ML20133C840
| ML20133C840 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/27/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20133C768 | List: |
| References | |
| 50-282-96-14, 50-306-96-14, NUDOCS 9701080109 | |
| Download: ML20133C840 (18) | |
See also: IR 05000282/1996014
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U.S. NUCLEAR REGULATORY COMMISSION
. REGION III
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Docket Nos: 50-282, 50-306
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Report No: 50-282/96014, 50-306/96014
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i Licensee: Northern States Power Company
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Facility: ' Prairie Island Nuclear Generating Plant
$ Location: 1717 Wakonade Drive East
Welch, MN 55089
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Dates: October 9 - November 19, 1996
Inspectors: S. Ray, Senior Resident Inspector
R. Bywater, Resident Inspector
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Approved by: J. Jacobson, Chief, Projects Branch 4
Division of Reactor Projects
9701000109 961227
PDR ADOCK 05000282
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EXECUTIVE SUMMARY
Prairie Island Nuclear Generating Plant, Units 1 & 2
NRC Inspection Raport 50-282/96014,50-306/96014
This inspection included aspects o# licensee operations, maintenance,
engineering, and plant support performed by the resident inspectors.
Operations
a The inspectors . observed that the conduct of routine plant operations was
generally good. Operators were observant and knowledgeable of plant
conditions. Shift turnover meetings were excellent, logs and verbal
communications were usually good. (Section 01.1)
- . The inspectors identified that the licensee failed to test the redundant
diesel generator as required when one diesel generator was determined to
be inoperable. This was due to a licensee misinterpretation of the
requirements but was a violation of Technical Specifications.
(Section 01.2)
. The inspectors and licensee determined that several cable tray
separation discrepancies existed in addition to those previously
identified. (Section 02.1)
l . The inspectors observed that licensee activities associated with spent
l fuel cask loading were performed carefully and correctly.
l (Section 02.2)
Maintenance
. Inspector observed maintenance and surveillance activities were well !
l conducted with good communications, proper pre-job planning, safe work
practices, and excellent coordination between departments.
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(Section M1.1)
l . Operators failed to perform two steps in s diesel generator test
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procedure which resulted in a unanticipated start of the engine and a
violation of Technical Specifications. (Section M1.2)
l . The licensee made a conservative initial report to the NRC concerning
, the above event while the reporting requirements were clarified.
(Section M1.2)
. The inspectors determined that cotter pins on spindle nuts on main steam
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relief valves appeared to be properly installed and that maintenance
l procedures for relief valve assembly were adequate to prevent the
l problem that other facilities had with the cotter pins. (Section M2.1)
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. The licensee identified an inadequate surveillance for component cooling
pumps during activities associated with NRC Generic Letter 96-01. This
', was considered a non-cited viclation. (Section M3.1)
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Enaineerina
. The inspectors determined that licensee corrective actions for
previously identified problems with 480-volt motor starters were behind
l the original schedule but still adequate. (Section E2.2) ;
Plant Support
. The inspectors deternined that licensee operation of the hypobromous
acid feed system a short time before the system was completely turned
over for operations following a major modification was acceptable.
(Section R3.1)
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Report Details
Summary of Plant Status
Both units operated at or near full power for the entire inspection period
except for brief power reductions for various testing and maintenance
activities.
During this period the fifth dry spent fuel storage cask was loaded and
l transported to the Independent Spent Fuel Storage Installation.
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On Nove'nber 13, 1996 the licensee submitted a letter to the NRC requesting
that the Commission's review of the recently submitted license application for
an offsite Independent Spent Fuel Storage Installation be suspended pending
the outcome of the Minnesota Court of Appeal's review of a lawsuit involving
l the issue. On November 15, 1996, the NRC Spent Fuel Project Office staff l
responded by letter and granted the request for suspension of review !
l activities.
I. Operations
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l 01 Conduct of Operations
l 01.1 General Comments
a. Inspection Scope (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent
I reviews of plant operations. These reviews included observations of
control room evolutions, shift turnovers, operability decisions,
l logkeeping, etc. Updated Safety Analysis Report (USAR) Section 13,
l " Plant Operations," was reviewed as part of the inspection.
