ML20062H318

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $112,500.Violations Noted:Failure to Identify Potentially Significant Condition Adverse to Quality,Failure to Control Design & Testing Documents & Startup W/O DGs

ML20062H318
Person / Time
Site:	Clinton
Issue date:	11/26/1990
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20062H305	List: IR 05000461/1990005 ML20062H304 ML20062H318
References
EA-90-108, NUDOCS 9012040255
Download: ML20062H318 (4)

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTIES Illinois Power Company Docket No. 50-461 Clinton Power Station License No. NPF-62 EA 90-108 During NRC' inspections conducted on March 14 through May 14, 1990, and May 18 through May 31, 1990, violations of NRC requirements were identified. in accordance Enforcement with the "10 Actions," General Statement CFR Part of Policy 2, Appendix (and C 1990), Procedure the for NRC Nuclear Regulatory l Commission proposes to impose civil penalties pursuant to Section 234 of the i Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. l The particular violations,. and associated civil penalties, are set forth below:

1. - Violation Associated with Untimely Corrective Action i 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires I that measures shall be established to assure that conditions adverse to -

quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and-corrective action taken to preclude repetition. The identification of the significant condition adverse to-quality, the cause of the condition, and the corrective action taken shall be documented and reported to the appropriate levels of management.

Contrary to the above, on January 24, 1990, Plant Technical Staff engineers "

identified a potentially significant condition adverse to qualit to low flow indications through the shutdown service water pump(SX) room y relating heat exchanger IVH07SA, but failed to promptly initiate a Condition Report or. determine its cause. Though the low flow data was initially reported to the Nuclear Station Engineering-Department (NSED) for trending on that date, the licensee failed to identify the potential significance of the condition and initiate appropriate corrective action until the Supervisor, Plant Testing, reviewed the data on February 15, 1990.

This is a Severity Level III violation (Supplement I). ,

Civil Penalty - $50,000.

II. Violations Associated with the Design and Testing of the Shutdown Service WaterSystem(SX).

A. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that measures be established to assure that the design bases g?O12040250901126 DR ADOCK 05000461

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r Notice of Violation s are correctly translated into specifications, drawings, procedures and instructions. The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, or the use of alternate or simplified calculational methods.

Contrary to the above, prior to initial plant startup on April 17, 1987, the licensee failed to assure that the design bases of the shutdown service water and control room heating, ventilation, and air conditioning (HVAC) chilled water systems were correctly translated into specifications, drawings, procedures and instructions, and that F. design control measures properly verified or checked the adequacy of the design. Specifically, the performance of these systems did not meet the design basis requirements specified respectively in Sections 9.2.1.2 and 9.4.1.1-of the Final Safety Analysis Report, due in part to inadequate design input supplied by an equipment vendor that resulted in less than design specified cooling water flow to numerous system components. Design control measures for verifying or checking the

adequacy of the . vendor supplied data failed to note that data was not appropriate for the type of cooling coils purchased.

B. 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires that a test program be established to assure that all testing, 1 required to demonstrate that structures, systems, and components will L

perform satisfactorily in service, is identified and performed in 0

accordance with written test procedures which incorporate the requirements and' acceptance limits contained in applicable design documents.

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O Contrary to the above, on March 15, 1990, it was determined that SX pre-operational test,- PTP-SX-01, Revisions, 0,- 1, and 2 were deficient jf in that:

j 1. Inaccurate design flow differential pressure (dP) data was used for the American Air Filter heat exchangers;

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2. Non-conservative flow measurement acceptance criteria were

} applied without a technical basis; 3-

3. The dP flow balance measurement did not account for pressure j

losses between the dP tap and the component being measured; and i 4. Flow balancing of the SX system was not performed after L

installation of the flow restricting orifices.

Violations II.A and II.B have been categorized in the aggregate as a 1 Severity Level III problem (Supplements I and II).

III. Violation Associated with Inoperable Diesel Generators Technical Specification Limiting Condition for Operation (LC0) 3.8.1.1.B i requires, as a minimum, that three separate and independent diesel generators j-o

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Notice of Violation be operable in Operational Conditions 1, 2, and 3. Action Statement 3.8.1.1 9 requires that with diesel generators 1A and IB INOPERABLE, restore at least one to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Technical Specification LC0 3.0.4 requires that entry into an Operational Condition, or other specified condition, not be made unless the conditions for the limiting condition for operation are met without reliance on provisions contained in the action requirements.

Technical Specification 1.27, OPERABLE, states that a system, subsystem, train or component shall be OPERABLE when it is capable of performing its specified function and all necessary attendant inetrumentation, controls, electrical power, cooling or seal water or other suxiliary equipment required for that system, subsystem, train or component to perform its function are also capable of performing their related support function.

Contrary to the above, on May 14, 1990, the licensee commenced a reactor startup from cold shutdown (Operational Condition 4), reaching startup (Operational Condition 2) at 10:40 a.m., where it remained for a period in excess of 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> with diesel generators 1A and IB inoperable. Diesel generators 1A-and 1B were inoperable in that SX valves ISX005A & B, ISX064A, and ISX065B were incorrectly positioned, preventing the SX system from performing its necessary attendant cooling support function.

This is a Severity Level III violation (Supplement 1).

Civil Penalty - $62,500.

' Pursuant to the provisions of 10 CFR 2.201, Illinois Power Company (Licensee) is hereby required to submit a written statement of explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Comission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalties (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the: corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance is achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other actions as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required under 10 CFR 2.201, the License may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United f

Notice of Violation States in the cumulative amount of the civil penalties, or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U. S. Nuclear Regulatory Comission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice, in whole or in part, (2)demonstrateextenuatingcircumstances,(3)showerrorinthisNotice,or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties, in whole or in part, such answer may request remission or mitigation of the penalties.

In requesting mitigation of the proposed penalties, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1990), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in repl; pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g.,

citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties.

Upon failure to pay any civil penalties due which subsequently Mye been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to:

Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Comission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137 and a copy to the NRC Resident inspector at the Clinton Power Station.

FOR THE NUCLEAR REGULATORY COMMISSION A. Bert Davis Regional Administrator Dated at Glen Ellyn, Illinois this 26th day of November 1990

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DoJc'itMo,50-461 Ti 90-708%

111 er Company ATith J. S. Perry Vice President Clinton Power Station Mail Code V-275 P. O. Box 678 Clinton, IL 61727 Gentlemen:

l This refers to the.special team inspection conducted others of this office during March 14 through May 14, 1990, of by Dr. J. F. Sch6pker and activities related to the inadequate design flow through components using the shutdown service water system for cooling water at the Clinton Power Station authorize by HRC Operating License No. NPF-62 and Thisto the discussion inspection also of our find Mr. J. S. Perry at the conclusion of the inspection.

reviewe.1 the licensee's actions associated with Generic Letter (GL) 89-13,

" Service Water System Problems Af fecting Saf ety-Related Equipment".

