IR 05000498/2007007: Difference between revisions

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| issue date = 02/13/2008
| issue date = 02/13/2008
| title = IR 05000498-07-007 and 05000499-07-007; on 09/24/2007 - 01/22/2008; South Texas Project, Units 1 and 2; NRC Inspection Procedure 71111.21, Component Design Bases Inspection.
| title = IR 05000498-07-007 and 05000499-07-007; on 09/24/2007 - 01/22/2008; South Texas Project, Units 1 and 2; NRC Inspection Procedure 71111.21, Component Design Bases Inspection.
| author name = Bywater R L
| author name = Bywater R
| author affiliation = NRC/RGN-IV/DRS/EB1
| author affiliation = NRC/RGN-IV/DRS/EB1
| addressee name = Sheppard J J
| addressee name = Sheppard J
| addressee affiliation = South Texas Project Nuclear Operating Co
| addressee affiliation = South Texas Project Nuclear Operating Co
| docket = 05000498, 05000499
| docket = 05000498, 05000499
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES NU CLE AR RE GU LATOR Y C O M M I S S I O N ary 13, 2008
[[Issue date::February 13, 2008]]


James J. Sheppard, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483
==SUBJECT:==
 
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000498/2007007 AND 05000499/2007007
SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000498/2007007 AND 05000499/2007007


==Dear Mr. Sheppard:==
==Dear Mr. Sheppard:==
On November 26, 2007, the U.S. Nuclear Regulatory Commission (NRC)
On November 26, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed onsite portions of a component design bases inspection at your South Texas Project Electric Generating Station, Units 1 and 2. The preliminary results were discussed with you and members of your staff on November 26, 2007. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The enclosed report documents our inspection findings.
completed onsite portions of a component design bases inspection at your South Texas Project Electric Generating Station, Units 1 and 2. The preliminary results were discussed with you and members of your staff on November 26, 2007. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The enclosed report documents our inspection findings.
 
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commission
=s rules and regulations and with the conditions of your license. The team reviewed selected procedures and records, observed activities, and interviewed cognizant plant personnel.
 
The report documents six NRC identified findings, each involving a violation of NRC requirements. All of the findings were evaluated under the risk significance determination process as having very low safety significance (Green). Because of their very low safety significance and because they are entered into your corrective action program, these violations are being treated as noncited violations, consistent with Section VI.A of the Enforcement Policy. If you contest the subject or significance of any of these noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the South Texas Project Electric Generating Station, Units 1 and 2.
 
STP Nuclear Operating Company - 2 -In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,/RA/
 
Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety
 
Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80
 
===Enclosures:===
NRC Inspection Report 05000498/2007007
 
and 05000499/2007007
 
===w/Attachment:===
Supplemental Information


cc w/enclosures:
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commission=s rules and regulations and with the conditions of your license.


E. D. Halpin Site Vice President STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483
The team reviewed selected procedures and records, observed activities, and interviewed cognizant plant personnel.


Ken Coates Plant General Manager STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483
The report documents six NRC identified findings, each involving a violation of NRC requirements. All of the findings were evaluated under the risk significance determination process as having very low safety significance (Green). Because of their very low safety significance and because they are entered into your corrective action program, these violations are being treated as noncited violations, consistent with Section VI.A of the Enforcement Policy.


S. M. Head, Manager, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 Wadsworth, TX 77483
If you contest the subject or significance of any of these noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the South Texas Project Electric Generating Station, Units 1 and 2.


C. T. Bowman STP Nuclear Operating Company - 3 -General Manager, Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483
STP Nuclear Operating Company -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Marilyn Kistler Sr. Staff Specialist, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code 5014 Wadsworth, TX 77483  
Sincerely,
/RA/
Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80 Enclosures:
NRC Inspection Report 05000498/2007007 and 05000499/2007007 w/Attachment: Supplemental Information cc w/enclosures:
E. D. Halpin Site Vice President STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 Ken Coates Plant General Manager STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 S. M. Head, Manager, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 Wadsworth, TX 77483 C. T. Bowman


C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road  
STP Nuclear Operating Company  -3-General Manager, Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Marilyn Kistler Sr. Staff Specialist, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code 5014 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 J. J. Nesrsta/R. K. Temple/
E. Alercon/Kevin Pollo City Public Service Board P.O. Box 1771 San Antonio, TX 78296 Jon C. Wood Cox Smith Matthews 112 E. Pecan, Suite 1800 San Antonio, TX 78205 A. H. Gutterman, Esq.


Austin, TX 78704
Morgan, Lewis & Bockius 1111 Pennsylvania Avenue NW Washington, DC 20004 Director, Division of Compliance & Inspection Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326


J. J. Nesrsta/R. K. Temple/
STP Nuclear Operating Company -4-Environmental and Natural Resources Policy Director P.O. Box 12428 Austin, TX 78711-3189 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 Anthony Jones, Chief Inspector Texas Department of Licensing and Regulation Boiler Program P.O. Box 12157 Austin, TX 78711 Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122, P.O. Box 13087 Austin, TX 78711-3087 Ted Enos 4200 South Hulen Suite 422 Fort Worth, TX 76109 Steve Winn/Christine Jacobs/
E. Alercon/Kevin Pollo City Public Service Board P.O. Box 1771
 
San Antonio, TX 78296
 
Jon C. Wood Cox Smith Matthews 112 E. Pecan, Suite 1800
 
San Antonio, TX 78205
 
A. H. Gutterman, Esq.
 
Morgan, Lewis & Bockius 1111 Pennsylvania Avenue NW Washington, DC 20004
 
Director, Division of Compliance & Inspection Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street
 
Austin, TX 78756
 
Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue
 
Austin, TX 78701-3326
 
STP Nuclear Operating Company - 4 -Environmental and Natural Resources Policy Director P.O. Box 12428  
 
Austin, TX 78711-3189  
 
Judge, Matagorda County Matagorda County Courthouse  
 
1700 Seventh Street Bay City, TX 77414  
 
Anthony Jones, Chief Inspector Texas Department of Licensing and Regulation Boiler Program P.O. Box 12157  
 
Austin, TX 78711  
 
Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122, P.O. Box 13087  
 
Austin, TX 78711-3087  
 
Ted Enos 4200 South Hulen  
 
Suite 422 Fort Worth, TX 76109  
 
Steve Winn/Christine Jacobs/
Eddy Daniels/Marty Ryan NRC Energy, Inc.
Eddy Daniels/Marty Ryan NRC Energy, Inc.


211 Carnegie Center Princeton, NJ 08540  
211 Carnegie Center Princeton, NJ 08540 INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-3064 Lisa R. Hammond, Chief Technological Hazards Branch National Preparedness Division FEMA Region VI 800 N. Loop 288 Denton, TX 76209
 
INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-3064  
 
Lisa R. Hammond, Chief Technological Hazards Branch National Preparedness Division FEMA Region VI 800 N. Loop 288  
 
Denton, TX 76209  
 
STP Nuclear Operating Company - 5 -


STP Nuclear Operating Company - 6 -Electronic distribution by RIV: Regional Administrator (EEC)
STP Nuclear Operating Company -5-STP Nuclear Operating Company  -6-Electronic distribution by RIV:
Regional Administrator (EEC)
DRP Director (DDC)
DRP Director (DDC)
DRS Director (RJC1)
DRS Director (RJC1)
Line 130: Line 63:
RITS Coordinator (MSH3)
RITS Coordinator (MSH3)
DRS STA (DAP)
DRS STA (DAP)
D. Pelton, OEDO RIV Coordinator (DLP1)  
D. Pelton, OEDO RIV Coordinator (DLP1)
 
ROPreports STP Site Secretary (HLW1)
ROPreports STP Site Secretary (HLW1)  
SUNSI Review Completed: ___Y__ ADAMS: 6 Yes No Initials: ___WSifre___
 
6 Publicly Available Non-Publicly Available Sensitive 6 Non-Sensitive SRI:EB1 RI:PBC RI:EB1 OE:OB C:EB1 C:PBA C:EB1 WSifre/lm MChambers SMakor GApger RLBywate CEJohnson RLBywater b    r
SUNSI Review Completed: ___Y__ ADAMS: Yes No Initials: ___WSifre___ Publicly Available Non-Publicly Available Sensitive Non-Sensitive  
/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
1/2/08 12/18/08 1/2/08 1/2/08 2/13/8 2/12/08 2/13/08


SRI:EB1 RI:PBC RI:EB1 OE:OB C:EB1 C:PBA C:EB1 WSifre/lm b MChambers SMakor GApger RLBywate r CEJohnson RLBywater /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ 1/2/08 12/18/08 1/2/08 1/2/08 2/13/8 2/12/08 2/13/08 STP Nuclear Operating Company - 7 -OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax  
STP Nuclear Operating Company -7-OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
 
Enclosure - 1 -


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000498/2007007 and 05000499/2007007; September 24, 2007 through January 22, 2008;  
IR 05000498/2007007 and 05000499/2007007; September 24, 2007 through January 22, 2008;


South Texas Project Electric Generating Station, Units 1 and 2; NRC Inspection Procedure 71111.21, "Component Design Bases Inspection."
South Texas Project Electric Generating Station, Units 1 and 2; NRC Inspection Procedure 71111.21, "Component Design Bases Inspection."


The report covered a 4-week period of onsite inspection and additional in-office inspection performed by six region-based inspectors and two contractors. The inspection identified six Green noncited violations. The significance of most findings is indicated by its color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
The report covered a 4-week period of onsite inspection and additional in-office inspection performed by six region-based inspectors and two contractors. The inspection identified six Green noncited violations. The significance of most findings is indicated by its color (Green,
White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.


===A. NRC - Identified Findings===
===NRC - Identified Findings===


===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
: '''Green.'''
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," having very low safety significance for the failure to specify in a design calculation allowable relay setpoint tolerances. Specifically, the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures. The issue was documented in the corrective action program as Condition Record 07-15443.
The team identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion III, "Design Control," having very low safety significance for the failure to specify in a design calculation allowable relay setpoint tolerances.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control."  It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition did not represent a loss of safety function of a system or a train.  (Section 1R21.b.1)
Specifically, the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures.
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," having very low safety significance for the failure to include all potential loads in the standby diesel generator fuel oil sizing calculation. Specifically, the licensee did not account for increased standby diesel 


- 2 -generator fuel oil usage resulting from the addition of manual electrical loads during the 7-day mission run time. The licensee entered this finding into their corrective action program as Condition Record 07-15592. The licensee subsequently demonstrated that the spent fuel pool cooling pumps would be the only additional manual loads actually used during the 7 days of operation in the bounding design basis scenario and that there were additional conservative assumptions in the sizing calculation to demonstrate sufficient margin.
The issue was documented in the corrective action program as Condition Record 07-15443.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Pow er Situations," Phase 1 screening, the finding screened as having very low safety significance (Green)because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality.  (Section 1R21.b.2)
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," of very low safety significance for the failure to translate design basis information into specifications and procedures. Specifically, a non-conservative system pressure was used as an input to an engineering design calculation for the auxiliary feedwater outside containment isolation valves. This finding has been entered into the licensee's corrective action program as Condition Record 07-15455.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control."  It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Pow er Situations," Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss safety function of a system or a train.  (Section 1R21.b.3)
The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition did not represent a loss of safety function of a system or a train.
: '''Green.'''
The team identified a noncited violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, having very low safety significance for the licensee's failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable. This issue was entered into the licensee's corrective action program as Condition Records 07-14903 and 07-14959.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control."  It impacts the 
              (Section 1R21.b.1)
 
- 3 -cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Pow er Situations," Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss of safety function of a system or a train.
 
(Section 1R21.b.4)
: '''Green.'''
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," having very low safety significance for the licensee's failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service.
The team identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion III, "Design Control," having very low safety significance for the failure to include all potential loads in the standby diesel generator fuel oil sizing calculation. Specifically, the licensee did not account for increased standby diesel generator fuel oil usage resulting from the addition of manual electrical loads during the 7-day mission run time. The licensee entered this finding into their corrective action program as Condition Record 07-15592. The licensee subsequently demonstrated that the spent fuel pool cooling pumps would be the only additional manual loads actually used during the 7 days of operation in the bounding design basis scenario and that there were additional conservative assumptions in the sizing calculation to demonstrate sufficient margin.


Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation. The licensee entered the finding into their corrective action program as Condition Record 07-15817.
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance."  It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not result in a loss of safety function of a system or a train.   (Section 1R21.b.5)
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality. (Section 1R21.b.2)
: '''Green.'''
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," of very low safety significance for the failure to adequately translate design basis information into specifications and procedures. Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values used during periodic technical specification surveillance testing. The licensee entered the finding into their corrective action program as Condition Record 07-15752.
The team identified a noncited violation of 10 CFR Part 50, Appendix B,
Criteria III, "Design Control," of very low safety significance for the failure to translate design basis information into specifications and procedures.


The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control."  It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Pow er Situations," Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or a train.
Specifically, a non-conservative system pressure was used as an input to an engineering design calculation for the auxiliary feedwater outside containment isolation valves. This finding has been entered into the licensee's corrective action program as Condition Record 07-15455.


(Section 1R21.b.6)
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.


- 4 -B. Licensee-Identified Findings
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss safety function of a system or a train. (Section 1R21.b.3)
: '''Green.'''
The team identified a noncited violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, having very low safety significance for the licensees failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable. This issue was entered into the licensees corrective action program as Condition Records 07-14903 and 07-14959.


None.
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.


- 5 -U.S. NUCLEAR REGULATORY COMMISSION REGION IV
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss of safety function of a system or a train.


Dockets: 05000498, 05000499
  (Section 1R21.b.4)
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B,
Criterion XI, "Test Control," having very low safety significance for the licensees failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service.


Licenses:
Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation. The licensee entered the finding into their corrective action program as Condition Record 07-15817.
NPF-76, NPF-80


Report: 05000498/2007007; 05000499/2007007
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance. It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A,
Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not result in a loss of safety function of a system or a train. (Section 1R21.b.5)
: '''Green.'''
The team identified a noncited violation of 10 CFR Part 50, Appendix B,
Criteria III, "Design Control," of very low safety significance for the failure to adequately translate design basis information into specifications and procedures.


Licensee:
Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values used during periodic technical specification surveillance testing. The licensee entered the finding into their corrective action program as Condition Record 07-15752.
STP Nuclear Operating Company


Facility:
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.
South Texas Project Electric Generating Station, Units 1 and 2


Location  FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or a train.


Dates:  September 24, 2007 through January 22, 2008k
  (Section 1R21.b.6)


Inspectors:
B. Licensee-Identified Findings None.
W. Sifre, Senior Reactor Inspector, Engineering Branch 1 M. Chambers, Resident Inspector, Branch C B. Henderson, Reactor Inspector, Engineering Branch 1 S. Makor, Reactor Inspector, Engineering Branch 1 S. Rutenkroger, Reactor Inspector, Engineering Branch 1 G. Apger, Operations Engineer, Operations Branch


Contractors:
U.S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets:      05000498, 05000499 Licenses:    NPF-76, NPF-80 Report:      05000498/2007007; 05000499/2007007 Licensee:    STP Nuclear Operating Company Facility:    South Texas Project Electric Generating Station, Units 1 and 2 Location      FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates:        September 24, 2007 through January 22, 2008k Inspectors:  W. Sifre, Senior Reactor Inspector, Engineering Branch 1 M. Chambers, Resident Inspector, Branch C B. Henderson, Reactor Inspector, Engineering Branch 1 S. Makor, Reactor Inspector, Engineering Branch 1 S. Rutenkroger, Reactor Inspector, Engineering Branch 1 G. Apger, Operations Engineer, Operations Branch Contractors: H. Anderson, Mechanical Contractor J. Chiloyan, Electrical Contractor Approved By: Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety
H. Anderson, Mechanical Contractor J. Chiloyan, Electrical Contractor  
 
Approved By:
Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety


=REPORT DETAILS=
=REPORT DETAILS=
Line 226: Line 153:
==1R21 Component Design Bases Inspection==
==1R21 Component Design Bases Inspection==
{{IP sample|IP=IP 71111.21}}
{{IP sample|IP=IP 71111.21}}
The team selected risk-significant components and operator actions for review using information contained in the licensee
The team selected risk-significant components and operator actions for review using information contained in the licensee=s probabilistic risk assessment. In general, this included components and operator actions that had a risk achievement worth factor greater than two or Birnbaum importance value greater than 1E-6.
=s probabilistic risk assessment. In general, this included components and operator actions that had a risk achievement worth factor greater than two or Birnbaum importance value greater than 1E-6.


