ML20210K147

Insp Rept 50-458/99-09 on 990510-28 with in-office Insp Until 990701.Noncited Violations Identified.Major Areas Inspected:Review of Licensee Actions Re Testing & Cleaning of Auxiliary Bldg Unit Coolers

ML20210K147
Person / Time
Site:	River Bend
Issue date:	07/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210K139	List: ML20210K135 ML20210K147
References
50-458-99-09, NUDOCS 9908060028
Download: ML20210K147 (13)

See also: IR 05000458/1999009

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION j

! REGION IV

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Docket No.: 50-458

License Nos.: NPF-47

Report No.: 50-458/99-09

Licensee: - Entergy Operations, Inc.

Facility: River Bend Station

Location: 5485 U.S. Highway 61

St. Francisville, Louisiana

Dates: May 10 to 28 with inoffice inspection until July 1,1999

Inspectors: P. Goldberg, Reactor inspector

Engineering and Maintenance Branch

M. Runyan, Senior Reactor inspector

Engineering and Maintenance Branch

Approved by: Dr. Dale A. Powers, Chief,

Engineering and Mei 'sance Branch

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Division of Reactor.S ity

Attachment: SupplementalInformation

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9908060028 990730

L. PDR ADOCK 05000458 1

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EXECUTIVE SUMMARY

River Bend Station

NRC Inspection Report 50-458/99-09

The purpose of this specialinspection was to review licensee actions relating to testing and

cleaning of the auxiliary building unit coolers.

Jinaineerino

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The licensee failed to assess adequately the operability of four auxiliary building unit

coolers that were found by test or calculation to have degraded capacity. As a result of

these degraded conditions, the predicted post loss-of-coolant accident temperatures in

the affected rooms were increased from 122 to 132 degrees F. The operability

evaluations were inadequate because they failed to consider several effects of the

higher predicted temperatures, such as decreases in motor-operated valve motor

efficiency, decreases in cable ampacity, and changes in the operating margins of

temperature-actuated isolations. In response to this finding, the licensee performed a

complete analysis and determined that equipment operability was not affected. This

issue was identified as a noncited violation of 10 CFR Part 50, Appendix B, Criterion V

(Section E8.1).

The licensee failed to perform a 10 CFR 50.59 evaluation to determine if an unreviewed

safety question existed as a result of its calculations showing that the maximum post-

accident temperature in some auxiliary building rooms, housing safe shutdown

equipment, could exceed design limits specified in the Final Safety Analysis Report.

This issue was identified as a noncited violation of 10 CFR 50.59 (EA 99-150). The

licensee's unreviewed safety question determination was pending, but the determination

of operability indicated that the consuquences of this condition were minor

(Section E8.1).

During a period from October 1996 to January 1997, the licensee failed to initiate

condition reports in a timely manner (or not at all) for four auxiliary building unit cooler

test failures. The test results revealed that the unit coolers had inadequate capacity to

maintain the supplied rooms at the design temperatures. Moreover, the licenseo failed

to address in an adequate manner three auxiliary building unit coolers that were in a

degraded state for a period of 4 years. While the operabi!ity of the equipment in the

rooms serviced by the coolers would not have been challenged, the plant would have

been unable to meet the design basis limiting temperatures for several auxiliary building

rooms housing emergency core cooling system pumps and other safety related

components. This issue was identified as a noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI (Section E8.1).

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The licensee failed to initiate a condition report and restore over a 3 year period missing

insulation on piping located in the high pressure core spray pump room in a timely

manner after the discovery of this deficiency even though this situation exacerbated an

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already deficient condition of the unit cooler that serviced this room. The insulation was

discovered missing in late 1995 and not restored until September 1998. This issue was

identified as an additional example of a noncited violation of 10 CFR Part 50,

Appendix B, Criterion XVI (Section E8.1).

Maintenance

• An unresolved item was identified concerning the licensee's handling of the auxiliary

building unit coolers within the Maintenance Rule Program. The existing performance

measures were observed to not address the maintenance implications of unit coolers

that had failed to meet their design capacities (Section M8.1).