The en losed copy of our inspection report identifies areas lexamined tive during-the ir.spection. .W ithin these areas, the inspection consisted of a se ec m

exam'. nation of procedures and representative records, observations, and int'erviews with personnel.

During the course of this inspection, certain activities appeared to be in violation of HRC requirements. These deficiencies concerned the Shutdown Service Water System having inadequate The apparentflow from the violations, ultimate described in heat sink to certrin safety-related components.

Paragraphs 2.a. , 2.c. , 2.f. , and' 4. of this report, are being review potential enforcement action. No written response is required of our decision regarding enforcement action.

until you are notified of the proposed enforcement action.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy o this letter and the enclosed inspection report will be placed in the NRC Public Document Room.

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. llk ? 1 E:3 111inois Power Company 2 We will gladly discuss any questions you have concerning this inspection.

Sincerely, T. : . .. .: L. ; . . ~ ;. . ' ) . > -

Hubert J. Miller, Director '

Division of Reoctor Safety

Enclosures:

1. Indpaction Report No. 50-461/90005(0RS)

2. Division 1 EDG Engine Closed Cooling Water 4 System

3. Division 1 SX Schematic

4. DP tleasurements

5. Heat Transfer Correlations

6. Table 1 - Flows through Components in SX System cc w/ enclosures:

J. Cook,_ Manager. Clinton Power Station F. Spangenberg, Ill, Manager -

Licensing-and Safety DCD/DCB (RIDS)

Licensing Fee tianagement Branch Resident inspector, Rlli J. Hickman NRR b" J L h"> 0 05-T CCI O "

R. Bernhard, Region 11 D. Jarrell, Battelle

7. PJoo,O'AG R--

J. McCaffrey, Chief, Public b . A MD , bd'**'r Utilities Division H. Taylor, Quality Assurance Division. Sargent & Lundy

- Engineers Patricia O'Brien, Governor's

' Office of Consumer Services S. Zabel, Esquire, Schiff, Hardin,

& Waite L. Larson, Project Manager, General Electric Company Chairman, DeWitt County Board Illinois Department of Nuclear Safety R1 RI I Rlli Ril R1 Rlll Rlll 5 i p r/jk ub LaI ary Da e n e tin 1. er O'/: 0/90 05/ /90 05/3/90 05So/90 05/3o/90 0'5 / 31 /9 0 05/y /90 /g/90 0

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V. S. IlUCLTAR REGULATORY C0!iMISS1014 REG 1011 111 Report flo.: 50-461/90005(DRS)

Doctet-No.: 50-461 License fio.: liPF-02 Licensee: lilinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL 61727

- Inspection Conducted: March 14 through May 14, 1990 Inspectors: J. F. Schapker, Team Leader Region 111 M. P. Huber, Region 111 R. Bernhard, Region 11 P. G. Brochman, SRI, Clinton S. P. Ray, RI, Clinton D. Jarrell, Battelle, Consultant I

Approved By: 27 Vm 6/3'76 D. H. Danielson, Chief Date Materials and Processes Section <

Inspection Suninary I -

Inspection on March 14 through May 14, 1990 (Report No. 50-461/90005(DRS))

[ Areas Inspected: Special, announced team inspection of a licensee identified reportable event of inadequate design flow through components using the Shutdown Service Water (SX) System for cooling water, and actions associated with Generic c Letter (GL) 89-13. " Service Water System Problems Affecting Safety-Related Equipment".

Results: Of the areas inspected, three apparent violations were identified; multiple examples of inoperable SX and Control Room Ventilation System components I (Paragraphs inadequate test2.f.and4.)fParagraph2.c.).Basedontheresultsofthisinadequate control correc inspection, the following weaknesses were noted:

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-* The licensee's' corrective-a'ction upon identification of low flow rate F1 Lthrough a safety-related component in the SX System was not prompt, and therefore unduly extended the inability of the SX component to perform its design. function in case of a design basis accident (DBA).

b ' The-inability of engineers to recognize the safety significance of the-above deficiency was apparently the cause of the . lack of corrective action.

Engineering errors in-the development and implementation of the preoperational test contributed to.the SX System being outside its design basis since:startup of. the plant. _

-' . inaccurate design : input,-supplied by- the equipment manuf acturer, was oa usedito calculate: operational-flow requirements through one model of-a heat' exchanger,.'used in the SX and Control ' Room Ventilation . Systems. The inaccuracies contributed to these components having inadequate flow to meet their design. requirements as stated in-the Clinton USAR.

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DETAILS

1. Persons Contacted lilinois Power Company (IP)

• J. S. Perry, Vice President

• F. A. Spangenberg, Manager, Licensing and Safety

• J. G. Cook, Manager, Clinton Power Station

• J. A. Miller, Manager, Nuclecr Safety Engineering Department

• R. E. Wyatt, Manager, Quality Assurance

• R. W. liorgenstern, Mar.oger, Scheduling and Outage Management

• J. F. Palchak, Hane.ger, Nuclear Planning and Support

• S. P. Hall, Dire tor, Nuclear Program Assessment Group

• R. S. Frantz. Staff Engineer, Licensing and Safety

• K. A. Baker, Supervisor, Inspection and Enforcement Interf ace

• J. D., Palmer, Manager, Nuclear Training Department e

F. C. Edler, Project Manager, Heat Exchangers l

K. C. Moore, Director, Plant Technical J. A. Brownell, Project Speciclist, Licensing l

Sargent and Lundy Engineers (S&L)

J. Blattner, Project Site Manager M. Stout, HVAC Project Manager U. S. Nuclear Regulatory Commission (U. S. NRC)

• J. . Schapker, Team Leader, Region Ill M. Huber, Reactor Inspector, Region Ill-

• M. Ring, Branch Chief Engineering Branch, Region 111 P. Brochman, SRI, Clinton Power Station, Region 111 S. Ray, R1, Clinton Power Station, Region 111 R.-Bernhard, Reactor Inspector, Region 11 D.JJarrel, Consultant (Battelle) l E

• Denotes those present during the exit interview conducted on April 26, 1990.

Other members of the plant staff and contractors were contacted during the course of this inspection.

