ML20128L361
| ML20128L361 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/07/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128L329 | List: |
| References | |
| 50-298-96-19, NUDOCS 9610150033 | |
| Download: ML20128L361 (20) | |
See also: IR 05000298/1996019
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ENCLOSURE 2
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Docket No.
50-298
License No.-
Report No.:
50-298/96-19
Licensee:
Nebraska Public Power District
Facility:
Cooper Nuclear Station
Location:
P.O. Box 98
Brownville, Nebraska
Dates:
July 28 through September 7,1996
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Inspectors:
Mary Miller, Senior Resident inspector
Chris Skinner, Resident inspector
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Ray Azua, Reactor Inspector, Region IV
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Approved By:
Elmo Collins, Chief, Project Branch C
Division of Reactor Projects
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ATTACHMENT:
Supplemental Information
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9610150033 961007
ADOCK 05000298
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EXECUTIVE SUMMARY
Cooper Nuclear Station
NRC Inspection Report 50-298/96-19
This routine, announced inspection included aspects ,f licensee operations, engineering,
modifications and testing, maintenance, plant suppon. and Updated Safety Analysis
Report. The report covers a 6 week period of residen 1spections.
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Operations
Routine operations were generally professional and well controlled. Operators
questioned risk assessment by maintenance planning, and generally maintained
strong ownership and support of the plant. Control room response to a reactor
water cleanup pump trip was strong.
Operators demonstrated a strong questioning attitude regarding plant activities.
Operators identified that a work package from maintenance for replacement of a
primary containment boundary valve did not have the correct postmaintenance test.
Also, operators identified that interim instructions provided to address a fire were
technically incorrect and may have needed approval by the station operations
review committee. One noteworthy exception was that operations did not identify
the need for an operability assessment for installation of an unqualified relay and
housing in 4160V vital bus undervoltage circuitry. The effect of this relay on the
operability of plant systems was not fully understood until questioned by the
inspector.
Maintenance
Maintenance activities were performed in a generally effective manner.
Inspectors identified two examples of violations, one associated with the high
pressure core injection turbine stop valve and one associated with the diesel
generators, in which the test equipment was not removed prior to declaring the
equipment operable.
During replacement of the emergency transformer undervoltage relay, the inspectors
identified a violation in that maintenance activities resulted in jumper installation on
operable Vital Bus F undervoltage circuitry without an evaluation or operability
assessment.
Inspectors found that some minor performance weaknesses associated with
preventive maintenance would not have been addressed by the Phase ill preventive
maintenance improvement.
Initial corrective actions to address a maintenance work package which did not
contain proper postmaintenance testing were weak. After inspector questioning,
additional actions were initiated.
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Enaineerina
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Inspectors found that technical support for electrical maintenance was weak in that
incomplete evaluations were performed. These resulted in the impact of
maintenance activities on operability not being fully understood.
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Engineering was proactive in identifying issues and was effectively addressing them
from a safety perspective. Also, the licensee continued to identify and address
discrepancies between USAR descriptions and the plant.
Plant Support
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Initiallicensee review of a switch found out of position was incomplete in that
security reporting and investigation were not conside,ed until questioned by the
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inspectors. Subsequent corrective actions were strong.
Technical Support Center and Emergency Operations Facility ventilation and
electrical boundaries appeared appropriate.
The response by health physics to the reactor cleanup pump trip and coupling leak
was good.
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Report Details
I. Operations
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Conduct of Operations
01.1 General Comments (71707)
Inspectors observed that routine operations were generally professional and well
controlled. Shift turnovers were thorough and addressed relevant plant conditions.
Operators questioned risk assessment by maintenance planning and generally
maintained strong ownership and support of the plant.
01.2 Reactor Water Cleanuo Isolation
a.
Inspection Scope (71707)
The inspectors rewewed control room response to a reactor water cleanup pump
trip. Inspectors also reviewed applicable procedures, logs, and drawings related to
the reactor water cleanup pump trip and interviewed the control room operators,
b.
