ML20217L831
| ML20217L831 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217L038 | List: |
| References | |
| 50-443-98-01, 50-443-98-1, NUDOCS 9805040311 | |
| Download: ML20217L831 (25) | |
See also: IR 05000443/1998001
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-443
License No.: NPF-86
Report No.: 50-443/98-01
Licensee: North Atlantic Energy Service Corporation
Facility: Seabrook Generating Stetion, Unit 1
Location: Post Office Box 300
Seabrook, New Hampshire 03874
Dates: February 1,1998 - March 28,1998
Inspectors: Ray K. Lorson, Senior Resident inspector
Javier Brand, Resident inspector
Robert Summers, Project Engineer
Approved by: Curtis J. Cowgill, Chief, Projects Branch 5
Division of Reactor Projects
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cP8050403tt H30427
PDR ADOCK 0 4j3
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EXECUTIVE SUMMARY
Seabrook Generating Station, Unit 1
NRC Inspection Report 50-443/98-01
This inspection included aspects of licensee operations, engineering, maintenance, and
plant support. The report covers a 9-week period of resident inspection.
= Ooerations:
e The licensee had a method for evaluating spent fuel pool (SFP) liner integrity based
on the SFP sump in-leakage. However, in one instance licensee personnel did not
identify that the SFP sump level alarm was non-functional which precluded use of
this redundant method for monitoring the spent fuel pool liner integrity.
'o The inspectors noted good operator performance during motor driven emergency
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feedwater pump (EFW) testing and during venting of the emergency core cooling -
system (ECCS) discharge piping. The operators performed these activities in q
accordance with the applicable procedures and demonstrated an excellent
questioning attitude,
e .The safety system walkdowns were a positive initiative to improve the plant I
material condition. l
Maintenance:
e An electrician demonstrated excellent attention to detail and a questioning attitude,
to detect and identify the incorrect installation of two operating mechanism springs
on a safety-related breaker. The licensee determined that this condition did not
render the breaker (or any other similar breakers used at Seabrook) inoperable, and
initiated a plan to inspect and correct any additional non-conforming conditions prior
to the end of the next refueling outage.
e The licensee performed the planned freeze seal activities well. The work package,
and associated on-line maintenance and freeze seal evaluations, and management
oversight were effective. The inspector identified that the level of detail provided in
the freeze seal thawing instructions could have been enhanced. The licensee
promptly enhanced the work instructions to address this' concern.
e Safety-related degraded voltage bus testing was performed well, and the test
results satisfied technical specification requirements.'
e The licensee reported several examples of failure to develop adequa:e surveillance
test procedures. The licensee subsequently revised the test procecures and
properly tested each component. This licensee identified violation of failure to
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develop adequate test procedures is being treated as a non-cited violation. (NCV
98-01-01)
Enaineerina;
o The licensee failed to implement adequate design controls to ensure that the safety-
related components within the residual heat removal system pump room would
remain within their required temperature limits prior to modifying the room
ventilation system. A subsequent licensee analysis, performed after the NRC
identified this deficiency, indicated that the modification reduced the room
ventilation flow by about 50%, however, the room temperature limits would not
have been exceeded. This is a violation of 10 CFR 50, Appendix B Criterion lli
(NOV 98-01-02)-
o The licensee promptly reviewed and evaluated the identification of boric acid
accumulation on a RHR drain line. The identification of this condition reflected
positively on the licensee's new system walkdown program. The inspector noted
that the licensee's response to this condition did not include identification of the
- other plant areas potentially susceptible to periodic wetting. The licensee
l implemented appropriate actions to address this concern.
e Operations personnel performed well by identifying the safety injection accumulator
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L nitrogen leaks. The licensee promptly investigated the leakage and implemented
j appropriate repairs to reduce the leakage. Engineering properly assessed the impact
l of this minor leakage on the accumulatcr operability.
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e The licensee determined that incorrectly installed coupling hubs (a condition which
occurred during initial installation), caused a degraded EFW motor outboard bearing
condition. The pump remained operable in this condition and the licensee
implemented appropriate corrective actions to address this deficiency.
