IR 05000237/2003012

IR 05000237-03-012 & 05000249-03-012, on November 17-21, 2003, Dresden, Units 2 & 3. Supplemental Inspection IP 95001; Mitigating Systems; 10 CFR 50.9 Violation

ML033530204
Person / Time
Site:	Dresden
Issue date:	12/18/2003
From:	Dave Hills NRC/RGN-III/DRS/MEB
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
EA-02-264, EA-02-265 IR-03-012
Download: ML033530204 (28)

Text

ber 18, 2003

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 NRC SUPPLEMENTAL INSPECTION REPORT 05000237/2003012(DRS);

05000249/2003012(DRS)

Dear Mr. Skolds:

On November 21, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at the Dresden Nuclear Power Station, Units 2 and 3. The enclosed report documents the inspection results which were discussed on November 21, 2003 with Mr. R. Hovey and other members of your staff.

The NRC performed this supplemental inspection to assess your evaluation of the failure to demonstrate the Unit 3 high pressure coolant injection (HPCI) system to be operable following a July 5, 2001, scram. A HPCI pipe support was likely damaged when HPCI automatically activated during this event. A hydrodynamic transient/water hammer occurred as a result of a combination of air pockets and steam voids in the piping due to inadequate venting of the system as indicated in Licensee Event Report 2002-005-00. Your staff determined that the HPCI system was inoperable following a reactor scram on July 5, 2001, until September 30, 2001, when the damaged HPCI support was repaired, an adjacent HPCI pipe hanger was adjusted to support pipe dead weight loads, and the system was vented at the high point vent.

This issue was previously characterized as having low to moderate risk significance (White)

(EA-02-264) in the NRCs final significance determination letter dated June 23, 2003.

The NRC also performed this supplemental inspection to assess your evaluation of the failure of your staff to provide accurate information to the NRC as required by 10 CFR 50.9, Completeness and Accuracy of Information, related to the Unit 3 White issue. During a telephone conversation on September 27, 2001, between members of NRC staff and members of your staff, the condition of a specific HPCI support was being discussed and an accurate description of its condition was not provided to the NRC staff. The inaccurate information was material to the NRC because the NRC staff was evaluating your operability determination for the HPCI system. This violation was previously characterized at Severity Level III (EA-02-265)

in a letter to you dated June 23, 2003. The inspection examined activities conducted under your license as they related to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

Within these areas, the inspection consisted of a selected examination of procedures and representative records, and interviews with personnel. Specifically, this inspection focused on your assessments and corrective actions associated with the White and 10 CFR 50.9 issues.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

David E. Hills, Chief Mechanical Engineering Branch Division of Reactor Safety Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 Enclosure: Inspection Report 05000237/2003012(DRS);

05000249/2003012(DRS) w/Attachment: Supplemental Information See Attached Distribution

SUMMARY OF FINDINGS

IR 05000237/2003012(DRS); 05000249/2003012(DRS); 11/17/03 - 11/21/03; Dresden Nuclear

Power Station, Units 2 & 3; Supplemental Inspection IP 95001; Mitigating Systems; 10 CFR 50.9 Violation This supplemental inspection was performed by a regional inspector and the Dresden senior resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Inspector Identified Findings

Cornerstone: Mitigating Systems

The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees root cause evaluation, extent of condition determination, and corrective actions associated with the inoperability of the Unit 3 high pressure coolant injection (HPCI)system following a reactor scram on July 5, 2001, until September 30, 2001. This performance issue was previously characterized as having low to moderate risk significance (i.e. White) in an NRC letter dated June 23, 2003, which communicated the final assessment of the finding documented in NRC Inspection Report 50-237; 50-249/01-21(DRS), and is tracked as VIO 2003009-01. During this supplemental inspection, performed in accordance with Inspection Procedure 95001, the inspectors concluded that the licensee had developed a comprehensive corrective action plan that addressed this issue and adequate measures were in place that should prevent similar problems from occurring in the future. The inspectors determined that the issue was appropriately addressed and resolved by the licensee.