Observations and Findinas
On August 22,1996, the control room operators responded to a reactor water
cleanup pump trip. During the event, the control room supervisor implemented the
following procedures: Procedure 5.8, " Emergency Operating Procedures," Flow
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Chart 5A (high temperature in the Reactor Water Cleanup Pump Room A),
Procedure 2.4.2.5.1," Reactor Water Cleanup System Failure," due to the filter
demineralizer and pump trip, and Procedure 2.4.2.1.2,"Small Leak Outside Primary
Containment." The licensee investigated the potential for a mechanical seal leak, a
bonnet leak on the discharge valve, and a leak on the discharge piping. Operators
determined that the pump mechanical seal had f ailed. Within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, operations
had backwashed and precoated the filter demineralizers and had Pump B in service.
The inspectors found that operators wrote problem identification reports to
document the event in accordance with the corrective action program. The
inspectors developed a time line from observations, interviews with the operators,
review of control room logs, and the alarm printout and found no discrepancies.
c.
Conclusion
The operator's response to the reactor water cleanup pump trip was appropriate and
the event was documented accurately.
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04
Operator Knowledge and Performance
04.1 4160V Bus F Undervoltaae Circuitry Maintenance
a.
Inspection Scope (71707)
On September 5,1996, at approximately 7 a.m., the inspector observed the
replacement of Relay EE-REL-(27-ET3), the Division I emergency transformer second
level undervoltage relay.
b.
Observations and Findinas
The relay functions as a permissive to allow the emergency transformer breaker to
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close to supply electrical power to the 4160V vital bus if sufficient voltage is
available from the emergency transformer. The inspector found that operations had
entered the Technical Specification action statement associated with the emergency
transformer power supply to vital Bus F.
The licensee identified that the replacement relay supplier was not certified for
essential equipment. The licensee decided to release the relay from the warehouse
in a hold status and install the relay while they completed determining the
qualification status of the supplier. Problem Identification Report 2-03758 was
initiated to document the qualification status of the relay, and the relay and housing
were then installed.
The inspectors found that the review to evaluate the effect of the installation of the
unqualified relay and housing on operability had not considered the dc power to the
relay. Problem Identification Report 2 00861 was written to address the lack of an
evaluation of the dc relay power circuit, and to determine the operability of the DC
power circuit loop, during relay replacement. The relay replacement had been
completed at about 7:15 a.m. on September 6. The inspector identified the concern
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about 10:30 a.m. The licensee informed the control room of the potential
operability concern about 2 p.m., and started a 24-hour period for preparation of an
operability assessment. The relay qualification was completed within the following
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The assessment addressed the time for which the action statement had
not been entered and concluded that the relay and housing were operable.
Technical Specification 1.0.J applies for inoperable second level undervoltage
protection function for a vital 4160V bus and is a 6-hour shutdown action
statement.
10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting
quality shall be prescribed by documented instructions or procedures, of a type
appropriate to the circumstances, and shall be accomplished in accordance with
these instructions or procedures. Procedure 0.5, " Problem identification and
Resolution," Revision 8, Step 4.4.3, states, in part, that an operability assessment
is required for conditions which could potentially affect the operability of structures,
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systems, and components. The f ailure to perform an operability assessment to
address Prob lem identification Report 2-03758 regarding the installation of the
unqualified relay and housing is a violation (298/96019-01).
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c.
Conclusions
The inspector identified that no operability evaluation had been performed to
address the installation of an unqualified relay and housing in the operable 4160V
Vital Bus F undervoltage protection circuit. The effect of this relay on the
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operability of plant systems was not fully understood. This is a violation. The
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subsequent evaluation found that the relay and housing were operable.
04.2 Appendix R instructions
8nspection Scope (71707)
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The inspector assessed the control room actions associated with compensatory
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b.