• Weaknesses were identified in the licensee's program developed to implement the

recommendations of Generic Letter 89-13," Service Water System Problems Affecting

Safety-Related Equipment." The decision to clean marginal auxiliary building unit

coolers in lieu of testing was not appropriately justified, the sequence of cleaning with

respect to past testing was contrary to NRC guidance, a baseline test program was not

established, and actions following test failures were not consistent with the

recommendations of the generic letter (Section M8.2).

• The licensee failed to identify an operator workaround and train operators concerning a

temperature-actuated isolation of the residual heat removal system that was designed to

isolate a leak in the system but which had a temperature setpoint below the design no-

leak post-accident temperature. There was a possibility that a spurious isolation of the

residual heat removal system could have occurred during a loss-of-coolant accident,

which would have complicated accident recovery since operators would have had to

diagnose the condition and take manual actions to initiate or restore shutdown cooling

(Section M8.3).

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ReDort Details

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Summarv of Plant Status

The plant was in Mode 5 during the onsite portion of the inspection.

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E8 Miscellaneous Engineering issues (92903)

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E8.1 (Closed) Insoection Followuo item 50-458/9813-06: Review of licensee's response to

NRC on how Recommendation ll of Generic Letter 89-13 would be implemented

This item was opened because of concerns relating to the licensee's decision to

perform cleaning and temperature monitoring of the auxiliary building heating,

ventilation, and cooling unit coolers in lieu of testing. The licensee generated Condition

l Report CR-RBS-1998-0794, dated June 24,1998, which developed a number of

l corrective actions, including a new response to the NRC describing how the licensee

was following with the recommendations of Generic Letter 89-13.

Test History

< Out of a total of 11 safety-related auxiliary building unit coolers that provide room

l cooling to the auxiliary building (including the emergency core cooling pump rooms), the

! licensee had tested 4 of these unit coolers. The inspectors reviewed the test histories of

these auxiliary building unit coolers.

Unit Cooler HVR-UCS, which serves the high pressure core spray pump room, was

tested in April 1995. It was determined that the heat exchanger had a capacity of

525,644 Btu /hr. In November 1996, the heat exchanger had a measured capacity of

532,139 Btu /hr. The vendor design capacity for this cooler was 592,300 Btu /hr, and

the required capacity, based on the calculated heat transfer needed to maintain a

post-accident temperature of 122 degrees F, was 655,824 Btu /hr. The required

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capacity was greater than originally designed because of a lack of insulation on the high )

pressure core spray piping. This was a discrepant condition that existed during the two

tests described above Based on these results, this cooler had failed both of the tests.

The insulation was restored in 1998 and the calculated required capacity was lowered I

to 569,938 Btu /hr. The inspectors noted that the test results also did not meet this )

revised requireo capacity, meaning that the unit coolers would have failed the tests even

if the insulation problem had not existed. ]

Unit Cooler HVR-UC6, which serves the Residual Heat Removal Heat Exchangers A

and C and Pump Room A, the low pressure core spray pump room, and the reactor core

isolation cooling pump room, was tested in 1995,1996, and 1997. The unit cooler failed

all three tests with the measured test capacity being less than the required capacity.

See Table 1 for the test values.

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Unit Cooler HVR-UC9, which serves the Residual Heat Removal Heat Exchangers B

and D and Pump Rooms B and C, was tested in 1995 and 1997. The unit cooler failed

both tests with the measured test capacity being less than the required capacity. See

Table 1 for the test values.

Cooler HVR UC7 was tested twice and was the only unit cooler of those tested whose

measured test capacity exceeded the required capacity. See Table 1 for the test

values.

Current Status of Coolers

The inspectors reviewed Purchase Specification 215.252, Addendum 7 to Revision 2,

which specified the original design requirements for purchasing the auxiliary building

unit coolers, and Purchase Specification 215.253, " Auxiliary Building Unit Cooler

Replacement Cooling Coils," Revision 3, which resulted in the replacement of the

cooling coils in all of the auxiliary building unit coolers. The inspectors noted that i

the current required capacity for three of the unit coolers exceeded the required

capacities listed in the purchase specification. The licensee's representative stated

that the required capacities had increased since the time when the original specification

was made because of changes to the method used to calculate the heat load from l

the motors. No physical changes were made to the rooms to cause the required heat  !

loads to increase. As a result of the revised calculated heat loads, the margin between  !

the design capacity and the required capacity decreased for Unit Coolers HVR-UC5,

HVR-UC6, and HVR-UC9, which were the same three unit coolers that failed all

previous performance tests.