2. Inspection of Shutdown Service Water (SX) System low Flow Rates

a. Background I

i The SX System provides a reliable source of cooling water for station auxiliaries which-are. essential to safe shutdown of the station following a design basis loss of coolant accident. The SX System consists of three divisions which correspond to the three electrical safety divisions. Any two of these divisions, operating 3

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together, are adequate'to ensure safe shutduwn of the station. This system is also designed such that no single f eilure of a component will compromise the ability of the system to sof ely shut down the station, in response to Generic Letter (GL) 89-13, " Service Water System Problems Affecting Safety-Related Equipment", the licensee's plan was to open, inspect, and obtain baseline data on safety-related heat exchangers (HX) and develop a program to monitor the performance of the heat exchangers for the life of the plant.

In late December 1989, uiter approximately three years of commercial operation, a Division 1 emergency diesel expansion tank high level was observed. The high level was caused by opparent in-leakage from the SX system (having a line pressure of approximately 100 psig) to the emergency diesel generator (EDG) engine closed cooling water system (slightly above atmospheric pressure), reference Enclosure 2.

The Division 1 EDG was declared inoperable and, during the subsequent

-Limiting Condition for Operation (LCO) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee examined the suspect HX and found through wall pitting in one tube of the dual HX units. The defective tube was replaced with a new tube of like material (90/10 Cu/Ni), the HX was tested, and the EDG was returned to service.

Approximately one week later, a similar tube f ailure occurred. The HX was repaired, eddy current tested and approximately half of the tubes were cleaned, within a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO. =A third failure took place on January 15, 1990, at which time the licensee completely retubed and hydrostatically tested both Division 1 EDG HX units. A consultant associated with the Electric Power Research Institute (EPRI) was called in to examine the degraded HXs and identified the degradation mechanism as local Microbiologically Induced Corrosion (MIC) accelerated by the thermal and stagnation environment present in the.EDG HX-tubes.

Suspecting that a global MIC condition could exist in the SX System, the licensee commenced an inspection of all Division 1 HXs (see Enclosure 3) to assess their physical condition. The remaining Division I HXs exhibited only minor tube wall pitting (maximum depth of 20% wall), along with moderate general corrosion and light siltation. The lack of evidence of widespread MIC attack supports the theory that the combination of thermal and stagnation conditions l

found in the EDG HXs promoted. micro-organism growth and the resulting degradation of the copper-nickel tube wall.

On January 24, 1990,=with the plant in Mode 1 at 100% power, licensee test engineers were performing HX performance testing to establish the as-found system flow conditions. Flow measurements of Division i SX System pump room cooling coil IVH07SA disclosed as-found flow of 3

32 gallons per minute (gpm). This as-found flow was significantly lower than the 82 gpm required by design documents. The test

j. engineers did not report these values to the Shift Supervisor i

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beCouse they did not b'elieve the test equipment was providing a correct indication of flow. The test engineers reported the flow test results to engineering for trending purposes to indicate the condition of the cooling coil prior to the inspection and cleaning of SX Division I heat exchangers.

On January 23, 25, and 29,1990, four additional SX heat exchangers were tested for flow rates and the results reported to Engineering in d letter to the Project Manager for Heat Exchangers on January 30, 1990. 1 The OVG075B heat exchanger tested on January 23, 1990, was reported within the design required flows. The IVH075A heat exchanger tested un January 24, 1990, was reported as exceeding alarm values, the -

IVX135A heat exchanger tested on January 25, 1990, was reported at >

an alert value, and the IVXO6CA tested on January 29, 1990, was

. reported as exceeding alarm values. These values were calculated heat exchanger performance. This using formulaa came formula foradetermining from contractor (MPR Associates, Inc.) who prepared a performance testing monitoring program for the licensee.

On Tebruary 13, 1990, theplantenteredMode4(ColdShutdown) "

because of a failure to meet primary containment integrity.

1 On February 15, 1990, the flow test data for IVH07SA was reviewed by the Supervisor, Plant Testing, and he detersnined that the Shif t Supervisor (SS) should be notified of the es-found flow rate. The r SS was immediately notified of this condition r.d directed test i engineers to calibrate the te';t equipment and measure the flow rate h again. After verifying instrument calibration, test engineers P measured the flow rate at three different locations and found it to L be 55 gpm. At 1343 hours0.0155 days <br />0.373 hours <br />0.00222 weeks <br />5.110115e-4 months <br />, the SS directed the Area Operator to L restore design flow through IVH07SA by adjusting flow through valve E ISX009A to approximately 85 gpm and relocking the valve. The SS further requested that engineering evaluate the operability of cooling coil IVH07SA.

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k On February 24, 1990, test engineers notified the SS that performance h testing of the Division I Reactor Core Isolation Cooling Syste: rBH]

D pump room cooling coil identified an as-found flow through the cooling coil of 12 gpm. Design documents require a flow of 18 gpm j[ through this cooler.- The SS directed engineering to determine the heat removal capability of the cooling coil at the. as-found flow rate

., J and directed that this condition be resolved prior to increasing reactor pressure above 150 pounds per square inch gauge (psig).- The

)" SS further directed that engineering coordinate proper corrective 7 *

{ actions with Plant Engineering if failures of other heat exchanger

[. performance. tests were identified. 1 On March 2, 1990, engineering held a meeting and discussed flow balancing of the SX system. At this meeting, Sargent and Lundy

[. (S&L), the Clinton Power Station architect-engineer, was assigned 8

responsibility for developing appropriate acceptance criteria and techniques for flow balancing the SX system.

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On March 5,1990, whili developing the criteria and technique f or

-flow balancing, S&L identified that the acceptance criteria used in preoperational test PTP-SX-01 of the SX system prior to initial plant operation was not consistent with specifications. The acceptance criteria used in PTP-SX-01 for cooling coil IVH075A was a differential pressure of 18.1 int.hes water gauge while the design / procurement specification indicated a differential pressure of 58.8 inches water gauge. The use of the 18.1 inches water gauge value caused the flow rate to be set incorrectly for cooling coil IVH075A.

On March 6,1990, while reviewing SX system CRs, a system engineer identified that Division 11 SX System pump room cooling coil IVH075B

' could' have the same problem as IVH07SA and theref ore, could also have its flow rote incorrectly set.

On March 6,1990, at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, engineering notified the SS that the flow rate acceptance criteria used in PTP-SX-01-for Divisions I and 11 SX System cooling coils IVH075A and IVH075B was not correct and therefore, the required design flow rate was not met.

Engineering further identified that the SX System had been outside design basis since initial plant operation as a result of using the incorrect acceptance criteria.