Plant Suooort:
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e ' The inspector that identified four workers were performing maintenance on the "B"
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containment spray pump in a posted as a contaminated area without wearing any
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protective clothing as required by the radiation work permit and posted
instructions. 'The licensee promptly evaluated this issue and implemented adequate
corrective actions. This is a violation of Technical Specification 6.10.1. (NOV 98-
01-03)-
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TABLE OF CONTENTS
EAGA
EX EC UTIV E SU M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
TA8LE OF CONTENTS .............................................. iv
l . Ope ratio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ,
02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . 1
02.1 Safety System Walkdowns and Status . . . . . . . . . . . . . . . . . . . . 1
04 Operator Knowledge and Performance .........................2 l
04.1 Operator Performance During Surveillance Testing . . . . . . . . . . . . 2
04.2 Spent Fuel Pool Liner integrity Monitoring . . . . . . . . . . . . . . . . . . 2 .l
08 Miscellaneous Operations issues (92901) . . . . . . . . . . . . . . . . . . . . . . . 3 i
08.1 (Closed) Unresolved item 50-443/97-06-01 . . . . . . . . . . . . . . . . . 3
II . Mainte na nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
M1.1 incorrect Spring Location on Safety Related Breakers . . . . . . . . . . 5
M1.2 Freeze Seal to Support Repair.of a Chemical and Volume Control
Valve...........................................6
M1.3 Safety Bus Degraded Voltage Surveillance Testing . . . . . . . . . . . . 7
M8 Miscellaneous Maintenance issues (92902) . . . . . . . . . . . . . . . . . . . . . . 7
M8.1 (Closed) Violation 50-443/96-04-01 . . . . . . . . . . . . . . . . . . . . . . 7
M8.2 Licensee Event Report Review: .........................7
Ill. Engineering ...................................................8
E1 Conduct of Engineering (37751) ..........,..................8-
E1.1 Residual Heat Removal System Ventilation Covers . . . . . . . . . . . . 8
E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . 10
E2.1 Accumulation of Boron on Residual Heat Removal System (RHR) Drain
Pipe Connection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
E2.2 Nitrogen Leak Of Safety injection Accumulators Supply Header . . 11
E2.3 Degraded Emergency Feedwater Motor Outboard Bearing, and
(Update) of Unresolved item 9 7-08-0 5 . . . . . . . . . . . . . . . . . . . 12 1
E8 Miscellaneous Engineering issues (92903) . . . . . . . . . . . . . . . . . . . . . . 13 l
E8.1 (Closed) Violation 50-443/96-08-01 . . . . . . . . . . . . . . . . . . . . . 13
E8.2 (Closed) Unresolved item (URI) 9 7-07-0 3, . . . . . . . . . . . . . . . . . 13
E8.3 (Closed) Escalated Enforcement issues (EEI) 97-08-02, 97-08-03, 97- ,
08-04, and 97-08-06. ..................... ........ 13 l
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IV. Plant Support ................................................14
R1 Radiological Protection and Chemistry Controls . . . . . . . . . . . . . . . . . . 14
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R1.1 Maintenance Work In Posted Contaminated Area Without Protective
Clothing
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S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . 16
S1.1 General Comment (71707, 71750) . . . . . . . . . . . . . . . . . . . . . . 16
F8 Miscellaneous Fire Protection Issues (92904) . . . . . . . . . . . . . . . . . . . . 16
F8.1 (Closed) Violation 50-443/96-03-01 . . . . . . . . . . . . . . . . . . . . . 16
F8.2 (Closed) Violation 50-443/96-03-02 . . . . . . . . . . . . . . . . . . . . . 16
V. Management Meetings ..........................................17
X1 Exit Meeting Summary . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
X3 Other NRC Activities ....................................17
PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
INSPECTION PROCEDU RES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
LIST OF ACRONYMS U SED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
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Report Details
Summarv of Plant Stglug
The facility operated at approximately 100% of rated thermal power throughout the
inspection period with routine minor power reductions performed to support instrument
calibrations and testing.
1. Operations
01 Conduct of Operations
Using inspection Procedure 71707, the inspectors conducted frequent reviews of
ongoing plant operations. In general, routine operations were performed in ;
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accordance with station procedures and plant evolutions were completed in a
deliberate manner with clear communications and effective oversight by shift
supervision. Control room logs accurately reflected plant activities, and observed
shift turnovers were comprehensive and thoroughly addressed questions posed by
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the oncoming crew. Control room operators displayed good questioning ~l
l perspectives prior to releasing work activities for field implementation. The
inspectors found that operators were knowledgeable of plant and system status.
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02 Operational Status of Facilities and Equipment
- 02.1 Safety System Walkdowns and Status (71707. and 62707) ;
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_ The inspectors routinely conducted independent plant tours and equipment
walkdowns of selected portions of the primary auxiliary building, emergency diesel
generator, service water, and emergency feedwater buildings. These activities ,
consisted of verification that safety-related system configurations, power supplies, j
process parameters, support systems, and operational status were consistent with !
Technical Specification (TS) requirements, and the Updated Final Safety Analysis
Report (UFSAR) descriptions. Additionally, system, component, and general area
material conditions and housekeeping status were observed.
The inspectors observed a significant increase in the number of equipment
daficiency tags hung on safety system components during the systematic licensee
walkdowns. The inspectors reviewed selected deficiency tags and noted that the I
deficiencies identified minor system defects that did not present any operability
concerns. The inspectors concluded that the system walkdowns were a positive
licensee initiative to _ improve the plant material condition and will continue to follow ;
licensee progress in this area. !
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04 Operator Knowledge and Performance
04.1 Operator Performance Durina Surveillance Testina
The inspectors noted good operator performance during motor driven emergency 1
feedwater pump (EFW) testing and during venting of the emergency core cooling
system (ECCS) discharge piping. The operators performed these activities in
accordance with the applicable procedures and demonstrated an excellent
questioning attitude.
The operators noted, while venting the ECCS discharge piping per operating
procedure, OX1456.02, "ECCS Monthly Valve Verification", that the procedure
acceptance criteria of "no gas observed" was not satisfied. Engineering determined
that the small bubbles were due to expansion of dissolved nitrogen in the water
during the. venting process and revised thc procedure to clarify the acceptance
criteria. The operators subsequently performed the venting activity satisfactory.
The inspectors obrerved that the EFW surveillance test procedures did not provide
i clear acceptance limits for venting the pump recirculation line. The in_spectors
discussed this issue with station management who agreed to review this procedure.
The inspectors concluded overall good operator performance during motor driven
l EFW pump testing and during venting of the ECCS discharge piping. The operators
performed these activities in accordance with the applicable procedures and
demonstrated an excellent questioning attitude.
04.2 Soent Fuel Pool Liner Intearity Monitorina
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a. Inspection Scooe
The inspectors reviewed the licensee's method for utilizing the spent fuel pool (SFP)
system sump to evaluate the SFP liner integrity, and also the basis for concluding
that identified leakage out of two SFP sump leak detection pipes was groundwater.
b. Observations and Findinas
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The SFP sump was designed to collect any leakage from the SFP liner. Seabrook
USAR Section 9.1.2.2 states, in part, that, "The SFP is monitored for leakage by a
series of leak detection channels located adjacent to each liner seam weld," and "by
monitoring the leakege rate, any change in the integrity of the liner can be
established." The inspector noted that this method of monitoring SFP liner integrity
was independent to SFP level indication system.