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b. Observations and Findinas
, Operators were attentive to their panels and knowledgeable of the cause
i of annunciators and unusual plant conditions. Both the operators and
supervisors were cognizant of the status of ongoing surveillance testing
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and significant maintenance activities.
l Shift turnover meetings were disciplined, comprehensive, and attended by
representative of all appropriate departments. All necessary
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information on plant conditions, expected evolutions, recent problems,
significant changes to procedures, etc. were covered. During the
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turnover meetings operators remained in view and attentive to their
l panels. The supervisors conducting the meetings gave the opportunity
l for all members of the crew to contribute information.
! Both control room and outplant operators were diligent in identifying
equipment problems and initiating work orders. Logs were accurate,
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complete, and timely. Verbal communications between operators was
usually in accordance with management expectations.
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c. Conclusions
The inspectors observed that the conduct of routine plant operations was
generally good. No significant operational challenges occurred during
the inspection period. One problem with operators performing a
surveillance activity is discussed in Section M1.2 of this report.
01.2 Failure to Demonstrate Operability of the Redundant Diesel Generator
with one Diesel Generator Inocerable
a. Insoection Scope (92901)
On November 14, 1996, an outplant operator noticed that ventilation
supply fan dampers for the D5 diesel generator were not controlling
properly. The diesel was declared inoperable until the problem was
repaired. However, the inspectors noted that the redundant diesel
generator was not tested with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by Technical
Specification 3.7.B.1. The inspectors reviewed the licensee's decision
process for not conducting that test. USAR Section 8.4, " Plant Standby
Diesel Generator System ," was reviewed as part of the inspection.
b. Observations and Findinas
The system engir,eer was contacted to evaluate the diesel ventilation
system immediately after the operator's finding. The engineer
determined that the dampers were failed in such a position that outside
air cooling would not be supplied. In that condition, the engineer
determined that the engine might not be able to perform its intended
function and the diesel was declared inoperable.
The operators and engineer immediately determined that the ventilation
dampers on the redundant D6 diesel generator were operating normally.
The problem appeared to be with loose connection on the controller for
the 05 ventilation. The problem was repaired later the same day.
Also on the same day, the licensee's Operations Committee, led by senior
plant management, reviewed the issue and determined that there was no
common mode problem and that testing of the D5 diesel was not necessary.
Technical Specification 3.7.B.1 required, in part, that during startup
or power operation, one diesel generator may be inoperable for 7 days
provided that operability of the other diesel generator is demonstrated
by performance of surveillance requirement 4.6.A.1.e within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
That requirement applied unless the diesel generator was inoperable due
to preplanned preventative maintenance or testing. Surveille. ace
requirement 4.6.A.I.e specified a slow start and 60 minute loaded run of
the diesel (the normal monthly surveillance test).
The Technical Specification Bases for Section 3.7 stated that "following
the inoperability of a diesel generator, the redundant diesel generator
is tested to prove that the cause of the inoperability does not affect
both diesel generators." Licensee management indicated they believed
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they had adequately proved that the cause of the inoperability of the D5
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diesel generator did not affect both diesel generators and therefore
that the Bases of the Technical Specifications allowed them not to test
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l the D6 generator. In addition, licensee management pointed out that
l Improved Standard Technical Specification (ISTS) 3.8.1..B.3.1 clearly
l allowed the option of determining that the redundant diesel was not
l inoperable due to a common cause failure without performing the diesel
l operability surveillance. The licensee was in the process of adopting
the ISTS.
The inspectors informed licensee management that, although there was no
i operability concern with the D6 diesel generator, the current Technical
Specifications as written still required the diesel to be tested. This
was a violation. .(306/96014-01)
c. Conclusions
l Failure to test the redundant diesel generator was a violation of
Technical Specification 3.7.B.1. Licensee management reviewed the
condition at the time and took what they believed to be appropriate
action to verify that a common mode problem did not exist. Not testing
the redundant diesel was the result of a misinterpretation of
requirements and was based on wording in the basis scction and ISTS.