====a. Inspection Scope====
====a. Inspection Scope====
Line 234: Line 160:
The team reviewed maintenance work records, corrective action documents, and industry operating experience information to verify that licensee personnel considered degraded conditions and their impact on the components. For the review of operator actions, the team observed operators during simulator scenarios associated with the selected components, as well as observing simulated actions in the plant.
The team reviewed maintenance work records, corrective action documents, and industry operating experience information to verify that licensee personnel considered degraded conditions and their impact on the components. For the review of operator actions, the team observed operators during simulator scenarios associated with the selected components, as well as observing simulated actions in the plant.


The team performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design issues, margin reductions due to modification, or margin reductions identified as a result of material condition issues. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as failed
The team performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design issues, margin reductions due to modification, or margin reductions identified as a result of material condition issues. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as failed
- 7 -performance test results; significant corrective actions; repeated maintenance; 10 CFR 50.65(a)1 status; operable, but degraded, conditions; NRC re sident inspector input of problem equipment; system health reports; industry operating experience; and licensee problem equipment lists. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins.
 
performance test results; significant corrective actions; repeated maintenance; 10 CFR 50.65(a)1 status; operable, but degraded, conditions; NRC resident inspector input of problem equipment; system health reports; industry operating experience; and licensee problem equipment lists. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins.


The components selected for review were:
The components selected for review were:
Line 263: Line 190:
* Starting auxiliary feedwater if engineered safety features actuation system fails during a control room fire.
* Starting auxiliary feedwater if engineered safety features actuation system fails during a control room fire.


The operating experience issues were:
The operating experience issues were:
- 8 -
* NRC Information Notice (IN) 2006-06, "Loss-of-Offsite Power and Station Blackout Are More Probable During Summer Period."
* NRC Information Notice (IN) 2006-06, "Loss-of-Offsite Power and Station Blackout Are More Probable During Summer Period."
* NRC IN 2007-09, "Equipment Operability Under Degraded Voltage Conditions."
* NRC IN 2007-09, "Equipment Operability Under Degraded Voltage Conditions."
Line 272: Line 198:


====b. Findings====
====b. Findings====
b.1. Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations  
b.1. Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations    


=====Introduction.=====
=====Introduction.=====
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to specify in a design calculation the allowable relay setpoint tolerances stated in the licensee's relay setpoint calibration test procedures. Under postulated electrical fault or overload conditions, the lack of adequate relay coordinating time intervals between relay operating characteristics would lead to spurious tripping and to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate.
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to specify in a design calculation the allowable relay setpoint tolerances stated in the licensees relay setpoint calibration test procedures. Under postulated electrical fault or overload conditions, the lack of adequate relay coordinating time intervals between relay operating characteristics would lead to spurious tripping and to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate.


=====Description.=====
=====Description.=====
During the review of licensee's completed protective relay trip setpoint calibration test procedures, relay setting records and relay setting calculations to verify whether the applied relay settings were consistent with the designed basis calculations, the team noted that the acceptance criteria for the allowable values of relay setpoints stated in calibration test Procedures PM EM-2-03000814, WAN 274021 and relay setting sheets were neither specified nor verified in the design basis relay setting Calculation EC-5029, "4.16kV Switchgear Relay Setting." Following discovery, the licensee performed a preliminary evaluation for affected components using the worst-case scenario of relay setpoint tolerances stated on the relay setting records and concluded that the affected components would still perform their required safety functions in the event of an electrical fault. The issue was documented in licensee's corrective action program as Condition Record 07-15443.
During the review of licensees completed protective relay trip setpoint calibration test procedures, relay setting records and relay setting calculations to verify whether the applied relay settings were consistent with the designed basis calculations, the team noted that the acceptance criteria for the allowable values of relay setpoints stated in calibration test Procedures PM EM-2-03000814, WAN 274021 and relay setting sheets were neither specified nor verified in the design basis relay setting Calculation EC-5029, "4.16kV Switchgear Relay Setting." Following discovery, the licensee performed a preliminary evaluation for affected components using the worst-case scenario of relay setpoint tolerances stated on the relay setting records and concluded that the affected components would still perform their required safety functions in the event of an electrical fault. The issue was documented in licensees corrective action program as Condition Record 07-15443.


=====Analysis.=====
=====Analysis.=====
The licensee's failure to specify relay setpoint tolerances and verify the effects on coordination margin in relay setpoint calculations for relays used on 4.16kV emergency safety feature switchgears was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating
The licensees failure to specify relay setpoint tolerances and verify the effects on coordination margin in relay setpoint calculations for relays used on 4.16kV emergency safety feature switchgears was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating
- 9 -events and prevent undesirable consequences. The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations", Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition had not resulted in a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.
 
events and prevent undesirable consequences. The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition had not resulted in a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.


=====Enforcement.=====
=====Enforcement.=====
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, "Design Control," requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by performance of a suitable testing program.
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, Design Control, requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by performance of a suitable testing program.


Contrary to the above, the licensee's design control measures failed to either specify the relay setpoint tolerances or verify the adequacy of the design for safety-related 4160V electrical distribution system to ensure that the trip settings of the protective relays were adequate to ensure selective tripping in the event of a fault. Specifically, the team identified that the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15443, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-01, Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations.
Contrary to the above, the licensees design control measures failed to either specify the relay setpoint tolerances or verify the adequacy of the design for safety-related 4160V electrical distribution system to ensure that the trip settings of the protective relays were adequate to ensure selective tripping in the event of a fault. Specifically, the team identified that the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15443, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-01, Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations.


b.2. Failure to Consider Manual Loads for Fuel Oil Storage Tank Sizing Calculation  
b.2. Failure to Consider Manual Loads for Fuel Oil Storage Tank Sizing Calculation


=====Introduction.=====
=====Introduction.=====
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators' seven day mission time for the fuel oil storage tank sizing calculation.
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators seven day mission time for the fuel oil storage tank sizing calculation.


=====Description.=====
=====Description.=====
The Final Safety Analysis Report, Revi sion 0, stated that the fuel oil storage tanks were sized to have sufficient capacity to provide for continuous operation of the diesel generators for 7 days at their continuous rating, (i.e., 5935 kW). The licensee revised the Updated Final Safety Analysis Report (UFSAR) on December 9, 1992, to replace the loading at the standby diesel generator continuous rating with the "engineered safety features load requirements.However, the documented review contained in Unreviewed Safety Question Evaluation 91-0031 and Calculation MC-6256, "Sizing of SDG FOST," Revision 0, both discussed including all the non-engineered safety features loads listed in UFSAR, Table 8.3-3, as part of the fuel and storage tank sizing requirement.
The Final Safety Analysis Report, Revision 0, stated that the fuel oil storage tanks were sized to have sufficient capacity to provide for continuous operation of the diesel generators for 7 days at their continuous rating, (i.e., 5935 kW). The licensee revised the Updated Final Safety Analysis Report (UFSAR) on December 9, 1992, to replace the loading at the standby diesel generator continuous rating with the engineered safety features load requirements. However, the documented review contained in Unreviewed Safety Question Evaluation 91-0031 and Calculation MC-6256, Sizing of SDG FOST, Revision 0, both discussed including all the non-engineered safety features loads listed in UFSAR, Table 8.3-3, as part of the fuel and storage tank sizing requirement.


- 10 -In particular, the Unreviewed Safety Question Evaluation 91-0031 stated, "This [including all the listed non-engineered safety features loads] is in accordance with the ANSI N195 Standard which states, 'If the design includes provision for an operator to supply power to equipment other than the minimum required for the plant condition, such additional load(s) shall be included in the calculation of required fuel oil storage capacity.Regulatory Guide 1.137, "Fuel Oil Systems for Standby Diesel Generators,"
In particular, the Unreviewed Safety Question Evaluation 91-0031 stated, This
Revision 1, dated October 1979, refers to the requirements described in ANSI N195-1976, "Fuel Oil Systems for Standby Diesel-Generators," to be a method acceptable to the NRC staff for complying with the Commission's regulations regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality. The safety evaluation report originally prepared for South Texas Project Electric Generating Station used ANSI N195 as the standard to evaluate the acceptability of the fuel oil storage tank design and sizing.
[including all the listed non-engineered safety features loads] is in accordance with the ANSI N195 Standard which states, If the design includes provision for an operator to supply power to equipment other than the minimum required for the plant condition, such additional load(s) shall be included in the calculation of required fuel oil storage capacity. Regulatory Guide 1.137, Fuel Oil Systems for Standby Diesel Generators, Revision 1, dated October 1979, refers to the requirements described in ANSI N195-1976, "Fuel Oil Systems for Standby Diesel-Generators," to be a method acceptable to the NRC staff for complying with the Commissions regulations regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality. The safety evaluation report originally prepared for South Texas Project Electric Generating Station used ANSI N195 as the standard to evaluate the acceptability of the fuel oil storage tank design and sizing.


Since the UFSAR, as revised, did not discuss the additional manual loads, which must be considered in order to evaluate the fuel oil storage tank sizing, Calculation MC-6256, Revision 0, was ultimately re vised in Revision 3, dated October 3, 1996, to remove consideration of all manual loads. Therefore, beginning with that revision the design basis non-conservatively removed consideration of expected actual plant operations with respect to manual loads during the bounding design basis accident analysis.
Since the UFSAR, as revised, did not discuss the additional manual loads, which must be considered in order to evaluate the fuel oil storage tank sizing, Calculation MC-6256, Revision 0, was ultimately revised in Revision 3, dated October 3, 1996, to remove consideration of all manual loads. Therefore, beginning with that revision the design basis non-conservatively removed consideration of expected actual plant operations with respect to manual loads during the bounding design basis accident analysis.


The team interviewed engineering and operations personnel in order to determine what equipment from UFSAR, Table 8.3-3, would be supplied power other than the minimum required for the plant condition. These interviews revealed a range of possible equipment, which could be utilized since the operations philosophy would be to exceed the minimum required for the plant condition in order to place the plant in as safe a condition as possible. The upper range of potential manually loaded equipment would have resulted in exceeding the minimum technical specification fuel oil volume requirement of 60,500 gallons during the 7-day mission time of the standby diesel generators during the worst-case design basis accident considered. However, in further discussions, licensee personnel balanced the operations philosophy with the 7-day fuel oil requirements considered as part of the design basis event and concluded the spent fuel pool cooling pumps would be the only additional manual loads utilized during the bounding scenario. The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high head safety injection, and containment spray pumps would be run continuously for 48 hours following a large break loss of coolant accident. Therefore, the licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensee's corrective action program as  
The team interviewed engineering and operations personnel in order to determine what equipment from UFSAR, Table 8.3-3, would be supplied power other than the minimum required for the plant condition. These interviews revealed a range of possible equipment, which could be utilized since the operations philosophy would be to exceed the minimum required for the plant condition in order to place the plant in as safe a condition as possible. The upper range of potential manually loaded equipment would have resulted in exceeding the minimum technical specification fuel oil volume requirement of 60,500 gallons during the 7-day mission time of the standby diesel generators during the worst-case design basis accident considered. However, in further discussions, licensee personnel balanced the operations philosophy with the 7-day fuel oil requirements considered as part of the design basis event and concluded the spent fuel pool cooling pumps would be the only additional manual loads utilized during the bounding scenario. The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high head safety injection, and containment spray pumps would be run continuously for 48 hours following a large break loss of coolant accident. Therefore, the licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensees corrective action program as Condition Record 07-15592.


Condition Record 07-15592.
=====Analysis.=====
The team determined that the failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators 7-day mission time for the fuel oil storage tank sizing calculation was a performance deficiency. The finding


=====Analysis.=====
was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not accounting for the additional manual loads increases the likelihood that the required inventory of fuel oil for a 7-day mission time would not be available.
The team determined that the failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators' 7-day mission time for the fuel oil storage tank sizing calculation was a performance deficiency. The finding 
- 11 -was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not accounting for the additional manual loads increases the likelihood that the required inventory of fuel oil for a 7-day mission time would not be available.


Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality.
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality.


This finding was reviewed for crosscutting aspects and none were identified.
This finding was reviewed for crosscutting aspects and none were identified.


=====Enforcement.=====
=====Enforcement.=====
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.


Contrary to the above, the licensee had not correctly translated design basis information into the standby diesel generator fuel oil tank sizing analysis. Specifically, the licensee failed to translate the loading and usage associated with additional manual loads, reasonably expected to be utilized during the bounding design basis accident, into Calculation MC-6256, Revision 4. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15592, it is being treated as a noncited violati on consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-02, Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation.
Contrary to the above, the licensee had not correctly translated design basis information into the standby diesel generator fuel oil tank sizing analysis. Specifically, the licensee failed to translate the loading and usage associated with additional manual loads, reasonably expected to be utilized during the bounding design basis accident, into Calculation MC-6256, Revision 4. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15592, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-02, Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation.


b.3. Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves.
b.3. Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary     Feedwater System Outside Containment Isolation Motor Operated Valves.


=====Introduction.=====
=====Introduction.=====
Line 327: Line 253:
The team identified that the pressure loading calculation in the motor-operated valve weak link analysis for the auxiliary feedwater outside containment isolation valves used a system pressure of 1250 psig. This value was based on the steam generator power-operated relief valves in the main steam systems being normally set at 1225 psig for normal operation and an additional 25 psig was added to the nominal steam generator power-operated relief valve set point to allow for any set point uncertainty.
The team identified that the pressure loading calculation in the motor-operated valve weak link analysis for the auxiliary feedwater outside containment isolation valves used a system pressure of 1250 psig. This value was based on the steam generator power-operated relief valves in the main steam systems being normally set at 1225 psig for normal operation and an additional 25 psig was added to the nominal steam generator power-operated relief valve set point to allow for any set point uncertainty.


- 12 -This did not take into account accident conditions that result in the backpressure from the main steam system being greater than 1250 psig.
This did not take into account accident conditions that result in the backpressure from the main steam system being greater than 1250 psig.


In response to the team's questions that the pressure could be greater than 1250 psig, the licensee issued Condition Record 07-15455-4, "Discussion Paper; Re-perform Weak Link Calculation at 1324 psid and 200°F," received October 24, 2007; and Condition Record 07-15455, "Discussion Paper; Weak Link Discussion of Motor-Operated Valves During Normal and Accident Operation," received October 15, 2007. The licensee determined that an increase in steam generator pressure greater than normal operating pressure would occur during certain design bases accident conditions. The appropriate input to the calculation was determined to be a steam generator pressure of 1324 psig, which allows for a 1 percent margin for setting tolerance and 2 percent for pressure drop in the piping connecting the safety valves to the steam generator from the lowest safety valve set point of 1285 psig. With the revised 1324 psig value and the original assumed valve temperature of 200°F the new weak link calculation resulted in two of the eight auxiliary feedwater outside containment isolation valves (one in each unit) having a torque switch setting that exceeded the weak link calculated set point in the close direction. The weak link for these valves is the valve seat. Valve thrust plus system pressure exceeding the valve seat strength could result in thrusting the valve disc into the seat and failure of the valve.
In response to the teams questions that the pressure could be greater than 1250 psig, the licensee issued Condition Record 07-15455-4, "Discussion Paper; Re-perform Weak Link Calculation at 1324 psid and 200°F," received October 24, 2007; and Condition Record 07-15455, "Discussion Paper; Weak Link Discussion of Motor-Operated Valves During Normal and Accident Operation," received October 15, 2007. The licensee determined that an increase in steam generator pressure greater than normal operating pressure would occur during certain design bases accident conditions. The appropriate input to the calculation was determined to be a steam generator pressure of 1324 psig, which allows for a 1 percent margin for setting tolerance and 2 percent for pressure drop in the piping connecting the safety valves to the steam generator from the lowest safety valve set point of 1285 psig. With the revised 1324 psig value and the original assumed valve temperature of 200°F the new weak link calculation resulted in two of the eight auxiliary feedwater outside containment isolation valves (one in each unit) having a torque switch setting that exceeded the weak link calculated set point in the close direction. The weak link for these valves is the valve seat. Valve thrust plus system pressure exceeding the valve seat strength could result in thrusting the valve disc into the seat and failure of the valve.


