHA were inoperable for the 75 minutes the
door was open.
On September 4, the licensee submitted
LER 50-528/96003, reporting this as a condition which could have prevented
the fulfillment of a safety function.
These three events resulted from a combination of workers not familiar with the
door control procedure
and workers confusing the room number labels for the door
number.
The events on June 6, June 26, and August 2 were three examples of
failure to follow procedures
{Violation 528; 530/9613-01).
Although each of the events was identified by the licensee, the inspectors
determined that they could have been prevented
had the licensee implemented
interim corrective actions in a timely manner.
Instead, the immediate corrective
-7-
actions for the May 7 event and the subsequent
events in June were limited to the
crews and doors involved and long term corrective actions, although more
comprehensive,
had not been implemented.
While the causes of the August 2
event were very similar to the causes of the previous three events, the event was
significant in that it resulted in both trains of a safety system being inoperable.
The
licensee did implement more comprehensive
interim corrective actions after the
August 2 event by taking actions to increase worker awareness
of the door control
procedure requirements
and by improving door labeling.
The inspectors noted that
the interim actions, while more comprehensive,
were simple in approach
and
execution and considered that there was sufficient basis to have expected these
actions to have been taken prior to the August 2 event.
C.
Conclusion
The licensee did not implement fully effective corrective actions following a May,
1996, event involving the control of ventilation boundary doors, when they
recognized weaknesses
in worker understanding
of door control procedures
and in
the labeling of doors.
Three similar events subsequently
occurred which could have
been prevented
had corrective actions been implemented.
Following the third
event, the licensee implemented more comprehensive
interim corrective actions and
planned longer term corrective actions to prevent recurrence.
II. Maintenance
M1
Conduct of Maintenance
M1.1
General Comments on Maintenance Activities
a.
Ins ection Sco
e 62707
The inspectors observed
all or portions of the following work activities:
32MT-9ZZ56 Motor Operated Valve Testing on Low Pressure
Safety
Injection Heat Exchanger
Bypass Valve SIA-HV-306 (Unit 1)
33MT-9ZZ02 Freeze Seal Installation for Low Pressure
Safety Injection
Minimum Flow Recirculation Valve SIA-UV-669 Work (Unit 1)
b.
Observations
and Findin
s
The inspectors found these work activities were performed acceptably
and in
accordance
with procedures.
-8-
M1.2
General Comments on Surveillance Activities
a.
Ins ection Sco
e 61726
The inspectors observed
all or portions of the following surveillance activities:
~
Economizer Feedwater Isolation Valves - Inservice Test (Unit 3)
~
73ST-9ZZ18 Main Steam Safety Valve Online Set Pressure
Verification
(Unit 1)
b.
Observations
and Findin s
The inspectors found these surveillances were performed acceptably
and as
specified by applicable procedures.
In addition, see the specific discussion of
surveillance observed
in Section M4.1.
M1.3
Removal of the UGS Unit
1
a.
Ins ection Sco
e
627~07
On September
26, 1996, while in the process of lifting the Unit
1 UGS prior to
defueling operation, one of two guide bushings
became stuck on its guide pin and
the arm holding the guide bushing was damaged.
The inspectors attended
a
management
review and prejob brief and observed the subsequent
liftoperation.
b.
Observations
and Findin s
About midnight on September
26, as maintenance
personnel were in the process of
conducting the UGS lift operation, they heard
a loud noise.
Upon further inspection,
they determined that one of the guide bushings
had become stuck and, as the UGS
was lifted, the arm that holds the bushing was deformed.
Maintenance
personnel
lowered the UGS back into place and informed outage management.
The licensee convened
a management
review team at 6 a.m. to review the
condition of the UGS and discuss plans for its subsequent
removal.
The inspectors
noted that the management
review was thorough, covering several possible
scenarios.
Ultimately, they concluded that a second lift attempt be made, provided
that maintenance
personnel
add precautions to their work instructions and cameras
to monitor the UGS removal.
The inspectors observed the prejob briefing and found that the appropriate
personnel were in attendance
and the work scope was adequately
covered.
