ML20217B297

Insp Repts 50-498/91-06 & 50-499/91-06 on 910204-15.Major Areas Inspected:Licensee Response to Implementation of Commitments Made in Response to Generic Ltr 89-13

ML20217B297
Person / Time
Site:	South Texas
Issue date:	02/28/1991
From:	Barnes I, Ellershaw L, Gilbert L, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217B284	List: ML20217B278 ML20217B297
References
50-498-91-06, 50-498-91-6, 50-499-91-06, 50-499-91-6, GL-89-13, NUDOCS 9103120053
Download: ML20217B297 (12)

See also: IR 05000498/1991006

Text

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APPENDIX

U.S. NUCLEAR RECULATORY COMMISSION

REC 10t1 IV

P

llRC Inspection Report: 50-498/91-06 Operating Licenses: NPF-76

50-499/91-06 NPF-80

Docket: 50-498

50-499

Licensee: Houston Lighting & Power (llL&P) Company

P. O. Box 1700

Houston, Tuas _77251 -

Facility Name: SouthTexasProject(STP),-Units 1and2

Inspection At: STP, Matagorda County, Texas

- Inspection Conduct d: February 4-15, 1991

Inspectors: N -  % . i/.

. C E. Ellershow, fieactor Inspector, Matt. rials Dhte

and Quality Programs Section, Division of

Reactor Safety '

1

Sw. - . .. 2./1g/9) {

"

4 L. D. Gilbert, Feactor Inspector, Materials Date

and Quality Programs Section, Division of

Reactor Safety

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W. M. McNeill,- lieactor Inspector, Materials Date

and Quality Programs Section, Division of .

Reactor Safety l

Approved: 3% 2 /2.r/f/ .

l. Barnes, Chief, Matt: rials and Quality . Date

Programs Section, Division of Reactor Safety

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9103120053 910304

gDR ADOCK 0500049s -

PDR ,

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Inspection Sumary

inspection Conducted. February 4-15,1991 (Report.50-498/91-06; 50-499/91-06)

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Areas. Inspected: Routine, announced inspection of the licensee's res

implementation of comitments made in response to Generic Letter (GL)ponse 89-13 to

concerning service water system problems affecting safety-related equipment.

Results: The implementation status of actions taken in response to GL 89-13

was found to be generally consistent with the comitments contained in the

licensee's response letter. One exception was noted pertaining to the

inability to perform comitted testing of the component cooling water heat

exchangers during the current refueling outage. This circumstance arose

because of the unexpected Unit I reactor. trip which preceded the refueling

outage, and the resulting loss of necessary heat loads for conducting the

tests.

Biofouling controls were observed to be effective, with satisfactory

inspections.to detect biofouling being performed. A weakness was noted,

however, in regard to the absence of procedural guidance for conducting.the

biofouling inspection activity. Review of performance test data (for the

essential chillers and the Train C standby diesel generator lube oil and

jacket water coolers) identified pressure and temperature data anomalies which

appeared to invalidate the tests. The anomalies appeared to be related to

instrumentation selection and use. In regard to instrumentation selection and

use, the governing test procedure was noted to lack s

A noncited violation was identified (paragraph 2.1.2)pecificity

with respectintoitsthe

guidance.

- failure to " red line" a control room copy of a drawing to reflect installation

of an essential: cooling water side stream heat exchanger. The routine inspection

and preventative maintenance programs appeared to be satisf actory, with the

exception of the weakness noted above. An inspector followup item was also

identified (paragraph 2.1.3) with respect to review of a formalized program for

monitoring de-aluminization of large bore cast aluminum bronze components.

- Comitments made with respect to:as-built verification and review of maintenance

practices, operating and emergency procedures, and training (which involve the

essential cooling water-system) were verified to have been satisfactorily

' implemented.

