ML17333A893

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Insp Repts 50-315/97-04 & 50-316/97-04 on 970215-0329. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
ML17333A893
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 05/06/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17333A889 List:
References
50-315-97-04, 50-315-97-4, 50-316-97-04, 50-316-97-4, NUDOCS 9705150312
Download: ML17333A893 (50)


See also: IR 05000315/1997004

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

50-315, 50-316

License Nos:

DPR-58, DPR-74

Report No:

50-31 5/97004; 50-31 6/97004

Licensee:

Indiana Michigan Power Company

Facility:

Donald C. Cook Nuclear Generating Plant

Location:

1 Cook Place

Bridgman, Ml 49106

Dates:

February 15, 1997 - March 29, 1997

Inspectors:

B. L. Bartlett, Senior Resident Inspector

B. J. Fuller, Resident Inspector

J. D. Maynen, Resident Inspector

Approved by:

Bruce L. Burgess, Chief

Reactor Projects Branch 6

9705%50312

970506

PDR

ADOCK 05000315

8

PDR

Executive Summary

D. C, Cook Units

1 and 2

NRC Inspection Report 50-315/97004, 50-316/97004

This inspection included aspects of licensee operations, maintenance,

engineering, and

plant support.

The report covers a 6-week period of resident inspection and includes the

follow-up to issues identified during previous inspection reports.

~rien

Licensed operators failed to include all control room instrumentation in their routine

scans of the control room panels.

This Ied to three of four over power recorder

pens being inoperable for four to seven days until identified by the NRC inspectors.

In addition, the operating crews and ILC were aware of the poor operating history

of the recorder pens yet action was not taken until prompted by the NRC

inspectors.

The failure to have chart recorders capable of recording overpower

transients was a deviation from a commitment in the UFSAR. Section 01.2

The Unit 1 down power and shutdown to enter the Unit 1 refueling outage was

performed in a professional and appropriate manner.

Effective command and

control was maintained by the operating staff. Section 01.3

An inadequate

procedure was used during a reactor trip recovery activity and

resulted in an inadvertent ESF actuation when the TDAFP was reset too close to

the SG low low level setpoint.

This was considered

an example of a violation.

The failure to implement adequate corrective actions to prevent the reoccurrence of

a failure of a Taylor Mod 30 controller was an example of a violation. Section 01.4

The licensee took immediate, comprehensive

corrective action to restore and

maintain the flowpath for water to reach the recirculation sump.

The licensee's

safety assessment

had shown that in the event of a loss of coolant accident while

shutdown, the sump was important to maintaining the unit in a safe shutdown

condition.

Section 01.5

The startup following the Unit 2 unplanned reactor trip proceeded well. The

inspectors noted effective command and control was maintained, and that

communications were excellent during the pre-job briefing and during the approach

to criticality. In addition, there was a low, manageable

number of personnel

present and control room distractions were minimized.

Section 01.6

M i

Plastic shields installed in the control room in order to keep snow out of the backs

of the control panels were not recognized as a temporary modification.

Even

though the licensee has made significant progress in the improvement of temporary

modifications, unrecognized temporary modifications may remain installed in the

plant. The installation of a temporary modification without the proper evaluations

was a violation. Section M2.1

~

A poorly worded TS surveillance requirement concerning the turbine driven auxiliary

feedwater pump (TDAFWP) was identified by the inspectors.

The licensee

recognized these problems and agreed to initiate the appropriate TS change

requests.

Section M3.1

The inspectors noted that the licensee',s procedure for testing the containment

evacuation alarm was inadequ'ate, the coverage of the horns inside containment

was inadequate,

and that when informed. of an inoperable horn that the Unit

Supervisor failed to initiate an action request.

In addition, the procedures covering

use of the containment evacuation alarm were inconsistent in requiring a plant

announcement.

Section M3.2

The licensee failed to adequately remove the spiral wound gasket material from the

RHR system following the second spiral wound gasket failure on 1-IRV-311,

identified on January 31, 1996, resulting in this material entering several

components

in the RHR system and also entering the reactor coolant system.

This

was considered

a violation. The failure to address

ECCS check valve operability is

an unresolved item. Section M4.1

~

The failure to install the cage spacers after refurbishing 1-QRV-114 and 1-NRV-163

were two cases of contractor personnel failing to follow procedure.

These were

two examples of a violation. Section M4.2

~

The technicians working within the FMEZ next to the refueling cavity did not

consistently apply the practices established to keep foreign material out of open

systems.

The failure to follow FME procedures was a violation. Section M4.3

~En ini~rin

The licensee conservatively expanded the scope of their inspection to Unit 2 after

identifying cracks in Unit 1 flood-up tubes.

Following the identification of flaws in

two Unit 2 flood up tubes, the licensee declared, the affected equipment inoperable

and made a required report to the NRC.

The environmental qualification of equipment associated with cracked flood-up

tubes was an unresolved issue.

A violation was identified when the licensee failed

to make a timely report to the NRC concerning equipment that had been identified

as inoperable due to the cracked flood up tubes in Unit 1. Section E2.1

~

The inspectors raised questions concerning the licensee's testing configuration for

the coritrol room emergency ventilation system.

After promptly performing a test

to verify there were no operability concerns the licensee initiated a procedure

change request in order to better control the test configuration.

Section E3.1

Pl n

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Routine observations were made by inspectors with no discrepancies

noted.

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Unit 1 main'ransformer temperature limitations forced operation of the Unit at 92 percent

to 94.7 percent power during the beginning of the inspection period.

On February 15,

1997, power was reduced as part of the "coastdown" into the refueling outage.

On

February 27, 1997, reactor power was stabilized at 51% in order to perform steam

generator code safety valve testing.

On March 1, 1997, the Unit was shutdown and

entered the refueling outage.

Unit 2 was at full power at the beginning of the inspection period.

On February 8, 1997,

power was reduced to 55 percent in order to perform corrective maintenance

on the East

Main Feedpump.

The Unit was returned to full power on February 17, 1997.

On March

11, 1997, the Unit tripped from full power when a feedwater regulating valve failed

closed.

The valve failed closed when its controller failed. The Unit was returned to full

power on March 18, 1997, following repairs to various controllers and the replacement of

a circulating water pump discharge valve.

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01

Conduct of Operations

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Using Inspection Procedure 71707, the inspectors conducted frequent reviews of

ongoing plant operations.

The conduct of operational activity that was observed

was generally good.

Specific events and noteworthy observations

are detailed in

the sections below.

012

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During routine control room observations the inspectors identified that three of four

nuclear instrumentation power range recorders were malfunctioning.

