ML20140B792

Insp Repts 50-348/97-01 & 50-364/97-01 on 970104-0215. Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support

ML20140B792
Person / Time
Site:	Farley
Issue date:	03/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20140B782	List: ML20140B777 ML20140B785 ML20140B792
References
50-348-97-01, 50-348-97-1, 50-364-97-01, 50-364-97-1, NUDOCS 9704010214
Download: ML20140B792 (22)

See also: IR 05000348/1997001

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U.S. NUCLEAR REGULATORY COMMISSION (NRC)

REGION II

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Docket Nos: 50-348 and 50-364

License Nos: NPF-2 and NPF-8

Report No: 50-348/97-01 and 50-364/97-01

Licensee: Southern Nuclear Operating Company. Inc.

Facility: Farley Nuclear Plant (FNP), Units 1 and 2

Location: 7388 North State Highway 95

Columbia. AL 36319

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Dates: January 4 - February 15, 1997

Inspectors: T. Ross, Senior Resident Inspector

J. Bartley, Resident Inspector

Approved by: P. Skinner. Chief, Projects Branch 2

Division of Reactor Projects

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Enclosure 2

9704010214 970317

PDR ADOCK 05000348

I G PDR

EXECUTIVE SUMMARY

Farley Nuclear Power Plant. Units 1 and 2

NRC Inspection Report 50-348/97-01, 50-364/97-01

This integrated inspection included aspects of licensee operations,

engineering, maintenance, and plant support. The report covers a 6-week

neriod of resident inspections.

Operations

e Operations personnel performed well while maintaining plant conditions

during Unit 1 and 2 at steady state full power operation. Power

reductions and increases on both units were well controlled

(Sections 01.1 and 01.3). The conduct of Operations personnel and

management was consistently in compliance with procedures and regulatory

requirements (Sections 02.4 and 02.5).

e Unit 1 new fuel receipt inspection and transfer to the s)ent fuel pool

was performed in a deliberate and methodical manner, witlout incident

(Section 01.2).

e Housekeeping and )hysical conditions were generally adequate, although

certain areas loot particularly poor. Licensee efforts to improve

targeted areas was evident. However. overall efforts to improve plant

appearances are proceeding very slowly. Overall plant lighting is good

but remains a persistent challenge (Section 02.1).

e System walkdowns verified that selected safety systems were properly

aligned and capable of fulfilling their design function (Sections 02.2).

o Licensee efforts to identify. resolve, and prevent problems remained

effective (Section 07.1).

o Employee concerns collected during exit interviews with contractors

during the last Unit 2 outage were not forwarded to the Concerns

Coordinator and were not processed according to Concerns Program

procedures (Section 07.2).

Maintenance

o Maintenance and surveillance testing activities were routinely conducted

in a thorough and competent manner by well qualified individuals in

accordance with plant procedures and work instructions (Sections M1.1

and M1.4), except for one instance (see below).

e A violation was issued for numerous examples of failing to follow

procedure by a test engineer during surveillance testing of the Unit 1

Penetration Room Filtration system. The test engineer also lacked

familiarity with the test procedure and in-depth knowledge of the system

being tested (Section M1.3).

Enclosure 2

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fnoineering

e Configuration Control Board meetings continue to be an effective process

in screening and prioritizing proposed design changes (Sec* ion E1.1).

• Corporate and onsite engineering support in resolving numerous issues

regsrding Penetration Room Filtration system operability, design

requirements, reportability, and testing was responsive, well

coordinated. and thorough (Section E2.1).

Plant Sucoort

e Health Physics control over the radiologically controlled area, and the

work activities conducted within it, was good. Efforts to ensure proper

use of personnel dosimetry have been generally effective, yet 3roblems

have not been completely eliminated. Several instances of pro 31 ems with

contamination control catches were identified (Section R2.1).

e Security activities continued to be performed in a conscientious and

capable manner, assuring the physical protection of protected and vital

areas. Corrective actions to address improper key carding of vital area l

doors were prompt and effective (Section S1.1).

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e The Unit 1 smoke detection system in containment continues to be

unreliable (Section F2.1).

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Enclosure 2

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Report Details

Summary of Plant Status

Unit 1 operated continuously at 100% power for the entire inspection period,

except for two short power reductions. On January 19, while at 89% power for

routine main turbine generator (MTG) governor valve (GV) testing, the MTG #2

throttle valve (TV) actuator shaft sheared, and the #3 GV actuator shaft

became unpinned. The #3 GV was repinned and unit returned to full power on

January 22, with the #2 TV in the failed closed position. Later, on

January 22, the unit was reduced to about 30% power after the #4 TV

unexpectedly drifted partially closed and then reopened. The #2 TV actuator

linkage and the #4 TV electro-hydraulic servo control valve were subsequently

replaced. Unit I returned to full power on January 25.

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Unit 2 operated continuously at 100% power for the entire inspection period. '

except for January 31 through February 3. During this weekend unit power was

reduced to 15% power to conduct scheduled steam generator (SG) flushes and a

boron soak.