Given the licensees acceptable performance in addressing the inoperability of the Unit 3 HPCI system, the White finding associated with this issue will only be considered in assessing plant performance for a total of four quarters in accordance with the guidance in NRC Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. As a result, the White finding will be closed at the end of the fourth quarter 2003.

10 CFR 50.9: Completeness and Accuracy of Information The U.S. Nuclear Regulatory Commission (NRC) also performed this supplemental inspection to assess the licensees focused area self assessment and corrective actions associated with inaccurate information given to the NRC related to the Unit 3 HPCI White finding. During a telephone conversation on September 27, 2001, between members of NRC staff and members of the licensees staff, the condition of a specific HPCI support was being discussed and an accurate description of its condition was not provided to the NRC staff. The inaccurate information was material to the NRC because the NRC staff was evaluating the licensees operability determination for the HPCI system. This violation was previously characterized at Severity Level III in the NRCs letter dated June 23, 2003, and is tracked as VIO 2003009-02.

During this supplemental inspection, the inspectors concluded that the licensee had developed a comprehensive corrective action plan that addressed this issue and adequate measures were in place that should prevent similar problems from occurring in the future. The inspectors determined that the issue was appropriately addressed by the licensee.

Given the licensees acceptable performance in addressing the inaccurate information that was material to the inoperability of the Unit 3 HPCI system, the violation associated with this issue will be closed.

Report Details 01

INSPECTION SCOPE

The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees evaluation associated with the inoperability of the Unit 3 high pressure coolant injection (HPCI) system following a reactor scram on July 5, 2001, until September 30, 2001. This performance issue was previously characterized as White in an NRC letter dated June 23, 2003, which communicated the final assessment of the finding documented in NRC Inspection Report 50-237; 50-249/01-21(DRS) and tracked as VIO 2003009-01. This performance issue is related to the mitigating systems cornerstone in the reactor safety strategic performance area.

The U.S. Nuclear Regulatory Commission (NRC) also performed this supplemental inspection to assess the licensees evaluation associated with inaccurate information given to the NRC related to the Unit 3 HPCI White finding. During a telephone conversation on September 27, 2001, between members of NRC staff and members of the licensees staff, the condition of a specific HPCI support was being discussed and an accurate description of its condition was not provided to the NRC staff. The inaccurate information was material to the NRC because the NRC staff was evaluating the licensees operability determination for the HPCI system. This violation was previously characterized at Severity Level III in the NRCs letter dated June 23, 2003, and is tracked as VIO 2003009-02.

EVALUATION OF INSPECTION REQUIREMENTS - WHITE VIOLATION 02.01 Problem Identification a.

Determination of who (i.e., licensee, self-revealing, or NRC) identified the issue and under what conditions The inoperable Unit 3 HPCI system issue was identified by the licensee during an inspection of vacuum breaker bellows on July 19, 2001, when it was observed that anchor bolts for a nearby HPCI pipe support were partially pulled out from a concrete slab. The licensees initial operability evaluation,01-031, revision 0, determined that the HPCI system was operable for the original design basis loads. The licensees subsequent apparent cause evaluation (ACE) (Action Request 70181-02) indicated, in part, the apparent cause of the event is a transient (i.e. water hammer) associated with the scram on July 5, 2001.

The resident inspector reviewed the licensees operability determination and requested technical assistance from regional specialists. In September 2001, regional inspectors concluded that the licensees operability evaluation was indeterminate because: the damaged support had not been repaired, no action had been taken to prevent recurrence of the hydraulic transient, and the system operability determination had not been evaluated with recurring hydraulic transient loads (refer to Dresden Inspection Report 2001021).

In discussions between NRC staff and licensee staff, the licensee questioned the validity of their ACE conclusion that the HPCI support had been damaged by a hydraulic transient. In a telephone conversation on September 27, 2001, the licensee stated that system walkdowns did not identify additional damage to other HPCI supports as expected. Also, the licensee felt that the system was water solid because it was aligned to the condensate storage tank (refer to Dresden Inspection Report 2001021).

On September 28, 2001, region inspectors walked down the HPCI system and identified another support, M-1187D-83, to have discrepancies that might have been caused by a water hammer event. The licensee engineers had discounted this support discrepancy observation as not adversely affecting the functionality of the piping (refer to Dresden Inspection Report 2001021).

