ML20199E197

Rev 1 to Insp Repts 50-498/97-05 & 50-499/97-05 on 970629-0809,correcting Errors in Numbering of Insp Followup Sys Open Items & Some Items Identified in Executive Summary

ML20199E197
Person / Time
Site:	South Texas
Issue date:	11/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199E133	List: ML20199E129 ML20199E197
References
50-498-97-05, 50-498-97-5, 50-499-97-05, 50-499-97-5, NUDOCS 9711210119
Download: ML20199E197 (32)

See also: IR 05000498/1997005

Text

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ENCLOSURE 2

Revision ;1.

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV-

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Docket Nos: 50 498,-50-499-

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License Nos: NPF-76i NPF 80

Report No. . 50-498/97-05, 50-499/97 05

Licensee: Houston Lighting & Power Company

- Facility: South Texas Project Electric Generating Station,

Units 1 and 2

Location: 8 Miles West of Wadsworth on FM 521

Wadsworth, Texas 77483

Dates: June 29 through August 9,1997

Inspectors:- D. P. Loveless. Senior Resident inspector

J. M. Keeton, Resident inspector '

W. C. Sifre, Resident inspector

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D. B. Pereira, Project Engineer

R. A. Kopriva, Project Engineer, Branch A - -

- Accompanying ,

Personnel: J. C. Edgerly, Resident insocctor Trainee

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Approved by: J. l. Tapia, Chief, Project Branch A

Division of Reactor Projects

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EXECUTIVE SUMMARY- -

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- Revision 1

South Texas Project, Units '1 and 2 - ,

NRC Inspection Report 50-498/97-05:50-499/97-05

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This resident inspection included aspects of licensee operations, engineering, maintenance,

andl plant support. The report covers a 6 week period of resident inspection.  ;

Qoerations f

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• - Control room _ operators performed their duties in a professional manner, were

- attentive to control board indications, and maintained a good focus on safety

(Section 01.1). ,

• The failure to tr'ack the Technical Specification action statements associated with  ;

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j !- the inoperability of the hydrogen' analyzer was in violation of administrative

requirements. This condition continued for 7 days without identification by on shift - -4

operators,~ This nonrepetitive licensee identified and corrected violation is being ,

treated as a noncited violation, consistent with Section Vll.B.1 of the MEG:

Enforcement Policy (Section 01.2).

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• Incomplete corrective action for a previous event resulted in an inadvertent partial

drain down of the Unit 1 spent fuel pool (Section 01.3).

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• Plant systems were maintained in good material condition. The instrument air

4 system and selected containment isolation valves were prop-ly aligned

(Sections 02.1, 02.2 and O2.4). ,

• A reactor plant operator exhibited good attention to detail and safety system

knowledge by identifying low hydraulic fluid level in a power operated relief valve

(Section O2.3).

• One example of an inadequate equipment clearance order resulted in an inadvertent

start of a Unit 2 essential cooling water screen wash booster pump while the

system was drained (Section 04.1).

Maintenance

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i- * Planners failed to identify that painting of the air start solenoids could adversely

affect Standby Diesel Generator 11 operability (Section 02.1).

• In general, maintenance activities were performed in accordance with

management's expectations, However, several examples of the failure to properly

implement maintenance related programs were discussed (Section M1.1).

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• Surveillance test procedures were well performed and properly implemented

- -Technical Specification surveillance requirements (Section M1.2).

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• Craf tsmen did not initially remove plastic bags from containment as required by the

containment inspection procedure. Previous corrective actions were inadequate to

ensure that plant workers fully understood the requirements of Technical

Specifications regarding loose debris in containment (Soction M4.1).

• A second example of the failure to establish an effective equipment clearance order

boundary was identified when craftsmen breached an unisolated portion of the

component cooling water system. In addition, craftsmen had prior opportunity to

identify this condition (Section M4.2).

Ennineerinn

• The actions of the engineers in stopping the attempted removal of the essential

cooling water structure gantry crane was notable. The recalculation of the crane

weight and potential impact on operability of the essential coolirig water systems

were considered to be conservative (Section E1.1).

• The f ailure to perform adequate surveillance testing of the Pressurizer Pressure

Interlock P 11 was a violation of Technical Specification surveillance requirements.

This nonrepetnNe licensee-identified and corrected violation is being treated as a

noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

(Section E2.1).

• The identificatirn of surveillance testing inadequacies associated with

Permissive P-11 during an operational experience review was considered to be

excellent (Sec ion E2.1).

• Maintenance and engineering personnel properiy evaluated the causes of a fire that

initiated dunng a leak sealing evolution on main steam isolation Valve 2D. The

associated temporary modification package was properly developed and reviewed.

The use of an injection clamp during this evolution was considered conservative

(Section E2.2).

• The licensee's f ailure to assure that all of the requirements of IEEE 338-1997,

Regulatory Guide 1.22, and Regulatory Guide 1.118, related to removing the AFW

and containment spray systems from service, were correctly translated into the

applicable procedure for testing of the AFW system was a violation. This

nonrepetitite, licensee identified and corrected violation is being treated as a

noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

I (Section E2.3).

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Plant Sufw_QLt

• Routine observations of radiological work practices indicated that controls were in

place and effective with one minor exception. Several contaminated area signs

were not properly secured and had f allen down (Section R1.1).

• Routine observations of daily security force activities, secondary chemistry controls,

emergency response facility readiness, and meteorological tower operability

indicated appropriate management attention to these functional areas

(Sections R1.2, P2.1, P2.2, and S1.1).

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Summary of Plant 'Statug -

At the beginning of this inspection period, Unit 1 was subcriticalin Mode 2 after having '

completed drop testing of the rod cluster control assemblies.- The reactor was made

critical at 12:04 a.m. on June 29, and Unit 1 was returned to full power on June 30. - At- '

the end of this inspection period,-Unit 1 was operating at 100 percent steady state power.

Unit 2 operated at essentially 100 percent reactor power throughout this inspection period.

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. !. Operations

01 Conduct of Operations

01.1. Control Room Observations (Units 1 and 21

a. Inspection Scope (71707)

- Using inspection Procedure 71707, the inspectors routinely observed the conduct of

operations in the Units 1 and 2 control rooms. Frequent reviews of control board

status, routine attendance at shift turnover meetings, observations of operator

performance, and reviews of control room logs and documentation were performed,

The inspectors observed portions of the following evolution in addition to full power

operations:

• Unit 2 response to fire in the isolation valve cubicle (July 15)

b. Observations and Findinas

During routine observations and interviews, the inspectors determined that the

control room operators were continually aware of existing plant conditions.

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Operators responded to annunciator. alarms in accordance with approved

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procedures. Annunciator alarms were promptly announced to the control room staff

who, in turn, acknowledged by restating the announcement. The inspectors

routinely attended shift turnover meetings. The on shift operators provided clear

and concise information to the oncoming operators. Oncoming operators routinely

reviewed the control room logs, discussed current plant conditions, and verified

major equipment status.

On July 15, maintenance personnel were repairing a leak on Main Steam Isolation

Valve 2D. The mechanics stopped work momentarily and exited the Isolation Valve

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Cubicle (IVC) to take a break from the heat. A security officer entered the IVC as

. part of his routine tour. Shortly af ter entering the IVC, the of ficer reported by

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1 telephone to the Unit 2 control room that he observed a fire on the lagging adjacent

to Main Steam Isolation Valve 2D The inspector was in the control room when this

call was received and observed that the shift supervisor questioned the security

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officer as to whether he observed smoke, steam, or a flame. The officer stated that

he observed a small flame. As the shift supervisor was activating the fire brigade, a

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second call came into the control room from the IVC. One of the mechanics

reported that he used a fire extinguisher to put out the fire. The shift supervisor

subsequently dispatched the fire brigade leader to verify that the fire was out and

notified management of the event.

