ML20211A105
| ML20211A105 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/19/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20211A062 | List: |
| References | |
| 50-445-97-17, 50-446-97-17, NUDOCS 9709240118 | |
| Download: ML20211A105 (23) | |
See also: IR 05000445/1997017
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ENGLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV-
Docket Nos.: 50 445
50-446
License Nos.: NPF 87
NPF 89
Report No.: 50-445/97 17
50-446/97 17
Licensee: TU Electric
Facility: Comanche Peak Steam Electric Station, Units 1 and 2
Location: FM 56
Glen Rose, Texas
Dates: July 20 through August 30,1997
Inspectors: G. E. Werner, Acting Senior Resident inspector
H. A. Freeman, Resident inspector
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R. L. Nease, Technical Assistant, Division of Reactor Projects
W. C. Sifre, Resident inspector, South Texas Project
W. J. Wagner, Reactor Inspector, Division of Reactor Safety
Approved By: J l. Tapia, Chief. Projects Branch A
Division of Reactor Projects
ATTACHMENT: Supplemental information
O d
9709240118
DR 970919
ADOCK 05000445
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EXECUTIVE SUMMARY
Comanche Peak Steam Electric Station, Units 1 and 2
NRC Inspection Report 50 445/97 17:60 446/97 17
Doerations
- The inspectors determ:ned that operations personnel operated the plant in a safety
conscious manner with appropriate management overtight (Section 0.1.1).
- Housekeeping and material condition of plant equipment were excellent
(Section 0.1.1).
- A violation of Technical Specification 6.B.1 was identified with three examples of
operators failing to follow procedures. The three recent incidents involved errors
due to inattention to-detail. The licensee acknowledged the need to evaluate
whether an adverse trend was occurring and the need for additional corrective
actions (Section 08.1).
Maintenance
- The failure to have a spare orifice available was a poor work practice which resulted
in taking safety related equipment out of service without the capability to repair the
deficiency (Section M1.3).
- The control room emergency pressurization surveillance was conducted by
knowledgeable and conscientious engineers. Their performance was good,
however, some weaknesses were identified in the documentation of the test results
(Section M1.4),
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- The corrective actions taken for prior failures of the transfer cask grapple had been
ineffective in resolving the gripper problems. The licensee was currently taking
appropriate steps to resolve the problems with the transfer assembly
(Section M2.1).
- The technician's previous action to pry open the transfer cask grapple when they
had trouble releasing it, and then not document this action in a work request or a
corrective action document, was inappropriate (Section M2.1).
- - The inspectors identified a violation of Technical Specification surveillance
requirements when the licensee failed to perform stroke time testing of a
containment isolation valve following actuator maintenance (Section M7).
- The inspectors concluded that the licensee failed to follow the procedure in at least
one instance when a containment isolation valve bushing was modified without
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proper documentation, review and approval. As part of this issue, a review of
similar vendor recommended maintenance activities that may have been conducted
without proper approval will be conducted. The inspectors also found that steam
generator atmospheric relief valves had not been properly classified in maintenance
documents. These issues will .emain unresolved pending the licensee's
investigation (Section M7).
Enaineerina
- The inspector determined that no adverse operational concerns existed with the
reactor coolant leakage from Pressurizer Safety Valve 2 80108 (Section E2).
Plant Suevolt
- The inspectors determined that radiological postings were current, plant personnel
were aware of radiological work permit requirements and radiation protection
personnel provided good support to work activities (Section R1).
- The inspector identified t. violation of illumination requirements within the protected
area. Security personnel responded immediately and installed temporary lighting
(Section S1).
- The inspector concluded that the Thermo Lag fire barrier installations, located in
Rooms 1096 and 1241, were easy to inspect and showed no signs of degradation
or damage. A noncited violation was identified for discrepancies between actual
Thermo Lag barrier locations and completed insenction forms (Section F2).
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BfR9rt De1911.1
Summarv of PlanLSlatus
Unit 1 and Unit 2 operated at 100 percent power throughout the inspection period,
l. Ooerglions
01 Conduct of Operations
01.1 Plant Tours (71707)
a. lumpection S.wng
The inspectors conducted frequent plant tours to verify safe operation of plant
equipment and to inspect general plant materhl and housekeeping conditions. As
part of the tours, the inspectors performed routine control room observations, and
walkdowns of safety related flow paths and locked compenent lists,
b. Observations and Findinas
Overall, the inspectors determined that operations 9ersonnel operated the plant in a
safety conscious manner with appropriate management oversight. Safety systems
were properly aligned. Plant housekeeping and materici condition of plant
equipment were excellent. The inspectors identified several minor housekeeping
and equipment material deficiencies. These deficiencies were appropriately
dispositioned by the licensee.
O.1.2 Clearance Tao Verifinnilga
a. Insoection Scone (71707)
The inspector reviewed the clearance tags hanging on Waste Gas Compressor X 02,
checked the position of the tagged components, the locations of the tags, and
compared them to the positions on the clearance document,
b. Observations and Findinas
The inspector noted that the equipment nomenclature on several of the tags had
been changed by the individual hanging the tags and that the tags werJ attached to
the appropriate components. Additionally, the inspector noted that tha required
position on one of the tags had been changed from " auto after close' to "close."
