ML17313A391

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Insp Repts 50-528/98-03,50-529/98-03 & 50-530/98-03 on 980308-0418.Violations Noted.Major Areas Inspected: Operations,Maint,Engineering & Plant Support
ML17313A391
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/22/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17313A389 List:
References
50-528-98-03, 50-528-98-3, 50-529-98-03, 50-529-98-3, 50-530-98-03, 50-530-98-3, NUDOCS 9806010329
Download: ML17313A391 (46)


See also: IR 05000528/1998003

Text

ENCLOSURE 2

U.S. NUCLEAR REGULATORYCOMMISSION

REGION IV

Docket Nos.:

50-528

50-529

50-530

License Nos.: NPF-41

NPF-'51

NPF-74

Report No.:

50-528/98-03

50-529/98-03

,50-530/98-03

Licensee:

Arizona Public Service Company

Facility:

Palo Verde Nuclear Generating Station, Units 1, 2, and 3

Location:

5951 S. Wintersburg Road

Tonopah, Arizona

March 8 through April 18, 1998

Inspectors:

Jim Moorman, Senior Resident Inspector

Nancy Salgado, Resident Inspector

Dan Carter, Resident Inspector

Frank Brush, Resident Inspector, Callaway

Dave Corporandy, Project Engineer, Branch F

Approved By: Phil H. Harrell, Chief, Projects Branch D

Attachment:

Supplemental Information

'F8060i0329 '&0522

PDR

ADGCK 05000528

G

PDR

ll

0

E

UTIVE SU

MA Y

Palo Verde Nuclear Generating Station, Units 1, 2, and 3

NRC Inspection Report 50-528/98-03; 50-529/98-03; 50-530/98-03

~O~r~ion

~

Operator oversight and direction of the Unit 1 drain down to midloop evolution, and

decisions to take conservative actions during the evolution, were excellent.

Licensee

activities related to midloop operation demonstrated

a strong safety focus (Section 01.1).

~

Inattention to detail by two licensed operators resulted in improper installation of danger

tags.

This was identified as an isolated example, and as a result, a noncited violation

was identified (Section 01.2).

The licensee demonstrated

good communications and a formal safety approach when

performing refueling operations.

Operations exercised good judgment by suspending

core alterations and movement of irradiated fuel in containment while a containment

integrity issue was being resolved (Section 01.3).

Maintenance of the control room essential filtration system was very good as evidenced

'y the material condition of the components (Section 02.'1).

Unit 2 auxiliary feedwater (AFW) system was installed and maintained per the applicable

design and operating requirements for those portions of the system reviewed.

The

material condition of the AFW system was good (Section 02.2).

Unit 3 containment spray (CS) Train A was installed and maintained per the applicable

design and operating requirements for those portions of the system reviewed.

The

material condition of the CS system was good. The CS system unavailability was very

low (Section 02.3).

Routine and outage-related

maintenance activities were generally conducted in a safety

conscious manner by knowledgeable technicians using approved procedures.

Good

work and foreign material control practices were observed (Section M1.1).

Engineering personnel performed boroscope inspections on Unit 1 Emergency Diesel

Generator (EDG) A cylinder liners without obtaining proper authorization.

This is a

violation of Technical Specification (TS) 6.8.1 for the failure to follow procedure

(Section M1.3).

A violation was identified for the failure to provide specific criteria for licensee personnel

to determine the minimum required level in the pool prior to moving spent fuel. This is a

violation of TS 6.8.1 for the failure to provide an adequate procedure (Section M1.4).

1

0

I

-2-

the permanent repair of a leak in the Unit 1 Steam Generator 2 downcomer sampling line was

consistent with the system design requirements (Section M1.5).

Observable material condition of the three units was satisfactory.

Material condition of

the interior of components disassembled

for the Unit 1 outage was good (Section M2.1).

Material condition of the equipment in the Unit 1 containment was good'(Section M2.2).

EncnE.e~er

The licensee's

10 CFR 50.59 screening and evaluation for the modification to add an

inspection port to Unit 1 Steam Generator

1 was thorough and comprehensive

(Section E1.1).

Licensee plans to address operational and equipment problems resulting from the

inability of some components and computer software to correctly interpret some dates

that occur before and after the year 2000 appeared to be comprehensive

(Section E1.2).

The radiological protection program was effectively implemented in those areas reviewed

(Section R1.1).

Re

o

De

il

Summ

ofPlan Sa us

Unit 1 operated at 100 percent power until March 14, 1998, at which time the unit was shut down

for the planned seventh refueling outage.

The unit was in Mode 3 at the end of this inspection

period.

Units 2 and 3 operated at essentially 100 percent power for the duration of this inspection

period.

01

Conduct of Operations

01.1

'doo /R duced lnvento

Ac'v s

Uni

1

a.

I se 'n

e 71707

On March 17, 1998, the licensee drained the reactor coolant system (RCS) to the

midloop condition using Procedure 40OP-9ZZ16, "RCS Drain Operations," Revision 9.

This was done to allow installation of steam generator nozzle dams in preparation for

eddy current testing of the steam generator tubes.

The inspectors reviewed the

licensee's preparations for midloop operations and observed control room operators as

they performed the various evolutions.

b.

Observations and Find'n

The licensee augmented the onshift operating crew with a team dedicated to perform

=

midloop operations.

The midloop team was comprised of a control room supervisor,

reactor operator, and shift technical advisor, who acted as the midloop coordinator.