Observations and Findinas
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On August 20,1996, the inspector reviewed the instructions provided to the
control room by engineering concerning recently identified Appendix R circuit
vulnerabilities. The control room supervision had returned the instructions to
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engineering since the instructions were not technically complete and did not
properly address overriding interlocked cabinet doors. The control room also did not
accept the information from engineering because it involved multiple step
instructions, which had not been approved by the Station Operations Review
Committee. Further discussion with engineering resulted in more appropriate
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guidance being pro.ided to the control room.
c.
Conclusions
Control room personnel show a good questioning attitude and high standards by
refusing to accept incomplete instructions.
04.3 Postmaintenance Test for Primary Containment Valve
a.
Inspection Scope (71707)
The inspector assessed the actions of control room personnel associated with a
maintenance work package.
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b.
Observations and Findings
While reviewing a maintenance work package to replace a primary containinent
valve, the control room shif t supervisoi identified that the package did not include
the proper postmaintenance testing requirement of 58 psi. The supervisor returned
the package to maintenance and initiated a problem identification report to
document the problem. The work to replace the valve was postponed to an outage.
No primary containment boundary work was actually accomplished using the work
package. The corrective actions for the problem identification report are discussed
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Conclusions
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Control rocm personnel demonstrated a strong awareness of primary containment
testing requirements.
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04.4 River Level Measurements
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a.
Inspection Scope (71707)
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The inspector reviewed logs and the emergency procedure associated with high
river level,
b.
Observations and Findinas
On August 12,1996, while in the flood emergency procedure, the inspector noted a
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logged early morning river level of 889 feet,6 inches. About 10 a.m., the inspector
was informed by the shif t supervisor that the river level was 888 feet, 2 inches.
The inspector questioned the validity of the measurements, based on the drop of
over a foot in a fe a hours. The control room staff identified that river level was
taken from variour bays without clear procedural controls.
The licensee stated that the safety significance of the discrepancy was minimal
since the major procedure response steps such as a plant shutdown occur at river
levels above the tops of the bays and the level could be measured on the sides of
buildings as occurred during 1993. At the end of the inspection period, the licensee
was evaluating whether other plant parameters were not measured in a consistent
manner. None had been identified,
c.
Conclusions
The lack of consistent measurement of river level was considered a weakness. The
licensee response to this issue was appropriate.
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Quality Assurance in Operations
07.1 Safety Review and Assessment Board (SRABJ
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a.
Inspection Scope (71707)
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The inspector observed the SRAB meeting conducted in July 1996.
b.
Observations and Findinas
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The inspector observed that the focus of SRAB activities involved efforts beyond a
compliance-based perspective. Items addressed included 10 CFR Part 50,
Appendix R, activities, quality assurance and line organization relationships, possible
precursor events,10 CFR 50.59 program vulnerabilities,10 CFR Part 50
Criterion XVI problem identification activities, SRAB involvement in evaluating plant
processes, SRAB member observations of crew chiefs and maintenance
management involvement in plant activities, and SRAB member observations during
a procedure compliance standdown.
c.
Conclusions
SRAB deliberations were generally safety-focused.
II. Maintenance
M1
Conduct of Maintenance
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M 1.1 General Comments
a.
Inspection Scope (62706 and 61726)
The inspectors observed all or portions of the followinc, work activities:
Procedure
Title
MWP 96-1398
Relay Replacement and Calibration
6.1 ADS.304
ADS Water Level
6.1 RPS.307
Calibration and Functional (Division 1)
MWP 96-1362
Reactor Building Ventilation Flow Monitor
Maintenance
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MP 96-112
Appendix R Modification to Diesel Generator 2
circuitry
MP 96-113
Appendix R Modification to RCIC Safe Shutdown
Circuitry
MWR 96-1374
Torque nut on High Pressure Coolant injection
Stop Valve, HPCI-HO-HOV10, Coupling
(Maintenance Procedure 7.2.71).
HPCI IST and Quarterly Test Mode Surveillance
Operation
MWR 96-1398
Troubleshooting and Replacement of EE-REL-(27-
ET3), Emergency Transformer Undervoltage
Relay
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b.
Findinas and Observations
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Inspectors observed that procedures were followed and activities were properly
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controlled. Staff knowledge and performance were good with exceptions noted
later in this report,
c.