Nevertheless, the licensee was bound by their current Technical
Specifications and should have performed the test. The requirements !
were clarified by discussions between the inspectors and licensee
management.
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02 Operational Status of Facilities and Equipment
02.1 Enaineered Safety Feature System Walkdowns
a. Inspection Scope (71707. 92903)
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The inspectors used Inspection Procedures 71707 and 92003 to walk down i
selected portions of the safeguards cable tray system. USAR j
Section 8.7, " Cables and Raceways," was reviewed as part of the i
inspection. I
b. Observations and Findinos
The inspectors conducted the walkdowns in conjunction with the
licensee's investigation of the extent of cable tray interaction
problems first discussed in Inspection Report 282(306)/96008,
Section E2.1. Some of the walkdowns were in the company of licensee
personnel performing Work Order 9611421.
Both the inspectors' and licensee's walkdowns and the licensee's drawing
reviews indicated that the number of tray interactions not meeting the
separation criteria of USAR Section 8.7 was significantly greater than
i those originally identified. While most of the interactions involved
l cable trays added as part of the event monitoring modification, some
j involved original construction or other modifications.
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Except for the single interaction involving pressurizer heater cables
discussed in Inspection Report 96008, to date, none of the additional
interactions inspected appeared to violate the criteria established by
the licensee in their justificat on for continued operation (JCO) safety
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i evaluation discussed in Inspection Report 96008. Thus no new immediate
l operability concerns were identified.
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j c. Conclusioni
This issue continued to be reviewed by the NRC as Unresolved Item
l 282/96008-09. During this inspection period, the plant manager
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the next refueling outage on each unit without reliance on the JCO.
02.2 Dry Spent Fuel Storaae Cask loadina Activities
l a. Inspection Scope (71707)
The inspectors observed a limited number of activities associated with
the loading of spent fuel into h dry fuel storage cask. Activities
observed included fuel assembly inspections, movement of spent fuel into
the cask, removal of the cask from the spent fuel pool, and movement of
the cask to the Independent Spent Fuel Storage Installation (ISFSI).
ISFSI Safety Analysis Report (SAR) Section 10, " Operating Controls and
Limits," was reviewed as part of the inspection.
b. Observations and Findinas
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During loading of the fifth ~ pent fuel cask the licensee experienced i
problems with the fuel thimble gripping tool that was used to transfer )
certain of the older fuel assemblies. The tool was used because of .
suspected problems with the thimble tubes' attachment to the top nozzle
which made it prudent to move the assemblies without reliance on
gripping the top nozzle. Previous problems with the tool were discussed
in Inspection Report 282(306)/96006, Section 01.5. The tool began to i
slip to the extent that the licensee abandoned its use for the remainder
of the loading of the fifth cask and selected alternate assemblies to be
loaded.
The inspectors were concerned that, if the tool was not considered
reliable, then ISFSI Technical Specification 3.1.1.(6) might not be met.
That specification stated that fuel assemblies known or suspected to
have structural defects or gross cladding failures (other than pinhole
leaks) sufficiently severe to adversely affect fuel handling and
transfer capability shall not be loaded into the cask for storage. A
similar statement was included in ISFSI SAR Section 10.1.1.1.f. In
addition, the inspectors were concerned that 10 CFR 72.122(1), which
, required that storage systems must be designed to allow ready retrieval
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of spent fuel for further processing or disposal, might not be met.
l The inspectors, licensee representatives, and representatives of the NRC
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Spent Fuel Project Office (SFP0) held a conference call on October 18,
j 1996, in which the issues were discussed. Licensee representatives
i stated that the thimble tube tool would work properly for some time
after mandrels were replaced before it began to slip, and thus could be
used for cask unloading if necessary.
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c. Conclusions !
The conclusion of the SFP0 during the conference call was that the l
regulations and specifications were met. The NRC Region III Division of
Nuclear Material Safety was in the process of requesting for a written
interpretation from the SFP0 on those issues.