The

inspectors performed routine follow-up to the licensed operators'ailure to identify

the malfunctioning recorders.

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During routine control room observations

on February 25, 1997, the inspectors

observed that the recorder pens recording power level for nuclear instrumentation

power range channels N-41, N-42, and N-43 were not accurate.

The four nuclear

instruments were recorded on two chart recorders.

Each of the two chart recorders

had a range of from 0 percent to 200 percent in order to record any large scale

overpower excursions.

The inspectors observed that on the two chart recorders

the pens were showing the values given below:

N

l

0

Nuclear Instrument Channel

Chart Recorder Reading

Reactor Power Level

N-41

Recorder 1-SG-13

N-42

Recorder 1-SG-14

N-43

Recorder 1-SG-13

N-44

Recorder 1-SG-14

92%

86%

'92%

78%

78%

78%

78%

78%

The inspectors questioned the two reactor operators

(ROs) and determined they

were not aware that the three overpower nuclear instruments were showing

incorrect values.

I

Unit 1 reactor power was being reduced. at a rate of 2 percent per day as part. of

the end of cycle power reduction., This meant that the meters stuck on 92 percent

had been inoperable for approximately one week and that the meter stuck on 86

percent had been inoperable for approximately four days.

Interviews with randomly selected

ROs revealed that,the chart recorders had a

history of sticking.

Chart recorder 1-SG-13 had an action request (AR) written

against it since December 2, 1996, saying that the pens were sticking. The AR

was wntten by IRC personnel following a surveillance test.

Following the inspectors'.identification of the sticking recorder pens, the RO opened

the recorder covers and reset them to the correct, power level.

In addition, the RO

wrote an AR for the stuck recorder that did not already have an existing AR.

UFSAR Chapter 7, Instrumentation and Control, section 7.4.1 stated, "The power

range channels are capable of recording overpower excursions up to 200 percent of

full power." Even though there were other meters which monitored overpower

transients up to 200 percent of full power; these were the only pens which would

record postulated overpower transients.

The inspectors determined that:

H

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The reactor operators, unit supe'rvisors,

and shift supervisors were not

including these recorders in their scans of the control boards.

~

The chart re'corders had a history of operability problems.

Licensee

personnel informed the inspectors that since June of 1991, the failure rate

was such that the percent pen unavailability average was 14.9 percent.

The

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'noperability of the recorders was a deviation from the licensee's

UFSAR

commitment to have chart recorders capable of recording overpower

transients (50-315/97004-05

(DRP)).

The low reliability/availability rate combined with the lack of use for

operations or surveillances had apparently led to the licensed operators

giving these pens a negligible "scan rate."

No operations or surveillance procedures

used these chart recorders.

When

changing power levels the operators used recorders/meters

with a fine scale,

so these recorders were not used.

Corrective actions by the licensee following the identification of this issue by the

inspectors consisted of:

~

Informing the operating crews to include these chart recorders in their scans

of the control room instrumentation.

Instructing the operating crews to scan the entire control room and to ensure

that all degraded instrumentation was identified and corrected in a timely

manner.

Performing a modification to remove these chart recorders and to record

these channels on other chart recorders.

This modification had been in the

planning stages prior to the inspectors'oncerns

being identified. This

modification was in progress on Unit 1 at the end of the report period and

was being planned for Unit 2 during its next refueling outage.

Performing a one time special review of control room instrumentation to

ensure that all degraded instruments were identified and were scheduled to

be repaired on a timely basis.

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Licensed operators failed to include all control room instrumentation in their routine

scans of the control room panels.

This led to three of four over power recorder

pens being inoperable for four to seven days until identified by the NRC inspectors.

In addition, the operating crews and l&C were aware of the poor operating history

of the recorder pens yet action was not taken until prompted by the NRC

inspectors.

The failure to have chart recorders capable of recording overpower

transients was a deviation from a commitment in the UFSAR.

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Auxiliary Power Transfer Test Surveillance

Procedure,

Revision 7

The inspectors observed licensee personnel perform the shutdown of Unit 1. The

shutdown was performed to enter the Spring 1997 refueling outage.

Licensee

procedures

observed included:

01-OHP-4030.STP.026

~

'1-OHP 4021.055.004

Removing a Main Feedpump and Feedpump

Turbine From Service, Revision 6

01-OHP 4021.001.003

Power Reduction, Revision 12

"" 01-OHP 4021.002.005

RCS Draining, Revision 20, to half loop

conditions

"" 01-OHP 4021.001.004

Plant Shutdown from Hot Standby to Cold

Shutdown, Revision 29

b.

On the evening of March 1, 1997, the inspectors observed the licensee perform a

routine shutdown from power to enter a refueling outage.

The inspectors observed

that effective command and control was maintained by the Unit Supervisor and the

Shift Supervisor.

This command and control was challenged; however, by the

relatively large number of personnel present to support the shutdown.

At various

times there were between 25 and 35 operators, lhC technicians, managers,

and

other personnel in the Unit 1 control room.

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-The Unit 1 down power and shutdown to enter the Unit 1 refueling outage was

performed in a professional and appropriate manner.

Effective command and

control was maintained by the operating staff.

01.4

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On March 11, 1997, Unit 2 tripped from 100.percent power as a result of a failed

feed regulating valve corItroller. This caused

a low level in its associated

steam

generator (S/G). All equipment functioned as expected with the following

exceptions:

the main turbine turning gear motor failed, a main feedwater pump

8

turning gear failed to engage,

and the turbine driven auxiliary feedwater pump

(TDAFWP) experienced

an inadvertent ESF actuation.

The inspectors reviewed the

licensee's response to the trip.

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The Unit 2 reactor trip was initiated by low steam generator level coincident with a

steam flow/feed flow mismatch, as a result of failure of the controller for feed

regulating valve, 1-FRV-210.

The Balance of Plant (BOP) operator, in preparation for a surveillance on steam

generator number

1 level instrument, attempted to place the controller in manual

mode.

The controller face went blank when he touched the face plate.

The failure

of the controller resulted in the feed regulating valve going shut:

The controller, a Taylor Mod 30, was known to be susceptible to electrostatic

discharge effects (see NRC.inspection report 50-315/316-96004

(DRP)).

Beginning in March 1996, problems with electrostatic discharge sensitivity of

Taylor Mod 30 controllers were identified as a result of a controller failure leading to

8 Unit 1 reactor trip. Four other controllers in Units

1 and 2 exhibited similar

sensitivity.

Failure of a controller'in Unit 1 caused

a halt in unit power escalation in

June 1996.

Determination of a root cause was undertaken.