There was a clearly defined division of the control room activity oversight between the

midloop team and the normal shift crew. The inspectors'observed

that the midloop team

niaintained positive control of the evolution at all times.

The inspectors reviewed Procedure 40OP-9ZZ16, prior to the reduction of RCS inventory

and verified that all the prerequisites were met.

From discussions with the midloop crew

members, the inspectors determined that the midloop crew had received training and

were knowledgeable of the drain down procedure, contingency plans, and the shutdown

risk assessment.

The inspectors verified that the licensee had calculated and was

sensitive to the short amount of time that existed between loss of shutdown cooling and

boiling in the core.

The licensee minimized unnecessary

work while the unit was in a'reduced inventory

condition. To prevent a loss of shutdown cooling or RCS level perturbations, the

licensee stationed a senior reactor operator at the entry of the auxiliary building to screen

work activities going into the field. In addition, the licensee maintained sources of offsite

and onsite power available, and limited access to critical equipment areas.

I

,(

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During the draindown, at approximately the 102-foot, 8-inch level, the midloop crew

identified discrepancies

in level indication among the locally-installed gage glass and the

refueling water level indication system instruments.

The operators stopped the drain

down and initiated efforts to determine the cause of the level discrepancy.

After the

vented side of the gage glass was purged, the refueling water level indication system

was in agreement with the gage glass within the tolerance allowed. The draindown was

recommenced

and completed successfully.,

Unit 1 entered midloop operation when reactor vessel level dropped below the 103-feet,

1-inch level and was in the midloop condition for approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

During that

time, the licensee appropriately implemented and maintained the requirements specified

by Procedure 40OP-9ZZ1 6.

/inclusions

Operator oversight and direction of the Unit 1 draindown to midloop evolution, and

decisions to take conservative actions during the evolution, were excellent.

Licensee

activities related to midloop operation demonstrated

a strong safety focus.,

01.2'e

r

ce Ta s

o e

Ins alled

Uni

1

pe

07

Condition report/disposition request (CRDR) 1-8-0142, dated March 16, 1998,

documented that a clearance acceptor walkdown of danger tagged equipment identified

components that were danger tagged, but not in the position required by the tags.

The

inspectors reviewed the circumstances surrounding this event to determine compliance

with applicable licensee procedures.

b.

se

a'ons and Fi di

s-

On March 16, 1998, tags for Clearances

98-01452, "Replace Solenoid Valve Type

V5H-71990," and 98-01074, "Replace Solenoid Valve Type V5H-71990," were hung and

independently verified by two licensed reactor operators.

Operators issued the

clearances to replace air-operated solenoid valves on Main Steam Isolation

Valves UV-0170 (SG 1, Line 1) and UV-0171 (SG 2, Line 1). As part of the clearance

boundary, electrical disconnects for the air solenoid valves were to be tagged in the OFF

position. The ON and OFF positions were clearly marked, with the ON position at the 12

o'lock position and the OFF position counterclockwise approximately 45 degrees.

At

. the time the operators hung the tags, other disconnect switches on the same panel were

tagged in the OFF position. Procedure 40DP-9OP30, "Clearance Processing," required

the clearance acceptor to perform a physical walkdown of the clearance boundary prior

to conducting work.

lt

-3-

During this walkdown, technicians (the clearance acceptor) observed that two electrical

disconnects on each clearance that were required to be tagged in the OFF position, were

tagged, but were in the ON position. As an immediate corrective action, the operators

involved were coached on the importance of adhering to the clearance procedure.

Investigation by the licensee determined that the root cause was a lack of attention to

detail on the part of the licensed operators.

Procedure 40DP-9OP30 provided the requirements for danger tag placement and

independent verification when a clearance was established.

Aweakness

in attention to

detail by two licensed reactor operators resulted in a violation of this procedure.

This

non-repetitive, licensee-identified, non-willfuland corrected violation is being issued as a

noncited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy

(50-528/9803-01).

ggnnclusi

ns

Inattention to detail by two licensed operators resulted in improper installation of danger

tags.

This was identified as an isolated example, and as a result, a noncited violation of

the clearance procedure was identified.

0 serv t'on of

ore Reloa

'

'

Ins

ion S o e

071

During this inspection period, the inspectors observed the licensee's performance of the

Unit 1 core reload as controlled by Procedure 72IC-9RX03, "Core Reloading,"

Revision 9.

Ob erva ion and Fi

in s

The Unit 1 core reload was appropriately controlled by Procedure 72IC-9RX03. Allfuel

movement was coordinated with the control room and logged in accordance with the

procedure.

Good communications were observed between the refueling senior reactor

operator, fuel pool bridge crane operator, and control room personnel.

On April4, 1998, the licensee experienced difficultyin seating slightly bowed Fuel

Assembly J511 in core Location B07. Procedural controls allowed the generation of a

transfer sequence

revision log to allow rotation of the fuel assembly

90'ounterclockwise

from the north to the west orientation.

The fuel assembly was

successfully seated in this orientation with the support from two other fuel assemblies.

Procedure 78OP-9FX01, "Appendix M - Action Plan for Movement of a Difficult

Assembly," Revision 9, recommended

that, ifdifficultywas encountered

in seating an

assembly,

a box of fuel assemblies was to be built around the difficultposition to provide

guidance for the difficultassembly.

On April 8, the fuel assembly was successfully

reoriented back to the north after the reload was complete.

