IR 05000317/1990025

Insp Repts 50-317/90-25 & 50-318/90-25 on 900916-1020.No Violations Noted.Major Areas Inspected:Plant Operations, Radiological Protection,Surveillance & Maint,Emergency Preparedness,Security,Engineering & Technical Support

ML20217A024
Person / Time
Site:	Calvert Cliffs
Issue date:	11/08/1990
From:	Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217A019	List: IR 05000317/1990025 ML20217A013
References
50-317-90-25, 50-318-90-25, NUDOCS 9011200166
Download: ML20217A024 (25)

Text

i

,

,

.-

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.: 50-317/90-25; 50-318/90-25

.

License Nos.: DPR-53/DPR-69 -

>

Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203

]

Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, Maryhnd Inspection conducted: September 16,1990 to October 20,1990 Inspectors: Larry E. Nicholson, Senior Resident Inspector

. Allen G. Howe, Resident Inspector Tae J. Kim, Resident Inspector Victor M. McCree, Operations Engineer Jennifer L. Dixon, Reactor Engineer a

' Eric Benner, Reactor Engineer i

. William Oliveira, Reactor Engineer Approved by: AAd . >- 8 Pd hitr'ry (,/Nicholson, Acting Chief ' ' bate

'

Reactor Projects Section l A Division of Reactor Projects ,

t l

Inspection Summary: This inspection report documents routine and reactive inspections during day and backshift hours of station activities including: plant operations; radiological protection; surveillance and maintenance; emergency preparedness;. security;. engineering and technical L .

support; and ~ safety assessment / quality verificatio . -

L

'

Results: TA non-cited ~ violation was identified in which the license. exceeded technical y

~~

L ' specification 3.0.5 limiting condition for operation. An unresolved item was identified regarding

'

licensee review and correction of observed weaknesses in operations. An unresolved item was l identified- regarding: completicn of licensee evaluation' to determine the root cause and retrospective safety significance of previous operations with tilted ex-core nuclear instrument ;

detectors. An Executive Summary follow PDR ADOCK 05000317-Q PNU

-( ,

. _ . .

EXECUTIVE SUMM ARY Plant Operations: (Modules 71707,93702) Inspection effort during this period focur d on the startup and operation of Unit 1. The operations staff was responsive and their performance during the startup was generally good. Taken individually, the operational events that occurred during this inspection period had. minimal safety significance. However when viewed t collectively, these events and those discussed in NRC inspection report 50-317/90-23 and 50-318/90-23 were of concern and indicate weaknesses in the control of plant equipment and activities. The inspectors expressed concern that the common contributors, if left uncorrected, could lead to more serious events. This concern was discussed with senior station management during the inspection perio ,

Rndiolonical Protection: (Module 71707) The radiological controls staff was observed to be responsive in anticipating changing radiological conditions. Review of this area identified no adverse finding Surveillnnce and Mnintennnee: (Modules 61726,62703) Initial implementation of a quarterly system schedule program for coordinating maintenance appears sound. Routine review of maintenance and surveillance activities found that they were performed effectively and that problems were addressed and resolved in a conservative manne '

Emernency Preparedness: (Module 71707) Routine review in this area identified no noteworthy finding Security: (Module 71707) The licensee identified a failure to post adequate compensatory guards prior to lifting an equipment hatch. Licensee response to this event was adequat Routine review in this area identified no additional noteworthy finding Engineerine and Technient Support: (Modules 71707, 90712, 92700)

The engineering support for the operation of unit I was found to be generally thorough and well- ,

documented. The inspectors noted with concern the inability of the licensee to implement a comprehensive and quantifiable service water heat exchanger monitoring program prior to Unit I startu Snfetv Assessment /Ounlitv Verifiention: (Modules 71707,30703) The Startup Review Board provided an effective medium for communication and problem resolutio )

> ,  ;

u. .

DETAILS 1,. Summary of Facility Activities Unit 1 began the inspection period in cold shutdown. A startup was performed and the unit was taken to full power. A chronology of the significant events of this evolution was as follows:

'l September 17,0245 hour0.00284 days <br />0.0681 hours <br />4.050926e-4 weeks <br />9.32225e-5 months <br />s: Entered Mode 4 September 23,1005 hour0.0116 days <br />0.279 hours <br />0.00166 weeks <br />3.824025e-4 months <br />s: Entered Mode 3 October 3,0613 hour0.00709 days <br />0.17 hours <br />0.00101 weeks <br />2.332465e-4 months <br />s: . Achieved Criticality O.tober 4,0643 hour0.00744 days <br />0.179 hours <br />0.00106 weeks <br />2.446615e-4 months <br />s: Parallel to Grid October 12,0300 hour0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />s: Unit 1 at 100% powe 'l a

- Unit 2 remained defueled for the extended Cycle 8 refueling outage with the fuel in the ;

spent fuel pool. Repair of the steam generator thermal sleeves was completed during this inspection pe-io ? Plant Operations i

2.1- 'Onerational Safety Verification I The inspectors observed plant operation and verified that the facility. was operated !

safely and in accordance with licensee procedures and regulatory ' requirement . Regular tours were conducted of the following plant areas:

- control room .

