ML20141E961

Errata Sheets for NRC Insp Rept 50-298/96-24.Sheets Consists of Pages IV & 5 of Insp Rept

ML20141E961
Person / Time
Site:	Cooper
Issue date:	05/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141E145	List: ML20141E139 ML20141E961
References
50-298-96-24, NUDOCS 9705210155
Download: ML20141E961 (3)

See also: IR 05000298/1996024

Text

C

J

ATTACHMENT 5

Errata Sheets for

NRC Inspection Report 50-298/96-24

(pages iv and 5)

l

I

i

l

l

f

l

l

l

1

!

i

9705210155'970514

PDR ADOCK 05000298

0 PDR

_ _ _ __ _ _ _ _ _ _ _ _ - _ . _ . _ . . _ _ _ . _ _ _ _ . . _ _ ._

a

J

t

• The team identified a generic issue regarding the licensee's technical basis for the

emergency operating procedures related to an anticipated transient without scram

event. The licensee had not fully considered the mixing effects related to boron

displacement during cooldown. In addition, hot and cold shutdown boron worth

were not calculated conservatively. This item is unresolved pending further

evaluation by the Office of Nuclear Reactor Regulation (Section E3.2).

Maintenance l

The team identified one violation of Technical Specification 6.3.1 involving the ,

failure of a maintenance worker and a quality control inspector to follow procedural

l

requirements. This experience is contrary to the information provided in a letter l

dated November 1,1996. The team also identified that procedural guidance for the  !

installation of the scram valve actuator mounting brackets needed improvement,

and that the licensee's corrective actions addressing repetitive instances of non-

conforming scram valve actuator mounting assemblies have been ineffective

(Section E2.1).

, Enaineerino

The team identified several unverified or questionable assumptions in the sample of

reactor protection system and anticipated transient without scram setpoint

calculations; however, none of the discrepancies affected equipment operability. 1

The licensee had programmatically identified similar setpoint calculation problems

during a 1996 quality assurance audit and was in the process of correcting and

updating the calculations. This licensee-identified and corrected violation is being  ;

treated as a noncited violation, consistent with Section Vll B.1 of the NRC l

Enforcement Policy (Section E1.1).

The licensee did not clearly describe their intent with respect to implementation of

Safety Guide 11, " Instrument Lines Penetrating Primary Containment," in either the

Final Safety Analysis Report or in the Updated Safety Analysis Report V.2.3.5,

" Primary Containment isolation Valves." Further, the inspection team could not

determine whether the current administrative controls met the intent of the

Supplement to Safety Guide 11 with respect to providing a method to verify during

operation the status of each isolation valve. This item is unresolved pending further

evaluation by the Office of Nuclear Reactor Regulation (Section E1.2).

• The licensee had modified their standby liquid control system and made it l

electrically less reliable. Whether this design change was in violation of

10 CFR 50.59 is unresolved, pending an Office of Nuclear Reactor Regulation

review of the licensing basis (Section E1.3).

l

,

-

iv

i

c0

4 j

i

Notwithstanding the licensee's position, the team was concerned that the lack of j

separation and qualified isolation devices represented an unevaluated deviation from  ;

the standby liquid control system safety evaluation described in the USAR. I

10 CFR 50.59 requires that a proposed change, test, or experiment shall be deemed

to involve an unreviewed safety question if the probability of occurrence or the

consequences of an accident or malfunction of equipment important to safety I

previously evaluated in the safety analysis report may be increased. The team was '

concerned that the licensee had not initially identified or evaluated this additional j

vulnerability and its effects, as required to comply with 10 CFR 50.59. Further, the l

team questioned the licensee's interpretation that allowed them to delete the single I

failure requirement for the electrical portion of the system without a license I

amendment. This item will be referred to the Office of Nuclear Reactor Regulation )

to determine whether the licensee's interpretation of their licensing basis is correct. l

This item is considered unresolved (50-298/9624-03).

)

During the inspection, the team was also concerned that this data acquisition

system interface practice might have been extended to essential circuits other than l

standby liquid control system (for example, diesel fuel oil transfer pumps, reactor

building closed cooling water pumps, core spray motor-operated valves, etc.). The

team reviewed an additional sample of essential system interfaces with the plant i

monitoring information system and the plant monitoring information system

procurement specifications. Based on this review and discussions with the

licensee, the team found that the licensee had correctly designed the interface for

essential systems.

l

c. Conclusions '

The licensee had modified their standby liquid control system and made it less  !

reliable. With the modified configuration, a common single failure could be

postulated (i.e., a short and/or ground of the redundant 120V ac control power

circuits) that would de-energize the standby liquid control system pump contactor

circuits and squib valve firirg circuits, rendering them allinoperable until the fault

was located and repaired. On a system level, the standby liquid control system is  ;

not required to be single failure proof. Whether this design change was in violation I

of 10 CFR 50.59 is considered unresolved, pending Office of Nuclear Reactor

Regulation review of the licensing basis. The licensee had correctly implemented

the modification to add plant monitoring system inputs to essential systems.

l

E1.4 USAR Discrecancies (10 CFR 50.71(e))

a. Insoection Scoce (93801, 37550)

l

The team evaluated compliance to selected USAR commitments. l

l

1

l

1

5

l

l

,