The table below lists the 11 auxiliary building unit coolers and their capacities and

margins. 1

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TABLE 1

AUXILIARY BUILDING UNIT COOLER DESIGN AND TEST INFORMATION

Aux Bldg Vendor onginal original Current Current Test Test Results

Unit Cooler Design Required Margin Require,d Margin Date

Capacity Capacity (Design Capacity (Design

(Btu /hr) From less (Blu/hr) less

Purchase Required) Current)

spec. (Btu /hr) (Otu/hr)

(Blu/hr)  !

HVR-uC2 158,300 149,700 8,600 110.962 47,338 NA NA

HVR UC3 307,500 293,200 14.300 265,806 41,694 NA NA

HVR-uC4 284,800 266,000 18,800 216,030 68,770 NA NA

HVR-uCS 592,300 547,100 45,200 569,938 22,862 4/95 525,644

11/96 532,139

HVR-uC6 764,000 705,700 58,300 747,429 16,571 3/95 707,433

1G96 656,865

l 2/97 651,359

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Table 1 (continued)

Aux Bldg vendor original Onginal Current Current Test Test Results

Unit cooler Design Required Margin Required Margin Date

Capacity Capacity (Design Capacity (Design

(Btu /hr) From less (Blu/hr) less ,

Purchase Required) Current)  !

spec. (Btu /hr) (Btu /hr) l

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(Btu /hr)

HVR-UC7 472,000 449,600 22,400 322,349 49,651 11/95 435,524

3/97 429,743

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HVR UC8 404,100 360,300 43,800 260,517 143,583 NA NA l

HVR-UC9 664,800 627,400 37,400 648,847 15,953 3/95 575,459

1/97 646,584

HVR-UC10 118,000 109.100 8,900 101,557 16,443 NA NA

HVR-UC11 A 1,278,900 1,214,700 64,200 688,798 590,102 NA NA

HVR-UC11B 1,278,900 1,214,700 64,200 688,798 590,102 NA NA

This table indicates that each of the 11 unit coolers currently have sufficient design i

margin. However, as discussed above, Unit Coolers HVR-UC5,6, and 9 have, without

exception, failed all performance tests, where the measured heat transfer rate has been

less than the design requirement. j

The inspectors noted that the design capacities listed above benefit from the installation

of new cooling coils that were installed in all of the auxiliary building unit coolers during

1992 and 1993. The licensee's representative stated that the original coils had less

capacity than their replacements. The coil replacement was necessitated by excessive

corrosion that resulted from operation under the previous open design of the service

water system, in which the discharged cooling water was not recirculated back to the

supply piping. Prior to the coil replacement, the licensee modified the service water

system to a closed configuration.

In addition to the three unit coolers that had previously failed performance tests, the

inspectors noted that Unit Cooler HVR-UC10 had a small analytical original margin (prior

to coil replacement). The inspectors concluded that this unit cooler would likely fail a

performance test if it were to be conducted because, according to the licensee's

representative, the uncertainty involved in measuring the heat transfer rate was greater

than the available margin.

Plant Walkdown

The inspectors performed a walkdown of the rooms in the auxiliary building that were

cooled by Unit Coolers HVR-UC5,6,9, and 10. In this effort, the inspectors focused on

identifying equipment that could be affected by elevated temperatures. The list of such

equipment found i,1 the rooms included motor-operated valves, temperature detectors

used to initiate alarms and isolations, electrical cabling, and pump motors.

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The inspectors also examined the airflow patterns in the rooms to determine if local hot

spots existrvt that could affect sensitive equipment. No areas of this nature were

identifie ?

Operabiktv Determination

The inspectors reviewed the licensee's current operability assessment, performed in

1998, of auxiliary building Unit Coolers HVR-UC5, 6, and 9, which was contained in

Condition Report CR-RBS-1998-0794. The current design and licensing bases

specified that all areas of the auxiliary building would be maintained at less than or equal ,

to 122 degrees F under all postulated normal, off-normal, and accident conditions.