The licensee subsequently provided the following justification for the operability of the valves using the 1324 psid accident pressure. "From a review of all accidents that result in an increase in Steam Generator pressures also result in the starting of the auxiliary feedwater pumps. The auxiliary feedwater system water supply has a design temperature range of 32°F to 120°F. Single failure criteria states that one of the auxiliary feedwater pumps may not start, however it is NOT creditable for a pump to not start and to have sufficient back leakage to raise the temperature of the outside containment isolation valve to 200°F at the same time. Therefore, the maximum abnormal temperature is 170°F.The licensee determined that the weak link calculation at 1324 psid and 170°F results in adequate margin between current thrust settings of all eight auxiliary feedwater outside containment isolation valves and the calculated weak link stresses of the valve seats to assure operability under accident conditions.
The licensee subsequently provided the following justification for the operability of the valves using the 1324 psid accident pressure. From a review of all accidents that result in an increase in Steam Generator pressures also result in the starting of the auxiliary feedwater pumps. The auxiliary feedwater system water supply has a design temperature range of 32°F to 120°F. Single failure criteria states that one of the auxiliary feedwater pumps may not start, however it is NOT creditable for a pump to not start and to have sufficient back leakage to raise the temperature of the outside containment isolation valve to 200°F at the same time. Therefore, the maximum abnormal temperature is 170°F.
 
The licensee determined that the weak link calculation at 1324 psid and 170°F results in adequate margin between current thrust settings of all eight auxiliary feedwater outside containment isolation valves and the calculated weak link stresses of the valve seats to assure operability under accident conditions.


=====Analysis.=====
=====Analysis.=====
The failure to use a conservative design input in the engineering analysis was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not represent a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.
The failure to use a conservative design input in the engineering analysis was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not represent a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.


- 13 -Enforcement. Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, "Design Control," states, in part, that measures shall be established to assure that design basis are correctly translated into specifications and procedures. Contrary to the above, in Calculation MC-145, the licensee did not use a conservative pressure input necessary to prevent damage to auxiliary feedwater outside containment isolation valves during a design basis event. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15455), it is being treated as a noncited viola tion consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-03, Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves.
=====Enforcement.=====
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, "Design Control," states, in part, that measures shall be established to assure that design basis are correctly translated into specifications and procedures. Contrary to the above, in Calculation MC-145, the licensee did not use a conservative pressure input necessary to prevent damage to auxiliary feedwater outside containment isolation valves during a design basis event. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15455), it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-03, Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves.


b.4. Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus  
b.4. Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus


=====Introduction.=====
=====Introduction.=====
The team identified a Green noncite d violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, for the licensee's failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable.
The team identified a Green noncited violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, for the licensees failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable.


=====Description.=====
=====Description.=====
Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires "Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval.The team requested to review the strip chart data recorded from the surveillance tests that demonstrated this surveillance requirement had been performed satisfactorily. Licensee personnel recognized, however, that the actual loading times referenced in the surveillance requirement had not been included in the measurements. Procedure 0PSP02-SF-001A, "ESF Diesel Sequencer Timing Test Train A," Revision 11 (Trains B and C similar), only tests the time that the sequence timer demands breaker closure and does not measure and/or record the actual load times.
Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval. The team requested to review the strip chart data recorded from the surveillance tests that demonstrated this surveillance requirement had been performed satisfactorily. Licensee personnel recognized, however, that the actual loading times referenced in the surveillance requirement had not been included in the measurements. Procedure 0PSP02-SF-001A, ESF Diesel Sequencer Timing Test Train A, Revision 11 (Trains B and C similar), only tests the time that the sequence timer demands breaker closure and does not measure and/or record the actual load times.


The licensee entered Technical Specification 4.0.3 for all three trains of standby diesel generators for both units, allowing 24 hours to fully perform the surveillances successfully. By reviewing the strip chart recorder data for the last loss-of-offsite power and loss-of-offsite power with emergency safety features actuation testing of the standby diesel generators, the licensee verified Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was successfully met for Standby Diesel Generators 11, 21, and 22. In the case of Standby Diesel Generators 13 and 23, the recorded information had a time resolution loss due to switching of recording speeds during the test. The licensee performed a risk evaluation to delay the complete performance of the surveillance test until the next scheduled time (the next outage scheduled for Spring 2008). The team reviewed this assessment and agreed with its conclusions since the data that was available fully supported the equipment being able to perform its safety function.
The licensee entered Technical Specification 4.0.3 for all three trains of standby diesel generators for both units, allowing 24 hours to fully perform the surveillances successfully. By reviewing the strip chart recorder data for the last loss-of-offsite power and loss-of-offsite power with emergency safety features actuation testing of the standby diesel generators, the licensee verified Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was successfully met for Standby Diesel Generators 11, 21, and 22. In the case of Standby Diesel Generators 13 and 23, the recorded information had a time resolution loss due to switching of recording speeds during the test. The licensee performed a risk evaluation to delay the complete performance of the surveillance test until the next scheduled time (the next outage scheduled for Spring 2008). The team reviewed this assessment and agreed with its conclusions since the data that was available fully supported the equipment being able to perform its safety function.


- 14 -However, for Standby Diesel Generator 12, a review of the strip chart data revealed that Essential Chiller 12B had loaded on the bus at 168 seconds versus the design interval of 270 seconds. This condition had not been discovered in prior surveillance testing because Procedure 0PSP02-SF-001A did not contain instructions to verify the timing of relays outside of the sequence timer itself.
However, for Standby Diesel Generator 12, a review of the strip chart data revealed that Essential Chiller 12B had loaded on the bus at 168 seconds versus the design interval of 270 seconds. This condition had not been discovered in prior surveillance testing because Procedure 0PSP02-SF-001A did not contain instructions to verify the timing of relays outside of the sequence timer itself. The licensee declared Standby Diesel Generator 12 inoperable at 09:45 on October 5, 2007, entering Technical Specification 3.8.1.1, Actions B and D.


The licensee declared Standby Diesel Generator 12 inoperable at 09:45 on October 5, 2007, entering Technical Specification 3.8.1.1, Actions B and D.
The cause of the timing discrepancy was isolated to a 35 second blocking circuit external to the chiller that would not prevent the chiller from performing its design safety function. As such, the safety functions of the sequence timer, the standby diesel generator, and Essential Chiller 12B were not adversely affected by the condition, nor would those safety functions be impacted by starting/loading times of the essential chillers between 65 and 270 seconds. The licensee revised the design documents referencing the loading time of the essential chillers to be between 65 and 270 seconds.


The cause of the timing discrepancy was isolated to a 35 second blocking circuit external to the chiller that would not prevent the chiller from performing its design safety function. As such, the safety functions of the sequence timer, the standby diesel generator, and Essential Chiller 12B were not adversely affected by the condition, nor would those safety functions be impacted by starting/loading times of the essential chillers between 65 and 270 seconds. The licensee revised the design documents referencing the loading time of the essential chillers to be between 65 and 270 seconds. Once completed, the surveillance testing was declared successful, and the licensee declared Standby Diesel Generator 12 operable at 18:25 on October 11, 2007. This issue was entered into the licensee's corrective action program as Condition Records 07-14903 and 07-14959.
Once completed, the surveillance testing was declared successful, and the licensee declared Standby Diesel Generator 12 operable at 18:25 on October 11, 2007. This issue was entered into the licensees corrective action program as Condition Records 07-14903 and 07-14959.


=====Analysis.=====
=====Analysis.=====
The team determined that the failure to adequately perform Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not fully performing the required surveillances increases the likelihood that the standby diesel generators and supported equipment would not perform their design safety functions when needed. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because the finding did not represent a loss of safety function of the sequence timer, standby diesel generator, or the essential chiller. This finding was reviewed for crosscutting aspects and none were identified.
The team determined that the failure to adequately perform Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was a performance deficiency.
 
The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not fully performing the required surveillances increases the likelihood that the standby diesel generators and supported equipment would not perform their design safety functions when needed.
 
Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the finding did not represent a loss of safety function of the sequence timer, standby diesel generator, or the essential chiller. This finding was reviewed for crosscutting aspects and none were identified.


=====Enforcement.=====
=====Enforcement.=====
Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires "Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval.Contrary to the above, the licensee failed to verify the actual loading times of the sequenced loads. Specifically, the licensee only verified the time that the sequence timer demands breaker closure and did not perform the "verified to be loaded" requirement. Because the violation was of very low safety significance and has been entered into the licensee's corrective action program as  
Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval. Contrary to the above, the licensee failed to verify the actual loading times of the sequenced loads. Specifically, the licensee only verified the time that the sequence timer demands breaker closure and did not perform the verified to be loaded requirement. Because the violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Records 07-14903 and 07-14959, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498;


Condition Records 07-14903 and 07-14959, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 
499/2007007-04, Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus.
- 15 -499/2007007-04, Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus.


b.5. Inadequate Test Program for 125V DC Molded Case Circuit Breakers  
b.5. Inadequate Test Program for 125V DC Molded Case Circuit Breakers


=====Introduction.=====
=====Introduction.=====
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," for the failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service. Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation.
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service. Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation.


=====Description.=====
=====Description.=====
During the review of surveillance tests for the Auxiliary Feedwater Motor-Operated Valve 0019, the team discovered that the molded case circuit breaker had not been exercised or subjected to testing since the initial plant operation. In addition, further inspection discovered that the majority of 125V dc-fed molded case circuit breakers were also not exercised or subjected to periodic testing since installation in 1986. The types of molded case circuit breakers undergoing any type of preventative testing/maintenance included battery chargers, distribution panels, and inverters since they were infrequently cycled by other maintenance activities. Conversely, the breakers that fed loads to standby diesel generator field flash, reactor trip switchgear, 4.16kV switchgear control power and emergency safety feature load sequencers appeared to have not been tested since it was assumed that they were cycled in other maintenance activities.
During the review of surveillance tests for the Auxiliary Feedwater Motor-Operated Valve 0019, the team discovered that the molded case circuit breaker had not been exercised or subjected to testing since the initial plant operation. In addition, further inspection discovered that the majority of 125V dc-fed molded case circuit breakers were also not exercised or subjected to periodic testing since installation in 1986. The types of molded case circuit breakers undergoing any type of preventative testing/maintenance included battery chargers, distribution panels, and inverters since they were infrequently cycled by other maintenance activities. Conversely, the breakers that fed loads to standby diesel generator field flash, reactor trip switchgear, 4.16kV switchgear control power and emergency safety feature load sequencers appeared to have not been tested since it was assumed that they were cycled in other maintenance activities.


The team noted that the licensee performed tests on molded case circuit breakers to satisfy Information Notice IEN 93-64 and ensure that molded case circuit breakers installed remained functional during plant operations. Following the test was an engineering evaluation acknowledging that molded case circuit breakers were subject to potential age-related degradation, which could result in a failure to trip in accordance with the published time-current characteristic curves because of various factors, such as grease hardening. In 2001, the licensee decided that the sample size for the dc-fed loads  
The team noted that the licensee performed tests on molded case circuit breakers to satisfy Information Notice IEN 93-64 and ensure that molded case circuit breakers installed remained functional during plant operations. Following the test was an engineering evaluation acknowledging that molded case circuit breakers were subject to potential age-related degradation, which could result in a failure to trip in accordance with the published time-current characteristic curves because of various factors, such as grease hardening. In 2001, the licensee decided that the sample size for the dc-fed loads indicated that limited failures in the test population did not warrant a pre-established test program. Essentially, credit was taken for circuit breakers being cycled as a part of other maintenance programs, but it was realized that these tests performed on breakers, failed to actually cycle the breaker. In fact the handswitch was used to open and close the valve.


indicated that limited failures in the test population did not warrant a pre-established test program. Essentially, credit was taken for circuit breakers being cycled as a part of other maintenance programs, but it was realized that these tests performed on breakers, failed to actually cycle the breaker. In fact the handswitch was used to open and close the valve.
Updated Final Safety Analysis Report, Section 8.3.2.1.4, provides for Periodic testing Class 1E dc power system equipment is performed in accordance with Regulatory Guide 1.32 to verify its ability to perform its safety function. Information Notice 93-64, Periodic Testing and Preventative Maintenance of Molded Case Circuit Breakers, stated, "Detecting or assessing degradation could only be accomplished through appropriate periodic testing and monitoring." The team found that the licensees evaluation and approach to the industry experience, design life, potential common mode failures, and component age concerns were not addressed in the test program. The licensee entered this finding into their corrective action program as Condition Record 07-15817.
 
- 16 -Updated Final Safety Analysis Report, Section 8.3.2.1.4, provides for "Periodic testing Class 1E dc power system equipment is performed in accordance with Regulatory Guide 1.32 to verify its ability to perform its safety function.Information Notice 93-64, "Periodic Testing and Preventative Maintenance of Molded Case Circuit Breakers,"
stated, "Detecting or assessing degradation could only be accomplished through appropriate periodic testing and monitoring." The team found that the licensee's evaluation and approach to the industry experience, design life, potential common mode failures, and component age concerns were not addressed in the test program. The licensee entered this finding into their corrective action program as Condition Record 07-15817.


=====Analysis.=====
=====Analysis.=====
The team determined that the lack of periodic testing on all of the dc molded case circuit breakers was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance.It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations,"
The team determined that the lack of periodic testing on all of the dc molded case circuit breakers was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance. It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or train. This finding was reviewed for crosscutting aspects and none were identified.
Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or train. This finding was reviewed for crosscutting aspects and none were identified.


=====Enforcement.=====
=====Enforcement.=====
Part 50 of Title 10 of the Code of Federal Regulations
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion XI, "Test Control," stated, in part, that test programs shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service. Contrary to the above, the licensee failed to implement a test program to assure all installed safety-related molded case circuit breakers will perform satisfactorily in service. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15817, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-05, Inadequate Test Program for 125V DC Molded Case Circuit Breakers.
, Appendix B, Criterion XI, "Test Control," stated, in part, that test programs shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service. Contrary to the above, the licensee failed to implement a test program to assure all installed safety-related molded case circuit breakers will perform satisfactorily in service. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15817, it is being treated as a noncited violati on consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-05, Inadequate Test Program for 125V DC Molded Case Circuit Breakers.


b.6. Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Surveillance Requirement 4.5.2.f)  
b.6. Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Surveillance Requirement 4.5.2.f)


=====Introduction.=====
=====Introduction.=====
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the failure to adequately translate design basis information into specifications and procedures. Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values during periodic technical specification surveillance testing.
The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the failure to adequately translate design basis information into specifications and procedures. Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values during periodic technical specification surveillance testing.


- 17 -Description. Technical Specification Limiting Condition for Operation 3.5.2, Surveillance Requirement 4.5.2.f.1 for the high head safety injection pump, and Surveillance Requirement 4.5.2.f.2 for the low head safety injection pump require:
=====Description.=====
Technical Specification Limiting Condition for Operation 3.5.2, Surveillance Requirement 4.5.2.f.1 for the high head safety injection pump, and Surveillance Requirement 4.5.2.f.2 for the low head safety injection pump require:
For the High Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 1480 psid.
For the High Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 1480 psid.


For the Low Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 286 psid.
For the Low Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 286 psid.


Upon review of Surveillance Procedures 0PSP03-SI-0001 and 0PSP03-SI-0004, the team identified that the pump developed head acceptance criteria in the procedures did not include consideration of measurement instrument uncertainties and were numerically equal to the technical specification values. As a result, there was no documented assurance that the recorded current and historical surveillance test results would demonstrate pump developed heads above the required minimum technical specification requirements when measurement instrument uncertainties were taken into consideration. Therefore, the technical specification surveillance test acceptance criteria were non-conservative.
Upon review of Surveillance Procedures 0PSP03-SI-0001 and 0PSP03-SI-0004, the team identified that the pump developed head acceptance criteria in the procedures did not include consideration of measurement instrument uncertainties and were numerically equal to the technical specification values. As a result, there was no documented assurance that the recorded current and historical surveillance test results would demonstrate pump developed heads above the required minimum technical specification requirements when measurement instrument uncertainties were taken into consideration.


