ML17331A953

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Insp Repts 50-315/93-16 & 50-316/93-16 on 930616-0727. Violations Noted.Major Areas Inspected:Plant Operations, Maint & Surveillance,Engineering & Technical Support
ML17331A953
Person / Time
Site: Cook  
Issue date: 08/17/1993
From: Jorgensen B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17331A951 List:
References
50-315-93-16, 50-316-93-16, NUDOCS 9308250296
Download: ML17331A953 (24)


See also: IR 05000315/1993016

Text

U. S.

NUCLEAR REGULATORY COHHISSION

REGION I I I

Report

Nos.

50-315/93016(ORP);

50-316/93016(ORP)

Docket Nos. 50-315;

50-316

Licensee:

Indiana Hichigan Power

Company

1 Riverside

Plaza

Columbus,

OH

43216

License

Nos.

OPR-58;

DPR-74

Facility Name:

Donald

C.

Cook Nuclear

Power Plant, Units

1 and

2

Inspection At:

Donald

C.

Cook Site,

Bridgman,

HI

Inspection

Conducted:

June

16,

1993 through July 27,

1993

Inspectors:

J.

A.

Isom

D. J. Hartland

- T. Tella

Approved By:

. L.

g

sen,

Chief

Reactor

rojects Section

2A

ate

(7

Ins ection

Summar

Inspection

from June

16,

1993,

through July 27,

1993.

(Report Nos.

50-315/93016(DRP);

50-316/93016(ORP) )

Areas

Ins ected:

Routine,

unannounced

inspection

by the resident

and region-

based

inspectors of:

plant operations;

maintenance

and surveillance;

engineering

and technical

support;

actions

on previously identified items;

reportable

events;

and, safety assessment/quality

verification.

Results:

Two Severity Level

IV violations were identified.

0

11,

p f

i

ti

g

d.

Il

,

p

did not address

compliance to technical specifications for unidentified

leakage during

a plant evolution until prompted

by the inspector.

In

addition, the licensee

declared

the time of inoperability of the Unit 2

"M"

'entrifugal charging

pump to be the time when

pump performance

was observed

to

be deteriorating,

only after the inspector

discussed

the issue with plant

management.

Haintenance:

Overall, the quality of work observed

by the inspector during

this period was good.

However, the inspector

noted that the planning for the

repair work on valve 1-IRV-300 was inadequate,

which resulted

in the plant

being in an undesirable

line-up for

an extended

period of time.

En ineerin

and Technical

Su

ort:

The inspection disclosed

a weakness

in the

licensee's

handling of a "minor" HDAFW. pump packing leak.

This resulted

in

the

pump outer bearing

becoming seriously degraded,

such that

pump capability

to perform its desigb function was questionable.

. 9308250296

9308f7

(5

PDR

ADOCK 0500031'5

"8

PDRg

Safet

Assessment

ualit

Verification:

The inspection disclosed

a weakness

in the licensee's

failure to perform

a formal safety evaluation prior to de-

energizing

an

EDG room ventilation damper in the

open position.

This

ultimately contributed to the inoperability of the

EDG.

In addition, the

licensee's

investigation into the event failed to identify this as

a root

cause.

DETAILS

Persons

Contacted

A.

  • K.

L.

  • J

B.

T.

p.

D.

.L.

T.

  • S

p.

  • J

L.

G.

D.

  • M.

A. Blind, Plant Manager

R. Baker, Assistant Plant Manager-Production

S. Gibson, Assistant

Plant Manager-Projects

E. Rutkowski, Assistant

Plant Manager-Technical

Support

A. Svensson,

Executive Staff Assistant

P. Beilman, Maintenance

Superintendent

F. Carteaux,

Training Superintendent

L. Noble, Radiation Protection Superintendent

.J. Matthias, Administrative Superintendent

K. Postlewait,

Design

Changes

Superintendent

A. Richardson,

Operations

Superintendent

G. Schoepf,

Project Engineering

Superintendent

S. Wiebe, Safety

5 Assessment

Superintendent

H. Vanginhoven, Site Design Superintendent

A. Weber,

Plant Engineering

Superintendent

C..Loope,Chemistry

Superintendent

L. Horvath, guality Assurance

Supervisor

The inspector also contacted

a number of other licensee

and contract

employees

and informally interviewed operations,

maintenance,

and

technical

personnel.

  • Denotes

some of the personnel

attending the Management

Interview on

August 4,

1993.

Plant

0 erations

71707

71710

42700

The inspector

observed routine facility operating activities

as

conducted

in the plant and from the main control

rooms.

The inspector

monitored the performance of licensed

Reactor Operators

and Senior

Reactor Operators,

of Shift Technical Advisors,

and of Auxiliary

Equipment Operators

including procedure

use

and adherence,

records

and

logs,

communications,

and the degree of professionalism of control

room

activities.

The inspector

reviewed the licensee's

evaluation of corrective action

and response

to off-normal conditions.

This included compliance with

any reporting requirements.

The inspector

noted the following with regard to the operation of Units

1 and

2 during this reporting period:

a.

Unit

1 Status:

The licensee

operated

the unit at full power throughout the

inspection period, with no significant operational

problems noted.

-3

b.

Unit 2 Status:

The licensee

operated

the unit at

70 percent

power during the

period until July 10,

1993,

when power was raised to 91 percent to

support

system grid demand.