I. Doerations

01 Conduct of Operations

01.1 Routine Observations of Control Room Goerations

a. Insoection Scooe (Insoection Procedure (IP) 71707)

Resident inspectors conducted frequent inspections of ongoing plant

operations in the Main Control Room (MCR) to verify proper staffing,

operator attentiveness, adherence to approved operating procedures,

communications, and command and control of operator activities. The

inspectors also regularly reviewed operator logs and Technical ,

S)ecifications (TS) Limiting Condition of Operation (LCO) tracking

sleets, walked down the Main Control Boards (MCB), and interviewed

members of the operating shift crew to verify operational safety and i

compliance with TSs. The inspectors regularly attended daily plant j

status meetings to maintain awareness of overall facility operations,

maintenance activities, and recent incidents. Morning reports and l

Occurrence Reports (ors) were reviewed on a routine basis to assure that i

potential safety concerns were properly reported and resolved.

b. Observations. Findinas and Conclusions

Overall control and awareness of plant conditions during the inspection

period remained excellent. During tours of the MCR, the inspectors

observed that the Unit 1 MCBs and Balance of Plant Janels were

frequently in a " blackboard" condition. Whereas, tie Emergency Power

Board and Unit 2 MCBs consistently had one or two persistent annunciator

alarms. Aggressive efforts to maintain MCB deficiencies at very low

levels were effective. The combined number of MCB deficiencies remained

below 15, the lowest level for many months. Operator attentiveness and

Enclosure 2

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res)onse to changing plant conditions remained very good. Interviews

wit 1 the operators indicated that they were well aware of plant

conditions and the status of on-going activities.

01.2 Receint. Insoection and Transfer of New Fuel For Unit 1 (IP 60705) i

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The inspectors observed the receipt. inspection, and transfer of new

fuel assemblies from the shipping containers to the Unit 1 spent fuel

3001 (SFP). Inspectors reviewed FNP-0-FHP-3.0. Receipt and Storage of

iew Fuel. Revision 28. and verified that licensee Jersonnel were l

following the procedure. Licensee personnel were (nowledgeable and very j

methodical in their handling and inspection of the new tuel assemblies. l

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01.3 Resoonse to Unit 1 Governor Valve and Throttle Valve failures (IP 71707) j

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On January 19. 1997, while troubleshooting the 1B reheat stop valve. the i

1. 2 TV went shut for ro apparent reason (it was later determined that the

actuator shaft had si?ared). Later that day, the #3 GV became unpinned

and drifted shut. An inspector was in the MCR when the #3 GV went shut

and observed the crew's response to the transient and troubleshooting i

efforcs. The inspector determined that shift response was prompt and l

well-controlled. Troubleshooting efforts and analysis of plant

conditions were thorough and conservative. On January 20 the inspector

observed the retest of the #3 GV, including the 3re-evolution briefing.

The inspector determined that the Jre-evolution 3riefing was thorough

and covered potential problems. T1e operators' control of the plant and

communications were excellent.

02 Operational Status of Facilities and Equipment

02.1 General Tours of Soecific Safety-Related Areas (IP 71707) i

General tours of safety-related areas were performed by the resident

inspectors to examine the physical conditions of plant equipment and

structures, and to verify that safety systems were properly aligned and ,

in good material condition. These general walkdowns included the '

accessible portions of safety-related structures systems and

components were in the following areas:

e Unit 1 and 2 SFP and SFP cooling pump rooms ,

o Unit 1 and 2 new fuel storage areas

e Unit 1 and 2 piping penetration rooms (PPR) on 100 foot elevation ,

e Unit 1 and 2 PPRs on 121 foot elevation '

e Unit 1 and 2 electrical penetration rooms and vital motor control

centers

e Unit 1 and 2 penetration room filtration (PRF) systems

e Unit 1 and 2 charging pump rooms and hallway

e U.nt 2 residual heat removal (RHR) heat exchanger (HX) rooms

e Unit 2 RHR pump rooms

e Unit 1 and 2 component cooling water (CCW) pump and HX rooms

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e Unit 2 CCW surge tank and safety parameter display system

uninterruptible power supply (UPS) rooms

e Unit I refueling water storage tank (RWST)

e Unit 2 post accident hydrogen analyzers

e Unit 1 and 2 vital 4160 volt alternating current (VAC) switchgear

and vital 600 VAC load center rooms, trains A and B

e Turbine building

e Unit 1 and 2 vital 125 volt direct current battery chargers,

inverters and buses

e Emergency diesel generator (EDG) building

e Unit 1 turbine-driven auxiliary feedwater (TDAFW) pump rooms

e Unit 1 motor-driven auxiliary feedwater pump rooms

a Unit 1 and 2 containment spray (CS) pump rooms

e Service water intake structure (SWIS) including service water i

system (SWS) pumps and switchgear i

e Unit 1 and 2 control room emergency filtration system (CREFS) and

control room air conditioning system (CRACS)

General material conditions and housekeeping for both units were

adequate. Plant areas were generally clear of trash and debris, but

most painted surfaces of floors and equipment were chipped, stained and

looked well worn. Efforts to improve physical appearances of targeted

plant areas and equipment are ongoing, indicating continued management

attention. However, overall efforts to improve plant a)pearances are

]roceeding very slowly. Equipment and housekeeping pro]lems identified

)y the inspectors during their routine tours were reported to the

responsible Shift Supervisor (SS) and/or maintenance department for .

resolution. None of these problems represented operability concerns.  !

Some of the more significant and/or repetitive discrepancies identified I

by the inspectors included:

e Numerous burned out lights in various rooms in the Radiologically

Controlled Area (RCA), especially the new fuel storage and SFF '

areas;

e Flooding inside the Unit 1 RWST missile shield:

e 4KV SWS breakers in the SWIS were not properly secured for seismic  !

qualification considerations; and. I

e Poor physical conditions of charging pump skids, especially l

2B charging pump (excepting 2A charging pump that was recently

cleaned and painted).

02.2 Biweekly Insoections of Safety Systems (IP 71707) 1

Resident irspectors used IP 71707 to verify the operability of the

following selected safety systems:

e Unit 1 high head safety injection (HHSI) system

o Unit 2 CCW system

Enclosure 2

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Accessible portions of these systems were verified to be properly

aligned and operable. The inspectors did not identify any significant

issues that adversely affected system operability. However, the

ins)ectors did identify a number of minor problems (e.g.. equipment

lea (s. labeling incon.sistencies, burned out lighting, inadequate catch

containment) that were identified to the SS.