On March 6,1990, at 1620 hours0.0188 days <br />0.45 hours <br />0.00268 weeks <br />6.1641e-4 months <br />, at the direction of the SS, the Area Operator adjusted flow through valve 1SX009B to provide a flow rate of approximately 85 gpm through cooling coil IVH075B. The SS also directed that flow through.IVH07SA be determined and corrected as necessary, in addition, the SS determined that the flow rate problem was reportable as a Licensee Event Report (L'R) under the provisions of 10 CFR 50.73(A)(?)(ii)(B) because the flow rate problem resulted-in the plant being in a condition outside its design. basis.

The licensea's test engineers identified low flows through the

.SX System pump room haat exchanger IVH07SA on January 24,.1990.

-No further action was taken by the test engineers to verify the accuracy of the test data found but the data.was reported to.

engineering. Licensee engineering.also took no action, and.

apparently. did not recognize'the safety. significance of the reported low flows. The Clinton-Power Station was in Mode.1 on January 24, 1990, at 100% power. Not until February 15,.1990, when the supervisor of

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plant testing reported the low flows to the Shif t Supervisor, was any action taken to verify the accuracy of the flow measurements, and corrective-measures initiated-to restore flow to the affected heat exchanger.

The lack of timeliness of the licensee'to implement corrective actions in response to the identification.of apparent low flow through.a~ safety-related component necessary to mitigate the consequences of a design basis accident, was identified as an apparent violation of 10 CFR 50, Criterion XVI, Corrective Action.

Criterion XVI requires, in part: " Measures shall be established to assure that conditions adverse to quality, such as failures, 1

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malfunctions, deficierlies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." (461/90005-01)

b. Inspection -

A special team inspection was conducted de ing the period of March 14 through May 14, 1990, to evaluate the licensee's corrective action prior to restart, to assess the safety significance of the as-found low flow rates through the SX System, and to determine the root cause of the deficiency.

The.NRC inspectors performed observations of the licensee's activities of the inspection of heat exchangers for cleanliness, L fouling, flow rate measurements, and flow balancing of the SX System.

Reviews of the licensee's preoperational procedure for testing of the SX System were performed and review of the architect-engineer's (S&L) "

calculations of required flow rates was made by a consultant to the HRC.

c. Service Water System Preoperational Testing The NRC inspectors reviewed the preoperational testing of the SX '

System in order to evaluate the testing methodology and determine whether test results.and acceptance' criteria were within design specifications. The review enaompassed preoperational test pTP-SX-01, Revision 2, " Shutdown Service Water System", completed on f.pril 26, 1986, a review.of' vendor urawings and manuals, design specifications', additional vendor supplied data, and discussions with ,

the licensee and S&L engineers.-

Preoperational procedure PTP-SX-01 was performed to demonstrate the r ability of the SX System to supply cooling to the various components that it serves, in addition to demonstrating that the interlocks and '

automatic actuations operated properly. The flow path of the SX System was to be verified by placing system flow through all  :

components of the system and then measuring the flow through each 1 component to verify compliance to design criteria. The technique used for verifying proper system flows was either: (1) measurement of.the flow through the cooler using a clamp-on flowmeter; or (2)'

measurement of thf pressure. drop across the cooler and ensuring that the pressure drop _was comparable to the drop associated with the required flow. The measurements were taken with the entire system in 4 operation while simultaneously throttling the flow through each-cooler to achieve the desired flow rates.. This testing methodology is acceptable; 'however, the subsequent discovery that the service- ~

water system flows were inadequate is the result of a complex series of events, which are detailed below.

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Following the completio'n of the flow balancing of SX System Divi-sion 1, the licensee determined that flow orifices were necessary to restrict flows for the RHR and Fuel Pool Cooling (FPC) heat exchangers, to their design requirements. The flow orifices were designed, installed in the system and tested to verify that the heat exchanger flows were within design requirements.

The problems noted by the inspectors with respect to the testing are detailed below:

(1) Flow Rate Acceptance Criteria The flow rote acceptance criteria used in the testing procedure were provided by the Nuclear Station Engineering Department at Clinton. These criteria were supposed to be based on K-spec data, vendor manuals and drawings, or vendor supplied data.

Since the largest percentage of flow measurements were taken using instruments to measure differential pressures across the individual SX System coolers, pressure drop values that corresponded to the desired flow rates were needed for incorporation into the procedure. Powever, for the cooling coils provided by American Air Filter ( AAF) Company, Inc. , no pressure drop data was provided to Clinton and additional communication between S&L and AAF was required. Several letters were sent to S&L which provided the cooling coil performance data on computer printouts for the AAF coils utilized :n the SX System, and the pressure drops were included in the performance data. AAF provided data, however, that was not appropriate for the type of cooling coils purchased and installed by the licensee. Specifically, the data did not include appropriate head losses for clean-out plugs included on the AAF model which was installed as room coolers for Engineered Safety Feature Systems. This contributed to less than design specified cooling water flow being supplied to the cooling coils of the room coolers. Subsequently, S&L issued a Design Information Transmittal, DIT-CP-ilVAC-0293 to Clinton to provide the water flow requirements and pressure drops for all HVAC equipment supplied in the tervice water system, except for the Service Water System Pump Room and Main Steam Isolation Valve (MSIV) Leakage Inboard Room Cooling Coils.

The NRC inspectors verified that the incorrect vendor specified pressure drops were used in the service water system testing and found that all the vendor supplied data was incorporated in the test procedure except for the Service Water System Pump Room Cooler, which used a pressure drop of 18 inches'instead of 30 inches. No basis for this error could be determined.

(2) 110% Tolerance Band The licensee specified a 210% tolerance on the flew rates for which the inspectors could determine no basis for inclusion in 8

~

the preoperationil procedure. Based on discussions with the licensee, it was determined that the acceptable flow rates '

specified in the preoperational test procedure were minimums, L and therefore, the -10% tolerance should not have been included.

l Several of the SX System flow rates through the heat exchangers and coolers were less than the design flow rate but all were l within the 110% tolerance during preoperational testing.

(3). Affect of instrumentation on Acceptance Criteria It was noted during the review that the acceptable i b a rate values supplied by engineering made no additional allowances for any pressure drops between the tops for dif ferential pressure  ;

measuring devices and the cooling coils. The vendor supplied pressure drop data was accouMable only for the pressure drop L across the coil. The actual locations of the instrumentation

! used during the preoperational tests could not be established, but assumptions were made of the pc:.:;ible pressure tap locations

) and additional line losses should have been accounted for.

