ML20198M280

Insp Rept 50-382/97-24 on 971102-1213.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20198M280
Person / Time
Site:	Waterford
Issue date:	01/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198M274	List: ML20198M269 ML20198M275 ML20198M280
References
50-382-97-24, NUDOCS 9801200061
Download: ML20198M280 (22)

See also: IR 05000382/1997024

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ENCLOSURL2  ;

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.:- 50 382  :

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License No.: NPF 38

Report No.: i

50 382/97 24

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Licensee: Entergy Operations, Inc.

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Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy.18 ,

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Killona, Louisiana

Dates: November 2 through December 13,1997

Intpectoro: J. M. Keeton, Resident inspector

G. A. Pick, Senior Project Engineer

C. E. Johnson, Reactor inspector

Accompanied By: J. C. Edgerly, Resident Inspector Trainee

Approved By: P. H. Harrell, Chief, Project Branch D

ATTACHMENTS: Supplemental inforrnation j

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EXECUTIVE SUMMAllY

Waterford Gteam Electric Station, Unit 3

NRC inspection Report 50-382/97 24

This routine, announced inspection included aspects of operations, maintenance,

engineerint,, and plant support activities. The report covers a 6 week period of resident

inspection.

DDDLEtlDDS

• A violation resulted from the failure to provide adequate postmaintenance testing

instructions (EA 97 588) (Section 02.1).

• Dirt and debris in the reactor auxiliary building (RAB) drains had the potential for

adversely affecting safety equipment and no progrt.m existed for routinely cleaning

the drains. This issue remains unresolved (Section 02.2).

• The failure to complete the surveillance of the flow low bypass prior to entering

Mode 2 in 1989 resulted in a violation of Technical Specification 4.3.1.2. This is a

noncited violation (Saction 08.5).

Maintenance ,

• Replacement of the pressure analog comparator card was performed in a

professional manner, with good supervisory oversight (Section M1.2).

The maintenance rule program for the process radiation monitor system was

appropriately implemented (Section M2.2).

Engiacering

The f ailure to account for recirculation flow to a tank resulted in a nonconservative

determination for the onset of vortexing r. i resulted in a violation (EA 97 587) ,

(Section E1.1).

• The engineering evaluation for the single component failure effects on the

condensate storage pool (CSP) was thorough, timely, and addressed the issues

appropriately (Section E2.1).

Plant SuoDQLt

• The inspector observed good command and controlin the control room simulator

and technical support center during the graded emergency exercise (Section P1.1).

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Report Details

Summarv of Plant Statt,t3

During this inspection period, the plant operated at essentially 100 percent power.

LOAttall0Da

01 Conduct of Operations

01.1 General C mments

9 1717071

s The inspectors perMrmed frequent reviews of ongoing plent evaluations, control

room panel walkdowns, and plant tours. Observed activities were performed in a

rnanner consistent with safe operation of the facility. The inspectors also observed

several shif t turnovers and daily routine shif t activities. The inspectors observed

operators using self checking and peer checking techniques when manipulating

equipment. Three way communications were consistently used by the operators

within the control room and in external communications with equipment operators

and maintenance personnel.

02 Operational Status of Facilities and Equipment

02.1 Comoonent Coolina Water (CCW) Valve to Containment Fan Coolers inonerable for

an Extended Period

a. Insoection Snone (71707)

The inspectors reviewed the circumstances related to Valve CC 835B, CCW flow

control for Containment Fan Coolers B and D, being found gagged in a partially shut

position. The inspectors interviewed members of the licensee staff, reviewed

documentation, and reviewed the corrective actions taken by the licensee to address '

this concern.

b. Qhigtyations and Findinos

On October 17,1997, operators performed the quarterly inservice testing stroke

test for Valve CC 835B in accordance with Procedure OP 903118, "Prirnary

Auxiliaries Quarterly IST Valve Tests." Valve CC 835B controls the CCW flow to

Containment Fan Coolers B and D. During the test, an operator stationed at the

valve discovered that the mechanical gag for Valve CC 835B was partially engaged,

which restricted valve travel to only about 80 percent open. Control room personnel

directed the operator to adjust the gagging device and satisf actorily retested the

valve to verify it opened 100 percent. Operatior.s personnelinitiated Condition

Report (CR) 97 2450 to investigate thia event.

The licenlee subsequently determined that the valve had been gagged fully shut

during a,t operator maintenance on September 9,1997 (39 days previously). Tne

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gag should have been fully disengaged by operations personnel after the l

Instrumentation and control (l&C) technicians completed the work activities.