The licensee

reduced

power back to 70

percent

on July 17,

and intended to operate

the unit at that power

level for the remainder of the cycle in order to separate

the two

units'cheduled

1994 refueling outages.

The

NRC granted

the licensee

a Notice of Enforcement Discretion

(NOED) on July 9,

1993, to extend the

72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement for

Technical Specifications

(TS) 3. 1.2.4

and 3.5.2

due to the

inoperability of the Unit 2

"W" centrifugal charging

pump

(CCP).

The

NOED allowed for an additional

60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> s to repair the

pump

without the requirement to initiate

a plant shutdown.

At about

10:37 p.m.,

on July 6, the licensee

switched from the

"W"

to the "E" CCP after experiencing difficulty in maintaining

pressurizer

level with the

"W" CCP in service.

The licensee

did

not declare

the

pump inoperable at that time because

the

TS

requirement for pump discharge

pressure

was satisfied at the time

the

pump was shut

down.

The licensee

declared

the

pump inoperable

at 10:32 a.m. the following day after it exhibited high vibrations

during

a troubleshooting

run.

On July 8, after discussions

with

the inspector,

the licensee

moved back the time of inoperability

to 10:37 p.m.

on July 6.

--The licensee

replaced

the -internal rotating assembly

and declared

the

pump operable after

a successful

surveillance

run at

ll:45 p.m.

on July 10.

The inspector

observed

portions of the

pump repair

and surveillance

run and verified licensee

compliance

'to the compensatory

measures

documented

in the

NOED.

The

inspector did not identify any deficiencies.

The licensee

had not

yet

determined

the root cause of the

pump failure, but had

shipped

the internal

assembly to the vendor for disassembly

and

inspection.

The inspector will review the licensee's

determination of the root cause of the

pump failure and the

corrective action taken,

as appropriate.

No violations, deviations,

unresolved,

or inspector followup items were

identified.

Haintenance

Surveillance

62703

61726

42700

The inspector

reviewed maintenance

activities

as detailed

below.

The

focus of the inspection

was to assure

the maintenance activities were

conducted

in accordance

with approved

procedures,

regulatory guides

and

industry codes or standards,

and in conformance with Technical

Specifications.

The following items were considered

during this review:

the Limiting Conditions for Operation

were met while components

or

systems

were removed from service;

approvals

were obtained prior to

initiating the work; activities were accomplished

using approved

procedures;

and post maintenance

testing

was performed

as applicable.

The following activities were inspected:

a ~

Solid State Protection

S stem

SSPS

Test Circuit Card

Re lacement

b.

The inspector

observed

licensee

actions

taken in response

to

problems

encountered

during performance of SSPS surveillance

testing.

The inspector determined that the licensee

response

was

satisfactory

and that the

ILC personnel

involved appeared

to be

knowledgeable.

On June

16,

1993, while checking that the test circuitry was

functional per step 7.3. 12 of "Reactor Trip SSPS

Logic and Reactor

Trip Breaker Train "A" Surveillance

Test (Monthly)," lIHP4030

STP.410,

the licensee

did not receive the required

response

from

the testing

lamps.

At that time, the licensee

was in a

2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

Limiting Condition for Operation

(LCO) per

TS No. 3.3. 1. 1 due to

the bypassing of the Train "A" reactor trip breaker/automatic trip

logic during the surveillance testing.

Upon review and

concurrence

from supervision,

the Instrument

and Control

(I&C)

technicians

determined that

a test circuit card

had probably

failed; however,

the test circuit did not affect operability of

the

SSPS trip logic.

Therefore,

the licensee carefully backed out

of the surveillance

and exited the

LCO.

The following day,

I&C replaced

the card per Action Request

(AR)

A0045723,

which provided generic instructions to troubleshoot

and

repair the problem while performing the surveillance.

The

inspector

observed that

I&C successfully

completed

the

surveillance after replacing the card.

Re air of Valves 1-IRV-300 and 1- RV-303

The inspector

observed activities associated

with the repair of

chemical

and volume control

system

(CVCS) letdown valves

1-IRV-300

and

I-HARV-303.

The inspector

observed that, overall, the

evolution was well-executed

and that the quality of the

maintenance

was good.

However, the licensee

did not address

TS

compliance to unidentified leakage during

a preliminary evolution

until prompted

by the inspector.

In addition, the licensee

was

delayed

in completing the repairs

on

1-IRV-300, which resulted

in the plant being in a undesirable

line-up for an extended

period of time.

On June

16,

1993, the licensee

removed

normal

letdown from service

and established

excess

letdown in an attempt to quantify leakage

past letdown isolation valves

HARV 160,

161,

& 162

and to observe

5

and monitor conditions while letdown was isolated.

The licensee

performed the evolution in preparation for the scheduled

repair of

1-IRV-300 and I-QRV-303.

The licensee

performed

a reactor coolant

system

(RCS) leakrate

calculation during the evolution

and determined that about

1.3

GPH

was leaking past the orifice isolation valves.

At that point, the

inspector queried the operations

crew as to whether this leakage

was considered

to be identified or unidentified.

The licensee

was

required to enter

TS

LCO No. 3.4.6.2

for unidentified leakage

in

excess of

1

GPH.

Only after being prompted

by the inspector did

the licensee

address

the issue.

The operations

crew determined

after

some debate that since the leakage

source

had not been

specifically identified, nor was it measured

to

a closed

system,

that they were in the

TS

LCO.