The
inspectors subsequently
observed the liftoperation from the refueling bridge.
The
licensee proceeded
with caution and the lift attempt was successful.
-9-
At the end of the inspection period, the licensee had not yet determined what had
caused the guide bushing to become stuck on the guide pin.
The licensee has
experienced difficulty in the past with the guide bushings and, in an earlier Unit 2
outage, the guide bushing had detached
from the UGS.
The licensee did identify
that within 3 feet of the final position, there was little clearance between the guide
bushing and the guide pin which appeared
to contribute to interference.
The
licensee initiated a CRDR to evaluate this recurring problem and to develop repairs
to the Unit
1 UGS.
c.
Conclusions
The licensee responded
effectively to problems experienced
while lifting the Unit
1
UGS by stopping the evolution, involving plant management,
and developing
an
appropriate
plan.
The root cause of the problem is being evaluated
according to the
CRDR process.
Ni4
IVIaintenance Staff Knowledge and Performance
M4.1
Class
1E Station Batter
Channel A Dischar
e Test
Unit
1
a.
Ins ection Sco
e 61726
The inspectors observed the performance of Procedure 32ST-9PK03, "18 Month
Surveillance Test of Station Batteries," Revision 10.
b.
Observations
and Findin s
On September
23, the inspectors observed
electrical maintenance
technicians
perform a surveillance test on the Class
1E Station Battery Channel A. During this
observation,
the technicians,
in the process of performing Step 8.3.2.2, lifted the
leads on the spare battery bank, prior to performing preceding Step 8.3.2.1 to open
the output circuit breaker on the battery charger.
The inspectors questioned
the test director about performing the step out of
sequence.
The test director indicated that the procedure allowed performance of
steps out of sequence.
The inspectors reviewed the procedure
and did not find any
such allowances.
This discrepancy was discussed
with the test director, who noted
that the conduct of maintenance
procedure
allowed the performance of steps out of
sequence.
The test director subsequently
stopped work, prior to the technicians performing
Step 8.3.2.2, and contacted
an electrical maintenance
supervisor to resolve the
issue of performing the procedure out of sequence.
The electrical maintenance
supervisor directed the test director to perform the procedure
as written.
t
-10-
The inspectors subsequently
determined that Procedure 01DP-OAP01, "Procedure
Process," Section 7.8, "performance of activities out of sequence,"
provided
applicable requirements.
The procedure allows the performance of steps out of
sequence,
if plant safety is not compromised,
the performance does not cause an
intent change to the procedure,
the change
is properly documented,
the work leader
has authorized it, and the SS is notified.
The inspectors noted that while the test director did not clearly understand
the
requirements
for performing the procedure out of sequence,
he took appropriate
actions by stopping work, notifying supervision,
and obtaining clarification.
The inspectors discussed
the issue with the electrical maintenance
department
leader.
The department
leader indicated that it was management's
expectation to
perform the procedures
as written. However, he was unclear as to the specific
requirement for performing steps out of sequence
and where they were located.
The department
leader noted that, in this instance, performing the steps out of
sequence
would not have affected the intent of the surveillance test.
The department
leader concluded that the requirements for performing steps out of
sequence
were not well understood
by maintenance
department
personnel
and
planned to provide training on the procedural requirements.
C.
Conclusion
Management's
expectations
and procedural requirements for performing procedure
steps out of sequence
were not clearly understood
by certain maintenance
personnel performing the surveillance.
III. En ineerin
E2
Engineering Support of Facilities and Equipment
E2.1
0 en
Ins ection Followu
Item 50-528 96012-01
Ins ection Sco
e
This item involved the control of EHA boundary penetrations.
On July 7, the
inspectors found an unsealed
penetration through the 100'HA boundary.
The
had been opened to allow cable routing for an ongoing radio
communications
modification.
The licensee initiated an investigation and
determined that they had not established
appropriate controls of the EHA boundary
The inspectors reviewed the licensee's
response
to this issue and
performed EHA boundary walkdowns.