The team reviewed Design Basis Document 5Z529ZB01025, "Technical Specification/ Limiting Conditions for Operation Design Basis Document," Revision 2, and determined that it had erroneously stated for both high-head safety injection pumps and low-head safety injection pumps that "This value is a conservative, nominal value and needs no additional instrument uncertainty margin. This value is acceptable for use. This value is only used in this application (Technical Specifications 4.5.2.f.1 and Technical Specification 4.5.2.f.2)."
Therefore, the technical specification surveillance test acceptance criteria were non-conservative.


The licensee issued Condition Record 07-15752. The condition record stated that "The pump test procedures currently use the technical specification values as the low limit for operability and should be revised. The most recent performance of all safety injection pumps meets the "upward adjusted" low limits."
The team reviewed Design Basis Document 5Z529ZB01025, "Technical Specification/
Limiting Conditions for Operation Design Basis Document," Revision 2, and determined that it had erroneously stated for both high-head safety injection pumps and low-head safety injection pumps that This value is a conservative, nominal value and needs no additional instrument uncertainty margin. This value is acceptable for use. This value is only used in this application (Technical Specifications 4.5.2.f.1 and Technical Specification 4.5.2.f.2).
 
The licensee issued Condition Record 07-15752. The condition record stated that The pump test procedures currently use the technical specification values as the low limit for operability and should be revised. The most recent performance of all safety injection pumps meets the upward adjusted low limits.


=====Analysis.=====
=====Analysis.=====
The failure to include consideration of measurement instrument uncertainties, in relation to the instrumentation utilized in periodic surveillance tests to measure the pump developed head, into the technical specification surveillance test acceptance criteria was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Pow er Situations," Phase 1 screening, the finding screened as having very low safety significance (Green) because it
The failure to include consideration of measurement instrument uncertainties, in relation to the instrumentation utilized in periodic surveillance tests to measure the pump developed head, into the technical specification surveillance test acceptance criteria was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it
- 18 -did not represent a loss of safety system function. This finding was reviewed for crosscutting aspects and none were identified.
 
did not represent a loss of safety system function. This finding was reviewed for crosscutting aspects and none were identified.


=====Enforcement.=====
=====Enforcement.=====
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, states, in part, that measures shall be established to assure that design bases are correctly translated into specifications and procedures. Contrary to the above, the licensee did not conservatively account for the effect of instrument uncertainty in development of acceptance criteria for the technical specification surveillance values for Technical Specification Limiting Condition for Operation 3.5.2. Thus, the minimum allowed high head safety injection and low head safety injection pump developed head had not been definitively demonstrated during surveillance testing to exceed the minimum Technical Specification limiting condition for operation values. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15752, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-06, Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Specifically Surveillance Requirement 4.5.2.f).
Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, states, in part, that measures shall be established to assure that design bases are correctly translated into specifications and procedures. Contrary to the above, the licensee did not conservatively account for the effect of instrument uncertainty in development of acceptance criteria for the technical specification surveillance values for Technical Specification Limiting Condition for Operation 3.5.2. Thus, the minimum allowed high head safety injection and low head safety injection pump developed head had not been definitively demonstrated during surveillance testing to exceed the minimum Technical Specification limiting condition for operation values. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15752, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-06, Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Specifically Surveillance Requirement 4.5.2.f).


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
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==4OA5 Other Activities==
==4OA5 Other Activities==


a.1 Unresolved Item Associated with the Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment  
a.1 Unresolved Item Associated with the Effect of Standby Diesel Generator Technical     Specification Voltage Variation on Supplied Equipment


=====Introduction.=====
=====Introduction.=====
Line 419: Line 351:


=====Description.=====
=====Description.=====
The design analysis assumed maximum supplied voltage variations based upon offsite power supplies which were analyzed to vary less than the technical specification allowed steady state variation for the standby diesel generators. Components throughout the plant would be adversely affected by either an undervoltage or overvoltage condition.
The design analysis assumed maximum supplied voltage variations based upon offsite power supplies which were analyzed to vary less than the technical specification allowed steady state variation for the standby diesel generators.
 
Components throughout the plant would be adversely affected by either an undervoltage or overvoltage condition.


Since this is a very broad issue that encompasses components powered from the standby diesel generator during a design basis event, the licensee will require significant time to evaluate its effects. Although available safety margins will be less, the degree of this effect is not yet known since the effect of the variation varies upon the analyzed parameter and currently analyzed margins vary significantly. The actual safety function of equipment is not expected to be compromised since the standby diesel generators are presently controlled to a tighter band of voltage operation than allowed by technical specifications and review of the surveillance testing of the standby diesel generators confirms this tighter band is currently being maintained.
Since this is a very broad issue that encompasses components powered from the standby diesel generator during a design basis event, the licensee will require significant time to evaluate its effects. Although available safety margins will be less, the degree of this effect is not yet known since the effect of the variation varies upon the analyzed parameter and currently analyzed margins vary significantly. The actual safety function of equipment is not expected to be compromised since the standby diesel generators are presently controlled to a tighter band of voltage operation than allowed by technical specifications and review of the surveillance testing of the standby diesel generators confirms this tighter band is currently being maintained.


- 19 - Once the licensee has evaluated the effect of the allowed steady state voltage variation and determined the degree of safety margin impact throughout the plant, the NRC can complete the inspection of that analysis in order to close this issue. The licensee has  
Once the licensee has evaluated the effect of the allowed steady state voltage variation and determined the degree of safety margin impact throughout the plant, the NRC can complete the inspection of that analysis in order to close this issue. The licensee has documented this issue in Condition Record 07-15554 and the item is unresolved pending the licensees completion of its analysis and NRC review: URI05000498; 499/2007007-07, Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment.


documented this issue in Condition Record 07-15554 and the item is unresolved pending the licensee's completion of its analysis and NRC review: URI05000498; 499/2007007-07, Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment.
a.2 Unresolved Item Involving Combined Adverse Conditions not considered in Fuel Oil Storage Tank Sizing
 
a.2 Unresolved Item Involving Combined Adverse Conditions not considered in Fuel Oil Storage Tank Sizing  


=====Introduction.=====
=====Introduction.=====
Line 433: Line 365:


=====Description.=====
=====Description.=====
Calculation MC-6256, "Sizing of Standby Diesel Generator Fuel Oil Storage Tank," Revision 4, determined a total 7-day fuel oil requirement of 51,500 gallons, comparing this value with a technical specification requirement of 60,500 gallons. However, this calculation did not consider the effects of vortexing or generator frequency variations. Condition Record 97-14434-10 included an evaluation of fuel oil vortexing completed as part of a "Review of Safety Related Tanks (other than Refueling Water Storage Tank & Auxiliary Feedwater Storage Tank) for Vortexing Concerns."  Separately, Calculation EC-5100, Standby Generator Transient Response Model," Revision 2, contained an evaluation performed under Condition Record 97-13089-1 in order to "Perform Evaluation of Electrical Frequency Variations on Mechanical Fluid Systems."
Calculation MC-6256, Sizing of Standby Diesel Generator Fuel Oil Storage Tank, Revision 4, determined a total 7-day fuel oil requirement of 51,500 gallons, comparing this value with a technical specification requirement of 60,500 gallons. However, this calculation did not consider the effects of vortexing or generator frequency variations. Condition Record 97-14434-10 included an evaluation of fuel oil vortexing completed as part of a Review of Safety Related Tanks (other than Refueling Water Storage Tank & Auxiliary Feedwater Storage Tank) for Vortexing Concerns.


The vortexing evaluation determined that 13.5 inches of fuel oil volume would be susceptible to excessive air entrainment, representing 4120 gallons of unusable fuel oil with a 7-day fuel oil requirement of 55,360 gallons (referencing Calculation MC-6038, "Standby Diesel Generator Fuel Oil Storage Tank Level Setting Calculation."  The total required volume would therefore be 59,480 gallons.
Separately, Calculation EC-5100, Standby Generator Transient Response Model, Revision 2, contained an evaluation performed under Condition Record 97-13089-1 in order to Perform Evaluation of Electrical Frequency Variations on Mechanical Fluid Systems.


The frequency effects evaluation determined that "Standby Diesel Generator load would increase by roughly 6% because the majority of load consists of pumps and fans with primarily friction system loads.The evaluation then compared this 6 percent increase in load with the standby diesel generator fuel oil storage tank calculated margin of more than 10 percent.
The vortexing evaluation determined that 13.5 inches of fuel oil volume would be susceptible to excessive air entrainment, representing 4120 gallons of unusable fuel oil with a 7-day fuel oil requirement of 55,360 gallons (referencing Calculation MC-6038, Standby Diesel Generator Fuel Oil Storage Tank Level Setting Calculation. The total required volume would therefore be 59,480 gallons.
 
The frequency effects evaluation determined that Standby Diesel Generator load would increase by roughly 6% because the majority of load consists of pumps and fans with primarily friction system loads. The evaluation then compared this 6 percent increase in load with the standby diesel generator fuel oil storage tank calculated margin of more than 10 percent.


However, the vortexing evaluation had already effectively reduced the majority of the analyzed margin with a remaining 1020 gallons of fuel oil between 59,480 gallons and the technical specification requirement of 60,500 gallons. Therefore, applying a 6 percent increase in standby diesel generator load in addition to considering vortexing effects would have exceeded the technical specification requirement under those analyzed conditions.
However, the vortexing evaluation had already effectively reduced the majority of the analyzed margin with a remaining 1020 gallons of fuel oil between 59,480 gallons and the technical specification requirement of 60,500 gallons. Therefore, applying a 6 percent increase in standby diesel generator load in addition to considering vortexing effects would have exceeded the technical specification requirement under those analyzed conditions.


- 20 - In addition, the most recent fuel oil storage tank sizing calculation determined a 7 day fuel oil requirement of 51,500 gallons. As discussed in the finding "Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation," this requirement neglected manual loads during the 7 days for which provision would be made to use during a design basis event. A bounding analysis considering the actual anticipated manual loads, in addition to the vortexing reduction and increased load frequency effect, exceeds the minimum technical specification requirement.
In addition, the most recent fuel oil storage tank sizing calculation determined a 7 day fuel oil requirement of 51,500 gallons. As discussed in the finding Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation, this requirement neglected manual loads during the 7 days for which provision would be made to use during a design basis event. A bounding analysis considering the actual anticipated manual loads, in addition to the vortexing reduction and increased load frequency effect, exceeds the minimum technical specification requirement.


The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high-head safety injection, and containment spray pumps would be run continuously for 48 hours following a large break loss-of-coolant accident. The licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensee's corrective action program as Condition Request 07-14398 and 07-15592.
The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high-head safety injection, and containment spray pumps would be run continuously for 48 hours following a large break loss-of-coolant accident. The licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensees corrective action program as Condition Request 07-14398 and 07-15592.


After further discussions with staff from the NRC Office of Nuclear Reactor Regulation, the team concluded that this issue of failure to account for the combined effect of vortexing and standby diesel generator frequency variation in the fuel oil storage tank sizing would remain open as an unresolved item. Additional NRC staff review was necessary to determine whether the issue was acceptable, whether it was a finding, or whether it constituted a deviation or violation. Pending completion of this review, this item is unresolved: URI 05000498; 499/2007007-08, Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing.
After further discussions with staff from the NRC Office of Nuclear Reactor Regulation, the team concluded that this issue of failure to account for the combined effect of vortexing and standby diesel generator frequency variation in the fuel oil storage tank sizing would remain open as an unresolved item. Additional NRC staff review was necessary to determine whether the issue was acceptable, whether it was a finding, or whether it constituted a deviation or violation. Pending completion of this review, this item is unresolved: URI 05000498; 499/2007007-08, Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing.
Line 450: Line 384:
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==


On October 26, 2007, the team leader presented the preliminary inspection results to Mr. E. Halpin, Site Vice President, and other members of the South Texas Project staff. After additional offsite and onsite inspection a preliminary exit meeting was conducted on November 26, 2007, with Mr. J.
On October 26, 2007, the team leader presented the preliminary inspection results to Mr. E. Halpin, Site Vice President, and other members of the South Texas Project staff.
 
Sheppard, President and Chief Executive officer and other members of the licensee's staff. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The licensee acknowledged the findings during each meeting. While some proprietary information was reviewed during this inspection, no proprietary information was included in this report.


A-1
After additional offsite and onsite inspection a preliminary exit meeting was conducted on November 26, 2007, with Mr. J. Sheppard, President and Chief Executive officer and other members of the licensees staff. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The licensee acknowledged the findings during each meeting. While some proprietary information was reviewed during this inspection, no proprietary information was included in this report.


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 461: Line 393:


===Licensee personnel===
===Licensee personnel===
: [[contact::C. Bowman]], General Manager Oversight  
: [[contact::C. Bowman]], General Manager Oversight
: [[contact::K. Coats]], Plant General Manager  
: [[contact::K. Coats]], Plant General Manager
: [[contact::R. Engen]], Manager, Maintenance Engineering  
: [[contact::R. Engen]], Manager, Maintenance Engineering
: [[contact::E. Halpin]], Site Vice President  
: [[contact::E. Halpin]], Site Vice President
: [[contact::S. Head]], Manager, Licensing  
: [[contact::S. Head]], Manager, Licensing
: [[contact::K. House]], Manager, Design Engineering  
: [[contact::K. House]], Manager, Design Engineering
: [[contact::B. Jenewein]], Manager, Testing/Programs Engineering  
: [[contact::B. Jenewein]], Manager, Testing/Programs Engineering
: [[contact::R. Lovell]], Manager, Industrial Alliances  
: [[contact::R. Lovell]], Manager, Industrial Alliances
: [[contact::M. Meier]], General manager Station Support  
: [[contact::M. Meier]], General manager Station Support
: [[contact::J. Mertink]], Manager, Operations  
: [[contact::J. Mertink]], Manager, Operations
: [[contact::M. Murray]], Manager, Systems Engineering  
: [[contact::M. Murray]], Manager, Systems Engineering
: [[contact::G. Powell]], Manager, Site Engineering  
: [[contact::G. Powell]], Manager, Site Engineering
: [[contact::D. Rencurrel]], Vise President, Engineering  
: [[contact::D. Rencurrel]], Vise President, Engineering
: [[contact::M. Ruvalcaba]], Supervisor, Engineering  
: [[contact::M. Ruvalcaba]], Supervisor, Engineering
: [[contact::J. Sheppard]], President and Chief Executive Officer  
: [[contact::J. Sheppard]], President and Chief Executive Officer
: [[contact::D. Towler]], Manager, Quality  
: [[contact::D. Towler]], Manager, Quality
 
===NRC personnel===
===NRC personnel===
: [[contact::W. Jones]], Chief, Engineering Branch 1  
: [[contact::W. Jones]], Chief, Engineering Branch 1
: [[contact::J. Dixon]], Senior Resident Inspector  
: [[contact::J. Dixon]], Senior Resident Inspector


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Line 486: Line 417:
===Opened===
===Opened===


URI05000498; 499/2007007-07 URI Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied  
URI05000498; 499/2007007-07         URI   Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment URI05000498; 499/2007007-08         URI   Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing
 
Equipment URI05000498; 499/2007007-08 URI Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing  


===Opened and Closed===
===Opened and Closed===


NCV05000498; 499/2007007-01 NC
NCV05000498; 499/2007007-01         NC   Failure to Specify Setpoint Calibration Limits in V    Relay Setpoint Calculations NCV05000498; 499/2007007-02         NC   Manual Loads not Considered for Fuel Oil Storage V    Tank Sizing Calculation Attachment
V Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations  
 
NCV05000498; 499/2007007-02 NC
V Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation
 
NCV05000498; 499/2007007-03 NC
V Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary
Feedwater System Outside Containment Isolation
Motor Operated Valves
 
NCV05000498; 499/2007007-04 NC
V Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus
 
NCV05000498; 499/2007007-05 NC
V Inadequate Test Program for 125V DC Molded Case Circuit Breakers