Corrective actions

were enacted to prevent recurrence of the controller failure. The corrective actions

included: increasing control room humidity, instructing operators to ground

themselves

prior to operation of Taylor Mod 30 controllers, installation of static

grounding mats, verification that control room carpeting was anti-static, installation

of ground wires and verifying connection of static drain clips in the controllers.

Some controllers, including the controller for 1-FRV-210, had not yet been modified

to the optimal configuration, because

of the operating status of the unit.

The BOP operator had taken'the required precautions,(grounding

himself against the

control panel, and standing on the static grounding mat), but the controller

exhibited the characteristic electrostatic discharge failure. A violation of Criteria

XVI of 10 CFR Part 50 Appendix B was identified in that inadequate corrective

actions to prevent the reoccurrence of controller failures were taken by the licensee

(50-31 6/97004-02a

(DRP)).

During the post-trip shutdown, the licensee replaced the controller with a controller

modified to be less susceptible to the'effects of electrostatic discharge.

Additional

corrective actions included requiring operators to wear static control heel grounding

assemblies

on their shoes, procurement of low static electricity chairs for the

control room cr'ew,.and directing the operators to ground themselves to bare metal

prior'to touching the controller

faceplate.'he

operators secured the TDAFWP, as allowed by 02-OHP 4023.ES-0.1,

Reactor

Trip Response, to minimize the cooldown of the reactor coolant system.

Steam

generator (S/G) level oscillations near the low-low level TDAFWP start setpoint

generated

a second start signal as S/G levels were being increased during post-trip

9

0

recovery actions.

Procedure

ES-0.1 did not contain guidance for the operators

concerning where to maintain S/G levels in order to avoid a restart of the TDAFWP.

The licensee considered this to be an operator knowledge item, which was covered

during operator training. The quality of the procedure ES-0.1 was not of a type

appropriate to the level of knowledge of the operator. This was a violation of 10 CFR Part 50, Appendix 8, Criterion V (50-315/316/97004-01a

(DRP)).

After the main turbine tripped, the motor for the main turbine. turning gear failed.

The cause for the failure was worn/damaged

bearings which allowed the rotor to

drop down in contact with the stator causing arcing and smoke.

The motor was

replaced and the turbine was placed on the turning gear.

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An inadequate

procedure was used during a reactor trip recovery activity and

resulted in an inadvertent ESF actuation when the TDAFP was reset too close to

the SG low low level setpoint,

This was considered

a violation.

The failure to implement adequate

corrective actions to prevent the recurrence of a

failure of a'Taylor Mod 30 controller was a violation.

01.5

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On March 11, 1997, the licensee stopped fuel movement operations due to the lack

of a flow path to the emergency core cooling system (ECCS) recirculation sump in

lower containment.

The inspectors performed routine followup to the.licensee's

resolution of the issue

as the inspectors had identified the debris at about the same time as licensee

management.

In addition to the followup, the inspectors reviewed licensee

procedure, OHI-4100,'Outage Technical Advisor Risk Assessment,

Revision 0.

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During a routine containment tour, the inspectors identified a large accumulation of

bagged material in the area directly in front of the grates at the entrance to the

ECCS recirculation sump in lower containment.

The materials consisted of

scaffolding, S/G'eddy current inspection equipment and a large amount of bagged

insulation removed in preparation for S/G inspections.

The licensee had

independently identified that transient material had;been allowed to accumulate and

was in the process of taking action to.remove the material.

'I

OHI-4100 Attachment 3, Inventory - IVlode 68, required maintaining one loop of

residu'al heat removal (RHR) operable with a flowpath from the reactor coolant

system (RCS) and recirculation sump.

As the material in front of the recirculation

sump screens could block water from reaching the sump in the event of a refueling

10

cavity seal failure, the licensee conservatively declared the recirculation sump

inoperable..With the sump inoperable, the licensee entered

a red path for shutdown

risk, which by licensee procedures required immediate compensatory'action.

Core alterations were suspended

in accordance with OHI-4100 while actions were

taken to restore the flowpath. The actions included a concentrated

cleanup effort

which involved restowing and securing items that would float. Plant Manager'

Standing Order (PMSO) 179, Transient Materials in Containment While the Unit is

Shutdown, Revision O,.was issued to provide guidance for control of transient

materials in containment during reactor shutdown conditions.

Core alterations were

restarted after completion of the cleanup.

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The licensee took immediate, comprehensive

corrective action to restore and

maintain the flowpath for water to reach the recirculation sump.

The licensee's

safety assessment

had shown that in the event of a loss of coolant accident while

shutdown, the sump was important to maintaining the unit in a safe

shutdown'ondition.

01.6

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On March. 16, 1997, the licensee started up the Unit 2 reactor following the reactor

trip. The inspectors observed all or part of the following activities and procedures:

~ ""02-OHP 4021.001.002

- Reactor Start-Up, Revision 18

~ ""02-OHP 4021,001.006

1

~ ""02-OHP 4021.050.001

Power Escalation, Revision 15

Turbine Generator Normal Startup and

Operation, Revision 9

~ 02-OHP 4021.01 3.005

~ 02-OHP 4024.210

Visual Audio Count Rate Channel (NIS),

Revision 4

Annunciator ¹210 Response:

Flux Rod,

. Revision 6

~ ""12 EHP 6040 PER.370

Estimation of Critical Position, Revision

1

~ Technical Data. Book

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The inspectors observed that licensed reactor operators complied w'ith their

procedures and maintained effective command and control during the startup.

The

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inspectors also observed that the operators, were attentive during their pre-job brief

before the pull to criticality. Comments made to the operators by a member of

operations management

concerning repeat backs resulted in significant increase in

the us'e of three point communications.

During a review of the startup procedures

in use, the inspectors'oted

that alarm response

procedure 02-OHP 4024.210

Revision 6, CS-2, Drop 29, listed a deleted technical specification as a reference;

however, this did not affect the actions required by the procedure.

The, unit

supervisor was notified of the discrepancy,

and the procedure was revised.

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The startup following the Unit 2 unplanned reactor trip proceeded well. The

inspectors noted effe'ctive command and control was maintained, communications

were excellent during the pre-job briefing and during the approach to criticality. In

addition, there was a low, manageable

number of personnel present and control

room distractions were minimized.

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Conduct of Maintenance

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Refueling Surveillance, Revision 14

Portions of the following maintenance

job orders, action requests,

and surveillance

activities were observed or reviewed by the inspectors:

~ 01-0HP 4030.STP.037

~ ""12-EHP 4030.STP.229

~ C0040106

~ 01-OHP-4030.STP.026

.