(

Reference:

Enclosure 4)

(4) Post Flow Balance Modification Testing As previously discussed, flow restriction orifices were installed on the discharge lines of the FPC and RHR Heat Exchangers to eliminate the need for throttling of the FPC and RHR valves to obtain required flow through these heat ex-changers. The subsequent testing of the SX System following l

the completion of the SX flow balancing (PTP-SX-01) was not well l documented, in fact, several problems were noted with the testing and are discussed below:

No specific flow rates wen .ecorded following the modifications. (

• The licensee did not consider the impact of the addition of the flow orifice to the discharge line of the RHR Heat Exchanger on flow to the.RHR Heat Exchanger 1A Room Cooler.

The orifice was located downstream of the point where the discharge piping from the room cooler taps into the RHR Heat Exchanger piping and therefore, the orifice would reduce the flow through the room cooling coil. No documentation was found to support any testing performed to

-reverify that the room cooling coil flow rate was adequate.

No SX system rebalance was performed following the installation of the flow restricting orifices.

The licensee was informed at the exit interview that these deficiencies identified in the preoperational procedure were apparent violations of 10 CFR 50, Appendix B, Criterion XI, Test Control, which requires, in part: "A test program shall be established to assure that all r

9

( (

testing required to desonstrate that structures, systems, and components will perform satisfoctorily in service is identified and v.cformed in accordance with writtov 'est procedures which incorporate the requirements and acceptance limits wotained in applinc3ble design documents. Test procslures shall include provisions for assuring that all prerequ:sius for the given test have been met, that adequ6te test instrumentation is available and used . . ."

(461/90005-02)

The NRC inspectors revieweo preoperational test results for a sample of three other systems to determine if similar problemt may exist. Ho additional problems were discovered during the review. The licensee also conducted o review of other preoperational tests to determine if similar problems existed. No additiceal deficiencies were identified in those reviews.

d. Review of Flow Measurement Accuracy Using Ultrasonic Devices Until 1989, Clinton, like most utilities, primarily depended on differentialpressure(0p)measurementstobalanceandensureadequate mass flow to the multiple parallel heat exchangers in the SX System (see Enclosure 4). Vendor measurements of pressure drop as a function of mass flow through the individual HX tubing were used in conjunction with a temporarily installed differential pressure transducer to adjust a throttling valve located on the inlet side of most of the HX components. This approach to determining component mass flow presents several possibic generic mechanism problems which were discussed in paragraph 2.c. of this report. With the advent of high accuracy nonintrusive liquid velocity measurement devices, a check on the original methodology is now available.

Two liquid flow velocity meters were utilized to provide mass flow values for system components:

For pipe sizes in excess of six inches, a Leading Edge Flow Measurementdevice,Model-801A(LEFM-801A)withstrap-ontransducers (manufactured by Westinghouse Corporation) was used. Discussions with the Westinghouse representative established the instrument tccuracy at 0.5% of the indicated velocity. By measuring pipe wall thickness (usingacalibratedultrasonictestinggauge)andcircumference, pipe flow area may be determined to an accuracy of 8.75% for an 8-inch >ipe and to 2.36% for a 30-inch pipe. This accuracy accounts for bot 1 the actual pipe wall thickness, and allows for a 1/8 inch uniform corrosion plus veriable nodule layer as was observed to exist. The fleid density will vary with temperature, but over the limited range expected during the measurement process, it is considered negligible. The continuity equation is then used to calculate the mass flow from the measured fluid velocity in the pipe.

10 l

( ('

( '

o The resulting totol root mean square (rms) uncertointy in large bore mass flow measurement is then:

for 30" pipe ------ -- 2.411 for 8" pipe --------- 8.76%

for small bore piping (less than six inches), a polysonics model DH1-p was used. This device works on a high f requency doppler shif t principle, and the instrument is specified es accurate to 5% of range. For determining the msss flow in small bore pipe, site personnel use nominal pipe data, which has a di6 meter tolerance of approximotely 51. This translates to e flow crea uncertainty of 9.751. Agt.in, assuming a 1/8 inch crud layer and moderate variabic tuberculation in the pipe, an additional 19.2' uncertainty in flow area is introduced. Utilizing the rms value f or independent uncertainties gives a total mass flow measurement uncertainty for the 21-inch schedule 40 test case of 22.1%. This is the smollest pipe, and consequently, the largest uncertainty (barring geometric anomalics and measurements in non-fully developed flow regions) that would commonly be expected in the $X System.

The minimum component mass flows shown in Enclosure 6 are then found by subtracting the measurement uncertainty from the indicated measurement value, for couple, the first entry (1VH07sA) had a component design flow rate of 82 gpm, while the as-found flow (sonic transducer measurement prior to any flow adjustment) was measured at 20.5 gpm. 1he minimum possible flow is then found by substracting the uncertainty in the measurement f rom the registered value. This means that the flow could have been as low as 16.0 gpm. Following the flow balance, the component had a flow measured by sonic transducer of 102 gpm.

e. Beview of Heat Transfer Correlations it should be noted that the flow through the HX is not a direct measure of the calculated heat removal capacity of the component.

The basic relationship for water to air heat exchangers is shown in Enclosure 5. This enclosure indicates that, at least in a generic case, a reduction to only 20% of the design liquid flow for the HX results in the component still being able to remove a) proximately 40%

of its design heat load. A second observation that s;ould be made is the difference between the heat exchanger design heat removal capacity (design heat load), which is the manuf acturer's performance guarantee for rate flows and temperatures, and the maximum heat rejection rate required during a loss of coolant accident (LOCA) or other potential core damage sequence (required emergency load). The required emergency load is the value (Btu /hr) required by Technical Specifications to avoid exceeding the ambient temperature limitations of equipment in the proximity of the HX, and is considerably lower than the HX design load. This difference in capacity allows for variations such as lower than design flow rates, fouling of heat transfer surfaces, and the like, while still providing protection to the local equipment.

i 11

f 7 As previously mentione'd, the task of determining the actual heat transfer capability of d heat exchan;er requires a substantial .

thermal load to be placed on the component. Without differential twperatures of at least five to ten degrees, inaccuracies in temperatures and flow quickly render the measurement useless. The alternative used here is to calculate the projected heat removal rates based on an analytical model of the heat transf er process.

This discussion focuses on heat exchangers which nust transfer compartment or room heat loads to the SX system, i.e., room coolers.

The calculated heat transfer capacity of room cooler units for both SX divisions was prepared by S&t. engineers using the pC-00lLSY14 program developed by professor f. C.14cQueston of the Oklahoma State University. The documentation which explains the code was well written, and appeared to be both correct and complete. Dr. McQueston is well recognized for his work in heating, ventilation, and air conditioning (HVAC) teaching and texts.