NCV05000498; 499/2007007-06 NC
NCV05000498; 499/2007007-03    NC    Failure to Use Correct Design Inputs in V      Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves NCV05000498; 499/2007007-04    NC    Surveillance Procedure Lacked Check for Timing of V      Chiller Loading on the Bus NCV05000498; 499/2007007-05    NC    Inadequate Test Program for 125V DC Molded Case V      Circuit Breakers NCV05000498; 499/2007007-06   NC     Failure to Incorporate Instrument Uncertainties into V      Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Specifically Surveillance Requirement 4.5.2.f)
V Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical
Specification Limiting Condition for Operation 3.5.2  
(Specifically Surveillance Requirement 4.5.2.f)  


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
===Calculations===
: Number Title Revision/Date
: MC-5694 Auxiliary Feedwater System Failure Modes and Effects Analysis 3
: EC-5008 Class 1E Battery, Battery Charger and Inverter Sizing 13
: EC-5100 Standby Diesel Generator Transient Response Model 2
: MC-6213
: GNL 89-10 Calc for MOV 1AF0019 6
: ZC-7038 Loop Uncertainty Calcul ation for QDPS Cabinet Temperature Instrumentation
: EC-5001 Fault Analysis 6
: MC-6462 DVAC Calculation for DC Motor MOVs 0
: EC-5031 480 Volt Load Centers 7
: EC-5018 Short Circuit Current Analysis - Class 1E 125 VDC and Non-Class 1E 250, 125, and 48 VDC Systems
: EC-5003-02 Cable Ampacity in Underground Ducts 8
: EC-5037 Maximum Allowable Length of AC Power Cables 4
: EC-5033 Protection Non 1E 48 VDC, 125 VDC & 250 VDC and Class
: IE 125 VDC Systems
: EC-5004 Cable Ampacity
: 7 3Q159MC6038 SDBY DG FOST Level Setting Calculation 2 5Q159MC5912 NPSH on the Fuel Oil Transfer Pump
===Calculations===
: Number Title Revision/Date
: EC-5008 Class 1E Battery, Battery Charger and Inverter Sizing 13
: EC-5033 Protection Non 1E 48 VDC, 125 VDC & 250 VDC and Class 1E 125 VDC Systems
: EC-5018 Short Circuit Current Analysis - Class 1E 125 VDC and Non-Class 1E 250, 125 and 48 VDC Systems
: EC-5100 Standby Diesel Generator Transient Response Model 2
: MC-5037 RWST Volumes & Limits 9
: MC-6256 Sizing of SDG FOST 4
: MDCN 89219-75 Protection - DC System (CB & RLY Settings) 01/15/97
: ZC-7029 Loop Uncertainty Calculation for Standby Diesel Generator Fuel Oil Storage Tank Level Monitoring Instrumentation
: EC-5000 Voltage Regulation Study 12
: EC-5003-6 Cable Ampacity in Underground Ducts-Data Sheets 11
: EC-5004 Cable Ampacities 7
: EC-5014 Maximum Length of Control Cables 4
: EC-5022 Transformer Neutral Grounding Resistor sizing 2
: EC-5020 Main Transformer Sizing Calculation 3
: EC-5024 Diesel Generator Neutral Grounding 2
: EC-5028 Protection 13.8 KV Switchgear 9
: EC-5029 4.16 KV Switchgear Relay Setting 5
: EC-5030 Class 1E Diesel Generation Protection 1
: EC-5034 Standby Transformer Protection 3
: EC-5036 DC Cable Sizing 7
: EC-5039 Control Cable Size Verification 0
: EC-5052 Degraded and Undervoltage Protection 6
: CC-06425 1997 Emergency Cooling Pond Sediment Calculation 0
: CC-09959 2002 Emergency Cooling Pond Sediment Calculation 0 FRSS/CWBS-C-121 TGX Minimum and Maximum Safeguards 07/13/87
: MC-5430 Emergency Cooling Water Intake Structure Cooling and Heating Loads
: MC-05860 Containment Emergency Sump Performance 1
: MC-6220 SI & CS Pump NPSH 4
: MC-6251 Essential Cooling Water Transient Analysis 0
: MC-6412 Essential Chilled Water Load 1
: MC-06482 Essential Chilled Water / EAB HVAC Design Basis Loads with Capacity of 300 Tons per Train
: PFD-FTE-285 Standard Single and Twin Units - 4XL Model Fluid Systems Process Flow Diagrams and Piping Design
: Requirements
: V-EC-1330 Motor Operated Valve (MOV) Evaluation (A2SIMOV0031A)
: ZC-7024 Loop Uncertainty Calculation for RWST Level 2
===Calculations===
: Number Title Revision/Date Monitoring Instrumentation 2N129MC5519 Pressure Drop Evaluation for the Safety Injection System 0 2N129MC5815 RWST Vacuum Potential 0 2N129MC6091 Minimum Flow Orifices SI System - Low Head - Line 3"SI1302PB2
: 3N129HMC6100 Evaluate Safety Related Pump Miniflows per NRC Bulletin 88-04
: 3R289MC5429 Head Losses Calculation - Essential Cooling Water System 1 3R289MC5633 Essential Cooling Water Pump Submergence 2 3V110MC5234 Expansion Tank Sizing for Essential Chilled Water System 2 5N129MC5519 Pressure Drop Evaluation for the Safety Injection System 0 5R289MC5812 Essential Cooling Water (ECW) Hydraulic Network Analysis (HNA)
: 88-EW-002 ECW Pump Discharge and Suction Pressure 
===Calculations===
: 3Q159MC6038 Standby Diesel Generator Fuel Oil Storage Tank Level Setting Calculation
: 5Q159MC5912 NPSH on the Fuel Oil Transfer Pump 0 3N129HMC6100 Evaluate Safety Related Pump Miniflows 0 3S149MC5051 Auxiliary Feedwater Pump Discharge Pressure 4 3S149MC5861 Auxiliary Feedwater Pump Design TDH (Total Discharge Head), Flow Rate and Pump Runout
: 3S149MC5057 Maximum and Minimum Flow Requirements of the AFW System
: 3L482MC6204 GNL (Generic Letter) 89-10 Calculation for MOVD2AFMOV0019 (Weak Link Analysis)
: DCN
: MC-145 Revision of Mc 6204 to Incorporate Yield Stress Values for Weak Link Calculation at Design Temperatures.
: 7/31/1992
: MC-6163 Penetration Seals for HELBA (High Energy Line Break Analysis) and Flooding
: MC-5557 IVC (Isolation Valve Cubicle) Flood Analysis 8
: ZC-7029 FOST (Fuel Oil Storage Tank) Wide Range Level Indicating Loops, page 7.
: MC-6256 Sizing of Standby Diesel Generator FOST 4
: Condition Records
: 07-14379 07-14383 07-14422 07-14463 07-14520 07-15473
: 07-15752 07-14425 07-14423 07-15418 07-15443 07-3647 
: 07-3745 07-4926 07-5278 07-5465 07-5652 07-7917
: 07-14387 07-14398 07-14663 07-14903 07-14959 07-15449
: 07-15554 07-15592 07-15568 07-15586 07-15801 07-15828
: 07-16309 07-15817 07-15847 07-15702 07-11491 07-11517
: 07-15499 06-16616 06-10937 06-4423 06-16998 05-2442
: 05-15477 05-14112 05-15251 04-5149 04-15477 04-15476
: 04-4428 03-928 03-8824 03-14479 03-9356 01-15847
: 97-14434
===Drawings===
: Number Title Revision/Date 
: 00009E0VAAB#2 Single Line Diagram Vital 120V AC Distribution Panels
: DP 1202,
: DP 1203
: 00009E0PMAK#2 Single Line Diagram Class-IE Motor Control Center E2A4
: EAB 18 00009E0DJAB#2 Single Line Diagram 125 V DC 1E Distribution Switchboard E2D11
: 00009E0AF14#1 E/D AFW Turbine Pump 14
: MOV 0019 11 00009E0PLAB#2 Single Line Diagram, 480 V Class 1E Load Center E2B 12
: 00009E0PKAA#2 Single line Diagram, 4.16KV Class 1E Switchgear E2A 10
: 00009E0EW01#2 Elementary Diagram, Essential Cooling Water Pumps 2A, 2B, & 2C
: 00009E0DJAB#1 Single Line Diagram, 125VDC 1E Distribution Switchboard E1D11
: 00009E0PMAD#2 Single Line Diagram, 480 V Class 1E Motor Control Center 21 00009E0VAAB#1 Single Line Diagram Vital 120V AC Distribution Panels
: DP 1202,
: DP 1203
: 00009E0PMAD#2 Single Line Diagram 480 V Class 1E Motor Control Center E2B1 (EAB)
: 00009E0HE13#2 Elementary Diagram E.A.B. HVAC Return Fans, FN001, FN002 & FN003
: 00009E0HE09#2 Elementary Diagram E.A.B. HVAC Main Supply Air Vent Fans, FN014, FN015, & FN016
: 00009E0AAAB#1 Single Line Diagram Class 1E 125V DC & 120V Vital AC Non-Class 1E 48V, 125V, 250V, DC, & 120V Vital AC Non-Class 1E Inverter Power for Computer
: 208V/120V AC Regulated Power
: 00009E0DJAA#1 Single Line Diagram 125VDC Class 1E Distribution SWBD. E1A11 (Channel I) (E.A.B.)
: 00009E0DJAB#1 Single Line Diagram 125V DC Class 1E Distr. Switchboard E1D11 (Channel II) (EAB)
: 00009E0PMAD#2 Single Line Diagram, 480 V Class 1E Motor Control Center 21 00000E0AAAA Main One Line Diagram for Units No. 1 & 2 (site 19 
: A-6Drawings Number Title Revision/Date
: Electrical Di stribution) 00009E0DJAA#1 Single Line Diagram 125VDC Class 1E Distribution SWBD. E1A11 (Channel I) (E.A.B.)
: 00009E0DJAC#1 Single Line Diagram 125V DC Class 1E Distribution SWBD E1B11 (Channel III) (EAB)
: 00009E0DJAD#1 Single Line Diagram 125V DC Class 1E Distribution SWBD E1C11 (Channel IV) (EAB)
: 00009E0DJAE#1 Single Line Diagram 125V DC Class 1E Distribution Panels PL039A, PL039B, PL039C, PL040A (EAB)
: 00009E-PKAB-01
#2 Single Line Dwg 4.16KV Class 1E Switchgear 9 00009EOPCAB #2 Single Line Dwg 13.8KV Switchgear 2GA 14 00009EOPLAB #2 Single Line Dwg 480V Class 1E Load Center E2B 16
: 00009EOPC21 #2 Elementary Diagram 13.8KV Standby Bus 2G Supply BKR
: ST-260 from #2 Standby XFMR, Sheet1
: 00009EOPC25 #2 Elementary Diagram 13.8KV Standby Bus 2G Supply BKR
: ST-280 from #1 Standby XFMR, Sheet 1
: 00009EOPK03 #2 Elementary Diagram 4.16KV Feeder to 480V Loadcenter Transformer E2A2, E2B2, E2C2, Sheet 1
: 00009EOPK02 #2 Elementary Diagram 4.16KV Feeder to 480V Loadcenter Transformer E2A1, E2B1, E2C1, Sheet 1
: 00009EOPK01 #2 Elementary Diagram 4.16KV ESF Bus E2A, E2B, E2C Supply Breaker Control, Sheet 1
: 00009EODG01 #2 Elementary Diagram Standby Diesel Generator DG22 4.16KV Feeder Breaker, Sheet 3
: 00009EOPC19 #2 Elementary Diagram 13.8KV 2G Aux and Standby Bus Tie BKR T-240, Sheet 1
: 3V119V10002#1 P&ID - HVAC / Essential Chilled Water System 13 3V119V10003#1 P&ID - HVAC / Essential Chilled Water System 18 3V119V10004#1 P&ID - HVAC / Essential Chilled Water System 9 4352-00006JF 125V DC Distribution Switchboard E1D11 G
: 4352-00004JF Class 1E 125 VDC Distribution Switchboard E1D11 BOM F 5Q159F00045#1, Sheet 1 Piping & Instrumentation Diagram Standby Diesel Generator Fuel Oil Storage & Transfer System
: 5Q159F00045#1, Sheet 2 Piping & Instrumentation Diagram Standby Diesel Fuel Oil 10 5Q159F22540#1 Piping & Instrumentation Diagram Standby Diesel Jacket Water 20 5Q159F22541#1 Piping & Instrumentation Diagram Standby Diesel Cooling Water
: 5Q159F22542#1 Piping & Instrumentation Diagram Standby Diesel Lube Oil 19 
: A-7Drawings Number Title Revision/Date 
: 5Q159F22543#1 Piping & Instrumentation Diagram Standby Diesel Air Intake & Exhaust
: 5Q159F22544#1 Piping & Instrumentation Diagram Standby Diesel Starting Systems & Alarms
: 5Q159F22545#1 Piping & Instrumentation Diagram Standby Diesel Shutdown System
: 5Q159F22546#1 Piping & Instrumentation Diagram Standby Diesel Starting Air
: 9-E-DJAF-01#1 Single Line Diagram 125V DC Class 1E Distribution Panels PL139A, PL139B, PL139C (DGB)
: 5R289Z42077#2 Essential Cooling Water Pumps Logic Diagram 13 5R289Z42081#2 ECW Pump Discharge Valves Logic Diagram System: EW 8 5V119Z41572 E.A.B. HVAC Return Fans Logic Diagram 12 5S149Z40136 AFW Turbine Pump Isolation Valve Logic Diagram 9
: 5S142F00024 Piping & Instrumentation Diagram Auxiliary Feedwater 10 5S141F00024 Piping & Instrumentation Diagram Auxiliary Feedwater 11 5S142F00024 Sheet Piping and Instrument Drawing for Auxiliary Feedwater System 10 5S142F00024 Sheet Piping and Instrument Drawing for Auxiliary Feedwater System 10 5G-15-9-P-0053 Composite Piping - Isolation Valves Cubicle Plan at El.
: 34'-0" 3 5N129F05013#1 P&ID - Safety Injection System 27 5N129F05016#1 P&ID - Safety Injection System 14
: 5N169F20000#1 P&ID - Residual Heat Removal System 24
: 5R289F05038#1 P&ID - Essential Cooling Water System - Train A
: 13
: 5R289F05039#1 Sheet 1, P&ID - Essential Cooling Water System 16
: 5V119V10001#1 P&ID - HVAC / Essential Chilled Water System 31 5V119V10001#2 P&ID - HVAC / Essential Chilled Water System 31 5V119V25000#2 P&ID - HVAC / Electrical Auxiliary Building Main Area System 16 5V159V00027#2 P&ID - HVAC Miscellaneous Buildings Essential Cooling Water Intake Structure
: 6P-20-0-M-0031 General Arrangement Drawing - Essential Cooling Water Intake & Discharge Structures
: 8114-01036-WU Vendor Dwg L.V.M.E. "DS" SWGR C 8121-01023-GU Vendor Dwg Indoor Metal-Clad SWGR 5HK B
: 9G069F10006 #2 Piping and Instrumentation Diagram Isolation Valves Cubicles Building Sump Pump & Drains System for oily