All cask loading operations observed by the inspectors were conducted
carefully and correctly.
JI. Maintenance l
M1 Conduct of Maintenance
M1.1 General Comments
a. Inspection Scope (61726. 62707)
The inspectors observed all or portions of the following l
maintenance and surveillance activities. Including in the
inspection was a review of the surveillance procedures (SP) or
work orders (WO) listed as well as the appropriate Updated Safety
Analysis Report (USAR) sections regarding the activities.
. SP 1093 D1 Diesel Generator Slow Start Test
. SP 1102 11 Turbine-Driven Auxiliary Feedwater Pump Test
. SP 1305 D2 Diesel Generator Slow Start Test
. SP 2088 Safety Injection Pumps Test
. SP 2095 Bus 25 Load Sequencer Test
. SP 2102 22 Turbine-Driven Auxiliary Feedwater Pump Test
. SP 2226B Containment Hydrogen Monitor Quarterly Calibration
. WO 9611406 Repair Oil Leak on D2 Diesel Generator
. WO 9611420 Check Grease in D2 Diesel Generator Governor
. WO 9611421 Inspect Cable Tray Separation in Auxiliary Building
. WO 9611916 Troubleshoot the Fuel Thimble Grip Tool
b. Observations and Findinas
. While observing SP 1093, the inspectors noted that an air
line to one of the cylinders air start control valves was
dented. The inspectors pointed the problem out to the
system engineer. The system engineer contacted a vendor
representative who stated that the problem should not affect
operability. The engineer and the inspectors also reviewed
NRC Information Notice 89-07, " Failures of Small-Diameter
Tubing in Control Air, Fuel Oil, and Lube Oil Systems Which
Render Emergency Diesel Generators Inoperable." The
inspectors determined that the line was not susceptible to
excessive vibration and the dent would not be likely to
cause a vibration induced crack.
. For SP 1305, an operator error during the procedure caused an
unanticipated engine start. This event is discussed in
Section M1.2 of this report.
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. For both SP 2088 and SP 2102 the inspectors noted excellent ,
communication and performance by the operators. Although the ,
procedures could be and were performed as written, operators
recognized some procedure enhancements were possible and took the
proper actions to initiate the revision process. '
. For WO 9611421, the results of the inspections were discussed in ;
Section 02.1 of this report. The inspectors noted that the ;
engineers performing the inspections were meticulous in conducting ;
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the measurements and thorough in documenting the results. !
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. For WO 9611916, issues which lead to the need for the work order
were discussed in Section 02.2 of this report. The inspectors
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observed that the work which involved mechanics, riggers,
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engineers, quality services personnel, radiation protection ,
personnel, and a vendor representative was well coordinated and
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l c. Conclusions
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l Inspector observed maintenance and surveillance activities were well
conducted with good communications, proper pre-job planning, safe work
, practices,.and excellent coordination between departments. The
l- inspectors noted continued strong system engineer involvement in all
phases of maintenance and surveillance activities.
M1.2 Operator Error Durina Surveillance Test
j a. Insoection Scope (61726)
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l On October 30, 1996, while performing post maintenance testing on the D2
l diesel generator, an operator error caused an unanticipated start of the
i diesel. The inspectors reviewed the circumstances of the event. The
inspectors also reviewed USAR Section 8.4, " Plant Standby Diesel
Generator Systems," as part of the inspection.
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b. Observations and Findinas
The licensee was performing Surveillance Procedure SP 1305, "D2 Diesel
Generator Slow Start Test," revision 13, as part of post maintenance
testing for Work Orders 9611406 and 9611420. The diesel was
successfully run and was then shutdown in accordance with the procedure.
! Step 7.67.6 of the procedure directs that between 10 and 15 minutes
after the engine shutdown, the operators were to air roll the engine at
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least one revolution to displace excess oil above from the upper
pistons.
