ML20135B600
| ML20135B600 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/27/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20135B590 | List: |
| References | |
| 50-445-96-12, 50-446-96-12, NUDOCS 9612050070 | |
| Download: ML20135B600 (22) | |
See also: IR 05000445/1996012
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Docket Nos.: 50-445 i
50-446
License Nos.: NPF-87 !
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Report No.: 50-445/96-12
50-446/96-12
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l Licensee: TU Electric
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l Facility: Comanche Peak Steam Electric Station, Units 1 and 2
! Location: FM-56
Glen Rose, Texas
Dates: September 29 through November 9,1996
l Inspectors: A. T. Gody, Senior Resident inspector
l H. A. Freeman, Resident inspector
l V. L. Ordaz, Resident inspector
j W. J. Wagner, Reactor inspector
Approved By: J.1. Tapia, Chief, Project Branch A
Division of Reactor Projects
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Attachment: Supplemental Information
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9612050070 961127
PDR ADOCK 05000445
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EXECUTIVE SUMMARY
! Comanche Peak Steam Electric Station, Units 1 and 2
NRC Inspection Report 50-445/96-12:50-446/96-12
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This resident inspection included aspects of licensee operations, engineering, maintenance,
and plant support. The report covers a 6-week period of resident inspection.
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Qperations
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Operations response to transients continued to be characterized by strong command
and control and effective three-way communications (Section 01.3).
- An inadequate system operating procedure resulted in a reactor vessel level
fluctuation during draindown. The licensee took immediate and appropriate
corrective actions (Section O3.1).
- Operations surveillances were conducted well with thorough pre-evolution briefs !
focused on safety. Operators demonstrated questioning attitudes and good
command and control and consistently used three-way communications. Shift
management used good self assessment techniques in their critiques of the
surveillance activities (Section 04.1).
Maintenance
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Maintenance and maintenance surveillance activities were conducted well and
indicated an overall improvement from previous outages (Section M1.1).
- A work package for safety chiller maintenance was poorly written in that work )
steps could not be followed as written (Section M2.2).
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- Work planners expressed a lack of confidence in the master equipment list and
noted that an incorrect relief valve setpoint was entered in a work package because
it had inaccuracies (Section E2.2).
Enaineerina
- The control room air conditioning system engineer was not aware of the location of
all his assigned equipment and did not understand the purpose of an emergency
response guideline tag (Section 02.1).
- In general, the inspectors observed good engineering support for the Unit 1 refueling
i outage and Unit 2 operation (Section E1.1).
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- The inspectors found that the licensee's procedure for testing relief valves did not
meet ASME/ ANSI Code requirements (Section E2.2).
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Plant Support
The licensee's ALARA planning for the Unit 1 pressurizer inservice inspection was
very good. Radiation protection technicians provided excellent support to minimize
the dose to workers. The use of a mock-up for electrical maintenance and the
modification to the pressurizer insulation were found to be program strengths
(Section R1.2).
The licensee identified and immediately corrected a failure to properly post a locked
high radiation area as required by Technical Specifications (Section R4.1).
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Site access control was implemented in accordance with station procedures and l
security personnel were attentive and knowledgeable of their positions
(Section S2.1).
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Report Delans
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i Summary of Plant Status
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l Unit 1 began the inspection period at 100 percent power. On September 30, Unit 1 began
- coasting down prior to entry into the fifth refueling outage which was entered on
j October 4. At the end of the report period, Unit 1 was in Mode 5, making preparations for
- entering Mode 4.
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l Unit 2 began the inspection period at 100 percent power. On October 18, a loss of power
to Reactor Coolant Pump 2-03 caused a reactor trip (Section 01.3). Unit 2 was restarted
on October 19 and remained at approximately 100 percent power for the remainder of the
j report period.
I. Operations
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- 01 Conduct of Operations
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1 01.1 General Comments (71707) l
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q Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing
- plant operation by touring the plant, walking down control boards and safety systems, and
] performing periodic reviews of logs. In general, the conduct of operation was professional.
Operations personnel demonstrated a safety-conscious approach towards plant operations;
j specific events and noteworthy observations are detailed in the sections below.
01.2 End of Cycle Shutdown (Unit 1)
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I Scope (71707)
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4- The inspector reviewed portions of the procedure, attended the pre-evolution
, briefing, and observed the unit shutdown from 100 percent to approximately
60 percent power prior to entry into a refueling outage.
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j b. Observations and Findinas
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The inspector found that the licensee controlled the shutdown well and in
accordance with the procedure. The pre-evolution brief was thorough and focused
on safety.