Auxiliary Power Transfer Test Surveillance

Procedure,

Revision 7

Control Room Emergency Ventilation System,

Revision 2

~ "" 01-EHP 4030 STP.2'17B

Diesel Generator

1 AB Load Sequencing

and ESF

Testing, Revision. 3

Fisher V100 Vee-Ball Control Valve

Maintenance,

on 1-IRV-310, using "," 12 MHP

5021.001.102

~

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~ R0022763

Foreign Material Exclusion (FME), inspection of

.

~ Unit 1 Refueling Water Storage Tank using 12

PMP 2220.001.001

12

~ R0049426

Pressurizer

Pressure Transmitter Calibration,

using "" 01 IHP 6030.IMP.363

~ R0049473

Leak test'of valve 1-ICM-129; using "" 12 EHP

4030.STP.242

~ R0051820

Darling S-350W-SC Swing Check Valve

Maintenance,

on 1-Sl-166-02 using "" 12 MHP

5021.001

~ 1 1 6

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The inspectors found'the work performed under these activities to be generally of

good quality with procedures

present and in use.

Comments for specific work

activities are discussed

in further detail below.

M2

Maintenance and IVlaterlaI Condition of Facilities and Equipment

M21

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On March 6, 1997, at 3:30 a.m., licensee personnel identified a plexiglass.

rain/snow cover located just below the return air duct to the Unit 2 control room.

This cover had the potential to affect the operability of the Unit 2 control room

emergency ventilation system (CREVS). 'Both trains of the Unit 2 CREVS were

declared inoperable and TS 3.0.3 was entered.

Shortly afterwards the cover was

removed and TS 3.0.3 was exited.

The inspectors performed follow up to the

event.

Licensee documents reviewed, included:

.

~

Condition Report 97-0590

~

Plant Managers. Procedure,

PMP 5020.RTM.001, Revision 0, Restraint of

Transient Material.

~

UFSAR 9.10, Control 'Room, Ve'ntilation System

~

Drawing OP-2-5149-29, Flow Diagram Control Room Ventilation Unit No. 2

~

PMP 5040.MOD.001, Revision 5, Temporary Modification

~

Action Requests C0034756, C0034755, R064539, R064538

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During the routine testing of the Unit 1 engineered safety features actuation

system, the CREVS for both Unit 1 and Unit 2 would actuate as designed.

During

one of the Unit 1 tests, the Unit 2 control room operators observed

a plexiglass

rain/snow cover causing pressure fluctuations in the Unit 2 control room. The

operators observed the cover moving up, partially blocking the return air duct and

then falling away.

As blockage of the return air duct could interfere with the proper operation of the

CREVS, the. operators declared one train of CREVS inoperable.

Shortly thereafter,

discussions with a licensing engineer determined that since the duct was common

to both trains of CREVS, calling both trains of CREVS inoperable would be

appropriate and entry should be made into TS 3.0.3.

The need to enter TS 3.0.3

was.recognized

at 4:10 a.m., the plastic shields were removed, and TS 3.0.3 was

exited at 4:35 a.m.

As required by 10 CFR 50.72 the licensee made a one hour report to. the NRC for

the discovery of a condition outside the design basis for Unit 2. A plastic shield

was also. installed under the Unit 1 return air duct, however it had been restrained

differently than the Unit 2 plastic shield.

Thus, the Unit 1 plastic shield did not

interfere with the proper operation of the Unit 1 CREVS.

The licensee's investigation showed that the shields were installed to prevent snow

from entering the backs of the control room panels.

At the time of installation,

some licensee personnel questioned whether the plastic shields were temporary

modifications.

A review resulted in a licensee determination. that the plastic shields

were not temporary modifications but were housekeeping

items. This

determination was in error as the plastic shields could interfere with the proper

operation of the CREVS.

Even though the plastic shields were not deemed to be temporary modifications,

the personnel who wrote the work instructions recognized the need to restrain the

shields.

Accordirigly, the job orders contained work instructions to fasten the

plastic shields in a manner to prevent them from being sucked up against the inlet

ducts.

This was done for Unit 1 however, the Unit 2 plastic shield was not

properly restrained,

This licensee change to the facility as described in the UFSAR without following

plant procedures governing temporary modifications and without a required written

safety evaluation, which provides the bases for the determination that the change

does not involve an unreviewed safety question is a violation of 10 CFR Part 50.59

(50-31 5/31 6-97004-04(DRP)).

Temporary modifications have been the subject of previous NRC inspection reports.

Reports 50-315/316-96002

and 96014 discussed

examples of poor safety

evaluations.

Report 50-315/316-96011

discussed

a violation for implementing a

change to the facility but not recognizing that it was a temporary modification.'n

14

response to the issues discussed

above, the licensee has spent considerable effort

in training personnel in the understanding

of and the proper 'use of temporary

modifications.

Since these corrective actions have been implemented, the

inspectors have noted a marked increase in the quality and use of temporary

modifications.

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Plastic shields installed in the control room in order to keep snow.out of the backs

of the control panels were not recognized as a temporary modification.

Even

though the licensee has made significant progress in the improvement of temporary

modifications, unrecognized temporary modifications may remain installed in the

plant.

The installation of a temporary modification without the proper evaluations

was a violation.

M3

Maintenance Procedures

and Documentation

M3.1

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ions Concernin

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TDAFWP

B

h Uni

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In

in

27

During a routine review of licensee surveillance tests the insp'actors questioned

whether the TDAFWPs were being tested in accordance with technical specification

requirements.

The inspectors reviewed the licensing basis of the TDAFWPs,

reviewed completed surveillance tests, interviewed licensee personnel,

and held

telephone conferences with NRR p'ersonnel in order to evaluate the licensee's

surveillance procedures for verifying TDAFWP operability.

Documents reviewed by the inspectors included:

~

Design Basis. Document DB-12-AFW, Auxiliary Feedwater System Design

Basis Document

""01(2)-OHP 4030.STP.017T,

Turbine Driven Auxiliary Feedwater System

Test, Revisions 9, 10, and 11.

~

Licensee Technical Specification Clarification 61, Auxiliary Feedwater

System Surveillance Requirements,

dated April 21, 1994

'I

~

Technical Specification Amendments 203 to license number DPR-58 and

188 to license number DPR-74

~

UFSAR'Chapters

14.'1, 14.2; 14.3, and 10.5

~

Licensee letter AEP:NRC:0969AM, Donald C. Cook Nuclear Plant - Unit 1

Pump Inservice Test Program

1.5

rv

ion

nd Findin

Technical Specification (TS) surveillance requirement 4.7.1.2.b stated, in part,

"Each auxiliary feedwater pump shall be demonstrated

OPERABLE when tested

pursuant to Specification 4.0.5 by:... Verifying that the turbine driven'auxiliary

feedwater pumps'eveloped

head at the test flow point is greater than or equal to

the re'quired developed head. when the secondary steam supply pressure

is greater

than 310 psig.