waste. 6 9-M-06-9-B-0177 Plumbing Isolation Valve Cubicle Building Floor Plan 2 
: A-8Drawings Number Title Revision/Date
: EL. 34'-0" Area 11 9-M-06-9-B-0175 Plumbing Isolation Valve Cubicle Building Embedment Plan EL. Area 11
: 9EAF14-01#1 Elementary Diagram Aux Feedwater Turbine Pump 14 Isolation
: MOV-0019 
===Procedures===
: Number Title Revision/Date
: 0POP02-AM-0001 ERFDADS Computer 120 VAC
: UPS 13 0POP02-AE-0004 120 VAC ESF Vital Distribution Power Supplies 25 0POP02-AF-0001 Auxiliary Feedwater 24
: 0POP02-HE-0001 Electrical Auxiliary Building HVAC System 26 0POP02-EW-0001 Essential Cooling Water Operations 41 0POP04-HE-0001 Loss of EAB or Control Room HVAC 7 1POP09-AN-03M2 Annunciator Lampbox 1-03M-2 Response Instructions 26 2POP09-AN-03M2 Annunciator Lampbox 2-03M-2 Response Instructions 23 0POP09-AN-22M3 Annunciator Lampbox 22M03 Response Instructions 20 0POP09-AN-02M3 Annunciator Lampbox 2M03 Response Instructions 19 0PGP03-ZE-0073 Molded Case Circuit Breaker Testing Program 2 0PMP05-NA-0004 Molded Case Breaker Test 25
: 0PSP03-HE-0001 Control Room Emergency Ventilation System
: 0PSPS03-AF-0010 Auxiliary Feedwater System Valve Operability Test 21 0PSP03-EW-0017 Essential Cooling Water System Train A Testing 24 0PSP03-AF-0011 Auxiliary Feed Flow Verification 7
: 0PSP03-SP-0019D Turbine Driven Auxiliary Feedwater Actuation and Response Time Test
: 0POP01-ZO-0009 Ground Isolation 0 0POP02-DG-0001 Emergency Diesel Generator 11(21) 42
: 0POP02-DG-0002 Emergency Diesel Generator 12(22) 48
: 0POP02-DG-0003 Emergency Diesel Generator 13(23) 45
: 0POP02-EE-0001 ESF (Class 1E) DC Disctribution System 16 0POP04-AE-0001 First Response to Loss of Any or All 13.8 KV or 4.16 KV Bus 34 0POP04-DJ-0001 Loss of Class 1E 125 VDC Power 20 0POP05-E0-EC00 Loss of All AC Power 18
: 0POP09-AN-0102 Annunciator Lampbox 1(2)-102 Response Instructions 12 0POP09-AN-0104 Annunciator Lampbox 1(2)-104 Response Instructions 12 0POP09-AN-0106 Annunciator Lampbox 1(2)-106 Response Instructions 12 0POP09-AN-02M3 Annunciator Lampbox 2M03 Response Instructions 19 0POP09-AN-03M3 Annunciator Lampbox 3M03 Response Instructions 22 0POP09-AN-22M3 Annunciator Lampbox 22M03 Response Instructions 20 0PSP02-SF-0001A ESF Diesel Sequencer Timing Test Train A 11
===Procedures===
: Number Title Revision/Date
: 0PSP03-DG-0001 Standby Diesel 11(21) Operability Test 33
: 0PSP03-DG-0002 Standby Diesel 12(22) Operability Test 31
: 0PSP03-DG-0003 Standby Diesel 13(23) Operability Test 34
: 0PSP03-DG-0007 Standby Diesel 11(21) LOOP Test 20
: 0PSP03-DG-0008 Standby Diesel 12(22) LOOP Test 18
: 0PSP03-DG-0009 Standby Diesel 13(23) LOOP Test 20
: 0PSP03-DG-0013 Standby Diesel 11(21) LOOP - ESF Actuation Test 20 0PSP03-DG-0014 Standby Diesel 12(22) LOOP - ESF Actuation Test 19 0PSP03-DG-0015 Standby Diesel 13(23) LOOP - ESF Actuation Test 21 0PSP03-ZQ-0028 Operator Logs 98
: 0PSP06-DJ-0001 125 Volt Class 1E Battery 7 Day Surveillance Test 28 0PSP06-DJ-0002 125 Volt Class 1E Battery Quarterly Surveillance Test 19 0PSP06-DJ-0003 125 Volt Class 1E Battery Surveillance Test 13 0PSP06-DJ-0006 Battery Charger 8 Hour Load Verification 19
: 0PSP06-DJ-0007 125 Volt Class 1E Battery Combined Service and Performance Surveillance Test
: 1POP09-AN-03M2 Annunciator Lampbox 1-03M-2 Response Instructions 26 2POP09-AN-03M2 Annunciator Lampbox 2-03M-2 Response Instructions 23
: IP-3.20Q Interdepartmental Procedures 10CFR50.59 Evaluations 4
: 0POP01-ZQ-0022 Plant Operations Shift Routines 52
: 0PSP03-DG-0016 Standby Diesel 11(21) Twenty-Four Hour Load Test 23
: 0PSP06-PK-0001 4.16KV Class 1E Undervoltage Relay Channel Calibration/TADOT-Channel 1
: 0PSP06-PK-0002 4.16KV Class 1E Undervoltage Relay Channel Calibration/TADOT-Channel 2
: 0PSP06-PK-0003 4.16KV Class 1E Undervoltage Relay Channel Calibration/TADOT-Channel 3
: 0PSP06-PK-0004 4.16KV Class 1E Undervoltage Relay Channel Calibration/TADOT-Channel 4
: 0PSP06-PK-005 4.16KV Class 1E Degraded Voltage Relay Calibration/TADOT-Channel 1
: 0PSP06-PK-006 4.16KV Class 1E Degraded Voltage Relay Calibration/TADOT-Channel 2
: 0PSP06-PK-007 4.16KV Class 1E Degraded Voltage Relay Calibration/TADOT-Channel 3
: 0PSP06-PK-008 4.16KV Class 1E Degraded Voltage Relay Calibration/TADOT-Channel 4
: 0P0P02-CH-0005 Essential Chiller Operation 44
: 0P0P03-CH-0001 Essential Chilled Water Pump 11A(21A) Inservice Test 15 0PSP03-EW-0008 Essential Cooling Water Pump 1A(2A) Reference Values Measurement
: 0PSP03-EW-0017 Essential Cooling Water System Train A Testing 24
: 0PSP03-CH-0004 Essential Chilled Water Pump 11A(12A) Reference 7
===Procedures===
: Number Title Revision/Date Values Measurement 0PSP03-SI-0001 Low Head Safety Injection Pump 1A(2A) Inservice Test 13 0PSP03-SI-0004 High Head Safety Injection Pump 1A (2A) Inservice Test 12 0PSP03-SI-0007 Low Head Safety Injection Pump 1A(2A) Reference Values Measurement
: 0PSP03-SI-0010 High Head Safety Injection Pump 1A(2A) Reference Values Measurement
: 0PSP03-SI-0026 High Head Safety Injection Pump Flow Rate Measurement
: 0PSP03-SI-0027 Low Head Safety Injection Pump Flow Rate Measurement
: WAN 127044 Preventive Maintenance 4160V Switchgear E1A CUB 1 0
: WAN 147480 Preventive Maintenance AUX ESF XFMR E1A To 4.16KV ESF BUS E1A
: WAN 177227 PM Inspect Breaker, Unit 2 STBY XFMR TO STBY Bus
: 2G 7
: WAN 220394 PM Inspect Breaker, Unit 2 STBY XFMR To STBY BUS
: 2G 2
: WAN 256076 13.8KV To 4160 VAC ESF Transformer E2B 1
: WAN 257849 480V Load Center E2B 7
: WAN 265895 PM Unit 2 Standby Transformer 1
: WAN 268512 PM Inspect Breaker, To 4.16KV AUX ESF XFMR E2B 8
: WAN 274021 PM Calibrate Relays, To 4.16 KV AUX ESF XFMR E2B 0 
===Miscellaneous Documents===
: Number Title
: Revision/Date
: 4E519EB1108
===Design Basis Document===
: 4.16KV AC Power (PK) System 3 4E53EB1109 Design Basis Document Class 1E AC Power (PL/PM) System 2 4E549EB01110 Design Basis Document, Class 1E Vital 120V AC System 2 4E510EQ1005 Design Criteria Class 1E AC Power Distribution 8 4E520EQ1006 Class 1E 125 Vdc Design Criteria 6 5R289MB1006 Design Basis Document Essential Cooling Water System 5 5S149MB01016 Design Basis Document Auxiliary Feedwater System 5
: 5V119VB01022 Design Basis Document HE/HE (CRE) System 4 5E540EL5031
: Electrical Setpoint Index 3
: STP Interconnection Agreement 8/15/2002
: ERCOT Operating Procedure Manual Transmission & Security Desk
: 8454-00017-KV 4160/480V Transformer E2B1 Nameplate A 8454-00014-KV 4160/480V Transformer E2B2 Nameplate A 
: A-11Miscellaneous Documents Number Title
: Revision/Date
: 8074-01024-WM 13.8KV/4160V Transformer E2B Nameplate A 8074-01004-WM 13.8KV/4160V Transformer E2B Test Data A
: 8394-00037-ZF 25/13.8KV Unit 2 Auxiliary Transformer Nameplate G
: 8045-01007-WB 362.25/13.8KV Standby Transformer 2 Nameplate A
: 8045-01005-WB 362.25/13.8KV Standby Transformer 2 Test Data A
: VTD - W120-250 VTD - Maintenance Program Manual for Safety Related Type DS Low Voltage Metal Enclosed Switchgear
: VTD-B455-0047
: VTD-Installation/Maintenance Instructions for Metal Clad Medium Voltage Power Switchgear Type 5HK
: VTD-B455-0042
: VTD-Installation/Maintenance Instructions Medium Voltage Power Circuit Breakers Type 5HK
: NRC Letter to Mr. Bradford M. Radimer, Chairman, IEEE Battery Working Group
: 01/11/90
: Reply to Notice of Violation 9235-03 Regarding a Failure to Fully Test Essential Chiller ESF Loading Timing
: Sequence 04/02/93
: South Texas Project, Units 1 and 2 - Issuance of Amendments RE: Technical Specification 3/4.8.2 for Batteries and DC Systems (TAC Nos. MD0333 and
: MD0334) 07/20/07 5Q159MB1023
: 4A.1.6 Fluid System Margins, Page 4A-25 3 ANSI N195-1976 American National Standard Fuel Oil Systems for Standby Diesel-Generators
: 04/12/76
: CN-2824 Revise UFSAR Table 9.4-1 "Normal Parameters Temp." to Reflect a "Normal Parameters Temp" Range of 70°F to
: 77°F Instead of the 73°F to 77°F Range Currently Listed
: 2/27/06 DCP# 04-5388 Install Diodes Across Battery Chargers E2C11-1 and E2C11-2 Alarm Relays
: 04/20/04 DCP# 04-6544 Replace Float/Equalize Sw itches of Class 1E Battery Chargers 09/08/05 NSAC 125 Guideline for 10
: CFR 50.59 Safety Evaluations 06/1989
: NUREG-0800 USNRC Standard Review Plan 2
: NUREG/CR-2792 An Assessment of Residual Heat Removal and Containment Spray Pump Performance Under Air and Debris Ingesting Conditions
: 09/1982
: PR-880403 Weekly Surveillance Performed Incorrectly 10/06/88
: PR-910030 Surveillance Performed and Reviewed Incorrectly 02/24/92
: PRA-07-010 Unit 1 ESF
: DG 13 and Unit 2 ESF
: DG 23 TS Surveillance 4.8.1.1.2.e.11 Not Fully Performed
: 10/05/07 Regulatory Guide
: 1.137 Fuel Oil Systems for Standby Diesel Generators 0 Regulatory Guide Fuel Oil Systems for Standby Diesel Generators 1 
: 2Miscellaneous Documents Number Title
: Revision/Date
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: SPR 910145 Operability Questionable on Class 1E Batteries 10/12/92
: SPR 921482 Sequence Start Times for Essential Chiller 21B did not Meet Design Value Anticipated Start Times
: 2/11/92 USQE 91-0031 FSAR
: CN-1725 06/07/91 VTD-W120-0678
: AB De-Ion Circuit Breakers Time Current Characteristics Curves for Standard and Mark 75
: Thermal Magnetic Circuit Breakers
: VTD W120-0152 Type MME Magnetic Contactor 0
: VTD-W120-0216 AB De-Ion Circuit Breakers Standard Seltronic Mark 75 and Tri-Pac Designs
: VTD-W120-0300 Qualified Display Processing System (QDPS) 0 R289XG170BHY Essential Cooling Water Induction Motor Data Sheet
: 05/21/82 B03050-0008H4 Vendor Drawing AMTEK 10 KVA Inverter
: A
: B03050-0007H4 Vendor Drawing AMTEK 10 KVA Inverter C
: B03050-0005H4 Vendor Drawing AMTEK 10 KVA Rectifier B
: VTD-A363-0021 VTD - 10 KVA Inverter 3
: 2-E-EM-0822 Configuration Control Package 00
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Latest revision as of 06:12, 22 December 2019

IR 05000498-07-007 and 05000499-07-007; on 09/24/2007 - 01/22/2008; South Texas Project, Units 1 and 2; NRC Inspection Procedure 71111.21, Component Design Bases Inspection.
ML080450543
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 02/13/2008
From: Russ Bywater
Region 4 Engineering Branch 1
To: Sheppard J
South Texas
References
IR-07-007
Download: ML080450543 (35)


Text

UNITED STATES NU CLE AR RE GU LATOR Y C O M M I S S I O N ary 13, 2008

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000498/2007007 AND 05000499/2007007

Dear Mr. Sheppard:

On November 26, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed onsite portions of a component design bases inspection at your South Texas Project Electric Generating Station, Units 1 and 2. The preliminary results were discussed with you and members of your staff on November 26, 2007. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The enclosed report documents our inspection findings.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commission=s rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed cognizant plant personnel.

The report documents six NRC identified findings, each involving a violation of NRC requirements. All of the findings were evaluated under the risk significance determination process as having very low safety significance (Green). Because of their very low safety significance and because they are entered into your corrective action program, these violations are being treated as noncited violations, consistent with Section VI.A of the Enforcement Policy.

If you contest the subject or significance of any of these noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the South Texas Project Electric Generating Station, Units 1 and 2.

STP Nuclear Operating Company -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80 Enclosures:

NRC Inspection Report 05000498/2007007 and 05000499/2007007 w/Attachment: Supplemental Information cc w/enclosures:

E. D. Halpin Site Vice President STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 Ken Coates Plant General Manager STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 S. M. Head, Manager, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 Wadsworth, TX 77483 C. T. Bowman

STP Nuclear Operating Company -3-General Manager, Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Marilyn Kistler Sr. Staff Specialist, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code 5014 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 J. J. Nesrsta/R. K. Temple/

E. Alercon/Kevin Pollo City Public Service Board P.O. Box 1771 San Antonio, TX 78296 Jon C. Wood Cox Smith Matthews 112 E. Pecan, Suite 1800 San Antonio, TX 78205 A. H. Gutterman, Esq.

Morgan, Lewis & Bockius 1111 Pennsylvania Avenue NW Washington, DC 20004 Director, Division of Compliance & Inspection Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326

STP Nuclear Operating Company -4-Environmental and Natural Resources Policy Director P.O. Box 12428 Austin, TX 78711-3189 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 Anthony Jones, Chief Inspector Texas Department of Licensing and Regulation Boiler Program P.O. Box 12157 Austin, TX 78711 Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122, P.O. Box 13087 Austin, TX 78711-3087 Ted Enos 4200 South Hulen Suite 422 Fort Worth, TX 76109 Steve Winn/Christine Jacobs/

Eddy Daniels/Marty Ryan NRC Energy, Inc.

211 Carnegie Center Princeton, NJ 08540 INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-3064 Lisa R. Hammond, Chief Technological Hazards Branch National Preparedness Division FEMA Region VI 800 N. Loop 288 Denton, TX 76209

STP Nuclear Operating Company -5-STP Nuclear Operating Company -6-Electronic distribution by RIV:

Regional Administrator (EEC)

DRP Director (DDC)

DRS Director (RJC1)

DRS Deputy Director (ACC)

Senior Resident Inspector (JLD5)

Branch Chief, DRP/A (CEJ1)

Senior Project Engineer, DRP/A (TRF)

Team Leader, DRP/TSS (CJP)

RITS Coordinator (MSH3)

DRS STA (DAP)

D. Pelton, OEDO RIV Coordinator (DLP1)

ROPreports STP Site Secretary (HLW1)

SUNSI Review Completed: ___Y__ ADAMS: 6 Yes No Initials: ___WSifre___

6 Publicly Available Non-Publicly Available Sensitive 6 Non-Sensitive SRI:EB1 RI:PBC RI:EB1 OE:OB C:EB1 C:PBA C:EB1 WSifre/lm MChambers SMakor GApger RLBywate CEJohnson RLBywater b r

/RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

1/2/08 12/18/08 1/2/08 1/2/08 2/13/8 2/12/08 2/13/08

STP Nuclear Operating Company -7-OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

SUMMARY OF FINDINGS

IR 05000498/2007007 and 05000499/2007007; September 24, 2007 through January 22, 2008;

South Texas Project Electric Generating Station, Units 1 and 2; NRC Inspection Procedure 71111.21, "Component Design Bases Inspection."

