ML20137U602
| ML20137U602 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137U594 | List: |
| References | |
| 50-348-97-04, 50-348-97-4, 50-364-97-04, 50-364-97-4, NUDOCS 9704170045 | |
| Download: ML20137U602 (15) | |
See also: IR 05000348/1997004
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U.S. NUCLEAR REGULATORY COMMISSION (NRC)
REGION II
Docket Nos: 50-348 and 50-364
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Report No: 50-348/97-04 and 50-364/97-04
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Licensee: Southern Nuclear Operating Company. Inc
Facility: Farley Nuclear Plant (FNP). Units 1 and 2
Location: 7388 North State Highway 95
Columbia.'AL 36319
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Dates: January 25 - March 14. 1997 j
Inspectors: T. Ross. Senior Resident Inspector
J. Bartley, Resident Inspector
R. Caldwell. Resident Inspector (In training)
Approved by: P. Skinner. Chief. Projects Branch 2
Division of Reactor Projects
Enclosure
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9704170045 970402
FDR ADOCK 05000348
(D PDR 2
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EXECUTIVE SUMMARY
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Farley Nuclear Power Plant. Units 1 And 2 I
NRC Inspection Report 50-348/97-04. 50-364/97-04
This special inspection documents the results of a detailed Engineered
- Safeguards Feature system review and walkdown of the Unit 1 and Unit 2
Penetration Room Filtration (PRF) systems, including associated surveillance
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test and system design requirements.
Ooerations
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e The PRF system was physically well maintained. However, procedural
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guidance for normal operation, surveillance testing, and emergency
l conditions was inadequate. Licensee corrective actions to date have
- been thorough and prompt. The most serious procedural deficiency was
, the lack of guidance for ensuring system operation prior to and during
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post loss of coolant accident' (LOCA) cold leg recirculation in a manner
consistent with the Updated Final Safety Analysis Report (UFSAR) design
and safety function descriptions. Based on the combination of
inadequate PRF procedural guidance and excessive penetration room
i boundary (PRB) in-leakage. the Unit 1 and 2 PRF systems may not have
l been able or available to perform their intended safety function under -
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all required accident conditions (Sections 02.1 M2.1).
e Fuel movement was performed in the Unit 2 spent fuel pool (SFP) with
both trains of the PRF system inoperable. This was a condition
- prohibited by Technical Specification (TS) 3.9.13 (Section 08.1).
k M.intenance
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e The inspectors and licensee identified many discrepancies in the data
i recorded during PRF surveillance testing. Unclear test procedure
! guidance contributed significantly to the many documented errors. One
i surveillance test conducted on December 1.1992. resulted in failing to
i meet TS system flow acceptance criteria (Section M1.1).
1
- e The PRB has degraded to such an extent that in-leakage was many times
greater than assumed in the UFSAR. Excessive in-leakage 3revented the
PRF system from operating per the design descriation in tie UFSAR. This
condition has existed for many years and could lave been recognized by
the licensee with the evidence available from routine surveillance
testing (Section M2.1).
e The PRF system surveillance test procedures contained numerous
- deficiencies and failed to provide adequate guidance for testing the PRF
system (Section M2.1 and M3.1)
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e The licensee failed to fully implement the Unit 1 and 2 TS surveillance
requirements (SR) for airflow capacity tests, visual inspections, and
heater testing for the PRF system. Control Room Emergency Filtration
System, and Containment Purge exhaust filter (Section M3.2).
l Enclosure
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Reoort Details
I. Ooerations- i
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02 Operational Status of Facilities and Equipment
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02.1 Enaineered Safeauards Feature System Walkdown l
a. Insoection Scoce (IP 71707)
Ins)ectors used Inspection Procedure (IP) 71707 to perform a detailed
wal(down of the accessible portions of the Unit 1 and Unit 2 Penetration
Room Filtration (PRF) system. The inspectors also performed a detailed
review of the current licensing basis for PRF and compared it to the
existing plant configuration and procedural guidance including
Emergency Response Procedures (ERPs). System Operating Procedures
(SOPS). Annunciator Response Procedures (ARPs), and Surveillance Test
Procedures (STPs). Refer to paragraphs M1.1. M2.1, M3.1. and M3.2 for
inspection findings regarding PRF system surveillance testing and
discrepancies between the as-built versus Updated Final Safety Analysis '
. Report (UFSAR) design description.