-- security access point

'

-- primary auxiliary building -- protected area fence

-- radiological control point . -- intake structure

'

-- electrical switchgear rooms -- diesel generator rooms '

-- auxiliary feedwater pump rooms -- turbine building Control room instruments and plant computer indications were observed.for correlation between channels and for conformance with technical specification (TS) requirements. Operability of engineered safety features, other safety related systems and 'onsite and offsite power sources was. verified. The in_spectors observed various alarm conditions and confirmed that nperator response was in y accordance with plant operating procedures. Routine opeivions surveillance, testing was also observed. Compliance with TS and implementdion of appro-priate action statements for equipment out of service was inspeved. Plant radiation monitoring system indications and plant stack traces were reviewed for unexpected changes. Logs and records were reviewed to determine if entries were I

accurate and identified equipment status or deficiencies. These records included operating logs, turnover sheets, system safety tags, temporary modifications, and

-

"

. .

. .

}

the jumper and lifted lead book. Plant housekeeping controls were monitored, including control and storage of flammable material and other potential safety hazards. The inspectors also examined the condition of various fire protection, meteorological, and seismic monitoring. systems. Control room and shift manning were compared to' regulatory requirements and portions of shift turnovers were observed. The inspectors found that control room access was properly controlled

. and that a professional atmosphere was maintaine :

In addition to normal utility working hours, the review of plant operations was !

routinely conducted during portions backshifts (evening shifts) and deep backshifts (weekend and midnight shifts). Extended cove age was provided for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> -

during backshifts and 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> during deep backshifts. Operators were alert and displayed no signs of inattention to duty or fatigu .2 Etigineered Safety Features System Walkdown In addition to routine observations made during regular plant tours, the inspectors conducted walkdowns of the accessible portions of selected safety related system The inspectors verified system operability through reviews of valve lineups, control' room system prints, equipment' conditions, . instrument calibrations,

surveillance J test frequencies and results, and control' room indication Additionally, outstanding maintenance orders and nonconformance reports on the system were reviewed to determine their impact on system operability. The inspectors performed walkdowns of the following unit I systems during the ,

inspection period: '

-

Containment Iodine Removal System

-

Low Pressure Safety injection System

-

Auxiliary Feedwater System

-

125V DC System i

The inspectors found no unacceptable conditions.- i i

?

-

v ,: ,

l

..

c 3

.

i

~

2.3 Followun of Events Occurrinn Durine Insocction Period During the inspection period, the inspectors provided onsite coverage and F

followup of unplanned events. Plant parameters, performance of safety systems, and licensee actions were reviewed. The inspectors confirmed that the required notifications were made to the NRC. During event followup, the inspectors reviewed the corresponding CCI-I18N (Calvert Cliffs Instruction) " Nuclear Operations Section. Initiated Reporting Requirements" documentation, including j the event dettils, root cause analysis, and corrective actions taken to prevent recurrence. The following events were reviewe Feedwater Flow Transmitter Isolation Unit I was restarted with the feedwater flow transmitters to both steam i

- generators (S/G) _ inadvertently isolate Following criticality -os October 3,1990, the feed flow transmitter to the No '12 steam genera'ar -

did not come on scale. Instrument technicians entered the contaiaraent early the next morning (10/4) and discovered that the root isolation valves for flow transmitter FT-1121 were closed. The.tecl'nicians opened the valves, recalibrated the flow instrument, and thus corrected the problem with the No.12 S/G feedwater flow. The unit was subsequently paralleled a

'

to the grid and ramped to approximately 25% powe '

While increasing reactor power, the control room operators noticed that the feedwater flow to the No. .ll S/G appeared higher than normal. .With both steam generators steaming about the same and their levels remaining

'

constant, the licensee began to question the accuracy of the No. Il' S/G ,

feedwater flow. A containment entry was made that night (10/4) and the root isolation valves for the No. I1 S/G feedwater flow transmitter (FT--

1111) were found closed.- These valves were opened and the indicate .  ;

feedwater flow returned to normal. The licensee has concluded that these t valves were closed but leaked enough to provide a differential pressure and therefore a flow signa ,

h i

. e3--

"

!

..

4 l

,

The safety significance of this event was analyzed by the licensee and determined to be minimal. These flow transmitters do not provide an input to any engineering safety feature actuation system, although they are -

used for determining the calorimetric power level. Because the indicated flow for No.11 S/G was somewhat higher than the actual flow, the calorimetric power was indicating approximately 5% higher than actual power. When nuclear instrumentation power was adjusted to match .

calorimetric power, the protective setpoint would be reached earlier during an operating transient. The control room operators were observed to be controlling the plant using the most. conservative indication Administrative controls already in place would 'have prevented a nonconservative nuclear instrumentation adjustment if- the indicated !

feedwater flow had been erroneously low and resulted in an incorrect !

calorimetric power that was lower than actual powe ,

"

These instruments are listed in the technical specification as required post-accident instrumentation. The licensee was unable to determine why these

.feedwater flow instruments were included as post accident monitoring instruments since auxiliary feedwater flow is measured by a separate set of transmitters. A licensing effort has been initiated to remove this i requirement from the T .

The licensev management responded to this event by mandating that an event review be conducted prior to any further pover escalation. This review concludd that the procedure for verifying containment integrity (STP-O-55 A) was used to close the valves after an operations _ valve lineup had verified that the valves were open. The_ operators that used the STP j did not_ implement'the accompanying controls to ensure _ that the valves were appropriately repositioned. This problem appears to have' been ,

caused by a combination of an unclear procedure and an inattention to detai The licensee conducted an extensive. followup review and # ,

determined that this was' an isolated cas ,

The inspectors reviewed the licensee actions in response to this even This . review included attendance at a special Plant Operations and Safety Review Committee (POSRC). Licensee response to this event was determined to be thorough and prompt. The inspectors agreed with the .

licensee conclusions.-- Although the safety significance of this item was- [

minimal, it was.an example of an inattention to detail regarding plant ' i"

operations. No additional questions or concerns were identified.

p i

L l

l L

- _ - - .