~I

On April 8, operators suspended

core alterations and movement of irradiated fuel in

containment.

This was done as the result of identification of a cracked 3/8-inch stainless

steel sample line from Steam Generator 2, which indicated a potential containment

integrity issue (see Section M1.6 of this report). Operations allowed core alterations and

movement of irradiated fuel in containment to continue once the containment closure

requirements of Procedure 40ST-9ZZ08, "Containment Building Atmospheric

Penetrations Weekly Surveillance," Revision 1, were completed and verified to be

satisfactory.

~

c.

~Conclusi

The licensee demonstrated

good communications and a formal safety approach when

performing refueling operations.

Operations exercised good judgement by suspending

core alterations and movement of irradiated fuel in containment while a containment

integrity issue was being resolved.

02

Operational Status of Facilities and Equipment

02.1

Ins

cionof he

onro R omEs enial

ilra ion

ste

nis2and3

a.

I s ec ion Sco

e 71707

The inspectors performed an inspection of the control room essential filtration systems

for Units 2 and 3, using the following documents:

Updated Final Safety Analysis Report (UFSAR) Sections 6.4, 9.4, and 9.4.1

~

~ Preliminary Safety Analysis Report, Section 6.4

Technical Specifications, Section 3/4.7.7

Control Building HVAC [Heating Ventilation and AirConditioning] System Design

Manual, Revision 7

Procedure 33ST-9HJ01, "Control Room AirFiltration Unit AirflowCapacity and

Pressurization Test," Revision 2

Procedure 40OP-9HJ01, "Control Building HVAC Operations Procedure,"

Revision 4

Procedure 40ST-9HJ01, "Control Room Essential Filtration System Operability

Test," Revision 2

Procedure 16DP-OEP14, "Satellite Technical Support Center Actions," Revision 3

CRDR 2-6-0016

\\

l

-5-

CRDR 9-6-1415

CRDR 9-7-1961

bserva ions and Fin

i

s

During review of system documentation, the inspectors determined that the UFSAR

defined a limited stay time for personnel in the control room when the essential filtration

system was in the isolation mode.

The stay time was based on the number of people

and the expected carbon dioxide buildup level in the control room envelope.

The

inspectors identified that the licensee had not included this limitation in the appropriate

procedures to ensure control room habitability was maintained.

The licensee initiated a

CRDR to identify the appropriate corrective actions.

This item will be reviewed further to

determine what actions the licensee has taken to correct this issue and will be tracked as

an inspection followup item (50-529/9803-02).

The UFSAR stated that, while in the emergency mode, the essential filtration system was

designed to pressurize the control room to 1/4 inches of water gauge (iwg) pressure with

a makeup air flow of less than or equal to 1000 cfm. TS Section 3/4.7.7, the design

basis manual, and Procedure 33ST-9HJ01 stated that the required pressure was greater

than or equal to 1/8 iwg with makeup air flow less than or equal to 1000 cfm. The

inspectors questioned the licensee concerning the differences in the design and required

pressures

using the same flow rate.

The licensee stated that, in the original Preliminary Safety Analysis Report, dated

February 12, 1979, the required pressure was 1/4 iwg. However, NUREG 800,

Revision 2, issued in July 1981, reduced the required pressure to 1/8 iwg. Both

pressures

assumed

a maximum makeup air flow rate of 1,000 cfm. The makeup flow

rate was based on the ability of the control room charcoal filters to remove radionuclides.

The 1/4 iwg value in the UFSAR was the design capability, whereas, the 1/8 iwg value

referenced

in the TS and elsewhere was the design requirement.

The licensee was

performing an UFSAR review and planned on revising the appropriate sections to clarify

the difference between the two pressures.

The material condition and cleanliness of the systems was very good. The inspectors

observed that: (1) all accessible system components were in the required positions, (2)

power supplies and breakers were correctly aligned, (3) support systems, such as

essential chilled water and instrument air, were operational, and (4) system components

were correctly labeled.

c.

Conclusions

Maintenance of the control room essential filtration system was very good as evidenced

by the material condition of the components.

i

-6-

02.2

Wal down of h AFWS s

m Uni 2

a.

Ins ection Sco

e 71707

The inspectors conducted a walkdown of the Unit 2 AFW system to verify the as-built

configuration corlformed with the UFSAR description and piping and instrumentation

diagrams (P8 ID). The following P&IDs were reviewed:

P8 ID 02-M-AFP-001, "AuxiliaryFeedwater System," Revision 22

P&ID02-M-SGP-002, "Main Steam System," Revision 25

P8 ID 02-M-CTP-001, "Condensate Storage and Transfer System," Revision 16

b.

Observato sa dFindin s

The inspectors compared the UFSAR description of the AFW system to the Design Basis

Manual. The documents were in agreement on system design, function, and operation.

The inspectors walked down portions of the AFW system and verified the as-built

configuration conformed to the P&IDs. All major AFWvalves were in the required

position for full power operations.

A sample of key manual isolation valves in two

adjoining systems, the condensate

storage and transfer and main steam systems, were

verified locked open, as required by plant procedures.

In addition, the inspectors verified

that valve positions and indications for components with indications on both the control

room and remote shutdown panels were consistent with each other. The inspectors

identified no burnt out light bulbs or other material deficiencies on either of the control

panels.

