ML20133K935
| ML20133K935 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133K926 | List: |
| References | |
| 50-445-96-16, 50-446-96-16, NUDOCS 9701210409 | |
| Download: ML20133K935 (19) | |
See also: IR 05000445/1996016
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ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.. 50-445;50-446
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Report No.: 50-445/96-16:50-446/96-16
Licensee: TU Electric
Facility: Comanche Peak Steam Electric Station, Units 1 and 2
Location: FM-56, Glen Rose, Texas
Dates: Nodmber 10 through December 21,1996
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Inspectors: A. T. Gody, Jr., Senior Resident inspector
l H. A. Freeman, Resident inspector
V. L. Ordaz, Resident inspector
,
G. M. Good, Senior Emergency Preparedness Analyst
R. A. Kopriva, Project Engineer
Approved By: J. l. Tapia, Chief, Project Branch A
Division of Reactor Projects
ATTACHMENT: Supplemental information
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9701210409 970116
PDR ADOCK 05000445
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I EXECUTIVE SUMMARY
Comanche Peak Steam Electric Station, Units 1 and 2
NRC Inspection Report 50-445/96-16:50-446/96-16
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( This inspection included aspects of licensee operations, engineering, maintenance, and
l plant support. The report covers a 6-week period of resident inspection.
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Doerations
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i Operations demonstrated good ownership of the plant during postrefueling outage cleanup
inside radiological controlled areas (Section 01.1).
Operators exceeded the reactor power ramp rate procedure limitations during power
- ascension (Section 01.2).
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l Control room operators were knowledgeable of annunciators, but failed to communicate
! them to unit supervision on some instances during power ascension activities
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Operations surveillances were conducted well, with good communications and independent
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verification utilized (Section 02.2).
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! An operator error during initial main turbine loading resulted in a significant reactor coolant
system temperature transient and a loss of reactor coolant system letdown (Section 05.1).
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i An operator inadvertently deenergized a safety bus when the wrong component was
j operated during an emergency diesel generator surveillance (Section 05.2).
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- Auxiliary operators were inconsistent in fuse replacement processes, and the inconsistency
may contribute to premature fuse holder degradation (Section 05.3).
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l Maintenance
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Electricians exhibited the appropriate level of knowledge and exercised the proper amount
- of safety awareness during emergent maintenance on a safety-related battery cell
j (Section M1.1).
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i Overall, battery maintenance activities were performed well and in accordance with
j procedural requirements (Section M1.2).
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Enaineerina
- While reactor engineering continued to demonstrate technical proficiency, the inspectors
- again observed minor attention-to-detail deficiencies, mainly of an administrative nature
I (Section E1.1).
I Engineering had appropriately documented and evaluated the lack of breaker coordination
for the reactor protection set primary and alternate power supolies (Section E2.1).
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Continued excellent use of vendor information led to the identification of unaccounted
aluminum in containment preaccess filters. The licensee's decision to replace the filters
was conservative (Section E3.1).
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Plant Sucoort
The commitment to perform onshift dose assessments was clearly described in the
emergency plan and implementing procedures. Further evaluation of the information
obtained using the temporary instruction will be conducted by NRC Headquarters personnel
(Section P3.1).
Radiation workers were generally knowledgeable of their radiation work permit
requirements (Section R4.1).
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Reoort Details
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l Summarv of Plant Status
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Unit 1 began this inspection period in Mode 5, making preparations for entering Mode 4
after completion of the fif th refueling outage. Unit 1 entered Mode 1 operations on
November 16 and attained 100 percent power on November 22. Unit 1 remained at full
power through the end of the inspection period.