b. Observations and Findinas
The UFSAR identifies that the PRF system is a dual purpose system
designed to: 1) process air from the fuel handling area during a fuel
handling accident and 2) establish a negative pressure within the
penetration room boundary (PRB) and provide a filtered release path for
airborne radioactivity during a loss of coolant accident (LOCA). The i
PRF system is normally aligned to exhaust air from the spent fuel 2001
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(SFP) and is designed to automatically start upon receipt of a hig,
radiation signal or low SFP ventilation system exhaust flow. In the <
event of a LOCA. the PRF system is designed to automatically start on a
containment phase B signal (i.e., high-high-high containment pressure
setpoint of 27 psig) and must be manually realigned to allow cleanu) of
radioactive containment leakage and emergency core cooling system (ECCS)
component leakage into the PRB.
As described in the UFSAR. each PRF train is composed of: 1) a filter
bank containing a prefilter. High Efficiency Particulate Air (HEPA)
filter, and charcoal adsorber section. 2) two fans, a 4500 cubic feet
per minute (cfm) recirculation fan and a 500 cfm exhaust fan, which take
a suction on the outlet end of the filter Dank. and 3) the associated
ducting and dampers to contr01 the flow path of the system. The exhaust
fan has only one discharge path, which is out the plant vent stack. The
recirculation fan has two discharge paths. one out the plant vent stack
(exhaust) and the other back into the PRB (recirculation). On a phase B
actuation, both fans are designed to start in the exhaust mode to
rapidly draw a negative pressure in the PRB. When the Residual Heat
Removal (RHR) system heat exchanger room reaches approximately -2 inches
of water pressure, the recirculation fan recirculation valve is designed
to automatically modulate open until pressure in the PRB reaches
Enclosure
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l approximately -1.7 inches of water. In this alignment, the !
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recirculation path provides for cleanup of the PRB and reduces the '
exhaust flow out the plant vent stack, thus reducing the amount of I
radioactivity released to the environment and providing for filtration :
- of the PRB atmosphere for increased cleanup. )
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[ UFSAR Section 6.2.3.2.2 describes two manual operator actions necessary
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to o)erate the PRF system in the post-LOCA mode. The operator has to: 1
1) slut the SFP area suction dampers to the PRF system, and 2) shut the )
- recirculation fan exhaust damper, when the recirculation valve receives !
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an o)en signal .cr the PRB low pressure annunciator is received. to place
{ the 3RF system in the recirculation mode. The UFSAR also identifies
that the safety function of the PRF system is to: 1) keep the SFP area
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at a negative pressure for fuel handling accidents, and 2) maintain the i
PRB at a negative pressure to ensure that containment and ECCS component
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leakage during post-LOCA reactor coolant recirculation is filtered prior
to release.
The inspectors reviewed applicable ERPs. SOPS, ARPs, and STPs to verify
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that operator actions were properly specified and that the PRF system
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was tested in a manner to ensure that it would operate as stated in the
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UFSAR. On January 28. 1997, the inspectors determined that shutting the
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suction dampers from the SFP area to the PRF system was identified in
plant operating and test procedures. However, shutting the PRF
recirculation fan exhaust damper, to shift into the recirculation mode,
was not identified in any ERP or SOP. Existing ERP guidance only
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directed operations to verify that both trains of the PRF system
started, and then place one train in standby. UFSAR Section 6.2.3.2.2
states. "When either a two out of three differential pressure signal of
l -2 in, or a recirculation line valve open signal is annunciated in the
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control room, the operator closes the valve at the discharge of the
recirculation fan;" and "the analysis of the combined system (fans vs.
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in-leakage) indicates a setpoint of -2 in. wg pressure to be used for
i switching to recirculation operation." Also, Alabama Power Company
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Drawing D-205013. HVAC: Process Flow Diagram Penetration Filtration
System. Revision 6, specifically identifies Post LOCA Recirc Mode and
i Post LOCA Exhaust Mode as PRF system configurations which correspond
with the system operation described in the UFSAR. However, instructions
for PRF system operation in the recirculation mode, exhaust mode, or
combined mode of operation, were not contained in alant procedures.
Further review by the inspectors discovered that tais UFSAR discrepancy
was identified by the licensee's UFSAR reverification program on
September 30, 1996. However, no corrective actions had been taken.