The provisions of Specification 4.0.4 are not applicable for entry

into MODE 3."

The licensee routinely performed the surveillance test at a secohdary side pressure

of between 500 psig and 900 psig.

The inspector's concerns centered

on the

question of whether the licensee was required to perform the surveillance test at

just greater than 310 psig (e.g., 311 psig).

The licensee informed the inspectors that their interpretation of the TS surveillance

requirement differed in that they thought the test could be performed at any

pressure greater than 310 psig.

Since 500 to 900 psig was greater than 310 psig,

the licensee thought that the test was being properly performed.

When questioned

as to the basis for greater than 310 psig the licensee performed a review of the

license basis and determined that there appeared to be no technical justification for

the specific value of 310 psig. The licensee also stated that in 1994, they had

attempted to run the surveillance at 310 psig, but the pump was not capable of full

rated speed, flow, or discharge pressure at such a low secondary side pressure.

The TS surveillance requirement had been changed

on October 17, 1995, by

amendment 203 to the Unit 1 TSs.'he inspectors review of the previous TS

surveillance, requirement identified that it did require a pump discharge pressure

and

flow rate that the TDAFWP was incapable of while at a secondary side pressure of

greater than 310 psig. The licensee disagreed with the inspector's conclusions and

stated that the TDAFWP was never expected to perform at a high discharge

pressure

and flow rate at low secondary side pressures.

'I

NRC,internal discussions confirmed the inspectors'inding that the previous TS

requirements were clear and that the TDAFWP had been required to perform at the

higher rated discharge pressure

arid flows. However, the inspectors review of the

design basis and. licensing basis of the TDAFWP confirmed the licensee's statement

that the TDAFWPs were not taken credit for in any accident analysis at the

secondary side pressure of 310 psig. Therefore, even though the surveillance

procedures

did not meet the previous TS surveillance requirement they did comply

with the present TS surveillance requirements

and at all times had complied with

the licensing basis.

The inspectors identified several other licensee documents which appeared to show

the TDAFWP'was capable of high discharge'pressures

and flows at a low

secondary side pressure.

The licensee stated th'at these statements

were in error

and would be corrected.

16

The ins'pectors completed their assessment

of this issue and had no operability

concerns with the present surveillance*requirements.

The licensee stated that a TS

change request would be submitted to clarify the existing surveillance requirements.

C.

n

i'

A poorl'y worded TS surveillance requirement concerning the turbine driven 'auxiliary "

feedwater pump (TDAFWP) was identified by the inspectors.

The licensee

recognized these problems and agreed to initiate the appropriate TS change

requests.

M4

Maintenance Staff Knowledge and Performance

M4.1

ir IW

n

k

M

ri iin h

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a

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r

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n

On March.12, 1997, during core off-load, the licensee found spiral wound gasket

material on the bottom nozzles of three fuel assemblies.

Additional material was

found on the lower core plate.

During inspections of the emergency core cooling

systems

(ECCS), spiral wound gasket material was found in accumulator discharge

check valves 1-Sl-166-2 and 1-SI-166-3.

The loop 4 safety injection (Sl) and

residual heat removal (RHR) cold leg check valve, 1-SI-161-L4, also contained a

piece of spiral wound gasket material.

The inspectors followed the licensee's

investigation into the possible sources of the material, the scope of the problem,

and the corrective actions.

In addition, the following documents were reviewed:

~ C0040106

"" 12 MHP'5021;001.102,

Fisher V100 Vee-Ball Control

Valve Maintenance, Revisiori 1, on 1-IRV-310

~ R0022763

12 PMP 2220.001.001,

Foreign Material Exclusion (FME),

Revision 0, inspection of Unit 1 Refueling Water Storage Tank

I

~ R0051820

"" 12 MHP 5021.001.116,

Darling S;350W-SC Swing Check

Valve Maintenance,

Revision 1, on 1-SI-166-02

~

NRC Inspection Report 50-315/316-95010

b.

~

NRC Inspection Report 50-315/316-96002

i n

n

Fin in

The licensee's investigation identified several possible sources of the spiral wound

gasket material which was found in the ECCS'and reactor vessel.

Residual heat

removal (RHR) heat exchanger outlet valves, 1-IRV-310 and 1-IRV-320, each

contained two spiral wound gaskets.

A similar valve, the RHR heat exchange'r

bypass valve, 1-IRV-311, had two earlier spiral wound gasket failures, but its

1'7

gaskets were replaced with compressed

fiber gaskets following the second failure.

These failures were discussed

in NRC Inspection Reports 50-315/316-95010

and

50-315/316-96002,

respectively.

Additionally, the spiral wound gaskets were

found separated

and missing some material on'-QRV-114, the reactor coolant

excess letdown to excess letdown heat exchanger shutoff valve, and 1-NRV-163,

the pressurizer spray control valve.

Both 1-IRV-310 and 1-IRV-320 were inspected,

and approximately 21 total feet of

spiral wound gasket material was missing from these two valves.

Additionally, the

licensee speculated that some spiral wound gasket material may have remained, in

the RHR system from the earlier gasket failures of 1-IRV-311. The loop 4 Sl and

RHR cold leg check valve, 1-SI-161-L4, failed an "as found" leak rate test in Mode

4. Subsequent

inspection of this valve and two other check valves, 1-SI-166-2 and

1-SI-166-3, accumulator discharge check valves, revealed spiral wound gasket

debris in all three. valves.

Additional inspections for spiral wound gasket material

were performed on the refueling water storage tank (RWST), the ECCS suction

header from the RWST, and the lower reactor vessel.

The lower reactor vessel was

found to contain some spiral wound gasket material, but no spiral wound gasket

material was found in either the RWST or the ECCS suction header.'he

failure to

adequately remove the spiral wound gasket material from the RHR system and RCS

was a significant condition adverse to quality in which corrective action was not

taken to prevent recurrence.

This failure was a violation of 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action (50-315/316/97004-02b

(DRP)).

The licensee concluded that any gasket material from 1-QRV-114 was captured in

the excess letdown heat exchanger and did not enter the RCS.

The spiral wound

gasket material missing from 1-NRV-163 was determined to have remained either in

the pressurizer spray line or in the pressurizer due to low flow rates and had not

entered the reactor vessel.