The inspector discussed the quest;oning of the security officer with the shift

supervisor. The shif t supervisor stated that the lagging was not flammable and he

was not aware of any other burnable materialin the vicinity of the valve. The shift

supervisor also stated that a steam leak was much more likely to occur on the valve

and would require different action than a fire.

The fire brigade leader determined that the fire was out. The inspector entered the

IVC and observed that the fire had occurred on a small area of frayed lagging where

some material from the leak repair had spilled. The mechanic stated that the

material used in the leak repair was not supposed to burn. A condition report was

written to investigate the cause of this event. The investigation and cause of this

event is discussed in Section E2.2 of this report. The shif t supervisor posted a fire

watch in the area until no danger of reflash existed.

c. .Qonclusitrls

Licensed operators in the control room performed in a professional manner and were

continuously aware of existing plant conditions with a good focus on safety. Shift

turnover meetings were thorough and routinely attended by plant management. The

response to annunciator alarms was prompt and accurate. The Unit 2 shift

supervisor took prompt, conservative action in resnonse to a reported fire in the

IVC.

01.2 Incorrect Trackina of Technical Specification Action Statement

a. Inspection Scone (71707)

On June 18, a licensed operator discovered that an incorrect operability assessment

system (OAS) entry had been made when the Unit '2 Hydrogen Analyzer CM 4105

was found to be inoperable. The inspector reviewed Condition Report 97-10207,

the procedures as.cociated with OAS entries, and corrective actions proposed by the

licensee.

b. Observations and Findinas

On June 11, Hydrogen Analyzer CM-4105 f ailed a surveillance test, indicating that

the ana' rzer was inoperable. Licensed operators created an OAS entry to track the

action statement associated with Technical Specification 3.6.1.4. This action

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-statement required.that the analyzer be returned to service within 30 days or the

unit be shut down/

However, the operators failed to recognize.that Technical Specification 3.3.3.6 was.

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also_ applicable. This specification required that the accident monitoring function of

the hydrogen analyzer be returned to service within 7 days or the unit be placed in

hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

On June 18, during restoration of the hydrogen analyzer following corrective

maintenance, an operator discovered that the OAS entry did not include the most

restrictive Technical Specification action statement. Operators initiated Condition

Report 0710207 to investigate the problem and determine the root cause and

corrective actions required. Although the 7 day allowed outage time had expired,

the hydrogen analyzer had been returned to service with approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />

remaining in the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> permitted to shut the unit down. In accordance with

. guidance recently issued in Enforcement Guidance Memorandum 97 013, a

Technical Specification violation did not occur because the time clock of the action

-statement had not expired.

The inspectors reviewed Plant General Procedure OPGPO3 ZO-0039, Revision 9,

" Operations Configuration Management." Section 5.5 provided guidelines for

making OAS entries and stated, in part:

"When any of the following systems / components are removed from service,

THEN an OAS entry SHALL be initiated if the inoperability is expected to

extend beyond the current shift and the system / component is required for

the current plant mode,

a. Equipment required by Technical Specifications"

The operators. violated this requirement in that they failed to identify and enter the

most restrictive Technical Specification action statement.

- The corrective actions identified in the condition report require development of an

on-line program that would flag any applicable Technical Specification when making

OAS entries. Also, additional training of licensed operators in the identification of -

multiple Technical Specification requirements has been proposed during applicable

simulator training.

The inspector reviewed the violation and determined that: the violation was

' identified by licensee personnel; corrective actions had been developed to ensure

that multiple Technical Specification requirements will be reviewed; the violation

was.not a repeat of a previous violation or finding; and the violation was not willful.

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Therefore, this non repetitive, licensee identified and corrected violation is being

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treated as a noncited violation, consistent with Section Vll.B.1 of the N3Q

Enforcement Policy (NCV 499/97005-01),

c.. Conclusion

-The inspectors concluded that a violation of administrative requirements had

occurred and was a result of less than adequate procedural guidance to ensure that

all applicable Technical Specifications were considered when making OAS entries.

. This condition existed for 7 days without identification by oncoming crews.

01.3 Inadvertent Partial Drain of Soent Fuel Pool (Unit 21

a. 'Insoection Scope (71707)

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On June 19, mechanical maintenance technicians placed a submersible pump in the

annulus between the inner and outer gates that separate the spent fuel pool and the

fuel transfer canalin Unit 2. The pump was installed to drain the annulus between

-the gates to f acilitate postmaintenance testing of the inner gate seal. At 1:05 p.m.,

the Unit 2 control room received a Spent Fuel Pool Hl/LO Level alarm. Upon

investigation, the field supervisor found that the spent fuel pool level was

66 feet (= 20.1 meters) mean sea level (msl),2 inches (= 5.1 centimeters) lower

than the earlier logged level. Water was draining from the spent fuel poof past the

uninflated inner gate seal, through the deenergized pump and hose into the fuel

transfer canal. The hose was removed, the gate seal was inflated, and the spent

fuel pool level restored. Condition Report 97 10274 was developed to address this

event. The inspectors reviewed this report and the associated procedures,

evaluations, and licensee investigations.

b. Observations and Findinas

An event review t .,a was assembled to investigate the event. The investigation

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determined that upon completion of the inner gate seal replacement and prior to

inflating the seal, the craftsmen placed the submersible pump in the annulus

between the gates with a discharge hose going to the fuel transfer canal. At

approximately 11:30 a.m., the craft energized and ran the pump for approximately

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15 seconds to verify proper pump rotation. This was later determined to have

started a siphon pathway through the idle pump.

Next, the craftsmen contacted the unit supervisor to have an operator connect and

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operate the air source to the sealin accordance with Plant Maintenance

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Procedure OPMPO4-FH-0005, Revision 4, "In Containment Fuel Storage Area and

Spent Fuel Pool Gate Removal and Installation." The unit supervisor informed the

mechanic that an operator was 'not available. The craftsmen then informed the unit

supervisor of the status of the job and that they would be leaving the area to break ,

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for lunch. The unit supervisor directed the craf tsmen not to run the pump until an

operator was present and the gate seal was inflated. Howevu, the craftsmen failed

to inform the unit supervisor that they had momentarily run the pump. The siphon

continued to drain the pool.

The inspector reviewed the condition report engineering evaluation to determine the

postulated finallevel of the spent fuel pool if the siphon had continued undetected.

In the evaluation, the engineerir.g staff conservatively assumed the initial fuel

transfer canal level was 3 feet (= 0.91 meters) lower than the spent fuel pool level.

The actual difference in level was approximately 2 feet (= 61 centimeters). Based

on the calculation, the lowest level the spent fuel pool could have achieved was

65 feet,8 inches (= 20.0 meters) msl. The minimum level permitted by Technical

Specifications was 62 feet (= 18.9 meters) msl. Therefore, the safety significance

of this event was low.

Licensee personnel determined that the root cause of this event was ineffective

correctivo action from a previous spent fuel pool siphoning event documented in

NRC Inspection Report 50-498/95-23; 50-499/95-23. The corrective actions for

the ptr%us event were too narrow in scope and did not address the potential fo,

personnel other than operators to be involved in activities that could cause

inadvertent siphoning of the spent fuel pool.