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DETAILS

1. PERSONS CONTACTED

1.1 HL&P

+ S. Rosen, Vice President, Nuclear Engineering

+ M. Wisenburg, Plant Manager

4 T. Jordan, General Manager, Nuclear Assurance

• R. Balcom, Director, Quality Assurance

• R. Gangluff, Chemical Operations & Analysis Manager

• D. McCallum, Plant Operations Support Manager

• K. Christian, Unit 1 Operations Manager

+*M. Chakravorty, Director,= Nuclear Safety Review Board

+ A. McIntyre, flanager, Des _ign Engineering Department-(DED)

+ S. Timmaraju, Senior Consulting Engineer, DED

+ A. Harrison, Manager, Nuclear Licensing

+*C. Ayala, Supervising Licensing Engineering

+ A. Khosla, Senior Licensing Engineer

• P. Walker,. Senior Licensing Engineer

+ W. Jump, Maintenance Manager

+ J. Lovell, Technical Services Manager-

+ J.- Sharpe Deputy Itaintenance Manager

+ S. Melton, Supervisino Engineer

• B. Mukherji, Essentiai Cooling Water System Engiraer -

• D. Musick, Supervisor, Nuclear Steam Supply System (NSSS) Engineering

.J.. .lohnson, Supervisor, Engineering Assurance

• V. Starks, Mechanical Engineer

• J. Light, Nuclear Assurance Engineer

• G. Boghosian, Nuclear Assurance Engineer

S. Harvey; Senior Nuclear Chemist

J. Cole, Diesel Generator System Engineer

S. Citzler, General Supervisor, Unit 1 Chemical Analysis

'. M. Rejcek, General Supervisor,. Unit 1 Chemical Operations

L -W. Slotman, instrumentation & Controls (180) Preventive Maintenance

'

Coordinator

! 1.2 NRC

+ J. Tapia, Senior Resident inspector

+*R. . Evans, Resident Inspector

The:insoectors also interviewed other employees during the inspection.

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• Denotes attendance at interim exit interview conducted on February 8,1991.

+ Denotes attendance 'at exit interview conducted on february 15, 1991.

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2. ESSENTI AL COOLING WATER SYSTD' . (92701)

At STP, the Service Water (SW) system defined in General Design Criterion 44

" Cooling Water" of 10 CFR Part LO, Appendix A, is comprised of the Essential

Cooling Water (ECW) system and the Component Cooling Water (CCW) system. These

systems provide for the transfer of heat loads to the Essu>tial Cooling Pond

(ECP), which is the ultimate heat sinn.

The CCW is a closed loop system used to transfer heat from various components

to the ECW system, which is a once-through cooling water system that discharges

to the ECP. The ECP is shared between Units 1 anc 2.

2.1 Generic Letter 89-13

By letter dated July 18,1989 "Scrvice Water System Problems Affecting

Safety-Related Equipment (Generic Letter 89-13)," NRC requested all ruclear

power plant licensees to comit to certain tests and evaluations of SW systems

and to respond to this requirement for information within 180 days of receipt

ofthegenericletter(GL). In addition, each licensee was required to confirm

that all of the recommended actions or their justified alternatives had been

implemented within 30 days of such implenentation. HL&P, in response to the

five recomended actions contained in GL-89-13, addressed their SW program for

STP by letter dated January 29, 1990. The letter also stated that since Unit 1

is a more limiting representation of ECW condition because it has been in

operation longer than Unit 2, the recomended actions would be implemented by

the third refueling outage for Unit 1 (1RE03). The 1RE03 was underway at the

time of the inspection. Further, the testing program identified in GL 89-13

would only be performed on Unit 1, since the Unit 2 cesign is identical.

Corrective actions resulting f rom any identified conditions on Unit 1 would

also be applied to Unit F. The NRC subsequently accepted HL&P's response by

letter dated February 4,1991. During this inspection, the inspectors reviewed

the actions taken by HL&P to fulfill the comitments made to the NRC and

observed the following.

2.1.1 Biofouling Control

Recommended Action I of GL 89-13 addressed the need to impitnent and maintain

an ongoing program of surveillance end control to reduce significantly the

incidence of flow blockage problems resulting from biofouling. Encionre 1 'o

GL 89-13 described a program accepteble to the NRC for meeting the objectives

of Recommended Action 1; this program consisted of surveillance and control

techniques. HL&P responded by stating that, initially, three bays of the ECW

intake structure would be inspected once every 18 months for macroscopic

Should foulin

biological fouling organisms, sediment, and corrosion. sediment, i.e., and the corrosion not be

number of bays) may be reduced to one bay per interval. HL&P also discussed

their chemical treatment program to limit biological fouling and inhibit

corrosion and scaling and stated that since chemically shocking the ECP, no

clams had been detected. A comitment was also made to revise all operating

procedures by August 31, 1990, to require flow testing of any ECW heat

exchanger left idle for extended periods.