Unit 2 began this inspection period at 100 percent power. On December 10, power was
briefly lowered to 50 percent as a precaution prior to performing maintenance on an
instrument inverter power supply. The unit was returned to full power and remained there
through the end of the inspection period.
l. Operations
01 Conduct of Operations
01.1 Plant Tours
a. Insoection Scone (71707)
The inspectors conducted periodic plant tours of both units during the inspection
period to ascertain the plant material condition and assess the conduct of operations
and maintenance. ,
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b. Observations and Findinos
The inspectors found that material condition and housekeeping were generally good, l
with a few exceptions. The inspectors accompanied operators on the Unit 1 1
postrefueling outage containment close-out inspection. A considerable amount of
debris was discovered on the floor from previous maintenance activities. Operators
performing the containment close-out inspection appropriately concluded that the
Unit 1 containment building was not sufficiently clean for entering Mode 3 and
provided good feedback to outage management on what actions needed to be
performed. The inspector found that the containment close-out effort was an
iterative process that ensured that the containment building was properly cleaned
for the operating cycle and that the operations department demonstrated good
ownership of the plant. The inspector entered an emergency core cooling system
containment sump structure and found that it was clean and free of debris. The
inspectors also found that the postrefueling outage cleanup in the radiological
controlled areas outside of containment was good.
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01.2 Unit 1 Reactor Power Ramo Rate
a. Insoection Scone (92901 and 92903)
On November 17, the licensee identified that the procedurallimit for reactor power
ramp rate was exceeded during a power ascension on Unit 1. The inspector
reviewed the reactor power records, corrective actions, and fuel design limits
associated with the event.
b. Observations and Findinas
During power ascension, operators are required to limit power ramp rate to
s 3 percent per hour when reactor power is greater than 20 percent, in accordance
with Procedure IPO-003A, " Plant Operations." Below 20 percent reactor power,
there are no power ramp restrictions. On November 17, Unit 1 operators raised
reactor power at approximately 6 percent per hour, until the main generator reached
20 percent, without realizing that it corresponded to 26 percent reactor power.
Operations held reactor power steady for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to ensure no pellet-to-clad
interactions would occur during the planned power ascension. The inspector
discussed the 2-hour soak period with reactor engineers, reviewed the vendor
recommendations associated with reactor fuel soaking, and found that the
licensee's decision to perform the soak was appropriate.
Operators exceeded the power ramp rate because they mistakenly began monitoring ,
the rate when they thought main generator load was equivalent to 20 percent j
reactor power rather than at the 20 percent reactor power indicated by the nuclear i
instruments. The licensee stated that Procedure IPO-003A contributed to the
misunderstanding and, following a review of the procedure, the inspector agreed.
The inspector reviewed the licensee's changes to Procedure IPO-003A and found
that they made it very clear when operators were required to begin monitoring
reactor power ramp rate.
The inspector reviewed the Unit 1 reactor power records and found that operators
misread them since the actual ramp rate was 7.5 percent per hour in lieu of 6
percent per hour. The inspector discussed the actual ramp rates with reactor
engineering and reviewed the fuel design requirements to determine if exceeding the
power ramp rate procedural limit could induce f ailures on the Westinghouse and
Siemens fuel in the core due to excessive fuel pellet-to-cladding interactions. The
inspector found that the Siemens fuel was operated within its design limits since
there are no restrictions on Siemens fuel below 87 percent reactor power, and the
Westinghouse fuel was operated within its design limits since the ramp rate was i
below a previously evaluated reactor power ramp rate of 10 percent. The inspector j
found that operations was not accurate in their interpretation of the reactor power
records. However, the inspector agreed with the licensee's conclusion that,
although the procedurallimit of s 3 percent per hour was exceeded, it was unlikely
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l that any fuel damage would be caused due to the increased power ramp rate. This
licensee-identified and corrected violation is being treated as a noncited violation,
i consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-445/9616-
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01.3 Unit 1 Power Ascension
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a. Insoection Scooe (71707)
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The inspector observed control room operators perform portions of the power
ascension following the Unit 1 refueling outage. These included the turbine
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generator surveillances, reactor criticality, and Mode 1 entry.
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b. Observations and Findinas l
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d During the power ascension activities, the inspector obse.vad the communications j
l between control room operators and the unit supervisor un both the primary and I
secondary plant. The inspector identified instances where operators physically I
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acknowledged annunciators on the secondary plant, but failed to properly announce
the annunciators and communicate them to the unit supervisor who was in the
j process of monitoring the reactivity changes and stabilization of the primary plant.