Technical Specification Surveillance Requirement 4.0.2.2.b.3 requires that each

cooling water control valve actuates to its fully open position on a safety injection

actuation signal test signal. As a result of Valve CC 835B being gagged so it would

only open to 80 percent, the valve f ailed to meet the action requirements of *

Technical Specification 3.6.2.2 for an operable system. The licensee performed an

eva!uation of the as founo position of Valve CC 835B with respect to as found flow

rates to the containment f an coolers. Based on the evaluation, the licensee

determ'ned that the valve was technically inoperable since it was not fully open;

however, the system remained functional since the system flow rates were well

above that required for th9 system to perform its design basis function.

The inspectors independently reviewed the evaluation completed by the licensee.

Based on this review, the inspectors established that adequate flow would have

been available to each fan cooler to provide its safety function even though

Valve CC 8358 was restricted to 80 percent open. Valve CC 835B is an 8 inch

butterfly valve with flow characteristics sut.h that 100 percent flow !s obtained with

the valve at 40 percent open. Observed flow through each fan cooler with the valve

at approximately 80 percent open was about 1450 ppm. The minimum flow  :

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requirement is 1200 gpm. The inspectors determined that, although the valve could

not meet the specific requirements of Technical Specification 4.6.2.2.b.3, the safety

significance of the valve only opening 80 percent was minimal since the system

remained fully functional.

The inspectors reviewed Work Authorization (WA) 01163329, which authorized

replacement and adjustment of the air regulator for Valve CC-835B on September 9.

It was noted that the WA provided instructions for the I&C technicians to disengage

the gag; however, the instructions for performance of the postmaintenance test

(i.e., verify the gag was fully removed) were inadequate because the instrt.:tions did

not require Valve CC 8358 to be stroked opened and closed to ensure the gag had-

been fully disengaged. Technical Specification 6.8.1 raquires that instructions be

provided for performance of maintenance on safety relited systems. The failure to

provide adequate instructions for postmeintenance tes'ing of Valve CC 8358 is a

violation (50-382/9724 01).

The inspectors reviewed the actions taken by the licensee to bound the extent of

this problem. A search of the CR data base from April 1,1997 (beginning of the

refueling outage), un:il the present was performed to determine if any valves had

l failed the Inservice test stroke test. The licensee identified that only Valve CC-8358

had maintenance performed without the appropriate retest.

The licensee issued LER 97 025 to document this event and to provide the

4 corrective actions taken to address this issue. A discussion of the review performed

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of the licensee's impiementation of the corrective actions is provided in Section

08.6 of this report. 2

c. Conclusions

A violation for inadequate postmaintenance instructions was identified.

02.2 Dirt and Debris in RAB Floor Drains

a. Insoection Scooe (717071

The inspectors toured the RAB for the purpose of inspecting floor drains for dirt and

debris to verify the drains were able to parform their intended function,

b. Observations an 1 Findio.g3

On November 4,1997, during a tour of the RAB, the inspectors noted that the floor

drains on the + 21.fciot level contained enough dirt and oebris to potentially cover

. any open drain path. This prompted inspection of all floor drains in the RAB,

including all safety related pump rooms. Most of the floor drains in the RAB

contained dirt, paint chips, and other det,ris, which covered the acreens on the drain

insrats.

The inspectors notified the shift superintendent, who immediately notified the

radiation protection field support supervisor and wrote CR 97 2544. The inspectors

asked if a routine surveillance existed for verification that the floor drains were

functional and established that a program for periodically cleaning the drains did not

exist.

Immediate attention was given to the drains in the diesel ganerator rooms and the

safety related pun.p rooms. The screens were cleaned and ilow paths were verified

to be open. Other drains in the RAB were also suosequently cleaned.

As of the end of this inspection, the licensee had not completed long term corrective

actions associated with the CR, nor had an evaluation been completed to determine

the impact on plant operations for the clogged drains. This issue is unresolved

pending review of the long term actions to resolve this issue (50 382/9724 02).

c. Conclusions

~ A condition existed in the RAB that had the potential for adversely affecting safety.

equipment. This condition should have been identified by operators during routine

tours.

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08 Miscellaneous Operations issues (92901)

08.1 CasediLER 50-382/98 004: Failure to meet intent of Technical Specification

surveillance because of inadequate corrective actions.

The LER describes the same condition as Enforcement

Action (EA) 50 382/96-025/01013, which is discussed in Section 08.3 of this

report. Since the corrective actions for that violation were satisf actory, this item is

considered closed.

08.2 Coled)LER 50 382/96-006: Reactor trip following a failure of the control element

drive motor / generator (M/G) set voltage regulator

A reactor trip occurred on May 17,1996, with the plant operating at 100 percent

power. The trip resulted from the low of both M/G sets because the M/G Set A

voltage regulator failed. The licensee determined that heat related aging caused the

failure.