01.3 Unit 2 Reactor Trio Caused by a Service Air Comoressor Failure
a. Insoection Scone (93702,62707,37551)
On October 18, with Unit 2 operating at 100 percent of rated power, the Service
Air Compressor 2-01 motor developed a phase-to-ground short which caused the
Non-Class 1E Bus 2A3-1 supply breaker to trip. Because Bus 2A3 supplied power
to Reactor Coolant Pump 2-03, the reactor tripped on low flow. The inspectors
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responded to the control room and observed the operator response to the event.
After the plant was stabilized, the inspectors observed electrical maintenance and
reviewed the engineering support.
b. Observations and Findinas
The inspectors verified that all safety equipment responded as expected. The
inspectors noted that the control room crew responded well to the trip. Operators
monitored annunciators and noted parameter trends. The inspectors verified that
the crew used the appropriate emergency procedures. The inspectors found that
the operator response was characterized by strong command and control and
effective three-way communications.
During the trip, the control room received a report that sparks were coming from the
Unit 2 auxiliary transformer. The licensee found that the shield wire from the
neutral ground of one of the secondary windings had come loose. The end of the
shield wire was burnt, most likely from excessive current flow. The licensee found
that the ground wire shield from the other secondary winding on the Unit 2 auxiliary
transformer was bolted to the transformer casing. Both ground wire shields were
properly grounded at the other end near the ground resistor. The licensee repaired
both Unit 2 auxiliary transformer secondary neutral ground shield wires.
The inspectors reviewed the engineering evaluation of the cause of the trip in the
licensee's posttrip startup justification and found that the engineering
documentation of the most-probable cause of the trip was adequate.
c. Conclusion
Operator performance during the reactor trip was good. The licensee adequately
corrected the grounding problems prior to restart. The licensee's engineering
evaluation of the potential cause of the trip documented in their restart justification
was acceptable and verified that breaker coordination was proper.
02 Operational Status of Facilities and Equipment
O 2.1 Enaineered Safetv Feature System Walkdown
a. Inspection Scoce (71707)
The inspector performed a walkdown of the accessible portions of the common
control room air conditioning (CRAC) system and the emergency filtration and
pressurization units. The inspector reviewed the Final Safety Analysis Report,
Technical Specifications and their bases, design basis documents, plant drawings,
and standard operating procedures for the system.
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b. Observations and Findinas
The inspector found that equipment operability, material condition, and
housekeeping were acceptable. The CRAC system and the emergency filtration and
pressurization units were maintained in a condition as described in the Final Safety
Analysis Report and were tested in accordance with Technical Specification
requirements. The inspector questioned the system engineer during a separate tour
of the CRAC system about component tags, including an emergency response
guideline tag, and on the location of the CRAC system on the control room panels.
The inspector found that the system engineer was not f amiliar with the purpose of
the emergency response guideline component tag nor with the location of the CRAC
system components in the control room.
O3 Operations Procedures and Documentation
O3.1 Unit 1 Reactor Vessel Level Indication Fluctuation Durino Draindown
a. Inspection Scope (71707)
On October 9, af ter lowering the Unit 1 reactor coolant system level to 120 inches
above the core plate, indicated level increased by 40 inches when the first
thermocouple conoseal was loosened. The inspector reviewed the licensee's
investigation into the cause of the reactor coolant system level fluctuation and the
corrective actions taken.
b. Observations and Findinas
The inspector found that the licensee appropriately documented the level fluctuation
incident in Operations Notification and Evaluation (ONE) Form 96-1102. The
licensee's investigation revealed that the level fluctuation occurred as a result of a
vacuum being drawn in the reactor vessel head area during the draindown process
because the temporary hose for the reactor vessel head vent had some water in it
and created a loop seal. Once the conoseal was loosened, the vacuum in the
reactor vessel head returned to atmospheric pressure and the indicated level
fluctuation occurred. The inspector noted that actual reactor vessel level changed
by less than 1 inch and that the indicated level during the draindown was less than
actual level.
The loop seat in the vent line occurred because Step 5.3.17 of
Procedure SOP-101B," Reactor Coolant System," was not adequate in alerting
operators to the importance of ensuring that all water was drained from the vent
hose when placing the system into r.ervice. The licensee immediately removed the
water from the vent line and restored the reactor vessellevelindication system.
The licensee revised Procedure SOP-1018 by providing a caution statement that
described the importance of removing water from the vent line. The inspector
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noted that the licensee was considering a modification to the vent line to replace
the hose with a permanent piping arrangement, which would prevent a loop seal
from occurring.
This licensee-identified and corrected violation of Technical Specification 6.8.1 is i
being treated as a noncited violation, consistent with Section Vll.B1 of the NRC i
Enforcement Policy (NCV 50 445/9612-01).