The inspector discussed the post-LOCA PRF system operation with several
licensed reactor operators and senior reactor operators. These
personnel were not aware of the post-LOCA PRF system recirculation mode
nor with the design basis requirement to shut the PRF system
recirculation fan exhaust valve. Feiling to shift the PRF system into
the post-LOCA recirculation mode as described in the UFSAR would cause
Enclosure
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. higher than designed exhaust flow and lower than designed recirculation
4 cleanup of the PRB. Although the higher exhaust flows could increase
1- the rate of radioactive release, the quantity of release would be within
l' the bounds of the UFSAR evaluation that concluded such releases would be
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less than 10 CFR 100 limits. The lower than designed recirculation flow
would reduce the effectiveness of the recirculation cleanup and could
result in higher dose rates and exposures in the PRB during a:cident
recovery activities. Failure to operate the PRF system in the
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recirculation mode would adversely affect licensee ability to maintain
doses "as low as reasonably achievable."
- UFSAR Sections 6.2.3 and 15.4.1.10 describe that the safety function of
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the PRF system is to maintain the PRB at a negative pressure to ensure
- that ECCS equipment leakage during the post-LOCA reactor coolant
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recirculation phase is filtered prior to release. UFSAR
i Section 6.2.3.2.2 stated. "In the event of a LOCA. the penetration room
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filtration system will be manually realigned to operate in the LOCA mode
orior to the end of in.iection [ underline added] and will operate
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automatically." However, the PRF system is only designed to start
automatically on a phase B containment isolation signal. as a
4 consequence of a very large break LOCA. For the broad range of smaller
- . is not designed to automatically start. The inspectors reviewed
FNP-1/2-ESP-1.3. Transfer to Cold Leg Recirculation. Rev u 'n 11. and
other applicable ERPs. and found that they did not provide any
i instructions for starting the PRF system. Since plant ERPs did not
- direct starting the PRF system arior to initiation of )ost-LOCA cold leg
recirculation (i.e. , prior to tie end of injection), t1e PRF system
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would only perform its intended safety function for those LOCAs that
, result in containment pressure over 27 psig. There was no indication
. . that the PRF system would ever be started during LOCAs involving small
or medium sized breaks. The inspectors also noted that plant ERPs did
not direct the operators to periodically monitor PRF system operation to
ensure that it was operating properly. Interviews of operators
determined that they were not aware that the PRF system was required to
be running prior to initiating cold leg recirculation.
The inspectors reviewed FNP-1/2-ESP-1.1. SI Termination. Revision ll,
and FNP-1/2-ESP-1.2. Post LOCA Cooldown and Depressurization.
Revision 12. FNP-1/2-ESP-1.1. step 3. and FNP-1/2-ESP-1.2. step 4.
direct the operators to secure one train of the PRF system and place it
in standby. However, the procedures did not )rovide operator
instructions for monitoring the PRB to atmosplere differential pressure
(dP) to ensure that the remaining PRF train was performing properly.
The PRB to atmosphere differential pressure is not indicated in the main
control room at-the-controls area nor does an annunciator alarm to
indicate loss of PRB negative pressure. The inspectors concluded that
the ESPs did not provide adequate operator guidance for placing one
train of the PRF system in standby during post-LOCA operation. This
lack of guidance could have resulted in operators securing one train of
Enclosure
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the PRF system, with the other train being unable to maintain a negative
pressure due to excessive PRB in-leakage. ,
in The inspectors reviewed FNP-1/2-SOP-60.0, Penetration Room Filtration
System. Revision 11. and determined that it did not contain guidance for
aligning the PRF system to the recirculation mode nor how to operate and
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monitor system performance after one train was secured as directed in :
1 the ERPs.
Plant procedural deficiencies regarding PRF system operation, testing i
l. (see Sections M2.1 and M3.1). and emergency response are examples of ,
l Escalated Enforcement Item (EEI) 50-348. 364/97-04-01. Inadequate l
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- Procedural Guidance for PRF System Operation and Testing - Multiple
Examples.