The gasket failures of 1-QRV-114 and 1-NRV-163 are

discussed

in section M4.2;

An operability evaluation performed after the second failure of the gasket on 1-IRV-

311 determined that the ECCS systems.remafned

operable, even with some

material left in the system.

This operability evaluation discussed

pump operability

and fuel damage potential from spiral wound gasket material; however, it did not

address

ECCS valve operability. The failure to address

ECCS valve operability is an

Unresolved Item (50-315/97004-06

(DRP)) pending the'esults of the ECCS testing

and evaluation of check valve operability.

/

/

k

The licensee conducted flushes of the RHR 'and connected

ECCS systems in order

to dislodge any spiral wound gasket material in the piping and collect it in the

defueled reactor vessel for removal.

The licensee planned to perform an additional

test of the ECgS pressure isolation valves prior to returning Unit 1 to full power.

'I

The licensee failed to adequately'remove

the spiral wound gasket material from the

RHR system following the second spiral wound'gasket failure on 1-IRV-311,

18

h'l,

'f

/

II

identified on January 31, 1996, resulting in this material entering several

components in the RHR system and also entering the reactor coolant system.

This

failure constituted a violation.

The failure to address check valve operability is an.unresolve'd

item pending the

results of the ECCS testing and evaluation of check valve operability.

M4 2

i

in

r

n 1-NRV-1

n

1- RV-114

i

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27

On March.11, 1997, during refurbishment of valve 1-QRV-114, the reactor coolant

excess letdown to excess letdown heat exchanger shutoff valve, the spiral wound

cage gasket was found to be separated

and broken in pieces.

On March 13, 1997,

during disassembly for corrective maintenance

on valve 1-NRV-163, the pressurizer

spray control valve, the spiral wound cage gasket was found to be damaged with

some material missing.

Both valves were found to be missing cage spacers,

an

internal valve part designed, in part, to compress the cage gasket. The evaluation of

the missing gasket material is discussed

above in section M4.1. The inspectors

followed the licensee's corrective actions and reviewed the following documents:

~ ""12 MHP 5021.001.126

Copes-Vulcan Bellows Seal Control Valve

Maintenance,,Revision

1

~ ""12 MHP 5021.001.057

.

Copes-Vulcan Isolation Valve Maintenance,

Revision

1

~ R0020879

~ R0020974

Refurbishment of 1-NRV-163 during the Unit 1

1995.refueling outage

Refurbishment of 1-QRV-114 during the Unit 1

1994 refueling outage

b.

b

rv

i n

n

Fin in

The licensee's investigation into the missing cage spacer identified previous

refurbishments in 1994 for 1-QRV-114 and in 1995 for 1-NRV-1'63 as the most

likely times when the cage spacer was not installed.

The licensee stated that the

missing cage spacer was the most likely reason that 1-NRV-163 was inoperable

during all of the most recent fuel cycle. The licensee also stated that the missing

cage spacer on 1-QRV-114 was got noticed earlier because the valve was

infrequently operated.

Step 7.3.2 of ""12 MHP 5021.001.126,

Copes-Vulcan Bellows Seal Control Valve

Maintenance,

Revision 1, required tha't the cage spacer be installed during valve

reassembly.

Step 6.3.2 of "" 1.2 MHP 5021.001.057,

Copes-Vulcan Isolation

Valve Maintenance, also required that the cage spacer be installed during valve

19

t

reassembly.

Job Order Activity(JOA) R0020879 required the use of "" 12 MHP

5021.001.126,

and JOA R0020974 required the use of ""12 MHP 5021.001.057.

In both cases,

a valve contractor performed the maintenance work. The licensee

speculated that the contract workers may not have been familiar with Copes-Vulcan

valves.

The failure to install the cage spacers after refurbishing'-QRV-114 and 1-

NRV-163 were two cases of contractor personnel failing to follow procedure.

The

failure to follow procedure "" 12 MHP 5021.001.057 was one example of a

violation (50-315/97004-01c

(DRP)). The failure to follow procedure "" 12 MHP

5021.001.126 was another example of a violation (50-315/97004-01d

(DRP)).

For

the current refueling outage, the licensee used a different valve contractor than was

used dunng the earlier valve refurbishments.

The valves were reassembled,

all of the parts were installed, and.successfully

tested.

Two mock up Copes-Vulcan valves for training on proper disassembly and

reassembly. were obtained, and the licensee planned to revise the procedures to

more 'clearly state how these valves are to be reassembled.

nl in

The failure to install the cage spacers after refurbishing 1-QRV-114 and'1-NRV-163

were two examples of contractor personnel failing to follow procedure.

These

failures were two examples of a violation for failure to follow procedures..

M4.3

F rei nM

rialEx

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27

On March 23, 1997, during core barrel former bolt work in Unit 1 containment, the

inspectors observed contractor; personnel working in a foreign material exclusion

zone.

The contractors were'reparing

a camera for use in machining prior to

installation of:a new former bolt. After the inspectors left the area, they reviewed

the licensee's

procedures concerning FME and developed questions concerning

procedural adherence.

4

The inspectors reviewed licensee procedure 12 PMP.2220.001.001,

Foreign

Material Exclusion, Revision 0.

b.

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Fin in

The contractor'echnicians

prepared

a camera assembly by attaching two camera

modules and a light to a frame.

The work was performed in the area directly

adjacent to the refueling cavity near the location of the core barrel. This area had

been established

as a Foreign Material Exclusion Zone (FMEZ) in accordance with

PMI 2220, Foreign Material Exclusion.

12 PMP 2220.001.001,

Foreign Material Exclusion, step 5.2.7 required, in part,

that light hand tools be secured to the person using them by a lanyard or, tagline.

20

l

> II

The technicians used tools such as open end wrenches, needle-nosed

pliers and

lock-wire pliers to attach and captivate the assembly.

Each of the tools used had

an attached lanyard to secure the tool to the person.

In several instances, the

inspectors observed that the person using the tool did not attach the lanyard to his

arm while the tool was in use.

The inspector's subsequent

review of the licensee's

procedures

led to the questioning of this practice.

12 PMP 2220.001.001,

Foreign Material Exclusion, step 5.2.8 required in part, that

tools shall not be left laying loose within the FMEZ. All such tools shall be

.

restrained in an appropriate manner to prevent their introduction into any open

equipment or system.

The workers used the temporary bridge over the cavity.as

their tool laydown area.

When a tool was needed, the technician would obtain it

from the laydown are'a.

In several instances, the inspectors observed that tools

were left loose on the tarp covering the work area instead of returned to the

laydown area.

The inspector's subsequent

review of the licensee's

procedures

led

to also questioning this practice.