04 Operator Knowledge and Performance
04.1 Operations Surveillance Tests
a. Inspection Scone (61726)
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The inspectors observed all or portions of the following Unk 2 operations
surveillance tests:
- Safeguards Slave Relay K641 actuation test
- Safety injection blackout sequencer test
- Emergency Diesel Generator 2-02 operability test
- Safeguards Slave Relay K634 actuation test
> * Safeguards Slave Relay K644 actuation test
- Safeguards Slave Relay K645 actuation test
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- Containment spray pump and valve operability test
t b. Observations and Findinas
The inspectors found that the surveillance tests performed by the operators were
conducted well and in accordance with plant procedures. Communications between
the operators at the controls and the unit supervisors was consistently good.
Operators demonstrated a thorough knowledge of the procedural requirements and
demonstrated a questioning attitude. Unit supervisors demonstrated good
command and control of the surveillance activities observed. The inspectors
reviewed selected procedures and verified that the surveillance test satisfied
Technical Specification requirements and that the components were restored to
their proper positions at the completion of the tests.
The inspectors found that the operators thoroughly reviewed the procedure during
the pre-evolution briefing. The inspectors observed the shift manager use a briefing
critique form to provide feedback to the unit supervisor concerning areas for
improvement.
Prior to the emergency dier,el generator operability test on October 10, the inspector
discussed the effect that an offsite breaker problem had on the test and found that
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the licensee had appropriately considered risk before proceeding with the test. The
j, inspector found that the surveillance was well controlled and that the licensee's
self-assessment efforts were good.
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11. Maintenance
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i M1 Conduct of Maintenance I
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M 1.1 Maintenance Observations !
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j a. Insoection Scope (62707. 61726) I
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i The inspectors observed all or portions of the following maintenance and ;
maintenance surveillance tests, reviewed the Technical Specification requirements, ;
and verified compliance with station procedures: j
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- Unit 1, safety chiller maintenance l
Unit 1, source range detector troubleshooting !
- Unit 2, main feedwater pump maintenance !
Common Control Room Air Conditioner X-03 maintenance !
- Unit 2, Service Air Compressor Breaker 2-01 maintenance ;
- Unit 2, channel calibration for reactor coolant flow, Loop 2 - i
Unit 2, channel calibration for reactor coolant flow, Loop 4
Unit 1, Residual Heat Removal System Heat Exchanger 1-01 component j
cooling water return valve maintenance j
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Observations and Findinas
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The inspectors found that maintenance and maintenance surveillances were !
performed in accordance with station procedures. Work packages were properly i
maintained and the appropriate approvals were obtained prior to the initiation of
work. The inspectors observed maintenance personnel follow appropriate personnel ,
safety practices. Foreign material exclusion procedure improvements were evident.
Foreign material exclusion boundaries were properly established and materials
entering the areas were properly controlled. The inspectors also observed
maintenance personnel use appropriate radiological work practices. In general, the 1
inspectors concluded that maintenance was performed in a safe manner and the
amount of required rework was less than in previous outages, indicating an
improvement in quality.
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M2 Maintenance and Material Condition of Facilities and Equipment
M 2.1 Unit 1 Source Ranae Detector Dearadation
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a. Insoection Scope (62707. 92902) !
The inspector observed portions of the licensee's troubleshooting efforts, reviewed
engineering calculations for acceptance criteria, and discussed replacement and
repair plans with licensee management. The inspector compared Technical
Specification operability requirements with the licensee's outage schedule.
b. Observations and Findinas
Following shutdown of Unit 1 for a refueling outage, the licensee identified that one
of the source range detectors indicated approximately one-half of what the other
detector indicated. Because the licensee's procedure required that both detectors
indicate the same value within a factor of two, the licensee investigated the
problem and later declared the channel inoperable. The licensee adjusted the
detector high voltage and verified the proper operation of the detector. The
inspector found that the licensee's evaluation and resolution of the problem was
good.
The inspector reviewed the licensee's outage schedule and found that the licensee
had correctly considered the effects of an inoperable detector into the schedule.
The inspector found that the licensee was in compliance with Technical
Specification prohibitions on adding positive reactivity without two operable I
detectors.
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M2.2 Electrical Breaker Troubleshootina
a. Inspection Scoce (62707) 1
On October 18,1996, when Unit 2 was stable in Mode 3 after the reactor trip, the
inspectors observed maintenance troubleshooting activities. ;
b. Observations and Findinas I
Electricians removed the Service Air Compressor 2-01 breaker and performed as-
found testing. The inspectors noted that the breaker passed all the tests performed. i
The electricians were thorough in their visualinspection and measurements. The
maintenance activity was characterized by good independent verification and sound i
personal safety practices. The inspectors noted that the system engineer was
actively involved in the work package preparation and troubleshooting.