The material condition of the AFW system was good.

c.

conclusions

The Unit 2 AFW system was installed and maintained per the applicable design and

operating requirements for those portions of the system reviewed. The material

condition of the AFW system was good.

02.3

alkdownoftheConta'nmentS

ra

S sem

Unit3

a.

Ins ec ion Sco

e 71707

The inspectors reviewed the Unit 3 CS system to verify the UFSAR description

conformed to the as-built condition, Design Basis Manual, and the individual plant

examination (IPE) assumptions.

The inspectors also verified the licensee had

adequately addressed'motor-operated

valve pressure locking and thermal binding

concerns. The inspectors also reviewed the unavailability of the system.

The following

documents were reviewed:

~

Design Modification Work Order (DMWO) 00768975, "Design to Eliminate

Pressure

Locking Thermal Binding Problems in Sl Valves (Sl-671 8 672)"

-7-

Mechanical System Drawings M-SIP-001, Revision 22; M-SIP-002, Revision 19;

and M-SIP-003, Revision 07, "Piping and Instrumentation Diagram Safety

Injection 8 Shutdown Cooling System"

The inspectors also walked down the CS system and interviewed the system engineer

and control room operators.

bserv

i n

d Findin s

The inspectors compared the UFSAR description of the CS system to the Design Basis

Manual and IPE assumptions.

In general, the documents were in agreement on system

design, function, and operation.

Minordiscrepancies

noted by the inspectors had also

been identified by the licensee as part of the UFSAR review program.

The identified

discrepancies

did not effect system operability. The IPE Human Reliability Analysis

section detailed the human performance issues associated with the CS system.

The

inspectors reviewed emergency operating and annunciator response procedures and

verified these documents adequately addressed

the IPE human response

issues.

The inspectors reviewed DMWO 00768975, which was generated to address the

concerns of NRC Generic Letter 95-07, "Pressure Locking and Thermal Binding of

Safety-Related Power Operated Gate Valves." The licensee performed an analysis and

concluded that CS Header Isolation Valves SIBUV-0671 and SIAUV-0672 were

potentially susceptible to Generic Letter 95-07 concerns.

Corrective actions were

initiated by the licensee to eliminate this susceptibility. The DMWO, which increased the

capacity of the valve motor operator to overcome the potential thermal binding of the

valves, included the required 10 CFR 50.59 screening and evaluation.

The evaluation

addressed

the effects on the system design because of the added power consumption

on the EDG and a slight change in valve stroke time and concluded these changes to the

actuator were within the limits of the UFSAR. The design modification package was well

prepared and complete, including the 10 CFR 50.59 evaluation.

The licensee had completed the modification on Valve SIBUV-0671 in Units 2 and 3, and

was performing the modification in Unit 1 during the refueling outage.

The modifications

of Valve SIAUV-0672 were to be performed in each unit during their next refueling

outage.

This time line was consistent with the licensee's implementation schedule for

corrective actions, which was submitted to the NRC by letter dated June 28, 1996.

The inspectors discussed, with the system engineer, the unavailability of the CS system

and reviewed performance and condition monito'ring activities associated with the

system.

The system engineer provided documentation indicating that the unavailability

of the CS systems for all three units averaged approximately

1 percent over the last year

and was well below the maintenance

rule trigger level of 3.75 percent unavailability.

Further, the low number of maintenance

rule functional failures compared to the number

of demands. on the system (1/450), over the last 4 years, demonstrated the CS system

far exceeded the performance criteria mandated by the Maintenance Rule Program.

The

system engineer was very knowledgeable of the system.

1

fl

'1

1

ll

h

-8-

The inspectors conducted a walkdown of portions of Unit 3 CS Train A and verified that

the as-built configuration conformed to P8 IDs. All observed valves were in the required

position for full power operations.

The material condition of the CS system was good.

Some minor material condition and housekeeping

issues were identified and brought to

the'attention of the control room shift supervisor.

These concerns were addressed

and

corrected in a timely manner.

None of the concerns affected operability of the CS

system.

The inspectors also verified operability of the CS pumps, motor-operated valves, check

valves, and relief valves in the system design basis accident flow path.

Operability was

determined by ensuring that these components were included in the surveillance testing

program and that the tests were current. The inspectors further verified that these

surveillances were performed within the required periodicity for the last 18 months.

Conclusions

Unit 3 CS Train A was installed and maintained per the applicable design and operating

requirements for those portions of the system reviewed.

The material condition of the CS

system was good. The CS system unavailability was very low.

08

Miscellaneous 0 erations Issues

92901

08.1

Closed

Viola 'on 50-529/9716-01:

Inadequate Shutdown Cooling Ftow

This violation documented that Unit 2 was operated in Mode 5 with less than the required

shutdown cooling flow. The inspectors reviewed the response,

dated

November 26, 1997, to the Notice of Violation and verified that the corrective actions

were appropriately implemented to prevent recurrence.

II. Maintenance

M1

Conduct of Maintenance

M,1.1

General Commen so

Maintenance Ac iviies Units 1

2 and 3

a.

Ins ection Sco

e 62707

The inspectors observed all or portions of the following activities performed per the

following work orders (WO):

WO 828772:

Rework the Seat Leakage and Repack Valve 1PSIBV842 As Required

WO 828802:

Disassemble Valve 1PSIBV555 and Rework As Required To Stop

Leakage Past the Seat.

Replace the Downstream Nipple and Cap.