A deficiency tag, dated February 20,1998, stated that "two spent fuel pool leak
detection pipes have groundwater leaking." The inspector reviewed the applicable
system drawing and confirmed that the two potential leakage sources included:
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groundwater and the spent fuel pool. The inspector questioned operations -
personnel and the system engineer regarding the basis for concluding that this
leakage was groundwater and learned that chemistry personnel had analyzed the
sump contents and determined that the leakage was not SFP water. The inspector
concluded that the licensee had properly evaluated this leakage.
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The system engineer indicated that the SFP sump was equipped with a level alarm
set to actuate at one foot of water above the sump floor, and this volume of water
was equivalent to an approximate 0.25 inch decrease in SFP water level. The SFP
sump alarm response procedure required the checking of indications to confirm the i
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SFP liner integrity. The inspector concluded that the licensee had established a )
method for using SFP sump in-leakage to evaluate the SFP liner condition.
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The inspector questioned whether the SFP level alarm was functioning properly
however, based on a report from a radiation waste technician that approximately
four feet of water had been recently pumped out of the SFP sump. The licensee
reviewed the alarm database and determined that the SFP sump level alarm had not
actuated since January 1996. The licensee subsequently determined that the alarm
level switch was not functional. The licensee replaced and verified the switch to be
operational. The period of time that the alarm was non-functional was
indeterminate since no data was available regarding the actual sump conditions
during this period of time. The inspector concluded that the recent example where -
the licensee did not identify that the SFP sump alarm failed to actuate demonstrated
a weakness in the identification of degraded equipment. The licensee initiated an
adverse condition report (ACR) to review the program for monitoring the SFP sump.
c. Conclusions
The licensee had a method for monitoring SFP sump in-leakage as an independent
confirmation of the SFP liner integrity, however, in one example, licensee personnel
failed to identify that the SFP sump level alarm was non functional which prevented
use of this method.
08 Miscellaneous Operations issues (92901)
08.1 (Closed) Unresolved item 50-443/97-06-01: review of licensee decision to reduce
power during September 15,1997 feed pump oscillation event. This item refers to
the operational decision to contiriue with a planned power reduction to about 90%
power during the subject event after experiencing a failure of the rod control
system. An abnormal operating procedure for the rod control system required that
power evolutions be stopped when an urgent failure of the rod control system
occurs. At the time of the event the "A" main feed pump governor controls were
oscillating, resulting in associated high pressure steam supply pipe oscillations.
While the operators had determined that this condition did not warrant an
immediate plant trip or shutdown, there was concern about the possible adverse
effect of the oscillations on the equipment. As a result, plans were implemented to
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reduce power to either eliminate the oscillations or remove the "A" main feed pump
from service so that repairs could be effected.
When the operators initiated the power reduction a failure in the rod control system
occurred, such that the control rods could not be manually inserted. After
determining that the control rods were still able to perform the plant trip function
and that adequate shutdown margin was available, the decision was made to
continue with the planned power reduction using chemical shim injection (through
the emergency boration flow path). The basis for this decision was that, excepting
the feed pump oscillations, the plant was stable; and, that l&C recommended that a
small change in power may fix the feed pump control problem, or at least reduce
the risk of the oscillations causing equipment damage. The operators were also
briefed at the time that if, during the down power evolution, they believed the plant
was not stable, or if they were excessively challenged, that a plant trip should be
initiated.
As allowed by station procedures, the shift manager (a senior licensed operator)
authorized initiating a 10% power reduction to reduce the feed pump oscillations.
The basis for this decision comes from Station Management Manual Chapter 2,
which permits noncompliance with procedures for very limited conditions involving
either protection of the health and safety of the public, prevention of personnel
injury or life threatening situations, or prevention of damage to major plant
equipment. Operators concluded that the deviation from the abnormal operating
procedure was acceptable in order to avoid possible damage to the main feed
pump, or the associated steam supply pipe and resultant plant transient condition,
i Operators maintained all associated technical specification requirements within
allowable conditions, such as shutdown margin and axial flux difference. The
evolution was well controlled and at about 92 % power, the feed pump oscillations
were significantly reduced, removing the threat to this major plant equipment.
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in NRC inspection report 50-443/97-06, the inspectors questioned the
appropriateness of the operator actions during the September 15 event. An
unresolved item was issued pending review of the licensee's ACR findings. The
licensee noted that an ACR had not been immediately initiated following the
operator's decision to deviate from the operating procedure. At the time, the
licensee's ACR process did not explicitly require an evaluation for this type of
event. As a result, the licensee subsequently revised the guidance to require that
an ACR be initiated for events where this Station Management Manual guidance
was implemented. The inspectors determined during this current inspection that
the operator actions were taken in accordance with station procedures. This
unresolved item is closed.
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11. Maintenance
M1 Conduct of Maintenance -
M1~ 1. incorrect Sorina Location on Safety Related Breakers
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a; inspection Scone:
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On February 25, during refurbishment of a " spare" 4160 volt breaker, an electrician
identified that two breaker operating mechanism springs had been incorrectly
interchar.ged by the manufacturer (ABB Services Inc.), during a previous breaker
refurbishment. The springs, which included the charging carrier reset spring and 1
the third toggle tension spring, are very similar in appearance, however one of the d
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springs provides a greater tension force. The inspector evaluated the licensee's !
response to this issue, reviewed applicable documentation, and met with electrical
engineering personnel. 1
b .- Observations and Findinas:
The licensee disassembled the breaker and the springs were installed as
- recommended by the manufacturer. The final configuration was consistent with the
L Seabrook breaker refurbishment . procedure, and the vendor drawing. The vendor
l indicated that originally, these two springs were identical, but in about 1984, the
charging carrier spring had been redesigned to address a concern with their use in a - J
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different style of breaker, however, the part replacument was effected on several of
the vendor supplied breakers to eliminate duplicity.