Conclusion
Maintenance activities were performed in a generally effective manner.
M1.2 4160V Undervoltaae Circuit Relav Replacement
Inspect on Scope (62707)
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a.
On September 5,1996, at approximately 7 a.m., the inspector observed the
replacement of Relay EE-REL-(27-ET3), the Division i emergency transformer second
level undervoltage relay,
b.
Observations and Findinas
Work Package 96-1398 included procedures for relay replacement, calibration, and
instructions to identify and install electrical jumpers to provide continuity on the
relay circuits as needed. Jumpers were needed to provide power to the
downstream relays in the de circuit and were installed using a jumper control log.
The inspector questioned the potential effects of the jumpers on other components
in the circuit, since, based on review of the drawings, several additional relays
appeared to be affected. Section 04.1 discusses that the effects of the unqualified
relay and housing were not properly considered.
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The licensee confirmed that additional relays were affected by the installed jumpers.
These relays included the Bus F Second Level Undervoltage Relays (27-1F2 and A2)
and the load shed lockout relay and timers for the 4160V bus undervoltage
essential functions. Failure of this circuit due to a blown fuse could prevent the
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second level undervoltage relay function from actuating on the Division 14160V
bus.
At the end of the inspection period, the licensee had not determined the effects of
the jumper installation on operability. Problem identification Report 2-00861,
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written to address the lack of an evaluation of the dc relay power circuit and to
determine the operability of the dc power circuit loop during relay replacement, will
track the licensee's evaluation of the impact of the jumpers. The jumpers were only
installed for about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. They were removed after relay installation, at about
7:15 a.m. on September 6.
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10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting
quality shall be prescribed by documented instructions or procedures, of a type
appropriate to the circumstances, and shall be accomplished in accordance with
these instructions or procedures. Procedure 7.3.16, Revision 8, " Replacement of
Low Voltage Relays," Step 6.1, directed engineering, with operations, to evaluate
jumpers required to perform the replacement and to determine the extent of circuits
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affected. This evaluation was not performed appropriately. Jumpers were installed
in essential undervoltage relay circuity with neither an operability evaluation nor
entry into appropriate Limiting Condition For Operations. The installation of jumpers
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to f acilitate replacement of a relay and its associated huusing, without fully
researching and evaluating potential interactions with respect to operability, is a
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violation (298/96019-01).
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c.
Conclusion
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The inspector identified that procedures had not been followed when jumpers were
installed on operable 4160V Vital Bus F undervoltage protection circuitry without
proper evaluation. This is a violation.
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M1.3 Hinh Pressure Core Iniection (HPCI) Svstem Test Eauioment
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a.
Inspection Scope (61726)
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On August 27,1996, inspectors observed performance of Surveillance
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Procedure 6.HPCI.103, "HPCI IST and Quarterly Test Mode Surveillance Operation,"
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Revision 2, and followed up on the completion of the surveillance test. Discussions
were held with maintenance workers, system engineers, control room operators,
and supervisors.
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b.
Observations and Findinas
At 6:15 a.m. on August 28,1996, while touring the control room, the inspectors
found that the surveillance test procedure was still open. The inspectors also found
from the shif t supervisor's log that the HPCI system had been declared operable
following the completion of the surveillance test. Licensee personnel stated that, on
August 27, during the restoration section of the procedure, an operator identified a
step reference number error in Step 9.2. This step directed the removal of a lanyard
potentiometer from the stop valve. The shift supervisor was informed of the
procedural error and put the procedure on hold until the error could be corrected.
Step 9.2 was not completed. The shift supervisor subsequently reviewed the
results of the surveillance test and declared the high pressure coolant injection
system operable at 4 p.m. on August 27 with the lanyard potentiometer installed.
Discussions with the shift supervisor indicated that no evaluation had been
performed which demonstrated that the system was operable with the lanyard
potentiometer installed. The inspectors found that the system engineer had not
been informed and was not aware of these activities. The test equipment had been
installed for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on the system without an evaluation of the affect on
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operability.