-9-

WO 803415:

ModifyValve 1JSIBUV0667 From a Rising, Rotating Stem To a Rising,

Non-rotating Stem', and Replace Operator.

WO 755377:

Implement The Electrical Portion of DMWO 739596 (Design Package For

Low Pressure Safety Injection Pump Shaft Retrofit) Per The Attached

Instructions (Unit 1).

WO 835433:

Troubleshoot Diesel Control Circuits Per Engineering Gameplan (Unit 2).

WO 835620:

Lubricate and Functionally EDG Fuel Cylinder Control Valves (Unit 2).

WO 082703:

EDG B Piston Modification.

WO 081649:

WO 716930:

Replace Capacitors in Inverter 1-E-PKC-N43.

Install Transformer Cooling Fan Units in Accordance With DMWO 704966

On 4160-vac to 480-vac Transformer 1E-PGA-L31.

WO 767832:

Install Bonnet Bypass Spring Check Valve 1JAFCUV0036.

WO 803414:

Install DMWO 705815 To Install SMB-00-10 Limitorque Operator On

1JSIBUV0646, High Pressure Injection System 2 Flow Control To RC 1B

Containment Isolation.

b.

Observa 's

n

Findi

The inspectors found the work performed under these activities to be professional and

thorough.

Allwork observed was performed with the work package present and in active

use.

Generally, good work practices were observed.

Foreign material exclusion

practices were good. Technicians were experienced and knowledgeable of their

assigned tasks.

c.

Conclusions

Routine and outage-related

maintenance activities were generally conducted in a safety

conscious manner by knowledgeable technicians using approved procedures.

Good

work and foreign material control practices were observed.

M1.2

General

ommen

on S

'Ilanc

Activities Uni 3

a.

Ins ec ion Sco

e

1726

The inspectors observed portions of Surveillance Test 73ST-9CL10, "Containment

Ventilation Purge Isolation Valves (42 inch) - Penetration 57 (Unit 3)."

4

i

i

1'

-10-

Observa ions and Findin s

The inspectors found this surveillance to be performed acceptably and as specified by

the applicable procedure.

M1.3

Failure to Perform All Prere

uisites Prior o Ins ectin

In ernals of an ED

ni 1)

Ins ec ion Sco

e

62707

During the Unit 1 refueling outage, the inspectors observed maintenance

being

performed on EDG A. The inspectors reviewed associated

procedures, work orders, and

active clearances.

b.

Observa ion

n

Fin in

The licensee was performing Procedure 31ST-9DG01, "Diesel Engine Surveillance

Inspection," Revision 16, during the refueling outage.

The objective of the procedure

was to perform the annual and 5-year inspection requirements,

as specified in Vendor

Technical Manual VTM-C628-001. The purpose of the procedure was to perform and

document inspections, analysis, and evaluations to ensure the mechanical condition of

the EDG was maintained in agreement with the manufacturer predictive maintenance

guidelines.

On March 31, 1998, the inspectors observed mechanics perform boroscope inspections

of the cylinder liners through the injector ports in accordance with Step 8.7 of

Procedure 31ST-9DG01.

The inspector identified that Prerequisite Steps 7.4.1 and 7.11,

- which provided authorization for work activities to begin, had not been completed prior to

the start of work. The licensee halted boroscope inspections and removed the

boroscope.

Appropriate signatures documenting the completion of all prerequisites were

obtained prior to recommencement

of work. The licensee initiated CRDR 1-8-0206 to

document this event.

Personnel failed to obtain the appropriate authorization prior to commencing boroscope

inspections, as required by procedure.

The failure to follow a procedure for a

safety-related work activity is a violation of TS 6.8.1 (50-528/9803-03).

Recent NRC Inspection Reports 50-528;529;530/98-02

and 50-528;529;530/97-018

document varying degrees of work performance problems in the maintenance

area.

One

report documented

a weakness where a work order was inadvertently misplaced while

work was in progress.

Another report documented that, during the performance of a

surveillance task, documentation was not being kept current.

Management recognized

the significance of the recent failures and was reiterating their expectations on proper

procedural adherence

to the maintenance staff.

ji

-11-

~

Engineering personnel performed boroscope inspections on Unit 1 EDG A cylinder liners

without obtaining proper authorization.

This is a violation of TS 6.8.1 for the failure to

follow procedure.

M1.4

ov m n S en Fue

ol

i

ns

i

co

617 6

CRDR 9-8-0511, initiated on March 27, 1998, documented an event that occurred when

refueling and mechanical services personnel relocated a spent fuel bundle inside the

Unit 1 spent fuel pool. During movement of the bundle, higher than expected radiation

levels were experienced on the spent fuel handling machine and locally near the spent

fuel pool on the 140-foot elevation.

The inspectors reviewed the circumstances of this

event to determine ifcompliance with applicable licensee procedures was a contributing

cause.

b.

a

Findin s

On March 26, refueling and mechanical services personnel planned and conducted three

tasks inside the Unit 1 fuel building. One of these activities was to move a fuel bundle

from one location to another inside the spent fuel pool.

The target location for the bundle was directly in front of and approximately 2 feet from

the steel gate separating the fuel transfer canal and the spent fuel pool. The spent fuel

pool was at its normal level of 137 feet.

However, the fuel transfer canal was being kept

at a lower level to minimize the amount of leakage past the Fuel Transfer Tube Isolation

Valve PCN-V118. Prior to starting the job, the team conducted a briefing in the control

room with the shift manager.