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The inspectors were informed that the Unit 1 ECW intake structure's A-hay was

being dewatered in preparation for inspection. It was learned that C-bay had

-already been inspected and B-bay was scheduled later during this outage. The

-inspectors accompanied the ECW system engineer and the senior nuclear chemist

during the inspection of A-bay. It was noted that inspection procedures did

not exist, however, the HL&P personnel did a thorough job in examining the

walls, traveling screens, ECW pump housing and the underside of the inlet bell,

and the piping associated with the chemical spargers. Samples of sediment,

wc11 and pump housing scrapings, and deposits were collected. It was learned

that the samples are sent to two independent laboratories (Eetz Industrial and

Nalco Chemical Company) for microbiological and deposit (chtmical) analysis.

There was no indication of bivalve macrofouling. There were areas on the

vertical and horizontal stay bars of the traveling screens where some of the

coating had come off. resulting in local corrosion in those areas. Small

clusters of bryozoans, an aquatic invertebrate which reproduces by budding and

forming moss-like colonies, were noted to be present. According to the HL&P

personnel, the number of colonies was very small when compared to the time

before initiation of chemical treatment (i.e.,- sodium hypochlorite and bromine

injection).

The inspectors also observed the condition of the end bells, divider plates,

tube sheets, and tubes of the Unit 1. Train A standby diesel generator's (SBDG)

lube oil cooler, jacket water cooler, and intercooler. Both the lobe oil

cooler and the jacket water cooler exhibited corrosion in the areas of the

divider plates, cover plates, and end bells where the coating had been lost.

The outlet passes had a buildup of approximately 1-5 mils of scale. There was

no indication of macrobiological fouling. -Each of these two coolers was

constructed of titanium tubes, aluminum bronze tube sheet, and coated carbon

I steel shell, plates, and end bells._ The intercooler.was observed to be heavily

l corroded with approximately 40 percent-of the tubes blocked. There was no

evidence of macr d ological fouling. The heavy corrosion was present on the

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end bells, baffle plates, and tubesheets, as a result of being constructed of

j uncoated carbon. steel. As part of HL&P's evaluation regarding their: response

l - to GL 89-13, it was recognized that the intercooler carbon steel parts were not 4

coated, and it was decided to coat them during 1RE03. The inspectors observed

the cleaning of the intercooler and rodding of the tubes in preparation for

coating. Again,.the lack of procedures or instructions was apparent with

respect to'the inspection process.

Discussions with the senior nuclear chemist and the manager of chemistry

operations and analysis indicated that inspection procedures have not been

formalized. The finalizing of data obtained from different sources (i.e.,

independent laboratories, engineering, and chemistry operations and analysis)

during 1RE03 plus the- data acquired -during previous inspections of the various-

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L ECW heat exchangers and coolers will be used to develop the inspection guidance

for future'use. A considerable amount of operating data and analyses have been -

accumulated; however, the recordkeeping appeared to be somewhat fragmented.

The inspectors reviewed and observed the sodium hypochlorite distribution

system, sodium bromide injection system, and the corrosion inhibitor injection

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system. The bromide injection system ties into the sodium hypochlorite

distribution system so thst both are injected at the same time (i.e.,

20 minutes every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). The amount of corrosion inhibitor added is

based on the results f rom corrosion coupons which are analyzed and replaced at

specified intervals.

The inspectors reviewed operating procedures (see Attachnient) to verify that

they had been revised to require flow testing of any ECW heat exchanger left

iole for extended periods. The procedures were found to have been revised to

require flow testing if any ECW beat exchanger was idle in excess of 31 days.

In general, the inspectors found that HL&P has implenented a biofouling cortrol

and inspection program. Based on the inspectors observation of one bay in the

ECW intake structure, the diesel generator coolers (not including the uncoated

intercooler), and review of records of previous inspections, the chemistry end

corrosion control efforts appeared to be effective. The lack of specificity

with respect to providing inspection guidance / instructions is considered to be

a weakness.