The inspectors verified that the following corrective actions had been completed:

(1) imolemented a stand off resistor modification to improve the heat dissipation of

the M/G voltage regulators; (2) developed repetitive tasks to replace the M/G

over voltage relays at 10 year intervals; and (3) initiated a station modification

request to evaluate annunciator system improvements for a tripped M/G set. The

licensee will assess whether any modification would improve syc. tem reliability for

high voltage conditions and to reduce operating temperature in the M/G set local

control panel.

Based on the reviews performed by the inspectors, it was concluded that the

licensee had taken the appropriate actions to address this issue.

08.3 (Closed) EA 50-382/96 025/01013: Failure to preclude the development of voids in

the Auxiliary component cooling water system.

This violation resulted from f ailure to identify the root cause and take adequate

corrective actions on numerous occasions from 1994 to 1996 to eliminate volds in

the Auxiliary component cooling water system. After the NRC expressed concern

with this deficiency, the licensee initiated a root cause analysis and identified

comprehensive corrective actions. The licensee attributed the root cause to air

intrusion through relief valves and column separation.

The inspectors confirmed that the licensee implemented the following immediate

corrective actions: (1) relocated all system engineering planning functions to the

maintenance planners; (2) assigned responsibility for performing ultrasonic testing of

hydraulic piplag to quality assurance; (3) revised Procedure UNT 005-012

" Repetitive Task Identification," to ensure a planner must create and oversee

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repetitive tasks, ensure that tasks must be accepted prior to beirig assigned, and (

address the planning function; (4) reviewed for any other late repetitive tasks;

(5) disseminated to maintenance planners, operations, system engineering, and

quality assurance personnel, lessons learned from this experience; (6) revised

Procedure W2.501, * Corrective Action," to ensure that root cause analyses and the

recommended corrective actions are presented to the Condition Review Board for

approval; and (7) evaluated the open CR to determine whether additionalinterim

corrective actions were required.

The inspectors verified that the licensee completed the following corrective actions

to address generic consequences: (1) enginacts evaluated susceptibility of other

safety related systems to fluid transients and assessed adequacy of fill and vent

procedures; (2) operations and operational experience engineering completed

separate, independent reviews of surveillance procedures in order to identify

workarounds; and (3) an outsido regency completed a corrective action process

audit.

The licensee identified that three surveillance procedures contained test

arrangement that required engineering review to eliminate the potential

workarounds. As of the end of this inspection period, the licensee indicated that

engineering requests would be initiated to ensure a detailed review would be

completed. The items requiring review included: (1) evaluating whether the all

emergency feedwater (EFW) flow paths must be velified through both sets of valves

for each steam generator, (2) testing of Valves CVC 216A(B), pressurizer auxiliary

spray isolation, not performed because a note indicates valves cannot close against

reactor coolant system pressure, and (3) evaluating the reason for closing

Valves CC 125A,125B, and 125AB, CCW discharge isolation, prior to securing the

pump.

The inspectors found the above corrective actions to be satisf actory. However,

since the engineering evaluation had not been completed for the three workarounds,

additionalinspection will be performed to review the results of the evaluation. This

offort will be tracked as an inspection followup item (50 382/9724-03).

08.4 (Closedl EA 50 382/96-025/03014: Failure to properly test the Auxiliary

component cooling water system.

This violation was cited because the licensee f ailed to perform the system

surveillance test, as described in the applicable design documents. The licensee

tested the system with the discaarge valve closed instead of open, the normal

standby position for a design basis accident, bacause of a proceduralized

workaround.

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The corrective actions for this violation were the sam? as for

EA 50-382/96 025/01013, which is discussed in Section 08.3 of this report. Since

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the Inspectors found the corrective actions eatisfactory, this item is considered

closed.

08.5 1 Closed) LER 50 382/97-0Q5: Failure to perform Technical Specification required

reactor ecolant flow low operating bypass surveillance.

On February 20,1997, the licensee determinvd that a surveillance for the reactor

coolaat flow low bypass, required to be performed prior to reactor startup, had not

i been performed prior to entering Mode 2 in July 1989. The licensee verified that

the surveillance had been completed during all subsequent outages and identified the

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root cause as a falture to incorporate procedure cont ols following the modificat;on

That instal led the bypast circuitry in 1988.

The inspectors verified the following the correctit 3 actions were completed by the

licensee: (1) reviewed the event with operations and licensing department personnel

as part of their required reading; (2) impler inted repetitive tasks to test the bypass;

!3) revised Procedure CP 903-107, " Plant I otection System Channels ABCD

Functionel Test," Revision 13, to require performance of the bypass functional test

prior to each startup; and (4) initiated a modification for the bypass circuit that

would permit operation of all four reactor ciolant during the bypass test.