Radiation protection personnel were also notified of the

jobs and their scope.

With the level in the transfer canal low, the extra shielding that

would have been provided by the water in the transfer canal did not exist.

Refueling and

mechanical services personnel discussed this with the shift manager and it was decided

that an adequate

level existed in the fuel transfer canal to support the fuel move.

This judgment was made based upon the guidance provided in Procedure 78OP-9FX03,

"Spent Fuel Handling Machine," Revision 8. When the technicians moved the bundle, it

was moved in such a manner that it approached the face of the gate in a vertical

orientation. As the bundle neared the gate, radiation levels on the spent fuel handling

machine and outside of the fuel pool began to rise. The levels exceeded the 15 mr/hr

alarm set point of the area monitor on the spent fuel handling machine and caused a

frisker near the fuel pool to alarm. An RP technician in the area measured

a field of

approximately 300 mr/hr near the fuel transfer canal. The trainee who was operating the

spent fuel handling machine under instruction was directed to leave the area and the

experienced operator continued operation of the spent fuel handling machine.

At the

time of the radiation alarms, the bundle was above the target location and, by direction of

i

0

-12-.

an RP technician, was lowered into the fuel racks to clear the condition. The elevated

radiation levels existed for less than

1 minute.

Due to the short duration, no significant

personnel exposure resulted.

The licensee initiated CRDR 9-8-0511 to document this

event.

The immediate corrective action was to require that the fuel transfer canal level

be within 6 inches of spent fuel pool level prior to any fuel movement.

Operation of the spent fuel handling machine was conducted in accordance with

Procedure 78OP-9FX03, which listed the prerequisites

in Section 4.2. Step 4.2.1

directed personnel to check the level in the cask loading pit and fuel transfer canal.

Although the level in the fuel transfer canal was considered to be satisfactory by the shift

manager prior to making the fuel move, adequate compliance with this prerequisite step

was not achieved because of the inadequate guidance provided in the procedure.

Specifically, the procedure did not provide sufficient information on how to determine

what the minimum level should be. The failure to adequately maintain a procedure is a

violation of TS 6.8.1 (50-528/9803-04).

~Conc

sions

M1.5

A violation was identified for the failure to provide specific criteria for licensee personnel

to determine the minimum required level in the transfer canal prior to moving spent fuel.

This is a violation of TS 6.8.1 for the failure to provide an adequate procedure.

a

in S

am

enera

2 Dow co

er Blowdown Sam

le Line

ni

1

nsecin

c

e 62

7

The inspectors evaluated the licensee's actions to repair a leak on a 3/8-inch diameter

downcomer sampling line connected to Unit 1 Steam Generator 2. The applicable

Deficiency Work Order 00775579 and supporting calculations were reviewed.

Observa io s and Findin s

In October 1996, the licensee performed a temporary Furmanite leak seal repair to stop

a leak identified on Sample Line 1PSGEL181A for Steam Generator 2. The licensee

intended to permanently repair the line to return it to its original configuration during the

current Unit 1 refueling outage.

While removing the Furmanite box from the sampling

line, the licensee observed a crack in the Swagelok fitting adjacent to the steam

generator nozzle connection for the sampling line. There was still a short section of

tubing and a ferrule protruding out of the existing threaded male fitting welded to the

steam generator.

To keep the design function of this tubing configuration intact, maintenance engineering

repaired the line by the following method. A socket-welded tubing union was welded to

the non-threaded

side of a Swagelok nut. The nut,was threaded onto the existing fitting

welded to the steam generator.

Once in place, the threaded assembly was seal welded

to ensure a leak tight joint. The stainless steel tubing was socket welded to the

I

-13-

socket-welded side of the Swagelok fitting assembly.

The installation was consistent

with the licensee's design requirements,

including the ASME code.

The inspector

considered that by seal welding the threaded joint, the licensee had taken additional

conservative measures to ensure system leak tightness.

The inspectors reviewed the evaluation completed by the licensee prior to installing the

temporary Furmanite leak seal.

Engineering determined that additional restraint of the

system would be required to accommodate

the additional weight of the Furmanite box.

The decision was made to attach the Furmanite box to an adjacent box connected to the

steam generator.

This was accomplished by using long bolts that protruded from the

Furmanite box and were tack welded to the adjacent box. The WO specified that the

tack weld be made at each of the four protruding bolts and that the welder should

attempt to perform the tack weld around as much of the circumference of each protruding

bolt as possible.

The inspectors noted that tack welds are typically used by welders to

hold pieces into place for welding, and tack welds do not have any particular

requirements that could be converted into an equivalent structural strength.

Because of

the small loads associated with this modification, however, the instructions to tack weld

would be within the skill of the craft to accomplish a structurally sufficient weld. This was

supported by the licensee's observation that the welds were intact when the Furmanite

box was removed and the line was returned to its original configuration.

In reviewing the stress model of the sampling line, the inspectors noted that a 3-way

restraint had been modeled at the location of the Furmanite box. The inspectors

disagreed with this modeling of the restraint because the Furmanite box was securely

tightened onto the 3/8-inch sampling line and would not have allowed it to rotate.

The

inspectors considered that modeling an anchor that would restrain the line from moving

in all three translational and rotational directions would have been appropriate.

The

licensee remodeled the system considering an anchor-type restraint at the Furmanite

box. Although some stresses

and loads increased

in the ren>odeled system, the system

did not exceed its design basis.