2.1.2 System Testing

Recomended Action 11 of GL 89-13 required a test program to be established to

verify the heat transfer capability of all safety-related heat exchangers

cooled by SW. The recomendation also included alternative methods that would

be considered acceptable. HL&P respcnded to GL 89-13 and identified the

safety-related heat exchangers to be tested and the method by which each heat

exchanger's design capacity would be verified. The response stated that for

each train, the CCW/ECW heat exchanger, SBDC intercooler, SBDG lobe oil cooler,

SBDG jacket water cooler, CCW pump supplementary cooler, and the two essential

chillers would ue tested during 1RE03 anc the next two refueling outages in

accordance with Procedure OPEP07-EW-0001, " Performance Test for Essential

Cooling Water Heat."

The inspectors verified that this testing had been implemented during 1RE03 and

was ongoing during this inspection. tie testing used ultrasonic instrumentation

for flow measurement, surface mounted resistance temperature devices (RTDs) and

certain installed instrumentation. The acceptance of a performance test was to

be based on a comparison of an overall fouling factor, as calculated from

measured flow and temperatures, with the design overall fouling factor. The

testing which had been accomplished included Trains A, B, and C essential

chillers (six tests); Train C SBDG-intercooler, lube oil cooler, and jacket

cooler (three tests) and Train C CCP puaip supplementary cooler. The remaining

tests were planned to be completed Jring IRE 03 except for the CCW/ECW heat

exchangers. Although testing of CCW/ECW heat exchangers was comitted to in

the response letter, it was not possible to test them during this outage

because the outage had begun with an unexpected reactor trip. The unexpected

reactor trip resulted in the loss of heat loads that were necessary for testing

the CCW/ECW heat exchangers. HL&p agreed to update the response letter in

regard to testing of the CCW/ECW heat exchanges.

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The inspectors reviewed the data that had been collected to date and the

calculations (MC-6219) used to establish acceptance criteria with HL&P staff.

The data had not been finally accepted and was in the process of being evaluated.

During review of the data with licensee personnel, the inspectors noted that

the tests performed on the essential chillers appeared to be inadequate. This

was-because of inconsistent data from the installed instrumentation for the

shell side pressure. It also appeared that test conditions were not optimum in

that an insufficient heat load may have been used for testing. The SBDG lube

oil cooler and jacket water cooler tests also appeared to be inadequate, as a

result of inconsistent data from the installed instrumentation for the lobe oil

and jacket water outlet temperatures. The instrumentation may not have been

optimized with resptict to location end was not under proper calibration control.

The HL&P stafI agreed that retesting of these components would be perforrred

during this outage. The inspectors noted that the procedure appeared to be in

need of revision to better specify the instrumentation to be used and the

necessary test conditions,

in their response letter HL&P identified that an ECW side stream heat

exchanger (SSHX) (a model heat exchanger to provide continuous information on

t.ctrosionand-foulingcharacteristicsformaterialsfoundintheECW)hadbeen

installed. Tbc information from the model would be used with the heat exchanger

-test results to determine the final performance testing f requency. The SSHX

had been installed and data collected since August 1990. During review of the

SSHX. the inspector noted that it had been installed under the direction of

Modification Package No.88-109. However, this system was not found on the ECW

piping and instrumentation diagram (P&lD). The control room copy of this

modification package indicated that the design had been completed on July 26,

1989, but the installation activities had not been signed off. Upon

identification of the apparent improper handling of this mocification by the

inspector, HL&P reviewed the histor

-issued Station Problem Report (SPR)y of Modification

91-0052. Package

HL&P, as part No. out

of the close 88-109 and  ;

activities for this SPR, will review the generic impact of this finding and- '

establish corrective actions. The control room copy of the applicable-P&lD was

subsequently * red lined" with the-correct information. A Notice of Violation

is not being issued because the criteria of Section V.A. of the NRC's Enforcement

Policy have been met. 1

The operation of the SSHX was addressed in Procedure OPCP15-EW-0001, "ECW Side  :

Stream Corrosion Monitor Start-up and Shutdown." The inspectors conducted a j

walkdown of this system and reviewed the data that had been collected from  !