The failure to complete the surveillance of the bvoass prior to entering M 2 in

1989 is a violation of Technical Specification 4.3.1.2. This nonrepetitive,

licensee-identified, tnd corrected violation is being treated as a noncited violation

consistent with Section Vll.B.1 of the NRC Enforcemant Policy (50-382/9724-04).

08.6 LChsed) LER 50-392/97-025: Gag for Valve CC 835B was partially engaged, which

rastricted the valve to cpproximately 80 percent open.

On October 17,1997, the gag for Valve CC-835B was found partially engaged,

which restricted the CCW Haw to Containment Fan Coolers B and D. The root

cause was identified by the licensee as inadequate work Instructions.

The inspectors reviewed 'he corrective actions and found that appropriate guidance

had been implemented to ensure future work packages required the fuil stroke

- verification of air operated valves after the actuat9r gag had been disengaged

following maintenance. See Section O2.1 of this report for additional details.

- Based en review.of the corrective actions implementer by the licensee, this LER is

considered closed.

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11. Maintenance

M1 ~ . Conduct of Maintenance

M1.1 - General Comments -

The inspectors observed the following surveillance activities:

• OP 303 068 -- Emergency Diesel Generator (EDG) and Subgroup Relay

Train A Operabili ty Test

• OP OO3 014. Control Room Heating and Venti;ation

in addition, the inspectors observed portions of the following maintenance activities

performed in accordance with the listed WA:

• WA 01164836 Replace pressure analog comparator card for Train A

shield building ventilation exhaust fan (S3V-114A) and

perform calibration. 1

• WA 01164976 Replace pump mounting bolts on EFW Pump A/B

• WA 01165761 Replace guide vane controller for Chill Water

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e The inspectors found the conduct of these maintenance and srveillance activities to

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be good. All activities observed were performed with an appropriate author 5ation

package or test procedure. The inspectors observed supervisors monitoring job

progress.

M1.2. I&C Maintenance Activity

a. Insoection Scone (62707)

The inspectors observed portions of the maintenance activities to replace the

pressure analog comparator card for Train A shield building ventilation exhaust fan

(SRV 114A) and perform the instrument calibration.

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b. Observation ar d Fir;dirgi

' The inspectors attended the prejob briefing given by the l&C supervisor to the

te'chnicians for.WA 01164836. The ILC supervisor's projob briefing was clear,

detailed, and well presented,

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The inspectors observed the removal of the old pressure analog cw.parator card and

installation of the new pressure analog comparator card. The inspectors noted that

the technicians followed the work instructions, performed double verification, and

were very knowledgeable of the system. Upon completion of the maintenance

activity, the l&C technicians performed the calibration using Procedure Mi-005 251,

" Westinghouse 7300 In Place Card Calibration," Revision 6. Instrumentation used

for the calibration of the new pressure analog comparator card was verified by the

inspectors to be within the required calibration dates,

c. Conclusions

Replacement of the pressure analog comparator card was performes :n a

professional manner, in accordance with work instructions, and received good

.apervisory oversight.

M2 Maintenance and Material Condition of Facilities and Equipment

M 2.1 EDS B Postmaintenance Ooerability Verification

a. Insocction Scone (62707)

The inspectors reviewed the adequacy of corrective actions initiated by the licensee

in response to a f ailed postmaintenance operability verification on EDG B.

b. Observations and Findings

CR 97 2624 was initiated because EDG B had tripped during the pedumance of

Procedure OP 903-068, " Emergency Diesel Generator and Subgroup Helay .

Operability Verification," Revision 12, following maintenance. The licensee stated

that the trip occurred approximately 16 20 seconds after reaching rated speed and

) voltage during a manual start initiated by the operators,

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The oper its performed several instrumented test runs on EDG B but could not

duplicat he original failure. All manual starts were successful. Additionally, a

number of components that could have cont: buted to or caused tt e original f ailure

were tested and no deficiencies were identified. The licensee was cble to show that

the part of the starting circuit that was the most probable cause of .ne failure was

no, in the emergency start circuit and would have been bypassed during an

emergency start.

c. Conclusions

The cause of the f ailure wcs not determined; however, the safety significance was

considered negligible as the suspected cause of the failure would not have

prevented an Emeigency start.

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M2.2 Maintenance Sula

a. Insoection Scone (62706)

The inspectors reviewed the maintenance history and current maintenance activities

for the process radiation monitors to determine if the system was appropriately

monitored under the licensee's maintenance rule program and whether goals

established were commensurate with safety.

b. Observations and Findinas

The process radiation monitoring system consists of a total of nine process radiation

monitors that were included in the Maintenance Rule Program. The system was

initially placed in the a(2) category when the Maintenance Rula Program was

implemented in July 1998. The performance criteria established for this system was

less than or equal to two MPFF per 3 years. However, the system wss placed in the

all) category, in January 1997, because it did not meet its performance criteria due

to exceeding two MPFF in 3 years. The licensee had established goals to monitor

the process radiation monitor system. The inspectors determined through review of

maintenance history that the licensee's determination of MPFFs was appropriate and

that the licensee's goals for monitoring the system were satisf actory.