The report covered a 4-week period of onsite inspection and additional in-office inspection performed by six region-based inspectors and two contractors. The inspection identified six Green noncited violations. The significance of most findings is indicated by its color (Green,

White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

NRC - Identified Findings

Cornerstone: Mitigating Systems

Green.

The team identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion III, "Design Control," having very low safety significance for the failure to specify in a design calculation allowable relay setpoint tolerances.

Specifically, the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures.

The issue was documented in the corrective action program as Condition Record 07-15443.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.

The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition did not represent a loss of safety function of a system or a train.

(Section 1R21.b.1)

Green.

The team identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion III, "Design Control," having very low safety significance for the failure to include all potential loads in the standby diesel generator fuel oil sizing calculation. Specifically, the licensee did not account for increased standby diesel generator fuel oil usage resulting from the addition of manual electrical loads during the 7-day mission run time. The licensee entered this finding into their corrective action program as Condition Record 07-15592. The licensee subsequently demonstrated that the spent fuel pool cooling pumps would be the only additional manual loads actually used during the 7 days of operation in the bounding design basis scenario and that there were additional conservative assumptions in the sizing calculation to demonstrate sufficient margin.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality. (Section 1R21.b.2)

Green.

The team identified a noncited violation of 10 CFR Part 50, Appendix B,

Criteria III, "Design Control," of very low safety significance for the failure to translate design basis information into specifications and procedures.

Specifically, a non-conservative system pressure was used as an input to an engineering design calculation for the auxiliary feedwater outside containment isolation valves. This finding has been entered into the licensee's corrective action program as Condition Record 07-15455.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss safety function of a system or a train. (Section 1R21.b.3)

Green.

The team identified a noncited violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, having very low safety significance for the licensees failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable. This issue was entered into the licensees corrective action program as Condition Records 07-14903 and 07-14959.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not represent a loss of safety function of a system or a train.

(Section 1R21.b.4)

Green.

The team identified a noncited violation of 10 CFR Part 50, Appendix B,

Criterion XI, "Test Control," having very low safety significance for the licensees failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service.

Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation. The licensee entered the finding into their corrective action program as Condition Record 07-15817.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance. It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A,

Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not result in a loss of safety function of a system or a train. (Section 1R21.b.5)

Green.

The team identified a noncited violation of 10 CFR Part 50, Appendix B,

Criteria III, "Design Control," of very low safety significance for the failure to adequately translate design basis information into specifications and procedures.

Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values used during periodic technical specification surveillance testing. The licensee entered the finding into their corrective action program as Condition Record 07-15752.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or a train.

(Section 1R21.b.6)

B. Licensee-Identified Findings None.

U.S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets: 05000498, 05000499 Licenses: NPF-76, NPF-80 Report: 05000498/2007007; 05000499/2007007 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: September 24, 2007 through January 22, 2008k Inspectors: W. Sifre, Senior Reactor Inspector, Engineering Branch 1 M. Chambers, Resident Inspector, Branch C B. Henderson, Reactor Inspector, Engineering Branch 1 S. Makor, Reactor Inspector, Engineering Branch 1 S. Rutenkroger, Reactor Inspector, Engineering Branch 1 G. Apger, Operations Engineer, Operations Branch Contractors: H. Anderson, Mechanical Contractor J. Chiloyan, Electrical Contractor Approved By: Russell L. Bywater, Chief Engineering Branch 1 Division of Reactor Safety

REPORT DETAILS

REACTOR SAFETY

Inspection of component design bases verifies the initial design and subsequent modifications and provides monitoring of the capability of the selected components and operator actions to perform their design bases functions. As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The plant risk assessment model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems and Barrier Integrity cornerstones for which there are no indicators to measure performance.

In addition to performing the baseline inspection, the team reviewed actions taken by the licensee in response to previously identified significant issues associated with engineering performance.

1R21 Component Design Bases Inspection

The team selected risk-significant components and operator actions for review using information contained in the licensee=s probabilistic risk assessment. In general, this included components and operator actions that had a risk achievement worth factor greater than two or Birnbaum importance value greater than 1E-6.

a. Inspection Scope

To verify that the selected components would function as required, the team reviewed design basis assumptions, calculations, and procedures. In some instances, the team performed independent calculations to verify the appropriateness of the licensee engineers' conclusions. The team also verified that the condition of the components was consistent with the design bases and that the tested capabilities met the required criteria.

The team reviewed maintenance work records, corrective action documents, and industry operating experience information to verify that licensee personnel considered degraded conditions and their impact on the components. For the review of operator actions, the team observed operators during simulator scenarios associated with the selected components, as well as observing simulated actions in the plant.

The team performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design issues, margin reductions due to modification, or margin reductions identified as a result of material condition issues. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as failed

performance test results; significant corrective actions; repeated maintenance; 10 CFR 50.65(a)1 status; operable, but degraded, conditions; NRC resident inspector input of problem equipment; system health reports; industry operating experience; and licensee problem equipment lists. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins.

The components selected for review were:

  • 345/138,13.8kV Standby Transformer ST002A
  • 13.8kV/4/16 Auxiliary Engineered Safety Feature Transformer E2B
  • 4.16kV Engineered Safety Feature BUS E2B
  • Standby Diesel Generator 22
  • 4.16kV/480 V Load Center Transformer E2B
  • 480V Load Center E2B2
  • 125V DC Battery and Charger Train B
  • Electrical Auxiliary Building HVAC
  • 10KVA Inverter E1V 2201
  • High Pressure Safety Injection Pump 2A
  • Low Pressure Safety Injection Pump 2A
  • Refueling Water Storage Tank
  • Essential Cooling Water Pump 2A
  • Essential Chilled Water Pump 2A The selected operator actions were:
  • Opening electrical auxiliary building doors and start of smoke purge on loss of ventilation to switchgear rooms.
  • Diagnosis of a steam generator tube rupture to start appropriate procedures.
  • Starting auxiliary feedwater if engineered safety features actuation system fails during a control room fire.

The operating experience issues were:

  • NRC IN 2007-09, "Equipment Operability Under Degraded Voltage Conditions."
  • NRC IN 2006-18, "Significant Loss of Safety-Related Electrical Power at Forsmark, Unit 1, in Sweden."

b. Findings

b.1. Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations

Introduction.

The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to specify in a design calculation the allowable relay setpoint tolerances stated in the licensees relay setpoint calibration test procedures. Under postulated electrical fault or overload conditions, the lack of adequate relay coordinating time intervals between relay operating characteristics would lead to spurious tripping and to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate.

Description.

During the review of licensees completed protective relay trip setpoint calibration test procedures, relay setting records and relay setting calculations to verify whether the applied relay settings were consistent with the designed basis calculations, the team noted that the acceptance criteria for the allowable values of relay setpoints stated in calibration test Procedures PM EM-2-03000814, WAN 274021 and relay setting sheets were neither specified nor verified in the design basis relay setting Calculation EC-5029, "4.16kV Switchgear Relay Setting." Following discovery, the licensee performed a preliminary evaluation for affected components using the worst-case scenario of relay setpoint tolerances stated on the relay setting records and concluded that the affected components would still perform their required safety functions in the event of an electrical fault. The issue was documented in licensees corrective action program as Condition Record 07-15443.

Analysis.

The licensees failure to specify relay setpoint tolerances and verify the effects on coordination margin in relay setpoint calculations for relays used on 4.16kV emergency safety feature switchgears was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating

events and prevent undesirable consequences. The failure to verify the effects of relay setpoint tolerances on relay coordination time intervals could have resulted in a loss-of-relay coordination and could lead to either a loss of power to safety-related components or lead to a potential for compromising other equipment on a single fault that the relay was designed to isolate. Using Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the condition had not resulted in a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, Design Control, requires, in part, that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by performance of a suitable testing program.

Contrary to the above, the licensees design control measures failed to either specify the relay setpoint tolerances or verify the adequacy of the design for safety-related 4160V electrical distribution system to ensure that the trip settings of the protective relays were adequate to ensure selective tripping in the event of a fault. Specifically, the team identified that the licensee failed to specify and verify in the relay setpoint calculations the relay setpoint tolerances used in the calibration test procedures. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15443, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-01, Failure to Specify Setpoint Calibration Limits in Relay Setpoint Calculations.

b.2. Failure to Consider Manual Loads for Fuel Oil Storage Tank Sizing Calculation

Introduction.

The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators seven day mission time for the fuel oil storage tank sizing calculation.

Description.

The Final Safety Analysis Report, Revision 0, stated that the fuel oil storage tanks were sized to have sufficient capacity to provide for continuous operation of the diesel generators for 7 days at their continuous rating, (i.e., 5935 kW). The licensee revised the Updated Final Safety Analysis Report (UFSAR) on December 9, 1992, to replace the loading at the standby diesel generator continuous rating with the engineered safety features load requirements. However, the documented review contained in Unreviewed Safety Question Evaluation 91-0031 and Calculation MC-6256, Sizing of SDG FOST, Revision 0, both discussed including all the non-engineered safety features loads listed in UFSAR, Table 8.3-3, as part of the fuel and storage tank sizing requirement.

In particular, the Unreviewed Safety Question Evaluation 91-0031 stated, This

[including all the listed non-engineered safety features loads] is in accordance with the ANSI N195 Standard which states, If the design includes provision for an operator to supply power to equipment other than the minimum required for the plant condition, such additional load(s) shall be included in the calculation of required fuel oil storage capacity. Regulatory Guide 1.137, Fuel Oil Systems for Standby Diesel Generators, Revision 1, dated October 1979, refers to the requirements described in ANSI N195-1976, "Fuel Oil Systems for Standby Diesel-Generators," to be a method acceptable to the NRC staff for complying with the Commissions regulations regarding diesel fuel oil systems for standby diesel generators and assurance of adequate diesel fuel oil quality. The safety evaluation report originally prepared for South Texas Project Electric Generating Station used ANSI N195 as the standard to evaluate the acceptability of the fuel oil storage tank design and sizing.

Since the UFSAR, as revised, did not discuss the additional manual loads, which must be considered in order to evaluate the fuel oil storage tank sizing, Calculation MC-6256, Revision 0, was ultimately revised in Revision 3, dated October 3, 1996, to remove consideration of all manual loads. Therefore, beginning with that revision the design basis non-conservatively removed consideration of expected actual plant operations with respect to manual loads during the bounding design basis accident analysis.

The team interviewed engineering and operations personnel in order to determine what equipment from UFSAR, Table 8.3-3, would be supplied power other than the minimum required for the plant condition. These interviews revealed a range of possible equipment, which could be utilized since the operations philosophy would be to exceed the minimum required for the plant condition in order to place the plant in as safe a condition as possible. The upper range of potential manually loaded equipment would have resulted in exceeding the minimum technical specification fuel oil volume requirement of 60,500 gallons during the 7-day mission time of the standby diesel generators during the worst-case design basis accident considered. However, in further discussions, licensee personnel balanced the operations philosophy with the 7-day fuel oil requirements considered as part of the design basis event and concluded the spent fuel pool cooling pumps would be the only additional manual loads utilized during the bounding scenario. The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high head safety injection, and containment spray pumps would be run continuously for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> following a large break loss of coolant accident. Therefore, the licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensees corrective action program as Condition Record 07-15592.

Analysis.

The team determined that the failure to account for manual electrical loads in determining fuel oil usage during the standby diesel generators 7-day mission time for the fuel oil storage tank sizing calculation was a performance deficiency. The finding

was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not accounting for the additional manual loads increases the likelihood that the required inventory of fuel oil for a 7-day mission time would not be available.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality.

This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, the licensee had not correctly translated design basis information into the standby diesel generator fuel oil tank sizing analysis. Specifically, the licensee failed to translate the loading and usage associated with additional manual loads, reasonably expected to be utilized during the bounding design basis accident, into Calculation MC-6256, Revision 4. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15592, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-02, Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation.

b.3. Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves.

Introduction.

The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the failure to translate design basis information into specifications and procedures. Specifically, the team identified that a non-conservative system pressure was used as an input to the engineering design calculation for the auxiliary feedwater outside containment isolation valves (MC-6204 Document Change Notice MC-145 issued 7/31/1992, Revise Motor-Operator Valve Thrust and Torque Calculation for AF-19, AF-48, AF-65, and AF-85).

Description.

The team identified that the pressure loading calculation in the motor-operated valve weak link analysis for the auxiliary feedwater outside containment isolation valves used a system pressure of 1250 psig. This value was based on the steam generator power-operated relief valves in the main steam systems being normally set at 1225 psig for normal operation and an additional 25 psig was added to the nominal steam generator power-operated relief valve set point to allow for any set point uncertainty.

This did not take into account accident conditions that result in the backpressure from the main steam system being greater than 1250 psig.

In response to the teams questions that the pressure could be greater than 1250 psig, the licensee issued Condition Record 07-15455-4, "Discussion Paper; Re-perform Weak Link Calculation at 1324 psid and 200°F," received October 24, 2007; and Condition Record 07-15455, "Discussion Paper; Weak Link Discussion of Motor-Operated Valves During Normal and Accident Operation," received October 15, 2007. The licensee determined that an increase in steam generator pressure greater than normal operating pressure would occur during certain design bases accident conditions. The appropriate input to the calculation was determined to be a steam generator pressure of 1324 psig, which allows for a 1 percent margin for setting tolerance and 2 percent for pressure drop in the piping connecting the safety valves to the steam generator from the lowest safety valve set point of 1285 psig. With the revised 1324 psig value and the original assumed valve temperature of 200°F the new weak link calculation resulted in two of the eight auxiliary feedwater outside containment isolation valves (one in each unit) having a torque switch setting that exceeded the weak link calculated set point in the close direction. The weak link for these valves is the valve seat. Valve thrust plus system pressure exceeding the valve seat strength could result in thrusting the valve disc into the seat and failure of the valve.

The licensee subsequently provided the following justification for the operability of the valves using the 1324 psid accident pressure. From a review of all accidents that result in an increase in Steam Generator pressures also result in the starting of the auxiliary feedwater pumps. The auxiliary feedwater system water supply has a design temperature range of 32°F to 120°F. Single failure criteria states that one of the auxiliary feedwater pumps may not start, however it is NOT creditable for a pump to not start and to have sufficient back leakage to raise the temperature of the outside containment isolation valve to 200°F at the same time. Therefore, the maximum abnormal temperature is 170°F.

The licensee determined that the weak link calculation at 1324 psid and 170°F results in adequate margin between current thrust settings of all eight auxiliary feedwater outside containment isolation valves and the calculated weak link stresses of the valve seats to assure operability under accident conditions.

Analysis.

The failure to use a conservative design input in the engineering analysis was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it did not represent a loss of safety function of a system or a train. This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, "Design Control," states, in part, that measures shall be established to assure that design basis are correctly translated into specifications and procedures. Contrary to the above, in Calculation MC-145, the licensee did not use a conservative pressure input necessary to prevent damage to auxiliary feedwater outside containment isolation valves during a design basis event. Because this violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Record 07-15455), it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-03, Failure to Use Correct Design Inputs in Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves.

b.4. Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus

Introduction.

The team identified a Green noncited violation of Technical Specification Surveillance Requirement 4.8.1.1.2.E.11, for the licensees failure to adequately perform the technical specification surveillance requirement. Specifically, the licensee failed to verify the loading times of the essential chillers in order to verify the automatic load sequence timer was operable.

Description.

Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval. The team requested to review the strip chart data recorded from the surveillance tests that demonstrated this surveillance requirement had been performed satisfactorily. Licensee personnel recognized, however, that the actual loading times referenced in the surveillance requirement had not been included in the measurements. Procedure 0PSP02-SF-001A, ESF Diesel Sequencer Timing Test Train A, Revision 11 (Trains B and C similar), only tests the time that the sequence timer demands breaker closure and does not measure and/or record the actual load times.