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The inspector reviewed the electrical drawing and concluded that the clearanco
planner had incorrectly interpreted the note which stated, "3 position spring return
right to center standard handle." The close position was to the lef t and was not
spring returned to the center position. The "close" position was appropriate for the
switch.
The inspector verified that the changes had been authorized by a cognizant
authority and that corrections to the master equipment list were planned or in
progress to correct the required location / position. The inspector found that the
clearance was appropriate for the maintenance activity.
04 Operator Knowledge and Performance (71707,61726)
The inspectors performed a field observation of Emergency Diesel Generator
(EDG) 102 operability test. The systems performed as expected and no concerns
were identified.
08 Misco:laneous Operations issues (92901)
08.1 Closad IFl 50 446/9714 02: while performing OPT-4578, " Train A Safeguards
Slave Relay K740 and K741 Actua lon Test," Revision 2, a licensed operator failed
to perfor-m a step in the procedure. The operator missed Step 8.8 which required
Valve 2 8812A to be closed and at a result, the surveillance test failed to meet its
acceptance criteria. The test f ailuri resulted from improperly positioning a valve
prior to test actuation. Although the surveillance test failed, the system was still
capable of performing its safety function.
Technical Specification (TS) 6.8.1 requires that written procedures be established,
implemented, and maintained covering activities recommended in Regulatory
Guide 1.33, Revision 2, Appendix A. Appendix A requires general operating
proceuutes_ for power _ operation, startup, and shutdown of safety related systems
and for conducting maintenance. The failure of the operator to position the valve in
accordance with Proctdure OPT-457B is the first example of a violation of TS 6.8.1
(50 445(446)/9717 01). Two additional examples of a failure to follow procedures
were identified during this inspection period.
On August 7 during the post maintenance testing of EDG 2 01, an operator failed to
immediately load the EDO as required by Procedure OPT 214B, " Diesel Generator
Operability Test," Revision 4, Step 8.1.V and the EDG tripped on reverse power.
No safety consequence was involved since the EDG was already inoperable as a
result of maintenance. However, the failure of the operator to immediately load the
EDG in accordance with the procedure is the second example of a violation of TS 6.8.1 (50-445(446)/9717 01).
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On August 21 operations personnel identified that the Unit 1 chemical and volume
control system cation bed was not properly secured in accordance with Procedure
SOP 103, " Chemical and Volume Control System," Revision 10. The cation bed
was placed in service fo* lithium control. An auxiliary operator opened the bypass
valve but f ailed to close the inlet and outlet valves to the bed as required by
Step 5.3.10. Indicated flow through the bed w6s zero and a subsequent chemistry
analysis identified a slight decrease in lithium of approximately 0.02 ppm. Reactor
coolant chemistry remained within desired limits. The failure of the auxiliary 9
operator to close the inlet and outlet valves of the cation bed is the third example of
a violation of TS 6.8.1 (50-445(446)/9717 01).
The inspectors deterrnined that the corrective actions taken for each individual error
were appropriete. However, the three recent incidents involved errors due to
inattention to-detail and the !!censee acknowledged the need to evaiuate the errors
to determine if an adverse trend was occurring and whether there is a need for
additional corrective actions.
08.2 (Closed) Licensoe Event Reoort 50 445/96 005: Unit 1 entry into TS 3.0.3 due to a
cracked weld in the safety injection system piping. This event was previously
reviewed as documented in NRC Inspection Report 50 445/96-06;50 446/96 06.
The previous review included inspector reviews of activities associated with the
licensee corrective actions. No new issues were revealed by this report.
11. Maintenanga
M1 Conduct of Maintenance
M1.1 General Comments
a. Inspection Scone (62707 and 61726)
The inspectors observed all or portions of the following work activities:
- Leak Rate Testing of Penetration MV 14
- Containment Spray 101 and 103 Bearing Cooler Service Water Flow
Element inspection and Cleaning
- Control Room Emergency Pressurization Surveillance Test
- Auxiliary Feedwater Pump 2 02 Motor Breaker Protective Relay Calibration
b. Observations and Findinas
The inspectors found that the work performed under these activities was
appropriately conducted. Specific details are listed below.
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M1.2 Leak Rate Testina of Penetration MV 14 (Unit 1 Containment Pressure Relief
Penetration Line)
The workers conducting the test were knowledgeable of the leak rate testing
requirements and used good work practices. During the removal of the leak rate
testing gear from the penetration vent valve, ona of the workers f ailed to wear
gloves to protect against potential contamination while removing the testing gear
from the penetration. Discussions with the worker and a radiation protection (RP)
technician indicated that this penetration vent valve has never shown any
contamination and that wearing gloves was a precaution. The RP technician stated
that he instructed the worker to wear gloves while working on the penetration
connection. This is another example of recently identified poor radiological work
practican de.umented in NRC Inspection Report 50-445/97 15;50 446/97 15.
Radiation protection managemont agreed that this was a poor work practice and
counseled the individual.