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Based on an analysis of the aforementioned test results, the licensee concluded that the

unit coolers were capable of maintaining normal and post loss-of-coolant accident

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ambient temperatures at equal to or less than 132 degrees F, or 10 degrees F higher

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than the 122 degrees F specified in the Updated Safety Analysis Report. The

132 degrees F temperature was established by applying the highest measured

degradation of heat exchanger performance, as revealed by the previous test results, to

each of the unit coolers. The licensee evaluated the equipment located in the higher

accident temperature areas and found that all of the equipment was environmentally

qualified for ambient temperatures greater than 132 degrees F. Consequently, the

licensee concluded tr at the auxiliary building unit coolers were operable and would

continue to perform their intended safety function based on their current and projected

condition. This operability evaluation was effective until May 2,1999, or entry into

Mode 3 following Refueling Outage 7, whichever occurred first. After the outage

schedule was extended because of unrelated problems, the operability evaluation due

date was extended to July 1,1999. i

The inspectors noted that the licensee had not fully considered the operability impact of l

higher room temperatures on the equipment within the affected rooms, other than the j

environmental qualification implications as discussed above. The types of evaluations

missing from consideration included potential changes to electrical resistance (voltage

drop), cable ampacity, efficiency effects on Limitorque motor-operated valve motors and

emergency core cooling system pump motors, and design margins for temperature-

actuated alarms and isolations. In response to the inspectors' finding, the licensee

initiated Condition Report CR-99-0875 to investigate the potential effects of the

increased room temperature.

The inspectors reviewed condition reports generated following the unit cooler test  ;

failures to ascertain the adequacy of the operability evaluations associated with these j

condition reports. j

Condition Report CR 98-0591, dated May 14,1998, identified that the high pressure

core spray Unit Cooler HVR-UC5 failed to pass the thermal performance test performed  ;

on November 15,1996. The licensee determined that the test cooling capacity was l

532,139 BTU /hr compared to an acceptance criterion of 655,824 Btu /hr, based on

Calculation G13.18.2.1*061, Revision 1, dated August 29,1996. l

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The inspectors reviewed the operability evaluation and found that, because of the

negative margin of the heat removal rate. the maximum temperature of the room

following a design basis accident increased from 122 to 127 degrees F. The licensee

stated, within Condition Report 98-0591, that this elevated temperature would have no ,

impact on the operability of the environmental qualification components. However, the

licensee failed to evaluate other conditions, as discussed above, that could affect

operability.

Condition Report CR 96-1952, dated November 14,1996, identified that the high

pressure core spray Unit Cooler HVR-UC5 failed to meet the heat transfer acceptance

requirements on April 12,1995. The operability evaluation stated that the environmental

qualification components would not be affected by an elevated temperature greater than

the design temperature of 122 degrees F and the components would still be operable.

Again, this evaluation was inadequate because it failed to considet many of the effects

of the higher temperatures.

Condition Report CR 97-0025, dated January 10,1997, identified that Unit

Cooler HVR-UC9 failed to meet the required cooling capacity during testing j

conducted March 17,1995. The operability evaluation contained in this condition l

report was inadequate for the same reasons discussed above. l

The inspectors reviewed the January 16,1997, test failure of Unit Cooler HVR-UC9 and

the October 2,1996, test failure of Unit Cooler HVR-UC6 and determined that a

condition report had not been issued for either failure. i

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10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality

shall be prescribed by documented instructions, procedures, or drawings, of a type

appropriate to the circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings. Procedure RBNP-078, " Operability

Determinations," Revision 4, states that when performing an operability evaluation, the

following guideline objective was required to be accomplished: " Determine the impact of

the degraded or nonconforming SSC." The inspectors considered that the licensee had

failed to adequately perform this objective for the unit cooler problems, in that, the

impact of the higher temperatures on safety-related equipment had not been fully

determined (examples listed above). The licensee's failure to perform an adequate J

operability evaluation within Condition Reports CR-98-0794, CR 98-0591, CR 96-1952,

nad CR 97-0025 was considered to be a violation of 10 CFR Part 50, Appendix B,

Criterion V. This Severity Level IV violation is being treated as a noncited violation

(50-458/9909-01), consistent with Appendix C of the NRC Enforcement Policy. The i

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violation is in the licensee's corrective action program as Condition Report CR-99-0875.