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M3 Maintenance Procedures and Documentation
M3.1 Unit 2 Main Feedwater Pumo Maintenance
a. Insoection Scooe (62707. 37551)
The inspector reviewed the licensee's troubleshooting plans to repair Main
Feedwater Pump 2-02 speed oscillations and observed portions of the repair.
b. Observations and Findinas
The inspector found that the licensee's troubleshooting plans to repair the speed
oscillations of Main Feedwater Pump 2-02 were thorough. The inspector noted that
the licensee had determined potential causes for the oscillations prior to removing
the pump from service. Appropriate vendor involvement was also assurred. The ,
inspector concluded that the licensee's decision to downpower the unit to perform
repairs to the feedwater pump was conservative.
The inspector also noted that the downpower and repairs were performed because
an earlier work package, which was performed to rework the main feedwater pump
hydraulic operating cylinder, did not specify the proper postmaintenance testing.
The inspector discussed this with licensee management who indicated that this was ;
a good lesson learned since the digital feedwater control system was more sensitive
to small alignment changes than had been originally thought.
M4 Maintenance Staff Knowledge and Performance
M4.1 Common Control Room Air Conditionina Unit X-03 Corrective Maintenance
a. Insoection Scope (62707)
On October 23, the inspector observed prompt team electricians perform emergent
maintenance on CRAC Unit X-03 in accordance with work order instructions and
the applicable procedure. The purpose of the maintenance activity was to replace a
failed heater element in the compressor crankcase for CRAC X-03.
b. Observations and Findinas
The inspector found that the activity was performed in accordance with the work
order instructions and procedural requirements. The inspector verified that CRAC
,_ Unit X-03 was appropriately tagged out of service, and the redundant train was
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operating in accordance with Technical Specification requirements. A quality
!- controlindividual verified portions of the activity and signed the work package,
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when required. The Prompt Team supervisor was present near the end of the
i activity and monitored the job for conformance with management expectations.
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The inspector verified that Technical Specification 3.7.7.2 was properly entered
when the activity commenced and exited when the oil temperature for the
compressor reached its operational limit.
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M4.2 Unit 1 Safety Chiller Maintenance '
a. Inspection Scope (62707)
The inspector reviewed Work Order 3-96-309131 and Maintenance
Procedure MSE-PO-7333 which were being used to perform preventive maintenance
on Safety Chiller 1-05. The inspector also discussed the ongoing activity with an
electrician performing the maintenance,
b. Observations and Findinas
The inspector found that the electrician was knowledgeable and that the work was
being conducted under the supervision of a vendor representative.
The inspector also found that the work order being used to perform the work was
not written clearly nor ordered sequentially. For example, Step 2A of the work
order removed the refrigerant from the chiller while Step 2C stated, " record amount
of refrigerant added or removed." The inspector noted that refrigerant was not
added to the chiller until Step 11. Step 4 required that, " applicable sections of
MSE-PO-7333.that can be accomplished while power is off," be performed. .
Procedure MSE-PO-7333 included a variety of instructions which included: oil filter I
replacement, compressor motor filter change, megger testing, and overload relay
testing. Procedure MSE-PO-7333 was not written in sequential order and,
consequently, different sections were in various stages of completion. The l
inspector concluded that the work order was poorly written in that work steps could
not be followed as written and that successful completion of the work relied heavily
on the skill and knowledge of the craft performing the maintenance.
Ill. Enaineerina
E1 Conduct of Engineering
E1.1 General Observations
in general, the inspectors observed good engineering support to the Unit 1 refueling
outage and Unit 2 operation. System engineers were involved in emergent
troubleshooting activities and typically provided timely and correct engineering l
support of operations and maintenance issues. The inspectors noted that the
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licensee established a 24-hour engineering support team for the Unit 1 refueling
outage and observed that the new team was an improvement in engineering
support.
E2 Engineering Support of Facilities and Equipment
E2.1 Unit 1 Steam Generator Chemical Cleanino impact
a. Inspection Scope (37551)
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The inspector reviewed the engineering evaluation for the steam generator chemical
cleaning process to determine whether control room habitability would be impacted.
b. Observations and Findinas
The steam generator cleaning process involved the storage of several volatile
chemicals. The inspector discussed the analysis of chemical concentrations that
would be released to the atmosphere following a postulated rupture of the storage
tanks with the lead engineer. The inspector independently verified the licensee's
conclusion that there would be no impact on control room habitability.