Before rolling the engine, step 7.67.3 of the procedure required the
operators to place the local diesel generator control switch to STOP to
energize the shutdown solenoid which isolated the fuel racks. Step
l 7.67.4 required the operators to. attempt to open the governor fuel
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control linkage to verify the shutdown solenoid was energized. Due to
miscommunications between the two operators performing the test, those
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steps were not accomplished. Thus when the diesel was rolled using the
starting air, the fuel control linkage admitted fuel to the cylinders
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and the engine started and came up to normal speed. The engine was i
subsequently shutdown and properly air rolled.
The inspectors interviewed the operator responsible for performing the
procedure. The operator stated that they were near the end of the 10 to
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15 minute window indicated in the procedure and there was some perceived
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time pressure to complete the roll. The operator asked a second .
operator if the steps to prepare the engine for rolling had been done I
and said a positive but somewhat unclear response was received. The '
responsible operator did not personally verify that steps 7.67.3 and
7.67.4 were completed.
After the event, the licensee and inspectors reviewed 10 CFR 50.72 and l
associated guidance to determine if the event was reportable to the NRC l
as an Engineered Safety Feature actuation. 10 CFR 50.72(b)(2)(ii)(B)(1) I
exempted reporting of invalid actuations that occurred while the system l
was properly removed from service. NUREG-1022, Supplement No. 1,
" Licensee Event Report System," dated June 7, 1984,Section II 6.6
stated that the event would be not reportable if the system was removed
from service such that it can not oerform its intended function
(inspectors' emphasis). However the Statements of Consideration for 10
CFR 50 published as 57 FR 41378 on September 10, 1992, stated that the
event would not be reportable if the system was properly removed from
and all reouirements of plant procedures for removina eouipment from
service had been met. (inspectors' emphasis).
The system was considered out of service at the time of the event but
the diesel was available and could have performed its intended function.
Licensee procedures for removing the diesel from service required that
the engine be placed in a functional condition so that its post
maintenance test could be run and then be considered in service after
the test was successfully completed and reviewed. The inspectors
discussed the requirements with representatives of the NRC Office for
Analysis and Evaluation of Operational Data who stated that the
Statements of Consideration were published later than the NUREG and were
the current NRC guidance.
Since the documents listed above were somewhat unclear, the licensee
conservatively reported the event to the NRC on October 30, 1996. The
licensee retracted the report on November 7, 1996, when the reporting
requirements were clarified and it was determined that the diesel was
properly out of service administratively in accordance with licensee
procedures,
c. Conclusions
The failure of the operators to perform steps 6.67.3 and 6.67.4 of
SP 1305 resulting in an unanticipated start of the D2 diesel generator
was considered a violation of Technical Specification 6.5.A.4 which
required that detailed written procedures for surveillance and testing
which coula affect nuclear safety be prepared and followed.
(282/96014-02)
! Although it was an unnecessary challenge to a safety system, the event
was not safety significant. All equipment performed as expected. The
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l violation would normally be eligible for the exercise of discretion. I
However, as discussed in the cover letters of the previous-two resident !
inspector reports (282(306)/96008 and 282(306)/96010) the NRC has been l
concerned with a negative performance trend in operator performance of
surveillance activities. Thus the event was considered a violation that :
could have been prevented by the licensee's corrective action for those l
previous findings ~and was therefore cited. ;
The licensee's initial reporting of the event to the NRC pending I
clarification of the reporting requirements was considered a
conservative decision.
L M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Soindle Nut Cotter Pins in Main Steam Safety Valves
a. Inspection Scope (92902)
The inspectors became aware of recent findings at other plants where
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spindle nut cotter pins in main steam safety valves were missing. That
- could result in the spindle nut moving down the spindle due to
l vibration, causing the valve to fail to close after opening. The
l inspectors examined the plant's main steam safety valves. In addition,
the inspectors reviewed USAR Section 11.4, " Steam Safety, Relief and
Dump Systems," as part of the inspection,
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b. Observations and Findinas
Although the licensee's safety valves were a different manufacturer than
those at the other affected plants, they appeared to be of similar
design where the manual lifting lever pushed on a release (spindle) not
to manually open the valve. The release nut was held in place by a
i cotter pin. If the nut traveled down the shaft, it could cause the
valve to stick open.