The licensee

exited the

LCO after

returning normal letdown to service later that day.

On July 7,

1993, the licensee initiated repairs

on the two letdown

valves.

In order to isolate the valves,

the licensee

again

was

required to isolate letdown

and establish

excess

letdown.

The

licensee

directed the 1.3

GPH leakage

from the orifice isolation

valves to a floor drain.

The licensee

valved in

a leak-off bottle

periodically to monitor the leak rate.

The licensee

also purged

the piping connected

to 1-QRV-303 with nitrogen to remove

any

hydrogen

and waste

gas from the piping,

and then pressurized

the

piping downstream of an isolation check valve to prevent

any

potential

in-leakage

from the waste

gas

system.

The inspector

attended

briefings

and observed

portions of the

valve isolation evolution and repair activities.

The inspector

observed that the evolution was well-planned

and coordinated.

The

quality of the maintenance

work was also good.

However,

the

licensee

experienced

a delay in completing the repairs to 1-IRV-

300 because

improperly-sized

gaskets

were staged for the job.

As

a result,

the licensee

maintained

excess

letdown in service for 24

more hours than expected

in order to obtain the gaskets

from the

manufacturer.

The inspector

noted that being

on excess

letdown was not

a

desirable

condition because,

in the event of a safety injection

(SI) actuation,

operator action would have

been required to

reestablish

CCP recirc flow from the volume control tank

(VCT) to

the suction of the

CCP.

The realignment

would have

been necessary

to prevent the

VCT from overpressurizing,

which would have lifted

a safety valve and diverted

some SI flow from the core to the

CVCS

hold-up tanks.

This scenario

would have

been likely in the event

of a small-break loss-of-coolant-accident

(LOCA), as the recirc

valves automatically would have

gone closed

on

a SI actuation

but

reopened until

RCS pressure

was reduced to 2000 psig.

In order

for the valve realignment to take place,

an operator

would have

had to have

been dispatched

by the control

room, dressed

out in

full anti-c's,

and entered

the

VCT hallway to manipulate the

6

valves.

This process

would have easily taken several

minutes to

complete.

During follow-up discussions,

the inspector discovered that

maintenance

personnel

had identified improperly-sized

gaskets

as

a

potential root cause for the problem with 1-IRV-300, but that the

gaskets

that were staged for the job were not checked for correct

sizing until shortly before the work started.

The inspector also

reviewed the job order (¹ 0268)

and noted that it was generic in

nature

and did not require that the gaskets

be inspected.

The

inspector

concluded that planning for this high profile job was

inadequate

due to

a lack of coordination

between

the planner

and

the maintenance

supervisor,

which resulted

in the plant being in

the undesirable

line-up for an extended

period of time.

The inspector also observed

the following activities

and did not

note

any deficiencies:

Surveillances

"Turbine Driven Auxiliary Feed

Pump Trip and Throttle Valve

Operability Test,"

lOHP4030.STP.017TV

"Steam Generator

Stop Valve Dump Valve Surveillance Test,"

10HP4030.STP.018

"Steam Generator

Stop Valve Partial

Closure Surveillance Test,"

10HP4030.STP.019P

Maintenance

JO ¹ C14939,

Repair of Unit

1

CD

EDG 1-LLA-115, Hi Lube Oil Level

Alarm

JO ¹ C16640, As-Left Static Testing of 1-NMO-753

JO ¹ C16924,

Replace

2-FRV-240 Master Controller

No violations, deviations,

unresolved,

or inspector followup items were

identified.

En ineerin

and Technical

Su

ort

37828

The inspector monitored engineering

and technical

support activities at

the site and,

on occasion,

as provided to the site from the corporate

office.

The purpose of this monitoring was to assess

the adequacy of

these functions in contributing properly to other functions

such

as

operations,

maintenance,

testing, training, fire protection,

and

configuration management.

7

Unit

2 East Motor-Driven Auxiliar

Feedwater

Pum

Unit 2 East Motor-Driven Auxiliar

Feedwater

HDAFW

Pum

Bearin

Dama e:

2)

3)

The inspector

concluded his investigation into the failure

of the Unit 2

HDAFW pump bearing

(50-315/93011-03(DRP);

50-316/93011-03(DRP))

through review of various licensee

documents

and interviews with system

and maintenance

engineers.

The inspector

concluded that Unit 2

HDAFW pump

outboard thrust bearings

had sustained

severe

damage to the

point where

pump operability was questionable

when the water

in the oil was discovered

on April 20,

1993.

Additionally,

the inspector

concluded that under the best of

circumstances,

the Unit 2 East

HDAFW pump had

been in this

condition from the

end of its last run, which concluded at

10:54 a.m.,

on March 5,

1993.

Therefore,

the Unit 2

HDAFW

pump was potentially inoperable

from about

March 5,

1993, to

April 20,

1993,

a period of 45 days.

Water Found in Unit 2

MDAFW

um

outer bearin

oil:

On April 20,

1993, while performing

a routine oil change

on

the Unit 2 East

HDAFW pump, the mechanics

discovered

water

present

in the oil from the outer bearing

housing.

The

licensee,

as part of the plant's preventive maintenance

program,

performs

an oil change

on the

HDAFW pump every 48

-weeks.

Because of the water found in the bearing oil, the

licensee

decided to disassemble

and inspect the outboard

bearing

assembly.