The corrective actions for this event included a revision to

Procedure OPMPO4 FH-0005 to require that an operator be present to coordinate

the installation and operation of submersible pumps in the spent fuel pool.

c. ,Gonclusions

Although of low safety significance, a repeat of a previous inadvertent siphoning

event represents a failure to adequately control the use of submersible pumps in the

spent fuel pool and connecting systems and a lack of rigor in the development of

previous corrective actions.

O2 Operational Status of Facilities and Equipment

02.1 Plant Tours (Units 1 and 2)

a. inspection Scone 171707)

The inspectors routinely toured the accessible portions of plant areas in Units 1

and 2. Areas of special attention during this inspection period included:

• Units 1 and 2 auxiliary feedwater cubicles

e Standby diesel generator Rooms 11 and 12

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• Unit 1 fuel-handling building

• lsolation Valve Cubicles 1 A,1D, and 2B

• Units 1 and 2 turbine-generator buildings

b. Observations and Findinas

in general, the inspectors observed that in both units, systems and components had

been maintained in good material condition. However, the inspectors noted several

minor labeling problems during a tour conducted inside the Unit 2 containment

building. These inaccuracies were reported to the unit supervisor for correction.

On July 17, the inspectors toured Standby Diesel Generator * 1. Painting activities

were in progress in accordance with Work Authorization 97392. The work order

authorized pain'ing of the diesel below the catwalk and indicated that this would

not affect critical components. During the tour, the inspectors noted a technician

painting one of the air start solenoids. Excessive paint on the vent screen of this

component could cause the failure of the diesel to start.

The inspectors discussed this with the unit supervisor. He stated that during the

projob briefing, a prohibition on painting of screens had been emphasized. in

addition, he stated that the postmaintenance tect would , iclude an engine start and

run. However, the inspectors noted that a run of the machine was not documented

in the postmaintenance test matrix of the work order. The unit supervisor ensured

that this was added to the package. The inspectors verified that this run was

satisf acto.ily conducted on July 28,

c. Conclusions

The inspectors concluded that the material condition of systems and components

observed in both units was noteworthy. The postmaintenance test matrix for

testing a standby diesel generator following painting did not consider that the air

start solenoids were critical components that could be adversely affected by

painting and did not require a diesel run to verify that this was not the case.

02,2 Containment Isolation Valve Alinnment

a. In_soection Scoce (717021

The inspector reviewed the configuration and status of containment isolation valves

as described in the Updated Final Safety Analysis Report Section 6.2.4 and

Figure 6.2.41. The described configuration was compared to associated piping and

instrumentation diagrams, and with Plant Surveillance Procedure OPSPO3 SI-OO16,

Revision 2, " Containment Integrity Checklist." The inspectors also verified the

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configuration of valves associated with the isolation of a sample of' mechan' cal-

penetrations,

b. IObservati2ns and Findinas

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The inspectors verified that the sample of penetrations were aligned properly? All

penetrations identified in Figure 6.2.41 were shown in the positions indicated in the

piping and instrumentation diagrams. However, several discrepancies were noted.

- Penetrations M 71 and M 87, the integrated leak rate test penetrations, were not-

shown on Figure 6.2,41. The inspectors verified that the penetrations were still-

installed and required a locked closed valve and a blank flange to provide ~ '

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During a review of Procedure OPSP03 SI-0016, tno inspectors noted that the

manual valves associated with 10 penetrations were not included on the outside '

containment integrity checklist. The following penetrations were affected:

.* Three trcins of component cooling water to the residual heat removal system

• Penetration M 3J

• Penetration M-35

• Penetration M-37

• Three trains of component cooling water to the reactor containment fan

coolers

• Penetration M 24

• Penetration M-25

• Penetration M 27

• - Four trains of auxiliary feedwater to the steam generator

• . Penetration M 28

• Penetration M 84

• Penetration M 94

• Penetration M-95

' Procedure OPSP03-SI-0016 implemented the requirements of Technical

Specification Surveillance Requirement 4.6.1,1.a. This specification required that:

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Primary containment integrity shall be demonstrated at least

.once per 31 days by verifying that all penetrations not capable

of being closed by operable containment automatic isolation

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valves and required to be closed during accident conditions are

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closed by vaives,- blind. flanges, or deactivated automatic

valves secured !n their positions  ;

Licensee engineers stated that the penetrations addressed _were not required to be

closed _during accident conditions. Therefore, the specification was not considered --

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applicable to the'.10 subject penetrations. However, the inspectors noted that

certain manual valves providing isolation of piping within the penetration isolation

scheme were not capable of automatic closure and _were required to be closed ,

during accident conditions.

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-The applicabliity nf Technical Specification 4,6.1.1.a to the manual valves

sssocle'ed with the 10 subject penetrations will be reviewed further by the NRC.- in

additionilicensee personnel were reviewmg the two penetrations not documented in

the Updated Final Safety Analysis Report. These issues will be tracked as an

' - unresolved item (URI 498;499/97005 02).

c.- .Cpnclusions

Two mechanical wntainment penetrations were not described in Figure 6.2.4-1-of

the Updated Final Safety Analysis Report. The applicability of Technical

Specification 4.6.1.1.a to the manual valves associated with 10 containment

nenetrations remeined unresolved,

O2.3 Reactor Plant Operator Tours (71707)

The inspectors routinely discussed plant conditions with the reactor plint operators

in the field. On July 31, a reactor plant operator identified low hydraulic fluid level

in the Steam Generator Power-0perated Relief Valve 28 actuator during his routine

- rounds. The valve was declared inoperable and removed from service and

subsequently repaired. The reactor plont operator exhibited good atter. tion to detail

and safety system knowledge.

'02.4 Enaineered Safetv Features Walkdown of Instrument Air System (71707.1

On July 20, the inspectors performed a we"tdown of the instrument air systems

from the compressors to the distribution headers in Units 1 and 2. The material

condition of the systems was good. Minor deficiencies were identified and -

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appropr 3tely documented by the licensee staff. The system flow path was verified

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- to be 'a accordance with Piping and Instrumentation Diagrams 8Q119FOOO48

Sheet 1 and 80119F00049, No alignment discrepanCes were identified and the

system components appeared to be in good condition.

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04 ~ Operator Knowledge and Performance

04.1 Essential Cootino Water Screen Wash Booster Pomo 2A Inadvertent Start

On June 24, the Unit 2 operating staff removed the Train A essential cooling water

system from service and established Equipment Clearance Order 97-76518 for

planned maintenance activities. The system was also drained to support the

maintenance activities. One of the maintenance activities was the replacement of a

relay in the screen wash booster pump logic circuit in accordance with Design

Change Package 95 14323-4, During the relay installation, Screen Wash Booster

Pump 2A, o safety-related pump, inadvertently started, Condition Report 97-10415

was developed to address the f ailure of Equipment Clearancu Order 97 76518 to

prevent the pump from starting with the system drained.

The pump operated for approximately ten minutes with the system drained before it

was secured by a control room operator. Following completion of maintenance

activities and filling and venting of the essential cooling water system, Screen Wash

Booster Pump 2A was tested. All acceptance criteria for flow, pressure, and

vibration were met in accordance with Plant Seveillance

Procedure OPSP03-EW-0017. Revision 10, "Essudi I Cooling Water Train A

Testing." Personnel safety was not affected since .ere was no work being

' performed on the pump or screen wash system during the inadvertent start. This

event was the result of an inadequate equipment clearance order boundary.