The licensee entered Technical Specification 4.0.3 for all three trains of standby diesel generators for both units, allowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fully perform the surveillances successfully. By reviewing the strip chart recorder data for the last loss-of-offsite power and loss-of-offsite power with emergency safety features actuation testing of the standby diesel generators, the licensee verified Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was successfully met for Standby Diesel Generators 11, 21, and 22. In the case of Standby Diesel Generators 13 and 23, the recorded information had a time resolution loss due to switching of recording speeds during the test. The licensee performed a risk evaluation to delay the complete performance of the surveillance test until the next scheduled time (the next outage scheduled for Spring 2008). The team reviewed this assessment and agreed with its conclusions since the data that was available fully supported the equipment being able to perform its safety function.

However, for Standby Diesel Generator 12, a review of the strip chart data revealed that Essential Chiller 12B had loaded on the bus at 168 seconds versus the design interval of 270 seconds. This condition had not been discovered in prior surveillance testing because Procedure 0PSP02-SF-001A did not contain instructions to verify the timing of relays outside of the sequence timer itself. The licensee declared Standby Diesel Generator 12 inoperable at 09:45 on October 5, 2007, entering Technical Specification 3.8.1.1, Actions B and D.

The cause of the timing discrepancy was isolated to a 35 second blocking circuit external to the chiller that would not prevent the chiller from performing its design safety function. As such, the safety functions of the sequence timer, the standby diesel generator, and Essential Chiller 12B were not adversely affected by the condition, nor would those safety functions be impacted by starting/loading times of the essential chillers between 65 and 270 seconds. The licensee revised the design documents referencing the loading time of the essential chillers to be between 65 and 270 seconds.

Once completed, the surveillance testing was declared successful, and the licensee declared Standby Diesel Generator 12 operable at 18:25 on October 11, 2007. This issue was entered into the licensees corrective action program as Condition Records 07-14903 and 07-14959.

Analysis.

The team determined that the failure to adequately perform Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 was a performance deficiency.

The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Not fully performing the required surveillances increases the likelihood that the standby diesel generators and supported equipment would not perform their design safety functions when needed.

Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because the finding did not represent a loss of safety function of the sequence timer, standby diesel generator, or the essential chiller. This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Technical Specification Surveillance Requirement 4.8.1.1.2.E.11 requires Verifying that the automatic load sequence timer is OPERABLE with the first sequenced load verified to be loaded between 1.0 second and 1.6 seconds, and all other load blocks within +/- 10% of its design interval. Contrary to the above, the licensee failed to verify the actual loading times of the sequenced loads. Specifically, the licensee only verified the time that the sequence timer demands breaker closure and did not perform the verified to be loaded requirement. Because the violation was of very low safety significance and has been entered into the licensee's corrective action program as Condition Records 07-14903 and 07-14959, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498;

499/2007007-04, Surveillance Procedure Lacked Check for Timing of Chiller Loading on the Bus.

b.5. Inadequate Test Program for 125V DC Molded Case Circuit Breakers

Introduction.

The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure to implement a test program to assure that all installed safety-related molded case circuit breakers will perform satisfactorily in service. Specifically, the licensee had not adequately exercised or subjected to periodic testing all of the 125V dc molded case circuit breakers since initial plant operation.

Description.

During the review of surveillance tests for the Auxiliary Feedwater Motor-Operated Valve 0019, the team discovered that the molded case circuit breaker had not been exercised or subjected to testing since the initial plant operation. In addition, further inspection discovered that the majority of 125V dc-fed molded case circuit breakers were also not exercised or subjected to periodic testing since installation in 1986. The types of molded case circuit breakers undergoing any type of preventative testing/maintenance included battery chargers, distribution panels, and inverters since they were infrequently cycled by other maintenance activities. Conversely, the breakers that fed loads to standby diesel generator field flash, reactor trip switchgear, 4.16kV switchgear control power and emergency safety feature load sequencers appeared to have not been tested since it was assumed that they were cycled in other maintenance activities.

The team noted that the licensee performed tests on molded case circuit breakers to satisfy Information Notice IEN 93-64 and ensure that molded case circuit breakers installed remained functional during plant operations. Following the test was an engineering evaluation acknowledging that molded case circuit breakers were subject to potential age-related degradation, which could result in a failure to trip in accordance with the published time-current characteristic curves because of various factors, such as grease hardening. In 2001, the licensee decided that the sample size for the dc-fed loads indicated that limited failures in the test population did not warrant a pre-established test program. Essentially, credit was taken for circuit breakers being cycled as a part of other maintenance programs, but it was realized that these tests performed on breakers, failed to actually cycle the breaker. In fact the handswitch was used to open and close the valve.

Updated Final Safety Analysis Report, Section 8.3.2.1.4, provides for Periodic testing Class 1E dc power system equipment is performed in accordance with Regulatory Guide 1.32 to verify its ability to perform its safety function. Information Notice 93-64, Periodic Testing and Preventative Maintenance of Molded Case Circuit Breakers, stated, "Detecting or assessing degradation could only be accomplished through appropriate periodic testing and monitoring." The team found that the licensees evaluation and approach to the industry experience, design life, potential common mode failures, and component age concerns were not addressed in the test program. The licensee entered this finding into their corrective action program as Condition Record 07-15817.

Analysis.

The team determined that the lack of periodic testing on all of the dc molded case circuit breakers was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Equipment Performance. It impacts the cornerstone objective of ensuring the availability, reliability, capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green)because it did not result in a loss of safety function of a system or train. This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion XI, "Test Control," stated, in part, that test programs shall be established to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service. Contrary to the above, the licensee failed to implement a test program to assure all installed safety-related molded case circuit breakers will perform satisfactorily in service. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15817, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-05, Inadequate Test Program for 125V DC Molded Case Circuit Breakers.

b.6. Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Surveillance Requirement 4.5.2.f)

Introduction.

The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the failure to adequately translate design basis information into specifications and procedures. Specifically, measurement instrument uncertainties were not included in the determination of minimum allowed high head safety injection pump and low head safety injection pump developed head values during periodic technical specification surveillance testing.

Description.

Technical Specification Limiting Condition for Operation 3.5.2, Surveillance Requirement 4.5.2.f.1 for the high head safety injection pump, and Surveillance Requirement 4.5.2.f.2 for the low head safety injection pump require:

For the High Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 1480 psid.

For the Low Head Safety Injection pumps, verification that the pump develops a differential pressure on recirculation flow when tested pursuant to Technical Specification 4.0.5 greater than or equal to 286 psid.

Upon review of Surveillance Procedures 0PSP03-SI-0001 and 0PSP03-SI-0004, the team identified that the pump developed head acceptance criteria in the procedures did not include consideration of measurement instrument uncertainties and were numerically equal to the technical specification values. As a result, there was no documented assurance that the recorded current and historical surveillance test results would demonstrate pump developed heads above the required minimum technical specification requirements when measurement instrument uncertainties were taken into consideration.

Therefore, the technical specification surveillance test acceptance criteria were non-conservative.

The team reviewed Design Basis Document 5Z529ZB01025, "Technical Specification/

Limiting Conditions for Operation Design Basis Document," Revision 2, and determined that it had erroneously stated for both high-head safety injection pumps and low-head safety injection pumps that This value is a conservative, nominal value and needs no additional instrument uncertainty margin. This value is acceptable for use. This value is only used in this application (Technical Specifications 4.5.2.f.1 and Technical Specification 4.5.2.f.2).

The licensee issued Condition Record 07-15752. The condition record stated that The pump test procedures currently use the technical specification values as the low limit for operability and should be revised. The most recent performance of all safety injection pumps meets the upward adjusted low limits.

Analysis.

The failure to include consideration of measurement instrument uncertainties, in relation to the instrumentation utilized in periodic surveillance tests to measure the pump developed head, into the technical specification surveillance test acceptance criteria was a performance deficiency. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone attribute of "Design Control." It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, Phase 1 screening, the finding screened as having very low safety significance (Green) because it

did not represent a loss of safety system function. This finding was reviewed for crosscutting aspects and none were identified.

Enforcement.

Part 50 of Title 10 of the Code of Federal Regulations, Appendix B, Criterion III, states, in part, that measures shall be established to assure that design bases are correctly translated into specifications and procedures. Contrary to the above, the licensee did not conservatively account for the effect of instrument uncertainty in development of acceptance criteria for the technical specification surveillance values for Technical Specification Limiting Condition for Operation 3.5.2. Thus, the minimum allowed high head safety injection and low head safety injection pump developed head had not been definitively demonstrated during surveillance testing to exceed the minimum Technical Specification limiting condition for operation values. Because this violation was of very low safety significance and has been entered into the licensees corrective action program as Condition Record 07-15752, it is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498; 499/2007007-06, Failure to Incorporate Instrument Uncertainties into Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Specifically Surveillance Requirement 4.5.2.f).

OTHER ACTIVITIES

4OA5 Other Activities

a.1 Unresolved Item Associated with the Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment

Introduction.

The team identified an unresolved item associated with the steady state output voltage supplied by the standby diesel generators is allowed to vary by Technical Specification 3/4.8.1 from 3744 V to 4576 V (+/- 10%) during a loss of offsite power event. Specifically, the licensee has not analyzed for the effect of this full variation.

Description.

The design analysis assumed maximum supplied voltage variations based upon offsite power supplies which were analyzed to vary less than the technical specification allowed steady state variation for the standby diesel generators.

Components throughout the plant would be adversely affected by either an undervoltage or overvoltage condition.

Since this is a very broad issue that encompasses components powered from the standby diesel generator during a design basis event, the licensee will require significant time to evaluate its effects. Although available safety margins will be less, the degree of this effect is not yet known since the effect of the variation varies upon the analyzed parameter and currently analyzed margins vary significantly. The actual safety function of equipment is not expected to be compromised since the standby diesel generators are presently controlled to a tighter band of voltage operation than allowed by technical specifications and review of the surveillance testing of the standby diesel generators confirms this tighter band is currently being maintained.

Once the licensee has evaluated the effect of the allowed steady state voltage variation and determined the degree of safety margin impact throughout the plant, the NRC can complete the inspection of that analysis in order to close this issue. The licensee has documented this issue in Condition Record 07-15554 and the item is unresolved pending the licensees completion of its analysis and NRC review: URI05000498; 499/2007007-07, Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment.

a.2 Unresolved Item Involving Combined Adverse Conditions not considered in Fuel Oil Storage Tank Sizing

Introduction.

The team identified an unresolved item involving accounting for the combined effect of vortexing and standby diesel generator frequency variations in fuel oil storage tank sizing.

Description.

Calculation MC-6256, Sizing of Standby Diesel Generator Fuel Oil Storage Tank, Revision 4, determined a total 7-day fuel oil requirement of 51,500 gallons, comparing this value with a technical specification requirement of 60,500 gallons. However, this calculation did not consider the effects of vortexing or generator frequency variations. Condition Record 97-14434-10 included an evaluation of fuel oil vortexing completed as part of a Review of Safety Related Tanks (other than Refueling Water Storage Tank & Auxiliary Feedwater Storage Tank) for Vortexing Concerns.

Separately, Calculation EC-5100, Standby Generator Transient Response Model, Revision 2, contained an evaluation performed under Condition Record 97-13089-1 in order to Perform Evaluation of Electrical Frequency Variations on Mechanical Fluid Systems.

The vortexing evaluation determined that 13.5 inches of fuel oil volume would be susceptible to excessive air entrainment, representing 4120 gallons of unusable fuel oil with a 7-day fuel oil requirement of 55,360 gallons (referencing Calculation MC-6038, Standby Diesel Generator Fuel Oil Storage Tank Level Setting Calculation. The total required volume would therefore be 59,480 gallons.

The frequency effects evaluation determined that Standby Diesel Generator load would increase by roughly 6% because the majority of load consists of pumps and fans with primarily friction system loads. The evaluation then compared this 6 percent increase in load with the standby diesel generator fuel oil storage tank calculated margin of more than 10 percent.

However, the vortexing evaluation had already effectively reduced the majority of the analyzed margin with a remaining 1020 gallons of fuel oil between 59,480 gallons and the technical specification requirement of 60,500 gallons. Therefore, applying a 6 percent increase in standby diesel generator load in addition to considering vortexing effects would have exceeded the technical specification requirement under those analyzed conditions.

In addition, the most recent fuel oil storage tank sizing calculation determined a 7 day fuel oil requirement of 51,500 gallons. As discussed in the finding Manual Loads not Considered for Fuel Oil Storage Tank Sizing Calculation, this requirement neglected manual loads during the 7 days for which provision would be made to use during a design basis event. A bounding analysis considering the actual anticipated manual loads, in addition to the vortexing reduction and increased load frequency effect, exceeds the minimum technical specification requirement.

The fuel oil storage tank sizing calculation included additional conservative assumptions regarding expected pump operation during design basis accident scenarios. For example, the calculation assumed auxiliary feedwater, high-head safety injection, and containment spray pumps would be run continuously for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> following a large break loss-of-coolant accident. The licensee recalculated the fuel oil storage tank sizing using more realistic assumptions with respect to load profile and determined sufficient fuel oil margin does exist with all design basis conditions considered. This issue was entered into the licensees corrective action program as Condition Request 07-14398 and 07-15592.

After further discussions with staff from the NRC Office of Nuclear Reactor Regulation, the team concluded that this issue of failure to account for the combined effect of vortexing and standby diesel generator frequency variation in the fuel oil storage tank sizing would remain open as an unresolved item. Additional NRC staff review was necessary to determine whether the issue was acceptable, whether it was a finding, or whether it constituted a deviation or violation. Pending completion of this review, this item is unresolved: URI 05000498; 499/2007007-08, Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing.

4OA6 Meetings, Including Exit

On October 26, 2007, the team leader presented the preliminary inspection results to Mr. E. Halpin, Site Vice President, and other members of the South Texas Project staff.

After additional offsite and onsite inspection a preliminary exit meeting was conducted on November 26, 2007, with Mr. J. Sheppard, President and Chief Executive officer and other members of the licensees staff. After additional in-office inspection, a telephonic exit was conducted on January 22, 2008. The licensee acknowledged the findings during each meeting. While some proprietary information was reviewed during this inspection, no proprietary information was included in this report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Bowman, General Manager Oversight
K. Coats, Plant General Manager
R. Engen, Manager, Maintenance Engineering
E. Halpin, Site Vice President
S. Head, Manager, Licensing
K. House, Manager, Design Engineering
B. Jenewein, Manager, Testing/Programs Engineering
R. Lovell, Manager, Industrial Alliances
M. Meier, General manager Station Support
J. Mertink, Manager, Operations
M. Murray, Manager, Systems Engineering
G. Powell, Manager, Site Engineering
D. Rencurrel, Vise President, Engineering
M. Ruvalcaba, Supervisor, Engineering
J. Sheppard, President and Chief Executive Officer
D. Towler, Manager, Quality

NRC personnel

W. Jones, Chief, Engineering Branch 1
J. Dixon, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

URI05000498; 499/2007007-07 URI Effect of Standby Diesel Generator Technical Specification Voltage Variation on Supplied Equipment URI05000498; 499/2007007-08 URI Combined Adverse Conditions not Considered in Fuel Oil Storage Tank Sizing

Opened and Closed

NCV05000498; 499/2007007-01 NC Failure to Specify Setpoint Calibration Limits in V Relay Setpoint Calculations NCV05000498; 499/2007007-02 NC Manual Loads not Considered for Fuel Oil Storage V Tank Sizing Calculation Attachment

NCV05000498; 499/2007007-03 NC Failure to Use Correct Design Inputs in V Determination of the Weak Link for the Auxiliary Feedwater System Outside Containment Isolation Motor Operated Valves NCV05000498; 499/2007007-04 NC Surveillance Procedure Lacked Check for Timing of V Chiller Loading on the Bus NCV05000498; 499/2007007-05 NC Inadequate Test Program for 125V DC Molded Case V Circuit Breakers NCV05000498; 499/2007007-06 NC Failure to Incorporate Instrument Uncertainties into V Surveillance Requirements for Technical Specification Limiting Condition for Operation 3.5.2 (Specifically Surveillance Requirement 4.5.2.f)

LIST OF DOCUMENTS REVIEWED