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Not all of the nut cotter pins were accessible without scaffolding.
owever, the ones observed were all in place and the free ends of the
cotter pins were bent to keep them from falling out. For the cotter
pins that were not accessible, the inspectors verified that the release
! nut appeared to be in the normal position on the spindle. The vendor
technical manual (Consolidated Maxiflow Safety Valve Manual 3700, dated
November 1970) specified a 1/8" gap between the top lever and release
nut. It appeared that all release nuts met that specification. The
vendor manual also contained instructions for securing the release nut
with a cotter pin.
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The inspectors reviewed licensee maintenance procedure D44.1, " Pressure
Relief Valve Testing and Repair for Valves Governed by ASME/ ANSI
OM-1987," revision 1. The procedure referred the mechanics to the
vendor manual for specific assembly instructions. The inspectors also
verified that licensee engineers were aware of and reviewing the
! industry problems with the cotter pins. !
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c. Conclusions
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The inspectors' observations indicated no obvious problems with missing
cotter pins in the relief valves. The inspectors determined that the
licensee's procedures for valve assembly referred to the vendor manual ;
which contained adequate instructions for installing the cotter pin.
The inspectors also determined that the licensee was proactive in
reviewing the recent industry events regarding the missing pins. j
M3 Maintenance Procedures and Documentation
M3.1 Inadeauate Surveillance of Component Coolina Water Pumos
a. Inspection SCoDe (92700)
On October 10, 1996, while performing reviews of surveillance testing in
accordance with NRC Generic Letter 96-01, " Testing of Safety-Related
Logic Circuits," the licensee identified that the automatic start of
component cooling water pumps on low system pressure had not been
formally tested at part of the surveillance program. The licensee
issued Licensee Event Report (LER) 282(306)/96-10 on November 12, 1996, !
to report the cause and corrective actions for the finding. The ,
inspectors reviewed the LER and circumstances surrounding the finding. J
In addition, the inspectors reviewed USAR Sections 10.4.2, " Component
Cooling System," and 8.4, " Plant Standby Diesel Generator Systems," as
part of the inspection.
b. Observations and Findinas
As reported in the LER, the licensee discovered that the low pressure
start of the pumps was credited in the Updated Safety Analysis Report
after loss of offsite power to prevent loss of reactor coolant pump
seals. Although Technical Specification 4.5.A 4.a stated that system
tests shall be performed each refueling shutdown by tripping the
actuation instrumentation, no surveillance test existed to test the low
pressure starts on the pumps.
However, the low pressure start of the each of the pumps had been
demonstrated within the most recent surveillance interval either through
a combination of other tests or actual events such as the June 29, 1996,
loss of offsite power to the safeguards busses on both units. In
addition, the low pressure start of one of the pumps, for which a
documented operation was not immediately available, was tested on the
day of discovery. The licensee committed to revise the surveillance
testing of the pumps to include the low pressure start its next due
date. Completion of additional reviews and actions in accordance with
Generic Letter 96-01 was continuing.
c. Conclusions
The inspectors concurred with the licensee's conclusion as discussed in
the LER that the operability of the low pressure start feature of all
component cooling pumps had been adequately demonstrated during the
current surveillance interval. However, no such assuranie existed for
previous intervals.
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Failure to perform the surveillance testing required by Technical
Specification 4.5.A.4.a was a violation. This licensee-identified and
corrected violation is being treated as a Non-Cited Violation, i
consistent with Section VII.B.1 of the NRC Enforcement Policy.
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(282/96014-03) LER 282(306)/96-18 remained open pending the inspectors'
review of the completion the committed procedure revisions to include l
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testing of the low pressure start of the pumps. l
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) M8 Miscellaneous Maintenance Issues (92700,92902)
M8.1 (Closed) Licensee Event Report 282(306)/96-17: This event was
previously discussed in Inspection Report 282(306)/96010, Section M3.2.