The steam generator cleaning process described in the evaluation included a high
temperature crevice cleaning step which required periodic opening of the
atmospheric relief valves (ARVs) to depressurize the system and allow boiling in the i
steam generators. The gases vented through the ARVs were composed of water l
vapor and small amounts of ammonia, hydrazine, and methanol. The inspector j
verified that the calculations for hydrazine and methanol were acceptable. The !
amount of ammonia was evaluated using a Stone and Webster Engineering
Corporation computer code. The evaluation stated that the amount of ammonia
discharged from the ARVs was within the threshold limit of 25 parts-per-
million (ppm). The inspector questioned what the actual value of the ammonia level
was. The licensee indicated that the actual value was 0.02 ppm. After the
inspector's questions, the licensee reanalyzed the ammonia value and found that the
value was actually 7.0 ppm. Although the revised value was still below the 25 ppm
threshold limit, the inspector was concerned about the error in the original
calculation. The inspectors plan to evaluate the licensee's review process for
approving calculations as an inspection followup item (IFl 50-445(446)/9612-02).
The inspector found that there would be no impact on control room habitability
during the chemical cleaning process due to the stored chemical tanks or the
venting process since the concentrations were within acceptable levels. In addition,
other compensatory meas. :es were planned to prevent gaseous vapors from
entering the control room intake. These included: obtaining air samples during the
venting process to monitor for ammonia, installing f ans on top of the ARVs to
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disperse the gases 100 feet in the air, and implernenting a procedural requirement
for operators to maintain control room intake through the damper farthest away
from the ARVs.
E2.2 Relief Valve Testino Prooram
a. Inspection Scoce (92903. 62707. 37551)
The inspector reviewed the licensee's corrective actions associated with past relief
valve failures and evaluated changes to their relief valve testing program.
b. Observations and Findinos
During a review of ONE forms, the inspector noted that a number of relief valve
failures occurred during the Unit 2 Spring 1996 refueling outage. The licensee
appropriately documented the failures on ONE forms and then wrote a single ONE
form to combine the failures in one document (ONE Form 96-306). The inspector
reviewed the engineering recommendations in the resolution of ONE Form 96-306
and found that the recommendations would generally improve relief valve test
reliability, with one exception.
One recommendation resulted in a revision to Procedure MSM-GO-0204," Safety
Valve and Relief Valve Bench Testing." The revision, dated September 30,1996,
changed Step 8.3.1.22 to read, "if seat leakage was satisfactory, cycle valve as
necessary to remove entrapped air, then reduce pressure to zero." The procedure
then tests the "as found" pressure and records the value in Step 8.3.1.25. The
inspector concluded that cycling the valve to vent the entrapped air in the relief
valve inlet nozzle, as described in Step 8.3.1.22, had the potential to affect the "as
found" setpoint test.
Technical Specification 4.0.5 requires that inservice testing of ASME Ccde Class 1,
2, and 3 valves be performed in accordance with Section XI of the ASME Boiler and
Pressure Vessel Code. Section XI, Subsection IWV, ' Inservice Testing of Valves in
Nuclear Power Plants," requires that valve testing be performed in accordance with
the requirements stated in ASME/ ANSI Operations and Maintenance, Part 10.
Part 10, paragraph 4.3.1, requires that safety and re ief valves meet the inservice
test requirements of Part 1. Part 1, Paragraph 7.3, " Periodic Testing," requires that
no maintenance, adjustment, disassembly, or other activity which could affect the
"as found" set pressure or seat tightness data be conducted prior to valve testing.
The inspector noted that only one relief valve failed testing following the procedure
change. One corrective action recommendation listed in the resolution of ONE
Form 96-0306 required that a small group of mechanics should be trained on the
use of the relief valve test apparatus because of the difficulty in getting consistent
results. The inspector found that, during the Unit 1 refueling outage, relief valve
testing was performed by the mechanical shop and not by a small group specially
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contained an erroneous setpoint. Planners were reluctant to rely on the master ,
equipment list because of past problems and planners did not always use the proper
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format for setpoint pressure tolerance in work packages which required mechanics ;
to calculate the setpoints, i
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E8 Miscellaneous Engineering issues (92700)
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E8.1 (Closed) Licensee Event Report (LER) 50-446/94018: pressurizer safety valves (
found out of tolerance on October 25 and 26,1994. The licensee performed j
maintenance on all three pressurizer safety valves and they were tested !
satisfactorily. The inspectors reviewed the results of pressurizer safety valve !
setpoint testing since the event report and concluded that no significant problem l
existed with the pressurizer safety valve test program or with pressurizer safety
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setpoint drifting. '
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E8.2 1 Closed) LER 50-445/95002: dual unit automatic reactor trip caused by lightning i
strike. This event was discussed in NRC Inspection Report 50-445(446)/95-07.