Conclusion

The permanent repair of a leak in the Unit 1 Steam Generator 2 downcomer sampling

line was consistent with system design requirements.

M2

Maintena'nce and Material Condition of Facilities and Equipment

M2.1

Review of Material Condi ion Durin

Plan T

ns

e

ion Sco

e 62707

e

During this inspection period, routine tours of all units were conducted to observe the

status of plant equipment and evaluate plant material condition.

<J

-14-

rva ion

indin s

Inspector observation of plant material condition identified no major observable material

condition deficiencies.

Minor deficiencies brought to the attention of the licensee were

documented with work requests.

During the Unit 1 outage, the inspectors observed several disassembled

electrical

components and motor-operated valve actuators.

This included 125-vdc to 120-vac

Inverter PNC-N13, 125-vdc to 480-vac Inverter PKC-N43, 4160- to 480-vac Transformer

PGA-L31, Containment Electrical Penetration 1ESFBZ380, and high pressure safety

injection flow control Valve Sl-UV-646. The material condition of these components was

good.

c.

~Con ~vien

Observable material condition of the three units was satisfactory.

Material condition of

the interior of components disassembled

for the Unit 1 outage was good.

M2.2

Con

in

en

lo

re

al

wn

ni

1

a.

I

ion coe 670

Tours of the Unit 1 containment were made to assess

material condition of the

equipment.

b.

0 s rvaionsa

dFindi

s

On April 15, 1998, with the unit in Mode 5, the inspectors accompanied the licensee

during performance of Procedure 40ST-9ZZ09, "Containment Cleanliness Inspection,"

Revision 9. Prior to the tour, the inspectors reviewed CRDR 98-0620, which

documented

a list of materials inside the containment building. These materials were

required for inservice inspection at normal operating pressure and temperature

(NOP/NOT) during Modes 4 and 5. Containment cleanliness and material condition were

generally good. The inspectors identified minor debris in various areas, which the

licensee retrieved and disposed of properly. The containment coordinator indicated that

an additional tour would be done at NOP/NOT, at which time they would verify final

containment cleanliness.

On April 17, the inspectors conducted an independent walkdown of portions of the

containment at NOP/NOT. Canned lagging that had not been installed at the time of the

previous inspection was identified and properly staged for reinstallation.

The inspectors

did not observe any active leakage or evidence of previous leakage.

I

-15-

c.

~Con Iusions

Material condition of the equipment in the Unit 1 containment was good.

MS

Miscellaneous Ilaintenance Issues

M8.1

I

Lic nsee Even

e o

E

5 -528/96-003-01: Open AuxiliaryBuilding Door

Causes

Fuel Building Essential Filtration Inoperability.

Revision 0 of this LER noted problems with door numbering ergonomics and door control

methods that contributed to the event.

Details of the event were discussed

in NRC

Inspection Report 50-528, -529, -530/96-13.

Revision

1 of this LER described the

following additional corrective actions implemented by the licensee to prevent

recurrence:

New door signage clearly differentiated between the door number and room

number.

Procedure 40DP-9ZZ17, "Control of Door Hatches, and Floor Plugs;" was revised

(Revision 8) to update the design basis functions of the doors.

~

Training on procedure changes and door control was accomplished.

The inspector verified these corrective actions to be acceptable and complete.

E1

Conduct of Engineering

E1.1

Review of Modifica io

o

n Ins ection Port o Steam Generator

1

Unit 1)

cin

co e 3751

The inspectors reviewed the licensee's

10 CFR 50.59 screening and evaluation for

adding a 2.25-inch inspection port to Unit 1 Steam Generator 1.

b.

Observations and

Find'uring

routine eddy-current testing inspection of Steam Generator 1, degradation of

several tubes just above the cold leg flow distribution plate was observed.

It appeared

that the degradation was potentially caused by foreign objects in the vicinity. The

proposed inspection port would allow the capability to visually inspect and potentially

retrieve any foreign objects from this area.

The port was designed to extend through the

5.75-inch thick secondary side shell and through the nominal 1.5-inch thick economizer

feedwater box.

It was located approximately 4 inches above the elevation of the top of

the flow distribution plate.

Four 3/4-inch diameter stud holes and a gasket mating

4

I

-16-

surface were machined into the secondary side shell to allow closure of the inspection

port by a gasketed cover plate.

The inspectors noted that the 10 CFR 50.59 screening and evaluation were thorough.

Justifications to the generic screening questions were comprehensive

and detailed.

Changes to the UFSAR were identified and it was determined that the modification was

not an unreviewed safety question.

c.

~Conclusi

The licensee's

10 CFR 50.59 screening and evaluation for the modification to add an

inspection port to Unit 1 Steam Generator

1 was thorough and comprehensive..

E1.2

Year 2000

Y2

eadiness

Un'ts1

2 and 3

a.

ns

c ion

c

e

37551

On March 26, 1998, the inspectors conducted discussions concerning the licensee's

readiness to address operational and equipment problems resulting from the inability of

some components and computer software to correctly interpret some dates that occur

before and after the year 2000.

b.

Observa ions and Findin s

Computers and related technologies are in use throughout the equipment in the three

units and by plant support organizations.

As a result, issues raised by the Y2K problem

require action on the part of the licensee to ensure continued safe operation of the units.

The potential problems related to the Y2K issue include possible simultaneous trip of all

three units and possible unavailability of emergency power sources.