M1.3 Containment Sorav Bearina Cooler Service Water Flow Element inspection and
Cleanina
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On August 7 the inspector observed maintenance personnel clean and inspect the
Train A containment spray service water flow element. The orifice was being
inspected because the control room annunciator for this particular flow element was
locked in. A freeze seal was established to isolate the downstream side of the flow
orifice from the service water return header. The technicians properly assembled
and n.alntained the freeze seal for the duration of the activity. Overall, the
maintenance activity itself was well performed. Two areas for improvement were
noted:
- Contrary to a request made by the operations supervisor, a replacement
orifice was not fabricated prior to the maintenance task. A communication
error in work control allowed the work package to be issued without the
replacement orifice being available. A subsequent inspection identified that
algae was interfering with the orifice ano that the orifice was partially
, corroded. Although the orifice openhg did not meet design specifications,
the orifice was reinstalled because na spare was available. Indicated flow
increased slightly but was still below 'he alarm setpoint. The f ailure to have
a spare part available resulted in taking a safety related system out of service
without the capability to repair the deficiency.
- Approximately 10 minutes after securing the freeze seal, maintenance
personnel began disassembling the freeze seal without using protective s
equipment (f ace shield, gloves, etc.). This was an unsafe work practice. ;
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M 1.4 Control Room Ememency Pressurization Surveillance Test
a. Insocction Scope (61720)
The inspector witnessed the performance of a major surveillance test on control
room emergency pressurization Unit 21. The inspector reviewed the test procedure
to determine whether it implemented the requirements of TS Surveillance
Requirement 4.7.7.1l Current work schedules were reviewed to determine whether
planned maintenance activities could affect the outcome of the surveillance,
b. Observations and Findinos
The inspector reviewed Procedure PPT SX 7505A, " Control Room Pressurization
Test Train A," and verified that the surveillance requirements of TS 4.7.7.1j were
properly implemented. The inspector verified that the method for converting pitot
tubo differential pressures into air flow used accepted standard formulas The
inspector noted that the procedure did not have a space for recording each micro-
manometer measured reading. The measured reading had to be doubled to obtain
the actual differential pressu o and could have led to test result errors.
The inspector walked down temporary tubing installed in the control room to
measure differential pressures and found one tube connected to the wrong side of a
differential pressure gage. The procedure did not previde detailed explanations or
drawings to describe the required connections. The inspector observed the
performance and test engineer check connections in a different location using an
informal drawing. When questioned, the engineer verified that the connection in the
control room was indeed incorrect and then corrected the problem. Some minor
weaknesses were noted in the procedure and the licensee informed the inspector
that they intended to correct these weaknesses in a future revision. The inspector
concluded that this was appropriate.
Through a review of th r plan-of the-day, the inspector identified several
maintenance activities on ventilation components which were scheduled to be
performed prior to the test. These activities included major inspections and
functional strokes of four motor operated ventilation dampers. The inspector
questioned the licensee whether any of the maintenance activities could present a
proconditioning situation. For example, on dampers which must reposition for
proper pressurization operation, whether adding lubricant to the gear box during the
inspection or stroking of the dampers prior to the surveillance would precondition
the dampers and invalidate the surveillance. The licensee did not have time to fully
address these questions prior to the scheduled maintenance activities so they made
a conscrvative decision to cancel the maintenance until after the surveillance test.
Following the surveillance test, the licensee concluded that the planned
maintenance would not have constituted preconditioning. The inspectors reviewed
the licensee's conclusion and had no questions.
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On August 7 the licensee cunducted the surveillance test. During the surveillance
test, the engineers measured a thw of 888 cim. Surveillance Requirement 4.7.7.1j
required that each pressurization unit maintain a positive pressure of 2:0,125 inches
ww.er gage relative to the adjacent areas at a makeup flow rate of 5800 cfm. The
licensee initiated a Operations Notification and Evaluation (ONE) form, modified the
work order (WO) to adjust the inlet damper, and then adjusted the flow to 755 cim.
The engineer informed the inspector that any time flow exceeded 800 cfm that the
unit was declared inoperable and then flow adjusted.
During the adjustment of the damper, the engineer noted that the wing nut holding
the damper in place was not as tight as expected. The control of the damper
position was governed by Prncedure STA-601, " Authority for Equipment
Operation." Although this adequately controlled the position of the damper, a
specific requirement to verify the tightness of the wing nut was not called out in
this procedure. The licensee stated that the surveillance procedure would be
enhanced to specify that the damper be snug ti0 ht and that this would be
accomplished by tightening the nut with a wrench.
The inspector observed that the method used to measure air flow did not appear to
be easily repeatable which may have led to errors. Previous surveillance tests on
emergency pressurization Unit 21 measured flows of 817 cim,625 cfm,788 cfm,
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and 888 cfm. Because of the variations noted between successive tests and the
vent damper adjustment nut being found looser than expected, the inspector will
review the maintenance history, and compare the test method to national standards
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to determine potential causes of these differences during a future inspection as an
inspection followup item (50/445(446)/9717-02),
c. Conclusions
The procedure adequately implemented the surveillance requirements of
TS 4.7.7.1j.
The control room emergency pressurization surveillance was conducted by
knowledgeable and conscientious engineers. Their performance was good,
however, some weaknesses were identified in the documentation of the test results.
M2 Maintenance and Material Condition of Facilities and Equipment
M 2.1 Reactor Coolant Svstem Filter Transfer
a. Insoection Scope (62707. 71750)
While transferring a contaminated reactor coolant system filter on August 16, the
filter became unlatched from the grapple inside the shielded transfer assembly and
toppled onto its side on the transfer assembly base when the licensee was in the
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process of transferring the filtv to a storage vault. The licensee used long handled
tools to right the filter, which Clowed the filter to be regrappled inside the shielded
assembly.