.,

.., ,

..

' Overfill <d the Spent Fuel Pool On October 17,1990, at approximately 1:57 a.m., operators overfilled the spent fuel pool (SFP) when approximately 12,630 gallons of water was

,

inadvertently transferred from the No. 21 refueling water tank (RWT) to

"

the SFP. The overflow water entered the floor drain system in the auxiliary building and a cable chase located just above the SFP and 7 subsequently spilled into the lower levels of the auxiliary building including the No.' 12 emergency core cooling system (ECCS) pump roo Spillage into the lower levels occurred when the floor drain system backed up due to clogging of a strainer in the lines. The licensee has determined a that J1 the water that overflowed the SFP was contained in the auxiliary

,

- buildin No gaseous or particulate material was released via the 1 ventilation syste , The event was initiated when the operators were preparing to recirculate

'the No. 21 RWT per section XIV of-operating instruction (01) 24. A ,

drain path from the No. 21 RWT to the SFP was inadvertently established during the valve lineup for recirculation. The path included valve SFP-r 147 which was opened for an earlier fill of the spent fuel pool and :

'

improperly left open during the restoration of that task. Additional facts regarding this event include:

-

After notification by health physics personnel that water was ,

flowing down'the wall in the 45 foot level, the operators quickly responded and had isolated the flowpath about in 10 minute .

-

The auxiliary building operator performing much of tlm evolution y was relatively inexperienced (he had qualified in early July) and'

was not directly supervised for this operation.. He had not

, performed any SFP operations with the SFP lined up for cooling !

without purification as was the case when he took the watc .

-

SFP-147 should have been closed per Step 10 in section XIV of OI ,

'

24 (the SFP fill procedure). This step was vague and was apparently misinterpreted ~ by the operator involved. The step - ,

directs the operator to other sections in OI 24 to either restore or secure purification. Given this general step, operator knowledge

,that' restoration of purification was not desired, and that purification -was already " secured",' the . operator determined that this step was complete. In doir g so, the operator failed to close SFP-147 which was the purification return to the SFP.

1:

L -

There is apparently no clear policy on what self checks are needed to assure that steps in a procedure are appropriately complete . , ?., & .

-... s

>

i

';l!

• -

Operators have indicated that SFP operations are complicated and were aware of several mishaps. They very strongly stated that they

,

'

Z do all operations on this system with the greatest of care because :

s of the potential for mishaps. Operations management is also aware of this potential.

(, 1

-

Operators we e not monitoring RWT level indication nor the SFP

'

leve The setpoint for the SFP high level alarm is one half inch higher than the overflow to the floor drain system. A problem report was .

!

generated on September 28,1990, by design engineering to address this issu !

'

-- The SFP high level annunciator alarmed sometime earlier in the shift and had not cleared.

,

m

-

There . are at least two field . change requests- pending -

implementation and an additional " work smarter" recommendation >

to address previous SFP overflow event While recognizing that operations has taken interim actions to address this issue, the inspectors are concerned with this event and the indications that

'

previous similar events have occurred. This event resulted in radioactive contamination of numerous areas in the auxiliary building, the potential ,

wetting of electrical equipment in the auxiliary buPding, and the potential

. flooding of. the- ECCS pump rooms. An apparent ' weak procedure, inattention to detail, and unclear management expectations for procedure ;

performance played a role in this even , Inonerable Control Room HVAC Units On October 18,.1990, the licensee determined that the unit I technical-specification li_miting . condition for operation 3.0.5 may have' been exceeded on October 8,'1990, when the No.11 control room heating ventilation and air conditioning (HVAC) unit was removed from service l for approximately eight hours during preventive maintenance while the emergency power source was inoperable for the No.12 control room HVAC uni .

r ,

'

"

. - . .

7' -

e Preliminary conclusions from the licensee's evaluation indicated that 4 inadequate control of equipment status was a root cause of the event. The licensee also determined that operation of Unit I without the emergency power supply to No.12 control room HVAC unit for an unlimited period i of time appears inconsistent with plant safety, although allowed by the technical specifications. The No. 21 cmergency diesel generator supplies emergency power to the No.12 control room HVAC unit and has been inoperable since on or about July 15, 198 The licensee's corrective actions to date include: 1) restoring No. 21 ,

< emergency diesel generator to a functional status to support operability of No.12 control room HVAC; 2) review of other systems common to both

<

units for a similar concern; 3) evaluation to determine a need for a Technical Specification amendment; and 4) interim implementation of an administrative. functionality requirement for No, 21 cmergency diesel generator to support operability of No.12 control room.HVAC. The

-

licensee also plans to revise applicable operating instructions to reinforce 4 control _of equipment status for the control room HVAC units and: i associated sub-systems. The licensee' initiated a CCI-ll8 report and a problem report. Licensee plans to submit a Licensee Event Repor '

The inspector determined that the licensee's corrective actions were appropriate and timely. The apparent licensee-identified violation of the unit I technical specification limiting' condition for operation 3.0.5 is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied, However, the inspector expressed a concern to licensee management that inadequate control of equipment status,isla _ weakness, which warrants continuing-licensee management attentio '