The C0lLSYH program is a flexible and technically comprehensive code for liquid to vapor heat transfer processes, it necessarily places a responsibility on the user to clearly define the process variables.

Much of the consultant's effort was focused on the verification of these input variables. While it was not possible to check all the data, nevertheless, geometry factors from design prints, materials from manufacturer's specifications, fluid flows, input temperatures, and fouling factors were spot checked on several runs, in addition,

" sanity checks" were performed on the output data to show that the calculated result fell within the bounds of reason. The viability of all questionable results were challenged.

All checked input data was found to be accurate, and, with the exception discussed below, calculated results were found to be reasonable.

One non-conservatism was found to exist in the input data, in that there was no reduction in the secondary (air) side heat transfer of the room cooler heat coefficient to account for possible foulirig(water) transfer surfaces. Fouling of the primary side was set at 0.002 which was shown to be appropriate, i

~

On the conservative side, 95'F coo'.ng (SX) water was assumed for all computed runs. Actual Lake Clinton temperature has never exceeded 91*F which would have the effect of increasing the cooler capacity.

f. Operability Conclusion

(1) Current Operability Conclusions

Based on the review of the measured fluid flow to each of the

? Divisions I, 11, and 111 heat exchangers, the accuracy of the

measurements, and the calculations performed, the Clinton SX 1

! 12 3

(~ (

e 1

~

System is capable of removing the emergency heat load (as indicated in Enclosure 6) f rom all of the safety-relatu! shutdown components serviced by the system.

(2) SX System OperaHlity with As-found flows Applying the same analysis techniques discussed in Parograph 2.e., calculations of projected SX System heat removal capobility under the component flow values in the as-found (flow balanced using differential pressure cell measurements) were conducted.

The as-found flow values were measured using the sonic flowmeters previously described. The same series of calculetional checks were used in the post-flow balance conditions.

All but one of the pre-flow balance calculated heet removal capacities were found to be accurate, with the previously r..entioned caveat of no allowance of decreased heat transfer due to fouling on the secondary side of the room coolers.

The reasonableness of one of the calculations was found to be in question. The as-found flow to the Combustible Gas Control System room cooling coil cabinet (1VR095) was measured at 7.1 gpm using the ultrasonic detector. Without any allowance for instrument accuracy, the code indicated that the coil could still remove the emergency heat load.

With a 6.8 inch tube diameter (10), an apparent flow velocity of 0.6 feet per second was calculated by the code, liand calculations show the selocity to be 0.41 feet per second.

An assumption required by the code is that the liquid flow inside the tube should be fully turbulent. AReynolds(Re) number of 2500 or less will abort the run based on non-turbulent flow conditions, lland calculations did, in fact, show the Reynolds number to be approximately 2600. Reference texts indicate that the desired flow regime probably would not exist ,

at this velocity. A subsequent run usino an input flow rate of 7.0 gpm tripped the low Re logic and would not compute a heat removal capacity. Allowing for a measurement accuracy of +/-

22.1% gives a minimum possible flow of 5.53 gpm which will produce a heat removal rate which is clearly below the required emergency limit. The as-measured flow rates for all remaining code runs provide a clear indication of a valid turbulent flow regime.

Prior to flow balancing using uitrasonic velocity detection devices described previously in this resort, the following Divisions I and 11 heat exchangers in tie safety-related portion of the SX System were calculated to have insufficient cooling capacity to meet the LOCA and/or cooldown requiremnets as specified by the Clinton USAR. The conclusions reflect the pre-flow balanced condition as measured by the ultrasonic flow velocity transducers, and instrument accuracy has been accounted for in all calculations.

13

,' (~ [

' DIYlS1011 1 As-found Capability Meets Requirements for:

Heat Exchancer Designation LOCA Cooldown Low Pressure Core Spray Pump Room Cooler IVYO15 Yes No Residual Heot Removal Pump Room Cooler 1YYO25 Yes fio Residual Heat Removal Heat Exchanger Room Cooler IVY 035 tio No Reactor Core Isolation Cooling Pump Room Cooler IVYO45 No No Service Water System Pump Room Cooler IVH075A No N/A Standby Gas Treatment Room Cooler OVG05SA No N/A Combustion Gas Control System Room i Cooler IVR095 No N/A

DIVISION 11 As-Found Capability

' Reets Requirements for:

Heat Exchanger Designation LOCA Cooldown Residual Heat Removal Heat Exchanger Room Cooler IVY 055 No No Standby Gas Treatment Room Cooler OVGOSSB No N/A H Recombiner Room Cooler OVG075B No N/A 2

i 1 The licensee was informed at the exit interview that this

! condition is an apparent violation of the Clinton Power Station i Technical Specifications Paragr h 3.7.1.1, which states: "The shutdown service water (SX) loop )shallbeoperableduring times when its associated syste ) or components are required i to be operable." This includes Modes 1, 2, 3, 4, 5, and when i handling irradiated fuel in the Fuel Handling Building or primary containment.

J The SX System was apparently inoperable from June 21, 1986 to April 6, 1990, due to inadequate design flow rates through several safety-related heat exchangers (reference the above t

listed SX System heat exchangers) could not meet the LOCA and/or

) cooldown heat capacity requirements as specified by the Clinton

? VSAR. (461/90005-03) 1 H

a l

l 14 1

,' . (~ (*

The licensee inf ormed the tWC that an analysis of the safety significance of the SX System low flows through the components for mitigating the consequences of a design basis .

necessary(DBA) accident is currently in the process and will be completed by May 25, 1990.

g. 0hervations of SX Insfections and flow Balancino The imC inspectors observed the licensee's activities to restore adequate flow through the SX heat exchongers, inspection of heat j exchancer and piping for fouling and degradotion, and observations j of cleaning and treatment of the diesel generator heat exchangers  !

for microbiologically induced corrosion. The inspectors  !

observed the use of ultrasonic flow tietector measurements of component (

flows using the LEfM-801A, f or piping in excess of six inches 10. For piping sizes less than six inches ID, the Polysonics, Mudel DHT-P was used. The Polysonics model was licensee owned and calibrated in accordance with the licensee's procedure and manufacturer's requirements. The LEfM-801A was not the licensee's equipment, but was contracted for and inspection services provided by Caldon incorporated, who supplied operators / inspectors and calibration specifications for use of the equipment. The licensee, in evaluating Seat exchanger performance testing, initially used the polysonic and parametric flow meters for measurements of flows within the SX System.

The parametrics flowmeter was used for information only (for the flow measurements during this inspection, as calibration of the equipment was not current).