The process radiation monitor system was being implemented in accordance with

10 CFR 50.65, the licensee's maintenance rule program, and commensurate with

safety.

c. Conclusions

The licensee had appropriately determined MPFF for the process radiation monitor

system, and the system was being implemented in accordance with 10 CFR 50.65,

the licensee's maintenance rule program, and commensurate with safety.

M8 Miscellar.eous Maintenance issues (92902)

M P.1 (Closed) Violation 50-382/9701-01: Failure to include a safety-related system

! containment atmosphere relief system) into the maintencnce rule program scope.

The inspectors verified the corrective actions described in the violation response

were reasonable and appropriately implemented. No similar problems were

identified.

. M8.2 : IClosed) Violation 50-382/9701-02: Failure to monitor the unavailability of

functions associated with the engineered safety feature a.:tuatica system, plant

protection system, core protection calculators, broad range gas monitors, and

- containtnent polar crane.

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The inspectors verified the corrective actions described in the violation response to

be reasonable , 'd appropriately implemented. No similar problems were identified.

M8.3 (Closed) EA 50 382!97-025/02014: Change in the scope of a WA without the

originators review.

~ This violat=n was identified because a system engineer marked the differential

pressure test for Valves CS 125A(B) "nat applicable" without the original reviewers

reviewing the change. Similarly, a maintenance planner marked a postmaintenance

test as "not applicable" without the consent of the original reviewers.

The inspectors verified that the licensee had issued a memorandum reemphasizing

the procedure requirement for review of work package scope changes, Further, the

inspectors verified that the licensee clarified the requirements in

Procedure UNT 005-015, " Work Authorization Preparation and Unplementation," for

what constitutes a change !n work scype. The inspectors found these corrective

actions satisfactory,

111. Enaineerina

E1 Conduct of Engineering

E1.1 Evaluation of Vortex Calculation Deficiencv

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a. Scoce (92903. 37551)

The inspectors reviewed the circumstances related to the calculation generated to

determine the onset of vortexing in various safety-related tanks. The inspectors

discussed the detailed engineering evaluation with the design engineer who prepared

the evaluation and reviewed several documents referenced in the operability

evaluation for CR 97-1596.

b. Observations and Findinas

in August 1995, a licensee seif assessment of the EFW system identified that the

CSP design basis did not include an allowance for vortexing; consequently, the

licensee initiated CR 95-0657 to document this design deficiency and developed a

calculation to document tt = onset of vortexing in various safety-related tanks.

Calculation EC M95-012,_" Minimum Pipe Submergence to Prevent Vortexing,"

Revision 0, determined the minimum level for vortexing in the CSP based on vortex

height versus flow curve in a vendor pump manual,

in May 1996, the licensee contracted with Combustion Engineering to perform a

calculation to determine the onset of vortexing in the refueling water storage pool in

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order to take advantage of the expertise in this area by an individual who worked at

Combustion Engineering. In December 1996, the licensee revised

Calculation EC-M95 012 to determine the level for vortexing in the safety-related

tanks using the method developed by Combustion Engineering. The licensee made

this decision to take advantage of the analytical methodology rather than relying on

a curve from a vendor manual.

On July 17,1996, the licensee submitted Technical Specification Change Request

NPF 38170 to raise the CSP level from 82 to 91 percent to account for vortexing

and instrumerit uncertainty. On June 3,1997, the licensee supplemented Technical

Specification change request NPF 38-179 witt. additionalinformation that accounted

for a previous failure to consider the increase in short term volume required for the

CCW makeup system in the design basis of the CSP. The supplement attached

Calculation EC-M95-012, Revision 1, and addressed instrument uncertainties related

to operation of the controlled ventilation area system on the CSP.

During review of the July 1997 supplement to Technical Specification change

request NPF 38-179, an NRC reviewer questioned the conservatism of the value for

the onset of vortexing in tiie CSP (1.53 percent level). The reviewer held

discussions with the licensee on June 10 and 17,19P7, to urderstand the basis of

the analytical method documented in Calculation EC-M95-012, Revision 1.

Additionally, the NRC reviewer indicated a concern as a result of his knowledge of

the sump tests documented in NUREG CR-2759, "A Parametric Study of

Containment Emergency E, ump Performance Results of Vertical Outlet Sump Tests."

The licensee did not agree that the value determined by their analytical method was

noncenservative, but acknowledged that empirical test data was needed to support

the methodology.