The inspectors reviewed the above events in the aggregate and considered the following~ events from the previous inspection period, Inspection Report 50-317/90-23 and 50-318/90-23:

i

-

Incorrect system alignment resulting in both unit -1 cmergency diesel generators being inoperabl Inadvertent' start of Unit 1 No.12A reactor coolant pum . Loss of Unit I shutdown coolin :

i r

y

^

pp

, eg a . ,

. ,.

t

Taken individually, the operational events that occurred during this inspection period as well as those identified above had minimal safety

'

significance. However when viewed collectively, these events were of concern and indicate weaknesses in the control of plant equipment and

_

activities. The inspectors expressed concern that the common contributors, if left uncorrected, could lead to more serious events. This concern was discussed with senior station management during the inspection perio This item is unresolved pending licensee review and resolution of this matter. (UNR 50-317/90-25-01; 50-318/90-25-01) l IllicI Nuclear Instrument Detectors On August 24,1990, while in Mode 5, The licensee discovered that the Unit I nuclear instrument (NI) ex-core detectors for reactor protection system (RPS) channels "C" and "D" had been in their maintenance position, tangentially tilted, rather than their vertical-operating position, for an undetermined amount of time. The licensee solicited assistance from the reactor vendor for an evaluation.of detector operability in the tilted position.and requirements to ensure future operability. The power range detectors for RPS channels "A" and "B" are permanently restrained in the vertical position, i

The reactor vendor's analysis concluded that the detectors should be 3 considered: inoperable in the tilted position. In ' order to return the :

K detectors to' operability, the vendor recommended that the detectors be l placed in the vertical position. Although a decalibration existed after

,

returning the detectors to vertical position, the analysis determined that

. sufficient margin was contained in the trip setpoints to allow operation to a F _'35% power.

'

In accordance witti the reactor vendor's recommendations, the licensee

,

1 returned the detectors to the vertical position and performed excore Axial

.. Shape Index calibrations on all four channels at.30% power. No  !

E discrepanciesw~ ere noted during the calibrations. At 85% power, another . ;

excore Axial Shape Index calibrations was performed- to' ensure the detectors were -calibrated at conditions close to -nominal operatin conditions. The licensee. inspected the Unit 2 excore detectors for a ';

similar discrepancy and found that the NI excore detector for RPS channel

'

,

'

"C" was in a tilted position'. The detector was returned to the vertical position. -

,

L fs j ,;

i

..

,

9 ,

The inspetors determined that the ';censee's actions to identify and restore -

- the detectors to an operable condition was appropriate. The licensee's t evaluation is ongoing to duermine the root cause and retrospective safety [

i significance of previcas operations with tilted detectors. The licensee plans to submit a Licensee Event Report to the NRC within the i, ext few ';

'

weeks, documenting results of their evaluation. ' This item'is unresolved pending completion of the licensee's evaluation (UNR 50-317/90-25-02; ,

50-318/90-25-02). l

! Temocrary Modifications for Unit 1 The inspectors examined the licensee's program and instruction (CCI-ll7) for:

control of temporary modifications (TMs). The licensee uses TMs to disable, bypass or change systems, subsystems or components when equipment problems or plant circumstances require reconfiguration until the plant can be restored to

.its original condition or a~ design change is complete *

'The inspectors reviewed CCI 117 and found it clear and consistent with technical j

, ; specification Section 6.5.1.6. The inspectors found that the licensee maintained a TM log book for both units and log sheets that listed active TMs .were placed '

in front of the log books. "'he TM log books also contained data packages for all l

'

active TMs. Selected da'.a packages for unit I were examined and found to b complete. The inspectors also observed that quarterly reviews of TMs had been performed as required by CCI-ll7.' The inspectors noted that the number of- .!

r1 active temporary modifications, numbering approximately 50, appeared to be -

excessive and that about one-third of the active TMs had been in place for 2 or

.more years. ;The licensee acknowledged a need to reduce the backlog of TMs and has ' initiated recommendations to expedite the maintenance and engineering activities for aged temporary modifications. >The licensee noted that efforts to ensure long-term control of the' number of active TMs would require the

> recommendations to be formalized, i

I'  ;

q

'

L

..

h

-

F, -

,

,

n. , - y ,- .-

'

l

l

The inspectors developed a concern regarding the potential adverse impact of a l recent temporary modification. On October 1,1990, during a tagout of "11" l auxiliary fee 6vra',r pump governor, the inspectors noted that the tagout process 1 failed to recognize an unisolable suction source from the condensate storage tank l (CST). A relief valve in the auxiliary feedwater system recirculation line was

,, expected to provide isolation for the planned work.' The taggers were unaware

. however, that a recent TM (TM-190-134) had removed the internals of the relief

'

valve creating an uniso' ble path from the CST to the pump suction. The licensee ;

'

generated a Problem Report and a Non-Conformance Report (NCR) to document s and address the issue. The General Supervisor-Operations Support stated that h there is no immediate safety impact based on his staff's review of the active TM a The inspectors concluded that the safety significance of this issue was minimal, e However, the inspectors determined that this represented weakness in the

'

licensee's ability to assess the impact of TMs on system isolatio .5 -. Unit 1 Startun i

!

The inspectors monitored the preparations and return to power of unit 1 that l occurred during this inspection period. This expanded coverage. include : attendance at many of the key POSRC and site management meetings, as well as extensive around the-clock inspections during the power ascension. The following

' items were specifically reviewed during this effort, , Startun Checklist - .