02.3 Enaineered Safeauards Feature System Walkdown (IP 71707)

A detailed walkdown of the PRF system was conducted during this

inspection period: the results will be documented in NRC inspection

report (IR) 50-348, 364/97-04.

02.4 Taa Orders (IP 71707)

During the course of routine resident inspections, portions of the

following tag orders (TO) and associated equipment clearance tags were  ;

examined by the inspectors: ,

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e TO# 97-039-1 TDAFW pump

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e TO# 97-113-2 2A service air compressor '

e TO# 97-163-2 2A charging pum)

e TO# 97-172-2 Unit 2 main tur)ine #2 throttle valve

e TO# 97-234-1 CS header flow transmitter

o TO# 97-255-2 2B charging pump room cooler

e TO# 97-278-2 2D SWS pump

e TO# 97-336-1 1-2A EDG

e TO# 97-388-1 1A PRF

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All tags and TOs examined by the inspectors were properly executed and i

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implemented.

02.5 TS LCO Trackina (IP 71707)

Resident ins)ectors routinely rer ewed the TS LC0 tracking sheets filled

out by the slift foremen (SF) whenever a TS LCO action statement was

entered. All tracking sheets for Unit 1 and 2 reviewed by the

ins)ectors were consistent with plant conditions and TS recuirements,

wit 1 one exception. On February 12, 1997, o)erators taggec out the

B train CREFS and CRACS to complete Design C1ange Package (DCP)

S95-0-8816. The shift personnel properly entered and logged the one

time 30-day TS LCO for the CREFS recirculation filtration function and

for the CRACS. However, when reviewing the Unit 1 LC0 log on

February 14. an inspector noted that the SF had not processed an LCO

tracking sheet for the 7 day LC0 of the Train B CREFS pressurization

function. The resident inspector questioned why operators had not

initiated a TS LC0 tracking sheet. The inspector determined that the

specific cperators questioned (i.e. . SF) were not aware that the

pressurization function was not aart of the one-time 30-day extension.

The inspector discussed this witl Operations supervision and determined

Enclosure 2

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that, although the specific shift personnel were not aware of the 7-day i

LCO Opeations management was aware of a id tracking the out-of-service i

time. TH inspector verified that the LCO action time was not exceeded. )

07 Quality Assurance in Operations i

07.1 Effectiveness of Licensee Control in Identifyina. Resolvina. and I

Preventina Problems (IP 71707 and 40500) 1

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The resident inspectors briefly reviewed all newly initiated ors and i

completed ors approved by the Operations Manager during the inspection I

period to ensure that plant incidents which affect or could potentially )

affect safety were properly documented and processed in accordance with l

FNP-0-AP-30. Preparation and Processing of Incident Reports. 1

Revision 22. Certain selected ors were reviewed is detail as part of-  !

the routine inspection program. )

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Overall, the inspectors concluded that the licensee's program for

identifying and resolving problems remained effective and was being

accomplished in accordance with FNP-0-AP-30. Plant personnel and

management exhibited an appropriate threshold for identifying problems,

initiating ors. and assigning formal root cause teams. Each new OR

received prompt attention and was regularly discussed in the morning

status / plan of the day meeting. Furthermore, the Operations manager

continued to pursue the OR backlog with other managers to reduce the

number.

The following ors were reviewed for accuracy. completeness, and

reportability; and adequacy of corrective actions was confirmed or

verified:

OR 1-97-033; MCR Pressurization Damper Sticking Open

OR 1-96-406: Nitrogen bottle tied off to service air piping

OR 2-96-390: IBD Rod Control Power Cabinet Failure

OR 1-97-015: Unit 1 #2 Throttle Valve Failed Closed

07.2 Emoloyee Concerns Proaram

On February 13. an inspector met with the site manager for Williams I

Power Corporation (WPC) and a licensee representative from Plant

Modification and Design to discuss implementation of the Southern

Nuclear Company (SNC) Concerns Program, in particular the exit interview

process for contractors. According to section 5.14 of the SNC Concerns '

Program. Revision 1. exiting employees should be given the opportunity

to state their concerns in writing using a standard form, and whenever

possible exiting employees wil1 be given an exit interview prior to

departing the site. Completed exit interview forms are then forwarded

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to the Concerns Coordinator (CC). Section 5.7. for quality and non-

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Quality concerns, states that an investigation report wil1 be prepared

i and submitted, normally within 30 days. The results of the

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investigation will then be summarized and sent to the concerned

individual via an acknowledgement letter.

During the meeting with the WPC site manager, the inspector

independently reviewed exit interview forms containing specific concerns

by contract employees that were filled out following the recent Unit 2  ;

refueling outage. Some of these forms were dated in November 1996: most i

were not dated. Only one of the forms documented the conduct of an exit

interview. Of the completed forms reviewed, six of them documented

concerns regarding the quality of FNP Health Physics (HP) personnel and ,

practices, and inadequate. emergency communications capability in certain i

areas of the plant. None of the forms had been forwarded to the CC for i

processing in accordance with the SNC Concerns Program. Consequently. l

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none of the FNP concerns had been investigated. The inspector

subsequently met with the CC and responsible manager to discuss the -

Concerns Program, and specifically questioned how the WPC exit interview l

forms were overloo'ked. By the end of the inspection report period, the ,

licensee was still reviewing this issue.  ;

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II. Maintenance )

M1 Conduct of Maintenance

M1.1 General Comments

Inspectors observed and reviewed portions of various licensee corrective

and preventive maintenance activities. and witnessed routine i

surveillance testing to determine conformance with plant procedures.  :

work instructions. industry codes and standards, technical i

specifications (TSs), and regulatory requirements. l

a. Insoection Scooe (IP 61726 and 62707)