However, during flow verification inspections, the polysonic flowmeter demonstrated increased inaccuracies for large bore piping flows l

(piping in excess of six inches). This was established during flow measurements of large bore piping adjacent to the Division 1 SX pump, L where a flow indicating differential pressure (DP) cell is installed in the system. This DP cell indicated flows in excess of the polysonic flowmeter. The licensee determined that the doppler shift principle for measuring flows in the large bore piping was not l

providing accurate flow measurements. This inaccuracy was attributed l

to the concentration of particles in the water influencing meter l

accuracy. In an established flow profile, the flow at a point near the center of the flow stream travels at a faster rate. As the concentration of reflectors increases, the instrument averages more of the slower moving reflectors since the depth of sound penetration is reduced. All doppler flowmeters are influenced by flow profile.

For this reason, the licensee explored other non-intrusive flow measuring devices and contracted for the services of Caldon Inc., to perform flow measurements on the piping in excess of six inches in diameter. The LEfM flowmeter does not use the doppler principle for flow measurement.

The LEfM flow measurement is based on the principle that the speed of propagation of acoustic energy in a fluid is influenced by the rate of flow of that fluid. The LEFM-801A uses this measured line 15

( (

velocity to determine'the volume flow rate, flow measurements in large bore pipe were performed and found occuracies corresponded to the DP cell indications of flow. T.e NRC inspectors explored the eccuracies of these non intrusiv; acoustic flow measuring devices which is discussed in paragrap', 2.d. of this report.

With the aid of these flow measuring devices, the licensee restored flows to the SX components es required. 1 A pipe routing modification was necessary to restore adequate flow to RHR system heat exchanger cooling coils IVYO35 and 1YYO55 of Divisions ' and 11. The HRC inspector's review of this modification l concluded that the licensee's action to restore flow to the heat l exchangers complied with the Clinton USAR and regulatory require- l ments. The modification was necessitated by an inadequate post flow 1 balancing inspection after installation of the RHR orifice during (

preoperational testing.

3. Review of Licensee's Response to Generic Letters i

(0 pen)GenericLetter(GL) 89-13-01

" Service Water System Problems Kffecting Safety-Related Equipment"

[

! In response to GL 89-13, the licensee planned to open, inspect, and obtain baseline data on safety-related HX's and develop a program to monitor the performance of the HX for the life of the plant. This inspection was l planned for the plant's second refueling outage in the Fall of 1990. The inspections were accelerated when leaks due to microbiological corrosion were discovered in the Divisions 1 and 11 diesel generators heat

! exchangers, r

Due to the deficiencies discovered during the course of this inspection, the licensee has performed extensive system verification, i.e., flow measurements, through each heat exchangers, inspections, cleaning, and piping and orifice modifications to assure adequate flow through the SX heat exchangers. Further, inspection, cleaning and orifice modifications are lanned to be implemented in the next refueling outage (September 1990 .

The licensee's action in response to the GL appears to be adequate to resolve the issues contained therein. Corrective actions to address the

! recommended action contained in GL 89-13 are in progress. These correctise

[ . actions will be reviewed during a future NRC inspection.

4 American Air Filter ( AAF) Heat Exchangers Installed in the Control Room Ventilation (VC) System The licensee inspected the flow rates through the AAF heat exchangers installed in other plant systems due to the differential pressure (DP) deficiency described in paragraph 2.c.(1) of this report. The result of this inspection identified low flow rates through the following VC

'l 16 4

4

o

( .

neat exchangers:

' Equiement Room Cooler OVC18AA

• Equipment Room Cooler OVC18AB The licensee took corrective measures and restored the proper flows to the above heat exchangers. Mr. f. A. Spangenberg was inf ormed by telecon on May 14, 1990, that the inadequate flow rates through the above identified VC heat exchangers f roni June El,1980 to April 3,1990, is an apparent violation of the Clinton Technical Specifications, Section 3/4.7.2,

" Control Room Ventilation System", paragraph 3.7.2, which states: "1wo independent Control Room Ventilation Systems shall be Operable."

Applicability: "All Operational Conditions and when irradiated fuel is being handled in the secondary containment." (461/90005-04)

The licensee reported to the NRC the AAF differential pressure errors under 10 CFR part 21 on March 29, 1990, and documented the notification in a letter to the NRC on April 3, 1990. The NRC has subsequently issued Information Notice No. 90-26, " inadequate flow of Essential Service Water to Room Coolers and Heat Exchangers for Engineered Safety-feature Systems",

to all holders of operating licenses or construction permits for nucicar power reactors to alert licensees of potential problems from using differential pressure drop to measure flow through heat exchangers.

5. Exit Interview The NRC team leader met with licensee representatives (denoted in paragraph

1) at the conclusion of the inspection on April 26, 1990, and via telecon on May 14, 1990. The NRC team leader sununarized the scope and findings of the inspection noted in this report. The NRC team 1cader also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the NRC team leauer during the inspection.

The licensee did not identify any such documents or processes as proprietary.

17

= = - . = - . - - . - - - - . = - - - - - - - _ - . . . -- -- - .-

o .

Vent v

1 Surge

=

LevelIndicator/ Alarm Tank r

Emergency Leak i Shutdown

=

Diesel Service Water System g

o EDG Heat Diesel Cooling Exchanger Water System .,

G  :

a t a

=

=

FIGURE 1. Emergency Diesel- SX System Interface

H2Recomb

~. t

-c4 SBGT e

A

-tM

' 3 A

M/U usw 6 q ,

t.eakage RHR HX f b N ^- M lll ,, , ,n -

U"3 lb '

~ ~

vass j lll

/ **'  !

n ,'

Fkm T%

XS **

RHR --

Ma'$ Fm., ' Coil SGTS

~

Rad Mon _ h Cc.i ~

Contes r, ,l.

1) _

N' Cabinet Lake Clinton '

( UHS Source) g g t

Circ Water Im@rRmm f c mter g ,

E

=

nc

-- EDGHX d 5 EDGHX -

FIGURE 2.. Simplified SX Division 1 Schematic (Major Heat Loads)

D Low High Side .

Side O Tap r Tap O i

i j

I d Pipe = = 8 Component = = d Pipe -

m i

' = .

P a

a FIGUf1E 4. Component Differential Pressure Drops

I

.

• f ( ENCLOSURE 5 s i m

ELGURE2 Chiiled Water Terminal Flow versus Heat T 100 -

00 -

E

• z -

4 E

$0

! t .