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The inspector informed the unit supervisor of the observations and he immediately
corrected the situation.
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Overall, the inspector found that operators maintained continuous and thorough
monitoring of the reactivity changes and that apt.rators were knowledgeable of the
annunciators. Operators generally exhibited propor communication during
evolutions, with some minor exceptions noted above that deviated from
management expectations. The inspector found that the communication
observations were isolated and that the unit supervisor took the appropriate
corrective action.
O2 Operational Status of Facilities and Equipment
O 2.1 Periodic Control Board Walkdowns and Loa Review
a. Insoection Scone (71707)
The inspectors periodically performed a walkdown of the Units 1 and 2 control
boards, reviewed operating logs, and observed the conduct of operations,
b. Observations and Findinas
The inspectors noted that the licensee effectively maintained plant equipment in a
manner that frequently resulted in no control board annunciators being illuminated.
For degraded annunciators, the cause of the problem and the corrective action was
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properly identified in plant operating logs and any required compensatory measures
were appropriately identified and implemented. Operators were knowledgeable of
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the cause of alarm conditions and were generally cognizant of corrective actions in
progress. Operating logs were maintained in a legible E.nd auditable form and the
inspectors found them to be generally complete. i
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The inspectors noted good communications among operators and the unit
supervision, with very few minor exceptions. When communications were weak,
, the inspectors observed unit supervision correct the problem. Equipment was found
l to be aligned properly for both operating and standby equipment.
02.2 Ooerational Surveillances l
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a. Insoection Scone (61726) l
The inspectors observed all or portions of the following operational surveillance
tests:
- Unit 2 Safety injection Pump 2-01 Operability Test (OPT-204) on
- November 20
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l * Unit 2 Safety injection System Radioactive Leakage Inspection Test
(ETP 2048) on November 20
- Unit 2 Train A Safeguards Slave Relay K608 Actuation Test (OPT-466B)on
November 21
j b. Observations and Findinas
The inspectors verified that the surveillances were performed in accordance with
procedures and that the equipment was appropriately restored following the
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surveillance tests. The inspectors reviewed the test results and found that all test
requirements were satisfied. Communications between the operators were good,
and the independent verification steps in the procedures were performed correctly.
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l O2.3 Unit 1 Turbine Oversoeed Protection System Test
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l a. Insoection Scoce (61726)
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On November 16, the inspector observed the Unit 1 turbine overspeed protection
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system tests. These tests were performed to verify the operability of each
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mechanical overspeed trip device as required by Technical Specifications. An actual
turbine overspeed test, which was conduced in accordance with vendor
recommendations, was also observed.
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b. Observations and Findinas
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j The inspector reviewed the procedure prior to the surveillance tests and verified that
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j the procedure met Technical Specification requirements. The inspector observed
j that auxiliary operators, system engineers, and vendor representatives were
stationed at the turbine during the surveillance to monitor parameters and identify
l leaks as the main turbine increased in speed. The inspector noted that work
- requests were generated for identified oilleaks. During the actual overspeed test,
{ the inspector verified that the turbine tripped at the appropriate limits required by
j procedure. Overall, the inspector found that the turbine tests were well controlled
I and implemented in accordance with procedures and Technical Specification
j requirements.
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{ 05 Operator Training and Qualification
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l 05.1 Unit 1 Reactor Plant Transient
j a. Insoection Scone (71707)
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1 The inspector evaluated the circumstances surrounding a November 16 reactor ;
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! plant transient which was caused by raising main turbine generator load too rapidly.