The inspectors reviewed Plant General Procedure OPGPO3-ZO-ECO1, Revision 6,

" Equipment Clearance Orders." Procedure OPGP03-ZO ECO1 required that

squipment clearance orders provide adequate boundaries to ensure personnel safety

and equipment integrity. The execution of Equipment Clearance Order 97 76518

did not properly implement this safety related procedure. The failure to properly

implement this safety related procedure was the first example of a violation of

Technical Specification 6.8.1 (498;499/97005-03).

II. Maintenance

M1 Conduct of Maintenance

M 1.1 General Comments on Field Maintenance Activities

a. Insoection Scone L62707)

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The inspectors observed portions of the following on-going work activities identified

by their work authorization numbers:

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Unit 1: :-

e: 95013550 - Bench Test Charging Pump Cooler Air Handling' Unit 11 A/

- Component Cooling Water Return Pressure Relief Valve

(June 30)

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e- 114733 Rod Cluster Control Assembly Tool Repairs (July)17,21)'

e 347683 Residual Heat Removal Purap 18 Flange Leak Repair and

, Impeller inspection (July 21)

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iUnit 2: _

e- 114761 Steam Generator 2A' Main Steam Pressure Low Alarm

Lead / Lag Card and.Comparator Card Replacement and

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Calibration (July 16)_

e' 347818 Steam' Generator 2D Main Steam isolation Valve has a Small

Hissing Steam Leak at the Body-to-Bonnet-Flange

b. Observations and Findingg e

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in general, the inspectors found the work performed during those activities thorough

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--and conducted in a professional manner. The work was performed by-

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knowledgeable, qualified technicians utilizing ar. proved procedures. Supervisors

were observed providing an appropriate level of oversight. System engineers were

observed providing. quality technical support as needed. Prejob briefings were

thorough and radiological controls were in place where applicable. However,.

exceptions to these general findings were identified as discussed below and in

Sections M4.1, M4.2, and M8.1 of this inspection report.

--During the observation of activities being performed in accordance with Work.-

Authorization Number 95013550, the inspectors noted several minor discrepancies.

Worker understanding of the procedural requirements was weak. Measurements

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taken were not precise en'ough to measure the stated parameter. The inspector

observed several minor deviations from the procedure during this performance.

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Although_ workers deemed the actions to be technically equivalent to the procedural _

requirements, the inspector discussed expectations for procedural compliance with

the technician's management.

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On July 22, the inspectors observed portions of the leak sealant injection performed

4 - - on main steam isolation Valve 2D. The injection was being performed by contract

- personnel in v.:cordance with Temporary Modification TL2 97-8224-2. The work

.was_ properly performed by qualified technicians with proper oversight by licensee

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supervisory personnel. The work was performed utilizing the appropriate nuclear

grade leak sealant and was conducted in accordance with the vendor procedure, as

revised. The review of an earlier event associated with this work activity was

documented in Sections 01.1 and E2.2 of this report.

c. CDardnipnf

in general, the observed r.wintenance activities were conducted in a professional

manner. Personnel involved were thorough and mct management's expectations for

the implementation of the maintenance program. However, several minor

discrepancies were observed during the testing and replacement of a relief valve.

M1.2 Grneral Comments on Surveillance Testina

a. Inspection Scope (01726)

The inspectors observed portions of the following surveillance activities:

Unit 1:

• Plant Surveillance Procedure OPSP03-AF-0003, Revision 6, " Auxiliary

.%edwater Pump 13(23) Inservice Test"

Unit 2:

• Plant Surveillance Procedure OPSP02-RC-0455, Revision 5, " Pressurizer

Pres.sure ACUT"

b. Ouservations and Findinn.)

The inspectors found that the observed surveillance activities were performed in

accordance with approved procedures. The inspectors verified that the test

equipment calibrations were current. Good communications between the control

room operators and personnel performing the tests were r oted. Protest briefings

were thorough and comprehensive. During the testing of Auxiliary Feedwater

Pump 13, the inspectors noted several minor material deficiencies associated witt

valves in the pump discharge fbwpath. Thess were reported to the reactor plant

operators performing the test and condition reports were written to correct the

problems, in addition, the performance of Procedure OPSP02 RC-0455 was furthei-

discussed in Sections M8.2 and E2.1 of tHe inspection report.

c. Conclusions

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The surveillance activities observed were performed in accordance with the  !

applicable Technical Specification surveillance requirements and approved  !

procedures. Minor material deficiencies ass 9ciated with system valves were l t

documented for correction.  ;

M4 Maintenance Staff Knowledge and Performance  !

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M4,1 Plastic Materials in Containment

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a. insocction Scope -(61726)  !

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On July 21, the inspectors observed the performance of work on Residual Heat i

Removat Pump 1B performed in accordann with Work Authorization ,

Number 347083. Upon rempletion cf a cc,ntainmer' entry, the craftsmen removed

their equipment and performed a visualinspot. tion of the area in accorrience with i

Plant Surveillance Procedure OPbP03 XC-0002A, Revision 1, * Partial Containment ,

inspection (Containm::nt Integrity Established)." The inspector noted that the i

craf tsmen had left three plastic bags containing vibration probes. The craftsmen ['

stated that bagging and leaving instrumentation was a standard practice. However,

the unit supervisor was notified and he directed that the bags be rernoved. The- i

inspectors re"lewed this occurrence,

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b. Observations and Findinaji

Procedure OPSP03 XC 0002A, Form 2, Step 3.0 stated that the craftsmen shall, r

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" Perform an inspection of the affected portion (s) of

Containment AND travel route (s) to and from the work area (s)

and ensure NO loose materialis present. Document any  ;

discrepancies in the Remarks section of this form."

The procedure defines loose debris as, "any material that could become debris and -

possibly contribute to blocking the Emergenc/ Sump Screens during Cssign Basis '

Accident conditions in Containment."

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The f ailure of the craftsmen to initially remove the plastic bags from the work site

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was not a violation because the inspecter prompted them to further evaluate the

condition.- In addition, the contribution o? three plastic bags to blocking the sump ,

screens would be negligible. Hoviever, this occurrence indicated that conflicts

existed between work procec'ures and the containment inspection procedures. As

documented in NRC Inspection Report 50-498/97-02:50 499/97 02, previous

problems associated with containment inspection were cited as a repeat violation.

Licensee corrective actions, at that time, had not been adequate to ensure that

materials were properly removed from primary containment. The inspectors  ;

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expressed concern that workers Pill did not understand the Technical Specification

requirements to remove allloose i.iaterial from containment,

in discussions with sevmalindividuals, the inspectors noted that some workers

misundersmod prov!. ions of Revision 1 to Procedure OPSP03 XC 0002A, The

proceduto Ated that, "any material discovered must be removed from the RCB and

evaluated by a Senict Reactor Operator." Addendum 1 then provided the senior

reactor operator with guidance for evaluating the condition. The individuals

interviewed stated that if material met the acceptance criteria delineated in the

guidance that it was acceptable to leave the materialin containment. This did not

conform with the procedural requirements.

Maintenance personnel documented the occurrence in Condition Report 97 11630.