Licensee senior management

had performed tours of the turbine and auxiliary

buildings and upper and lower containment on each shift for the entire outage.

Their post-tour observations reviewed by'the inspectors, repeatedly stated that

worke'rs 'needed to clean up their areas.

Licensee management

informed the

inspectors that FME awareness

and compliance were not at the level desired.

These failures to follow procedures were an example of a violation of Technical Specification 6.8.1. (50-315/97004-.01b

(DRP)).

ncl

i n

The technicians working within the.FMEZ next to the refueling cavity did not

consistently apply the practices established to keep foreign material out of open

systems.

The failure to follow FME procedures was a violation.

E1

Conduct of Engineering

During the resident inspection activities, routine observations were conducted in the

areas of engineering using Inspection Procedure 37551.

Engineering personnel

were observed,to promptly respond to plant issues and to perform good

evaluations.

E2

Engineering Support of Facilities and Equipment

E2.1

D m

FI

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T

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ForEnvir nm

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The electrical penetrations for containment are located below the calculated

containment flood-up level following a loss of coolant accident (LOCA). Because

safety related cables had not been qualified for submergence

in water, they were

contained inside, stainless steel tubes which provide a barrier 'between the cable and

the water in containment during postulated post-accident conditions.

The licensee had previously identified some moisture in a flood-up tube.

As a

'esult,

the licensee had made an internal commitment to inspect about one-third of

the flood-up tubes in each unit during the. next three refueling outages.

Inspection

of flood-up tubes in Unit 1, was performed in March, 1997.

The inspection

revealed some'tubes with moisture but also identified cracks, flaws, or arc strikes

in nine tubes. 'hese flaws would provide a pathway for water to enter the tubes

following a postulated accident.

A condition report was initiated an'd the equipment

associated with these flood-up tubes was declared inoperable.

Licensee personnel

decided to evaluate the actual operability of Unit 1 equipment after performing an

immediate inspection of Unit 2 for flawed flood-up tubes.

The licensee conservatively decided to perform an inspection of flood-up tubes in

Unit 2,'instead of waiting for its next scheduled refueling outage.

Th'e inspection

was performed on March 23, 1997 and identified cracks in two tubes.'

condition

report was initiated and the equipm'ent associated with these flood-up tubes was

declared inoperable.

The power cable for containment recirculation fan 2-HV-CEQ-1 was located in one

of the cracked tubes.

Operability of the fan could not be guaranteed with water in

the tube after a LOCA. The licensee could not determine when the cracks

developed in the tube; but believed that the flaws in the tubes in both units h'ad

been present since the tubes were originally installed.

This meant that the flaws

had been present for many years and that the equipment had been inoperable for

many years.

The licensee made a one hour notification to the NRC in accordance with 10 CFR 50.72(b)(1)(ii)(A) for Unit 2 once this condition was identified. This was due to the

other train of containment recirculation fan being inoperable for maintenance

periodically in the past.

This meant that periodically both trains of recirculation fans

were inoperable.

This necessitated

an entry into TS 3.0.3 due to Unit 2 being in an

unanalyzed condition.

However, the licensee did not also report that the

inoperability of.2-HV-CEQ-1 exceeded the allowable outage time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as

specified in the action statement of Tet;hnical Specification 3.6.5.6, which also

would have placed the Unit in TS 3.0.3.. This failure to report under this additional

reporting requirement was minor in nature as the condition had already been

reported.

I

The inspectors also identified a violation,of 10 CFR 50.72(b)(2)(i) reportability

requirements for Unit 1. The licensee had the same information available for Unit 1

that was available'or Unit 2. Unit 2 equipment was declared inoperable and a

timely report to.the NRC was made, however, the licensee failed to make a timely

report for equipment identified after the inspection in Unit 1. The required report to

22

the NRC for Unit 1 was made at 1205 on March 27, 1997, following the inspectors

notification to the licensee that the failure to report was a violation (50-315/97004-

03'(DRP)).

Environmental qualification of equipment is necessary to ensure equipment will

perform its intended function when exposed to the environment- resulting from

postulated accidents.

Flood-up tubes perform an environmental qualification

function for electrical conductors not qualified for submergence

in water after a

LOCA. The licensee was still evaluating what flood-up tubes were affected and

what effects tube cracking had on e'quipment operability.

The environmental

qualification of equipment associated with cracked flood-up tubes is an unresolved

issue (50-31 5/31 6-97004-07(DRP)).

The licensee conservatively expanded the scope of their inspection to Unit 2 after

identifying cracks in Unit 1 flood-up tubes.

Following the identification of flaws in

two Unit 2 flood-up tubes, the licensee declared the affected equipment inoperable

and made a required report to the NRC.

The environmental qualification of.equipment associated with cracked flood-up

tubes was an unresolved'issue.

A violation was identified when the licensee failed

to make a timely report to the NRC concerning equipment that had been identified

as inoperable due to the cracked flood-up tubes in Unit 1.

E3

Engineering Procedures

and Documentation

E3.1

fi

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7

1

During the follow-up to a regional request for information the inspectors questioned

the control of the test boundary for the CREVS. The inspectors interviewed

licensee personnel and reviewed the licensee's testing procedure, ""12-EHP

4030.STP.229,

Revision 2, Control Room Emergency Ventilation System.

b.

rv

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Fin

During routine follow-up to a regional request for information the inspectors began

questioning the control of the test bouridary for the CREVS. The inspectors

observed that the status of the auxiliary building emergency exhaust system

(referred to as the AES fans) was not controlled during testing of the CREVS.

/

The control room pressure envelope included an opening to the control room cable

vault. The cable vault directly communicates with the auxiliary building ventilation

23

(

f 'I

t f

fl

system.

Even though the cable vault door was closed with a hatch, the inspectors

were concerned that enough air could flow between the rooms that the cable vault

could reduce the positive pressure

in the control room.

During routine plant operations only one AES fan is operating,'however,

following a

safety injection signal all AES fans operate.

This significantly changes the negative

pressure

in the auxiliary building which could reduce the positive pressure

in the

control room.

The licensee's

CREVS test procedure did not address the status of

the AES fans.

Thus during most testing, only'one AES fan was operating.

Following the inspectors'concerns

with the testing configuration, the licens'ee

performed a test of the.CREVS with all AES fans operating.

No difference could be

observed in the CREVS positive pressure between one AES fan and all AES fans

operating.

Subsequently,

the licensee initiated a procedure change to add the AES

fan.configuration to the testing procedure.

C.

nl in

The inspectors identified questions concerning the licensee's testing procedure for

the control room emergency ventilation system.