j Licensee procedures, training, accuracy of simulator modeling, initial correctiv'e
actions, and the effectiveness of the licensee's investigation into the transient were
j reviewed. ;
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i b. Observations and Findinas
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i On November 16, while performing a normal plant startup on Unit 1 following a 4
{ refueling outage, a loss of chemical volume and control system letdown occurred '
- during initialloading of the main generator. The balance of plant reactor operator
l raised load too rapidly and, as a result, the reactor coolant system pressure and
j temperature decreased. The unit supervisor ordered main generator load decreased
and ordered five separate rod pulls over a 2-minute period for a total of 30 steps of
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rod motion. Once the reactor plant was stabilized, letdown was reestablished and
rods were normalized. The licensee initiated Operations Notification and
Evaluation (ONE) Form 96-1455. The inspector noted that the ONE form disposition
j was marked " Manager's Trend (No Further Action Required)." i
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! On November 21, operations management and the operating crew conducted an
informal performance review of the transient. Severalissues were identified during
j the meeting: (1) During the pre-evolutionary brief, the unit supervisor did not
j discuss the potential transients that could occur with a positive moderator
i temperature coeffieicent during a main turbine startup nor the associated actions
operators should take; (2) The unit supervisor did not establish manual trip criteria:
! (3) Although the unit supervisor knew that it was the first time the balance of plant
reactor operator had started up a main turbine, little direct supervision was provided
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to the operator. The inspector noted that the licensee appropriately reclassified the l
ONE form to a plant incident following the informal performance review. j
The inspector reviewed plant operating procedures for power operations and found
that the procedure provided clear information concerning the sensitivity of the main
generator load control while in the speed reference mode of operation. The
procedure also informed operators that two quick depressions of the push button i
should be sufficient. This transient was initiated when the balance of plant operator
pushed the push button four distinct times.
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The inspector discussed the transient with the training manager and found that the l
licensee's training department was actively involved in understanding the causes of !
the transient and developing corrective actions. The training department evaluated
the simulator to determine if the simulator modeled the main turbine loading controls
correctly and found that the simulator responded much quicker. The training
manager stated that the balance of plant operator may have been mislead by the
simulator. The training manager indicated that they planned to incorporate lessons
learned into both simulator modeling, if possible, and future training plans.
l Although the licensee's investigation into the transient was progressing well, the
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initial ONE form classification was poor. The inspector planned to continue to
follow the licensee corrective actions as an inspection followup item (IFl 50-
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l 05.2 Inadvertent De-enemization of Unit 2 Safety Bus 2EB4
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l a. Insoection Scone (71707)
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The inspector reviewed the circumstances surrounding the inadvertent
de-energization of 480 Vac safety Bus 2EB4, This involved a review of the
j associated procedure and interviews of personnel involved in the incident.
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b. Observationa nd Findinos
On Dece.. .12, while performing a surveillance on the Train B emergency diesel
generator, the balance of plant operator inadvertently opened the feeder breaker for
480 Vac safety Bus 2EB4 when he attempted to reduce emergency diesel generator
load. The operator failed to follow Procedure OPT-214B," Diesel Generator
Operability Test," when he manipulated the incorrect switch. The unit supervisor
appropriately directed operators to enter abnormal operating procedures to respond
to and restore the de-energized bus.
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! The inspector interviewed several personnel involved in the incident and discussed
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corrective actions with licensee management. Operations management
) reemphasized self-verification with all operators.
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The failure to follow Procedure OPT-214B was a violation of Technical !
Specification 6.8.1. This licensee-identified and corrected violation is being treated ;
a.s a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement
Policy (NCV 50-446/9616-03).
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05.3 Unit 2 Loose Fuse Clio Event
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a. Insoection Scone (92903)
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, The inspector reviewed the licensee's corrective actions following an inadvertent
start of the Unit 2 turbine-driven auxiliary feedwater pump when one of the steam
admission valves failed open due to the loss of control power.
b. Observations and Finding
On November 30, the Unit 2 turbine-driven auxiliary feedwater pump started due to
a f ailed open steam admission valve. Operators immediately closed the upstream
isolation valve to the steam admission valve and secured the turbine-driven auxiliary
feedwater pump. The licensee's troubleshooting revealed that the steam admission
valve control power fuse clips were loose. The licensee tightened the fuse clips and
replaced the fuse to correct the problem. The inspector verified that the system
was properly restored and that the Technical Specification was exited.
The inspector questioned eight auxiliary operators on how they replaced fuses. The
inspector found that there were at least four different methods used in the field for
installing fuses. There have been several previous events associated with loose
fuse clips in the past. The inspector was concerned that inconsistent fuse
replacement techniques could have contributed to the failures. The inspectors will I
review the adequacy of the corrective actions to the fuse control program i
associated with this and previous events as an inspection followup item (IFl 50- l
445(446)/9616-04).