This LER was previously discussed in Safety Assessment and Quality Verification
inspection Report 50-445(446)/95-18. Following these trips, the licensee installed
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a new lightning deterrent system to help prevent lightning induced reactor trips;
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however, Unit 1 tripped on August 9,1996, and Unit 2 tripped on September 18, j
1996, both due to lightning strikes. These trips were reported in NRC Inspection i
Reports 50-445/9610:50-446/96-10and 50-445/96-11:50-446/96-11. Further i
corrective actions will be reviewed during the review of the corresponding LERs 1
(50-445/96007and 50-446/96006).
E8.3 (Closed) LER 50-446/96001: allowed outage time exceeded in conjunction with
enforcement discretion for the reactor coolant system instrument channel. On
December 31,1995, the licensee discovered that the channel position indication for
the wide range reactor coolant temperature was reading zero. The licensee found
! during troubleshooting that the red and black wires for the resistance temperature
j detector (RTD) were grounded. The licensee determined that the location of the
! ground was in an area inside containment that was normally only accessible during
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shutdown due to radiation levels and temperature. The Technical Specification
action statement required that an inoperable instrument be restored to operable
within 7 days. The licensee was granted a notice of enforcement discretion which
allowed them to keep Unit 2 in Mode 1 with the wide range temperature remote i
shutdown until the February 1996 refueling outage. !
The inspectors reviewed the licensee's One Form and Plant incident Report and
noted that the licensee found that the reflective insulation had crimped the RTD
! leads in two places, causing the failure. The licensee's corrective actions included
i trimming the insulation to avoid the possibility of crimping in the future. The
! licensee inspected the other loops and found one similar problem. The licensee j
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adjusted the insulation to remove the potential of another failure. In addition, the '
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j licensee initiated a work request to inspect the Unit 1 RTD leads. The inspector
concluded that the licensee properly corrected the deficiency.
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R1 Radiological Protection and Chemistry Controls
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R 1.1 General (71707, 71750)
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During periodic plant tours, the inspectors noted that radiation workers adhered to
radiation work permits and followed appropriate radiation work practices. Radiation
workers were observed utilizing radiation protection staff expertise to determine the
specific hazards that they could encounter during their assigned activities. The
inspectors observed that radiological hazards were properly posted and controlled in
a manner that kept dose ALARA (as low as reasonably achievable).
l R1.2 Unit 1 Pressurizer Surae Line Inservice Inspection and Heater Cable Maintenance
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a. Inspection Scope (71707,37551,62707,71750)
The inspector reviewed the licensee's ALARA, work order, and inservice inspection
planning and observed the mock-up training facility, work order implementation,
conduct of maintenance, inservice inspection, and radiological implementation for
the Unit 1 pressurizer surge line weld inservice inspection activity.
b. Observations and Findinas
The inspector reviewed the ALARA planning for the pressurizer surge line inservice
inspection activity. The work plan involved erecting scaffolding, removing heat
l insulation, removing all the pressurizer heater cables, performing dye penetrant
tests, ultrasonic tests of the Unit 1 pressurizer surge line welds, and restoring the i
pressurizer configuration.
The inspector noted that the licensee's ALARA plan estimate of the dose rates for
i the electrical work were very accurate and that the time estimates were slightly
l higher than actual. A review of the dose data following the completion of the
l activity showed that the dose rate estimate was very accurate. The inspector also
l noted that the ALARA planning for the insulation removal and installation was low
(.560 person-rem planned ve mas .819 person-rem actual). The inspector was told I
that this was primarily due t ) oifficulties encountered by the insulation workers.
The inspector noted that the licensee designed new insulation for the pressurizer j
heaters which would allow easy access to the lower end of the pressurizer without
removing all the pressurizer heater cables. The inspector concluded that the design
change would reduce dose during future inservice inspection of the pressurizer.
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The inspector performed a walkdown of the pressurizer heater mock-up training
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facility and found it to accurately represent the field conditions. The inspector's
review of ALARA planning meeting minutes revealed that the mock-up training
provided several insights on how to perform the heater cable removal and
installation in a more efficient manner, which resulted in a dose savings of about
1.2 person-rem. The inspector concluded that the use of a mock-up facility in
training electrical maintenance workers was a significant contribution towards
maintaining dose ALARA.
The inspector observed licensee personnel perform the 10-year inservice inspection
of the pressurizer surge nozzle safe-end welds as required by the inservice test
program. The inspector concluded that the licensee followed inservice inspection
procedures.