The inspector reviewed + tvent to verify that radiation exposures were not
excessive and surveyed tos ransfer assembly to verify that the assembly was
properly posted. Additionally, the inspector reviewed the recent f ailure history and
corrective actions of the transfer assembly,
b. Observations and Findinas
The inspector found that the licensee had taken appropriate radiological steps to
minimize exposure to the technicians while restoring the filter to an upright
condition. The technicians received a total of 39 millirem dose during the evolution.
The floor surrounding the transfer assembly was decontaminated. No
contamination became airborne and none of the technicians were entaminated.
The inspector verified that the transfer assembly was appropriately posted as a high
radiation area inside the assembly.
The inspector found that the transfer assembly has had several failures over the
past two and one-half years. Three events which occurred in early 1996 were
documented and dispositioned together in one plant incident resolution (a more
detailed review of an event that requires a root cause analysis). In one of those
events, a filter dropped approximately 1 foot onto the floor. Corrective actions
included purchasing a high resolution camera to help ensure that the grapple
properly secured the filter and implementing a regular preventative maintenance
program.
The most recent failure was documented on ONE Form 97-881 and will be resolved
as a plant incident resolution. The inspector discussed the proposed corrective
actions with the system engineer. The engineer believed that debris in the collector
could have been the cause of the difficulty experienced releasing the filter and could
have caused the unlatching. Several potential problems were identified and
corrected during troubleshooting. These included electrical connection problems
with the controller pendent, debris in the takeup reel collector and deficiencies in
the design of the grapple. The licensee plans to replace the grapple at a future date.
The engineer identified that several weeks prior to the f ailure, technicians had
trouble releasing the grapple from a filter and pried the grapple open. The
technicians did not initiate a work request or a ONE form to investigate the causc of
the jammed grapple at that time. No physical damage to the grapple was identified
during subsequent troubleshooting.
c. Conclusions
The inspector concluded that the corrective actions taken for the prior failures of
the transfer cask grapple had been ineffective in resolving the grapple problems.
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The licensee was currently taking appropriate steps to resolve the problems with the
transfer assembly. Finally, the inspector concluded that the technicians actions to
pry open the grapple and not document this action was inapnropriate.
M2.2 Reactor Coolant Pumo SealIniection Filter Vent Valve Lgaj
a. -inspection Scope
On August 17 Unit 1 reactor operators noted a lowering levelin the volume control
tank and a drop in sealinjection flow while an auxiliary operator was flushing the in-
service sealinjection filter vent valve, The valve was being flushed in an attempt to
reduce leakage. The licensee estimated that the leak was approxiraately 15 gpm
and entered the action statement for TS 3.4,5, " Reactor Coolant System Leakage."
The other sealinjection filter was placed in service and the filter with the leaking
vent valve was isolated, securing the leak.
The inspector reviewud the circumstances surrounding the leakage, the licensee's
actions to isolate the leak and portions of the corrective maintenance activities,
b. Observations and Findinas
The following day, the licensee's regulatory affairs organization concluded that
since the leakage was from the chemical and volume control system, easily
identified and isolated, and not from the reactor coolant system, entry into the TS-
3,4,5 action statement had not been required. The inspectors agreed with the this
position.
The inspectors reviewed the licensee's procedure for placing the filters in service
and found that the procedure required that the vent valve be cracked open to
remove any air prior to placing the filter in service. This places a pressure of over
2,000 psi across the valve seat. After reviewing the vendor manual, the inspector
concluded that the operation of the filter assembly was appropriate.
The inspector attended a prejob briefing prior to conducting troubleshooting on the
leaking vent valve. The briefing was attended by allindividuals involved with the
activity including the auxiliary operator, reactor operator, unit supervisor, and
system engineer. The plan was detailed and organized.
The inspector observed portions of the corrective maintenance activity to repair the
vent valve. The mechanics were knowledgeable and followed the WO and
procedure, Excellent verification techniques were used to establish the correct
torque during valve operator reassembly,
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M7 Quality Assurance in Maintenance Activities (62707 and 92902)
a. Scope
The inspectors reviewed: ONE forms associated with the performance of
maintenance, completed maintenance WOs, vendor information, the Final Safety
Analysis Report (FSAR) and portions of other licensee documents related to work
conducted on Valve 1 HV-4175, Unit 1 containment isolation accumulator sample
valve,
b. Observations and Findinas
On August 22 the inspector noted that, although ONE Form 97 900 was initiated on
August 20, the adverse condition had been discovered on July 24. The ONE form
was written by a quality control (OC) technician to document a modification to the
valve actuator bushing without any documentation or evaluation. The inspectors
reviewed WO 4 97109682 and noted that there were no work instructions or
drawings for modifying the actuator bushing in either the WO or in the referenced
procedures, in addition, the inspectors noted that post maintenance testing was
not performed.
During the review of the completed WO, a QC technician determined that
maintenance personnel drilled holes in the accumulator sampling valve actuator
bushing to facilitate its removal. An evaluation was not performed nor was the
modification documented in the WO. The QC technician returned the WO package
to the responsible WO supervisor and attached a QC WO review sheet which stated
that a ONE form should have been initiated on this modification. The responsible
WO supervisor responded that a ONE form was not required since this activity was
not a modification. The supervisor provided a telefaxed memo from the vendor
dated August 20,1997, stating that this type of modification to actuator bushings
was acceptable. The QC technician then initiated the ONE form himself,
documenting this issue three weeks after its discovery. The inspectors determined
that the delay in writing the ONE form was a poor practice and could contribute to
unnecessary equipment inoperability.