To demonstrate that the analytical model supported the determination of the onset

of the point of vortexing 'n the CSP, the licensee developed a scale model of the

pool. The tests performed in the scale model demonstrated that the analytical

method was nonconservative related to the onset of vortexing. The licensee

initiated CR C7-1596 tc, document that Calculation EC-M95-012, Revision 1, was

nonconservative since the methodology employed was based on static tank

conditions and did not account for recirculation flow to the refueling water storage

and condensate stomoe pools. Immediate corrective actions for this deficiency

involved the modeling ;f vortex breakers in the CSP scale mode! and installing the

actual vortex breakers in the pool. Since engineers hac; used the same calculation

method on all of their safety related tanks, which included the refueling water

storage pool, the licensee assessed the other safety-related tanks.

The licensee febricated a scale model of the refueling water storage pool, without

vortex breakers installed, to determine the actual level for the onset of vortexing to

provide inforniation for a past operability determination. In addition, the licenseo

modeled cruciform vortex breakers to demonstrate that the planned corrective

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actions would correct the deficiency. The model and evaluations demonstrated that

vortexing would not occur with the vortex breakers installed. However, additional

evaluation was necessary to demonstrate that the low pressure safety injection,

high pressure safety injection, and containment spray pumps remained operable prior

to transfer from the refueling water storage pool to the containment sump.

The design engineer used available industry information on swirling flow and

vortexing in containmo71 sumps and us'd the video tape of the oaset of vortoxing in

the scale model of the refueling water storage pool to perform a detailed engineering

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evaluation. The engineer determined that the minimum refueling water storage pool

level that would have been required to prevent vortexing was 25.6 inches, which

corresponded to the beginning of a swirling Type 6 (full air core) vortex. However,

'hc minimum refueling water stora3e poollevel achieved when a recirculation

actuation signal occurred corresponded to 13.1 inches. The engineer concluded that

vortexing would have occurred 12.5 inches abave the recirculation actuation signal

setpoint, which corresponded to about 30,000 gallons of refueling water storage

poolinventory. At a rate of 8400 gpm (required combined accident flow rate for the

low pressure safety injection, high pressure safety injection, and containment spray

pumps) from the refueling water storage pool, the pumps would operate for

approximately 4 minutes with vortexing occurring.

The inspectors, in consultation with an NRC reiewer, confirmed that the

methodology employed in Calculation EC-MC7-026, " Required Submergence to

Prevent Vortexing in the RWSP," satisf actorily demonstrated the physical

characteristics to be expected in a design basis accident. The inspectors noted that

this followed the same methodology used in determining the onset of vortexing in

the CSP, which the NRC reviewer had evaluated. The inspectors agreed with the

design engineer's determination that a fuil air core vortex would be generated and

that vortexing would be limited to air ingestion of 2 percent by volume. The design

enginee ased the industry experience described in NUREG CR-2759; the

conclusions in the report " Swirling Flow Problems at intakes," dated 1987; the test

data from *he sca'e model; and the video generated during scale model testing to

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determine that the safety injection and spray pumps remained operable.

The inspectors reviewed the past operr.ility evaluation, interviewed the engineer

who performed the operability evaluation, and assessed the soundness of ti.e

engineering judgment used to conclude that safety systems remained operable. The

inspectors agreed with the conclusion that the low pressure safety injection, high

pressure safety injection, and containment spray pumps would have remained

operable prior to transfer from the refueling water storage pool to the contain. ment

sump. The inspectors noted that the licensee required a detailed evaluation to

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justify past operability and that an NRC reviewer questioned conservatism in the

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licensee's calculation. The f aLure to ensure that design basis information was

properly transferred into a calculation (specification) is considered a violaticn of

Criterion ill (50 382/9724-05).

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c. Conclusions

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After an NRC reviewer questioned conservatism in the calculation for determining

the onset of vortexing in the CS:', the licensee determined that their methodology

was nonconsarvative. The failure to account for recirculation to the tanks, resulting

in a nonconservative determination for the onset of vortexing, is a violation.

E2 Engineering Support of Facilities and Equipment -

E2.1 Enoineerino Evaluation of CSP Loss of Inventerv Due to a Sinole Failure

a. insoection Scoce (37551171707)

The inspectors verified that immediate contingency actions were reason 9ble and had

been implemented and reviewed the engineering evaluation,

b. Observations and Findines

On November 5,1997, during a system review, an engineer discovered that the

CCW makeup system was subject to a single failure that could remdly reduce

inventory in the CSP, thus reducing water available to the EFW system during

accident conditions. Upon discovery, CR 97-2551 was generated to document this

issue.