Operations uses procedure OP-6, " Pre-Startup Checklist", to verify that >

q essential prerequisites have been accomplished prior to entry into the next startup mode. This procedure was maintained in the shift supervisor' office and was reviewed by the licensee management on a regular basis.-

The inspectors reviewed this procedure during the startup and concluded-the following:

-

' The. procedure wa's comprehensive in that it required the vsrious

. site organizations to verify that their respective . actions werc completed to support startup. One exception was noted, however, that the licensing staff.was.not-included in the checklist. This !

could be a problem if a licensing issue needed to be resolved prior to restar The use of excepticns was confusing and inconsistent. Station management urged the various site organizations to sign their respective blocks in the checklist early and list the outstanding items as exceptions. This philosophy created numerous exceptions that had to be cleared or evaluated prior to restart. As a result, this startup checklist was used to actually manage the end of the ( outage, in lieu of verifying readiness for restar .

• f. o .

..

The station management stated that they had reached similar conclusion No additional concerns or questions were identifie Valve Lincuos A complete walkdown was performed on the accessible portions of the following Unit 1 Engineering Safety Features Systems:

- Salt Water Cooling System

-

Component Cooling System

-

4.16 Kv Safety Electrical Distribution System

-

Auxiliary Feedwater System The inspectors verified system operability through reviews of valve lineups, equipment and space conditions, plant drawings, instrument calibrations, maintenance backlogs and system labeling. The above

,

systems were found to be in proper alignment and in generally good condition. During the course of this inspection, however, problems were

_

-

noted in the secondary plant with regards to labeling, missing supports,

'

broken handwhccis, and balance of plant drawings. Although these problems were limited to systems that support the main condenser, a

,"

failure in this area could result in more complicated plant operations. No other concerns were identified, Estimated Critical Condulett b , The estimated critical condition calculations were reviewe The procedure allows either a computer generated calculation or a manual calculation. A computer generated calculation was performed for this startup. The inspector verified that approvals were properly made and that

'o no discrepancies existed. Requh inents to achieve criticality within four'

hours of the calculation were met. Actual critical conditions were within the accuracy of the calculation. No unacceptable conditions were note !-

~

i

'

, o,

.

12 Extended Control Room Observation During the startup control room activities were extensively monitore The inspectors observed that the operators were responsive to alarms and indications. Communications were generally good and were reinforced by management. Procedures were in use for activities observed. The inspectors verified that the operators understood the reasons for the various annunciators tha' were in the alarm condition. The conduct of operations was determined to be professional during the startu . Radiolonical Controls During routine tours of the accessible plant areas, the inspectors observed the implementation of selected portions of the licensee's Radiological Controls Program. The utilization and compliance with special work permits (SWPs) were reviewed to ensure detailed descriptions of radiological conditions were provided and that personnel adhered to SWP requirements. The inspectors observed controls of access to various radiologi-cally controlled areas and use of personnel monitors and frisking methods upor exit from these areas. Posting and control of radiation areas, contaminated areas and hot spots, and labelling and control of containers holding radioactive materials were verifie d to be in accordance with licensee procedures. Health Physics technician control and nonitoring of these activitics were determined to be adequate. The following areas were reviewed during this period:

--

Controls for containment access and areas inside containment j

--

Controls for auxiliary building acce;s and areas within the auxiliary building No unacceptable conditions were identifie !

i 4. Malutenanct.and Surveillance hiaintenance Observation The inspectors observed maintenance activities, interviewed personnel, and !

reviewed maintenance orders (MOs) and other records to verify that work was conducted in accordance with approved procedures, technical specifications, and applicable industry codes and standards. The inspectors also verified that: !

redundant components were operable, administrative controls wem followed, ,

I tagouts were adequate, personnel were qualified, correct replacement parts were used, radiological controls were proper, fire protection was adequate, quality H control hold points were adequate and observed, adequate post-maintenance testing was performed, and independent verification requirements were implemente The inspectors independently verified that selected equipment was properly returned to servic ;

_ _ _

'

, o ,

Outstanding work requests were reviewed to ensure that the licensee assigned appropriate priority to safety related maintenanc The inspectors observed / reviewed portions of the following maintenance activities, Renalr of No.11 Auxillary Feedwater Pump Governor The scope of the work involved a modification of the base plate support to the governor linkage to allow alignment of the linkage in accordance with MO 200-270-479A. The inspectors observed portions of the linkage disassembly. The tagout was verified to be adequate and redundant components were verified operable. The inspectors noted that the mechanical maintenance s ipervisor and a quality control inspector were at the worksite. The inspectors assessed that the work was performed effectively and in accordance with the controlled work package, No.12 Steam Generator Wide Range 1.crel ludication Calibration The inspectors observed portions of the calibration of the No.12 Steam Generator wide range level indication in accordance with MO 200 269-435A. Controls for bypassing and restoring the Auxiliary Feedwater Actuation System trip logic were observed. Quality control hold points were observed. The work was performed efficiently and professionally, Troubleshooting of No.12 Main Steam Isolation Valve (MSIV)

The inspectors observed portions of the licensee's activities to address intermittent partial closure signals received on No.12 MSI The ,

licensee, after no success in detecting and isolating the cause of the closure signal, suspected that the cause was an intermittent ;round in the test solenoid. The licensee analyzed that any postulated failure e the circuit would not result in the inoperability of the MSIV. The inspectors reviewed licensee activities and attended licensee discussions on this matMr and found them to be conservative and appropriat ImDitmentation of Ouarterly System Scheduling The inspectors reviewed the implementation of the site quarterly system scheduling (QSS) process that occurred during this inspection period. This

'

system is designed to schedule system and train outages for both corrective and preventive maintenance on a schedule that is driven by the surveillance test interval. The licensee is developing this planning method to reduce the large corrective maintenance backlog while minimizing the i

unavailability of equipment. This program is designed to function while I a unit is at powe i

e 0 ,

j

.