10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality
shall be prescribed by documented instructions or procedures, of a type appropriate
to the circumstances, and shall be accomplished in accordance with these
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instructions or procedures. Surveillance Procedure 6.HPCl.103, "HPCI IST and
Quarterly Test Mode Surveillance Operation," Revision 2, Step 9.2, specified to
remove the lanyard potentiometer. The f ailure to remove the potentiometer prior to
declaring the high pressure coolant injection system operable is an example of a
violation of 10 CFR Part 50, Appendix B, Criterion V (298/96019-02).
The procedural error was corrected on August 28, when the test equipment was
removed and the surveillance procedure was completed at 8 a.m. Engineering
subsequently determined that the stop valve had been operable with the lanyard
potentiometer attached.
c.
Conclusion
The inspectors identified that procedures were not followed when test equipment
was not removed with the high pressure coolant injection system considered
operable. This is a violation.
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M1.4 Diesel Generator Test Eauipment
a.
Inspection Scope (62707)
On August 28,1996, the inspectors monitored portions of the maintenance activity
performed on Diesel Generator 2. On August 29, the inspectors performed a
postmaintenance walkdown.
b.
Observations and Findinas
During the post maintenance walkdown, the inspectors identified that a motion
encoder, bracket, and extension piece used with surveillance test equipment were
lef t installed on the diesel generator from the testing the day before. The shift
supervisor indicated that removal or installation of test equipment in advance of
and/or after the allowed outage time for the performance of a surveillance test was
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a common practice. System engineers also indicated this was common. The
inspectors found that the 10 CFR 50.59 safety evaluation performed for
Procedure 7.2.53.7, " Operation of Engine Analysis Equiupment," Revision 0.2,
stated that the test equipment should only be installed within the allowed outage
time or when the diesel generator was inoperable. These requirements were not
incorporated into the procedure and allowed the emergency diesel generators to be
considered operable with the test equipment installed.
10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting
quality shall be prescribed by documented instructions or procedures, of a type
appropriate to the circumstances, and shall be accomplished in accordance with
these instructions or procedures. The f ailure to incorporate procedure instruction to
have the test equipment removed prior to declaring Diesel Generator 2 operable,
consistent with the safety evaluation, is a violation (298/96019-02). Licensee
evaluation later concluded that the equipment was operable with the test equipment
installed.
c.
Conclusions
The inspectors identified that the emergency diesel generator test procedures were
not appropriate in that no instructions were provided to ensure that test equipment
was remnved before considering the equipment operable. This is a violation.
M6
Maintenance Organization and Administration
M6.1 Phase lll Preventive Maintenance improvement Procram
a.
insoection Scone (62707)
Inspectors reviewed the Phase ll1 Improvement Plan for actions associated with
preventive maintenance in view of recent performance weaknesses.
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b.
Observations and Findinas
The inspectors had noted several minor performance weaknesses in preventive
maintenance activities for items not directly associated with plant systems. These
included inventories, emergency operating procedure contingency materials, and
preventive maintenance accomplished as corrective maintenance activities.
The improvement plan actions included integrating the preventive maintenance for
plant systems and did not address the types of performance weaknesses noted
above. The licensee acknowledged that these weaknesses should be addressed and
stated that they planned to enhance the Phase ill plan to include preventive
maintenance which was not directly associated with plant systems,
c.
Conclusions
Inspectors found that the Phase lli improvement Plan only addressed preventive
maintenance activities for plant systems. Inspectors had previously identified minor
performance weaknesses in preventive maintenance activities not directly
associated with plant systems.
M7
Quality Assurance in Maintenance Activities
M 7.1 Primary Containment Testina Reauirements
a.
Inspection Scope (62707)
On September 6,1996, the inspector evaluated the status of corrective actions to
preclude maintenance on primary containment valves without adequate primary
containment pressure testing.
b.