\\'
-11-
b.
Observations
and Findin s
The licensee initiated CRDR 9-6-0691 to address
this issue.
As immediate action,
on July 8, system and maintenance
engineers
performed walkdowns of the auxiliary
buildings in all three units and identified a number of penetration deficiencies.
Engineers performed analyses of the as-found condition in all units and determined
that the additional area would not have had a significant impact on the ability of the
EHA to maintain a negative pressure following a SIAS. An EHA system description
is provided in Section 02.3 of this report.
The inspectors performed
a subsequent
walkdown and found eight additional
unsealed
in Units
1 and 2. These penetrations
were for piping running
from the south yard to the essential pipe tunnel area,
a tunnel within the boundary
of the EHA which is under the yard and runs between the refueling water tank and
the auxiliary building.
These penetrations
appeared
to be of more significance since
they were located relatively near the tunnel which connects the EHA to the fuel
handling building essential ventilation trains.
The inspectors determined that these unsealed
had not been identified
during the July walkdowns and the maintenance
and system engineers
were not
aware of this condition.
However, civil engineering
had work requests,
initiated in
1995, to repair these and 22 other EHA boundary penetrations.
The inspectors
reviewed the history of these penetrations
with the licensee and was informed of
the following:
In 1991, the licensee established
seal project to identify all
building penetrations,
establish the functions of each, and identify
deficiencies.
Eight thousand
discrepancies
were identitied in fire function barriers.
These
barriers were given first priority for repair and were all dispositioned
by late
1 994.
Approximately 2000 discrepancies
were identified in barriers with flood, high
energy line break (HELB), and ventilation functions.
The licensee had
established
that all these penetrations
be classified as "not quality related."
As a result, they did not place a high priority on the resolution of these
deficiencies.
An evaluation, documented
in Calculation 13-NS-A73, determined that there
was no safety significance to the unsealed
barriers with flood and HELB
functions.
The licensee was not able to identify where they had performed
similar reviews for the barriers with ventilation functions.
II;
E
I
I
I
1
4
-12-
~
By 1995, civil engineering
had dispositioned
all but 170 of these
as "use-as-is."
Work requests
were initiated for the remaining
170 penetrations.
~
At the time of the inspection, the licensee was in the process of evaluating
600 penetrations
which served as radiation accident mitigation.
They had
not repaired any of the 170 penetrations
with open work requests.
In response
to the inspectors'uestions,
the licensee determined that the additional
unsealed
to the EHA boundary did not impact the operability of the
EHA. They based this determination on the successful tests which had been
performed in each unit during the past year (See Section E3.1).
The inspectors determined that, for both the penetrations
identified in July 1996,
and the penetrations
identified during the September
1996 walkdown, the
were not in conformance with design drawings.
In each case, the
licensee had established
work requests to bring these penetrations
into
conformance with the design drawings.
However, in both cases
the licensee had
not performed an evaluation of the impact on the EHA until questioned
by the
inspectors.
Additionally, the deficiencies identified during the September
1996,
walkdown had been known to the licensee since 1992.
The licensee had established
that all the penetrations with flood, HELB, and
ventilation boundary functions were not quality-related.
This determination
appeared to be inconsistent with the licensing basis and the quality assurance
program documented
in UFSAR Section 17.2.
The licensee has established that
design basis flood and HELB mitigation are safety-related functions.
Additionally,
EHA has been identified as a safety-related
system with the primary function of
preventing unfiltered release paths.
At the end of the inspection, the licensee
stated that they would review the classification of these penetrations.
This item
remains open pending the conclusion of this review and the licensee's development
of a resolution for the penetrations.
c.
Conclusions
Civil and system engineering organizations
demonstrated
poor communications
on
the status of unsealed ventilation boundary penetrations.
Additionally, although
civil engineering
had made progress
in the resolution of penetration design
deficiencies, they had not ensured that the interim condition had been adequately
reviewed for system impact.
E2.2
S ill While Fillin
a SG
Unit
1
92903
The inspector reviewed the licensee's investigation in response
to overfilling the SG.