The inspector observed that the dose rate on one area of the pressurizer was about
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1,200 millirem per hour on contact. Radiological support for the job was excellent;
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radiation protection technicians were very knowledgeable of the dose rates and
maintained very good control of worker positioning to minimize accumulated dose.
c. Conclusions
The inspector concluded that ALARA planning was good (4.25 person-rem planned
versus 3.15 person-rem actual). ' Radiation protection technicians provided excellent
support to minimile the dose to workers. Inservice inspection was completed in
accordance with station procedures. The use of a mock-up for the electrical work
and the modification to the pressurizer insulation were found to be program
strengths.
R4 Staff Knowledge and Performance
R4.1 Failure to Properly Post a Locked Hiah Radiation Area
a. Inspection Scope (92904)
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The inspector evaluated the effectiveness of licensee corrective actions following
the identification of an improperly posted, locked high radiation area. The inspector
also determined whether the cause was similar to a previously identified issue in
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l b. Observations and Findinas
! The radiation protection manager inforrr.ed the inspector of a f ailure to properly post
l a locked high radiation area. After removing and bagging a spent sealinjection filter
, from Unit 1 on October 28, a radiation protection technician placed the filter within
j a shielded booth located in the auxiliary building. The filter dose rate was
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8,000 millirem per hour on contact and 1,500 millirem per hour at 1 foot. The
highest dose rate outside the shielded booth was 450 millirem per hour on contact.
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Technical Specification 6.12.2 requires that areas accessible to personnel with
radiation levels such that a major portion of the body could receive a dose greater
than 1000 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> be provided with locked doors to prevent unauthorized !
entry. Licensee proceduras provide alternate ways to satisfy the locking j
requirements when an area cannot be reasonably locked. In those cases, the I
licensee is required to barricade the area to the extent practical and post the area
with a flashing light.
The licensee found that the off-going crew had replaced a Unit 1 sealinjection filter j
late that night. Because the off-going lead radiation protection technician did not '
know the specific status of the filter, the on-coming lead technician had the area
surveyed and found that the area within the shielded booth was required to be
locked and posted as a locked high radiation area. The licensee immediately posted
the booth and installed a flashing light as required by station procedures. The
inspector concluded that the on-coming lead radiation protection technician
demonstrated a questioning attitude and took the appropriate immediate corrective !
actions once the condition was identified.
The inspector noted that the area was not properly posted for a period of
approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The inspector also noted that the area surrounding the I
shielded booth was a high radiation area that required contacting radiation )
protection prior to entry. Therefore,little opportunity for excessive radiation
exposure to personnel existed. However, the licensee's failure to properly post the
area was a violation of Technical Specification 6.12.2.
The inspector questioned radiation protection department management about the
effectiveness of corrective actions that were implemented for a previous violation
cited in NRC Inspection Report 50-445/96-08:50-446/96-08 where a locked high
radiation area door was found by the inspectors to be unlocked. In addition, the
inspector reviewed the licensee's changes to Station Administrative Procedure 660,
" Control of High Radiation Areas," Revision 6, dated July 26,1996,in response to
the previous violation. The inspector concluded that the corrective actions from the !
previous violation would not have prevented the failure to properly post the area.
This licensee-identified and corrected violation is being treated as a noncited
violation, consistent with Section Vll.B1 of the NRC Enforcement Policy
(NCV 50-445(446)/9612-05).
c. Conclusion
The inspector concluded that the circumstances surrounding the f ailure to properly
post an area were different from a previously identified violation and that the
problem was identified by the licensee because of a questioning attitude
demonstrated by radiation protection personnel. The licensee took immediate and
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proper corrective actions which included properly posting the area and discussing
lessons learned with the individuals involved.
S2 Status of Security Facilities and Equipment
S2.1 Protected and Vital Area Access Control
a. Inspection Scope (71750)
The inspectors evaluated protected and vital area access control throughout the
report period by direct observations and discussions with security personnel.
b. Observations and Findinas
The inspectors frequently toured the plant and discussed compensatory security l
measures with posted security personnel and concluded that compensatory l
measures were appropriate for the affected protected and vital area boundanes. j
Security personnel were knowledgeable of the purpose of their assignments and the i
potential threats caused by the degraded barriers. Overall, the inspectors concluded )
that access control was generally implemented in accordance with station ;
procedures and security personnel were attentive and knowledgeable of their posted
positions.
F1 Control of Fire Protection Activities
F1.1 Fire Impairments, Control of Fire Hazards, and Firefiahtina Eauipment
a. Inspection Scone (71750)
The inspector observed the licensee implement their fire protection program during ;
numerous outage-related maintenance activities. !
b. Observations and Findinas
The inspector observed the licensee use firewatches with the proper firefighting
equipment available. Impaired fire doors had the proper fire impairment review and
were tagged and tracked in accordance with licensee procedures. The inspector
noted that the door to the fire hose station adjacent to the Unit 1 inverter
installation activity was taped shut. Workers immediately untaped the hose station j
when the inspector identified the condition to them. The inspector concluded that !