After prompting by the NRC, on September 30, 2001, the licensee repaired damaged support M-1187D-80, adjusted hanger M-1187D-83 to support dead weight loads as designed, and vented the system high point and removed entrapped air. After these corrective actions were completed, the NRC inspectors concluded that the HPCI system would have been operable if subjected to a similar hydraulic transient event.

After the NRC inspector identified that the venting procedure did not vent at an intermediate high point, the licensee vented the system again and removed another volume of entrapped air (refer to Dresden Inspection Report 2001021).

After the NRC exit meeting for Inspection Report 2001021, the licensee identified data from their transient analysis display system recorded during the July 5, 2001, scram.

Using this data the licensee concluded that the Unit 3 HPCI experienced a hydraulic transient event due to the July 5, 2001, scram.

In December 2001, the licensee accepted a vendor calculation that concluded the HPCI system would have been operable if the system had initiated and a hydraulic transient recurred with support M-1187D-80 damaged. The NRC reviewed this operability determination and requested additional information pertaining to the methodology and design input used to establish operability. The NRC reviewed the proposed calculation changes and again had comments pertaining to the methodology and design input used to establish operability. The licensee later decided that historical system operability could not be demonstrated by analytical means. On December 2, 2002, the licensee completed licensee event report (LER) 50-249/2002-005-00, Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer Event.

b. Determination of how long the issue existed, and prior opportunities for identification The licensee determined during the apparent cause evaluation that the support deficiencies were likely caused as a result of a transient (water hammer) associated with the July 5, 2001, scram. Data from the transient analysis display system (TADS)indicated that the HPCI system did experience a water hammer event when the unit scrammed on July 5, 2001.

In their apparent cause evaluation, the licensee indicated that prior to July 19, 2001, the licensee had not noted discrepancies on the HPCI piping. Later, the licensee system walkdowns identified discrepancies on support M-1187D-83, but the licensee discounted that the discrepancies might be due to a hydraulic transient. Also, had the system been vented after the licensees August 24, 2001, ACE concluded that the system had experienced a hydraulic transient, entrapped air at the system high point would have been removed.

After prompting by the NRC, on September 30, 2001, the licensee repaired damaged support M-1187D-80, adjusted hanger M-1187D-83 to support dead weight loads as designed, and vented the system high point and removed entrapped air. After these corrective actions were completed, the NRC inspectors concluded that the HPCI system would be operable if subjected to a similar hydraulic transient event.

As determined in LER 2002-005-00, the Unit 3 HPCI was inoperable from the July 5, 2003, scram until September 30, 2001.

c.

Determination of the plant-specific risk consequences (as applicable) and compliance concern associated with the issue The licensee had initially determined that the HPCI system remained operable with the degraded HPCI support. NRC inspectors reviewed the licensees initial operability evaluation and proposed corrective actions. NRC Inspection Report 50-237; 50-249/01-21(DRS) concluded that the operability of the HPCI system was indeterminate because: 1) no action had been taken to prevent recurrence of the hydraulic transient nor had the system operation been evaluated with recurring hydraulic transient loads; and 2) the damaged support had not been repaired. NRC inspectors concluded that HPCI system would have experienced another hydraulic transient event had the system automatically initiated, but the effects on the degraded system had not been evaluated.

On December 3, 2002, the licensee declared that the HPCI system was inoperable following an automatic system initiation on July 5 until September 30, 2001, when the pipe supports were repaired and the system vented.

The NRC documented in the evaluation of the issue that HPCI being inoperable from July 5 until September 30, 2001, was classified as a White finding (i.e., a finding of low to moderate safety significance). The issue was classified as a White finding because it could not be determined that the degraded HPCI system would have performed its designed safety function following an additional automatic system initiation.