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4- The inspectors identified each of above discrepancies to plant
! management as they were identified. Several meetings were held with
! licensee personnel between January 29 and February 14 to discuss these
and other findings described in this report. On January 31., the
licensee informed the inspector that the plant was within the design
basis because: 1) the offsite dose calculations for the design basis
accident did not depend on the PRF system exhaust flow rate, and 2) PRF
was able to achieve a negative pressure in the PRB with the current I
plant 3rocedural guidance. The licensee also stated that it considered I
the PR system to be operable because FNP-1/2-STP-20.0. Penetration Room 4
Filtration System Train A(B) Quarterly Operability and Valve Inservice ,
Test Revision 23. 'had demonstrated the system's capability to maintain l
.a negative pressure in the PRB (albeit in the exhaust mode only, and
only while running one train at a time). ,
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On February 5. the licensee provided the inspectors a copy of the PRF
system operability determination. That afternoon. the Plant Operations
Review Committee reviewed and approved a safety evaluation to change the
UFSAR. This change allowed operators the flexibility to align the PRF
system in either the recirculation or exhaust mode of operation. The
inspectors reviewed these documents and considered them to be adquate.
However, the inspectors disagreed with the specific statecent in the
safety evaluation that described the operator action to shut the
recirculation fan exhaust damper as an " inconsistency between FSAR
sections." The licensee also revised all ap)licable ERPs and S0P to
incorporate adequate instructions to ensure 3RF system operation during
all LOCAs.
Licensee corrective actions to address the procedural deficiencies were ,
prompt and thorough. All- procedure deficiencies were corrected by !'
temporary change notices and/or procedure revisions The inspectors
reviewed these procedure corrections and determined that they adequately
, addressed the deficiencies. Most changes were implemented within seven
days of identification, The procedure changes for the ERP deficiencies
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Enclosure '
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! were implemented two days after the inspectors identified the deficiency
- to the licensee.
The system components were in good condition and installed as described-
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in the UFSAR. The PRF system room was clean and well-maintained. J
- c. Conclusions
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The system was physically well maintained. However, procedural guidance
! for normal operation. surveillance testing, and emergency conditions was
l- inadequate. Licensee corrective actions to date have been thorough and
- prompt. A lack of procedural guidance for ensuring system operation
prior to and during )ost-LOCA cold leg recirculation in a manner
consistent with the JFSAR design and safety function descriptions was :
, identified. The inspectors determined that, based on the combination of
i inadequate PRF system procedural guidance and excessive PRB in-leakage
j (Section M3.2), the Unit 1 and Unit 2 PRF systems may not have been able
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or available to perform their intended safety function under all
p required accident conditions.
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f 08 Miscellaneous Operations Issues (IP 92901)
$ 08.1 .(Closed) URI' 50-364/96-13-01. PRF Ooerability Reauirements for SFP.
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} This issue concerned the failure to meet the TS operability requirements
L for the PRF system on October 31. 1996, while moving fuel in the Unit 2
- SFP area. Both the onshift o)erating crew and inspectors independently
L concluded that two' trains of 3RF were inoperable during fuel movement in
l the Unit 2 SFP. Plant management disagreed with this conclusion and
, subsequently documented its position in a letter to the NRC dated i
i November-27. 1996, requesting a formal TS interpretation. On March 6.- ,
. 1997, the NRC issued a reply to Southern Nuclear Operating Company. Inc. j
L (SNC), supporting the operators' and inspectors' original conclusions.
i Consequently. on October 31, 1996. fuel movement had been performed in
j the Unit 2 SFP while both trains of the PRF system were inoperable.
- This was a condition prohibited by TS 3.9.13 and should have been l
terminated as soon as possible and reported pursuant to 10 CFR 50.73.
The licensee's failure to conform wit 1 their TS and required reporting
requirements is identified as EEI 50-364/97-04-02. Moving Fuel in a
Condition Prohibited by TS. URI 50-364/96-13-01 is closed based on
identifying this item as an apparent violation.
Enclosure
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II. Maintenance
M1 Conduct of Maintenance
M1.1 Penetration Room Filtration (PRF) System Performance Test
a. Insoection Scoce (IP 37551)
The inspectors reviewed past test data packages of FNP-1/2-STP-124.0,
Penetration Room Filtration Performance Test, performed in 1995 and the
' test results dating back to 1992.
b. Observations and Findinas
On January 28, 1997, the inspectors reviewed seven data packages which
documented the performance of FNP-1/2-STP-124.0 in 1995 on both units.