The modified bushing was part of a Fisher-Type 667 actuator that is air to-open and
spring to-close. Fisher-Type 667 actuators are used in numerous systems
throughout plant. Maintensnce workers drilled and tapped the top of the bushing to
f acilitate its removal for elastomer change out, instead of removing the bushing by
dismantling the actuator as described in a maintenance procedure, in discussions
with the valve team supervisor, the inspectors were told that maintenance workers
had been modifying Fischer-Type 667 actuator bushings in this manner since 1994
in accordance with a vendor letter. The craft were trained in this technique,
therefore, the valve team supervisor considered this process to be within the skill of
the craf t and not an alteration or modification. Licensee personnel were unable to
retrieve the 1994 Fischer letter describing this change. Procedure STA-206,
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" Review of Vendor Documents and Vendor Technical Manuals," Revision 19, states
that vendor documents or correspondence that will be used for design, testing, or
other input for licensee activities, shall receive review and approval on a vendor
document review traveler, or be incorporated into an applicable vendor technical
manual prior to final acceptance and approval of the activity.
The inspectors requested a list of all valves with Fisher-Type 667 actuators where
the bushings had been modified in the above described manner. The licensee
compiled a list of 79 valves where the elastomers had been replaced. Because
modification of the bushings was not documented, the licensee had not yet
determined which of those 79 valves have modified bushings. The licensee is
continuing to investigate this matter. This issue will remain unresr'ied until the
inspectors review the licensee's identification of which of the 79 dve actuator
bushings have been modified without the required review and approval and/or
incorporation into an applicable vendor technical manual. In addition, a review for
other vendor-recommended maintenance activities that may have been conducted
without proper approval will be conducted (50-445(44619717-03).
The inspectors reviewed the list and found that the steam generator atmospheric
relief valves (ARVs) for both units were listed. The inspectors noted that only one
of the eight steam generator ARVs were designated as ASME Code Class 2 and
ANSI Safety Class 2 valves; the remaining ARVs were designated as "NA" for both
ANSI Safety Class and ASME Code Class. The inspectors found that the FSAR
designates these valves as ASME Code Class 2. The FSAR states that these ARVs
are required to be operable following a safe shutdown earthquake coincident with a
loss of offsite power, and that the steam generator ARV actuators are provided with
safety-related air accumulators. The inspectors also reviewed the ASME Section XI
inservice tasting plan and found that steam generator ARVs are listed as ASME
Section XI valves. The inspectors questioned whether the steam generator ARVs
and other Section XI valves might have had elastomers replaced without post-
maintenance testing. The licensee found that there were no elastomer change-outs
since the last quarterly surveillances on the steam generator ARVs and therefore, all
steam generator ARVs were considered operable. However, the licensee had not
determined whether the bushings in the actuators had been modified and whether
post-maintenance testing had been performed after the elastomers were replaced.
The inspectors will review this information when the licensee has made these
determinations. This will be reviewed as part of the above unresolved item (URI).
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Upon receipt of ONE Form 97-900, on August 20,1997, operations personnel
immediately verified operability of Valve 1-HV-4175 by performing stroke time
testing. The inspectors identified that no post-maintenance testing was completed
following maintenance on July 8. Technical Specification 4.6.3.1 states, "The
containment isolation valves shall be demonstrated OPERABLE prior to returning the
valve to service after maintenance, repair or replacement work is performed on the
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valve or its associated actuator, control or power circuit by performance of a
cycling test, and verification of isolation time." The failure to stroke time test-
Valve 1 HV 4175 following maintenance on the valve actuator is a violation of
TS 4.6.3.1 (50-445/9717-04).
c. Conclusions
The inspectors identified a violation of TS Surveillance Requirements when
operators failed to perform strche time testing of a containment isolation valve
following actuator maintenance. It was concluded that the licensee failed to follow
procedures in at least one instance when a containment isolation valve bushing was
. modified without the proper documentation, review, and approval. As part of this
issue, a review of other similar vendor-recommended maintenance activities that
may have been conducted without proper approval will be conducted. Moreover, it
was discovered that the steam generator ARVs had not been properly classified in
maintenance documents. These issues will remain unresolved pending the
licensee's investigation.
M8 Miscellaneous Maintenance issues (92902)
(Closed) Licensee Event Report 50-445/96 008: two Unit 1 pressurizer safety
valves were found with unsatisf actory lift setpoints. This event was previously
reviewed as documented in NRC Inspection Report 50-445/96 12;50-446/96-12.
The previous evaluation included reviews of activities associated with the licensee
corrective actions. No new issues were revealed by this report.
Ill.- Enaineerina
E1 Conduct of Engineering
a. insoection Scope f37551)
The inspectors .*eviewed the FSAR and design basis document (DBD) on the control
room emergency pressurization system. The inspectors discussed the surveillance
test results with the licensee,
b. Observations and Findinas
The inspectors found that the DBD and the FSAR listed the maximum flow rate of
each pressurization unit as 800 cim. The inspectors noted that Surveillance
Requirements 4.7.7.1b(1), 4.7.7.1b(3), 4.7.7.1d(1), 4.7.7.1g, and 4.7.7.1h list
- pressurization unit flow rate limits of 800 cfm i 10 percent (between 720 cfm and
880 cfm). The inspectors asked the licensee if the unit would be declared
inoperable and the flow reset if the pressurization unit flow rate was measured
above 800 cfm during a surveillance. The inspectors also asked if flow had ever
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been measured above 800 cim. The licensee was also asked to provide the basis-
for the GDC 19 dose calculation.