The licensee identified approximately 23 other similar ABB breakers (fifteen of
which are currently being used in safety related applications) that may have been
affected by the possible misassembly. The licensee performed an operability l
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determination based on a vendor supplied analysis, which concluded that
interchanging the two springs did not affect the breaker operability. The vendor
also recommended that the springs be installed in the correct location, and
Seabrook initiated a plan to inspect all breakers and ensure adequate spring
~ installation by the end of the next refueling outage (in 1998).
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The licensee determined that this issue was not reportable under 10 CFR Part 21, )
" Reporting Defects and Noncompliance", because the breakers were evaluated to
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remain operable. The vendor initiated testing to demonstrate that the breakers with
the interchanged springs (incorrect spring location) will remain operable for the
entire service life (period of nine years), and is evaluating this issue for Part 21 I
applicability.
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c. Conclusion:
The inspector concluded that a Seabrook electrician demonstrated excellent
attention to detail and a good questioning attitude, to detect and identify the
interchanged installation of two breaker operating mechanism springs on a safety
related 4160 volt breaker. The licensee determined that this condition did not
render the breaker (or any other similar breaker used at Seabrook) inoperable, and
had initiated a plan to inspect and correct the situation prior to the end of the next
refueling outage.
M1.2 Freeze Seal to Sucoort Repair of a Chemical and Volume Control Valve
a. Insoection Scope:
On March 27, the inspector observed pipe freeze seal activities performed by
mechanical maintenance technicians to support inspection and repairs on valve CS-
V-408, which isolates the boric acid transfer pump minimum flow recirculation line.
The inspector reviewed the work package, applicable procedure, interviewed the
system engineer and work supervisor, and visually inspected the activities.
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The licensee conducted briefings prior to performing the freeze seal. The work
package was thorough and included an adequate on-line maintenance assessment.
Additionally, required precautions, system lineups and contingencies were included
to prevent or mitigate the consequences of a freeze seal failure. The inspector
observed proper field coverage by fire protection, management oversight and health
physics personnel. The system engineer was knowledgeable of the evolutions, and
provided good support. The oversight group performed a liquid penetrant test of
the affected pipe before and after the freeze, which confirmed adequate pipe
conditions.
The inspector noted that the work scope included an infrequently performed activity
to speed up the freeze seal thawing process to ensure that any boron in the pipe
quickly returned to solution. A heat gun with a capacity of 500'F was used, and
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the inspector noted that the licensee implemented controls which included
continuously monitoring the pipe surface temperature to prevent exceeding a
maximum temperature of 150'F. The inspector noted that the work procedure
instructions could have provided additional guidance to ensure that this infrequently
performed activity was performed correctly. The licensee addressed the inspector's
concerns by implementing a work scope change to include additional guidance. The
freeze seal and subsequent thawing process were completed successfully.
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c. Conclusion:
The licensee performed the planned freeze seal activities well and effective
management oversight and support were observed. The work package and
associated on-line maintenance and freeze seal evaluations were adequate. The
licensee implemented prompt actions to address an inspector concern regarding the
level of detail provided in the work package instructions for controlling the freeze
seal thawing activity.
M1.3 Safety Bus Dearaded Voltaae Surveillance Testina
The inspector observed electrical technicians perform safety-related bus degraded
voltage testing on February 25. The inspector noted that the test activities were
performed safely and in accordance with the test procedures. The inspector
observed good supervisory oversight, communications, and use of self-checking
practices. Measuring and test equipment were calibrated properly, and the
equipment performance satisfied the TSs surveillance requirements.
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M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation 50-443/96-04-01: inoperable turbine driven emergency feedwater
pump as a result of inadequate installation of mechanical seals. The inspector
verified the corrective actions described in the licensee's response letter, dated
August 8,1996, to be reasonable and complete. Among the corrective actions
verified were: revisions to the associated maintenance procedures describing
greater detail for seal clearances and use of calibrated M&TE to verify adequate
clearance; submittal of a supplement to LER 50-443/96-003 to better describe the
root causes of the failure, including the repeat nature of the problem and corrective
actions for that concern; and, changes to the corrective action program to provide
root cause training to the management review team and SORC members, and to
. improve the operational experience feedback process, providing clear guidance for
the types of events requiring a formal root cause analysis. No similar problems
were identified.
M8.2 Licensee Event Reoort Review:
The following licensee event reports (LERs) are closed based on an in-office review
of the LER and the planned and completed corrective actions.