During the inspection, at the inspectors' request, the licensee brictly reviewed the

impacts of the higher temperatures on motor-operated valves, cable ampacity, and

temperature-related isolations, and found that, although each of these components were

affected, no operability concems resulted. Based on the information provided by the

licensee, the irispectors agreed with this assessment. However, the licensee's effort did

not constitute a formal operability determination. The licensee's representative agreed

with the inspectors that a revised operability assessment would be required before unit

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

V. Bacanskas, Senior Lead Technical Specialist

R. Biggs, Coordinator, Safety and Regulatory Affairs

R. Brian, Manager, Design Engineering

O. Bulich, Project Engineer

S. Dhingra, Design Engineering

D. Dormandy, Manager, Performance and System Engineering

R. Fili, Supervisor, System Engineering

W. Fountain, Technical Specialist

J. Fowler, Manager, Quality Assurance

R. King, Director, Nuclear Safety and Regulatory Affairs

D. Loriing, Supervisor, Licensing

D. Pace, Director, Design Engineering ]

D. Parks, Design Engineering i

J. Schlesinger, Technical Assistant )

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P. Sicard, Manager, Safety and Engineering Analysis

D. Stewart, System Engineer

D. Williamson, Senior Licensing Specialist j

NRG

N. Garrett, Resident inspector

G. Replogle, Senior Resident inspector

INSPECTION PROCEDURES USED

92902 Followup-Maintenance

92903 Followup-Engineering

ITEMS OPENED AND CLOSED

Opened

50-458/9909-01 NCV Inadequate Operability Evaluation of Degraded Auxiliary Building

Unit Coolers (Section E8.1)

50-458/9909-02 NCV Failure to Perform a 10 CFR 50.59 Evaluation (Section E8.1)  ;

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50-458/9909-03 NCV Failure to Take Adequate Corrective Actions to Replace Missing

insulation on High Pressure Core Spray Pump Room Piping and

to Restore Degraded Unit Coolers to Design Capacities (Section

E8.1)

50-458/9909-04 URI Handling of Auxiliary Building Unit Cooler Test Failures within the

Maintenance Rule Program (Section M8.1)

Closed

50-458/9813-06 IFl Review of Licensee's Response to NRC on How

Recommendation 11 of Generic Letter 89-13 Would be

implemented (Section M8.2)

50-458/9909-01 NCV Inadequate Operability Evaluation of Degraded Auxiliary Building

Unit Coolers (Section E8.1)

50-458/9909-02 NCV Failure to Perform a 10 CFR 50.59 Evaluation (Section E8.1)

50-548/9909-03 NCV Untimely Corrective Actions to Restore Missing Insulation on High

Pressure Core Spray Pump Room Piping (Section E8.1)

DOCUMENTS REVIEWED

Procedures

RBNP-030," Initiation and Processing of Condition Reports," Revision 14

RBNP-078," Operability Determinations," Revision 4

PEP-0046, "Servbe Water Heat Exchanger inspections," Revision 4 -

S:\ OPS \OWA DOC," Operator Work Around Main Control Room Deficiency Program."

Revision 7

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Calculations

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PM-194, " Standby Cooling Tower Performance and Evaporation Losses Without Drywell Unit

Coolers," Revision 3 '

G13.18.2.1*059-1 A, " Control Building Heat Load Evaluation During LOCA w/Offsite Power  ;

Available and Normal Operating Conditions," Revisions 1 and 1 A

G13.18.2.1*610," Auxiliary Building Normal Operation Heat Loads, Unit Cooler Sizing

Verification," Revisions 0,1,1-A

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PB-030, " Heat Gain in Auxiliary Building," Revision 3

G13.3 E-225, "Vcitage Calculation of Category I 480 V Motor Operated Valves," Revision 4

PB-210, " Heat Gain for Containment Outsids Drywell," Revision 2, Addenda B

PB-326, "Effact of LOCA on Containment Unit Coolers," Revision 0

BV-15.1, " Fan External Totu Pressure Unit Coolers,1HVR*UC1 A, UC1B, UC1C," Revision 0