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The inspectors identified discrepancies in the data entries for the
tests and asked the licensee to verify the data and test results for
prior tests. The licensee performed an evaluation of Unit 1 and Unit 2
test data for FNP-1/2-STP-124.0 starting in 1992. Licensee engineers !
identified four data transposition errors and one calculational error in !
'the 1992 tests. The calculational error was corrected and flow was ;
still within the Technical Specification (TS) acceptance criteria. Data- 1
transposition errors resulted in the wrong duct size being used to
determine flow through the 14-inch recirculation exhaust line. After
correcting the data and recalculating, the licensee determined that the ;
system flow rate for the Unit 2 A train PRF system, as measured on
December 1, 1992, was 5615 cubic feet per minute (cfm). This flow rate
was outside the TS Surveillance Requirement (SR) 4.7.8.b.3 acceptance I
criteria of 5000 1 10%. However, the next 18-month performance of !
FNP-1/2-STP-124.0 for the 2A PRF system on May 18, 1994 did meet the TS ;
acceptance criteria. No modifications or attempts to change system ,
performance were made during the intervening period. The licerisee's
failure to meet TS acceptance criteria is identified as EEI
50-364/97-04-03, Failure to Meet TS SR 4.7.8.b.3 Acceptance Criteria.
c. Conclusions
The inspectors and licensee identified many discreaancies in the data
recorded during PRF system surveillance testing. Jnclear test procedure
guidance contributed significantly to the many documented errors. An
apparent violation was identified in one surveillance test conducted on
December 1, 1992, which resulted in failing to meet TS system flow ;
acceptance criteria.
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Enclo:;ure i
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M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Penetration Room In-leakaae
a. Insoection Scooe (IP 61726)
The inspectors reviewed past test data packages of FNP-1/2-STP-124.0, !
Penetration Room Filtration Performance Test, aerformed in 1995 and the '
test results dating back to 1992. Data from t1e tests were compared
with design assumptions identified in the Updated Final Safety Analysis
Report (UFSAR). The inspector also reviewed the guidance contained in
FNP-1/2-STP-20.0, Penetration Room Filtration System Train A(B)
Quarterly Operability and Valve Inservice Test. PRF system testing
conducted on February 6. 1997 was observed by the inspectors.
b. Observations and Findinas j
' UFSAR section 6.2.3.1.2 describes the criteria used to determine PRF !
design flow rates, and states. "The exhaust flow rate is equivalent to
the penetration room boundary in-leakage: 1.e. , the sum of all possible
in-leakages when a pressure of -1.5 in. wg is maintained within the ;
penetration room boundary." It also states. " Minimizing the penetration '
room in-leakage increases the system effectiveness," and "...for
estimating the exhaust fan capacity, it has been conservatively assumed
that, with a -1.5 inches wg pressure, the in-leakage is 100 percent of
the penetration room volume per day. This in-leakage is equivalent to
250 scfm.
The previous FNP-1/2-STP-124.0 test results from 1995, indicated that
the penetration room boundary (PRB) in-leakage was much greater than
that assumed by the UFSAR. The data reviewed by the inspectors
indicated approximately 3700 cfm in-leakage on Unit 1, and 3000 cfm on
Unit 2, while at slightly less than -1.5 inches of water pressure. This ;
condition has been evident in surveillance test data since at least i
1992. A surveillance test procedure (STP) observed on January 25, 1997,
(refer to Inspection Report (IR) 50-348, 364/97-01) indicated that the
Unit 1 PRB in-leakage was greater than 4000 cfm. far in excess of the .
250.cfm allowed in the UFSAR. !