The licensee identified two occasions when the pressurization unit flow was left
greater than 800 cft,. A surveillance test on train A conducted on September 11,
1994,left the flow rate at 617 cfm. The next surveillance measured the flow rate
at 625 cfm on January 12,1996,16 months later. A surveillance test on train B
conducted on July 15,1996, also left the flow rate at 817 cim. The next
surveillance measured the flow rate at 781 cfm on August 8,1997,13 months
later. With one control room emergency pressurization system train inoperable, TS 3.7.7.1 requires that the train be restored to an operable status within 7 days or be
in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the
following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. On August 28,1997, the licensee determined that the design
basis for GDC 19 calculation was 800 cfm and not 800 cfm +10 percent, and
concluded that, for the two identified time periods, the limiting condition for
operation of TS 3.7.7.1 had not been met and that this was reportable to the NRC
under 10 CFR 50.73. The licensee determined that while the dose to the operators
would have increased, the dose was still below General Design Criterion 19 limits
assuming a flow rate as high as 888 cim.
The inspectors questioned the licensee as to whether one emergency pressurization
train had ever been technically inoperable for surveillance or maintenance purposes
while the other train was rendered inoperable because it had been left with a flow
rate above 800 cfm. At the end of the inspection, the licensee was in the process -
of determining the answer.
c. Conclusions
Two time periods were identified where the control room emergency pressurization
_
flow was left greater than design assumptions for longer than the outage time
allowed by Technical Specifications. This will remain an URI pending review of
control room operator dose calculations to determine the significance of leaving the
flow above the calculation limit, and pending a determination of whether the other
train was inoperable during the time period when the as lef t flow was greater than
600 cfm (50-445(446)/9717-05).
E2 Engineering Support of Facilities and Equipment
a. insoection Scope (37551)
The inspectors reviewed the FSAR, DBD, technical manuals, plant logs, and
trending data in order to dete rmine the significance of the Pressurizer Safety Valve
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2 8010B seat leakage. Interviews with licensed operators and with an engineer
were conducted.
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. b. Observations and Findinas
A concern with reactor coolant leakage into the pressurizer relief tank (PRT) from
the pressurizer safeties and/or the power operated relief valves (PORVs) was
identified as early as April 14,1997. At that time, the laak rate was small and no
correlation could be made as to the leaking component, Leakage into the PRT
continued at a very small rate (0.020 gpm) and no correlation could be made until a
containment entry identified that Pressurizer Safety Valve 2 8010D had an elevated
tailpipe temperature of 175'F as compared to 111 F for the other two safeties. At
that time, it was estimated that at the end of this operating cycle on
October 25,1997, the leakage from the safety would be approximately 0.32 gpm.
Within the past month, numerous temperature alarms have been received for the
PORVs and for higher tailpipe temperatures on Valve 2 80108.
Discussions with an engineer responsible for trending the leakage disclosed that as
of August 25, the leakage into the PRT was only 0.0432 gpm. The engineer also
stated that although leakage from Veive 2-8010B was erratic, only a slight increase
in leak rate was predicated until the end of the cycle. Based upon the review of -
trending data, the inspectors determined that the calculated leak rate was
appropriate. In addition, the engineer explained that Westinghouse personnel were
contacted and they recommended no action other than continuing to monitor leak
rate.. The inspectors reviewed the FSAR, DBD, and technical manuals and dio not
identify any concerns associated with long-term minor seat leakage,
c. -Conclusions
The inspectccs determined that no adverse operational concerns existed with the -
reactor coolant leakage from Pressurizer Safety Valve 2-80108.
IV. Plant Sunoort
R1 Radiological Protection and Chemistry (RP&C) Controls (71750)-
The inspectors determined that radiological postings were current; plant personnel
were aware of radiological work permit requirements; and RP personnel provided
good support to work activities. The. inspectors reviewed primary and secondary
chemistry results on a routine bais and found the results satisfactory.
During a plant tour, the inspectors identified a'non-radioactive drain posted with an-
"information tag" dated October 1994. The tag specified that the floor drain was
capped with an inflatable rubber device as a result of internal contamination.
Although not a requirement, the inspectors noted that a good practice would be to
clearly identify the drain as being potentially contaminated. The RP manager agreed
that the drain should be clearly labeled and a radioactive material tag was placed on
the drain. The drain was surveyed for activity and no activity was found. The
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manager indicated that they would perform a flush to check for activity and
determine posting requirements based on the sample. The inspectors determined
this to be appropriate action.
R4 Staff Knowledge and Performance in Radiological Protection and Chemistry Controls
(71707 and 71750)
. The inspectors observed a chemistry technician prepare equipment to support
containment atmosphere venting. The technician properly source-checked and reset
alarm setpoints for various detectors. The technician used excellent self verification
-techniques that ensured that the detector setpoints were adjusted in accordance
with the pre-release data.