The liennsco determined that the apparent cause of the event was the failure of the

instrumentation and controls technicians to communicate their intent to leave the

bags in containment with the unit supervisor. Corrective actions proposed included

shop discussions of the event and of the requirements of

Procedure OPSP03 XC 0002A,

c. CQDrdu210M

Maintenance personnel f ailed to initially remove plastic bags from containment upon

completion of a containment entry. The inspectors determined that, previous

corrective acilons had failed to ensure that maintenance workers understood the

,

Technical Specification requirements to remove allloose material from containment.

Conflicts between standard work practices and the containment inspection

requirements went unchallenged.

M4.2 Inndecsate Eauipment Ciearance Order for Residual Heat Removal Punip_111

Maintenance Activitie.g

a. IDERection Scongj6_2707)

On July 21, the inspectors observed portions of the Residual Heat Removal

Pump 1B flange leak repair and impeller inspection. During the pump disassembly,

mechnical maintenance personnel disconnected the component cooling water lines

to the pump seal cooler and observed considerable flow of water from the lines.

The mechanics initially attributed the water to the draining of long lines to the

isolation valves. When the flow did not subside, the mechanics realized that the

component cooling water system had not been isolated. They promptly

r econ. . d the component cooling water htting to stop the leak and contacted

their supervisor and the control room. The inspectors reviewed this event, the

licensee's response, and the associated documentation.

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b. Qhservations_gnd Findinns

When the crew began the pump disassembly, the health physics technician asked

one of the mechanics if the line connected to the seal cooler was a contaminated

cynM*n. The mechanic stated that it was component cool!N water and was not

contaminated. He also stated that they would have to disconnect the line. The

inspector asked the mechanic if the component cooling water system boundary was

part of Equipment Clearance Order 97 1 71009. The mechanic stated that he

would walk down the component cooiing water portion of the equipment clearance

order bocause he was not certain that the line was included in the equipment

clearance order. Af ter this discussion and before disconnecting the component

cooling water line, the mechanics took a break and exited the reactor containtnent

building.

As the mechanics resumed the pump disassembly, the inspector observed water

dripping from the seal coc,ler fittings as they were being loosened. When the

inspector questioned the mechanics about the water, one of the mechanics stated

that the drainage was expected because the line between the seal cooler and the

equipment clearance order boundary valve um ong. Withire a minute it became

clear to the mechanics that the water flow was not det esing and they

reconnected the line to stop the leakage. The lead mechanic stopped the job and

determined that the component cooling water line was not included in the

equipment clearance order. The equipment clearance order was revised, the line

isolated, and the work completed as planned.

Condition Report 97 11659 was developed to address the inadequate equipment

clearance order. This event was identified as a significant condition adverse to

quality, and an event review team was assembled to determine root cause and

recommend corrective actions. The event review team identified the following root

causes:

• The work package did not identify the need to establish a component cooling

water boundary,

• The job scope was not fully understood by either the equipment clearance

order preparer not reviewitt,

• The equipment clearance order acceptor did not adequately walk down the

boundary.

The inspectors reviewed Plant General Procedure OPGP03-ZO EC01, Revision 6,

• Equipment Clearance Orders." Procedure OPGP03 ZO ECO1 required that

equipment clearance orders provide adequate boundaries to ensure personnel safety

and equipment integrity. The execution of Equipment Clearance Order 97-1 71609

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did not property implement this safety related procedure. The failure to properly

implement this safety related procedure was the second example of a violation of

Technical Specification 6.8,1 (498;499/97005 03).

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c. Conclusions

This event and the event discussed in Section 04.1 of this inspection report nave

regulatory significance because equipment clearance orders establish necessary

boundaries to protect critical equipment and to ensure personnel safety. Both of

these events were of. low safety significance because the consequences were

relatively inconsequential. _ However, the f act that neither personnel safety nor

equipment integrity were jeopardized cannot be attributed to the equipment

clearance order quality. This event disclosed, non repetitive, licensee corrected

violation is being cited because the licensee had prior opportunity to identify the

inadequate equipment clearance order when the mechanics discussed the need to

walk down the component cooling water boundary.

M8 M!scellaneous Maintenance items (92902)

M8.1 Use of Liftina Device Without Proper inspection (93001)

On July 17, during an observation of activities being performed under Work

Authorization Number 114733. The inspectors observed a problem associated with

,.

the use of a temporary lifting device. Workers in the fuel handling building

determined that an additional hoist was desirable while removing a refueling tool

from the spent fuel pool. An electric hoist attached to a rail mounted trolley on the

_

refueling machine was utilized. The inspector asked the craftsmen and operators

present and was mformed that no one had performed a daily inspection of the

trolley, as required by the licensee's lifting program. Management was informed of

the problem, and Condition Report 97 12532 was written to document the

occurrence and evaluate appropriate corrective actions.

M8.2 (Closed) Licensee Event Report 50 498/97-007: Engineered Safety Features

Actuation System Pressurizer Pressure System Interlock Not Fully Tested by

Surveillance

..

This event was documented in Section E2.1 of this inspection report. The

,

licensee's corrective actions included: immediato implementation of Technical

Specification surveillance requircments; revision and reperformance of the

appropriate surveillance test procedures; additional training for surveillance

procedure writers; and the addition of new testing methodology in the surveillance

procedure writer's guide to be completed by December,1997.

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E1 Conduct of Engineering

E1,1 Demovpl and Dismantlinn of Crane Attached to Seismic Structure

a. Inspection Scop _e (37551)

The inspectors reviewed the documentation associated with the removal of the

essential cooling water intake structure gantry crane. The potential for a large load

drop on the roof c" the seismic structure was evaluated. The following documents

were reviewed:

• Unreviewed Safety Question Evaluation 97-0023, " Load Drop Evaluation for

ECW Gantry Crane Removal."

• Condition Report Engineering Evaluation (CREE) 97 7961 2

• Calculation CC 8411, Revision 1

• Plant Chango Form PCF334999A

• Plant General Procedure OPGP03-ZA 0069, Revision 9, " Control of Heavy

Loads"

6. Qhiny31 ions and Findinna

On July 22, an attempt was mado to remove the gantry crano from the essential

cooling water intake structure. The lif t attempt was terminated when the mo'>ilo lif t

crano's load cellindicated that the load was at the admireistrativo limit allowed by

CREE 97 79612 and CREE 97 7961-0 and near the safe operating limits of the

mobile lif t crano for the operating radius and boom length. The gantry crane was

then unhooked from the rigging and returned to the tio down location where it was

secured to the tie down lugs until further evaluation could be performed.

The permanent seismic rail clips had been cut to allow the gantry crane to be lif ted.

CREE 97 79618 was generated to evaluate the impact of the removal of the

seismic clips, the increased gantry crane weight, and a revised removal method

using two cranes. The original weight calculation was based on weight of the steel

in the crano compor ents and had not considered that concrete had been added to

the trolley af ter coristruction for tornado considerations. The revised calculations

took the weight of the concrete into account.