Observations and Findings
Section 04.3 of this report discusses a control room review of a primary
containment work package which identified inadequate postmaintenance testing
requirements. The problem identification report written to address this occurrence
had been categorized as a work item only, with the work deferred to the following
outage. The inspector found that the problem identification report was closed after
rescheduling the maintenance. No corrective actions had been taken or planned to
address the cause of inadequate primary containment postmaintenance testing
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requirements. This appeared incomplete, since the work control staff had prepared
a maintenance work package which would not have adequately accomplished
primary containment testing and had provided this package to the control room as
ready for work.
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Af ter discussion with the inspector, the licensee initiated a second problem
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identification report to determine how the design requirements of primary
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containment boundary work should be verified after maintenance activities.
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c.
Conclusions
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Initial corrective actions for this occurrence were weak in that they did not address
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primary containment postmaintenance testing requirements by maintenance
planners.
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E2
Engineering Support of Facilities and Equipment
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E2.1
Unaualified Relav and Housina
a.
inspection Scope (37828)
The inspector assessed the technical support for the replacement of an
undervoltage relay.
b.
Observations and Findinas
Sections 04.1 and M1.2 of this report discuss the evaluation of the installation of
an unqualified replacement relay and housing and the lack of an evaluation of the
affect of jumpers on operability. The evaluation performed for electrical jumpers
was incomplete in that only the need for jumpers was considered. The evaluation
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did not address the affect of the jumpers on undervoltage circuitry operability.
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Similarly, the evaluation of the problem identification report for relay qualification
was incomplete in that it addressed only the circuit which the relay monitored. The
review did not address the effect of the unqualified relay housing on the de power
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circuitry. Subsequently, the unqualified relay was evaluated to be acceptable. The
jumpers were only installed for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
c.
Conclusion
Technical support for the relay replacement was weak in that incomplete
evaluations were performed. These incomplete evaluations resulted in the impact of
maintenance activities on operability not being fully understood.
E2.2 Temporary Modifications Installed by Procedures
a.
Inspection Scope (37828)
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The inspector reviewed the design controls for jumpers and temporary modifications
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which were installed by procedures.
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b.
Observations and Findinas
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The inspector found that design changes may affect jumpers and plant temporary
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modifications which were installed by operations procedures. A portion of
operations review of design modifications involves determining if plant jumpers
invoked during emergency operating procedures may be affected. The inspector
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noted that jumpers installed by procedures which were not emergency procedures
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could also be affected. The only barrier in place to prevent circuit alterations which
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could affect these jumpers was the review by operations for emergency operating
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procedures. The inspector also questioned the fact that few jumpers had been
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tested, and past modifications may have affected these jumpers. The inspector
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noted that this question was raised during the recent engineering self-assessment,
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but was not addressed as a concern.
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The licensee stated that the potential that past modifications may have altered
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circuits used by jumpers, the lack of inclusion of the concern in the engineering self-
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assessment, and the lack of testing when opportunities were available were
concerns which would be evaluated to determine their safety consequences. A
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problem identification report was initiated to address these issues. The licensee
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planned to address the full scope of these concerns and determine if past
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modifications have affected jumpers, in.the first quarter of 1997. The NRC plans to
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review the results of the licensee's determination. This is an inspection followup
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item (298/96019-03).
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E2.3 Enaineerina Identification of issues
a.
Insoection Scope (37751)
The inspector reviewed activities by engineering to identify and evaluate issues.
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b.
Observations and Findinas
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The licensee identified that the scram discharge isolation drain valves contained only
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one automatic isolation valve per scram discharge volume. The other drain isolation
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valve was a manual valve. This is not typical of scram discharge valve installations,
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however, the licensee determined that the configuration had been approved by a
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license amendment. The associated operability evaluation addressed the
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consequences of a failure of the automatic drain valve and pointed out that the
consequences were bounded by existing analyses. The inspector noted that
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operations crews routinely train with this scenario and have various options to
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respond to the condition. The operability evaluation did not document the expected
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operations response and engineers were unaware that operations responded to this
event in training on a routine basis. The licensee has initiated plans to correct the
condition with a plant modification.