The licensee

found the brass retaining

rings were in several

pieces

and

some of the ball bearings

were badly deformed.

Subsequent

review of the Unit 2 East

HDAFW pump bearings

by the bearing manufacturer

confirmed

that the cage

(brass retaining ring) had broken into pieces,

the inner ring turned

and

smeared

to the shaft,

and

some of

the ball bearings

were distorted.

Cause of the Bearin

Failure:

The licensee

determined that the cause of the bearing

failure on the Unit 2 East

HDAFW pump was water intrusion

into the bearing

housing from an excessive

outboard

packing

leak.

The licensee

found about

20 percent

water in the

lubricating oil.

The presence

of water in the oil reduced

the oil viscosity and accelerated

bearing

cage

wear

and

fracture.

The

HDAFW pump outer bearings

are angular contact ball

bearings.

There are two bearing units which are mounted

onto the shaft in the "back-to-back" configuration.

The

bearing unit consists of the inner race,

the ball bearings

(which are

housed

in the cage

assembly

sometimes

referred

8

to as the brass retaining ring),

and the outer race.

The

cage retains the ball bearings

in their proper positions in

the annular

area

formed by the inner and outer races.

The

inner and outer races

are designed

not to rotate with the

shaft.

The inspector

examined

the

damaged

bearings

and

made the

following observations:

the surface of the inner thrust bearing inner race

was

grooved,

indicating the shaft

had turned against

the

inner race.

the surface of the outer thrust bearing inner race

appeared

to be smeared,

indicating that the inner race

had

been slipping against

the shaft.

The maintenance

and system engineers

informed the inspector

that the shaft surface

was found to be blue.

The licensee

concluded that the color of the shaft in the bearing

area

was from intense

heat

due to the friction from the condition

of the inner races for the inner and outer thrust bearings.

After inspecting the

damaged

bearings,

reviewing various

documents,

reports,

and interviewing numerous

licensee

personnel,

the inspector

agreed with the licensee's

root

cause

analysis that the cause of the severe

damage to the

Unit .2 East

HDAFW pump thrust bearing discovered

on April

20,

1993,

was water intrusion into the oil.

4)

Unit 2 East

HDAFW Pum

0 erabilit

Determination:

After examinin

the condition of the outboard

um

bearin

s

the ins ector concluded that with the outboard thrust

bearin

s in the condition found

on

A ril 20

1993

the Unit

2 East

HDAFW

um

was at that time

robabl

not ca able of

erformin

its full safet

functions.

In addition

the

ins ector concluded that the

um

had

been in that condition

for a certain

eriod before

A ril 20

1993.

To determine

at about what time period the Unit 2 East

HDAFW

pump bearing

became

damaged,

the inspector relied

on the

following facts:

the outboard

pump packing

had

been leaking since

October 9,

1991,

as

documented

on Action Request

A0005591.

On August 9,

1992, the Unit 2 East

HDAFW pump outboard

bearing temperature

was

105 degrees

Fahrenheit

9

the previous routine oil change

on the Unit 2 East

HDAFW pump was performed

on October 7,

1992.

The licensee's

recent interviews with the mechanics

who performed the oil change

on October 7,

1992,

indicated that they

saw no abnormalities with the

drained oil.

Date:

The Unit 2 East

HDAFW run history from October 7,

1992, to April 20,

1993:

Run Hours:

Oct.

20,

1992

Nov.

5,

1992

Nov.

10,

1992

Nov.

11,

1992-

Nov. 30,

1992

Dec.

6,

1992-

Dec.

8,

1992

Dec.

9,

1992-

Dec.

10,

1992

Dec.

11,

1992-

Dec.

18,

1992

Har.

5,

1993

Total Hours:

2.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

9.9

hours'3.7hours

451.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

48.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />

23.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

161.1

hours

2.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

723. 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

Based

on the

above facts,

the inspector

made the following

observations:

The outboard bearings

were in a satisfactory condition

to support continued

and prolonged

pump run on

August 9,

1992,

as evidenced

by the bearing

temperature

taken

on this date.

The packing leak and the water intrusion into the oil

reservoir worsened

sometime after the October

1992 oil

change.

At the very latest,

the

damage to the bearings

existed

by the time the

pump last operated

(for about

7

minutes

from 10:47 a.m. to 10:54 a.m.

on Harch 5,

1993) before

damage discovery

on April 20,

1993.

Based

on the observations

made

above,

the inspector

concluded that bearing

damage

from presence

of water in the

oil must have occurred

sometime after the October 7,

1992,

oil change

and the most recent

pump run on Harch 5,

1993.

The damage to the East

HDAFW pump bearings

must

have existed

by Harch 5,

1993,

because

the type of bearing

damage

10

observed

could only be sustained

during

pump operation.

With the

pump at rest,

the heating of the

pump shaft

as

a

result of the frictional forces

caused

by the condition of

the inner

and outboard

races

could not have occurred.

Such

heating of the shaft from bearing failure could only occur

when two moving elements

touched

one another with little or

no lubrication.

The inspector

concluded that,

as of April 20,

1993, the

Unit 2 East

HDAFW pump was in

a condition such that it could

not be relied upon to mitigate the consequences

of accidents

for which it was designed.

Specifically, the ability of the

pump to sustain

prolonged periods of operation,

as designed,

was very questionable.

Although the Unit 2 East

HDAFW pump was probably inoperable

for a period greater

than the time period allowed by the TS,

this condition was not absolutely certain,

and

no Notice of

Violation is in order to address

pump operability.