'

The inspectors concluded that this program appears ambitious but achievable. Although it will take several years to fully implement this concept of scheduling work and performing tests, the potential benefits

'

appear substantia .2 Surveillance Observation The inspectors witnessed selected surveillance tests to determine whether properly approved surveillance test procedures (STP) were in use, technical specification frequency and action statement requirements were satisfied, necessary equipment ,

tagging was performed, test instrumentation was in calibration and properly used, testing was performed by qualified personnel, and test results satis 0cd acceptance criteria or were properly dispositioned. Portions of the following activities were reviewed, STP-O-9A-1. AFW System Refuelinn Test This STP was performed on several occasions between September 29 and -

October 2,1990, as post-maintenance operability tests for No. I1 AFW pump erratic speed control problems. The problems were evidenced by cyclic stroking of the turbine governor when operators attempted to start the pump from cold conditions. The licensee successfully performed the ,

'

STP after they replaced the governor and corrected binding problems in the governor linkage. The inspectors attended the pre-evolution brief and observed a thorough review of the procedure and general precautions by operators and maintenance. The inspectors observed good communication -

and effective coordination of the evolution by control room operator The inspectors also noted appropriate quality verification and management i attention during the tes STP-M 3-1. Main Steam Safetv Valve Tests

-

On September 26,1990, the inspectors reviewed selected portions of the licensee's tests of main steam safety valves in preparation for unit I ;

'

startup. The inspectors reviewed the licensee's procedure and observed the performance of tests locally in the MSIV room. The inspectors noted that the test was adequately supervised and controlled and was observed by a quality control inspector. At the completion of the test, four valves were weeping. Attempts to rescat the valves were unsuccessful for three of four valves. The licensee evaluated the situation and was satisfied that no safety concerns exist, The inspectors determined that the test conduct and post test actions were adequat .- _-_-_ _ _ _ - _ - _ _ - _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . ._ _ - - _

l

-

. o .

l

15

, Ennineerinn Test Procedure (ETP) 90-44. FCR 90-64 Low Pressure Post Modification This ETP was performed to test the auxiliary feedwater system (AFW)

modiDeations to the positioners for CV-4070 and CV 4071, the steam admission valves. The pretest brief was thorough. The inspectors observed the initial test of CV-4071 and noted that it was conducted in a professional and controlled manner. Good coordination was noted between the test director and the operators performing the test. The test was unsatisfactory because the time to reach the required flow was longer than allowable. This problem was corrected by adjusting the time delay in the positioner logic. Another problem occurred when the operator placed the CV-4071 c : trol panel switch to "open" to match actual valve position. The vaive moved to mid position and then reopened. The licensee determined that this response was due to the " break before make" characteristic of the handswitch, which reset the valve open logic and caused the valve to move. A problem report was written to address the issue and a label was placed next to the handswitches for the steam supply valves to instruct operators to not match switch positions after an automatic actuation. Final resolution of the problem report will evaluate the need to modify the circuit. The inspectors found that licensee performance of the ETP and actions taken in response to the problems observed were appropriate, Portions of the Followinn Additional Activities were Observed:

- STP-O-651, Quarterly Valve Operability Verincation STP-O-9-1, Auxiliary Feedwater Actuation (AFW) System Monthly Logic Test

- STP O 51, Auxiliary Feedwater System Test

'

- STP-0 6-1, RPS Startup Test

- P STP-13-1, Rod Drop and Group Rod Speed Test

- STP O-29-1, Partial CEA Movement Test STP-O 47-1, htSIV Partial Stroke Test

-

STP-M-2131, Calibration of Power Range Nuclear Instruments by Comparison with incore Nuclear Instruments No noteworthy deficiencies were identifie l

.

. o,  ;

..

5. Emergency Panaredness The inspectors routinely toured the onsite emergency response facilities and discussed program implementation with the applicable personnel. The resident inspectors had no noteworthy findings during this inspection perio . Security During routine inspection tours, the inspectors observed implementation of portions of the security plan. Areas observed included access point search equipment operation, condition of physical barriers, site access control, security force staffing, and response to system alarms and degraded conditions. These areas of program implementation were determined to be adequate. No unacceptable conditions were identifie On October 1,1990, the inspectors were informed of a security event that involved the opening of an equipment hatch in a vital area without proper security coverage. The !

licensee made appropriate notifications regarding the event. Licensee investigation determined that the event was caused by a personnel safety concern and the need to quickly ventilate the area of acid fumes produced from work in the area. The licensee determined that compensatory security measures were in place within 10 minutes and later took action to reinforce worker awareness of security requirements. The inspector had no further question . Engineering and Technical Support j l