The engineering activities preceding the SG cooldown were not effective in
H'
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designing
an accurate
SG level monitoring system.
Further aspects of this event are
discussed
in Section 01.1.
E3
Engineering Procedures
and Documentation
E3.1
EHA Surveillance Testin
a.
lns ection Sco
e 37551
The inspectors reviewed Surveillance Procedure
33ST-9HF01 for the testing of each
train of EHA in the SIAS mode and discussed
the results of the test with the
maintenance
and system engineer.
b.
Observations
and Findin
s
Procedure
had been revised in 1995 to add testing to verify that a
measurable
negative pressure
between the EHA and outside atmosphere
was
established
consistent with UFSAR requirements.
Prior to this revision, the licensee
had not performed
a similar test since system startup testing.
Testing had been
completed in all units and had determined that each train could maintain a
measurable
negative pressure.
A brief description of the system's design basis is
provided in Section 02.3.
The inspectors reviewed the test results and noted considerable
variations in the
differential pressures
achieved from train to train and from test to test.
For
example:
~
The differential pressure
achieved on August 14, 1996, for Unit 1 Train A
was -0.045" water gage {w.g.). The following week, the differential
pressure
for Train B was -0.134" w.g.
~
For Unit 2 Train A, testing in June 1995, established
a differential pressure
of -0.410 w.g. Testing of the same train in August 1996, established
a
differential pressure
of -0.070" w.g.
Maintenance
and system engineers
could not explain why there was such
a
variation in the test results.
The inspectors reviewed the test procedure
and found
that it did not establish sufficient prerequisites to control of the EHA envelope
during the test, thus establishing uniform conditions to assure test repeatability, by
ensuring that doors remained closed.
Additionally, the test did not establish control
of the ventilation configuration in other buildings.
The inspectors noted that either
of these factors could contribute to the variation of test results.
Licensee
engineering
stated that they planned to address
these issues
in future procedure
revisions.
(
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Additionally, the surveillance established
the test acceptance
criteria to be
measurab(e
negative pressure,
but did not provide a numerical limit. The inspectors
subsequently
found that a numerical acceptance
criteria for a measurable
negative
pressure of -0.01 inch w.g. had been established
in a 1987 UFSAR change
evaluation.
However, this minimum criteria had not been translated into either the
surveillance test or other design basis documents.
The inspectors did note that all
of the current tests met the acceptance
criteria.
The inspectors noted that the test acceptance
criteria was based on the capabilities
of the instrumentation
and did not address
other physical characteristics
such as:
~
air expansion
caused by post loss-of-coolant accident room heating,
potential wind effects on the outside building reference leg of the differential
pressure instrumentation,
and
~
whether the measurement
location was at a point in the building, which
would be expected to be the least negative.
Engineering stated that they would assess
these attributes and determine whether
they had established
the appropriate criteria.
The inspectors noted that while a test
for negative pressure
was not required by the current TS, it was a requirement
in
the proposed
improved TS, submitted by the licensee for NRC review on October 4,
1 996.
c.
Conclusions
Engineering's
recently established
testing of the EHA design basis requirement to
develop
a measurable
negative pressure was seen as improvement to the testing
program, although the acceptance
criteria and the initial conditions for the test had
not been well established
to assure that the test results were both accurate and
could provide meaningful trend information.
Miscellaneous Engineering Issues
E8.1
Closed
LER 50-529 96005:
inadequate
procedure controls allow equipment
qualification boundary to be breached.
On June 12, a hatch through the
100'levation
of the Unit 2 main steam support structure, which leads to the Train B
AFW pump room, was open for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The licensee subsequently
determined that the hatch served
as a barrier to protect the AFW pump room vaults
from the environmental
and flooding impacts of a postulated
HELB. Additionally,
they determined that the hatch served
as an EHA boundary since the AFW vaults
communicate with the auxiliary building through ventilation ducts.