Further,

the inspector

concluded that the licensee

did not know

before April 20,

1993, that the

pump was potentially

inoperable,

nor did they have information which would have

led them to question its operability.

Corrective Action For an

A ril 1991

Event:

The inspector

reviewed the licensee's

corrective action for

a similar bearing failure which had occurred

on April 23,

1991.

The cause of the lubrication breakdown in 1991 could

not be firmly established.

Therefore,

the root causes

for

the lubrication breakdown in 1991

and

1993 could

be

dissimilar.

Nonetheless,

the inspector

concluded that the

~ licensee's

corrective action taken in 1991

was weak,

because

the recommended

preventive action from the

1991

investigation resulted

in no new information being taken to

monitor for possible

bearing degradation.

The previously similar condition in 1991

was documented

in

Problem Report 91-0532.

Although it was initially assigned

to the maintenance

department for investigation,

PR 91-0532

was subsequently

transferred

to the corporate

problem

assessment

group for resolution.

On April 23,

1991, while the mechanics

were investigating

a

concern raised

by the operators that the slinger ring for

the Unit 2 East

NDAFW pump appeared

to be not throwing oil

to the top of the bearing

assembly,

they found that the

thrust bearing

brass retainer ring was broken into two

pieces

and that there were wear particles present

in the

oil.

The licensee's

analysis of the discolored oil detected

brass material.

Also, the bearing

and

pump manufacturer

concurred that the most likely cause of the bearing failure

11

was due to lubrication breakdown.

At the time of the

bearing failure, it was determined that these

bearings

had,

only about

8 to

10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operation

from the pump's

monthly surveillance tests.

The licensee

could not identify the cause for the

lubrication breakdown.

They reviewed

such potential

causes

as the use of proper oil, proper

balance

drum setting

(which

would minimize the thrust

on the bearings),

and the proper

oil level.

None could

be determined

as the root cause for

this accelerated

bearing

wear

and failure.

As a preventive action,

the licensee stipulated

performance

of a bearing temperature

test whenever maintenance

of the

pump rotor or bearings is performed,

This requirement

was

incorporated

into the auxiliary feed pumps'aintenance

procedure with the test to be performed per the requirements

of 4030 STP.17.

The inspector determined that the licensee's

preventive

action

was weak because

acquisition of the bearing

temperatures

was contingent

upon the

use of the auxiliary

feedwater

pump maintenance

procedure,

"Motor Driven

Auxiliary Feed

Pump Maintenance,"

    • 12HHP5021.056.001,

Revision 5, March 12,

1993.

This procedure

may not be used

between refueling outages.

This procedure

provides

mechanics with the instructions

and documentation for

disassembly,

inspection or repair,

and assembly of the motor

driven auxiliary feedwater

pump.

During the period from

August of 1992 to April of 1993, the type of corrective

maintenance

activities performed

on the

pumps during reactor

power operations

did not utilize this maintenance

procedure.

As noted

above,

during the investigation into the April 1991

bearing failure, the licensee

determined that the brass

retaining ring on the Unit 2 East

MDAFW pump had failed

after 8 to

10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operation.

However, at the time of

the bearing failure in April of 1993, the inspector

calculated that the

pump had accumulated

about

999 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.801195e-4 months <br /> of

operation

since the last bearing temperature

measurement

was

taken

on August 9,

1992.

The inspector

concluded that although the corporate

engineers

had stated their concern for potential

pump

inoperability if the bearing condition was not promptly

detected

(September

20,

1991,

memorandum),

the licensee

took

weak preventive actions to monitor and detect for bearing

wear

and damage.

It is not possible to absolutely

conclude

that stronger corrective action for the

1991 bearing

problem

would have prevented

the

1993 problem.

Therefore,

a Notice

of Violation regarding

inadequate

corrective action is not

in order.

12

Leakin

Packin

Gland Job Order:

The inspector also reviewed the causes

behind the protracted

repair-of the leaking packing= gland,

which was first

identified as

a maintenance

deficiency

on October 9,

1991,

(A/R Number A0005591)

by the operations staff.

The

inspector

had

been

concerned for some time on the number of

backlogged

maintenance

job orders

which may affect system

performance.

The inspector

had previously reviewed the

licensee's

computer printout to determine

whether

any Action

Requests

had

a potential to impose

an operability impact

with any of the safety-related

systems.

As discussed

in

paragraph

3.c of Inspection

Report 50-315/93011(DRP);

50-316/93011(DRP),

the inspector did not identify any

AR

which could potentially impact the operability of safety-

related

equipment at that time.

Because

the failure to repair the leaking packing gland

was

the cause for the water found in the bearing oil, the

inspector contacted

the integrated

scheduling

group to

determine

the reasons

why it took so long to make the

repair.

The inspector's

discussion

with the plant

integrated

scheduling

group found that the packing leak

repair,

a priority 30 job,

was never identified for work

during the Unit 2 outage in 1992.

In addition,

although it

was scheduled

to be done during the week of Harch

1,

1993,

it was deferred

because

of resource

constraints.

The repair

was then rescheduled

to be done during Hay 1993;

however,

before identification of the bearing failure on April 20,

1993, created

an opportunity to correct the leak.

The

licensee

repaired

the packing leak on the

pump packing

during the

same period it was out of service to replace the

pump shaft

and the outboard bearings.