The excessive in-leakage of the Unit 1 and Unit 2 PRBs was reconfirmed
when the licensee performed FNP-1/2-STP-124.0 on the Unit 1 Train A PRF
on February 6, 1997. This test demonstrated that Train A could only
attain -0.9 inches of water in the Unit 1 PRB with both fans running in
the exhaust mode (indicating in-leakage of at least 4500 cfm). Three
minutes after shifting Train A to the recirculation mode, the Unit 1 PRB
returned to atmospheric pressure. Concurrently on Unit 2 the licensee
performed FNP-1/2-STP-20.0. Penetration Room Filtration System Train
A(B) Operability Test, on the B train PRF. The inspector observed that
while the 2B PRF system was in the recirculation mode, the Unit 2 PRB
pressure was atmospheric. This indicated that Unit 2 PRB in-leakage was
Enclosure
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greater than the capacity of the exhaust fan (which has a minimum design
capacity of 500 cfm). UFSAR section 6.2.3.3.2. states, "The 3enetration
rooms are maintained at a pressure of -0.5 to -1.5 in. wg wit 1 only the
exhaust fan operating. If the recirculation fan were to remain in
operation in the exhaust mode, the pressure in the penetration rooms
could be maintained at 3.0 in. wg." These tests indicated that the
Unit 1 and Unit 2 PRBs did not meet the UFSAR design descriptions. This
is identified as eel 60-348. 364/97-04-04 PRB In-leakage in Excess of
UFSAR Design. i
The inspectors reviewed the licensee's STPs to determine if any testing
was performed to specifically identify PRB degradation.
FNP-1/2-STP-20.0 contained a " Note" describing indications of proper
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system operation (with PRB doors closed), acceptance criteria (i .e. .
recirculation valve open at -2.2 inches of water. -3 inches of water at
the PRB with both fans in the exhaust mode), and requirements for
corrective action if the expected system operation was not observed.
However, the )rocedure did not direct the operator to observe nor record
PRB-to-atmosplere differential pressure (dP) when the system was
configured in the modes identified by the note. Also there was no
evidence (e.g. , deficiency report) that operators recognized the
degraded PRB conditions during prior tests. This lack of guidance for
PRF testing is identified as an example of EEI 50-348, 364/97-04-01.
Inadequate Procedural Guidance for PRF System Operation and Testing -
Multiple Examples.
c. Conclusions
The PRB had degraded to such an extent that in-leakage was many times
greater than the design described in the UFSAR. The excessive in-
leakage prevented the PRF system from operating as described in the
UFSAR and was not recognized by the licensee staff even during the
conduct of FNP-1/2-STP-20.0, due to inadequate procedure guidance and
training.
M3 Maintenance Procedures and Documentation
M3.1 Unit 1 Penetration Room Filtration Performance Test (IP 61726)
The inspector observed the performance of FNP-1-STP-124.0. on the
Unit 1. Train A PRF system. Details of this observation were documented
in IR 50-348, 364/97-01. As a result of this observation the inspector
identified the following procedural deficiencies in FNP-1/2-STP-124.0.
e Several steps were no longer applicable due to updated equipment.
e The procedure did not specify the technique for obtaining the air
velocities. On one of the ducts, the test personnel performed
both horizontal and vertical traverses because the readings for
the horizontal traverse put the air flow below the acceptance
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L criteria. Only a vertical traverse was performed on the other
duct.
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e The precedure did not identify from which ducts to take air
j velocity measurements. There are three ducts per train but the
- STP provides data columns for only two ducts.
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! e The note prior to step.7.7 incorrectly specifies that the
individual velocity readings be within 20% of the average
velocity.
$ e TS 4.7.8.b.3 states that cystem flow rates be tested in accordance
j with Section 8 of ANSI N510-1980. However STP-124.0, which-
F implements this TS required test, did not perform system
i resistance flow tests as identified in Section 8 of ANSI N510-
L 1980.
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e The inspector also determined that, while FNP-1/2-STP-124.0.
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step 7.5, directed operations to start the PRF train to be tested
- and align it in the recirculation mode, neither the STP-nor the
system operating procedure (SOP) contained guidance for-
} configuring the system for the recirculation mode.- The inspector
i noted that the system was not aligned in the recirculation mode as
described by the UFSAR for the performance of this test.
, The inspectors concluded that the above identified deficiencies are
! examples of inadequate guidance for testing the PRF system. This is an
i example of EEI 50-348, 364/97-04-01. Inadequate Procedural Guidance for
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PRF System Operation and Testing - Multiple Examples. These ,
- deficiencies were discussed with Engineering Su) port (ES) management 1
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during various meetings between January 27 and rebruary 14. ES l
management was responsive to the inspectors' findings.
- FNP-1/2-STP-124.0 was subsequently revised and reperformed. ]
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- M3.2 Surveillance Testino of Safety-Related Ventilation Systems Per American
i National Standards Institute. Inc. (ANSI)'N510 ,
j a. Insoection Scoce (IP 61726)-
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) The inspectors compared the PRF system STPs to the TS surveillance
! requirements including ANSI N510-1980: reviewed previously completed
- STPs
- and reviewed original acceptance tests.