.e (Closed) LER 50-443/96-06-00: Missed Surveillance Requirement -
e (Closed) LER 50-443/97-03-00: Missed Surveillance Turbine Trip on Reactor
Trip
e (Closed) LER 50-443/97-04-00: Remote Shutdown Circuits Control Room
Isolation Function Not Tested Completely
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e (Closed) LER 50-443/97-017-00: Inadequate SSPS Surveillance Testing
e (Closed) LER 50-443/98-001-00: Inadequate ECCS Venting Surveillance
Each of the licensee identified LERs listed above involved the failure to develop
adequate surveillance test procedures to ensure that all required system
components were tested properly. In each case the licensee declared the affected
system inoperable, entered TS 4.0.3 as appropriate, and successfully completed the
required testing within the allotted 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period. These events were of
minor significance since each system functioned properly when tested. The
inspector concluded that this was not indicative of a programmatic breakdown in
the surveillance test program. The licensee discovered these procedural deficiencies
during design basis and operational experience reviews and corrected the applicable
procedures. Additionally, the licensee implemented a generic procedure upgrade
project to identify and correct any additional potentially affected procedures. This
licensee identified violation of failure to develop adequate surveillance test
procedures is being treated as a non-cited violation consistent with Section Vll.B.1
of the NRC Enforcement Policy. (NCV 98-01-01)
lit. Enoineerina
E1 Conduct of Engineering (37751)
E1.1 Residual Heat Removal System Ventilation Covers
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a. Insoection Scooe:
The inspectors reviewed the engineering analysis performed to install temporary
covers over the ventilation duct openings in both residual heat removal (RHR) pump
rooms. The covers were installed per work requests (WAS) 97 WOO 3878 and
97 WOO 3884 to redirect the ventilation flow to minimize the potential spread of
contamination from minor system leakage through the bonnet studs of check valves
RH-V4, and RH-V-40.
b". Observations and Findinas:
The inspectors observed that the plastic covers were securely fastened to three
sides of the RHR pump room ventilation duct openings. The covers reduced the
area for ventilation flow and introduced an approximate 90' change in the direction
of the exit flowpath. The inspectors were concerned that these covers would
reduce the ventilation flow into the RHR pump room and possibly lead to a
overtemperature condition and failure of safety-related components inside the room
during a design basis event.
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The ventilation covers were installed per Procedure MA4.8, " Control of Temporary
Equipment", and were not intended to reduce the ventilation system flow. The
(MA4.8) evaluation provided general information and guidance and concluded that
the covers were acceptable as long as they only diverted and did not reduce the
approximate 12,700 cfm of flow required to maintain the room environmental
conditions. Neither the evaluation nor the work request provided any specific
design or installation details to ensure that the "as built" covers would meet the
design requirements.
In response to the inspector's questions, the licensee promptly removed the
ventilation covers and initiated an engineering evaluation (SS-EV-98-008) to
determine the impact of the covers on the ventilation system and RHR pump room
temperature. The evaluation calculated that the installed covers would reduce the
ventilation flow into the RHR pump rooms by about 50% to approximately 6100
cfm. This would increase the RHR pump room temperature following a loss of
coolant accident about 15'F from approximately 134*F to about 149'F.
The inspector noted that the postulated temperature increase would not have
exceeded the RHR pump room temperature limit of 189'F, and therefore would not
have rendered any of the safety related RHR pump room components inoperable.
The inspector noted that the failure to provide sufficiently detailed design i
instructions resulted in an inappropriate application of the MA4.8 program and a
significant reduction in the ventilation flow into the RHR pump room following the
installation of this modification. ;
Appendix B Criterion lil, requires, in part, that measures be implemented to assure
that the design basis is correctly translated into specifications, drawings, 1
procedures, and instructions. Contrary to the above, adequate instructions were
riot developed to ensure that the RHR pump room ventilation system modification
would not reduce ventilation system flowrate below an unacceptance level. This is
a violation of 10 CFR 50, Appendix B, Criterion lli (VIO 50-443/98-01-02).
c. Conclusion:
l
The licensee failed to implement adequate design controls to ensure that the safety- !
related components within the residual heat removal system pump room would ;
remain within their required temp.erature limits prior to modifying the room i
ventilation system. A subsequent licensee analysis, performed after the NRC
identified this deficiency, indicated that the modification reduced the room
ventilation flow by about 50%, however, the room temperature limits would not
have been exceeded.
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E2 Engineering Support of Facilities and Equipment-
E2.1 Accumulation of Boron on Residual Heat Removal System (RHR) Drain Pioe
Connection
a. Insoection Scope:
The RHR system engineer identified a ring of dried boric acid accumulation on the
half-coupling for drain valve RH-V-105 on March 5,1998, during a Seabrook
Improvement Plan system inspection. The engineer initiated an adverse condition
report (ACR 98-0782) to review this condition. The drain line is immediately below
relief valve RH-V57. The boron was identified between the pipe insulation and the
branch "T" fitting where the drain line connects to the "B" Train RHR system
discharge piping. The inspector reviewed the licensee's response to this issue,
visually inspected the piping, interviewed applicable personnel, and reviewed
nondestructive test results,
b. Qbservations and Findinas:
. The licensee promptly removed the insulation and inspected the pipe. No visible
evidence of leakage.was noted. Additionally, the licensee performed liquid
penetrant testing which revealed a linear indication in the 8 inch pipe within the
heat affected area of the 3/4 inch drain line weld connection. The licensee
performed ultrasonic testing to characterize the flaw, and determined that the
indication was small and the pipe had adequate wall thickness. The licensee
elected to repair this indication. The boron residue was attributed to previous fluid
l spillage when the relief valve, located above this piping, was removed for testing.
i
The inspectors determined that the licensee responded well to this condition, and
that it did not impact plant safety. The inspectors also noted that this finding
indicated that the current system walkdown inspections were thorough, and
improved over previous licensee inspection activities. The inspector noted a minor
weakness in that the licensee's investigation of an earlier event involving a minor
through wall pipe leak below valve RC-V89 did not include a review of other plant
areas where insulation was periodically wetted. The licensee subsequently
'
identified a total of five (5) other similar configurations susceptible to periodic
,. wetting (areas relating to relief valves RH-V13, RH-V25, SI-V101, SI-V113, and SI-
( _V76). Inspections of these areas by the system engineer identified no boric acid
deposits.- Additionally, since the RC-V89 incident, workers have been instructed to
exercise care to avoid wetting of insulation during relief valve removal, and to
request replacement of insulation when wetted.
c. Conclusion:
The licensee promptly reviewed and evaluated the identification of boric acid
, accumulation on a RHR drain line. The identification of this condition reflected
l
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11
I-
positively on the licensee's new system walkdown program. The inspector noted
that the licensee's response to this condition did not include identification of the
other plant areas potentially susceptible to periodic wetting. The licensee
implemented appropriate actions to address this concern.