PN-311. " Spent Fuel Pool Temperatures Based on an 18-Month Refueling Cycle," Revision 0

PB-257, " Average and Maximum Design Temperatures for Diesel Generator Control Rooms A

and B," Revision 0

12210/E 167, "5 kV Cable Sizing," Revision 1

PB-029-2, " Heat Gain Auxiliary Building-Piping," Revision 0

No.176, " Analytical Limits for Leak Detection System Temperature Setpoh," Revision 0

PB-250, " Average and Maximum Design Temperatures for Each Zone in the Auxiliary Building,"

Revision 0

12210-ZA-E31*1,"Setpoint Calculation of RHR Equipment Area Ambient and Differential

Temperature Monitors," Revision 0

Enaineerina Reauests

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ER 96-0733, Update auxiliary building HVAC calculations and EDC due to issuance of

Calculations G13.18.2.1*061 and G13.18.2.1*062

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Modification Reauests

87-0719. "Uprate of Chiller Units to 200 Tons," October 10,1987

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Condition Reoorts

87-1667, When pressure testing unit cooler HVR-UC8,19 cooling coil leaks were noted

95-0099, The USAR heat load for room cooler HVR-UC6 is greater than the actual heat loads

for the area

95-0887, High pressure core spray system room coolers had catastrophic failure causing the ,

system to be inoperable l

96-1581, Inability to maintain 122 degrees F in HPCS room

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96-1891, Operability for EQ equipment located in the auxiliary building under LOCA/ LOOP

conditions

96-1952, Engineering eval'uation of the heat transfer capacity performance of room cooler

HVR-UC5 indicates that cooling coil will not remove the required heat load

97-0025, Failure of room cooler HVR-UC9 to meet the required cooling capacity

97-0081, Documented failure of room cooler HVR-UC6 during test to meet required cooling rate

97-0375, initiated to evaluate installation of baffle plates in the auxiliary building room coolers

98-0591, Justification of why room cooler HVR-UC5 remains operable in spite of failing tests

98-0659, Quality Assurance audit discovered that design cooling capacity value in SAR table

was wrongly corrected by Revision 8 LCN

98-0794, Degraded condition of auxiliary building unit coolers

99-0875, Effect of elevated temperatures in auxiliary building

99-0885, Missing insulation on HPCS piping

99-0890, Leak detection setpoint for the RHR system is 117 degrees F which is lower than the

design temperature of the RHR rooms, so RHR could isolate without a leak present'

Maintenance Action items

312074 HVR-UCS Subject Test

Specifications

General Electric Specification 22A3093, "BWR Equipment Environmental Interface Data,"

Revision 3

General Electric Specification 22A6926,"BWR Equipment Environmental Interface Data,"

Revision 0

General Electric Specification 22A3155AK," Design Specification Data Sheet, Heat Exchanger,

Cleanup, Regenerative," Revision 0

241.234," Insulated 600-V Power Cable," January 22,1981

215.252, " Containment Unit Coolers and Auxiliary Building Unit Coolers with ASME Ill, Class 3

Coils," Addendum 7 to Revision 2

215.253," Auxiliary Building Unit Cooler Replacement Cooling Coils," Revision 3

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Environmental Opalification Assessmont Reports

EOAR-024,' Westinghouse Mediurn Duty Motors," Revision 0

EOAR 057,"Rosemount 1153 Series B Alphaline Pressure Transmitters," Revision 0

EOAR-073, "GE Vertical 4160V Pump Motors," Revision 0

Drawinas

0215.252-057-007C," Containment Unit Cooler Bill of Material'

0215.252-057-010H, " Unit Cooler Outline Drawing"

0244.700-004-019G, " Lube Oil Coolers EGS-EG1 A/1 B"

Miscellaneous

6215.257-057-002A," Fan Performance Curve"

MR 87-719, letter Carrier to J. Hamilton, Gulf States Utilities Company, computer runs of chilled

water units  ;

0247-250-329-026J, " Supplier's Document Data Form, Outline Configuration Process

Monitors," Revision E

Report E/IC-95-002," River Bend Station Engineering Report for Environmental Qualification of

Reliance Electric 50 HP Fan Motor," Revision 0

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