02.02 Root Cause and Extent of Condition Evaluation a.

Evaluation of method(s) used to identify root cause(s) and contributing cause(s)

The licensees evaluation of the inoperability of the Unit 3 HPCI system from July 5 until September 30, 2001, used the Event and Causal Factor Charting method to describe the event, identify areas for further investigation, and to identify failure modes. The licensee also used System Improvement, Inc., TapRoot methodology to identify causes due to programmatic and human performance weaknesses. Overall, the two methods used were appropriate to identify the root cause and contributing causes.

b. Level of detail of the root cause evaluation The licensees root cause analysis report, Inadequate Management of U3 HPCI Support M-1187D-80 Failure, approved on December 20, 2001, was thorough and identified the primary root causes of the event to be: 1) licensee management of the issue, failure of Design Engineering to evaluate the HPCI operability issue from the proper safety perspective because the focus was on demonstrating operability and not recognizing the extent of the degraded condition, and 2) cause of the damage to the support, hydraulic transient / water hammer during system actuation on July 5, 2001, due to air pockets and steam voids in the HPCI pump discharge piping. The licensee determined the cause of the air pockets was due to inadequate venting of the system.

c. Consideration of prior occurrences of the problem and knowledge of prior operating experience The licensees evaluation included a review of LER-89-029-04 that showed both Unit 2 and Unit 3 HPCI systems experienced significant back leakage through the injection and check valves. Also noted in the licensees root cause report was the acknowledgment that although the LER characterized the 1989 event as a thermal transient, the NRC concluded that the steam voids created by the back leakage were the source of multiple water hammers on the system.

d. Consideration of potential common cause(s) and extent of condition of the problem The licensees evaluation considered the potential for common cause and extent of condition associated with the potential for flashing of hot water due to high pressure /

low pressure system back leakage. The remaining emergency core cooling system (ECCS) injection piping, core spray (CS) and low pressure coolant injection (LPCI)systems, were reviewed for extent of condition. The licensee documented that the CS and LPCI systems have all the high point vents identified in ECCS venting procedure DOS 1400-07. The concern that intermediate HPCI system high point vents were not identified in procedure DOS 1400-07 was previously documented in NRC Inspection Report 50-237; 50-249/01-21(DRS).

The Unit 3 isolation condenser system experienced a water hammer event on January 8, 2002. The licensee determined the cause to be flashing of the hot water trapped between the isolation condenser condensate return isolation valves, 3-1301-3 and 3-1301-4. Two causes of this event were identified: 1) there was no pressure or temperature instrumentation for the volume between the condensate return isolation valves, and 2) the existing procedures did not provide adequate instructions to assure proper pressure equalization across the isolation condensate return isolation valve 3-1301-3, prior to valve opening.

02.03 Corrective Actions a.

Appropriateness of corrective action(s)

On September 30, 2001, the licensee took corrective actions to make the Unit 3 HPCI system operable. Damaged support M-1187D-80 was repaired, degraded support M-1187D-83 was adjusted to support dead load as designed, and the system was vented to removed entrapped air. The licensee later vented the system and removed additional entrapped air at the system intermediate high point.

The licensee has implemented corrective actions to address the root cause of the system water hammer. In addition, the licensee has implemented a program to require increased management oversight and review of operability evaluations and apparent cause evaluations.

The inspectors determined that the corrective actions appeared appropriate to prevent recurrence.

b.

Prioritization of corrective actions After licensees corrective actions restored the Unit 3 HPCI system to operability on September 30, 2001, the licensee revised procedures to require the HPCI system to be vented when aligned to the condensate storage tank and vent at the intermediate high points in the system. System modifications were installed to monitor for high pressure/

low pressure back leakage and to prevent heated water from flashing to steam on an initiation signal.

c.

Establishment of schedule for implementing and completing the corrective actions The licensee implemented modifications and procedural changes to prevent recurrence.

Also, administrative changes were in place that require increased management oversight and review of operability evaluations and apparent cause evaluations.

d.

Establishment of quantitative or qualitative measures of success for determining the effectiveness of the corrective actions to prevent recurrence The license enhanced its temperature monitoring of the HPCI system in the vicinity of the injection valve to detect high pressure / low pressure back leakage. The licensee also implemented a modification to prevent heated water from flashing to steam on an initiation signal.