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,- The possible load drop effects upon the essential cooling water roof structure and

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adjacent commodities was reevaluated. In the anchored position, tne gantry crane  !

was determined to be adequately secured to resist seismic, as well as tornadic, l

loading without the seismic clips. The response of the crane to a postulated i

seismic event during gantry crane travel was also evaluated. A conservative,  :

bounding analysis was used to demonstrate that a worst case collapse scenario l'

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would not result in unacceptable consequences. An actual collapse was considered

very unlikely by engineering judgment. The analysis showed that the roof could  :

withstand the collapse impact with no loss of function. l

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The calculation was revised to consider a load drop of _the 145 ton _

(131.5 metric ton) crane, and a collapse onto the roof, This assumed that the [-

weight of the crana above the legs was 55 tons (49.9 metric tons),36 percent

more than the 40.5 tons (36.7 metric tons) ussd in the original calculation. Both of

these conditions (drop and collapse) were shown to be acceptable. The actual  !

measured weight was found to be 104.5 tons (94.8 metric tons), significantly less 1

than the 145 tons (131.5 metric tons) that the roof cotJd withstand based on the ,

. 3 foot load drop analysis. [

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The gantry crane was removed on July 2b in accordance with PCF 33499A and

CREE 97 79618 without affecting the operability of any of the essential cooling ,

water system trains. t

c. Conclusions

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The actions of the engineers in stopping the attempted removal of the essential

cooling water intake structure gantry crane with a single mobile crane was good.

, The recalculation of the crane weight and the assessment of potentiM impact on

operability of the essential coolireg water systems were conservative. Engineering

support was timely.

E2 Engineering Support of Facilities and Equipment

E2.1 Operability of Pressurizer Pressure Interlopk P 11 (37551,62707)

.

On July 7, the inspector observed technicians verify the operability of Pressurizer .

Pressure Interlock P 1_1 utilizing a revised Procedure OPSP02 RC 0455. On-

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' June 19, engineers performing an operational experience review had identified

deficiencies in the previous testing methods. Permissive P-11 had been declared

inoperable and Technical Specification 3.3.2 Action 21 was implemented to ensure

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that the interlock was in its required state. The technicians were knowledgeable of ,

the system and the appropriate testing methods. The permissive was properly I

tested and returned to service. Observed indications verified that the permissive

had been properly returned to service. The inspectors determined that the- >

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identification of this condition resulted from a quality operational experience review

process.

As documented in Section M8.1 of inis inspection report, the licensee properly

reported this problem in Licensee Event Report 50-498/97 007. However, the

f ailure to properly test Permissive P 11, prior to June 19,1997, in accordance with

Technical Specification Surveillance Requirement 4.3.2.1, Table 4.3.2 was a

violation. This licensee identifierf and corrected violation is being treated as a

noncited vivlation, consistent with Section Vil.B.1 of the NRC Enforcement Poliev

(498:499/97005-04).

E2.2 Fire Durina Hiah Temoerature Leak Sealina Activities

a. jngnection Scope (93702. 37551)

On July 15, a small fire was discovered on the insulation surrounding Main Stearn

isolation Valve 2D during steam leak sealing activities. The crew performing the

leak scaling activities left the area followmg a series of leak sealant injections.

Shortly thereafter, a security officer making a routine patrol of the area observed the

flames and contacted a nearby mechanic. The mechanic extinguished the flame

with a fire extinguisher. The fire brigade was notified, the insulation removed, and

the embers extinguished. The inspectors reviewed the licensee's response to and

evaluation of the event; the event review team's report; and the temporary

modification package associated with the leak sealing activity,

b. Observations andlindinns

An event review team noted that the material safety data sheet indicated that the

leak sealant material should not have caught fire in the specific application nor at

the piping temperatures encountered. The team determined that mineral oilin the

leak scalant material had leached out from under the injection clamp and collected in

the fiberglass insulation. The conditions were then sufficient to cause the oil to

autoignite. Licensee engineers stated that the spontaneous ignition of oil soaked

insulation can occur under the following conditions:

• The liquid is insufficiently volatile to evaporate rapidly.

• The insulation is sufficiently porous to allow oxygen to diffuse to the surface

of the absorbed liquid.

• The oilleak is slow enough that the pores of the insulation are not blocked

thereby excluding oxygen from the high temperature region.

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The inspectors reviewed the licensee's corrective actions, which included, notifying

other plants of the possibility for the leak scalant material to autolgnite under certain

conditions.

The inspectors reviewed Temporary Modifica: ion Package TL2 97 8224 2, which

approved the installation of the injection clamp and sealant materials. The

modification package designated a limited amount of ieak sealant that could be

utilized without additional reviews. A screening of the modification was performed

which met the requirements of 10 CFR Section 50.59. Appropriate evaluations of

the weight of the clamp and associated piping stresses were also performed. The

inspector also determined that the use of an injection clamp vice direct injection of

the flange was conservative.

c. .C.gnclusions

Maintenance and engineering personnel properly evaluated the causes of a fire that

initiated during the leak sealing evolution. The cause and the scientific phenomena

were fully understood. The associated temporary modification package was

properly developed and reviewed and utilized a conservative leak sealing technique.

The requirements of 10 CFR Section 50.59 were met prior to modifying plant

equipment.

E2.3 Det. inn of the Auxiliarv Feedwater Sv1Lem related tednaineered Safetv FeaMea

Testina (37551)

a. Insoection Sgpjt

The inspector reviewed Condition Reports 9614496 and 9616132 that identified

severalissues regarding compliance of the Auxiliary Feedwater (AFW) System

design with industry standards during Engineered Safety Features (ESF) testing. On

November 20,1996, during a licensee review of Updated Final Safety Analysis

Report (UFSAR) Section 7.3. licensee engineers identified that the AFW system

testing circuitry did not appear to meet the requirements of Regulatory Guide 1.118

and IEEE Standard 338 1977. The licensee initiated Condition Report 9614496 on

November 20,1996, to identify the issues with AFW system testing. Condition

Report 96 16132 was initiated on December 19,1996, to prepare a modification

evaluation package that would determine the impact of modifications to correct the

deficient conditions.

The condition report indicated that actuation test signals applied to the AFW system

would cause the system to start and feed water to the steam generators, in order

to prevent this action during testing, the system would be isolated with fused

asconnects opened, As a result of a review of UFSAR Section 7.3, the licensee

found that the design did not appear to be in accordsnce with Regulatory Guide

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1,118 and its associated IEEE Standard 338 1977. UFSAR Table 3.121 Indicated .[

that the licensee conformed to this regulatory guide.. In addition, the condition

report indicated that the associated IEEE standard required the generation of a

system level " bypass /inop" annunciator whenever a system was taken out of .  ;

service. This did not occur during testing of the AFW system. The concern also

applied to the safety injection and the containment spray systems whenever

Refueling Water Storage Tank Outlet Valve SI MOV 0001 was closed. It appeared

that only the safety injection system level bypass /inop window on the control board

- was activated. ,

The inspector reviewed Condition Reports 9614496 and 9616132 and d.iscussed

this review whh appropriate operations, system engineering, licensing, and

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management personnel.

b. Observations and Findinas  ;

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The condition reports documented that the bypassing of the AFW for testing

purposes was not annunciated in the control room. There are no annunciators for

the manual discharge valves being shut, nor for the AFW steam driven pump inlet

valves opened fused disconnects. As such, the AFW motor-driven pump bypass L

testing did not fully conform to IEEE Standard 338 1977, wtJch required that each  !

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test bypass condition utilized at a frequency of more than once a year shall be

individually and automatically indicated to operators in the main control room in

such a manner that the bypassing of a protective function is immediately evident

and continuously indicated,

in both cases (fused disconnects or closed manual discharge valves) the inspector

determined that because each system is isolated, the AFW system is in a bypass '

condition. The inspector also determined that this design flaw was applicable to the

containment spray system, whenever Valve SI MOV 0001 was closed. Although

this condition !s not automatically indicated to the operator in the main control

room, when the system is bypassed, the inoperable status of the AFW train is

logged and monitored by the operations personnel via the Technical Specification

3,7.1.2 action statement. The licensee had developed a field change to install a

second slave relay that willinactivate the discharge motor-operated valve in the

respective train. The field change had been scheduled to be implemented during

1998 and 1999 refueling time frames. Once the second slave relay is installed, the '

system design will be in compliance with IEEE Standard 338 1977, because no

manual or fused disconnects will be used. In addition, a valid engineered safety

features signal will override the slave relay and activate the AFW train in test.