The prolonged failure to perform corrective maintenance,

over

a period of 18 months,

allowed

a condition which was

originally considered

"minor" to develop

consequences

which

were not minor,

as described

above.

As such,

the original

condition adverse to quality, which involved an equipmen't or

material defect,

was not promptly corrected.

Title 10 of

the

Code of Federal

Regulations,

Part 50, Appendix B,

Criterion XVI, requires that conditions

adverse

to quality,

including equipment or material defects,

shall

be promptly

corrected.

Failure to correct the

known seal

leakage

on

Unit 2 East

NDAFP,

a safety-related

component,

over

a period

of 18 months, is considered

a violation of Appendix B,

Criterion XVI (Viol ati on 50-316/93016-01(DRP)

) .

The inspector's

discussion with the head of the integrated

scheduling

group found that work activities classified

as

priority 30 are currently repaired within 6 months.

13

7)

Oil Chan

e Pro ram:

The inspector

reviewed the licensee's

practice of oil

changes

performed

on all auxiliary feedwater

pumps

and found

that it was inconsistent with the frequency

recommended

by

the vendor manual.

Although the inspector

concluded that

the licensee's

oil change periodicity performed

on the

pump

may not necessarily

cause

any damage to the bearings,

he did

conclude that the licensee

may want to consider additional

oil changes

based

on

pump run hours.

Currently, the

licensee's

program does not require oil change

based

on the

number of hours of pump operation.

The licensee's

vendor manual

made the following

recommendations:-

"Remember that oil requires

frequent replenishment

at

normal temperatures

and very frequent replenishment

at

high temperatures.

Oil is always subject to gradual

deterioration

from use

and contamination

from dirt and

moisture.

In time the accumulated

sludge will be

harmful to the bearings

and cause

premature

wear.

For

this reason,

draining

and flushing are necessary

at

regular intervals (at least

every

3 months)."

"It is

a good practice to change

the oil every 600

hours of operation."

The licensee

performed oil changes

on the auxiliary

feedwater

pumps every 48 weeks.

The inspector's

review of

the oil changes

on the Unit 2 East

HDAFW pump using the

completed job order packages

found that the licensee

was

. performing the scheduled oil changes

on the Unit 2 East

HDAFW pump.

At the time of discovery of the Unit 2 East

HDAFW pump bearing failure, the

pump had accumulated

about

723 hours0.00837 days <br />0.201 hours <br />0.0012 weeks <br />2.751015e-4 months <br /> of operation

since the last oil change.

The inspector also conducted

discussions

with some of the

engineers

and found that although the licensee

does

have oil

analysis

programs for the turbine

and the diesel

generator

systems,

they did not have it implemented for the other

safety related

pumps at the time of the April 1993

HDAFW

bearing failure.

Consequently,

some of the oil samples

taken from the

HDAFW pumps were never analyzed.

Currently,

the licensee

is in the process of implementing

an oil

analysis

program for other safety-related

pumps to determine

what type of impurities are being found in the oil.

AFW Pum

Seal

Packin

Leaka

e

The inspector

reviewed licensee

action in response

to concerns

related to packing leakage

on the

AFW pump outboard seals.

The

inspector

noted that the licensee

took appropriate

preventive

action after being prompted

by the inspector.

The licensee

had identified the root cause of the failure of the

Unit 2 "E" HDAFP outboard thrust bearing,

as discussed

above

and

in earlier inspection reports,

to be water intrusion into the

bearing

housing from an excessive

pump outboard

seal

packing leak.

During a subsequent

routine plant walkdown, the inspector

observed

that leakage

from the Unit 2 turbine-driven auxiliary feedwater

pump

(TDAFP) outboard

seal

was excessive

in relation to the other

pumps.

The licensee

determined that the leak was not

an immediate

operability concern;

however,

the inspector noted that the

licensee

did not take

immediate action to monitor seal

leakage,

including providing guidance to plant personnel

as to what was

acceptable

leakage.

In response

to the inspector's

concern,

the licensee initiated

AR

¹ 17327 to monitor seal

leakage

during the Unit 2 TDAFP routine

surveillance

run on July 22,

1993.

The inspector

observed

the

activity and noted that there

was minimal leakage after the

pump

was started

and seal

temperatures

remained

acceptable;

therefore,

only a minimal packing adjustment

was required.

As preventive action,

the licensee

proposed

to provide guidance

in

auxiliary equipment operator shift tours

and appropriate

maintenance

procedures

to monitor seal

leakage

to verify no water

migration from the seals to the bearing housings.

The inspector

will continue to monitor licensee

actions

in response

to this

issue.

One violation,

and

no deviations,

unresolved,

or inspector followup

items were identified.

Actions on Previousl

Identified Items

92701

92702

a ~

(Closed)

Open Item 315/88007-02:

Non-Class

IE Motor Installed in

a Class

lE Valve Motor 0 erator

as

a

Tem orar

Modification

Replacement

of a class

1E motor with a non-class

lE motor for

valve

I-WMO-754 in Temporary Modification (TM) No.

152;

and delay

in closeout of this TM.

The vendor qualified the installed motor for class

lE

applications,

and this

TM was closed out.

The inspector

reviewed

the licensee's

TH status report dated

June

28,

1993.

There were

only 10 non-outage

related

TMs open for both units.

The

TMs were

prioritized based

on the importance of these modifications.