After promptly performing a test

to verify there were no operability concerns the licensee initiated a procedure

change request in order to better control the test configuration.

R1

Radiological Protection and Chemistry Controls (71750)

During the resident inspection activities, routine observations were conducted in the

areas of radiological proteqtion and chemistry controls using Inspection Procedure 71750.

No discrepancies

were noted.

S1

Conduct of Se'curity and Safeguards Activities (71750)

During normal resident. inspection activities, routine observations were conducted in

the areas of security and safeguards activities using Inspection Procedure 71750.

No discrepancies

were noted.

F1

X1

Control of Fire Protection Activities (71750)

During normal resident inspection activities, routine observations

w'ere conducted in

the area of fire protection activities using Inspection Procedure 71750.

No

discrepancies

were noted.

Exit Meeting

The inspectors presented the inspection results to members of the licensee

management at the conclusion of the inspection on March 29, 1997.

The licensee

requested additional information on several of the findings presented.

24

I

, There was considerable discussion between the NRC inspectors and the

licensee personnel present concerning Section M3.1, "Questions Concerning

Surveillance Tests of the Turbine Driven Auxiliary Feedwater Pump."

Specifically, licensee personnel disagreed with the NRC position that the

previous TS surveillance required that the TDAFWP be able to achieve 700

gpm at full discharge pressure with any secondary side steam pressure of

greater than 310 psig (e.g., 311 psig).

Licensee personnel stated that the

TDAFWPs were not required to. provide full flow at SG pressures

below 550

psig.

The inspectors stated that it was the NRC's position that the. previous

TS surveillance requirement did require full rated flow at 310 psig SG

pressure.

Licensee personnel stated that they would agree to disagree.

~

During discussions concerning the licensee's failure to report following the

identification of flawed Unit 1 flood-up tubes, the inspectors stated that it

appeared that the licensee had not recognized the need to make a report.

In

response,

licensee personnel stated that they had been.evaluating

the need

to report but had been slow in reaching a conclusion.

PARTIAL LIST OF PERSONS CONTACTED

¹IVI. Ackerman, Manager Nuclear Licensing

¹J. Allard, Maintenance Superintendent

¹G. Arent, Operations Procedure Supervisor

¹K. Baker, Manager Production Engineering

¹P. Barrett, Director Performance Assurance

¹A. Blind, Site Vice President

¹S. Brewer, Manager Regulatory Affairs

¹M. Depuydt, Licensing Coordinator

¹S: Farlow, Supervisor

I&C Engineering

¹M. Finissi, Supervisor Electrical Systems.

¹R. Gillespie, Operations Superintendent.

¹C. Golden, System Engineer

¹D. Hafer, Manager Plant Engineering

¹S. Hodge, Manager Work Control

.

¹J. Kobyra, Manager Nuclear Engineering

¹D. Londot, Environmental

¹D. Loope, Training Manager

¹A. Lotfi,'Performance

Engineer

¹D. Morey, Chemistry Superintendent

¹D. Noble, Radiation Protection Superinteiident

¹F. Pisarsky, Supervisor, Component Engineering

¹T. Postlewait, Site Engineering Support Manager

¹T. Quaka, Project Management 5 Inst. Services

¹P.'ussell,

Plant Protection Superintendent

¹J. Sampson,

Plant Manager

~

¹P. Schoepf, Manager Safety-Related Systems

25

C

0

¹L. Smart, Licensing Coordinator

¹D. Spencer, Performance Engineering'

¹M. Stark, Supervisor Performance Testing

.

¹A. Verteramo, Supervisor Reactor Engineering

¹J. Wiebe, Manager Engineering and Analysis

¹Denotes those present at.the March 27, 1997 exit meeting.

26

C

'NSPECTION PROCEDURES USED

IP 37551

IP 60710

IP 61726

IP 62703

IP 71707

IP 71750

On-site Engineenng

Refueling Outage

Surveillance Observations

Maintenance Observation

Plant Operations

Plant Support Activities

ITEMS OPENED and CLOSED

Qggnnn.

50-316/97004-01 a(DRP)

VIO

Inadequate

Procedure resulted in

Inadvertent ESF Actuation

50-31 5/97004-01 b(DR P)

50-31 5/97004-01c,d(DRP)

50-315/316/97004-02a(DRP)

50-31 5/31 6/97004-02b(DR

P)

VIO

Failure to Follow Procedures

(FME

Practices)

VIO

Failure to Follow Procedures

(Missing

Cage Spacers)

VIO

Failure to Implement Adequate Corrective

Action (Taylor Mod 30 Controller Failure)

VIO

Failure to Implement Adequate Corrective

Action (Spiral Wound Gasket Material in

RCS)

50-31 5/97004-03(DR

P)

50-31 5/31 6/97004(DRP)

50-31 5/97004-05(DR

P)

50-31 5/97004-06(DR

P)

50-31 5/31 6-97004-07(DR

P)

GhmC

None

VIO

Failure to Make Timely 50.72 Report

VIO

. Failure to Perform 50.59 Evaluation

(Ventilation Catch Basin in CR Panels)

DEV

Overpower Chart Recorder Pen

Inoperability

URI

Failure to Address Check Valve

Operability

URI

Environmental Qualification of Equipment

Associated with Cracked Flood-up Tubes

27

l

AEP

AR

BOP

CFR.

CR

CREVS

DRP

ECCS

ESF

FMEZ

gpm

JOA

LER

LOCA

MDAFWP

MHI

MHP

NRC

OHP

PDR

PMI

PMP

PMSO

Pslg

RHR

RG

RO

RWST

SI

S/G

SS

TDAFWP

TS

UFSAR

US

List of Acronyms

American Electric Power

Action Request

Balance of Plant

Code of Federal Regulations

Condition Report

Control Room Emergency Ventilation System

Division of Reactor Projects

Emergency Core Cooling System

Engineered Safety Features

Foreign Material Exclusion Zone

gallons per minute

Job Order Activity

Licensee Event Report

Loss of Coolant Accident

Motor Driven Auxiliary Feedwater Pump

Maintenance Head Instruction

Maintenance Head Procedure

Nuclear Regulatory Commission

Operations Head Procedure

Public Document Room

Plant IVlanager's Instruction

Plant'Manager's

Procedure

Plant Managers Standing Order

Pounds per Square Inch Gage

Residual Heat Removal

Regulatory Guide

Reactor Operator

Refueling Water Storage Tank

Safety Injection

Steam Generator

Shift Supervisor.

Turbine Driven Auxiliary Feedwater Pump

Technical Specification

Updated Final Safety Analysis Report

Unit Supervisor

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