S1 . Conduct of Security and Safeguards Activities
a. inspection Scone (717501
On August 27,1997, the inspectors performed a walkdown of outside spaces
within the protected area to verify adequate illumination,
b. Observations and Findinas
During the walkdown of outside spaces located within the protected area, the
inspectors identified that the undersides of two material storage trailers and a
vending truck appeared to have inadequate lighting. Security officers in the
secondary alarm station were informed of this concern and officers were stationed
at the suspect locations. Subsequent measurements identified that lighting
conditions were less than the 0.2 foot-candles required by the Physical Security
Plan. The actual readings were 0.121, 0.116, and 0.133 foot-candles.
Security personnel immediately installed temporary lighting and measured
illumination to ensure adequate lighting. Security personnel initiated Security Field
Report 0720 97 to document the discrepancy. Followup conversations with the
security manager indicated that security personnel had two opportunities earlier in
the evening to identify these discrepancies.
License Condition 2.H requires the licensee to fully implement and maintain in effect
all provisions of the physical security plan. Physical Security Plan, Revision 27,
Section 7.1.3,'"lliumination," required at least 0.2 foot-candles of light in the
protected area as measured on horizontal ground. The inspectors determined that
the f ailure to ensure the protected area is adequately illuminated is a violation of
License Condition 2.H (Violation 445(446)/9717-06).
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c. Conclusions
The inspectors identified a violation of illumination requirements within the
protected area. Security personnel responded immediately and installed temporary
lighting.
F2 Status of Fire Protection Facilities and Equipment
a. In3paglion Scope (64704)
This inspection included a review of the licensee's fire barrier inspection activities
which included a visual inspection of fire barrier installations that was performed to
determine the status of the Thermo-lag fire barriers. The inspection also included a
review of the corrective actions taken to address a licensee finding described in
ONE Fossi 97-324, dated April 4,1997, where fire barrier conditions where found
to be inconsistent with those described in fire barrier inspection data sheets,
b. Observations and Findinas
The inspectors found that Section IV-2,1.g.1.a of the licensee's Fire Protection
Report contained the inspection requirements for fire barriers. This document
required that fire barriers be inspected at least once every 18 months to confirm
operability by visual inspection of the exposed surfaces of each type of fire barrier.
The licensee considered this inspection to encompass all of the fire barriers located
in designated rooms.
The licensee conducts fire barrier inspections in accordance with Procedure FIR-
311, " Fire-Rated Assembly Visual inspection." This procedure implemented the
inspection requirements of Section IV-2.1.g.1.a of the Fire Protection Report.
Section 8.2.3 of Procedure FIR-311 specifically addressed visual inspection of the
exposed surfaces of the applied Thermo-lag on each applicable electrical raceway
component. Additionally, this section required verification that the Thermo-lag was
present, intact and showed no signs of degradation or damage. The procedure
considered degradation or damage to be flaking, peeling, gouges, cracks, water
damage, erosion and/or deformation of the Thermo-lag.
During a limited quality control walkdown of rooms 1-096 and 1-241 on April 3,
1997, to verify the effectiveness of the FIR-311 Thermo-lag inspection, the licensee
found discrepancies between the Thermo lag cable tray fire barrier assembly
locations and the inspection records; this condition was documented on ONE Form
97-0324. The licensee's investigation found that on March 20,1996, when the
Thermo-lag inspections were performed, Revision CP-4 of Drawing M1-1700,
"Thermo-lag and RES Schedule," which provided the installation requirements, was
in effect. The licensee found that during the upgrade of the Thermo lag fire barrier
enclosures in rooms 1-096 and 1-241 and in some raceways were ve.ded or deleted
from the M1-1700 series drawings Consequently, the technician performing the
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inspection was not aware that 8 of 23 fire barrier entries on the FIR 311 data
sheets for Room 1241 and 4 of 21 fire barrier entries on the FIR 311 data sheets
for Room 1096 were still on the Procedure FIR-311 inspection form even though
these fire barriers were removed from the rooms. As a result of this finding, quality
control expanded their walkdown inspection to include a 100% inspection of the
Thermo-lag installation in these rooms. This inspection identified the removed fire
barriers, it was noted that the quality control inspections did not identify any
deficiencies with the existing Thermo-lag installations which indicated that the
integrity of the Thermo-lag installations was acceptable.
The inspectors found that Revision 1 to Procedure FIR 311, dated April 12,1993,
was used to perform the fire barrier inspections in Rooms 1096 and 1-241 and that
the licensee's investigation determined that Procedure FIR-311 did not provide clear
instructions regarding inspection documentation. Review of FIR 311 by the
inspectors supported these licensee findings. That is, the performance of the
inspection of the Thermo lag in Rooma 1096 and 1-241 meant that the entire room
was satisfactory and not that each cable tray, conduit, etc., was inspected
individually. This type of inspection was consistent with the inspection
requirements of the Fire Protection Report.
Using the inspection criteria documented in Procedure FIR 311, the inspectors
performed a visual inspection of the Thermo-lag fire barrier installations located in
Rooms 1096 and 1-241, which were the rooms that were the subject of ONE Form
97 324. The inspectors did not identify any unsatisfactory Therme-lag fire barriers
during this inspection.
The inspectors noted that another finding identified in ONE Form 97-324 involved
advice to the technician performing the inspections by a training instructor.