September through November 1990. The SSHX data collection and evaluation is

performed by a subcontractor (Detz Industrial).- The SSHX had two independent

subsystems: a Cooling System Monitoring Station -(C0SMOS) and a Monitell. The

COSMOS was a~ heat exchanger and data acquisition system. The Monitall contained

an electrically heated test rod for measurercent of fouling rates. Both of the

subsystems measured cunductivity, pH, temperatures, and calculated heat flux

and fouling f actors. It was noted that the SSHX is limited in its data

collection capability because the procedure required both Trains A and B to be

operating in order for the SSHX to be operational. The SSHX takes a suction

from one train and discharges into the other.

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In that the data collected to date represents the initial operation of the

SSHX, it was difficult to fully evaluate the information for trends. The

inspectors noted that procedures did not identify the information required from

the subcontractor end HL&P staff (i.e., SSHX operational status, and plant

status and evolutions, respectively) in order to make the data meaningful and

understandable.

2.1.3 System Inspection and Evaluation

Recorreended Action 111 of GL 89-13 required the establishment of a routine

inspection and traintenance program for open-cycle service water system piping

and components to ensure that corrosion, erosion, silting, and biofouling

cannot degrade the performance of the safety-related systems served by service

water. HL&P responded by stating that the preventative maintenance program

meets the requirements of this Recommended Action for open-cycle service water

systers and as a project commitment, GL 89-13 will be specifically referenced

in the preventative traintenance progran by November 15, 1990.

The inspectors were informed that the preventative maintenance program is

controlled by Procedure OPHP02-ZG-0008. This procedure provides instructions

for the identification, development, and revision of preventative maintenance

activities. The reference to GL 89-13 was noted as having been incorporated

into the procedure on August 15, 1990. The inspectors verified that the

preventative maintenance activities (PMs) included the inspection and c1 caning

of safety-related heat exchangers cooled by the ECW system. The inspectors

observed, as discussed in paragraph 2.1.1 above, the inspection of the lobe oil

cooler, jacket water cooler, and intercooler for the Train A SBDG in Unit 1.

The inspectors requested the completed documentation for PMs involving the

inspection and cleaning performed on Train C of the service water system. The

preventative maintenance and related work request and order documents nade

available to the inspectors indicated that the inspection of CCW lleat Exchanger

IC, Essential Chillers 11C and 120. and SBDG 13 intercooler, SBDG 13 lube oil

cooler, and SBDG 13 jacket water cooler was performed during this refueling

outage. Although the documentation was f ragmented, the inspectors determined

through review of the documentation and discussions with the system engineer

and chemistry personnel that the components had been opened, inspected, and

cleaned. The frequency specified in the PMs for the CCW heat exchanger and

essential chillers was each refueling cycle, whereas the frequency specified

for the SBDG coolers was each third refueling cycle. The inspection performed

on the inside of the SBDG coolers ottected corrosion damage to the surface of

the carbon steel corrponents. The parts of the SBDG coolers made of carbon

steel were sandblasted, checked for minimum wall thickness, and recoated, or in

the case of the SBDG intercooler, coated for the first time, using ceramic

metal coating materials. In addition to the inspection of the heat exchanger,

chillers, and coolers, the system engineer and cFemistry personnel indicated

that accessible portions of the ECW piping systems were also inspected and

cleaned when deemed necessary by the system engineer.

The inspectors also discussed the routine corrorion and erosion monitoring

program with design engineering. The inspectors were informed that the CCW and

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ECW piping systems were eliminated from the piping systems reauiring monituring

for wall thinning. The CCW system was excluded because the carbon steel system

is treated with a corrosion inhibitor. The ECW system was excluded because the

system was constructed of aluminum bronze material which, for the most part,

has a very low corrosion rate. The inspectors requested a status on the

engineerino evaluation of corrosion caused by de-alloying (de-aluniinization) of

the cast aluminum bronze raterials which was identified during initial

operation of Unit 1. The inspectors were informed that cast materials in the

small bore piping of 2-inch and less, in both units, have been replaced. A

short-term monitoring program of de-alloying in large bore piping cast aluminum

bronze materials was completed in 1989. The necc for a formalized long term l

ronitoring program to direct further evaluations and trending of the data was l

discussed with design engineering. Since further monitoring activities were l

planned, design engineering stated that a formalized monitoring program woulo

be developed for further de-aluminization evaluation activities. Review of the

foriralized monitoring program will be an inspector followup item. (498/9106-01)