There

were only two items

on this status

report which were

open for over

18 months.

These

items were not considered

to be safety

significant.

This item is considered

closed.

15

b.

(Closed)

Unresolved

Item 316/88018-01:

Re

1 acement

ESW

Pum

Failed to Meet Performance

Curves

Low developed

head for Unit 2 West Essential

Service

Water

(ESW)

pump did not meet

UFSAR statements.

A UFSAR revision, clarifying

the

ESW flow requirements

was submitted for approval

in July 1993.

The differences of

ESW requirements

in Technical Specifications

for Units

1 and

2 have

been reconciled

by revisions to these

documents.

Table 9.8-5 of the proposed

UFSAR revision states

that

an

ESW flow of 6890

gpm is required for LOCA injection.

Each of

the

ESW pumps were being tested

at

a flow of 7000

gpm for a

minimum differential pressure

of 67.8 psid.

The inspector

reviewed the

pump performance

data trended for all

the

ESW pumps since January

1991,

and concluded that these

pumps

currently meet the minimum requirements

set for these

pumps.

This

item is considered

closed.

c.

(Closed)

Unresolved

Item 315/88023-02:

Potential Violation of

E

Re uirements

For Reactor

Vessel

And Pressurizer

Head Vents

d.

Discrepancies

in configuration of junction boxes

and flex conduits

for=reactor

head

and pressurizer

vent solenoids resulting in

environmental qualifications

(Eg) concerns.

The licensee

issued

an

LER (315/88010)

and

a Problem Report

(PR-88-732) to address

this issue.

The configuration

discrepancies

were corrected.

Several

procedure

enhancements

were

made to preclude similar discrepancies.

The licensee

started

a

comprehensive

program to compile

Eg design data

and to confirm the

as built configurations

by walkdowns.

The licensee

provided

Eg

training to several

plant personnel

in Engineering,

Operations,

Maintenance,

and

gA/gC Groups.

This item is considered

closed.

(Closed)

Unresolved

Items

315 93011-03

316 93011-03:

Root

Cause

s

of the Unit 2 East

MDAFW Pum

Bearin

Failure

Unit 2 East

MDAFW pump thrust bearings

were found to have failed

catastrophically

on April 20,

1993.

The licensee

conducted

an

investigation into the causes

of failure.

The inspector

reviewed the licensee's

investigation into the

causes

of the Unit 2 East

MDAFW pump bearing failure and agreed

that the primary cause

was the water found in the oil which caused

the lubricating properties of the oil to degrade.

A detailed

discussion of the root causes

and other aspects

of this issue is

discussed

in paragraph

4.a. of this inspection report.

No violations, deviations,

unresolved,

or inspector followup items were

identified.

16

I

6.

Re ortable

Events

92700

92720

The inspector

reviewed the following Licensee

Event Reports

(LERs) by

means of direct observation,

discussions

with licensee

personnel,

and

review of records.

The review addressed

compliance to reporting

requirements

and,

as applicable,

that immediate corrective action

and

appropriate

action to prevent recurrence

had

been

accomplished.

a 4

(Closed)

LER 316/92005-LL:

The Flan

e Seals

on the Containment

E ui ment Hatch

and Personnel

Airlock Were Not T

e-B Tested

Since

Initial Start-u

Due to Pi in

Errors

This

LER was closed

based

on adequate

root cause

determination

and

corrective action.

On April 15,

1992, the licensee

discovered that piping intended to

facilitate Type

B leak rate testing of the Unit 2 equipment

hatch

and personnel

airlock flange seals

was not connected

to the flange

seal test ports,

but to other holes only partially penetrating

the

flanges.

As a result,

the licensee

determined that it had not

performed the Type

B testing

on the flanges since initial plant

start-up.

The licensee

determined

the root cause

to be

an error in the

original plant piping configuration drawing.

As corrective

action,

the licensee verified the correct piping configuration

on

Unit

1 and revised the appropriate

plant procedure

to properly

test the Unit 2 seals.

The licensee

successfully

tested

the seals

on Unit 2 on April 17,

1992.

In addition, the licensee initiated

a design

change to remove the piping connected

to the wrong flange

penetrations.

This event involved

a violation of TS 3.6. 1.2

and

10 CFR Part 50,

Appendix J, which required

a Type

B leak rate test

be performed

every

24 months.

However, the event

had minimal safety

significance

because

the flange seals

were successfully

challenged

during previous

Type

A integrated

leak rate tests

(ILRTs).

In

addition, the licensee

properly reported the event

and took

appropriate corrective action.

Therefore,

pursuant to the

NRC

enforcement policy, (10 CFR 2, Appendix C), the

NRC is exercising

enforcement discretion for this matter,

and

no Notice of Violation

will be issued.

b.

(Closed)

LER 315/92002-LL:

Ino erable

Emer enc

Diesel

Generator

Caused

B

Low Governor Oil Tem erature

The inspector determined that the licensee

performed

an adequate

root cause

evaluation

and took appropriate corrective action to

prevent recurrence

of the event.

However, the inspector

determined that the licensee failed to perform an adequate

safety

17

evaluation of the condition which resulted

in the event,

as

required

by plant procedures,

and their investigation failed to

identify this

as

a contributing cause.

On February

10,

1992,

the Unit

1

AB EDG tripped

on overspeed

during

a routine surveillance test.