Specifically, it appeared that instructions provided to the technician by the training
instructor were contrary to the requirements of Procedure FIR-311. The inspectors
found that the training instructor assumed that the cable trays listed on the
inspection sheets accurately reflected the as built drawings and that a 100%
inspection of the Thermo-lag meant that all cable trays were inspected individually.
However, the design changes to M1 1700 combined with the lack of awareness of
these design changes by the fire protection supervisor, who developed the list,
contributed to the erroneous inspection results. The inspectors also noted that
there was no formal training provided to the technician who performed the Thermo-
lag inspections in Rooms 1-096 and 1241, that is, only verbal instructions were
provided.
The licensee determined that the root cause of the discrepancies in the inspection
records was due to inadequate training of inspection technicians and the lack of
verification of the accuracy of the inspection data sheets provided to the inspecting
personnel.
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The inspectors found that the following corrective actions addressed in ONE Form
97-324 were accomplished:
- Drawing M1-1700 was revised as Revision CP-5 to incorporate all
outstanding design change notices,
- Procedure FIR 311 was revised as Revision 2 on June 20,1997 to correct
the procedure data sheets and clarify the inspection requirements, The
notable revisions were to Section 6.1 which required obtaining working
copies of M1-1700 including all outstanding design documents, and to
Section 8.2.4 which required that each item inspected be initiated and dated
on inspection data sheet FIR 311-1.
- This training consisted of a procedural overview, a discussion of the
inspection expectations and field familiarization. The discrepancies identitled
in ONE Form 97-324 were also included in this training. This three hour
training was given June 20 and July 2,1997.
The discrepancies between the Thermo-lag cable tray fire barrier assembly locations
and the completed inspection report were identified as a violation of 10 CFR 50.
Appendix B, Criterion V, " Instruction, Procedures, and Drawings." This non-
repetitive, licensee-identified and corrected violation is being treated as a Non-Cited
Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-
445/9723-01),
c. Conclusions
The inspectors concluded that the Thermo-lag fire barrier installations located in
rooms 1-096 and 1-241 were in accordance with the Fire Protection Report and
that the licensee's corrective actions for the findings in ONE Form 97-324 were
effective.
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the results of the inspection to members of licensee management
at the conclusion of the inspection on September 4,1997. During the exit meeting, the
licensee acknowledged that they planned to review the circumstances surrounding the
three examples of a failure to follow procedural requirements in order to identify any
common root cause and, based on their findings, take additional corrective actions if
needed. No proprietary information was identified.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
Bednar, D., Senior Quality Control Technician
Bhatti, O., Senior Regulatory Compliance Engineer
Blevins, M. R., Plant Manager
Curtis, J. R., Radiction Protection Manager '
Guldemond, W. G., Shif t Operations Manager
Kelley, J. J., Vice President, Nuclear Engineering and Support
Terry, C. L., Group Vice President, Nuclear Production
Walker, R. D., Regulatory Affairs Manager
INSPECTION PROCEDURES USEQ
37551 Onsite Engineering
61726 Surveillance Observations
62707 Maintenance Observations
64707 Fire Protection Program
71707 Plant Operations
71750 Plant Support Activities
92901 Followup - Plant Operations
92902 Followup - Maintenance --
92904 Followup - Plant Support
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ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50 445(446)/9717-01 VIO Three examples of operators failing to follow
procedures (Section 08.1).
50-445(446)/9717-02 IFl Compare testing of control room emergency
pressurization units to national standards
(Section M1.4).
50-445(446)/9717-03 URI Review scope of accumulator bushing modification
and generic aspects of maintenance modifications
- (Section M7).
50-445/9717-04 VIO Failure to perform stroke time testing of containment
isolation valve following actuator maintenance
(Section M7).
50-445(446)/9717-05 URI Control room dose and dual train inoperability
associated with control room emergency
pressurization units high flow rate (Section E1). -
50 445(446)/9717-06 VIO Inadequate protected area illumination (Section S1).
50-445/9717-07 NCV Licensee-Identified Discrepancies with Thermo-Lag -
Inspection Procedure (Section F2).
50-445/9723-01 NCV Licensee identified Discrepancies with Thermo-lag
Inspection Procedure (F2).
Closed
50-446/9714-02 IFi Review human performance enhancement system on
missed surveillance step (Section 08.1).
50-445/96-005 LER Entry into TS 3.0.3 - cracked weld in safety injection -
system piping (Section 08.2).
50-445/96-008 LER Two pressurizer safety valves found with
unsatisf actory lift setpoints (Section M8).
50-445/9717-07. NCV Licensee-Identified Discrepancies with Thermo-Lag
Inspection Procedure (Section F2).
50-445/9723-01 NCV Licensee Identified Discrepancies with Thermo-lag
inspection Procedure (F2).
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LIST OF ACRONYMS USED
ANSI American National Standards Institute
ARV atmospheric relief valve
ASME American Society of Mechanical Engineers
cfm cubic feet per minute
DBD design basis document
EDG emergency diesel generator
FSAR Final Safety Analysis Report
gpm gallons per minute
IFl inspection followup item
NCV noncited violation
, ONE Operations Notification and Evaluation
PORV power operated relief valve
PRT - pressurizer relief tank
i
psi pounds per square inch
OC quality control
RP radiation protection
TS Technical Specification ,
URI sinresolved item
VIO -violation
WO work order
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