However, this-is the first example of a f ailure of the licensee to inalement the

design commitments related to the AFW and containment spray systems.

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The licensee also identified that the AFW steam driven pump bypass testing does }

not conform to Regulatory Guide 1.118, Section C.6.b, which stated that

"... Removal of fuses.or opening a breaker is permitted only if such action causes (1)  ;

the trip of the associated protection system channel, or (2) the actuation (startup

and operation) of the associated Class 1E load group." Because the removal of the

inlet valve disconnect fuses does not cause the startup and operation of the

associated Class 1t! load group, the AFW system bypass testing does not fully

conform to Section C.6 b.  ;

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The inspector noted that a potential existed for an operator to reposition the inlet

valve disconnect fuses should an accident occur during testing. However, this

makeshift test setup, although not significant, does represent a deviation from the

!

regulatory guide recommendations. Again, once the second slave relay is installed,

the licensee will not remove the inlet valve disconnect fuses and they will be in full '

compliance with Regulatory Guide 1.118. Similar to the previous item, the licensee  ;

had identified this discrepancy and had implemented corrective actions to resolve 1

the condition. This is a second example of a failure to implement the design .

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commitments from Regulatory Guide 1.118 into the AFW system design.

The inspector also reviewed the related requirements of Plant Surveillance

Procedure OPSPO3 SP-0009A, Revision 6, "SSPS Actuation Train A Slave Rela /

Test." in order to prevent injection of v ?.ter into the steam generators during

protection system testing, the followirig actions were accomplished in accordance

with this test procedure:

• the AFW line for the respective motor-driven pump was isolated by shutting

,

a manual isolation valve; and

• the steam driven pump was isolated by opening fused disconnects to the

inlet valve to prevelt the steam driven pump from starting.

The inspector confirmed that the current testing method prevented actuation of the -

motor driven AFW train as a result of shutting of the train's manual discharge

isolation valve. The actuation of the steam driven AFW train is similarly bypassed

by opening the inlet valve disconnect fuses, which prevents steam entering the

turbine. A licensee engineering evaluation conducted in December 1996, indicated

_

that Regulatory Guide 1.22, " Periodic Testing of Protection System Actuation  ;

Functions," Section D,'" Regulatory Position," allowed this type of bypass testing to i

occur. The inspector noted that Section 2.c of the Regulatory Guide indicated that

acceptable methods of including the actuation devices in the periodic tests of the

protection system include preventing the operation of certain actuated equipment

during a test of their actuation devices, in addition, Subsection b of the Regulatory

Guide _ indicated that acceptable methods of including the actuation devices in the

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periodic tests of the protection system included testing all actuation devices and

actuated equipment individually or in judiciously selected groups.

Based on a review of Regulatory Guide 1.22, the inspector confirmed that the

licensee was conducting their actuation device testing in accordance with the

regulatory guidance and that the bypass testing was acceptable. However, the

inspector noted that this testing methodology did not specifically meet the

description provided in the original FSAR design. UFSAR 7.3.1.2.2.5.4.5 stated

that automatic actuation circuitry will override testing activities and actuate the

system. The licensee identified this discrepancy and had decided to install a field

change to install a second slave relay which willinactivate the discharge motor-

operated valve in the respective train. The field change had been scheduled to be

implemented during the 1998 and 1999 refueling outage time frames. This is a

third example of a f ailure to implement the design commitments from applicable

regulatory guidance into the AFW system design.

10 CFR 50, Appendix B, Criterion lil, " Design Control," requires, in part, that

measures be established to assure that applicable regulatory requirements be

correctly translated into specifications, procedures, and instructions. The three

examples of the licensee's failure to assure that all of the requirements of IEEE 338-

1997 and Regulatory Guide 1.118 were correctly translated into the applicable

procedures for testing of the AFW system represents a violation of Criterion lil of

Appendix B to 10 CFR 50. However, the inspector determined that: the violation

was identified by licensee personnel; corrective actions had been developed; the

violation was not a repeat of a previous violation or finding; and the violation was

not willful. Therefore, this nonrepetitive, licensee identified and corrected violation

is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRQ

Enforcement Poliev (NCV 498;499/97005-05).

In light of these findings, the inspectot questioned whether these issues required a

report to the NRC in accordance with 10 CFR 50.73(a)(2)(ii)(B), which stated that

the licensee shall report any condition that was outside the design basis of the

plant. The inspector noted that on November 26,1996, the licensee had generated

a reportability review for Condition Report 96 14496, wherein they concluded that

the AFW system testing deficiencies were not reportable. The licensee stated that

the testing of the AFW system was done with the system properly removed from

service in accordance with the Technical Specifications, and that the testing

adequately tests the system components in accordance with the Technical

Specification requirements.

The inspector agreed with the licensee determination that the issues were not

reportable because the testing of the AFW system was conducted with the

applicable train properly removed from service in accordance with the Technical

Specification 3.7.1.2 action statement. Based on the redundancy of having four

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trains, there was always a sufficient number of trains available, such that the AFW

system was not degraded during the testing of one train of the system, in addition,

the AFW train was taken out of service for testing with the full knowledge of all

operators and monitored by entry in the control room log _of the Technical

Specification action statement. There were no ESF actuations involved. The

testing conditions did not result in an inability to mitigate an accident or maintain

safe shutdown (tbee remaining AFW systems were operable and only one AFW

system is required to achieve safe cooldown), nor did it involve potential common

modo f ailure mechanisms. Thatefore, none of the other 10 CFR Section 50.73

criteria apply,

c. Conclusion

Although the bypassing of the AFW system for testing purposes and isolating the

containment spray system suction was not annunciated in the control room, as

required by lEEE Standard 378,1997, licensed operators appropriately entered the

Technical Specification 3.7.1.2 applicable action statement for each AFW test. This '

action was noted and tracked by control room operators to completion. The

licensee tracked the restoration status to restore the system following completion of

the slave relay test.

The AFW steam driven pump design requires the inict valves to be isolated during

testing by opening fused disconnects to prevent the pump from starting. This

opening of the fused disconnects for the inlet valves does not trip the associated

protection system channel nor does it cause the startup and operation of the

associated Class-1E load group. Therefore, the AFW steam driven pump bypass

testing does not fully conform to Regulatory Guide 1.118 because removal of the

disconnect fuses does not cause the startup and operation of the associated Class-

f E load group. However, licensee engineers had initiated a design change that will

install a second slave relar This action will negato any further removal of the fused

disconnects.

Although the AFW system would not respond following a valid engineering safety

features signal during operability testing of the engiacered safety features actuation

system slove relays, the licenses was conducting its AFW system testing in

accordance with Regulatory Guide 1.22. The licensee has decided to install a field

change to install a second slave relay that will allow actuation of the AFW system

during operability testing.

The licensee's f ailure to assure that all of the requirements of IEEE 338 1997,

Regulatory Guide 1.22, and Regulatory Guide 1.118 were correctiy translated into

the applicable procedure for testing of the AFW system was e violation. This

nonrenetitive, licensee identified and corrected violation is being treated as a

noncited violation, consistent with Section Vll.B.1 of the NJR_C Enforcement Poliev.