The licensee

determined that

the

EDG could have

been

inoperable

since

February

6,

1992,

when

I-HV-DGS-DAB, Unit

1

AB EDG room supply damper,

malfunctioned

and

was de-energized

in the open position to ensure

adequate

cooling

to the

EDG.

The open

damper allowed outside air, with

temperatures

between

15 and

36 degrees

F, to cool the

EDG governor

warming line which was located adjacent

to the damper outlet.

This resulted

in a low governor oil temperature

and, ultimately,

sluggish governor operation

which caused

the overspeed trip.

As immediate corrective action,

the licensee

repaired

the damper,

returned the warming line to normal operating temperature,

and

restored

the

EDG to an operable

status

on February

10,

1992.

As

long-term corrective action,

the licensee verified adequate

flow

in the governor warming lines

on all four EDGs and placed

insulation

on these lines.

In addition, the licensee initiated

a

design

change to improve the reliability of the damper.

As follow-up, the inspector determined that the licensee failed to

perform

a documented

safety evaluation prior to failing the damper

open.

The purpose of the damper

was to prevent cold outdoor air

from entering the

EDG room during the winter whenever the

EDG was

not operating.

The damper

was normally maintained

in the closed

position

when both the supply

and exhaust

fans were not running.

The damper

was interlocked to open if either fan started.

The

fans were designed

to start automatically

when the

EDG started or

when the

room temperature

reached

90 degrees

F,

and stop

when room

temperature

decreased

to 70 degrees

F.

Paragraph

4.1 of licensee

procedure

"Temporary Hodifications,"

PHP

5040 HOD.001, defined

a temporary modification as

"any short term

configuration that exists

on plant systems,

components,

or

structures ... which does not conform to approved plant drawings

...

and is being used to maintain operation of the plant."

The

definition also provided "blocked open valves"

as

an example of a

temporary modification.

In the case

described

above,

the licensee

failed to implement

a temporary modification,

as required

by

PHP

5040 HOD.001, for failing the Unit

1 AB EDG ventilation damper in

the open position.

This is considered

a violation (Violation 50-

316/93016-02(DRS)).

One violation,

one non-cited violation,

and

no deviations,

unresolved

or

inspector followup items were identified.

18

Safet

Assessment

ualit

Verification

37701

38702

40704

92720

The effectiveness

of management

controls, verification,

and oversight

activities, in the conduct of jobs observed

during this inspection,

was

evaluated.

The inspector frequently attended

management

and supervisory meetings

involving plant status

and plans

and focusing

on proper co-ordination

among departments.

Corrective Action to Reactivit

Excursion Transient

The inspector

reviewed the licensee's

investigation into

a reactivity

excursion transient

and determined that the root cause

evaluation

and

corrective action were adequate.

On April 11,

1993, shortly after placing the Unit

1 "S"

CVCS mixed bed

demineralizer

in service,

the Reactor Operator

(RO) observed

an

unplanned

increase

in Tave.

In response,

the

RO attempted

to borate

using

l-HARV-400,

CCP suction

from the "N" boric acid blender,

and then

l-HARV-451, "N" boric acid blender to the

VCT.

Both of these

normal

boration flow paths failed to provide any boric acid injection.

The

RO

then took manual

control of the control rods to maintain Tave

and

commenced

emergency boration

when the

TS limit for axial flux

distribution

(AFD) was approached

to stabilize the reactivity transient.

The licensee

observed

a maximum power spike at

102 percent for a brief

period

and accumulated

a total of 6 penalty minutes outside their AFD

target

band during the transient.

The licensee

determined that the root cause of the temperature

excursion

was the incomplete boration of the demineralizer

which had

been

performed

on April 6,

1993, after the resin

was replaced.

The

incomplete boration

was due to inadequate

coordination

between

the

reactor

operators

and the Chemistry technician

who was taking the

RCS,

samples.

As corrective action,

the appropriate

operations

procedure

was

enhanced

to provide more specific guidance

on borating

a new

demineralizer

bed.

In addition,

a

memo

was distributed to all

operations

personnel

to stress

the importance of proper coordination

with Chemistry technicians

when

RCS samples

are being taken.

With regard to the failure of the parallel

normal boration flow paths to

provide boric acid, the licensee

determined that the failure I-HARV-400

to operate

was

due to severe galling to the stem

and bushings.

The

licensee

could not determine

the root cause of the failure of the flow

path through

I-HARV-451.

Since the valve opened

as expected

during the

event,

the fault appeared

to be intermittent blockage in the line

upstream of the blender.

Boric acid flow was attained

through this path

after the transient

was over.

The System Engineer walked

down the

affected piping and did not detect

any indication of faulty heat tape.

The System

Engineer will continue.to monitor system

performance

as part

of his normal responsibilities.

19

No violations, deviations,

unresolved,

or inspector followup items were

identified.

Mana ement Interview

The inspectors

met with licensee

representatives

denoted

in paragraph

1

on August 4,

1993, to discuss

the scope

and findings of the inspection.

In addition, the inspector also discussed

the likely informational

content of the inspection report with regard to documents

or processes

reviewed

by the inspector during the inspection.

The licensee

did not

identify any such

documents

or processes

as proprietary.

The licensee

disagreed

with the inspector that the Unit 2 East

MDAFW

pump was inoperable with the failed thrust bearings

on April 20,

1993.

They believed that the

MDAFW pump would have performed satisfactorily to

fulfillits design functions.

20

k'