The licensee implemented administrative changes that require increased management oversight and review of operability evaluations and apparent cause evaluations. The inspectors reviewed apparent cause evaluations to verify upper management review and observed an apparent cause evaluation review by the licensees management review committee.

03 EVALUATION OF INSPECTION REQUIREMENTS - 10 CFR 50.9 VIOLATION 03.01 Problem Identification a.

Determination of who (i.e., licensee, self-revealing, or NRC) identified the issue and under what conditions The NRC identified that during a telephone conversation on September 27, 2001, between members of NRC staff and members of the licensees staff, an accurate description of the condition of HPCI support M-1187D-83 was not provided to the NRC staff. The inaccurate information was material to the NRC because the NRC staff was evaluating the licensees operability determination for the HPCI system.

On September 28, 2001, regional inspectors walked down the HPCI system and identified that support M-1187D-83 did not support pipe weight as designed. During a presentation to the NRC on October 15, 2001, licensee staff stated that this discrepancy had been identified during walkdowns on September 26, 2001. The licensees engineers had discounted this observation because the discrepancy did not affect functionality of the piping. The licensee did not mention this walkdown observation during discussions with the NRC on September 27, 2001 (refer to Dresden Inspection Report 2001021).

03.02 Root Cause and Extent of Condition Evaluation a.

Evaluation of method(s) used to identify root cause(s) and contributing cause(s)

The licensee performed a focused area self assessment of the 10 CFR 50.9 violation related to the White violation to identify causes due to programmatic and human performance weaknesses. Overall, the method used was appropriate to identify contributing causes and extent of condition.

b.

Level of detail of the root cause evaluation The licensees focused area self assessment, Dresden 10 CFR 50.9 Issues, was thorough and identified a contributing cause of the violation to be: lack of an established continuing training program to site managers ( first line supervisors and below) concerning proper regulatory communication/interface, and of the requirements of 10 CFR 50.9 and its interpretation and meaning. The licensee identified that the extent of condition for this deficiency includes all departments at Dresden which have accredited training programs.

03.03 Corrective Actions a.

Appropriateness of corrective action(s)

The licensee developed training for its staff on proper communication/interface with the NRC, and the requirements of 10 CFR 50.9 and its interpretation/meaning.

The inspectors interviewed licensee staff to assess the adequacy of the licensees training pertaining to 10 CFR 50.9, Completeness and Accuracy of Information. The interviews included licensee staff in departments that are likely to interface with the resident or regional inspectors. No significant concerns were identified.

During their preparation for this inspection, the licensee identified that evidence to demonstrate Dresden had established appropriate continuing training for site managers related to 10 CFR 50.9 could not be found. This concern was entered into the licensees corrective action program (CR 182281).

The inspectors determined that the corrective actions appeared appropriate to prevent recurrence.

4OA3 Event Follow-up

.1 Review of Previously Identified Items

a. Inspection Scope

The inspectors reviewed previously identified unresolved items, licensee event reports and cited violations to determine if sufficient information existed to close the issue.

b. Observations (Closed) Unresolved Item 50-249/01-21-01, The Operability of the HPCI System with a Degraded Pipe Support Was Indeterminate. The licensee declared that HPCI was inoperable with the degraded support, LER 50-249/2002-005-00, Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Unresolved Item 50-249/01-21-02, Failure to Provide Adequate Documentation in an Operability Evaluation as Required. The licensee declared that HPCI was inoperable with the degraded support, LER 50-249/2002-005-00, Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Unresolved Item 50-249/01-21-03, Four Examples of Inadequate Corrective Action Associated with a Damaged Pipe Support. The item was a contributing factor for the HPCI system to be inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Unresolved Item 50-249/01-21-04, Inadequate Surveillance Procedure Resulted in a Significant Amount of Air in the HPCI System. The item was a contributing factor for the HPCI system to be inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02).

This item is closed.