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l b .' Observations and Findinas
TS SR 3.7.8.b describes the 18-month testing requirements for the High
- Efficiency Particulate Air (HEPA) filter and charcoal filter efficiency, !
i and system flow. TS SR 3.7.8.b.3 requires " verifying system flow rate '
of 5000 cfm 10% during system operation when tested in accordance with l
! Section 8 of ANSI N510-1980." The inspector reviewed Section 8 of j
j Enclosure ,
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ANSI N510-1980 to verify that the observed tests met the ANSI l
specifications. On January 28, 1997, the inspector reviewed
FNP-1/2-STP-124.0 and determined that it did not incorporate the " dirty
filter" tests specified in steps 8.3.1.6 and 8.3.1.7 of ANSI N510-1980.
Section 8.3.1 Airflow Capacity Test. The inspector asked the licensee
to address why the " dirty filter" testing of section 8 was not being
performed. The licensee stated that the " dirty filter" tests are only
required for acceptance tests and are not required for periodic
surveillance. The insaectors disagreed with this interpretation. The
ins)ectors requested tlat the licensee provide the acceptance test
paccages for the PRF system documenting the conduct of the " dirty
filter" tests. The licensee provided the PRF system acce)tance test
package for Unit 2 but was unable to locate any Unit 1 PR system
acceptance package indicating that " dirty filter" testing was
performed. Also, the Unit 2 package did not clearly demonstrate that l
the " dirty filter" tests were performed per ANSI N510-1980. The '
inspectors verified that the " dirty filter" testing was not performed by
any periodic STP. This failure to perform TS SR 3.7.8.b.3 Jer '
ANSI N510-1980 is identified as EEI 50-348, 364/97-04-05, railure to
Perform TS Surveillance Requirements for Safety-Related Ventilation
Systems - Multi)le Examples. The licensee commenced " dirty filter" .
testing of the Jnit 1 and Unit 2 PRF systems on February 19 in !
accordance with ANSI N510-1980, and successfully completed this testing
by February 21. 1997.
In addition to system flow testing to demonstrate PRF operability.
TS SR 4.7.8.b.1.a requires a visual inspection of PRF filters every 18
months, in accordance with Section 5 of ANSI N510-1980, and TS
SR 4.7.8.d.3 requires PRF heater testing, in accordance with Section 14
of ANSI N510-1980 every 18 months. Testing to ANSI N510-1980
requirements every 18 months also applies to other safety-related
ventilation systems. To demonstrate operability of the Control Room
Emergency Filtration System (CREFS). TS SR 4.7.7.1 requires visual
filter inspections, in accordance with Section 5: system flow
verifications, in accordance with Section 8: and pressurization system
heater testing. in accordance with Section 14. TS SR 4.9.14 requires
visual inspection of the Containment Purge exhaust filter, in accordance
with Section 5.
On February 23, 1997, after considerable review effort, the licensee
concluded that its surveillance test program did not include numerous
portions of ANSI N510-1980. Sections 5, 8, and 14. Testing and
,
inspection in accordance with these sections of ANSI N510 were required
! by TS SR 4,7.8 (PRF system). TS 4.9.14 (Containment Purge exhaust) and
TS SR 4.7.7.1 CREFS. This issue is identified as an example of
i EEI 50-348, 364/97-04-05. Failure to Perform TS Surveillance
Requirements for Safety-Related Ventilation Systems - Multiple Examples.
]
On February 26, 1997, at 12:27 PM CST. the licensee declared that it had
entered into TS 3.0.3 for' Units 1 and 2. for failing to comply with the
Enclosure
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TS SRs of the PRF system (TS 4.7.8), Containment Purge (TS 4.9.14) and
CREFS (TS 4.7.7.1). After entry into TS 3.0.3. the licensee requested .
that the NRC issue a notice of enforcement discretion (NOED), which was
subsequently granted by the NRC. After receiving verbal notification of '
the NOED, the licensee exited TS 3.0.3 at 1:51 PM CST the same day. The
licensee submitted its formal request for an NOED by letter dated
February 27. By letter dated February 28, the NRC issued the NOED.
c. Conclusions
The licensee failed to fully implement the Unit 1 and Unit 2 TS SRs for
airflow capacity tests, visual inspections, and heater testing for the -
PRF system, CREFS, and Containment Purge exhaust filter.