At the time of that report, the LER had not yet been issued. The LER
was issued on November 1, 1996, and the inspectors determined that it
, met all the requirements of 10 CFR 50.73. Violation 282/96010-03 was j
issued for the event described in the LER. Thus the LER is closed to
avoid duplicate tracking and its corrective actions will be verified i
when the violation is closed. !
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III. Enaineerina
E2 Engineering Support of Facilities and Equipment
E2.1 Review of Updated Safety Analysis Report (USAR) Commitments (37551)
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While performing the inspections discussed in this report, the
inspectors reviewed the applicable portions of the USAR that related to
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the areas inspected end used the USAR as an engineering / technical
support basis dccument. The inspectors compared plant practices,
- procedures, an6/or parameters to the USAR descriptions as discussed in
- each section. No new discrepancies were identified.
E2.2 Review of 480-Volt Motor Starter Problems
a. InsDeCtion ScoDe (92903)
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Inspection Reports 282(306)/94010, Section 7.a, and 282(306)/94015,
Section 2.d, discussed problems and proposed corrective actions for
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licensee-identified problems with 480-volt motor starters due to
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hardened grease. The 480-volt breakers were considered an "(a)(1)"
category system in accordance with the Maintenance Rule (10 CFR 50.65)
, due to hardened grease problems and the issue was briefly reviewed in
the recent Maintenance Rule Baseline Inspection documented by Inspection
1 Report 282(306)/96012.
The inspectors met with licensee engineering personnel on November 1,
- 1996, to obtain an update on the progress of corrective actions and
review recent performance of the motor starters. The inspectors also
reviewed USAR Section 8.3.2.4, "480-Volt Auxiliary System," as part of
the inspection.
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b. Observations and Findinos
There were a total of 344 480-volt breakers with motor starters in which
the factory installed grease was subject to hardening. As discussed in
the previous inspection reports, the licensee conducted an extensive
investigation and testing program to determine an acceptable replacement
grease and to determine the expected useful life of the original grease. i
They then embarked on a program to refurbish all the affected breakers i
which included cleaning out the old grease and installing acceptable
grease.
The original refurbishment schedule was to complete three to six
breakers per week during operations and 30 to 40 during each refueling
outage. While the refueling goals have been met, the licensee was
unable to maintain the schedule during operations primarily due to
concerns with on-line maintenance risk. As of November 1, 1996, the
licensee still had 48 breakers on unit I and 45 breakers on unit 2 that
had grease that had exceeded its expected useful life and hadn't been J
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replaced. )
The inspectors determined that the vast majority of the remaining l
breakers either had no safety function or the component they supplied i
was normally in its safety position so the motor starter would not l
normally be called upon during an event. The licensee had priorities
established for the grease replacement project that considered such
things as age of the grease, environmental conditions, safety function
of the equipment, normal and accident states of the equipment, whether i
the equipment was routinely exercised, whether the equipment was in the
Maintenance Rule scope, etc. The inspectors determined that the
prioritization system was appropriate.
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The inspectors reviewed recent failures of 480-volt starters due to
hardened grease. There had been eight failures in the previous year but i
only one in the previous six months. Most of the failures were '
associated with ventilation fans. None of the failures were associated
with starters that had. replacement grease and none of the failures were
for breakers with old grease that had not yet reached the end of its
expected useful life. Thus the licensee's evaluation of the old grease
lifetime and corrective action of replacing the grease with a different
type both appeared to be effective.
c. Conclusions
The inspectors concluded that, while the licensee's corrective actions
were behind the original schedule, motor starter grease replacement was
proceeding steadily and proper priorities had been established.
Performance of the breakers was being monitored against established
goals such that reasonable assurance was provided that the associated
systems could fulfill their intended functions.
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IV. Plant Support
R1 Radiological Protection and Chemistry Controls (71750)
During normal resident inspection activities, routine observations were
conducted in the areas of radiological protection and chemistry controls using
Inspection Procedure 71750. No discrepancies were noted.