The licensee identified that the reactor water cleanup system high energy line break
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assumed a 4 inch line break. However, a 6-inch line is in place downstream of the
outboard isolation valves and upstream of the 4-inch line. The licensee evaluated
that, for each case, they are bounded within equipment qualification assumptions of
analyzed accidents. However, the 6-inch line break scenario may result in
exceeding the design pressure of a block wall designed as an equipment access
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port, currently stacked with concrete block and encased in corrugated steel.
The licensee concluded that the failure of the access port wall would not be
significant, since the area and equipment outside the port is nonessential, or located
,
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several feet away, and pressure would drop significantly during incremental f ailure
of the wall. Further detailed evaluation indicated that the outer metal panel may
exceed yield stress and separate at the lower edge. The inner panel and blocks
would not be expected to deform or translate significantly. The licensee issued an
industry notification concerning this vulnerability. The licensee operability
evaluation determined that the high energy line break environmental effects were
bounded and plans to analyze this further and implement permanent corrective
action as required,
c.
Conclusion
The licensee was proactive in identifying engineering and configuration issues, and
was effectively addressing them from a safety perspective. Only minor weaknesses
were noted.
E2.4 Identification of USAR Discrenancies
a.
Scone (37751)
The inspector reviewed the status and issues associated with the licensee initiative
to identify and resolve USAR discrepancies (Inspection Followup Item 298/96007-
06, open).
b.
Observations and Findinas
The licensee has continued to identify cases where the plant practices and
configurations differ from that described in the USAR. Most are of minor safety
significance, and all have been or are being evaluated. Changes to the USAR have
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been initiated. About 25 items are in the process of evaluation.
One issue involved the procedure for transferring water from the torus to the
condensate system during shutdown conditions. This procedure was approved
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several years ago and has been used; however, the capability to perform this
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transfer is not described in the USAR. At the end of the inspection period, the
licensee was evaluating the acceptability of this flow path.
Also, for several event scenarios discussed in USAR and design basis documents
and tables, the licensee determined that the pump flows and system configurations
,
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listed for specific scenarios do not clearly indicate context and do not cover
common scenarios making understanding difficult. The licensee initiated a problem
identification report and was taking actions to review equipment performance
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requirements with respect to the information in the USAR.
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Other findings involved ambiguity of descriptions, drawings and tables which are
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not current, lack of license amendment references, such as station blackout and
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anticipated transient without scram requirements, and typographical errors.
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a
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inspectors performed a routine review of the USAR description of the reactor
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coolant system. The USAR stated that the control rod withdraw piping and Scram
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discharge volume piping were not part of the reactor coolant system boundary.
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Inspectors noted that the ASME Class I reactor coolant boundary as described in
plant drawings and procedures included the Scram Discharge Voiume and portions
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of the control rod withdraw piping. The licensee responded by changing the piping
and volume to ASME Class 11, consistent with the USAR and standard industry
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practice. The licensee stated that the inspection requirements would not be
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changed as a result of the lower classification,
c.
Conclusions
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The licensee continued to identify and properly address discrepancies between
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USAR descriptions and plant practices and equipment.
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IV. Plant Support
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R1
Radiological Protection and Chemistry Controls
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R 1.1 Radiation Protection Response to a Reactor Water Cleanuo Pumo Trio and Leaks
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a.
Inspection Scope (71750)
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On August 22,1996, the inspectors reviewed surveys and questioned the radiation
protection technicians concerning the radiation protection response to a reactor
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water cleanup pump trip.
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b.
Observations and Findinos
inspectors found that the radiation protection technicians had updated the surveys
to include the steam and water leaks, taken air samples, and contained and directed
the leaks to the drains to prevent further contamination.
c.
Conclusions
The inspectors determined that radiation protection technicians appeared to have
taken appropriate actions in response to a reactor water cleanup pump trip.