Several contingency actions were implemented that required operators to take

mamal actions to mitigate the consequences if a single failure occurred. The

contingencies identified the alarms and indications that opuators coula expect to

see and the subsequent actions required to be performed by the operators. The

inspectors verified that the contingency actions were incorporated in the control

room procedures and that the operators understood the requirements.

The engineers completed an operability assessment in a timely manner. The

%ssessment was detailed and addressed all systems that could potentially be

affected by single failure of any one of the CCW makeup isolation valves failing in

the open position during a loss of offsite power. The system tank level switches

were also evaluated for single failure, which coue result in a continuous demand for

CCW makeup. The engineers found that continuous makeup to any of the tanks

would result in flooding areas in the RAB, potentially containing safety-related

equipment.

The engineering ev'aluation concluded that the essential chill water, CCW, Auxiliary

component cooling water, EDG and EFW systems remained capable of performing

their safety function. The inspector agreed with the conclusion in the engineering

evaluation for the ability of the systems to perform their intended safety function.

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LER 97 026, " Single Failure Effects Condensate Storage Pool Inventory," was issued

to address this deficiency. A root cause analysis was in progress and the licensee

,vas in the process of determining whether or not a modification would be required

for the final corrective actions. The LER will be amended when the root cause

analysis has been completed. Routine foilowup review will be per*ormed when the

LER is received,

c. Conclusions

The inspectors reviewed the engineering evaluation and determined that it was

thorough, timely, and addressed the issues appropriately.

E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Insoection Followuo item 50-382/9607-03: Toxic gas detectors not

provided for the south air intake.

This item was initiated to ensure review of the requirements for in-line chlorine and

toxic gas monitors for both the north and south air intakes. The inspectors verified

that, the current configuration raquirement to ha,a toxic gas and chlorir.e detectors

at the north but ntt the south air intake complies with the current licensing basis.

E8.?. (Closed) hsoection Followao item 50 382/9607 04: Leak testing of emergency

intake dampers.

This item was initiated to ensure review of the requirements to perform leak testing

of the emergency intake dampers installed in series in both the north and south fresh

a; intakes. Thr. hspectors determined that the decision to not test the emergency

air intake dampars because they are considered low leakage and because testing

onfirmed they were low leakage complies with their current licensing basis.

E8.3 (Closed) Violation 50-382/9607-05: Failure to implement effective corrective

actions to preclude repetition of the breach of the control room boundary.

This violation resulted from a failure of engineering and operations personnel to have

a self-critical and questioning attitude. Personnel f ailed to question the capability of

a single control room airlock door to maintain control room integrity under

design-basis requirements.

The inspectors verified that the licensee initiated actions to address organizational

performance and facility culture issues and implemented changes to their corrective

action process to increase the sensitivity to deficient conditions. The inspectors

noted that the number of CR identifying deficietit conditions had increased

noticeably. Further, the inspectors noted that an increasing number of design basis

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waaknesses were being identified by plant personnel. The inspectors found these

corrective actions satisf actory.

E8.4 [Closedl Violujon 50 382/9704-06:- Inadequate safety evaluation for containment

isolation valvas.

This violation resulted because a 10 CFR 50.59 evaluation had allowed the licensee _ /*

to credit Valve EFW 224A, EFW flow control, as a containment isolation valve when

it did not meet all the requirements for such credit. From June 11-14,1996,-

operators relied upon Valve EFW-224A as a containment isolation valvo for

62.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />; however, the position indicator for Valve EFW 224A did not meet the

requirements of Regulatory Guide 1.97, " Instrumentation for Light Water Cooled

- Nuclear Power Plants to Assess Plant and Environs Conditions During and Following

an Accident," in that it did not have " direct" position indication.

The inspectors verified the licensee implemented the following corrective actions:

(1) established appropriata guidance in Procedure OP-100-014, " Technical

Specifications and Technical Requirements Compliance," Section 5.2.18.6 to

-prohibit use of the flow control valves as containment isolation valves; (2' prepared

update paget to Updated Final Safety Analysis Report and updated the Technical

Requirements Manual; and (3) provided training to licensing and design engineering

personnel on the event and 10 CFR 50.59 requirements. The inspectors found

these corrective actions satisfactory.

E8.5 [ Closed) LER 50-382/97-001: Regulatory Guide 1.97 containment isolation valve

position indication.

The corrective actions for this event report were the same as

Violation 50-382/9704-06, which was closed in Section E8.4 of this inspection

. report. This item is considered closed.