R3 Radiological Protection and Chemistry /rocedures and Documentation
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R3.1 Modification to Hvoobromous Acid Feed System
a. Inspection Scope (71750)
The inspectors reviewed the implementation a recent major modification
to the hypobromous acid feed system. The inspection included observing ,
system operation and discussions with engineering, chemistry, and l
operations personnel. This system was not discussed in the Updated l
Safety Analysis Report. l
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b. Observations and Findinas j
On the date inspected (Monday, October 21,1996), the modification was
nearly complete. All construction work was completed but the system had
not been turned over for operations yet. Valve tags, equipment labels,
tank level indicators, and revised procedures were not yet in place.
However, the system had been operated by chemists during the previous
weekend.
The inspectors determined that procedures had been revised but had not
been distributed. Valve and equipment tags were manufactured and in
fact were in the process of being attached during the inspection. Tank
levels could be determined by observing the fluid because the
polyethylene tanks were not completely opaque.
The inspectors determined that the system was only operated by chemists
and that all duty chemists had been trained on the post-modification
configuration and operation of the system. The chemists determined that
it was desirable to add chemicals to the intake water over the weekend
even if the system had not been completely turned over for operations.
c. Conclusions
The inspectors determined that operation of the system prior to
completing all equipment labeling and procedure distribution was
acceptable under the circumstances that it was only for a weekend period
and the appropriate chemistry personnel had been trained. Better
communication of the system status between engineering. chemistry, and
, operations personnel could have prevented confusion.
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P1 Conduct of Emergency Preparedness Activities (71750)
During normal resident inspection activities, routine observations were
l conducted in the area of emergency preparedness using Inspection Procedure
71750. No discrepancies were noted.
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S1 Conduct of Security and Safeguards Activities (71750)
During normal resident inspection activities, routine observations were
conducted in the areas of security and safeguards activities using Inspection
Procedure 71750. No discrepancies were noted.
An additional inspection of licensee activities in this area was conducted
during this period and was discussed in Inspection Report 282(306)/96013.
F1 Control of Fire Protection Activities (71750)
During normal resident inspection activities, routine observations were
conducted in the area of fire protection activities using Inspection
Procedure 71750. No discrepancies were noted.
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of the licensee
management at the conclusion of the inspection on November 19, 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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PARTIAL LIST OF PERSONS CONTACTED
Licensee
M. Wadley, Plant Manager l
K. Albrecht General Superintendent Engineering '
J. Goldsmith, General Superintendent Design Engineering
J. Hill, Manager Quality Services
G. Lenertz, General Superintendent Plant Maintenance
D. Schuelke, General Superintendent Radiation Protection and Chemistry
M. Sleigh, Superintendent Security
J. Sorensen, General Superintendent Plant Operations
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations
IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92700: Onsite followup of Written Reports of Nonroutine Events at Power
Reactor Facilities
IP 92901: Followup - Operations
IP 92902: Followup - Maintenance
IP 92903: Followup - Engineering
ITEMS OPENED. CLOSED. AND DISCUSSED
Opened
306/96014-01 VIO Failure to Test the Redundant Diesel Generator
282/96014-02 VIO Failure of Operators to Follow Surveillance Procedure
282/96010-03 NCV Missed Surveillance of Low Pressure Auto-Start of
Component Cooling Pumps Due to Inadequate Procedure '
282(306)/96-18 LER Missed Surveillance of Low Pressure Auto-Start of
Component Cooling Pumps Due to Inadequate Procedure
Closed
282(306)/96-17 LER Failure to Perform Section XI Testing on Chemical Feed
Discussed
282/96006-09 URI Cable Tray Separation Discrepancies
282/96010-03 VIO Failure to Perform Section XI Testing on Chemical Feed
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LIST OF ACRONYMS USED
CFR Code of Federal Regulations !
FR Federal Register l
IP Inspection Procedure i
ISFSI Independent Spent Fuel Storage Installation
ISTS Improved Standard Technical Specifications
JC0 Justification for Continued Operation
LER Licensee Event Report
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
PDR Public Document Room
SAR Safety Analysis Report
SFP0 Spent Fuel Project Office
SP Surveillance Procedure
URI Unresolved Item
USAR Updated Safety Analysis Report
VIO Violation
WO Work Order
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