V. Manaaement Meetinas and Other Areas !
l
X1 Review of Updated Final Safety Analysis Report (UFSAR) Commitments
]
A recent discovery of a licensee o)erating its facility in a manner
contrary to the UFSAR description lighlighted the need for a special 1
focused review that compares plant practices, procedures and/or l
parameters to the UFSAR descriptions. While performing the inspections ]
discussed in this re) ort, the inspectors reviewed the applicable ;
portions of the UFSAR that related to the areas inspected. Several J
significant inconsistencies were identified between the wording in the
UFSAR and actual plant practices, procedures and/or parameters. These
inconsistencies principally involved the PRF system as described in
UFSAR Section 6.2.3, and are discussed in detail in the previous
inspection report paragraphs.
X2 Exit Meeting Summary
The resident inspectors presented the ins)ection results to members of
licensee management on March 13, 1997. T1e licensee acknowledged the
findings presented.
The resident inspectors asked the licensee whether any materials
examined during the inspection should be considered proprietary. No
proprietary information was dentified.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
M. Aj1 uni SNC (Corporate) Licensing Manager - Farley Project
R. Coleman, Maintenance Manager
D. Grissette. Operations Manager
R. Hill, General Manager - FNP
Enclosure
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0. Jones. SNC (Corporate) Engineering Manager - Farley Project [
R. Martin, Superintendent Operations Support :
C. Nesbit Assistant General Manager - Support t
R. Rogers, Engineering Support Supervisor - Engineering Support
J. Sims. SNC (Corporate) Project Engineer
L. Stinson, Assistant General Manager - Plant Operations
.J. Thomas, Engineering Support Nanager :
NRC ;
J. Zimmerman. Project Manager - Farley Nuclear Plant
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations
IP 71707: Plant Operations
IP 92901: Followup - Operations
ITEMS OPENED, CLOSED, AND DISCUSSED -
Opened
lyng Item Number Status Descriotion and Reference i
!
EEI 50-348, 364/97-04-01 Open Inadequate Procedural Guidance for PRF
System Operation and Testing - Multiple
Examples (Sections 02.1, M2.1, and M3.1). ;
EEI 50-364/97-04-02 Open Moving Fuel'in a Condition Prohibited by
TS (Section 08.1).
EEI 50-364/97-04-03 Open Failure to Meet TS SR 4.7.8.b.3 Acceptance
Criteria (Section M1.1).
EEI 50-348, 364/97-04-04 Open PRB In-leakage in Excess of UFSAR Design
(Section M2.1).
-EEI 50-348, 364/97-04-05 Open Failure to Perform TS Surveillance
Requirements for Safety-Related
Ventilation Systems - Multiple Examples
(Section M3.2). :
Enclosure
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Closed
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URI 50-364/96-13-01 Closed PRF Operability Requirements for SFP
- (Section 08.1).
!
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j. LIST.OF ACRONYMS USED
.
! ANSI American National Standards Institute, Inc.
l ARP Annunciator Res)onse Procedure
- cfm Cubic Feet-per iinute
CFR Code of Federal Regulations
CREFS Control Room Emergency Filtration System
!' dP Differential Pressure
! EEI Escalated Enforcement. Item
! ERP Emergency Response Procedure
1 ES Engineering Sup) ort
- FNP Farley Nuclear )lant
j HEPA High Efficiency Particulate Air
! HVAC Heating. Ventilation, and Air Ccnditioning
! IP Inspection Procedure
Inspection Report
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IR
- LC0 Limiting Condition of Operation
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LOCA Loss of Coolant Accident
NOED Notice of Enforcement Discretion
! NRC- U.S. Nuclear Regulatory Commission
3 PRB Penetration Room Boundary
i PRF Penetration Room Filtration
l 3sig )ounds per square inch gauge
t lHR Residual Heat Removal
P scfm standard cubic feet per minute
! SFP Spent Fuel Pool
i SI Safety Injection
- SNC Southern Nuclear Operating Company, Inc.
i S0P System Operating Procedure
! SR Surveillance Requirement
STP Surveillance Test Procedure
j TS Technical Specifications
Updated Final Safety Analysis Report
'
URI Unresolved Item
wg Water Gauge
>
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Enclosure
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