The resident inspectors observed all or portions of the following

maintenance and surveillance activities, as identified by their

associated work order (WO) work authorization, or Surveillance Test

Procedure (STP):

e FNP-2-STP-11.2. 2B RHR Pump Quarterly Inservice Test

e FNP-1-STP-16.1. lA CS Pump Quarterly Inservice Test

e FNP-1-IMP-220.22. Calibration of Containment Air Temperature

Recorder and Indicator

e FNP-1-STP-17.0. Containment Cooling System Train B Operability

Test

e FNP-0-IMP-425.3. Pressure Actuated Switches (Unit 1 TDAFW Pump)

e WO 00538634. Replace TDAFW Pump Drain Pot Level Control Valve

e FNP-1-IMP-205.2. Safety Injection Header to BIT tank Flow FT-943

e WO 470202. Clean and Flush 2A Air Compressor Cooling Jackets

e WO S00079676. B Train MCR HVAC. Install New Motor and Sheeve

(DCP S95-0-8816)

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e WO S96005269. Install Blanks for A Train MCR Recirculation Unit

e WO 96006106. Replace 2A HHSI Pump Seal

e WO M9700045. Repair Unit 2 #2 TV

e ' NP-2-ETP-4181. Technical Support Center Filtration Systems

Performance Testing

e FNP-1-STP-124.0. Penetration Room Filtration Performance Test

e DCP 595-0-8816. B Train CRACS Modification

b. Observations. Findinas and Conclusions

All of the maintenance work and surveillance testing observed by the

inspectors was performed in accordance with work instructions,

procedures, and applicable clearance controls. No adverse findings were

identi fied. Safety-related maintenance and surveillance testing

evolutions were well planned and executed. Responsible personnel

demonstrated familiarity with administrative and radiological controls.

Surveillance tests of safety-related equipment were consistently  :

performed in a deliberate step-by-step manner by personnel in close j

communication with the main control room (MCR). Overall. operators and

technicians appeared knowledgeable, experienced, and well trained for i

the tasks they performed. i

M1.2 Calibration of Unit 1 Containment Sorav (CS) System Flow Transmitter and  !

Indicator. B Train  !

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On January 28. an inspector observed Instrumentation and Control (I&C) i

technicians attempt to calibrate the 1B CS system flow indicator in

accordance with FNP-1-IMP-208.2. Containment Spray Flow FT958B Loop

Calibration. Revision 11. This dual train flow indicator was recently

l replaced due to problems with the train A indication, so I&C technicians

also had to perform an initial calibration of the B train flow

indicator. The A train indicator had already been calibrated and

returned to service on January 24. During the 1B CS flow indicator

calibration. I&C technicians determined that the indicator would not 1

calibrate within prescribed tolerances. Consecuently, the technicians i

stopped, notified the shift supervisor (SS), anc left the MCR to discuss ,

the matter with their supervision. Up to this point the I&C l

technicians had performed their calibration activities according to

procedural instructions and had proceeded as far they could without

additional guidance.  :

On January 28. the 1B CS flow indicator was determined to be out of

calibration and could not be readily adjusted within allowed tolerances.

The indicator had been left uncalibrated over the previous weekend,

after being re) laced. However, the current operating crew had been .

unaware that t7e 1B CS flow indicator was not calibrated prior to

releasing work to the I&C technicians on January 28. Apparently, the

various operating crews did not adequately turn over the status of the

1B CS flow indicator nor identify it in any visible manner on the main

control board (MCB) (e.g. deficiency tag). The inspector discussed

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l this situation with the Operations manager, who promptly sent a Night  :

Orders memo to all licensed shift personnel explaining the problem and

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reiterating management expectations. '

l M1.3 Unit 1 Penetration Room Filtration (PRF) Performance Test

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a. Insoection Scooe (IP 61726) i

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i - The inspector observed the performance of FNP-1-STP-124.0 Penetration

i Room Filtration Performance Test. Rev.11, while it was being conducted i

l on the Unit 1. Train A PRF system. The ins)ector started the

j observation just as Operations started the 3RF system, per step 7.5.

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b. Observations and Findinas

i The inspector started identifying deficiencies with the 3erformance of

the STP almost immediately. Upon entering the Unit 1 PR room, the

inspector observed the Engineering Support (ES) engineer shifting the

l. test apparatus from the Train B filter housing to the Train A filter

i housing. The ES engineer and a contractor had mistakenly set u) their

equipment on the Train B PRF filter housing. They recognized t1eir

L mistake when operators started Train A. This error did not impact the

operability of the Train B PRF due to the method of installing the test .

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The inspector reviewed the official test copy of the procedure and noted

that step 7.4 (visual inspection) had been signed off .1s complete and

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that steps 5.0 (Precautions and Limitations) and 6.0 U nitial

Conditions) were signed off by the SS but not the test supervisor 4

j (i.e.. ES engineer). The inspector asked the ES engin.er to describe 1

l the scope of the visual inspection which had been per' n ed. The ES

i engineer then explained that an external visual inspcctu n was

! performed. The inspector reviewed the procedure in more detail and

j noted that step 7.4 referred to an inspection check list in Data Package

1 STP-124.0A. After reviewing the inspection checklist. Data Sheet 2.

l " Visual Inspection Check List." the inspector concluded that an internal

i visual inspection of the filter housing was required. Also, the

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inspector noted that step 5.4 of the " Precautions and Limitations" )

required tagging out the system prior to performing the visual

inspection. The inspector then reviewed the official test copy and

found that Data Sheet 2 did not contain any signoffs for the visual

l inspection. This discrepancy and the requirement to tagout the system

were identified to the ES engineer, who appeared unfamiliar with the

i visual inspection checklist. After further discussion, the ES engineer

stated they would conduct the internal visual inspection after

completing the flow. High Efficiency Particulate Air (HEPA) filter, and

j charcoal filter tests. The sign off of step 7.4 by the engineer prior

4 to completing this step and the failure to sign off steps 5.0 and 6.0

2 prior to commencing the test are examples of Violation (VIO)

, 50-348/97-01-01: Failure To Follow PRF Operability Test Procedure.