However, these
functions of the hatch were not captured
in the licensee's door control
Procedure 40DP-9ZZ17.
w ~
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The licensee determined that the personnel involved in opening the hatch had
properly reviewed and followed the door control procedure.
Additionally, the
appropriate operations
and ventilation maintenance
engineering personnel had been
involved in the initial assessment
for opening the door.
The licensee found that an
error had been made in a recent revision of the door control procedure.
The failure
to have a procedure
adequate
for the circumstances
is a violation.
The inspectors
reviewed CRDR 2-6-0123, and found the licensee's investigation, safety analysis,
and corrective actions to be appropriate.
This issue is being treated as a noncited
violation consistent with Section Vll of the NRC Enforcement Polic
(50-529/961 3-02).
IV. Plant Su
ort
R1
Radiological Protection and Chemistry Controls
R1.1
RP Controls
a.
Ins ection Sco
e 71750
During the inspection period, the inspectors performed several tours in the
radiological controlled areas including high radiation and locked high radiation areas.
Specifically, the equipment drain tank (EDT) rooms, 88 foot elevation pipe chases,
and mechanical piping penetration rooms were examined.
b.
Observations
and Findin s
On August 29, the inspectors identified that Valve SIBV-832 (High Pressure Safety
Injection Header Drain and Test Valve), located in the Unit 2 east mechanical piping
room, had a yellow shoe cover wrapped around
a leaking pipe cap in
place of a drip catch.
Tape labeled as "Internal Contamination" was used as the
posting information.
In addition, the inspectors observed that a piece of the tape
used to label the covering had fallen off and was stuck to the floor. The inspectors
showed
an RP department
leader the drip catch, and the leader concluded that the
drip catch was unacceptable
and did not meet his expectations.
RP subsequently
replaced the containment with a proper drip catch.
The inspectors determined
these actions were acceptable.
On September
18, the inspectors
and a RP technician toured the Unit 1 EDT room.
Although the EDT room was a locked high radiation area, it was not posted
as a
contaminated
area.
Additionally, the room had last been surveyed approximately 'l4
months prior to the inspectors'ntry
and licensee entries into this room were
infrequent.
The inspectors observed
a valve in the mezzanine
area above the EDT
was labeled "Contaminated Area - bottom of valve and inside packing gland" and
had no containment or enclosure device.
In addition, the inspectors observed
a
vertical pipe with boron leaking from a flange coupling.
After leaving the EDT room,
'I
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-1 6-
the inspectors performed
a personal frisk and identified contamination of
approximately 2000 DPM/100 cm~ on a shoe.
The licensee decontaminated
the
shoe and prepared
a personnel contamination report.
Radiation protection surveyed the EDT room and identified contamination on the
pipe flange and pipe, the posted valve, on the tank below the valve, and on the
floor of the room.
The licensee subsequently
posted the EDT room as a
contaminated
area.
The RP operations manager indicated that it would have been
prudent to survey or to have required protective clothing prior to entering this
infrequently surveyed room.
The licensee issued
a RP night order establishing precautionary contamination
controls when entering any area that has not been accessed
within the fast 90
days.
The licensee also initiated a CRDR to evaluate the event and provide
corrective actions.
The inspectors determined these actions were appropriate.
c.
Conclusions
Radiological protection personnel demonstrated
weak health physics practices when
entering infrequently accessed
areas that have not recently been surveyed
and in
the fabrication of an inadequate
drip catch.
However, RP management
responded
appropriately to inspectors concerns.
R2
Status of RP and Chemistry Facilities and Equipment
R2.1
Material Condition and Housekee
in
a.
Ins ection Sco
e 71707
71750
The inspectors performed routine walkdowns and inspections of the facility and
assessed
plant material condition and housekeeping.
b.
Observations
and Findin
s
On August 29, the inspectors identified an inadequate
containment
on
Valve CHB-HV530 (Refueling Water Tank to Safety Injection Train B Valve).
The
containment
had openings that could allow contamination to leak out.
The drip
hose connection leaked liquid onto the floor below the valve.