2.1.4 As-Euilt Verification

Recommendation IV of GL 89-13 required confirmation that the SW system will

perform its intended function in accordance with the licensing basis for the

plant. The confirmation was to include recent system waltdown inspections to

ensure that the as-built system is in accordance with the appropriate licensing

basis documentation. HLEP responded by stating that configuretion control

programs maintain plant systems in accordance with the design basis. In

addition to a system turnover reconciliation which included detailed waltdcwns

at the time of plant licensing, a safety system functional inspection (SSFI)

had been perforced of the ECW. The response further stated that the SSF1

concluded that the system configuration had been maintained and that the system

would perform its design function.

The inspectors reviewed the SSFI report (89-06) which was perforced during

October 23 through December 1, 1989. The report was found to have 34

observations which resulted in 38 action items, of which all but 10 were closed

as of this inspection. The oepth of review and scope of the SSFI was noted to

be particularly good. The SSFI noted several important functional weaknesses

and some progranynatic weaknesses that affected functionelity. The inspectors

did note that one of the programmatic weaknesses icentified was that the

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es-installed, as-operated configuration did not always agree with the documented

configuration. In this regard, HL&P agreed to arend their response letter to

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GL 89-13 to accurately reflect the SSF1 conclusions. The SSF1 did identify

i sofre strengths with respect to the design which was found to have considerable

l margin, flexibility, and reliability. The SSFI concluded that the system would

i perform the designed function. The SSFI, consisting of six HL&P personnel and

l four consultants, arrived et their conclusions based on review of design and

l- operation documents, walkdowns of the system, and interviews with engineering,

l operatiuns. and maintenance personnel.

In addition to the SSFI, the inspectors found that a design basis cocument,

" Essential Cooling Water System," (5R289MB1002) had been issued on fiarch 15,

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1990. This document summarized the design of ECW and consisted of a number of

design documents which appeared to have been subjected to review by the SSF1.

The inspectors did note that the design basis document did not address the SSHX

modification noted earlier in this section and a temporary modification. The

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temporary modification removed electro-hydraulic control of valves used to

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regulate chiller condenser pressure because problems had been encountered in

automatic operation of these valves. The throttling of inlet flow became a

manual operation. This temporary modification (T1-EW-89-063, T1-EW-064, and

T3-EW-89-065) has been in place since Hay 1989, without a permanent resolution

to the problem.

The HL&P response letter also addressed the CCW system and committed to conduct

a walkdown of one train in Unit 1 during 1RE03. HL&P id(ntified that Train A

had been selected and the inspectors reviewed the walldown records. The

walkdown was performed in accordance with Procedure 1 PSP 15-CC-0001 and P&ID

SR209F05017 with no significant problems identified. The other trains, as

well as the common headers and loads outside the reactor building, are also

planned to be the subject of a walkdown during 1RE03.

2.1.5 Procedures and Maintenance

Recomended Action k of kl 89-13 required confirmatiun that maintenance

practices, operating and emergency procedures, and training that involves the

SW system are adequate to ensure that safety-related equipment cooled by the SW

system will function as intended and that operators of this equipment will

perform effectively. This confirmation should include recent (within the past

2 years) reviews of practices, procedures, and training modules. HLEP responded

by stating that maintenance procedures and operating procedures including

emergency and off-normal procedures are up to date. These procedures are also

subject to biennial review to assure compliance with plant configuration and

operational requirements. As further assurance, HL&P will review the procedures

for ECW and CCW operation and the maintenance procedures specific to ECW and

CCW components. This review will be. cone prior to startup of Unit 1 from its

third refueling outage. Training involving SW systems supporting safety

equipment (ECW and CCW) has been reviewed. Areas reviewed were Licensed

Operator, Non-Licensed Operator, and Maintenance Personnel Training programs.

The results of this review indicate that safety-related equipment cooled by

these systems should function as intended and operators of the equipment will

perform effectively.