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The inspector observed the conduct of the flow and filter tests. These

tests were mainly conducted in accordance with the procedure. However, i

the irispector noted t'nat when the 12-inch exhaust line did not meet the  !

minimum flow, the test personnel performed a horizontal traverse

, measurement and averaged the readings with the vertical traverse .

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measurement. The horizontal traverse was not performed on the other  ;

duct. The inspector questioned the contractor about this practice and

determined the practice was not prohibited nor was it directed by the

procedure. The data table for recording the data only provided spaces

for one traverse measurement.

The contractor was knowledgeable, professional, and very familiar with

l the equipment and ventilation system design requirements. However, the

l contractor was not familiar with plant specific procedural requirements.

The ES engineer in charge of the test also did not appear to be familiar

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with the test procedure, nor the test equipment. The inspector's

observations and the engineer's failure to follow procedure

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requirements, were subsequently discussed with ES supervision and

management.

l The test personnel completed the flow and filter tests and proceeded to

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start the internal inspection. Prior to opening the filter housing, the

inspector again reminded the ES engineer of the requirement to tag out

the system as required by step 5.4. The ES engineer continued with the

l inspection without tagging out the system. This is another example of .

VIO 50-348/97-01-01: Failure To Follow PRF Operability Test Procedure. '

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The inspector discussed the tagout requirement with the ES engineer a

! third time and suggested that the issue (whether or not the tagout was

I required) be resolved with the Unit 2 SS prior to performing the STP on )

l Unit 2. The inspector also discussed the procedural violations with the  ;

Unit 1 SS who promptly initiated Occurrence Report (OR) 1-25-028.  ;

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l The inspector verified that the flow. HEPA filter, and Charcoal filter '

f test results met the acceptance criteria. The air flow measurements

l indicated an airflow of 4509 cubic feet per minute (cfm). This was only

l 9 cfm above the minimum band of the acceptance criteria (5000 2 500 cfm)

and 491 cfm below the systems design flow as identified in the Updated

Final Safety Analysis Report (UFSAR).

The inspector reviewed ap)licable TS surveillance requirements (SRs) and

determined that TS 4.7.8.3.1 required performing a visual ins)ection ]

prior to the HEPA and Charcoal filter leak tests. However, t1is

requirement was inconsistent with the conduct of STP-124.0 observed by

the ins)ector, because the internal visual inspection was performed

after tie HEPA and Charcoal filter leak tests. The inspector reviewed l

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the procedure and determined that it did prescribe the test sequence to '

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ensure conformance with the TS SRs. However, the sequence in which the

engineer performed the test did not comply with the TS SRs. Licensee

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personnel were unaware that the TS required a visual inspection to be

performed first. 1

Licensee management took prompt and comprehensive corrective actions in  ;

I response to the inspector's findings. These actions included ,

counselling the test engineer, a major revision of STP-124.0, and re- '

performance of the STP using the revised procedure. The revised version

of STP-124.0 was re-)erformed on Unit 1 Train A on February 6. The

inspector observed t1e test and determined that the previously 1

identified procedural deficiencies were corrected.  !

c. Conclusions l

The ES engineer supervising the test was not familiar with the test

procedure, the test equipment. nor PRF system operability to adequately

l oversee the contractor. Three examples of failure to follow procedure  !

were identified. Licensee corrective actions were prompt and i

comprehensive.

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M1.4 Desion Chance Packaoe (DCP) S95-0-8816. Tie-In of New Control Room Air .

Conditionino System (CRACS). B Train I

l On February 12, 1997, the licensee initiated the final stage of

DCP S95-0-8816 by tagging out the B train CRACS and Control Room

Emergency Filtration System (CREFS). The B train CRACS outage was

scheduled for 21 days. An ins)ector observed the start of work,

including installation of blanc flanges in the ducts for preserving MCR

pressure boundary integrity and the removal of the old comaressor,

i receiver, and cooling coils. Previous observations of wor ( on the CRACS

modification were documented in irs 50-348, 364/96-03 and 96-09. The J

inspector determined that the work was well planned and coordinated.  !

M8 Miscellaneous Maintenance Issues (IP 92902) ,

M8.1 (Closed) VIO 50-348.364/95-21-02: Excessive Maintenance Overtime During

l Refueling Outage

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The licensee responded to this violation in correspondence dated

March 26, 1997 and initiated Corrective Action Report (CAR) No. 2186.

An inspector reviewed the licensee's letter and completed CAR, including

attached training sheets. The inspector also reviewed applicable

, changes made to FNP-0-AP-64 Work Schedules for Personnel, Revision 3.

I

that incorporated new administrative guidelines to prevent recurrence.

Furthermore, the inspector reviewed the " Maintenance 1996 Fall Outage

Schedule" for October 5 through November 29, 1996, and selected time and

attendance sheets for certain maintenance teams during the Unit 1 outage

to verify that scheduler practices and actual working hours limited

personnel overtime per FNP-0-AP-64 and TS requirements. Licensee

corrective actions were effective, this violation is closed.