The floor drain,
containing the drip hose, had boron build-up above the drain cover, which had
smearable
contamination of 1500 DPM/100 cm'.
The licensee repaired the
containment
and decontaminated
and modified the drain cover.
The inspectors
determined these actions to be acceptable.
On September
17, the inspectors identified a 12 foot length of unattached
grounding cable in the Unit 2, 88-foot pipe chase.
The licensee issued
a work
request to attach the grounding cable.
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On September
18, the inspectors identified the following housekeeping
deficiencies
in the Unit 1, 88-foot pipe chase:
an unusual radiation protection stantion,
a
12 x 12 foot plastic sheet covered with debris, and a bag of old light bulbs.
The
licensee removed all materials from the area.
The inspectors determined this action
to be appropriate.
As noted in Inspection Report 50-528, 529, 530/96-12, the licensee had recently
initiated a housekeeping
improvement program which had established
housekeeping
standards
for 111 plant areas.
Throughout this inspection period, the licensee was
in the process of inspecting these areas and addressing
weaknesses.
At the end of
the inspection period, they had concluded that only 9 areas of the 111 had met
their standards.
Conclusions
The inspectors continued to identify material condition and housekeeping
issues
which have not been previously identified by the licensee.
The licensee was
continuing to implement their housekeeping
improvement program.
V. IVlana ament IVleetin s
X1
Exit Meeting Summary
The inspectors presented
the inspection results to members of licensee management
at the
conclusion of the inspection on October 2, 1996.
The licensee acknowledged
the findings
presented.
The inspectors
asked the licensee whether any material examined during the inspection
should be considered
proprietary.
No proprietary information was identified.
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ATTACHMENT 1
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Flood, Department Leader, System Engineering
C. Foster, Engineer,
Design Engineering
R. Fullmer, Director, Nuclear Assurance
J. Gaffney, Department Leader, Radiation Protection
J. Glover, Engineer, System Engineering
R. Hazelwood, Engineer, Nuclear Regulatory Affairs
W. Ide, Vice President,
Engineering
K. Jones,
Section Leader, Design Engineering
A. Krainik, Department Leader, Nuclear Regulatory Affairs
R. Lucero, Department Leader, Electrical Maintenance
D. Mauldin, Director, Maintenance
G. Overbeck, Vice President,
Nuclear Operations
M. Powell, Department Leader, Nuclear Engineering
F. Riedel, Acting Director, Operations
C. Seaman,
Director, Emergency Services
M. Shea, Director, Radiation Protection
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INSPECTION PROCEDURES USED
IP 37551:
Onsite Engineering
IP 61726:
Surveillance Observations
IP 62707:
Maintenance Observations
IP 71707:
Plant Operations
IP 71750:
Plant Support Activities
IP 9290'I: Followup - Operations
IP 92903:
Followup - Engineering
IP 92904:
Followup - Plant Support
IP 93702:
Prompt Onsite Response
to Events
ITEMS OPENED
CLOSED AND DISCUSSED
~Oened
50-528; 530/9601 3-01
50-529/9601 3-02
failure to follow procedures
for ventilation boundary
door control
inadequate
procedure controls allow equipment
qualification boundary to be breached
Closed
50-528/96003
50-529/96005
50-529/9601 3-02
LER
open auxiliary building door causes
fuel building
essential filtration inoperability
LER
inadequate
procedure controls allow equipment
qualification boundary to be breached
inadequate
procedure
controls allow equipment
qualification boundary to be breached
Discussed
50-528/9601 2-01
50-530/96007-04
IFI
control of ventilation boundary penetrations
failure to follow procedure for blocking open
controlled doors
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LIST OF ACRONYMS USED
CRDR
EDT
EHA
LER
SSM
TS
UGS
W.g.
Auxiliary Operator
condition report/disposition request
equipment drain tank
auxiliary building essential ventilation system
Licensee Event Report
Motor Control Center
Radiological Protection
safety injection actuation signal
Shift Supervisor
Site Shift Manager
Technical Specifications
Updated Final Safety Analysis Report
upper guide structure
water gage
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