IV. Plant Suncort

P1 Conduct of Emergency Planning Activities (71750)

P1.1 Biennial Exercise

On November 5,1997, the inspectors participated in the graded biennial exercise. -

The inspectors observed activities in the control room simulator and relocated to the

technical support center when the shift superintendent transferred emergency.

director responsibilities to that facility director. The inspectors observed good

command and contro!in both facilities. Communications within the areas tended to

be complete, three-way communications. However, there were instances when

external communications appeared to be incomplete or misleading. All issues were

- addressed in NRC Inspection Report 50-382/97-18,

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V. Management Meetings

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X1 . Exit Meeting Summary

. The inspectors presented the inspection results to members of licensee management

on December 18,1997. The licensee acknowledged the findings presented.

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Proprietary information reviewed by the inspectors was returned to the appropriate

individuals.

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ATTACHMENI

SUPPLEMENTAL INFORM ATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

E. G. Beckendorf, Superintendent, Security

S. G. Bruner, Manager, Planning and Scheduling '

F. J. Drummond, Director Site Support -

C. M. Dugger, Vice-President, Operations

T. J. Gaudet, Manager, Licens:ng

E. C. Ewing, Director, Nuclear Safety & Regulatory Affairs

C. Fugate, Superinter dent, Operations

P. A, Gropp, Manager, Design Engineering-

J. G. Hoffpauir, Manager, Operations

T. R. Leonard, General Manager, Plant Operations

T. P. Lett, Lead Supervisor, Rad!ation Protection

J. J. Lewis, Manager, Emergency Planning

D. C. Matheny, Outage Manager

D. Matthews, Specialist, tJcensing

- G. D. Pierce, Director of Quality

D. L. Shipman, Maintenance

D. W. Vinci, Superintendent, System Engineering

A. J. Wrape, Director, Design Engineering

INSPECTION PROCEDURES USED

IP 3,551: Onsite Engineering

IP 62706: Maintenance Rule

IP 62707: Malntenance Observations

IP 61726: Surveillance Observations

IP 71707: Plant Operations

IP 71750: Plant Support Activities

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_IP 92901: _ Followup - Operations

IP 92902: Followup - Maintenance

-- IP 92903: - Followup - Engineering

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i ITEMG OPENED, CLOSED, AND DISCUSSF.D

Ooened

50-382/9724-01 VIO Inadequate instructions provided in a WA

for Valve CC-835B (Section 02.1).

50-382/9724-02 URI Dirt and debris in RAB floor drains (Section 02.2).

50 382/9724-03 IFl Review workaround evaluations (Section 08.3)

50-382/9724-04 NCV Failure to comolete the surveillance for flow low bypass

(Section 08.5).

50-382/9724-05 VIO Vortexing calculation not adequate (Section E1.1)

Clated

50 382/96-004 LER Failure to meet intent of Technical Specification

surveillance because of inadequate corrective actions

(Section 08.1).

50-382/96-006 LER Reactor trip following a failure of the CED M/G set

voltage regulator (Section 08.2).

50-382/96-025/01013 EA Failure to preclude voids in the Auxiliary component

cooling water system (Section 08.3).

50-382/96-025/030 4 EA Failure to properly test the Auxiliary component cooling

water system (Section 08.4).

50-382/97-005 LER Failure to perform flow low bypass surveillance

(Section 08.5).

50-382/9724-04 NCV Failure to complete the surveillance for flow low bypasu

(Section 08.5).

50-382/97-025 LER Gag for Valve CC-835B was partially engaged

iSection 08.6).

50-382/9701-01 VIO Failure to include the containment atmosphere relief

systern into the maintenance rule program

(Section M8.1).

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50 382/9701-02 VIO Fail'are to monitor the unavailability of various plant j

- systems (Section M8.2).

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50 382/97-025/02014 EA Change in the scope of a WA without the originators I

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review (Section M8.3).

50-382/9607-03 IFl Toxic gas detectors not provided for the south air intake

(Section E8.1).

50 382/9607-04 :IFl Leak testing of ' emergency intake dampers

(Section E8.2).

50-382/9607-05 VIO Failure to implement effective corrective actions to

preclude repetition of the breach of the control room

boundary (Section E8.3).

60 382/9704-06 VIO Inadequate safety evaluation for containment isolation

valves (Section E8.4).

50-382/97-001- LER Regulatory Guide 1.97 containment isolation valve

position indication (Section E8.5).

LIST OF ACRONYMS USED

~ CCW compone:.i cooling water

CFR Code of Federal Regulations

CR conditbn report

CSP condensate storage pool

EA enforcement action

EDG- emergency' diesel generator

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EFW emergency feedwater

fgprn gallons per minute ,

IFl - inspection followup item

'LER licensee event report

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- M/G . : motor / generator -

-MPFF maintenance preventable functional failure

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NCV noncited violation-

NRC Nuclear Regulatory Commission

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PDR public document room -

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RAB: - reactor auxiliary building -

VIO violation

URI unresolved item

.WA work authorization '

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