Enclosure 2

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M8.2 (Closed) Licensee Event Report (LER) 50-364/95-09: Entry into Mode 2 l

with Intermediate Range Neutron Flux Detector Inoperable: and i

LER 50-364/95-09-01. Entry Into Specified Condition With A Intermediate i

4

Range Neutron Flux Detector Inoperable

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These LERs are considered closed based on inspector review and licensee

actions taken to address VIO 50-364/95-20-03 as discussed below.

M8.3 (Closed) VIO 50-364/95-20-03: Reactor Startup With Disconnected Nuclear

Instrumentation System (NIS) Intermediate Range Detector (NI-36)

The licensee responded to this violation in correspondence dated

February 21. 1996 and initiated CAR No. 2184. An inspector reviewed the

licensee's letter, completed CAR, and applicable STP revisions for

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source range. intermediate range. and power range NIS instrumentation.

>

These procedures were revised to provide clearer instructions. and

require independent verification, when reconnecting NIS detector cables.

The corrective actions detailed in CAR No. 2184 were consistent with the

i corrective actions described in the LERs of Section M8.2 above. The

i inspector verified that Unit 2 intermediate range NIS channel NI-36 was

returned to service. This violation is closed.

M8.4 (Closed) VIO 50-348. 364/95-18-03: Uncontrolled Use Of Non-temperature

Compensated HEISE Gauges

The inspector verified that the corrective actions described in the

licensee's response letter dated December 19, 1995, were reasonable and

complete. The inspector spot checked test pressure devices in the

Calibration Lab and Hot Instrument Shop and found them to be properly

i labelled. No similar problems were identified. This violation is

closed.

i M8.5 (Closed) LER 50-364/95-005: Manual Reactor Trips Following A Loss Of

i Electro-hydraulic Fluid

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l This event was documented in Inspection Report (IR) 50-348.364/95-11.

. The inspector reviewed the LER and the licensee's failure analysis.

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which determined that the failures were due to excessive stresses on the

tubing caused by mechanical and hydraulic oscillations, which were in

turn the result of servo valve failures. The licensee replaced the

j servo valves and conducted extensive vibration analysis. The licensee

has also taken significant (and successful to date) actions to im) rove

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the quality of the Electro-hydraulic Control system fluid. This _ER is

i closed. ,

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Enclosure 2

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III. Enaineerina  ;

El Conduct of Engineering (IP 37551) i

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E1.1 Confiauration Control Board Meetina

On January 8.1997, inspector attended a regular bimonthly meeting of

the Configuration Control Board (CCB). At this meeting a number of new

ideas and previously tabled ideas were discussed. Responsible and

affected groups made presentations to the CCB. Based on the

presentations and collegial deliberations. the CCB decided which ideas

to recommend as design changes and when they could be scheduled.

Overall, the inspector considered the CCB to be an effective process for

screening new ideas and prioritizing proposed design changes.

One of the ideas discussed was Idea Form 196-013 regarding potential

improvements for the Unit 1 containment smoke detection system 1A-22.

In response to Request for Engineering Assistance (REA) 96-1179.  :

Southern Company Services had evaluated 196-013 and proposed several

solutions to improve 1A-22 reliability. The CCB approved implementation

of a design change for both units to replace 1A-22 and 2A-22 with

i entirely new, independently addressable, smoke detection systems.

! However, due to competing resources and priorities the CCB did not

choose to recommend replacement until the 1998 refueling outages for

both units.

E2 Engineering Support of Facilities and Equipment q

E2.1 Penetration Room Filtration (PRF) System Desian and Licensina Bases. and  !

! Testina Reauirements 1

l During the months of January and February the inspectors had frequent

, meetings and conference calls with Corporate and onsite engineering '

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I support (ES) management and personnel regarding numerous PRF system

issues. These issues involved Updated Final Safety Analysis Report

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(UFSAR) design discrepancies, deficient operating and emergency

I procedures, excessive penetration room inleakage due to boundary

, degradation. and failure to fully implement technical specification (TS)

surveillance requirements (SRs). As a consequence, the licensee

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developed several operability determinations implemented extensive

l penetration room boundary repairs revised plant procedures.

l re-performed surveillance tests, and requested enforcement discretion to

address PRF system related problems. Due to the number and complexity

j of these issues, the inspectors will document the details and

l conclusions from their inspection efforts in inspection report

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(IR) 50-348, 364/97-04. Corporate and onsite engineering staffs have

coordinated well throughout the discussion and resolution of these

issues, and provided good, responsive support to Operations. ES has

taken the lead in revising PRF system surveillance test procedures

Enclosure 2

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(STPs) to conform with applicable American National Standards Institute.

Inc. (ANSI).N510 sections and conducting the tests.

E8 Hiscellaneous Engineering Issues (IP 92903)

E8.1 (Closed) LER 50-364/95-02. includina revision 1: Increased Clad Oxide

and Deposit Coating On Fuel

Both the original LER and subsequent revision were issued on a voluntary

basis by the licensee. Unit 2 was the pilot plant for reactor coolant

system (RCS) zinc injection in a pressurized water reactor to help i

mitigate primary water stress corrosion cracking. After Cycle 10

operation, the licensee observed unexpected indications of potentially J

excessive clad oxidation and abnormal CRUD deposition on the removed

fuel. Subsequent root cause investigations by the licensee and vendor

concluded that the anomalous clad oxidation behavior was within design

limits and that zinc injection had no more than a small detrimental

effect. The inspectors met with the licensee and vendor on several

occasions during their investigation, and directly observed clad oxide

measurements of Unit 1 and 2 spent fuel assemblies. RCS zinc injection

was not restarted on Unit 2 during Cycle 11 while the root cause

investigation was in progress. The licensee now plans to recommence

zinc injection on Unit 2 during the Summer of 1997. After Cycle 12. the ,

fuel will be reexamined, and de)ending upon the results, the licensee I

may begin zinc injection on bot 1 units. This LER is closed.