05.4 Conclusions
The inspectors concluded that, based on the examples contained in Sections 01 and i
05, poor operator attentiveness, supervisory oversight weaknesses, and a lack of
operator self-verification contributed to the discussed operator errors. The
inspectors noted that a number of the errors were made by newly qualified
operators and that the errors may reflect training weaknesses. This negative trend
in operator performance concerned the inspectors. When questioned, licensee
management agreed that the individual operator performance was not as expected,
but stated that they believed the examples were isolated and did not represent a
trend in the overall performance of the operations department. The inspectors will
continue to review the licensee's corrective actions for the identified followup
items.
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j 11. Maintenance
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! M1 Conduct of Maintenance
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} M1.1. Unit 2 Emeraent Maintenance on Class 1E Station Batterv Cell
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f a, insoection Scone (62707)
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The inspector observed an emergent maintenance activity to raise the low specific
j gravity of a Class 1E station battery cell above the Technical Specification
- requirement,
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j b. Observations and Findinas
j The inspectors attended the prejob briefing and noted that the discussions
appropriately included the details of the activity and the contingency measures to be
i taken in the event that the hazardous electrolyte solution spilled onto the
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electricians or the floor. During the activity, the inspector found that the
electricians donned the appropriate safety gear to add the electrolyte to the battery
cell. Electricians removed all jewelry and loose items to prevent entry into the cell.
After the work activity, the inspector verified that the specific gravity was
satisfactory and met the Technical Specification limit of 2: 1.195. The inspector
found that the electricians were knowledgeable of the activity and exercised the
proper amount of safety awareness.
M1.2 Unit 2 Class 1E Station Batteries Weektv Insoection
a. Insoection Scoce (61720)
The inspector observed portions of the weekly battery surveillance tests for the
Unit 1 and Unit 2 Train B batteries on December 5.
b. Observations and Findinas
The inspector observed the measurements of the individual cell voltage, the
electrolyte level, the electrolyte temperature, and the specific gravity. The inspector
also verified that the calculated values for specific gravity appropriately corrected
the actual electrolyte temperature and levelin accordance with the procedural
requirements. The electricians were questioned about which posts were used to .
measure voltage for battery cells in the double bus bar configuration. The l
electricians indicated that the procedure only specified how to measure voltage
across single bus bar configurations. When the electricians reperformed the l
measurement on different posts of the bus bars, the inspector verified that the same
voltage reading resulted. The foreman informed the inspector that he planned to
submit a procedure change request to clarify how to measure voltage across l
batteries with the double bus bar configuration. Overall, the inspector found that
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the maintenance activity was performed well and in accordance with procedural
requirements. The electricians exercised the appropriate leveI of electrical safety
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awareness and were knowledgeable of the battery cell requirements.
M 1.3 Inverter 2C3 Maintenance
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j a. Insoection Scooe (62707)
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The inspector attended pre-evolutionary briefings, observed the conduct of
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i maintenance, reviewed abnormal operating procedures, discussed planned operator
l compensatory actions with operators, and discussed the conduct of the on-line
maintenance with licensee management.
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b. Observations and Findinas
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- On December 8, nonsafety-related inverter 2C3 experienced several intermittent
a " loss of synch" and " bypass out of limits" alarms. The licensee transferred the
i inverter to bypass and found that the oscillator board had failed. The oscillator
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board was replaced and the inverter was returned to service. Several minutes after i
returning the inverter to service, the " loss of synch" and " bypass out of limits"
I alarms were again received. Because the alarms were locked in, the inverter could
not be transferred to bypass. The licensee reduced reactor power to 50 percent,
l manually synchronized and transferred the inverter to bypass, and replaced the
oscillator board again. '
The inspector found that the licensee was thorough in reviewing of the loss of
118Vac Bus 2C3 power. The licensee duplicated the event in the simulator and
trained operators on the proper response. The licensee's decision to reduce power
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was conservative and based on preventing a significant transient and possible
j safety injection initiation in the unlikely event Bus 2C3 were to lose power.