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The _ inspector reviewed the issues identified in the condition reports and determined ,

that they were not reportable in accordance with 10 CFR 50.73 because, the AFW {

system was never outside its design basis, The removal of each AFW system .

)

,

during testing was conducted in accordance with the Technical Specification 3.7.1.2 action statoment, noted in the control room, and tracked to completion. l

1% PlanL5_9pn9_t1  !

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M1: Radiological Protection and Chemistry Controls .

R1.1_Ipurs of Radioloalcal Controlled Areas \

?

a. impection Scope f71750) l

The inspectors routinely toured the mechanical auxiliary and fuel bandling buildings  ;

>

- in Units 1 and 2. These tours included observation of work, verification of proper

radiological work permits, sampling of locked doors, review of radiological postings,

i

and observations of personnel entrance and egress from the radiological controlled

areas,

b. Qbservations and Controljt  :

Radiological housekeeping in the areas toured was very good. Doors required to be

!

locked in accordance with Technical Specification 0.12.2 and the licensee's

radiological program were proprirly secured. No entrance / egress discrepancies were

--

- identified.

However, on July 17, during a routine tour of cie fuel handling building, the  ;

inspector identified eight contaminated area signs that had fallen down. The signs

had been hung across portholes going mto emergency core cooling system pump l'

room sump areas. The radiation protection technician determined that high

- condensation la the area had loosened the adhesive used to hang the signs. The i

signs were immediately re hung. The postings were later secured with bolts to the

wallt for more permanent mountings, The significance of this condition was low

because access through the portholes would be difficult and unnecessary.

On July 17, the inspectors observed health physics technicians providing -

radiological control oversight in support of the rod clustcr control assembly tool

repair in Unit 1. - Two technicians provided continuous coverage. One technician

" was in the contaminated area monitoring and making contamination surveys. The  ;

other technician operated an air monitor and provided support from outsida the

- contaminated area. A thorough radiological protection briefing was conducted

before the start of the work. The toollaydown area was properly marked and

,

plastic sheeting was placed on the refuelling deck to control contamination.

.

a~----w -e e v-, w-.-.-..w-%-- w+c...%5w.s.-c.-,.-,-.w-+- re-..r ,-n 1,%.--,.ro,=,-<r----mtyw- e- yv e E w -w--,,-. - pr --v .rw - w v v- v & - c ,- * -,rne- e v- i --n-w ir w w-"--w w <wn'f

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On July 21 the inspector accompanied three maintanance crews and a health

physics technician, ten people in all, on an at power containment entry in Unit 2.

The purpose of the containment entry was to repair a flange leak on Residual Heat

Hemoval Pump 20. The prejob radiological protection briefing was thorough. The

health physics technician verified that each worker had properly denned the

protective clothing and was wearing alarming dosimetry that would indicate high

dose rate areas. The workers were cognizant of radiological conditions and

exhibited good work practicos,

c. Cpnclusions

Houtino radiological controls observed were considered in place and effective with '.

one exception. On two occasions, the radiological work practices of health physics

technicians and maintenance personnel were considered notable.

R 1.2 Secnndary Chemistry Controls

The inspectors routinely reviewed secondary water chemistry reports and radiation

rnonitor alarm status. Secondary chemical analysis, the cal::ulated primary to

secondary leak rate, and indication from the Nitrogen 16 radiation monitors all

confirmed steam generator tube integrity. The chemical analysis results provided

evidence of menagement attention and cornmitment to maintaining chemistry

parameters within appropriate limits.

P2 Status of EP Facilities, Equipment, and Resources

P2.1 Emernency Reiname Facilities (71750)

The inspectors observed that the Technical Support Centers and Operations Support

Centers in both units were readily available and maintained for emergency

operation.

P2.2 Meteorolonical Towers and Indications (71750]

The inspectors routinely observed indica'.icn af meteorological conditions in the

main control rooms of both units. The data obtahad indicated that both the

10-meter and the 60-meter towers remained operable.

S1 Conduct of Security and Safeguards Activities

S 1.1 Raily Phv.sical Security Activity Qbsorvations (71750)

a. IrLspection Scope (717501

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Revision 1

The inspectors observed the practices of security force personnel and the condition

of security equipment on a daily basis. On one occasion, the inspector reviewed

the practice of skirting temporary trailers on site.

b. Observations and Findinos

The security officers searched packages and personnel in a professional manner.

_

Vital area doors were verified to be locked and in working condition. The inspectors

verified that isolation zones around protected area barriers were maintained free of

equipment and debris. During backshif t tours, the inspectors determined that the

protected area was properly illuminated.

During this inspection period, the inspectors observed the placement of temporary

trailers inside the protected area in preparation for the upcoming outage in all

cases, the trailers were properly skirted or had temporary lighting installed for

illumination,

c. Conclusions

Daily security force operations were handled professionally. Trailers in the

protected area were skirted or properly illutninated.

(~

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ATTACHMENT

EUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Revision 1

Licensee

T. Cloninger, Vice Presidant, Nuclear Engineering

W. Cottle, Executive Vice President and General Manager Nuclear

D. Dowdy, Manager, Operations, Unit 2

J. Groth, Vice President Nuclear Generation

E. Kalpin, Manager, Maintenance, Unit 2

S. Head, Licensing Supervisor

K. House, Supervising Engineer, Design Engineering Department

T. Jordan, Manager, Systems Engineering

M. Kanavos, Manager, Mechanical / Civil Design Engineering

A. Kent, Manager, Electrical / Instrumentation and Controls Systems

D. Logan, Manager, Health Physics

R. Lovell, Manager, Operations, Unit 1

B. Masse, Plant Manager, Unit 2

G. Parkey, Plant Manager, Unit 1

T. Waddell, Manager, Maintenance, Unit 1

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 61726: Surveillance Ot'servations

IP 62707: Maintenance Observation

IP 71707: Plant Operations

IP 71750: Plant Support

IP 92700: Onsite Followup of Written Reports at Power Reactor Facilities

IP 92902: Followup Maintenance

IP 93001: OSHA Interf ace Activities

ITEMS OPENED, CLOSED, AND DISCUSSED

QP10Ed

499/97005 01 NCV Entry of Incorrect Technical Specification Action

Statement into Operability Assessment System

499:499/97005 02 URI Manual Valves in Certain Containment Penetrations not

Surveilled in Accordance with Technhal

Specification 4.6.1.1.a

498;499/97005 03 VIO Two Examples of inadequate Equipment Clearance

Order Boundaries

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498:499/97005 04 NCV Failure to Properly Test the Pressurizer Pressure {

Interlock P 11 in Accordance with Tachnical i

Specifications  ;

498:499/97005-05 NCV - Failure to Translate Design Commitments into AFW and - '

Containment Spray Systems Design  ;

.

-

Closed

t

499/97005 01 NCV Entry of incorrect Technical Specification Action  !

Statement into Operability Assessment System j

498;499/97005-04 NCV Failure to Properly Test the Pressurizer Pressure _

f

Interlock P.11 in Accordance'with Technical  !

Specifications

i

498;499/97005 05 NCV Failure to Translate Design Commitments into AFW and

Containment Spray Systems Design

,

50-498/97 007- LER Eng:neered Safety Features Actuation System

_

Pressurizer Pressure Interlock Not Fully Tested by

Surveillance l

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