E8.2 (Ocen) Insoector Followuo Item (IFI) 50-348. 364/95-18-06: Electrical

Distribution System Functional Inspection (EDSFI)-Degraded Voltage

Commitments

This IFI documented two commitments made in SNC letter to the NRC dated

June 6.1995, that were also identified in a Safety Evaluation Report I

dated August 9. 1995. The commitments were:

e Include LCOs and SRs for the degraded grid alarm relays in the

Improved Standard TS (ISTS) package, and if SNC decided not to

implement the ITS. to submit a TS amendment within six months of i

the decision not to implement ITS.

e Document the offsite system operating voltage range and its

purpose in the UFSAR update to be performed in the spring of 1996.

The inspector verified that the offsite system operating voltage range

and its purpose were in Section 8.2.2.4 of UFSAR. Revision 13.

Discussions with the licensee indicate that they will incorporate the

LCOs and surveillance for the degraded grid alarm relays in their ISTS

application package. However, at this time the specific ISTS section

had not been written. This item will remain open pending completion of

this ISTS section.

Enclosure 2

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l -E8.3 (Closed) IFI 50-348. 364/96-02-01: Seismic Monitoring System FSAR Update l

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(Closed) IFl 50-348/96-04-07: Review of UFSAR, Revision 13 '

l These IFIs concerned the updating of the UFSAR for plant modifications. t

l The inspector reviewed Revision 13 of the UFSAR and verified that l

! Section 3.7.4 was updated to reflect the modifications made to the  !

l seismic monitoring system. The inspector also selected four  !

L modifications performed during U1RF13 and verified that the changes were

reflected.in Revision 13 to the UFSAR. These IFIs are closed.

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IV. Plant Suocort l

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R2 Status of Radiological Protection Facilities and Equipment '

R2.1 Tours of the Unit 1 and 2 Radioloaically Controlled Areas (RCAs)

l ilf 71750)

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During the course of the inspection period, the resident inspectors

conducted numerous tours of the auxiliary building RCA for Units 1

and 2. In general, health physics (HP) control over the RCA, and the  ;

work activities conducted within it, were good. Corrective actions to i

e address past problems with impro]er wearing of personnel dosimetry have  ;

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been effective, although the pro)lem has not been eliminated. However,  :

l several instances of inadecuate catches for controlling the spread of-

! contamination were observec by the inspectors (e.g. , 2B Residual Heat r

Removal Heat Exchanger (RHR HX). Unit 2 High Head Safety Injection *

(HHSI) flow orifice) and were identified to the shift supervisor (SS).

51 Conduct of Security and Safeguards Activities

i S1.1 Routine Observations of Plant Security Measures (IP 71750)

l

During routine inspection activities, resident inspectors verified that

portions of site security program plans were being properly implemented.

This was evidenced by: proper display of picture badges by plant

personnel: appropriate key carding of vital area doors: adequate

stationing / tours of security personnel: proper searching of

packages / personnel at the primary access point and service water intake

structure (SWIS). Security activities observed during the inspection

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period were performed well and were adequate to ensure physical

protection of the plant. However, on January 6, an inspector observed

several maintenance personnel enter the main control room (MCR) without

waiting for the green light to clear on the card reader for the MCR

vital area door. Although the individuals involved appeared authorized

for entry into the MCR, the inspector became concerned that this

)ractice was inconsistent with the licensee's policy regarding proper

cey card use After notifying the Security Chief, immediate actions

l were implemented to ensure proper use of vital area card readers. The

Security Chief and Maintenance Manager took prompt and effective

i Enclosure 2

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corrective actions to ensure all site personnel were reacquainted with

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F2 Status of Fire Protection Facilities and Equipment

F2.1 Unit 1 Containment Fire Detection System InoDerable (IP 71750) l

The Unit 1 Containment smoke detection system 1A-22 has failed numerous

times for extended periods (see Inspection Report 50-348.364/96-15,

Section F2.1). At the beginning of this inspection period.1A-22 was j

inoperable and had been since November 2. 1996. While 1A-22 remained  !

inoperable, the inspectors verified that operators implemented the

compensatory measures prescribed by the Updated Final Safety Analysis

Report (UFSAR) Fire Protection Program (i.e.. monitoring containment air

temperature on a regular basis). On January 24. maintenance personnel

conducted a containment entry and were able to locate a failed smoke

detector, replace it, and return 1A-22 to service. However, on

February 16. 1A-22 failed again. Poor reliability of 1A-22 has been a

chronic problem for which the licensee is currently planning a design

change as a longterm fix (see Section E1.1). In the meantime. the

Maintenance department is considering a proactive replacement plan of

existing smoke detectors during the upcoming Unit 1 refueling outage

that targets detectors with the highest. failure rate.

L Manaaement Meetinas and Other Areas )

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X1 Review of Updated Final Safety Analysis Report (UFSAR) Commitments  !

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A recent discovery of a licensee o]erating its facility in a manner l

contrary to the UFSAR description lighlighted the need for a special

focused review that compares plant practices, procedures and/or

parameters to the UFSAR descriptions. While performing the inspections i

discussed in this re] ort. the inspectors reviewed the applicable  ;

portions of the UFSAR that related to the areas inspected. The

inspectors verified that the UFSAR wording was consistent with the

observed plant practices, procedures and/or parameters, the only

exceptions being several discrepancies associated with the PRF system l

that are described in IR 50-348, 364/97-04.  !

X2 Exit Meeting Summary

The resident inspectors presented the inspection results to members of

licensee management on February 18. 1997, after the end of the

inspection period. The licensee acknowledged the findings presented.