The inspectors verified that quality-t elated plant procedures were subject to a

biennial review. The biennial review requirement was specified in Procedure

OPGP03-7.A-0010. " Plant Procedure Compliance, Implementation, and Review."

Revision 11. The inspectors requested a status of the review of the maintenance

and operating procedures. The inspector was provided documentation which

confirmed that an in-depth review of n:aintenance procedures that involve SW

systems had been performed to assure that current procedures adequately address

the concerns of GL 89-13. In the area of operations, the ECW and CCW system

operator actions were reviewee during the Emergency Operating Procedure

Enhancement Program completed August 1990. The off-normal procedures were

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walked down and technically reviewed in December 19F9 as part of an NRC

commitrnent and no deficiencies with safety significance were found, although

, some minor labeling discrepanciet were noted in the procedures. These

discrepancies will be corrected curing the Annunciator F.esponse/0ff-Normal

' Procedure Enhancement Program due for completion in liarch 1992. Other plan

actions include: (1) review of SpRs for ECW problems related to procedure

discrepancies, (2) review of ECW and CCW system operating procedures and SPRs

for technical and human f actors deficiencies, (3) walkdown of the ECW system to

note any labeling discrepancies, and (4) review of ECW surveillance tests for i

technical and human factors deficiencies. In the area of training, the Nuclear '

Training Department conducted a review of training involving ECW and CCW

systems supporting- saf ety-releted equipment. The results of this review-

indicates that the training currently provides and should ensure that safety-

related equipment cooled by these. systems should function as intended and that

operators of the equipment will perform effectively. The inspectors verified

that lesson plans existed for the training of licensed and non-licensed operators

which addressed the design basis of the ECW and CCW systems and the operability

requirements to meet the engineering safety feature support function of these

systems.- In addition to operator training, the inspectors verified that the

training department had developed lesson plans for the training of maintenance

personnel in the design and functional operation of heat exchangers, pumps, and <

valves,

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3. EXIT. INTERVIEW  ;

Exit interviews were conducted on February 8 and February 15, 1991, with those i

personnel denoted in paragraph 1. At these exit interviews, the inspection

findings were sunnarized. No informatior. was presented to the inspectors that

was identified by the licensee as proprietary.

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ATTACHMENT

. DOCUMENTS REVIEWED

STPEGS UFSAR, Section 9.2.1.2, " Essential Cooling Water System," Revision 0

Procedure IPOP02-EW-0001, " Essential Cooling Water Operation," Revision 10

Procedure OPMPO4-ZG-0011, " Heat Exchanger Cleaning," Revision 4

Specification NO-18, " Purchase of Proprietary Chemical Treatment for Main &

Essential Plant Cooling Water Supplies," Revision 1

Procedure IP-3.6Q, " Operational Recurrence Control Program for Microbiological 1y

InfluencedCorrosion(MIC)," Revision 0

.

Procedure OPCP11-SH-003, Sodium Hypochlorite Distribution System Operation,"

Revision 2-

Procedure OPCP02-ZB-0009, " Determination of Chlorine - DPD Method," Revision 3

Procedure OPEP07-EW-0011. " Performance Test for Essential Cooling Water Heat

Exchangers," Revision 1

Procedure OPHP02-23-0008, "PM Development," Revision 1 -

Procedure OPCP15-EW-0001, "ECW Sids Stream Corrosion Monitor," Revision 0-

Drawing SR289F05038, " Piping & Instrumentation Diagram, Essential Cooling

Water," Revision 19

.

Drawing 5R289F22537, " Process flow Diagram Essential Cooling Water System,"

-Revision 8

Design Basis Document SR289MB1002, " Essential Cooling Water System," Revision 0

Report 189-06, Safety System Functional Assessment of the Emergency Cooling

Water System," Revision 0

Calculation MC-6219, Revision 0

Various Inspection Reports,- Laboratory Reports, and Monthly Reports regarding

the ECW system and beat exchangers, dating from 1987

Document No. 5A639P7000, " Erosion / Corrosion Program / Manual," Revision 1

HL&P Letter ST-HL-AE-2938, " Leakage of Aluminum-Bronze Essential Cooling Water [

System," dated January 17,1989

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