4 0 40 -

m u E

" 20 -

80 100 0 , ,

40 60 0 20 PERCENT DESIGN FLOW k

i l'

4 l

f  ! ENewsVRE 6 lable 1 Divisions 1 f. 2 Shutdown Service Water (SX)

Pre- and Post-balance Component flows Division 1_

Equipment Component I  % of Design Designation Flow Rate (GPM) Flow IVH075A j SX Pmp koom i Flow:

Design 82 100 As-Found 20.5 25 Minimum 16.0 19.5 As-Left 102 124 DVGOSSA SBGT Room Flow:

Design 90 100 As-Found 40.3 45 Minimum 31.4 35 As-Left 98.6 110 OVG07SA H Recombiner l!$om flow:

Design 82 100 As-Found 50.8 62 Minimum 39.6 48 As-Left 92.6 113 IVYO35 ECCS - RHR 1A HX Room Flow:

Design 60 100 t As-Found 23.0 38 4 Minimum 17.9 30 As-Left 70.9 118 k

T1.1 i i- 1 i

. g .-

o lable 1 (cont'd)

Equipment Component 4 of Design Designation Fivw Rate (GPM) Flow l l IVX135A l Inventer Room

! TE:

Design 20 100 l As-found 15.7 79 I

Minimum IP.2 60 As-Left 23.7 118 IVYO95 i MSIV leakage 1 koom l TE: l I

Design 60 100 As-Found 43.3 72 Minimum 33.7 56 As-Left 58 97 I

OVC13CA Control Room HVAC Chiller i Flow: 1 l

~

Design 800 100 As-Found 874 109 Minimum 804 100.5 l As-Left 849 106 OPR13A SGTS Exh Rad Monitor Cooler Flow:

Design 20 100 4

As-Found 13.8 69 Minimum 10.7 53 As-Left 19.3 96

, IDG11AA/1DC12AA EDG HX flow:

Design 450/600* 100/100 As-Found 1139/1092 253/232 Minimum. 1048/1005 233/167 As-Left 553/743 123/124 i

• Verified by Technical manual reference. j l T1.2 l

i i

f- ,

l 1

. lat'le 1 (cont'd)

' 1 Equipment Component  % of Design l Designation Flow Rate (GPM) Flow q l

1E12B001A RHR HX Ilow:

Design 5800 100 4466 77 As-Found Minimum 4243 73 As-Left 5671 98 IVX06CA Div. 1 Switchgear HX TTow:

Design 160 100 As-Found 231 144 l-Minimum 203.3 127 l

As-Left 207.5 130 IVY 02S ECCS RHR 1A Pump Room Flow:

Design 60 100 As-Found 52 87 Minimum 40.5 67 As-Left 88.1 147 1E12C002A RHR Pump Seal

^

Cooler Flow:

Design 20 100 As-Found 22 110 Minimum 17.1 85 As-Left 22 110 1

! IVYO15 ECCS LPCS Pump Room TE:

Design -

90 100 As-Found 57.5 64 Minimum 44.8 50

As-Left 106.8 119 T1.3

7 ,-

o

. lable 1 (cont'd)

Equipment Component 8s of Design Designation flow Rate (GPH) flow ,

f IVYO45 ECCS RCIC Pump koom

)

Tiow: 1 Design 18 100 As-round 10.1 56 7.9 44 Minimum As-Left 17.5 97 IVR095 CGCS Room Tlow:

Design 36 100 As-Found 7.1 20 Minimum 5.5 15 4 As-Left 27.4 76

^

IVP14CA Drywell Chiller Flow:

Design 2000 100 As-Found 2140 107 Minimum 2033 102 l As-Left 2058 103 IFC01AA

> Fuel Pool Cooling l HX TTow:

1 e Design 4143 100 As-Found 3376 81 Minimum 78 As-Left 3898 94 IVH07SB l SX Pump Room Flow:

ll Design 82 100 j

As-Found 38 46 Minimum 29.6 36 i

As-Left 99.5 121 l

i T1.4 I

l

, f~~ (

.', leble 1 (cont'd)

Equipment Component 8. of Design Designation finw Ratt (GPM) rion OlvlS10ti 2 OVG05SB SBGT Room IB Tlows gc, 100 Design 45 As-Found 40.3 31.4 35 Minimum 114 3 127 As-Left OVG075B H,, Recombiner Rm Tiow:

90 100 Design 20.9 23 As-Found 16.3 18 Minimum 72 80 As-Left IVYOSS ECCS RHR HX Room flow:

60 100 Design 26 43 As-Found 20.2 34 Minimum 76.5 127 As-Left IVX13SB Inverter Rm 1B Flow:

20 100 Design 15.4 77 As-Found 12 60 Minimum 20.9 105 As-Left IVY 10A MSiv Leak Otbd Room TTow:

Design 10 100 As-Found 12 120 9.4 94 Minimum As-Left 11 110 l

T1.5

lable 1 (cont'd) 4 of Design Equipmer.t Component Designation flow Rate (GPM) flon IVX145 Div 4 inverter hoom TlE:

Design 60 100 28.4 47 As-found 22.1 37 Minimum 66.5 111 As-Left OVC13CB Control koom liVKl~ Chi 11er flow:

Design 800 100 As-Found 905.6 113 Minimum 833 104 As-Left 872 109 1DG11AB/1DG12AB EDG HX flow:

l Design 450/600 100/100 As-found 1326/1362 295/227 L Minimum 1220/1253 271/209 l As-Left 625/751 139/125 1E1280018 RHR HX 18 flow:

Design 5800 100 As-found 5643 97 Minimum 5360 92 As-Left 6342 109 IVXO6CB-Div 2 Switchaear HX Condenser flows

. Design 160 100 As-found 74.9 47 Minimum 65.9 41 As-Left 178.8 112 i

l T1.6

y F ('

lable 1 (cont'd)

[quipment Component  % of Design Designation Flow kate (GPM) riow IVYO6S/1VYO75 ECC RHR Pump hoom TE:

Design 60 ca. 100 As-Found 34.7/35.8 58/60 Minimum 27/27.9 45/47 As-Left 75.4/64.2 126/107 1E120002B&C RHR Pump Seal Cooler Flow:

Design 20 et.. 100 As-Found 12.9/11.6 64/58 Minimum 10.0/9.0 50/45 As-Left 21.1/18.2 105/91 IVR125 CGCS Room Flow:

Design 36 100 As-Found 9.2 26 Minimum 7.2 20 As-Left 20.3 55 IVPO4CB Drywell Chiller IB TIow:

Design 2000 100 As-Found 2301 115 itinimum 2186 109 As-Left 2230 111 IFC01CB Fuel Pool Cooling HX TTow:

Design 4143 100 As-Found 4847 117 Minimum 4677 113 As-Left 3607 87 T1.7