The resident inspectors asked the licensee whether any materials

examined during the inspection should be considered proprietary. No

proprietary information was identified.

Enclosure 2

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee

M. Ajluni. SNC (Corporate) Licensing Manager - Farley Project

B. Bell Maintenance Team Leader

R. Coleman. Maintenance Manager

S. Dawkins. Concerns Coordinator

L. Enfinger. Administrative Manager

S. Fulmer. Technical Manager

D. Grissette. Operations Manager

T. Harrison. WPC Site Manager

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R. Hill. General Manager - FNP

C. Hillman. Security Chief

D. Jones. SNC (Corporate) Engineering Manager - Farley Project

R. Martin. Su)erintendent Operations Support

M. Mitchell, iealth Physics Superintendent

C. Nesbit. Assistant General Manager - Support

J. Powell. Superintendent Unit 2 Operations

R. Rogers. Engineering Support Supervisor - Engineering Support

, L. Stinson. Assistant General Manager - Plant Operations

J. Thomas. Engineering Support Manager

NRC

, J. Zimmerman Project Manager - Farley Nuclear Plant

INSPECTION PROCEDURES USED

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IP 37551: Onsite Engineering

IP 40500: Effectiveness of Licensee Controls in Identifying. Resolving, and

i Preventing Problems i

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IP 60705: Spent Fuel Pool Observations

IP 61726: Surveillance Observations

i IP 62707: Maintenance Observations i

IP 71707: Plant Operations

IP 71750: Plant Support Activities

IP 92902: Followup - Maintenance i

IP 92903: Followup - Engineering l

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Enclosure 2

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ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Iygg Item Number Status Descriotion and Reference

-VIO 50-348/97-01-01 Open Failure To Follow PRF Operability

Test Procedure (Section M1.3)

Discussed

Tyag Item Number Status Descriotion and Reference

IFI 50-348, 364/95-18-06 Open EDSFI-degraded Voltage Commitments

(Section E8.2)

Closed

TY2g Item Number

_ Status Description and Reference

VIO 50-348.364/95-21-02 Closed Excessive Maintenance Overtime

During Refueling Outage

(Section M8.1)

LER 50-364/95-02 Closed Increased Clad 0xide and Deposit

Coating On Fuel (Section E8.1)

LER 50-364/95-02-01 Closed Increased Clad 0xide and Deposit

Coating On Fuel (Section E8.1)

LER 50-364/95-09 Closed Entry Into Mode 2 with Intermediate

Range Neutron Flux Detector

Inoperable (Section M8.2)

LER 50-364/95-09-01 Closed Entry into Specified Condition with

an Intermediate Range Neutron Flux

Detector Inoperable (Section M8.2)

VIO 50-364/95-20-03 Closed Reactor Startup with Disconnected

Nuclear Instrumentation System (NIS)

IR Detector (NI-36) (Section M8.3)

VIO 50-348, 364/95-18-03 Closed Uncontrolled Use of Non-temperature

Compensated HEISE Gauges

(Section M8.4)

LER 50-364/95-005 Closed Manual Reactor Trips Following a

Loss of Electro-hydraulic Fluid

(Section M8.5)

Enclosure 2 I

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IFI 50-348, 364/96-02-01 Closed Seismic Monitoring System FSAR

Update (Section E8.3)

IFI 50-348/96-04-07 Closed Review of UFSAR. Revision 13

(Section E8.3)

LIST OF ACRONYMS USED  !

ANSI American National Standards Institute. Inc.

AP Administrative Procedure

CAR Corrective Action Report

CC Concerns Coordinator l

CCB Configuration Control Board '

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CCW Component Cooling Water

cfm Cubic Feet per Minute

CFR Code of Federal Regulations l

CRACS Control Room Air Conditioning System

CREFS Control Room Emergency Filtration System

CS Containment Spray

i DCP Design Change Package

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EDG Emergency Diesel Generator

EDSFI Electrical Distribution System Functional Inspection

ES Engineering Support

l ETP Engineering Test Procedure

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FHP Fuel Handling Procedure

FNP farley Nuclear Plant

l GV Governor Valve

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HEPA High Efficiency Particulate Air '

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HHSI High Head Safety Injection

HX Heat Exchanger

l I&C Instrumentation and Control

IFI Inspector Followup Item  ;

IMP Instrumentation Maintenance Procedure

IP Inspection Procedure

IR Inspection Report

ISTS Improved Standard Technical Specifications

ITS Improved Technical Specification

! LC0 Limiting Condition of Operation

l LER Licensee Event Report ,

l MCB Main Control Board

1 MCR Main Control Room

i MTG Main Turbine Generator

l NIS Nuclear Instrumentation system

NRC U.S. Nuclear Regulatory Commission

OR Occurrence Report

PPR Piping Penetration Room

PRF Penetration Room Filtration

RCA Radiologically Controlled Area

RCS Reactor Coolant System

REA Request for Engineering Assistance

Enclosure 2

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RHR Residual Heat Removal

RWST Refueling Water Storage Tank

SF Shift Foremen

SFP Spent Fuel Pool

SG Steam Generator

SNC Southern Nuclear Company

SR Surveillance Requirement

SS Shift Supervisor

STP Surveillance Test Procedure

SWIS Service Water Intake Structure

SWS Service Water System

TDAFW Turbine Drive Auxiliary Feedwater

TO Tag Order

TS Technical Specifications

TV Throttle Valve

UFSAR Updated Final Safety Analysis Report

UPS Uninterruptable Power Supply

VAC Volt Alternating Current

VIO Violation

WO Work Order

WPC Williams Power Corporation

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Enclosure 2

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