To address the Y2K problem, the licensee established

a project organization, in

January 1998, which reported directly to the Vice President, Nuclear Engineering.

It had

a full-time project manager and a core team of individuals from different disciplines. Also

associated

with the project were single points of contact in key areas.

The project was

proceeding in a planned manner to assess

the extent of the Y2K problem, determine the

extent of remediation necessary,

and correct the identified problems.

There were four areas that were being addressed

by the Y2K project, as discussed

below:

The first involved problems with programmed computer chips internal to some

components; referred to as embedded systems.

Examples of components with

possible embedded systems were certain transmitters and data recorders.

The

licensee was approximately 80 percent complete in their efforts to inventory

embedded systems.

The licensee expected to have completed the assessment

of the embedded system components by October 1998.

>i

f>

b

-17-

~

The second area involved process systems, such as the core protection

calculators.

The licensee expected to have a detailed, Y2K remediation plan

completed by June 1998.

~

The third area involved information technology supported systems, such as large

database

systems and engineering computer code.

The licensee expected to

complete items in this area by December 1998.

The fourth area involved department supported systems, such as the plant

simulation facilityand computerized measuring and test equipment.

The licensee

expected to have a detailed Y2K remediation plan completed by June 1998.

c.

Conclusions

Licensee plans to address operational and equipment problems resulting from the

inability of some components and computer software to correctly interpret some dates

that occur before and after the year 2000 appeared

to be comprehensive.

IV

a

Su

R1

Radiological Protection and Chemistry Controls

R11

Gen

r

I

mmenso

nr Is

is1

d3

a.

In

ection Sco

e

17 0

The inspectors monitored RP activities during routine site tours.

b.'bserva

ions and Findin

The inspectors observed radiation protection personnel, including supervisors, routinely

to'uring the radiologically controlled areas.

Licensee personnel working in radiologically

controlled areas exhibited good radiation work practices.

Contaminated areas and high radiation areas were properly posted.

Area surveys

posted outside rooms were current. The inspectors checked a sample of doors, required

to be locked for the purpose of radiation protection, and all were in accordance with

requirements.

Conclusions

The radiological protection program was effectively implemented in those ares reviewed.

I

,l

-18-

V

a

a

e

entMeeti

s

X1

Exit Meeting Summary

The inspectors presented the inspection results to members of the licensee's staff at the

conclusion, of the inspection on April 21, 1998. The licensee acknowledged the findings

presented.

a

The inspectors asked the licensee whether any material examined during this inspection

should be considered proprietary.

No proprietary information was identified.

c

PARTIALLIST OF PERSONS CONTACTED,

P. Borchert, Shift Manager, Operations

D. Garnes, Unit 2 Department Leader, Operations

P. Crawley, Director, Nuclear Fuel Management

D. Fan, Section Leader, System Engineering

D. Kanitz, Engineer, Nuclear Regulatory Affairs

P. Kirker, Unit 3 Department Leader, Operations

A. Krainik, Department Leader, Nuclear Regulatory Affairs

J. Levine, Senior Vice President, Nuclear

D. Mauldin, Director, Maintenance

D. Marks, Section Leader, Nuclear Regulatory Affairs

M. Muhs, Department Leader, RAMS/Maintenance

G. Overbeck, Vice President, Nuclear Production

T. Radke, Director, Outages

J. Scott, Director, Site Chemistry

G. Shanker, Department Leader, Speciality Engineering

M. Shea, Director, Radiation Protection

D. Smith, Director, Operations

E. Sterling, Department Leader, Nuclear Assurance Department

J. Velotta, Director, Training

P. Wiley, Department Leader, Operations

M. Winsor, Department Leader, Maintenance Engineering

INSPECTION PROCEDURES USED

IP 37551:

IP 60710:

IP 61726:

IP 62707:

IP 71707:

IP 92901:

Onsite Engineering

Refueling Activities

Surveillance Observations

Maintenance Observations

Plant Operations

Plant Operations Followup

i

I

0

~Oned

50-'528/9803-01

50-528/9803-02

-2-

ITEMS OPENED CLOSED, AND DISCUSSED

NCV

Improper installation of da

o danger tags (Section 01.2)

IFI

Review licensee's actions for con

ons or control room habitability limi s

50-528/9803-03

50-528I9803-04

VIO

EDDG internal inspections performe

(S

t

M1 3)

VIO

Failure to provide an adequate procedur

(S t'1 4)

50-529/9716-01

50-528/96-003-01

50-528/9803-01

VIO

Inadequate shutdown c

n cooling flow (Section 08.1)

LER

Open auxilia

'

ry building door causes fuel b '

bilit (S

tio

M8.1)

NCV

Improper installation of da

o danger tags (Section 01.2)

S 0

US

D

ARN

CFR

CRDR

CS

DMWO

EDG

HVAC

. IPE

Iwg

LER

NOP/NOT

P8 ID

RCS

RP

TS

UFSAR

WO

Auxiiliaryfeedwater

Code of Federal Regulations

p rt/disposition request

.

Condition re o

ontainment spray

Design modification work o d

gency diesel generator

or er

Heating ventilation and air conditionin

inches ofwater gauge

Licensee event report

normal operating pressure and tern era

Piping and instrume

t

t'enation diagram

Reactor coolant system

Radiation protection

Technical Specifications

Safety Analysis Report

Updated Final S

'

I