E2.2 Nitroaen Leak Of Safety Iniection Accumulators Sunolv Header
i
a. Insoection Scooe:
On February 2,1998, operators identified that the nitrogen pressure in the safety
injection (SI) accumulators was decreasing by approximately 13.5 psig/ day. The
licensee performed system walkdowns, tests, and evaluations to identify the nitrogen
l leak source (s) and to implement repairs as necessary. The inspector evaluated the
l- licensee's response to these issues, interviewed the system engineer and operations
l personnel, and reviewed the engineering evaluations.
!
l
b. Observations and Findinas:
'
The Sl accumulators are safety-related, and are required to inject borated water into
l
! the reactor coolant system (RCS) piping loops during certain postulated loss of
l
coolant events. Technical Specifications (TS) Section 3.5.1.1, requires the
j accumulator pressure to be maintained between 585 and 664 psig. Nitrogen is used
l to pressurize and maintain the accumulators pressure within the required range.
The inspector reviewed and found acceptable a 50.59 evaluation performed to
support the leak detection testing. During their investigation the licensee identified
several sources of leakage including valve packing, seat, and body-to-bonnet joints.
The licensee tightened the body to bonnet bolts and adjusted the packing on those
valves that could be repaired at power, and initiated work requests to repair the
remaining valves. One of the largest nitrogen leaks was through the packing of valve
NG-V14 which the inspector noted had been recently repacked. The inspector-
identified that the licensee did not question whether this repeat packing deficiency
was due to improper maintenance performance. The inspector discussed this
observation with the system engineer who then initiated ACR 98-0771 to review this
issue.
The licensee evaluated the identified seat leakage through the "D" accumulator
nitrogen supply valve NG-V23 and the header manual isolation valve NG-V123 and
determined that the accumulator remained operable with the minor amount of seat
leakage,
c. Conclusions:
Operations personnel performed well by identifying the safety injection accumulator
nitrogen leaks. The licensee promptly investigated the leakage and implemented
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appropriate repairs to reduce the leakage. Engineering properly assessed the impact
of this minor leakage on the accumulator operability.
E2.3 Dearaded Emeroency Feedwater Motor Outboard Bearina. and (Undate) of Unresolved
Item 97-08-05
a.' Insoection Scope:
On February 4, the licensee operated the motor-driven emergency feedwater (EFW)
pump to investigate abnormal lubricating oil analysis results which indicated a high
.
tin content. The inspector reviewed these activities and the licensee's lubrication
analysis program. During this review, the inspector interviewed the system engineer
'
and the lubricating oil program coordinator, attended meetings and briefings held by
the licensee, and reviewed applicable documentation.
b. Observations and Findinas:
There are two EFW pumps at Seabrook required to supply water to the steam
generators to remove heat from the reactor coolant system during emergency
conditions. One pump is turbine driven, while the other pump is motor driven. Each
pump is capable of supplying 100% of the required flow.
The pump parameters such as flow, pressure and vibration were normal during the
run. The bearing temperature was approximately 179'F (below its design
temperature limit of 194*F) and appeared to be steady or increasing very slightly
when the run was secured. The licensee elected to open and inspcet the outboard
bearing following the run and identified that approximately .065 inches of material
had been removed from the non-load carrying motor bearing thrust face. The
licensee performed a root cause evaluation and determined the coupling hubs had
been installed backwards. The condition appeared to have existed since original
installation in 1987. The system engineer concluded, based on the pump test data,
and bearing condition that the EFW pump was operable. The inspectors
independently reviewed the data and determined that the operability _ determination
was sound.
The licensee replaced the bearing, correctly re-installed the coupling hubs and
i initiated an activity to inspect the other potential coupling hub installation problems.
!' The inspector concluded that the licensee responded well to this specific issue. -The
! inspector questioned however, whether licensee responded properly to earlier
'
indications of elevated tin concentrations within the motor bearing lubricating oil.
l Inspection report 97-08 identified potential program deficiencies involving -
l implementation of lubricating oil analysis program and opened unresolved item 97-
08-05 to review this issue. Evaluation of the licensee's response to the motor driven
EFW pump oil anomalies will be reviewed along with URI 97-08-05.
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The licensee has initiated measures to address the inspectors concerns including:
initiation of an evaluation team to evaluate and redesign Seabrook's lubrication
program, . industry bench marking and acquiring external assistance. Additionally,
the oversight program performed an independent evaluation and documented
extensive findings and proposed corrective actions.
c. Conclusion:
The licensee determined that incorrectly installed coupling hubs (a condition which
occurred during initialinstallation), caused a degraded EFW motor outboard bearing
condition. The pump remained operable in this condition and the licensee
implemented appropriate corrective actions to address this deficiency.