The inspector reviewed selected design changes and modifications made to the facility '

l which the licensee determined were not unreviewed safety questions and did not require prior NRC approval e described by 10 CFR 50.59. Particular attention was given to p safety evaluations, Plant Operations and Safety Review Committee (POSRC) approval, j procedural controls, post-modification testing, procedure changes resulting from this modification, operator training, and Updated Final Safety Analysis Report (UFSAR) and drawing revisions. The following activities were reviewed: Auxillary Feedwater System Design and Procedural Controls The inspectors reviewed licensee activities to resolve concerns regarding the clarity of their commitments for the euxiliary feedwater (AFW) system. Several safety significant technical concerns involving high energy line break (HELB)

criteria and pipe breaks in the AFW discharge piping were raised from the

,

licensee's revie ,

-

i o ,

e

When reviewing the adequacy and licensing basis of the AFW s) stem, the licensee examined their March 9,1981, letter to the NRC which addressed the ability of the AFW system to ensure the capability to supply required flow to the steam generators assuming various pipe breaks and component failures. The licensee critically examined their HELB commitments and their designed ability to respond to pipe breaks in the AFW discharge piping. They concluded that the current design of the AFW system is appropriate, redundant, reliable and meets licensing requirements. They also reviewed procedural controls to ensure that cross-connected AFW pumps were appropriately considered in maintenance planning and plant status review The inspectors reviewed licensee documentation and attended various liceuce meetings to resolve the concerns. Licensee activities were thorough, we3 documented and effectively resolved the identified concerns. Ne unacceptable conditions were identifie .2 Service Water Heat Exchanger Fouling The inspectors reviewed the licensee actions regarding the fouling of the service water heat exchangers. These heat exchangers function during normal and accident conditions to transfer heat from equipment important to safety to the ultimate heat sin The inspectors determined that the licensee's program to monitor heat exchanger fouling and assess operability, as discussed in NRC Inspection Report 50-317/90-23, did not provide meaningful data dt.cing the restart of Unit 1. As a consequence, the licensee was forced to revise their monitoring program to use salt water flow as the key parameter. Although this method can detect an increase in macrofouling (i.e., tubesheet blockage), it is unable to detect problems with shell side microfouling. The previous program used a change in temperature across the heat exchanger to calculate a heat balance and derive a foullng facto The licensee concluded that lowering bay temperatures would provide an adequa:e safety margin to proceed without an established method for quantifying macrofotding (i.e., fouling factor) or monitoring microfoulin The inspectors oterved the engineering staff activities to resolve this issue and attended a presentation of their findings to station management. The inability of the licensee to impicment a comprehensive and quantifiable service water heat exchanger monitoring program prior to unit I startup was noted with concer Although it appears that adequate margin exists to ensure operability with current bay temperatures, it is also apparent that operability cannot be assured with significantly higher bay temperatures. The licensee established an engineering open item to develop and implement an improved heat exchanger monitoring program before bay temperatures begin to rise significantly next summer. No additional concerns were identifie '

- - - . _ _ _ _ - _ - _ - - - _ - _- - _____- __ ___-___ _ - - _ _ _ _ _ _ _

i

'

so .

o 18 Auxillary Feedwater Pumo Mininmm Recirculation Flow

,

The inspectors reviewed the licensee actions involved in changing the required minimum recirculation flow for auxiliary feedwater (A MV) pumps. The licensee engineering staff proposed a change in an acceptarse criteria of the STP-O-5-1,

" Auxiliary Feedwater System Test," to lower Qe minimum recirculation flow j from 80 gallons per minute (gpm) to 50 gpm, '.ollowing failure of the 'll' AFW ;

l pump to meet the required minimum recircu'.ation flow by 13 gpm on September 24,1990. The engineering justi' cation for the change concluded that the 50 gpm recirculation flow was adegi. ate to carry away pump heat. The licensee's POSRC approved the proposed change, l The licensee system engineers attribsted the decrease in the measured flow-rate to a recently implemented temporar', modification (TM-1 90134) which removed the internals of a relief valve in 'he AFW recirculation li.ie. As a result, the relief valve provided an unmea'urable flowpath to the pump suction which bypassed the measured recirculat'on flowpat The inspectors reviewed the mini.uum recirculation flow ongineering calculations, including the assumptions involved, and found no disen pancies. The inspectors also verified that the pump satisfied TS surveillance requirements. No additional concerns were identifie . Safety Assessment and Ouality Verifkatimi Plant Operations and Safety Review Committee The inspectors attended several Plant Operations and Safety Review Committee (POSRC) meetings. TS 6.5 requirements for member attendance were verifie The meeting agendas included procedural changes, proposed changes to the TS, Facility Change Requests, and minutes from previous meetings. Items for which adequate review time was not available were postponed to allow committee members time for further review and comment. Overall, the level of review and member participation was adequate in fulfilling the POSRC responsibilities. No unacceptable conditions were identifie .2 Review of Written Reports Periodic and Special Reports, Licensee Event Reports (LERs), and Safeguards Event Reports (SERs) were reviewed for clarity, validi ty, accuracy of the root cause evaluation and safety significance description, and tdequacy of corrective action. The inspectors determined whether further informatit n was required. The

,

inspectors also verified that the reporting requirements of 10 CFR 50.73,10 CFR l- 73.71, Station Administrative and Operating, and Security Procedures, and

'

Technical Specification 6.9 had been met. The following reports were reviewed:

-

. . . .