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this observation was isolated. Overall, the inspector concluded that the licensee
! properly implemented their fire protection program during outage activities.
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F8 Miscellaneous Fire Protection issues
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F8.1 Fire Barrier Penetration Seal Review
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a. Inspection Scope (64704)
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The inspector visually inspected 22 silicone foam fire barrier penetration seals
installed in openings surrounding large pipe located in the auxiliary building, also
known as the common area, between Units 1 and 2. The purpose of this inspection
was to verify that the design of the installed silicone foam penetration seals were j
qualified by a fire test report and/or an engineering evaluation.
b. Observations and Findinns
The inspector verified that the 22 silicone foam fire barrier penetration seals were
installed in the proper configuration and in accordance with Brand Industrial Service
Company (BISCO) report 748-49," Fire Test Configuration for a Three Hour Rated
Fire Seal Utilizing BISCO SF-20 Where: A Steel Sleeve Condition with Pipe Penetrant
Exists," dated July 9,1981.
The inspector also reviewed the licensee's engineering evaluation of BISCO
Report 748-49, which was documented in Engineering Report ER-ME-038,
" Evaluation of Fire-Rated Penetration Seal Details," Revision 1, dated October 2,
1989. The purpose of the engineering report was to define the method, design
inputs, assumptions, acceptance criteria and results of reviews of fire test used to
support the design of fire rated penetrations seals. The inspector found that the ;
engineering report provided a proper evaluation of BISCO Report 748-49. j
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c. Conclusion l
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The silicone foam fire barrier penetrations located in the common area were of
proper configuration for use as a 3-hour fire-rated barrier as defined in BISCO
Report 748-49.
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management ;
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at a final exit meeting on November 7,1996. The licensee acknowledged the '
findings presented. No proprietary information was identified during the exit
meetings.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
TU Electric
Blevins, M. R., Plant Manager
Byrd, R. C.', Mechanical Maintenance Manager
Curtis, J. R., Radiation Protection Manager
Ellis, S. L, Instrument and Controls Maintenance Manager
Flores, R., System Engineering Manager
Hope, T. A., Regulatory Compliance Manager
Kelley, J. J., Vice President, Nuclear Engineering and Support
Kross, D. C., Operations Support Manager
Moore, D. R., Operations Manager
Muffett, J. W., Station Engineering Manager
INSPECTION PROCEDURES USED
37551 Onsite Engineering
61726 Surveillance Observations
62707 Maintenance Observations
64707 Fire Protection Program
71707 Plant Operations
71750 Plant Support Activities
92700 Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Facilities
92902 Followup - Maintenance
92903 Followup - Engineering
92904 Followup - Plant Support
93702 Prompt Onsite Response To Events At Operating Power Reactors
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ITEMS OPENED l
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50-445/9612-01 NCV inadequate Procedure Resulted in a Reactor Vessel
Level Indication Fluctuation During Reactor Vessel
Draindown l
50-445(446)/9612-02 IFl Engineering Calculation Review and Approval Process ,
50-445/9612-03 VIO Failure to Meet ASME/ ANSI Code Requirements For
Relief Valve Testing
50-445(446)/9612-04 IFl Master Equipment List !
50-445(446)/9612-05 NCV Failure to Properly Post a Locked High Radiation Area
ITEMS CLOSED
50-445/9612-01 NCV inadequate Procedure Resulted in a Reactor Vessel .
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Level Indication Fluctuation During Reactor Vessel
Draindown
50-445(446)/9612-05 NCV Failure to Properly Post a Locked High Radiation Area
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50-446/94018 LER Pressurizer safety valves found out of tolerance on ,
October 25 and 26,1994
50-445/95002 LER Dual unit automatic reactor trip caused by lightning
strike i
50-446/96001 LER Allowed outage time exceeded in conjunction with
enforcement discretion for the reactor coolant system
instrument channel
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LIST OF ACRONYMS USED
ALARA as low as reasonably achievable
ANSI American Nuclear Standards institute
ASME American Society of Mechanical Engineers
ARV atmospheric relief valve
BISCO Brand Industrial Service Company
CFR Code of Federal Regulations
CRAC control room air conditioning
ERG emergency response guideline
IFl inspection followup item
LER licensee event report l
NCV noncited violation
ONE Operations Notification and Evaluation
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ppm parts per million
RTD resistance temperature detector
VIO violation
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