E8 Miscellaneous Engineering issues 192903)
E8.1 (Closed) Violation 50-443/96-08-01: covering floor drains in the emergency
feedwater pumphouse without performance of a safety evaluation. The inspector
verified the corrective actions described in the licensee's response letter, dated
December 20,1996, to be reasonable and complete. Among the corrective actions
verified were: revisions to appropriate maintenance and operating procedures to
ensure that 10 CFR 50.59 evaluations are performed prior to plugging or blocking
floor drains; engineering development of a list of floor drains requiring engineering _
review prior to blocking; revisions to the Regulatory Compliance Manual to provide ,
clear management expectations regarding 10 CFR 50.59 reviews for procedure )
'
changes; and, implementation of supervisor training for procedure revision reviews
and 10 CFR 50.59 evaluations. No similar problems were identified.
E8.2 (Closed) Unresolved item (URI) 97-07-03. Maintenance rule implementation for the
control building air conditioning (CBA) system. The inspector questioned in
Inspection Report 97-07 whether the licensee should have previously categorized the
CBA system as an "A-1" system in response to a history of repeated CBA
compressor (train) failures. During this period, the inspector reviewed the issue and
noted that the Expert Panel had categorized this system as a normally operating, non-
l risk significant system. This type of system would not have required train level
monitoring and therefore previous individual compressor failures would not have
! caused the maintenance rule performance criteria to be exceeded. The inspector
l concluded that the licensee's previous decision not to classify the CBA system as an
A-1 system did rot violate the maintenance rule requirements. This unresolved item
is closed.
E8.3 (Closed) Eccalated Enforcement issues (EEI) 97-08-02. 97-08-03. 97-08-04. and 97-
08-06. Inspection report 97-08 identified fcur issues tnat were classified as
apparent violations. These issues were discussed at a pre-decisional enforcement
conference on March 24. The NRC determined that three of the issues were
violation:, of NRC Requirements and transmitted this decision in separate
correspondence. These issues included eel 97-08-03, eel 97-08-04, and eel 97-08-
[
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14
06 which are being closed administratively. Followup licensee actions to these
violations will be tracked under the following enforcement action items: 98-073-
01013, 98-073-02013, and 98-073-03013.
The final issue involving operation of the safety injection system (eel-97-08-02) was
determined not to be a violation and is closed.
IV. Plant SuDDort
R1 Radiological Protection and Chemistry Controls
R1.1 Maintenance Work in Posted Contaminated Area Without Protective Clothina
- a. Inspection Scone:
On March 13,1998, the inspector observed three maintenance technicians and one
engineer performing maintenance activities on the "B" containment building spray
(CBS) pump, inside a posted contamination area without any protective clothing.
The activities wHch included sampling of the pump bearing oil, and repair of the
pump inboard bearing thermocouple, were being performed under radiation work
permits (RWPs) 98 R-00002, 98-R-00004, and 98-R-00011.
b. Observations and Findinas:
The inspector observed that all four workers had reached across the contamination
boundary with their bare hands to perform or support the maintenance activ! ties. The
inspector questioned the workers whether they had consulted with the health physics
department (HP) on the acceptability of working without protection inside the
contaminated boundary. One worker indicated that he had spoken with a HP
technician and believed that he had been authorized to perform the maintenance
activities without any additional protective clothing.
The inspector reported the events to a HP technician and notified the HP Manager.
Thwe individuals stated that they expected all personnel working inside a contaminated
area to wear, as a minimum, hand protection. The inspector reviewed the applicable
radiation work permits (RWP-98-R-00002,98-R-00004, and 98-R-00011) and
confirmed that all three RWPs required the ute of nuerts, and rubber gloves.
The inspector r . Aened iP radiological surveys of the applicable areas performed before
and after this e- m' o,d noted that the survey levels were lower (approx. 409
DPM/100 m ' ' man the required posting value (Greater than 1,000 DPM/100 cm).
l However, Hf e sted these areas conservatively due to the potential for varying
radic:cgical! onditions. None of the four workers or the tools used became
contaminated during these activities. however, the inspector was concerned that
!
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15
multiple workerc across a number of disciplines failed to comply with the Station HP
requirements.
On March 16,1998, HP management removed the workers' dosimetry to prevent their
entry into the RCA, and initiated a full investigation of this issue (ACR 98-0882). The
- event was thoroughly reviewed and several corrective actions were implemented
including:
o Coachin0 and counseling of allindividuals involved
- HP management held briefings with engineering and maintenance personnel, 'o
review this incident and reinforce HP expectations.
o Performing reviews of the rad training materials for " Contaminated Areas"
boundary delineation and controls, to ensure adequate understanding of postings
and to enforce contaminated area practices.
- Evaluating existing " Contaminated Area" postings, to ensure better delineation of
posted boundaries.
The inspector determined that the licensee addressed this issue well and that their
investigation was comprehensive.
Technical Specification (TS) 6.10.1 requires that procedures for personnel radiation
protection be prepared consistent with the requirements of 10 CFR Part 20 and shall be
adhered to for all operations involving personnel radiation exposure. Seabrook
administrative procedure RP 9.1, "RCA Access / Egress Requirements", revision 12,
dated 2/11/98, requires, in part, that personnel perform work inside the RCA in
accordance with the RWP and posted instructions. Contrary to the above, on March
13,1998, four individuals failed to comply with their RWP and posted radiological
instructions. This is violation of TS 6.10.1 (VIO 50-443/98-01-03).
c. Conclusion:
The inspector identified four workers performing maintenance on the "B" containment
spray pump which had been posted as a contaminated area without wearing any
protective clothing as required by the radiation work permit and posted instructions.
The Ucensee promptly evaluated this issue' and implemented adequate corrective
actions.
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S1 Conduct of Security and Safeguards Activities
S1.1 General Comment (71707, 71750)
The inspectors observed security force performance during inspection activities.
Protected area access controls were found to be properly implemented during random
observations. Proper est. ort control of visitors was observed. Security officers were
alert and attentive to their duties.