(Closed) Unresolved Item 50-249/01-21-05, Two Examples of Inadequate Fill and Vent Procedures for the HPCI System. The item was a contributing factor for the HPCI system to be inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Unresolved Item 50-249/01-21-06, The Allowable Temperature on the HPCI Discharge Pipe following an Injection Valve Actuation Had Inadequate Basis. The item was a contributing factor for the HPCI system to be inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Unresolved Item 50-249/01-21-07, Inadequate Corrective Action Associated with a 1989 Event in which HPCI Discharge Piping Was Affected. The item was a contributing factor for the HPCI system to be inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02).

This item is closed.

(Closed) Licensee Event Report 50-249/2002-005-00, Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer Event. The LER was a result of the HPCI system being inoperable in excess of technical specification time limitations. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Licensee Event Report 50-249/2002-005-01, Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer Event. The inspectors determined that the LER was revised to document that corrective action for a previous HPCI system water hammer would not have prevented the event described in this LER. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated to cited violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Licensee Event Report 50-237/1989-029-05, Elevated High Pressure Coolant Injection (HPCI) Discharge Piping Temperature Due to Reactor Feedwater System Back Leakage. The inspectors determined that the LER was revised to document that the elevated discharge piping temperatures identified in the LER 1989-026 rendered the HPCI system inoperable. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with violation (White) 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Violation 50-249/03-09-01, HPCI Inoperable for Longer Than Technical Specifications Allowable Time. The inspectors reviewed the licensees root cause report, the associated corrective actions to prevent recurrence and other documents associated with the violation (White). The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 02). This item is closed.

(Closed) Violation 50-237; 50-249/03-09-02, Licensee Provided Material Inaccurate Information. The inspectors reviewed the licensees focused area self assessment (FASA), the associated corrective actions to prevent recurrence and other associated documents. The inspectors also interviewed licensee staff to assess the adequacy of the licensees training pertaining to 10 CFR 50.9, Completeness and Accuracy of Information. The inspectors determined that the corrective actions appeared appropriate to prevent recurrence (Section 03). This item is closed.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. R. Hovey and other members of licensee management at the conclusion of the inspection on November 21, 2003. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Hovey, Site Vice President

D. Bost, Plant Manager

J. Aguiar, Design Engineer

L. Coyle, Work Management Director

P. DiSalvo, HPCI Systems Engineer

D. Galanis, Design Engineering Manager

T. Gallaher, Site CAPCO

J. Griffin, NRC Coordinator

J. Hansen, Regulatory Assurance Manager

J. Henry, Operations Director

T. Loch, Mechanical Design Engineering Lead

J. Reda, Design Engineer

R. Rybak, Lead Licensing Engineer

A. Shahkarami, Engineering Director

J. Sipek, Nuclear Oversight Manager

C. Symonds, Training Director

Nuclear Regulatory Commission

D. Smith, Senior Resident Inspector

P. Pelke, Resident Inspector

D. Hills, Chief, Mechanical Engineering Branch

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

05000249/2003009-01 VIO HPCI Inoperable for Longer Than Technical Specifications Allowable Time

05000237/2003009-02 VIO Licensee Provided Material Inaccurate Information

05000249/2003009-02

05000237/1989-029-05 LER Elevated High Pressure Coolant Injection (HPCI)

Discharge Piping Temperature Due to Reactor Feedwater System Back Leakage

05000249/2002-005-00 LER Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer Event

05000249/2002-005-01 LER Unit 3 High Pressure Coolant Injection System Inoperable Due to Water Hammer Event

05000249/2001021-01 URI The Operability of the HPCI System with a Degraded Pipe Support Was Indeterminate

05000249/2001021-02 URI Failure to Provide Adequate Documentation in an Operability Evaluation as Required

05000249/2001021-03 URI Four Examples of Inadequate Corrective Action Associated with a Damaged Pipe Support

05000249/2001021-04 URI Inadequate Surveillance Procedure Resulted in a Significant Amount of Air in the HPCI System

05000249/2001021-05 URI Two Examples of Inadequate Fill and Vent Procedures for the HPCI System

05000249/2001021-06 URI The Allowable Temperature on the HPCI Discharge Pipe following an Injection Valve Actuation Had Inadequate Basis

05000249/2001021-07 URI Inadequate Corrective Action Associated with a 1989 Event in which HPCI Discharge Piping Was Affected

Discussed

None.

Attachment