P2
Status of Emergency Preparedness Facilities, Equipment, and Resources
P2.1
Insoection of Emeraency Operations Facility and Technical Support Center
Ventilation and Electrical Power Systems
a.
inspection Scope (71750)
The inspectors walked down the Emergency Operation Facility (EOF) and Technical
Support Center (TSC). Both f acilities were undergoing major modifications. The
inspectors physically inspected all of the penetrations leading into each of the
facilities and questioned licensee personnel on the ventilation systems and power
sources for each f acility (emergency and nonemergency power), in addition, the
,
inspectors reviewed Surveillance Procedures 15.HV.101," EOF Emergency Fan
Charcoal and HEPA Filter Leak Test, Fan Capacity Test, and Charcoal Sampling,"
Revision 0, and 15.HV.102, "TSC Emergency Fan Charcoal and HEPA Filter Leak
,
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Test, Fan Capacity Test, and Charcoal Sampling."
b.
Observations and Findinas
The inspectors found that the penetrations were appropriately sealed to support
habitability within each f acility following a design basis accident. Availability of
emergency power to the appropriate equipment necessary to support the f acility,
during a loss of normal power, was noted. The surveillance procedures were
appropriate for monitoring the operability of the emergency fan charcoal and high
efficiency particulate air filter in each facility,
c.
Conclusion
The facility penetrations in both the EOF and TSC appeared satisfactory to support
habitability.
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S1
Conduct of Security and Safeguards Activities
S 1.1
Lack of Guidance to Inform Security of Events
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a.
Insoection Scope (71750)
Inspectors evaluated whether a switch found in an incorrect position was reported
to security.
b.
Observations and Findinas
An operator found an emergency diesel generator fuel oil pump switch in an
incorrect position. As a result of the incorrect switch position, the diesel was
operable since the pump would have started automatically on it's diesel fuel tank
low level. It would not have started automatically on a low level on the other
diesel's fuel tank.
The inspector observed that security had not been informed of the mispositioning of
the switch and, consequently, had not determined if the event was reportable under
10 CFR Part 73 requirements and had not reviewed the event for misconduct. The
licensee had not determined a definite root cause of the mispositioned switch.
The event was subsequently determined not to be reportable and no potential for
misconduct was found. The inspector questioned whether security should routinely
be informed of occurrences such as this. The licensee responded by conducting
briefings of supervisors to ensure that these types of events were reported to
security. The licensee planned to trend these types of events and develop
procedural guidance to inform security of events such as these.
c.
Conclusion
Initial review of this occurrence by the licensee was incomplete in that security
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reporting and investigation were not considered until questioned by the inspector.
Security and corrective action group response was strong in that briefings were
performed promptly to ensure that these types of occurrences be reported to
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security. Procedure revisions to include this guidance were initiated promptly.
VI. Manaaement Meetinas
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
exit meeting on September 10,1996. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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SUPPLEMENTAL INFORM ATION
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
Mike Boyce, Engineering Manager
Dan Buman, Design Engineering Manager
)
Jack Dillich, Maintenance Manager
)
Rick Gardner, Operations Manager
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Jim Gausman, Plant Engineering Manager
Robert Godley, Nuclear Licensing and Safety Manager
Philip Graham, Site Manager
Mike Pec' ham, Plant Manager
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 37828: Installation and Testing of Modifications
IP 61726: Surveillance Observation
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IP 62707: Maintenance Observation
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IP 71707: Plant Operations
IP 71750: Plant Support Activities
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ITEMS OPENED AND UPDATED
Opened
298/96019-01
failure to properly assess operability of unqualified relay
installed in 4160v circuit (Section 04.1) and failure to properly
evaluate jumpers installed in 4160v undervoltage circuitry
(Section M1.2)
298/96019-02
inappropriate installation of test equipment on safety-related
equipment (Sections M1.3 and M1.4)
298/96019-03
IFl
potentiallack of design controls and testing of jumpers in
operating, annunciator responses, and abnormal procedures
(Section E2.2)
Updated
298/96007-06
IFl
licensee initiative to address Final Safety Analysis Report
discrepancies (Section E2.4)