! The inspector planned to follow the licensee's root cause determination and future j
corrective actions as an inspection followup item (IFl 50-446/9616-05).
Ill. Enaineerina
El Conduct of Engineering
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E1.1 Conduct of Unit 1 Reactor Physics Tests
- a. Insoection Scone (61726)
On November 20, during plarit startup, the inspector observed the licensee perform
portions of the reactor physics test during startup in accordance with Work
Orders 5 96-500386-AA and 5-96-500702-AD. The insp<,ctor reviewed the work
orders and associated procedures.
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b. Observations and Findinas
The inspector found that the reactor engineer conducting the testing was
knowledgeable of the procedure and was following the procedure. The inspector
also found that necessary prerequisite conditions were met. While reviewing the
work order cover sheets, the inspector noted that none of the special instructions
(radiation work permit, clearance, fire impairment, etc.) had been filled in prior to ;
starting the testing for Work Order 5-96-500386-AA. The inspector verified that
none of the special conditions were required for the testing. The inspector
concluded that the unfilled blanks in the work order represented a lack of attention
to detail by both the maintenance activity (reactor engineering) and the work start
approval authority (operations).
E2 Engineering Support of Facilities and Equipment l
E 2.1 Review of Final Safety Analysis Reoort (FSAR) Commitments
A recent discovery of a licensee operating their facility in a manner contrary to the
Final Safety Analysis Report (FSAR) description highlighted the need for a special
focused review that compares plant practices, procedures, and parameters to the
FS AR description.
While performing the inspections discussed in this report, the inspectors reviewed
the applicable portions of the FSAR that related to the areas inspected. During the
inspection, several inconsistencies were noted, both internal to the FSAR, and
between the FSAR and the emergency operating procedures for the switchover of
the emergency core cooling system from injection to recirculation. See
Section E2.3 for a discussion of the inconsistencies.
E2.2 Loss of Reactor Protection Set Channel lll
a. Insoection Scone (71707. 37551)
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On November 5, the primary de power supply shorted and caused a loss of power '
to Reactor Protection Set Channel 111 in Unit 2. The alternate dc power supply did
not maintain power to the cabinet because the distribution breaker on the load
center had tripped open. The licensee identified that the distribution breaker was of
a smaller rating (20 amps) than the primary and alternate de power supply fuses
(30 amps). The inspector reviewed the f ailure to determine if the licensee had an
unanalyzed breaker coordination problem. The review included the licensee's
investigation into the f ailure a.1d design documents,
b. Observations and Findinas
The licensee documented the failure on ONE Form 96-1379. The inspector noted
that the licensee had previously identified and documented this lack of breaker
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coordination in Calculation TNE-EE-CA-0008-557. The inspector reviewed a portion
of Calculation 2-EE-0002 and noted that the fullload current for the reactor
protection set channel was approximately 8.7 amps. Since only one of the power
l supplies provided this current while the other was in standby, the inspector
concluded that the 20 amp distribution breaker was adequate. The licensee showed
the inspector that the vendor manual for the protection set specified 30 amp fuses
for both the primary and alternate power supplies. The licensee informed the
inspector that the distribution breaker could not be upgraded without upgrading or
j reanalyzing the distribution panel, the cables, and the cable trays and fill analysis.
The inspector reviewed licensing documents, including the FSAR, and did not
identify any requirement or analysis which assumed that each protection set had
two independent power supplies. The inspector concluded that the lack of breaker
coordination between the distribution panel and the primary and alternate power
supplies did not have any safety impact. The inspector found that the licensee had
l- appropriately documented this design deficiency.