F8 Miscellaneous Fire Protection issues (92904)
F8.1 (Closed) Violation 50-443/96-03-01: two examples of staff failure to follow procedures
regarding control of combustible materials and repair of emergency lights. The first
example involved a failure to adhere to fire protection procedure 2.2, Rev 2, " Control of
Combustibles," when, on April 18,1996, three plastic pails of a Class I combustible
(epoxy primer paint) were inappropriately stored and left unattended in the turbine
building. The second example involved a failure to adhere to operations procedure
OSO443.47, Revision 5, "8 Hour Emergency Lighting Units Monthly Functional Test,"
when, on January 28,1996, three inoperable emergency lights were found, but not
properly reported to the Unit Shift Supervisor (USS), nor was a work order initiated to
restore the lights to service. The inspector verified the corrective actions described in
the licensee's response letter, dated July 12,1996, to be reasonable and complete.
Among the corrective actions verified were: procedure changes to ensure the control of
combustible materials, providing additional clarification of requirements for approved
storage; procedure changes to ensure timely notification of the USS and initiation of
work orders for inoperable emergency lighting; and, licensee records indicating that
othar required activities were completed. No similar problems were identified. This
item is closed.
F8.2 (Closed) Violation 50-443/96-03-02: one example of inadequate fire protection
procedures regarding timely restoration of inoperable emergency lighting. This violation
involved two Seabrook procedures not incorporating Seabrook Design Basis Document,
DBD-FP-01, " Emergency Lights," design criteria of returning emergency lights to an
operable status within 30-days of being identified as inoperable. The inspector verified
the corrective actions described in the licensee's response letter, dated July 12,1996,
to be reasonable and complete. Among the corrective actions verified were: procedure
changes to the associated surveilla;.ce and maintenance procedures to ensure that
inoperable emergency lighting would be assigned a priority 2 work request; completien
of an effectiveness monitoring program in the maintenance organization to ensure that
'
. this violation did not repeat; and, a re-evaluation by the maintena.1ce organization of
other similarly "self-identified" violations where corrective actions had not been fully
implemented leading to repeat violations. This latter action was considered by the
inspector as a comprehensive review and self-assessment of the corrective actions
program tracking system for maintenance concerns. No similar problems were
'
identified. This item is closed.
.. . - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -
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V. Manaoement Meetinas )
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management,
following the conclusion of the inspection period, on April 8,1998. The licensee
acknowledged the findings presented.
X3 Other NRC Activities
A pre-decisional enforcement conference was held on March 23,1997 at the Region I
office in King of Prussia, Pennsylvania. The conference was conducted to review four
apparent violations of 10 CFR 50 Appendix B Criterion XVI. The NRC enforcement
decision was transmitted via separate correspondence.
,
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
W. Diprofio, Unit Director
R. White, Design Engineering Manager
J. Grillo, Technical Support Manager
G. St Pierre, Operations Manager
B. Seymour, Security Manager
J. Linville, Chemistry and Health Physics Manager
J. Vargas, Engineering Director
.
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INSF'ECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observation
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
Facilities
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
NCV 98-01-01 Failure to Develop Adequate Surveillance Test Procedures
VIO 98-01-02 Failure to implement Adequate Design Controls
VIO 98-01-03 Failure to Adhere to Radiation Work Permit and Posted Instructions
Closed
VIO 96-03-01 Failure to Follow Procedures Regarding Control of Combustible Materials
and Repair of Emergency Lights
VIO 96-03-02 Inadequate Fire Protection Procedures Regarding Timely Restoration of
,
VIO 96-04-01 Inadequate Emergency Feedwater Pump Maintenance
l URI 97-06-01 Review of Operator Actions Following a Main Feedwater Pump Pipo
l Oscillations
l LER 96-06-00 Missed Surveillance Requirement
l LER 97-03-00 Missed Surveillance Turbine Trip on Reactor Trip
! LER 97-04-00 Remote Shutdown Circuits Not Tested Completely
LER 97-17-00 Inadequate SSPS Surveillance Testing
LER 98-01-00 Inadequate ECCS Venting Procedurs
NCV 98-01-01 Failure to Develop Adequate Surveillance Test Procedures
VIO 96-08-01 Covering Floor Drains Without a Safety Evaluation
URI 97-07-03 Review of Maintenance Rule Characterization of Control Building Air ;
Conditioning Compressors l
eel 97-08-02 Operation of the Safety injection System Test Header j
eel 97-08-03 Failure to implement Prompt Correctivo Action for a Degraded Pipe
eel 97-08-04 Failure to implement Prompt Corrective Actions for Degraded Control
Building Air Conditioning Compressors
eel 97-08-06 Failure to implement Prompt Corrective Actions for a Degraded Positive
Displacement Charging Pump ,
i
Discussed
URI 97-08-05 Potential Lubricating Oil Program Deficiencies
i
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LIST OF ACRONYMS USED
ACR Adverse Condition Report
ASME American Society of Mechanical Engineers
CAS Central Alarm Station
CBS containment building spray
EDG Emergency Diesel Generator
FME Foreign Material Exclusion
gpd gallons per day
gpm gallons per minute
LCO Limiting Condition for Operation
MOV motor operated valve
MPCS Main Plant Computer System
NSARC Nuclear Safety and Audit Review Committee
psig pounds per square inch gauge
QC Quality Control
l SIR Station Information Report
l. SORC Station Operations Review Committee
SUFP Startup Feedwater Pump
i
l TDEFW Turbine Driven Emergency Feedwater Pump
L _TS Technical Specifications
'
UFSAR Updated Final Safety Analysis Report
WR Work Request
I