', o ,

,

O

LER 90-24 Failure to Test Fire Detection Circuit Supervision Due to inadequate Controls Special Report inoperable Meteorological Monitoring Instrumentation Channels (Dated 8/28/90) -

No unacceptable conditions were identifie .3 Startuo Review Board The inspectors attended the licensee Startup Review Board (SURB) conducted on ,

'

October 8,1990. The purpose of this meeting was to assess plant readiness for entry into mode The SURB committee recommended to the plant manager that restart should proceed pending resolution of previously identified concerns. The inspectors noted comprehensive and safety conscious discussions between management and SURB committee members which created an effective medium for communication and problem resolution. No concerns were identifie . Followun of Previous Inspection Findimts Licensee actions taken in response to open items and findings from previous inspections were reviewed.. The inspectors determined if corrective actions were appropriate and thorough and previous concerns were resolved. Items were closed where the inspectors determined that corrective a:tions would prevent recurrence. Those items for which additional licensee action was warranted remained open. The following items were reviewe .1 (Closed) UNR 50-317/8815-01 and 50-318/8815-01

,

Administrative procedures involved la processing faciliti change requests (FCRs)

were not up-to-datc. The inspectorf review confirms that the licensee has satisfactorily updated the procedures in question including a complete rewrite of CCI 126J, " Administrative Con'.rol of Facility Change Request". This item is closed.

In l

l

.

.. c ,

%o e ,

-

o

0,2 (Closed) UNR 50-317/89-200-09 and 50-318/89-200-09 (Closed) .NY3 50 317/89-15-06 and 50 318/89-16-06 These imics concern nndings, by the Special Team inspection and a followup inspection, that the licensee had failed to establish instructions, procedures, and plans for quality assurance inspection of safety related activities. These issues were identified and tracked by the licensee as ST129. Actions to correct STi 29 were reviewed and closed in NRC inspectic.i report 50-317/90-02 and 50-318/90-02. The inspectors determined that additional inspection of these items t was not required. These items are considered close ' (Closed) UNR .80-318/89 200-01

This issue concerns Gndings, by the Special Team inspection, regarding the lack of procedural controir for the calibration of certain M&TE prior to installation for testing, for receipt of *eturned M&TE, for recall of M&TE for recalibration, and for the reliability of th test data. These issues were identified and tracked by the licensee as STl-1. Attions to correct ST11 and unresolved item 50-317/89 200-01 were reviewed and closed in NRC inspection report 50 317/90- -

02 and 50-318/90-02, The inspectors determined that additional inspection of this item was not required. This issue is considered close . Management Meeting During this inspection, periodic meetings were held with station management to discuss-inspection observations and Rndings. At the close of the inspection period, an exit meeting was held to summarize the conclusions of the inspection. No written material was given to the licensee and no proprietary information related to this inspection was identine '

1 Ertlhulnary Insocction nndiens A non-cited violation was identified in which the licensee exceeded technical specification 3.0.5 limiting condition for operation. An unresolved item was identified regarding licensee review and correction of observed weaknesses in operations. An unresolved item was identined regarding completion of li#nsee evaluation to determine the root cause and retrospective safety significance of previous operations with tihed ex core nuclear instrument detectors.

!

l

. _ . ._- ._

m , , ,

o e ..

o

'

t 10.2 Attendance at Mananernent Meetinos Conducted by Region Butd Intneetorti inspection Reporting ,

Dale Subject Report N Insoeetor 10/5/90 Emuents 50-317/90-27 J.Jang 50-318/90 27 10/11/90 Security 50-317/90-28 G. Smith 50-318/90-28

\

>

-

.

L

r ..- ,

,a;s, i

,

Form 6 Rev. Dec. 86 OUTSTANDING ITEMS FILE SINGLE DOCKET ENTRY FORM RR.7RT HOU . Operations n 7. Engineering / a Docket No. 50-317 L1, Rad Con _n Tech Support 50-318 3. Maintenance .,,,,2 8. Safety Assess / n Originator: Nicholson 4. Surveillance J Qual. Ve . Emerg, Pre ,, Reviewing 6. Sec/Safegrds 2 - Supervisor: Cowgill item Number Type SALP Area Area Resp Action Due Date Updt/Close/Rpt Date Open 317/90-25-01 UNR- P1A 10 20-90-318/90-25-01 UNR

,

Originator _ Modifier / Closer Nicholson Description: Review the licensee's root cause evaluation and cor. .ctive actions regarding operational weaknesses that resulted in a series of operational events, item Number Type SALP Area Area Resp Action Duc Date Updt/Close/Rpt Date OpenC l 317/90-25 01 UNR- P1A 10-20-90 318/90 25-01 UNR Originator Modifier / Closer Kim Description: Review the licensee's root cause evaluation and determination of the retrospective safety significance of

_

E previous operations with tilted ex-core nuclear instrument detectors.

I*

l

!

!

l

f , , , Y~ ~ '

c 4.. .o 0,

tem Number Type SALP Area Area Resp Action Duc Date Close/Rpt Date Close 317/88 15-01 90-25 10-20-90 318/88-15-01 Originator Closer OLIVEIRA Description:

Item Number Type SALP Area Area Resp Action Duc Date Close/Rpt Date Close 317/89-200-09 90-25 10-20-90 318/89-200-09 Originator Closer HOWE Description:

i

'

.

< Item Number Type SALP Area Resp Action Due Date Close/Rpt Date Close 317/89-15 06 90-25 10-13 90 318/89-16-06 Originator Closer HOWE i

Description:

Item Number Type SALP Area Resp Action Due Date Close/Rpt Date Close 318/89 200-01 90-25 10-13 90 Originator Closer-HOWE O Description:

.. i h