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l E2.3 Emeroency Core Coolina System Switchover from Iniection to Recirculatio_rl
a. Insoection Scoce (71707. 37551)
i The inspectors performed a detailed walkdown of the Unit 1 centrifugal charging
l pumps to verify their function as high head injection pumps. The inspectors
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reviewed system drawings, the FSAR, Technical Specifications, and emergency
operating procedures.
b. Observations and Findinas
The inspectors found that the portion of the centrifugal charging system inspected
was maintained in accordance with design documents. However, the inspectors
noted that the emergency response procedure for the switchover from injection to
recirculation, Procedure EOS-1.3A, Revision 6, was not consistent with the steps
listed in FSAR Table 6.3-7 in that Procedure EOS-1.3A contained nine additional
steps than those listed in the FSAR. Additionally, Table 6.3-7 stated that Steps 1-6 )
were required to align the suction of the emergency core cooling system pumps to I
the containment recirculation sumps, while the analysis listed on Table 6.3-11, l
"RWST [ refueling water storage tankl Outflow Large Break - Worst Single Failure," '
analyzed the water usage only for the first five steps. Finally, FSAR
, Section 6.3.2.8 stated that 94,179 gallons were available for transfer while
l Table 6.3-11 stated that 90,166 gallons were required to complete the switchover.
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Using the same method as Table 6.3-11, the water usage would exceed the
j available water if the additional steps listed in the emergency operating procedure
were analyzed.
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The inspectors found that the analysis contained in the FSAR was not consistent
with the emergency operating procedure and that the FSAR was not internally
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consistent. The licensee documented the inspectors' findings in One Form 96-1555
and initially concluded that operability was not affected. Because this issue was
found at the end of the inspection period, the inspectors characterized the issue as
an unresolved item (URI 50-445(446)/9616-06). The inspectors will review
whether the licensee had adequately analyzed the additional steps prior to
implementing the changes to Procedure EOS-1.3A. Additionally, the inspectors will
verify the licensee's calculations for required water versus available water to
confirm the licensee's conclusion that adequate inventory exists for the worst case
accident scenario.
E3 Engineering Procedures and Documentation
E 3.1 Containment Combustible Gas Control (37551,71707)
a. Insoection Scoog
Several ONE forms were recently issued concerning containment combustible gas
contro!. The inspector reviewed the licensee's program for controlling the addition
- of aluminum or zine to containment and the resolution of the ONE forms.
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b. Observations and Findinas
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The inspector noted that two of the ONE forms were issued to document the
identification that the preaccess filtration units have unaccounted aluminum in their
construction. The identification was the result of followup by the licensee on
vendor information dated August 21,1996. The licensee's ONE forms were issued
2 weeks later. The inspector found the licensee's conclusion that the filters did not
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represent an operability concern to be appropriate. The inspector concluded that
this was another example of the good use of vendor information.
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A third ONE form documented a recent design modification which used galvanized
steel conduits instead of stainless steel conduits. The inspector reviewed how this
additional amount of zinc affected the amount of scaffold material to be left inside
of containment during power operations. The inspector noted that the licensee had
identified that a mistake had been made in the amount of acceptable scaffold
material but that the licensee had corrected the amount prior to entering Mode 6.
The inspector found that the process for determining the amount of acceptable
scaffolding involved several handoffs between different organizations which may
have contributed to the mistake and that the licensee was considering modifications
to the process. The inspector found that the combustible gas control process was
acceptable.
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E8 Miscellaneous Engineering issues
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E 8.1 (Closed) Unresolved item 50-446/9610-01: inservice testing program scope for
relief valves. In NRC Inspection Report 50-445/96-10: 50-446/96-10, the
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meet the current NRC position that ASME/ ANSI OMa, Part 10, defined the inservice +
testing program scope for relief valves. The licensee's program was based on the .
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definition provided by ASME/ ANSI OMa, Part 1, which eliminated approximately
77 relief valves per unit. The licensee decided to incorporate the inservice testing ;
i program scope defined by ASME/ ANSI OMa, Part 10, for relief valves in order to '
! resolve questions in this area, !
E8.2 (Closed) Licensee Event Report 50-446/96002: missed surveillance for turbine *
overspeed. This licensee event report was a minor issue and was closed.
E8.3 (Closed) Unresolved item 50-445(446)/9608-02: failure to maintain the facility ,
consistent with the FSAR. This item was left unresolved to determine the
I appropriate enforcement which involved a discrepancy between the as-built
condition and the FSAR description of the water-tight integrity of the component
cooling water pump rooms. As reported earlier, the inspectors noted that the !
l licensee had appropriately analyzed the consequences of changing the water-tight l
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integrity of the rooms prior to changing the design. The inspectors noted that the '
licensee's failure to update the FSAR was a minor administrative error. This failure
constitutes a violation of minor significance and is being treated as a noncited
violation, consistent with Section IV of the NRC Enforcement Policy (NCV 50- i
445(446)/9616-07). l
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IV. Plant Support !
Staff Knowledge and Performance
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a. Insoection Scooe (71707. 71750)
During tours in the radiological controlled areas, the inspectors questioned licensee
personnel on their knowledge of the radiation work perrnit requirements.
b. Observations and Findinas
The inspectors found that the radiation workers were generally knowledgeable of
the radiation work permit requirements.
P3 Emergency Preparedness Procedures and Documentation
P3.1 Licensee Onshift Dose Assessment Caoabilities (Tl 2515/134)
a. Ln.goection Scope
i Using Temporary Instruction 2515/134,the inspectors gathered information
- regarding
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Dose assessment commitment in emergency plan
Onshift dose assessment emergency plan implementing procedure ,
Onshift dose assessment training l
b. Observations and Findinos
On December 16,1996, the inspectors conducted an in-office review of the
emergency plan and implementing procedures to obtain the information requested
by the temporary instruction. The inspectors conducted a telephone interview with
the licensee on December 18,1996, to verify the results of the review. Based on
the documentation review and licensee interview, the inspectors determined that
the licensee had the capability to perform onshift dose assessments using real-time
effluent monitor and meteorological data and that the commitment was clearly
described in the emergency plan and implementing procedures,
c. Conclusion
The commitment to perform onshift dose assessments was clearly described in the
emergency plan and implementing procedures. Further evaluation of the information
obtained using the temporary instruction will be conducted by NRC Headquarters
personnel.
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V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the l
conclusion of the inspection on December 19,1996. The licensee acknowledged the
findings presented and did not identify any concerns with the inspectors characterization.
The licensee did not identify any information that was reviewed during the inspection
period as proprietary.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
D. E. Buschbaum, Technical Compliance Manager
D. L. Davis, Nuclear Overview Manager
J. J. Kelley, Vice President, Nuclear Engineering and Support
M. R. Killgore, Nuclear Engineering Manager
M. L. Lucas, Maintenance Manager
D. R. Moore, Operations Manager ,
R. D. Walker, Regulatory Affairs Manager i
INSPECTION PROCEDURES USED
37551 Onsite Engineering
61726 Surveillance Observations
62707 Maintenance Observations i
71707 Plant Operations
71750 Plant Support Activities
92901 Followup - Operations
92903 Followup - Engineering
Ti 2515/134 Licensee Onshift Dose Assessment Capabilities
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50-445/9616-01 NCV exceeded power ramp rate following refueling
50-445/9616-02 IFl operator induced reactor plant transient
50-446/9616-03 NCV inadvertent trip of safety bus during diesel surveillance
50-445(446)/9616-04 IFl corrective actions for lose fuse clips
50-446/9616-05 IFl Inverter J3 card failure
50-445(446)/9616-06 URI ECCS swapover, FSAR discrepancies
50-445(446)/9616-07 NCV CCW pump rooms not watertight as per FSAR
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Clorid
50-446/9610-01 URI inservice testing program scope for relief valves
50-445/9616-01 NCV exceeded power ramp rate following refueling
50-446/96002 LER missed surveillance for turbine overspeed
50-445(446)/9608-02 URI f ailure to maintain the facility consistent with the Final
Safety Analysis Report
50-446/9616-03 NCV inadvertent trip of non-safety bus
50-445(446)/9616-07 NCV CCW pump rooms not watertight as per FSAR l
LIST OF ACRONYMS USED
IFl inspection followup item
FSAR Final Safety Analysis Report
ONE form Operations Notification and Evaluation form
Mwe mega-watts electric
NCV noncited violation
URI unresolved item
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